ML20024D062

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Forwards Summary of Analysis of Facility Compliance W/ 40CFR190 Per Request During Jan 1982 IE Insp.Facility in Full Compliance.Listing of Assumptions in Computer Code, Input Parameters & Resulting Calculated Doses Included
ML20024D062
Person / Time
Site: Humboldt Bay
Issue date: 07/26/1983
From: Schuyler J
PACIFIC GAS & ELECTRIC CO.
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8308030101
Download: ML20024D062 (9)


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77 DEALE GTREET. SAN FRANCISCO, C ALIFORNI A 94106. (415) 781 4211 TWX 910 372-6587 G3GiO t ;yp J.O.SCHUYLER M t s u u r*T hvCLE A R PrJ e( m (,t %( b & f tG 4 July 26, 1983 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Comission, Region V 1450 Maria Iane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-133 License No. DPR-7 Humboldt Bay Power Plant Unit No. 3 Capliance with 40 CFR 190

Dear Mr. Martin:

In January 1982, during a routine inspection by Mr. G. Yuhas of Region V, it was requested that an analysis be performed to demonstrate Huuboldt Bay Power Plant, Unit No. 3 ccepliance with the limits of 40 CFR Part 190.

'Ibe analysis has been performed and a simmmy is attached.

'Ibe results of the analysis conclude that Unit No. 3 is in empliance with 40 CFR Part 190. A copy of the complete report, including a listing of assucptions in the cmputer code, input parameters and remilting calculated doses, is available for inspection at Humboldt Bay Power Plant.

i Kindly acknowledge receipt of this material on the enclosed copy i

of this letter and return it in the enclosed addressed envelope.

Sh m1y, 1

Attachnent 8309030101 830726 j

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SUMMARY

OF THE ANALYSIS OF COMPLIANCE WITH 40CTR PART 190 FOR THE HUMBOLDT BAY POWER PLANT INTRODUCTION Recent. changes in Nuclear Regulatory Commission (NRC) regulations require that licensees engaged in uranium fuel cycle operations comply with the Environmental Protection Agency's Regulation 40CFR Part 190. This environmental protection standard requires that operations be conducted in such a manner as to provide reasonable assurance that (1) radiation doses to real individuals in the general public do not exceed annual totals of 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ; and (2) the total quantity of radioactive materials entering the environment from the entire uranium fuel cycle does not exceed 50,000 curies of krypton-85, 5 millicuries of iodine-129, and 0.5 millicuries combined of plutonium-239 and other alpha-emitting transuranic radionuclides with hcif-lives greater than one year, per gigawatt year of electrical energy produced by the fuel cycle.

This report contains 'a summary of an analysis of the operation of Humboldt Bay Power Plant's nuclear unit to determine its current and future compliance with 40CFR Part 190.

METHODOLOGY The quantity limits established in 40CFR Part 190 for radionuclides entering the general environment apply only to those generated by the fission process after December 1, 1979 for the alpha-emitting transuranics, and af ter January 1,1983 for krypton-85 and iodine-129.

Since the nuclear unit at Humboldt Bay Power Plant has not operated since 1976, these limits do not apply and were not considered in this analysis.

To determine compliance with the 40CFR Part 190 dose limits for members of the general public, it is necessary to concider doses resulting from radioactive effluents and doses resulting from direct and scattered radiation.

Doses from direct and scattered radiation were determined based on site

-boundary radistion survey data and occupancy factors. Doses from radioactive effluents were determined based on offsite dose calculations using appropriate models.

Doses Frem Liquid Effluents Doses to members of the general public from radioactive liquid effluents were calculated using the TECHSPEC computer code. The TECHSPEC code was developed by Pacific Gas and Electric Company and is based on the guidance contained in NUREG-0133. Results from TECHSPEC have been checked by hand calculations, and have been compared to corresponding results from the NRC PARTS code to assure calculations are performed in conformance with available guidance.

In accordance with the NUREG-0133 methodology, offsite doses from liquid effluents from saltwater sites come from consumption of fish and invertebrates.

For current plant conditions, the input parameters for TECHSPEC (i.e.

total annual quantity of radionuclides released in liquid effluents, total quantity of effluent released and total volume of dilution water discharged) were taken from the 1981 Semiannual Effluent Release Reports.

A continuous discharge was assumed during the year.

To demonstrate future compliance, a second set of input parameters were prepared for the TECHSPEC code.

