ML19324A618

From kanterella
Jump to navigation Jump to search
Technical Evaluation Rept for Evaluation of ODCM (Updated Through Rev 19) San Onofre Nuclear Station Units 2 & 3.
ML19324A618
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 10/31/1988
From: Serrano W, Thomas Young
EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:
NRC
Shared Package
ML13303B153 List:
References
CON-FIN-D-6034 EGG-PHY-8282, NUDOCS 8909010024
Download: ML19324A618 (30)
v • d • e


Text

p -.' ,

.' .: ), , ,

c ,.

k# ,

i h  !

!- EGG PHY-8282

[l, b' i i

i

. TECHNICAL EVALUATION REPORT s for the

r EVALUATION CF ODCM l

(UPDATED THROUGH REVISION 19)

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 NRC Docket No. 50-361 NRC License No. NPF-10

.NRC Docket No. 50-362 NRC Licy.se No. NPF-15 1

-T. E.. Young W. Serrano 4 e

x .

I 1

p Published October 1988 ,

Idaho National Engineering Laboratory  :

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 4

S Prepared for the i

U. S. Nuclear Regula ry Commiss9on Washington, D . 20555 Under DOE Contract No. DE AC07 761001570 FIN No. D6034 f

/C i o % 'o ) O R 'J ,y '

'N --- ,/ 30ryg k.....__._.

)

a .  :

I .c - .;**y f

i i

ABSTRACT The. 0ffsite Dose Calculation Manual (ODCM) for the San Onofre Nuclear j Generating Station, Units 2 and 3 contains current methodology and parameters for calculation of offsite doses due to radioactive liquid and gaseous effluents, determinatica of gaseous and liquid effluent monitors' l alarm / trip setpoints, and for conduct of the environmental radiological  :

monitoring program. Revisions.of the ODCM for Units 2 and 3 are submitted  ;

n to the NRC in the Monthly Operating Reports as required by the Licensee's -

Technical Specification 16.4.2 It was determined that the ODCM, updated through Revision 19, uses methods that are, in general, consistent with the guidelines of NUREG-0133. Most deficiencies noted were relatively minor. However, it is recommended that a revision containing requirements for including gaseous effluents from Unit 1 in monitor setpoint and offsite dose rate calculations be submitted by the Licensee, and that other deficiencies identified in the review be addressed in a future  ;

revision.

b f

1 i

I t

4 .

s i

FOREWORD ,

This report is submitted as partial fulfillment of the " Review of f Radiological Issues" project being conducted by the Idaho National Engineering Laboratory for the 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 D&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, 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.

l L

l 11 l

l l

r, .

i U

I J L'e, . - g, ,

s i

i ut  ;

CONTENTS j i

Page  ;

-Abstract. . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. i Foreword. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ,

1. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . 1 i
2. Review Criteria . . . ... . . . . . . . . . . . . . . . . . . . 1 ,

e

3. Evaluation. . . . . . . . . . . . . . . . . . . . . . . . . . . 2'
4. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . 21
5. References. . . . . . . . . . . . . . . . . . . . . . . . . . . 24 FIGURES i
1. Diagram of the shared radioactive liquid waste treatment system i for SONGS Units 2 and'3. . . . . . . . . . . . . . . . . . . . . 4
2. Radioactive liquid waste effluent pathways and monitors for SONGS Uni ts 2 and 3 . . . . . . . . . . . . . . . . . . . . . . 6
3. Diagram of the radioactive gaseous waste treatment systems for SONGS Units 2 and 3 . . . . . . . . . . . . . . . . . . . . . . 10
4. Release pathways and monitors of radioactive gaseous effluents for SONGS Units 2 and 3 . . . . . . . . . . . . . . . . . . . . 11 iii

.2-

& 4,* - - - -

f &4 e a

.' i

  • 1*

g  ;

i

1. INTRODUCTION 1.1 Puroose of Review j i

This document reports the review and evaluation of the most recent version of the Offsite Dose Calculation Manual (ODCM) submitted by the Southern California Edison Company (SCE), the Licensee for San Onofre '

Nuclear Generating Station (SONGS), Units 2 and 3 (Combustion Engineering PWRs). The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirementsIll. .

1.2 Plant-Soecific Backaround ,

San Onofre Units 1, 2, and 3 are all located on the same site, but the ODCM for Units 2 and 3 is a separate document from the ODCM for Unit 1.

Changes to the ODCM for Units 2 and 3 are submitted to the NRC in the  !

Monthly Operating Reports, as required by Technical Specification 6.14.2 l l

for the two units. Nineteen revisions have been submitted by the

! Licensee. The ODCM, updated through Revision 17, dated Jurie 15,1985[2),

was reviewed for the NRC by an independent review team at the Idaho l National Engineering La'u oratory (INEL). The Licensee subsequently i submitted Revisions 18I33 and 19I43 to the NRC, and the NRC transmitted l l these' revisions to the INEL for review. The ODCM, complete with all revisions, was reviewed by EG&G at the INEL and the results of the review are presented in this report.

i

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

NUREG-0472 RETS for PWRs[5]

NUREG-0133, Preparation of RETS for Nuclear Power Plants [6]

1

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

" General Contents of the Offsite Dose Calculation Manual,"

Revision I II),and Regulatory Guide 1.109, Revision 1[8),

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 er 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 radioactive liquid, gaseous, and solid waste management systems. A description and the location of samples in support  !

I of .the environmental monitoring program are also needed in the ODCM.

3. EVALUATION The ODCM for SONGS Units 2 and 3, updated through Revision 19, j effective May, 1988 was reviewed, and the results of the review are l presented below. The technical specifications for SONGS Unit 2 and SONGS Unit 3, which requ-Ire specific methodology to be included in the ODCM, are essentially identical. Therefore, the Licensee uses one ODCM for Units 1 and 2. Another ODCM applies to Unit 1.

