ML13310B613

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Forwards Rev 1 to Offsite Dose Calculation Manual & Response to NRC 840418 Comments
ML13310B613
Person / Time
Site: San Onofre 
Issue date: 08/01/1984
From: Medford M
SOUTHERN CALIFORNIA EDISON CO.
To: Crutchfield D
Office of Nuclear Reactor Regulation
Shared Package
ML13310B615 List:
References
TAC-08101, TAC-59403, TAC-8101, NUDOCS 8408030166
Download: ML13310B613 (8)


Text

REGULATURYqNFORMATION DISTRIBUTION SYOEM (RIDS)

ACCESSION NBR:8408030166 DOC.DATE: 84/08/01 NOTARIZED: NO DOCKET #

FACIL:50-206 San Onofre. Nuclear Station, Unit 1, Southern Californ 05000206 AUTHNAME AUTHUR AFFILIATION MEDFORD,M,0.

Southern California Edison Co.

RECIR,,NAME RECIPIENT AFFILIATION CRUTCHFIELD,D.

Operating Reactors Branch 5

SUBJECT:

Forwards Rev 1 to "Offsite Dose Calculation Manual" &

response to NRC 840418 comments.

DISTRIBUTION CODE: A009S COPIES RECEIVED:LTR -ENCL.

SIZE:.

7 0 TITLE: OR/Licensing Submittal: Appendix I NOTES:J Hanchett Icy POR Documents. NRR/DL/SEP Icy, 05000206 OL:03/27/67 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR OR5 BC 01 7

7 INTERNAL; ADM-LFMB 1

0 ELD/HDS2 19 1

0 NRR/DL/ORA8 1

0 NRR/DL/TAPMG 1

1 NRR/DSI/AEB 1

0 ETB 08 1

1 NRR/DSI/RA 10 1

1 REG FILE 04 1

1 RGN5 I

1 R

EPRPB 1

I EXTERNAL; ACRS 11 6

6 LPDR 03 1

1 NRC PDR 02 1

1 NSIC 05 1

1 NTIS 1

1 NOTES:

a 2

TOTAL NUMBER OF COPIES REQUIRED; LTTR 29 ENCL 25

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 M.O. MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING August 1, 1984 (213) 572-1749 Director, Office of Nuclear Reactor Regulation Attention: D. M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Gentlemen:

Subject:

Docket No. 50-206 Offsite Dose Calculation Manual San Onofre Nuclear Generating Station Unit 1

Reference:

Letter, D. M. Crutchfield, NRC, to K. P. Baskin, SCE,

Subject:

Offsite Dose Calculation Manual, dated April 18, 1984 The referenced letter requested SCE to submit corrected pages to the Offsite Dose Calculation Manual (ODCM) to support the NRC staff's review of the radiological effluent technical specifications (RETS).

The 00CM was submitted as part of SCE's December 12, 1983, license amendment application on RETS. The purpose of this letter is to submit corrected pages for the ODCM and to respond to the NRC staff's comments which were enclosed with the referenced letter. SCE's response to the NRC staff's comments are provided in and the corrected pages are provided in Enclosure 2.

If you have any questions or comments, please let me know as soon as possible.

Very truly yours, Enclosures cc:

E. McKenna, Project Manager

3. B. Martin, Region V Administrator A. E. Chaffee, Senior Resident Inspector 6408030166 840801 PDR ADOCK 05000206 P

PDR RESPONSES TO NRC QUESTIONS ON THE OFFSITE DOSE CALCULATION MANUAL SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 The information provided below responds to the NRC's April 18, 1984 comments concerning the Offsite Dose Calculation Manual (ODCM).

The NRC questions and comments below correspond to the order they appeared in the enclosure of the NRC's April 18, 1984 letter.

NRC Comment No. 1 The use of Ceff in Equation 1-1 for the effluent concentration limit, in Equation 1-2 for the total concentration (not necessarily a limiting value),

and in Equation 1-4 for the weighted sum of concentration of gamma emitters, is confusing.

Each of these quantities should be represented by different symbols.

It is suggested that Ceff in Equation (1-1) be changed to CMPC, Ceff in Equation (1-2) be changed to CT, and that no change be made in Equation (1-4).

Response

Ceff in Equation (1-1) has been changed to CMPC.

See revised page 1-1 of the ODCM in Enclosure 2.

NRC Comment No. 2 The use of Ceff in Equation 1-1 for the effluent concentration limit, in Equation 1-2 for the total concentration (not necessarily a limiting value),

and in Equation 1-4 for the weighted sum of concentrations of gamma emitters, is confusing. Each of these quantities should be represented by different symbols.

It is suggested that Ceff in Equation (1-1) be changed to CMPC, Ceff in Equation (1-2) be changed to CT, and that no change be made in Equation (1-4).

Response

Ceff in Equation (1-2) has been changed to CT. See revised page 1-3 of the ODCM in Enclosure 2.

-2 NRC Comment No. 3 Either the summation symbol (Ei) should not be included in the definition of Cy1 for Equation 1-2, or the words should be changed to state that the definition is for "all radionuclides."

Response

The words of the definition have been changed as follows:

EiCyi = The sum of the measured concentrations for each radionuclide, 1, in the gamma spectrum.

See revised page 1-3 of the ODCM in Enclosure 2.

