ML17139A651

Advises That Effluent Treatment Sys Branch Reviewed Sections of Facility Offsite Dose Calculation Manual Re Monitoring Setpoint.Radiological Assessment Branch Reviewed Sections on Dose Calculating methodology.Marked-up Pages Encl

ML17139A651
Person / Time
Site:	Susquehanna
Issue date:	05/03/1982
From:	Schwencer A Office of Nuclear Reactor Regulation
To:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
References
NUDOCS 8205140092
Download: ML17139A651 (10)

Text

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Docket Nos.

50-387/388 DISTRIBUTION:

Docket File LB¹2 Fil e EHyl ton RPerch I81E

Cutchin, OELD ACRS (16) bcc:

NRC PDR Local PDR PRC I'Ir. Norman W. Curtis Vice President Engineering and Construction - Nuclear Pennsylvania Power 8 Light Compa 2 North Ninth Street Allentown, PA 18101

Dear IIr. Curtis:

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Subject:

Review of the Susquehanna Offsite Dose Calculation Manual(ODCM)

The Effluent Treatment Systems Branch reviewed sections of the subject document dealing with monitoring setpoints.

The Radiological assessment Branch reviwed sections dealing with.dose calculati.ng methodology and environmental monitoring.

Enclosure 1 contains a copy of marked-up pages with comments in these areas.

Enclosu're 2 contains specific questions that should be addr essed with respect to the subject matter.

Sincer ely,

Enclosures:

As stated A. Schwencer, Chief Licensing Branch Na".,2

= Division of Licensing cc:

See next page 8205i400912 820503 PDR ADOCK 05000387 PDR OFFICE Q SURNAMEQ OATE Q RPerch:pt

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NRG FORM 318 (10-80) NRCM 0240 OFF!CIAL RECORD COPY lJ)QPO: 1981~r960

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Mr. Norman W. Curtis Vice President Engineering and Construction Pennsylvania Power 8 Light 'Company Al 1 ento',

Pennsyl vania 18101 cos:

Jay Si lberq, Escuire

Shaw, Pictman, P '-;s a Trowvr'.-ge 1800 M Street, N.

W.

Washington, D; C. 20036 Edward M. Nagel, Esquire General Counsel and Secretary Pennsylvania Power

& Light Company 2 North Ni.nth Street Allentown, Pennsylvania 18101 Mr. Willian E. Barberich Nuclear Licensing Group Super'v/sor Pennsylvania Power 8 Light Company 2 North Ninth Street.

Allentown, Pennsylvania 18101 Mr. G.

Rhodes Resident Inspector P. 0.

Box 52 Shickshinng, Pennsylvania 18655 Gerald R. Schultz, Esquire Susquehanna Environmental Advocates P.

O'. Box'560 Wilkes-Barre, Pennsylvania 18703'r.

E. B. Poser Project Engineer Bechtel Power Corporation P. 0.

Box 3965 San Francisco, California 94119 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Poser

'433 Orlando Avenue State College, Pennsylvania 16801 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsyl'vania P. 0.

Box 2063 Harr isburg, Pennsylvania 17120 Ms. Colleen Marsh

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Mountain Top, Pennsylvania 18707 Mr. Thomas J. Halligan Correspondent The Citizens Against Nuclear Dangers, P. 0.

Box 5

Scranton, Pennsylvania 18501 Mr. J.

W. Millard Project Manager Mail Code 395 General Electric Company 175 Curtner Avenue

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Jose, California 95125 Robert W. Adler, Esquire Office of Attorney General 505 Executive House P. 0.

Box 2357 Harrisburg, Pennsyl vania 17120

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7.0 TOTAL DOSE aaJ it/

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S ecification 3.11.4 - The dose or dose comnitment to any real individual from uranium fuel cycle sources shall be limited to less.

than or equal to 25 mrem to the total body or any organ (except the thyroid, which shall be limited to less than or equal to 75 mrem) over 12 consecutive months.

The cumulative dose to any member of the public due to radioactive releases from the SSES site is determined by suoming the calculated doses to critical organs from the previously discussed effluent

. sources.

