ML14183A481

Requests Addl Info Re Review of Offsite Dose Calculation Manual for Plant

ML14183A481
Person / Time
Site:	Robinson
Issue date:	11/25/1992
From:	Le N Office of Nuclear Reactor Regulation
To:	Watson R CAROLINA POWER & LIGHT CO.
References
TAC-M82758, NUDOCS 9301040040
Download: ML14183A481 (36)

Text

?0 UNITED STATES NUCLEAR REGULATORY COMMISSION o

WASHINGTON, D.C. 20555 November 25, 1992 Docket No. 50-261 Mr. R. A. Watson Senior Vice President Nuclear Generation Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602 O

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING REVIEW OF THE OFFSITE DOSE CALCULATION MANUAL -

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 (TAC NO. M82758)

By letter dated February 24, 1992, Carolina Power & Light Company (CP&L) submitted Revision 3 of the Offsite Dose Calculation Manual (00CM) for the Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP), along with the Semiannual.

Radioactive Effluent Release Report in accordance with Technical Specification 6.9.1.4. The initial SHNPP's ODCM was approved by the staff in May 30, 1986, and no major changes were made in the ODCM until a complete ODCM was submitted by CP&L with the semiannual report for January-June 1989 dated August 29, 1989.

Minor changes to improve the clarity and completeness of the ODCM were submitted with the subsequent semiannual reports by letters dated March 2, 1990, February 27, 1991, and February 24, 1992.

The revised SHNPP's ODCM has been reviewed in its entirety by an NRC contractor, the Idaho National Engineering Laboratory (EG&G Idaho, Inc.)

Their discussion and comments regarding the SHNPP's ODCM are contained in the enclosed Technical Evaluation Report (TER) number EGG-PHY-10462. The NRC staff has reviewed the TER and agrees with the contractor that the methods used in the SHNPP's 00CM are, in general, consistent with the staff guidance.

By this letter, the staff requests that CP&L review the enclosed TER and address the Category A comments (Section 5, pp 23-24) within 90 days of receipt of this letter. All other recommended changes to the ODCM are relatively minor; however, the staff deems that CP&L should review and consider these recommended changes as appropriate for inclusion in future ODCM revisions.

The request stated in this letter affects nine or fewer respondents and, therefore, is not subject to Office of Management and Budget review under P. L.96-511.

9301040040 921125 PDR ADOCK 05000261 P

PDR

• e 0

November 25, 1992 Mr. R. A. Watson

- 2 If you have any questions regarding this review, please contact Ms. Antoinette N. Massey at (301) 504-1078, or myself at 301-504-1458.

ORIGINAL SIGNED BY:

Ngoc B. Le, Project Manager Project Directorate II-1 Division of Reactor Projects -

I/II Office of Nuclear Reactor Regulation

Enclosure:

Technical Evaluation Report cc:

See next page DISTRIBUTION:

VDocket File7 NRC/Local PDRs PD II-1 Reading S. Varga G. Lainas E. Adensam N. B. Le S. Little OGC A. N. Massey J. Cunningham ACRS (10)

L. Plisco, EDO E. Merschoff, R-II OFC LA;PT21:DRPE PM:PD21:DRPE 0__2,DRPE NAME S,

Ie NBLe:tms EA sam DATE 11/3 /92 11/24 /92 11/;.f/92 Document Name:

HAR82785.LTR

Mr. R. A. Watson Shearon Harris Nuclear Power Plant, Carolina Power & Light Company Unit 1 cc:

Mr. H. Ray Starling Regional Administrator, Region II Manager - Legal Department U.S. Nuclear Regulatory Commission Carolina Power & Light Company 101 Marietta Street, Suite 2900 P. 0. Box 1551 Atlanta, Georgia 30323 Raleigh, North Carolina 27602 Resident Inspector/Harris NPS Mr. C. S. Hinnant c/o U. S. Nuclear Regulatory Commission Plant General Manager Route 1, Box 315B Harris Nuclear Plant New Hill, North Carolina 27562 Post Office Box 165 New Hill, North Carolina 27562 Mr. Gerald E. Vaughn, Vice President Harris Nuclear Project Mr. Dayne H. Brown, Director Harris Nuclear Plant Division of Radiation Protection Post Office Box 165 N. C. Department of Environmental, New Hill, North Carolina 27562 Commerce & Natural Resources Post Office Box 27687 Mr. H. A. Cole Raleigh, North Carolina 27611-7687 Special Deputy Attorney General State of North Carolina Mr. R. B. Starkey Post Office Box 629 Vice President Raleigh, North Carolina 27602 Nuclear Services Department Carolina Power & Light Company Public Service Commission Post Office Box 1551 State of South Carolina Raleigh, North Carolina 27602 Post Office Drawer 11649 Columbia, South Carolina 29211

ENCLOSURE EGG-PHY-10462 Technical Evaluation Report for the Evaluation of ODCM Revision 3 Shearon Harris Nuclear Power Plant, Unit 1 NRC Docket No. 50-400 NRC License No. NPF-63 T. E. Young T. S. Bohn D. W. Akers Published September 1992 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Under DOE Contract No. DE-ACO7-401001020 FIN No. D6034

ABSTRACT The Offsite Dose Calculation Manual (ODCM) for the Shearon Harris Nuclear Power Plant, Unit I (SHNPP) contains current methodology and parameters used to calculate offsite doses, dose rates, effluent monitoring alarm/trip setpoints, and conduct the radiological environmental monitoring program. The NRC transmitted the most recent complete SHNPP ODCM, Revision 3, updated through Advance Change 3/4, dated December 18, 1991, to the Idaho National Engineering Laboratory for review by EG&G Idaho, Inc. The ODCM was reviewed by EG&G, and the results are presented in this report. It was determined that the ODCM uses methods that are, in general, within the guidelines of NUREG-0133.

However, the following items should be addressed promptly: (a) doses due to liquid-related pathways should include components due to the long-term buildup of radionuclides in Harris Lake, (b) the dilution associated with potable water pathways should be limited, and errors in the calculation of doses to the teen and child age groups should be corrected, (c) input parameters for GASPAR and LADTAP II calculations should be added to the ODCM; GASPAR II should be used for dose calculations, (d) methodology used to determine release rates and total releases of gaseous effluents should added.

70 FOREWORD This report is submitted as partial fulfillment of the "Review of Radiological Issues" project being conducted by the Idaho National Engineering Laboratory for the U. S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation. The U. S. Nuclear Regulatory Commission funded the work under FIN D6034 (Project 5) and NRC B&R Number 20 19 05 03.

This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warrant, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, or of any information, apparatus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately-owned rights.

I

CONTENTS Pge ABSTRACT...........................................................

