ML20128C626

Responds to Bj Youngblood 720718 Request for Comments on Des for Facility.Continued Plant Operation Until Modified Offgas Sys Becomes Operational Can Be Expected to Have Only Minor Environ Impact

ML20128C626
Person / Time
Site:	Monticello
Issue date:	10/05/1972
From:	Tedesco R US ATOMIC ENERGY COMMISSION (AEC)
To:	Muller D US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 9212040490
Download: ML20128C626 (8)

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DockeU'ile Els vutON OCT 5 1372 JYR Docket No. 50-263 Daniel R. Muller, Assistant Director for Enytroamental Projects, L RESPONSE TO AGENCI COMKENTS - DES FOR M)NTICELLO NUCLEAR crunnATING PLANT Hame of Plant Monticello Nuclear Generating Plant Licensing 8taget POL Decket Naber: 50-263 Responsible Branch Environmental Pr0jects Branch No. 3 '

Project Leader R. Bevan Requested Completion Date: November 2, 1972 Description of Response: Response to Agency Comanento Review Status: Completed In response to a request from B. J. Youngblood, Chief. Environmental Projects Branch No. 3 dated July 18, 1972, we have reviewed comments from the various agencies on the DES for the Monticello Nuclear Plant and submit the following remarks to be included in the FES.

Environmental Protection Aaency

1. Operation of the Monticello Nuclear Generating Plant during 1971 resulted in the discharge of radioactive gases at levels that were small percentages of 10 CFR 20 limits. Based on 1971 experience, continued operation until the modified offgas system becomes operational can be expected to have only a minor environmental impact. Rowever, current operating data should be summined and presented in the final statement co see if they corroborate this conclusion.

Comment Table I gives the gaseous and liquid releases for the period January through June 1972. These data supplement the data presented in Table III-6 and III-7 which show liquid and gaseous releases for calendar year 1971. Eval-untion of these data support the eenclusion, that releases resulting from continued operation of the plant until the augmented offgas system is installed will be well below the. limits in 10 CFR Part 20.

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i l TDU I boticello Buclear Generating Flest Caseous and Liquid Isleases January - June 1972*

Geseous Balesses Noble Genes ~ Iodine-131 Meath Ci/Meath Ci/ Month i

1.7 x 1$4 -

Jammary 20 i

February 14,000 3.1 x 10-2

, March 31,000 2.7 x 10-2 l April 32,000 5.6 x 10-2 May 59,000 0.11 June 57,000 9.4 x 10-2

, Total 193,000 O.32 Average Noble Ces Release Rate @ 15,500 y Ci/sec.

j Nnimm= Moble Gas Release Rate = 33,000 m C1/sec.

I l Liquid Releases J

a Gross Activity Tritium Vol. of Liquid Month __ Ci/ Month Ci/ Month liters January 2.9 x 10-6 7.6 x 10-5 3.78 x 103 (There were no other discharges of liquid effluent dur1ng the reporting period).

I j During the reporting period Monticello operated at a plant capacity l factor of ' 68%.

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i 2. The iodine discharge from the turbine building should be redueed to l

meet proposed Appendix I,10 CFR part 50 guidelines and to ensure that the radiation dose to the ahild's thyroid is maintained at

) levels comparable to those suggested in AppanMu 1. (The potential dose estimated by the AEC (67 arem] would be eseessive.)

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j As indiested in the Enviroemental Statement, ventilation air in the turbine i

building is ashausted by two pathways. The areas.below the turbine (equip-i ment areas and lower levels) are ashmasted to the main plasma and the air

released untreated to the atmosphere via the plant vent. This embaust duct

is monitored esatianeusly for radietodina. The operating areas below the l

turbine are the principal sources of staan leakage sentributing to radio-j iodine releases.

l When required, ventilation air from the main floor of the turbine building l

is exhausted through roof mounted exhaust fans. The main purpose of these

! exhaust fans is to maintain the desired ambient senditions above the turbina.

Since operation of these ekhaust fans is very infrequent, routine releases i of radioiodine from this area are not anticipated.

With regard to proposed Appendix I, the licensee is required tc meet all j present and future regulations issued by the Commission. At such time that

proposed Appendix I has been formally issued, the licenses will be-required

( to make the necessary modifications to meet the design objoetives set forth in this regulation.

