ML20209B962

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Effluent & Waste Disposal Semiannual Rept,Jan-June 1986
ML20209B962
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 06/30/1986
From:
CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML14176B061 List:
References
NUDOCS 8609080359
Download: ML20209B962 (25)


Text

Enclosura 1 to Ssrials RNPD/86-3790 4

Pega 1 cf 25 EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT 1/1/86 - 6/30/86 I

CAROLINA POWER AND LIGHT COMPANY H. B. ROBINSON SEC PLANT - UNIT 2 FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 4

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s Enclosura 1 to Ssrials RNPD/86-3790 Pega 2 of 25 TABLE OF CONTENTS I. Introduction 3 II. Supplemental Information 4 III. Caseous Effluents 8 IV. Liquid Effluants 13 V. Solid Waste Shipments 17 VI. Changes To ODCM 18 e

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. to-Serialt RNPD/86-3790 Page 3 of 25 I. INTRODUCTION This Effluent and Waste Disposal Report is submitted per Technical Specification 6.9.1.d to the H. B. Robinson Steam Electric Plant - Unit 2 Fccility Operating License No. DPR-23. The data in this report covers the period from January 1 to June 30, 1986, and is the first semiannual report under the full implementation of the Radiological Effluent Technical Specifications (RETS).

The summations of gaseous and liquid effluents are in accordance with the tables in Regulatory Guide 1.21 (Re'v. 1, 6/74) Appendix B. The summations of the solid waste shipments are slightly different but similar to Regulatory Guide 1.21 due to additional reporting requirements by the operating license and 10CFR Part 61.

The values reported for the activity of nuclides released are the actual measured activities. If no activity for a nuclide was detected for a quarter, the reader is referred to the respective Lower Limit of Detection (LLU) Table for that radionuclide. The total of activity released is a total of only the nuclides that had measured activity.

Compliance with 10CFR50, Appendix I'for maximum individual doses is h

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demonstrated by using average meteorology and the methods in the Offsite Dose Calculation Manuaf.

The meteorological data for this report period is on-file in the format of Regulatory Guide 1.21 and is available to the NRC upon request. This data will be sent 60 days after January 1, 1987, with the second semiannual Effluent and Waste Disposal Report for 1986.

There have been no changes to the NRC (May 16, 1986) approved Process Control Program (PCP) and no changes to the radioactive waste systems (liquid, gaseous, or solid) during this report period.

The land use census, conducted May 6, 1986, revealed no new or additional locations that require sampling.

The Radioactive Liquid and Caseous Effluent Monitoring Instrument,ation listed in Tables 3.5-6 and 3.5-7 of the Technical Specifications Amendment No. 85 have not exceeded any of their continuous inoperability requirements.

Revision 1 and Revision 2 of the Offsite Dose Calculation Manual (ODCM) were reviewed and approved by the Plant Nuclear Safety Committee (PNSC) on November 20, 1985 and March 6, 1986, respectively. These changes do not reduce the accuracy or reliability of the dose calculations or setpoint determinations.

Enclosura 1 to S2rialt RNPD/86-3790 Page 4 of 25 II. SUPPLEMENTAL INFORMATION A. Regulato'ry Limits

1. Fission and Activation Cases:

10CFR20 Limits (Instantaneous Release Rate)

Total Body $500 mrem /yr Skin $3000 mrem /yr 10CFR50 Appendix I For Calendar Quarter Gamma Dose $5 mead Beta Dose <10 mrad For Calendar Year Gamma Dose $10 mrad Beta Dose $20 mrad  ;

2. Iodine - 131, 133, Tritium, and Particulates >8 day half-lives:

10CFR50 Limits (Instantaneous Release. Rate)

Inhalation (only) to a child to any organ $1500 mrem /yr 10CRF50 Appendix I For Calendar Quarter <7.5 mrem V

For Calendar Year $15 mrem

3. Liquids:

Concentrations are specified in 10CFR20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2E-4 pCi/ml total activity.

