ML18093B355

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Forwards Rev 5 to Salem Nuclear Generating Station Offsite Dose Calculation Manual, in Response to Questions Raised in Tech Specs Rept,Per 880624 Request
ML18093B355
Person / Time
Site: Salem  PSEG icon.png
Issue date: 12/27/1988
From: Miltenberger S
Public Service Enterprise Group
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18093B356 List:
References
NLR-N88208, NUDOCS 8901040013
Download: ML18093B355 (12)
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Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC ACCEPTANCE OF THE OFFSITE DOSE CALCULATION MANUAL, REV. 3 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) hereby submits a revision to the ODCM in response to your letter dated June 24, 1988. Paragraph 2 of your cover letter requested a response to each point raised in the conclusion section of the Technical Specification Report (TER). Enclosed as Attachment 1 is the response you requested.

Should you have any questions regarding this submittal, please contact Mr. David Mohler at (609) 339-4546.

Sincerely, Attachment e901040013* aaf221-- -~-----

PDR ADOC~ 05000272. .

p PNU

  • Document Control Desk 2 DEC 2 7 1988 w/o Attachment c Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson, Acting Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

' TER PART 4 - MAJOR DISCREPANCIES ITEM 1.

It was requested that the 'SFp' seasonal correction factor (0.5) used in Equation 2.11 of the ODCM be "adjusted to agree with that fraction of a quarter when the 0.5 factor is applicable."

The purpose of the SFp factor is to adjust for that half of the year when milch animals are provided feed from stored vegetation.

During this half of a year (November thru April) the milch animals do not graze. So as not to grossly overestimate the dose from the possible release of radioiodines and particulates during this non-grazing time period, the average dose is calculated.

The SFp factor provides the means for an average dose for the grass-cow-milk and vegetation pathways throughout the year.

This correction factor was considered adequate in discussions with the Nuclear Regulatory Commission. This average dose was considered to be within the errors of the dose calculation methods provided in NUREG-0133 and Reg. Guide 1.109.

We feel the SFp correction factor is adequate and that no adjustment is necessary to Equations 2.11 and 2.12 of the Salem ODCM.

ITEM 2.

It was requested that the calculated organ dose equation in Section 2.5.1 (Equation 2.11) be clarified to mean the dose due to all pathways not just the controlling pathway.

In Revision 5 of the Salem ODCM the definition of Dao in Equation 2.11 was changed from "dose or dose commitmeRt via controlling pathway p and age group a (as identified in Table 2-4) .. "to "dose or dose commitment via all pathways p and controlling age group a (as identified in Table 2-4) .* ".

ITEM 3.

The definition of the term CW in Equation 1.5 was requested to be changed from " .. release period" to " .. reporting period".

NUREG-0133 describes the equivalent (dilution flow) as "the near field average dilution factor during any liquid effluent release." Reg. Guide 1.21 reporting requirements define the term as the "Average stream flow during periods of release .. " (NOTE: stream (dilution) flow is considered to be the circulating water system, no credit is taken for additional Delaware River dilution). It is our interpretation the dilution flow during a liquid release's release period is .reported, not 1

salem odcm

ITEM 3 (cont'd).

the' dilution flow over the entire reporting period. The term

'reporting period' is interpreted to mean over an entire quarter.

Changing to this requested definition could be interpreted to mean liquid releases are being made continuously at Salem sta-tion. As well, the dose calculations under this definition would be grossly underestimated and the volume of dilution water reported grossly overestimated.

Based on our interpretation of NUREG-0133 and Reg. Guide 1.21 the definition of cw is appropriate as currently written.

TER PART 4 - ADDITIONAL DISCREPANCIES ITEM 1.

The reference to the tables was corrected from Table 2-1 and Table 2-2 to Table 2-2 and Table 2-3 respectively in section 2.2.2.

ITEM 2.

It was questioned as to why Table 2-4 does- not identify the child-vegetation pathway as discussed in section 2.5.1, last paragraph.

