ML20002C835
| ML20002C835 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/14/1977 |
| From: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Desiree Davis Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8101120127 | |
| Download: ML20002C835 (11) | |
Text
.
C.C0mpBDy COOSum8FS t POW 8r Genend Offices: 212 West MicNgan Avenue. Jackson, Michigan 49201
- Area Code 617 788 0550 E.".,. er:[b
~,c#'y LW=@..'
June ik, 1977 y
i f.!,
h
".Y h
Director of Nuclear Reactor Regulation d/ G
\\\\
y g F O,$
Att: Mr Don K Davis, Acting Branch Chief
_J B
fjN. p$ gy) 4 7 Operating Reactor Brauh No 2 g
pyyb US Nuclear Regulatory Co= mission i
Washington, DC 20555 DOCKET 50-155, LICENSE DPR g\\\\
s BIG ROCK POINT PLANT - FURTHER DATA ON RIJEASTE CONCERTRATOR T/S CHANGE By letter dated May 25, 1977, Consumers Power Company requested a change to the Big Rock Point Technical Specifications allowing the removal of the radvaste concentrator and associated piping and replacing them with a system of filters.
The purpose of this change is to meet the total suspended solids limitation in-poced by the State of Michigan in the NPDES permit effective July 1, 1977. Sub-sequent to that submittal, there have been discussions with your staff concerning the effect of the removal of the radvaste concentrator on total effluent radio-activity discharged and on the results of the 10 CFR 50 Appendix I calculations submitted June h,1976. The purpose of this letter is to document portions of those discussions.
As stipulated in our Technical Specifications change request submittal of May 25, 1977, the radvaste concentrator system installed at Big Rock Peint is obsolete and incapable of performing its function. This system was part of the criginal equipment at Big Rock Point (late 1950's Fesign); therefore, does not meet cur-rent standards or technology. The concentrator system utilizes auxiliary steam, or extraction stecs, to concentrate effluents. This steam is then returned, in the form of condensate, to the se.ne tanks it was used to condense. Thus, because of this, the process has the unfortunate characteristic of producing more efflu-ent than it concentrates.
Further, if the radvaste concentrator system were re-plaend by the filtratien system as t roposed in the May 25 submittal, the resultant decontamination factor (DF) is expected to be approximately 2.
It should be noted
, that the 10 CFR 50 Appendix I calculations submitted for Big Rock Point take no credit for the operability or use of the radvaste concentrator system. The only mention of this system lies in the schematic submitted with the June h,19761 tter that shows the. Liquid radvaste system as it Currently exists (with Concentrator).
Attached is a cost / benefit study of the radusste concentrator system as it affects
(
the enviro 1:ent for the Big Rock Point. The study makes the optimistic assumption 8/6/ mow?
vtumnosa
s 2
I that through modification of the radvaste concentrator system the DF could be increased to 100, making it comparable to the currently approved DF for present day evapora ion units (assuming detergent vaste). Using this assunption, it postulates i he total man-Rem saving within a 50-mile radius of Big Rock Point.
This saving amounts to 0.35 man-Rem.
Using the criteria established in 10 CFR 50 Appendix I, Section II.D, the maxi-mum. justifiable annualized cost to reaconably effect this modification vould be
$350.
Considering the scope of the modifications necessary to raise.the DF of the radvaste concentrator system to 100, it is readily apparent that this is not possible under the established monetary constraints. However, if, based on the staff's review of our June h,1976 submittal (10 CFR 50 Appendix I calculations),
an alternative approach is necessary (consistent with the guidelines established by 10 CFR 50 Appendix I, Section II.D) to further limit liquid effluent releases, Consumers Power Company vill take appropriate action to do so.
As indicated in our letter of May 25, 1977, Consuncrs Power Company is under a significant time restraint in the installation of the filtration system; thus,
your expedient action in approval of the proposal is requested.
.-, [ :.
ib JY,
{N j
David A Bixel
/
Nuclear Licensing. Administrator CC: JGKeppler, USNRC
i 3
Atttchm:nt 1 COST-BENEFIT INFORMATION RELATING TO BIG ROCK POINT TECHNICAL SPECIFICATIONS CHANGE Removal of Radioactive Waste Concentrator The following sections describe 443. determination of population dose for the case where no radioactive vaste concentrator is used, as is the actual case at
-Big Rock Point (Section 1.0), and for the theoretical case where optimum con-centrator operation is postulated (Section 2.0).
