ML20154B616
| ML20154B616 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/30/1988 |
| From: | Serrano W, Thomas Young EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20154B621 | List: |
| References | |
| CON-FIN-D-6034 EGG-PHY-8079, NUDOCS 8805170255 | |
| Download: ML20154B616 (36) | |
Text
EllCLOSURE EGG-PHY 8079 TECHNICAL EVALUATION REPORT for the EVALUATION OF UPDATED 00CM (UPDATED THROUGH AUGUST 27,1987)
BIG ROCK POINT P A T NRC Docket NO. 50 155 NRC LICENSE NO. DPR-6 W. Serrano T. E. Young Published April 1988 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U. S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE-AC07 76ID01570 FIN No. D6034 3
tecpt.uye.29 f(I'
//
o 9;'
ACKNOWLEDGMENTS The authors wish to acknowledge the contribution made by Cecilia Amaro by checking the contents of various data tables and pre reviewing equations in the Licensee's 00CM.
t l
l l
l 1
l l
L
ABSTRACT The Offsite Dose Calculation Manual (ODCM) for the Big Rock Point Plant contains current methodology and parameters used in the calculation of offsite doses due to radioactive liquid and gaseous effluents and in the calculation of gaseous and liquid effluent monitoring alarm / trip setpoints. Changes to the original 00CM were submitted to the NRC in the Semiannual Radioactive Effluent Release Reports for July-December 1985, July December 1986, and a revised report for January-June 1987 by letters dated, respectively, February 28, 1986; February 27, 1987; and August 27, 1987. The NRC transmitted the original ODCM and all changes to the Idaho National Engineering Laboratory (INEL) for review. The ODCM, complete with all changes, was reviewed by E%G Idaho at the INEL and results of the review are presented in this report. It was determined that the ODCM, updated through changes submitted August 27, 1987, uses methods that are, in general, in agreement with the guidelines of NUREG-0133. However, it is recommended that another revision to the ODCM be submitted to addreas and correct the discrepancies identified in the review, ii
i .
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 Comission, Office of Nuclear Reactor Regulation. The U. S. Nuclear Regulatory Comission funded the work under FIN D6034 and NP.C BAR Number 20 19 05 03.
This report was prepared as an account of work sponsored by an agency of the Uni *ad 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, 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.
iii l
l
.-- - ~
a
. l CONTENTS p, E.its.e Acknowledgments. . . . . . . . . . . . . . . . . . . . . . . . . i ,, ,
f Abstract. . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ,J s ll 1
Foreword. . . . . . . . . . . . . . . . . . , , , . , , , , , ,jjj ) ,
i) ,
- 1. Introductior., . . . . . . . . . . . . . . . , . . , , , , , , 1
- 2. Review Criteria . . . . . . . . . . . . . . . . . . . . . . . 2 l 3- Eusl e.-+
2--
88on.......................... 3 )
- 4. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . 24 i s
)
- 5. Re fe renc e s . . . . . . . . . . . . . . . . . . . . . , , , , , 30 ,
f
- 9. 5 i ,' f FIGURES f
- 1. Liquid effluent pathways and radioactivity monitors at Big Rock '
Po i n t Pl an t . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- 2. Gaseous effluent pathways and radioactivity monitors at Big Rock Point Plant. . . . . . . . . . . . . . . . . . . . , 7 -
l i
l
)
iv
\ /
/
s
[.
i
.L.,_k
.y ;; -
r1 l, f
1, INTRODUCTION
^
7 Puroose of Review
/! The purpose of this report is to accument the review and evaluation of i
f'/ the Offsite Dose Calculation H$nual (ODCM) submitted by the Consumers Power Company (CPC) for the Big Rock Point Plant (BRP), with all changes
( submitted through August 27, 1987.,'The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirements.Ill Scooe of Review t
e As specified in NUREG-0473[2], the'0DCM is to be developed by the
,, Licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the radioactive effluent systems. As a minimum, the ODCM should provide equations and methodology for the following topics:
. Alarm and trip setpoints on effluent instrumentation Liquideffluentpencentrationsinunrestrictedareas Gaseous efflueni dose rates at or beyond the site boundary
. Liquid and gaseous effluent dose contributions
. Liquid and gaseous effluent dose projections.
In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management sptems. A description and the location of samples in support of the environmental monitoring program are also normally included in the 00CM.
1
/
t
., i i 1
1 .
Plant-Soecific Backaround (
l The Licensee submitted an ODCM for the Big Rock' Point Plant (BRP), by a letter dated January 7, 1985. The ODCM was reviewed by the NRC and determined to be, in general, an acceptable reference as stated in an NRC memorandum dated April 30,1985,[3] and a letter to the L'censee dated August 26, 1985 I43. The Licensee submitted changes to the ODCM in the Semiannual Radioactive Effluent Release Report (SRERR) for the July-December 1985 period by a letter dated Februa* 28,1986.[5]
Further changes to the ODCM were submitted in the :mERR for the July-December 1986 period by letter dated February 27,1987;[6] the same changes were resubmitted in a revised SRERR for the July-December 1986 period by a letter dated August 27,1987.I73 The NRC transmitted the original 00CM and all changes to the INEL for review. The complete ODCH, updated through the changes submitted August 27, 1987, was reviewed by ,
EG&G Idaho at the INEL. The results and conclusions of the review are presented in this report.
- 2. REVIEW CRITERIA Review criteria for the ODCM were provided by the NRC in two documents:
NUREG-0473, RETS for BWRs[2]
NUREG-0133, Preparation of RETS for Nuclear Power Plants.[8]
In the ODCM review, the following NRC guidelines were also used:
' General Contents of the Offsite Dose Calculation Manual, Revision" I I93, Regulatory Guide 1.109[10), Regulatory Guide 1.111 Ill), and Regulatory Guide 1.113[12] The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.
l t
i
- 3. EVALUATION Liauid Radwaste Treatment System The Big Rock Point Nuclear Plant consists of a single boiling water reactor (BWR) operating with a once-through circulating water system.