2

i o ,

7,.  !

g' .

The' detailed explanations accompanying Revision 19 were somewhat less specific than those accompanying Revision 18. Preparation of a very l detailed explanation of the changes made by Revision 19 would probably l have prevented the omissions and duplications noted in Section 3.4 below, and would have prevented the erroneous pagination at Tables 2-5 through 1 2-7 that results from direct substitution of pages from Revision 19 into the ODCM.  :

+

The methodology in the ODCM generally follows the guidelines of  ;

NUREG-0133, but in some sections significantly more site-specifi.c parameters should be included. Also, in some sections conservatively high doses will be calculated using the methodology given.

3.1 Liouid Effluent Pathway 1 The SUNGS site is located on the shore of the Pacific Ocean about 5 ,

miles southeast of San Clemente, California. Main condenser cooling for the three reactors on the site is provided by three separate once-through circulating water systems with intakes and release points (outfalls) in the  ;

Pacific Ocean. Units 2 and 3 share a common liquid radwaste treatment .

L system. A simplified diagram of this radwaste system, obtained from the l ODCM, is shown in Figure 1. The effluent monitors shown in the figure do not appear to be consistent with the monitoring required by the technical specifications and identified in the setpoint determination methodology in the ODCM. Two radiation monitors are shown in the figure, whereas only one is identified in the ODCM to monitor effluents from the liquid radwaste system. Dilution water flow for radioactive liquid waste from Units 2 and 3 is provided by circulating water pumps and saltwater pumps for i Unit 2. The maximum dilution water flow is 774,000 gpm (1724 cfs).

Releases of radioactive liquid waste from Units 2 and 3 are considered s'eparately from releases from Unit 1, since the dilution water flow for Units 2 and 3 is completely separate from that for Unit 1.

3

  • I, l

i l

v.  ;

n.

m L= .

a n - v..:

. I.-  ;

.  !. 9..

O ~i e t7  !* 7  :

C I* il i .I

  • i. 1 8-  ?

i

  • ms -

g i H2 -

i 8

  • f I

i . u I .ge:t i...t : - i s.

- u egi i === g ,-

.  :==

1 :est 33 I III ~T I !.g i is* M  :

q 4 u*r J

  • I a 1.

l*

E ~~"

t

: 8 . -4 I

.. .e gi s

s  :. a ll.g a 1.:. -

.~ -

= . a s

.l s v $$

> 8

- w .-

l 4I *.

. 3-

. a 7 a el E5 *!

E 3.3g .3

e. *l . .g .5 I

e i

e E :I 31 y

=

:. i =

gu v

1. 3. =.u s .i -- %a . I .

mA

.- o me  :=:  ; I-  :=

e i i 4

..s 5 =

. 3 - I . i

= " '

n --

4 g .l 1

= ,I

.= e u

v *-  : 'a g  :. og:ge .. . . [*]

. .-  ?-

. s. :

ug

! " i .: o a -

au l

g

=

    • g:. .t E o

. . a-

a o .=s'

~~

i 51

?

s

T "t

T. m.

o. .. .

I

  • I: Bg ou

$ ** s.

8 23.!-3 E

o:c $! it! 2h v , <>

< ..o s- [t*

g.o .r T e-n*a i Er u

o dL

= ..

m.-- -

. >=> s. M a 9

" .=

ti

.=

38.s

.o t *5 et 32 a gl.e 1... 18. E g

. s g . a. ed .

= ._

m au s  : 25 cea  : :

l 4

i

. ,. j s .

.s I Technical Specification 3.3.3.8 for Units 2 and 3 requires '

radioactivity monitors providing alarm and automatic termination of release

]

on the following lines:

a. Liquid Radwaste Effluent Line (2/3RT-7813), Unit 2 and Unit 3.
b. Steam Generator Blowdown (Neutralization Sump) Effluent Line (2RT-7817), Unit 2.
c. Steam Generator Blowdown (Neutralization Sump) Effluent Line (3RT-7817), Unit 3.
d. Turbine Building Sumps Effluent Line (2RT-7821), Unit 2.
e. Turbine Building Sumps Effluent Line (3RT-7821), Unit 3. .
f. Steam Generator Blowdown Bypass Effluent Line (2RT-6759), Unit 2.
g. Steam Generator Blowdown Bypass Effluent Line (2RT-6753), Unit 2.
h. Steam Generator Blowdown Bypass Effluent Line (3RT-6759), Unit 3.
1. Steam Generator Blowdown Bypass Effluent Line (3RT-6753), Unit 3.  ;

In addition to these nine monitored pathways, Table 4.11-1, '

" Radioactive Liquid Waste Sampling and Analysis Program," of the Licensee's RETS indicates radioactive liquids may be released in continuous mode from the Miscellaneous Waste Evaporator and in saltwater discharge from the Component Cooling Heat Exchanger. Concerning monitoring of continuous I releases from the Miscellaneous Waste Evaporator, the RETS states,

" Sampling of this flow is' not required if, at least once per 31. days, 3 condensate monitor bypass valve, SA 1415-2 1/2-200, is verified locked shut." This statement implies that continuous releases from this source are not intended to be normal practice.

Figure 1 is a copy of Figure 4-1 from the Licensee's ODCM for SONGS Units 2 and 3, showing the shared radioactive liquid waste treatment system, but not showing all of the release pathways. Figure 2 is a diagram of the release pathways for radioactive liquid wastes released from Units 2 and 3 drawn from information in the Licensee's FSAR, RETS, and ODCM to show all release pathways. Figure 2 is based on the reviewers' interpretation of the system descriptions, and has not been reviewed by the Licensee.

