BVY 03-119, Second Response to RAI Regarding Technical Specification Proposed Change No. 262 for Incorporation of an Alternative Source Term

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Second Response to RAI Regarding Technical Specification Proposed Change No. 262 for Incorporation of an Alternative Source Term
ML040070088
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 12/30/2003
From: Thayer J
Entergy Nuclear Vermont Yankee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 03-119
Download: ML040070088 (44)
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Text

MUMMM1W Entergy Nuclear Vermont Yankee, LLC Entergy Nuclear Operations, Inc.

E n [ACer zV185 J Old Ferry Road

~~~~~~~~~~~~~~~~~Brattleboro, VT 05302-0500 December 30, 2003 BVY 03-119 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Vermont Yankce Nuclear Powver Station License No. DPR-28 (Docket No. 50-271)

Technical Specification Proposed Change No. 262 Alternative Source Term Second Response to Request for Additional Information This letter provides a response to NRC's request of December 1, 20031, for additional information (RAI) regarding Vermont Yankee's 2 (VY) license amendment request to incorporate an Alternative Source Term (AST) methodology into the Vermont Yankee Nuclear Power Station (VYNPS) licensing basis.

VY originally proposed to amend Facility Operating License DPR-28 to support the full-scope application of the AST at VYNPS by letter dated July 31, 20033. VY provided a partial response to the RAI by letter dated December 11, 20034. Thle responses provided herewith address tile remaining questions in the RAI.

Attachment I to this letter provides a response to the remaining three RAI questions (6, 8 and 9). The sensitivity evaluation information provided in response to RAI question 6 is not intended to expand the scope or change the conclusions of the analyses of the original application for license amendment. Our response to RAI No. 9 provides revised Safety Assessment Tables 2-3, 2-5, 2-6, 2-14, 3-1 and 3-4 (pages 36 - 41). These revised tables replace the aforementioned tables of the original safety assessment provided in tile letter dated July 31, 20033.

The information and changes provided herewith do not change the determination of no significant hazards consideration.

1U.S. Nuclear Regulatory Commission letter to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - Alternative Source Term Request for Additional Information (TAC No. MC0253)," NVY 03-94, December 1,2003.

2Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. are the licensees of tile Vermont Yankee Nuclear Power Station.

3Vermont Yankee letter to U.S. Nuclear Regulatory Commission, "Proposed Change No. 262, Alternative Source Term," BVY 03-70, July 31, 2003.

4 Vermont Yankee letter to U.S. Nuclear Regulatory Commission, "Proposed Change No. 262, Alternative Source Term, Response to Request for Additional Information," BVY 03-117, December 11, 2003.

A7oN

BVY03-119/Page2 If you have any questions in this regard, please contact Mr. James DeVincentis at (802) 258-4236.

Sincerely, (Jay . iTayer I LiPe Vice President STATE OF VERMONT

)ss WINDHAM COUNTY Then personally appeared before me, Jay K. Thayer, who, being duly sworn, did state that he is Site Vice President of the Vermont Yankee Nuclear Power Station, that he is duly authorized to execute and file the foregoing document, and that the statements therein are true to the best of his knowledge and belief.

Mary J. 16<~4(, Notary Public My Commission Expires February 10, 2007 Attachment cc:

-4

.:N.X *.

USNRC Region I Administrator v.- - -

USNRC Resident Inspector- VYNPS -

USNRC Project Manager - VYNPS r Vermont Department of Public Service - I-c.-. i'- -

Docket No. 50-271 BVY 03-119 Attachment I Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 262 Alternative Source Term Second Response to Request for Additional Information

BVY 03-119 / Attachment I / Page 1 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION RAI No. 6 hi the Safety Assessinent (Attachineni 5) for Jlis amendment request, on page 8 it states that an assunted post-isolation wnfiltered inleakage rate equal to tihe pre-isolation unfiltered intake rate (3700 cubic feet per minute (cfin)) into the control room is usedfor the analyses. No credit iw'as takenfor manuallyplacing the control room ventilation system into recirculationmode after t/ie accident. Control room isolation is only achieved t/hro ugh manual initiation. In effect, these assumptions imply )1o credit for control room isolation after a design basis accident (DBA).

a. Have you performed control rooan envelope inleakage testing? Ifso, w/at wtas i/ie result, and how does that compare to the assumption of 3 700 cfin of unf/itered inleakage?
b. Have you determined how the dose results of each of the postulated DBAs would be affected by assuming manual control room isolation occurs with/ a lesser imflltered inleakage rate thain currently assunied? A greaterunf1iltered inleakage rate?

Response to RAI No. 6 a.

Vermont Yankee performed tracer gas testing of the Control Room envelope in 1982 which resulted in an in-leakage volumetric flow rate of 21.5 cfm. The assumption of 3700 cfm bounds the 1982 in-leakage measuremcnt.

Response to RAI No. 6 b.

Each of the four DBA analyses (Loss of Coolant Accident (LOCA), Control Rod Drop Accident (CRDA),

Fuel Handling Accident (FHA), and Main Steam Line Break (MSLB)) has been evaluated considering this RAI.

Summary of Sensitivity Evaluation Rcsults The FHA and MSLB Control Room dose analyses currently assume an infinite unfiltered exchange rate between the Control Room and the environment. LOCA and CRDA assume a value greater than the design allows. Therefore, greater unfiltered in-leakage values do not need to be considered.

With respect to isolation, the following results (in the third column of the following table) are for Control Room isolation assumed at t = 10 minutes and de-isolation at t = 25 minutes. It is possible that isolation occurring immediately following a large release could trap activity in the Control Room. However, prolonged isolation is not expected, because for the limiting events, outside air activity concentration rapidly falls below that of the isolated Control Room (when analyzed conservatively). The Control Room 1-131 concentration (as an example) may be -2,000 to -10,000 times the Derived Air Concentration (DAC) at the time of isolation for the cases studied in this sensitivity evaluation. Fifteen minutes later, the outside air concentration would be a minimum of a factor of five less than the Control Room value.

Other conservatisms in the analyses compensate for not considering isolation in the original analyses.

Any isolation would be a temporary condition and these sensitivity analyses demonstrate that isolation is unnecessary to protect the Control Room operators under DBA conditions.

BVY 03-119 / Attachment I / Page 2 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Original Control Room Dose Control Room Dose with Event (3700 cfm continuous Control Room Isolation and Control Room Ventilation) Other Analysis Enhancements LOCA, SGTS failure 3.4 rem TEDE 4.2 rem TEDE ")

LOCA, SGTS failure 3.4 rem TEDE 1.9 rem TEDE (2)

MSLB, "puff" X/Q, 4.0 2.0 rem TEDE 2.3 rem TEDE gCi/gm coolant activity 2.r

1. Control Room ventilation modeling enhancements only
2. Control Room ventilation modeling enhancements plus bypass hold-up (36 volumes per day Reactor Building (RB) exchange with environment after loss of normal ventilation until RB pressure negative at t = 10 minutes)

Background

The design of the Vermont Yankee Control Room ventilation system does not have High Efficiency Particulate Air (HEPA) or charcoal filtration. During normal operation, the ventilation system has a fresh air intake of 3700 cfm. However, the ventilation system is designed to supply the Control Room with about 2700 cfm of fresh air (i.e., (9100/12500)x3700) and the remaining fresh air is supplied to other building locations. This configuration is depicted on the following sketch.

  • to Cabic Vault A "recirculation" ventilation mode exists where fresh air intake (FAT) is eliminated. However, placing the Heating Ventilation and Air Conditioning (HVAC) system in recirculation mode requires manual operator action that is controlled by procedure. The Control Room ventilation system is placed in recirculation mode for some conditions including high radiation.

Evaluation Mcthodology The original analyses assumed either an infinite exchange rate of air between the Control Room and the environment (in which the operators were effectively assumed to breathe outside air - FHA and MSLB) or assumed no Control Room isolation (i.e., continued supply of outside air at 3700 cfm - LOCA and CRDA). The objective was to show that no isolation of the Control Room is needed (given AST) to provide adequate protection to Control Room operators.

BVY 03-119 / Attachment I / Page 3 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION In terms of supplying air at rates greater than 3700 cfm, the FHA and MSLB already assume an infinite rate and the LOCA and CRDA assume maximum design rate. However, 3700 cfm is more than can actually be supplied.

