ML20082G590

Forwards Ltr Rept Containing Eg&G Review of Rev 10 to ODCM for Plant

ML20082G590
Person / Time
Site:	Farley
Issue date:	06/07/1991
From:	Thomas Young EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	Essig T NRC
Shared Package
ML20082G573	List: ML20082G590
References
TEY-18-91, NUDOCS 9108190238
Download: ML20082G590 (9)

Text

O Enclosure

~

INEhr Idaho National Eng neerung Laboratory June 7, 1991 Mr. T. H. Essig Radiation Protection Branch Hail Stop 1004 U. 5. Nuclear Regulatory Commission Vashington, D. C. 20555 FINAL LETTER REVIEV 0F FARLEY ODCM REVISION 10 - TEY-18-91 Dear Mr. Essig Attachment 1 is a Letter Review of the complete Joseph H. Farley Nuclear Plant the (FNP) ODCH, Revision 10, submitted by Alabama Power Company (APC),

licensee for FNP. This submittal was transmitted by a letter from V.13, G.

1990.

Hairston, III (APC) to Document Control Desk (NRC), dated September The first two sections of the attached Letter Review address the licensee's dated August responses to the EG&G review of ODCM Revision 7 (EGG-PHY-8674, 1989). These responses to the initial EG&G review vere transmitted to the NRC by a letter from V. G. Hairston, III (APC) to Document Control Desk (NRC),

dated May 9, 1990. Attachment 2 is a copy of the licensee's responses to the initial EG&G reviev.

The latest revision of the FNP ODCM (Revision 10) includes corrections and additions committed to in the attachment to the APC letter dated May 9, 1990.

It also includes changes addressing two of the six suggestions made in the EG&G TER. The only significant deficiency in Revision 10 concerns In the addition to the calculation of organ dose rates due to gaseous effluents.

weekly calculations nov required by the ODCH, these dose rates should be calculated following power changes of >15% of rated thermal power and when grab samples are analyzed prior to batch releases.

In addition to changes made in response to the EG&G review of Revision 7, the The most significant licensee made other improvements to the ODCH.

improvement is the correction of an error in the liquid effluent monitor setpoint calculations of Section 2.2. This error was not identified in the earlier review. It was detected by the licensee and reported in a Licensee

(

l Event Report (LER) transmitted to the NRC with a letter from W. G.

12, 1990, Hairston, III (APC) to Document Control Desk (NRC), dated April f QS19023e910812 p ADOCK OSoco34g PDR EGcGn. ,n< P.O. Box 1G25 Idaho Falls. ID 83415

Revision 10 also includes editorial improvements and additional dose factors for the calculation of doses due to liquid effluents. Recommendations for a correction to the current Section 2.2 and updating of the dose factors are included in Attachment 1.

Sincerely yours, Y [

Radiological Physics Attachments: As stated ce: J. J. Hayes, Jr., NRC-HO, MS 1004

=

l l

l t

Attachmont 1

, TEY-18-91 June 7, 1991 Page 1 of 7 LETTER REVIEV 0F THE JOSEPH M. FARLEY NUCLEAR PLANT (FNP) ODCH, REVISION 10 In a letter from E. A. Reeves (NRC) to V. G. Hairston, III (Alabama Pover Company, APC), dated November 9, 1989, the NRC requested that deficiencies and suggested improvements identified in a review of the FNP ODCH, Revision 7 be addressed. The review is documented in EGG-PHY-8674, dated August 1989. The licensee responded in a letter from V. G. Hairston, III (APC) to Document Control Desk (NRC), dated May 9, 1990. An attachment to the letter discussed each deficiency identified in the reviev, and committed the licensee to make most of the recommended changes. On September 13, 1990, the licensee submitted a complete ODCM, updated through Revision 10, which included changes committed to in the May 9, 1990 letter. This Letter Reviev contains an eval " tion of the entire OD;M. The first two sections address the concerns id ... ed in EGG-PHY-8674. The third section discusses responses to suggestions in the reviev and additional changes since Revision 7.

Attachment 2 is a copy of the licensee's responses to the concerns identified in EGG-PHY-8674 The concerns and responses have been numbered to simplify their reference in the following review.

