ML20198G222
| ML20198G222 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/15/1997 |
| From: | Gundrum L NRC (Affiliation Not Assigned) |
| To: | Grigg R WISCONSIN ELECTRIC POWER CO. |
| References | |
| TAC-M92346, TAC-M92347, TAC-M95350, TAC-M95351, TAC-M96261, TAC-M96262, TAC-M97839, TAC-M97840, NUDOCS 9708250226 | |
| Download: ML20198G222 (6) | |
Text
f....g 172/174 / I 12/l95
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UNITED STATES f
j NUCLEAR REZULATORY COMMISSION WA&HIHoToN, D.C. 305&bC001
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August 15, 1997 Mr. Richard R. Grigg Chief Nuclear Officer Wisconsin Electric Power Company 231 West Michigan Street, Room P379 Mdwaukee, WI 53201
SUBJECT:
POINT BEACH NUCt. EAR PLANT, UNIT NOS.1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: TECHNICAL SPECIFICATION CHANGE REQUESTS RELATING TO RADIATION PROTECTION (TAC NOS. M92346/7, M95350/1, M96261/2, AND M97839/40)
Dear Mr. Grigg:
Additional information is required to continue the review on Technical Specifications Change Requests (TSCR) 172, TSCR 174, TSCR 182, and TSCR 195 for the Point Beach Nuclear Plant (PBNP). TSCR 172, submitted May 2,1995, and supplemented on October 12,1995, and March 26,1996, proposes to eliminate the minimum frequencies for checks, calibrations, and testing of the radiation monttonng system instrument channels (TS Table 15.4.11, Item 30) except for the main steam line radiation monitors. TSCR 174, submitted April 24, 1996, proposes to eliminate all radioactive liquid and gaseous effluent monitors in accordance with guidance provided in Generic Letter 89-01. TSCR 182, submitted November 17,1995, and supplemented on July 29,1996, requests replacing the Health Physics Manager with the Health Physicist. TSCR 195, submitted January 21,1997, requests updatiag references to 10 CFR Pari 20.
Additionalinformation is needed on the types of radiation monitors included in the radiation monitoring system, those radiation monitors listed as effluent monitors that provide only a monitonng function, the health physicist position desenption, and the extent of PBNP's adherence to 10 CFR Part 20 requirements. The request for additionalinformation (RAI) is enclosed. Please respond to the RAI within 120 days of receipt and provide the needed changes to the submittals. Supplementalinformation in response to specific TSCRs can be submitted separately any time prior to the end of the 120-day period.
REC'D PBNP
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(Q _o S W ]
AUG 271997
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R. R Grigg August 15, 1997 if you have additional questions, please contact Linda L. Gundrum at 301415-1380.
Sincerely, h Ysd1 %
Linda L. Gundrum, Project Manager Project Directorate lil 1 DMslon of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos 50-266 and 50 301
Enclosure:
RAI cc w/ encl:
See next page k'
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Mr. Richard R. Gngg Point Beach Nuclear Plant
[
Wisconsin Electdc Power Company ?
Unit Nos.1 and 2
[
cc:
Emest L Blake, Jr.
- Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, DC 20037 Mr. Scott A. Patuiski
- i Vice President Point Beach Nuclear Plant Wisconsin Electdc Power Company f
6610 Nuclear Road
- Two Rivers, Wisconsin. 54241
- Mr,' Ken Duveneck l
[
- Town Chairman:
Town of Two Creeks j
- 13017 State Highway 42 Mishicot, Wiscorisin 54228 i
Chairman Public Service Commission of Wisconsin-P.O. Box 7854 Madison, Wisconsin 53707 7854 Regional Administrator, Region til i
U.Si Nuclear Regulatory Commission 801 Wanenville Road -
Lisle, Illinois - 60532-4351 Resident inspector's Office U.S. Nuclear Regulatory Commission 6617 Nuclear Road Two Rivers, Wisconsin 54241 Ms. Sarah Jenkins
-- Electdc Division -
Public Service Commission of Wisconsin P.O. Box 7854
~ ! Madison,' Wisconsin' 53707 7854 s
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REQUEST FOR ADDITIONAL INFORMATION TSCR.172 Operational Safety Review Radiation Monitonng System As discussed in Generic Letter 9510, issued December 15,1995, four critena were est.blished to determine which design conditions and associated surveillances should be located in the 'S as limiting conditions for operation. Four enteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36. These four enteria are: (1) installed instrumentation that is used to detect, and indicate in the control roum, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assuma the failure of or presents a challenge to the integnty of a fission product banier, (3) a structure, system, or component that is part of the pnmary success path and which functions or actuates to mitigate a design basis accident (DBA) or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, and (4) a structure, system, or component which operating experience or probabilist;c safety assessment has shown to be significant to public health and safety.
Based on the 10 CFR 50.36 enteria, Attachment A lists examples of radiation monitors that may need to be retained in standard technical specifications. Please note that the radiation monitors are part of the system specification. The radiation monitors on closed systems need to be included if the monitors provide signals for equipment that must reposition to maintain the system as closed.
Providing answers to the following questions, will assist in the review of TSCR 172.
l 1.
It is the NRC's understanding that PBNP has three categones of monitors in the radiation monitonng system. area monitors, effluent monitors and process monitors.
Please venfy the lists of radiation monitors in A"Jehment B, Tables 1,2, and 3 include all radiation monitors in the radiation monitonng system.
2.
In each category, some of the monitors, listed in Attachment B. Table 4, have control functions that may meet the requirements of 10 CFR 50.36. Please address those monitort hsted in Attachment B. Tables 1,2,3, and 4 which have control functions and provide additionalinformation on why these monitor do/do not meet any of the enteria of 10 CFR 50.36.
3.
Please prowde information on other radiation monitors, identified by item 1, that meet the entena of 10 CFR 50.36. Provide justification on why these monitors, if any, are not included in technical specifications (TS).
4.
Submit the appropriate TS changes, in accorriance with 10 CFR 50.36, for tho, t radiation monitors that should/must remain in TS. Include limiting conditions for operation, applicability, action statements with conditions, required action and completion time specified, surveillance requirements, surveillance frequencies, required number of monitors, monitor setpoints, and bases.
TSCR 174 Radiological Effluent Technical Specifications 5.
New guidance (Attachment C) was provided to the Nuclear Energy Institute (NEI) on April 9,1997, on TS for the radioactive effluent controls program. This new guidance includes 10 CFR Part 20 changes. Please review the new guidance and revise your submittal as appropriate. ENCLOSURE
S 6.
Revise submittal to remove only those radiological efflu:nt monitors that do not meet the requirements of 10 CFR 50.36.
TSCR 182 Health Physics Manager Qualification 7.
Please provide sufficient information to describe the Health Physicist position description.
The desenption should document that the position is in a professional, supervisor position 1
that affords adequate authonty and opportunity to represent program interests on a plant.
wide basis. Additionally, describe the involvement of the designated Health Physicist in the day to4ay operation and ovttsight of the plant radiation protection program, TSCR 195 Radiation Protection Program 8.
New guida' ice (Attachment D) was provided to NEl on April 9,1997, on TS administrative controls for a high radiation area. This new guidance includes 10 CFR Part 20 changes.
Please review the new guidance and revise your submittal as appropriate.
9.
If you choose not to revise your submittal per the new guidance, please describe how your program complies with the new Part 20 requirements for high radiation areas with dose rates greater than 1.0 rem / hour at 30 centimeters from the radiation source or from any surface penetrated by the radiation, but less than 500 rads / hour at i meter from the
+
radiation source or from any surface penetrated by the radiation.
Attachments: A through D 2
STANDARD TECHNICAL SPECIFICATION RADIATION MONITORS The following Technical Specifications (TS) provide limiting condrtions for operation and applicability statements, action statements, surveillance requirements, and a bases section which discusses the background and applicable safety analyses. The need to include radiation monitors in the TS is established by the consequences of the limiting Design Basis Accident analysis and whether the control functions performed by the radiation monitor are credited in the accident analysis, if the radiation monitor is not relied upon in the analysis, the consequences must not exceed the consequences of a DBA.
TS 3.3.3 Post Accident Monitoring (PAM) Instrumentation includes containment area radiation monitors (High Range)
TS 3.3.5 Containment Ventilation isolation Instrumentation includes containment radiation gaseous and particulate monitors TS 3.3.6 Control Room Emergency Air Treatment System Actuation Instrumentation includes control room intake iodine, noble gas, and particulate radiation monitors TS 3.4.15 RCS Leakage Detection Instrumentation includes containment atmosphere radioactivity monitors relied upon to detect leakage of reactor coolant into the containment. Plant vent gaseous or particulate radiation monitors need to be addressed if they perform a leakage detection function.
TS 3.7.7 Component Cooling Water System Radioactivity monitor may need to be included if the system is not a normally closed system outside of containment and the radiation monitor provides a signal to ensure system closure.
TS 3.7.8 Service Water System Radioactivity monitors may need to be included in TS if the radiation monitors provide controlinput to isolate valver that prevent discharges.
TS 3.7.9 Control Room Emergency Air Treatment System includes gaseous, particulate, and iodine radiation monitors which result in actuation.
TS 3.7.10 Auxiliary Building Ventilation System includes noble gas, particulate, and iodine monitors for the plant vent stack which result in actuation of equipment.
A1 ATTACHMENT A
TABLE 1 RADIATION MONITORING SYSTEM AREA MONITORS DETECTOR NO.
NAME INDICATION RE 101m control room monitor indicates dose rates in control room 1(2)RE 102 containment low range monitor provides dose rates within containment 4
around access hatch RE 103 chemistry lab area monitor provides indication of dose rates in chemistry lab and associated halfways 1(2)RE 104 charging pumps low-range area indicates dose rates in hallway;, east of monitor charging pump cubicles RE 105 spent fuel pit low range area provides indication of doso rates in the monitor vicinity of spent fuel pit (affected by high radiation levels in containment) 1(2)RE 106 primary side sample room low indicates dose rate inside sample room range area monitor when sampling system is in operation 1(2)RE 107 seal table area monitor provides an indication of general dose rate near seal table RE 108 drumming station area monitor provides dose rate indication within the drumming station 1(2)RE 109 post accident sample line monitor provides an indication of failed fuel by monitoring the primary coolant sample activity RE 110 Safety injection (SI) pump room provides an indication of the dose rate low range monitor in general area of Si pumps RE 111 C59 panel area monitor provides general area dose rate near C59 panel RE 112 central PAB indicates general area dose rate on PA8 El. 8' i
RE 113 PAB Elevation (El.) -19' area provides an indication of the dose rate monitor in PAB El.19' sump and general area RE-114 CVCS holdup tank area monitor indicates general area dose rate in cubicle RE-116 letdown system valve gallery area indicates general area dose rate in monitor letdown valve gallery 1(2)RM 126 unit 1(2) containment high range indication is via readout module in the 1(2)RM 127 radiation monitors computer room and on the auxiliary 1(2)RM-128 safety instrumentation panels B-1 ATTACHMENT B
DETECTOR NO.
NAME INDICATION
)
1(2)RE 134 charging pump room high range -
provides an indication of general area area monitor dose rates in the event low range i
monitor saturates RE 135 spent fuel pit high range area provides an indication of general area i
monitor dose rates in the event low range i
f monitor saturates i
1(2)RE 136 primary side sample room high provides an indication of general area range area monitor dose rates in the event low range 4
monitor saturates RE 140 SI pump room high range are -
provides an indication of general area 4
monitor dose rates in the event low range mi
.,aturates RE 23g
technical support center (TSC)
- cilcates general area TSC dose rates area monitor RE 240cr' TSC El.18.5' assembly area indicates general ares El.18.5' dess munitor rates RE 243
emergency operations facility indicates general ares EOF dose rates (EOF) area monitor "8 Refer to Table 4 for control function
'2' Monitors not part of main RMS I
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B-2<
TABLE 2 RADIATION MONITORING SYSTEM - PROCESS MONITORS i
DETECTOR NO.