For these parameters, it was assumed that effluent and dilution volumes stayed at 1981 levels and annual release quantities of radionuclides were approximately one to two orders of magnitude above the 1981 totals.

If future releases of radionuclides remain below the values utilized in this case, it can be reasonably assured that resultant doses will remain below those calculated. This calculation is intended to provide an upper limit on possible doses to the general public from liquid releases.

This upper limit value may be used in future analyses of offsite doses, if none of the annual release quantities of the various radionuclides used in the calculation are exceeded.

It should be noted that a number of conservative assumptions were made in the calculations of doses from liquid effluents and actual doses should be substantially lower than the values derived.

For example, no credit was taken for the dilution of effluent in the receiving waters and many of the radionuclides assumed to be in the effluent have not actually been detected, Quantity values for these undetected radionuclides were based on the maximum quantity that might be present, yet would remain undetected (i.e., the lower limit of detection for the instrument used in the analysis).

Doses From Gaseous Effluents Doses to members of the general public from airborne radioactive releases were also calculated utilizing the TECHSPEC code.

For current plant conditions, source terms (annual quantities of radionuclides j

- released) were taken from the 1981 Semiannual Effluent Release Reports.

For the assumed upper limit calculation, source terms were taken to be approximately an order of magnitude above the 1981 values, Meteorological input parameters (X/Q's and D/Q's) were taken from the c

l report, " Analysis of Compliance with 10CFR50, Appendix I for the Humboldt l

Bay Unit 3 Nuclear Plant," that was submitted to the NRC in November 1976. The meteorological data used in the referenced report came from onsite measurements conducted during 1966 and 1967.

l Air doses were calculated at 51 locations for both the cut'reit and the upper limit cases. These locations included the critical distances in l

each of the sixteen compass sectors that gave the highest beta and gamma i

air doses, as shown in the Appendix I submittal.

l Organ doses, and annual dose rates from noble gases, were calculated at 21 locations for both the currant and the upper limit cases. These locations included the critical distance in each compass sector, based on the location of the nearest dose pathway (milk cow, meat animal, vegetable garden, residence) as shown in the Appendix I submittal.

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Doses From Direct And Scattered Radiation To determine doses to members of the general public from direct and spattered radiation for current plant conditions, a site boundary ra-diation survey was conducted on August 18 and 19, 1982.

This' survey involved taking measurements with calibrated pressurized ion chambers (Reuter-Stokes Model RSS-111, S/N 3579 and S/N 3580) at 16 locations 2

around the site boundary, one measurement in each compass sector. A background measurement was made at a location approximately 10 miles from the plant in a predominantly upwind location.

Measurements were taken and averaged over a minimum of 10 minutes at each location. Figure 1 shows the location where measurements were taken around the site boundary. The background control measurement was taken approximately one mile south of the Arcata airport.

Table 1, taken from PGandE Department of Engineering Research Test Report 420-82.283, provides the measured exposure rates and calculated exposure rates in excess of background at each location.

To determine complia'nce on an ongoing basis, environmental thermolumi-nesecnt dosimeters were installed in June 1983 around the plant fence-line and at control locations remote from the site.

Annual doses are determined from dose rate and occupancy time. Only locations on the northwest portion of the site boundary, bordering Humboldt Bay, had dose rates measurably in excess of background. These locations are accessible to the general public, by means of a footpath which runs between the plant fence line and the bay.

Occupancy factors for these locations have been taken from Table E-5 of Regulatory Guide 1.109, for shoreline recreation. Table 2 provides calculated annual doses to the maximum exposed individuals from direct and scattered radiation.

RESULTS AND CONCLUSIONS Table 3 provides a summary of current (1981) annual doses to the maximum exposed individuals as a result of operations at Humboldt Bay Power Plant.

It is assumed in Table 3 that the same individuals receive the maximum doses from liquid effluents, gaseous effluents and direct and scattered' radiation.

It is also assumed that organ doses from direct and scattered radiation are equal to the annual doses calculated in Table 2, from Pressurized Ion Chamber measurements.

The highest whole body dose is 5.609 x 10-1 mrem tr a teenager. The highest thyroid dose is 4.864 x 10-1 mrem to a teenager. The highest dose received by any other organ is 6.377 x 10-1 mrem to the liver of a teenager. These values are significantly below the limits established by 40CFR Part 190.

i Due to the conservative assumptions used to calculate the dose and the minimal values derived, there is reasonable assurance that operations at Humboldt Bay Power Plant are in compliance with 40CFR Part 190 requirements.

