ML20209C740

Confirms Commitments Made During 870303 Meeting W/Nrc in Bethesda,Md Re Radiological Liquid Effluent Matters.Dose Based Surveillance Std Appropriate for Ensuring Compliance w/10CFR50,App I Regulation.List of Commitments Encl

ML20209C740
Person / Time
Site:	Rancho Seco
Issue date:	04/20/1987
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
References
JEW-87-465, TAC-64735, NUDOCS 8704290064
Download: ML20209C740 (4)

Text

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Osuu.SACRAMENTO MUNICIPAL UTILITY DISTRICT U P. O. Box 15830, Sacramento CA 95852-1830.(916) 452 3211 AN ELECTRIC SYSTEM SERVING THL HEART OF CALIFORNIA JEW 87-465 APR 2 0 W Director of Nuclear Reactor Regulation

! Attn: Frank J. Miraglia, Jr.

l Division of PWR Licensing-B U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Miraglia:

1 The Sacramento Municipal Utility District wishes to confirm commitments made l during a meeting held in Bethesda, Maryland, on March 3, 1987, on radiological l liquid effluent mitters. Our understanding of these commitments and their status are described below.

During this meeting, we presented the initial justification for implementing a dose-based Technical Specification surveillance standard to meet the ALARA dose guidelines of 10 CfR 50, Appendix 1. We would like to reemphasize the importance we place on the stafI's accepting a dose-based surveillance standard for compliance with 10 CFR 50, Appendix ! at the Rancho Seco Nuclear Generating Station. To that end, we believe that a dose-based surveillance standard is inherently appropriate for ensuring compliance with the dose-based 10 CFR 50, Appendix ! regulation for the following reasons:

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Rancho Seco's cooling water systems and rocciving waters are highly I atypical since we are a dry site e Decause 10 CFR 50, Appendix ! is written as a dose-based regulation, the measurement objective of the surveillance Technical Specification for l assuring compliance with this regulation should be met by a system which l will determine and track the projected dose in the environment I e The dose calculated as a result of the liquid offluent released is l proportional to the activity released, which depends on volume released, the flow rate of the discharge, and activity concentration

'((3 f y O N o 0 , ,[2 p i.s 1 .

l HANCHO StCO NUCLt AH GtNtHAf tNG 8 tail 0N 14440 Twm Citme Hoad. Herald, CA 95030 0709 (209) 333 203S

frank J. Miraglia, Jr. JEW 87-465

• The practice at nuclear power plants with typical cooling water systems

• and receiving waters has been to arbitrarily set the minimum detectable '

concentration (MDC) at a very low fraction, such as ID percent, of the  ;

i concentration associated with Technical Specification dose limits. As a result, liquid volume released and flow rate of the discharge may fluctuate j widely without significantly affecting the calculated dose. The typical I approach, if applied at the atypical Rancho Seco plant, would present  !

severe operating restrictions. Specifically, the typical MDC levels would be two orders of nugnitude smaller than those found in the standard Radiological Environmental Technical Specifications (RE15) for liquid effluents. Release of potentially radioactive liquid effluent could be unduly delayed, and could result in plant shutdown due to excessive effluent inventories.

! We have provided your staff with information for the review and evaluation of

our proposed methodology. Considering the importance of resolving this i

matter, please do not hesitate to contact Mr. John Vinquist at (916) 452-3211, extension 4244, if you require additional information, i

t i Sincerely,  !

s

%g

/.

. ' ~ ' . - John E. Ward Deputy General Manager, Nuclear'*ss s '

i N i cc: G. Kalman, NRC, Bethesda A. D'Angelo, NRC, Rancho Seco 4

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COMMITMENTS MADE OURING NRC MEETING ON MARCH 3, 1987 BETHESDA, MARYLAND l Commitment Status Completion Due

. 1. Expand the scope of Proposed Initial Draft completed Submittal  ;

l Technical Specification and distributed for projected for Amendment (PA) No.155 to review and comment. May 1987 l

include the review and >

revision, as necessary of the entire Radiological Environ-l mental Technical Specifications

2. Formally submit PA 155, the PA 155 (see Item 1). Prior to Offsite Dose Calculation 00CM and REMP revisions Restart  ;

Manual (00CM) and Data Base, are under review by and the Radiological Environ- management. .

mental Monitoring Program l (REMP) Manual for NRC review l and approval

3. Provide an update to Special JEW 87-586 dated Complete Report 84-07, dated September April 15, 1987 27, 1984, to discuss the design bases of the modifica-tions to the Regenerant Holdup Tanks. Compare design i bases to our previously proposed construction of evaporation ponds

4. Resolve the LLO issue. If Additional information Prior to PA 155 target dose concept is to was provided on submittal be pursued, provide addi- March 17, 1987 tional information on this '

proposed method of demon-Starting compliance with Appendix !

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5. Submit slides from the Included in information Complete March 3,1987, presentation provided on March 17, 1987 on the target dose concept

6. Compile a more comprehensive Efforts are underway Prior to and detailed list of concerns next meeting related to radiological ing with NRC 11guld effluents; discuss the concerns and their resolutions with NRC

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Commitment Status Completion Due

7. Clearly state in the Technical Will be included in TS

Prior to Specifications and the PA 155 and next USAR restart l updated FSAR that SMUD plans update USAR: Next

! to release radioactive submittal, i

materials of primary system July,1987 j origin in the plant effluents, i under controlled conditions

such that these releases conform with 10CFR50 Appendix !

guidelines, and the limits of i

40CFR90 and 10CFR20. '

l 8. Clarify the formality of the Will be included in Prior to ,

! administrative controls on PA 155 Restart i the ODCM and REMP documents

! in Technical Specifications I

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