ML20128B463

Discusses Review of Proposed TSs for Radioactive Effluents for Plant

ML20128B463
Person / Time
Site:	Monticello
Issue date:	02/18/1969
From:	Anderson F US ATOMIC ENERGY COMMISSION (AEC)
To:	Vassallo D US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 9212030662
Download: ML20128B463 (6)

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DRL Reading l Branch Reading D. J. Skovholt i

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D. L. Ziemann (file)

F. Anderson Domenic B. Vassallo Reactor Project Branch #1 Division of Reactor Licensing TERU Dennis L. Eiemann, Chief Operating tasctor Branch f2, DEL TECHNICAL SPECIFICATIONS FOR RAD 10&CTIVE EFTLUENts (SECTION 3.6) -

NONTICELLO NUCLEAR GENERATING PLANT (UNIT NO. t)

During my regiou of the proposed teshaiset specifiestion for radio-active effluents of the subjoet nucisar plant, some inconsistencies appeared to be present between the specifications en plant stack of-fluents and 10 CFR 20 reguistions. To starify my evaluaties of the proposed specifications, I have prepared a step-by-step analysis of the subject specification and bases with the applisable section(s) of 10 CFR 20. I have discussed the following senserns with Dr. Ferrest Western, RFS, and I. 8pickler, RESTS, DRL. It is my understanding af ter discussing these concerns with 1. Spickler and V. Stelle, RFB #1, DRL, that other BWR plants since Oyster Creek Nuclear Generating Flant (Unit No.1) may have the same proposed technical specificaties for radioactive affluents.

In the following analysis, I have only addressed my comments to the plant stack effluents and the off-gas system as it may relate to normal plant operation. The related consequences resulting from minor accidents should also be reviewed in establishing appropriate specifications for radioactive affluent release limits, i.e., Limiting Conditions for Operation and Limiting Safety System Settings. -

Specification - Section 3.6 - Radioactive Effluents A.1.a. The annual average sentinuous release rate of radioactivity, except halogens and particulates with a half-life greater than 8 days, shall not exceed 0.48 Ci/sec.

Discueston ..

The above limit is based upon a time-averaging analysis of the site for a typical year of meteorological senditions. The limit value seuld result in a whole body dose of 500 area in a given sector and givea

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distance off-site which receives the highest radienstive afflueet eencontratten during a year, the gustity of the radioactive effluent misture would sessist asialy of the noble gases (Ar and Es) and activa.

tien gases and would auslude 1 131 speettiaally and prehably the rematador of the halesens (9s, I and tr).

It is my maderstanding that an analyets by DEL using a sta11er saleuta-tiemal method might result is a redustiam of the proposed limit by a facter of 2,1.s., 0.1 to 0.3 01/ses, for the sans osadittees.

N hases for the limit as derived sente be found in 10 0FR 20, testies 20.196, paragraph (b)(2) if paragraph (b)(1) has been antisfied. I eaanet find where paragraph (b)(1) has been satisfied by the app 1&oast, i.e., "a reassemble effort to minimise the radiomativity in affluents to unrestricted areas".

b limit which would be determined to satisfy the primary regulation J' for effluents, i.e.,10 CFR 20, testies 30.106, paragraph (a), would  ;

he approniastely a faster of 10 less than the proposed limit er 0.04 ~

to 0.05 C1/ses escording to BEL analysis of other sites. Asserding to the applicant, the seraal steek emissies este would be less than 0.002 C1/ses or a faster of t0 less than the unlimited release rete to satisfy 10 CFR 20, Sestica 20.106, paragraph (a).

If the applisant requests the propeeed limit for additional operettomal freedom above and beyond that provided by the primary regulation of 10 CFR 20, we might propose that ha make a reassemble effort to minimise the release equivalent to the faster gained by the ps:;:::f ' g' limit. For the quality et the radiomative affluent misture presented by the applicant, a decay period of approminately a bours La the off-gas  :-

system prior to stack release would provide a redestion faster of appreminately 10 La the mermal steek emission rate. -

A.1.b. h release rate of radiomativity, easept halogens and partion. " M.

lates with a half life greater than a days, shall not easeed 0.31 01/see for a persed in essess of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> la any seven eenseestive days. ,c?

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h h above limit is based open astnerelegiaal seeditions of 1 m/ses wind speed during equal periods of stable end unstable condittees q

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for the 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> and could result in a maximum whole body dose of 100 area off site la the 38W sector. To satisfy the requirement stated by the applicant, i.e., the limit would result in less than 100 mrom whole body dose in any seven day ported, addittomal releases from the steek durias the rematador of the seven days (148 heers) could met be allowed into the gives oestet. k applicant assumes that the quality of the radionettre effinent misture will remata the same as need for the annual average seatinuous relenos rate.

h bases for the limit as derived by the applicant does met estet ta any applisable seetism of it WR 20. b appiteant ases Seeties 20.105 paragraph (b)(3) of 10 CFR 20 as the bases for the limit but this sostion refers to permissible levels of radiation la unrestricted areas met effluent levels. Also, the intent of the referested seatica as discussed with Dr. Westorm was for intermittant operation of s u k equipment as a ray machines, limmer ascelerators and possibly high radiation level sources. h continueue escupancy term was used as describing an area such as a hallway, a sidewalk er an area naar the equipment in use which might be esempted by usunomitered individuals and was met construed to indicate residency or individuals living to permanent quarters off= site. brefore, the use of this section of 10 CFR 20 as a bases for the proposed limit is met justified.