NAME INDICATION 1(2)RE 211 containment air particulate monitor indicates particulate activity inside containment or purge exhaust stack j
1(2)RE 2118 background monitor for RE 211 background data for both RE 211 and RE-212 1(2)RE 212"8 containment noble gas monitor provides indication of containment, or purge exhaust stack noble gas activity RE 214"'
PAB indicates high gaseous activity release from gas decay tanks or potential PAB airbome activity 1(2)RE 215 condenser air ejector noble gas indicative of steam generator pnmary-monitor to secondary leak. May be indicative of potential airbome radiation exposure in turbine hall.
1(2)RE 216 containment fan coolers liquid provides indication of potential process monitor contamination of cooling water (service water retum) 1(2)RE 2168 background monitor for 1RE 216 provides background data for RE 216 1(2)RE 217"'
component cooling water liquid provides indication of component process monitor cooling water contemination 0
RE 218 3 waste disposal system discharge monitors waste condensate activity liqud process monitor being discharged RE 2188 background monitor for RE 220 provides background data for RE 218 1(2)RE-219"'
steam generator blowdown liquid provides indication of steam generator process monitor blowdown activity and steam generator tube leak rates 1(2)RE 2198 background monitor for RE 219 provides background data for RE 219 RE 220 spent fuel pit (SFP) heat provides indication of service water exchanger service water liquid contamination from a spent fuel pool process monitor heat exchanger tube leak RE-220B background monitor for RE 220 provides backgrouri data for RE 220 RE 221 drumming area vent stack noble
, indicates noble gas activity released gas monitor from spent fuel pit and drumming area, which may be indicative of a potential PAB airbome release 1(2)RE-T.22"8 steam generator blowdown tank indicates activity level in blNidam..mx outlet liquid process monitor B-3
DETECTOR NO.
NAME INDICATION RE 223"'
waste distillate discharge liquid monitors activity of waste distillate process monitor being discharged RE 223B background monitor for RE 223 provides background for RE 223 RE-224 gas stripper building exhaust indicates activity of gaseous release noble gas monitor from letdown gas stripper building RE-225 combined air ejector low range indicative of primary to secondary leak noble gas monitor in steam generators. may also indicate potential radiation exposure sources within turbine building i
RE 226 combined air ejector high range indicative of primary to-secondary leak noble gas monitor in steam generators, may also indicate potentiai radiation exposure sources within turbine building 1(2)RE 229 service water discharge liquid monitors activity of service water process monitor discharge 1(2)RE 2298 background monitor for Re 229 provides backgromd data for RE 229 RE 230 retention pond discharge liquid monitors activity levelin retention pond process monitor effluent RE 2308 background monitor for RE 230 provides background data for Re 230 1(2)RE-231 steam line "A" atmospheric monitors activity of steam released -
release monitor steam line "A" 1(2)RE 232 steam line "B" atmosphenc monitors activity of steam released -
release monitor steam line "B:
RE 234 control room iodine monitor monitors iodine activity in control room RE 2348 control room iodine and noble gas provides background data for RE 234 sample system background monitor RE 2350) control room noble gas monitor monitors noble gas activity in control foC *n RE 237*
TSC iodine monitor monitors noble gas activity in control room RE 238*
site boundary control center monitors iodine activity of air supply to (SBCC) iodine monitor SBCC RE 242*
SBCC noble gas monitor monitors noble gas activity of supply air to SBCC
" Refer to Table 41or control function
- Monitors not part of main RMS B-4
TABLE 3 SPECIAL PARTICULATE, IODINE, AND NOBLE GAS MONITORS DETECTOR NO.
NAME INDICATION it2)RE 301 containment purge exhaust indicates activity in containment purge monitor (beta particulta) exhaust 1(2)RE 302 containment purge exhaust indicates activity in containment purge monitor (alpha particu' ate) exhaust 1(2)RE 303 containment purge exhaust indicates activity in containment purge monitor (iodine) exhaust 1(2)RE 305"8 containment purge exhaust indicates activity in containment purge monitor (low range gas) exhaust 1(1:RE 306 containment purge exhaust indicates activity in containment purge munitor (area monitor) exhaust 1(2)RE 307 coistainment purge exhaust indicates activity in containment purge monitor (mid range gas) exhaust 1(2)RE 308 containment purge exhaust indicates activity in containment purge monitor (Iow range gas exhaust background) 1(2)RE 309 containment purge exhaust indicates activity in containment purge monitor (high range gas) exhaust RE 311 auxiliary building exhaust monitor indicates activity in auxiliary building (bete particulate) exhaust RE 312 auxiliary building exhaust monitor indicates activity in auxiliary (alpha particulate) building exhaust RE-313 auxibary building exhaust monitor indicates activity in auxiliary (iodine) building exhaust RE 315 auxiliary building exhaust monitor indicates activity in auxiliary (low range gas) building exhaust RE-316 auxiliary building exhaust monitor indicates activity in auxiliary (area monitor) building exhaust RE-317 auxiliary building exhaust monitor indicates activity in auxiliary (mid range gas) building exhaust RE-318 auxiliary building exhaust monitor indicates activity in auxiliary building (Iow range gas background) exhaust RE-319 auxiliary building exhaust monitor indicates activity in auxiliary building (high range gas) exhaust RE 321 drumming area exhaust monitor indicates activity in drumming area (beta particulate) exhaust B-5
. _ _ _ _ [
A.
DETECTOR NO.
NAME IND' CATION RE 322 drumming area exhaust monitor indicates activity in drumming area (alpha particulate) exhaust RE.323 drumming area exhaust monitor indicates activity in drumming area (iodine) exhaust RE 325 drumming area exhaust monitor indicates activity in drumming area (Iow range gas) exhaust RE 326 drumming area exhaust monitor indicates activity in drumming area (area monitor) exhaust RE 327 drumming area exhaust monitor indicates activity in drumming area (mid range gas) exhaust RE 328 drumming area exhaust monitor indicates activity in drumming area (Iow range gas background) exhaust
"' Refer to Table 4 for control function B-6
TABLE 4 RADIATION MONITOR CHANNELS WITH CONTROL FUNCTIONS DETECTOR NO.
NAME INDICATION RE 101 control room area shifts control room ventilation to l
Mode 3 (100 percent recirculatic,n) 1(2)RE 212 containment noble gas containment ventilation isolation closes purge valves, secures forced vent and puts monitor in recirculation RE 214 PAB vent closes vent gas release valve and t
switches PAB vent discharge to charcoal filters i
RE 217 component cooling water closes CCW surge tank vent RE 218 waste condensate overboard closes waste condensate pump valve 1(2)RE 219 steam generator blowdown shuts blowdown valves, blowdown tank outlet valve, and steam generator sample valves 1(2)RE 222 blowdown tank area shuts blowdown valves and blowdown l
tank outlet valve RE 223 waste distillate overboard closes discharge valve RE 235 control room noble gas shifts control room ventilation to Mode 3 (100 percent recirculation) j 1(2)RE 305 containment nobli. ' gas containment ventilation isolation e
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-- B 7
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Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shallinclude remedial actions to be taken whenever the program limits are exceeded. The program shallinclude the following elements:
a.
Limrtations on the functional capability of radioactive liquid and gaseous monitoring instnJmentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; b.
Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted area, conforming to 10 times the concentration value in Appendix B.
Table, 2, Column 2 to 10 CFR 20.1001 - 20.2402; Monitoring, sampling, s,nd analysis of radioactive liquid and gaseous effluents in c.
accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM; d.
Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive matenals in liquid effluents released from each unit to unrestricted areas, conforming to 10 CFR 50 Appendix 1; e.
Determination of cumulative and projected dose contribution' ' rom radioactive effluents for the current calendar quarter and current calend year in accordance with the methodology and parameters in the ODCM at least every 31 days; L mitations on the functional capability and use of the liquid and gaseous effluent f.
i tre.4tment systems to ensure that appropriate portions of these systems are used to redece releases of radioactivity when the projected doses in a period of 31 days would exceed 2 percent of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50, Appendix I; g.
Limitations on the dose rate tcsulting from radioactive material released in gaseous effluents from the site to areas at or beyond the site boundary shall be limited to the following:
1.
For noble gases: less than or equal to a dose rate of 500 mrem per year to the total body and less than or equal to a dose of 3000 mrems per year to the skin, and 2.
For iodine 131, iodine 133, tntium, and for all radionuclides in particulate form with hatf trves greater than 8 days: less than or equal to a dose rate of 1500 mrenVyear to any organ.
h.
Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the site boundary, conforming to 10 CFR 50 Appendix I; ATTACHMENT C C-1
t l.
- Limitations on the annual and quarterly doses to a member of the public from
)
iodine-131, iodine 133, tritium, and all raolonuclides in particulate form with half lives
> 8 days in gaseous effluents released from each unit to areas beyond the site l
boundary, conforming to 10 CFR 50, Appendix I; and i
t J.
Limitations on the annual dose or dose commitment to any member of the public, l
beyond the_ site boundary, due to releases of radioactivity and to radiation from l
uranium fuel cycle sources, conforming to 40 CFR 190.
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High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls reqGred by paragraph 20.1601(a) and (b) of 10 CFR Part 20:
{
High Radiation Areas with Dose Rates Not Exceeding 1.0 rem / hour at 30 Centimeters from the Radiation Source or from Any Surface Penetrated by the Radiation; Each entryway to such an area shall be barricaded and conspicuously posted a.
as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.
b.
Access to, anc.setivities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area (s) and other appropriate radiation protection equipment and measures.
j c.
Individuals qualified in radiation p.*otection procedures (e.g., health physics i
technicians) and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigneJ duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such area.
d.
Each Individual or group entering such an area shall possess:
1.
A radiaticn monitoring device that con'inuously displays radiation dose rates in the area; or 4
2.
A radiation monit0 ring device that continuously integrates the radiation dose rules in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or 3.
A radiation raonitoring device that continuously transmits dose rate and cumulative dose to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or
.4.
A self reading dosimeter (e.g., pocket iont:ation chamber or electronic dosimeter) and,
' (i)
Be under the surveillance, as specified in the RWP or 6quivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiatiori monitoring device that continuously displays radiation dose rates in the are; who is responsible for controlling personnel exposure within the area, or ATTACHMENT D D1
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v (in Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individualin the area.
Except for individuals qualified in radiation protection procedures, entry into e.
such areas shat! be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.
High Radiation Areas with Dose Rates Greater than 1.0 re' / hour cl. 30 Centimeters from the Radiation Source or from Any Surface Penetrated by the sadiation, but Less than 500 nenetrated by the rads / hour at 1 Meter from the Radiation Source or frm ny Surface Radiation:
Each entryway to such an area shall be 7nspicuously posted as a high a.
radiation area and shall be provided with s locked door or gate that prevents unauthorized entry, and, in addition:
1.
All such door and gate keys shall be maintained under the administrative control of the shift supervisor, radiation protection manager, or his or her designee.
2.
Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.
b.
Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area (s) and other appropriate radiation protection equipment and measures.
c.
Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
d.
Each individual or group entenng such an area shall possess:
1.
A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or 2.
A radiation monitchng device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible 1.
controlling personnel radiation exposure within the area with the means to communicate with and control every individual in the area, or 3.
