ML20210E657

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Submits Comments for Consideration Prior to Reinstatement of License DPR-76,including Recommendation for Full Implementation of NUREG-0737,Item II.F.1 Re Addl Accident Monitoring
ML20210E657
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 08/19/1983
From: Scarano R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Bishop T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20209C222 List:
References
FOIA-86-151, RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8609250066
Download: ML20210E657 (7)


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/ UNITED STATES

. 2. o NUCLEAR REGULATORY COMMISSION

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-l# REGION V 1480 MARIA LANE.sulTE 210 j WALNUT CREEK. CALIFORNIA 94805

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!  ; AUG .191983 1,

1 i MEMORANDUM TO: Tom Bishop, Director, Division of Resident, j

e Reactor Projects, and Engineering Programs 1

FROM: Ross A. Scarano, Director Division of Radiological Safety and Safeguards Program

SUBJECT:

COMMENTS FOR CONSIDERATION PRIOR TO REINSTATEMENT OF LICENSE FOR I

. DIABLO CANYON UNIT 1 Below are a number of comments that are worthy of consideration prior to lifting the suspension of License DPR-76. Attachment 1 details each issue.

Briefly they are as follows:

. 1. No implementation date has been established for License Condition 2.6(8)h. This condition deals with the Post Accident Sampling

') System. Our inspection reveals that the licensee has not yet fully implemented this requirement. We reconsend required full implem'entation

, prior to exceading 5% power.

.' 2. No implementation date has'been established for License Condition l 2.6(8)K. This condition deals with NUREG 0737 Item II.F.1, Additional

] Accident Monitoring. Again, our inspections revealed that these

,l requirements have not been fully implemented. We recommend full j implementation prior to exceeding 5% power.

. 3. In light of items 1 and 2 above the effective date of Technical

{ Specification 6.8.4 should be clarified. This Technical Specification

! requires a program for post accident sampling.

4. Technical Specifications 3.3.3.6/4.3.3.6, Accident Monitoring Instrumentation, and 3.3.3.1/4.3.3.1, Radiation Monitoring Instrumentation, do not include the NUREG 0737 monitors. We recommend that the instruments listed on Table 1 of the Attachment be included.

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5. The Technical Specifications and the Offsite Dose Calculation Procedure t

(ODCP) are not consistent regarding utilization of real time vs average annual meteorology. The ODCP is reviewed and approved by NRR. We think i that the ODCP should be made consistent with the Technical Specifications.

8609250066 860916 PDR FOIA

HOLMES86-151 PDR 4

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,' Tom Bishop 2 AUG 101933

6. Statements in SER supplements 12 and 14 imply that the licensee shall

,  : have a noble gas monitor and a particulate and iodine sampler on the steam generator blowdown tank vent and a particulate and iodine sampler in the atmospheric steam dumps. The licensee does not have these instruments and is not planning to install them. It is not clear that NRR really intends the licensee to have these monitors / samplers. This i issue should be resolved.

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Items 3 and 4 were brought to NRR's attention in a memorandum dated July 22, l i 1983. Items 1, 2 and 6 have been discussed with Bart Buckley, NRR Project Manager on our day to day contact. Item number 5 was discussed briefly with Charley Willis months ago.

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f For more details, contact Emilio Garcia.

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  • i l 1 Ross A. Scarano, Director

, ,, Radiological Safety and Safeguards Programs Division t

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j ATTACHMENT 1 ]

A. Clarification of License Conditions and Technical Specifications.

i l 1. License condition 2.6(8)h states: , _ _ , _

"(8) NUREG-0737 Conditions I Each of the following conditions shall be completed to the j satisfaction of the NRC by the times indicated below. Each of

! the following conditions references the appropriate item in SER

! Supplements No. 10 and/or No. 12.

