ML20095B584

Forwards Response to NRC 840716 Request for Addl Info Re Offsite Dose Calculation Manual & Revised Offsite Dose Calculation Manual.Related Correspondence

ML20095B584
Person / Time
Site:	Limerick
Issue date:	08/15/1984
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML20095B588	List: ML20095B584 ML20095B597
References
OL, NUDOCS 8408220165
Download: ML20095B584 (7)

Text

PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 1215)84l-4502 AUG 15 884 ano.= n no am na samen Mr. A. Schwencer, Chief Docket Nos.: 50-352 Licensing Branch No. 2 50-353 Division of Licensing U.S. Nuclear Regulatory Conmission Washington, D.C. 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 Request for AddItlonal Information on Offsite Dose Calculation Manual (ODCM)

REFERENCE:

Letter, A. Schwencer to E. G. Bauer, Jr.,

dated 7/16/84 FILE: GOVT 1-1 (NRC)

Dear Mr. Schwencer:

The reference letter provided conments and requested additional information regarding the Limerick ODCM. Philadelphia Electric Company's response to each item is provided in Attachment 1. As indicated in the responses, the ODCM has been revised and is included as Attachment 2.

Sincerely, f

'd W AJM/dg/08098404 Attachments Copy to: (See Attached Service List)

A Rh&5840815 0500035g PDR q (p

sh

cc: Judge Iawrence Brenner (w/ enclosure)

Judge Peter A. Morris (w/ enclosure)

Judge Richard F. Cole s w/ enclosure)

Troy B. Conner, Jr., Esq. (w/ enclosure)

Ann P. Hodgdon, Esq. (w/ enclosure)

Mr. Frank R.' Romano (w/ enclosure)

Mr. Robert L. Anthony (w/ enclosure)

Maureen Mulligan (w/ enclosure)

Charles W. Elliott, Esq. (w/ enclosure)

Zori G. Ferkin, Esq. (w/ enclosure)

Mr. Thomas Gerusky (w/ enclosure)

Director, Penna. Emergency (w/ enclosure)

Management Agency Angus Love, Esq. (w/ enclosure)

David Wersan, Esq. (w/ enclosure)

Robert J. Sugarman, Esq. (w/ enclosure)

Martha W. Bush, Esq. (w/ enclosure)

Spence W. Perry, Esq. (w/ enclosure)

Jay M. Gutierrez, Esq. (w/ enclosure)

Atomic Safety & Licensing Appeal Board (w/ enclosure)

Atomic Safety & Licensing Board Panel (w/ enclosure)

Docket & Service Section (w/ enclosure - 3 copies))

James Wiggins -

(w/ enclosure)

Timothy R. S. Campbell (w/ enclosure)

ATTACtfENT 1 PECO RESPONSE TO NRC/FRC COPfiENTS ON LGS ODCM SUBJECT PAGE NO._ RESPONSE Liquid Setpoint 20 Units have been assigned for C g.

21 A methodology to calculate setpoints for the service water monitor has been provided in the ODCM.

Liquid and Gaseous Setpoints 21 A methodology for adjusting the nonitor setpoints if simultaneous releases have made from several streams has been provided in the COCM for gaseous releases. For IIquid releases, routine reicases are expected only via the radwaste discharge line. A safety margin of 3 provides assurance that 10CFR20 limits will not be exceeded.

Gaseous Setpoints 24 Methodologies for adjusting the release point monitor setpoints have been provided in the ODCM.

In addition, a methodology for the monitor used to evaluate con-tairvnent purge has been provided in the ODCM.

25 The values for the whole body dose factor (K;), the beta skin dose factor (L g),

and the air dose factor (M,) have been provided in th6 ODCM as Table III.B.2.

26 The values for the inhala-tion dose factor (P,) have been provided in th6 ODCM.

Liquid Concentration 1 The words "the dissolved or entrained noble gases" have been added to the ODCM.

1 An MPC value of 1X10 -7 uCI/ml has been added for any unidentified radionucildes.

Gaseous Dose Rate 5 Kr-87 and Kr-88 are the most limiting Isotopes for skin and total body dose respec-tively due to their. half-lives relative to Kr-89. Due to Kr-89's short half-Ilfe, its

RESPONSES (CONTINUED) i SUBJECT PAGE NO. RESPONSE I Gaseous Dose Rate dose factor will be lower than (continued) that of Kr-87 and Kr-88 at the receptor site. A discussion of these considerations has been added to the ODCM Bases.