5

Steam Steam Steam Steam Turbine Turbine Unit 2 Main t Gen. 2A Gen. 2B Gen. 3A Gen. 3B Plant Plant Condenser Sump 2 Sump 3 y3RT-7821(continuous) 2RT-7821 (continuous) y3RT-6753,SteamGen.BlowdownBypass(continuous)

y3RT-6759,SteamGen.BlowdownBypass(continuous) y2RT-6753,SteamGen.BlowdownBypass(continuous)_

y2RT-6759,SteamGen.BlowdownBypass(continuous) hisc. Waste (continuous if released & sampled) l Blowdown Blowdown Evaporator =

cn Processing Processing

, System System Saltwater from (continuous - sampled)

Neutralization Neutralization Component Cooling =

Sump Sump Heat Exchanger y3RT-7817(batchorcontinuous) f2RT-7817(batchorcontinuous)

Radwaste Primary Tanks y 2/3RT-7813 Liquid Radwaste Effluent Line (batch) e Radwaste Secondary Tanks Primary Plant Makeup Tanks -

Condensate Monitor Tanks PACIFIC OCEAN u Intake 9 Radioactivity Monitor OutFall Figure 2. Radioactive liquid waste effluent pathways and monitors for SONGS Units 2 and 3.

~

(Drawn from descriptions of system and monitoring requirements of FSAR, ODCM, and RETS.)

' ~

l r.

The main pathway for the release of radioactive liquid effluents is the Liquid Radwasta Effluent Line, by which contents of the Radwaste Primary Tanks, Radwaste Secondary Tanks, Primary Plant Makeup Tanks, and Condensate Monitor Tanks may be released to the dilution stream. Radioactive liquid waste from the coolant radwaste (shown unlabeled in the top part of Figure 1),

coolant and boric acid recycle, and miscellaneous liquid waste subsystems are processed in the radwaste system and then either recycled or released.

Releases by this pathway are in batch mode. Sections 1.1.1.2 and 1.1.2.1 of the ODCM indicate that releases from the Steam Generator Blowdown Neutralization Sumps may be made by either batch or continuous mode. Releases through the Turbine Building (Plant) Sumps Effluent Lines and the Steam Generator Blowdown Bypass Effluent Lines are made in continuous mode.

3.2 _Liauid Effluent Monitor Setooints Section 1.1 of the ODCM contains the methodology to determine the 1 setpoints for the liquid radwaste effluent monitors, as required by Technical Specification 3.3.3.8. Technical Specification 3.3.3.8 requires that the '

setpoints for the liquid effluent monitors be set to ensure that radioactive i materials released as effluents shall not result in concentrations in l unrestricted areas in excess of the values specified in 10 CFR 20, Appendix B, Table II, Column 2I93 1

i l The Licensee's ODCM contains complete methodology to determine setpoints l l

l of the radioactive liquid waste effluent monitors in pCi/ml. Some E additional information could be furnished to make it clear how the calibration constants given in Table 1-1 are used to convert from total pCi/ml in the j effluent to counts per minute (cpm) of the monitor. Also, the ODCM should  ;

require that the analyses required by Technical Specifications 4.11.1.1.1 and I 4.11.1.1.3 be used to to obtain the radionuclide concentrations necessary to j determine the setpoints. Each monitored effluent line is administratively I assigned some fraction of the 10 CFR 20 concentration limit. The methodology ensures that the monitored releases do not result in release to the unrestricted area of liquids containing concentrations of radioactive material exceeding the 10 CFR 20 limit.

7 l

l L

s-  ;

Technical Specification 3.11.1.1 requires sampling and analysis of continuous releases of the Miscellaneous Waste Evaporator Condensate and  :

saltwater discharge from the Component Cooling Heat Exchanger discussed in Section 3.1 above. These liquids are apparently not expected to contribute  :

radioactive material to the effluents during normal operation. In Figure 1, condensate from the Miscellaneous Waste Evaporator is shown as being routed ,

to the Condensate Monitor Tanks, which are released by batch mode through i the Liquid Radwaste Effluent Line. The saltwater discharge from the Component Cooling Heat Exchanger is considered part of the dilution flow in Section 1.1 of the ODCM. Any radioactive matarial entering this saltwater must pass through the intermediate Component Cooling Water System barrier, l which the FSAR states is regularly monitored for radioactivity.

Nevertheless, the Licensee apparently considers the possibility of releases i via this pathway since Section 1.1.1 of the 00CM states that the administrative value associated with the effluent monitors will be periodically reviewed based on actual release data, including any saltwater discharge of the Component Cooling Water Heat Exchanger.

A future revision of the ODCM should contain a description, preferably including a schematic drawing, of the release pathways for liquid ef fluents. The description should clarify the use of the administrative factors B2 and B3 for both batch and continuous releases through the ,

Neutralization Sump Discharge Lines. For completeness, " steam generator blowdown bypass"'should be added to the parentheses in Item 2 of Section 1.1.2.

l Nevertheless, the Licensee's methodology to determine the setpoints of l

the radioactive liquid effluent monitors is, in general, within the I

guidelines of NUREG-0133, and is considered acceptable.

l l

l l

8 L

-l 7 .- ,,

{

.Y '

g 3.3 Gaseous Effluent Pathways I

i Technical Specification 3.3.3.9 requires noble gas radioactivity monitors on the following gaseous affluent pathways: ,

a. Waste Gas Holdup System (2/3RT-7808, 2RT 7865-1 or 3RT-7865-1), same for Unit 2 and Unit 3.)

b.- Condenser Evacuation System (2RT-7818 or 2RT-7870 1), for Unit 2; [

and (3RT-7818 or 3RT-7870-1), for Unit 3.