3. Several modes of operation of the liquid waste management system have been discussed in the FSAR, environmental report, and draf t statement. Since each mode would result in different environmental impacts, the final statement should describe how the liquid waste-treatment equipment will be operated.

Counnent i

I operating procedures for the liquid weste treatment system have evolved over

the time period between preparation of the FSAR, the Enviroansatal Esport r and the DES. por the past-14 months of operaties, the 11eensee has damsm-l strated a revised method of operaties which has reemited in virtually me releases of liquid wastes to the enviroommat. -As a result of this asthed j of operaties, releases sea be eensidered as low as praatieabis. The licensee has indicated his intent to continue operation of the radwaste j system as described in the ES.

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Page 3, paragraph 2 and page 4, paragraph 2.

No assurance is given that the system (liquid waste) will be operated

! as described. Further, the treatment of liquid waste as described l in the draft statement is 4-istent with the applicant's descrip-l tism in the envir=====tal suport and FgA1. ,

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j h validity of the ARC analyses ====vains operaties'obthe weste treatment system is not avident sinoa there may be ao requiremsat

en the applicant to operate the equipment in the er described.;

{ In addities, the applicant's criteria for providing additional 74 treatment er to fattiste discharge to the enviremment'should be t i detailed.

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l The c=-i=sion's regulation 10 CFR 50.36a requires that equipment j installad in the radioac,tive weste treatment systems be maintained and

used to keep releases of radioactive materials released to unrestricted

areas during aermal operations, including expected operational occur-

' ramens, as law as practicable. Such requirements are. defined by the approved technical specifications.

l In addition, detailed records of the waste system operation along with

! a semi-annual reporting of the operation to the AgC are required.

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Throughout the operating life of the plant, modification of the opere-ting procedures and equipment utilization will be made to accommodate j

changing eenditions of the reactor and the radioactive' waste management j systmas.

We recognise that there are differences in the description of the rad-waste treatment from that which has been described in the FSAR and the Ravi e ntal Report. These changes in operating procedures have resulted in ameh leser liquid releases than espected. = As indicated in-l Comment #3 the liesseee expects to continos operation of the system as described la the ES. ~

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j The statesmat does met eeneider the enviremmental offseta of' .

etfluents resulting from maintenames operations, seek as draising '

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unintenance, er the ability of the liquid waste tr==*===t systen ' '

to process these large velemme of saat==f==r e d liquids.

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i We disagree with EPA's ecument noted above that the ES does not seasider i the environmental effsets of affluents resulting from maintenance opera-i tions.

j In our evaluation of the liquid radwaste treatment system, we eensidered l normal operations of the reaeter. As indicated in the ES, we espest that i releases of radiomative material in liquid affluents will be a fraction of i the values shout in Table III-5. Bewever, to esapemeate for equipment downtime and expoeted operational eseurreness, imeloding maintenance, the

! values shows la Table III-5 have been mer-14=ad to 3 C1/ year. Although

there is some doubt that the waste handling eM treatment system as

! installed is capable of handling large volumes of liquid waste such as that from the tours, releases to the environment are not expected to emaaed

5 ci/ year.

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! As noted'in Table I under Comment 1, there was only one release of liquid waste to the environment'for the period January through June 1972. This i release occurred in January and enounted to 3.78 a 10-5 liters of liquid f waste and 2.9 x 10-6 suries of activity. These data together with release l data for 1971 shown in Table III-6 support our evaluation of the liquid j waste treatment system as present in the ES.

! Without sufficient operating history, it is not possible to predict the i eoneantration of radionuclides that would result from nonroutina operations.

l Equally difficult to predict is the frequency cf such events. -As operating l data become available from this plant and other operating BWR'r, we latead to evaluate the potential offset these monroutine operations may have on the waste treatment systems and recessmond any appropriate changes as may be necessary. Until more data become available, we believe our evaluation is conservative and provides for operational securrences.

6. Page 5, paragraph 2 i The mathed of processing radiomative ehemical wastes should be more-i elaarly defined because of inconsistencias between the draft state-i meat and the environmental report. For esemple, as deseribed la the l draft statement, radiomative ehemisal wastes are blended with other i liquid wastes and d==4=aralised or eelidified by using them os i- wetting asents for the sement in the solid waste systen. The~appli-

! eent ladicates, however, the wastes are filtered before being released to the environment, if the radioactivity levels are seceptable.