The last paragraph of section 2.5.1 states; "For evaluating the maximum exposed individual, the infant age group is controlling for the milk pathway and the child age group is controlling for the vegetation pathway. "Only the controlling age group and pathway as identified in Table 2-4 need be evaluated for compli-ance with Technical Specification 3.11.2.3."

In Table 2-4 the pathways listed for radioiodines and particulates are the infant-milk and ground pathway for an unrestricted area (residence/dairy) and the child-inhalation pathway at the site boundary. These locations and pathways are taken from the Safety Evaluation Report, Supplement No. 3 for the Salem Generating Station, Unit 2 NUREG-0517, December 1978, pages 11-6 to 11-8 and Table 11.6. NUREG-0517 considered the maximum exposed individual for the unrestricted area to be the infant-milk pathway from a cow grazing location 4.8 miles NNE of the vent. Since there is no edible vegetation and no dairy farm located at or near the site boundary NUREG-0517 listed the child-inhalation pathway to be the controlling pathway of the site boundary, not the child-vegetation.

In summary, the child-vegetation pathway is not included in 2

salem odcm

ITEM 2 (cont'd).

Tabie 2-4 because it is not the limiting dose pathway for Salem's site boundary or unrestricted area. The limiting pathways are the child-inhalation at the site boundary and infant-milk for the unrestricted area per NUREG-0517. There are no vegetation nor milk pathways at the site boundary. The statement; "** and the child age group is controlling for the vegetation pathway." has been removed from Section 2.5.1 in Revision 4 of the Salem ODCM.

ITEM 3.

It was requested that the units of the term W in section 2.5.2 be corrected.

The units of the term W in section 2.5.2 were corrected from 1/m to 1/m2 .

ITEM 4.

It was requested that some additions be made to definitions in Equation 2.16.

The following additions were made to Equation 2*16 on page 27 of the ODCM; the definition of 0.13 was added and the subscript i was added for the term PF.

Since the equation, as defined by the term Qi*, is the release rate of a single pathway j then no su~script j need be added to the summation sign in the equation.

ITEM 5.

It was noted that a simplified diagram illustrating the solid waste treatment system was not included.

Figure 1-3, which may have inadvertently been omitted from the distribution to the NRC, is included in this revision.

ITEM 6.

It was noted that some dose conversion factors within Table 2-5 of the ODCM needed to be checked for correctness.

These values were recalculated using NuReg-0133 and Reg Guide 1.109 and compiled below. There were some discrepancies between the ODCM and the correct values. The latest revision of the ODCM reflects the corrections to these discrepancies.

The results of the comparison is below:

3 salem odcm

ITEM 6 (cont'd)

Equation 1 for inhalation pathway dose conversion factors P = K(BR) DFA = 1E6
  • BR

p = dose rate conversion factor K = unit conversion = 1E6 pCi/uCi BR = breathing (m 3 /yr) rate of group from R.G. 1.109 Table E-5 DFA = dose factor from Reg. Guide 1.109 Table E-7 to E-10 PATHWAY: Inhalation Path Isotope BR DFA p ODCM #

Teen-lung Ag-llOm 8000 8.44E-04 6.75E5 6.75E5 Teen-lung Te-125m 8000 6.70E-05 5.36ES 5.36ES Child-liver Rb-86 3700 5.36E-05 1.98ES 1.98ES Infant-lung Fe-59 1400 7.25E-04 1.01E6 1.02E6 Based on our calculations the numbers in the ODCM are correct and do not need to be changed.

Equation 2 for cow-milk (food) dose conversion factors:

Q (U)

P = K r --------- (ref. NuReg-0133, p. 26) where:

p = dose rate conversion factor K = unit conversion = 1E6 pCi/uCi Q = cow's consumption rate from R.G. 1.109 Table E-3 =SO u = food consumption rate from R.G. 1.109 Table E-5 y = agricultural productivity from R.G. i.109 Table E-15

= 0.7 for grass-cow-milk-man pathway F = stable element coefficients from R.G. 1.109 Table E-1 r = fraction of deposited activity retained on crops

= 1 for iodines, 0.2 for others from R.G. 1.109 Table E-15 DFL = maximum organ ingestion dose factor from Table E-11 to E-14 Ai = decay constant for radionuclide of concern (sec-1)

""'Aw = decay constant for removal of activity from leak and plant surfaces by weathering= 5.73E-7 sec-1 t = transport time from pasture to cow, milk, person from Table E-15 = 1.73ES secs 4

salem odcm

ITEM 6 (cont'd).