c. Plant Vent Stack (2/3RT-7808, 2RT-7865-1 or 3RT-7865-1), same for  ;

Unit 2 and Unit 3. l d.. Containment purge System (2RT-7828 or 2RT-7865-1(1)0, for Unit 2; ,

(3RT-7828 or 3RT-7865-1(1)), for Unit 3.

t-Figure 3 is a copy of Figure 4-2 from the Licensee's ODCM, showing the '

gaseous radwaste treatment systems at SONGS 2 and 3 and some of the effluent

i. radioactivity monitors. (One of the labels associated with Primary System Degassing and Tank Cover Gases should apparently be " Unit 3.") Figure 4 is a j simple diagram of the gaseous effluent pathways and radioactivity monitors drawn from information in the Licensee's RETS, ODCM, and FSAR. The Unit 2 and [

Unit 3 stacks are shown divided into two vents as described in the FSAR. This figure is based on the reviewer's interpretation of the available information, and has not been reviewed by the Licensee. The turbine building ventilation  !

system does not direct its exhaust to any monitored vents, since the building l contains partially open areas. The gland seal system exhausts to the l atmosphere through the turbine building wall. <

1 1

3.4 Gaseous Effluent Monitor Setoolnts Section 2.1 of the ODCM contains the methodology used to determine the L

L alarm and alarm / trip setpoints for the noble gas radiation monitors, as required by Technical Specification 3.11.2.1. Methodology is given to determine setpoints for all the regular and wide-range monitors of gaseous effluent pathways for Units 2 and 3 required by the technical specifications.

Replacement of page 2-13, Revision 16 by page 2-13, Revision 19 eliminates g

, - ~ . . . - u ~ o , , , . . , - , > , . - , - , ~ .,p-.e-

,- ,,e - - - ,-n.en-- - e- .- ,--'

( ( a.* A., ...h. .a m -V. - - . . 44-n.ii 5' .t 4

' 13 a s I .t 0

\{

' i o. I q

') II IID  !

gq SCO  ?. ~g 5 3

~

+ o.,. n b

,=^

1

>g h i

'n Is rAIg : p n a e 11

-s

=1 -g o

d gl III 1 1

=* .I g N

.li s

Ud.$

  • ui n f $

W r=== # .i .

~

j (A k 1-

-~

t g M L . by N I 3" 1- 1 58 3

3k W 5 ai '

g  : ma as

{I

= a g 5o  ?

V .

.E g:

8 s ;I I ,, e

.i z. .

= E

$ g5

. h ~

o '

- t g

. .h e.  :

". d -

I al d I I j(

3

.a 3 5>a (! s t oO gt O 3 =o1 n e o1 t. sa WO e g M .

4 sE0

  • g go

>W p 5 0 O D =c

' m g aEg Es *

. EI o o

= ! {g e I 3

$$w Ea$g * "

T" . ="

i= G2s 5I

= t a

.% .. C 10

6

~** , . .

Atmosphere Atmosphere Atmosphere Atmosphere

  • Unit 3 Vent *

--Unit 2 Vent

-4 2RT-7870-1 3RT-7865-1 6- 3RT-7870-1 6-(high range) (high range) (high range)

2RT-7865-1(1) 0- -9 2RT-7865-1 -4 '3RT-7865-1(1)
(high range) (high range) (high range)

-4 2RT-7818 -4 3RT-7818

. -9 2/3RT-7808 l 3 -4 2RT-7828 3RT-7828 9-P1 ant +

i Unit 2 Vent Unit 3 Containment Containment Purge Purge l

I I Unit 2 Building Unit 3 Building Ventilation Exhausts y  ; y Ventilation Exhausts Unit 2 Condenser Gas Decay Unit 3 Condenser Evacuation System Tanks (6) Evacuation System 9 Radioactivity Monitor Figure 4. Release pathways and monitors of radioactive gaseous effluents for SDNGS Units 2 and 3.

(Drawn from information in the Licensee's REIS, ODCM, and FSAR.)

'l

~ ~ - -wm, r - - -

.v-

+n. e, , __ _ _ . _ _ _ _ - _ _ _ _ _ _ - u____ _ _ _ _ _ _ __ __

K ,' , f the definitions of the terms in Eq. (2-8), removes Eq. (2-9), and duplicates

s. the top half of page 2-14. This editing error should be corrected. '

The headings, subheadings, and text in Sections 2.1.3 and 2.1.4 should

- specifically address each monitor. By use of the word "or", Items 1 and 4 of Technical Specification Table 3.3-13 imply that monitors 2RT-7865-1 and 3RT-7865-1 may only be used one at a time to monitor effluents. However, Section 2.1.1 of the ODCM accounts for simultaneous use of these two monitors. l

  • ^

Therefore, it is not clear what pathways are permitted for releases from the Waste Gas Holdup System and Plant Vent Stack. The different descriptions of  !

I releases should be made consistent. Table 2-1 contains no calibration constants for monitors 2RT-7870-1, 3RT-7870-1, 2RT-7865-1, 3RT-7865-1, 2RT-7865-1(1), 3RT-7865-1(1), 2RT-7828, or 3Rl 7828. If these monitors read ,

directly in yCi/cc the calibration must be baseo on some asstimptions concerning the composition of the monitored gas, and these assumptions should be stated. ,

i The methodology accounts for simultaneous releases from the different j release points at Units 2 and 3, but does not consider releases from Unit 1.

1 Since the dose rate limits are site linits, the methodology for determining the setpoints should be modified to account for releases from Unit 1. ,

Except for the lack of provisions to account for releases from Unit 1, the L methodology to determine setpoints for the noble gas effluent radioactivity i monitors is considered to be within the guidelines of NUREG-0133.

