ML20147B939

Forwards Response to NRC 871117 Questions Re Util 870612 Application for Amends to Licenses NPF-35 & NPF-52,revising Tech Spec Tables 3.3-12,4.3-8 & 4.11-1 to Clarify Radioactive Liquid Effluent Monitoring Requirements

ML20147B939
Person / Time
Site:	Catawba
Issue date:	01/08/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-65591, TAC-65592, NUDOCS 8801190032
Download: ML20147B939 (9)

Text

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I DUKE POWER GOMPJLNY -

P.O. BOX 33180 CHARLOTTE, N.C. 98949 HAL B. TUCKER TE LEP9 EON.S vxa essessewt (704) 073-4631 sectram recauction January 8, 1988 U. S. Nuclear Regulatory Commission Attention: . Document Control Desk Washington, D. C. 20555

Subject:

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

Dear Sir:

On June 12, 1987 Duke Power Company submitted a Technical Specification amendment request that would clarify the radioactive liquid effluent monitoring requirements of Tables 3.3-12, 4.3-8 and 4.11-1. This request was supplemented on July 9, 1987. On Navember 17, 1987 the Staff requested additional information concerning the proposed changes. By letter dated December 17, 1987, Duke advised the Staff that a response would be provided by January 22, 1988. Since that letter, preparation of responses to the two questions was accelerated and are provided as an attachr.ient to this letter.

As noted in the June 12 and July 9, 1987 submittals, the Technical Specification changes were requestrd for clarification and consistency and were not required in order to allow low levels of radioactivity to be discharged through the Conventional Wastewater Treatment (WC) System from the Turbine Building sump since Technical Specification 3/4.11.1, Table 4.11-1 already identifies the WC

-System as a radioactive release point. The attached responses support our previous conclusion that releases can be made from the Turbine Building sump in accordance with the Technical Specifications and will not result in unacceptable concentrations of radioactive effluents released offsite.

Very truly yours, aA- k k _

Hal B. Tucker RWO/1213/sbn il gfh 3 0 P

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F U. S. Nuclocr Regulatory Commission January 8, 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. Hcyward 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 Dottic Sherman, ANI Library The Exchange, Suite 245 270 Fannington 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 l

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Catawba Nuclear Station Response to NRC Letter of November 17, 1987 By letter dated November 17, 1987, NRC Staff requested Duke to:

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1(1) Specify how the releases from the turbine and auxiliary building sumps are to be made and to provide an analysis showing that the present Technical Specification LLD value is adequate; and (2) Add the Conventional Waste Water (WC) System as a secondary effluent release point when calculating dose to show compliance with Technical Specification 3/4.11.1.2.

(1) The attached flow schematics illustrate the flow path and how the releases from the turbine and auxiliary building sumps will be made during normal operation and during or after any primary to secondary leaks.

Figure 1 Catawba Nuclear Station Liquid Radwaste (WL) System includes the flow path for both the Low pressure Service Water (RL) and the WC systems.

As identified in Technical Specification 3/4.11.1, Table 4.11-1, liquid releases consist of two types: 1) Batch Waste Release for normal contaminated liquid waste discharged by the liquid effluent monitor EMF-49 (RL System); and 2) continuous releases for potentially contaminated sources (such as Turbine Building Sumps, etc...) discharged by liquid effluent monitor EMF-31 (WC System).

Figure 2 illustrates the flow path alignment for normal operation. During the normal operation, all the releases through these two paths will meet 10 CFR part 20 Appendix B limits, 10 CFR Part 50 limits and limits specified in the Station Technical Specifications, such as LLD requirements, sampling and surveillance requirements. During primary to secondary leaks, the turbine building sumps can become contaminated with very low levels of radioactivity. 'f the activity exceeds normal detectable. levels, Duke plans to provide portable equipment to treat the water. The treated waste water will be discharged into the RL System. Figure 3 illustrates the flow path alignment for primary to secondary leaks and indicates various sampling and monitoring locations. The radioactive release rates will meet 10 CFR part 20 Appendix B limits, 10 CFR part 50 and the limits imposed by the Technical Specifications.

The flow pathway in Figure 3 incorporates composite sampler and flow instrumentation which is not specifically addressed in the current Technical Specifications. It also involves the use of radiation monitor EMF-31 (either Unit 1 or Unit 2) for direct control of processed waste liquid discharge. The purpose for this amendment of Technical Specification Tables 3.3-12, 4.3-8 and 4.11-1 is to add operability and surveillance requirements specifically for the mode of operation shown in Figure 3. The mnendment provides requirements for the radioactive liquid effluent monitoring instrumentation for the Turbine Building sump and provides radioactive liquid waste sampling and analysis program requirements for the Turbine Building sump demineralizer skid and radiation monitor EMF-31.