A synopsis of the evaluations of the licensee's responses is given belov, followed by more detailed evaluations.

1. Summary of the Evaluations of Resconses to the Reviev of Revision 7 of the ODCM

1. Acceptable.

2. _ Acceptable.

3. Acceptable. However, it is suggested that " effluent pathway, p" be specifically defined in Section 2.2 by naming each of the possible sources.

4. Acceptable.

5. Acceptable.

6. Acceptable.

7. Acceptable.

8. Acceptable.

9. Modification needed. In addition to the weekly calculations nov required, organ dose rates due to gaseous effluents should be calculated for the 24-hour periods following changes of >15% of rated thermal power and when radioiodines are detected in the grab sample analyses prior to batch releases.

10. Acceptable based on current KRC guidance. For consistency, the licensee may vish to revise Technical Specification 3.11.2.1.b to remove the requirement for calculation of doses due to C-14.

11. Acceptable.

, w....... . -l

-TEY-18-91 Juno 7, 1991-

, Pege 2 of 7 .

12. Acceptable, but see Evaluation 10.

13. Acceptabla.

14. Acceptable.

15. Acceptable.

16. Acceptable.

17. Acceptable.

18. Acceptable.

19. Acceptable.

20. Acceptable.

21. Acceptable.

22. Acceptable.

23. Acceptable.

2. Detailed Evaluations of Egsoonses to th' +v sv of Revision 7 of the ODCM

. Evaluation 1 - Acceptable.

The licensee has added Figure 2.2 that defines the pathways of liquid vaste and the dilution water applicable to each source, as recommended.

Evaluation 2 - Acceptable.

This concern stated that Figure 2-1 should be expanded to show the solid vaste management system, or that a figure showing this system should be added to the ODCM. The licensee's reply notes that the solid vaste management systems are discussed in the FNP Process Control Program, and proposes that it not be included in the ODCH. General Contents of the Offsite Dose Calculation Manual," Revision 1, Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979 recommends inclusion of a diagram of the solid vaste system in the ODCM. Bovever, Generic Letter 89-01 specifies that documentation concerning the solid vaste treatment system is to be included in the Process Control Program instead of the ODCM. Because of this more recent guidance, omission of the diagram appears to be acceptable.

Evaluation 3 - Acceptable, with an addition suggested.

The licensee has rewritten Section 2.2. It nov includes methodology to determine liquid effluent monitor setpoints for simultaneous releases from any number of release paths. The revised ODCM eliminates the problem identified in Concern 3. However, it vould improve the clarity of this section if a statement vere added naming the pathways that might be included in the summation over " effluent pathway, p." (The revised -

methodology used to determine liquid effluent monitor setpoints is discussed more completely on the last page of this attachment.)

i 1

b

Attachmxnt 1 TEY-18-91

• - June 7, 1991 Page 3 of 7 Evaluation 4 - Acceptable.

The items in. Concern 4 are addressed in Evaluations 1 and 3 above.

Evaluation 5 - Acceptable.

The licensee has conducted a vater use survey and determined that the only pathways of liquid effluents to man are fish and irrigated vegetable consumption. These pathways are considered in the dose calculations in Revision 10, so concern 5 is resolved.

Evaluation 6 - Acceptable.

This concern stated that Liquid Dose Conversion Factors for Mo-99 should be included in Table 2-3. This should not have been listed as a concern, since they are already included, as stated by the licensee in the response.

Evaluation 7 - Acceptable.

The licensee has corrected the definition of 0 , in Section 3.3 by 3

removing the vord " average", as recommended.

Evaluation 8 - Acceptable.

The licensee has added vording to Section 3.4 to indicate that the ILRT

-(integrated leak rate test) vents are included in the setpoint calculations. (They were already included in the calculations, but this fact vas not stated in the ODCM.)

Evaluation 9 - Modification needed.

This concern recommended that the averaging of noble gas releases over a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and other releases over a period of 1 week in Section 3.4 (to assess compliance with Technical Specification 3.11.2.1) be changed or justified.

l Noble Gases. The licensee's response notes that the methedology in Section 3.3 for calculating the alarm setpoints of the noble gas monitors agrees with the guidance of NUREG-0133 vhile requires that the instantaneous release rate be limited to 10 CFR 20 values. Since the instantaneous (1-second) release period is satisfied by the monitors, the 1-hour averaging period for the backup analysis of dose rates due to noble gases appears reasonable.