With a Control Room volume of approximately 41,500 ft3 and an exchange rate of 3700 cfm, it would require less than 34 minutes to provide three air changes in the Control Room. Even considering the fact that 27% of this fresh air is diverted to the Cable Vault (i.e., 3400/12500 cfm of total intake plus recirculation flows) the occupied space is still purged at a rate of about 2700 cfm (i.e. (1-0.27) x 3700 cfm), providing three air changes in about 46 minutes. Therefore, should contamination levels within the Control Room become excessive because of normal ventilation during periods of high activity release (and atmospheric concentration) followed by isolation during periods of low activity release (and atmospheric concentration), the concentration of activity in the Control Room can be rapidly reduced to atmospheric levels and the original analyses have shown that such levels are acceptable. In other words, de-isolation can be implemented without a concern that the operator doses may exceed the Control Room dose limits of RG 1.183.

Presently, Control Room isolation is governed by Off-Normal Procedure ON-3153. According to this procedure, the decision to isolate is guided by (1) air samples taken in the Turbine Building being above 0.3 DAC values of IOCFR20 Appendix B, Table 1, Column 3 or (2) the existence of a "source of the abnormally high radiation levels [that] cannot be readily determined or contained ...". Both conditions call for the placement of the Control Room HVAC Recirc Mode Select switch in the "EMER" position.

However, it is also noted in ON-3 153 that "Steps [in the procedure] may be performed in any order ... " as directed by senior Operations personnel.

Certain Design Basis events (or specific variations of Design Basis events) provide the most significant challenge to Control Room habitability. These are the DBA-LOCA with failure of a Standby Gas Treatment System (SGTS) train (leading to a positive pressure period for the Reactor Building), and MSLB. These events lead to an assumed early and rapid ground level release of activity (unlike the CRDA and FHA events, for example) and these were re-evaluated in support of responding to the RAI with tile following assumptions.

Assumptions Assumption 1: The sensitivity evaluation assumed initial isolation of the Control Room would be within ten minutes (t = 10 minutes) for the DBAs listed above.

Justification: Within that time, for the DBAs listed above, it would be clear that a "source of ...

abnormally high radiation levels [that] cannot be readily determined or contained ... "

exists.

Assumption 2: If excessive activity concentration levels exist within the post-DBA Control Room, the sensitivity evaluation assumed action would be within twenty-five minutes (t = 25) minutes to de-isolate the Control Room if ambient atmospheric levels are much lower.

Justification: "Excessive" (as defined for the purposes of this assumption) is > -83 times the DAC, since such a level would result in Control Room operator doses > 5 rem TEDE within -24 hours. Since Control Room isolation, itself, is tied to Turbine Building airborne activity levels that might adversely impact tile Control Room (established at a level of 0.3 times

BVY 03-1 19 / Attachment I / Page 4 od41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION the DAC), it is reasonable to assume that a level 275 times greater within the Control Room would call for dc-isolation as long as ambient atmosphere levels were lower.

Since (1) 1-131 is the dominant dose contributor for all of the DBAs listed above, (2) the DAC for 1-131 is 2E-8 iCi/cc (or Ci/M3 ), and (3) the VY Control Room volume is approximately 41,500 ft (or 1176 in3), the activity in tile Control Room may be considered "excessive" (for the purposes of this assumption) when the 1-131 activity in the Control Room exceeds approximately 2E-3 Ci (i.e. 2E-08 x 176 x 83).

As analyzed in the original analyses, the 1-131 activity in the Control Room at ten minutes after the start of the LOCA and MSLB events is as follows:

LOCA, SGTS failure, no MSLB, conservative Event Reactor Building hold- Polestar "puff" X/Q, 4.0 up for first 10 minutes KtCi/gm coolant activity Activity 7.1 E-2 Ci 4.6E-2 Ci As can be seen, the 1-131 activity in the Control Room within 10 minutes into the event is considerably in excess of 2E-3 Ci. This is precisely the result of making analysis assumptions that skew the activity release to the beginning of the event. What this means is that the activity release will be decreasing substantially with time. This is evidenced by the following charts, based on the original analyses that show the release rate in Ci/sec as a function of time (minutes):

LOCA Average 1-131 Rate of Release, Ci/sec 1.OOE-01 8.OOE-02 6.OOE-02 4.OOE-02 2.OOE-02 O.OOE+OO rV111'11 p

BVY 03-119 / Attachment I / Page 5 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION MSLB Average 1-131 Rate of Release, Ci/sec 8.OOE-02 6.OOE-02 4.OOE-02

-77~~~~~~~~~~

2.OOE-02 O.OOE+00 0' 5P0 I(Z !C If, for each of the events, one considers the 1-131 activity concentration in the Control Room at the end of ten minutes and compares it to "outside air" concentration based on the average 1-131 release rate and the Control Room X/Q between 10 and 30 minutes after the start of the event, the following comparison may be made:

LOCA, SGTS failure, no MSLB, conservative Polestar Event Reactor Building hold-up for "puff" X/Q, 4.0 piCi/gm coolant first 10 minutes activity CR 1-131 Concentration 6.1E-05 Ci/m3 3.9E-05 Ci/m3 at 10 min (3050 x DAC) (1950 x DAC)

Outside Air 1-131 Concentration, 10 to 30 1.2E-05 Ci/m3

  • 0.OE+00 Ci/m3 min
  • Based on reactor building N-2 line bypass pathway X/Q The minimum reduction is a factor of five lower concentration for the outside air (for the LOCA) beyond ten minutes. It is on the basis of (1) decreasing activity release with time and (2) the dramatically reduced outside air concentration that one can assume that isolation of the Control Room would not continue beyond 25 minutes after the start of the event for any of the limiting events being considered.

BVY03-1l9/Attachment I /Page6of41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Design Inputs Modeling in this evaluation will make use of the original analysis STARDOSE models for DBA-LOCA with SGTS failure. No STARDOSE model existed for MSLB, so one was developed for this evaluation.

Evaluation LOCA The Control Room ventilation model has been changed to reflect the actual configuration. In normal mode, 8800 cfm is recirculated and 3700 cfm of outside air is added to tile mixing plenum. Of the total return flow of 12,500 cfm, 3400 cfm is delivered to the Cable Vault area, leaving 9100 cfm returning to the Control Room. Therefore, the 3400 cfm flow to the Cable Vault area acts like a 27.2% efficient filter for all activity (including noble gas), and this removal efficiency applies to both the 8800 cfrn recirculation flow and the 3700 cfm intake flow. The normal Control Room exhaust is 300 efin. In the emergency mode, Control Room leakage is assuimed to be 22 cfm based on testing conducted in 1982. A graphical depiction of the normal operational mode (illustrating the 27.2% effciency) is as follows:

l91o 900cfm l 12500cfm X Ci/ml It , l8800 efm @

300 cfm Y Ci/cM3 3400 cfm @ (0.272 X + 0.272 Y) Ci/m3

  • (Note 0.272 = 3400/12500)
  • to Cable Vault The assumed Control Room isolation is at t = 10 minutes and the drywell sprays are assumed to be actuated five minutes later, at t = 15 minutes. The Reactor Building drawdown will have been completed by t = 10 minutes, as well, even with the loss of one train of SGTS. Therefore, with the elimination of activity being released at ground level from the Reactor Building and with the drywell sprays operating five minutes after the establishment of the secondary containment function, one would expect a decreasing atmospheric activity concentration. Indeed, that is what has been observed (Assumption 2).

The original LOCA analysis contains the conservatism of the Control Room ventilation system simplification. In addition to that conservatism, there are several others: (1) the fact that during the 10 minute drawdown period, the Reactor Building is actually at a positive pressure for only six minutes and (2) the fact that nitrogen supply system secondary containment bypass pathway will exhibit aerosol retention characteristics similar to those of the steam lines (72% aerosol removal efficiency). However, there is another major conservatism as follows:

BVY 03-119 / Attachment I / Page 7 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION The normal Reactor Building ventilation system provides for about 1.5 volume changes per hour (36 volume changes per day) and an elevated release. If it were assumed that forced ventilation ceases immediately at the start of the accident, that the reactor building pressure immediately becomes positive, and that the reactor building leaks at ground level at a rate equal to that of the forced ventilation exchange (36 volume changes per day), the containment leakage now assumed to be instantaneously released to the environment would experience a hold-up equivalent to about 2.5E-2 volumes per minute. The containment leakage could be assumed to experience this degree of hold-up for the first 10 minutes during the time that the remaining SGTS train is drawing down the reactor building, The release is still a bypass release with no credit for filtration or the stack (as an elevated release point).