Determine the annual dose to critical drgans of a real indi-vidual for the liquid effluents by.using Equations 10 and 11 of Section V.

Determine the annual dose to critical organs of a real individual for the noble gases released in the gaseous effluents by using Equation /~r~

12 modified by replacing Hi with Ki from Table 1 for the whole body dose and Equation 13 modified by replacing N; by (L; + 1.1 M;)

Wa C~ii&~X<r~

from Table 1 for the skin dose of Section 6.0.

Determine the annual ~.@y ~ ious

" dose to critical organs of a real individual for the radionuclides other than noble gases released in the gaseous effluents by using Equa-tion 14 of Section 6.0.

For all dose calculations from gaseous efflu-

ents, the annual average relative concentration or relative deposition rate used in the analysis should be at the receptor location of the..

individual being evaluated, not the highest calculated annual average relative concentration or relative deposition rate for any area at or beyond the site boundary as given in Table 2.

Determine the direct radiation from the site from the environmental monitoring program's direct radiation (TLD) monitors.

Since all other uranium fuel cycle sources are greater than 20 miles away, only the SSES site need be considered as a uranium fuel cycle source.for meeting the EPA regula-

.tions.

In actual

practice, the LADTAP and GASPAR computer code developed by the HRC to implement the liquid and gaseous dose methodology of Regulatory Guide 1-109 will. be used to perform the total dose calcula-tions for the SSES.

The methods outlined above are consistent with those of the LADTAP and GASPAR code; site specific dose factors have been computed and are available for implementing the method de'scribed above, if required.

23

TABLE'5 (Continued)

Page 3 of 4

~ a Exposure Pathway Number of Samples

~d/

S 1

dL Sampling and Collection Frequency Type and Frequency of Analysis Materborne Surf ace kj0~~ <c6~~~~

5SB intake arean A4 6S5 outfall areab Grab sample over monthly period.

Gamma isotopic analysis monthly.

Composite tritium analysis at leas once per 92 days.

~ 1202 Shultz Farm - 1.69 mi WSM 13E3 Dent Farm - 4.9 mi M

5E1 Bloss Farm - 4.4 mi E

10G1 Davis Farm - 14 mi SSMa Semi-monthly when animal s are on pasture, monthly at at other times..

Fish and Invertebrates Outfall area 2G Falls, Pa.

(Approximately 30 mi NNE)

I Sample in season.

One sample of each of the following speciesb:

1.

Malleye

?.

Catfish Drinking 12H2 Danvi lie Mater Co.

Monthly composite.

(Approximately 30 miles downstream)

Ised; a e

-rnv4 +S(>

'>I ~An~ dJ,eapl 'h.nd. J<<M

.A jaCWHI~

LSediment from 78 Bell Bend - 1.2 mi SE Semiannually.

Shoreline Hilk Gross beta and gamma isotopic analyses monthly.

Composite for tritium analys quarterly.

Gamma isotopic analysis semiannually.

Gamma isotopic and I-131 analysis of each sample.

S+ita I70glclr l] no~ ck~caL es&%

( A)OIAU) od eiW fL~

Gamoa isotopic on edible portions.

TABLE 5 (Continued)

Page 4 of 4 Exposure Pathway and/or Sam le Number of Samples and Locations

.Sampling and Collection Frequency Type and Frequency of Analysis At time of harvest.

Gamma isotopic on edible portions.

Food Products 1281 Kisner Farm - 1.15 HSH-vegetable 1101 Zehner Farm - 4.3 mi SW vegetable 702 Heller's Farm - 1.5 mi SE fruit 2H1 Yalick's Produce - 21 mi NNEa vegetable 4~ ~~ pe8 W ef'J p

a 'Control sample location. ~ ~ t&43.ala (~-~a ot +~~~+ p<<,l>~ tl,'<>f Temporary locations until compositor is installed in intake and discharge lines; then frequency changes to composite sample collected over one-month period and. location changes to 6S6 intake line, 6S7 discharge line.

Other species in the same family could be sampled instead of the stated species if deemed desirable by the biological consultants.