FOREWORD..........................................................

n1

1. INTRODUCTION.....................................................

1

2. REVIEW CRITERIA....................................................

1

3. RADIOACTIVE EFFLUENT RELEASE ROUTES.............................

3

4. EVALUATION......................................................

11

5.

SUMMARY

23

6. CONCLUSIONS

• ....................................................26

7. REFERENCES 27 FIGURES

1. Liquid waste process flow diagram for SHNPP...............................

4

2. Liquid effluent flow stream diagram for SHNPP................................

5

3. Normal service water flow diagram for SHNPP...................

.6

4. Other liquid effluent pathways at SHNPP....................................

7

5. SHNPP gaseous waste streams, Unit 1......................................

6. Schematic of SHNPP airborne effluent release points.............................

9

7. SHNPP condenser off-gas system at SHNPP..................................

.10 lil

1. INTRODUCTION 1.1 Purpose of Review This document reports the review and evaluation of the most recent version of the Offsite Dose Calculation Manual (ODCM) for the Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP),

submitted by the licensee, Carolina Power & Light Company (CP&L). The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirements.' This review was performed to assess conformity of the SHNPP ODCM to the SHNPP Technical Specifications and current NRC guidelines.

1.2 Plant Specific Background Initial approval of the ODCM for SHNPP is documented in a letter from B. Buckley (NRC) to E. E. Utley (CP&L), dated May 30, 1986.2 No major changes were made in the ODCM until a complete ODCM was submitted with the semiannual effluent report for Jan-Jun 1989.'

Minor changes to improve the clarity and completeness of the ODCM were submitted with the semiannual reports for Jul-Dec 1989,' Jul-Dec 1990,s and Jul-Dec 1991.6 The SHNPP plant is located in a central North Carolina farming area approximately 16 miles SW of Raleigh, North Carolina.

2. REVIEW CRITERIA Review criteria for the ODCM were provided by the NRC in two documents:

NUREG-0472, "Standard Radiological Effluent Controls for PWRs"7 NUREG-0133, "Preparation of RETS for Nuclear Power Plants"'

The following NRC guidelines were also used in the ODCM review:

Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I"'

Branch Technical Position, "General Contents of the Offsite Dose Calculation Manual (ODCM)"'o 1

As specified in NUREG-0472, the ODCM is to be developed by the licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the radioactive effluent systems. As a minimum, the ODCM should provide equations and methodology for the following:

Alarm and trip setpoints on effluent instrumentation Liquid effluent concentrations in unrestricted areas Gaseous effluent dose rates at or beyond the site boundary Liquid and gaseous effluent dose contributions Liquid and gaseous effluent dose projections.

In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the liquid and gaseous management systems. A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

2

3. RADIOACTIVE EFFLUENT RELEASE ROUTES 3.1 Liquid Effluent Release Routes Liquid effluents from SHNPP are diluted by the cooling tower discharge line which has a normal discharge rate of 16.5 cfs. The discharge is to a reservoir, which has a volume of 3.35 x I0 cubic feet. This reservoir appears to be referred to interchangeably as Harris Lake, the Harris reservoir, the Buckhorn Creek impoundment, or the main reservoir. "Harris Lake" will be used to reference the main water storage reservoir. The annual average flow from the Harris Lake to the Cape Fear River is approximately 43 cfs.

Technical Specification 3.3.3.10 requires the following radioactivity monitors with alarm/trip setpoints set to ensure that the limit of TS 3.11.1.1 are not exceeded:

1.

Radioactivity Monitors Providing Alarm and Automatic Termination of Release

a. Liquid Radwaste Effluent Lines.

1) Treated Laundry and Hot Shower Tanks Discharge Monitor.

2) Waste Monitor Tanks and Waste Evaporator Condensate Tanks Discharge Monitor.

3) Secondary Waste Sample Tank Discharge Monitor.

2.

Radioactivity Monitors Providing Alarm But Not Providing Automatic Termination of Release.

a. Normal Service Water System Return From Waste Processing Building to the Circulating Water system.

b. Normal Service Water System Return From the Reactor Auxiliary Building to the Circulating Water System.

Figures 1, 2, 3, and 4, copied from the SHNPP ODCM, show the treatment pathways and release routes of liquid effluents.

3.2 Gaseous Effluent Release Routes Section 3.0 states, "At SHNPP there are four gaseous effluent release points: Plant Vent Stack 1, Turbine Building Vent Stack 3A, and the Waste Processing Building Vent Stacks 5 and SA. These are shown in Figures 3.1, 3.2, and 3.3 along with their tributaries. All gaseous effluent releases at the plant are considered ground level releases." The figures showing the waste streams and release points are reproduced as Figures 5, 6, and 7 in this report.

Technical Specification 3.3.3.11 requires monitors on the Turbine Building Vent Stack, Plant Vent Stack, Waste Processing Building Vent Stack 5, and Waste Processing Building Stack SA, but does not specify whether they are to provide alarm only, or alarm and automatic termination of release.

3

S eaeondawry Dolergentl storage ilrtneverse E

oDemineralize ad ILSh Dri Sm TnsOsmosis SI TanksHTanks FpFpro d

d rReverse Osmosis PDemineralizilon

_S-Storag,9-el Concentrate System TanksF Evaporalor Floor Storagei1'"

R lo Reverse DmnrlzrWaste Monitor DMain Sump Tanks Osmosis-Tanks E quip m eiinit S torage it ai nR everse.

D.

J 6 e mi ine alizer raCoa Drain Sump Tanks FitainOsmosis Toda Bypass Condensale Lo odciiySecondary Polisher Regin -

lrg Tak Filtration Demnineralize Waste Solution Sample Tank Bypass.

High Conductivity Storage Tanks Figure 1. Liquid waste process flow diagram for SHNPP (Reproduced from Figure 2.1-1 of the SHNPP ODCM).

IflEASED LAUNDAHY &

IEATED LAUNjDnY &

1IOf SHOWER TANK 1101 SHIOWEII TANK nEM IWL-3640 z

SECONDARY WASTE 0

0 SAMPLE TANK 3:

0 z

E NDW I

ASIE NEUTtALIZAION TANK TANK O

SETLING ASIN+

ftEM-21WL-3541 LEGEND:

TANK ORt BASIN HlAris LAKE WASTE EVAPORATOR WASTE EVAPOtATOR 0

ftADIATION EFFLUENT MONITOft CONDENSATE TANK CONDENSATE IANKAT

,PM iladoactive liquids are not permited by procedure to be sent to Ihe Waste Neutrallization Basin.

Figure 2. Liquid effluent flow stream diagram for SHNPP (Reproduced from Figure 2.1-2 of the SHNPP ODCM).

e I.