7 An explanation of how inhala-tion dose factors P and P arecalculatdd,13dasbeen adddb3to the ODCM bases as Note 2.

8 In accordance with Limerick FES response PECo-24, studies at Rancho Seco and Paradise plants have shown that cooling tower wake effects do not exist at low wind speeds and hyperbolic cooling towers do not. produce sharp down-drafts at moderate to high wind speeds causing 100% ground level releases. Rather, enhanced turbu-1ence results. Therefore,tg of 6.29X10 calcugated(X/Q) sec/m is approp Elate.

Liquid Dose 4 LGS Technical Specification Section 4.11.1.2 requires cal-culating total body and organ dose. The limiting organ dose from liquid effluents at LGS is the bone dose (Reference LGS EROL Section 5.2).

27 The bicacctanulation factor (BF,)

and the ingestion dose conversion factor (DF g) were used to develop the liquid effluent ingestion factor (A, ) which is listed on Table II.A.I. All references for the specific values used are indicated. It is not necessary or proper to list all of the BF, and DFy values in the ODCM.

l 27 Units have been assigned for the Ingestion dose conversion factor (DFy ).

RESPONSES (CONTINUED)

SUBJECT PME NO. RESPONSE Gaseous Air Dose 9 The data for the beta radiation air dose factor (N ) has been provided in the as part of Table III.B.2. 1 i

Gaseous Dose for 27 The limiting location for LGS I-131 and I-133 is a goat farm. The grass-cow milk pat Nay does not exist at the locatlon. The grass-meat patNay and the vegetation pat Nay are not appilcable since the limiting individual is an infant. The ground-plane pat Nay contributes less than 0.03% to the total dose and therefore is not significant (Reference LGS EROL Section 5.2).

28 The Ingestion dose factor (DFL;}

for I-133 has been provided in the ODCM.

Liquid Dose Projection 3 A method to describe how oncoming situations could be forseen to be able to predict radioactivity releases for the next month has been provided.

Gaseous Dose Projection 11 A method to describe how oncoming situations could be forseen to be able to predict radioactivity releases for the next month has been provided.

Total Dose 12 The method provided in the second paragraph under Section IV.B is used only to evaluate the contri-bution from direct radiation dose. The direct radiation dose is then added to the dose or dose conmitment determined in accor-dance with the first paragraph under Section IV.B to detennine total dose from all pathways.

Radiological 15 1. Table VI.A.1 has been revised Environmental to indicate control locations Monitoring Program for all pathways.

RESPONSES (CONTINUED) i SUBJECT PAGE NO. RESPONSE Radiological 2. The locations of the farTns are Environmental not ilsted due to longstanding Monitoring Program agreenent with the farTrers (continued) involved. In return for being allowed to sample and analyze milk, PECo has agreed not to divulge the location of the fa rTns.

3. Fish Sarrpilng station 16C5 is downstream from LGS.

17, 18, 19 The figures (IV.A.1, VI.A.2, and VI. A.3 have been rrodified to include a scale.

Liquid and Gaseous 31, 32 1. The diagrams have been Effluent Flow Diagrams modified to clearly show release points for IIquid and gaseous effluents.

2. Radiation monitors are explained in the diagrams.

3. Dilution flow has been indicated on Figure IX.A.1 for liquid effluents.

Liquid and Gaseous 4. The north vent is shared by Effluent Flow Diagrams both units. 'The south vent has separate stacks for Unit I and Unit 2 which are tronitored by separate equipment.

5. Vent / stack elevations of release points and mode of releases have been desig-nated for gaseous effluents.

6. Figure IX.A.2 has been replaced with a sinpler flow diagram.

Interlaboratory LGS Technical Specifications do Comparison Program not require a description of the Interlaboratory Corrparison Program in the ODCM.

Gaseous Pathway Dose 5/III 1. A nurbered and captioned Calculations figure showing the site boundary arxl the unres-tricted area boundary for gaseous and liquid effluents

has been provided.

RESPONSES (CONTINUED)

SUBJECT PAGE ND. RESPONSE Gaseous Pathway Dose 2. The date of the land-use Calculations census that was used in (continued) Identifying the control 1ing receptor location has been provided.

3. A reference to docunent the verification of computer codes tus been provided in the ODCM.

Site Specific Data 27/VIII The reference for the P-32 data (Nece 1: Second Paragraph) has been revised to ICRP-30 and NUREG-1336.

JWB/dg/07268401

.-