With all the constants multiplied the above equation for isotopes other than radio-iodines reduces to:

1.43E7 * (U)

  • F
  • DFL
  • e-()d
  • 1.73E5) p = -----------------------------------------

(ft_+ 5.73E-7)

The above equations were then utilized to calculate the dose factors for the isotopes, pathways and organs listed in the NRC review:

PATHWAY: Grass-Cow-milk organ Isotope ---=-F__ _y_ DFL p ODCM #

Adult-Liver Rb-86 4.30E-7 3.0E-2 310 2.llE-5 2.59E9 1. 35E5 Adult-T.Body Rb-86 4.30E-7 3.0E-2 310 9.83E-6 1. 21E9 5.90E4 Adult-GI-LL! Rb-86 4.30E-7 3.0E-2 310 4.16E-6 5.11E8 l.66E4 The conversion factors in the ODCM have been corrected in this revision.

Adult-Bone Zr-95 1. 22E-7 5.0E-6 310 3.04E-8 9.46E2 1. 07E5 Adult-Liver Zr-95. 1.22E-7 5.0E-6 310 9.75E-9 3.03E2 3.44E4 Adult-T.Body Zr-95 1.22E-7 5.0E-6 310 6.60E-9 2.05E2 2.33E4 Adult-Kidney zr-95 1. 22E-7 5.0E-6 310 1.53E-8 4.76E2 5.24E4 Adult-GI-LL! Zr-95 1. 22E-7 5.0E-6 310 3.09E-5 9.62E5 1.50E5 The conversion factors in the ODCM have been corrected in this revision.

Adult-Bone Nb-95 2.29E-7 2.5E-6 310 6.22E-9 8.25E4 1. 41E4 Adult-Liver Nb-95 2.29E-7 2.5E-6 310 3.46E-9 4.59E4 7.82E3 Adult-T.Body Nb-95 2.29E-7 2.5E-6 310 1.86E-9 *2.47E4 4.21E3 Adult-Kidney Nb-95 2.29E-7 2.5E-6 310 3.42E-9 4.54E4 7.74E3 Adult-GI-LL! Nb-9 2.29E-7 2.5E-6 310 2.lOE-5 2.79E8 1.04E5 The conversion factors in the ODCM have been corrected in this revision.

Teen-Bone Ce-141 2.47E-7 1. OE-4 400 1.33E-8 8.87E3 1. 99E4 Teen-Liver Ce-141 2.47E-7 1. OE-4 400 8.88E-9 5.92E3 1.35E4 Teen-T.Body Ce-141 2.47E-7 1. OE-4 400 1.02E-9 6.81E2 1.53E3 Teen-Kidney Ce-141 2.47E-7 1. OE-4 400 4.18E-9 2.79E3 6.26E3 Teen-GI-LL! Ce-141 2.47E-7 1. OE-4 400 2.54E-5 1.69E7 1. 20E5 The conversion factors in the ODCM have been corrected in this revision.

5 salem odcm

ITEM 6 (cont'd)~

PATHWAY: Grass-Cow-milk (cont'd)

Organ Isotope Ai ---=-F- _!L DFL P ODCM #

Teen-Liver Ba-140 6.27E-7 4.0E-4 400 3.48E-8 5.95E4 5.95E4 Based on our calculations the numbers in the ODCM are correct and do not need to be changed.

For radio-iodines the factor 1.43E7 in Equation 3 above becomes 7.14E7 because the factor r = 1.