A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, D-2 l
l
(i)
Be under the surveillance, as specified in the RWP or e
equivalent, whlkt in the area, of an individual qualified in i
radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii)
Be under the surveillance as specified in the RWP or equivalent,
- T while in the area, by means of closed circuit television, of '
personnel qualified in radiatien protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to consmunicate with and control every individualin the area, or 4,
in those cases where options (2) an (3), above, are impractical or.
determined to be inconsistent with the "As Low As is Reasonably Acti;0vable" principle, a radiation monitoring device that continuously displayt radiation dose rates in the area.
Except for ndividu, I qualified in radiation protection procedures, entry into e.
such area thall be made only after dose rates in the area hove been l
i determined ai i e ary personnel are knowledgeable of them.
f.
Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for the purpose of locking and where no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate, but shall be barricaded and conspicuous, clearly visible flashing light shall be activated at the area as a t
waming device.
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NRC-87-104 October 8, 1987 U.S. NUCLEAR REGULATORY COMMISSION Document control Desk Washington, D.C. 20555 Gentlemen:
DOCKET NOS. 50-266 AND 50-301 RESPONSE TO REQlIEST FOR ADDITIONAL INFORMATION FOR 10 CFR 20.302 APPLICATION POINT BEACH NUCLEAR PLA!C On July 14, 1987, Wisconsin Electric Power Company submitted an application, under the provisions of 10 CFR 20.302, for approval of a proposed procedure to dispose of sewage treatment sludge containing minute quantities of radioactive materials.
Sub-sequent to the application, Mr. Ted Quay of the NRC staff requested additional information regarding the environmental characteristics of the area surrounding the Point Beach Nuclear Plant.
The responses to this request were furnished in our submittal dated August 6, 1987.
By letter dated September 9, 1987, the NRC has requested Wisconsin Electric supply additional information in order to complete the review of our application.
This Repest for Additional Information (RAI) contains ten specific items which require responses or commitments from Wisconsin Electric.
In addition, the NRC requests the previously submitted information and the information-supplied in response to the RAI be compiled into "one complete, extensive, and self-contained package".
To facilitate your review, Attachment I is included to provide direct responses to the ten items contained in the RAI.
Attachment II is provided as the complete application, including the information from our letters dated July 14, 1987, and August 6, 1987, and information supplied in response to the NRC RAI.
We request that you complete your review of this complete, self-contained package and issue an approval of our application O
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.-___..._.___.___..._._________m._..___
NRC DocumpAt Control Desk-October.8, 1987 Page 2 as soon as possible.
In arder to facilitate your reviev and-l to expedite processing,_we would be pluased to discuss-these j
Please i
inatters or provide additional information by telephone.
i feel free to contact us.
Very truly yours, I
d' U.-fJ\\
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C. W. Fay Vice President
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Nuclear Power i
Lbjm Attachmer^1 Copies to NRC Resident Inspector NRC Regient.1 Administrator, Region III Blind copies to Britt/Gorske/Finke urstein, Charnoff, Fay, Krieser, e, Newton, Zach I
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ATTACHMENT I RESPONSES 70 (CEST!0NS C0dTAINED IN THE REQUEST FOR AOC TIONAL INFORMATION (RAI)
ON POINT pkACH I AND 2 R :0 VEST.
FOR DISP 05A6 0F LOW LEVEL RA,); 0 ACTIVITY CONTAMINATED SEWIUI SLUDGE BY LAld) APPLICATION.
WISCON5IN ELECTR C POWER C W PANY UNDER 10 CFl! 20.302(a)
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The numbering system used in these responses corresponds directly to numbering used in the NRC RAI, dated September 9,1987.
This request is for multiple applications, approximately 2 to 4 1.
a.
per year, b.
This request is for multiple years, expiration to coincide with conclusion of decomissioning activities associated with retirement of P8NP Units 1 & 2.
Please refer to the response to question number 10.
c.
2.
The pathways used to determine doses to both the maximally exposed individual and the inadvertent intruder are documented in Attachment II, Appendices D and E.
Due to tne extremely low concentrations of radionuclides in the sewage sludge and the associate low dores, Wisconsin Electric will control access to the disposal sites by conditions of use defined in lease agreements with the lease. Use of the land is not controlled beyond the conditions of the lease, thereby not restraining a casual visitor from the disposal site.
However continuous occupancy would be readfly observed, and remedial action would be taken.
3.
Information contained in previous submittals has been included in Attachment II with modifications to provide specific comitments to the NRC.
4.
Please refer to the responso to question number 10.
5.
Site maps have been updated and are included in Attachment II, Appendix C.
6.
The direct grazing of cattle on the proposed disposal sites is controlled by restrictions contained in the lease agreement.
There vill be no restrictions placed on fishermen on Lake Michigan.
Calculations of doses due to all pathways associated with a release to Lake Michigan (Attachment !!, Appendix E) do not indicate a need to apply restrictions to fishermen, 7.
Please refer to revised site saps included in Attachment II, Appendix C.
Site number 5 is located on company owned land beyond the PBNP site boundary.
All other sites are within the PBNP site boundary area.
8.
a.
Please refer to Attachment II, Section 3.2, Disposal Procedure.
b.
Please refer to Attachment II, Section 3.2, Disposal ProceduM.
c.
Please refer to Attachment II, Section 3.2. Disposal Procedure.
d.
Please refer to Attachment II, Appendix A.
9.
Please refer to Attachment 11, including Appendix 0 and Appendix E for additional pathways analyzed for this submittal.
These identified pathways will be analyzed prior to r.11 subsequent disposals to insure doses are maintained within prescribed limits, i.e.,1 arem/ year to the maximally exposed individual and 5 arem/ year to the inadvertent intruder.
10.
A limiting concentration level for the sludge contained in the storage tank is discussed, in Attachment II, Appendix F.
Since this application is for multiple applications over multiple years, Attachment II, Appendix F also addresses an activity limit.
E-5 1
e ATTACHMENT ]!
COMPLETE ANALYSIS AND EVALUATION POINT BEACH NUCLEAR PLANT 10 CFR 20.302(a) APPLICATION O
O i
E-6
i 1.0 Purpose By this submittal Wisconsin Electric Power Company requests approval of the U.S. Nuclear Regulatory Comission for a proposd procedure to dispose of sewage treatment sludge containing trace quantities of radionuclides generated at the Point Beach Nuclear Plant.
This request is submitted in accordance with the provisions of 10 CFA 20.302(a).
2.0 Waste Description 4
The waste involved in this disposal process consists of the residual solids i
remaining in solution upon completion of the aerobic digestion sewage treat-1 ment process utilized at PBNP.
The PBNP sewage treatment plant is used to process waste water from the plant sanitary and potable water systems.
These systems produce non-radioactive waste streams with the possible exception of wash basins located in the radiologically controlled area of the plant.
These wash basins are believed to be the primary source of the extremely small quantities of radionuclides in the sludge.
The sewage sludge generated at P8NP is allowed to accumulate in the sewage plant digestor and aeration basin.
Two to four times annually, depanding on work activities and corresponding work force at P8NP, the volume af the sludge in the digestor and aeration basin needs to be reduced to allow continued efficient operation of the treatment facility.
The total volume of sludge removed during each disposal operation is typically on the order of 15,000 gallons.
The maximum capacity for the entire P8NP treatment facility and hence the maximum disposal volume is about 30,000 gallons.
In the case of a maximum capacity disposal, doses would not necessarily increase in propertion to the volume, since more than one disposal site may be used.
Trace amounts of radionuclides have been identifi'.4 in PSNP sludge currently being stored awaiting disposal.
The radionuclides identified and their concentrations in the sludge are sumarized below:
huclide Concentration (uCi/ce)
L Co-60 2.33E-07 Cs-137 1.50E 07 The total activity of the radionuclides in the stored sludge, based on the identified concentrations and a total volume of 15,000 gallons of sewage sludge, are as follows:
Nuclide Activity (uci)
Co 60 13.2 Cs-137 8.5 These concentrations and activities-are consistent with expected values based on prior analyses of sewage sludge.
The radionuclide concentration in the sewage sludge has remained relatively constant during sampling conducted since December 30, 1983 A detailed sumary of the results of this sampling program are contained.in Appendix A for your review.
E-7
9 In addition to monitoring for the radionuclide content of the sludge, the WDNR requires several other physical and chemical properties of the sludge to be determir cd.
These properties are the percent total solids, percent to'al nitrogen, percent ammonium nitrogen, pH, percent tAtal phosphorus, percent total potassium, cadmium, copper, lead, nickel, mercury, cine, and boron. An example of a typical sludge sample analysis is included in Appendix 8.
3.0 Disposal Method In the context of-this application, Wisconsin Electric commits to the
-following methodology.
No distinction is made or intended between "shall" or "will", as used in the descriptions contained in this section.
3.1 Transport of Sludge The method used to dispose of the sludge shall utilize a technique approved by the WDNR.
The process of transporting the sewage sludge for disposal involves pumping the sludge from the FBNP sewage treatment plant storage tanks into a t'uck mounted tank. The truck mounted tank shall be required to be maintained tightly closed to prevent spillage while in transit to the disposal site.
The sludge shall be transported to one or more of the six sites approved by the WDNR for lend application of the sewage sludge from PBNP.
3.2 Dispcsai Procedure The radionuclide concentrations in the sludge shall be determined prior to each disposal by obtaining three representative samples from ea:h of,the sludge storage tanks. The sludge contained in the sludge tanks is prevented from going septic by a process known as complete mix and continuous aeration. This process completely mixes the slodge allowing for representative samples to be obtained.
The samples shall be counted utilizing a GeLi detector and multi-channel analyzer with appropriate geometry. The detection system is routinely calibrated and checked to ensure the lower limits of detection are within values specified in the Radiological Effluent Technical Specifications (RETS).
To insure t'he samples are tcpresentative of the overall concentration in the storage tanks, the radionuclide concentration determination for
- h of the thren samples shall be analyzed to insure each sample is
=sthin two standard deviations of the average value of the three
~
s ampl e s..
If this criteria is not met, additional samples will be obtained and analyzed to insure a truly representative radionuclide concentration is utilized for dose calculations and concentration limit determina' ions. The average of all statistically valid concentration determinations will be utilized in determining the storage tank concentration values.
4 4
E-8
Prior to disposal the waste stream will be monitored to determine the physical and chemical properties of the sludge, as discussed in the last The resuits will oe compared paragraph of Section 2.0, Waste Description.to State of Wisconsin l hazard to people or to the environment, The radionuclities identified in the sludge, along with their respective concentrations, will be compared to concentration limits prior to The methodology discussed in Appendix F will be used in disposal.
Th3 determining compliance with the proposed concentration limit.
total activity of the proposed disposal will be compared to the proposed activity limit as described in Appendix F.
If the concentration and activity limit criteria are met,.the appropriate exposure pathways (as described in Appendix 0) will be evaluated prior to These exposures will be evaluated to insure each application of sludge.
the dose to the maximally exposed individual will be maintained less than 1 mrem / year and the dose to the inadvertent intruder is maintained less than 5 arem/ year.
The exposures will be calculated utilizing the meth-odology used in Appendix E, including the current activity to be landspread The remaining radio-along with the activity from all prior disposal.
activity from prior disposals will be corrected for radiological decay prior to performing dose calculations for the seat, silk, and vegetable ingestion pathways, the inhalation of resuspended radionuclides, and all The residual radio-pathways associated with a release to Lake Michigan.
activity will be correcNd for radiological decay and, if appropriate, the mixing of the radionuclides in the soil by plowing prior to performing external exposure calculations.
