ML20127H184
| ML20127H184 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 05/26/1976 |
| From: | Weiss B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Strong L ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 9211180428 | |
| Download: ML20127H184 (3) | |
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)/N, MAY 2 6 1976-5 6 1GS Mr. Lenton W. Strong Technical Services Branch U. S. Environmental Protection Agency Eastern Environmental Radiation Facility P. O. Box 3909 Montgomery, Alabama 36109
Dear Mr. Strong:
We appreciate the opportunity of being able to coment on the draf t report. Air Pathways Exposure Model Validation Study at the Monti-cello Nuclear Generating Plant".
I am sorry that this review took more time than anticipated, but there were several groups within the Nuclear Regulatory Commission (NRC) who had an interest in reviewing the document. The enclosed comments represent a consol -
idated listing of the significant comemnts provided by these groups.
Sincerely, Originni signed by B.11. Weiss Bernard H. Weiss Safety and Environmental Programs Office of Inspection and Enforcement
Enclosure:
As stated abovo j
cc:
C. Phillips, EPA l'
bec:
L. Higginbotham l
J. Kastner, OSD J. Collins, NRR J. Goll, NRR l
B. Grimes, NRR 9211180428 760526 PDR ADOCK 05000263 p
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COMMENTS ON AIR PATHWAY EXPOSURE MODEL VALIDATION STUDY AT THE MONTICELLO NUCLEAR GENERATING PLANT 1.
The introduction contains a discussion of proposed rule changes and organizational funct1ons which cannot be considered directly related to model comparison and field measurements.
It is sug-gested that this discussion could be deleted but that the introduction express the idea that estimates of doses to individuals off-site require the use of models since environmental measurement at the levels under consideration are generally not considered reliable. However, if you would prefer to reference NRC regulations this paragraph should, as a minimum, be revised to reflect the final version of the Appendix I:
"On oby 5,1975, the Nuclear Regulatory Commission (NRC) published in effective form Appendix I to 10CFR-Part 50 which provides numerical guides for light water cooled nuclear power reaccors to keep radioactiv1ty in effluents as low as reasonably achievable. Basically, the proposed guides specify as design-objectives for doses to individuals, the values 3 mrem / year radioactive material in liquid effluents, 5 mrem / year of external radiation from radioactive material and gaseous effluents and 15 mrem / year to any organ from radioiodine and radioactive material in particulate form from all pathways of exposure."
2.
Page 2, last paragraph. The last sentence of this paragraph incorrectly implies that all 11censees report effluent releases in conformance with Regulatory Guide 1.21.
The sentence should be revised as follows:
"The gaseous effluent data provided by each reactor in accordance with plant technical specifications are used as the basic input data for this model."
3.
Page 7, Meteorological and Gaseous Release Data.
It would be helpful to describe the height at which wind speed and direction and sigma theta data were collected.
If the data used were from a different instrument level, the method used to adjust wind speeds representative of the stack release level should be described.
4.
Page 8, last paragraph.
It would be helpful to clarify whether any radionuclides were excluded from the input to the models..This paragraph raises some questions as to whether minor radionuclides were ignored.
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Page 8, last paragraph. Table 2 which is referenced in this paragraph gives a breakdown of the fractional abundance of the gaseous radionuclides and the resultant fractional ground level K
88 Since 87 r(Tl/2 = 1.3 hrs) and Kr(T1/2 = 2.8 hrs) exposure rate.
both have essentially the same fractional abundance and the gamma dose factors (mret/hr per microcurie /cc) differ by only a factor i
of 2.5, it is not understood why the calculated fraction of ground level exposure between the two radionuclides differs by a factor of 2.5, it is not understood why the calculated fraction of ground level exposure between the two radionuclides differs by a factor of 200.
In addition, the last three radionuclides should be "Xe" instead I
of "Kr".
6.
Page 16, second paragraph.
It appears that the plume centerline concentrations of 0.032 and 0.036 pCi/m3 should be given in units of uC1/m. We suggest that this be checked and, if our comment is correct, Table 8 should also be revised.
J 7.
Page 17, Discussion. The explanation of the methods used for measuring the natural background would be better placed in Section IV for both the PICS and the TLDs.
8.
Page 20.
In lines 3 and 14, there is reference to " Appendix I limits".
Appendix 1 specifies design objectives rather than limits.
4 9.
Page 20, last line. The phrase " estimate extreme violations of i
Appendix I guides" is somewhat unclear.
It is suggested that this
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phrase be' changed to " detect conditions where doses are substantially above design objectives given in Appendix I".
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