3.5 Concentrations in Liouid Effluents Section 1.1 of the ODCM contains the methodology to determine that the ,

radionuclide concentrations in the released liquid effluents are maintained within the limits of Technical Specification 3.11.1.1, as required by Technical Specifications 4.11.1.1.1, 4.11.1.1.2, and 4.11.1.1.3. Technical Specification 3.11.1.1 requires compliance to the concentration limits of 10 CFR 20, Appendix B, Table II, Column 2 for radionuclides other titan dissolved and entrained noble gases. For dissolved and entrained noble gases, the concentration is required to be limited to 2 X 10'4 pCi/ml total activity.

12

k

.c- ,

5 A future revision of the 00CM should note that the analyses of liquid ,

effluents required by Technical Specifications 4.11.1.1.1, 4.11.1.1.2, and 4.11.1.1.3 are used to determine the concentrations of various radionuclides in the liquid effluents. The technical specifications require that post-release analyses be used to assure that the concentrations at the point of release were maintained within the limits of Specification 3.11.1.1, but The Licensee may wish to modify the ODCM does not' address these calculations.

the technical specifications to more nearly agree with Revision 3. Draft 7" of NVREG-0472,'which contains somewhat less extensive calculational requirements than Revision 2, on which the Licensee's RETS are apparently based.

The Licensee's methodology to ensure that the concentration of radioactive material in liquid effluents is maintained within the concentration limits of 10 CFR 20 is an integral part of the methodology to determine the setpoints discussed in Section 3.2 above and is, in general, within the guidelines of NUREG-0133.

't 3.6 Dose Rates due to Gaseous Effluents i l

Section 2.2.1 of the ODCM contains the methodology to determine that the L dose rates due to the release of radioactive noble gases are within the limits of Technical Specification 3.11.2.1.a. as required by Technical Specification l' 4.11.2.1.1. Technical Specification 3.ll.2.1.a requires that the dose rates t

I due to noble gases at or beyond the site boundary be limited to less than or l equal to 500 mrem /yr to the whole body and less than or equal to 3000 mrem /yr to the skin.

l l Section 2.2.1 should be modified to include a description of the method l used to determine the release rates (Q) used in the dose rate equations,

l. (2-11) and (2-12), and should account for releases from all reactor units on the site. With these exceptions the Licensee's methodology to determine that the dose rates due to the release of radioactive noble gases are within the limits of Technical Specification 3.11.2.1.a is considered to be within the guidelines of NUREG-0133.

1 13 L

i

l i o l .

L *t Section 2.2.2 of the ODCM contains the methodology for determining that the dose rate due to release of radioactive gaseous effluents (other than noble gases) are within the limits of Technical Specification 3.11.2.1.b. as required by Technical Specification 4.11.2.1.2. Technical Specification 3.11.2.1.b requires that the dose rate due to radioiodines, tritium and all

( radioactive materials in particulate form with half lives greater than 8 days be limited to less than or equal to 1500 mrem /yr to any organ.

The methodology described in Section 2.2.2 sums the maximum organ dose to  ;

a child via the inhalation pathway, considering all locations and summing the maximum organ dose due to each radionuclide over all radionuclides. The Licensee may wish to change the requirements to match the recommendation in the bases statement for Technical Specification 3.11.2.1.b for SONGS Units 2

(

and 3 and NUREG-0472; i.e., that the organ dose limit may be applied to the thyroid of a child via the inhalation pathway. However, the more conservative methodology described is acceptable.

Section.2.2.2 should be modified to include a description of the method used to determine the release rates (Q) used in the dose rate equation (2-13) for the determination of the organ dose rate. The value of the release rate ,

should: include releases from Unit I as well as from Units 2 and 3, since the r organ dose rate limit is a site' limit. If the method for determining the release rates is described and releases from all reactors on the site are accounted for in the calculations, the Licensre's methodology to determine that the dose rates due to release of radioactive gaseous effluents other than noble gases are within the limits of Technical Specification 3.11.1.1.b is considered to be within the guidelines of NUREG-0133.

l 3.7 Dose Due to Liauid Effluents Section 1.2 of the ODCM contains the methodology to determine the dose or dose commitment to the maximum exposed member of the public due to radioactive materials in liquid effluents to demonstrate compliance with the dose limits of Technical Specification 3.11.1.2, as required by Technical Specification 4.11.1.2.

4 14

,,zt l

l i I '. ,

j i

Equation (1-19) of Section 1.2 is a general statement of the method for f calculating the dose due to liquid effluents. This section should identify j the releases considered in.the calculations, the individuals exposed, the -

exposure pathways considered and the consumption and occupation factors used j in the calculations. The releases considered in the calculations could be i identified by appropriate reference to 00CM 3ections 1.1 and 1.2, which identify all of the monitored release pathways in connection with the setpoint I calculations. The possibility of contributions to the offsite dose from ,

sampled and analyzed, but unmonitored, releases should also be addressed as is l done in Section 1.1 for monitor setpoints. Vt. lues of Dose Commitment Factors, Aj7, in Table 1-2 were checked for the radionuclides in Regulatory Gui%

1.109, assuming saltwater fish consumption of 21 kg/yr and saltwater ,

invertebrate consumption of 5 kg/yr for an adult. Since other values calculated by the reviewer using these assumptions agreed with values in Table 1-2 of the ODCM, it appears that Table 1-2 should be corrected to show .

the values given below:  ;

Nuclide T. Body Bone liver Kidney GI-LLI Na-24 4.57E-01 Zr-97 1.80E-01 Sr-91 3.71E+00 9.18E+01 ,

Ru-103 1.25E+04 Te-132 2.04E+02 Ce-143 4.46+02 The NRC Staff allows the dose for a reporting period (calendar quarter or ,

calendar year) to be calculated using the average dilution flow for the I reporting period. The Licensee may wish to consider this method to calculate reported doses.