Batch releases from various liquid waste tanks are diluted with the service water and the circulating water discharge before release to Lake Michigan. Wastes collected in the tanks are tested before release.
After analysis the waste may be reused, reprocessed, or released to the circulating water discharge canal. Continuous releases from the service water system are released directly to the circulating water discharge. A simplified block diagram of the liquid radwaste cleanup and discharge system is shown in Figure 2-2 of the ODCH. Figure 1 is a reproduction of ODCM Figure 2-2.
In addition to the effluent radiation monitors identified in Figure 2-2 of the ODCM, the BRP technical specification Tables 13-1, 13-2, and 13-3 require a composite sampler with a flow indicating device to monitor the circulating water discharge during periods of release.
Therefore, the monitoring instrumentation provides the necessary effluent monitoring for release of liquid radwastes from the BRP.
Liauid Radwaste Monitor Setooints l
Section II.B.1 of the ODCM contains methodology to determine the setpoints for the liquid radwaste effluent monitors, as required by Technical Specification 13.1.1.1. Technical Specification 13.1.1.1
, requires that the setpoints for the liquid effluent monitors be I
established to ensure that radioactive materials released as effluents I
shall not result in concentrations to unrestricted areas in excess of the values specified in 10 CFR 20, Appendix B, Table II, Column 2.
l l
3 1
1
1 i
l DIRTY WASTE CLEAN WASTE RECEIVER TA88KS RECEIVER TANKS g
I CHEMICAL T14A T148 f T33A Tl38 TIS ECEIVER k
YY YY TANK u SERVICE WATER {
l I '
i l 3 .
j RADWASTE WASTE MONITOR HI ALARM Note TANKS f
k CORISEIBSATE STORAGE j 1898NALARM TISA TISS TANK 4 j
y- 1-- -
H
- RE S274 4
, i ' 8275 2162 i r FLOW CONTR0t i
~
! OlSCHARGE $i 1' .- . CAleAL a
SERVICE ' '
a i
WATER I
RE LAEE 8273 HIGH ALARM 4
}
(
Figure 1. Liquid effluent pathways and radioactivity monitors at Big Rock Point Plant.
I (Figure copied from the Licensee's ODCM.)
l j
Section II.B contains the methodology for determining the radiation monitor setpoints corresponding to the minimum dilution flow (F) determined by the methodology of Section II.A.
The methodology described for determining minimum required dilution flow uses the definition of maximum permissible concentration (MPC) of a mixture of radionuclides as given in 10 CFR 20, Appendix B, Note 1. The methodology considers simultaneous releases. In section 11.8.1, the Licensee states, "Normally, a conservatively high dilution flow rate is used, that is flow rate used - (b )j (F) where b4 is a conservative factor greater than 1.0."
The nominal setpoint for the liquid effluent monitor at each release point corresponds to the measured concentration used to determine the minimum dilution flow rate allowed. However, the ODCM permits the setpoint to be set above the effluent concentrations by the "same factor (b)" utilized in setting the conservative dilution flow.
The discussions above of flow and setpoint determinations are based on reasonable interpretations of the meaning of several unclear terms in the ODCH. Primary defects in the write-up as it appears in the ODCM are the omission of appropriate subscripts and use erroneous references. The write-up would be greatly clarified by changing subscripts as follows, with an i subscript referring to a radionuclide and a j subscript to the release point for undiluted effluents: (a) add j subscripts to the C's on both sides of Eq. 2.1 and the definitions on the following page, (b) add a j subscript to the C in the numerator of Eq. 2.2 and the corresponding definition, (c) remove the subscript i from the b's in the definition of F for Eq. 2.3, (d) add j subscripts to the variables R, S, and C in Section II.B.1, and (e) add j subscripts to the C and f in the last paragraph of Section II.B.2. The definition of MPC in Section II.A.3 erroneously references Section 2.1.1 instead of Section II.A.I.
5
- - - - - - - - - - - - __ -- -__-------a
a .
1 The Licensee's method to determine the setpoints for the liquid effluent monitors is, in general, in agreement with the guidelines of NUREG-0133, and is considered acceptable.
Gaseous Radwaste Treatment System There are two gaseous effluent radioactivity monitors required by the BRP technical specifications at the BRP site: l Air ejector offgas monitor (with automatic termination of release)
Stack gas effluent monitor.
1 Gases from the air ejector offgas system are monitored by both the air ejector offgas monitor and the stack monitor, after a 30-minute holdup, and are then released from the stack (240 feet above grade). Gasos from the gland seal condenser pass through a 90-second holdup line before being monitored by the stack monitor and released from the stack. Gases from the containment, radwaste area, turbine building and service building are routed to the stack for monitoring and release. The Licensee's ODCM shows effluents from the emergency condenssr vent and chemistry laboratory vent released to the atmosphere without monitoring. Monitoring of these vents is not required by the technical specifications.
A simplified block diagram of the gaseous radwaste discharge system appears in Figure 1-1 of the ODCM. This figure is reproduced here as Figure 2. The Licensee's FSAR states, "The gates from the off-gas holdup line are all filtered through a high efficiency filter to remove all particulate matter prior to release in the stack." The filter is not shown in Figure 1-1 of the 00CM.
Table 13-2 of the Licensee's technical specifications requires a sampler flow rate monitor in the stack monitoring system for radiciodines, particulates, and noble gases. The Licensee's FSAR gives an estimate of 10.5 to 24.5 cfm release from the steam jet air ejectors, 145 cfm release 6
1 i
1 i < >
! wut i ' '
8000NEJPAAT SAatetEA
, c, ;,- -
l
- g secat t ,
_ GAS i
RE 8784 r
' MtA4NGE ' '
Noet E GAS l
7----
I
,I-----4-------------4 30 MIN 1
afAtorO O RE 8251 i
1
- ~! . . 4 , , ,
AIR ENCTOR .
j 2 y Of f GAS J J
1 VENT l
STAND SEAL 1 ' CONDEItsfA -
J RAstrASTE AREA CON 0fMSATE DEEsset *
,:,, ,,,, ,,.,A,,
. SERWICE SLOG vAavis ~R..NE .c -
O isc j t est ACE NCY i
fg C08051(N5( A / '
! 3
- [fa'el A1448 f4I Figure 2.