10CFR50 Appendix I For Calendar Quarter Total Body $1.5 mrem Any Organ 15 mrem For Calendar Year i Total Body $3 mrem Any Organ $10 mrem B. Measurements and Approximations of Total Radioactivity

1. Continuous Caseous Releases
a. Fission and Activation Cases - The total activity released is determined from the net count rate of the gaseous monitor, its calibration factor, and the total exhaust tiow. The activity of radiogas is determined by the fraction of that radiogas in the isotopic analysis for that period.

Enclosura 1 to S2rialt RNPD/86-3790 P:gs 5 of 25

b. Iodines - The activity released as iodice-131, 133, and 135 is based on the charcoal cartridge and particulate filter activities and the total vent fic'<.
c. Particulates - The activity released via particulates with half-lives greater than eight days is determined by isotopic analysis of particulate filters and the total vent flow.
d. Tritium - The activity '21 eased as tritium is based on weekly grab sample analysis and total vent flow.
2. Batch Caseous Releases
a. Fission and Activation Cases - The activity released is based on the volume released and the activity of the individual nuclides obtained from an isotopic analysis of the grab sample taken prior to the release.
b. Iodines - The iodines from batch releases are included in the iodine determination from the continuous Auxiliary Building release.

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c. Particulates - The particulates from batch releases are

- included in the particulate determination from the continuous Auxiliary Building release.

d. Tritium - The activity released as tritium is based on the grab sample analysis of each batch and the batch vol ume.

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3. Liquid Releases
a. Fission and Activation Products - The total release values (not including tritium, strontium, Iron-55, and alpha) ate comprised of the sum of the individual radionuclide activities in each batch released to the discharge canal for the respective quarter. These values represent the activity known to be present in the liquid radwaste effluent.
b. Tritium & Alpha - The measured tritium and alpha concentrations in a composite sample are used to calculate the total release and average diluted concentration during each period.
c. Strontium-89, 90, and Iron The total release values are measured quarterly from composite samples.

Encicsura 1 to Sarisit RNPD/86-3790 P gs 6 of 25 i

C. Estimated Total Errors

1. Estimated total errors for gaseous effluents are based on uncertainties in counting equipment calibration, counting statistics, vent flow rates, vent sample flow rates, non-steady releas9 rates, chemical yield factors, and sample losses for such items as charcoal cartridges.
2. Estimated total errors for liquid effluents are based on uncertainties in counting equipment calibration, counting statistics, non-steady release flow rate, chemical yield factors, sampling and mixing losses, and volume determinations.
3. Estimated total errors for solid waste are based on uncertainties in equipment calibration,_ dose rate measurements, geometry, and volume determinations.

III. CASEOUS EFFLUENTS

1. Batch Releases A. Nember of Batch Releases 1.10E+02 - .

B. Total Time Period for Batch Releases 7.40E+04 Min I C. Maximum Time Period for a Batch Release 4.32E+03 Min D. Average Time Period for Batch Releases 5.73E+02 Min E. Minimum Time Period for a Batch Release 2.00E+01 Min

2. Abnormal Releases ,
1. Number of Releases 0
2. Total Activity Released 0 Ci i

Enclosura 1 to Strict: RNPD/86-3790 P:ga 7 of 25 TABLE 1A EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORI - 1986 GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES UNITS IST QUARTER 2ND QUARTER A. Fission and Activation Cases:

l. Total Release Ci 3.03E+02 7.21E+01
2. Estimated Total Error  % 1.10E+02 1.10E+02
3. Average Release Rate for Period pCi/sec 1.93E+01 4.61E00
4. Percent of 10CFR50 Appendix I Quarterly Limit Gamma Air  % 5.86E00 1.07E-01 Beta Air  % 8.34E00 3.59E00 Yearly Limit Gamma Air  % 2.93E00 2.99E00 Beta Air  % 4.17E00 5.96E00 B. Iodines, Particulates, and Tritium:

Iodines

1. Total Iodine - 131 Ci 4.19E-03 7.22E-05
2. Estimated Total Error  % 1.10E+02 1.10E+02..
3. Average Release Rate pCi/sec 2.68E-04 4.62E Particulates
1. Particulates with Half-Lives >8 days Ci 1.76E-04 3.21E-06
2. Estimated Total Error  % 1.00E+02 1.00E+02

! 3. Average Release Rate for Period pCi/sec 1.12E-05 2.05E-07 Gross Alpha Radioactivity

4. Ci <LLD <LLD

! Tritium

1. Total Release Ci 2.15E00 6.81E-01
2. Estimated Total Error  % 9.00E+01 9.00E+01
3. Average Release Rate for Period pCi/sec 1.37E-01 _ 4.36E-02 i

I Percent of 10CFR50 Appendix I Quarterly Limit Organ Thyroid  % 5.16E+01 3.llE-01 Yearly Limit Organ Thyroid  % 2.58E+01 2.60E+01

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  • Cumulative total for the year-to-date.

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Enclosura 1 to Strialt RNPD/86-3790 Page 8'of 25 TABLE IB EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT - 1986 CASEOUS EFFLUENTS - ELEVATED RELEASES All releases at H. B. Robinson are made as ground releases.

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l Enclosura 1 to Sarials RNPD/86-3790 l i' Page 9 of 25 i

TABLE IC.

EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT - 1986 GASEOUS EFFLUENTS GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE UNITS lst QUARTER 2nd QUARTER lst QUARTER 2nd QUARTE:

1. FISSION CASES Ar-41 Ci <LLD <LLD 2.27E-02 7.34E-02

, Kr-85 Ci <LLD 7.15E+01 3.12E-01 6.57E-03

} Kr-85m Ci <LLD <LLD 3.72E-02 6.64E-05 Kr-87 Ci <LLD -

<LLD 4.41E-03 <LLD Kr-88 Ci <LLD <LLD 2.45E-02 <LLD Xe-131m Ci <LLD <LLD 1.84E00 1.75E-03 Xe-133 Ci 1.36E+02 3.16E-01 1,58E+02 1.67E-01 Xe-133m Ci <LLD <LLD 9.08E-01 -

1.92E-03 Xe-135 Ci 3.69E00 <LLD 1.12E00 5.36E-03 Xe-135m Ci <LLD <LLD <LLD <LLD Total for Period Ci 1.40E+02 7.19E+0i 1.63E+02 2.57E-01 4*

2. IODINES g I-131 Ci 4.19E-03 7.22E-05 i I-133 Ci 5.81E-05 8.55E-05 I-135 Ci <LLD <LLD ,

Total for Period Ci 4.25E-03 1.58E-34

,- 3. PARTICULATESg H-3 Ci 6.22E-02 4.35E-01 2.08E00 2.46E-01 l Cr-51 Ci- 1.58E-05 <LLD l Mn-54 Ci <LLD 1.31E-07

co-58 Ci 3.15E-05 1.61E-06 Fe-59 Ci <LLD <LLD Co-60 Ci 4.93E-05 1.04E-06 Zn-65 Ci <LLD <LLD Sr-89 Ci <LLD 2.59E-08 Sr-90 Ci <LLD 9.29E-09 Nb-95 Ci 1.70E-06 <LLD Mo-99 Ci <LLD <LLD Ru-103 Ci <LLD 2.04E-07 j Cs-134 Ci 2.64E-05 <LLD Cs-137 Ci 5.05E-05 1.86E-07 Ba/La-140 Ci <LLD <LLD Ce-141 Ci <LLD <LLD Ce-144 Ci <LLD <LLD Cross Alpha Ci <LLD <LLD Total for Period Ci 6.24E-02 4.35E-01 2.08E00 2.46E-0 gC ontinuous Accountability includes Batch Accountability (excludes H-3).

