ML20065Q536
| ML20065Q536 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Brunswick |
| Issue date: | 06/02/1978 |
| From: | Jay Collins Office of Nuclear Reactor Regulation |
| To: | Lear G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20064E577 | List: |
| References | |
| FOIA-82-389 NUDOCS 8210280024 | |
| Download: ML20065Q536 (2) | |
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UN4 TED STATES 8
NUCLEAR HEGULATORY COh.SEION
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June 2, 1978 Docket !!os. 50-324/325 MEMORANDUM FOR:
G. Lear $ Chief, Operating Reactors Branch #3, DOR FROM:
J. T. Collins, Chief Effluent Treatment Systems Branch, D5E
SUBJECT:
INFORMATION FRON BRUNSWICK FOR APPEi: DIX I EVALUATION We have reviewed the letter from E. E. Utley, Carolina Power and Light-Company (CPL), dated May 18, 1978, concerning the operation of the aug-mented offgas (A0G) system at Brunswick (BSEP), Unit Nos. I and 2, and their proposed plans for correcting the problems encountered with the operation of this system. He find the response from CPL to be unacceptable.
In conformance with Section V of Appendix I, CPL submitted on July 12, 1976, information necessary for the staff to evaluate the means employed for keeping levels of radioactivity in effluents ALARA and within the dose design objectives.of Appendix I.
In this submittal, CPL committed to the operation of the augmented offgas system (cryogenic). On page 3 of the
-subject letter, CPL states, in part, that actual doses due to releases
' from BSEP have been within the numerical limits of 10 CFR Part 50, Appendix I (without the operation of the A0G) and that CPL remains committed to meeting the numerical guidelines of 10 CFR Part 50, Appendix I, Sections II.A, B, C and D.
The fact that CPL has been able to keep releases, at the present time, below the design objectives of Appendix I without the operation of the A0G, is by no means satisfactory proof to show that BSEP has the capability to keep releases within the requirements of Appendix I over the 30 year operating life of the plant.
Using the cal-culational models and parameters contained in t!UREG-0016 and Regulatory Guides 1.111 and 1.109, we have made a preliminary evaluation which shows that BSEP does not have the capability of meeting the dose design objectives of Appendix I without the-operation of the A0G. Based on this preliminary evaluation, we show that the gamma and beta air doses at the site boundary due to noble gases are greater than a factor of 2 over the dose design objectives and that the doses to the nearest receptor are a factor of 6 for the total body and a factor of 5 to the skin over the dose design objectives.
In addition, we calculate that the dose to any organ (infant thyroid) from all pathways due to radiciodine and particulates, is a factor of 20 higher than the dose design objectives of Appendix I.
In all cases, we find these doses to be unacceptable. Based on this preliminary evaluation, it is our conclusion that BSEP does not conform to the require-ments of Appendix I, nor do they have radwaste treatment equipment to meet the ALARA requirements of 10 CFR Part 50.34a.
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June 2, 1978 In addition, we find the schedule proposed by CPL for designing and installing a new A0G to be unacceptable. We are prepared to accept a two year period to design and install a system to satisfy the requirements of Appendix I following a firm commitment from CPL to install such a system, however, five years is unacceptable.
In the interim period we recommend that the effluent Technical Specifications for BSEP, Unit 1.os. I and 2, be amended to provide reasun;cle assurance that releases in effluents are maintained within the dose design objectives of Appendix I without the use of the A0G.
We also reconcend that CPL provide the comlission periodic progress reports (perhaps quarterly) indicating progress in designing and installing a new A0G. This report should also indicate releases during the previous quarter and how they compare to -
the dose design objectives of Appendix I.
i We are prepared to meet with you to discuss'our concerns in more detail at your earliest convenience.
dRIGIrdLSIG!ED BY J. T. COLLINS i
John T. Collins, Chief Effluent Treatment Systems Branch i
Division of Site Safety and Environmental Analysis cc:
H. Denton R. Vollmer W. Kreger F. Congel W. Burke J. Boegli J. Hannon B. Grimes
.P. Wagner G. Knighton t
Distribution:
I NRC Docket File 50-324 I
50-325 DSE Reading File ETSB Reading File ETSB Docket File 50-324/325 i
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