Gaseous effluent pathways and radioactivity monitors at Big Rock Point Plant. (Figure copied i from the Licensee's ODCM.)
e
o .
from the gland seal condenser, and 30,000 cfm release of ventilation air added to dilute the gaseous effluents from other sources. Compared to these estimates, the 00CM specifies a conservative ' flow rate of 39,000 cfm to be used for stack monitor considerations.
The radiation monitors, samplers, and flow monitors provide the required effluent monitoring for release of gaseous radwaste from the plant.
Gaseous Radwaite Monitor SetoointsSection I.A of the ODCM contains the mechodology to determine the alarm / trip setpoints for the radioactive gaseous effluent monitors, as required by Technical Specification 13.1.1.1.
Technical Specification 13.1.1.1 requires that the setpoints for the gaseous effluent monitors be established to ensure that the limits of Specification 13.1.3.1 are not exceeded. Specification 13.1.3.1 limits the dose rates of noble gases to less than or equal to 500 mrem /yr to the total body and less than or equal to 3000 mrem /yr to the skin; and the dose rate for iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives greater than 8 days to less than or equal to 1500 mrec'/yr to any organ. The bases statement for the technical specification limits the dose rate to the child's thyroid to less than 1500 mrem / year via the inhalation pathway. The bases statement for 13.1.1.1 also specifies that the set points of the instrumentation shall be adjusted so the alarm / trip will occur prior to exceeding the concentration limits of 10 CFR 20. Thus, the setpoints are based on concentrations whereas the technical specification limits are dose rates.
This is acceptable as the concentration limits are, in general, more restrictive than the dose rate limits.
In Section II.A.I.0, a phrase states Rk is 'for the single (stack) release point" which implies the equation is to be used for a single monitor. However, the subscript "k" allows the equation to be used for l
8
either the stack monitor or the air ejector monitor. Therefore, the phrase is confusing and should expanded or deleted.
In Equation I.1:
The MPC term requires the subscript "i".
The definitions should specify that the Cj's are the undiluted concentrations.
1 Table 1.3 must be replaced as the values are not legible and it l 1s not clear how values of zero were obtained for some of the calculated X/Qs and D/Qs. I i
Values of X/Q are tabulated in Table 1.3, and values for critical '
receptors in Table 1.4a. The values in Table 1.3 are identified as "Elevated Release, 240' Stack" (73 meters) which is consistent with the terminology of Regulatory Guide 1.111, which classifies releases as elevated if the release point is more than twice the height of adjacent structures. However, the Licensee assumes the releases to be vent r releases (instead of elevated releases), since X/Qs are used in the dose rate and dose calculations. This is consistent with NUREG-0133 which l specifies the dividing line between ground-level and elevated releases as 80 meters. (Some confusion would be eliminated if the releases were not designated as "elevated" in Table 1.3.)
Section I.A.2.0 of the 00CM outlines the methodology for using the Rk calculated in Section I.A.1 to determine the setpoints for the effluent monitors. The Licensee states, "Stack monitor response calibrations are performed to fission gas typical of normal releases (30-minute delayed offgas). Air ejector offgas monitor measures only slightly decayed gases, however, so is calibrated to provide accurate response to relatively fresh fission gases." In Section I.A.2.0.1 the Licensee then states, "Total gas concentration (yCi/cc) at the monitor l
is calculated. The calibration curve or constant for cpm /(uct/cc) is applied to determine cpm expected." It is not completely clear how the value of the "total gas concentration" at the stack monitor is calculated.
9 l
l
(Does the Licensee 30-minute decay the mix and concentration of gases measured in the weekly grab samples obtained at the air ejector and assume this to represent the mix and concentrations at the' stack monitor?) More detailed information, including the flow rate at the air ejector, should be included in a description of the method used to determine releases at the stack based on concentrations at the air ejector off gas monitor. The Licensee further states, "The setting for monitor alarms is established at some factor (b) greater than 1 but less than 1/Rk (Equation 1.1) times the allowed (sic) concentration (c):
s-bxc (I-2)"
The term "c" is not t ia allowed concentration; but is the actual concentration at the mo.Jtor, represented as epm. It is the product b x c that is the allowed concentration, represented as cpm. As written the 00CM states that the setpoint is always set to correspond to greater than the "allowed concentration".a This statement should be corrected.
Section I.A.2.0.2) of the ODCM discusses Accident Releases. The methodology of NUREG-0133 addresses effluent releases Ar.d conitor setpoints for routine operating conditions and does not address accident conditions.
Therefore, it is beyond the scope of this review to comment or judge the contents of this section.
The Licensee's method to determine the setpoints for the gaseous effluent monitors is, in general. in agreement with the guide ~lir,es of NUREG-0133.
However, clearer definitions of the parameters in the equations should be included. Unless a corrected description of the meaning of Equation 1.2 is included, it is ui.certain if the method is acceptable for determining the gaseous effluent monitor setpoints,
- a. It is possible to interpret the terms in Eq. (I.1) and Eq. (1.2) differently than was done when the recomendations given here we e formulated. If recomendations made above are not consistent with plant interpretation, very detailed definitions of the terms in the equations should be added to the 00CM in order to prevent misinterpretation.
10
Concentrations in Liauid EffluentsSection II.A of the ODCM contains the methodolo'gy for determining that the radionuclide concentrations in the released liquid effluents are maintained within the limits of Technical Specification 13.1.2.1, as required by Technical Specification 13.1.2.3. Technical Specification 13.1.2.1 requires compliance +o the concentration limits of 10 CFR 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved and entrained noble gases. For dissolved or entrained noble gases, the concentration is required to be limited to a total of 2 X 10-4 pCi/mL total activity.
