ML20128A050
| ML20128A050 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/27/1985 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20128A054 | List: |
| References | |
| TXX-4499, NUDOCS 8507020552 | |
| Download: ML20128A050 (16) | |
Text
ATTACHMENT A RESPONSE TO NRC COMMENTS ON CPSES ODCM (10/84 SUBMITTAL) 1.
Section 1.1.2, Page 1-3 COMMENT:
The ODCM states that XRE-5253 is an in-line process monitor which only allows 46 gpm to flow past it.
Explain how this radiation monitor will control flow.
RESPONSE
Section 1.1.2 was revised to indicate that XRE-5253 restricts flow due to the physical characteristics of the monitor.
2.
Section 1.1.6, Page 1-4, Eq. 1 COMMENT:
should be defined.
The parameter Cg
RESPONSE
C is defined in Section 1.1.1.
g
-3.
Section 1.1.6, Page 1-5, Eq. 2 i
COMMENT:
The parameter AF should be defined.
i f
A m
RESPONSE
An Allocation Factor (AF) of 0.5 was originally included in the equation for F to allow for simultaneous releases from the liquid waste processing system and the Turbine Building Sumps.
Due to physical modifications, the Turbine Building Sump is no longer considered a continuous discharge pathway and simultaneous releases will not occur. Therefore, the parameter AF has been deleted from Section 1.1.6.
. 4.
Section 1.0, Liquid Effluents COMMENT:
A Section 1.5, Definition of Liquid Gaseous Effluent Parameters, similar to Section 2.4 should be added to the ODCM.
RESPONSE
F A new Section 1.6 has been added which lists definitions of common Liquid Effluent Parameters.
5.
Section 2.1.la, Page 2-2, Last Line i
COMMENT:
Units for flowrate, Qi, are incorrectly specified as u/sec.
Additionally, the units for the total body dose factor, K, are i
incorrectly specified as mrem / hear. The manual must be reviewed to include the correct units.
RESPONSE
The entire ODCM has been reviewed and revised, where i
appropriate, to include correct units.
l u
6.
Section 2.1.1d, Page 2-7 COMMENT:
X and F are incorrectly subscripted to read Xiaux F aux. The i
manual must be revised to include the appropriate labels.
RESPONSE
In Section 2.1.5, the Factor X aux Fiaux was corrected to read i
Xicont Ficont. Additionally, the entire ODCM has been reviewed and revised for consistency of use of variable, subscripts, and labels.
7.
Section 2.1.2a, Page 2-8 COMMENT:
Pi is defined and values for Pi are tabulated in the manual.
In addition, a reference to Appendix A for the derivation of Pi should be made in this section.
RESPONSE
A reference to Appendix A for the derivation of Pj has been included in Section 2.1.6.
8.
Section 2.2.1, Page 2-11 COMMENT:
1 l
a.
This section cites an incorrect reference to Technical Specification (TS) 3.11.2.1.
The correct reference is TS i
3.11.2.2.
h i
, _.. _ -.. _ _ _, _., _,. _. _ _, _, _ _ - -,, _,.. _.... _ _ _ _ _., _.,, _,, _ _ _.., _ _..,. _. _ _. _ _,. _ _. _ _ _ _ _ _ _, _. _. _, _ _,,. ~.
b.
Qj is defined as a cumulative release. The ODCM must also specify the time frame over which the release is made.
RESPONSE
a.
In Section 2.2.1, the reference to TS 3.11.2.1 was corrected to TS 3.11.2.2.
b.
The definition of Qi in Section 2.2.1 has been revised to specify the time frame over which the release is made.
9.
Section 2.2.2, Page 2-12 COMMENT:
a.
The equation for D must include a summation over all p
pathways in addition to all nuclides.
b.
In addition to all radionuclides, Rj must be idexed to pathway and age group, c.
Ri values are tabulated in the manual.
In addition, a reference to Appendixes B-F for the derivation of Ri should be included.
d.
The values for X/Q or D/Q are not consistent with the values found in Table 2.7.
The ODCM must resolve the difference.
RESPONSE
a.
The equation of Dp in Section 2.2.2 has been revised to include a summation over all pathways.
The parameter RP,a in Section 2.2.2 has been indexed to b.
i radionuclide, i; pathway, p; and age group, a.
A footnote has been added in Section 2.2.2 referencing c.
Appendixes B-F for the derivation of RP
,a-i d.
The definitions of X/Q, D/Q, X/Q and D/Q have been revised to eliminate confusion in the use of these different parameters. The entire ODCM was reviewed to ensure consistent use of these parameters throughout the manual.