The sewage sludge is applied on the designated area of land utilizing the WDNR approved technique and adhering to the following requirements of WPDES Permit Number WI-0000957-3.
Discharge to the land disposal system shall be limited so that during surface spreading all of the sludge and any precipitation falling onto or flowing onto the disposal field shall not overflow the peri-meter of the system.
Sludge shall not be land spread on land with a slope greater than 12%.
During the period from December 15 through March 31 sludge shall not be land spread on land with a slope greater than 5% unless the wastes are injected ismiediately into the soil.
Sludge shall not be surface spread closer than 500 feet from the nearest inhabited dwelling except that this distance say be reduced with the dwelling owner's written consent.
Sludge shall not be spread closer than 1,000 feet from a public water supply well or 250 feet from a private water supply well.
Sludge shall not be land spread within 200 feet of any surface water unless a vegetative buffer strip is maintained between the surface watercourse and the land spreading system, in which case a minimum separation distance of at least 100 feet is required between the system and the surface watercourse.
E-9
Depth to groundwater and bedrock shall be greater than 3 feet frem the land surface elevation during use of any site.
l Sludge shall not be land spread in a floodway.
Sludge shall not be land spread within 50 feet of a property line road or ditch unless the slufge is incorporated with the soil, in which I
case a minimum separation distance of at least 25 feet is required.
The pH of the sludge-soil mixture shall be maintained at 6.5 or higher.
Low areas of the approved fields, subject to seasonally high ground-water levels, are excluded from the sludge application.
Crops for human consumption shall not be grown on the land for up to one year following the application of the sludge.
The sludge shall be plowed, disked, injected or otherwise incorporated into the surface soil layer at appropriate intervals.
The flexibility implied in the latter provision for soil incorporation is intended to allow for crops which require more than a one year cycle.
For the Point Beach disposal sites, alfalfa is a common crop which is harvested for several years after a single planting.
Sludge disposal on an alfalfa plot constitutes good fertilization, but the plot cannot be plowed without destroying the crop.
The alfalfa in this case aids in binding the layer of sludge on the surface of the plot.
At a minimum, however, plowing (or disking or other method of injection and mixing to a nominal depth of 6 inches) shall be done prior to planting any new crop, regardless of the crop.
3.3 Administrative procedures Complete records of each disposal will be maintained.
These records will include the concentration of radionuclides in the sludge, the total volume of sludge disposed, the total activi'ty, the plot on which the sludge was applied, the results of the chemical composition determinations, and all dose calculations.
The annual disposal rate for each of the approved land spread sites will be limited to 4,000 gallons / acre, provided WDNR chemical composi-tion NRC dose guidelines, and concentration and activity limits are saintained within the appropriate values.
The farmer leasing the site used for the disposal will be notified of the applicable restrictions placed on the site due to the land spreading of sewage sludge.
4.0 Evaluation of Environmental'Imoact 4.1 Site Characteristics 4.1.1 Site Topography The disposal sites are located in the Town of Two Creeks in the northeast corner of Manitowoc County,. Wisconsin, on the E-10
west shore ef Lake Michigan about 30 miles southeast of the center of the city of Green Bay, and 90 miles NNE of Milwaukee.
This site is located at longitude 87* 32,5'W and'1atitude 44' The six sites are on property owned ana controlled by Wisconsin Electr c and are within or directly adjacent to theThe sites 17.0'N.
F Point Beach site boundary.
are outlined on the map contained in Appendix C as figure 3.
Site No. PB The approximately 15 acres located in the NE 1/4 of the NE 1/4 of Section 23. T. 21N - R. 24E.
Site No. PB The approximately 20 acres located in the SE 1/4 of the SE 1/4 of Section 14. T. 21N - R. 24E.
Site No. PB The approximately 5 acres located in the hv 1/4 cf Section 24, T. 21N - R. 24E.
Site No. PB The approximately 5 acres ic:ated in the hV 1/4 of the SW 1/4 of Section 24, T. 21N - R. 24E.
Site No. PB The approximately 5 acres located in the NE 1/4 of the NW 1/4 of Section 25 T. 21N - R. 24E.
Site No. PB The approximately 5 acres located in the NE 1/4 of the SW 1/4 of Section 14, T. 21H - R. 24E.
The overall ground surf ace at the site of the Point Beach Nuclear Plant is gently rolling to flat with elevations varying from Subdued knob 5 to 60 feet above the level of Lake Michigan.
The and kettle topography is visible from aerial photographs.
land surface slopes gradually toward the lake from the higher Higher grount adjacent glacial moraine areas west of the site.to the lake however, diverts
~
south.
The major surface drainage features are two small creeks which One creek discharges into the drain to the north and south.
lake about 1500 feet above the northern corner of the site and the other near the center of the site. During the spring, ponds As mentioned in of water may occupy the shallow depressions.
Section 3.2, Disposal Procedure, these low areas are excluded from the sludge application.
A site topographic map covering details out to a 5 mile radius may be found in the FSAR at Figure 2.2-3 and is included in Appendix C as Figure 2.
The disposal of sewage sludge at these six sites will have no impact on the topography of this area.
4.1.2 Site Geoloqy Prior to construction of the Point Beach Nuclear Plant, an evaluation of the geological characteristics of the area in and The geologic structure of tha-surrounding the site was made. Gently dipping sedimentary rock region is essentially simple.
E-11
strata of Paleozoic age outcrop in a horseshoe pattern a shield of Precambrian crystalline rock which occupies the h
estern western part of the region. 'The site is locat The by discontinuous outcrops of more resista d
The rocks form a sandstones with subordinate shale layers.
in succession of extensive layers that are relative Mfchigan at rates from 15 to 35 feet per mile.
thickness.
The uppermost bedrock under the site is Niagara Dolomite.
Bedrock does not outcrop on the site but is covered by The soils contain expansive clay i
till and lake deposits.
minerals and have moderately high base exchange capac ty.
In the area of the site, the overburden soils are approx Although the character of the 70 to 100 feet in thickness.
glacial deposits may vary greatly within rel llowing adjacent to Lake Michigan at the site consists of the fo sequence:
- 1. An upper layer of brown clay silt topsoil d
- 2. A layer of 20 feet of reddish-brown silty clay with some sand and gravel and occasional lenses of silt;
- 3. A layer of 25 feet of reddish-brown silty clay with layers of silty sand and lenses of silt;
- 4. A layer of 50 feet of reddish-brown silty clay with some sand and gravel, the lower portion of which contains gravels, cobbles, and boulders resting on a glacial e surface of Niagara dolomite bedrock.
Site drainage is poor due to the high clay content of the combined with the pock-marked surface.on rite geo The use of these sites for disposal of sewage sludge will n impact the geology of the area.
4.2 Area Characteristics Meteorology 4.2.1 _
The climate of the site region is influenced by the gener d
storms which move eastward along the northern tier o States and by those which move northeastward from the s This co.iti-western part of the country to the Great Lakes.
During nental type of climate is modified by Lake M markedly from the air temperature.to easterly directions E-12
i temperatures in spring and summer.
In autumn the relatively warm water to the lake prevents night-time temperatures from falling as low as they do s few miles inland from the shoreline.
Sunener time temperaturcs exceid 90'F for six days on the average.
Freezing temperaturu occur 147 days and below zero on 14 days of the winter on the average.
Rainfall averages about 28 inches per year with 55 percent falling in the months of May through September.
Snowfall averages about 45 inches per year.
Sludge spreading shall be managed such that the surface spreading together with any precipitation falling on the field shall not overflow the perimeter of the field.
Additional information on site meteorology may be found in Section 2.6 of the FSAR.
There will be no impact on the meteorology of the area due to the disposal of the sewage sludge.
4.2.2 Hydrology The dominant hydrological featura of t51s site is Lake Michigan, one of the largest of the Great Lakes.
The normal water level in Lake Michigan is approximately 580 feet above mean sea level.
In the gencral vicinity of the site, the 30 foot depth contour is between 1 and 1-1/2 miles offshore and the 60 foot contour is 3 to 3-1/2 miles off shore. The disposal sites are twenty cr more feet above the normal lake level.
There is no record that the sites have been flooded by the lake during modern times.
There are no rivers or large streams which could create a flood hazard at or near the sites.
The subsurface water table at the Point Beach site has a definite slope eastward toward the lake.
The gradient indi-cated by test drilling on the site is approximately 30 feet per mile.
It is therefore extremely unlikely that any release of radioactivity on the site could spread inland.
Furthermore, l
the rate of subsurface flow is small due to the relative impervious nature of the scil and will not promote the spread of releases.
Further information on site hydrology is detailed in the PBNP FSAR Section 2.5.
There will be no adverse impact on hydrology of the area due to disposal of sewage sludge by land spreading.
4.3 Water Usage 4.3.1 Surface Water Lake Pichigan is used as the source of pott.ble water supplies in the vicinity of the site for the cities of Two Rivers (12 miles south), Manitowoc (16 miles sourth), Sheboygan (40 miles
-south), and Green Bay (intake at Rostok 1 mile north of Kewaunee, 13 miles north).
No other potable water uses are recorded within 50 miles of the site along the lake shore.
All public water supplies drawn from Lake Michigan art treated in puri-fication plants.
The nearest surface water used for Jrinking other than Lake Michigan are the Fox River 30 miles NW and E-13
Lake
.ineb go 40 miles W of the site.
Lake Michigan is also utilized by various recreational activities, including fishing, swimming and boating.
There will be no impact on surface water usage due to the disposal of sewage sludge.
4.3.2 Ground Water Ground water provides the remaining population with potable supplies.
Public ground water supplies within a 20 mile radius of the site are listed in Table 2.5-3 of the FSAR.
Additional wells for private use-are in existence throughout 'the region.
The location of private wells within a two mile radius of PBNP are indicated on Figure 3,.'Spendix C.
The potable water for use at the Point Beach Nuclear Plant is drawn from a 257 feet deep well 1cated at the southwest corner of the plant yard. Water from this well is routinely sampled as part of the environmental monitoring program.
There will be no adverse impact on ground water usace due to the disposal of sewage sludge.
4.4 Land Usage Manitowoc County, in which the site is located, and the adjacent counties of Kewaunee, Brown, Calumet, and Sheboygan are predominantly rural.
Agricultural pursuits account for approximately 90% of the total county acreage. With the exception of the Kewaunee Nuclear Plant located 4.5 miles north, the region within a radius of five miles of the site is presently devoted exclusively to agriculture.
Dairy products and livestock account for 85% of the counties' farm production, with field crops and vegetables accounting for most of the remainder. The principal crops. are grain corn, silage corn',
oats, barley, hay, potatoes, green peas, lima beans, snap beans, beets, cabbage, sweet corn, cucumbers, and cranberries.
Within the township of Two Creeks surrounding the site (15 sq. miles), thert are about 800 producing cows on about 40 dairy farms.
Some beef cattle are raised 2.5 miles north of the site.
Cows are on pasture
-from the first of June to late September or early October.
During the winter, cows are fed on locally produced hay and silage.
Of the milk produced in this area, about 25 percent is consmed as fluid milk and 50 percent is coaverted to cheese, with the remainder being used in butter. making and other by? products.
It has been the policy of Wisconsin Electric to permit the controlled use of crop land and pasture land on company owned property.
No direct grazing of.iairy or beef cattle or other animals is permitted on these company owned properties.
Crops intended for htman consump-tion shall not be grown on the disposal sites for at least one year following the application of the sludge.
