ML20235C375

Proposed Tech Specs,Incorporating Equipment Staging Bldg Ventilation Sys as Gaseous Effluent Release Point

ML20235C375
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/02/1987
From:	DUKE POWER CO.
To:
Shared Package
ML20235C359	List: ML20235C355 ML20235C375
References
TAC-65437, TAC-65438, NUDOCS 8707090396
Download: ML20235C375 (35)

Text

{{#Wiki_filter:'.k ~', Wechange r rito..Onlly INSTRUMENTATION RADI0 ACTIVE GASE0tl5 EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive gaseous effluent monitoring instrumentation channels shown in' Table;3.3-13 shall be OPERABLE with their Alarm / Trip'Setpoints set to ensure that the limits of Specification 3.11.2.1-are not exceeded. The Alarm / Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the 00CM. APPLn ABILITY: As shown~in Table 3.3-13. ACTION: With a radioactive gaseous effluent monitoring instrumentation a. channel Alarm / Trip Setpoint less conservative than required by-the- ~ ab se specification, immediately suspend the' release of radioactive gs Sous effluents monitored by the affected channel, or deciare the i channel inoperable. b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take.the ACTION shown in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE status within the time specified in'the ACTION or, in lieu of a Licensee Event Report, explain in the next Semiannual Radioactive -Ef#luent Release Report why this inoperability was not corrected witnin the time specified. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. l SURVEILLANCE REQUIREMENTS 4.3.3.9 Each radioactive gaseous effluent monitoring instrumentation channel' shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST operations at the f requencies shown in Table 4. 3-9. 8707090396 070702 PDR ADOCK 05000369 P PDR McGUIRE - UNITS I and 2 3/4 3-71 Amendment No.52(Unit 1) Amendment No.33(Unit 2) s

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.T MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

10. EQUIPMENT STAGING BUILDING VENTILATION SYSTEM a.

NOBLE GAS ACTIVITY MONITOR (EMF-59) 1 37 b. FLOW RATE MONITOR 1 36 c. SAMPLER MINIMUM FLOW DEVICE 1 36 y e

J\\, No chon9e s ~ Q CO j TABLE 3.3-13 (Continue g a TABLE NOTATION =At'all times, an During WASTE GAS HOLOUP SYSTEM operation.

• • • 0uring gaseous affluent releases.

ACT'CN STATEMENTS ACTION 35 - With the numoer of cnannels CPERABLE less than recuired oy tne Minimum Chan'nels CPERABLE requirement, the contents of tne tank (s) may be released to the environment for up

• .o 14 days proviced that prior to initiating the release:

a. At least two independent samples of the tank's contents are analyzed, and b. At least two technically qualified members of the facility staff independently verify the discharge valve lineuo: 1) The manual portion of the computer ! rout for ne release rate calculations performed on the computer, or 2) The entire release rate calculations if such calculaj tions are performed manually. Ctnerwise, suspend release of radioactive effluents via this j patnway. ACTION 36 - With the numoer of channels OPERABLE less than recuired by the Minimum Channels OPERABLE requirement, effluent releases via this oathway may continue for up to 30 days provided tne flow rate is estimated at least once oer 4 hours. ACTION 37 - With the number of channels OPERABLE less than recui*ed oy tne Minimum Channels OPERABLE requirement, effluent releases via tnis patrway may continue for up to 30 days provicea grao samoles are taken at least once per 12 nours and tnese samo'es ( are analyzed for gross radioactivity aitnin 24 nours. i ACTICN 38 - With the number of channels OPERABLE less than recuired oy tre ) Minimum Channels OPERABLE requirement, immediately suspeno I PURGIllG or VENTING of radioactive effluents via tnis patnway. ACTION 39 - With the number of channels OPERABLE ane less tnan recuired oy the Minimum Channels OPERABLE requirement, coeration of :nis system may continue for up to 14 days. Witn two channels inoperaole, be in at least HOT STANDBY within 5 heers. ACTICN 40 - With the number of channels OPERABLE less than recuired by the f Minimum Channels CPERABLE requirement, ef fluent releases via i the effected pathway may continue for up to 30 days providec samples are continuously collected with auxiliary samoling ecuipment as required in Table 4.11-2. ACTION 41 - With the numoer of channels OPERABLE one less than recuired oy the Minimum Channels OPERABLE requirement, suspend oxygen supply to the racomoiner. Amendment No. 1 (Unit 2) McGUIRE - UNITS 1 and 2 3/4 3-74 Amencment No. 20 (Unit 1) 3 e/13/S3