Note that the value assigned to X/Q does not appear in Table 2.7, since X/Q is defined at the site boundary and Table 2.7 lists X/Q values at receptor locations.
10.
Section 2.2.3, Page 2-13 COMMENT:
The discussion of dose calculations includes a reference to
" dispersion parameters (X/Q, D/Q) which are concurrent with actual releases".
If real-time meteorological data will be used, the ODCM should describe how appropriate met data, i.e.,
wind speed, wind direction, stability, etc., will be determined and used.
RESPONSE
i A new Section 2.3.3 has been added to address how real-time meteorological data is collected, processed and used.
I I
11.
Table 2.2, Page 2-15 COMMENT:
a.
The incorrect short form for Manganese 54 (Mn 54) must be corrected.
b.
The columns under ground plane and food must be deleted as per Appendix A.
RESPONSE
a.
The short form for Manganese 54 in Table 2.2 has been corrected.
b.
The columns for ground plane and food have been delted from Table 2.2.
12.
Table 2.7, page 2-30 COMMENT:
a.
This table is not explicitly referenced in the ODCM.
It appears that the appropriate reference point is Section 2.2.3.
b.
This table should not be referenced to the Environmental l
Report, which can be changed by amendment without reference to the ODCM. This table may be changed only by i
amendment to the ODCM.
i i-
RESPONSE
a.
Tables 2.7 and 2.8 have been referenced in Section 2.2.2.
b.
The reference to the Environmental Report on Table 2.7 has been deleted.
1 13.
Section 3.2, Page 3-1 COMMENT:
f The description of the applicant's Interlaboratory Comparison Program is described only in general terms in the manual.
The text must be revised to show how the requirements of TS 3/4.12.3 will be met. Specifically, the manual should contain details of 3
i the program, e.g., who will actually perform the crosscheck analyses, procedures to be followed, etc.
t
RESPONSE
Section 3.2 has been revised to include a more detailed description of the Interlaboratory Comparison Program.
14.
Table 3.1, Page 3-4
}
COMMENT:
TS 12.1 and its Table 3.12 require that the radiological l
environmental sampling program (REMP) include milk sampling at f
four locations. Table 3.1 lists only 2 locations. The applicant should resolve the inconsistency between TS 12.1 and the ODCM.
I l
RESPONSE
A footnote was added at the end of Table 3.1 to eliminate confusion between the milk sampling locations specified in the ODCM and the requirements of TS 3.12.1.
15.
Figure 3-1, Pages 3-6 and 3-7 COMMENT:
This figure must depict the locations of the sampling points in the REMP. The present maps in Figure 3-1 are too vague and small for this purpose. The applicant must revise the maps clearly showing, among other things, site boundary for Comanche Peak and all monitoring locations. An enlarged, annotated map will facilitate review of the REMP locations.
RESPONSE
Figure 3-1 has been revised to more clearly show environmental sampling locations.
16.
Appendix A, Page A-1, Appendix B, Page B-1, Appendix C, Page C-1 COMMENT:
DFAj and DFGj are defined in the appropriate appendixes.
In addition, a reference for tabulated values must be provided.
RESPONSE
The definitions of DFAi and DFGi in Appendix A and Appendix B l
have been revised to include a reference to the tabulated values in Regulatory Guide 1.109.
l l
l
17.
Appendix D, Page 0-1 COMMENT:
C The equation for Ri must be reviewed for accuracy.
For example, Y must be in the denominator of the equation. Additionally, Rj and DFj must be indexed for receptor age.
RESPONSE
C TheequationforRjinAppendixDhgsbeenreviewedandrevised for consistency with NUREG-0133. Ri and DFLj have been indexed to receptor age.
18.
Appendix D, Page D-2 COMMENT:
FortheH-3ca[culationDFLjmustbeclearlydefinedinthe eguation for Rj, i.e., i can have only 1 value.
Additionally, Rj and DFLj must be indexed to receptor age.
RESPONSE
For the H-3 calculation in Appendix D, DFLj was redefined as DFL,a anditsdefinitionwasrevisedtoclearlystatgthatonly t
values for tritium should be used in the equation.
Rj and DFLt have also been indexed to receptor age.
19.
Appendix E, Page E-1 COMMENT:
Y3 must be in the demoninator for the expression (1-f *fs) and p
not for the whole equation.
Additionally, Rj' and DFLj must be I
indexed to receptor age.
t
RESPONSE
M The equation for Ri in Appendix E has been reviewed and revised M
for consistency with NUREG-0133.
Ri and DFLi have been indexed to receptor age.
20.
Appendix F, Page F-1 COMMENT:
V DFLj must be defined in the Appendix. Additionally, Rj and DFLj must be indexed for receptor age.
