ML17055C331
| ML17055C331 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/22/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17055C330 | List: |
| References | |
| NUDOCS 8609040343 | |
| Download: ML17055C331 (28) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO ACCEPTANCE OF REVISION 2 TO THE'FFSITE DOSE CALCULATION MANUAI ODCM NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT NUCLEAR STATION UNIT NO.
1 DOCKET NO. 50-220
- 1. 0 INTRODUCTION On November 2, 1984 the staff issued Amendment No.
66 to Facility Operating License No.
DPR-63 for the Nine Mile Point Nuclear Station Unit No.
1 (NMP-1).
The amendment incorporated the Radiological Effluent Technical Specifications (RETS) into the NMP-1 Technical Specifications (TS).
Section 6.9. l.e of the TS referenced an Offsite Dose Calculation Manual (ODCM) and prescribed the methods for its change.
2.0 EVALUATION The docketed submittal on March 7, 1984 of an ODCM by Niagara Mohawk Power Corporation (licensee) received NRC approval by letter dated November 2, 1984 from R. A. Hermann to the licensee.
Since
- 1984, a number of changes have been made in the NMP-1 ODCM and reported to NRC in ODCM revisions in accordance with NMP-1 TS 6.9.1.e.
The latest of these, Revision 2, dated February 1986 and submitted February 28,
- 1986, has been reviewed for us by Franklin Research Center (FRC) as part of our technical assistance contract program.
Their report (the enclosed section from TER-C5506-595) provides their technical evaluation of the compliance of the Licensee's submittal with NRC criteria.
The staff has reviewed this report, and agrees with the evaluation that the NMP-1 ODCM, Rev. 2, generally uses documented and approved methods that are consistent with the methodology and guidelines in NUREG-0133.
Therefore, we conclude that this ODCM is an acceptable reference for use with NMP-1 TS 6.9. l.e on an interim basis.
Although a number of discrepancies in the NMP-1 ODCM have been documented in the attached TER, the licensee has shown awareness of these items in the treatment provided them in the NMP-2 ODCM, Rev.
1 recently approved by the staff.
The NMP-1 ODCM Rev.
2 is a significantly different document from the NMP-2 ODCM, Rev.
1.
The NMP-2 ODCM is a more extensive working document than the NMP-1 OQCM. It is well cross-referenced to the Technical Specifications and is extensive
- enough, containing sufficient background, authoritative information, and acceptable methodology for fulfilling the commitments of PDR a
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the TS.
The approach used in the ODCMs for each plant should,
- however, be the same with only a few plant specific items different.
Therefore, within 6 months, it is recommended that the licensee provide a revised ODCM for NMP-1 addressing the listed deviations and combining the NMP-1 and NMP-2 ODCMs into a single document using the NMP-2 ODCM as the model.
3.0 CONCLUSION
S The NMP-1 ODCM, Rev.
2 is acceptable on an interim basis.
The changes incorporated in Revs.
1 and 2 are in compliance with NMP-1 TS 6.9.l.e.
Within 6 months, the licensee should revise the NMP-1 ODCM to address the listed deviations and combine the ODCMs for the two units into a single document using the NMP-2 ODCM as a model.
Principal Contributor:
W. Meinke Dated:
August 22, 1986
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TER-C5506-595 APPENDIX D EVALUATION OF LICENSEE-REPORTED REVISIONS TO ODCM FRANKt.lNRE5EARCH CENTER DIVISION OF ARVIN/CALSPAN 10th S RACE STREETS. PHILADELPHIA.PA19103
1
TERW5506-595 D.l.
EVALUATION OF LICENSEE-REPORTED REVlSZONS TO ODCM The Licensee has made numerous changes to the existing ODCM that ~s submitted by the Licensee on March 7, 1984 and approved by NRC on November 2, 1984.*
These changes appeared in a complete, revised ODCM (Rev. 2) submitted in the Semiannual Radioactive REfluent Release Report as issued hy the Licensee in the second 6 months of 1985: no changes were made to the ODCM by the Licensee during 1984.
This revised ODCM has been approved internally by the Licensee's Site. Operations Revie~ Committee (SORC) on February 26, 1986.
Zt is this revised ODCM (Rev. 2) that has been reviewed for this report.