Population dose without the use of the concentrator is found to be approximately 0.97 man-Rem. With con-centrator, allowing an' extra 365 days of decay due to concentrate storage prior to release, dose is reduced to approximately 0.62 man-Rem. Thus, the population dose reduction which theoretically could be achieved by utilizing an efficient concentrator is 0.35 man-Rem.
1.0 Population Dose Without Concentrator Calculations of population doses resulting from radioactive liquid effluents from Big Rock Point have been made using the NRC LADTAP code using models, parameter values, and assumptions as outlined in Regulatory Guide 1.109 (March 1976). Table 1 provides the LADTAP input data utilized, and summarizes the pertinent dose results.
Liquid effluents from Big Rock Point are discharged to Lake Michigan at the plant shoreline, after dilution with the plant cooling vater flow which ranges from L8,000 to 52,000 gpm under normal conditions. Pathways of exposure for significant population groups within 50 miles include internal exposure from water and fish ingestion, and external exposure while svim=ing, boating, or engaging in shoreline activities. Appropriate site specific use data for each of these exposure pathways were developed as input into the LADTAP program for dosq analysis. Site specific LADTAP input data and resultant doses are dis-cussed below, for each pathway individually.
e A dilution factor of 800 and a transit time of h.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (based on an estimate for the municipal water supply inlet of the city of Charlevoix, k.6 miles SW, Ref 1) was used for all liquid pathways. This approach is considered conser-vative since shoreline use, boating, and fish catch are all based on a 50-mile
(
radius of the plant.
1
l i
Z The only significant population group exposed via water ingestion, within 50 miles, is that of the city of Charlevoix. Based on a projected year 2000 population of 7,070 (1970 population 3,519), the population of Charlevoix will receive an annual whole body dose of 0.0025 man-Rem.
Population exposure via fish ingestion was calculated separately for sport fish harvest and com=ercial fish harvest. Table 2 provides an estimate of the nu=-
ber of sport fish caught annually by sport fishermen for shoreline counties within 50 miles of Big Rock Point, as well as the estimated average weight of each type of fish (Ref 2, 3). These data were analyzed to dete:aine the mass of sport fish harvested annually within 50 miles of the Aig Rock Point Plant; 5
a value of 3 29 x 10 kg/yr was estimated, based on an assumed edible fraction of 50 percent. The total edible catch was assumed to be eaten by the popula-tion within 50 miles cf the Big Rock Pr 'nt Plant as outlined in Regulatory Guide 1.109 The above data resulted in a dose estimate of 0.60 whole body man-Rem for the sport fish ingestion pathway, using the dilutien factor of 800.
For the commercial fish ingestion pathway, recent statistics (Ref h) indicate that 5 million pounds per year are a reasonable estimate of the mass of fish caught annually in Lake Michigan by Michigan fishermen (excluding alevives and chubs which are not normally processed for human consumption). Assuming that 25 percent of this total is harvested viti.in 50 miles of Big Rock Point and that the edible fraction is 30 percent yields an effective harvest rate of 1 70 x 10 kg/yr for the Big Rock Point vicinity. As indicated in Regulatory Guide 1.109 the commercial harvest is considered as pa*+. of the total US harvest.
As a result the concentration in commercial fish is distributed throughout the US in order to calculate the market dilution and, hence, the average concentra-tion for population dose purposes. Applying e, dilution factor of 800 yields a dose estimate of 0.0097 whole body man-Rem per year for the commercial fish 3ngestion pathway.
Published estimates of activity days per year for various water-related recrea-tional activities for regions of the State of Michigan (Ref 5) were ana;yzed to
- (
estimate the number of man-hours per year spent in shoreline activities, 2
J
^
-i swimming, and boating, by people within'50 miles of Big Rock Point. Shoreline I
I use was estimated at 3.8 x 10 man-hours per year, swimming at 1.2 x 10 man-I hours per year, and boating was estimated at 3 7 x 10 man-hours per year.
A dilution factor of 800 was applied uniformly to all three of these activity categories yielding whole body dose estimates of 0.35 man-Rem /yr for shoreline
-activities; 0.0007 man-Rem /yr for swimming; and 0.001 man-Rem /yr for boating.
Based on all of the above, the total annual whole body dose to the 0-50-mile population from Big Rock Point liquid effluents is about 0 97 man-Rem.
2.0 Population Dose With Concentrator Annual effluent release quantities, adjusted to an 80 percent capacity factor, are given in Table D-1, Ref 6.