SW RAgC*TOR Auxi sARY BU:L..,

MEAT LDAD$

WASTE PROCESSING MEAT LDADS BUILDING MAIN CONDENSER TURamsE BUILDING CIRCULATING WATER PUMPS LEGEND REM RADIATION EPPLUENT MONITOR CCOUING TOWER SASIN t

10 NSW. PUMPS CM us a0 a

MARRIS LAKCE COOLING TOWER BLOWDOWN NOTE:

Per owa*** ho-ors..

of serse nairr Synean l**er Figure 3. Normal service water flow diagram for SHNPP (Reproduced From Figure 2.1-3 of the SHNPP ODCM).

6

runmE BUItoING r toon onAINs ar Fauttur LIEs ITOILGANO SUM"S HAnA NUtliAWiAMION BASIN S IIG BASIN OUISIDE TANK AREA oAIN EFFLUENT LINE OUSSIDE TANK tnunn AIN

-4~

AntA DRAIN greggM N

IM CAN 3E OIVETED 10 SECONDARY WASI4 ITREATMENT SYSSIM CAN BE oIVEnIEDTO LIO UtDtADWAWSI IREAUMENI SYSIEM HARRMIS LAKE Figure 4. Other liquid effluent pathways at SHNPP (Reproduced from Figure 2.1.4 of the SHNPP ODCM).

Mid-RADIAnall Uf talist711 14feting VA'O-WASIE Otoffspil; fulG HAO-ftrA(Iot AtIXIIIARY PItt OIMbliffL IIAtlOtWIG BLOG WIIGN4-VNPC ftAliE GAS MWIDain,:

TURBINE BLDG VENT STACK 3A sor I-I w-353!S 4

o~

CONDENSER VOL AREA T

CotSIISER VACUUM PUMP ASTE PROCESSING BLDG VENT STACK 5 RMI-WV-3546-1 (WilCM)ftM RE) flM-sWV-3546 WPO 1101 & COLD LAUNDRY e

• R YI W

OFFICE AREA EXHAUST

-1 W O COIlInOL ROOM SMOKE EXHAUST WPO OFFICE AREA WPO GENERAL AREA EXHAUST PB CHILLER ROOM4 EXHAUST WASTE GAS DECAY TANKS WASTE PROCESSING AREAS FILTERED EXHAUST 1

WAS1EiPROCESSING BLDG VENT STACK 5A]

coRM71WV-354J-1 (1WGM)

RH e-jIARE14-IwV-3547 W

SWITCIIGEAR ROOM EXHAUST WPO IVAC EQUIP. ROOM EXHAUST a

WPO PERSONNEL HANDLING FACILITY EXHAUST I

WPO HOT & LOW ACTIVITY EXHAUST P

LAD AREA EXHAUST

[PLANT VENT STACK 1 PM-ZIAv-3509-IsA wnc )

REM-1LT-350t n

REM REM-IAV-3509A CONTAINMENT PRE ENTtY PURGE FHl NORMAL EXHAUST NORTH REM-ILT-3531 REM 1 RAI NORMAL EXHAUST f0ia NORMAL EXHAUST SOUTH RE-SAV-3532A REM-L-3506 RAD MERGNCYEXHAST

~

i4-AV-5~28REMFIIO NORMAL EXHAUST (OPER. FL) SOUITH RAO EMERGENCY EXHAUST EM-IAV-3320350 RAD VENTILAION SYSTEM fiT IOiMAL EXAUST (OER. FL) SOUTH HYDROGEI PURGE RM CM-IFL-350BA-SA RAO SMOKE PURGE ACM-lFL-350n8-IUS REMil NIOEMRMALC EXHAUSTOT RA0 PURGE EATO Figure 5. SHNPP gaseous waste streams, Unit I (Reprooduced from Figure 3.1 of the SHNPP ODCM).

8-

.IIV.3s36.II IIGM)

IUAM cuill.

MUAINj VALVE ILIDFANIEWeioe WIDE "ANGIE GAS MO'N6IOIU BLIlotA"G

-101 I6C

• IION 1 F LUC"I MooIon

'C0#DOENSMf VACUuMj Fwurt orLwg.y InIATMINr AIMtosrilon SYStEM Figure 6. Schematic of SIINPP airborne effluent release points (Reproduced from Figure 3.2 of the SHNPP ODCM).

Gi AOU

$usI I

MAI" VALVE ELINO 0FLANtGE WRM ivinE flANGE G.k$ Motailon fit" fIANIIA I50#4 EIFLUENI1 mol,,,on

• COlJO I tlS I n V ACUUMI PtivrflfL,INI I[Alffr AIMOSrIIlflE SYS IEM Figure 7. Condenser off-gas system at SHNPP (Reproduced from Figure 3.3 of the SIJNPP ODCM).

0

4. EVALUATION As stated by the licensee: "The Off-Site Dose Calculation Manual (ODCM) provides the information and methodologies to be used by Shearon Harris Nuclear Power Plant (SHNPP) to ensure compliance with Technical Specifications 3.3.3.10, 3.3.3.11, 3/4.11.1, 3/4.11.2, 3/4.11.4, 4.12.1, 4.12.2, 4.12.3, and 6.9.1 of the SHNPP Operating License. These specifications are those related to normal liquid and gaseous radiological effluents, environmental monitoring, and reporting. They are intended to show compliance with 10CFR20-based requirements and 10CFR50.36a, Appendix I of 10CFRSO, and 40CFR190 in terms of appropriate monitoring instrumentation and set points, dose rate, and cumulative dose limitations. Off-site dose estimates from non-routine releases will also be included in the cumulative dose estimates for the plant to comply with Appendix I of 10CFR50.

The ODCM is based on 'Westinghouse Standard Technical Specifications' (NUREG 0452),

'Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants' (NUREG 0133), and guidance from the United States Nuclear Regulatory Commission (NRC).

Specific plant procedures for implementation of this manual are presented in the SHNPP Plant Operating Manual. These procedures are utilized by the operating staff of SHNPP to ensure compliance with technical specifications."

The ODCM is generally well organized and complete, but some additions are needed.

4.1 Liquid Effluent Monitor Setpoints Pursuant to Technical Specification (TS) 3.3.3.10, Sections 2.1.1 and 2.1.2 of the ODCM contain methodology to determine the setpoints of the liquid effluent radioactivity monitors to ensure that the limits of TS 3.11.1.1 are not exceeded. Technical Specification 3.11.1.1 requires, "The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 5.1-3) shall be limited to the concentrations specified in 10 CFR 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10- microCurie/ml total activity."

