ML20127G148
| ML20127G148 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/30/1992 |
| From: | Thomas Young EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20126H796 | List: |
| References | |
| CON-FIN-D-6034 EGG-PHY-10461, NUDOCS 9211160305 | |
| Download: ML20127G148 (27) | |
Text
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EGO PHY 10461 Technical Evaluation Report for the Evaluation of ODCM Revision 3 Enrico Fermi Atomic Power Plant, Unit 2 NRC Docket No. 50-341 NRC License No. NPF-43 T.E. Young T.S.Bohn D. W. Akers Published September 1992 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Under DOE Contract No. DE AC07 401001020 FIN No. D6034
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ABSTRACT The Offsite Dose Calculation blanual (ODCht) for the Enrico Fermi Atomic Power Plant, Unit 2 (Fermi 2) contains current methodology and parameters used to calculate offsite doses, dose rates, effluent monitoring alarm / trip setpoints, and conduct the radiological environmental monitoring program. The NRC transmitted the most recent complete Fermi 2 ODChi, Revision 3, dated February 7,1991, to the Idaho National Engineering Laboratory for review by EG&G Idaho,Inc.
The ODChi was reviewed by EG&G, and the results are presented in this report. It was determined that the ODChi uses methods that are,in general, within the guidelines of NUREG 0133. Ilowever, an error in the methodology used to calculate the maximum offsite organ dose due to gaseous effluestts should be corrected promptly. There are also several equations that require the addition of summations over radionuclides and/or gaseous effluent release points to properly calculate the offsite doses.
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FOREWORD This report is submitted as partial fulfillment of the " Review of Radiological Issues" project being conducted by the Idaho National Engineering Laboratory for the U. S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, ne U. S. Nuclear. Regulatory Commission funded the work under FIN D6034 (Project 5) and NRC B&R Number 2019 05 03, This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warrant, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, or of any information, apparatus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately. owned rights.
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- CONTENTS
-,s A B S TR A CT..................................................'...... _... l '
. F O R E W O R D......................................................... 11 o
- 1. I NTR O D U CTI O N.................................................... 1
- 2. RE V I E W CRITERI A................................................. 2
- 3. RADIOACTIVE EFFLUENT RELEASE ROUTES..'........................... 3
- 4. E V ALU ATI O N...... -................................................ - 6 '
5. S U M MA R Y....................................................... 1 6 -
- 6. CO N CLU S I O N S.................................................... 2 0 -
- 7. R E FE R E NCES....................................................-.. 21_
FIGURES
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. 2. Gaseous effluent release routes at Fermi 2..-..... _............................ 5 L b
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- 1. INTRODUCTION 1.1 Purpose of Review This document reports the review and evaluation of the most recent version of the Offsite Dose Calculation Manual (ODCM) for the Enrico Fermi Atomic Power Plant, Unit 2 (Fermi 2), submitted by the licensee Detroit Edison Company (DE). The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I?1 This review was performed to assess conformity of the Fermi 2 ODCM to the Fermi 2 Technical Specifications and current NRC guidelines.
1.2 Plant Specific Background initial approval of the ODCM for Fermi 2 is documented in a letter from B. J. Youngblood (NRC) to W. Jens (DE), dated October 31,1984?! A revised Radiological Environmental Monitoring Program section of the ODCM was submitted with the semlannual report for the second six months of 1987?1 A completely revised ODCM, designated Revision 2, was submitted with letters from B. R. Sylvia (DE) to Document Control Desk (NRC), dated March 1,1989 and April 7,1989?#1 A complete ODCM, Revision 3, was submitted with the semiannual effluent report for the second six months of 1990?1 Changes incoQorated in Revision 3 were mainly improvements in the methodology of Revision 2. The licensee subsequently submitted a proposed Technical l
Specification Change, to implement the recommendations of Generic Letter 89 Ol'3 for transferring the procedural details of the RETS to the ODCM, with a letter dated November 26.1991?3 to this request for a Technical Specification Change is a Draft ODCM.
Part I, " Radiological Effluent Controls," of the Draft ODCM contains the procedural details of the RETS that are being transferred to the ODCM. Part II, " Calculational Methods," is essentially unchanged from Revision 3 of the ODCM (Ref. 6), except references to Technical Specification sections are replaced by references to ODCM sections; e.g.," Technical' Specification (TS) 3.3.7.11" is replaced by "Offsite Dose Calculation Manual (ODCM) 3.3.7.11. Sections in Part I are numbered the same as they were in the Technical Specifications, except for replacing "TS" with "ODCM."