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Comment la the startup and early plant phase, eartain changes and modificatiano l

uere made to the liquid and eelid weste headling systems. These ehanges

vere made to improve the operability and availability of these systamo. In

! addities, an effort was made to further redmee the questities of liquid i redwesta to the environs, as a reemit, =h==i==1 and 1==dg dents westes l are rested to the sledge hoppers la the Solid Radueste System and the system I operated me described in the Eg. , . , .

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The movirc====*=1 report indiestos that steem is available for mee in deicing the water intaka structure. The soaree of this steam is not described in either the FSAE or the enviremmental reporti the

draft statement did mot address this. If process steam is to be  !

l used for this purpose, the radiological consequences should be I

! evaluated and presented in the final statemaat.

Comment Process steam is not used to deies the water intaka structure. This steam is provided by the plant heating boilar and as such is not a source of radioactivity.

8. Page 6, paragraph 4 i

The decay tank system is designed to provide 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> decay at a condenser air islaskage of 20 efs. Since the decay time provided by the pressurised holdup tanks is a function of condenser' air in-leakage rates, the effisent discharges may be eensiderably different than the levels presented in the draft statement. In addities, a discussion of the applicaat's criteria for condenser repair and/or operating requireemate which would limit operation at i=1- 6 te ratas azeeeding'the assumed 20 efa value should be presented in the statement. ,

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,. ,p, While it is true that == h air islaskage will affect the deoey time in the heMay tanke and this, la tura, will alter the amount of activity released, we de met believe this ameresse will have a sisaificant inyect

on the servireement. _ The Technical Specifiestises will limit the amount j of radioactivity which can be relanned met the amount of eendenser air OFFICL

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l Daniel R. Muller i l inleakage. The licensee is aise required to maintain sad use equipment to l- assure that releases to unrestricted areas are as low as practicable, i

j With regard to maintenance requirements and operating preeedores, these are j established by the lieansee to amoure sentiamed good plant performenee and I confermance with release limits set forth in the Technical specifications.

l We de met believe it accesesry to deemment these r- =-i_ in the Es..

4. Page 8, paragraph 2 *

.s Beitherthedraftstatementmertheapplicant'sandreamental

! report indicate that the turbine building vents are monitored l for radiamativity. Sines ground level disoberges of radio-i meelidas from the turbine building and the future recombiner i building will contribute signi'icant releases (pertieslarly for I-131), these vents should be monitore A for gross radio-activity and iodine discharges.

I i Comment i The exhaust from the recombiner building ventilation system is used as i

dilment at the main gas affisant stack and, therefore, it.is measured with

radioactivity from the air ejector exhaust by the atack monitor. On page l 6 of EPA's comments, they indicate that leakage is not expected to significantly tacrease anticipated discharges of I-131 since there will be two charcoal adsorbers upstream from the decay tanka. We concur with EFA's j analysis in this regard.

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As indicated in Comment No. 2, ventilation air in the turbine building (equipment areas and lower levels) is exhausted to the mata plenum and released to the plant vent which is continuously usaitored.

j Ventilation air above the turbinas is =wh===ted through roof mounted exhaust fans. These fans are used to maintain ambient eenditions and, therefore, l eperate infrequently (about four months of the year). . With the asceptism of

. the turbine staan reheaters. on the turbine floor, there are no somrees of -

I radiesetivity during normal oper**iam er antiaipated treasients. Eeverthe-l 1ess, there are radiation monitors and alarms in'the turbine building. We believe that monitoring equipment presently inee=11md satisfies the require-meets of Safety Guide 21. -

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10. Page 7, paragraph 2 l Furthermore, the assumptions and/or their bases used in the does 4 evaluatises =61d be better defined. For instanse. (1) the state-seat indicates the espected releases are based an an assaal average stack disaharps rate of 44,000 y Ci/see skile Table III-3 indientes

100,000 y ci/see, - - - - - (3) the bases for the assumed stoaa

leakage, iodine partition facters and eeslant 1- N e rates are not ,

j presented.