Radioactivity monitors for batch releases have both alert alarm and high alarm setpoints. The alert alarm setpoint provides alarm only; the high alarm setpoints provide both alarm and automatic termination of release. Tank release rates are adjusted to dilute the tank activities to 50 percent of the allowable concentrations at the release point to Harris Lake.

In addition to the radioactivity monitors required by TS 3.3.3.10, Section 2.1.3 requires monitors providing automatic termination of release on the normally non-radioactive Outdoor Tank Area Drain Effluent Line and the Turbine Building Floor Drains Effluent Line.

11

If setpoints for the batch release monitors were determined using Eq. 2.1-7 the monitors would alarm intermittently or continuously. because the setpoints are at the concentration of the undiluted liquid effluents in the line. The instructions for determining an alarm setpoint should require that it correspond to a concentration greater than that in the effluent line. Similarly, Eq. 2.1-8, to determine the alert setpoint, should also define a setpoint corresponding to a concentration greater than that in the liquid effluent line. Therefore, the monitor would always indicate an alert status.

Both the alarm and alert setpoint determination methodologies described in the ODCM should be corrected to remove the problem of spurious alarms. Note: When the setpoints are increased to prevent spurious alarms, the tank release rates (RR) will need to be reduced to prevent the concentrations in the releases from exceeding the specified limits.

The long-term buildup of radionuclides in Harris Lake should be considered in the calculation of setpoints for the liquid effluent radioactivity monitors, since the concentration in the effluent stream is the sum of the steady-state concentration in the lake and the concentration due to the liquid radwaste added. An estimate of the steady-state concentration in Harris Lake, using data from the Final Environmental Statement," the completely mixed model in Regulatory Guide 1.113,"2 and release data for the first six months of 1989 indicates that for this period the true concentrations of radionuclides in the liquid effluents are 5 to 10 percent larger than those determined by the methodology of the ODCM. The safety factor of 2 included in Eq. 2.1-2 provides sufficient margin to prevent the limits of TS from being exceeded when the present ODCM methodology is used.

This problem is discussed more completely in Section 4.5 of this report.

Section 2.1.1 should require at least administrative controls to prevent simultaneous batch releases.

The first sentence of Subsection 5, Section 2.1.1 is true, but implies that the concentration of each radionuclide is permitted to be near the 10 CFR 2013 concentration. The concentration limit should be restated in the terms used in Item 1 of "NOTE" at the end of Appendix B to 10 CFR 20; or the equivalent, Item 4 of "NOTE" at the end of Appendix B to §§ 20.1001-20.2401 of 10 CFR 20."

The meaning of HSP. in Eq. 2.1-7 would be clarified if it were identified as the monitor setpoint in "equivalent Cs-137 concentration." If this change is not appropriate, the meaning of HSP. should be more completely defined.

The methodology to determine setpoints of the liquid effluent radiation monitors is within NRC guidelines, since the concentration of radionuclides in the effluents will not exceed the limits of TS [3.11.1.1 because of the factor of 2 safety margin. However, the ODCM should identify the effect of radionuclide buildup in the lake and the resulting contribution to the concentration of radionuclides in the effluents.

12

4.2 Gaseous Effluent Monitor Setpoints Pursuant to TS 3.3.3.11, Sections 3.1 through 3.1.3 contain methodology to determine gaseous effluent monitor setpoints to ensure that the dose rate limits of TS 3.11.2.1.a are not exceeded.

Technical Specification 3.11.2.1.a requires, "The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 5.1-1) shall be limited to the following:

a.

For noble gases: Less than or equal to 500 mrems/yr to the total body and less than or equal to 3000 mrems/yr to the skin, and.... "

The methodology for determining setpoints of the gaseous effluent radiation monitors considers simultaneous releases from all release points and the maximum release rate is based on the most restrictive of the total body and skin dose rates. Therefore, the methodology is within NRC guidelines.

4.3 Concentrations in Liquid Effluents Technical Specification 4.11.1.1.2 requires that the results of the radioactivity analyses required by TS 4.11.1.1.1 be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits of TS 3.11.1.1.

Pursuant to TS 4.11.1.1.2, Section 2.1.1.8 requires a post-release verification of compliance with TS 3.11.1.1. The requirements of TS 3.11.1.1 are given in Section 4.1 of this report.

For clarity, the definition of C, for Eq. 2.1-14 should require that the concentration of radionuclide "i" be determined by the analyses specified in Table 4.11-1. Also, the definition of Vk should specify "undiluted liquid effluent."

The determination of concentrations in the liquid effluents does not consider the buildup of radionuclides in Harris Lake. Applying the methodology of Regulatory Guide 1.113 will add 5 to 10 percent to the calculated concentration in released liquid effluents. These larger calculated concentrations will not result in an indication that the concentration limits are exceeded because a safety factor of 2 is included in Eq. 2.1-2, for the minimum acceptable dilution factor. The problem of the buildup of radionuclides in the lake is discussed in more detail in Section 4.5 of this report.

The licensee's methodology to assure that the concentrations at the point of release are maintained within the limits of Specification 3.11.1.1 is within NRC guidelines. However, the recommended clarifications should be considered.

13

4.4 Dose Rates Due to Gaseous Effluents Technical Specification 3.11.2.1 requires, "The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 5.1.3-1) shall be limited to the following:

a.

For noble gases: Less than or equal to 500 mrems/yr to the total body and less than or equal to 3000 mrems/yr to the skin, and

b.

For iodine-131, iodine-133, tritium, and for all radionuclides in particulate form with half lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ."

4.4.1 Dose Rates Due to Noble Gases Technical Specification 4.11.2.1.1 requires that the dose rate due to noble gases in gaseous effluents be determined to be within the limits of TS 3.11.2.1 in accordance with the methodology and parameters in the ODCM.

Pursuant to TS 4.11.2.1.1, Section 3.2.1 of the ODCM contains methodology to calculate the total body and skin dose rates due to releases of noble gases. This section contains the following statement: "The gaseous effluent monitor set points are utilized to show pre-release compliance with Technical Specification 3.11.2.1. However, because they may be based upon a conservative (GALE Code) mix of radionuclides, when using Table 3.1-1, the possibility exists that the set points could be exceeded and yet 10CFR20-based limits may actually be met. Therefore, the following methodology has been provided in the event the high alarm set points are exceeded, a determination may be made as to whether the actual releases have exceeded the dose rate limits of Technical Specification 3.11.2.1." Also, for each monitor, the high set point identified in Section 3.1.1.5 is at one-half the release rate allotted to the release route being monitored. Therefore, each monitor could alarm even though the total release rate from the site may be only slightly more than one-half the limit.

The description of the methodology in Section 3.2.1 is incomplete. The definition of Q, for Eq. 3.2-1 and 3.2-2 does not specify how the release rates of radionuclides are to be determined.