Other Than Noble Gases. The licensee states, "The hourly or weekly averaging of release rates is a practical means of assessing compliance with the regulatory limits and is consistent with the surveillance requirements of the technical specifications." Surveillance Requirement 4.11.2.1.2 requires that the organ dose rate shall be determined to be within the limits of the Technical Specification 3.11.2.1.a based on the rampling and analyses specified in Table 4.11-2. Therefore, the dose i

Attachmsnt 1 TEY-18-91 l Juno 7, 1991 l Page 4 of 7 rates should be averaged over the shortest time periods for which analyses is required by Table 4.11-2. This requires dose rates to be determined based on the following analyses:

(1) The weekly analysis of the Plant Vent Stack charcoal and particulate samplers.

(2) The 24-hour analysis of the Plant Vent Stack charcoal and particulate samplers following power changes of >15% of rated thermal pover.

(3) The analysis for principal gamma emitters of the grab sample taken prior to each batch release from the vaste gas storage tanks.

(4) The analysis for principal gamma emitters and H-3 of the grab sample taken prior to each containment purge through the large (48-inch) duct. (Note: Although the list of principal gamma emitters in the Farley ODCM does not include radioiodines, all radionuclides

.. identified in the grab samples must be reported. Radiciodines have been detected in batch releases according to several semiannual effluent reports.)

For clarity, additions requiring dose rate determinations prior to containment purges through the large duct should note that the requirement does not apply to the continuous purge through the small (18-inch) ducts i.e., the mini-purge in the terminology of Section 6.2.3.2.3 of the FSAR.

For consistency within the ODCM, containment purges through the large duct should be classified as batch releases and treated in the same vay as discharges from the Vaste Gas Decay Tanks in Section 3.1 and Table 3-1. Also, for consistency between the technical specifications and the ODCM, the licensee may want to revise Technical Specification Table 4.11-2 so the containment purge through the large duct and the mini-purge are addressed separately.

If current NRC guidance (e.g., Basis Statement 3/4.11.2.1 of Generic Letter 89-01) or the Licensee's Basis Statement 3/4.11.2.1 is used to interpret Surveillance Requirement 4.11.2.1.2, the calculation of the dose rate is required only when radiolodines are detected in the effluent.

Evaluation 10 - Acceptable. RETS revision suggested.

In response to the recommendation that the dose factors for C-14 in Table 3-4 be corrected, the licensee has omitted C-14 from the calculations, because current NRC guidance does not require the calculations. This action is therefore consistent with the intent of NRC guidance for the limitation of doses and dose rates due to gaseous effluents. (Technical Specification 3.11.2.1 is inconsistent vith the NRC

l

.Atth; M r. 1 i TEY-D *1 r- Jun3 7. 1991-Page 5 of 7-  ;

-f guidance, since it appears to-require the calculation organ _ doses due to l

C-14. The licensee may wish to revise Technical Specification 3.11.2.1.b to remove this apparent inconsistency.)

i Evaluation 11 - Acceptable. (

-The licensee has-added a statement identifying the assumptions used in j calculation' of the R,3's of Section 3.4(b), as - recommended. i Evaluation 12 - Acceptable.-but see Evaluation 10. i The licensee has committed to correct Sections 3.4(b) and 3.6.2 by [

eliminating the calculation of doses due to C-14, because current FRC i guidance does not-require the calculations. - This proposed action as- l therefore consistent with the intent of NRC guidance for the lisdtation of  !

L doses and dose rates due to gaseous effluents. (See Evaluation 10 for  ;

L further discussion of the treatment of C-14 in gaseous effluents.)

L l;

. Evaluation 13 - Acceptable. t The licensee has added summation symbols to the appropriate equations in Sections 3.6.1 and 3.6.2, so releases from the ILRT vents are included in i the dose calculations, as recommended.