The mt412 mn total body dose to the individual 2.3 millirem /yr, assuming the radvaste was calculated by NRC LADTAP code ts t concentrator inoperable.
In order to determine dose with the concentrator in operation, it was assuned that a satisfactorily operating concentrator would afford a DF of 100 (assu=ing detergent vaste) and further assumes concentrates could be stored for one year to allow decay prior to release.
Those nuclides which would remain as significant dose contributors after the
.1-year storage interval are shown in Table 3 It should be noted that Co-60 and Cs-137 dominate as the major dose contributors after the added year of decay. Dose percentages are derived by:
(1) Dividing the decayed activity by the the Design Objective' Annual Quantity (DOAQ)* as proposed in the Technical Specifications portion (Table 3.5.lb) of Reference 6, to give values in Table 3 headed "% DOAQ"; then (2) dividing the "% DOAQ" values by 0.767 which is the fraction 2.3 mrem /3.0 mrem of the Appendix I design limit (3 0 mrem) contributed by all nuclides without use of the concentrator. The resultant "% Dose" values of Table 3 are the percent of the " maximum individual" dose (2.3 mrem) obtained if all effluent were held 31 ho days plus on additional 365 days prior to re-lease assuming the use of an efficiently operating concentrator and the addi-tional holdup.
- That quantity of a nuclide which would result in an annual dose of 3 mrem to the total body from all' 11 quid paths.
l 3
4 i
1;.
(
The values of Table 3 are applied to population dose and presented in Table 4.
In terms of the calculation, it should be noted that the decay factors derived
'from the " maximum individual" are considered conservative when applied to popu-lation dose. This is true because the relatively longer decay interval between release and exposure of the general population minimizes the effect of increased decay in-plant. Thus, the true population dose reduction would be expected to be elightly less than the 0.35 man-hem calculated.
t u
_.. ~.
m-
~
/
TAhLE 1 Ladtap Input Data and Results, Fopulation Doses a
Transit Population Dose, Man-Rem /Yr Exposure Pathway
' Dilution Factor Time, Hours Population or Use Rate T Body-Thyroid Water Ingestion 800 h.6 7 07 + 3 (People)_
2.50-3 1 59-3
" Sport Fish Ingestion 800 h.6 3.29 + 5 (Kg/Yr) 6.04-1 1 72-3
- Commercial Fish 800 h.6 1.70 + 5 (Kg/Yr) 9 66-3 2.13-5 Ingestion Shoreline Activities 800 h.6 3.80 + 7 (Hours /Yr) 354-3 3.54-1 Swimming 800 h.6 1.20 + 7 (Hours /Yr) 6.53 h 6.53 Boating 800 h.6
-3 70 + 7 (Hours /Yr)
-1.01-3 1.01-3 Totals
-9 72-1 3 59-1 Other Date: Plant Discharge Flov
= 109 Cfs Recirculation Fraction = 0.03 Recirculation Delay
= 0.5 Heurs Shore Width Factor
= 0.3 50 Mile Population
= 2.39 + 5
" Note that the population dose resulting from sport fish ingestion assumes that all the sport fish caught within 50 miles of the plant are eaten by the 0-50 mile population. The dose resulting from commercial fish ingestion is based upon the distribution of all commercial fish caught within 50 miles of the plant throughout the total, US harvest.
~.
.. _-~
..-..+
e TABLE 2 Estimated Sport Fish Catch Rate for Counties Within 50 Miles (3)tiumber of Fish Caught Annually Yellow
.. Lake Rainbow Brown Chinook Coho County Perch Trout Trout Trout
-Salmon Salmon Charlevoix 4.h10 23,760
.720-1,530 360 1,hko' Emmet 51,8ho 23,0h0 5,0h0 1,350
.19,260 -
5,0h0
[
Mackinac 8,550 0
0 360 0
0
--Antrim 11,880 2,880 360 810 270 360 Grand Traverse 22,140 22,770 h,1h0 1,710 2,160 10,620
.m Lelanau 8,370 25,560 450 630 270 l',800 Totals 107,190 98,010 10,710 6,390 22.320 19,260 (4) cross Lb/ Fish 0.5 9
h.5 h.5 13 75 i
Oross.Lb/Yr 53,595 882,090 48,195 28,755 290,160 144,450 G
4
- - - - - -. - - -. - - ~.
