ML20128A742

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Submits Written Comments on SER
ML20128A742
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 01/29/1977
From: Gallo J
NRC
To: Ziemann D
Office of Nuclear Reactor Regulation
References
NUDOCS 9212030438
Download: ML20128A742 (3)


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January 29, 1973 W'M Memorandtn to Mr. Dennis Ziemann

SUBJECT:

MONTICELLO SAFETY EVALUATION REPORT Decause of our inability to get together due to conflicting schedules, I an reducing my coments to writing.

Once you have had the opportunity to analyze them, let's get together to dis-cuss the problems indicated below. My coments follow:

1.

The as im as practicable" discussion in 2.1 is not comblete.

We conclude that the plant is "as low as practicable" without ex-plaining whether we are relying on actual release data or on cal-culated release data.

I don't see anywnere a discussion of the calculated releases and doses of the current gaseousRRadwaste system (without augmentation).

The actual release data on page 4 is calculated to be as uninformative as possible. Stating percentages in tenus of un-known technical specification limits tells nothing. Let's sit dwn at your earliest convenience and sort this out.

In addition, has this write-up been compared with what we said in the Final Envirornental Statement?

2.

On page 13 it is stated that "It is undesirable to unnecessarily pressurize the containment drywell." As discussed last week, this should be clarified to indicate that the reason it is undesirable is because the applicant is economically motivated to achieve plant efficiency rather than because of safety related problems.

3.

As discussed with you last week, the additional sentence' in-serted on page 30 will require that the matter be resolved prior to the close of the upcoming hearings.

4.

Please refer to Sectten 7.2 on page 32.

I suggest the first two sentences be revised to read somewhat along the fo11 ming lines:

"The Monticello emergency plan was submitted as a part of the public record during the hearing for the provisional operating license. The plan has since been periodically reviewed and de-tailed implemental procedures have been de-veloped. The plan complies with the require-ments of 10 CFR Part 50 including Appendix E, and ii. is ampi.ebh Tu, vendieu undu e omct>

.ful l..itnn.1icense l lb^M sunnaut >

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I Mr. Dennis Ziemann i 5.

I want you to point out for me so that I fully understand, i

the exact places in the Safety Evaluation Report where we acconeo-date the comunents of the ACRS.

6.

The financial qualification section should be included in the final SER.

. i, 5

Joseph Gallo Assistant Chief Hearing Counsel cc:

Messrs. Thomas Engelhardt Don.Skovholt Jim Shen Fred Anderson I

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-r January 29,1973 Memorandum to Mr. Dennis Ziemann 1

SUDJECT:

MONTICELLO SAFETY EVALUATION REPORT Because of our inability to get together due to conflicting schedules,1 am reducing my comments to writing. Once you have had the opportunity to analyze them, let's cet together to dis-cuss the problems indicated below. My comments follow:

1.

The "as loa as practicable" discussion in 2.1 is not complete.

\\ !1e conclude that the plant is "as low as_ practicable" without ax-or on cal-plaining whether we are relying on actual release data culated release data.

I don't see anywhere a discussion of the..

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. calculated releases and doses of the current gaseous Radwaste

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system (without augmentation).

U The actual release data on page 4 is calculated to be as uninfomative as possible. Stating percentages in tems of un-known technical specification limits tells nothing. Let's sit down at your earliest convenience and sort this out! In addition, has this write-up been compared with what we said in the Final e

Environmental Statement?

e 12.

On page 13 it is stated that "It is undesirable to unnecessarily pressurize the containment drywell." As discussed lest week, this should be clarified to indicate that the reason it is undesirable s

is because the applicant is economically motivated to achieve plant efficiency rather than because of safety related problems.

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As discussed with you last week, the additional sentence in-3.

,t, serted on page 30 will require that the matter be resolved prior

/\\ to the close of the upcoming hearings.

Please refer to Section 7.2 on page 32.

I suggest the first-4.

'o sentences be revised to read somewhat along the following lines:

"The Monticello emergency plan was submitted as a part of the public record during the hearing for the provisional operating license.

The plan p

has since been periodically reviewed and de-iL O

tailed.implemental procedures have been de-

'/

veloped.

The plan complies with the require-ments of 10 CFR Part 50 including Appendix E, and it is acceptable for operation under a full term license."

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