-Evaluation 14 - Acceptable. f j

The licensee has edited the basic equation for Method B in Section 3.6.2

-to include-summation of doses over all applicable pathways, as j recommended. l

(~ Evaluation 15 - Acceptable. l The licensee added-vording to Section 3.6.2 to make it clear that tritium is included in the calculation of organ doses due to gaseous effluents, ,

sau.rying the intent of the recommendation.  ;

Evaluation 16 - Acceptable.  !

As recommended, the licensee added a statement to Table 5.1 explaining- i that no indicator locations for milk samples are identified because there  !

are no milk animals within 5 miles.  ;

Evaluation 17 - Acceptable. ,

The licensee addressed Concern 17, the omission of a subscript-in the -

definition of ot, in Section 2.4, by changing the subscript from s to 1 and inserting the 1 in all appropriate locations. )

i

-Evaluation 18 - Acceptable.  !

The licensee corrected Equation 3.6 in Revision 10, as recommended.- (In i

.the statement of this concern, " Equation 3.5" should have read j

" Equation 3.6.") '

f i

t I

[ I

Attachm:nt 1 l TEY-18-91

[# June 7, 1991 Page 6 of 7 Evaluation 19 - Acceptable.

The licensee defined M in Section 3.6.1, as recommended.

i Evaluation 20 - Acceptable.

The licensee corrected Figure 3-1, as recommended.

Evaluation 21 - Acceptable.

The licensee added vording to Section 3.4(b) specifically stating that organ dcsc rates due to tritium releases are included in the calculations.

This addition accomplished the same things as the recommended change.

(Note: The licensee might compare the vording in the technical specifications and the ODCM again.)

Evaluation 22 - Acceptable.

The licensee corrected the reference for R,,,, in Section 3.6.2 to read

" Table 3.5" instead of "an appendix," as recommended.

Evaluation 23 - Acceptable.

The licensee added the units of distance to Table 5-1, as recommended.

3. Reviev of Additional Chances to the ODCM Hade by the Licensee in Revision 10.

Items 1 and 2 belov describe changes made by the licensee in Revision 10 that address suggestions made in EGG-PHY-8674. Items 3 and 4 discuss other changes in Revision 10 and indicate minor corrections that should be made in a future revision of the ODCH.

1. Acceptable.

The licensee updated the bioaccumulation factor for P in Table 2-2 to agree with the value recommended int (a) E. F. Branagan, C. R. Nichols, and C. A. Villis, "Importance of P-32 in Nuclear Reactor Liquid' Effluents," Health Physics Society Annual Meeting, June 1982; and (b)

B. Kahn and K. S. Turgeon, "The Bioaccumulation for Phosphorus-32 in Edible Fish Tissue," NUREG/CR-1336, March 1980 This change ves suggested in the review of Revision 7.

2. Acceptable.

The Licensee modified the methodology of Section 3.6.2 so the maximum dose to a single organ and age group is compared to the dose limit of Technical Specification 3.11.2.3, as s uggested in the review of Revision 7.

I

Attachncnt 1

' TEY-18-91 June 7, 1991 Page 7 of 7

3. Acceptable, but cont 6 ins an error in a non-essential equation.

The licensee corrected the methodology in Section 2.2 for determining the setpoints of the liquid effluent monitors. The error in the methodology in Revision 7 vas detected by the licensee and reported in an LER transmitted to the NRC vith a letter from V. G. Hairston, III (APC) to Document Control Desk (NRC), dated April 12, 1990. The methodology in Revision 10 gives very conservative setpoints, since the maximum offsite concentration, determired independently for each unit, is restricted to one half the 10 CFR 20 limit. Therefore, at a time when the dilution flov is the same for both units and only one unit is releasing radioactive material, the offsite concentration is restricted to one-fourth the 10 CFR 20 Iimit. Simultaneous releases from any number of sources of radioactive material can be accounted for by the methodology, although normally only the liquid radvaste effluent lines and the steam generator

' blevdovns are expected to be radioactive.

Equation 2.2, to calculate the concentration of radioactive material in liquids released offsite, should be corrected; or it could be removed, since it is not used in the calculations. The correct equation, using the l symbols defined in Revision 10 is:

C 3 ,, = I ( I [C ,,,,

• f,, p) ) / ,I Fu i 3

instead of: C ,, = I ( I [C ,,,,

• f o ,,)

3 3

/ Fy ).