Section II.A of the ODCM contains methodology for analyzing the contents of each tank prior to release and determining the minimum dilution flow rate required to ens"re that the limits of 10 CFR 20, Appendix B, Table II, Column 2 are not exceeded in the liquid effluents discharged offsite to the lake.
The methodology given in the ODCM accounts for simultaneous releases from as many as three sources. The Licensee states that, normally, a conservatively
, high dilution flow rate is used. Therefore, the Licensee's method for determining that the concentrations of radioactive material in liquid effluents is in compliance with Technical Specifications 13.1.2.1 is consistent with the guidelines of NUREG-0133, and is acceptable.
Dose Rates Due to Gaseous EffluentsSection I.A contains methodology for determining that the dose rates due to the release of noble gases are within the specified limits, as required by Technical Specification 13.1.3.2. The dose rate is assured to be within the limits of Technical Specification 13.1.3.1.a by restricting the summation of ratios identified in 10 CFR 20, Appendix B, Note 1 to be 11.0. This is acceptable as the concentration limits are, in general, more restrictive than the dose rate limits. It is not clear how the Licensee obtains the Cj values for the noble gas concentrations in Equation I.l. With this exception, the Licensees's method for assuring the dose rate due to the release of noble gases is within the guidelines of NUREG-0133 and is considered acceptable.
11
1 Section I.F identifies a release rate (based on four year historical releases from the plant) that would produce the 500 mrem / year dose rate limit to the total body, which implies a dose rate due to noble gases. Thus, it appears that this section is discussing the release rate due to noble gases only; however, this is not perfectly clear.Section I.H describes the sampling frequency and analysis requirements for noble gases, and states that the data are used to calculate the monthly noble gas releases. It is not clear if the Licensee uses the release rate identified in Section I.F and results of the analysis described in Section I.H in the noble gas release rate calculations of Section I.A. The term "(l.29E-04)" in the last sentence of Section I.F should be "(l.29E+04)".
Section I.A contains methodology for determining that the dose rate due to the release of I-131, I-133, tritium, and all radionuclides in particulate form with half lives greater than eight days are within the specified limits, as required by Technical Specification 13.1.3.3. The dose rate is assured to be within the limit of Technical Specification 13.1.3.1.b by restricting the summation of ratios identified in 10 CFR 20, Apper. dix B, Note 1 to be 11.0.
However, it is not clear how the Licensee obtains the C3 values for the radionuclide concentrations in Equation I.1.
Section I.G describes the sampling frequency and analysis requirements for iodines and particulates. The section states that the data are used ?.o represent an integrated release rate (of iodines and particulates) from~the stack.Section I.I describes the Licensee's method for estimating the rate of tritium release in gaseous effluents. However, sampling und analysis for tritium is not required by the technical specifications. Nowhere in the ODCM is there a requirement for using the data described in Sections I.G and I.I in the release rate calculation of Section I.A, as is required by Technical Specification 13.1.3.3. With this exception, the Licensees's method for determining that the dose rate due to the release of iodines, particulates, and tritium is in compliance with Technical Specification 13.1.3.3 is within the guidelines of NUREG 0133 and is considered acceptable.
12
Oose Due to Liauid EffluentsSection II.C of the ODCM contains the methodology for determining the dose or dose commitment to a member of the public due to radioactive material released in liquid effluents to demonstrate compliance with the dose limits of Technical Specification 13.1.4.1, as required by Technical Specification 13.1.4.4. For "release analysis" the 00CM furnishes Eq. 2.5 to be used with ODCM Table 2.2; which contains curie quantities, "design objective annual quantities" or "design basis quantities" of 56 radionuclides, a dose conversion factor for each radionuclide, and the individual and organ that will receive the largest fraction of the annual dose limit due to the release of that nuclide. The product of the curie quantity and the dose conversion factor for a nuclide in Table 2.2 is equal to the annual limit of either 3 mrem or 10 mrem, depending on whether the limiting dose is to the total body or an organ.
In Section II.C.2 the 00CM requires that the sum, 2(Aj /Cj),
be performed for each batch and weekly for continuous releases, where Aj is the activity of the nuclide released, and Cj is the "design objective annual quantity" for that nuclide. (The ODCH states, "Radionuclides may be omitted from the summation if they fall under the allowed omission specified by Note 5 to Appendix B, 10 CFR 20.") If the sum is greater than 0.5, for the quarter, indicating the quarterly limit has been reached; or greater than 1.0 for the year, the 00CM requires that the NRC LADTAP code be run to ensure that Technical Specification 13.1.4.1 "has been met". All input parameters for LADTAP should be tabulated in the 00CM.
On the surface, this appears to be a very conservative approach to ensuring that Technical Specification 13.1.4.1 limits are not exceeded.
However,Section II.C.2 of the 00CM contains methodology for determining the design objective annual quantities tabulated in ODCM Table 2.2 which includes several apparently non-conservative assumptions. These assumption's are: (a) adult water consumption of 730 mL/d (266 L/y),
13
(b) a "dispersion factor" of 800 for drinking water, corresponding to the dilution factor D in w Section 4.3.1 of NUREG-0133,[8), (c) and a
, "dispersion factor" of 15 for fish consumption. The use of 730 mL/d for adult drinking water consumption instead of the 730 L/yr recommended in
! NUREG-0133 must be justified. The "dispersion factor" of 800 for drinking j water may be unrealistically large, since it is approximately two orders of magnitude greater than the factor calculated in the example problem in l Regulatory Guide 1.113 for a plant located on the shore of one of the l Great Lakes, as is BRP. The Licensee must justify the value of 800 used.
No dilution factor is permitted for the fish pathway by the guidelines of NUREG-0133, so this factor must be justified or removed. The adult ingestion dose commitment factors are stated to be used for all organs and radionuclides in obtaining Table 2.2 values, whereas the teen and child in addition to the adult are included in Table 2.2. Thus the statement conflicts with the specification of different age groups in the table.
This conflict should be resolved, and the apparently non-conservative assumptions should be justified or changed.
A factor of 1000 is omitted from Eq. 2.9, but is in Eq. 2.10 which is derived using Eq. 2.9.
