ML20151H648
| ML20151H648 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/22/1983 |
| From: | Rivenbark G Office of Nuclear Reactor Regulation |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| TAC-08043, TAC-08095, TAC-8043, TAC-8095, NUDOCS 8305040748 | |
| Download: ML20151H648 (15) | |
Text
. _ _ . . .__ -_
y,_.s , 1M3 db Docket Nos. 50-321 and 50-366 MEMORANDUM FOR: J. F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing FRON: G. W. Rivenbark, Project Manager Operating Reactors Branch #4 Division of Licensing
SUBJECT:
SUERY OF MEETINGS ON FEBRUARY'23 AND 24,1983 WITH GEORGIA POWER COMPANY (GPC) CONCERNING PROPOSED RADIOLOGICALEFFLUENTTECHNICALSPECIFICATIONS(RETS)
The subject meeting between the NRC staff and GPC was held at GPC's corporate offices in Atlanta, Georgia to discuss the NRC's questions related to its review of GPC's RETS submittal. A set of the questions discussed had been sent to GPC under the copy distribution of a November 23, 1982 letter from EG&G Idaho, Incorporated to C. Willis of the NRC staff.
GPC responded orally to each question during the two day meeting indicating for.most items whether and how they would modify their final submittal of RETS for the item in question. GPC stated that it planned to make its next submittal of the RETS and the Offsite-Dose Calculation Manual (00CM) in final form rather than in draft. GPC stated it would be meeting to discuss how it can schedule its final submittal and would advise the staff of its schedule. (GPCsubsequently infomed the staff by telephone that it would submit the RETS and the ODCM in final form by September 1,1983.)-
A copy of the list of questions discussed with GPC is attached as Enclosure 1. A list of meeting attendees is attached as Enclosure 2.
r 3,cd by George W. Rivenbark, Project Manager Operating Reactors Branch #4 Division of Licensing
Enclosures:
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NRC FCAM 318 (10 00) NACM ONO OFF1ClAL RECORD COPY usom iai-mm
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MEETING
SUMMARY
DISTRIBUTION Licensee: Georgia Power Company C
- Copies also sent to those people on service (cc) Ifst for subject plant (s).
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Project Manager -GRivenbark ~
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Licensing Assistant-RIngram -
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RADIOLOG: CAL EFFLUENT TECHN: CAL SPECIFICATIONS (RETS) REVIEW I. Purpose The purpose of this document is to provide licensees with advance notice (i.e., prior to the in-plant reivew) of areas where further clarification is needed in the. review of their RETS submittal and Off-site Dose Calculation Manual (0DCM). Some of the areas addressed .
are such that full compliance with the model RETS is necessary, however, in many cases a justified alternative that meets the intent will be considered in compliance. This document is being submitted to the NRC ,
plant manager for review. - -
II. Statements Not in Direct Compliance With the Model RETS The Licensee statements where clarification is required are listed below in the order of the model RETS:
NUREG Hatch .
No. 0473 RETS Comments 1 1.0 1.0 It is necessary that the defintion of channel calibration be provided for review purposes. The Licensee comments indicate that this definition is part of the technical specifications.
2 3.3.7.11 3.14.1 It is not stated that the alarm / trip 3.14.2 setpoints will be determined in accord-ance with the ODCM.
3 3.3.7.11 3.14.1 The word ACTION has been used in the Item b Item b specifications, but is not defined in the definitions section.
4 3.3.7.11 3.14.1 This specification, 6.9.1.9(b) has not Item c' been listed in the submittal. In the standard technical specifications, this is a requirement for a 30-day written report in the event that plant operation is permitted by a LCO.
5 3.3.7.11 ---
It is not clear that there would be no Action c shutdown requirement for violation of a limiting condition of operation present in the Hatch technical specifications.
6 Table Table 3.14.1-1 It is acceptable to allow the liquid 3.3.7.11-1 Item 1, 3a radwaste effluent monitoring instrumenta-Item 1, 3a tion to only be in operation when the radwaste discharge valves are not locked 1
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o MUREG Hatch
':o . 0473 RETS Comments closed. The plant states that releases can only occur when the valves are open.
7 Table Table 3.14.1-1 Are there no other potential in-leakage 3.3.7.11-1 Item 2 points to the service water system other Item 2 than the component cooling water system?
No method of determining radioactive leakage is present except during a degraded operational mode. . (System drawings would be helpful for the review meeting.)
8 Table Table 3.14.1-1 It is unclear whether pump curves are 3.3.7.11-1 Item 3a always used'to estimate liquid radwaste Item 3a flowrates. Also, the frequency of estimation is not listed. Use of pump curves is normally considered an action
, item in the event flow operation is inoperable.
