ML20125B319

Forwards 760427 Ltr Pertaining to Insp Rept 50-263/76-05 & Request That Licensee Provide Info Re Meteorological Data Per TS 6.7.A.2.h(2)

ML20125B319
Person / Time
Site:	Monticello
Issue date:	05/25/1976
From:	Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20125B294	List: IR 05000263/1976005 ML20125B292 ML20125B319 ML20125B346
References
NUDOCS 9212090307
Download: ML20125B319 (1)

See also: IR 05000263/1976005

Text

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UNITED STATES

NUCLEAR REGUL ATORY COMMISSION

f REolONlli

199 Roo&EVELT RO AD

OLEN ELLYN, ILLINot$ 60137

May 25, 3976

L. B. Higginbotham, Chief, Safety and Environmental Programs Branch

Office of Inspection and Enforcement, lleadquarters

NORTHERN STATES POWER COMPANY (MONTICELLO)

DOCKET NO. 50-263

(AITS NO. F30178110)

Attached is a copy of a letter dated April 27, 1976, from L. O. Mayer,

Manager of Nuclear Support Services, Northern States Power Company,

pertaining to the IE Inspection Report No. 050-263/76-05. Two points

on the meteorological program and elevated radioiodine levels raised

in the NSP letter in response to our inspection report were brought

to your attention in a acparate memo dated April 28, 1976, for

action (AITS F30178HO, revised completion date 6-10-76). Our memo

was sent to you prior to our receipt of the NSP letter. We would

appreciate receiving a prompt response to this AITS item so we can

prepare a followup response with the IE position to the items

addressed in the NSP letter. In accordance with the above, please

provide an interpretation of Technical Specification 6.7.A.2.h(2) when ,

the concentration levels in various environmental media indicate the

likelihood of public intakes in excess of 1% of those that could

result from continuous exposure to the concentration values listed

in Appendix B, Ta~leo II, Part 20.

We alsn understand that interim Technical Specifications on Section-

2.4 Radioactive Ef fluents and Section 4.8 Radiologici i Environmental

Monitoring Program are being prepared. Our commente on the proposed

T/S change request of October 15, 1975, and March 1, 1976, were

also sent to you on April 28, 1976. We believe it is necessary to

include a T/S change in the plant reporting requirements to clarify

the intent of Technical Specification 6.7.A.2.h(2).

Plcase provide guidance on how we can obtain information such as

meteorological data from the licensee in accordance with Regulatory

Guides 121 and 4.8 when such data are not renuired in the Technical

Specifications.

N

(  : CM GM )

w y-b James M. Allan, Chief

9212090307 760601 Fuel Facility and Materials

PDR ADOCK 05000263 i

G PDR Safety Branch

Attachment:

As stated

cc w/ attachment:

L. Cohen, IE:HQ

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April 27, 1976

Mr James M Allan, Chief

Fuel Facility and Materials Safety Branch

Office of Inspection & Enforcement, Region III

U S Nuclear Regulator'y Commission *

799 Roosevelt Road

G1en Ellyn, IL 60137

Dear Mr Allan:

MONTICELLO NUCLEAR GENERATING pud 1T

Docke t No. 50-263 License No. DPR-22

Your letter dated April 8,19/6, which was roccived on April 9,1976, transmitted

IE Inspection Report No. 050-263/76-05. 'The Inspection Report states at two

points that certain items of discussion will be referred to the Office of Nuclear

Reactor Regulation and will be ny amined at subsequent inspections. *1his letter is

written to provide clarificati nr the record of the NSp position on those.

matters and several other topic- iscussed with the NRC personnci during their

inspection. Our con:nents will reference the Inspection Report by page number and

paragraph designation.

Panc 2, paranraph A and pane 12, paronraph h

'

NSP took the position that there are no regulatory requirements or Technical

Specifications covering the Monticello plant which require the submission of

meteorological data. We further pointed out that the NRC Regulatory Guides are

not requirements. The discuccion that ensued from that point on uas with respect

to the recommandations contained in Regulatory Guides 4.8 and ' .21 for inclusion

with the semiannual effluents report of meteorological data and dose computations.

We have reviewed the impact of a reporting requirement of this nature and find

that a considerabic initial investment in manpcuer, ccxuputer programs, consultant

help and equipment would be required to provide this type of data. In addition, it

would require a continuing manpcuer requirement, beyond that which we currently

have avai1M 'e, and possibly intermittent or continuous consultant help to provide

the data that the NRC proposes to be submitted each six months.