The bioaccumulation factor for phosphorus in Table 2.0 is incorrect; the current "best value" for this factor is 3000.
The values in Table 2.2 were partially checked for consistency. The ingestion dose factor given in Regulatory Guide 1.109 for the GI-LLI of a teenager is more than 10/3 (the ratio: organ dose limit / total body dose limit) times the dose factor for the total body for eleven radionuclides for which Table 2.2 shows the total body to be the "organ" receiving the highest fraction of the annual dose limit due to ingestion of that radionuclide. Therefore, for these nuclides, the GI-LLI should be shown in Table 2.2. (Three of these eleven radionuclides are in the list of "principle gama emitters" in NUREG-0473.) Also, for a teenager the design objective annual quantity for I-132 should be based on the thyroid instead of the total body. It was not possible to crosscheck between age groups in the table because consumption rates were given in the ODCM only for adults or for an unspecified age group.
14
- - - - - l
The "design objective annual quantities" from Table 2.2 were used in calculations of doses to the adult bone and adult GI-LLI, respectively, for Sr-90 and La-140. The doses calculated were nearly twice the 10 mrem they should have been for agreement with Table 2.2. The number of apparent errors detected in this partial check of Table 2.2 indicates that all values in the table should be checked. Also, ingestion dose factors for testiager and child should be added to the ODCM, since dose calculations for these age groups are required for the data in Table 2.2.
The water and fish consumption for these age groups should also be added for the same reason.
Section II.C.3 states that the annual doses will to be calculated using the LADTAP computer code. The ODCM describes the LADTAP methodology for dose computation, which is essentially identical to that used to calculate the design objective annual quantities of Table 2.2, including some of the non-conservative assumptions. All input parameters used in the LADTAP calculations must be included in the ODCH.
The methodology for calculating doses due to release of radioactivity in liquid effluents follows the guidelines of NUREG-0133. However, the non-conservative assumptions discussed above must be justified or changed before the methodology can be considered acceptable since they appear to result in calculated doses one to two orders of magnitude lower than would be obtained by strict adherence to the methodology of NUREG-0133. Also, ingestion dose factors for teenager and child age groups should be included in the ODCM if calculations are done for these age groups, as indicated in Table 2.2.
t l Dose Due to Gaseous Effluents The methodology for calculating offsite doses due to radioactive material in gaseous effluents is given in Section I.B of the ODCM, as l required by Technical Specification 13.1.4.4. The methodology of Section I.B is used to determine design basis quantities (DBQ); i.e., the minimum quantity of a radionuclide that when released continuously to the atmosphere in one year would result in a dose not exceeding any of the 10 CFR 50, Appendix I calendar year dose limits for doses due to gaseous 15 I
effluents. The methodology is also used to calculate dose factors (Dc/Cc) which, when multiplied by the corresponding DBQ, gives the limiting dose. (Methodology is given in Section I.C and Section I.D for using the DBQs and (Oc /C c )s to demonstrate compliance to the dose limits of the technical specifications.]
Section 1.B is titled "Dose Rate Calculation" and the terms "dose" and "dose rate" are used interchangeably throughout the section, which is confusing. The first sentence in Section 1.B states, "The first step involves calculating a dose rate based on the design objective source term mix used in Appendix I licensing calculations." The meaning of this sentence is unclear, since this terminology is not used elsewhere in the ODCH. (Does the "source term mix" refer to the source term given in ODCM Table 1.17)
Section I.B.l.1 contains the methodology to determine doses due to noble gas effluents. In Section I.B.1.1.1, the Licensee states that for calculating doses from noble gases the "noble gas radionuclide mix is based on the historically observed source term mix in Table 1.1." This section also states that meteorclogical data used are those resulting in the X/Q's and D/Q's of Table 1.3. (These X/Q values are usort in ODCM Section I.A for determining the setpoints of gaseous effluent monitors.)
Values of X/Q and D/Q in the Licensee's ODCM Table 1.3 are, respectively, approximately 1/12 and 1/3 of the values given in tne NRC's evaluation with respect to Appendix I to 10 CFR 50.Il33 Values of X/Q and D/Q l
should be verified.
- Equation I.3 of Section I.B.I.l.2 is used to calculate the air concentration (gCi/m3 ) of any radionuclide. This equation is based on Eq. 3 of Regulatory Guide 1.111, Revision 1,Illl with added terms to account for radioactive decay between release and dose point and for plume depletion as allowed by the Regulatory Guide. The following corrections and additions are required to Eq. I.3
l l
- A k subscript must be added to a.
l l
Values of fjk should be included in the ODCH.
16 l
l . The number of wind speed classes in Assumption 14 (in Section 1B.1.1.1) must be made to agree with the number of classes summed over in Eq. I.3.
Definitions should be added for h andz a k.
The following corrections are required in Eq. 1.6:
. The factor "3.17E-02" must be removed from the equation.
. The units of D amust be mrad /yr instead of mrem /yr.
Section I.B.I.2 contains the methodology to determine doses due to radioiodines and particulates released in gaseous effluents. The historical source term given in Table 1.1 is used for the calculations. Provisions should be added to the ODCM requiring the source term used to be changed if the radionuclide mix determined by the sampling and analysis required by Technical Specification 13.1.3.3, Table 13.3 differs significantly from the historical source term.Section I.B.I.2.1 states, "Dose is to be calculated for the critical organ, thyroid, and the critical age groups, infant (milk) and child (green, leafy vegetables)." The methods in this section are used to calculate the DBQ values listed in Table 1.9. This quoted statement should be modified to include all four age groups since Table 1.9 includes all four age groups.
Inhalation dose factors for teens must be added to Table 1.7, and ingestion dose factors for infant, child, and teen must be added to Table 2.1 in the ODCM.
Section I.B.I.2.2.1 gives the methodology for calculating doses due to the inhalation pathway by using the air concentration equation, Eq. I.3, from Section I.B.I.1 and the inhalation dose factors from Table 1.7.