The ODCM methodology as written is too general and should identify the releases considered in the dose calculations, the individual for which the calculations were made, and the pathways and consumption rates used in the calculations. With these exceptions, the methodology to determine the doses '

due to radioactive materials released in liquid effluents are considered to be within the guidelines of NUREG-0133.

15

,-Q. .

)

1 3.8 Dose due to Gaseous Effluents 1 Section 2.3 of the ODCM gives general equations for the calculation of doses due to the release of radioactive material in gaseous effluents. The releases considered in the dose calculations should be specified in this section, either explicitly or by appropriate reference to ODCM Section 2.1, ,

which discusses monitor setpoints. Methods used to determine the total releases or release rates of radionuclides should also be included in this section.

Sections 2.3.1.1 and 2.3.1.2 of the ODCM contain the methodology for ,

cateulating the gamma air dose and beta air doses to demonstrate compliance with the air dose limits of Technical Specification 3.11.2.2, as required by Technical Specification 4.11.2.2. Technical Specification 3.11.2.2 require that the air doses from each reactor unit be limited to less than or equal to 5 mrad for gamma radiation and 10 mrad for beta radiation during any calendar quarter, and less than or equal to 10 mrad for gamma radiation and 20 mrad for ,

beta radiation during any calendar year.

Section 2.3.1.1 of the ODCM gives the general expression for calculating air doses based on historical meteorology and Section 2.3.1.2 gives the l general expression for calculating air doses based on meteorology concurrent with releases. The term " projected" in the definitions of 07and l

Dg in Section 2.3.1.1 serns inappropriate, since the doses are due to L releases already made.

l l

L The methodology of Sections 2.3.1.1 and 2.3.1.2 for determining gamma and I

beta air doses is considered to be within the guidelines of NUREG-0133 if the releases considered are identified and the methods used to determine the i quantities of radionuclides and the rates of release of radionuclides are described.

Sections 2.3.2.1 and 2.3.2.2 of the ODCM give general expressions for calculating the dose to an individual from tritium, radiciodines and radioactive materials in radioactive materials in particulate form with half-lives greater than 8 days in gaseous effluents, as required by Technical Specification 4.11.2.3. Section 2.3.2.1 contains an expression for 16

,o~.

calculations using historical meteorology and Section 2.3.2.2 contains a corresponding expression using meteorology concurrent with releases, i The ODCM Tables 2-5 through 2-14 are tables of dose parameters, Rj, for the inhalation and for the food and ground plane pathways for the infant, child, teen, and adult age groups. Values are given for ten sectors, with three to eight locations per sector. These tables give distance, sector, X/Q,  ;

and D/Q of " controlling locations." There is also a " Pathway" label on each

  • table, which seems to usually be a descriptive location but also includes
  • labels " Sheep (ment)" and " Deer Consumer." The pages of Tables 2-5 through 2-7 of Revision 19 are not numbered to be consistent with the pages of Revision 18.

The ODCM does not contain any of the parameters necessary for the calculation of the dose parameters, Rj. All parameters necessary for the ,

calculations should be included. Also, the equations used to calculate the values of R$ should be identified, either by giving the equations or by reference. The reviewer attempted to verify the Rj values in Tables 2-5 '

through 2-14 by calculations using equations from Sections 5.3.1.1 through 5.3.1.5 of NUREG-0133 and default parameters from Regulatory Guide 1.109. For j the inhalation pathway the highest values of Rj in the tables for each j radionuclide appear to be the highest organ dose factor for each age group, l except that the dose factor for the lung (which is the highest factor for l many radionuclides) is excluded without explanation. This exclusion should be ,

justified. The highest food and ground plane pathway values of Rg are comparable to the values obtained by summing the Rj's defined in Sections 5.3.1.2 through 5.3.1.5 of NUREG-0133 over the various pathways. However, both the inhalation pathway factors and the food and ground plane pathway factors j vary from near the values calculated using default parameters of Regulatory Guide 1.109 to a small fraction (=10%) of these values.

The footnote to Table 2-4 states that the table values are to be used in manual calculat, ions and are the maximum I(R ikWk) for all locations basedonthemostrestrictiveagegroupkwherekissummedoverallpathways).

A clearer definition of the term " controlling location" should be given in the ODCM. There appear to be 41 controlling locations identified in the ODCM.

17 l

I i;gr. '

l i

j r The use of the. sum of the highest organ doses for individual radionuclides a to calculate the maximum organ doses for comparison with the limit of  ;

Technical Specification 3.11.2.3 is expected to give a conservatively high calculated organ dose, which is acceptable. The Licensee may wish to modify the calculation so as to use the highest calculated dose to a single organ at the critical location (the location giving the highest calculated organ dose) '

for comparison with the technical specification limit.

More details of the methodology used and the parameters necessary for the calculations of the orgen doses need to be included in the ODCM for the methodology to be considered to be within the guidelines of NUREG-0133, the definition of the ODCM given in in the Licensee's technical specifications, and the NRC Staff guidance in the Radiological Assessment Branch Technical Position W .

3.9 Dose Pro.iections Technical Specification 4.11.1.3.1 requires that doses due to liquid l releases be projected at least once per 31 days in accordance with the ODCM.

l Section 3.1 of the ODCM specifies that the projected doses for 31 days will be equal to the previous twelve months doses divided by 12. The Licensee should

  • c address the possibility of anticipated unusual releases. However, the l methodology to project doses is considered to be, in general, within the guidelines of NUREG-0133.

i Technical Specification 4.11.2.4.1 requires that doses due to gaseous releases be projected at least once per 31 days in accordance with the ODCM.