-4
(
i TABLE 3
- Use of Concentrator - Effect of Increased Decay Nuclide Release 8 31 to kod 31 to h0d Plus Added 365 Days (Ci/ Year)
(Ci/ Year) (*% DOAQ) (**% Dese)
Co-60 h.51 E-01 3 96 E-01 h.0 5.2 Cs-137 6.30 E-01 6.16 E-01 hh.3 57.8 Sr-90 2.03 E-03 1 98 E-03 0.2 0.3 Fe-55 2 95 E-01 2.28 E-01 Total 63.3%
- Design Objective Annual Quantity c* Percent of No-Concentrator Dose TABLE h
(
Population Dose - Effect of Optimum Concentrator Use Effect Nuclide
% Dos 3 Man-Rem DF = 100 All 1.0 0.01 Decay Co-60 52 0.05 Decay Cs-137 57.8 0 56 Decay Sr-90 03 Nil Decay Fe-55 Nil Nil
{
Total 0.62
.". Man-Rem Saving = 0 97 - 0.62 = g 4 I T
\\.
I
(/
REFERENCES 1.
Ayers, J C, et al, " Big Rock Point Power Plant Hydrological Study,"
Institute of Science and Technology, University of Michigan, November 1961.
2.
Annual Mail Creel Census, Michigan Department of Natural Resources, 1973
.3. _ Telephone conversation, Jack Hayes, NUS Corperation, with Ned Fogle, Michigan Department of Natural Resources, Msy 21, 1976.
. h. '" Fishery Statistics of the United States," Statistical Digest No 63, US Department of Commerce (1972).
5 "1974 Michigan Recreation Plan Summary," Michigan Department of Natural Resources, Office of Planning Services, December 1975 6.
Letter from R B Seve11 to Director of Nuclear Reactor Regulation, Washington, DC, dated June h,1976.
I, c.
(
8 4
..__r
e U.C. NUCLE AR KEGULATC RY COMMI...ON DOCKET NUMIE R J.C FIRM So - / 55' 195
<2 7 >
""""2'"
NRC DISTRIBUTION FOR PART 50 DOCKET MATERI AL FROM:
DATE OF DOCUMENT TO:
Consumers Power Company 6/14/77 Mr. Don K. Davis Jack mn, Michi'gan oATE RECEivEo Davia A. Bixel 6/16/77
- AETTE R O NoToRizE D PROP INPUT FORM NUMBER OF COPIES RECEIVED 82".lGIN A L UNCLASSIFIED ljffQ &
QCOPY ENCLOSU RE DE:!C RIPTION Consists of further data on radwaste g
g concentrator tech spec change.......
r d
(2-P)
( 8-P )
PLANT NAtE: Big Rock Point RJL 6/17/77
//o e FOR ACTION /INFORMATION ENVIPSNMENTAL 9AFETY ASSIJNED ADr ASSIGNED AD:
V. MOORE (LTR)
/,
FRANCH CHIEFr CT) 2/& FAWN BRANCH CHIEF:
/21 68/ 6 PROJECT MANAGER:
PROJECT MANAGER: '
8
/
LICENSING ASSISTANT:
DIGG3 LICENSING ASSISTANT:
B. HARLESS INTERNAL DISTRIBUTION p
m A RFR FTT ER d SYSTFMS SAFETY PLANT SYSTEMS SITE SAFETY &
[FinR HEINEMAN TEDESCO ENVIRON ANALYSIS
/
T AF ( '1. I SCHROEDER BENAROYA DENION & MULLER LATNAS CRitTCMFTELD
/
nFfD
[COSSICK & STAFF ENGINEERING IPPOLITO
/
MANAITER KNIGHT F. ROSA ENVIRO TECH.
MTPC BOSNAK ERNST SIHWELL OPERATING REACTORS BALLARD J CA9E a
nnyn PAWLICKI
[
STELLO YOUNGBLOOD
/
ETRENHUT PRn TFCT MANACEFENT REACIDR SAFETY
/
SHAO synvHnLT ROSS
/
BAER P. COLLINS NOVAK
/
BUTLER GAMMILL (2)
MOUS'IDN ROS7TOCZY
/
GRIMES MELTZ
/ CHECK SITE ANALYSIS VOLLSER HELTEMES RR AT&T
_ BUNCH SALTZMAN
/ J. COLLINS KREGER RUTBERG i
EXTERNAL DISTRIBUTION CONTROL NUMBER
/ LPDRrfA4ELMIX NCf*
/
/ NSIC
~
~
Y71iAV
NAT LAB U
i REG IV (J. HANCHETT) p
/
16 CYS ACRS SENT CATEGORY &
jf ?
i N;CFtRM 195(2 76)
..