9 Table Table 3.14.1-1 It is not clear whether pump curves may 3.3.7.11-1 Item 3b be used as a substitute for monitoring Item 3b the discharge canal. Also, it appears that the flowrate monitor must be in operation normally only during degraded operation modes.
10 Table ---
No alarm / trip setpoints are based on 3.3.7.11-1 radioactivity recorders based on Licensee Item 4 comments dated 10/1/82.
11 Table The plant indicates that all permanent 3.3.7.11-1 tanks ar'e diked (letter dated 10/1/82).
Item 5 12 Table Table 3.14.1-1 The method of analysis (i.e., the speci-
< 3.3.7.11-1 Action 18 fication number) is not referenced.
13 Table Table 3.14.1-1 "MDC" is not defined or referenced in 3.3.7.11-1 Action 20 in this table.
Notation 112 14 ---
Table 3.14.1-1 "MC0" is not defined or referenced in Action 22 this table.
15 Table Table 4.14.1-1 The plant comments (dated 10/1/82) 4.3.7.11-1 Item 1 indicate that no provision for source Item la check exists for this instrument and that an adequate source check is the 2
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NUREG Hatch ec. vi72 EE 3 Comments determination that the instrument is on scale. Also, Comment No. 9 indicates that existing calibration procedures will be used, but do these methods meet the listed RETS requirements?
The definition of channel calibration -
is not present (Note: applicable also to the service water monitor).
16 ---
Table 4'.14.1-1 It is not clear that a quarterly
- Item 4 functional test would not be necessary for the differential pressure monitor for the function it is intended to perform.
l 17 ---
Table 4.14.1-1 The comment "During liquid additions Notation to the tank" denoted by two asterisks
. is not required in the table.
18 ---
Table 4.14-1 It is unclear why the numbering system Notation has been retained.
19 Table Table 3.14.2-1 The Licensee comments dated 10/1/82 3.3.7.12-1 indicate that the functions of the i Item 1 main condenser off-gas effluent -
monitoring system are performed by the stack effluent monitoring system. ,
20 Table Table 3.14.2-1 The Licensee comments dated 10/1/82 3.3.7.12-1 Item 2 indicate'that the main condenser Item 2 explosive gas system is designed for an explosion and only one hydrogen monitor is present. Also, from plant comment #14, it is unclear why this path-way cannot be totally secured as a result of building ventilation. Normally, automatic termination of explosive gas i
releases occurs prior to the addition of dilution air.
21 Table ---
Are any other gaseous release pathways 3.3.7.12-1 present? (Note: Drawings would be Item 5-9 helpful at the plant review.)
22 Table ---
Is there a condenser air ejector .
3.3.7.12-1 monitor present prior to the holdup Item 10 system? This is a normal SWR plant system.
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"c. 0473 RETS Comments 23 ---
Table 3.14.2-1 What is the purpose of monitoring his Item 4 system? If it is a potential release pathway, a flow rate monitor should be present unless adequate justification for not monitoring the flowrate is present.
24 Table Table 3.14.2-1 The purpose of the notation with three 3.3.7.12-1 Notation~~ asterisks is unclear. It is not used Notation in Table 3.14.2-1.
25 Table Table- 3.14.2-1 Eight hour grab samples are required 3.3.7.12-1 Action 27 on the ventilation release points Action 123 rather than, daily.
26 Table Table 3.14.2-1 For the reactor building ventilation 3.3.7.12-1 Action 27 system Action 123 of the model is Action 124 -
adequate. But, as the potential for.
larger releases is greater during a drywell purge, suspension of releases from the drywell is appropriate unless monitoring capability is present.
The 30-day limitation is no longer a requirement.
27 Table Table 3.14.2-1 The 28-day limitation or operation 3.3.7.12-1 Action 29 has been removed. Is there a calibra-Action 125 tion requirement for the temporary hydrogen analyzer.
29 Table Table 4.14.2-1 Is there a reactor building isolation 4.3.7.12.1 4.14.2-1 noble gas monitor that may require Item 3 Item 3 surveillance tests? The plant states that the vent monitoring system does
, not have a trip function.
30 Table Table 4.14.2-1 If an instrument, the recombiner building 4.3.7.12-l' Item 6 ventilation monitoring system, is listed in the instrumentation section as Item 4, the surveillar,ce requirement should also be included numbered as Item 4 rather than 6. -
31 Table Table 4.14.2-1 If no automatic termination of release 4.3.7.12-1 Notation 1 functions are present on the effluent pathways, this notation is not required.