Sections in Part II are numbered the same as in ODCM Revision 3, except the first digit is increased by 4; i.e., Section 2.0 becomes Section 6.0. Therefore, although the evaluations that follow reference the current Technical Specifications and ODCM Revision 3, the comments can easily be transferred to the Draft ODCM.
The Fermi 2 power plant is on the western shore of Lake Erie at Lagoona Beach, approximately 8 miles ENE of Monroe, Michigan; 30 miles SW of downtown Detroit, Michigan; and 25 miles NE of downtown Toledo, Ohio.
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- 3. RADIOACTIVE EFFLUENT RELEASE ROUTES 3.1 Liquid Effluent Release Routes Liquid effluents from Fermi 2 are diluted by the blowdown from the circulating water reservoir blowdown line and then discharged to Lake Erie. The Updated Final Safety Analysis Report (UFSAR)tui states that the minimum dilution flow is about 10,000 gpm (22.28 cfs).
Technical Specifiention 3.3.7.11 requires the following radioactivity monitors with alarm / trip setpoints set to ensure that the limit of TS 3.11.1.1 are not exceeded:
1.
Liquid Radwaste Effluent Line Dil N007 (providing alarm and automatic termination of release) 2.
Circulating Water Reservoir Decant Line Dll N402 (providing alarm only)
All radioactive liquid discharges from the site are made from the Waste Sample Tanks (3).
A diagram of the radioactive liquid release routes, copied from Figure 2.01 of the ODChi,is shown in Figure 1.
3.2 Gaseous Effluent Release Routes Section 11.3.7 of the UFSAR states. "The two release points for normal gaseous radwaste effluents are the reactor building vent and the turbine building vent. Technical Specification 3.3.7.12 requires the following radioactive effluent monitoring systems, with alarm / trip setpoint set to ensure that the limits of TS 3.11.2.1 are not exceeded:
1.
Reactor Building Exhaust Plenum Effluent Monitoring System (providing alarm) 2.
Offgas bionitoring System 3.
Standby Gas Treatment System (providing alarm) 4.
Turbine Building Ventilation Monitoring System 5.
Service Building Ventilation Monitoring System o
6.
Radwaste Building Ventilation Monitoring System 7.
Onsite Storage Building Ventilation Exhaust Radiation Monitor Discussions in the UFSAR and ODCM indicate that the building ventilation systems are the only routes by which gases are released from the buildings. A diagram of the gaseous effluent release routes, copied from Figuic 3.01 of the ODCM, Revision 3, is shown in Figure 2.
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Gaseous effluent release routes at Fermi 2. (Copied from Figure 3.0-1 of the Fermi 2 ODCM. Revision 3.)
the maximum no v rate from MAX RR to MAX RR/(1 + 4). For clarity, the discussion should indicate the renton for using DF for the total dilution now in Eq. 2 5 instead of (DF + RR) which is used in Eq. 21.
The value of MPCF determined using Eq. 2 2 is more conservative than required, because dissolved and entrained noble gases are included in the calculation with MPC, = 2E -04 pCi/mL. This is not necessary, since the limit on dissolved and entrained noble gases is independent of the limit on other radionuclides.
The methodology to determine the setpoint of the radioactivity monitor on the CWR Decant Line is given in Section 2.3.2. There are errors and inconsistencies in this section. The main error is the omission of a summation over "1" lo the numerator of Eq. 2-7.* A monitor sensitivity term should also be included, as in Equation 2 5. Equation 2 7 then becomes:
LC x SEN,) x SF i
SP s (2 7)
The definitions of C, and MPCF for Eq. 2 7 state that the C 's are obtained from the CWR decant i
line and the MPCF is calculated using the concentrations in a Waste Sample Tank. With these definitions (assuming MPCF > 1), the setpoint would correspond to a concentration less than the concentration in the Decant Line, resulting in continuous alarm. The definitions should be corrected and clarified. As an approxirnation, both the C,'s and the MPCF could be derived from the liquid radwaste, if it were assumed that the relative concentrations of radionuclides are the same in the CWR Decant Line as in the Liquid Radwaste Efauent Line.
Sections 2.3.4 through 2,4 describe monitoring of the normally non radioactive water from the GSW and RIIR systems prior to release to the CWR, These monitors are not required by the TS, and releases are subsequently monitored by the CWR Decant Line Radiation Monitor. These sections also discuss procedures to be followed if the GSW, RHB, or CWR systems are determined to contain radioactivity.
The methodology to determine setpoints of the liquid efnuent radiation monitors is within NRC
-guidelines except for the need of a summation sign and clarification of terms in Eq. 2-7, However, other identified deficiencies should be addressed.