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+.... 'g ANALOG CHANNEL MODES IN 'a*HICH CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST REQUIRED

10. EQUIPMENT STAGING BUILDING VENTILATION SYSTEM a.

NOBLE GAS ACTIVITY MONITOR D M R(3) Q(2) (EMF-59) b. FLOW RATE MONITOR D N.A. R Q c. SAMPLER MINIMUM FLOW DEVICE D N.A. R Q v

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t. f.* <a TABLE NOTATION r s ; 4,..., e At"all times except When the isolation valve is closed and locked. NH During WASTE GAS HOLDUP SYSTEM operation. Tne i.NALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic ( (1) . isolation of-this pathway and control room alarm annunciation occurs if any of the following conditions exists: g,7 -Instrument indicates measured levels above the Alarm / Trip Setpoint, a. (.y 'b. Circuit failure (alarm only), and Instrument indicates a downscale failure (alarm only), c. 4' (2) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that control room alain annunciation occurs if any of the following conditions exists: s ?).l g Instrument indicates measured levels above the Alarm Setpoint, I I a. b. Circuit failure, and M c. Instrument indicates a downscale failure. (3) Tne initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards Certified by the National Bureau of.Stanaarcs (NBS) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NB5. These standards shall permit calibrating the system over its intended range of energy and measurement range. For suosequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used. I The CHANNEL CALIBRATION shall include the use of standard gas samples (4) corresponding to alarm setpoints in accordance witn the manufacturer's recommendations. (5) Ti e CHANNEL CALIBRATION shall include the use of standard gas samples in eccordance with the manufacturer's recommendations. In addition, a standard gas sample.of nominal 4 volume percent oxygen, balance nitrogen, shall be used in the calibration to check linearity of the oxygen analyzer. Amendment No.10 (Unit 2) McGUIRE - UNITS 1 and 2 3/4 3-77 Amendment No. 29 (Unit 1) l )

\\ No changes RADI0 ACTIVE EFFLUENTS l CG 3/4.11.2 GASEOUS EFFLUENTS ~ DOSE RATE LIMITING CONDITION FOR OPERATION 3.11.2.1 The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to the following: a. For noble gases: Less than or equal to 500 mrem /yr to the whole body and less than or equal to 3000 mrem /yr to the skin, and b. For Iodine-131 and 133, for tritium, and for all radioactive materials in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrem /yr to any organ. APPLICABILITY: At all times. ACTION: With the dose rate (s) exceeding the above limits, immediately restore the release rate to within the aoove limit (s). { SURVEILLANCE REQUIREMENTS 4.11.2.1.1 The dose rate due to noble gases in gaseous effluents shall be determined to be within the aoove limits in accordance_wi th the methodology ar.d parameters in the ODCM. 4.11.2.1.2 The dose rate due to radioactive materials, other than noole gases, in gaseous effluents shall be determined to be witnin the above limit; ) in accordance with the methodology and carameters of tre ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 4.11-2. ) I i i i i MCGUIRE - UNITS 1 and 2 3/4 11-9 Amendment No. 52 (Uni t 1) j Amendment No. 33 (Unit 2) 1 l l - i