The result of the evaluation is intended to be a stand-alone
- document, and is given in the following attachment as Supplement to Appendix D.
<<Letter from R. A. Herman (NRC/DL) to S. G. Hooten NMPC), November 2, 1984.
SUPPLEMENT TO APPENDIX D EVALUATION OF LICENSEE-REPORTED REVISIONS TO THE ODCM FRANKLINRESEARCH CENTER DIVISION OF ARVIN/CALSPAN 20th 4 RACE STREETS, PHILADELPHIA.PR 19103
I
TER&5506-595 1.
INTRODUCTION 1.1 PURPOSE OF REVIEW The purpose of this document is to revie~ and evaluate revisions or
- updates made to'the Nine Mile Point Unit 1 Offsite Dose Calculation Manual (ODCM), through December 31, 1985, as reported in the Licensee's Semiannual
! Radioactive Effluent Release Reports.
These changes update the Licensee's
- ODCM from the one originally submitted on March 7, 1984
$ 1] and subsequently approved hy NRC by letter dated November 2, 1984
$2].
The ODCM is a supplementary document for implementing the Radiological Technical Specifications (RETS) in compliance with 10CFR50, Appendix I requirements [3].
1.2 SCOPE OF REVIEW As specified in NUREG-0472 t4] and NUREG-0473 [5], the ODCM is,4o he developed by the Licensee to document the methodology and approaches used to e
calculate offsite doses and maintain the operability of the effluent system.
As a minimum, the ODCM should provide equations and methodology for the following topics:
O 0
o o
o alarm and grip setpoint on effluent instrumentation liquid effluent concentration in unrestricted areas gaseous effluent dose rate 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 heing used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems.
A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.
- 1. 3 PLANT-SPECIFIC BACKGROUND On belf of Nine Mile Point Nuclear Station Unit 1, the Niagara Mohawk Po~er Corporation submitted revisions to the existing ODCM [1] in the Semiannual'Radioactive Effluent Release Reports issued by the Licensee.
The
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TER-C5506-595 Licensee issued Revision 1 of the DDT in the first 6 months [8] and Revision 2 in the second 6 months [9] of 1985; no changes vere made'y the Licensee for 1984 [8] ~
The Licensee's Semiannual'Reports and the revisions of the ODCH vere transmitted to an independent revie~ team at the Franklin Research Center (FRC) for revie~.
The revie~ '~as subsequently conducted by FRC. and the results and conclusions of the ODCH evaluation are presented in Sections 3 and 4 of this document.
It is the'atest ODCM (Rev. 2) that ~as reviewed for this report.
'TER-C5506-595 2.
REVIEW CRITERIA Review criteria for the ODCM were provided by the NRC in three documents:
NUREG-0472 [4], RETS for PWRs NUREG-0473 [5], RETS for SWRs NUREG-0133 [ll], Preparation of RETS for Nuclear Power Plants.
In the ODCM review, the following NRC guidelines are used:
. "General
" Contents of the Offsite Dose Calculation Manual." Revision 1 [10], and NUREG-0133 [ll]. Regulatory Guide 1.109 [12] also provides technical guidance for the review.
The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.
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TER&5506>>595 3.
EVALUATION The Lid'ensee has folio~ed the methodology of NUREG-D133 [ll] to determine the alarm and trip setpoints for the liquid and gaseous effluent monitors.
which ensures that the maximum permissible concentrations, as specified in 10CFR2D. will not be exceeded by discharges from various liquid or gaseous release points.
The Licensee's method for setpoint calculations meets the guidelines of NUREG-0133.
The Licensee.
ho~ever, has not considered situations when simultaneous discharges are made for liquid effluent releases.
The Licensee has not provided a method of calculating the radioactive liquid concentration by describing in the ODCM the means of collecting and analyzing representative samples prior to and after releasing liquid effluents into the'irculating ~ater discharge, per the Licensee's ne~ly implemented Technical Specification Section 4.6.15.a (effective January 1, 1985).
Methods are also included for showing that dose rates at or beyond the site boundary due to noble gases, iodine-131. iodine<<133. tritium, and particulates with half-lives greater than B days are in compliance with 10CFR20.