'The proposed land application of sewage sludge will not have any direct effect en the adjacent facilities. Additional land use E-14
information may be found in Section 7.4 of the FSAR.
4.5 Radiological Impact The rate of sewage sludge application on each of the six proposed sites will be monitored to insure doses are maintained within applic-able limits.
These limits are based on NRC Nuclear Reactor Regulation (NRR) staff proposed guidance (described in AIF/NESP-037, August, 1986).
These limits require doses to the maximally exposed member of the general public to be maintained less than 1 mrem / year due to the disposal material.
In addition, NRR guidance requires doses of less than 5 arem/ year to an inadvertent intruder.
To assess the doses received by the maximally exposed individual anc the inadvertent intruder, six credible pathways have been identified for the maximally exposed individual and four credible pathways for the inadvertent intruder. The identified credible pathways are described in Appendix D.
Calculations detailed in Appendix E demonstrate the disposal of the currently stored PBNP sewage sludge would remain below these limits.
The total annual exposure to the maximally exposed individual bued on the identified exposure pathways is equal *.o 0.072 arem.
The dose to a hypothetical intruder assuming an overly conservative occupancy factor of 100% is calculated to be 0.115 arem/ year. By definition, the inadvertent intruder would not be exposed to the t
processed food pathways (meat and milk).
The calculational methodology used in determining doses for the proposed disposal of sludge stored at DBNP shall be utilized prior to each additional land application to insure doses are maintained less than those proposed by NRR. This calculation will include radio-nuclides disposed of in previous sludge applications. The activity from these prior disposals will be corrected for radiological decay prior to performing dose calculations for the meat, milk, and vegetable ingestion pathways, the inhalation of resuspended radio-nuclides, and all pathways associated with a potential release to Lake Michigan.
The resideal radioactivity will be corrected for radio-logical decay and, if applicable, the mixing of radionuclides in the soil prior to performing external exposure calculations.
In addition, the dose to a farmer potentially leasing more than one application site will be addressed by summing the doses received from the external exposure from a ground plane source and resuspension inhalation pathways for each leased site.
In addition, the maximum site specific dose due to the other pathways identified in Appendix 0, will be utilized in the tetel exposure estimation.
5.0 Radiatica Protection The disposal operation will follow the applicable PBNP procedures to maintain doses as low as reasonably achiecable. Technical review and guidance will be provided oy the PBNP Superintendent - Health Physics.
E-15
~.
/
9
}
^#
4 APPENDIX A.
t 1
SUMMARY
OF RADIOLOGICAL ANALYSES OF-SEWAGE SLUDGE SINCE DECEMBER 30,:1983 v
8 4
-I e
9 e
a 5
+
E --.
. =..
~*
4 Sample Tank' Tank Radionuclide Concentration Date Volume (Gallons)
(uci/cc) 12-30-83
-Digester 8400 Co-58 5.58E-07 Co-60 1.87E-06 Cr-51 4.68E Cs-134 1.59E-07 Cs-137 3.57E-07 4-06-84 Digester 7560 Co-60 7.89E-07 Aeration 6667 Co-60 1.87E-07 12-05-84 Digester 7560 Co-58 1.75E-07 Aeration 6667 Co-60 8.29E-07 6-03-85l Digester 7560 Co-60 8.29E-07 Cs-137 2.46E-07 Aeration 6700 Co-60 3.27E-07 Cs-137 1.33E-07 4-10-86 Digester 7560 Co-60 6.79E-07 Cs-137 1.72E-07 Mn-54 4.91E-OS Co-60 1.65E-07 11-04-86 Digester 7560 Co-58 8.04E-08 Aeration &
Clarifier 25100 Co-58 1.37E-07 Co-60 2.18E-07 Cs-137
- 1. 64E-07 1
1 E-17
APPENDIX B CHEMICAL COMPOSITION ANALYSIS OF SEWAGE SLUDGE b
w+
e E-18
SLUDGE CHARACT, ERISTIC TAT oa m mom'N f
s**AmTuawT oe M Atuaan maaoue cas gg,,,,,;, gg,,,,, 347,g (1) and -
Wisconsin Alministrative Code NM 110.77(6) re e w.4so.d e mEv. a H e wage Treatment Plant Sludge
. seem somskte this form and send tg the Department of Netwal Resourtes sopropriete District /kse Office. Kses are copy for your reords.
for additional forms penses sensact yow approprwis District / Area Office.
. OE4 n n-ir nuusEn
,EamerTE4 W: X 0 !) 2.-.fi 2.
Wisconsin Electric Power Co:cany COUNT Y JTAEET O A AQVT E
.filwaukee t
231 N,.Vichigan Street TELEPr*0ht huweER (aMcLuoE AREA cocE4 CIT Y.5T ATE. It8 CODE
$*ilynube. Y!
53203 W 277-2154 1.
P6 eses nport laboretory testing results for the tallowing parameters:
- Peremeter Abbreviation Resutt
'Parswter Abbreviation Resutt I
A*
Chromium.,
Cr Total Solids. %
2200 I*"
Cu Total Nitrogen.%
TOT N Copcor,p 0.34 IN Ammonium Nitrogen,%
NHj-N
- 1. sed,,,,
Pb 3*0
'O*OI Total Phosphorow, %
P Mercury.,,,
Ng 0.25 12 Total Potassium %.
K Nickal,,,,
Ni 2"300 1.0 3,,
3 Aa Arsenic.,
I*0 I2*
pH Cadmium, p Cd
_.M erutysis preesdwes for the eheva perometers een he found in NR 219, oneW easts and proemdures,Wiscosn
- Administrative Code. As persmeters other then persent solids and pH shall be repersed oc e dry weight hesis.
2.
What is the name of no hboratory that ed the analysis and when was it performed?
April 12, 1933 Wisconsin Electric Power Co.
Dete m a
.aboratory Name 1.aboratory Services Division tre. :12ite heldin' tanh prior to h:ulin-where et,,e rewment paent wm the see tokan7 A"ril 12. 1933
.When ws:we esmote sken?
DATE Tili.59 3*E"ATW R E "r'*
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T 9
e APPENDIX 0 EXPOSURE PATWAYS 9
I a
e e
e e
g.
=,
I.
EXPOSURE PATHWAYS - MAXIMALLY EXPOSED INDIVIDUAL 1.
External whole body exposure due to a ground plane source of radionuclides.
2.
Milk ingestion pathway from cows fed alfalfa grown on plot.
3.
Heat ingestion pathway from cows fed alfalfa grown on plot.
4.
Vegetable ingestion pathway frca vegetables grown on plot.
5.
Inhalation of radioactivity resuspanded in air above application
-site, 6.
Pathways associated with a releast to Lake Michigan.
Ingestion of potable water at Two Rivers, Wisconsin municipal water supply, ingestion of fish from edge of initial mixing zone of radionuclide release, ingestion of fresh and stored vegetables irrigated with water source as Lake Michigan, ingestion of milk and meat from cows utilizing Lake Michigan as drinking water source, swimming and boating activities at edge of initial mixing zone, and shoreline deposits.
II.
EXPOSURE PATHWAYS - INADVERTENT INTRUDER 1.
External whole body exposure due to a ground plane source of rad,ionuclides.
2.
Vegetable ingestion pathway from vegetables grewn on plot.
3.
Inhalation of radioactivity resuspended in air above application site.
4 Pathways associated with a release to Lake Michigan.
Ingestion of potable water at Two P.ivers, Wisconsin municipal water supply, ingestion of fish from edge of initial mixing zone of radionuclide release, ingestion of fresh and stored vegetables irrigated with water source as Lake Michigan, ingestion of milk and meat from cows utilizing Lake Michigan as drinking water source, swimming and t.oating activities at edge of initial sixing zone, and shoreline deposits.
The milk and meat pathways are not included in calculating the dose to the inadvertent intruder. The doses due to these pathways are calculated based on feeding the cows alf alfa grown on the sludge applied land.
Since direct grazing on these lands is prohibited, the alfalfa must be cropped prior to being used as feed. This effectively removes the availability of these pathways to the inadvertent intruder, who by definition occupies the sludge applied land continuously, i
E-25
]!! CROUND WATER PATHWAY The ingestion of groundwater is not a credible exposure pathway.
The two factors contributing to this determination are as follows:
1.
The site sap in Appendix C, figure 3 details the spatial relation-ship betwen the proposed disposal sites and the local ground water wells.
The flow gradient of ground water was determined for the PBNP FSAR to be towards Lake Michigan.
Reviewing the sitas and local wells shows no private wil located in the path of radioneclide migration towards Lake Mit.higan.
The PBNP site well is located on the plant site, potentially in a path of radionuclide migration.
The PBNP well is routinely sampled as a requirement cf the PBNP environental sonitorf rg program.
2.
The cation exchange capacity (CEC) of the soils at each site has been determined.
Site Cation Exchange Capacity (MEQ/100g) 1 16 2
11 3
11 4
10 5
8 6
9 The cation exchange capacity of soil is dependent on the valance of the radionuclides snd is determined by the relation:
MEQ = ATOMIC WEIGHT
- 1.0E-03 VALANCE Radionuclide Valance CEC (ME0/1000)
+2 3.00E-02 Co-58
+2 2.90E-02 Cs-137
+1 1.37E-01 Mn-54
+2 2.70E-02 Cr-51
+3 1.70E-02 Cs-134
+1 1.34E-01 Using the values for Cs-137 and site 5 which has the lowest CEC, the total exchange capacity of the soil is 1.10 crans of Cs-137 100 grams of soil Caiculating the specific activity of Cs-137,
.578E+05
, 3.578E+05 Specific Activity =
Tyjy(yrs.)
ATOMIC MASS 30 137
= 87.1 Ci/ gram E-M
The cation exchange capacity of the soil expressed in tha number of Curies of radionuclide per 100 grar.: of soll is 95.8 Ci Cs-137 100 grams of soil Since the proposed disposal of sewage sludge contains quantities of radionuclides on the order of 10-100'pC1 the soil at each site has the capacity to effectively eliminate the migration of the radionuclide to ground water.
4 9
e E-27
4 6
=
APPENDIX E EXPOSURE ANA8.YSIS i
O L
I
)
E-28
GENERAL ASSLMPTIONS 1.
Sew m e sludge is uniformly appifed over plot acreage.
2.
Sewage sludge is applied to or.e of the 5 acre plots, site PB-03, PB-04, P8-05, or PB-06.
(Assuming the smallest site size is conservative for the calculation methodology herein.)
3.
Based on the sewage sludge currently stored at PBNP, the following data is used in the calculations.
Ground Plane Sludge Volume Activity Concentration Concentration Radionuclide (Gallons)
(cm3)
(pCl)
(pCi/c9)
(uCi/cm2)
Co-60 15,000 5.68E+07 11.2 2.33E-07 C:53E-08 Cs-137 15,000 5.68E+07 e.5 1.50E-07 4.21E-08 1.
CALCULATION OF EXTERNAL EXPOSURES A.
Specific Assumotions 1.
Conservatively astume radioactivity remains on surface of land plot'.
Calculation ignores any plowing or sixing of radioactivity within soil.
Calculations for the proposed disposal will therefore ignore self absorption or shielding from soil.
The external exposure at the application site due to prior disposals will be calculated utilizing the methodology in Appendix G and added to that calculated for the proposed disposal.
2.
The plots are owned by Wisconsin Electric and have been approved by the Wisconsin Department of Natural Resources (DNR) as disposal sites The land is leased and potentially farmed. Occupancy of the 1...d can be realistically expected only during plowing, planting
- and harvesting. Occupancy has been astimated to be 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> per year.