Breathing rates assumed in Section I.B.1.2.2.1 for a child and for an adult are conservatively higher than those recomended in NUREG-0133.
Equation 1.8 of Section I.B.I.2.2.2 ir used to calculate the ground concentration (of any nuclide) to be used in the calculation of doses due 17 1
^
l l
l
. . l l
to direct radiation from the ground plane. The equation is confusing because the definition of DR erroneously refers to Table 1.3 for the value of DR/2xx. (The confusion arises because values (of D/Q) in Table 1.3 include the sumation over k of other terms in Eq.1.8 in ;
addition to DR/2xx; and therefore the equation seems to require values as input that are part of the values being calculated.) The following corrections are required in Eq. 1.8 and the associated definitions:
A subscript k should be added to DR in both the equation and the definition of DR.
The "o2 " in the second exponent of Equation (I.8) should have a subscript zk.
The units of ozk should be given as "m2 " instead of "m".
The units of DRk in the definition following Equation (I-8) should be specified as 1/m instead of 1/m2 ,
In the definition of DR, the phrase "(Table 1.3 for DR/2xx)"
must be removed.
Equation 1.10 in Section i.B.I.2.2.3 is used to calculate the concentration (of any nuclide except C44 and H-3) in and on vegetation, to be used in the calculation of doses due to ingestion of milk and vegetation. The concentrations of C-14 and H-3 in vegetation are calculated using Equations I.11 and I.12. The title of Section I.B.I.P. 2.3 must be changed from "Milk Ingestion" to "Milk and Vegetation Ingestion". The following corrections are required to Eq. 1.10:
. A subscript k should be added to DR in the equation.
. In Equation I.10, the exponent "-h 2/2027" should be 2 2 '
" h /20 zk-18
Equation I.12 for the concentration of nuclides in cow's and goat's milk does not specify a quantity of food assumed to be consumed by the milk animal. This information should be furnished.
The definition of "UM" for Eq. I.13 must identify the age group associated with the consumption rates and the consumption rates for the teenager and the adult must be added.
The statement preceeding ODCM Equation I.14 must be generalized to include doses to the total body and other organs in addition to the thyroid. Also, the omission of the meat ingestion pathway must be justified.
Section I.B.I.3 defines the DBQ and dose factors (Dc /C c ) to be used in Section I.C and I.0 to ensure that the quarterly and annual dose limits of the technical specifications are not exceeded. The dose limits of 20 mrem to the skin of an individual and 10 mrem to the total body of an individual identified in this section must be changed to 10 mrad gama air dose and 20 mrad beta air dose at or beyond the site boundary. The DBQ for noble gases in Table 1.9 must be values corresponding to 10 mrad gama air doses and 20 mead beta air doses. (Table 1.9 presently implies all dose limits to be either 5 mrem to the total body or 15 mrem to an internal organ or the skin, as indicated by the product of "Dose Factor" and "Design Objective Annual Quantity" from the table.) For iodines and particulates the limiting dose should be 15 mrem to an organ, since there is no technical specification limit of 5 mrem for the total body dose due to l these radionuclides.
l The DBQ values in Table 1.9 could not be verified directly using the equations of Sections I.B.I.1 and I.B.I.2 because some necessary parameters were not included in the ODCM (as noted elsewhere in this review). However, l the DBQ values for the principle gama emitters from NUREG 0473, X/Q and 0/Q values from 00CM Table 1.3, and parameters given in the 00CM or parameters recomended by NUREG-0133 were used to determine if the 08Q values are consistent with the annual dose limits due to gaseous effluents. Reasonable consistency was shown to exist between the DBQ values in Table 1.9 and the dose limits related to them in the table, 5 mrem to the total body and 15 mrem to any organ or the skin.
l 19 1
1
(
Sections I.C and I.D contain approximate methods to ensure the quarterly and annual dose limits are not exceeded. Table 1.9 in the ODCM includes both the DBQ and the cD c /C for 59 radionuclides calculated using the methodology of Section I.B. Two very conservative calculations utilizing DBQ and D c /C c are used to determine if release limits for gaseous effluents may have been exceeded. In the method described in Section I.C the quantities Aj of all radionuclides released are sumed over i according to Eq. I.16 below:
I[Aj/(DBQ)j] s 0.5 for a qtr, or 1.0 for the year.
This is a very conservative calculation, since it sums air, total body, and organ doses together. If either limit in the equation is exceeded the Licensee '.ndicates more accurate calculations will be made (See below.)
An alternate or second method is given in Section I.0 in which estimated doses are restricted according to Eq. I.17 and I.18 below:
Dg - I[Ajg(D c/Cc)jg] s 5 mrad /qtr,10 mrad /yr; and Dpg - I[Apgj(Dc/Ce)pgj] s 7.5 mrem /qtr,15 mrem /yr; where Da is the air dose due to noble gases and Dpg is the organ dose due to particulates and iodines.
l These calculations are more realistic than the calculation using Eq. I.16 since air doses are not sumed together with total body and organ doses, but are still very conservative. Noble gas gama and beta air doses are sumed together, with the limits for the beta air dose assumed to be the same as for
- the gama air dose. Additionally, the organ dose calculated is conservative l since the dose is calculated for a pseudo organ using each nuclide's limiting dose factor for any organ.
l l In Section I.D.I.2 the Licensee states that if the above methods of estimating the doses indicate limits may have been exceeded, calculations I
will be made using the NRC GASPAR computer code. Meteorological data for not 20 l
[
less than three years and demographic and land use information identified by the most recent land use census will be used with the GASPAR code.
With the corrections recomended above, the methods for calculating the doses due to gaseous effluents are, in general, consistent with the guidelines of NUREG-0133 and are considered acceptable.
Dose Proiections Gases from the air ejector must pass through a 30-minute holdup line and a high efficiency filter prior to release at the stack. Gases from the gland seal condenser pass through a 90-second holdup line prior to release at the stack. The air ejector effluents account for about 95% of the radioactive effluents and those from the gland seal condenser are the second most important source of radioactive gaseous effluents. Since the treatment of gaseous effluents cannot be changed, no dose projections are necessary and none is required by the technical specifications. Therefore, no methodology for projecting doses is included in the ODCH.
