ML17055B617
| ML17055B617 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/02/1986 |
| From: | Haughey M Office of Nuclear Reactor Regulation |
| To: | Hooten B NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 8605120034 | |
| Download: ML17055B617 (26) | |
Text
May 2, 1986 Docket No. 50-410 Mr. B.
G. Hooten Executive Director of Nuclear Operations Niagara Mohawk Power Corporation 300 Erie Boulevard West
'yracuse, New York 13202
Dear Mr,
. Hooten:
WMeinke ACRS (10)
DIS BUTION:
c et o.
0-410 NRC PDR Local PDR BWD-3 r/f EAdensam MHaughey EHylton RBernero
- Attorney, OELD BGrimes JPartlow EJorden
Subject:
Request for Additional Information on the Proposed Offsite Dose Calculation Manual for Nine Mile Point 2
1 The staff has completed its review of the Nine Mile Point 2 (NMP-2) Offsite Dose Calculation Manual (ODCM) submitted March 5, 1986.
Our general comments on the ODCM, and the specific comments of our contractor, are enclosed in the form of a request for additional information (RAI).
A revised ODCM that addresses these comments and is consistent with the draft Technical Specifications should be submitted within three weeks of the date of this letter.
An NRC approved ODCM is required to support the NMP-2 Technical Specifications.
An advance draft copy 'of these comments was given to Mr.
Don Hill of your staff on April 23, 1986, to assist you in preparing your response.
Please contact me on (301) 492-9422 if you have any questions concer$ ing the enclosed RAI.
Sincerely,
Enclosure:
As stated Mary F. Haughey, Project Manager BWR Project Directorate No.
3 Division of BWR Licensing cc:
See next page 8605120034 860502 PDR ADQCK 050004'i0 A
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Mr. B.
G. Hooten Niagara Mohawk Power Corporation Nine Mi1e Point Nuclear Station Unit 2 CC:
Mr. Troy B. Conner, Jr
, Esq.
Conner 5 Wetterhahn Suite 1050 1747 Pennsylvania
- Avenue, N.W.
Washington, D.C.
20006 Richard Goldsmith Syracuse University College of Law E. I. White Hall Campus
- Syracuse, New York 12223 Ezra I. Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Resident Inspector Nine Mile Point Nuclear Power Station P. 0.
Box 99
- Lycoming, New York 13093 Mr. John W. Keib, Esq.
Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202 Mr. James Linville U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Norman Rademacher, Licensing Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. Paul D. Eddy New York State Public Service Commission Nine Mile Point Nuclear Station-Unit II Post Office Box 63
- Lycoming, New York 13093 Don Hill Niagara Mohawk Power Corporation Suite 550 4520 East West HighWay
- Bethesda, Maryland 20814
RE VEST FOR ADDITIONAL INFORMATION ON THE NINE MILE POINT-2 ODCM DOCKET NO.: 50-410 Revision 0 of the Nine Mile Point-2 ODCM is not acceptable for use as a reference document with the Nine Mile Point 2 Technical Specifications because of its brevity. and minimal usefulness to 'plant operators.
In a revised submission the following general and specific comments should be addressed, as well as any inconsistencies between the Final Draft Technical Specifications and the ODCM-The Offsite Dose Calculation Manual (ODCM) 'is a reference document that complements and extends the Radiological Effluent Technical Specifications (RETS).
Seventeen different Technical Specifications (TS) in the Nine Mile Point-2 RETS refer to ODCM, usually relative to the methodology and parameters for dose calculations.
These include TS 3.3.7.10, 3.3.7.11, 4.11. 1. 1,2, Table 4.11-1 Note 2, 4.11.1.2, 4.11.1.3. 1, 4.11.2.1.1, 4.11.2.1.2,
- 4. 11. 2. 2, 4.11. 2.3.
- 4. 11.2.5.1, 4.11.4. 1, 4. 11.4.2, 4.12.1, Table 3.12-1 Note 1, 4. 12.3, and 6.9. 1.8.