Section 3.2 of the ODCM specifies that the projected doses for 31 days will be equal to the previous twelve months doses divided 12. The Licensee should address the possibility of anticipated unusual releases. Mcwever, the metnodology to project doses is considered to be, in general, within the guidelines of NUREG-0133.

18

E i t; - . 4 R' ., a-

)

3.10 Dinarams of Effluent Pathways 1

l Simplified diagrams of the liquid, gaseous, and solid waste treatment )

systems are shown in Figures 4-1, 4-2, and 4-3 of the ODCM. However, maps showing site boundaries, unrestricted areas, and effluent release points are not included in the ODCM.

3.11 Total Dose Section 2.4 of the ODCM describes the method used to determine the total dose to any member of the public, to demonstrate compliance with 40 CFR 190,. ,

when the calculated dose from the release of radioactive materials in liquid #

or gaseous effluents exceed twice any of the limits of Technical Specifications 3.11.1.2.a. 3.11.1.2.b. 3.ll.2.2.a, 3.II.2.2.b, 3.ll.2.3.a or 3.11.2.3 b. The methodology includes determination of doses due to all releases of radioactive material from the site (Units 1, 2, and 3), doses i

due to direct radiation, and doses due to uranium fuel cycle sources within five miles of the site, and is therefore acceptable.

3.12 Environmental Monitorina Proaram Section 5.0 of the ODCM identifies specific parameters of distance and the direction sector from the site and additional information for the samples identified in Environmental Monitoring Table 3.12-1 of Technical Specification 3.12.1. All sample locations required by Technical Specification 3.12.1 are de:;cribed in the ODCM, as required by Technical Specification 4.12.1. The map of environmental monitoring locations identified as Figure 5.1 in ODCM Section 5.0 is not in the ODCM. This figure should be added, since a map of environmental monitoring locations is required by Technical Specification 4.12.1. Except for lack of a map of the environmental monitoring locations, Section 5.0 of the ODCM is considered acceptable.

19

.o ' * .

\

i 3.13 Summarv l The Licensee's 00CM, updated through Revision 19. uses documented and approved methods that are, in general, consistent with the methodology and guidance in ilVREG 0133. Most deficiencies noted were relatively minor.

However, it is recommended that the NRC request the ODCM to be revised so  !

gaseous effluents from Unit I are considered when gaseous setpoints and dose <

rates are calculated for Units 2 and 3, and that other deficiencies identified in this review be addressed in a future revision. -

(

1 1

l l

l 20 l

Y q--g -n -

,e . . i

.. " i E

CONCLUSIONS i The Licensee's complete ODCM for the San Onofre Nuclear Generating Station, Units 2 and 3, updated through Revision 19, dated May 4, 1988 was reviewed. It <

was determined that the ODCM uses methods that are, in general, consistent with the guidelines ~of NUREG-0133. Most deficiencies noted are relatively minor. >

However, it is recommended that the 00CM be revised to require that gaseous effluents from Unit I be considered when gaseous setpoints and dose rates are calculated for Units 2 and 3, and that other discrepancies identified in the  !

review be addressed in a future revision.  ;

The'following discrepancies should be addressed:

. Sections 1.1.1 and 1.1.2, respectively, should require that the ,

analyses required by Technical Specifications 4.11.1.1.1 and 4.11.1.1.3 l be used to determine the setpoints for the liquid effluent monitors. '

. Section 1.2 should identify the liquid releases considered in the dose calculations, the individuals exposed, the exposure pathways -

considered, and the consumption and occupation factors used.  ;

l . Table 1.2 should apparently be corrected as shown below (See Section 3.7):

l .

Nuclide T. Body Bone Liver Kidney GI-LLI Na-24 4.57E-01 L Zr-97 1. :.10E-01 l Sr-91 3.71E+00 9.18E+01 l Ru-103 1.25E+04 Te-132 2.04E+02 Ce-143 4.46+02

. Sections 2.1 and 2.2, respectively, for the setpoints of gaseous effluent monitors and gaseous effluent dose rates should account for releases from Unit 1.

21

.,j j , ]

e 1 e

. Table 2-1 should include calibration constants for all gaseous ,

effluent menitors or identify the mixture or means of determining the l mixture of radionuclides assumed for the calibration.

. Sections 2.2.1. and 2.2.2 should be expanded to include descriptions f

of the methods-used to determine release rates used in the calculation of dose rates due to gaseous effluents. 3 5

. Section 2.3 should identify the releases considered in the calculatio'n of doses due to gaseous effluents and the methods used to determine the total releases or release retes. ,

. Section 2.2.2 should include all parameters necessary for the ,

calculation of the dose parameters, Rj, in Tables 2-5 through 2-14. The' equations used to calculate the values of Rg should also *

[ be identified, either by giving the equations or by reference.

L t

? . The exclusion of doses to the lung in Tables 2-5 through 2-14 should be justified.

L

. Sections 3.1 and 3.2 should include provisions for considering  ;

anticipated unusual releases when making dose projections.

. A map of environmental monitoring locations should be added to Section 5.0.

l The following discrepancies, which apparently arise from typographical errors or editorial omissions, should be corrected: i

. In Table 1-2, the signs of the exponents of the liver factors for Zr-97 and Ce-143 should be changed, and the GI-LLI factor for Ru 103 should apparently be 1.25E+04 instead, of 2.25E+04.

. Page 2-13 of Revision 19 should be corrected so Eq. (2-9) and the definitions of terms in Eq. (2-8) are not deleted, and the top of page 2-14 is not duplicated.

22

~,

go o .

Sections 2.1.3 and 2.1.4 should be edited so setpoints af all gaseous effluent monitors are specifically addressed in the headings, subheadings, and texts. .