Although a specific regulation is met available as a bases for an upper release limit as proposed, the intent of such a specifisation appears to be reasonable and prudent. As discussed with Dr. Western, the upper release limit should result in a more restrictive yearly average level than the basic annual average emetinuous release rate.

Thus, if the preposed limit is used as a specification, additional restrictions se release levels fe11oving the use of this limit must

, be incorporated into the specification se that the dose level of

$00 mres/ year would met be esseeded in the oester into whiek the release is made. For esemple, as the applisant has determined, the sector affected by the release would resolve 20 percent of its permissible annual dose in to hours. k annual averego eastimoems release rate would therefore be reduced to 80 persant of the applicable spesifica.

tien for the remainder of the year provided such a reduetten was adequate to meet the permissible amamal does level. If releases de occur whiah aneced the sammal average esattamens release rate, such '

release rates, period of time and soster(s) affected should be re.

Ported to DRL and Compliance, for the resord.

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A.1.s. he release rate of radioastivity, omsort halogens and particu.

lates with a half life greater than 8 days, shall not aseeed 1.1 ci/ses for a period La eneses of 15 minutes La any one hour.

181' Hiltt he above limit was detessiaod by the appliaast in tie same way as apostricatten A.1.b. disemesed proviemely. h bases for this limit is 10 CFR 20, seeties 20.195, paragraph (b)(1) and La met applisable as previously disenesad. he above release rate with the limited release time would saly peoult in a 2 area whole body dose for the given oester. therefore, the restriotians required en the ese of the above spesiftsatsen would be en the ammber of times per year that eueh a relaaea rate seuld be used, the 11eenoes should hoop a resord of the times such a release rate le need te deterstne if any given sector wee betag subjected to such releasse more than several times a year.

he bases for the above limit may be aseestated with the aanmal average seatinuous release rate staea the limited estease time se sentrolled by the required delay time to detest the level and elese the off-gae Leetaties valves. stase the sategrated dose sesosisted with euch a release to one11 la semparison to the permissible amenal dose and possible detection uncertainties, a limiting value of twice the samuel average seatinuevo release rate should be adeguate for monitoring purpeees.

A.2. he release of radioactive affluente shall be continuously monitored for gross estivity. If this specificatt6a sammet be met, the reacter shall be placed La the feelated somdition.

, D$essesiva he above spesification dose met Ladisate the type of activity that will be semitered. The maattering Lastrument appears to be a gamme i sciattilaties detester. b refore, rather than grose activity, the speciftsatten should read groes samme estivity to obow that beta will not be detested and auch dioeriminattaa to met, available La the monstertag setup. the quostism rateed by this eyesiftsatten to whether er met the propeeed monstertag unit will be sapable of deter.

mining a differense in the gestity of the radioactive affluente er saly the geestity of grees.samme afflusste.

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A.3. he annual average continuous release rate of radioactive halogens and particulatas with a half-life greater than 8 days shall not exaeed 3.3 p C1/sec. Malegens and particulates released free the stack shall be collected for monitoring by 1

the en-line sample canister.

Discusstec goveral quostiens arise for the abeve specification eines the halogen release rate limit is sigtificantly lose than the noble gas release 1 rate limit. sines the present instrumentation does met appear sapable of determining quality of the redisestive sfilmeat, a abasse sa the ratto between the noble gas iractien and the halogen fraetien present1y assumed by the applisant (104 1-131) would not be observed until the weekly chareest sampler was removed. Is there any asens available to gamma osan the sanister in place to detemine the rate of build up of activity on the charcoal daily or sostituously? Will there be technical speciftsations en the chareoal sempler, air flow, and associated equipment to provide se escurate analysis of the kategen release rate per weekt the abeve limit dess met appear to be la appropriate units for comparison with the r9nitoring arrangement.

The only measured release rate for halogens from the stack will be in terme of possible gross halogen activity per week for a small l fraction of the total air volume exhausted. It would appear that j many extrapolations and assumptions must be used to detemine if the above specification is being met.

l The previous discussion concerning Specification A.1.a. in respect to the appropriate section of 10 CFR 20 applisable to such effluent limite appears to be pertinent to the halogen manual average continuous release rate. Apparently a total yearly release of 100 C1 of I-131 with the associated halogen radioisotopes in propertionate ratie results in approximately the permissible yearly dose. 31oco this release quantity is small in semparisse with the release quantity of noble gases, the licenses should have a more sensitive detection method than a weekly semple prior to off-gas release to the stask.

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. 6-If a gamma scan could be made of the canister as previously discussed, a calibration of acceptable build-up rate on the charcoal could be made that was sensitive to changes in off gas quality of radioactive affluents.

F. D. Anderson Operating Reactor Branch f2 Division of Assetor Licensing cc F. Howe, ERSTB, DE D. E ller, RF3 #1, DEL orFICE > ... . . .b . . DE

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