4. Acceptable, but values should be updated.

The licensee added Sb-124 and Sb-125 to Table 2-3 (Ingestion Dose Conversion Factors) and Table 2-4 (Liquid Dose Commitment Factors Ai).

l The ingestion dose conversion factors for Sb-125 in Revision 10 differ significantly from the the values given in " Age-Specific Radiation Dose Commitment Factors for a One-Year Chronic Intake", NUREG-0172, November 1977, and should be updated. The values, in mrem /pci, are compared below.

Organ Bcrw Liver T. Body 'Dryroid bry GI-ILI l

2.23LO6 2.40PAE 4.48E-07 1.98E-09 2.33E-04 1.97F45 Pev. 20 2.0T,-08 4.26E-07 1.82LO9 1.38E-06 1.97E-05 NURm-0172 1.79506 Other changes and additions made in the FNP ODCH by Revisions 8, 8A, 9, and 10 update or improve the ODCM, and are considered acceptable.

Attsch-ent 2:

TEY-16 .

,- June 7, 1991 a l

Page 1 of 8

w. o. M.wton, m s.n , vice pr...e.m May 9, 1990 Alabama Power "

Nw.., op.e.icni inesou w cen,c y ,m Docket Nos.=50-348 50-364 U. S. Nuclear Regulatory Commission -

ATTN: Document Control Desk Vashingtor DC 20555 e

Centlemen:

l Joseph M. Farley Nuclear Plant - Units 1 and 2

-Offsite Dose Calculation Manual Reviev e By letter dated November 9. 1989 the Nuclear Regulatory Co documents-their reviev of the J. M. Farley AsNuclear a resultPlant Offsite of this Dose reviev, technical Calculation Manual (ODCM), Revision 7.

several concerns vere raised for which the NRC requested resolution within six months of-the November 9, 1989 letter.

Alabama Pover Company has evaluated the concerns identified inResolution the.TER and for provides a response to each in an attachment to this letter.

some of the concerns vill require a formal-change to the ODCM computer softvare. Due to the amount of time required to prepare a correction, perform testing of the softvare revisions and-implement the changes,_the Alabama Power Company requested schedule for resolution cannot be met.

commits to complete the necessary charges to the ODCH and the computerT software by August 30, 1990.

the NRC Project Manager.

.In addition, several suggestions for possible changes to the ODCM vereAlabama provided in the TER for which specific responses were not Alabama Pover Company considers the November 9,1989 TER to be a letter of acceptance by the NRC pendint implementatian of the resolutions described in If the NRC dfsagrees with this position, please advise.

the attachment.

If there are any questions, please advise.

Respectfully submitted, uJJ.t M V. G. Hairston, III VGH III/BHVidst 18.1.19 Attachment ec: Mr. S. D. Ebneter ,

Mr. S. T. Hoffman Mr. G. F. Marvell L

_n-n ,9 i'

,F tiR ADO.6 & .5 .ew- eM

I ,

Attachm:nt 2  :

' TEY-19-91 June 7. '991 Page 2 -< gm i

J. M. Tarley INelear Plant - Units 1 and 2 offsite Dose calculation Manual Pavi v

/, NRC concern In section 2.1 anoth6r figure ard/or a detailed description should be addedtoclear$ydefinethepatfwsysofradioactiveliquidwasteand

-dilution water from each source to the discharge point in the Chattahoochee P.tver.

APco Position A figure will be added to the CDCM that clearly defines the patJways of liquid vaste and the dilution veter from each source.

[,NRCconcern rigore 1-1 should be expanded to show the solid waste managesent system or a figure shefir g this system should be added to the ODCM.

Arco Position solid weste management systems are discussed in the FNP Process control Program. A review of HUPar-0133 Irdicates no guidance regarding

'!herefore, we propose duplication of this information in the CDCM.

- that the 0001 not include a diagram of the solid waste management s', s tem.

g NRC concern section 2.,1 should include methodology to determine setpoints for the monitors on the steam generator blowdown effluent lines.

Arco Position section 2.3 will be modified to include the methodology for determining the setpoints for the steam generator blowdown monitnr.

Attscheent 2 1 7EY-18 91 June 7, 1991 l Page 3 of 8 .