5 Comment 3 ,

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j with regard to ites (1), Table III-3 should be revised to show a release rate of 100,000 y C1/see for a 34001 sit reseter. Comeerming ites (3) j it is met our intent to deemsset in each ES the basis for each and every i

assumption used in our evaluation of redweste treataset systems. Anti-cipated releases of radioactive materials in liquid and gaseous efflamat are based en past operating experience and eessider aermal operatima i

! of the remeter ever the 40 year life of the plant. We will be happy to discuse the bases for our assumptions with EPA shou 1J they so desire.

! We believe EPA is responsible for assessing the igact on the enviressmat act whether our assumptions are correct.

Additional comments are contained in the marked-up copy of the DES and 4

attached for your consideration.

Original cisned cyt i

kRobert L. Tedesco h424scy) i Assistent Director.for 4

Contain=at Systems ,

i Directorate of Licensing  ;

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i cc: A. Giambusso W. Mcdonald S. Hanauer DISTRIBUTION:

1 J. Hendrie M ocket (50-263) , #

} D. Skovholt L Reading D. Ziemann CS Reading e i ETSB Reading B. Youngblood

' R. Bevan ETSB' Staff J.-Shea" J. Collins CRESS c ,. ,, c e . f L. : ETS I ETSB/L ETSB/L  !

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ENVIRON, I" ~ " %)

JUL 2 51972 f/)&

Doer.cc No 50 203 B. J. Youngblood, Chief Environmental Projects Branch f3 Directorate of Licensing ILONTICELID NUCLEAR GENERATING FLANT - NORTHERN STATES POWER COMPANT C012IENTS ON DRAFT ENVIRONMENTAL STATEMENT

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This is in response to your memorandum on the above subject dated July 18 1972. During a telecon with A. Ward L. Heyer, and J. Eechtel on July 20 1971 these Northern States Power Company (NSPCo) repre-sentatives stated that:

1. NSPCo has submitted written comments, dated July 3 1972 in response to the AEC Draft Environmental Impact State-mont published in June noting that I-131 releases are unrealistically high and that the AEC calculational method is not consistent with the method employed in Pilgrit Hillstone and other BWEs.

2. The turbine building exnaust from the lower turbine and condenser space is released through the reactor building vent stack which is monitored for radioactivity.

3 During 8 months of the year . when the twelve roof vente are normally closed, ventilation in .the turbine building exaauats to the lower turbine and condenser room and out through the monitored reactor building vent stack.

4. Turbine building ventilation exhausts through the 12 turbine building roof vents for about 4 conths of the year. With the exception of turbine steam reheaters ,

s on the turbine. floor, there are no sources of radio-activity during normal operation or anticipated transientap Nevertheless, there are radiation alarms in the turbine _. _

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B. J. Youngblood Al 2 51972

5. Tne exhaust from the recombiner building ventilation systes is used as diluent at the main gas effluent stack and, therefore, is measured with the radioactivity from the air ejector exhaust by the stack radiation monitor.

Please advise if we can be of further assistap..;e.

.s Dennis L. Zienann Chief Operating Reactors Branch U Directorcte of Lice $uin;

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Docket File EL vntoN 5 1372

, pl DCT Docket No. 50-263 Danici R. Muller, Assistant Director for Environciental Projects, L PISPONSE TO AGENCY COMVINTS - DES FOR HONTICELLO NUCLEAR GENERATING FLWT Nasm of Plants Monticallo Nuclear Generating Plant Licensing Stsget POL Docket Number: 50-263 Responsible Branch Environmental Projects Branch No. 3 Project Leaders R. Bevan Requested Completion Dates November 2, 1972 l Description of Response Response to Agency Conunents i Review Status: Compinted In response to a tequest from B. J. Youngblood, Chief, Environmental Projects Branch No. 3 dated July 18, 1972, we have reviewed connannts from the rari m egencies on the DES for the Monticello Nuclear Plant and submit the following remarks to be included in the TES.

Environmental Protection Asney

1. Operation of the Monticello Nuclear Generating Plant during 1971 resulted in the discharge of radioactive gases at levels that were small percentages of 10 CFR 20 limits. Based on 1971 experience, continued operation until the modified offgas systen becomes operational can be expected to have only a minor environmental in: pact. However, current operating data should be examined and presented in the final statement to see if they corroborate this conclusion.