MSLB In order to study the impact of Control Room isolation for the MSLB, it was necessary to develop a STARDOSE model similar to those that already existed for the LOCA. What is unique about MSLB is the ground level "puff" release rather than a continuous release. To model a puff, the simplest approach is to create a control volume with the same volume as the puff, introduce the coolant activity into that volume, and then draw activity into the Control Room using the appropriate makeup or in-leakage rate and the appropriate transit time for the puff.

The original analysis steam puff volume is 3.64E+4 m3 (1.272E6 ft3 ). For the simple Polestar hemispherical puff passing by the intake at the puff's maximum diameter, the time is 51.7 seconds (0.0144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />) at an assumed wind speed of 1.0 m/sec (see original analysis). This yields a normalized time-integrated concentration of 51.7 sec/3.6E4 rn3 =I .44E-3 sec/M3 .

The original analysis included a calculation using the NRC model for puff release given in RG-1.194.

Tile NRC model considers a three-dimensional Gaussian distribution of the activity within the puff.

When integrated from -3a to +3a (the NRC default integration), the result (as in the original analysis) is about 1.166E-3 sec/m 3 . However, this would imply a distance from the point of the release to the Control Room air intake of about 50 m (since c, according to NRC model for a 3.6E4 m3 puff, would be about 16.6 mn). It's not likely that the distance would actually be more than about 33 mr(i.e., about 2a) which means that about 2.5% of the 3a integration is not actually appropriate. This would bring the integral down to about 1.13E-3 sec/M3 , about 22% less than the value obtained using the assumed hemispherical puff with a uniform activity distribution within (i.e. 1.44E-3 sec/M3 ). The 1.13E-3 sec/M3 was used in this evaluation after benchmarking the model using the 1.44E-3 sec/M3 value.

Sensitivity Case Results The Control Room dose results for the original LOCA, and MSLB cases, respectively, compared to the results of this sensitivity evaluation (considering both Control Room isolation and the removal of some conservatisms) are as follows:

BVY 03-1 19 / Attachment 1 / Page 8 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Event Original Control Room Dose Control Room Dose with Control (3700 cfm continuous Control Room Isolation and Other Room Ventilation) Analysis Enhancements LOCA, SGTS failure 3.4 rem TEDE 4.2 rem TEDE ('

LOCA, SGTS failure 3.4 rem TEDE 1.9 rem TEDE (2)

MSLB, "puff" X/Q, 4.0 jCi/gm 2.0 rem TEDE 2.3 rem TEDE coolant activity

1. Control Room ventilation analytical model enhancements only
2. Control Room ventilation analytical model enhancements plus bypass hold-up (36 volumes per day RB exchange with environment after loss of normal ventilation until RB pressure negative at t = 10 minutes)

Conclusions The FIIA and MSLB Control Room dose analyses currently assume an infinite unfiltered exchange rate between the Control Room and the environment. LOCA and CRDA assume a value greater than the design allows. Therefore, greater unfiltered in-leakage values do not need to be considered. It has been shown in the original analyses that an isolated Control Room is not necessary to limit Control Room operator doses to the dose limits of RG 1.183.

Two limiting events (and specific variations of those events) have been identified that involve a rapid ground level release of activity to the environment at the onset of the event. This rapid and early release at the ground level permits significant levels of activity (-2,000 to '-10,000 DAC for 1-13 1, for example) to be brought into the Control Room prior to isolation. The CRDA and FHA are not one of those events.

There was no assessment performed for the FHA since the activity released was assumed to be instantaneous at an elevated level (stack) resulting in a relatively low atmospheric concentration at the Control Room fresh air intake. This is evidenced in the calculated Control Room dose of 0.15 rem TEDE.

For the CRDA, no assessment was performed. This is because the activity release occurs uniformly (one percent condenser volume per day and 1.6 %/day for the coolant activity); and therefore, the kind of behavior exhibited by the limiting events in which a large ground level release occurs early followed by a much reduced release immediately following is not a factor.

Prolonged isolation is not expected because, for the limiting events, outside air activity concentration rapidly falls below that of the isolated Control Room (when analyzed conservatively). As noted, the Control Room 1-131 concentration (as an example) may be -2,000 to -10,000 times the DAC at the time of isolation for the cases studied in this calculation. Fifteen minutes later, the outside air concentration would be a minimum of a factor of five less than the Control Room value.

BVY 03-119 / Attachment I / Page 9 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION With respect to Control Room isolation, the justifications for Assumptions I and 2 support the conservatism of assuming isolation at t = 10 minutes and de-isolation at t = 25 minutes for the purposes of this study. The effect of isolation (which does tend to increase the Control Room dose if effected when atmospheric activity concentrations are very high) is largely compensated for by other conservatisms in the calculation.

In all of the original calculations, the Control Room ventilation was modeled as a continuous 3700 cfm exchange with the environment. In fact, the effective value is approximately 2700 cfm. This is one of the conservatisms removed in this study.

Additional conservatisms removed are as follows:

For the LOCA, minimal hold-up in the Reactor Building was assumed during the first 10 minutes when (for roughly six minutes out of the 10) the Reactor Building might be above atmospheric pressure.

During this 10 minutes, a ground-level release was assumed at a rate equal to the normal ventilation exhaust rate, even though the normal ventilation exhaust rate is sufficient to maintain the building at a negative pressure. With the normal ventilation off (the condition that leads to the transient positive pressure for the case of one SGTS train having failed), the natural exchange would have to be less than this value given that the building was at a negative pressure with respect to all sides when the normal ventilation was on. The Control Room dose for this case is 1.9 rem TEDE even with isolation; less than the original analysis value of 3.4 rem TEDE.

For the MSLB, no additional conservatisms were removed. The Control Room dose for this case is 2.3 rem TEDE even with isolation; only 15% greater than the original analysis value of 2.0 rem TEDE.

Hlowever, this result is for a coolant activity of 4.0 ptCi/gm Dose Equivalent (DE) 1-131, 3.64 times greater than the Technical Specification value of 1.1 pCi/gm. Using 1.1 4Ci/gm would reduce the Control Room dose to 0.6 rem TEDE even with isolation.

Overall, it has been shown that not considering isolation is compensated for by other conservatisms in the analysis. Isolation would be a temporary condition, and it has been shown to be unnecessary to protect the Control Room operators under DBA conditions.

BVY 03-119 / Attachment I / Page 10 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI No. 8 MIiM/, respect to Attachment 5 please provide a detailed description of all inputs and assumptionsfor all relative concentration (X/Q) values not previously approved by the US. Nuclear Regulatory Comnmnission (NRC). This appears to include the exclusion area boundary ground level reactor building (RB) bypass and siding, and stack 2-8 and 8-24 hour X/Q values; the low population zone (LPZ) ground level main steam isolation valve (MSIV) and ground level RB bypass and siding Z/Q values; and the control room

,/Q values for the loss-of-coolant accident (LOCA),, main steam line break (MSLB), andfiel handling accidents. Note 3 of Table 2-6 states that control rod drop accident ground level release LPZ X/Q values are documented in the UFSAR. Were these values previously approved by the NRC? If so, please provide a reference citation.

Response to RAI No.8 The (X/Q) tabulations and associated design inputs are presented in Tables 1-21, in the following sequence:

Table I

  • LOCA - MSIV Leakage (Turbine Building Releases) to EAB Table 2 LOCA - RB Bypass and RB Siding Releases to EAB Table 3
  • LOCA - Stack Releases to EAB Table 4 LOCA - MSIV Leakage, RB Bypass and RB Siding Releases to LPZ Table 5* LOCA - Stack Releases to LPZ Table 6 LOCA - RB Bypass Releases to CR and TSC Table 7 LOCA - RB Siding Releases to CR and TSC Table 8 LOCA - MSIV Leakage (via Turbine Building) to CR and TSC Table 9 LOCA - Stack Releases to CR and TSC Table 10* MSLB - Ground-Level Release to EAB Table 11 MSLB - Ground-Level Steam Puff Release to CR Table 12* Refueling Accident - Ground-Level Releases to EAB Table 13* Refueling Accident - Stack Releases to EAB Table 14 Refueling Accident - Ground-Level Releases to CR Table 15* Refueling Accident - Stack Releases to CR Table 16* CRDA - Ground-Level Releases to EAB Table 17* CRDA - Stack Releases to EAB Table 18 CRDA - Ground-Level Releases to LPZ Table 19* CRDA - Stack Releases to LPZ Table 20* CRDA - Ground-Level Releases to CR Table 21
  • CRDA - Stack Releases to CR The following are noted:

(a) Tables with asterisks (*) above indicate prior NRC review and approval of the (x/Q)s (TAC No.