., h. Post Accident Shapling (Section II.B.3)

PG&E shall complete corrective actions needed to provide the capability to promptly obtain and perform radioisotopic and chemical analyses of reactor coolant and

! containment atmosphere samples under degraded core conditions without excessive exposure. An implementation date for this item will be established by the NRC prior to

,; fuel loading in Unit No. 1."

i ACTION - Establish implementation date.

i ACTION - Define implementation.

l 2. License condition 2.6.-(8)k states:

J j "(8) NUREG-0737 Conditions Each of the following conditions shall be completed to the satisfaction of the NRC by the times indicated below. Each of i =l the following conditions references the appropriate item in SER lj Supplements No.10 and/or No.12.

k. Additional Accident Monitorict Instrumentation (Section II.F.1) 5

- PG&E shall install continuous indication in the control

room of the following parameters

-f (1) Containment radiation monitors. .

(2) Noble gas effluent from each potential release point.

An implementation date for this item will be established

, by the NRC prior to fuel loading in Unit 1."

'l l ACTION - Establish i:splementation date.

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, ACTION - Define implementation.

3. Technical Specification 6.8.4.e states:

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! "6.8.4 The following programs shall be established, implemented, '

! and maintained:

c. Postaccident Sampling A program which will ensure the capability to obtain i and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident

! conditions. The program shall include the following:

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.] 1. Training of personnel, I 2. Procedures for sampling and analysis,

3. Provisions for maintenance of sampling and analysis equipment."

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ACTION - Clarified effective date for this specification in light of items 1 and 2 above.

4. Technical Specifications 3.3.3.6 and 4.3.3.6, Accident Monitoring Instrumentation does not include those monitors and samplers needed i to fulfill the recommendations of NUREG 0737 Item II-F.1 l

Attachments 1, 2 and 3. The applicable monitors are noted on i Table 1.

i ACTION - Determined which monitors should be included in these specifications.

ACTION - Amend Specifications.

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5. Technical Specification 3.3.3.1 and 4.3.3.1, Radiation Monitoring Instrumentation, does not include the NUREG 0737 monitors noted on
, Table 1.

l ACTION - Determined which monitors should be included in these l specifications.

! ACTION - Establish, selected instruments parameters for Tables 3.3-6 and

. 4.3-3.

, ACTION - Amend Specifications.

6. Technical Specification 6.9.1.9 states in part:

, "The radioactive effluent release report to be submitted 60 days l . after January 1 of each year shall include an annual summary of hourly meteorological data collecte'd over the previous year. This ll annual summary may be either in the form of an hour-by-hour listing of wind speed, wind direction, atmospheric stability, and i i precipitation (if measured) on magnetic tape, or in the form of

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joint frequency distributions of wind speed, wind direction, and atmospheric stability. This same report shall include an assessment t

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! of the radiation doses dua to the radioactive liquid and gaseous i effluents released from the unit or station during the previous

! calendar year. This same report shall also include an assessment of 1

the radiation doses from radioactive liquid and gaseous effluents to individuals due to their activities inside the site boundary -

(Figures 5.1-3 and 5.1-4) during the report period. All assumptions used in making these assessments (i.e., specific activity, exposure l

. i time and location) shall be included in these reports.

I i . The meteorological conditions concurrent with the time  !

j of release of radioactive materials in asseous effluents (as

, determined by samplina frequency and measurement) shall be used i for determinia the asseous pathway doses. The assessment of l radiation doses shall be performed in accordance with the OFFSITE DOSE CALCULATION PROCEDURE (ODCP)."

The NRR' approved ODCP, licensee's procedure CAP A-8 "Off-Site Dose i Calculations" states on page 10:

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! "(2) Air dose in unrestricted areas due to noble gases.

(T.S. 3.11.2.2) i The air dose in unrestricted areas due to noble gases released l *in gaseous effluents shall be calculated in accordance with the 1

following expressions:

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D,7 = 3.17x10 n1[(x/Q)Q 11

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where: ...