To be consistent with the recommendations of NUREG-0473, Technical Specification Table 4.11.1.1 1 should show the CWR Decant Line as requiring sampling and analysis, it now requires sampling and analysis of the GSW (for which no monitor is required by the TS) but does not specifically require sampling and analysis from the CWR Decant line.
'This is apparently a typographical error, since the proper summation sign has been added in the Draft ODCM submitted in the RETS transfer proposal authorized by Generic Letter 89-01.
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the same distribution used in the dose calculation. The methodology of Section 3.3.2 should be acceptable, but a more comprehensive basis for its use should be added to the ODCM.
The last paragraph of Section 3.3.2 should be rewritten to state that the total body dose rate is a higher fraction of the dose rate limit than the skin dose rate, not that the total body dose rate is higher than the skin dose rate. Justification for this statement should be added to the ODCM.
Technical Specification Table 3.3.7.121 requires monitoring of the Offgas System, but TS 3.3.7.12 -
excludes methodology for determining setpoints of the Offgas Monitoring System from the ODCM.
liowever, TS 3.11.2.7 states,"The gross radioactivity rate of noble gases measured at the discharge of the 2.2 minute delay piping shall be limited to less than or equal to 340 millicuries per second after 30 minute decay" This TS may be considered as establishing the setpoint for the Offgas Monitoring System. The limit of 340.nlllicuries per second is related to the limits of 10 CFR 100 ")(25 rem to the total body and 300 rem to the thyroid)instead of the dose rate limits during normal operation, based on 10 CFR 20.I'M The methodology for determining setpoints of the gaseous effluent radiation monitors is within NRC guidelines based on the requirements of the Fermi 2 Technical Specifications. However, deficiencies identified above should be addressed.
To be consistent with the recommendations of NUREG-0473, TS 3.3.7.12 should not exclude the offgas monitoring system from the requirement that the setpoint be determined in accordance with the methodology and parameters of the ODCM, and TS Table 3.3.7.12 1 should require that the offgas monitor provide automatic termination of release. Also, the meaning of the entries in TS Table 3.3.7.121 should be clarified with a statement that all of the required monitors provide an alarm function. This table now indicates that only two of the seven monitors provide alarm.
4.3 Concentrations in Liquid Effluents Technical Specification 4.11.1.1.2 requires that the resubs of the radioactivity analyses required by TS 4.11.1.1.1 be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits of TS 3.11.1.1. The requirements of TS 3.11.1.1 aro given in Section 4.1 of this report.
Section 2.3 requires that the analyses required by TS 4.11.1.1.1 be used to determine the setpoints of the liquid effluent radioactivity monitors. The setpoint of the Liquid Radwaste Effluent Line Monitor and the Waste Tank discharge rate restrict the concentrations released to UNRESTRICTED AREAS to one-half the limits of TS 3.11.1.1. The setpoint of the CWR Decant Line is ambiguous, as indicated in Section 4.1 of this report. If either the Liquid Radwaste Effluent Line monitor or the CWR Decant Line monitor alarms during a liquid release, Section 2.3.5 requires analysis of the 9
The methodology of Section 3.6 appears to follow the interpretation of TS 3.11.2.1 contained in the basin miniements of NUREG 0473 the Fermi 2 "S; i.e., that compliance with TS 3.11.2.1 may be demonstrated by showing that the dose rate to the thyroid of a child via the inhalation pathway does not exceed 1500 mrem /yr. Ilowever, the thyroid is not specified. The following additions should be made to Section 3.6:
1.
The right side of Eq. 3.9 should be summed over all applicable release points, 2.
The values of R. should be identified as those for the thyrold, and 3.
The specification of the frequency at which evaluations are performed should include the sampling and analysis requirements of Notation c of TS Table 4.11.2.1-1.
The methodology to determine that the organ dose rate is within the limit of TS 3.11.2.1 is within NRC guidelines if the three corrections recommended above are made.
4.5 Dose Due To Liquid Effluents Pursuant to Technical Specification 4.11.1.2, Section 2.5 of the ODCM contains methodology to determine the cumulative dose contributions from liquid effluents for the current calendar quarter and current calendar year. Technical Specification 3.11.1.2 requires,"The dose or dose commitment to a MEMBER OF Tile PUBLIC from radioactive materials in liquid effluents released, from each scactor unit to UNRESTRICTED AREAS (see Figure 5.1.3-1) shall be limited:
a.
During any calendar quarter to less than or equal to 1.5 mrems to the total body and to less than or equal to 5 mrems to any organ, and b.