MB4610. License Amendment 212). In all these cases, the computercode employed was SKIRON-Il.

(b) The (X/Q)s for a given release point and a given receptor may appear in more than one table, for different accidents. For the EAB and ground-level releases, for instance, Tables I (LOCA), 10 (MSLB),

12 (RA) and 16 (CRDA) are identical. This was done to provide a complete set of (x/Q)s for each design-basis accident, independently.

BVY 03-119 / Attachment I / Page 11 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO RFOUEST FOR ADIhITIONAL INFORMATION Table 1 Design Input for Atmospheric Dispersion Factors LOCA - MSIV Leakage (Turbine Building Releases) to EAB (NRC Approved)

(x/Q)s 0 - 2 hrs l l l ll (sec/mr3 ) 1.69E-03 IRelease height lGround level Building cross-sectional area for building wake effects 954.2 m2 Building height (for building wake effects) 21.3 m Minimum wind speed acceptable as valid observation, and wind speed 0.268 m/sec assigned to calms Wind speed adjustment with height Not considered Plume rise Not applicable Average depth of limited mixing layer (for plume reflection) 950 m Temperature sensor separation (198'- 33') 50.3 m Plume meander Considered Receptor distances (minimum distance from the turbine building to the site area boundary for gaseous effluents within a 45-degree sector centered on the compass direction of interest, per Sec. C.l1.2 of Reg.

Design Input Guide 1.145):

Downwind sector: N 439.1 m NNE 436.9 m NE 436.9 m ENE 474.9 m E 474.9 m ESE 448.1 m SE 457.0 m SSE 483.9 m S 233.0 m SSW 188.2 m SW 183.7 m WSW 183.7 m W 192.7 m WNW 206.1 m NW 268.8 m NNW 537.7 m Terrain height above release-point grade elevation (all sectors) Om Computer Code & SKIRON-Il (1989 met data)

Met Data Base SIO-1199mtda Notes This atmospheric dispersion factor has been previously reviewed and approved by the US NRC (TAC No. MB4610, SER Page 4)

BVY 03-119/ Attachment I / Page 12 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RrSPONSF TO REOUEST FOR ADDITIONAL INFORMATION Table 2 Design Input for Atmospheric Dispersion Factors LOCA - RB Bypass and RB Siding Relcases to EAB (x/Q)s 0 - 2 hrs l l l l (sec/M 3 ) 1.476E-03 l_lll 0.42 (m/sec) 0.89, 1.56 3.35, 5.59 Upper wind speed in each wind-speed group (I1 groups) 8.27, 10.95 14.08, 17.21 20.78, 40.23 Wind speed assigned to calms 0.21 m/sec Release height 0m Adjacent building height (above release point grade) 41.5 m Adjacent building cross-sectional area 1416 m2 Average depth of limited mixing layer (for plume reflection) 950 m Temperature sensor separation (198' - 33') 50.3 m 424 m 415 m 415 m 419 m Design Input 445 m 445 m 455 m Distances to site area boundary for gaseous effluents (N through NNW, 506 m clockwise) 344 m 252 m 242 m 242 m 244 m 284 m 384 m 502 m Terrain height at receptor locations with respect to grade elevation at 2.44 m release point (all sectors) [Has no impact since > release height]

Plume meander Considered Wind speed adjustment with height Not 1considered Not Recirculation correction for annual (x/Q)s considered Computer Code & AEOLUS-3 (1995-1999 met data)

Met Data Base Notes The RB siding (X/Q) bounds the RB Bypass. The RB siding release was used for both releases.

BVY 03-119 / Attachment I / Page 13 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 3 Design Input for Atmospheric Dispersion Factors LOCA - Stack Relcases to EAB (NRC Approved)

(x/Q)s 0 - 0.5 hr 0.5 - I hr lI - 2 hrs 2 - 8 hrs 18 - 2411rs lhl (sec/rn 3

) 2.03E-04 I.54E-04 9.177E-05 4.04E-05 5.26E-06 Stack height 93.9 m Terrain height at receptor of interest 2.4 m Design Input Critical receptor distances from stack (shortest distance from the stack

[0 - 0. 5 hr, to a receptor on the Site Area Boundary for Gaseous Effluents within a 253 m Fumigation 45-degree sector centered on the compass direction of interest, per Sec. (WSW)

Conditions C.1.2 of Reg. Guide 1.145)

Plume standard deviations at 253 m: sigma-y 10.7 m sigma-z 4.8 m Wind speed 2 m/sec Release height (stack height) 93.9 m Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.268 m/sec assigned to calms Design Input Wind speed adjustment with height Not

[0. 5- 24 lrs, considered Normal Temperature sensor separation (295'-33') 79.9 m Conditions] Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Critical receptor distances from stack (where the terrain height first 2100 m exceeds the stack height)

Terrain height at critical receptor (W sector) 106.1 m Computer Code & Hand calculated value for the fumigation condition (based on Reg.

Met Data Base Guide 1.145). SKIRON-I1 (1985 met data) for the normal atmospheric conditions.

Notes Notes The (X/Q)s forby and approved 0-0.5, 0.5-1 the US and(TAC NRC 1-2 hrs No.have been previously MB4610, SER Tablereviewed 1)

BVY 03-119 / Attachment I / Page 14 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 4 Design Input for Atmospheric Dispersion Factors LOCA - MSIV Leakage, RB Bypass and RB Siding Relcases to LPZ (x/Q)s 0 -2 hrs 12 - 8 hrs 18 - 24 hrs 1 - 4 days 14 - 30 days 3

(sec/mr ) 5.25E-05 2.23E-05 1.47E-05 5.95E-06 1.63E-06 0.42 (m/sec) 0.89, 1.56 3.35, 5.59 Upper wind speed in each wind-speed group (II groups) 8.27, 10.95 14.08, 17.21 20.78. 40.23 Wind speed assigned to calms 0.21 m/sec Release height Om Adjacent building height (above release point grade) 41.5 m Adjacent building cross-sectional area 1416 m2 Average depth of limited mixing layer (for plume reflection) 950 m Wind speed adjustment with height Not considered Temperature sensor separation (198' - 33') 50.3 m Distances to receptors of interest at the LPZ (same for all sectors) 8050 m Design Input 234.1 m 319.4 313.3 265.8 203.6 Terrain heights at receptor locations with respect to grade elevation at 275.5 release point (N through NNW, clockwise) 154.8 302.7

[Provided as input but have no impact on the (X/Q)s since the release 2.9 height is 0.] 267.6 340.8 325.5 252.4 181.1 179.2 Plume meander Considered Recirculation correction for annual (x/Q)s Not considered Computer Code & AEOLUS-3 (1995-1999 met data)

Met Data Base ______

Notes In view of the LPZ 5-mile distance, the MSIV, RB Bypass and RB Notes Siding (x/Q)s are the same.