. In Sections 2.3.1.1 and 2.3.2.1, the term ' projected" should be removed, since it implies doses in the future instead of doses or dose commitments due to releases already made. '

. One of the " Unit 2" designations associated with Prim.try System Degassing and Tank Cover Gases in Figure 41 should be changed to

" Unit 3."

. Figures,4.1 and 4.2 should indicate all release pathways and monitors of liquid and gaseous effluents consistent with the release pathways and monitors identified in Sections 1.1 and 2.1.

Additionally, the Licensee may want to consider the following changes:

In Section 1.2, the Licensee may wish to use the average dilution flow for the reporting period in the calculations of doses due to liquid effluents, a method allowed by the NRC Staff.

. . The Licensee may wish to modify the requirements in Section 2.2.2 to match the recommendations in the bases statement for Technical Specification 3.ll.2.1.b for SONGS Units 2 and 3 and in NUREG-0472:

l 1.e., that the organ dose rate limit may be applied to the thyroid of i

j. a child via the inhalation pathway.

L . The Licensee may wish to modify Section 2.3.2 to calculate the highest calculated dose to a single organ at the critical location for comparison with the technical specification organ dose limit.

D . The Licensee may wish to amend Technical Specifications 4.11.1.1.1, L 4.11.1.1.2, and 4.11.1.1.3 to more nearly agree with Specifications

! 4.11.1.1.1 and 4.11.1.1.2 of Revision 3, Oraft 7" of NUREG-0472.

23

c,;o o -

i'

' . s.t. ,

o: ,

5. REFERENCES

-1.- Title 10, Code of Federal Reaulations, Part 50, Appendix I, ' Numerical l

. Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, 'As low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-cooled Nuclear Power Reactor 7 Effluents." ,

2. Letter from H.'E. Morgan (SCE) to Director, Office of Management ,

Information and Program Analysis (NRC),

Subject:

Docket Nos. ,

50-361/50-362 - Monthly Operating Reports for August 1985 -

San Onofre Nuclear Generating Station, Units 2 and 3, September 16, 1985.

3. . Letter fron' H. E. Morgan (SCE) to Director, Office of Management

.. Information and Program Analysis (NRC),

Subject:

Docket Nos.

50-361/50-361 - Monthly Operating Reports for May 1985 -

San Onofre Nuclear Generating Station, Units 2 and 3, June 12, 1986, i

4. Lett'er from H. E. Morgan (SCE) to Director, Office of Management Information and Program Analysis (NRC),

Subject:

Docket Nos.

50-361/50-362 - Monthly Operating Reports for June 1988 -

San Onofre l

Nuclear Generating Station, Units 2 and 3, July 15,1988.

/ 1

5. " Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3. Draft 7", intended for contractor guidance in ,

reviewing RETS proposals for operating reactors, NUREG-0472, September >

1982.

6. " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications," NUREG-0133, October 1978.
7. " General Contents of the Offsite Dose Calculation Manual," Revision 1 l Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.

24

a **O i

c. d' C' o-

't

8. Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the .*urpose of Evaluating Compliance with 10 CFR 50.

Appendix 1,' Regulatory Guide 1.109. Rev. 1, October 1977.

9. Title 10, code of Federr,' Raoulations Part 20. " Standards for Protection Against Radiation.'

i

.l l

h

( l f

I I

i l

e I

6 3

i 25

9 o j o 5, ' ,, l

.g . -

j i

l g,, me .. ........... . . . i . . . - , .e e - . . ~ ~  :

  • , ' ".*.7,' hituooRAPH6c OATA sweet EGG-PHY.8282

. . ,c. . m  ;

EE'dNIM"'l' VALUATION REPORT FOR THE EVALUATION OF ~

3DCM (UPDATED THROUGH REVISION 19) SAN ONOFRE NUCLEAR 3ENERATING STA' TION, UNITS 2 AND 3 ***""*'"*'"*  !

OCTOBEI'~ l 1980** [

T. E. Young . .. .. . ......

}

L W. Serrano l l OCTOBER 1988 *

.....m.4...........c....,.% . ,. c . i . . . . .

Radiological Physics i EG8G Idaho, Inc., ai'"**"="  !

P. O. Box 1625 Idaho Falls, ID 83415 06034 l

....<.m.4...........<...w,,,,,. ...n...... l Office of Nuclear Reactor Regulation i U. 5. Nuclear Regulatory Commission Final  :

Washington, D. C. 20555 "*a""*"--- I i

.,i .. . . ... .. e. L

. . . .. : ~ l The t'fsite Dose Calcuation Manuai (ODCM) for the San Onofre Nuclear i Generating Station, Units 2 and 3 contains current methodology and parameters for calculation of offsite doses due to radioactive liquid and gaseous effluents,  !

determination of gaseous and liquid effluent monitors alarm / trip setpoints, and  ;

for conduct of the environmental radiological monitoring program. Revisions of i the ODCM for Units 2 and 3 are submitted to the NRC in the Monthly Operating Reports as required by the Licensee's Technical Specification 16.4.2. It was '

determined that the ODCM, updated through Revision 19. uses methods that are, in general, consistent with the guidelines of NUREG-0133. Most deficiencies noted were relatively minor. However, it is recommended that a revision '

containing requirements for including gaseous effluents from Unit 1 in monitor '

setpoint and offsite dose rate calculati us be submitted by the Licensee, and '

that other deficiencies identified in the review be addressed in a future  ;

revision. t

.. .. .......... .... . ...t.... ..

...,.,.,.g.,,..

Unlimited

..................c...

. ... .. .. .. .. .m i ..a ma Unc1assified i Unclassified

.,......s...w

. *. iC I i

- -

Retrieved from "https://kanterella.com/w/index.php?title=ML19324A618&oldid=2488243"