ML20065Q540
| ML20065Q540 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Brunswick |
| Issue date: | 09/06/1978 |
| From: | Jay Collins Office of Nuclear Reactor Regulation |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20064E577 | List: |
| References | |
| FOIA-82-389 NUDOCS 8210280027 | |
| Download: ML20065Q540 (3) | |
Text
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i SEP 0 C 1978 NEHOP.AUDUM FOR:
T. Ippolito, Chief Operating Reactors Branch Nc. 3, DDR J. T. Collins, Chief FROM:
Effluent Treatment Syste::n P. ranch, DSE St'3 JECT:
CO.'5!iTS On lea su. s0 CM0LIG, F0;!ER & LIGHT COMPAO' In response to your request, I h$e reviewed the draft letter to Carolina Power & Light Company (CP&L) conccrr.ing the A0G system for Brunswick and my cc.nents are noted balou.
In addition, we have reviewed the codel Technical Specification enclosed with the draft letter and our comments are attached.
Your letter requests CP&L to provide a comittent to complete feasibility studies and select a design to modify the A0G system by April 1,1979, and a comitr.ent to submit a schedule by July 1,1979, for implementing an operable A03 system at Brunswick.
It is ay understanding that these dates vere agreed to at a meeting uith CP&L on July 27, 1978, which I did not attend.
I find both of these dates to be unacceptable and, therefore, I do not concur in the proposed letter.
It is my understanding that CP&L is studying the varicus types of recoabiners (thermal vs catalytic) and, based on the findings of this study, will decide which way to go.
It is not appcrent to rx. uhy such a study will require 9 conths to complete.
In r(v opinion, this is a delay tatic on the part of CP&L. To qy knowledge there are no thermal reconbir,ers presently being used on offgas systems.'in coamercial nuclear power plants.
Should CP&L decide to select this type of recombiner, we vill require a detail topical report which describes the design, operation, and performance of this recombiner before we would accept such a system for use in Bruhswick. Our review of such a system could take anywhere from six conths to a year. This could further delay the installation and opera-tion of an A0G sysica at Brunswick.
I would also like to point out that Appendix I to 10 CFR Part 50 specifically states, "radwaste systems shall include all items of reasonably deoonstrated technology," not new and un-proven systems.
I do not consider thermal recocbiners for use in BliR offgas systems to satisfy the criteria " reasonably deaanstrated technology".
ORIGINAL SIGNED BY
' JOHN T. COLLINS.
DISTRIBUTION:
EISB Reading File John T. Collins, Chief ETSB Docket File 50-324/325 Effluent Treatment Systems Branch JICollins Division of Site Safety and 8210280027 820917
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EN 82-389 PDR h.DSE:SA:ETSBobs:do
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Enclosure:
ETSB Combnts
cc:
R. DeYoung R. Vollmer G. Knighton k'. Burke e
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ETSB COMMENTS ON MODEL TECH SPFC5 FOR BRUNSWICK 1)
Table 2.5.2-1 needs another group for Unidentified Noble Gases.
2)
By requiring noble gas nuclides in this list to be measured, aren't you overlooking the impact from nuclides with half-lives less than 8 days (the iodines and particulates) due to operation without the-A0G? The computer run indicated that I-133 was major at Brunswick without the A0G, but is not limited by the present license, nor this change.
3)
Specification 2.5.2.c.(1) should have "and" rather than "or" between the equations.
4)
Specification 2.5.2.f should have "and" rather'than "or" between the equations.
5)
Specification 2.5.2.h should be required eyen when the A0G is not operating.
Since the temperature is not known (inoperable), the H 2 monitors (both) must be operating and the valves downstream of the recombiner closed if either monitor detects greater than 4% H I"
2 the offgas line downstream of the recombiners.
We will permit one monitor to be inoperable for a period not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, provided grab samples are analyzed every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, then valve closure shall be required (reactor shutdown).
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