No projections of doses due to liquid effluents are required by the technical specifications, and no means of doing the projections are included in the ODCH.
l Diaorams of Effluent Pathways A diagram of the gaseous radwaste effluent pathways is shown in Figure 1-1 of the 00CM (Figure 2 in this document.) The high efficiency filter in the effluent pathway for air ejector gases, described in the FSAR, should be added to the figure.
The liquid effluent pathways at BRP are shown in Figure 2-2 of the ODCM (Figure 1 of this document.)
A figure showing the solid waste management system in not included in the l 00CM.
21 l
l t
Total Dose Section III of the ODCM contains the methodolcg'y for calculating the total dose as required by Technical Specification 13.1.6.1. (The ODCM erroneously references the applicable Technical Specification as 13.2.6.1 instead of 13.1.6.1.) Doses are to be determined by use of the LADTAP and GASPAR computer codes.
The Licensee's description of how the "40 CFR 190 Dose" is obtained is not completely clear. In Section III.C it states "like organs and total body sumed." A reasonable interpretation of this statement is that doses to an organ from all pathways are summed, and that to this sum is added the total body dose and the "mean dose rate" which is the direct radiation contribution. This is acceptable since it is conservative. However, it is not what was intended by 40 CFR 190. The total dose limits are for each individual organ with the total body considered as an organ. The direct radiation contribution is a component of the total body dose.
The following corrections should be made to Equation 2.15:
A subscript should be added to 04 o to identify the organ The "limiting dose" should be defined as the cumulative dose to the organ from all pathways.
l .
The "source term" should be defined as the cumulative releases during the year.
The component due to shoreline fishing at the accessible shoreline adjacent to the site security fence should be identified as the direct radiation component.
The subject of doses due to nearby uranium fuel cycle sources is not addressed in the 00CM, and should be added.
22
The methodology given in the 00CM for demonstrating compliance to the 40 CFR 190 total dose limits is conservative and acceptable. However, the Licensee should consider the aforementioned suggestions.
Environmental Monitorina Procram The Big Rock Point Plant technical specifications do not require any information concerning the environmental monitoring program to be included in the 00CM. No such information is included in the 00CM, although results of the Land Use Census that pertain to the locations at which maximum offsite doses are calculated are included as required by Technical Specificttion 13.2.3.
! Summary In summary, t.5e Licensee's 00CM uses documented and approved methods
- that are, in general, consistent with the methodology and guidance in NUREG-0133, Flegulatory Guide 1.109, and Regulatory Guide 1.111. However, because of the discrepancies identified in this review, it is recommended that the NRC request another revision to address the discrepancies.
23
- 4. CONCLUSIONS The Licensee's complete ODCM, updated through the changes submitted in the revised July-December 1986 SRERR by a letter dated August 27, 1987 was reviewed. It was determined that the 00CM uses methods that are, in general, consistent with the the guidelines of NUREG-0133, with the qualification that the assumptions used in calculating doses due to effluents are justified and that values of X/Q and D/Q based on the methodology of Regulatory Guida 1.111 are acceptable. However, it is recomended that another revt of the ODCM be submitted to address and correct the discrepancies identified in the review.
The following summarizes the identified discrepancies:
The source of the Cj values used in Eq. I.1 must be stated.
Section I.B.I.0 should be clarified. The object of what is called "the first step" is unclear. The first and third sentences are particularly confusing.
. The purpose of Section I.F of the ODCH is not clear. The discussion of a 500 mrem /yr dose rate implies that the section deals with noble gas effluents, but this is not clear. It is also not clear if the release rate identified is used in the calculations of Section I.A.
. The purpose of Section I.G is not clear. The section states that the particulate and iodine samples are obtained to represent an integrated release from the stack. Nowhere in the 00CM is there a requirement for using the data described in Section I.G and I.I in the methodology to ensure that dose rates are within the limit of Technical Specification 13.1.3.1.b, as required by Technical Specification 13.1.3.3.
. Several "design objective annual cuantities" in Table 2.2 are based on doses to the wrong "organ," (e.g., Table 2.2 shows several design objective annual quantities based on dose to the 24
I total body of a teenager; whereas the dose factor for the GI-LLI, from Regulatory Guide 1.109, is more than 10/3 (10 mrem /3 mrem) times the dose factor for the total body.
The DBQ values in Table 2.2 for some nuclides (e.g., Sr-90 and La-140) appear to be too high, based on input parameters given in the ODCM.
Consumption rates assumed for calculation of doses due to liquid effluents were given only for some consumption by adults and some consumption by an unspecified age group, although consumption rates for a teenager and child are required for determination of the "design objective annual quantities" in Table 2.2.
Several apparently non-conservative assumptions are used for the calculation of the "design objective annual quantities" in Table 2.2 and (probably) for LADTAP calculations, (i.e., (a) adult water consumption of 730 ml/d; (b) a "dispersion factor" of 800 for drinking water, and (c) a "dispersion factor" of 15 for fish consumption.]
. All input parameters used in the LADTAP calculations referenced in Section II.C.3 for calculat'ag annual doses due to liquid effluents must be included in the ODCM.
The "dispersion factors" for water and fish are not specifically defined for Eq. 2.13 and Eq. 2.14, although they are presumably the same as those used for calculating data in Table 2.2.
In Eq. I.1, the MPC term requires an i subscript.
Table 1.3 must be replaced as some of the values are not legible.
The zero values of X/Q and D/Q in Table 1.3 should be explained or corrected.
25
Values of X/Q and D/Q in Table 1.3 need to be verified, since they are factors of from 3 to 12 lower than those given in the NRC's evaluation for Appendix I to 10 CFR 50.
The following corrections and additions art required to Eq. 1.3.
A k subscript must be added to a.
Values of fjk must be included in the DXM.
The number of wind speed classes in Assuation #14, preceeding Eq.I.3, must be made to agree with the number of classes summed over in the equation.