TABLE 6 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS Lower Limit of Detection (LLD)a Pag'e 1 of 2

~Anal sis gross beta H-3 Mn-54

~ I Fe-54 Co-58 Co-60 Zn-65

.Zr-95 Nb-95 I-131 Cs-134 Cs-137 Ba-140 La-140 Mater

~Ci/1 4

2000 15 30 15 15 30 30 j< ~

30 Ib'5 18 6'0 15 Airborne Parti cul ate or Gas Ci m3 1 x 10-2 7 x 10-2 5 x 10-2 6 x 10".2 Fish Ci/k wet 130 260 130 130 260 130 150 Milk

~Ci/1 1

15 10 60.

15 Food Products Ci/k wet 60 60 80 Ci/k dr 150 I 180

TABLE 6 (Continued)

Page 2 of 2 a The LLD is the smallest concentration of radioactive materjal in a

sample that will be detected with,.95 percent probability)wfth 5 percent probability of falsely concluding that a blank observation represents a "real" signal.

for a particular measurement system (which may include radiochemical separation):

4.66 sb 2.22 EVY exp

-~at where LLD is the lober limit of detection as defined above (as pCi pe unit mass or volume).

sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)

P E is the counting efficiency (as counts per transformation)

V is the sample size (in units of mass or volume) 2.22 is the number of disintegrations per.minute per picocurie Y is the 'fractional radiochemical, yield (when applicable)

A is the radioactive decay constant for the particular radio-

nuclide, and at is the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental

samples, not plant effluent samples)

T alue of sed in@he calcula+iiq of th LLD for p ticular mea ment syste should b

ased on &e actua

'/served

'e, of the ba kground cou ting rate r of the cb nting rath, of the ank samples (as appropr ate) rathe than on an unverifiQe theoret cally predicte variance.

In calculating the LLD for a radionuclide determined by gamna-ray spectrometry, the background should include the contributions of other radionuclides normally present in the samples (e.g.,

potassium-40 milk samples).

Typical values for E, V, Y, and at should be used in the calculation.

I 0

t residence in each of the 16 meteorological sectors within a distance of five miles.

A land use census will be conducted to identify the location of the nearest milk animal and the nearest residence in each of the 16 t

meteorological sectors within a distance of five miles.

When a land use census identifies a location(s) which yields a calculated dose o

dose corrnitment greater than the values calculated from current sample

. locations, appropriate changes in the sample locations will be made.

If a land use census identifies a location(s) with a higher average annual deposition rate (BTg) than a current indicator location, the following shall apply:

If the D7g is at least 20 percent greater than the previously highest D/9, one of the existing sample locations shall be 5~o/< ~

replaced with the new one within Rf days.

30 If the D/q is not 20 percent greater than the previously 9.3 'HTERLABORATORY CONPARISOH PROGRAM 2 ~

highest D/g, direction, distance, and D/g will be considered in deciding whether to replace one of the existing sample locations.

If applicable, replacement shall be wi.thin~8D days.

A land use census will be conducted at least once per-

/

~yems~by a door-to-door or aerial

survey, by consulting local agri-cultural authorities, or by any combination of these methods.

S ecification 3. 12.3 - Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program~for the applicable media and analysis.

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The laboratories of the licensee and licensee's contractors which perform analyses shall participate in the Environmental Protection Agency's (EPA's) Environmental Radioactivity Laboratory Intercompar-isons Studies (Crosscheck)'Program or an equivalent program.

This

- participation shall include.some of the determinations (sample medium-radionuclide combination) that are offered by EPA and that are ENCLOSURE 2:

1. llith regard to the P. values presented in Table 3, what age group were they calculated i

for? They need only be claculated for the child inhalation pathway.

2. ln accordance with NUREG-0133 the definition of A.

shold be changed to state that 7

ic it is a composite dose parameter.

Also, provide a table of the A.

values for adults.

ic

3. Table 4 of the ODCM should be updated to either contain R. values for all four age i

t groups and all potential pathways or Table 4 should contain a value for each pathway based on a single age group provided that for each nuclide listed the value calculated (R. ) is the most conservative.

4. Figure 7 should be resubmitted such that all of the monitor identification labels are legible.