In this calculation,'the Licensee has considered effluent releases from the main stack (stack height 350 ft): those, releases are being treated as elevated level..
The Licensee has made a commitment to use the highest annual average values of relative concentration (Z/Q) and relative deposition (D/Q) to determine the controlling locations.
The revised value:.for N/Q) is 2.4 x 10 for (sec/m
) at the site boundary.
The Licensee.
ho~ever.
has not
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considered the direct, radiation contribution from exposure to the finite plume of the elevated stack release, per the method described in NUREG-0133.
The I
Licensee intends to use the maximally exposed individual and the critical organ as the reference receptor.
The Licensee has also considered pathways from inhalation and ground-plane deposition.
although the ground-plane deposition is sot strictly required for gaseous dose rate calculations.
The Licensee has demonstrated that the described methods and relevant parameters have followed the conservative approaches provided by NUREG-0133 and Regulatory Guide 1.109 [12] for liquid effluent dose rate calculations.
However, since-the Licensee has not included iodine-133 in the sampling analysis program (Table 4.6.15-2 of the newly implemented RETS), a statement I
should be added to record the method to estimate for iodine-133 for the dose rate calculation. in accordance with the NRC Branch Technical Position [13].
9-6
I TER-C5506-595 Evaluation of the cumulative:dose is to ensure that the quarterly and annual dose design objectives specified in RETS are not exceeded.
For licpsid releases.
the Licensee has identified fish consumption as the viable path~ay.
In the calculation, the Licensee has used the suggested key parameters given in Regulatory Guide 1.109.
As in the case of dose rate calculation, the Licensee has used the maximally exposed individual as the reference receptor.
To correctly, assess the cumulative dose, the Licensee intends to estimate the dose oncej per 31 days.
These approaches to liquid dose calculations satisfy the guidance specified by NVREG-0133.
I Evaluation of the cumulative, dose from noble gas releases includes both beta and gamma and air doses at and beyond the site boundary.
The critical organs under consideration are the total body and skin for ganja and beta radiation, respectively.
The Licensee, however. has not included the exposure from the finite plume of the elevated main stack.
l For iodine-131.
iodine-133,.',tritium. and particulates with half-lives greater than 8 days, the Licensee has provided a method to demonstrate that cumulative doses calculated from 'the release meet both quarterly and annual I
. design objectives.
The Licensee;has demonstrated a method of calculating the dose using maximum annual average (X/Q) values for the inhalation pathway and has included
{D/Q) values for the food and ground-plane pathways.
The Licensee has identified the controlling locations at the cow milk path~ay at 2'.6 miles in the southeast sector.
The Licensee's approaches are consistent with the methodology of NUREG-0133.
As in the case for dose rate calculation, the License should also record the method to estimate for.iedine-133 for dose calculation.
The Licensee has not demonstrated a procedure to determine the monthly'ose and to ensure that the design objectives for the liquid radwaste system and the ventilation exhaust system are not exceeded, as per Licensee's I
Technical Specification 4.6.16.a (effective January 1. 1985).
Adequate flow diagrams defining the effluent paths and components of the radioactive liquid and gaseous waste treatment systems have been provided by the Licensee:
Radiation monitors specified in the Licensee-submitted RETS are
\\
also properly identified in the flow diagrams.
The information provided by the Licensee has satisfactorily met the guidance of HUREG-D133.
However.
improvement in legibility of these diagrams is still needed.
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TER-C5506-595
'he Licensee has provided a description of the revised sampling locations in the ODCM and has identified them in Table 5.1 and also in Figures 5.1-1 through 5.1-2 of the revised version.
These changes are consistent ~ith the sampling locations specified in the Licensee's RETS Table 3.6.20-1 on environmental monitoring, and thus satisfies the guidance of NUREG-0133.
In summary.
the Licensee's ODCM and the revised changes use documented and approved methods that are generally consistent with the methodology and guidance in NUREG-0133,,and therefore is an acceptable reference.
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TERW5506-595 4.
CONCLUSIONS The Licensee's Revision 2 {dated February 26, 1986) to the existing Offsite Dose Calculation Manual [l]. submitted by the Licensee in the Semiannual Radioactive Effluent Release Reports for the period of January 1.