Duke agreed that the LLD must be well below the allowable average concentration. The present LLD value in the Technical Specification and Duke's Offsite Dose Calculation Methodology were already approved by the NRC

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- r Staff. A LLD different from present Technical Specification requirements is not

-necessary. It should be noted that'the flow path in Figure 3 provides a sample

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and control point separate from the~ dilution effects of other WC' System sources, and therefore will provide a more sensitive' detection point than the presently-approved WC System _ effluent nonitoring point.

(2) Duke has already implemented the WC System as a second release point for radioactive liquids. The dose contribution from this release path is already taken into account in offsite dose calculations. Attachment pages 1 and 2 illustrate the liquid release rate calculation methodology from:the ODCM. For e:: ample, we administratively allocate 90% (0.9) of annual dose for the WL System and 10% (0.1) for the WC System liquid releases. ' Duke will provide an administrative control to adjust the release from each path Lto the need of station operations.

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ATTACHMENT, PAGE 1 C2.0 RELEASE RATE CALCULATION Generic release rate calculations are presented in Section 1.0; these calcula-'

tions will be used to calculate release rates for Catawba Nuclear Station.

C2.1. LIQUID RELEASE RATE CALCULATIONS There are two potential release points at Catawba. They are as follows:

1. Liquid Waste Effluent Discharge Line (WL)

2. Conventional Waste Water Treatment System Effluent Line (WC)

C2.1.1 Liquid Waste Effluent Discharge Line (WL)

There are three low pressure service water pumps with a minimum flow rate of 16,500 gpm each and four nuclear service water pumps with a minimum flow rate of 9,000 gpm each which provide the required dilution water needed for a release. The LPSW system flow rate monitor has a variable setpoint which term-inates the release by closing the isolation valve (1 b1124) should the dilution flow fall below the setpoint. The following is a typical equation which can be used to calculate a discharge flow, in gpm.

n f$FRL [ 0.9 J + [ o I _ fi j

( where:

i=1 MPC g f = the undiluted effluent flow, in gpm.

F = ctual low pressure service water flowrate, in gpm.

RL o = the recirculation factor at equilibrim (dimensionless),1.027.

1 0 cfr = 1.027 o=1+9-R = 1 + 4400 cfs 9H where:

QR = average dilution flow (120 cfs)

QH = average flow past Wylie Dam (4400 cfs)

Cg = the concentration of radionuclide, i, in undiluted effluent as determined by laboratory analyses, in pCi/ml.

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= the concentration of radionuclide, i, from 10CFR20, Appendix B, Table II, Column 2. If radionuclide, i, is a dissolved noble gas, the MPC. = 2.0E-04 pCi/ml.

1 0.9 = factor used to reduce the WL flowrate (f) to allow the WC system to t

simultaneously make 10% of the stations re),:ases.

C-4 Rev. 19 1/1/88

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ATTACHMENT, PAGE 2 4 C2.1.2 Conventional Waste Water Treatment System Effluent Line (WC)

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The conventional waste water treatment system effluent is potentially radio-active; that is, it is possible the effluent will contain measurable activity above background. It is assumed that no activity is present in the effluent until indicated by periodic analysis of the composite sample collected on that line. The water sources listed below that -are normally discharged via the conventional waste water treatment system and/or the Turbine Building Sump will be diverted if they will cause the WC discharge to exceed administrative limits designed to ensure that station release limits will not be exceeded.

a. Containment Ventilation Unit Condensate Effluent Line The containment ventilation unit condensate effluent line could potentially discharge into the Turbine Building sump, but if activity is detected above its monitor's setpoint, the discharge will be terminated and an alarm actuated. The containment ventilation unit condensate tank will then be pumped to the RHT or WMT, recirculated, sampled, processed thru the WL system if necessary, and then discharged through the liquid waste ,

effluent line and monitored.

b. Auxiliary Feedwater Sump Pumps and Floor Drain Sump Pump Line Normally the discharge line coming from these sumps will discharge into the Turbine Building sump, but if activity is detected above its monitor's setpoint, the discharge flow will automatically be routed to the C floor drain tank for processing and later be discharged through the liquid waste effluent line. Subsequent radioactive releases may be allowed to discharge into the TBS if administrative 1y cont. rolled to assure that .

release limits are not exceeded.

c. Steam Generator Blowdown Line Normally the discharge from the Steam Generator Blowdown will be pumped to the Turbine Building Sump, but if activity is detected above its monitor's setpoint, each blowdown flow control valve, the atmospheric vent, and the valve to the Turbine Building Sump will close, thus terminating the discharge. Blowdown can only be continued by venting the steam to "D" neater and pumping the liquid to the condensate system.

d. Turbine Building Sump Discharge Line Normally the discharge from the Turbine Building sump will go into the conventional waste water treatment system, but if activity is detected above its monitor's setpoint, the sump pumos A, B, and C will stop and an alarm actuated. The Turbine Building sump discharge line can then either '

be routed to the floor drain tank for processing, routed directly to the liquid waste effluent discharge line, or allowed to continue being dis-charged via the circuit with proper administrative controls implemented to assure that release limits are not exceeded.

t C-5 Rev. 19 1/1/88

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