Comment Table I gives the gaseous and liquid releases for the period January through June 1972. These data supplement the data presanted in Table III-6 and III-7 which show liquid and gaseous releases for calender year 1971. Eval-untion of these data support the conclusion, that taleases resulting from continued operation of the plant until the augmented offgas system is installed will be veil below the limits in 10 CPR Part 20.

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TABLE I l i

Meetitelle Dar1mme Osnerating Fiant l

) Geseems and Liquid Releases ,

] January - June 1972* I Gameses Balaames l

Noble Genes Iodine-131

Month C1/Meath Ci/ Month i

! January 30 1.7 a 104 i Pobruary 14,000 2 March 31,000 3.1 2.7 xx 1010-2 April 32,000 5.6 x 10-2 May 59,000 0.11 June _57,000 9.4 x 10-2 Total ,

193,000 0.32 Average Noble Gas Release Rate 15,500 y Ci/sec.

Nau h am Mobla cas Release Rate = 33,000 m Ci/sec.

l Liquid Releases

Cross Activity Tritium Vol. of Liquid i Month _ Ci/ Month C1/ Month liters l January 2.9 x 10-6 7.6 x 10-5 3.78 x 103 l

(There were no other discharges of liquid eff1 ment during the reporting period).

l During the reporting period Monticello operated at a plant capacity facter of ' 68%.

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2. The iodias discharge from the turbine building should be redueed to l meet proposed Appendix I, 10 CFR Part 50 guidelines sad to ensure i

that the radiation dose to the child's thyroid is maintained at

levels esaparable to these suggested in Appendia 1. (The potential l j dose estimated by the AEC (67 arem] would be eseessive.)

! Commeqt i

f As indiented in the Envireamsstal Statement, ventilation air in the turbine building is ashausted by two pathways. The areas below the turbina (equip-l

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meat areas and lower levels) are eukausted to the main piamma and the air released untreated to the atmosphere via the plant vest. This mammat duet i

is monitored esattamously for radietodine. The operating areas belme the i turbine are the principal sources of steam laakage sentributing to radie-l iodine releases.

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! When required, ventilation air from the main floor of the turbine building

is exhausted through roof meented ashaust fans. The mais purpose of these '

exhaust fans is to maintain the desired ambient .eenditions above the turbina.

i since operation of these exhaust fans is very infrequent, routine releases i

of radioiodina from this area are met anticipated.

! With regard to proposed Appendix I, the lisensee is required to meet all l present and future regulations issued by the Cossaission. At such time that i proposed Appendix 1 has been formally issued, the liseases will be required to make the necessary modifications to meet the design objectives set forth i in this regula. tion.

l l 3. Several moden of operatien of the liquid wasta management system have been discussed in the FSAR .eavironmental report, and draft statement. Since each mode would result in different environmental

! impacts, the final statement should describe how the liquid waste i treatment equipment will be operated.

t-comment l

! Operating procedures for the liguid waste treatment system have evolved ever i the time period between preparation of the FgAR, the Bavironmaatal Report and the des. For the past-13 months of operation, the liosases has demon-strated a revised method of operation which has resulted in virtually me

' releases of liquid wastes to the envireensat. As a result of this mathed l of operation, releases saa be seasidered as low as praatiemble. The

. licensee has indicated his intent to continue operation of the radwaste

system as described in the Es.

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4. Page 3, paragraph 2 and page 4, paragraph 2. '

Me assuremes is given that the system (liquid waste) will be operated as described. Further, the treatment of liquid wasts as described l in the draft statement is ineensistost with the applicant's descrip-tien la the envirummental report med Pg&R. o '

s The inlidity of the ARC analyses esmeerming operetiaa of the weste treatment system is met evident ainee there may be me requirement

, en the appliaast to operate the equipment in the umamer deseribed.

In addities, the applicant's eriteria for providing addittamal e r;

! treatment er to initiate disaharge go the enviremment should be l detailed.

