ML20235L397

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Forwards Rev to Discussion of Justification & Safety Analysis to Clarify 870612 Amend to Licenses NPF-35 & NPF-52 Re Radioactive Liquid Effluent Monitoring
ML20235L397
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 07/09/1987
From: Tucker H
DUKE POWER CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-65591, TAC-65592, NUDOCS 8707160681
Download: ML20235L397 (5)


Text

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.i-DUEE POWER GOMPAhT 18.0, HOK 33189 011AltLOTTE, N,0. e824e HALILTUCKER Tetzenown (704) 373-4s31 vm ennemmar NtMILMAE emODUCTION

,r" July 9, 1987 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.

C.

20555 Re:

Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413 and 50-414 Technical Specification Amendment Radioactive Liquid Eff.1 2ent Monitoring

Dear Sir:

This letter contains clarification to the proposed amendment to the Technical Specifications for Facility Operating License'Nos. NPF-35 and NPF-52 for Catawba Units 1 and 2 which was transmitted by letter dated June 12, 1987.

The request involves adding operability and surveillance requirements for radioactive liquid effluent monitoring-instrumentation for the Turbine Building sump and to provide radioactive liquid waste sampling and analysic program requirements i

for the Turbine Building sump demineralized. skid and radiation monitor EMF-31.

The attachment contains a revision to the discussion of the justification and safety analysis.

This request involves a supplement to our' previous amendment request to Catawba's Technical Specifications therefore, a check for $150.00 is not required.

j Pursuant to 10 CFR 50.91 (b) (1) the appropriate South Carolina State Official is being provided a copy of this amendment request.

Very truly yours, f vf Mb 7

["J/=-

Hal B. Tucker RWO/88/sbn l

Attachment.

8707160601 070709

>0 npOhi PDR ADOCK 05000413; p

PDR 11 th

U. S. Nuclear Regulatory Commission July 9, 1987 Page Two xc:

Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Heyward Shealy, Chief Bureau of Radiological Health South Carolina Department of Health &

Environmental Control 2600 Bull Street Columbia, South Carolina 29201 American Nuclear Insurers c/o Dottie Sherman, ANI Library The Exchange, Suite 245 270 Farmington Avenue Farmington, CT 06032 M&M Nuclear Consultants 1221 Avenue of the Americas New York, New York 10020 INPO Records Center Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station

I Discussion and Analysis of No Significant Hazards Consideration l

i l

The intent of this proposed amendment is to provide the option of discharging secondary and service system liquids through process and monitoring equipment to the Low Pressure Service Water (RL) System.

f The proposed amendment to Technical Specification Tables 3.3-12, 4.3-8 and 4.11-1 would add operability and surveillance requirements for radioactive liquid effluent monitoring instrumentation for the Turbine Building sump and provide radioactive liquid waste sampling and analysis program requirements for the Turbine Building Sump Demineralized Skid and radiation monitor EMF-31 during releases to the RL System.

Primary to secondary leaks can develop through reparable defects in i

the steam generator heat exchangers and into the normally i

non-radioactive turbine steam system (" secondary side") water.

Such l

leaks would be repaired as they occur, but require continued unit l

operation with leakage until the leak can be fully identified and characterized.

When these leaks occur, the Service or Turbine l

Building sumps can become radioactively contaminated.

The volume of wastewater produced during these leaks can exceed the treatment capacity of the Liquid Radioactive Waste Treatment System.

Duke Power Company plans to provide portable equipment as needed to treat the water from these potential situations.

The treated wastewater will be discharged into the RL System.

The attached flow schematic indicates the flow path.

The radioactive release rates will meet 10 CFR Part 20 Appendix B limits.

The NRC dose limit imposed by the Technical Specifications and 10 CFR Part 50 will also be met.

i A Nuclear Station Modification (NSM) is being installed which will I

provide influent and effluent flow paths for Chem-Nuclear Company I

equipment during a primary to secondary leak.

The processed water will be discharged through Radiation Monitor EMF-31 to the RL discharge piping in the Turbine Building from the Turbine Building sump.

The purpose of this modification is to allow very low levels of i

radioactivity to be discharged through the RL System from the Turbine

)

Building sump as a result of primary to secondary leaks as well as the i

Auxiliary Building drain sump when contaminated.

During a primary to secondary leak, the Turbine Building sump can be contaminated with Very low levels of radioactivity.

The quality and quantity of this j

wastewater may not be amenable to treatment in the Radwaste Treatment System (due to high volume) or by the WC System (due to the inability l

of the WC System to remove contaminants).

j 1

The decision of whether the wastewater will be routed to the Radwaste l

Treatment System, the WC System or the RL System would depend on the j

. level of activity, anticipated volumes of sump effluent, anticipated volumes of liquid waste requiring processing through radwaste, and the need to process normal nonradioactive wastes.

The Radwaste System has a process capacity of only 16,000 to 18,000 gallons per day.

Depending on the type of primary to secondary side leakage, sumps could add in excess of 72,000 gallons per day.

Technical Specification 3/4.11.1, Table 4.11-1 already identifies the WC System as a radioactive release point.

All releases through the WC System and RL System will be made in accordance with the Technical Specifications and will not result in unacceptable concentrations of radioactive effluents released offsite.

Neither will there be any increased risk to public health and safety.

It should be emphasized that the Radwaste Treatment System will remain the primary treatment system for processing highly contaminated radioactive wastes and their subsequent release.

The proposed modifications will be utilized for processing secondary side and trace-contaminated wastes such as Auxiliary Building ventilation condensate.

These waste waters will be controlled and their radioactive content reduced to within 10 CFR part 20, 10 CFR Part 50 and Technical Specification limits.

The discharge to the RL System will be monitored and discharged in compliance with all applicable radiological effluent concentrations and dose requirements stated in the stations Technical Specifications and Federal Regulations.

It will also be sampled and monitored in compliance with the NPDES permit.

10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation in accordance with the proposed amendment would not:

(1)

Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2)

Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed amendment does not involve an increase in the probability or consequences of any previously evaluated accident.

The probability of an accident is not increased because these changes involve addition of components to mitigate the consequences of previously evaluated accidents.

The offsite dose consequences resulting from primary to secondary leaks will be decreased as a result of this modification and Technical Specification amendment <

These changes will allow installation of processing equipment capable of reducing offsite doses.

This modification and Technical Specification amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated since these changes do not affect the design or operation of any Safety-Related Systems.

. These changes do not involve a significant reduction in a margin of safety since these changes do not affect the design or operation of any Safety-Related System.

For the reasons stated above, it is concluded that the propcsed amendment does not involve significant hazards consideration.

I

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