We carried the discussion further with the observation that the NRC is supplied

wi th site meteorology which is used in a conservative manner with plant effluent

infonnation t o set regulatory limits on radioactive effluents from the plant and

highly conservative design objectives. 'lhis is coupled with requirements for an

ext.cnuive Radiation Environmental Monitoring program to confirm that the limits

l and design objectives have been set at such a 1cyc1 that there are no unexpected

l cffects on the er.vironment from radioactive offinent releases from the plant. We

L

made the concluding observation that the nemlannual subminsion of meteorological

! data and dose calculations would appear to be more of a data collection ef fort

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Mr James !! Allan

Page 2

April 27,1976

than information that is needed for the assessment of safety related activitics

and that the manpuser and equipment expenditures that would be involved appear to

be unwarranted.

Several years ago NSP began work on a research project for providing transmission

of meteorological and of fluent data from NSP's fossil and nucicar plants to a

centralized computcr-oriented data collection system. A prototype " digitizing

transmitter" vas built, t ested, and installed at the !!onticello plant on the

meteorolegical tuser about nine months ago. The " digitizing transmitter" operation

has been reasonably successful for the purpose intended, but it has not been It was

suit abic for use for submittals to the NRC, such as Appendix I compliance.

also intended that a teletypewriter would be provided in the Monticello control

room to provide supplemental recording of the " digitizing transmitter" information.

It should be noted that the Monticello control room aircady has a wind direction

and velocity recorder in operation. Since the teletypcuriter system is based

,

on use of the prototype device, which might be replaced with more suitabic equip-

ment, it has been decided not to install this supplemental equipment in the

Monticello control room. Meteorological data continues to be obtained from the

,

300' tower in strip chart form and is retained in accordance with recordkceping

requirements.

Paragraph h on page 12 reference a computer printout as being availabic, but not

in use. This is information frcu the prototype " digitizing transmitter" equipment

and is not in a format or of the ;uality which could be put to beneficial use by

the nuclear plant. It should also be noted that the licensec is currently hand

reducing data from the metaorological strip charts in order to obtain a full year

,

j

of acceptabic quality meteorological data in connection with the Appendix I

compliance submittal. This infomation will update the meteorological data that

'

has been provided to the NRC in earlier submittals.

,

_ Pane 6_, paranraph 3.a

,

Since the Monticello plant does not have Appendix B Technical Specifications, the

conuncut in regard to ECAD maintaining cognizance of aquatic biota protection con-

ditions, reporting to NSS when protection conditions are exceeded, etc. , is not

,

'

applicabic to the Monticello plant at the present time.

+ The NSS Department .does not have administrative responsibility for non-radiological

sampling as mentioned in the second sub-paragraph. The !!SS responsibiliLy for a

,

reductiod and computer processing of the meteorological program results is not

routine responsibility but resulted f rom the needs for obtaining this information

on a one-time basis for the Appendix I cuepliance submi.ttal. The tiSS Department

has not initiated development of calculational procedures for donc pathway report-

ing to the NRC in line with discussion in an earlier paragraph that there are no

requirements for this at Monticello.

.

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NORTHERN GTATCO POWER COMPANY ,

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Mr Jame; M Allan

Page 3

April 27, 1976

Panc 7. parnnraph c .

We are not aware of any computerized system used by-the NSS Department for report-

ing the results of program audits and inspections to supervision and nanagement for

their review.

Panc 8, paranraph 5 ,

A revised Radiation Environmental Moultoring Program was submitted to the Ccmmission

on October 15, 1975 as a license amendment request; the program has not yet been

put into effect since the licenso amendment has not been issued by the NRC. The

March 1, 1976 submittal referenced in the inspection report involves interim

Technical Specifications on radioactive effluents; the Radiation Environmental

Monitoring Technical Specification pages that were included uith the liarch 1,1976

submittal were included only because there are changes in pagination in this section

due to the removal of radioactive effluents from Appendix A and their transfer to

Appendix E. .

Pancs 9-11, paranraph d

The inspection report correctly reficcts the increases in icvels of I-131 in milk

during the summer of 1975; hauever, it does not point out that these Icvnis have

been greatly reduced since replacement of the defective initial 7x7 fuel during

the refueling outage in October, 1975.

On the bottom of page 10 and the top of page 11, still under parsgraph d, there is

a discussion of the number of iodine sampics which should be included in the

averaging to determine if additional repprting is required on estimates of likely

exposurcs to individuals and population groups. The Technical Specification re-

quirement for supplemental reporting is based en the likelihood of intakes in .

execca of 17. of thosc that could result from continuous exposures to the concen-

tration values of Appendix B, Tabic II, Part 20. This appears to be similar to

design objective reporting. It is our position that the sampics should be

averaged over a calendar quarter and if the average concentrations of I-131 in

milk are greater than 2.4pci/1, then the supplemental information would be required.

Yours very truly,

c Y O. A "

r .

L O 11ayer, PE

Manager of Nuclear Support Services

.