Yet the pages of the Rev.
0 ODCM make reference to the TS in only a few sections.
The treatment of many sections of the Rev.
0 ODCM is generally abbreviated, sketchy and uneven.
Many sections are little more than outlines.
Although the TS commit to using the methodology and parameters of the ODCM, many sections give only the bare minimum of an equation and a few symbols.
Little attempt is made to tie sections to the TS.
Where site specific information is given, references or other authority are often inconsistent, contradictory or non-existent.
A licensee's ODCM should be a comprehensive working document, readily cross referenced to the TS, and extensive enough to provide background, authority, and meaningful methodology and specific parameters for fulfillingthe commitments of the TS.
The technical explanation and perspective presented on pages 34-40 of Rev.
0 for TS 4.11.4. 1, 4.11.4.2, 4.12.1, 4.12.3 and 6.9.3..8 is exemplary.
This is in contrast to the sketchy treatment for dose, dose rate and concentration.
Specific comments on Rev.
0 as provided by our. contractor Franklin Research Center are attached.
In addition the following should also be addressed.
- 1) Table 2-1, Table 3-1:
How does the applicant plan to check the accuracy of the response of the detectors provided by the supplier?
Tables 4.3.7. 10-l(c) and 4.3.7. 11-1(c) of the TS require periodic calibrations by NBS certified or traceable standards.
How will this be done and how will this affect ODCM Tables 2-1 and 3-1?
2). During discussions with the applicant on the Environmental Monitoring Program in the Proof 8 Review copies of the
- RETS, modifications to several table notations were made that referred to "discussion in the ODCM".,
These discussions should be added in the next revision.
5 3).A sit'e boundary map, similar to Fig. 5.1.3-1 of the TS, that shows the location of the meteorological tower should be included.
ODCM Review for Nine Nile Point Unit 2 Licensee:
Niagara Mohawk Po~er Corporation The review comments presented in this document were prepared by the Franklin Research Center under contract to the U.S. Nuclear Regulatory Commission (Office of the Nuclear Reactor Regulations, Division of Operating Reactors) for technical assistance in support of NRC reactor licensing actions.
This report is the result of reviewing the Licensee-submitted Offsite Dose Calculation Manual (ODCM) (Revision 0.
dated October 30, 1985) against the NRC guidelines (Regulatory Guide 1.109 and NIJREG-0133).
March 7, 1986
Nine Mile Point Unit 2 ODCM Review S~ub eat Comments Table of Contents The Licensee should provide a table of contents for the ODCH.
Liquid Radwaste Effluent Monitor Alarm Setpoint (Sec.
2.1.2')
The Licensee should specify the units for the alarm setpoints.
In the equation for the setpoint.
the factor 'k is not clearly defined.
The Licensee may apply the laboratory experience to introduce an appropriate safety factor for the se point calculation:
the factor should be a specific number.
The Licensee should provide nominal flow rates for the effluent line (f) and the dilution flow (F).
Also, the sources of dilution water should be identified.
Service Water A and B
and Cooling Tower Blowdown Radiation Detector Alarm Setpoint (Sec. 2.1.2.2)
Same as above, specify the units for alarm setpoint.
Same as above. specify the factor k.
Specify the nonminal flow rates for service water A and B, and the cooling tower blowdown.
I iquid Effluent Detectors Responses (Table 2-1) o The Licensee has not considered the simultaneous releases from more than one effluent line in the setpoint calculation.
It is not clear to what types of radiation (gamma. beta, or both) the detector responses provided in Table 2-1 are related.
0 What is the justification for considering only the isotopes listed in the tables?
Are other isotopes ignored?
Nine Mile Point Unit 2 ODCM Review (Cont.)
S~ub 'act Comments Liquid Concentration o
To demonstrate that the Licensee's Technical Specification 3.11.1.1 is met.
the surveillance requirements specify that the sampling and analysis program be implemented according to Table 4.ll-l of RETS.