22 3.11.1.1 3.15.1.1 The monthly operating report (Speci-Action a Action a fication 5.9.1.10) requirement is not stated in the model RETS.
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NUREG Hatch
- o. 0473 RETS Connents 33 4.11.1.1.1 4.15.1.1.1 The Licensee comments datec 10/1/82 state that the sampling requirement do not apply to process streams. How does this effect the monitoring of plant effluents?
34 Table 4.11-1 Table 4.15.1-1 The plant prefers the term " minimum detectable concentration (MDC)" rather than " lower limit of detection (LLD)"
as the measured values are in terms of concentration.
35 Table 4.11-1 Table 4.15.1-1 The plant finds a MDC of 1.0 x 10-6 for Fe-55 difficult to measure and prefers an acceptable alternative of 2.0 x 10-6, 36 Table 4.11-1 ---
The Licensee comment dated 10/1/82 Item b states that the plant has no continuous liquid release pathways. Are there potential pathways that could be contaminated release points?
37 Table 4.11-1 Table 4.15.1-1 The definition of MDC referenced does Notation a Notation a not refer to the MDC as an "a priori" value. This is helpful for clarity.
Also, for plant samples tr.e at has not been defined as the elapsed period between the midpoint of sample collection and time of counting.
Further, Footnote "a" is not referenced in Table 4.15.1-1.
38 Table 4.11-1 Table 4.15.1-1 The definition should include the Notation d Notation e statement that " Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed to assure representative sampling."
39 3.11.1.2 3.15.1.2 The current requirements are that the 3.11.1.3 3.15.1.3 report to be filed is a special report 3.11.2.2 3.15.2.2 pursuant to Section 6.9.2 in lieu of 3.11.2.3 3.15.2.3 an LER. The sections listed specify Action a Action a reporting in the monthly operating-report.
40 3.11.1.2 3.15.1.2 If drinking water is taken from the Action a Action a receiving water within three miles of the plant discharge, the special 5
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0473 RETS Comments report must include the results of radiological analyses of the drinking water source and the radiological impact on finished drinking water. .
41 3.11.1.3 3.15.1.3 The operability requiremen5s~ listed in the submittal are listed for a quarterly basis rather than monthly as required by the model. Also, the quarterly limits listed are higher than required for a summed three month I
period. The monthly requirement is expressed in RETS as 1/48 of the annual dose. -
42 3.11.1.4 3.15.1.4 The plant indicates that outside temporary tanks will be limited to
, less than or equal to 10 curies, but that disposable liners may contain more activity. It is expected that the potential for release from these liners is very low.
43 3.11.1.4 3.15.1.4 It is suggested that if the 10 curie limit is exceeded, the events leading to these conditions should be described in the Semiannual Report.
The current Specification 6.9.1.12 requires a prompt notification if the limit is exceeded for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
44 4.11.1.4 4.15.1.4 The Licensee specifies that a sample will be analyzed of each batch prior to release to the temporary tank. Is this as conservative as a sample every seven days when additions are being made?
45 3.11.2.1 3.15.2.1 The current' requirements specify the Item b Item b following words, "for iodine-131, iodine-133, for tritium, and for all radionuclides in particulate form with half lives greater than 8 days."
46 4.11.2.1.1 4.15.2.1.1 It is not stated that the dose rates 4.11.2.1.2 4.15.2.1.2 will be determined to be within the-
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NUREG Hatch
.7 0 . 0473 RETS Comments above limits in accordance with the ODCM. It is unclear that the wording listed in the model produces a conflict with the liquid system calculations as stated by the Licensee.
47 Table 4.11-2 Table 4.15.2-1 The waste gas storage tank system Item A Item A is considered a portion of RETS due
. to the potential for high level releases.
48 Table 4.11-2 Table 4.15.2-1 The Licensee comments indicate that Item B containment releases are vented through
, the standby gas treatment system to the main stack. Justify that this would reduce the potential of exceeding 10 CFR 20 instantaneous release limits as would a prerelease grab sample.
49 Table 4.11-2 Table 4.15.2-1 It is not indicated that the gross Item D Item C alpha and strontium analyses would be done on composite samples.
50 Table 4.11-2 Table 4.15.2-1 A ncble gas monitoring system has not Item D been included in the specification.
51 Table 4.11-2 Table 4.15.2-1 It is. indicated that analyses will be Notation b, d Item c, e performed at >l5 percent power when-ever a change in the radionuclide mix could occur.- This appears very restrictive and the model specifications prefer analyses following startup, shutdown, and 15 percent power changes within hour unless (1) analysis shows
. the dose equivalent I-131 concentration in coolant has not increased by a factor of 3 and (2) the noble gas activity monitor shows that effluent activity has not increased by a factor of three..