Methodology should be added to determine the Q,'s. The Q1,'s should include releases from all release points. This methodology should also include a commitment to determine the distribution of noble gas radionuclides by using the sampling and analyses required by TS Table 4.11.2, if releases are sufficiently large to make this possible. It should also describe the method used to determine the total activity if the GALE code distribution is used.

If appropriate methodology is added, as recommended in the previous paragraph, the licensee's methodology to determine that the dose rates due to noble gases in gaseous effluents are within the limits of TS 3.11.2.1 will be within NRC guidelines.

14

4.4.2 Dose Rates Due To Other than Noble Gases Pursuant to TS 4.11.2.1.2, Section 3.2.2 contains methodology to determine that the dose rate due to iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents are within the limits of TS 3.11.2.1.

Technical Specification 3.11.2.1 limits the dose rate due to these radionuclides to less than or equal to 1500 mrem/yr to any organ.

The methodology of Section 3.2.2 is based on the interpretation of TS 3.11.2.1.b contained in the basis statements of NUREG-0473 the SHNPP TS; i.e., that compliance with TS 3.11.2.1.b may be demonstrated by showing that the dose rate to the thyroid of a child via the inhalation pathway does not exceed 1500 mrem/yr.

A survey of semiannual effluent reports indicates that radioiodine and particulate releases have historically been below LLD values. Section 3.2.2 states, "The radionuclide mix is again based upon the normal operational source terms calculated using the GALE code and presented in Table 3.2-1 as a function of release point." It is not clear how the magnitudes of releases are determined; i.e., whether absolute values from Table 3.2-1 are used, or if the magnitude is scaled from some measurement. The dose rate to the thyroid of a child should be based on sampling and analyses specified in Table 4.11-2, as required by TS 4.11.2.1.2. In addition to the normal weekly iodine and particulate samples, the more frequent samples following shutdown, startup, or THERMAL POWER changes exceeding 15% of RATED THERMAL POWER within a 1-hour period should be used when required by Notation 7 of TS Table 4.11-2.

To be within NRC guidelines, the methodology to determine that the organ dose rate is within the limit of TS 3.11.2.1.b should be based on releases determined by the sampling and analysis specified in Table 4.11-2. Therefore, details of the method used to determine the magnitude of the radiolodine, tritium, and particulate releases should be added to Section 3.2.2.

4.5 Dose Due To Liquid Effluents Pursuant to Technical Specification 4.11.1.2, Section 2.2.1 of the ODCM contains methodology to determine the cumulative dose contributions from liquid effluents for the current calendar quarter and current calendar year. Technical Specification 3.11.1.2 requires, "The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released to UNRESTRICTED AREAS (see Figure 5.1.-3) shall be limited:

a.

During any calendar quarter to less than or equal to 1.5 mrems to the total body and to less than or equal to 5 mrems to any organ, and 15

b.

During any calendar year to less than or equal to 3 mrems to the total body and to less than or equal to 10 mrems to any organ."

The following errors/oversights should be corrected in Section 2.2.1:

1.

The dilution flow for potable water given by the product of the "applicable factor" (A,=95),

the Cooling Tower blowdown flow (Vd=10.47 cfs), and the dilution factor (D,=13.95) is 13,950 cfs. This is 4.46 times the average river flow (3125 cfs) and 194 times the 7-day minimum river flow (72 cfs). If the methodology now in Section 2.2.1 is retained as part of the dose calculation, the dilution flow should be restricted to no more than the flow of the Cape Fear River at the time of the waste discharge. However, an alternate methodology is recommended in the discussion of Item 3 below.

2.

The methodology of Section 2.2.1 to calculate the dose due to fish consumption does not account for the buildup of radioactive material in Harris Lake. The model described in Regulatory Guide 1.113, Appendix A, Section 5.a(1) can be used to estimate this buildup. For a non-decaying substance, the expression for the concentration in the lake is: Co = W t where Co is the steady-state concentration in the lake (Ci/ft3), W is the rate of addition of radioactive material to the lake (Ci/s), and qb is the rate of blowdown from the lake (ft3/s).

This expression is based on assumptions that the radioactive material is completely mixed on the lake (instead of the 80% mixing given in UFSAR Section 11.2.3) and that there is no decay of any of the radionuclides. The Regulatory Guide also gives expressions for the concentration which account for the half-lives of the radionuclides. Section 4.3.2.1 of the Final Environmental Statement gives 43 cfs as the discharge from the lake, q,, for 1-unit operation.

With these assumptions, the steady-state concentration in the lake is: Co = W(Ci/s)/43(ft3/s).

Long-term average values should be used for W and q,. With the very conservative assumptions of no decay and infinite operating time, a quick estimate shows that the dose due to the equilibrium concentration of radionuclides in the lake is approximately 23 times the dose calculated using only the methodology of the ODCM. Proper accounting for the radioactive decay after discharge to the lake will reduce the dose due to the equilibrium concentration of H-3 by 10 to 15 percent. This dose will also be reduced by including evaporation from the lake and consumptive use of water in the discharge rate, q,. for the tritium calculation. The calculated doses due to fish consumption should be the doses calculated with the present methodology plus the doses due to the steady-state concentrations in the lake; i.e., Co = W/qb or concentrations corrected for decay.

3.

The concentration of radionuclides at the point of consumption of potable water does not consider the mixing of effluents in the lake water or holdup time in the lake, and is not a function of the rate of discharge from Harris Lake to the Cape Fear River. The doses due to drinking water at Lillington should be calculated using the concentration of radionuclides in 16

the lake and the discharge from the lake to the river. Combining appropriate parts of Eq. 2.2-1 and 2.2-3 to cnlculate the dose due to water consumption gives:

D9 - 1[(1.14E+05) 730 (43 cfs/FR) DF, At Col eN, where:1.14E+05, 730, DF, Az, and t, are as defined in Section 2.2.1.

43 cfs -

the blowdown flow from the Harris Lake dam, ft'/s; F, = the flow of the Cape Fear River for the time period of the dose calculation, ft3/s; A = the time period for which the dose is calculated, s.

The 1991 doses to the teen and child age groups due to drinking water are reported as zero in the semiannual effluent report for Jul-Dec 1991. There is apparently an error that should be corrected in the program used to calculate these doses.

Concerning the assessment of doses due to radioactive liquid and gaseous effluents released during the previous calendar year, Technical Specification 6.9.1.4 requires, "The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM)." Section 1.0 of the ODCM states, "The assessment of annual radiation doses to members of the public from radioactive liquid and gaseous effluents from the plant is estimated using the NRC codes LADTAP II and GASPAR using concurrent meteorology for the report period." If used properly, LADTAP II should yield doses consistent with the methodology and parameters of the ODCM.