Enclosura 1 to Sarialt RNPD/86-3790 Page 10 of 25 TYPICAL LOWER LIMIT OF DETECTION TABLE FOR CASEGUS EFFLUENTS Nuclide LLD (uCi/cc)

H-3 1.00E-06 Ar-41 2.00E-06 Cr-51 1.40E-13 Mr-54 , 1.00E-Il Co-58 1.00E-ll Fe-59 1.00E-11 Co-60 1.00E-11 Zn-65 1.00E-ll Kr-85 8.90E-05 Kr-87 1.00E-04 Kr-88 1.00E-04 Sr-89 ,1.00E-11 Sr-90 1.00E-11 Nb-95 3.70E-14 Mo-99 1.00E-ll Ru-103 3.00E-13 I-131 1.00E-12 I-133 '

1.00E-10 Xe-133 1.00E-04 $

Xe-133m 1.00E-04 '

Cs-134 1.00E-ll Xe-135 1.00E-04 Xe-135m 9.30E-05 Cs-137 1.00E-11 Xe-138 1.00E-04 Ba/La-140 1.00E-13 -

Ce-141 1.00E-11 Ce-144 1.00E-ll Cross Alpha 1.00E-Il t

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Enclocura 1 to Saris 1: RNPD/86-3790 Page 11 of 25 IV. LIQUID EFFLUENTS

1. Batch Releases A. Number of Batch Releases 1.38E+02 B. Total Time Period for Batch Releases 3.05E+04 Min C. Maximum Time Period for-a Batch Release 9.00E+02 Min D. Average Time Period for Batch Releases 2.21E+02 Min E. Minimum Time Period for a Batch Release 3.00E+0lMin F. Average Stream Flow During Release Periods 2.09E+05GPM s
2. Abnormal Releases A. Number of Releases O B. Total Activity aeleased 0 Ci

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Enclosura 1 to S2 rials RNPD/86-3790 P ga 12 of 25 I

TABLE 2A EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT - 1986 LIQUID EFFLUENTS - SUFMATION OF ALL RELEASES UNITS ist QUARTER 2nd QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. Total Releases Ci 1.36E-01 2.08E-02
2. Total Estimated Error  % 1.00E+02 1.00E+02
3. Average Diluted Concentration pCi/ml 6.57E-09 2.50E-09 B. TRITIUM
1. Total Release ci 4.04E+01 1.71E+01
2. Estimated Total Error  % 4.00E+01 4.00E+01
3. Average Diluted Concentration pCi/ml 1.95E-06 2.06E-06 C. DISSOLVED AND ENTRAINED CASES
1. Total Release Ci 9.75E-03 <LLD -2
2. Estimated Total Error  % 1.00E+02 1.00E+02
3. Average Diluted Concentration pCi/ml 4.70E-10 <LLD D. CROSS ALPHA RADIOACTIVITY
1. Total Release Ci <LLD <LLD
2. Estimated Total Error  % 1.00E+02 1.00E+02 ~

E. VOLUME OF WASTE RELEASED Liters 1.84E+07 8.97E+05 F. VOLUME OF DILUTION WATER Liters 2.07E+10 8.33E+09 C. PERCENT OF 10CFR50 APPENDIX I Quarterly Limit Organ Liver  % 5.59E00 7.37E-01 Total Body  % 1.33E+01 1.79E00 Yearly Limit Organ Liver  % 2.80E00 3.17E00

  • Total Body  % 6.66E00 7.55E00 *
  • Cumulative total for the year-to-date.

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Enclosura 1 to Sarielt RNPD/86-3790 Page 13 of 25 TABLE 2B EFFLUENT AND WASTE DISPOSAL SEMIANNUAL PEPORT - 1986 LIQUID EFFLUENIS CONTINUOUS MODE BATCH MODE NUCLIDES UNITS ist QUARTER 2nd QUARTER lst QUARTER 2nd QUARTER RELEASED H-3 Ci <LLD <LLD 4.04E+01 1.71E+01 Na-24 Ci <LLD <LLD 1.15E-04 <LLD Cr-51 Ci <LLD <LLD 3.97E-03 5.02E-04 Mn-54 Ci <LLD <LLD 6.54E-04 2.33E-04 Fe-55 Ci <LLD <LLD 3.34E-03 <LLD Fe-59 Ci <LLD <LLD 1.96E-05 1.20E-05 Co-57 Ci 1.32E-04 1.59E-05 Co-58 Ci 2.67E-03 <LLD 5.99E-02 9.82E-03 Co-60 Ci <LLD <LLD 3.63E-02 4.03E-03 Zn-65 Ci <LLD <LLD 2.70E-05 1.74E-05 Sr-89 Ci <LLD <LLD 2.60E-05 3.74E-06 Sr-90 Ci <LLD <LLD <LLD <LLD Sr-92 Ci '