LOM/ak

.

cc: Victor Stc11o

G Charnoff

HPCA - Attu: J W Pennan

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• * UNITtD $T ATES

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NUCLEAR HUGULATORY COMMISSION

nroloN 11

799 floo5tVELT flo Ao

GLEN ELLYN, ILLlHolt C0137

May 25, 1976

L. B. Iligginbotham, Chief, Safety and_ Environmental Programs Branch

Of fice of Inspection and Enforcement, !!cadquarters

NORTilERN STATES POWER COMPANY (MONTICELLO)

DOCKET NO. 50-263

(AITS NO. F30378HO)

Attached is a copy of a Ictter dated April 27, 1976, from L. O. Mayer,

Manager of Nuclear Support Services Northern States Power Company,

pertaining to the IE Inspection Report No. 050-263/76-05. Two points

- on the meteorological program and c]cvated radiciodine levels raised

in the NSP 1ctter in response to our inspection report were brought

to your attention in a separate memo dated April 28, 1976, for

action (AITS F30178HO, revised completion date 6-10-76). Our memo

was sent to you prior to our receipt of the NSP letter. We would

appreciate rocciving a prompt response to this AITS iten so we can

prepare a followup response with the IE position to the items

addressed in the NSP letter. In accordance with the above, please

provide an interpretation of Technical Specification 6.7.A.2.h(2) when

the concentration IcVels in various environmental media indicate the

likelihood of public intakes in excess of 1% of those that could

result from continuous exposure to the concent ration values listed

'in Appendix B, Table 11. Part 20.

We also understand that interi, Technical Specifications on Section

2.4 Radioactive Effluents and Section 4.8 Radiological Environmental

Monitoring Program are being prepared. Our comments on the proposed .

T/S change request of October 15, 1975, and March 1, 1976, were

also sent to you on April 28, 1976. We believe it is necessary to

include a T/S change in the plant reporting requirements to clarify

the intent of Technical Specification 6.7.A.2.h(2).

Picase. provide guidance on how we can obtain information such as

meteorological data from the licensce in accordance with Regulatory

Guides L 21 and 4.8 when such data are not required in the Technical

Specificatiqns.

NY

, QW ** h i p. t t a V

- g g -James M. Allan, Chief

( Fuel Facility and Materials

Safety Branch

Attachment:

As stated

cc w/ attachment:

L. Cohen. IE:HO .

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N O H T_ H E n .4- _GTATCS PoWtn COMPANY

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April 27,1976 -.

.

Mr Jancs M Allan, Chief

Puc1 Facility and Materials Safety L.anch

Office of Inspection.6 Enforcement, Region III

U S_ Nuclear Regulator'y Ccanission '

799 noosevcit Road

Clon Ellyn, IL 60137

Dear Mr Allan: .

MONTICELLO HUCLEAR GENERATING Pud 4T

Docket No. 50-263 License No. DPR-22

Your letter dated April .8,1976, which was rFccived on April 9,1976, transmitted

-IE Inspection Report No. 050-263/76-05. The Inspection Report states at tuo

points that certain items of. discussion will be referred to the Office of Nuclear

Reactor Regulation.and will be examined at subecquent inspections. '1his letter is -

written to provide clarification for the record of the USP position on those

matters and ccveral other topics discussed uith the NRC personnel during their

i nspec tion.- Our coments will reference the Inspection Report-by page_ number and

paragraph designation.

Pane 2, paranraph A and pano 12. paranraph h

NSP took the position that: there arc _no- regulatory requirements or Technical

. Specifications covering the Monticello plant which. require the submission of

matcorological data. - We further pointed out that the URC Regulatory Guides are -

not requirements. The discussion that ensued from. that point -on was with respect

'

to the reconmendations contained in Regulatory Guides 4.8 and -1.21 for inclusion

_ with the-semiannual effluents report 'of meteorological data and dosc computations.

- ' We have ' revicued the impact of a . reporting requirement of this = nature and - find -

that a:considerabic initini investment in manpcuer, computer programs, _ consultant

hcip and equipment would be required to provide this~ type of dhta. In addition,';it

, would ' require a continuing' manpower requirement, heyond that i hich we currently

,

have availulle, and possibly1 intermittent or continuous consultant help to provide

l the data that the NRC, proposes to be submitted each six months.

We carried - the discussion further with the observation that the NRC is supplied

-

with site meteorology which is used in a conservative manner with plant ef fluent .

information Lo set regulatory limits- on radioactivo efflucnts from the plant and

' highly conservative design objectives. '1his is c_oupled with- requirements for an

'

extensive Radiation-Environmental Monitoring Program to confirm that the limits

4-

4'

and design _ objectives have been set at such a Icyc1 that there are no unexpected

cffects on the environment from radioactive affluent relcases from the. plant. - Uc

made the concluding ohnervation. that t he semiamnial submission of meteorological.