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. j' (x/Q) = 3.87x10 sec/m3 . The annual average relative concentration for the location where analyses of annual average air doses were found to be maximum i for any area at or beyond the unrestricted area l , boundary for long term releases (greater than

' -' 500 hrs / year). (Basis: NW sector, site

, boundary)."

l j ACTION - Seek amendment of the NRC approved ODCP to make it consistent with

! Technical Specification 6.9.19.

I B. Clarification of licensee commitments and requirements as described in

! Safety Evaluation Report (SER) Supplements 12 and 14.

} 1. SER Supplement 12 states on page II-8:

, 1 i . ."The potential gaseous effluent release points at Diablo Canyon, i Units Nos. I and 2, consist of the plant vent stack, the atmospheric

, 4 steam dump, and the steam generator blowdown tank vent. The

! applicant has committed to install mid/high-level noble gas effluent

! monitors at these three points by January 1, 1983. The monitors l .

will be designed to meet the requirements and satisfy the characteristics given in Table II.F.1-1. The monitors will be off-line type and the plant vent system will include new isokinetic probes in each release line."

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l The licensee does not have a accident range (NUREG 0737 Table II.F.1-1) monitor at the steam generator blowdown tank vent and does not plan to install one.

ACTION: - Determined whether or not the licensee is required to have an accident range noble gas monitor.

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j ACTION
- If the monitor is required, establish date for full implementation.

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}l 2. SER Supplement 14 states on page 3-15:

"In regard to position (1), the potential gaseous effluent release i~j points at Diablo Canyon, Unit Nos. I and 2, consist of the plant

' j- vent stack, the atmospheric steam dump, and the' steam generator

blowdown tank vent. The applicant has committed to install
mid/high-level noble gas effluent monitors at these three points by t January 1, 1982. The monitors will be designed to meet the requirements and satisfy the characteristics given in NUREG-0737 and is, therefore, acceptable.

In regard to position (2), the potential gaseous effluent release points at Diablo Canyon, Unit Nos. I and 2, are the same as for the noble gases. The applicant has committed to install new isokinetic

, probes in each release line by January 1, 1982. The applicant will i utilize the new and existing isokinetic probes and the off-line sampling systems to quantify release rates during an accident.

Silver-zeolite / charcoal cartridges will be reverse blown with air to

', purge interfering noble gases. The present counting room will

,  ; provide analysis. The system for measuring radioiodine for the accident meets the requirements and satisfies the characteristics i given in NUREG-0737, and is, therefore, acceptable."

The licensee has not installed isokinetic probes in the atmospheric i steam dumps or the steam generator blowdown tank vent and does not i

plan to installed them.

i Region V does not believe that it is technically feasible or" prudent to install isokinetic probes in the atmospheric steam I

dumps. .

I ACTION - Determined whether or not the licensee is required to install j isokineti,c probes to sample the atmospheric steam dumps.

ACTION - Determindd whether or not the licensee is required to install

.j isokinetic. probes in the steam generator blowdown tank vent.

ACTION - If the samplers are required, establish dates for full j implementation. ,

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. TABLE 1 l DIABLO CANYON NUREG 0737

,[ ITEM II.F.1 ATTACHMENT 1, 2 AND 3

. .I MONITORS AND/OR SAMPLERS ~

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'l j CHANNEL DESCRIPTION ATTACHMENT CONTROL

] ROOM

,  ! NO. NO. ALARM RE-29 Plant Vent Gross Gasmaa Monitor (High 1 Yes Range) -

RE-30 Containment Area Monitor (High Range) 3 Yes RE-31 Containment Area Monitor (High Range) 3 Yes j RE-32 Plant Vent Iodine Monitor (Mid Range) 2 Yes and Particulate Sampler RE-33 Plan Vent Noble Gas-Monitor (Mid Range) 1 Yes j RX-40 Particulate and Iodine Sampler (High Range) 2 No i RE-71 Main Steam Line Vent Monitor 1 ,

Yes RE-72 Main Steam Line Vent Monitor 1 Yes RE-73 Main Steam Line Vent Monitor 1 Yes l RE-74 Main Steam Line Vent Monitor -

1 Yes I

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