~ ) Fg O I T() I 0 I I I l I 9 I I O/ 4 4-6 4 6 4 6 MNm '0 0 0 0 '0 0 0 0 0 0 0 0 LIl 1 1 1 1 1 EE( x x x x x x x x x x x x 1 1 1 TC RCp 1 1 1 1 l l 1 1 l WT 1 1 1 1 1 1 1 OE LD ) I M ) ) I ) A ( R 7 I I I I I s G s s s s r R r r r r O e P e e e e t t t t t t i t t t i m m S i i i S S m m m m I E Y I E E E E a) L S A Y a a a a ms } n N L m m m u mr 0 A A m m m s ae ( Gh a 9 FN a a a a D OA G G G G t h -r lO p S N l l l a l A EY l PT a a a a A p G YI p p p p i1 i 1 3 c3 s 9 i i i N TV L T n n n n 3 3 n1 s 8 I c c c c i 3 i 3 i 3 1 1 i - o e I rI r r M A r r r r 1 9 I I P( G S P C i e l P P P P I 1 1 s 1 o A 9 S g' g t E h t T ) e e e S 2 l l t t t A A ( W e g ) ) a ea ea i tl tl S Y k g I n l 4 l U SC n r i I a I u iu iu O MI N a u I g Doe Dce Msce sce o cl i l oil Qoil M W W r rp t p pt p pt p E USE T S MYU h am rm mrm mrm A l LQ h S ha aa oaa oaa i AE c c iNR a a CS PS CPS CPS G t m E MAF E E ) ) ) ) 6 _6 6 6 ~ V ) ( ( ( ( I } 2( s s s s T D Y k g u u u u C e I e o o o o A u u u u I GC n r I u A I E l e P e I e e q n n n n D NN a u i i i PQ hb p ib p3 bp b p t t t t l E i l l ME cam cam am am n n n n l l R Lt c o o o o C C C C AR ara ara I ra ra SI EGS EGS WGS WGS 7s 5rr e e d a e E g g p. e P. y3 P a r t Y r u as e T ey nl s ne 1 o P t tt ia u eiv E S t si mi o s o A s e t a1 as h adb n 5 E a m n w1 tt e e eea r l t G n e d cnn n aaeo a es. V RFVCE W Ri4 l i E R e a l tk t t l d l sn S sn n i U aa o n O WT C U a b Aaa E S S AG 1 2 3 4 R ** y'$ 8 k5g h$d [g m I

g IVC C/lO l' O E i lGho Cn(/ . TABLE 4,11-2 ( :ntinued) TABLE NOTATION The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net (1) count, aDove system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal. For a particular measurement system (which may include radiochemical separation): 4.66 s b LLD = exp (-Ast) E V 2.22 x 10o Y Where: LLD is the "a priori" lower limit of detection as defined above y (as microcurie per unit mass or volume), is the standard deviation of the background counting rate or of,* stne counting rate of a blank sample as appropriate (as counts per b minute), E is the counting efficiency (as counts per disintegration), V is the sample size (in units of mass or volume), is the number of disintegrations per minute per microcurie, 6 2.22 x 10 Y is the fractional radiochemical yield (when applicable), \\ is the radioactive decay constant for the particular racionuclide, and it is the elapsed time between midpoint of sample collection and 1 time of counting (for plant effluents, not environmental satoles). Typical values of E, V, Y, and at shall be used in the calculation. It should be recognized that the LLD is defined as an a criori (before the fact) limit representing the capacility of a measurement system and not as an a posteriori (after tne f act) limit for a particular measurement. 3f4 11-11 McGUIRE - UNITS 1 and 2 I w. wg em o ne w "w

i IN C C.bO nQ e5 TABLE 4.11.2 (Continued) lGho Cn TABLE NOTATION (2) Sampling and analysis shall also be performed following shutdown, STARTUP, or a THERMAL POWER cnange exceeding 15% of RATED THERMAL POWER within a 1-hour period. (3) Tritium grab samp3es shall be taken at least cnce per 24 hours when the refueling canal is flooded. (a) Samples snill be changed at least once per 24 hours and analyses shall be completed within 48 hours after changing, or after removal from sampler. (5) Tritium grab samples shall be taken at least once per 7 days from the ventilation exnaust from the spent fuel pool area, whenever spent fuel is in the s]ent fuel pool. (6) The ratio of the sample flow volume to the sampled stream flow volume shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specifications 3.11.2.1, 3.11.2.2 and 3.11.2.3. l (7) The principal gamma emitters for which the LLD specification. applies include the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 in noble gas releases and Mn-54, Fe-59, Co-58, Co-60, Zn-65, 90-99, -131, Cs-134, Cs-137,and Ce3141 in iodine and particulate releases. The LLD for Ce-144 is 5x10 'uCi/ml. This list does not mean that only these nuclides are to te considered. Otner gamma ceaks that are identifiable, together with tnose of the acove nuclides, snail also be analyzed and reported in the Semiannual Raf oacti/e Effluent Release Report pursuant to Specification 6.9.1.7. (3) ~~e c:ecosite filter (s) sill be analyzed for alpna activity '/ analyzing one "lter cer -eek to ensure that at least four filters j are anal /:ea :er collection period. i ) l i McGUIRE - UNITS 1 and 2 3/4 11-12 i ) i i