52 Table 4.11-2 T_able 4.15.2-1 It is not indicated that 7 day samples Notation d Notation e for particulates and charcoal will.be taken and analyzed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
53 Table 4.11-2 Table 4.15.2-1 The Licensee notes dated 10/1/82 Notation e. i.ndicate that the spent fuel pool vents to the reactor building stack
, and a monthly grab sample is taken at this vent. This is an acceptable 7
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? o. 0473 RETS Conments alternative if changes in the fuel pool release rates are not normally expected.
54 Table 4.11-2 Table 4.15.2-1 The Licensee specifies that if higher Notation g Notation h, b than required MDC's are listed, the reasons will be documented in the Semiannual Report. Also, a calculation
, is shown for increasing the MDC based on the gamma yield. This is an acceptable method of correction for low gamma yield, or low energies.
55 3.11.2.2 3.15.2.2 The requirem'ent for reducing the dose design objectives based on public occupancy within the site boundary has been removed.
56 3.11.2.3 3.15.2.3 The proper terminology is "I-131, I-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days." The action statement also requires revision.
57 3.11.2.3 3.15.2.3 The doses are not stated as being Item a, b Item a, b "to any organ." Also, in Comment 80, the plant states that dose design objectives do not apply to operating pl ants. This needs to be clarified.
58 4.11.2.3 4.15.2.3.1 The statement that the dose calculations will be performed for "the total time period" is unclear.
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59 3.11.2.4 3.15.2 4 The doses listed for operation of the gaseous radwaste treatment system do not meet the 1/48 of the annual dose requirements for the ventilation exhaust system. The submittal appears '
to confuse the gaseous radwaste treat-ment system which must be in operation when the condenser air ejector is operating with the ventilation exhaust treatment system. The limits for the gaseous radwaste treatment system, 0.2,,
mrad ganma and 0.4 mrad beta during 31 days. The ventilation exhaust limit is 0.3 mrem to any organ in a 31 day period.
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NUREG Hatch
- 33. 0473 RETS Comments 60 3.11.2.7 3.15.2.7 Is 240,000 uCi/sec equivalent to 100 pCi/sec/MW t
? Also, is the location of the pretreatment monitor system downstream of the delay line?
61 3.11.2.7 3.15.2.7 What is the definition of operational '
Action a Action a condition 27 62 4.11.2.7.1 - - . It is not indicated that the radio-activity rate of noble gases at the main condenser air ejector will be continuously monitored.
63 3.11.2.8 --- The plant indicates that this specification is not necessary as the purge and vent system is hard-piped to the standby gas treatment system (letter dated 10/2/82).
64 3.11.3 3.15.3.1 The Process Control Program (PCP) 4.11.3 4.1.5.3.1 has not been addressed. The surveillance requirements on sampling of solid waste have not been addressed although a PCP is noted.
! 65 3.11.4 3.15.2.5 Only the liquid effluent release Action a limits (3.15.1.2) have been addressed in the action item and the surveil-lance requirement. Direct radiation shoulc be included. Also, all elements of the special report as listed in the model have not been included.
66 3.12.1 3.16.1 "Significant deviations" from the Action a Action-a environmental monitoring program are not defined.
67 3.12.1 3.16.1 The reporting requirements are based.
Action b Action b on the annual dose projection rather than the quarterly dose limits.
68 3.12.1 3.16.1 The plant indicates that vegetation Action c Action c samples may be unavailable outside the growing season and may not be taken. Also, it is indicated that milk sample locations may not be replaced as few milk animals are located in the vicinity (letter dated 10/2/82).
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NUREG Hatch No. 0473 RETS Comments 69 Table 3.12-1. Table 3.16.1-1 The radioiadine canister should have Item 1 Item 1 an analysis frequency of every 7 days.
The plant comments state that the analysis frequency is governed by-collection frequency and detection levels.
For beta analysis of composites, the period is specified as "approximately 91 days." This is an acceptable r
, alternative to 92 days.
70 Table 3.12-1 Table 3.16<l-1 The normal number of radiation Item 2 Item 2 dosimeters is 40 rather than 35.
Also the analysis frequency is not specified as quarterly.
71 Table 3.12-1 Table 3.16-1. The plant prefers not to do a Item 3b Item 3b gamma isotopic analysis on ground water samples as no positive identi-fications have been made in the previous ten years (letter dated 10/2/82).
72 Table 3.12-1 --- The plant indicates that the river Item 3c water is not used for drinking purposes and they do not perform the required analyses.