BVY 03-119 / Attachment I / Page 15 of 4l VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 5 Design Input for Atmospheric Dispersion Factors LOCA - Stack Releases to LPZ (NRC Approved)

(X/Q)s 0- I hr I --2 irs l2-8hrs l8 -24 hrs I -4 days 4 -30days (sec/rn3 ) 2.55E-05 1.87E-05 l1.0 IE-05 1.09E-06 6.90E-07 4.61 E-07 Release height (stack height) 93.9 m Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.268 m/sec assigned to calms Wind speed adjustment with height Not considered Design Input Temperature sensor separation (295'-33') 79.9 m Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Receptor distance from stack (all sectors) (8047 m)

Terrain height at receptors (arbitrarily set higher than the release height 100 m of 93.9 m; i.e., plume centerline is at ground level)

Computer Code & SKIRON-I1 (1985 met data)

Met Data Base Notes These (x/Q)s have been previously reviewed and approved by the US

____________ NRC (TAC No. MB4610, SER Table 1)

BVY 03-1 19 / Attachment 1 / Page 16 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 6 Design Input for Atmospheric Dispersion Factors LOCA - RB Bypass Relcases to CR and TSC (x/Q)s 0 - 2 hrs 12 - 8 lrs 18 - 24 hrs l1 - 4 days 14 - 30 days (sec/m 3 ) 2.25E-03 8.18E-04 3.53E-04 12.77E-04 12.23E-04 Height of lower wind instrument 10.7 m Height of upper wind instrument 90.5 m Wind speed units mph Release type Ground level, point source Release height 1.8 m Building cross-sectional area 1746 m2 Effluent vertical velocity, vent or stack flow, vent stack radius 0 Design Input Direction, intake to source (sector width) III deg (90)

Distance to intake 41 m Intake height 10.5 Terrain elevation difference 0 Minimum wind speed 0.5 m/sec Surface roughness 0.2 m Sector averaging constant 4.3 Initial plume standard deviations (sigma-y and sigma-z) 0m Computer Code & ARCON96 (1995-1999 met data)

Met Data Base

BVY 03-119 / Attachment I / Page 17 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 7 Design Input for Atmospheric Dispersion Factors LOCA - RB Siding Releases to CR and TSC (x/Q)s 0-0.5hr l l l (sec/mr3 ) 2.98E-03 Height of lower wind instrument 10.7 m Height of upper wind instrument 90.5 m Wind speed units mph Release type Ground level, diffuse area Release height 34.9 m Building cross-sectional area 0m2 Effluent vertical velocity, vent or stack flow, vent stack radius 0 Design Input Direction, intake to source (sector width) 75 deg (90)

Distance to intake 9.8 m Intake height 10.5 Terrain elevation difference 0 Minimum wind speed 0.5 mrsec Surface roughness 0.2 m Sector averaging constant 4.3 Initial plume standard deviations: sigma-y 7.3 m sigma-z 2.1 m Computer Code & ARCON96 (1995-1999 met data)

Met Data Base oldrn_____tm Notes Applicable only during RB draw-down time.

BVY 03-119 / Attachment 1 / Page 18 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 8 Design Input for Atmospheric Dispersion Factors LOCA - MSIV Leakage (via Turbine Building) to CR and TSC (x/Q)s 0 - 2hrs 12 - 8 hrs 8 - 24 irs I- 4 days 4 - 30 days 3

(sec/mr ) 4.66E-03 3.46E-03 1.45E-03 1.09E-03 9.92E-04 Height of lower wind instrument 10.7 m Height of upper wind instrument 90.5 m Wind speed units mph Release type Ground level, point source Release height 2.3 m Building cross-sectional area 150 m2 Effluent vertical velocity, vent or stack flow, vent stack radius 0 Design Input Direction, intake to source (sector width) 296 deg (90)

Distance to intake 33m Intake height 10.5 Terrain elevation difference 0 Minimum wind speed 0.5 m/sec Surface roughness 0.2 m Sector averaging constant 4.3 Initial values of sigma-y and sigma-z 0m Computer Code & ARCON96 (1995-1999 met data)

Met Data Base ______

BVY 03-1 19 / Attachment I / Page 19 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 9 Design Input for Atmospheric Dispersion Factors LOCA - Stack Releases to CR and TSC (x/Q)s 0 - 2 firs 2 - 8 rs 8 - 24 hrs I - 4 days 4 - 30 days 3 3.08E-07 1.79E-07 (sec/mr ) 1.92E-05 8.281E-07 3.36E-07 Height of lower wind instrument 10.7 m Height of upper wind instrument 90.5 m Wind speed units mph Release type Elevated Release height 93.9 m Building cross-sectional area 0.01 m2 Effluent vertical velocity, vent or stack flow, vent stack radius 0 Design Input Direction, intake to source (sector width) 337 deg (90)

(ARGON 96)

Distance to intake 276 m Intake height 10.5 Terrain elevation difference 0 Minimum wind speed 0.5 m/sec Surface roughness 0.2 m Sector averaging constant 4.3 Initial values of sigma-y and sigma-z 0m Continued

BVY 03-119 / Attachment I / Page 20 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 9 (Continued)

LOCA - Stack Relcases to CR and TSC 0.42 (m/sec) 0.89, 1.56 3.35, 5.59 Upper wind speed in each wind-speed group (11 groups) 8.27, 10.95 14.08, 17.21 20.78, 40.23 Release height [set equal to the difference between the heights of the 83.4 m stack (93.9) and the CR intake (10.5 m)] 83._m Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.447 and Design Input assigned to calms 0.21 m/sec (AEOLUS-3)

Wind speed adjustment with height Not considered Temperature sensor separation (295'-33') 79.9 m Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Receptor distances (looking for maximum x/Qs) 30 distances Terrain elevation (set equal to the effective elevation of the CR intake) 0m Not Recirculation correction on annual average (X/Q) considered Computer Code & ARCON96 and AEOLUS-3 (1995-1999 met data)

Met Data Base

a. The ARCON96 and AEOLUS-3 results were combined in Notes accordance with the guidance in Reg. Guide 1.194
b. The AEOLUS-3 (x/Q)s peak at 3000 m for the 0-2, 2-8 and 8-24 hr intervals, and at 2500 m thereafter.

BVY 03-1 19 / Attachment I / Page 21 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 10 Design Input for Atmospheric Dispersion Factors MSLB - Ground-Level Release to EAB (NRC Approved)

(x/Q)s 0 - 2 hrs l l l l (sec/rn3 ) 1.69E-03 Release height Ground level Building cross-sectional area for building wake effects 954.2 m2 Building height (for building wake effects) 21.3 m Minimum wind speed acceptable as valid observation, and wind speed 0.268 m/sec assigned to calms Wind speed adjustment with height considered Plume rise Not applicable Average depth of limited mixing layer (for plume reflection) 950 m Temperature sensor separation (198'- 33') 50.3 m Plume meander Considered Receptor distances (minimum distance from the turbine building to the site area boundary for gaseous effluents within a 45-degree sector centered on the compass direction of interest, per Sec. C.1.2 of Reg.

Design Input Guide 1.145):

Downwind sector: N 439.1 m NNE 436.9 m NE 436.9 m ENE 474.9 m E 474.9 m ESE 448.1 m SE 457.0 in SSE 483.9 m S 233.0 m SSW 188.2 in SW 183.7 mn WSW 183.7 In W 192.7 m WNW 206.1 in NW 268.8 in NNW 537.7 m Terrain height above release-point grade elevation (all sectors) Om Computer Code & SKIRON-I1 (1989 met data)

Met Data Base ______

Notes This atmospheric dispersion factor has been previously reviewed and eapproved

______________ by the US NRC (TAC No. MB46 10, SER Page 4)

BVY 03-119 / Attachment I Page 22 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 11 Design Input for Atmospheric Dispersion Factors MSLB - Ground-Lcvel Steam Puff Rcecase to CR (x/Q)s 0 -2 hrs I l l l l (sec/r 3 ) 1.44E-03 Design Input Reference Please see Polestar calculation PSAT 3019CF.QA.06 for details.

Computer Code &

Met Data Base

BVY 03-119 / Attachment I / Page 23 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 12 Design Input for Atmospheric Dispersion Factors Refueling Accident - Ground-Level Releases to EAR (NRC Approved)

(x/Q)s 0 - 2hrs lI I IlI (sec/M3 ) 1.69E-03 I I I I IRelease height Ground level Building cross-sectional area for building wake effects 954.2 m2 Building height (for building wake effects) 21.3 m Minimum wind speed acceptable as valid observation, and wind speed 0.268 rn/sec assigned to calms Wind speed adjustment with height Not considered Plume rise Not applicable Average depth of limited mixing layer (for plume reflection) 950 m Temperature sensor separation (198'- 33') 50.3 m Plume meander Considered Receptor distances (minimum distance from the turbine building to the site area boundary for gaseous effluents within a 45-degree sector centered on the compass direction of interest, per Sec. C.1.2 of Reg.

Design Input Guide 1.145):

Downwind sector: N 439.1 m NNE 436.9 m NE 436.9 m ENE 474.9 m E 474.9 m ESE 448.1 m SE 457.0 m SSE 483.9 m S 233.0 m SSW 188.2 m SW 183.7 m WSW 183.7 m W 192.7 m WNW 206.1 m NW 268.8 m NNW 537.7 m Terrain height above release-point grade elevation (all sectors) Om Computer Code & SKIRON-I1 (1989 met data)

Met Data Base _______

Notes . Presented here for information only since FHA analysis applied an elevated release.