The following corrections are required in Eq. I.3:
The factor "3.17E-02" must be removed from the equation.
The units of D amust be mrad /yr instead of mrem /yr.
Inhalation dose factors for teens must be added to Table 1.7, and ingestion dose factor for infant, child, and teen must be added to Table 1.1 in the ODCH.
The following corrections snd additions are required to Eq. I.8 and l the associated definitions:
The phrase "(Table 1.3 for DR/2x)" must be removed from the definition of DR.
l A subscript k should be added to DR in both the equation and the definition of DR.
The a2 in the second exponent should have a subscript zk.
l l
The units of azk should be given as m2 instead of m.
l 26 i
H
i The units of DR(k) in the definitions following Eq. I.8 !
should be specified as 1/m instead of'l/m2 ,
The following corrections are required to Eq. I.5.0:
A subscript k should be added to DR in the equation.
The exponent '-h2 /202Z . should be 2 2 '
" h /2o zk-The definitions for equation I.12 must specify the quantity of food consumed by the milk animal.
The definition for VM in Eq. I.13 should identify the consumption rates for all age groups.
The statement preceeding ODCM Eq. I.14 should be generalized to include doses to the total body and other organs than the thyroid. Also, the omission of the meat ingestion pathway must be justified.
The dose limits in Section I.B.1.3 must be changed to 10 mrad gama air dose and 20 mrad beta air don.
l The following less critical deficiencies and errors should also be corrected in a revision of the 00CM:
l Equations and references throughout the 00CM should be numbered consistently, with either Arabic or Roman numerals as the first
- digit.
The terms "dose" and "dose rate" should be used consistently throughout the 00CM, with dese rate used for values with instantaneous or short term limits and dose used for values with l
quarterly or annual limits.
27
q A conversion factor of 1000 is omitted in Eq. 2.9, but the equation derived from Eq. 2.9 is correct.
l The high efficiency filter in the effluent pathway of the air ejector, as described in the FSAR, should be added to Figure 1-1 if it exists.
In Section I.A.1.0, a phrase states Rk is "for a single (stack) release point" which implies that Eq. I.1 is to be used for a single monitor. However, the subscript k allows the equation to be used for either the stack monitor or the air ejector monitor.
Therefore, the phrase is confusing and should be deleted or explained.
The definitions for Eq. I.1 should specify that the Cj's are the undfluted concentrations.
s' The term "allowed concentration" preceedingng Eq. I.2 should be changed to "measured concentration" so the discussion does not state that the setpoints are always set at greater than the allowed concentration. '
4 The term "(1.29E-04)" in the last sentence of Section I.F should ,
be corrected to read "(1.29E+04).)
l .
Definitions should be added for h and a z k in Eq. I.3. 's l
. Assumption #1 in Section I.B.1.2.1 should be modified to include '
all four age groups.
The title of Section I.B.2.2.3 should be changed from "Milk Ingestion" to "Milk and Vegetation Ingestion." . 4 28
a;,
l
. The following corrections and additions should be made to Eq. 415:
A subscript should be added to 40 o to identify the organ.
The "limiting dose" should be defined as the cumulative dose to an orgr.n from all pathways.
The component due to shoreline fishing at the accessible shoreline adjacent to the site security fence should be identf[iedasthedirectradiationcomponent.
The subject of doses due to nearby uranium fuel cycle sources should be addressed.
In Section II.A, with i denoting nuclides and j denoting release points, the following changes should be made:
Add j subscripts to the C's on both sides of Eq. 2.1.
Add a j subscript to the C in the numerator of Eq. 2.2 and f the corresponding definition.
i emove the i subscripts from the bj's in the definition of Ffor,{q.2.3. ,
l .
Add j subscripts to the C and f in the last paragraph of
! Section II.B.2.
i Change "Section 2.1.1" to "Section II. A.1" in the definition of I
MPC in Section II.A.3.
The bioaccumulation factor for phosphorus in Tabta 2.0 should be changedto3p30,thecurrent"bestvalue."
29 i
i
- 5. REFERENCES
- 1. Title 10, Code of Federal Reaulations, Part 50,' Appendix I, "Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, 'As Low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents".
- 2. "Standard Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors, NUREG-0473, September 1982.
- 3. Memorandum from D. R. Muller (NRC) to D. W. Crutchfield (NPC),
Subject:
DSI Safety Evaluation and Environmental Consideracion of Big Rock Point Nuclear Power Plant Supporting a Licensee Amencment (RETS, MPA Item A-02), April 30, 1985.
- 4. Letter from J. A. Zwolinski (NRC) to D. J. VandeWalle (BRP),
Subject:
"Radiological Effluent Technical Specifications", August 26, 1985.
- 5. Letter from B. D. Johnson (BRP) to J. G. Keppler (NRC), "Semiannual Radioactive Effluent Release Report - July through December 1985, February 28, 1986.
- 6. Letter from 8. D. Johnson (BRP) to NRC, "Semiannual Radioactive Effluent Release Report - January through December 1986,"
February 27, 1987.
- 7. Letter from R. R. Frisch (BRP) to NRC, "Semiannual Radioactive Effluent Release Report - January through June 1987," Big Rock Point Plant, Consumers Power Company, August 27, 1987.
- 8. "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications," NUREG-0133, October 1978.
30
3
. o .
- 9. "General Cont'ints of the Offsite Dose Calculation Manual," Revision 1 Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.
- 10. "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I," Regulatory Guide 1.109, Rev. 1, October 1977.
- 11. "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents In Routine Releases from Light-Water-Cooled Reactors," Regulatory Guide 1.111, Revision 1, July 1977.
- 12. "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I,"
Regulatory Guide 1.113, Revision 1, April 1977.
- 13. Memorandum from J. T. Collins (NRC) to D. L. Ziemann (NRC),
Subject:
DSE Evaluation of Big Rock Point Nuclear Power Plant with Respect to Appendix I to 10 CFR Part 50; October 31, 1978.
t 31 i