See also comment 17 for H-3.
RESPONSE
For the H-3 calculation in Appendix F, DFLi was redefined as DFL,a anditsdefinitionwasrevisedtoclearlystatethgt t
only values for tritium should be used in the equation. Rj and 0FLj have been indexed to receptor age.
4 i
i
ATTACHMENT B
SUMMARY
OF CHANGES TO CPSES ODCM SECTION DESCRIPTION OF CHANGE p.vi A " Cross Reference to Technical Specifications" has been added.
In addition, efforts have been made to more thoroughly reference applicable Tech Specs in the text of the ODCM.
INTRODUCTION Paragraphs 2 and 3 have been reworded and expanded for clarity. These changes more clearly delineate the relationship between the RM-21 and the ODCM.
1.1 Minor rewording and addition to text for clarity.
(1.1 from 10/84 submittal) 1.1.1 No changes were made.
(1.1.1 from 10/84 submittal) 1.1.2 Minor rewording for clarity.
Words were added to indicate that XRE-5253 (1.1.2 from 10/84 restricts flow due to the physical characteristics of the monitor.
No changes submittal) in methodology were made.
1.1.3 No changes were made.
(1.1.3 from 10/84 submittal) 1.1.4 A " Note" was added to address the adjusted circulating water flow that should be (1.1.4 from 10/84 used if radioactivity is detected in the reservoir.
No changes in methodology submittal) were made.
1.1.5 A footnote was added indicating which MPC values from 10CFR20 should be used.
(1.1.5 from 10/84 The safety factor of 2 was deleted to reduce the amount of conservatism built submittal) into the equation. Other minor rewording for clarity.
1.1.6 The equation shown was corrected by adding the summation sign before C. The g
(1.1.6 from 10/84 alarm setpoint was redefined along with minor rewording of the text for submittal) clarity. The Allocation Factor (AF) shown in the equation for F was deleted
SECTION DESCRIPTION OF CHANGE since the Turbine Building Sump is no longer considered a continuous discharge pathway and simultaneous releases will not occur.
1.2 A new section was added to clarify the calculation of dase due to liquid effluents. The equation given shows the total dose is the sum of the dose received during a discharge and the dose received due to previously discharged radionuclides that have built up in the lake.
1.2.1 Parameters have been redefined and minor rewording for clarity.
No changes in (1.2 from 10/84 methodology were made.
submittal) 1.2.2 A new section was added based on the " NOTE' in Section 1.2 of the 10/84 (1.2 from 10/84 submittal. Guidance is given for calculating the dose due to measurable levels submittal )
of contaminants in the lake.
1.3 A new section discussing dose projections required by TS 3.11.1.3 was added.
1.4 The text was rewritten and variables redefined for clarity.
No changes in (1.3 from 10/84 methodology were made.
submittal) 1.5 Minor rewording for clarity.
No changes in methodology were made.
(1.4 from 10/84 submittal) 1.6 A new section defining common liquid effluent parameters was added.
FIGURE 1.1 Drawing modified to show location of monitor XRE-5253.
FIGURE 1.4 This figure was revised to show in greater detail and more accurately depict the liquid waste processing system.
2.1 Minor rewording for clarity.
(2.1 from 10/84 submittal) 2.1.1 This section was reworded and reformatted for ease of use.
No changes in (2.1.1.a from 10/84 methodology were made. A clearer definition of Qj is given. All units were suomittal) reviewed to ensure they are correct.
SECTION DESCRIPTION OF CHANGE 2.1.2 This section was revised to simplify the equations by redefining variables and (2.1.1.b from 10/84 ii.serting constants directly into the equations.
No changes in methodology were submittal) made. The discussion of the calculation of Qi was moved to Section 2.1.1.
2.1.3 A new section was added to address the setpoint methodology for the flow rate monitors specified in TS 3.3.3.11.
2.1.4 This section was revised to clarify the calculation of the auxiliary building (2.1.1.c from 10/84 vent monitor setpoint, including discussion of all assumptions used in the submittal) determination. The previous submittal arrived at the final equation by assuming that the concentration (uCi/cc) Auxiliary Building vent was much greater than the concentration from other sources. This was corrected to state that the source contribution (uCi/sec) from the Auxiliary Building vent was much greater than the source contribution from other sources. The methodology was not changed.
2.1.5 This section was revised to clarify the calculation of the containment (2.1.1.d from 10/84 atmosphere monitor setpoint, including discussion of all assumptions used in submittal) the determination. The previous submittal arrived at the final equation by assuming that the concentration (uCi/cc) from the Containment vent was much greater that the concentration from other sources. This was corrected to state that the source contribution (uCi/sec) from the Containment vent was much greater than the source contribution from other sources. The methodology was not changed. All variable subscripts were reviewed for consistency.