BVY 03-1 19 / Attachment I / Page 24 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 13 Design Input for Atmospheric Dispersion Factors Refueling Accident - Stack Releases to EAB (NRC Approved)

(x/Q)s 0 - 0.5 hr I0.5 - I hr I - 2 hrs l (sec/mi3 ) 2.03 E-04 1.54E-04 9.17E-05 Stack height 93.9 m Terrain height at receptor of interest 2.4 m Design Input Critical receptor distances from stack (shortest distance from the stack

[0 - 0. 5 hr, to a receptor on the Site Area Boundary for Gaseous Effluents within a 253 m Fumigation 45-degree sector centered on the compass direction of interest, per Sec. (WSW)

Conditions C.1.2 of Reg. Guide 1.145)

Plume standard deviations at 253 m: sigma-y 10.7 m sigma-z 4.8 m Wind speed 2 m/sec Release height (stack height) 93.9 mn Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.268 m/sec assigned to calms Design Input Wind speed adjustment with height Not

[0. 5 - 24 hrs, considered Normal Temperature sensor separation (295'-33') 79.9 m Conditions] Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Critical receptor distances from stack (where the terrain height first 2100 m exceeds the stack height)

Terrain height at critical receptor (W sector) 106.1 in Computer Code & Hand calculated value for the fumigation condition (based on Reg.

Mpt Code Guide 1.145). SKIRON-1I (1985 met data) for the normal atmospheric Met Data Base cnios..______

conditions.

Notes These (y]Q)s have been previously reviewed and approved by the US NRC (TAC No. MB4610, SER Table 1)

BVY 03-119 / Attachment I / Page 25 of 41 VERMONT YANKEE NUCLEAR POWER'STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 14 Design Input for Atmospheric Dispersion Factors Refueling Accident - Ground-Level Releases to CR (x/Q)s 0-2hr l l I (sec/M 3) 5.89E-03 Height of lower wind instrument 10.7 m Height of upper wind instrument 90.5 m Wind speed units mphi Release type Ground level, point source Release height 34.9 m Building cross-sectional area 1337.3 m2 Effluent vertical velocity, vent or stack flow, vent stack radius 0 Design Input Direction, intake to source (sector width) 75 deg (90)

Distance to intake 9.8 m Intake height 10.5 Terrain elevation difference 0 Minimum wind speed 0.5 m/sec Surface roughness 0.2 m Sector averaging constant 4.3 Initial values of sigma-y and sigma-z 0m Computer Code & ARCON96 (1995-1999 met data)

Met Data Base ______

Notes Presented here for information only since FHA analysis applied an elevated release.

BVY 03-1 19 / Attachment I / Page 26 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 15 Design Input for Atmospheric Dispersion Factors Refueling Accident - Stack Releases to CR (NRC Approved)

(x/Q)s 0 - 0.5 hr 0.5 -I hr l1 -2hr l lfi (sec/M 3) 2.39E-04 1.05E-06 8.70E-07 Stack height 93.9 m Design Input Distance from stack to CR building 213 m

[0- 0.5 hr.

Fumigation Terrain height at receptor of interest 2.4 m Conditions] Plume standard deviations at 213 m: sigma-y 9.1 m sigma-z 4.2 m Wind speed 2 m/sec Release height (stack height) 93.9 m Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.268 r/sec assigned to calms 0_268______

Wind speed adjustment with height Not Design Input considered

[0.5 - 24 hrs, Temperature sensor separation (295'-33') 79.9 in Normal Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Distance from stack to CR air intake

[Note: The concentration at the intake is higher than at the CR building, 259 m since, for elevated plumes, the plume spreads closer to the ground as the (SSE) distance from the release point increases.]

Terrain height at receptor of interest 2.4 m Computer Code & Hand calculated value for the fumigation condition (based on Reg.

Mpt Code Guide 1.145). SKIRON-I1 (1985 met data) for the normal atmospheric Met Data Base codtin ._____

conditions These (y/Q)s, as well as those for the remaining time intervals beyond 2 Notes hrs (see Table 21), have been previously reviewed and approved by the US NRC (TAC No. MB4610, SER Table 1)

BVY 03-1 19 / Attachment I / Page 27 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 16 Design Input for Atmospheric Dispersion Factors CRDA - Ground-Level Relcases to EAR (NRC Approved)

(x/Q)s 0-2 hrs l l l l (sec/m3) 1.69E-03 Release height Ground level Building cross-sectional area for building wake effects 954.2 m2 Building height (for building wake effects) 21.3 m Minimum wind speed acceptable as valid observation, and wind speed 0.268 rn/sec assigned to calms 0.268______

Wind speed adjustment with height Not considered Plume rise Not applicable Average depth of limited mixing layer (for plume reflection) 950 m Temperature sensor separation (198' - 33') 50.3 m Plume meander Considered Receptor distances (minimum distance from the turbine building to the site area boundary for gaseous effluents within a 45-degree sector centered on the compass direction of interest, per Sec. C.1 .2 of Reg.

Design Input Guide 1.145):

Downwind sector: N 439.1 m NNE 436.9 m NE 436.9 m ENE 474.9 m E 474.9 m ESE 448.1 in SE 457.0 in SSE 483.9 in S 233.0 in SSW 188.2 m SW 183.7 m WSW 183.7 m W 192.7 m WNW 206.1 m NW 268.8 m NNW 537.7 m Terrain height above release-point grade elevation (all sectors) Om Computer Code & SKIRON-1I (1989 met data)

Met Data Base ______

This atmospheric dispersion factor has been previously reviewed and Notes approved by the US NRC (TAC No. MB4610, SER Page 4)

BVY 03-119/ Attachment I / Page 28 of 41 VERMONT YANKEE NUCLEAR POWER'STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 17 Design Input for Atmospheric Dispersion Factors CRDA - Stack Releases to EAIB (NRC Approved)

(x/Q)s 0-0.5hr 10.5-I hr I1-2hrs l l (sec/n 3 ) 2.03E-04 1.54E-04 9.17E-05 Stack height 93.9 rn Terrain height at receptor of interest 2.4 m Design Input Critical receptor distances from stack (shortest distance from the stack

[0 - 0. 5 hr, to a receptor on the Site Area Boundary for Gaseous Effluents within a 253 m Fumigation 45-degree sector centered on the compass direction of interest, per Sec. (WSW)

Conditions C.1.2 of Reg. Guide 1.145)

Plume standard deviations at 253 m: sigma-y 10.7 m sigma-z 4.8 m Wind speed 2 m/sec Release height (stack height) 93.9 m Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wvind speed 0.268 r/secI assigned to calms m____

Design Input Wind speed adjustment with height Not

[0. 5 - 24 hrs, considered Normal Temperature sensor separation (295'-33') 79.9 rn Conditions] Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Critical receptor distances from stack (where the terrain height first 2100 m exceeds the stack height)

Terrain height at critical receptor (W sector) 106.1 mn Comp terCode & Hand calculated value for the fumigation condition (based on Reg.

omput er Guide 1.145). SKIRON-lI (1985 met data) for the normal atmospheric conditions.

Notes These (x/Q)s have been previously reviewed and approved by the US

____________ NRC (TAC No. MB4610, SER Table 1)

BVY 03-119 / Attachment 1 / Page 29 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 18 Design Input for Atmospheric Dispersion Factors CRDA - Ground-Level Releases to LPZ (x/Q)s 0 - 2 hrs 12 - 8 hrs 18 - 24 hrs I1- 4 days 4 - 30 days (sec/m3 ) 5.251E-05 2.23 E-05 1.47E-05 5.9513-06 1.6313-06 0.42 (m/sec) 0.89, 1.56 3.35, 5.59 Upper wind speed in each wind-specd group ( I1groups) 8.27, 10.95 14.08, 17.21 20.78, 40.23 Wind speed assigned to calms 0.21 m/sec Release height Om Adjacent building height (above release point grade) 41.5 m Adjacent building cross-sectional area 1416 m2 Average depth of limited mixing layer (for plume reflection) 950 m Wind speed adjustment with height Not considered Temperature sensor separation (198' - 33') 50.3 m Distances to receptors of interest at the LPZ (same for all sectors) 8050 m Design Input 234.1 m 319.4 313.3 265.8 203.6 Terrain heights at receptor locations with respect to grade elevation at 275.5 release point (N through NNW, clockwise) 154.8

[Provided as input but have no impact on the (x/Q)s since the release 282.97 height is 0.] 267.6 340.8 325.5 252.4 181.1 179.2 Plume meander Considered Recirculation correction for annual (x/Q)s Not considered Computer Code & AEOLUS-3 (1995-1999 met data)

Met Data Base Notes In view of the LPZ 5-mile distance, the (x/Q)s for Reactor Building Releases and Turbine Building releases are the same.