//. NRC coneern

, l ne methodology to determine setpoints of if. quid ef fluent monitors in 4 section 2.2 and compliance with the 10 Cnt 20 limits in Section 2.3 should s =cifically address :he sisultaneous release of radic. active '

material;s from several sources, including the turbine bJ11(ing sumps.  !

Also, the source of dilution water ficw for each radioactise effluent ,

stream should be identified.

APCo Position ne methodology to determine setpoints for all 11guld ef fluent monitors that considers the stuultaneous release of radioactive materials from several aourcea haa been developed and will be included in the next revision. Also a new figure will be added to the CDCM showing the ,

source of dilution water for each radioactive effluent stream.

f HRC concern Liquid pat! ways other t.han fish consumption should be a or stating that the pathways do not exist, as appropriate, APCo Position '

A water use survey of the Chattahoochee River will be performed, and the pathways for human exposure that are identified will beThose patJways th incorporated into the CDCM by August 30, 1990.

not exist will be explicitly stated as not existing. .

.I

[ NRC Concern

' Table 2-3, Liquid Dose conversion ractors, should include Mo-99, since it is one of the principal gassan emitters for which analysis is required by Hotation el of Technical specification Table 4.11-1.

APCo Position-Table 3.-3, Liquid Dose conversion factors, contains F.o-99.

e 3

, , . . . . ,- m,-

[

Attachoent 2 TEY-18-91

(

June 7,' 1991  !

Page 4 of 8 ,

I tmc concern 3 i In Section 3.3, the tenn ' average" shogid be teamed from the '

definition of 0,, since the dose rate limits are instantanecus.

3 s

APCo Position  !

j mis correction will be sade in the next revision of the 00CM.

j g NRC Concern me methodel in Section 3.3 to determine setpoints of the gaseous monitors sh d account for releases frcas the 2LRT vents.

AP o Pesition ne original intent of the 00CM was to include the 11.RT vents and the i

• compiter sof tware implementing the otot currently includes the ILRT <

vents. We wording of the Orot will be changed ln the next revisien to '

clarify the inclusion of the 11.RT vents in the setpoint calculations.  ;

g,NRCConcern f

me averaging of noble gas releases in section 3.4 over a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and other releases over 1 week should be changed or jutified, since IA! RIG-0133 reemmends *1 second" for the averaging peried.

Arco Position section 2.2 of NUREG-0133 states that a release rate is defined as 'the  !

discharge of radioactive materials in liquid or gaseous effluents per unit time.' A *second" is used as the practical reporting time unit for establishing compliance with the instantaneous lis.itations of 10crR 1

Part 20. me methodology described in section 3.3 of the CKX:n for ,

calculating the alara setpoint, which defines the allowed instantaneous We release rate, agrees with the guidance provided in NURIG0133.

allevable instantaneous release rate is calculated on a 'per second" i basis.

ne methodology described in section 3.4 of the 0001 for assessing compliance with the limits of 10CTR Part 20 is being performed in order to show ccupliance with technical specifications and agrees with the r We hourly or weekly averaging of  !

guidance provided in HURIG-0133. release rates is a practical means oi regulatory limits ard is consistent with the surveillance regairements of technical specifications. .

r I

i i

Attachm2nt 2 f TEY-18-91 Jun( 7, 1991 Page 5 of 8 1

/C,tecCencern the following corrections should be made in Tab'.f e 3-4, Inf ant Dose ractors, which is used with equation 3.25 for esiculating the organ dose rates (a) me ground plane dose factor for C-14 should be 0.0; (b) he cow-allk p goat-ellk dose factprs for C-14 should be 3.23r+06 ares /yr per uC1/m instead of 2 34E+09 m (are vyr) per uci/s, ba wd on ndix C of Regulatory Oulde 1.109; the dose methcdology for C-14 in and (c) goat-allk dose factors sh d be rm-sero for all nuclides with a transfer factor in either Table E-1 or E-2 in Regulatory Guide 1.109.

APeo Position l

for items (a) and (b) the dose factor for C-14 vill be eliminated frcn the 00cn since analysis of C-14 is not required by present ime gu1 Ance. (c) ooat milk done factors that are currently listed as zero will be calculated using the appropriete factors and will be provided in the next revision of the 000t.