According to the NRC Branch Technical Position. the Licensee should:
"Provide the equations and methodology to be used at the station or unit for each liquid release point according to the Specification 3.11.1.1.
For systems with continuous or batch releases, and for systems designed to monitor and control both continuous and batch releases.
provide the assumptions and parameters to be used to compare the output of the monitor with the liquid concentration specified.
State the limitations for combined discharges to the same release point.
.In addition, provide the method and assumptions for obtaining representative samples from each batch and describe the previous post-release analyses or composite sample analyses used to meet the specification."
Liquid Effluent Dose Dose Calculation Methodology {Sec. 2.2) o Liquid pathways are not clearly identified for the dose calcula-tion.
o Equations for the dose factor Aiz should be provided in the ODCM.
Table 2-2 o
The Licensee should explain why the table provides data only for the isotopes listed.
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Nine Mile Point Unit 2 ODCH Review (Cont.)
S~ub ect Pa e Number Comments Stack Noble Gas Detector A)arm Setpoint (Sec.
3.1.2.1).
o Units for the alarm setpoint not specified.
o The factor k used. for the setpoint equation is not defined or specified.
o
@hat is the height of the stack.
and the level of effluent releases (elevated vs. ground level)?
Vent Noble Gas Detector Setpoint (Sec.
3.1.2.2) o Same comments as stated for stack monitor above.
o Simultaneous releases not considered in the setpoint calculation.
o The resulting unit for the setpoint equation is not consistent with what it: is intended for; the end result will read "(m3/cc) (cpm)"
rather than just "(cpm)."
Offgas Pretreatment Noble Gas Detector Setpoint (Sec.
3.1.2.3) o The Licensee has not been consis-tent in choosing the units for the flow rates:
(m>/sec) was used in Sec.
3.1.2.2 and (cc/min) was used in Sec. 3.1.2.3.
Noble Gas Detector
Response
(Table 3-1) o Specify the types of radiation (gamma or bet'.a) for the detector responses.
o Provide justifications for having an)y a few isotopes for the table.
Dose Rate Calculation Methodology (Sec.
3.2) 10 o
The Licensee has not referenced the dose limits with which complicance is to be demonstrated for the dose calculations.
12 o
The Licensee use's 1.7E-06 (sec/m3) for the highest calculated annual (X/Q), which is lower than 2.0E-06 (sec/m3)
Nine Mile Point Unit 2 ODCM Review (Cont.)
S~ub ect Pa e Number Comments provide'd by the Licensee in Section 3.1.2.2 (p. 7).
Explain the discrepancy.
Plume Shine Parameters (Table 3-2) 13 o
The Licensee has not provided a methodology to calculate the plume shine factors Bi and Vi.
0 The Licensee did not provide any data for Table 3-2.
(The Licensee stated that "The values in this table will be provided at a later time.")
Tables 3-4 to, 3-21 15 to 32 0
Provide equations in the ODCM for the parameters calculated in the tables.
Uranium Fuel Cycle (Sec.
4.0) 35 o
The Licensee stated that fish con-'umption and shoreline sediment are the pathways used for liquid dose calculation.
However. the drinking ~ater pathway is not considered.
A)so, the methodology to calculate doses from shoreline sediment is not provided in the ODCM.
o No methodology is provided to estimate the direct radiation.
36 o
The equation given for factor R
is incorrect:
some typographic errors may have been committed.
Envi ronmenta 1 Monitoring Program 0
In Table 5.1 for sampling locations.
the nature of the locations (such as on-site.
control. or indicator) is not clearly specified for each location.
Since Nine Mile Point Units 1 =and 2 and the FitzPatrick
'lant ar'e located at the same site. the environmental sample locations, by agreement between the respective licensees.
are supposed to be identical.
However.
numerous
~
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r Nine Mile Point Unit 2 ODCM Review (Cont.)