BVY 03-119 / Attachment I / Page 30 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 19 Design Input for Atmospheric Dispersion Factors CRDA - Stack Releases to LPZ (NRC Approved)

(x/Q)s 0- 1 hr l1 - 2 hrs 12 - 8 hrs 18 - 24 hrs l1 - 4 days 4 - 30 days (sec/mr3 ) 2.55E-05 1.87E-05 I1.01 E-05 l1.091E-06 16.90E-07 4.61 E-07 Release height (stack height) 93.9 m Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.268 r/sec assigned to calms Wind speed adjustment with height Not considered Design Input Temperature sensor separation (295'-33') 79.9 m Plume rise Not credited Average depth of limited mixing layer (for plume reflection) 950 m Receptor distance from stack (all sectors) (8047 m)

Terrain height at receptors (arbitrarily set higher than the release height of 93.9 m; i.e., plume centerline is at ground level) m Computer Code & SKIRON-Il (1985 met data)

Met Data Base Notes Tihese (x/Q)s have been previously reviewed and approved by the US NRC (TAC No. MB4610, SER Table I)

BVY 03-1 19 /Attachment I / Page 31 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 20 Design Input for Atmospheric Dispersion Factors CRDA - Ground-Level Releases to CR (NRC Approved)

(x/Q)s 0- I fhr Il - 2 hrs 12 - 8 frs 18 - 24 hrs l - 4 days 4 - 30 days (sec/mr3 ) 3.67E-03 2.19E-03 17.57E-04 3.93E-04 12.71 E-04 2.04E-04 Release height Groundlevel (O m)

Building cross-sectional area for building wake effects (CR-affecting sectors) 1936 m2

[Note: In view of the short distance to the CR, plume meander was excluded, and no limit was imposed on the building-wake correction.]

Building height (for building wake effects, sector averaging model) 21 m Minimum wind speed acceptable as valid observation 0.268 m/sec Wind speed assigned to calms 0.134 m/sec Design Input Wind speed adjustment with height considered Temperature sensor separation (198'-33') 50.3 m Plume rise and terrain heights Not applicable Average depth of limited mixing layer (for plume reflection) 1000 m Downwind sectors which may potentially affect the Control Room NE, ENE, E,

[Note: Selected X/Q was for worst-case individual sector] ESE and SE Receptor distance (release point to CR) 25 m (all se~ctors)

Computer Code & SKIRON-Il, Murphy/Campe simulation option (1979 met data)

Met Data Base ______

Notes These (x/Q)s have been previously reviewed and approved by the US NRC (TAC No. MB4610, SER Table I)

BVY 03-119 / Attachment I / Page 32 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 21 Design Input for Atmospheric Dispersion Factors CRDA - Stack Relcases to CR (NRC Approved)

I- 2 hr 2 - 8hrs 8 - 24 hrs 1-I - 430days

_____________________________________4 days

.~~~~~~~~~~~I .23-0 8.70E-07 4.79E-07 2.34E-07 6.930E-08 93.9 m Design Input Distance from stack to CR building 213 m

[0 - 0. 5 hr, Fumigation Terrain height at receptor of interest 2.4 mn Conditions] Plume standard deviations at 213 m: sigma-y 9.1 m sigma-z 4.2 m Wind speed 2 m/sec

+ -t Release height (stack height) 93.9 in Building cross-sectional area and height for building wake effects, and Not plume meander applicable Minimum wind speed acceptable as valid observation, and wind speed 0.268 m/sec assigned to calms Wind speed adjustment with height Not Design Input considered

[0.5 - 24 hrs, Temperature sensor separation (295'-33') 79.9 m Normal Plume rise Not credited Conditions]

Average depth of limited mixing layer (for plume reflection) 950 m Distance from stack to CR air intake

[Note: The concentration at the intake is higher than at the CR building, 259 m since, for elevated plumes, the plume spreads closer to the ground as the (SSE) distance from the release point increases.]

Terrain height at receptor of interest 2.4 m Iand calculated value for the fumigation condition (based on Reg.

H&

Met Data Base Guide 1.145). SKIRON-I1 (1985 met data) for the normal atmospheric conditions Notes These (X/Q)s have been previously reviewed and approved by the US

_NRC (TAC No. MB4610, SER Table 1) I

BVY 03-119 / Attachment I / Page 33 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI No. 9 For the LOCA LPZ estimates, tit'y is there a difference between the ground level MSIV and RB siding and bypass Z/Q values? Is this only because the AEOLUS-3 methodology itas used in some of the calculations and tile SKIRON-HI methodology used when making other estimates? Provide a description of the differences between the AEOLUS-3, SKIRON-HI and Regulatory Guide (RG) 1.145, "Atmnospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants,"

methodologies and the expected impact of these differences on resultant estimated Z/Q values.

Response to RAI No. 9 The ground-level MSIV to LPZ X/Q values were calculated in 1986 with SKIRON-I1 utilizing the latest available meteorological data from 1985. The RB siding and bypass X/Q values were recently calculated using AEOLUS-3 utilizing meteorological data for the five year period of 1995-1999. The differences between the X/Q sets is due to the combined effects of using different codes and meteorological data.

The AEOLUS-3 methodology includes a 2a adjustment factor in the least-square-fit line through the 1-hr X/Q values per Regulatory Guide 1.145. For the worst-case LPZ sector, this adjustment amounts to 1.2.

SKIRON-Il uses a sliding window approach applied to hourly X/Q values; no adjustment is applied since the distributions are more uniform since these are hourly values with their unique meteorological data versus the joint-frequency distributions in AEOLUS-3 (with average wind speeds). This difference would account for a 20% difference between the two codes. If this adjustment factor from AEOLUS-3 is excluded, the AEOLUS-3/SKIRON-I1 ratios are about 1.12. The combined effect would account for about a 34% (or 1.34) difference between the two codes. Additional difference would be due to differences in the meteorological database.

Vermont Yankee recognizes the ground-level release X/Q values for the LPZ should be the same considering the proximity of the release points and the five mile distance to the LPZ receptor. The MSIV to LPZ pathway evaluation in the LOCA and CRDA calculations have been updated to use the same X/Q values as the RB siding and bypass pathways. The updated X/Q values for the LPZ result in a change to the LOCA LPZ dose results from 0.52 rem TEDE to 0.53 rem TEDE. Safety Assessment Table 3-1 is revised to reflect this update. The CRDA LPZ dose for "Case I + Case 3" in Safety Assessment Table 3-4 changes from 0.066 rem TEDE to 0.078 rem TEDE.

The updated LPZ X/Q input is reflected in revised Safety Assessment Tables 2-3 and 2-6 provided below.

The updated LOCA and CRDA results are revised and reflected in Safety Assessment Tables 3-1 and 3-4 respectively. The values that have been updated are in bold type. These tables follow the design input tables.

In addition, two typographical errors were found in Safety Assessment Tables 2-5 and Table 2-14. There is no impact to the analysis results since these were typographical errors limited to the preparation of tile Safety Assessment. The stack to EAB 0.5 - 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> value in Table 2-5 "X/Q Values for Radiological Dose Calculations Refuieling Accident" should be 1.54E-04 sec/M3 . The revised Table 2-5 is included in this response. The krypton-85 activity in Table 2-5 "Fission Product Inventory (Refuieling Accident)" should be 5.05E+02 Ci/MW. The adjusted activity on the table is correct. Also, footnote I of the table is revised to reflect the gap fraction adjustment made to krypton-85 and iodine-131 per RG 1.183.

BVY 03-119 / Attachment I / Page 34 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Revised Safety Assessment Tables

BVY 03-1 19 / Attachment I / Page 35 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 2-3 (Revision 1)

XIQ Values for Radiological Dose Calculations - LOCA (sec/m 3 )

Release Release Timing Location 10-0.5 hr l 0.5-1 hr l 1-2 hrs l 2-8 hrs l 8-24 hrs 1-4 days 4-30 days EAB M5IV 1.70E-03 -NA- -NA- -NA- -NA-Bypass 2 1.476E-03 -NA- -NA- -NA- -NA-Ground2 RB 1.47613-03 -NA- -NA- -NA- -NA-S iding _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ __ _ _ _

Stack 3 - 1.5413-04 9.17E-05 4.0413-5 5.26E-6 -NA- -NA-Fumig. 3 2.03E4 - _ -NA- -NA-LPZ Ground MSIV 5 Grouand R 5.25E-5 2.23E-5 1.47E-5 5.95E-6 1.63E-6 Ground RB Siding 5 Stack 6 2.55E-05 1.8713-05 1.01E-05 1.09E-06 6.9013-07 4.611E-07 CONTROL ROOM and TSC Ground RB 2.25E-3 8.18E-4 3.5313-4 2.77E-4 2.23E-4 Bypass 7 Ground RB 2.9813-3 -NA- -NA- -NA- -NA- -NA- -NA-Siding sg_ _ _ _ _ _

Ground MSIV 7 4.66E-3 3.46E-3 1.4513-3 1.0913-3 9.9213-4 Normal 1.9213-5 1.9213-05 8.28E-7 3.3613-7 3.08E-7 1.79E-07 Stumg. 9 .2E- _

BVY 03-119 / Attachment I / Page 36 of41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Table 2-3 (Revision 1)

XIQ Values for Radiological Dose Calculations - LOCA (sec/M3 )

NOTES SKIRON-I. Max. 0-2 hr. Previously calculated and 0-2 hr NRC reviewed (Ref. 9 and 10).

