ML20207A951

Forwards Preliminary Comments on Util 851209 Offsite Dose Calculation Manual.Comments Should Be Reviewed Prior to Planned 861107 Telcon

ML20207A951
Person / Time
Site:	Vogtle
Issue date:	11/06/1986
From:	Mark Miller Office of Nuclear Reactor Regulation
To:	Conway R GEORGIA POWER CO.
References
NUDOCS 8611110415
Download: ML20207A951 (5)

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.o-Docket Nos.: 50-424 and 50-425 NOV 0 6 1M6

'Mr. Richard Conway Senior Vice President and Project Manager Georgia Power Company Route 2, Box 282 Waynesboro, Georgia 30830

Subject:

Transmittal of Preliminary Connents on Vogtle Offsite Dose Calculation Manurl Enclosed are the staff's preliminary documents based on its review of the Vogtle 0ffsite Dose Calculation Manual (0DCM) submitted by letter dated December 9,1985.

Your staff should review these connents prior to our planned telecon on

.this subject on flovember 7 at 9:00 a.m.

Sincerely, h

fielanie A. Miller, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A

Enclosure:

As stated cc: See next page DISTRIBilTION:

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NRD PDR Local PDR PRC System PWR#4 Rdg BJYoungblood Rdg I'.Duncan fHiller 0GC/Bethesda ACRS (10)

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COMMENTS ON THE VOGTLE ODCM General If Georgia Power wants to take advantage of the technical specification improvement provisions accorded Seabrook, the

- appropriate section must be added to the ODCM.

' 1.

Liauid Effluents Page 1-1 In discussing monitoring of liquids from systems such as the turbine building drains it should be noted that monitoring can assure compliance with the concentration limits of TS 3/4.11.1.1 but sampling and analysis are needed to control doses (TS 3/4.11.1.2) because the average release concentrations must be so low.

Page 1-3.

The parenthetical statement in the explanation of "c"

seems incorrect.

Also a discussion is needed as to how the instrument reading is related to concentration.

1-6.

It seems appropriate to add some discussion of MPCs to remind the user of the wide range of values.

It might i

be noted, for example, that the most likely alpha emitter, Np-239, has an MPC of 1E-04 whereas the value for Cf-254 is 1E-07.

1-10 Detection criteria should be discussed; note the possible inadequacy of the Tech. Spec. LLD values.

For example, the LLD for Cs-137 is 0.6 pCi/ml while'the limit continuous release is.001 pCi/ml.

1-11 Equation 6 seems to need a double summation.

1-13 Manufacturer calibration is not acceptable; the licensee is responsible for calibration including the use of NBS traceable sources.

1-17 An upper bound should be specified for treating liquid as uncontaminated.

Note, for example, that the average concentration of Cs-137 (alone) must be kept below 1E-09 uCi/ml in releases.

1-19 Equation 13 incorrectly implies that only dilution flow during releases may be considered in dose calculations.

1-22 Table 1.2-1 uses 1EOS as the bicaccumulation factor for P-32; 3E03 is now acceptable.

1-27 It seems desirable to add a footnote saying that the dose factor is taken as zero when Regulatory Guide 1.109 reports "no data"; these dose factors are not really zero.

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1-28 It might be desirable to increase the ingestion dose factor 20% to match the child thyroid dose factor.

1-29 Dose projections are for a month, not a quarter, so equations 16 & 17 should be revised.

1-37 The line through RE-0018 should be solid.

2.

Gaseous Effluents 2-1 The discussion of a " confirmed" primary to secondary leak should be expanded to ensure (1) that it is not taken to mean "not until we get around to making a confirmatory measurement" and (2) that measurements are sensitive enough to meet needs for controlling doses (TS 11.2.2).

2.1 Setooints 2-3 In the discussion of "SF" it is not quite correct to say that "SF= 0.5 corresponds to 100 percent variation".

2-4 The discussion of C and R is insufficient; explain t

how i t is determine @; the problem comes up in several places.

2-6 The mixed-mode X/O value seems unacceptable because of the effect of the cooling towers.

the NRC value in the FES is 10 times higher.

2-17 Clarify Equations 14 & 15.

The indicated summations over "nm" and "ng" are unclear because the quantities being summed have no such subscripts.

Also the "G"

and "M" subscripts have defined meanings which make them unsuitable as indices for summation.

2-18 The above comments also apply to Equation 16 and others.

2-63 Table 2.2-11 has no values for B Veg/ soil and has F values for goat milk which are noE in the referenced

• table.

2-64 The bases are not clear for the values in Table 2.2-12.

2-67 " Grazes" is misspelled.

It would be desirable to add sources of the values; Reg. Guide Tables E-3 & E-15, GASPAR Code, etc.

2-71 X/O & D/O values need justification.

2.3 Meteoroloav

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,b '

Q This section is still being reviewed.

3.

Environmental Monitorina 3-2 Iodine and particulate airborne activity samplers should be added to locations 5 and 12.

3-2 Water samples should be taken from the closest stream flowing into the river.

3-3 A milk sample should be taken from the cow mentioned on Page 2-64 when available.

A control milk sample also is needed.

l..

ij Mr. R. E. Conway Georgia Power Company Vogtle Electric Generating Plant cc:

Mr. L. T. Gucwa Resident Inspector Chief Nuclear Engineer Nuclear Regulatory Comission Georgia Power Company P. O. Box 572 P.O. Box 4545 Waynesboro, Georgia. 30830 Atlanta, Georgia 30302-Mr. Ruble A. Thomas Deppish Kirkland, III, Counsel Vice President - Licensing Office of the Consumers' Utility Vogtle Project Council Georgia Power Company /

Suite 225 Southern Company Services, Inc.

32 Peachtree Street, N.W.

P.O. Box 2625 Atlanta, Georgia 30303 Birmingham, Alabama 35202 James E. Joiner Mr. Donald O. Foster Troutman, Sanders, Lockerman, Vice President & Project General Manager

& Ashmore Georgia Power Company Candler Building Post Office Box 299A, Route 2 127 Peachtree Street, N.E.

Waynesboro, Georgia 30830 Atlanta, Georgia 30303 Danny Feig Mr. J. A. Bailey 1130 Alta Avenue Project Licensing Manager Atlanta, Georgia 30307 Southern Company Services, Inc.

P.O. Box 2625 Carol Stangler Birmingham, Alabama 35202 Georgians Against Nuclear Energy 425 Euclid Terrace Ernest L. Blake, Jr.

Atlanta, Georgia 30307 Bruce W. Churchill, Esq.

Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.

Washington, D. C.

20037 Mr. G. Bockhold, Jr.

Vogtle Plant Manager Georgia Power Company Route 2, Box 299-A Waynesboro, Georgia 30830 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323