B.-
5,,u_ a,ag of Calculational Methodology 1.
Caiculate ground plane radionuclide concentrations in pCi/cm2, 2.
The dose from a plane of uniformly ileposited radionuclides is calculated using Regulatory Guide f.109, Revision 1, Appendi.- C, Formula C-2.
3.
Dose rates were u Mulated assuming continuous occupancy then adjusted for realistic occupancy factors.
t E-29
C.
Externa) Exposure Rete Calculations The dose from a plane of uniforsly deposited radionuclides is calculated using Regulatory Guide 1.109, Revision 1, Appei.4f x C, formula C-2 Dj(r,6)=G760Sg{Cf(r,8)DFGgy where Dj(r,8) = yearly dose 8760
= hours per year S
= 1.0, since no dose reduction due to residential p
shielding is applicable.
Cf (r,8) = ground plane radionuclide concentration (pCi/m2)
DFG(i,j) = external dose factor for standing on contaminated ground as given in Table E-6 of Regulatory Guide 1.109, Revision 1.
Ground Plane Ground Plane y Dose y Dose Factor Concentration Concentration Rate Radionuelide (ares /hr per pCi/m )
(uti/cm2L (pCi/s4)
(mrem /yr) 2 Co-60 1.70E-08 6.53E-08 6.53E+02 9.72E-02 Cs-137 4.20E-09 4.21E-08 4.21E+02 L 55E-02 TOTAL:
1.13E-01 area / year These calculated dose rates assume continuous occupancy.
In reality, these sites will be occupied only during plowing, planting, and harvesting.
Assuming an occupancy of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day,1 day p:7 week, and 32 weeks (8 month growing season) per year, the occupancy factor becomes 2 hr/ day
- 1 day / week
- 32 weeks /yr
- 1/8760 hours /yr = 7.3E-03.
EXTERMAL EXPOSURE DOSE RATE (aree/ year)
Radionuclide Continuous Occupancy Realistic Occupancy Co-60 9.72E-02 7.10E-04 Cs-137 1.5;E-02 1.13E-04 TOTAL:
1.13E-01 8.23E-04 E-30
)
11.
cat.CULATION OF MEAT AC MILK INGESTION PATWAY EXPOSURES A.
Specific Assumptions 1.
All feed contred by cow i' Pown on sludge applied acreage.
2.
All seat and alik consused by human is from cattle exclusively fed feed from sludge applied land.
Stable element transfer coef ficients (B are utilized from RegulatoryGuide1.109toestimatetheffa)ctionofradioactivity 3.
which is transferted from the soil to the feed.
O Radionuclide iv Co-60 9.4E-03 Cs-137 1.0E 4 Alfalf a has typically been grown on the plots.
Soil tests have indi-cated a minimum alfalfa yield of 4.1 tons per acre can be expected.
B.
Summary of Calculational Methodology 1.
The concentration of radionuclides in feed grown on the disposal plot-is estir.ated.
Transfer caefficients (B from Table E-1 of Regulatory Guide 1.109 were used to estimate tN) fraction of radio-nuclide which may be expected to transfer to the feed from the soil.
2.
Concentrations of radionuclides in milk and meat were estimated using Forsula A-11 from Regulatory Guide 1.109, 3.
Ingestion dose rates were estimated using For=ula A-12 from Ragulatory Guide 1.109.
C.
Milk and Meat incestion Pathway Dose Rate Calculation 1.
Concentration in feed.
Activity in Feed = B
- Activity in Soil gy Concentration in Feed = Activity in Feed /( U
- 5 Acres) cr Radionuclide Activity in Activity in Concentration in Radionuclide Soil (pCl)
Feed (pCi)
Feed (oC1/kg)
Co-60 13.2 1.24E-01 6.67E+00 Cs-137 8.5 8.50E-02
- 4. 57E40 2.
Concentration in Milk and Meat Calculate concentrations of radionuclides in milk and meat using E - _ _ - _ _ _ - _ _
l Formula A 11 in Regulatory Guide 1.109, Revision I which is 1
- Cgg%g Cgg, F94 radionuclide concentration of i in component A where Cgg : stable element transfer coefficient whose values are in F gg = Table E-1 of the Regulatory Guide C
radionuclide concentration in feed Qpif== consumption rate of feed = 50 kg/d (wet weight) from Regulatory Guide 1.109 Use the following Regulatory Guide 1.109 values for Fgg Element gg=,(d/1) for allk F93=Ff (d/kg) for seat F
Co 1.0E-03 1.3E-02 Cs 1.2E-02 4.0E-03 Concentration in Concentration in Radionuclide Milk (pCi/1)
Heat (pCi/ko)
Co-60 3.34E-01
- 4. ~>4 E+00 Cs-137 2.74E+00 9.14E-01 3.
Calculated Dose rates The fo sula for total dose from eating animal products fed vegeta-tion (alfalfa) grown on PBNP sludge applied land is given l).
Regulatory Guide 1.109, Revision 1, Fomula A-12, page 1.109-16.
But, as noted following equation A-13, it is necessary to compute separately the milk and seat portions of the dose.
DOSE = I(0,p*D,pg*exp(-A,t ))
g 3
where U
= consumption rate of animal product C h
= dose factor conc of radionuclide i in animal product A D
tfapg== average time between silking or slaughtering and consumption U,, by Age Group Infant.
Child Teenacer Adul t Milk (1/yr) 330 330 400 310 41 65 110 Heat (kg/yr)
C
= concentration calculated above yg O,pg = OF whole body dose f actors, Regulatory Guide 1.109 g
Revision 1.
E-32
A Whole Body Oose Factors (arem/pC' Incested)
Infant Child-Teenager Adult Nuclide Incestion Incestion Incestion Incestion Co-60 2.55E-05 1.56E-05 6.33E-06 4.72E-06 Cs-137 4.33E-05 4.62E-05 5.19E-05 7.14E-05
= 0 for milk (assume consumption on fars) a 20 days for seat (Regulatory Guide 1.109, Revision 1, Table E-15)._
T s MILK INGESTION DOSE RATE (mrem / year)
Radionuclioe Infant Child Teenacer Adult _
Co-60 2.81E-03 1.72E-03 8.46E-04 4.89E-04,
C,-137 3.92E-02 4.18E-02 5.69E-02 6.06E-02 TOTALS:
4.20E-02 4.35E-02 5.77E-02 6.11E-02 MEAT INGESTION DOSE RATE (arem/ year)
Radionuclide Infant Child Teenacer Adult 2.76E-03 1.77E-03 2.24E-03 Co-60 1.73E-03 3.08E-03 7.18E-03 Cs-137 4.49E-03 4.85E-03 9.42E-03
- TOTALS:
MEAT AND MILK INGESTION PATHWAY 005E RATES (are,/ year)
Infant
- 4.20E-02 Child
- 4.'80E-02 Teenager - 6.26E-02 Adult
- 7.05E-02 III. cal.CULATION OF VEGETALLE INGESTION PATHWAY EXPOSURES A.
Soecific Assumptions The WPDES permit issued to PBNP'for the disposal _of sewage 1.
sludge prohibits the growing of crops for human consumption for one par _ following the application of the sewage slude.
Therefore, prior to planting vegetables on the application site, the soil would be plowed.
Plowing is assumed to uni-formly six the top 6 inches of soil.
E-33
1 1
3 2.
The soil density is assumed to be 1.3 grams /cm.
3.
All vegetables consumed by the individual of interest are Crown on the sludge applied acreage.
4 Stable element transfer coefficients (84 ) from Regulatory Guide 1.109areusedtoestimatethefraltionofradio-activity transfered from the soll to the vegetables.
O Radionuclide iv Co-60 9.4E-03 Cs-137 1.0E-02
) and the mass basis The consumption factors of food medium (U,pTable E-5 are used 5.
distributions f os Regulatory Guide 1.109, to determine annual consumption of vegetables.
O,,by Age Group
- pg Child Teen Adult 280 kg/yr 340 kg/yr 280 kg/yr
" Based on 54% vegetable consumption by mass of fruit, vegetable, and grain.
6.
The Ingestion Dose Factors by age group are from Regulatory Guide 1.109, Tables E-11. E-12 E-13, and E-14.
Whole Body incestion Dese Factors (arem/pCi incested)
Radionuclide Infant Child Teen Adult
~
Co-60 2.55E-05 1.56E-05 6.33E-06 4.72E-06 Cs-137 4.33E-05 4.62E-05 5.19E-05 7.14E-05 7.
Radiological decay of the radionuclides applied to the plot is not taken into account in these calculations.
B.
Sumary of Calculational Methodology 1.
The radionuclide concentration in the soil is calculated in units of pCi/kg based on uniform application over 5 acre plot, plowing to a depth of 6 inches, and a soil density of 1.3 g/cm3 2.
The B values are applied to the soil concentration values to gy obtain the radionuclide concentration in the vegetables.
The consumption factors (U for each age group are then used to determine the annual raNo)nuclide intake by age group due 3.
to eating these vegetables.
'~'
i l-4.
Finally, the age dependant ingesti_on dose factors are used to obtain annual doses by age group.
C.
Vegetable Pathway Incestion Dose Rate Calculations 1.
Concentration in soil Cor: centration Activity Soil Volur,e Soll Mass In Soil Radionuclide Aoplied (pCI)
(cm3)
J)
(pCi/ko)
Co-60 13.2 3.08E+09 4.00E+06 3.30E+00 Cs-137 8.5 3.08E+09 4.00E+06 2.13E+03 2.
Concentration in vegetables Concentration Concentration In In Vegetables B
Radionuclide Soil (pCi/ko) iv (pCi/ko)
Co-60 3.30E+00 9.4E-03 3.10E-02 Cs-137
-2.13E+00 1.0E-02 2.13E-02 3.
Calculated Dose Rates The dose rate for direct ingestion of vegetables grown on the sludge applied land is given by the equation.
DOSE RATE = I U,p
- D,p)
- EXP (-A t)
- C9 j
g where U*P
= consumption ate of food medius DA *Ed== dose factor for radionuclide, i radiological decay constant g
t
= time between harvest and consumption c;
= concentration of radionuclide, i, in food
- medium, t, the time between harvest and ingestion, is assumed to be zero for this calculation.
VEGETABLE INGESTION DOSE RATE (arem/ year)
Radionuclide Infant Child Teen Adult Co-60 1.35E-04 6.67E-05 4.10E-05 Cs-137 2.76E-04 3.76E-04 4.26E-04 TOTAL 4.11E-04 4.43E-04 4.67E-04 E-35
IV.
CALCULATION OF INHALATION OF RESU$ PENDED RADIONUCLIDES PATHWAY EXPOSURE A.
Specific Assumptions 1.
The model used to determine the radionuclide concentration in air above th; sludge applied land is taken from VASH-1400 USNRC, Reactor Safety Study - An Assessuent of Accident Risks in Coenercial Nuclear Perar Plants, Appendix VI.
2.
The radionuclide concentration in air remains constant for year of interest, i.e., radiological decay and decrease in resuspension fat, tor are not taken into account for this calculation.
3.
ne maximally exposed member of the general public is assumed to be the farser using the plot of land with an occupancy of 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> per year.
4 The inadvertent intruder is assumed to occupy the plot of lend for the entire year.
5.
The Inhalation Dvse Factors by age group are from Regulatory Guide 1.109, Tables E-7, E-8, E-9, and E-10.