PATHWAY: Grass-Cow-milk (cont'd)

Organ Isotope "i F _!L DFL p ODCM #

Teen-Bone I-131 9.97E-7 6.0E-3 400 5.85E-6 5.38E8 5.38E8 Teen-Liver I-131 9.97E-7 6.0E-3 400 8.19E-6 7.53E8 7.53E8 Teen-T.Body I-131 9.97E-7 6.0E-3 400 4.40E-6 4.04E8 4.04E8 Teen-Thyroid I-131 9.97E-7 6.0E-3 400 2.39E-3 2.20Ell 2.20Ell Teen-Kidney I-131 9.97E-7 6.0E-3 400 1.41E-5 1. 30E9 1. 30E9 Teen-GI-LL! I-131 9.97E-7 6.0E-3 400 1.62E-6 1. 49E8 1. 49E8 Based on our calculations the numbers in the ODCM are correct and do not need to be changed.

Child-Bone Y-91 1. 36E-7 l.OE-5 330 6.02E-7 3.91E4 9.14E5 Child-T.Body Y-91 l.36E-7 1.0E-5 330 1.61E-8 1.04E3 2.44E4 Child-GI-LL! Y-91 1. 36E-7 1. OE-5 330 8.02E-5 5.21E6 l . 84E5 The conversion factors in the ODCM have been corrected in this revision.

PATHWAY: Vegetation Organ Isotope ~i B _!L DFL p ODCM #

Child-Bone Ce-141 2.47E-7 l.OE-4 520 2.0SE-6 1. 27E8 1.27E8 Child-Liver Ce-141 2.47E-7 1.0E-4 520 6.52E-7 3.98E7 3.98E7 Child-T.Body Ce-141 2.47E-7 1.0E-4 520 1.llE-7 6.78E6 6.78E6 Child-Kidney Ce-141 2.47E-7 l.OE-4 520 3.61E-7 2.21E7 2.21E7 Child-GI-LL! Ce-141 2.47E-7 l.OE-4 520 1.74E-4 1.04E10 1.04E10 Based on our calculations the numbers in the ODCM are correct and do not need to be changed.

The dose conversion factors listed in the ODCM are used in the RETSCode computer program at Salem. The RETSCode program 6

salem odcm

ITEM 6 (cont'd) is used for effluent release permits and generating the semi-annual report. A comparison was also done between the correct values calculated below and the RETSCode values. No discrepancies were found. In other words, the computer program used to determine dose per the ODCM has had the correct dose conversion factors while the Salem ODCM did not.

None of the isotopes with incorrect dose conversion factors below has been released from Salem Units 1 and 2.

ITEM 7.

It was requested that the term 'D' in Equations C.5 thru C.8 in the ODCM be properly subscripted.

These terms have been properly subscripted in this revision of the ODCM (Appendix c, page C-4).

ITEM 8.

It was requested that the dose rate conversion factor for

.I-131 to the thyroid of the infant on page D-2 of Appendix D be corrected from 1.675E12 to 1.05E12.

This dose rate conversion factor has been corrected from 1.675E12 to 1.05E12 in this revision of the ODCM (page D-3).

ITEM 9.

There was a request for clarity on the words "particulate radio-iodines" on page D-3 of Appendix D.

This term has been corrected from "particulate radio-iodines" to "particulates" in this revision of the ODCM.

ITEM 10.

It was questioned as to whether Table E-1 in the ODCM indicated three air sample locations near the site.

Salem Technical Specification Table 3.12-1 requires 3 airborne samples close to the site location.

Artificial Island, which is the site location of Salem Units 1 and 2, is surrounded by United States Wetlands and abuts the Delaware River. There is only one access road to the site and the nearest resident is 3.4 miles away. Due to the isolation of the site it is difficult to locate many air sample stations near the site because of little access to power supplies. As well, considering the use of the nearby wetlands, the cost for placing an air sampling station 7

salem odcm

ITEM 10 (cont'd) in these wet lands is not justified. Thus, it is our opinion that the locations of 5Sl, 5Dl and 16El fulfill the requirements of Technical Specification Table 3.12-1. The latest revision of the ODCM indicates all the air sample sites as:

5Sl - 1.0 miles E of vent 5Dl - 3.5 miles E of vent 16El - 4.1 miles NNW of vent lFl - 5.8 miles N of vent 2F2 - 8.7 miles NNE of vent (control location)

ITEM 11.