Doses due to liquid effluents were calculated using the methodology and parameters of the ODCM and the results were compared with the doses reported in Appendix 9, Enclosure 3, Table 1 of the Jul-Dec 1991 semiannual effluent report. For the fish consumption pathway, the calculated doses, except for the thyroid and GI-LLI, were between 53 and 60 percent of the reported doses. The calculated doses for the thyroid and GI-LLI were, respectively, 250% and 175% of the reported doses. For the potable water pathway, the calculated doses were between 14 and 18 percent of the reported doses.' These results indicate that there may be two types of inconsistencies between the ODCM methodology and the LADTAP II calculations. First, incompatible dilution factors could result in different magnitudes of the doses and different ratios of the doses due to the fish and

• Similar calculations were performed using the methodology of the ODCM and dilution factors reported in the Jul-Dec 1991 semiannual effluent report (10 and 66.7, respectively, for the fish and potable water pathways). The doses calculated using these dilution factors were higher by factors of 4 and 8, respectively, than the fish and potable water pathway doses using the dilution factors from the ODCM.

17

potable water pathways. Second, differences in half-lives, bioaccumulation factors, transit times, or dose factors could give the inconsistencies between the doses to the thyroid and GI-LLI and the other organ and total body doses. The inconsistencies between the methodology and parameters of the ODCM and the calculations with LADTAP II should be resolved if LADTAP I is to be used to calculate reported doses. Input parameters for LADTAP II should be included in the ODCM.

To be within NRC guidelines, the methodology of Section 2.2.1 should: (a) account for the buildup of radionuclides in Harris Lake, (b) use a more realistic methodology to determine the dose contributions due to potable water consumption; i.e., the maximum dilution for potable water should be limited by the flow of the Cape Fear River, (c) the error in the dose calculation for water consumption by the teen and child age groups (which gives zero doses) should be corrected, (d) the inconsistencies between the methodology of the ODCM and LADTAP I calculations should be eliminated, and (e) input parameters for LADTAP II should be included in the ODCM.

4.6 Dose Due to Gaseous Effluents Concerning the assessment of doses due to radioactive liquid and gaseous effluents released during the previous calendar year, Technical Specification 6.9.1.4 requires, "The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM)." Section 1.0 of the ODCM states, "The assessment of annual. radiation doses to members of the public from radioactive liquid and gaseous effluents from the plant is estimated using the NRC codes LADTAP II and GASPAR using concurrent meteorology for the report period." The most recent version of the GASPAR code should be used for calculations. If used properly, GASPAR II should yield doses consistent with the methodology and parameters of the ODCM.

4.6.1 Dose Due To Noble Gases Pursuant to TS 4.11.2.2, Section 3.3.1 (mislabeled on p. 3-21) contains methodology to determine the cumulative air dose contributions due to noble gases for the current calendar quarter and current calendar year. Technical Specification 3.11.2.2 requires, "The air dose due to noble gases released in gaseous effluents, to areas at and beyond the SITE BOUNDARY (see Figure 5.1.3) shall be limited to the following:

a.

During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation and,

b.

During any calendar year: Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation."

18

Methodology to determine the magnitude of the total releases of noble gases (the Q1,'s and q,,'s) should be included in Section 3.3.1.

The word "average" should be replaced with "total" in the definitions of the noble gas releases for Eq. 3.3-1 and 3.3-2; i.e., the definitions from NUREG-0133 should be corrected.

A definition of M for Eq. 3.3-1 should be added to Section 3.3.1.

Section 3.3.1 should include a commitment to determine the distribution of noble gas radionuclides from the sampling and analyses specified in TS Table 4.11-2 if this is feasible.

Doses due to noble gases in gaseous effluents were calculated using the methodology and parameters of the ODCM and the results were compared with the doses reported in Appendix 9. Enclosure 3, Table 3.A of the Jul-Dec 1991 semiannual effluent report. The calculated beta-air and gamma-air doses were, respectively, 79%-93% and 115%-178% of the doses reported in the ODCM, depending on the X/Q's chosen for the calculation. According to Section 1.0 of the ODCM, the reported doses were calculated using GASPAR. If GASPAR is to be used to calculate the doses reported in the semiannual reports, the GASPAR calculations should be correlated with the ODCM methodology and parameters, so equivalent doses are calculated. Also, all GASPAR parameters used for the calculations should be included in the ODCM.

The licensee's methodology to determine the gamma and beta air doses due to gaseous effluents is within NRC guidelines if the methodology used to determine the magnitude of noble gas releases is described and all parameters used for GASPAR calculations are added to the ODCM. The recommendations for other, relatively minor, additions should be considered.

4.6.2 Dose Due To Other Than Noble Gases Pursuant to TS 4.11.2.3, Section 3.3.2 (mislabeled on p.3-25) of the ODCM contains methodology to determine cumulative dose contributions for the current calendar quarter and current calendar year for iodine-131, iodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days. Technical Specification 3.11.2.3 requires, "The dose to a MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released to areas at and beyond the SITE BOUNDARY shall be limited to the following:

a.

During any calendar quarter-Less than or equal to 7.5 mrems to any organ and,

b.

During any calendar year: Less than or equal to 15 mrems to any organ.

19

Section 3.3.2 describes a method for calculating the maximum organ dose due to releases of radioactive material other than nohle gases in gaseous effluents that gives a conservative estimate.

The calculation is performed for the location of highest offsite D/Q using all possible pathways.

This methodology can reasonably be expected to give a calculated dose that is somewhat too high, but is acceptable as a method of showing that the limits of TS 3.11.2.3 are not exceeded. The advantage of the method is that calculations do not need to be changed to account for changes that may otherwise be required based on the results of the Land Use Census.

Section 3.3.2 states, "In the determination of the limiting location, the radionuclide mix of radiolodines amd particulates may be based upon the source terms calculated using the GALE Code." However, neither the method used to determine the magnitude of radionuclide releases or distributions are described in this section. The methods used to determine the quantities and distributions of radionuclides other than noble gases released from the site, and used in the dose calculations, should be described in Section 3.3.2. Both the quanities and distributions should be based on the sampling and analyses required by TS 4.11.2.1.2.

Doses due to gaseous effluents other than noble gases were calculated using the methodology and parameters of the ODCM, and the results were compared with the doses reported in Appendix 9,, Table 2.A of the Jul-Dec 1991 semiannual effluent report. The calculated total body and organ doses were within +/- 20% of the doses reported in the ODCM. According to Section 1.0 of the ODCM, the reported doses were calculated using GASPAR. If GASPAR is to be used to calculate the doses reported in the semiannual reports, the GASPAR calculations should be correlated with the ODCM methodology and parameters, so equivalent doses are calculated. All parameters used for the GASPAR calculations should be included in the ODCM.