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j The Commissian's reguistion 10 CFR 50.36a requires that equipment installed in the radioactive weste treatment systems be meistained and used to keep releases of rediesetive materiale reinesed to umswetricted

! areas durias sermal operations, including espected operattenal occur-

! romans, as law as practicable. Such requirweents are defined by the l approved techsteal specificatione.

l In addition, detailed reeerds of the waste system operation along with

! a semi-ammeal reporting of the operation to the AgC are required.

l

' Throughout the operating life of the plant, modification of the opere-ting precedures and equipment utilisation will be made to secommodate

{ changing osaditions of the reactor and the radionettve ' waste management l systems.

l l

We recognise that there are differences in the description of the red-waste treatumat from that which has been described in the F5AR and the

Raviremanatal Report. These changes in operating procedures have resulted in senek laser liquid releases than expected. As indicated in comment #3 the 11eemeee expects to sentiamo operation of the system as described in the 38 ,

5. Page 4, paragraph 3 i

The statament does met consider the enviremmental effects of -  ;

' afflemets ressleing from maintamanise operations, seek as draistag of the torus (which has already been massesary) and eandenser maintenames, or the ability of the liquid weste tr==*===t system '

to process these large volumes of samtaminated liquide.

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i Denial R. Haller i f

, consent l We disagree with EPA's somment meted above that the 58 does met seasider

! the envireemental effsets of affluents resulting from maintenance opera-l tions.

i '

In our evaluation of the liquid redweste trestasat system, we eeneidered mermal operations of the roaster. As indiented la the 38, we espect that

. releases of radiomative matarial in liquid affluents will la a freeties of

! the values shown in Table III-5. Bewever, to esapensate for equipment j

downtina and espeeted operational ossutresses, including malatemaase, the

values shown in Table 111-5 have been sev=a14=ad to S C1/ year. Although

there is some doubt that the waste headling and treatment system as installed is capable of handling large voltsses of liquid waste such as

that from the tours, releases to the enviremment are not espected to enseed j 5 Ci/ year.

As noted in Table I under Comment 1, there was only one release of liquid i

waste to the envirousset'for the period January through June 1972. This i release escurred in January and amounted to 5.78 m 10-3 liters of liquid waste and 1.9 x 10-6 suries of activity. These data tesether with release data for 1971 shown in Table III-6 support our evaluation of the liquid waste treatment system as present in the ES.

l Without sufficient operating history, it is not possible to predict the i eeneantration of radienuclides that would result from nonroutine operations.

1 Equally difficult to predict is the frequemey of such events. As operating data besens available from this plant and other operatihg BWR's. we intend to evaluate the potential effect these neuroutine operations may have en the waste treatment systems and recomend any appropriate thanges as may be necessary. Until more data become available, we believe our evaluation is senservative and provides for operational escurrences.

6. Page 5, paragraph 2 The method of prosessing radiomative eheminal wastes should be more clearly defined because of insensistanaies between the draft state-meat and the anwitemmental report. For esemple, as deseribed in the draft statement, radiomative ehemiaal westes are blended with other i liquid wastes and d==4==ralised or estidified by using them as wetting agents for the eensat in the es11d waste system. .The app 11-I east indicates, bewever, the wastes are filtered before being released to the envireement, if the radiometivity levels are

! seeeptable.

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\ comment i

i In the startup and early plant phase, eartain shauses and modifications were made to the liquid and se11d waste headling systems. These changes

, were made to taprove the opershility and availability of these systems. In i addities, an effort was made to further vedmos the geantities of liquid j redwesta to the environs, as a result, ebemical and 1==dn dress omstas

are rested to the eludge hoppers in the solid Badenste _ system and the system i operated as described in the ES. . , .

! 7. Page 6, Paragraph 1 '

} .< , '.. 9 .

l The environmental report indiaates that steem is available for use j in deieing the water intake structure. The sourse of this steam is l met described in either the p5AR er the envireemental repert; the i- dcaft statement did met address this. If process steam is to be l used for this purpose, the redielegical eensequences should be l evaluated and presented la the final statement.

l -

comment j Process steam is met used to deles the water intake structure. This steam l is provided by the plant heating boiler and as each is met a source of

( radioactivity.

1 I. 8. Page 6, paragraph 4 The decay tank system is designed to provide 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> decay at a

! condenser air inleakage of 20 efs. Simca the decay time provided by the pressurised heldup teoks is a function of eendenser' air in-laakage rates, the affloomt discharges may he monsiderably different than the levels presented in the draft statement. In addities, a

, discussion of the applicant's criteria for sendenser repair and/or l eparating requirements which would limit operation at inleakage i

rates azeeeding the assumed 20 afu value shemld be prenanted in the ,

l statement.