During any calendar year to less than or equal to 3 mrems to the total body and.to less than or equal to 10 mrems to any organ."
The meaning of the term " release period" should be clarified in Section 2.5. For batch Teleases it should be stated whether it refers to the time for an individual batch release or the entire time for which the dose is being calculated; i.e.,31 days, calendar quarter, or calendar year.
Section 2.5 should require that the cumulative dose contributions from liquid effluents for the current calendar year and the current calendar year be determined at least once per 31 days.
The methodology of Section 2.5 to determine dose contributions from liquid effluents is within NRC guidelines. Ilowever, the meaning of the term " release period" should be clarliied.
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The definition of Qi or Equations 314 and 315 should state that " cumulative release includes the f
effluents from all release points.
The definition of D, for Eq. 314 does not need to include the total body as an organ. However, the organ dose should include the total body dose due to radiation from the ground plane as a component of the organ doset 1.c., the organ dose is the sum of the total body dose due to radiation from the ground plane and the organ doses due to inhalation and lagestion pathways. (See Section C.3 and the last sentence of Section 1 of Appendix C of Regulatory Guide 1.109.)
The last paragraph of Section 3.8.1 states that only a single pathway needs to be evaluated to determine the organ dose to be compared with the limits of TS 3.11.2.3. This pan. graph should be rewritten to define the calculated organ dose to be compared with the limits of TS 3.11.2.3 as the highest organ dose obtained by summing the doses via all applicable pathways to an organ of an individual of a given age group; e.g., the dose to the thyroid of a child obtained by summing the doses via the ground plane, inhalation, vegetable, and milk pathways.
Section 3.8.2 should be revised to be consistent with changes in Section 3.8.1 recommended in the previous paragraph The licensee's methodology to calculate the maximum organ dose due to the release of radioactive material other than noble gases is considered to be within NRC guidelines except for the need to consider all pathways in the calculation of the organ dose.
4.7 Dose Projections Pursuant to TS 4.11.1.3.1 and TS 4.11.2.5.2, Sections 2.6 and 3.9, respectively, contain methodology to project doses due to radioactive liquid and gaseous effluents. To conform to the recommendations of NUREO 0133, the projections of doses by these sections should include a margin, based on operating data, for anticipated operational occurrences.
i 4.8 Diagrams of Effluent Release Routes The ODCM contains simplified flow diagrams defining the treatment paths and the components of the radioactive liquid and gaseous waste management systems, as recommended by the Branch Technical Position, dated February 8,1979.
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Table 6.01 identifies radiological environmental monitoring locations and the locations are shown in Figures 1,2, 3, and 4. as required by TS 4.12.1. All of the samplitig location required by TS 4.121 are identified by distance and direction from the reactor.
The !!censee's environmentalinonitoring program is completely described in ODCM Section 6.0.
It is consistent with the requirements of TS 4.12.1, and is within NRC guidelines.
4.11 Interlaboratory Comparison Program Section 6.3 describes participation in an Interlaboratory Comparisom Program, as required by TS 4.12.3. Therefore, the licensee's ODCM is within NRC guidelines with respect to this requirement.
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A monitor sensitivity term should also be added to Eq. 2 7 for the radioactivity monitor on the CWP Decant Line. (4.1) 3.
The definitions of C, and MPCF for Eq. 2 7 state that the C's are obtained from the i
CWR decant line rnd the MPCF la calculated using the concentrations in a Waste Sample Tank. With these definitions (assuming MPCF > 1), the setpoint would correspond to a concentration less than the concentration in the Decant Line, resulting la continuous alarm. The definitions should be corrected and clarified. (4.1) 4.*
To be consistent with the recommendations of NUREG 0473. Technical Specification Tabie 4.11.1.1-1 should show the CWR Decant Line as requiring sampling and analysis.
(4.1) 5.*
To be consistent with the recommendations of NUREO 0473. TS 3.3.7.12 should not exclude the offgas monitoring system from the requirement that the setpoint be determined in accordance with the methodology and parameters of the ODCM, and TS Table 3.3.7.121 should require that the offgas monitor provide automatic termination of release. Also, the meaning of the entries in TS Table 3.3.7.12-1 should be clarified with a statement that all of the required monitors provide an alarm function. This table now indicates that only two of the seven monitors provide alarm. (4.2) 6.
The last paragraph of Section 3.3.2 should be rewritten to state that the total body dose rate is a higher fraction of the dose rate limit than the skin dose rate, not that the total body dose rate is higher than the skin dose rate. The justification for this statement should be added to the ODCM. (4.2) 7.