WOLE BODY INHAL ATION 00$E FACTORS (arem/pCi inhaled)
Radionucl+3 Infant Child Tee n Adult
' Cc60 8.41E-05 6.12E-06 2.48E-06 1.85E-06 Cs 137,
3.25E 05 3.47E-05 3.89E 05 5.35E-05 LUNG INHALATION DOSE FA TORS (eres/pci inhaled)
Radionuclide Infant Child Teen Adult co-60 3.22E 03 1.SIE-03 1.09E-03 7.46E-04 Cs-137 5.09E-05 2.81E 05 1.51E-05 9.40E-06 E.
The age dependent inhalation rates are obtained from Regulatory Guide 1.109, Table E 5.
Inhalation Rates (m3/yr)
Infant Child Teer}
Adult
-1*10 3700 8000 8000 E' %
B.
Sunusary of Ca.eulational Methodology 1.
The ground plane radionuclide concentrations in pCf/m2 2.
Calculate the resuspension 7 actor utilizing equation given in WASH 1400.
3.
Obtain the radioneclide concentration in air (pCf/e3) above plot utilizing methodology in WASH-1400.
4.
Using parameters contained in Regulatory Guide 1.109, cal:ulate annual dose for continuous occupancy and for realistic occupancy.
C.
Inhalation of Resuspended Radionuclides in Air Pathway Dose Rate 9 1culations - Resuspension of Racionuclice in Air 4
1.
Ground plane radionuclide concentration Ground Plane Ground Plane Radionuclide Concentration (pCi/c,2)
Concentration (oC1/m2)
Co 60 6.53E-08 6.53E+02 Cs-137 4.21E-08 4.21E+02
~
2.
Calculation of resuspension factor, K (a )
From WASH-1400, K(t) = 1.0E-09 + 1.0E-05
- EXP [ 0.6769
- t]
wh'ere t = time since radionuclides were deposited on ground surface.
t is assumed ta be 0 for these calculations, thereby maximizing the resuspension factor.
Therefore, Kd 1.0E-05 a
3.
Calculate radionuclide concentration (pct /m3) in air.
From WASW 1400, K(a ) = air concentratici (pC1/m3}
surf ace deposit (pCi/m2) or Air Concentration (pCi/m3) = curf ace deposit (pCi/st) a X(m,3)
AIR CONCENTRATIONS Radionve11de Air Concentrations (pci/m3) i Co 60 6.53E-03 Cs-137 4.21E-03 E-37
4 Dose Rate Calculations Dose Rate (ares /yr) = Inhalation Rate (e3/yr)
- Air Conc. (pCf/m3)
- DoseConversionFactor(area /pCf)
Wh0LE BODY INHALATION DOSE RAYF (arem/ year)-
Radionuclide Infant Child Teen Adult Co-10 7.69E-05 1.48E-04
- 1. 92E-04 5.41E-04 1.31E-03 1.80E-03 TOTAL 2.69E-04
- 6. 89E-04 1.44E-03 1.90E-03 4
LONG INHALATION DOSE RATE (ares / year)
Radionuclfde
_ infant
_ Child Teen Adult Co-C0
- 2. 94 E-02 4.61E-02 5.69E-07 3.90E-02 '
- 3. 00E-04 4.38E-04 5.09i-04 3.17E-04 TOTAL 2.97E-02 4.65E-02 5.74E 02 3.93E-02 NHALATION OF RESUSPENDED RADIONUCLIDES IN AIR DOSE RATES WHOLE BODY DOSE RATE (eres/ year)
Occupancy Infant child Teen
, Adult Continuous
- 2. 69E- 04
- 6. 89E-04 1.44r.03 1.90E-03 Rea?istic 1.96E-06 5.03E 06 1.05E-05 1.39E-05 LUNGDOSERATE(aree/yearl
,0,ccupancL
- Infant, Child Teen Ad_ ult __
Continuous 2.97E-02 4.65E-02 5.74E-02 3.935-02 Realistic 2.17E-04 3.39E 04 4.19E-04 2.87E-04 V.
CALCULATION OF WHOLE B0CY EXPOSURES 00E TO RELEASE TO LAKE MICHIGAN t.
Specific Assumptions 1.
The methodology contained in the PSNP Offsite Dose Calculation Manual (00CH) is used to perform this calculation.
E-38
__=. _..
The entire activity contained in the sludge is released into 2.
Lake Nichigan.
The exposure pathways addressed by the ODCN methodology are 3,
ingestion of potable water from Two Rivers, VI water supply, f ingestion of fish at edge of initial mixing zone, ingestion o fresh and stored vegetables, irrigated with Lake Michigan as source of water, ingestion of allk and esat from cows utilizing Laire Michigan as drinking water source, swimming and beating activities at edge of initial mixing zone, and shoreline deposits.
B, Summary of Calculational Nethodology The activity released in the sludge is converted into 1.
Co-60 doss equivalent Curies.
The anneal design release limit from the ODCH is 94.7 Co-60 2.
equivalent curies.
The annual desigr release limit is based on a Ifmiting dose 3.
The anntal dose due to sewage of 6 ares adult whole body.
sludge is calculated by a ratio of.41culated release compared to release limit.
C.
Whole Body Exposure Calculations 1.
Co-60 equivalent Curies Co-60 eq.
Activity DF /DF Radionuclide (pCl) i Co 60 Activity (pCi)
Co-60 13.2 1.00E+00 13.2 Cs-137 8.5 1.51E+01 128.4 TOTAL 141.6pci Co-60 e>;uivalent Ratio of dose limit to annual design release limit 2.
6 eroe
'W.T~Co-60equivalentcuries 3.
Whole Body Dose Calculation Oose
=
6 mrem 141.6pci 94.7x10*pci Dose = 8.97E-06 mres WOLE BODY OOSE RATE (arem/vear)
P.iO
D0sE SUMM.Aky Naximally Exposed Individual The identified credible exposure pathways for the maximally exposed individual are:
1.) External exposure from grvund plane source (realistic occupancy) 2.) Milk ingestion pathway 3.) Meat ingestion pathway 4.) Yegetable ingestion pathway 5.) Resuspension inhalation pathway (realistic ocrupancy)
- 6. ) Pathways identified due to release to Lake Michigan.
AGE GROUP Pathway Infant Child Teen Adult External 8.23E-04
- 8. 23E-04 8.23E-04 8.23E-04 Mi'k 4.20E-02 4.35E 02 5.77E-02 6.11E-02 4.49E-03 4.85E-03 9.42E-03 Heat 4.11E-04
- 4. 43 E-04 4.67E-04 Vegetable Inhalation 1.S6E-06 5.03E-06 1.05E-05 1.39E-05 Water 8.97E-06 8.97E-06 8.97E-06 8.97E-06 TOTAL:
0.043
- 0. 04 9 0.064 0.072 (area / year)
Inadvertent intruder The identified credible exposure pathways for the inadvertent intruder are:
1.) External exposure from ground plane source (continuous occupancy) 2.) Vegetable ingestion pathway 3.) Resuspension inhalation pathway (continuous occupancy) 4.) Pathways identified due to release to Lake Michigan.
AGE GROUP Pathway Infant
_ Child Teen Adult Exten.a1 1.13E-01 1.13E-01 1.13E-01 1.13E-01 4.11E-04
- 4. 43E-04 4.67E-04 Vegetable Inhalation
- 2. 96E-04
- 6. 89 E-04
- 1. 44 E-03 1.90E-03 Water 8.97E-06 8.97E-06 8.97E-06 8.97E-06 TOTAL:
0.113 0.114 0.115 0.915 (aren/ year)
Reviewing these tables, the calculated limiting deses for both the m.1xima11y exposed individual and the inadvertent intruder occur for the adult age group.
These doses are:
Maximally Exposed Individual:
0.072 arem/ year Inadvertent Intruder:
0.115 ares / year e.an
.u
...sr.
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. -. +
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c APPENDIX F t
i BA515 FOR SETTING CONCENTRATION LIMITS AND ACTIVITY LIMIT
[
FOR DISPOSAL OF $LUDGE i
?
e t
l 4
r A
e 4
7 i
e i
9 e
'.5,.,.
?
i
- E -
+-
.,..,,, _.., __. a.- _
Analyses of previously disposed sewage sludge have identified six differe All six radionuclides did not occur in each radionuclides in the sludge.Therefore, it is dif ficult to determine a single conc limit for regulating the disposal of the sludge from the storage tanks.
disposal.
To provide a basis to regulate the disposal of the sew N
C, 1
jfy.1^MP{I 0
where
= number of different radionuclices identified in the N
sewage sludge.
a concer.tration of the ith radionuclide in the O g sewage sludge.
4 = the NPC value of the ith radionuclide in the HPC sewage sludge, as Ifsted in 10 CFR Part 20 Appendix 8 Table II, Column 2.
If this criteria is set, the sewage sludge say be disposed of by land spread-ing provided the dose calculations (as identified in Appendix E) indicate dose rates within the prescribed limits.
The attachment to this Appendix details calculations performed to determine The calculations a.re doses from four radionuclides identified in the sludge.
based on an identified concentration equal to 10% of the 10 CFR Part Appendix B. Table II, Column 2 valves.
in Appendix E along with the exposure pathways identified i.t Appendix 0 to These calculations indicate the usa of this determine the dose rates. methodology will maintain radiation doses within the The maximum allowable activity disposed of per year per acre is calculated utilizing 10% of the MPC value,10 CFR Part 20. Appendix B, Table II, Colu Volume limit per acre has been proposed at 4,000 gallons / acre / year.
for Co 58.
- Then, 3.785.43 cc/ gallon 1.0E-05 pCi/cc
- 4,000 gallons / acre / year x
= 151.4 pCl/ acre / year W ee f }
~ -~
Cs-134 Concentration in Sludge:
9.0E-07 sci /m1 Sludge Volume Concentration Activity Ground Plane (Gallons}
(cm3)
(pci/cm3)
(pC1)
Concentration (pCf/cm2) 15000 5.'