2 AEOLUS-3 generated. RB Siding X/Q bounds the RB Bypass. RB Siding release is used for both.

3 SKIRON-Il. Stack release previously calculated. 0-2 hr values NRC reviewed (Ref. 9 and 10).

4 Not used.

5 AEOLUS-3. In view of the 5 mile distance, the RB Bypass, Siding & MSIV LPZ X/Q are the same.

6 SKI RON-Il. Stack to LPZ have been previously reviewed (References 9 and 10).

7 ARCON96. Based on RG 1.194 point source

' ARCON96. Based on RG 1.194 area source. Applicable only during drawdown time.

9ARCON96 and AEOLUS. Based on RG 1.194 for habitability assessments.

NA -Not Applicable

BVY 03-119/ Attachment I / Page 37 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 2-5 (Revision 1)

X/Q Values for Radiological Dose Calculations Refueling Accident (sec/M3 )

EAB I

CONTROL ROOM I

I LPZ *

  • LPZ dose not necessary since release is limited to two hours and EAB is I

more limiting

' RB siding facing FAI treated conservatively as point source following RG 1.194.

2 Provided for information only since FHA results are based on elevated release.

BVY 03-119 / Attachment I / Page 38 of41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO REOUEST FOR ADDITIONAL :NFORMATION Table 2-6 (Revision 1)

X/Q Values for Radiological Dose Calculations - CRDA (sec/m 3 )

Release Release Timing Location 0-0.5 hr l 0.5-1 hr 1-2 hrs l 2-8 hrs 8-24 hrs 1-4 days 4-30 days EAB Ground' 1.70E-03 -NA- -NA- -NA- -NA-Noralk _ I.54E-4 9. E5 -NA- -NA- -NA- -NA-Stack SFtanick 2.03 E-04 _ -NA- -NA- -NA- -NA-LPZ Ground 3 5.25E-05 2.23E-05 1.47E-05 5.95E-06 1.63E-06 Stack 4 2.55E-05 j 1.87E-05 1.0IE-05 1.09E-06 6.90E-07 4.61E-07 CONTROL ROOM Ground 3.67E-03 2.19E-03 7.57£-04 3.93E-03 2.71 E-04 2.04E-04 Normal 6 1.05E-06 8.70E-07 4.792-7 2.34E-7 1.23E-7 6.902-08 Stack 2.39E-04 Fumig.6 .9-4 1SKIRON-Il. Max. 0-2 hr. Previously calculated and 0-2 hr NRC reviewed (Ref. 9 and 10).

2 SKIRON-II. Stack release previously calculated. 0-2 hr values NRC reviewed (Ref. 9 and 10).

3 AEOLUS-3. In view of the 5 mile distance, the RB Bypass, Siding & MSIV LPZ X/Q are the same.

4 SKIRON-II. Previously calculated and applied in CRDA. NRC reviewed (Ref. 9 and 10).

5 Murphy-Campe based. Previously calculated and applied in CRDA. NRC reviewed (Ref.9 and 10).

This values have been preserved in order to assess the impact of AST on the current licensing basis results.

6 Stack release. NRC reviewed. (Ref. 9 and 10)

BVY 03-1 19 / Attachment 1/ Page 39 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RFSPONSE TO REOUEST FOR ADDITIONAL !NFORMATION Table 2-14 (Revision 1)

Fission Product Inventory (Refueling Accident)

Isotope Ci/MWt Ci/MWt Ci/MWt t=0 Adjusted J t = 24 hr Br-83 4.2413+03 Kr-83M 4.2413+03 same 15.6 Br-85 9.61 E+03 *

  • Kr-85M 9.71 E+03 same 239 Kr-85 5.05E+02 1.01 E+03 1010 Kr-87 1.9413+04 same 0.038 Kr-88 2.75E+04 same 72.3 Kr-89 3.46E+04 same negligible Tc-131 M 4.31 E+03 1-131 2.85E+04 4.5613+04 42105 Xc-131M 3.18E+02 same 327 Te-132 3.9713+04 *
  • 1-132 4.0513+04 same 33065 Te-133M 2.3013+04 *
  • Te-133 3.3913+04 *
  • 1-133 5.79E+04 same 26656 Xe-133M 1.76E+03 same 1594 Xe-133 5.7813+04 same 55528 Te-134 5.31 E+04 *
  • 1-134 6.43 E+04 same negligible 1-135 5.39E+04 same 4351 Xe-135M 1.1413+04 same negligible Xe-135 2.3313+04 same 15285 Xe-137 5.07E+04 same negligible Xe-138 5.05E3+04 same negligible IAdjusted for increased gap fraction per RG 1.183.
  • Considcrcd as parent only

BVY 03-119 / Attachment 1 / Page 40 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RrSPONSE TO REOUEST FOR ADDITIONAL INFORMATION Table 3-1 (Revision 1)

LOCA Radiological Consequence Analysis (rem TEDE)

Offsite Dose Dose Component Control Room Dose EAB LPZ SGTS Single Failure Case Direct Primary Containment 1800 .

Leakage 1.8 0.08 2.8 Release Via RB and Plant.3 0.44 0.036 Stack Release Via Main Steam Lie a, Lines and MC MC 0.035 0.008 0.53 TOTAL SGTS Failure 3.14 0.53 3.40 MSIV Single Failure Direct Primary Containment 1.1 0.053 1.4 Leakage' Release Via RB and Plant 1.3 0.44 0.036 Stack Release Via Main Steam 0.039 0.008 0.56 Lines and MC TOTAL MSIV Failure 2.44 0.50 2.00 Regulatory Limit 25 25 5 Current Analysis (Regulatory 4.30E-01 (25) Gamma 2.80E-01 (25) Gamma 3.OE-03 (5) Gamma Limit) - rem 9.4E+01 (300) Thyroid 8.4E+00 (300) Thyroid 2.02E+01 (30) Thyroid I Primary leakage dircct to thc environment includes the reactor building bypass and reactor building siding pathways.

2Current analysis two hour doses were evaluated at the maximum off site distance of 1900 meters due to the topographical considerations since there is no effective stack height at this distance. Thirty day doses at 8050 meters.

(Reference 4, Table 14.9.4)

BVY 03-119 / Attachment I / Page 41 of 41 VERMONT YANKEE NUCLEAR POWER STATION ALTERNATIVE SOURCE TERM RESPONSE TO RFOUEST FOR ADDITIONAL INFORMATION Table 3-4 (Rcvision I)

Control Rod Drop Accident Radiological Consequence Analysis (rem TEDE)

Offsite Dose Control Room Dose Case EAB LPZ Case I 2.7E-0I 1.8E-02 3.5E-0I Case 2 1.7E-01 2.1 E-02 1.31E-03 Case 3 l.1E-01 6.0E-02 4.8E-02 Case I +Case3 3.8E-01 7.8E-02 4.0E-0I Case 2 + Case 3 2.8E-0I 8.1 E-02 4.9E-02 Regulatory Limit 6.3 6.3 5 Current Analysis 1.5E-02 (25) Gamma 7.4E-03 (25) Gamma 9.7E-03 (5) Gamma (Regulatory Limit) - 2.3E-02 (300) Beta 1.2E-02 (300) Beta 3.7E-01 (30) Beta rem 3.0E+00 (300) Thyroid 1.8E+00 (300) Thyroid 28 (30) Thyroid 1The current analysis values provided for the Control Room correspond to Case I + Case 3 and for the EAB and LPZ to Case 3 (References 9 and 10)

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