The values of R, in Eq. 3.9 should be identified as those for the thyroid. (4.4) 8.
In Section 3.6, the specification of the frequency at which evaluations of the offsite dose rates are required should mention the sampling and analysis requirements of Notation c of TS Table 4.!!.2.1 1. (4.4) 9.
The meaning of the term " release period" should be clarified in Section 2.5. For batch releases it should be stated whether it refers to the time for an individual batch release or the entire time for which the dose is being calculated; i.e. 31 days, calendar quarter, or calendar year. (4.5) 10.
Section 2.5 should require that the cumulative dose contributions from liquid effluents for the current calendar year and the current calendar year be determined at least once per 31 days. (4.5) 17 l
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Category D. The following items concern methodology and parameters that the licensee may wish to change because the change may simp!!fy calculations, remove unnecessary conservatism in the calculations, or make use of recent data:
1.
The value of MPCF determined using Eq. 2 2 is more conservative than required, because dissolved and entrained noble gases are included in the calculation with MPC, = 2E-04 pCi/mL. This is not necessary, since the limit on dissolved and entrained noble gases is independent of the limit on other radionuclides. (4.1) 4 2.
The presence of Eq. 4 2 in Section 4.2.1 implies that the skin is considered an organ for the purpose of assessing compliance with 40 CFR 190. This equatior should be removed, since the skin is specifically excluded by 40 CFR 190. (4.9) b 19
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- 7. REFERENCES 1.
Title 10, Code of Federal Regulations. Part 50, " Domestic Licensing of Production and Utilization Facilities" 2.
Letter from B. J. Youngblood (NRC) to W. Jens (DE); Subject; Approval of the Fermi 2 Offsite Dose Calculation htodel; October 31,1984.
3.
Letter from B. R. Sylvia (DE) to Document Control Desk (NRC);
Subject:
Semi Annual Radiological Effluent Release Report: February 29,1988.
4.
Letter from B. R. Sylvia (DE) to Document Control Desk (NRC);
Subject:
Semi-Annual Radiological Effluent Release Report; htarch 1,1989.
Letter from B. R. Sylvia (DE) to Document Control Desk (NRC);
Subject:
Request for Additional Copy of ODCht; April 7,1989.
6.
Letter from W. S. Orser (DE) to Document Control Desk (NRC);
Subject:
Semi Annual Radiological Effluent Release Report; hfarch 1,1991.
7.
Letter from S. A. Varga (NRC) to All Power Reactor Licensees and Applicants;
Subject:
Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation hianual or to the Process Control Program (Generic Letter 89 01); January 31,1989.
8.
Letter from W. S. Orser (DE) to Document Control Desk (NRC);
Subject:
Proposed Technical Specification Change (License Amendment)- Reloc2 tion of Radiological Effluent Technical Specifications (Implementation of GENERIC LETTER 89 01 Guidance; November 26,1991.
9.
" Standard Radiological Effluent Controls for Dolling Water Reactors"; NUREG-0473, Revision 3, Draft 9, August 28,1989.
10.
" Preparation of Radiological Efflue'nt Technical Specifications for Nuclear Power Plants, A Guidance hianual for Users of Standard Technical Specifications," NUREG-0133, October 1978.
11.
" Calculation of Annual Doses to bian from Routine Releases of Reacter Effluents for the Purpose -of Evaluating Compliance with 10 CFR 50", Regulatory Guide 1.109, Revision 1.
October 1977.
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BIBUOGRAPHIC DATA SHEET EGG-PHY-10461
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T. E. Young, T. S. Bohn, D. W. Akers September k9 2
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Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 FIN No. D6034
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t& sus.6144mf.av hCTis 11 44TM.GT(190we.e er'and The Offsite Dose Calculation +!anual (00CM) for the Enrico Fermi Atomic Power Plant,- Unit 2
. (Fermi 2) contains current methodology and parameters used to calculate offsite doses, dose rates, effluent monitoring alarm / trip setpoints, and conduct the radiological environmental monitoring program.
The NRC transmitted the most recent complete Fermi 2 ODCM, Revision 3, dated February 7,1991, to the Idaho National Engineering Laboratory for review by 'EG&G Idaho, Inc.
The ODCM was reviewed by EG&G Idaho, and the results are presented in this report.
It was determined that the ODCM uses methods that are, in general, within the guidelines of NUREG-0133.
However, an error in the methodology'used to calcula~te the maximum offsite organ dose due to gaseous effluents should be corrected promptly.
There are'a)so several equetions that require the addition of summations over radionuclides and/o gaseous effluent release points to properly calculate the offsite doses.
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