ML20198F852

Forwards Effluent Treatment Sys Branch Responses to EPA & Dept of Commerce Comments on Des.Comments Received After Deadline for Agency Comments

ML20198F852
Person / Time
Site:	Satsop
Issue date:	05/08/1975
From:	Jay Collins Office of Nuclear Reactor Regulation
To:	Regan W Office of Nuclear Reactor Regulation
References
CON-WNP-1250 NUDOCS 8605290119
Download: ML20198F852 (5)

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W. H. Regan, Chief, Rnvironmental Projects 2 ranch 4, P1 RESPONSE TC U.S. ENV30NMENTAL, PROTECTION AGENCi C2fMI2iTS AND U.S. D"PARTMENT OF CGIMERCE COMMETIS FOR WASHINGTON NUCLEAR PROJECT, U'41TS 3 AND 5. D2 AFT ENVIRONMEh"fAL STATEMENT Plant Name: Washington Nuclear Project, Units 3 and 5 Licensing Stage: CP Docket Numbers: SIN 50-508/509 Responsible Branch: EPB 4 Raquested Completion Date: April 21, 1975 Project Leader:

J. Norris Deccription of Response: Response to U. S. Department of Interior and U. S. Environmental Protection Agency Cor.annes Submitted af t.er Deadline Raview Status: Complate Enclosed are our responseo to comments from the Environmental Protection Agency and the Department of Commerce on the Draft Environraer.tal Stater.ent for Washington Nuclear Project, Units 3 'and 5. '

These comments vere received after the deadline for af,ency comoc'nts.

John T. Collins, Chief Effluent Treatment Systems Branch Div.tsion of Technical Revinv

Enclosure:

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S. Hanauer (w/o encl)

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a RESPONSE TO U.S. ENVIRONMENTAL PROTECTION AGENCY COMENTS Comment, Page 2, Radioactive Waste Treatment Based on our evaluation of the draft statement, the proposed gaseous and liquid waste management systems are expected to be capable of limiting the radioactive releases and the resulting doses to within the "as low as practicable" guidance,of the proposed Appendix I to 10 CFR Part 50, with the possible exception of radioiodine releases from the containment building. }kny recently designed PWR's have recirculating internal cleanup systems with flow rates exceeding 20,000 cfm versus 11,500 cfm for WPPSS 3.and 5.

It is not clear from the draf t statement or the Applicant's environmental report (ER) whether or not both of the parallel trains of the Containment Atmospheric Control System (CACS) will operate at the same time. Over one-third of the estimated radioiodine release from the proposed plant comes from the containment building. Since the calculated thyroid doses exceed the design objectives of the proposed Appendix 1, the adequacy of the CACS should be reevaluated and its design and operation should be discussed fully in the final statement relative to achieving "as low as practicable" discharges, consistent with " state-of-the-art" i~odine control design.

Response

The parallel trains of the Containment Atmospheric Control System (CACS) have the capability of operating simultaneously; however, since the l

system may be operated with only one train, we assumed single train operation in calculating the source term.

Since the WNP 3/5 calculated radioactive iodine dose is 17.9 mrem, the calculated thyroid doses do not exceed our acceptance criteria.

Iodine releases from this source could be further reduced by operating the system for longer periods of time or by operating both trains simultaneo.usly, if required to meet the limiting conditions of the Environmental Technical Specifications.

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RESPONSE TO U.S. DEPART >tE'iT OF C0!DIERCE COSDIENTS Comment, Page 5-20 Although the NRC staff assumed that the radioactive noble gases will-be released to atmosphere af ter 90-days holdup from a system containing nine 700-cu. f t. gas decay tanks, no specification was made of the frequency and length of time during which these gases are emitted.

If these releases from individual tanks occur over a period of less than an hour, for example; with a frequency of once' a month, the use of an annual relative concentration (chi /Q) in table 5.7 to compute annual individual doses due to gaseous effluents is meaningless and inappropriate. This particular comment by the National Oceanic and Atmospheric Administration (NOAA) has been made innumerable times during the past few years without response from NRC.

If the doses from non-accidental radioactive gases are inconsequential no matter how severe the atmospheric dispersion, then say so rather than using an inappropriate computational technique.

Response

Our source term and our calculated exposures from releases of noble gases are based on the premise that a large number'of nonaccidental releases from the Gaseous Waste Processing System (GWPS) occur under normal operating conditions over the projected 40-year plant life.

On this basis, we have assumed that the releases occur randomly and that average X/Q values apply.

While we recognize that unfavorable dispersion conditions could arise during any given release, we assume that the statistical average value for X/Q for a large number of releases occurring randomly over the 40-year plant life will approach the annual relative concentration (X/Q) and, therefore, we have used this value.

• There are a number of factors which substantiate this assumption:

(1) Discrete releases of gaseous effluents will be governed by the limiting cond.itions of the Environmental Technical Specifications.

It will be incumbent upon the plant operator to establish procedures for the control of gaseous releases to assure that the technica,1 specifications limiting conditions are not exceeded. The procedure usually employed to control doses at or beyond the site boundary from releases of noble gases is that of permitting release only

'under favorable meteorological conditions.

(2) The typical mode of release of gases from waste gas storage tanks is by a slow bleed, e.g.,1 to 2 scfm, into the plant vent. This provides a dilution factor prior to release which increases the 3 tank effective dispersion. Release of the contents of a 700 ft containing gases a't 270 psig would require approximately 3 days at a release rate of 2 scfm or.approximately 6 days at 1 scfm.

(3) Our calculations show that the GWPS has adequate capacity to permit holding two or more tanks in reserve for back-to-back shutdowns.

There should be no reason to require the operator to dispose of GWPS tank contents over a short period of time, i.e.,

less than one hour.

From the above, we conclude that releases will occur randomly, that individual releases will be of several hours duration, that releases

,will occur during more optimum meteorological conditions, and that substantial dilution of tank gases will occur prior to discharge from the plant vent. For these reasons, we consider that the use of the annual. relative concentration (X/Q) in determining annual dose to the population is appropriate and.is valid for the purposes of the Environmental Statement.

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