~ ,

comment > 4

- +

l While it is tree that ==d- air islaakage will affect the deoey time in the holder tanks and this, in term, will alter the nosent of activity r released, we de met holieve this ineresse will have a significant impeet l en the envireement. The Tasha4*m1 Speciftentions will itait the amount l of radioactivity which een be released met the amount of ==d==r air i  ;

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Denial R. Muller i

! inleakage. The licensee is aise required to maintain and use equipment to assure that releases to unrestricted areas are as low as practicable.

With regard to maintanamee rageiramente and operattag precedures, these are established by the lieanese to amoure sent4==ad good plant performenee and

, comformenee with release limits set forth in the Technical specifications.

j We de met believe it asseseary to h e these ,.: r " a is the M.

l l 8. Page 8, paragraph I -

1 meither the draft statement mer the applicant's savirsemental report indicate that the turbine buildin8 vents are monitored i for resteestivity. 81mee ground level diesberges of reste- ' l sec11das from the turbine building and the future recombiner  ;

building will contribute significant releases (particularly j for 1-131), these vente should be nemitered for grees radio-

activity and iodine discharges.

l Comment i

The exhaust from the recombiner building vestilatism system is used as dilment at the main gas afflamat etack and, therefore, it is measured with

! radioactivity from the air ejector exhaust by the steek monitor. On page 6 of EPA's commeste, they indicate that leakage is met espected to significantly Ameresse anticipated siecharges of I-131 since there will be two charcoal adsorbers upstream from the decay tanks. We comeur with EPA's

{ analysis in this engard, i

As indicated in Comment No. 2, ventilation air in the turbine building l (equipment areas and lower levels) is enhamsted to the main pleone and j released to the plant vent which is contimmensly mesitored.

i j Ventilaties air above the turbines is esimseted through reef mounted exhaust j fans. These fans are used to maintain ambient conditions and, therefore,

! eperate infrequently (about four months of the year). With the suception of l

the turbine steam reheaters en the turbine fleer, there are me sonreas of

! radieestivity during mermal operatise er astialpated transtants. Eeverthe-1 less, there are radiation maaiters and alarms in the turbine building. We believe that semitoring equipment presently Ameta11md satisfias the require-l meats of safety Guide 21. y 4

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I j Denial R. kiler i i

i 10. Page 7, paragraph 2 Furthermore, the assumptione and/or their bases used in the dose l ovaluatisms should be better defined. For instamos, (1) the state-i 4

meat indicates the espected releases are based on an -1 average stack dieabarps rate of 44,000 y C1/see while Table III-3 indientes 100,000 y Ci/see, - - - - - (3) the bases for the assumed steam

leakage, tadi== partitism facters and seolant laakage rates are not presented.

ceumont i

h Vith regard to item (1), Tabla III-3 should be revised to show a release rate of 100,000 y Ci/sec for a 3400 We remeter. Comeerming item (3) i t it As met our intent to docummat is each Es the basis for each and every assumpties used in our evaluaties of redweste treataset systems. Anti- ,

l eipated releases of radioactive aseterials la liquid and gaseems affluent '

are based se past operating experienes and seasider mermal operattee of the resetor ever tbs 40 year life of the plant. We will be happy to discuss the bases for our assumptions with EPA should they so desire.

We believe EPA is reopensible for assessing the impact en the enviremment not whether our assorytions are correct.

Additional casemmats are eestained in the marked-op copy of the DES and attached for your consideration.

Original cicned bYL l

i kM BIS' SC_O Robert L. Tedesco Assistant Director for contafammat systems Directorate of Licensing cc: A. Ciambusso

) W. Mcdonald i

S. Hanauer b DISTRIBUTION:

4 J. Hendrie M ocket L Reading-(50-263) -

} D. Skovholt CS Reading D. Ziemann B. Youngblood ETSB Reading R. Bevan ETSB Staff 4

J. Shea' J. Collins y

CRESS o,,,a. L:ETS ETSD/L ETSB/L j T: 3033,R6-13 iR.L.Tedescoj N

%,, ,! Jh f. ns l i9/ /72 ~

9/25/72 LL ,

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