NRC Comment No. 4 The use of Ceff in Equation 1-1 for the effluent concentration limit, in Equation 1-2 for the total concentration (not necessarily a limiting value),

and in Equation 1-4 for the weighted sum of concentrations of gamma emitters, is confusing.

Each of these quantities should be represented by different symbols.

It is suggested that Ceff in Equation (1-1) be changed to CMPC, Ceff in Equation (1-2) be changed to CT, and that no change be made in Equation (1-4).

Response

No change was made to Equation (1-4).

Ceff I correct.

NRC Comment No. 5 Is the monitor on the reheater pit sump or on the oily waste sump?

Response

Radiation monitor, RE-2100, is on the discharge to the reheater pit sump. See revised page 4-2 of the ODCM in Enclosure 2.

NRC Comment No. 6 Are there radioactive liquid inputs to the oily waste sump that would bypass the reheater pit sump?

(See Figure 4-1 on page 4-2).

Response

There are no radioactive liquid inputs to the oily waste sump that would bypass the reheater pit sump. Other non-radioactive inputs to the oily waste sump are the diesel generator drainage sump and the intake structure sump (area 9).

See revised page 4-2 of the ODCM in Enclosure 2.

-3 NRC Comment No. 7 TYPO:

The units should be pCi/cc/cpm.

Response

The units have been corrected to pCi/cc/cpm. See revised page 1-13 of the ODCM in Enclosure 2.

NRC Comment No. 8 TYPO:

The referenced Specification should be 3.15.2 instead of 3.11.1.2.

Response

The referenced Specification has been corrected to 3.15.2. See revised page 1-14 of the 00CM in Enclosure 2.

NRC Comment No. 9 The model Specification limits the gaesous releases to a quantified dose rate. The potential exists for this expression to exceed the dose rates since the expression limits the releases to concentrations instead of dose rates.

Response

Equation (2-1) has been redefined to determine the maximum instantaneous concentration at the detector in terms of a quantified dose rate.

Equation (2-1) now reads:

C < (2120)

MCB (2-1)

(X/Q) (flow rate) where:

C = the maximum instantaneous concentration at the detector in Ci/cc.

MCB = maximum concentration permitted at the site boundary

[lower of ( 5 x 10-4 E F1 K1 (2-la) or 3 x 10-3 E F1 (Li + 1.1 x M1) where:

F1 =

fractional abundance of the ith radionuclide as obtained by sample analysis

-4 Ki =

total body dose conversion factor from Table 2-2, in mrem -m3 MCi -

yr Li =

skin dose conversion factor from Table 2-2, in mrem -m3

.uCi -

yr Mi =

gamma air dose conversion factor from Table 2-2, in mrem -m3 pCi -

yr The other factors of Equation (2-1) remain the same.

See revised pages 2-1, 2-2 and 2-3 of the 00CM in Enclosure 2.

NRC Comment No. 10 The referenced Specification should be 3.16.1 instead of 3.11.2.1.

Response

The referenced Specification has been corrected to 3.16.1.

See revised page 2-2 of the ODCM in Enclosure 2.

NRC Comment No. 11 The referenced Specification should be 3.16.1 instead of 3.11.2.1.

Response

The referenced Specification has been corrected to 3.16.1.

See revised page 2-4 of the 00CM in Enclosure 2.

NRC Comment No. 12 C in Equation 2-3 is not defined.

Response

C in Equation (2-3) has been defined as follows:

C = maximum instantaneous concentration at the detector in pCi/cc, as obtained in Equation (2-1).

See revised page 2-4 of the ODCM in Enclosure 2.

NRC Comment No. 13 The method used to determine the total dose, including direct radiation as required by Specifications 3.17 and 4.17 should be described in the ODCM.

-5

Response

A discussion has been added to the ODCM to determine the total dose including direct radiation. See Section 2.4 of the ODCM in Enclosure 2.

NRC Comment No. 14 Table 2-3 is not referenced in the text.

Response

Table 2-3 is referenced in Section 2.2.2 of the 00CM.

NRC Comment No. 15 Table 2-14 is not referenced in the text.

Response

Table 2-14 has been referenced in Section 2.3.2.1.

See revised page 2-14 of the 0DCM in Enclosure 2.

NRC Comment No. 16 It would be convenient to locate and identify the effluent radiation monitors on Figure 4-1.

Response

Figure 4-1 has been redrawn to identify the location of the effluent radiation monitors. See revised page 4-2 of the ODCM in Enclosure 2.

NRC Comment No. 17 It would be convenient to locate and identify the effluent radiation monitors on Figure 4-2.

Response

Figure 4-2 has been redrawn to identify the location of the effluent radiation monitor. See revised page 4-3 of the 00CM in Enclosure 2.

NRC Comment No. 18 Does plant operation require use of evaporators? If so, what method is used to dispose of the bottoms. This is not indicated on Figure 4-3.

-6

Response

Unit 1 does not use evaporators.

Additional Changes Due to the numerous NRC comments, another review was performed on the 00CM.

Two additional errors were found.

They are:

1. The factor of 0.45 used in Equation (2-2) is an administrative value used to account for potential activity from other gaseous release pathways. This factor is not required for Unit 1 since only one monitor is used on the containment purge. See revised page 2-3 of the ODCM in Enclosure 2.
2. The dose parameter for Co-60 in Table 2-3 should be changed from 7.1 E+1 to 7.1 E+6.

This typographical error has been corrected on revised page 2-17 of the 00CM in Enclosure 2.

GPvN:1878F