S~cb ect Comments Environmental Honitoring Program (Cont.)
I
)
l l
differences are found between the sample locations of Nine Mile Point Unit 2 and the locations provided in the FitzPatrick ODCH (Rev.
2 dated June 25. 1985).
It appears that Nine Mile Point Unit 2 has a complete list of the most up-to-date information on sample locations.
However. the differences may reflect lack of coordination between the respective licensees on environmental sample programs.
Monthly Liquid Dose Projection (RETS 4.11.1.3el) o The Licensee did not provide a section to describe the meth-odology for monthly liquid dose projection per the Licensee's RETS 3.11.1.3.
Liquid and Gaseous Effluent Flow Diagrams o
The NRC Branch Technical Position as issued in 1979 specifies needs for the licensees to provide effluent flow diagrams to clarify and explain the operability of the radwaste treatment systems.
The Branch Technical Position states:
"Provide a flow diagram(s) defining the treatment paths and the components of the radioactive liquid. gaseous and 'solid ~aste management systems that are to be maintained and used.
pursuant to 10CFR50.36a, to meet Tech-nical Specifications 3.11.1.3.
Nine Mile Point Unit 2 ODCM Review (Cont.)
S~ub 'ect Comments Liquid and Gaseous Effluent Flow Diagram
{Cont.)
3.11.2.4 and 3.11.3.1.
Subcomponents of packaged equipment can be identified by a list.
For operating reactors whose construction permit applications were filed prior to January 2, 1971. the flow diagram(s) shall be..
consistent with the information provided in conformance with Section V.B.1 of Appendix I to 10CFR50.
For OL applications whose construction permits were filed after January,2.
1971. the flow diagram(s) shall be consistent with the information provided in Chapter ll of the Final Safety Analysis Report (FSAR) or amendments thereto."
The flow diagrams should also contain information on the effluent monitoring instrumen-tation regarding the setpoint calculation.
Thus. the information as required by the Branch Technical Position includes:
"The instrumentation for each alarm and trip setpoint, including radiation monitoring and sampling systems and effluent control features.
should be identified by reference to the FSAR {or Final Hazard Summary).
This information should be consistent with the recommendations of Section I of Standard Review Plan 11.5, NUREG-75/087, (Revision l)."
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I Nine Hile Point Unit 2 ODCM Revie~ (Cont.)
~Sch ect Estimation of I-133 Comments o
The Licensee did not provide a method to estimate the release of I-133.
On estimating the radioactivity of I-133, the NRC staff has specific guidance as fo) 1ows "Under appropriate conditions.
the I-133 contribution could be important to the Part 20 dose rates and to the Appendix I doses.
Therefore Specifications 3/4.11.2.1 and 3/4.11.2.3 should be written as shown in the enclosures.
These Specif ications will not explicitly require sampling and analysis to determine the I-133 releases.
Therefore.
Table 4.11-2 need not specify I-133.
Conversely.
the Specifications will require accounting for I-133 and the method for so doing must be detailed in the ODCH.
Acceptable methods will be addressed in NUREG-0133 Rev. l.
Acceptable approaches to estimating I-133 releases are as follows:
1.
Convert the samples for I-133',(as well as I-131) and assume a constant release rate so buildup is proportional to [1 exp(-Xt))/)
2.
Periodically take short-period samples to determine the ratio of I-131 to I<<133 activity.
Then use this ratio to estimate I-133 releases based on measurements of I-131 releases.
P
Nine Mile Point Unit 2 ODCM Review (Cont.)
S~ub 'ect Estimation of I-133 (Cont.)
Pa e Number Comments 3.
In special cases.
where a plant lacks capability for measuring I-133. assume that the I-133 activity release is 4 times the I-131 activity."
This requ'irement. is applicable to a
BWR such as Nine Mile Point Unit 2. especially since I-133 is not included in the sampling analysis program described in their RETS Table 4.11-2.
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