It was noted that Table E-1 does not include any drinking water locations, food product sample stations for crops grown with water affected by the liquid effluents, a surface water sampling location at the outfall, or a sediment sampling location at the outfall as required by Technical Specification Table 3.12-1.

The nearest public water supply is more than 30 miles upstream of the site. We believe the intent of the Technical Specification was to sample drinking water supplies that could be directly effected by a nuclear generating stations liquid effluents.

The Delaware River, at our discharge point, is brackish water. There are no direct effects on drinking water supplies. The water supply in and around the site of Salem Units 1 and 2 is well water. In the radiological environmental moni-toring program there are 2 well water sample locations - 5Dl, 3.5 miles E of vent, and 3El, 4.1 miles NE of vent. Thus, the well water sample locations fulfill the requirements of Technical Specification, Table 3.12-1.

Due to the brackish water there is no irrgation dowstream of Salem Station. There are no crop samples available which use the Delaware River for irrigation.

There are five surface water samples taken from the Delaware River:

llAl - 0.2 miles W of vent (outfall area) 12Cl - 2.5 miles WSW of vent (cross-stream) 7El - 4.5 miles SE of vent 1F2 - 7.1 miles N of vent 16Fl - 6.9 miles NNW of vent Location llAl takes the samples from the outfall area of liquid effluents. Location 12Cl takes samples across the river from the outfall area. Since the Delaware River is a 8

salem odcm

ITEM 11 (cont'd) tidal river the rest of the sample locations satisfy both of the required up-stream and down-stream locations.

At the location llAl there is a sediment sample obtained.

All of these locations are indicated in the enclosed revision 5 of the Salem ODCM on Table E-1. The last revisions (Revision 3 and 4) also lists these same sample locations on Table E-1.

ITEM 12.

It was noted that Figures 1-1, 1-2, 1-3, 2-1, 2-2, and E-1 were illegible.

In the last revision of the Salem ODCM (Rev. 4) Figures 1-1, 1-2, and E-1 were improved upon and are included in this revision. Figures 1-3, 2-1 and 2-2 are currently being improved upon and should be included in Revision 6 of the Salem ODCM. These were not included in Revision 5 due to current design changes being implemented.

TER PART 4 - SUGGESTIONS ITEM 1.

It was recommended that the use of the term Ci be limited to the accepted use as the unit for curies and that another symbol be used for concentrations throughout the document.

It was also recommended the use of the terms c and C should be reviewed to determine if better terms could be used to avoid confusion in some equations.

We agree that the terms 'Ci' (used in all equations section 1 of the ODCM), 'c' and 'C' (Equation 1.1) should be changed to eliminate any confusion. As well, the terms* 'f' and 'F' (Equation 1.1) should also be changed. However, the terms

'c','C','f' and 'F' were all adapted directly from the first equation in the addendum of NuReg-0133.

To reduce some of the confusion in the terms used in the equation from NuReg-0133 we redefined the terms c,f and F in the Salem ODCM. We feel, however the term Ci was adequate enough for defining the number of uCi/ml (concentration). To change this term in the ODCM would also require revisions to many procedures which utilize the same terms. It is our opinion that there is need to change the term Ci.

9 salem odcm

ITEM 2.

It was suggested that the term Ci include the definition of undiluted concentration instead of just concentration.

We have included this suggestion in Section 1.2.1 of Revision 5 of the Salem ODCM.

ITEM 3.

It was recommended that a low level alarm setpoint be considered for the liquid effluent monitors.

All the liquid effluent monitors for Salem station have a "warning" alarm setpoint which is administratively set at 50%

of the alarm setpoint. Where as this is not a required feature for effluent monitors and there is no documented guidelines for a "low level alarm" setpoint the "low level alarm" or warning setpoints are not included in the Salem ODCM.

10 salem odcm

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