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• 4 ATTACHMENT 2 5

5

l l i Justification and Safety Analysis

== Introduction:== By letter dated May 4, 1987, Duke submitted a report concerning the Maintenance / Equipment Staging Building (ESB) constructed at McGuire Nuclear Station, Unit 2. The submittal described the design, construction, and planned operation of the building and its systems. This submittal also took the position that no changes to McGuire's Technical Specifications were required to utilize the building's exhaust system. By letter dated May 13, 1987, the NRC formally informed Duke that NRC disagreed with Duke's conclusion that no changes to the Technical Specifications were necessary to utilize the building's exhaust system as a radiological release point, and such utilization requires prior Commission approval. Accordingly, the enclosed proposed changes to the McGuire Nuclear Station Technical Specifications seek to include the release point and associated equipment in the Technical feecifications, Tables 3.3-13, 4.3-9, and 4.11-2, and Figure 5.1-3. Tables 3.3-13 and 4.3-9 refer to Radioactive Gaseous Effluent Monitoring Instrumentation; Table 4.11-2 to Radioactive Gaseous Waste Sampling and Analysis, Program; Figure 5.1-3 to Gaseous Effluent Release points. The changes to Tables 3.3-13 and 4.3-9 add the system noble gas activity monitor,I flow rate monitor, and sampler minimum flow device to the Technical Specifications. The changes add Technical Specification requirements on the system identical to Items 8 and 9 of the tables (the contaminated parts warehouse ventilation system and the radwaste facility ventilation system, respectively). The monitor on the equipment staging building is of similar design and is expected to function under similar conditions as the monitors on the contaminated parts warehouse and the radwaste facility. The specification requires the operability of the monitor during gaseous effluent releases with sampling and flow estimates required if the monitor is inoperable. The surveillance required is the same as the contaminated parts warehouse and the radwaste facility ventilation systems as again, the system and operational conditions are expected to be similar. This similarity is also the banis for the proposed change to Table 4.11-2, Radioactive Gaseous Waste Sampling and Analyses Program. This specification will require additional sampling and analysis of the released effluents. This will require that total dose rate as calculated using methodology and parameters of the ODCM (Offsite Dose Calculation Manual) be maintained within the limits specified in Specification 3,11.2.1. The proposed change to Figure 5.1-3 is to designate the new gaseous effluent release point. The figure is titled " Site Boundary for Gaseous Effluents" and denotes the location of the station gaseous release points. The proposed change to Figure 5.1-3 adds the Equipment Staging Building and its release point to the figure. The notation of the point on the figure coupled with the requirements of Specifications 3.3.3.9 (Tables 3.3-13 and 4.3-9) and 3.11.2.1 (Table 4.11-2) will ensure control j of effluent releases from the facility to ALARA levels. t Additional changes are proposed to Table 4.11-2 and Figure 5.1-3. The change to Table 4.11-2 would change " Contaminated Materials Warehouse" to " Contaminated Parts Warehouse". The additional change to Figure 5.1-3 would change " Contaminated Parts j Storage Warehouse" to " Contaminated Parts Warehouse". These changes are strictly administrative to attain consistency in the Technical Specifications. i i l I \\

