ML20127C636
| ML20127C636 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/29/1985 |
| From: | Congel F Office of Nuclear Reactor Regulation |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127B237 | List: |
| References | |
| NUDOCS 8504100107 | |
| Download: ML20127C636 (7) | |
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Docket No: 50 458 hit 2 e 1985 DISTRIBUTION:
DOCKET FILES RAB READING FILE FJCongel/ FILE MEMORANDUM FOR: Albert Schwencer, Chief EFBranagan WWMeinke Licensing Branch No. 2, DL TMo CAWillis RFell WPGammill FROM:
Frank J. Congel, Chief JLevine Radiological Assessment Branch, DSI
SUBJECT:
COMMENTS ON THE PROPOSED OFFSITE DOSE CALCULATION MANUAL FOR RIVER BEND We have completed our first round review of the Offsite Dose Calculation Manual submitted in a letter from'J. E. Booker to H.R. Denton, dated January 7, 1985. Our specific comments on the ODCM are Enclosure 1.
The applicant should submit for a final review a revised ODCM that resolves the attached comments.
If you or the applicant have any questions concern-ingthesecomments,contactEdBranagan(x27614).
This review was performed by Ed Branagan and Tin Mo, RAB; and Bob Fell and Joe Levine, NETB.
Orfsinal droeur r * "an 1
Frank [. Congel, Chief Radiological Assessment Branch Division ~ of Systems Integration
Enclosure:
As stated cc: w/o encl.
R. Bernero D. Muller cc: w/ encl.
S. Stern J. Swift CWV DSI:METB DSI:RAB,"'
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- COMMENTS.0N THE PROPOSED i
0FFSITE DOSE CALCULATION MANUAL FOR RIVER BEND STATION j'
1.
General I
(a) The title page should contain a date for the latest revision of the ODCM.
l (b) Although Section 4.1 entitled, " Deviations from the RBS Environmental a
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Operating License Stage," is listed in the Table of Contents, it is L
not contained in the report. Either delete i 4.1 from the Table of f
Contents, or provide the section.
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l Sectio' 2.0.. " Liquid Effluent Methodology" 2.
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(a) Eq. 2.4.2-1 on p. 2-4 does not contain a tem for near field average dilution.
Ifappropriate,creditfornearfielddilution(upto1000cfs) may be used in this equation provided that the basis for the dilution factor is either given in the ODCM or referenced to another document.
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3.
Section 3.0, " Gaseous Effluent Methodology" (a)In53.3.1.2.3(p.3-4&5)equationsaregivenforevaluatingdoses l
from exposure via three pathways to show compliance with 10 CFR 20.
To show compliance with 10 CFR 20 the inhalation pathway is most
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limiting. Consequently, the discussion (and accompanying Tables G-2 & 3) on exposure via the ground plane, and cow milk pathways may be deleted from this section.
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(b) In Eq. 3.3.2-4 a summation over the index "i" is used to determine 4
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the set point value for the noble gas monitor.
It appears that a sunmation is not needed in this equation; verify this equation.
4.
Section 4.0, " Radiological Environmental Monitoring"
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(a) Provide a copy of the latest land use census that was used to determine the locations for collecting milk and produce samples.
Provide the date of the land use census.
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Appendix B (a) The liquid effluent dose parameters A, presented in Table B-1 of j
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the ODCM are about a million times or more (0.8 to 2 x 10 times) lower than the values calculated by the NRC staff. Check the
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A values in Table B-1 and briefly explain the basis for these g
values. Presumably these values were calculated using the metho-1 dology described in some of the Appendices in Regulatory Guide i
j 1.109, Rev. 1 (October 1977) and site-specific values for a few parameters. List the site-specific values used to estimate A, (e.g., the quantities of water, fish and invertebrates,
9 ingested).
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If a dose calculation method other than Regulatory Guide 1.109 was used to estimate A then briefly describe that method, and the 97, bases for values different than those in Regulatory Guide 1.109.
6.
Appendix F (a) The X/Q values listed in Table F-1 for evaluating the air dose are less than the highest values listed in Table E-1 for the site boundary. Resolve this apparent inconsistency, i
7.
Appendix G (a) Th' P values in Table G-1 are too low by several orders of magni-e j
tude.
Recheck these values.
8.
Appendix I (a) The environmental pathway dose conversion factors R9 presented in Tables I-3, I-5, I-9 and I-19 of the RBS-0DCM for the principal pathways of exposures of the maximally exposed individual to airborne radiofodine and particulates are about 3 orders of 3
magnitude (1to3x10 times) lower than the values calculated by the NRC staff. This may be due in part to a typographical errorintheunitsusedintheabovetablesforR{4)(i.e.,
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" rem /yr" should be used instead of " mrem /yr"). However, there are
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additional discrepancies between'the R values calculated by the 9
NRC staff and those presented in these tables for several radio-nuclides (e.g., I-131. I-133 and C-14). Check the Rg values in the
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t tables in Appendix I ar.d briefly explain the basis for these values i
in the next revision of the ODCM. Presumably these values were i
l calcu-lated using the methodology described in some of the Appendices in Regulatory Guide 1.109, Rev. 1 (October 1977) and site-specific values for a few parameters.
List the site-specific values used to i
estimate the pathway dose factors (e.g., the fraction of the year that j
animals graze on pasture, the fraction of daily feed that is pasture 1
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grass when the animals graze, the humidity). If a dose calculation 1
method other than Regulatory Guide 1.109 was used to estimate ~ R,j then briefly describe that method, and the bases for values different j
than those in Regulatory Guide 1.109.
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9.
Figures
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(a) Figure 1, 3 & 5 are illegible.
Provide foldout figures. Dis-charge points for liquid and airborne effluents should be clearly 1
indicated on Figures 1 and/or 3.
The site boundary, which is used as a basis to control airborne effluents, should be clearly indi-cated on Figure 3.
The unrestricted area boundary, which is used as a basis to control liquid effluents, should be clearly indicated on Figure 1.
I 10.
Se'ction 6.0, "Interlaboratory Comparision Studies". The second sentence of subsection 6.2.1 stater that the River Bend Station Environmental Services Group or a qualified contracting laboratory will participate at least annually in a nationally recognized 4
interlaboratory comparsion study. This statement should be revised i
j to conform. with the NRC's Radiological Assessment Branch Technical Position (BTP)-(revision 1, October 1979). The BTP states that the licensee and licensee's contractor laboratories should part-l ticipate in EPA's Environmental Radioactivity Laboratory Intercom-i parsion Studies (Crosscheck) Program or an equivalent program.
The BTP also states that this participation sha11' include all of the determinations (sample-radionuclide combinations that are offered by EPA and that also are included in the licensees-i i
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environmental monitoring program.
In addition, results of the Interlaboratory Program should be included in the annual enviro-mental raonitoring report to NRC.
Revisef6.2.1accordingly.
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