73 Table 3.12-1 Table 3.16-1 The comments dated 10/2/82 state Item 3d Item 3c that the sampling location is only uncovered for half the year, therefore, '
they obtain only an annual sample.
74 Table 3.12-1 Table 3.16-1 The plant comments state that only Item 4b Iten 4b one fish (shad) type is available in the immediate area.
75 Table 3.12-1 Table 3.16-1 The only vegetation apparently Item 4c Item 4c available for analysis is grass and two sample locations are provided with monthly samples.
76 Table 4.12-1 Table 4.16-1 The LLD for a gross beta analysis of water is not specified.
77 Table 4.12-1 Table 4.16-1 All values have been rounded to one place.
73 Table 4.12-1 Table 4.16-1 The LLD for I-131 is not specified as being for drinking water.
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NUREG Hatch
'f o . 0473 RETS Comments 79 Table 4.12-1 Table 4.16-1 The exponents have not been added for LLD's for airborne particulates or gases.
80 Table 4.12-1 Table 4.16-1 The value for.Cs-134 for fish was incorrectly reported. -
81 3.12.2 3.16.2 It is not indicated that the survey 4
, will include the nearest garden-greater than 500 feet. It is also indicated that an elevated release is present as the survey includes all milk animals within three miles.
82 3.12.2 3.16.2 The reports should be filed in the Action a, b Action a, b Semiannual Effluent Report.
83 3.12.2- 3.16.2 -
The plant indicates that any sample Action b Action b location with a greater dose commitment than current locations will be added
,to the sampling program.if samples are available.
84 3.12.2 3.16.2 It is not. clear what sampling Action b Action b location can be removed from the monitoring program.
85 - 4.12.2 4.16.2 The plant indicates that no date limitations are necessary for the survey as cows are on pasture year around.
86 BASES BASES All elements of the bases statement Total dose on total dose are not present.
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87 BASES BASES The discussion of "a priori" LLD's Environmental has not been included.
Monitoring 88 6.5.1.6.k 6.5.1.6.k The plant has put quantitative limitations on values that they must report.
89 6.5.1.6.1 6.5 1 6.1 Review of radwaste treatment system changes have not been included.-
90 6.5.2.8 6.5.2.8 The audits of the ODCM and PCP have not been addressed.
91 6.5.2.8.0 6.5.2.8.1 What is the reference for the quality f
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NUP.EG Hatch No. 0473 RETS Comnents assuranca progrma noted? The review should be annually.
92 6.8.1.1 6.8.1 Procedures for the quality assurance program have not been addressed.
93 6.9.1.7 6.9.1.7 The report does not include require-ments for (1) a summary description
' of the environmental monitoring-program (2) two legible maps covering sample locations and keyed from the centerline of the reactor (3) discussions of deviations from the sampling schedule and (4) discussion of when LLD's were not achievable.
94 6.9.1.9 6.9.1.9 The assessment of radiation doses on members of the public and the assumptions used have not been incluced.
95 6.9.1.9 6.9.1.9 The elements of the report to be submitted 60 days after January 1 have not been included.
96 6.9.1.9 6.9.1.9 Quantitative limits have been placed on the report of unplanned releases.
97 6.9.1.9 6.9.1.9 Changes to the 00CM have been moved from the monthly report to the semiannual.
98 6.9.1.12 6.9.1.12 Prompt notification requirements have been removed from the model.
99 6.9.1.13 6.9.1.13 Thirty day written reporting require-ments have been removed.
100 6.13 6.15 The plant considers the PCP and 00CM 6.14 6.16 as plant procedures available for audit.
101 6.15 6.17 The technical specification on major changes to radioactive waste treatment systems has not been included.
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LIST OF ATTENDEE $
FEBRUARY 23 AND 24, 1983 MEETING WITH GEORGIA POWER COMPANY ON RETS NAME ORGANIZATION George Rivenbark NRC/DL Charles A. Willis NRC/DSI Douglas W. Akers EG&G .
. Bill Serrano EG&G John Wray NRC/ Region II Don Evans ,
NRC/ Region II Michael Blackwood GPC/ Licensing Jean M. Diluzio GPC/ Power Generation H.P.
Steve Ewald Power Generation Engr. GPC R. D. Baker GPC/ Nuclear Regulatory Engr. Mgr.
J. T. Ponder
- GPC/ Hatch Site T. L. Elten GPC/ Hatch Site William Ollinger EPC/GD James N. McCloud SCS/NSLD R. C. Hand '
Lab Supervisor Plant Hatch
- Attended 2/23/83 meeting only.
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