The licensee's methodology to calculate the maximum organ dose due to the release of radioactiv%

material other than noble gases will be within NRC guidelines if all parameters required for the GASPAR calculations are added to the ODCM and the method used to determine the magnitudes and radionuclide distributions of releases are described.

4.7 Dose Projections Pursuant to TS 4.11.1.3.1 and TS 4.11.2.4.1, Sections 2.2.2, 3.3.1.2, and 3.3.2.2 contain methodology to project doses due to radioactive liquid and gaseous effluents. The methodologies to project doses include anticipated operational occurrences, and are therefore within NRC guidelines.

20

.~

U 0

4.8 Diagrams of Effluent Release Routes The ODCM contains simplified flow diagrams defining the treatment paths and the components of the radioactive liquid and gaseous waste management systems, as recommended by the Branch Technical Position, dated February 8, 1979. Therefore, the ODCM is within NRC guidelines with respect to diagrams of effluent release routes.

4.9 Total Dose Pursuant to TS 4.11.4.1 and TS 4.11.4.2, Section 6.0 contains methodology to evaluate compliance with TS 3.11.4. Technical Specification 3.11.4 requires, "The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mrems to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems."

Item 68 of Appendix 4 to that semiannual report, "Changes to the Off-site Dose Calculation Manual (ODCM) Technical Specification 6.14," states, "Revision 3 provides an improvement in the estimation of offsite doses by indicating that the Regulatory Guide 1.109 and NUREG 0133-based NRC codes LADTAP II and GASPAR should be used for this purpose. Section 6.1.1 discusses the use of LADTAP II and GASPAR for calculations that may be required by TS 3.11.4, but does not require their use. This section should include a requirement that any report of calculations required by TS 3.11.4 will include a complete statement of the assumptions and parameters used in the calculation.

The dose due to direct radiation associated with plant operation will be determined by comparing quarterly TLD measurements with four-year pre-operational TLD measurements.

The licensee's methodology to determine the uranium fuel cycle dose is considered to be within NRC guidelines if a commitment is added to include a comprehensive statement of the assumptions and parameters used in any report required by TS 3.11.4.

4.10 Environmental Monitoring Program Pursuant to Technical Specification 4.12.1, Section 4.0 identifies locations from which radiological environmental samples are to be collected.

Table 4.1 identifies radiological environmental monitoring locations, sampling and collection frequency, and analysis type and frequency for the monitoring program. Figure 4.1-1 shows the exclusion boundary surrounding SHNPP. The maps of Figures 4.1-2, 4.1-3, and 4.1-4 show the 21

locations of the various sampling points and TLD locations. The sampling locations in these figures are keyed to the descriptions of locations in Table 4.1 and Figure 4.1-5, which is a more concise table of sampling locations.

Section 6.0 completely describes the environmental monitoring program required by TS 4.12.1, and is therefore within NRC guidelines.

4.11 Interlaboratory Comparison Program Section 5.0 describes the licensee's Interlaboratory Comparison Program, as required by TS 4.12.3, and is therefore within NRC guidelines.

22

5.

SUMMARY

Deficiencies and suggestions are summarized below in four categories of decreasing importance.

The items in Category A identify the most serious deficiencies, including omissions that cause uncertainty as to whether the proper methodology is used in the ODCM. Category B contains less serious deficiencies, and Category C contains minor deficiencies and editorial recommendations.

Category D contains suggestions for changes the licensee may wish to make to simplify calculations, update data, or remove excess conservatism from the methodology. The number in parentheses at the end of each item [e.g., (4.3)] refers to the section in this review that contains a discussion of the item.

Category A. These items identify errors or omissions that may result in calculated doses, dose rates, or concentrations that are lower than those that would be obtained if the deficiencies were corrected.

Therefore, they should be addressed promptly.

1. In the methodology of Section 2.2.1, the dilution flow used for potable water consumption should be limited to the flow of the Cape Fear River. (Note: An alternate dose calculation methodology is recommended.) (4.5)

2. The methodology of Section 2.2.1 to determine doses via the fish pathway should account for the fact that the fish live in the steady-state radionuclide concentrations of Harris Lake.

Regulatory Guide 1.113 contains methodology to determine the steady-state concentrations.

(4.5)

3. The methodology of Section 2.2.1 to determine doses via the potable water pathway should be based on releases from Harris Lake at the steady-state radionuclide concentrations. (4.5)

4. The error in the dose calculation for water consumption by the teen and child age groups (which gives zero doses) should be corrected. (4.5)

5. The inconsistencies between the methodology of the ODCM and LADTAP II calculations should be eliminated. (4.5)

6. Input parameters for LADTAP II should be included in the ODCM. (4.5)

7. The method used to determine the release rates and total releases of the GALE code distribution of noble gas radionuclides should be described in Sections 3.2.1 and 3.3.1. (4.4.1 and 4.6.1)

8. The methods used to determine the release rates and total releases of radionuclides other than noble gases should be described in Sections 3.2.2 and 3.3.2. These should be based on the sampling and analyses required by TS 4.11.2.1.2. (4.4.2 and 4.6.2) 23

9. The method used to determine the radionuclide distribution of the total releases of radionuclides other than noble gases should be addressed in Section 3.3.2. (4.6.2)

8. All GASPAR parameters used for the calculations of doses due to noble gases should be included in Section 3.3.1. (4.6.1)

9. The most recent version of the GASPAR code, GASPAR II, should be used for calculations of doses due to gaseous effluents. (4.6)

10. All GASPAR parameters used for the calculations of doses due to radionuclides other than noble gases should be included in Section 3.3.2. (4.6.2)

Category B. The items below concern information that should be added to make the ODCM more complete, prevent erroneous interpretation of the methodology, or correct methodology that is erroneous.

1. The methodology in Section 2.1.1 to determine setpoints of the liquid effluent radioactivity monitors should define setpoints corresponding to concentrations greater than those existing in the undiluted liquid effluents, so continuous alarm does not occur. (4.1)

2. Section 2.1.1 should require at least administrative controls to prevent simultaneous batch releases. (4.1)

3. In Section 2.1.1, the long-term buildup of radionuclides in Harris Lake should be considered in the calculation of setpoints for the liquid effluent radioactivity monitors. (4.1)

4. The definition of C, for Eq. 2.1-14, Section 2.1.1, should require that the concentration of radionuclide "i" be determined by the analyses specified in Table 4.11-1. (4.3)

5. The definition of V for Eq. 2.1-14, in Section 3.1.1, should specify "undiluted liquid effluent."

(4.3)

6. Sections 3.2.1 and 3.3.1 should include commitments to determine the distribution and release rates of noble gas radionuclides in gaseous effluents from the sampling and analyses specified in TS Table 4.11-2 if this is feasible. (4.4.1 and 4.6.1)

7. Section 6.1.1 should include a requirement that any report of calculations required by TS 3.11.4 will include a complete statement of the assumptions and parameters used in calculating doses for the report. (4.9) 24

Category C. The items in this category indicate omissions and editorial deficiencies that are not likely to cause significant problems:

1. The first sentence of Subsection 5, Section 2.1.1 should be restated in the terms used in Item 1 of the Note at the end of 10 CFR 20, Appendix B. (4.1)

2.