Paga 2 A detailed description of the building was transmitted by Mr. H.B. Tucker's letter dated May 4, 1987. A technical description of the ventilation system is included in the.May 4 submitt'al as"is an assessment of expected effluent releases. When considering the expected effluents from the building, it is important to note that the effluents generated would be generated with or without the building; the work has merely been relocated to the maintenance / equipment staging building. As discussed in the May 4 submittal, the building and its HVAC system are not Nuclear Safety Related and serve no function for accident prevention or mitigation. During fuel movement, the equipment hatch will be closed in accordance with Specification 3.9.4 preventing any release from containment to the building in the event of a fuel handling accident, thus there is no dependence upon the building for the mitigation of an accident. The building was constructed as not to affect adjoining structures, i.e. the Reactor Building and the Fuel Building. As described in the May 4 submittal, contact between the Equipment Staging Building and the reactor and fuel buildings is through expansion joints; there are no rigid connections. Temporary bridges connect the building platform with the reactor building operating floor. The construction and operation of the facility has had and will have no impact upon plant operations. The facility is used independent of plant operation. It may be used in preparation for, during, and in cleanup following an outage without adversely impacting the station. Analysis of Significant Hazard Considerations 3 Pursuant to 10CFR50.91, the following analysis is performed to determine that the' proposed changes to the McGuire Nuclear Station Technical Specifications do not involve any significant hazard considerations as defined by 10CFR50.92. (1) The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated. The building is an independent, free standing structure. It adjoins the fuel building and the reactor building, but there are no rigid connections and thus no interaction can occur that can affect an accident sequence. The building systems and equipment have little interface with existing plant systems. Connections are made to the demineralized water (YM), breathing air (VB), hot and cold water (YD), contaminated liquid (WL) and sanitary sewage (WT) systems. Portions of the WL systems are nuclear safety related, but not those portions affected by the equipment staging building. The other systems are not nuclear safety related, and the building and systems have no afzect on or interaction with ECCS (Emergency Core Cooling Systems), thus no accident sequences are affected. Utilization of the ventilation system and exhaust point do not affect plant operation. Any releases from this point are as a result of work within the building. The equipment staging building does not contain any safety related equipment and is not involved in accident mitigation in any way. Building use or status is totally independent of plant status, and therefore cannot affect the probability or consequences of an accident. The proposed change to incorporate the radiation monitor to the Technical l Specifications is a more restrictive situation than now exists. As previously l discussed, utilization of the building / operation of the building exhaust does

/ Peg 2 3 not affect any accident sequence. The presence of the filter and monitor serve to first reduce then quantify any releases from the building. The changes to the Technical Specifications add requirements on monitor operability to ensure any releases are controlled and monitored. Again, any releases via this pathway are due to work within the building and this is not a post accident potential release pathway. Thus the probability or consequences of an accident are unaffected by placing Technical Specification requirements on the filter and monitor. (2) The proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. The building is a physically independent structure that does not directly interact with any safety related systems, structures, or components as to create any new accident scenarios as the equipment staging building does not affect and is not affected by unit operation. As discussed earlier, the only equipment staging building system interface of potential significance is that of the liquid waste recycle (WL) system. Liquid waste generated within the equipment staging building will be pumped from the sumps into the WL system, and ultimately to the liquid waste monito,r and disposal (WM) system. The systems involved do not affect reactor operation and thus cannot create any new accident scenarios. The proposed change to the Technical Specifications are to allow operation of the equipment staging building ventilation system as a release point for potentially contaminated air. Potential releases have been evaluated and found to be small. Estimates of potential releases were presented in the May 4, 1987 submittal, Table 3. These projections were based upon historical data from the Hot Machine Shop at Oconee Nuclear Station (Table 1 of the submittal) and historical data from McGuire Nuclear Station (Table 2). The work that may generate airborne contaminants for release would be performed elsewhere in the station (with the airborne contaminants being generated there) if the equipment staging building was not available, thus the building will not result in any new releases. The ventilation system and release point are, as the rest of the building, independent of and does not affect unit operation, thus no new accident sequences can be created. The proposed change to incorporate the monitor cannot create any accident scenarios. The monitor simply quantifies any release and does not interact with any other systems. The changes merely place Technical Specification requirements on the monitor to assure that all releases are monitored and accurately quantified as is presently required for the contaminated parts warehouse and the radwaste facility. The changes are more restrictive than the existing specifications (there are none specifically on this system) and thus cannot create any accident scenarios. (3) The proposed amendment would not involve a significant reduction in a margin of safety. The building and its associated systems and components do not interface or interfere with any safety systems. The ECCS are unaffected by this change as are all systems necessary to normally operate and shut down the units, thus safety margins are unaffected.

