ML20140C813

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Revised Proposed Findings of Fact & Conclusions of Law on Monitoring Subcontention Re NUREG-0737,Table II.F.1, Addl Accident Monitoring Instrumentation
ML20140C813
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 06/15/1984
From: Bier J
BIER, MILLS, CHRISTA-MARIA, ET AL
To:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8406190474
Download: ML20140C813 (1)


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i June 15,1984 i CCCVUrn UNITED STATES OF AMERICA N' NUCLEAR REGULAIURY COMM'SSIO: 4

'84 JUN 19 Al0:18 ,

BEFORE IllE AIOMTC SAFETI AND LICENSING BOARD i' Jr ._ ;. . .

I In the matter of } D[$ SS /r l ) Docket ho. 50-155 **

l Consumers Power Company ) (Spent Fuel Fool Modification)

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taig dock Point Plant) )

Intervenors Revised Proposed Findings of Fact and Conclusions of Law on the Mon-itoring Subcontention

1. The additional scale affixed to the Noble Gas Effluent Monitor Meter may read conservatively, but it cannot be accurate over a period of time and over a var-iety of meteorological conditions. The conversion from monitor response to uCi/cc is dependent on the particular mixture of noble gas radionuclides being monitored.

The mixture will change with core burnup, the rate of release of noble gases from the core and time after shutdown. The Big Rock Point Plant Monitors are not design-ed to correct for these chanEes.

2. All the cables for the stack monitoring system go through the cable penetration t

room. All three of the detectors associated with high range radiation instruments i are located in the outside cable penetration room. Big Rock Point Plant also has developed a calculational procedure, based on data from the containment radiation monitors, as an altemative to post-accident sampling. All these instruments are subject to common failure if there is a fire in the outside cable penetration room.

Although redundency is not a reguirement for the stack monitoring system, C.P.Co.

1 has an achilles heel for fire or sabotage.

3 Intervenors must be allowed to comment on all Tech Specs conserning monitors relating to contention.

4 Intervenors are conserned that the intent of hUREG 0737 Table U.F.1 may not be met. Monitoring of several dischargeinputs is acceptable. V assert that the in-tent is to demand more than one detection instrument or monitor, not more than one source of radiation. See deposition 36 and 42.

Respectfully sutriitted,

-[ er} 'c w Jo Anr,e Bier Interrenor pro se

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l 8406190474 840615 PDR ADOCK 05000155 C. s A PDR U

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