The HSP. in Eq. 2.1-7 should apparently be identified as the monitor setpoint in "equivalent Cs-137 concentration." (4.1)

3.

A definition of K for Eq. 3.3-1 should be added to Section 3.3.1. (4.6.1)

4.

The word "average" should be replaced with "total" in the definitions of the noble gas releases for Eq. 3.3-1 and 3.3-2; i.e., the definitions from NUREG-0133 should be corrected. (4.6.1)

Category D. The following items concern methodology and parameters that the licensee may wish to change because the change may simplify calculations, remove unnecessary conservatism in the calculations, or make use of recent data. No Category D items were identified.

25

6. CONCLUSIONS The SHNPP ODCM, Revision 3, uses documented and approved methods that are, in general, consistent with the methodology and guidance of NUREG-0133 and Regulatory Guide 1.109. The ODCM contains essentially all of the required methodology. However, because of significant omissions and errors, it is recommended that the NRC request another revision of the ODCM to address the most significant deficiencies identified in the review.

The most important corrections and additions needed are summarized below:

1. The methodology of Section 2.2.1 to determine doses via the fish pathway should account for the fact that the fish live in the steady-state radionuclide concentrations of Harris Lake.

Regulatory Guide 1.113 contains methodology to determine the steady-state concentrations.

2. In the methodology of Section 2.2.1, the dilution flow used for potable water consumption should be limited by the flow of the Cape Fear River. Also, see the following item.

3. The methodology of Section 2.2.1 to determine doses via the potable water pathway should be based on releases from Harris Lake at the steady-state radionuclide concentrations.

4. The error in the dose calculation for water consumption by the teen and child age groups (which gives zero doses) should be corrected.

5. The inconsistencies between the methodology of the ODCM and LADTAP II calculations should be eliminated; and input parameters for LADTAP II should be included in the ODCM.

6. Methodology to determine the magnitude of the total releases of radioactive materials in gaseous effluents (the Qg,'s and q1,'s) should be included in Sections 3.3.1 and 3.3.2.

7. All GASPAR parameters used for the calculations of doses due to gaseous effluents should be included in Sections 3.3.1. and 3.3.2.

8. The most recent version of the GASPAR code, GASPAR II, should be used for calculations of doses due to gaseous effluents.

26

7.REFERENCES

1.

Title 10, Code of Federal Regulations, Part 50, "Domestic Licensing of Production and Utilization Facilities"

2.

Letter from B. Buckley (NRC) to E. E. Utley (CP&L);

Subject:

Shearon Harris, Unit I Offsite Dose Calculation Manual; May 30, 1986.

3.

Letter from R. B. Richey (CP&L) to Document Control Desk (NRC);

Subject:

Semiannual Radioactive Effluent Release Report; August 29, 1989.

4.

Letter from R. B. Richey (CP&L) to NRC Document Control Desk (NRC);

Subject:

Semiannual Radioactive Effluent Release Report; March 2, 1990.

5.

Letter from R. B. Richey (CP&L) to NRC Document Control Desk (NRC);

Subject:

Semiannual Radioactive Effluent Release Report; February 27, 1991.

6.

Letter from R. B. Richey (CP&L) to NRC Document Control Desk (NRC);

Subject:

SemiAnnual Radioactive Effluent Release Report; February 24, 1992.

7.

"Standard Radiological Effluent Controls for Pressurized Water Reactors"; NUREG-0472, Revision 3, Draft 9, August 28, 1989.

8.

"Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications," NUREG-0133, October 1978.

9.

"Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I," Regulatory Guide 1.109, Revision 1, October 1977.

10.

"General Contents of the Offsite Dose Calculation Manual", Revision 1, Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.

11.

"Final Environmental Statement Related to the Operation of Shearon Harris Nuclear Power Plant, Units 1 and 2, Dockets Nos. STN 50-400 and STN 50-401, Carolina Power and Light Company," Nuclear Regulatory Commission, Washington, DC; NUREG-0972, October 1983.

12.

"Estimating Aquatic Dispersion of Effluents from Accidental or Routine Reactor Releases for the Purpose of Implementing Appendix I," Regulatory Guide 1.113, Revision 1, NRC, April 1977.

27

13.

Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation."

14.

Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation,"

Appendix B to §§ 20.1001-20.2401--Annual Limits on Intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage, (added to 10 CFR 20 by 56 FR 23360, May 21, 1991.)

28

SS.S 1UOGRAPHIC DATA SHEET EGG-PHY-10462 Sal lftslacv : I Oft '-1 alvissl 3 .*

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TECHNICAL EVALUATION REPORT FOR THE EVALUATION OF ODCM REVISION 3 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1-NRC Docket No. 50-400 NRC License No.

NPF-63 September 1992 T. E. Young, T. S. Bohn, D. W. Akers September 1992

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Idaho National Engineering Laboratory 9,

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EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 D6034 so

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astn*a rdaowse sa The Offsite Dose Calculation Manual (00CM) for the Shearon Harris Nuclear Power Plant, Unit 1 (SHNPP) contains current methodology and parapeters used to calculate offsite doses, dose rates, effluent monitoring alarm/trip setpoints, and conduct the radiological environmental monitoring program. The NRC transmitted the most recent complete SHNPP ODCM, Revision 3, updated through Advance Change 3/4, dated December 18, 1991, to the Idaho National Engineering Laboratory for review by EG&G Idaho, Inc. The ODCM was reviewed by EG&G Idaho, and the results are presented in this report. It was determined that the ODCM uses methods that-are, in general, within the guidelines of NUREG-0133.

However, the following items should be addressed promptly: (a) doses due to liquid-related pathways should include components due to the long-term buildup of radionuclides in Harris Lake, (b) the dilution associated with potable water pathways should be limited, and errors in the calculation of doses to the teen and child age groups should be corrected, (c) input parameters for GASPAR and LADTAP II calculations should be added to the ODCM; GASPAR II should be used for dose calculations, (d) methodology used to determine release rates and total releases of gaseous effluents should be added.

TAT0t0 Its" a S***C AS*

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