//, tac concern In section 3.4 (b), all asstaptions used in calculations of the R,,'s <

should be furnished in the 00cn (e.g., it eculd be stated that the default values of Regulatory Guide 1.109 are used for consumption, transit times, etc.).

APCo Position ,

's are based on the default Assumptions and calculations values f rca Regulatory ocide 1.109 and for the R*lCREG-0133 and the 0001 vill be revised to reflect the basis for the values in the next revision.  :

Jg,tacConeern in section 3.4 (b) and of R W and W in ne definitions section of W'specify the use of (XM) ,E.109).dir,C-Nforall 3.6.2 should Alternatively, pathways (see rquation C-8 in Regulatory Ouide it is the celculation of doses due to C-14 could be eliminated sinct not required by recent NRC guidance.

APco Position C-14 vill be eliminated frce the calculations and all tables of the Ocot in the next revision.

..e,- r,,,e ,.,v, e - - ~ t

4 Attacha:nt 2

? TEY.18 91 June 7, 1991 Page 6 of 8 Jf, tac coneern In section 3.6.1 and 3.6.2, all release points, including the lirr vents, should be specifically included in be calculations (e.g., tr/

identifying the vents included and suming over the subscript v).

APCo Position ne form:1as in section 3.6.1 ard 3.6.2 will be revised tn include the 11Er vents in the calculations by inclusion in the sus ters over all pathways in the next revision to the oc a .

j{tacconcern n e basic equation for Method B in Section 3.6.2 should require the suenation of doses over the applicable pathways.

APCo Position ne equation for Method a in Section 3.6.2 will be revised to include sunmation of doses ever all applicable pathways in the next revision to the occM.

/5.taccacne ne first senten:e of section 3.6.2 should be relocated so it applies to both Method A and Method B, and reworded so it requires calculation of doses due to tritium releases.

APco Position ne first sentence of section 3.6.2 will be relocated as it applies to ne current wrding is exactly the same as the both Methods A and B. ne rarley Technical specification and will be maintained as it is.

parenthetical statement, "trititas, radiolodines, and radio for clarification, o

\

s.

Attachment 2 .

l TEY-18-91 t Jule 7. 1991 6 Page 7 of 8 ,

. t

//,NRCConcern Indicator locations for allk sampling should b added to Table 5-1, or ,

an explanation given for their ondssion. i i

APCo Position i

We table will be changed to reflect the absence of r.11k animals within l 5 miles of the plant based on the current land use survey.

I t

17. tae Concern -

A subscrapt should be added to r in the definition of t, .in section j 2-4. '

APCo Position ,

ne appropriate subscript will be added to the r in the next revision '

of the CDCM. '

7 jg,tacconcern i ne 3 ir *wtion 3.5 of section 3.2 should be (3) .

APCo Position  !

' We CDcn uses the square root symbol and is correct.  ;

_g,NRCConcern i A definition of g should be included in section 3.6.1.

i i

APCo Position l l

We definition will be included in the next revision of the CDCM. l k

I l

l: >

t b

6 Attachmont 2 TEY-18 91 June 7, 1991 Fage 6 of 8 jg,imCConcern In DCCM rigure 3-1, rxanitor R-13 should apparently be thwn on the effluent line f ree all the waste gas decay tanks.

APeo Position rigure 3-1 has teen revised to reflect the actual configurstion of the vaste gas system, radiation conitors and the vent stack, g tse concern ne word

• radionuclides" in the first sentence of Section 3.4(b) should read

• radiotodines." Wis sentence should also be reworded so doses due to tritiu:n are required to be calculated.

APCo Position ne current wording is exactly the same as the rarley Technical ne parenthetical specification and will be mintained as it is, staterent, " tritium, radiciodines, and radionuclides in particulate form with half lives greater than eight days" will be added for clarification.

M,taCconcern n e definition of R ' in Section 3.6.2 should reference Table 3-5 instead of "an appeSix*.*

APCo Position his change vill be ude in the next revision of the OCC1.

tac Concern n e units of distance should be specified in Table 5-1.

APCo Position m is correction will be made in the next revision of the 00CM.

BRA: dst 18.1.17 f

I m