ML20093H254
| ML20093H254 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/18/1984 |
| From: | FRANKLIN INSTITUTE |
| To: | |
| Shared Package | |
| ML20093H241 | List: |
| References | |
| PROC-840618, NUDOCS 8407250005 | |
| Download: ML20093H254 (8) | |
Text
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Enclosure l
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ODOt Review for Limerick Generating Station Units 1 and 2 Licensee: Philadelphia Electric Company Docket Nos.:
50-352/50-353 "he review comments presented in this report were prepared by the Franklin Research Center under contract to the U.S. Nuclear Regulatory Connaission (Office of the Nuclear Reactor Regulatiens, Division of Operating Reactors) for technical assistance in suppnet of NRC reactor licensing actions. This report is the result of rer. wing the Licensee-submitted ODCM proposal (Revision 0, dated March 1983) against the NRC guidelines (Regulatory Guide 1.109 and NUREG-0133).
June 18, 1984 8407250005 840716 PDR ADOCK 05000 P
renidin Research Center Aobdman af the Fund $n bumer
Limerick ODO4 Review Subiect Page Number Comments Liquid Setpoint 20 The Licensee should assign units for C
- t 21 Provide a method to calcu late setpoints for the service water monitor required by the model RETS.*
Liquid and Gaseous 21 Provide a methodology for adjusting the Setpoints monitor setpoints if simultaneous re-leases are made from several effluent streams, including Unit 2.*
Gaseous Setpoints 24 Methodologies should be provided for ail monitors having automatic control features required by technical specification gov-erning normal releases.. SRP 11-5 Table 1 provides for a waste gas holdup system (charcoal treatment system in Limerick design) monitor with automatic control features.
Similar monitors are provided for in the SRP for containment purge and fuel storage and ventilation systems.
A similar monitor is provided for in the S2P for condenser evacuation systems but only if not monitored prior to the release point by downstream provisions.
No other monitors are provided for in the SRP with automatic control features.
Add setpoint methodologies for monitors not so addressed in the ODCM draft, but required by the SRP; Delete methodolo-gies for monitors not required by the SRP.*
25 Rather than simply referencing Regulatory Guide 1.109, the Licensee should provide the whole body gamma dose factor (K ),
the i
beta skin dose factor (L ), and i
the air dose factor (Mi) in the ODCM.
26 The Licensee has not provided data for the inhalation dose factor
.Pi in the ODCM.
- These comments were provided by C. Nichols, METB, NRC, in lieu of FRC comments.
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Liquid Concentration 1
Fer the sake of clarity, the Licensee should refer to the noble gases in the liquid waste as "the dissolved or entrained noble
~~
gases" as stated in the RETS for radioactive liquid concentrations.
1 The Licensee should also consider the unidentified radionuclide concentration in determining the dilution factor. For those nuclides, the suggested MPC value (according to 10CFR20) is lx10-7 uC1/al.
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e Subiect Page Number Comments Gaseous Dose, Rate 5
For the gross release method, Kr-89 has the most limiting dose factors for both total body and I
skin. The Licensee should explain why Kr-88 and Kr-87, instead of l
Kr-89, are considered as the most conservative isotopes for this calculation.
7 The Licensee should explain how inhalation dose factors P _131 I
and Py_133 are calculated.
8 Section 2 of Appendix D to the Limerick FES states that because of the airflow around the cooling towers, the vent releases were assumed at ground level with mixing allowed for turbulence in the wake of these struct ures.-
However, for a ground-level release, the Licensee's highest calculated (X/Q),of 6.29 x 10-7 sec/m3 seems low. The l
Licensee should explain the possible discrepancy.
Liquid Dose 4
What is the basis for selecting only the total body and bone as the critical organ?
27 The Licensee has not provided data for the bioaccumulation factor (BF ) and the ingestion dose i
conversion factor (DF ) in the 1
ODCM.
27 The Licensee should assign units for the ingestion dose conversion i
factor (DFg).
1 Gaseous Air Dose 9
For beta radiation, the Licensae i
should provide data for the air l
dose factor (N ) in the ODCM.
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Gaseous Dose fo'r I.131 and 2-133 27 In Note 2, the Licensee has provided an equation to calculate the grass-goat milk ingestion.
