ML20210R974
| ML20210R974 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/25/1997 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210R960 | List: |
| References | |
| 50-416-97-10, GNRO-97-00074, GNRO-97-74, NUDOCS 9709040198 | |
| Download: ML20210R974 (4) | |
Text
_ _ _ _ _ _ _ _ _ __
1-a y
2ntergy Operattons. Inc.
hh PO Boa 756 Port Goson. MS 39i50 -
Te, t01437 6470 -
W. K. Hughey C octu July 25,1997
%,*[ " " ' * * '
U.S. Nuclear Regulatory Commission hjG 4l997
~
Mall Station P137 Washington, D.C. 20555
, 74 -
- - _ ~ _ _. _.
Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF 29 Annual Fish Sampling for Radiological Environmental Monitoring Program j.
Report No. 50-416/97-10 Dated July 2,1997 (GNRI 97/00093)
GNRO 97/00074 Gentlemen:
{
Dunng the most recent she inspection performed by your Statf in the eres of; radioactive effluents, waste treatment, and environmental monitoring, concems were raised regard,1g the removal of fish samphng from our.Redeological Erwwonmental Monitoring Program (REMP). Entergy Operations, Inc. hereby submits this response
'to co' firm thscommitment that annual samphng of fish will be.re instated as a part ofe.
n
'theMMP.
If you have questions concoming this correspondence, contact Riley Ruffin at 601-437-2167.
Yours truly,
=/W
/RR atttachment cc:
(See Next Page) 9709040198 970827 PDR ADOCK 05000416 G
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I C..RO 97/00074 Page 2 of 2 cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr, L. J. Smith (Wise Carter) (wla)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (wla)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 l
Washington, D.C. 20555 1
I J
e_
Attachmint to GNRO 97/00074 Paev 1 of 1
-'t The REMP was established prior to commercial _ operations at the Grand Gulf Nuclear Station. The REMP was designed to establish a baseline of radioactivity in the environment and monitor any radioactive buildup as a result of plant operations. Following the establishment of a baseline, the REMP was continued during commercial operations to venfy the effectiveness of the Radiological Effluents Monitoring Program and identify any unmonitored or undetected radioactive effluent release points.
in 1995, GGNS began initiatives to reduce the radiological environmental monitoring program as specified in Regulatory Guide (RG) 4.1 ? Programs For Monitoring Radioactivity in The Environs Of Nuclear Power Plants". RG 4.1 indicates that licensees can, after three years of commercial power operation, reduce the number o/ media sampled in a pathway, as well as, the frequency of sampling if it is demonstrated that the dose and concentration associated with a particular pathway is sufficiently small Tphe particular med6umJn. question. is fish semples from the ingesteen pathway.
g Fish medium has been a part of the REMP for the ingestion pathway since 1978, along with milk and vegetation as described in NRC BTP'. Based on seventeen years of commercial and p;eoperational I
data, fish samples that have been obtained as a part of the REMP have not indeosted any_eothaty.
Therefore the.sompleng frequency could_ be feduceda The sempting of fish was removed from the REMP/but wee note #mimWedo It was retained as a part
+ef our Special Sempieng program. ' Currently, our special sampling program allows samples to be obtained to provide data if elevated levels of radioactive effluents are detected in our monitoring program or any other event necessitates additional data. Waterbome and sediment samples are still a part of the REMP. Since fish would be in contact with the water and could possibly ingest sediment, these data points would give indications of activity increases in plant effluents which would prompt fish samples to be obtained and analyzed.
Prior to implementation of the reduction, changes to _the program were discussed with MS State Dept.
of Rad Health, American Nucieer insurers and NRC staff. Understanding that indnadual memisere of a
<NRC eleft do not mehe pohoy or estabheh NRC position GGNS sensidered and implemented theiru wrecommendelions se e part of our overall REMP reduction implementation.
I We believe that " appropriate analysis or evaluations justifying the change *2 for moving the fish simple to our special sampling program was adequately performed. Additionally, the changes to the REMP along wF.h its supporting evaluation were reviewed and approved by both GGNS' Plant Safety Review Committee and the Safety Review Committee.
While lessening the burden of obtaining unwarranted samples, the relocation of this sample did not reduce the effectiveness of our radiological effluents monitoring program.' Additionally, placing this -
simple in the special sample program did not increase the rtok to'the environs.
Our actions were based on our interpretation of Regulatory Guide 4.1, ' Programs for Monitoring i
Radioactivity in the Environs of Nuclear Power Plants *, Revision 1, April 1975, and historical data that r:flected no detectable activity. We viewed the fish sample as a medium within the ingestion pathway; not as a pathway itself. YoGr StaffidatAd that the fish'are considered to be a part of the aquatic ingestion pathway. Based on other irWomal considerations and the Stefra interpretationW oommitted to~re instate floh sempling into the REMP at"an'ennuei frequency (
' NRC Branch Technical Position,
- Environmental Technical Specifications For Nuclear Power Plants" Revision 1 November 1979 8 GGNS Technical Specifications 5.5.1.a.1
)