! data nnd donc calculations would appear to be more-of n' data collection ef fort

.

.

,

...

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Jt) @ 4:o4 0 9

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NORTHERN GTATEG POWCrf COMPANY .

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ifr Jannes ti Allan

Panc 2

April 27,1976

than information that is necded for the assessment of safety related octivitics

and that the manpwer and equipment expenditures that would be involved appear to

be unwarranted.

Several years ago NSP began work on a research project for providing transmission

of matcorological and of fluent data from 11SP's for: and nucicar plants to a

centralized computer-oriented data collection system. A prototype " digitizing

transmitter" vas built, t ested, and installed at the 11onticc110 plant on the

meteorological twer about nine months ago. %c " digitizing transmitter" operation

has been reasonably successful for the purpose intended, but it has not been It was

suitabic for use for submittals to the NRC, such as Appendix I compliance.

also intended that a teletypewriter vould he provided in the Monticello control

room to provide supplemental recording of the " digitizing transmitter" information.

It should be noted that the Monticello control room circady has a wind dircetion

and velocity recorder in operation. Since the teletypcuriter system is based

on use of the prototype device, which might be replaced with more suitabic equip-

ment, it has been decided not to install this supplemental equipment in the

Monticello control room. Met corological data continues to be obtained f rcnr. the

300' tower in strip chart form and is retained in accordance with recordkeeping

r equi r eane nt s .

Paragraph h on page 12 reference a ccmputer printout as being availabic, but not

in use. This is information fro the prototype "digitining transmitter" equipment

and is not in a format or of the juality which could be put to beneficial use by

the nuclear plant. It should also be noted that the licensec is currently hand

reducing data from the meteorological strip charts in order to obtain a full year

of acceptabic quality meteorological data in connection with the Appendix I

compliance submittal. This information will update the meteorological data that

'

, has been provided to the NRC in earlier submittals. .

l _P_ age 6, paranraph 3. a ,

i Since the Monticello plant does not have Appendix D Technical Specifications, the

connent in regard to EGAD maintaining cognizance of aquatic biota protection con-

'

ditions, reporting to NSS when protection conditions are exceeded, etc., is not

applicabic to the Monticello plant at the present time,

e The NSS Department <loca not have administrative responsibility f or non-radiological

sampling as mentioned in the second sub-paragraph. The NSS responsibility for

reduc t ioti and cunputer processing of the untcorological program results is not a

.

routine renponnihility but resnited from the needs for obtaining this information

on a one-time basis for the Appendix 1 compliance submittal. The NSS Department

has not initiated development of calculational procedures for donc pathway report-

ing to the NRC in line with dircussion in an earlier paragraph that there are no

requirements for this at Monticello.

l

'

.

!

I

t

e

-_ _

.* NORTHERN OTATED POWER COM18ANY

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. . . ,

,

'

.

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,

fir James !! Atlan

Page 3 .

4

April 27.1970

Panc 7. onranraph c_* .

We are not aware of any computerized system used by the NSS Department for report-

ing the renults of program audits and inspections to supervision and manage;nent for

their review.

Panc 8, parnnraph 5

A revircd Radiation Environmental !!onitoring Program uns submitted to the Commission

<

on October 15, 1975 as a license amendment request; the program hoc not yet been

put into ef fect since the license amendment has not been issued by the !!nc. The

. March 1, 1976 submittal referenced in the inspection report involves interim

Technical Specifications on radioactive ef fluents; the nadiation F.nvironmental

Monitoring Technical Specification pages that were included with the !! arch 1,1976

cubmittal ucre included only because there are changes in pagination in this section

due to the removal of radioactive offluents from Appent _x A and their transfer to

Appendix B.

Pancs 9-11, paranraph d

'

The inspection report correctly reficcts the increases in Icvels of I-131 in milk

during the summer of 1975; however, it does not point out that these Icvels have

. been greatly reduced since replacement of the defective initial 7x7 fuel during

the refueling outage in October, 1975.

On the bottom of page 10 and the top of page 11, still under paragraph d, there is

a discussion of the number of iodine sampics which should be included in the

averaging to determine if additional reporting is required on estimates of likely

exposures to individuals and population groups. The Technical Specification re-

quirement for supplemental reporting is based on the likelihood of intahes in

excess of 17. of thosc that could result from continuous exposures to the concon-

tration values of Appendix B, Tabic II, Part 20. This appears to be similar to

design objective reporting. It is our position that the sampics should be

averaged over a calendar quarter and if the average concentrations of I-131 in

milk are greater than 2.4pci/1, then the supplementn1 information would be required.

Yours very truly,

b. & ff

'

L O Mayor, PE

Manager of Nuclear Support Scryices

.

1DM/ak

.

cc: Victor Stello

C Charnorf

MPCA - Attu: J W Ferman

.

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