How does the Licensee justify that the grass-cow milk pathway, ground-plane pathway, grass-meat pathway, and vegetation pathway need not be considered?
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F Subiect Page Number Comments Gaseous Dose for j
I-131 and I-133 28
'the Licensee has not provided the ingestion dose factor (DFL ) for i
I-133.
Liquid Dose Projection 3
The Licensee has not specifically described the method for the monthly dose projection'in connection with the operation of the liquid radwaste treatment system, according to the specified dose limits of RETS.
In this dose projection, a method should be provided to describe how the Licensee would foresee oncoming situations and be able to predict the radioactivity releases for the next month.
Geseous Dose Projection 11 As in the case of the monthly i
liquid dose projection, the Licensee should describe how the releases will be projected for the upcoming month.
'1btal Dose 12 The Licensee's method provided under "B" states: " Cumulative dose contribution from direct radiation = total dose at the site i
I of interest (as evaluated by TLD measurements) - mean of background dose (as evaluated by TLD's at background sites) - effluent
)
contribution to dose (as evaluated l
above)."
12 The Licensee seems to imply that the total' dose can be measured by j
TLD, which is not true.
- Instead, i
the Licensee should provide a method to estimate the direct radiation dose and add it to doses calculated from all other pathways.
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Radiological Environ-mental Monitoring Program 15 1.
'the Licensee has not specified the control locations for all pathways.
2.
The Licensee has not completed the description of the milk sampling station.
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F Subiect Page Number Comments Radiological, F.wiron-mental Monitoring Program 15 3.
One of the fish sampling (Cont.)
stations should be downstream.
17, 18, 19 The Licensee has not assigned a scale for each of the figures (VI.A.1, VI.A.2, and VI.A.3) shown.
Liquid and Geseous 31, 32 The foklowing deficiencies are Effluent Flow Diagrams found in the flow diagrams (Figures IX.A.1 and IX.A.2) provided by the Licensee:
1.
The diagrams have not clearly shown the release points for both liquid and gaseous effluents.
2.
Radiation monitors and controls are not explained in l
the diagrams.
3.
For liquid effluents, the dilution flow is not designated.
4.
It is not clear whether the gaseous effluent system is shared by both reactor units.
5.
For gaseous effluents, the vent / stack elevations of the release points and the mode of releases should be designated.
6.
Figure IX.A.2 is not legible; a, simpler flow diagram is suggested.
Interlaboratory Comparison Program
'the Licensee has not provided a l
description of the participation in the interlaboratory comparison j
program according to the RETS.
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Typographic Errors Page Number.
Iccation Comments 2
Second line of the The line should read, "...any the description of D organ,t, from liquid..."; the letter "q? is missing.
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Third line of the The line should read, "At from any description of Cil liquid release,..."; the symbol 4 is missing.
l-2 Last line of the The sentence should end with a description of Cil right parenthesis.
7 Equation for Dr Th,e variable "Qiy" should read "Qiv".
9 Eqcation for D7 The equation should end with'a right parenthesis.
10 Description of Ni The variable Ni should read for the Equation of "N".
20 Equation for Ct The variable MPC should read
'MPC ".
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27 Equation for A q The parameter Ai should read i
"Aig".
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I ADDITIONAL COMMENTS ON THE PRPOSED OFFSITE DOSE CALCULATION MANUAL FOR LIMERICK UNITS 1 & 2 (12/84)
Page No./Section Subject Comments 5/III Gaseous Pathway Dose
- 1. Provide a numbered and Calculations captioned figure showing the site boundary and the unrestricted area boundary for gaseous and liquid effluents.
- 2. Provide the date of the land-use census that was used in identifying ~ the~
controlling receptor.loca-tions.
- 3. Presumably the methodology described in the ODCM will be implemented via computer codes.
The computer codes should be verified. After the codes are verified, provide a reference (individual or company name, title of document, and date) in the ODCM to document the validation of the codes.
27/VIII Site Specific Data
- 1. The reference - in the document (Note 1: Second Paragraph) to Branagan et al., is unpub-lished.
It would be more appropriate to refer to ICRP-30 and NUREG/CR-1336 which are published.
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