Paga 4 Further, the proposed new release point will not affect the quantity of effluents released. 11e tasks that are planned for the equipment staging building will be performed elsewhere in the station, if necessary. Any airborne contamination will be the result of work, such as grinding, performed on contaminated materials, such that a given job will generate a given amount of airborne contamination, if it is performed in the equipment staging building or the auxiliary building. Since both the equipment staging building and the auxiliary building ventilation systems are filtered systems, effluent releases would not differ significantly, thus margins for releases to unrestricted areas and thus offsite doses are not significantly.affected. The addition of Technical Specifications for the monitor do not degrade safety margins; in fact, imposing operability requirements on the monitors will ensure that margins for offsite doses are satisfied as any releases are continuously monitored and quantified. Based upon the preceding analyses, Duke Power concludes that the proposed amendment does not involve any significant hazard considerations as defined by 10CFR50.92. l 9 e i

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Environmental Assessment Identification of Proposed Action: The change to the Technical Specifications j would identify a new gaseous effluent release point for McGuire Nuclear Station. The new release point is the exhaust of the equipment staging building ventilation system. The need for the Proposed Action: The proposed change to the Technical Specifications is required to allow work in the Equipment Staging Building which may generate airborne contamination. Activities planned for the building are detailed in Duke's submittal to NRC dated May 4, 1987 and include reactor vessel head stud cleaning, valve maintenance and repair, and equipment decontamination. Additionally, during this year's outages (1987), containment piping from the upper head injection system is being removed. Once removed, the piping must be cut into smaller pieces for shipment. The change would allow the tasks to be performed in the Equipment Staging Building as opposed to elsewhere within the station. If the tasks were required to be performed elsewhere in the station, it would require transport of the materials to a suitable location within the station, or in the case of UHI piping deletion (i.e. cutting up the pipe for shipping), conducting the work in place, i.e., in containment, would be required. i Environmental Impacts of the Proposed Action: The proposed change to the Technical Specifications would allow a new gaseous effluent release point at McGuire. The new release point will not result in a net increase in station radioactive effluent releases. The work planned in the equipment staging building is necessary and will either be deferred pending approval of the change or performed elsewhere in the station. Ultimately, each job will generate a given amount of airborne contamination within the station to be exhausted. As discussed in Duke's May 4 submittal, the Equipment Staging Building Ventilation System exhaust is filtered through a pre-filter and a HEPA (High Efficiency Particulate Absolute) filter to remove particulate prior to release. Based upon expected effluents as described in the May 4 submittal, actual radioactive releases are expected to be negligible. Projected releases are detailed in Table 3_9 the May 4,1987 equipment stgging f building submittal and range from 2.00x 10 C1/yr for Co-57 to 3.00 x 10 Ci/yr for Co-58 Co-60, and Cs-137. This compares with McGuire historical data of 15 1.06 x 10 Ci/yr fog Co-57 (equipment staging building ageounts for 1.89% of release),1.0}x10 C1/yr for Co-58 (0.28%), 4.87 x 10 C1/yr for Co-60 (0.62%), and 5.2 x 10 Ci/yr for Cs-137 (0.58%). Therefore, the proposed change will have no measurable net environmental impact. Alternative to the Proposed Action: Because it is concluded that there is no measurable net environmental impact associated with the proposed change, any alternative to this change will have either no environmental impact or greater environmental impact. The principal alternative would be to deny the requested changes. As the various tasks planned in the equipment staging building will be performed elsewhere in the station if necessary, the total environmental impact

.Pags 2 of the~two alternatives will not differ significantly. However, denial of the proposed change may cause the work to. be performed in an area with higher ambient. radiation and cause the time to perform a given job to increase (due to obstructions in the work area), and hence cause an increase in occupational dose. In addition, extending the time necessary to perform a given job, such as any work on a reactor coolant pump, may cause an outage to be extended. Alternative Use of Resources: This action does not involve the use of resources not previously considered in connection with the " Final Environmental Statement related to the operation of McGuire Nuclear Station," dated April 1976. Finding of No Significant Impact: Based upon the foregoing environmental i assessment, Duke concludes that the proposed action will not have a significant effect on the quality of the human environment. Y e

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