2.1.6 Minor rewording for clarity. No changes in methodology were made. Also, a (2.1.2.a from 10/84 reference to Appendix A was added for the derivation of Pj.
submittal) 2.1.7 A new methodology for determining the plant vent iodine monitor setpoint has (2.1.2.b from 10/84 been established. The setpoint is established in a manner similar to that for submittal) the plant vent noble gas monitor. Although this monitor is an integrating monitor, the software used in the RM-80 processes the data from the monitor and yields a channel output which is an estimate of instantaneous iodine concentration. Therefore, calculating a setpoint in the same manner as the noble gas monitor is considered appropriate.
SECTION DESCRIPTION OF CHANGE 2.1.8 A new methodology for determining the plant vent particulate monitor setpoint (2.1.2.c from 10/84 is established in a manner similar to that for the plant vent noble gas monitor, submittal)
Although this monitor is an integrating monitor, the software used in the RM-80 processes the data from the monitor and yields a channel output which is an estimate of instantaneous particulate concentration. Therefore, calculating a setpoint in the same manner as the noble gas monitor is considered appropriate.
2.2.1 Minor rewording for clarity.
No changes in methodology were made. The (2.2.1 from 10/84 reference to TS 3.11.2.1 was corrected to TS 3.11.2.2.
Also, the definition of submittal) a cumulative release was clarified to specify the time frame over which a release is made. A note was added describing substitutions to be made if this methodology is used to determine dose to an individual rsther than air dose.
2.2.2 The text was reworded for clarity. The equation for D was revised to include p
(2.2.2 from 10/84 a summation over all pathways. Ri was modifigd ig_be indexed to pathway and submittal) receptor age.
Definitions of X/Q, D/Q and X/Q, D/Q were reworded to eliminate confusion in the use of these different parameters. The entire ODCM was reviewed to ensure consistent use of these parameters throughout the manual. Note that the value assigned to x76 does not appear in Table 2.7 since X/Q is defined at the site boundary and Table 2.7 lists parameters at receptor locations.
Also, a reference to Appendixes B-F for the deviation of Rj was included. References to Tables 2.7 and 2.8 were added.
2.2.3 A new section discussing dose projections required by TS 3.11.2.4 was added.
2.2.4 This section was reworded for clarity and to ensure consistency with Tech Specs.
(2.2.3 from 10/84 The reference to TS 6.9.1.11 was deleted as this specification no longer exists, submittal)
TABLE 2.2 The columns for ground plane and food were deleted as per Appendix A.
TABLES 2.3 - 2.6 The correct units for the valves of all tritium pathways were added. The values in all of the tables were reviewed for accuracy.
In Table 2.6, the values for Zn-65, inhalation pathway; and I-131, cow-milk, cow-meat, vegetation, and goat-milk pathways were found to be in error and corrected.
TABLE 2.7 The reference to the Environment Report was deleted. Values for distance, X/Q, and D/Q in the SE sector were changed based on the results of the land use census.
SECTION DESCRIPTION OF CHANGE TABLE 2.8 The distance and pathway in the SE sector was changed based on the results of the land use census. The cow / milk pathway in the NW sector was deleted since no pathway actually exists in that sector.
2.3.1 and 2.3.2 These sections were reworded and reformatted for clarity.
In Section 2.3.2, (2.3 from 10/84 the equation for calculating D/Q was corrected by adding the variable Z to submitt:r) account for the fraction of time the wind blows to a given sector.
2.3.3 A new section was added to address the NRC's Comment No. 10. This section addresses how real time meterological data is collected, processed, and used.
FIGURE 2.1 This figure was revised to show in greater detail and more accurately depict the gaseous waste processing system.
3.2 This section was revised to describe in greater detail how the requirements of (3.2 from 10/84 TS 3.12.3 are met.
submittal)
TABLE 3.1 This table was revised to reflect the current sampling locations as determined by the land use census. Also, a footnote was added to the last page to clarify why milk samples are taken at only two locations.
FIGURE 3.1 This figure has been revised to more clearly show environmental sampling locations.
APPENDICES The equations in all appendixes were reviewed for accuracy and corrected, A-F where appropriate. When different methodologies are given for calculation of conversion factors for tritium, definitions were revised to clearly state that only values for tritium should be used in the equation. Also, where appropriate, parameters were indexed to receptor age.
References for sources of data were added.
APPENDIX G This appendix was deleted from the manual. The computer program used to calcu! ate dose conversion factors is maintained on file at CPSES and is available for review.