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TABLE 1 i

RESULTS OF HBpP EilVIR0tiMEllTAL RADIAT10!4 SURVEY Exposure Rate Exposure Rate Less Location (uR/hr)

Background (uR/hr) 1 7.3 O.9 2

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4 TABLE 2 Doses To Individuals From Direct And Scattered Radiation Maximum Exposure Rate Above Background 7.2 uR/Hr

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Infant Child Teen Adult Occupancy Factor (Hr/Yr) 0 14 67 12 Annual Dose (MREM) 0 1.01x10' 4.82x10'I S.64x10-2

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TA8LE 3 i

1981

SUMMARY

OF ANNUAL DOSES (MREM)

EONE LIVER TOTAL THYR 0ID KIDNEY LUNG GI-LLI l

BODY LIQ.

0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 i

GAS 4.369E-3 4.356E-3 4.351E-3 4.353E-3 4.352E-3 4.444E-3 4.350E-3 INFANT RAD 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 i

TOTAL 4.369E-3 4.356E-3 4.351E-3 4.353E-3 4.352E-3 4.444E-3 4.350E-3 8

LIQ.

1.200E-1 1.342E-1 5.065E-2 4.161E-5 4.628E-2 1.274E-2 4.871E-2 GAS 4.393E-3 4.360E-3 4.353E-3 4.354E-3 4.354E-3 4.489E-3 4.352E-3 l

CHILD RAD 1.010E-1 1.010E-1 1.010E-1 1.010E-1 1.010E-1 1.010E-1 1.010E-1 i

TOTAL 2.254E-1 2.396E-1 1.560E-1 1.054E-1 1.516E-1 1.182E-1 1.541E-1 LIQ.

9.704E-2 1.513E-1 7.452E-2 4.022E-5 5.440E-2 1.583E-2 1.366E-1 GAS 4.389E-3 4.360E-3 4.354E-3 4.353E-3 4.354E-3 4.518E-3 4.356E-3 TEENAGER RAD 4.020E-1 4.820E-1 4.820E-1 4.820E-1 4.820E-1 4.820E-1 4.820E-1

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TOTAL 5.834E-1 6.377E-1 5.609E-1 4.864E-1 5.408E-1 5.024E-1 6.230E-1 LIQ.

9.284E-2 1.471E-1 1.086E-1 4.390E-5 5.363E-2 1.304E-2 1.966E-1 GAS 4.382E-3 4.357E-3 4.354E-3 4.352E-3 4.353E-3 4.462E-3 4.356E-3 i

ADULT RAD 8.640E-2 8.640E-2 8.640E-2 8.640E-2 8.640E-2 8.640E-2 8.640E-2 I

TOTAL 1.836E-1 2.379E-1 1.994E-1 9.080E-2 1.444E-1 1.039E-1 2.865E 1 l

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i REFERENCES 1.

Title 10, Code of Federal Regulations, Part 20.

2.

Title 40, Code of Federal Regulations, Part 190.

3.

NUREG-0543, " Methods of Demonstrating LWR Compliance With The EPA Uranium Fuel Cycle Standard (40 CFR Part 190)", February 1980.

4.

Regulatory Guide 1.109, " Calculation of Annual Doses To Man From Routine Releases Of Reactor Effluents For The Purpose Of Evaluating Compliance With 10 CFR Part 50, Appendix I", Revision 1, October,1977.

5.

ilumboldt Bay Power Plant Unit No. 3, " Report On Radioactive Effluent Releases And Waste Disposal", covering the period January 1 through June 30, 1981.

6.

Humboldt Bay Power Plant Unit No. 3, " Report on Radioactive Effluent Releases And Waste Disposal", covering the period July 1 through December 31, 1981.

7.

" Analysis of Compliance With 10 CFR50, Appendix I For The Humboldt Bay Unit 3 Nuclear Plant", November 1976.

8.

ANSI /ANS-6.6.1-1979, " Calculation and Measurement Of Direct And Scattered Gamma Radiation From LWR Nuclear Power Plants", approved January 25, 1979.

9.

USNRC Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program", Revision 1 November 1979.

10.

NUREG-0133, " Preparation Of Radiological Effluent Technical Specification For Nuclear Power Plants", October 1978.

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