.+07
- 9. 00E-07 5.11E+01 2.53E-07 Externai Exposure y Dove Factor Ground Plane Concentre. tion y Oose Rate (mres/hr. per pC1/m2)
(pci/m2)
(arem/ year) 1.20E-08 2.53E+03 2.66E-01 Continuous occupancy: 2,66E-01 ares / year Realistic Occupancy:
1.94E-03 ares / year Heat A Milt Pathway Activity in Activity in Co.icentration in Concentration in Concentration.in Soil (pCi)
Feed (pCl)
Feed (p01/Ka)
Milk (pCi/1)
Meat (pCi/ko) 5.22E+01 5.11E-01 2.75E+(1 1.65E+01 5.50E+00 bilk Dose Rates (stem / year)
Infant Child Teenacer Adult 3.87E-01 4.41E-01 6.03E-01 6.19E-01 Heat Oose Rate (ares / year)
I nf ant __
Child Teenacer Adult 1.83E-02 3.27E-02 7.32E-02 Vegetable Pathway Activity Soil Volume Soil Hass Concentration Concentration (pC1)
(Cm3 )
(Ko) in Soil (pCi/Ko) in Vegetables (oCi/Kc) 5.11E+01 3.08E+09 4.00E+06 1.2aE+01
- 1. 28E-01 Ed'
l Veaetable Pathway Dese Rates (ares / year)
Infant Child _
Teenacer Adult
- 2. 90E-03 3.98E-03 4.34E-03 Inhalation Pathway Ground Place X
Air Concentration Concentration (pci/mt)
(m* )
(pci/m3) 2.53E+03 1.0E 05 2.53E-02
?nhalation Pathway Dose Rates (area / year)
Infant Child Teenacer Aoult Continuous occupancy 1.88E-03 5.68E-03 1.39E-02 1.84E-02 Realistic Occupancy 1.38E 05 4.15E-05 1.01E-04
(p01) 5.11E+01 2.56E+01 1.31E+03 6 mrem,. 1.31E+03 1 Ci
= 8.29E-05 ares 94.7 C1 1.0E+06 pC,1 Maximally Exposed Individual
- Infan_t, Child Teena m Adult External
- 1. 94 E-03 1.94E-03 1.94E-03 1.94E-03 Milk 3.87E-01 4.41E-01 6.03E-01 6.19E-01 1.83E-02 3.27E-02
- 7. 32E-02 Meat 2.90E-03 3.98E-03 4.34E-03 Vegetable Inhalatton 1.38E-05 4.15E-05 1.01E-04 1.35E-04 Water 8.29E-05 8.29i-05 8.29E-05 8.29E-05 Totals:
3.89E-01 4.64E-01 6.42E-01 6.99E-01 Inadvertens Intruder Infant y.d Teenacer Adult External 2.06E-01 2.66E-01 2.66E-01 2.66E-01 2.90E-03
- 3. 98E-03 4.34E-03 Vegetable Inhalation 1.88E-03 5.68E-03 1.39E-02 1.84E-02 Water 8.29E 05 8.29E-05 8.29E-05 8.29E-05 Totals:
2.68E 01-2.75E-01 2.84E-01 2.89E-01 v..s
. _. =
f P
Cs 137 Concentration in Sludge:
2.0E-06 pCi/a1 Sludge Volume Concentration Activity Ground Plane (Gallons)
(em3)
(pC1/co8)
(uti)
Concentration (DCf /cm2) 15000 5.68E+07 2.00E 06 1.14E+02 5.62E 07 External Exposure y Dose Factor Ground Plane Concentration y Dese Rste (arem/hr. per pCi/m2)
(pC1/m2)
(ares / year) 4.20E-09 5.62E+03 2.07E-01 Continuous occupancy:
2.07E-01 area / year Realistic Occupancy:
1.51E-03 aren/ year Heat & Milk Pathway Activity in Activity in Concentration in Concentration in Concentration in Soil (uct)
[eed(9C1)
Feed (pCi/Xo)
Milk (pC1/1)
Meat (pci/ko) 1.14E+02 1.14E+00 6l13E+01 3.68E+01 1.23E+01 M,11k Dese Rates (area / year)
Infant Child Teenacer Adult 5.26E-00 5.61E-01'
- 7. 64E-01 8.15E-01 Meat _ Dose Rate (area / year)
_ Infant Child Teenacer Adult 2.33E-02 4.15E-02 9.56E-02 Vegetable Pathway Activity soil Volume Soll Kass Concentration Concentration (pCi)
(tm3)
(Ka) in Soil (pci/Xc) in Vecetables (pci/Kg) 1.14E+02 3.08E+09 4.00E+06 2.85E+01 2.85E-01 4
Y,0 Y
Vegstable Pathway Dose Rates (crer/ year)
Infant Child Teenager Adult 3.69E 03 5.03E-03 5.70E-03 Inhalation Pathway Air Concentration Ground Plane K
Concentration (pCi/m2)
(m*3 )
(pCl/m3) 5.62E+03 1.0E-05 5.62E-02 Irihalation Pathway Dese Rates (ares / year)
Infant Child Teenager Adult Continuous occupancy 2.56E-03 7.22E-03 1.75E-02 2.41E-02 Realistic Occupancy 1.87E-05 5.27E-05 1.28E-04 1.76E-04 Release to 1.ake Michigan Activity 0F /DF Co-60 eq. activity j
Co-60 (uci)
(uci) 1.14E+02 1.51E+01 1.72E+03 6 arem, 1.72E+03,
1 Ci
. = 1.09E-04 arem 94.7 Ci I OE+06 pC1 Maximally Exposed Individual Infant Child Teenager Adult External 1.51E-03 1.51E-03 1.51E-03 1.51E-03 Milk 5.26E-01 5.61E-01
- 7. 64 E-01 8.15E-01 2.33E-02 4.15E-02 5.70E-03 Heat 3.69E-03 5.03E-03 5.70E-03 Vegetable Inhalation 1.87E-05 5.27E-05 1.2SE-04 1.76E-04 Water 1.09E-04 1.09E-04 1.09E-04 1.09E-04 Totals:
5.28E-01 5.90E-01 8.12E-01 9.19E-01 Inadvertent Intruder Infant Child Teenager Adult External 2.07E 01 2.07E-01 2.07E-01 2.07E-01 3.69E-03 5.03E-03 5.70E-03 Vegetable Inhalation 2.56E-03 7.22E-03 1.75E-02 2.41E-02 Water 1.09E-04 1.09E-04 1.09E-04 1.09E-04 Totals:
2.10E-01 2.18E 2.30E 2.37E-01 c 4e
i l
Co 58 Concentration in Sludge: 1.00E 05 pCi/ml 51adge Volume Concentration Activity Ground Piane (Gallons)
(em3)
(pCf/cm3)
(pCl)
Concentration (pCi/cm2) 15000 5.68E+07 1.00E 05 5.68E+02 2.81E-06 External Exposure y Dose Factor Ground Plar>e concentration y Dose Rate (ares /hr. per pC1/m2)
(pCf/s2)
(arem/ year) 7.00E-09
- 2. 81E+04 1.72E+00 Continuous occupancy:
1.72E+00 area / year Realistic Occupancy:
1.26E-02 aren/ year Meat & Hlik Pathway Activity in Activity in Concentration in Con;entration in Concentration in Soil (pCi)
Feed (uci)
Feed (pCi/Ko)
Milk (pci/1)
Meat (pCi/ko) -
5.68E+02
- 5. 34 E* 00 2.87E+02 1.44E+01 1.87E*02 Milk Dese Rates (ares / year)
Infant Child Teenacer Adult 4.27E-02 2.62E-02 1.29E-02 7.45E-03 Meat Oose Rate (aree/ year)
Infant Child Teenacer Adult 4.22E-02 2.72E-02 3.44E-02 Vegetable Pathway Activity Soll Volume Soil Mass Concentration Concentration (pCl)
(Cm3)
(Ko) in Soil (pti/Ko) in Vecetables (pCi/Kg) 5.6BE+02 3.08E+09 4.0rE+06
- 1. 42E-04 1.33E+00 E-47
Vecetable Pathway Dose Rates (ares / year)
Infant Child Teenacer
_ Adult 2.05E-03 1.01E-03 6.22E-04 Inhalation Pathway Ground Pl.ine X
Air Concentration Concentrationjpci/m2)
(m' )
(pCf/m3) 2.81E+04 1.0E-05 2.81E-01 Inhalation Pathway Dese Rates (aree/ year) t Infant Child
.<enacer Adult' continuous occupancy 5.11E-04 8.89E-04
- 7. 80E-04 5.82E-04 Realistic Occupancy 3.74E-06 6.49E-06 5.70E-06 4.25E-06 Release to Lake Michican Activity 0F /0F Co-60 eq. activity 4
Co 60 (pC1)
(uti) 5.68E+02 3.54E-01 2.01E+02 6 mrem, a 2.01E+02 pCi,
1 Ci
= 1.27E-05 arem 94.7 C1 1.0E+06 pCi Maximally Exposed Individual Infant Child Teenager Adult External 1.26E 1.26E-02 1.26E-02 1.26E-02 Milk 4.27E-02 2.62E-02 1.29E-02 7.45E-03 Meat 4.22E-02 2.72E-02 3.44E-02 Vegetable 2.05E-03 1.01E-03 6.22E-04 Inhalation 3.74E-06 5.49E-06 5.70E-06 4.25E-06 Water 1.27E-05 1.27E-05 1.27E-05 1.27E-05 Totals:
5.53E-02 8.31E-02 5.37E-02 5.51E-02 Inadvertent Intruder Infant
_ Child Teenager Adult _
External 1.72E+00 1.72E+00 1.72E+00 1.72E+00 Vegetable 2.05E-03 1.01E-03 6.22E-04 Inhalation 5.11E-04 8.89E-04 7.80E-04 5.82E-04 Water 1.27E-05 1.27E-05 1.27E-05 1.27E-05 Totals:
1.72E+00 1.72E+00 1.72E+00 1.72E+00 E-48
Co 60 Concentration in Sludge:
5.0E-06 pCl/al Sludge Volume Concentration Activity Ground Plane (Ca11ons)
(em3)
(pCf/cm3)
(pci) _
Concentration (pCi/cm2) 15000 5.68E+07 5.00E-06 2.84E+02 1.41E-06 External Exposure y Dose Factor Ground Plane Concentration i Oese Rate i
(mree/hr. per pC1/mt)
(DCi/s2)
(ares / year) 1.70E-08 1.41E+04 2.09E+00 Continuous occupancy:
2.09E+00 ares / year Realistic Occupancy:
1.53E-02 nres/ year i
Meat & Milk Pathway Activity in Activity in Concentratinn in Concentration in Concentration in soil (pci)
Feed (uci)
Feed (pC1/Ka)
Hilk (DCi/t)
Meat (pCi/kg)
- 2. 84 E+02 2.67E+00 1.44E+02 7.18E+00 9.33E401 Milk Dose Rates (aren/ year)
Infant Child Teenacer Adult 6.04E-02 3.70E 02 1.82E-02 1.05E-02 gatDeseRate(aren/ year)
Infant Child Teenager Adult 5.97E-02 3.84E-02 4.84E-02 Vegeta51e Pathway Activity Soil Volume Soil Mass Concentration Concentration (uct) '
(Cm3)
(Ko) in Soil (pci/Kg) in Vegetables (pCi/Kc) 2.84E+02 3.08E+09 4.00E+06 7.10E+01 6.67E-01 E-49
Vegetable Pathway Dese Rates (crem/ year)
Infant Child Teenager Adult 2.91E-03 1.44E-03 8.82E-04 Inhalation Pathway Ground Plane K
Air Concentration Concentration (pC1/m2)
(m~3)
(pci/m3) 1.41E+04 1.0E-05 1.41E-01 Inhalation Pathway Dese Rates (eres/ year)
Infant Child Teenager Adult Continuous Occupanc'/
1.66E-03 3.19E-03 2.80E-03 2.09E-03 Realistic Occupan.:y 1.11E-05 2.33E-05 2.05E-05 1.53E-05 Release to Lake Michigan Co-60 eq. activity Activity DF;/DFCo-60 (pCi)
(uC1) 6anm, 2.84E+02pti.
1 Ci
. = 1.80E-05 arem 94.7 Ci 1.0E+06 pCi Maximally Exposed Individual Infant Child Teenager Adult 1
External 1.53E-02 1.53E-02 1.53E-02 1.53E-O' Milk 6.04E-02 3.70E-02 1.82E-02 1.05E-02 5.97E-02 3.84E-02 4.84E-02 Heat 2.91E-03 1.44E-03 8.82E-04 Vegetable Inhalation 1.21E-05 2.33E-05 2.05E-05 1.53E-05 Water 1.80E-05 1.80E-05
- 1. 80E-05 1.80E-05 Totals:
7.57E-02 1.15E-01
- 7. 34 F-02 7.51E-02 Inadvertent Intruder Infant Child Teenager Adult External 2.09E+00 2.09E+00 2.09E+00 2.09E+00 2.91E-03 1.446-03 8.82E-04 Vegetable Inhalation 1.66E-03 3.1SE-03 2.80E-03 2.09E-03 Water 1.80E-05 1.80E-05
- 1. 80E-03 1.80E-03 Totals:
2.09E+00 2.10E+00 2.10E+00 2.095+00 E-M A
.