1984 through December 31, 1984, uses documented and approved methods and is consistent with the criteria of NU)KG-0133. except for the following discrepancies:
In Sections 2.1.2 and 2.1.3 of the submittal, the License'e has mis-takenly designated the dilution factor as Ci, which should be MPCi Ci i MPCi The Licensee has not considered simultaneous discharges for liquid setpoint calculation.
o The Licensee has not provided methodology and parameters for liquid concentrations to demonstrate compliance with 10CFR20 limits, in accordance with the Licensee's Technical Specification Section 3.6.15.a {effective January 1, 1985).
o The Licensee has not considered the exposure components from the elevated main stack for the following subjects:
alarm setpoints, dose rate.
and cumulative noble gase dose calculations.
o The Licensee states that the highest
{X/Q),is 1.5 x 10 6 {sec/m3).
Table 3-l of the submittal. ho~ever, indicates a higher value. i.e.,
2.4 x 10 6 {sec/m3).
o The Licensee has not provided a method to calculate the direct dose for demonstrating compliance with the total dose'40CFR190) requirement.
0 The Licensee did not provide a section to describe the methodology for monthly liquid dose projection per the Licensee's Technical Specification Section 3.6.16.a {effective January 1. 1985).
Improvement in legibility is needed for the Licensee's radwaste treatment flow diagrams with concise explanations are preferred.
'To demonstrate that, the Licensee's Technical Specification Section 3.6.15.b{3) is met, the surveillance requirements specify that the sampling and analysis program be implemented according to Table 4.6.15-2 of the specification.
Since the Licensee has not included I-133 in such a program.
a method is needed in the ODCM for estimating the release of Z-133.
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TER&5506-595 5.
REFERENCES Offs'ite Dose Calculation Manual for Nine Mile Point Nuclear Station Unit
- 1. Rev.
0 Niagara Mohawk Po~er Corporation NRC Docket No. 50-220 March 7, 1984 R. A. Hermann (NRC/DL)
Letter to B. G. Hooten (NMPC)
Subject:
NRC/DL Approval,of Nine Mile Point ODCM NRC Docket No. 50-220 November 2, 1984
- I Title.10, Code of Federal Regulations, Part 50. Appendix I. "Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion,
'As Low As Is Reasonably Achievable,'or Radioactive Material in Light-WaterWooled Nuclear Power'Reactor Effluents" "Radiological Effluent Technical Specifications for Pressurized Water Reactors,"
Rev.
3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors NRC, September 1982 NUREG-0472 "Radiological Effluent Technical Specifications for Boiling Water Reactors,"
Rev. 3, Draft", intended for contractor guidance in reviewing RETS proposals for operating reactors NRC, September 1982 NVREG-0473 "Semiannual Radioactive Effluent Release Report 30, 1984," Nine Mile Poin't Nuclear Station Unit Corporation NRC Docket No. 50-220 August 21, 1984
~ )
"Semiannual Radioactive Effluent Release Report 31, 1984," Nine Mile Point Nuclear Station Unit Corporation I
NRC Docket No. 50-220 April 26, 1985 "Semiannual Radioactive Effluent Release Report 30, 1985," Nine Mile Point Nuclear Station Unit Corporation NRC Docket No. 50-220 August 23 ~ 1985 "Semiannual Radioactive Effluent Release Report 31, 1985," Nine Mile Point Nuclear Station Unit Corporation NRC Docket No. 50-220 April 26, 1985 D-10
- January 1 through June 1, Niagara Mohawk Power
- July 1 through December 1, Niagara Mohawk Power
<< January 1 through June 1, Niagara Mohawk Power
- July 1 through December 1, Niagara Mohawk Power
"t "y r<
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'TER-C5506-595 10.
"General Contents of the Offsite Dose Calculation Manual," Revision 1
Branch Technical Position, Radiological Assessment Branch NRC, February 8, 1979 11.
"Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications" NRC, October 1978 NUREG-0133 P
12.
"Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR50, Appendix I" NRC. October 1977 Regulatory Guide 1.109, Rev.
1 13.
W. P. Gamill/F. Congel (NRC)
Memo to ETSB/RAB (NRC)
"Radiological Effluent Technical Specifications (RETS) Provisions for I-133" November 29, 1982
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