3.00E-04 1.57E-04

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Zr-95 Ci <LLD <LLD 1.41E-04 4.32E'-05 Nb-95 Ci <LLD <LLD 6.23E-04 1.89E-04 Nb-97 Ci <LLD <LLD 3.36E-04 <LLD Tc-99m Ci <LLD <LLD <LLD <LLD Mo-99 Ci <LLD <LLD <LLD <LLD Ag-110m Ci 7.09E-04 1.48E-04 Sb-124 Ci 1.26E-C2 2.23E-04 I-131 Ci 6.71E-06 <LLD 5.90E-04 2.30E-05 Cs-134 Ci <LLD <LLD 3.79E-03 2.00E-03 Cs-137 Ci <LLD <LLD 9.62E-03 3.38E-03 Ba/La-140 Ci <LLD <LLD <LLD <LLD Ce-141 Ci <LLD <LLD <LLD <LLD l Ce-144 Ci <LLD <LLD <LLD <LLD l

Total Ci 2.68E-03 <LLD 4.05E+01 1.71E+01 l Xe-133 Ci 1.40E-05 <LLD 9.68E-03 <LLD Xe-133m Ci <LLD <LLD 7.56E-06 <LLD Xe-135 Ci <LLD <LLD 5.73E-05 <LLD 1

Total Ci 1.40E-05 <LLD 9.75E-03 <LLD l

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I Enclosure 1 to Ssrimit RNPD/86-3790 Page 14 of 25 -

TYPICAL LOWER LIMIT OF DETECTION TABLE FOR LIQUID EFFLUENTS NUCLIDE LLD (uCi/ml)

H-3 1.00E-05 Na-24 2.10E-07

. Cr-51 7.10E-06 Mn-54 5.00E-07 Fe-55 1.00E-06 Co-58 ,

5.00E-07 Fe-59 5.00E-07 Co-60 5.00E-07 Zn-65 5.00E-07 Sr-89 5.00E-08 Sr-90 5.00E-08 Nb-95 1.10E-07 Zr-95 ,

2.00E-07 Nb-97 3.00E-07 Mo-99 5.00E-07 Tc-99m 6.60E-08 I-131 1.00E-06 Xe-133 1.00E-05 Xe-133m 1.00E-05 4*

Cs-134 5.00E-07

! Xe-135 1.00E-05 i Cs-137 5.00E-07 Ba/La-140 2.40E-07 Ce-141 5.00E-07 Ce-144 5.00E-07 Cross Alpha 1.00E-07 i

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Enclosura 1 to Strici: RNPD/86-3790 Page 15 of 25 V. SOLID WASTE AND IRRADIATED FUEL SHIPMENTS REPORT TIME PERIOD JANUARY I TO JUNE 30 YEAR 1986 A, SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (not irradiated fuel)

WASTE CLASS A ,

1. Type of waste Unit 6-month Est. Total Solid. Cent. Form No.

Period Error % Agent Type Ship,

a. Spent resins, filter' sludges, evaporator m# 1.78E+02 Dewatered bottoms, etc. CI 7.33E+01 6.50E+01 cement HIC,STP Solidified 19
b. Dry compressible waste, contaminated m' 1.28E+02 Compacted equip, etc. Cl 2.20E+01 6.50E+01 NA STP Uncompacted 7
c. Irradiated components, control m' O.00E00 rods, etc. Cl 0.00E00 NA NA NA NA NA
d. Other (describe) m# 0.00E00 Ci 0.00E00 NA NA NA NA NA
2. Estimate of major nuclide composition (by type of waste) 3. Solid Waste Olsposition Nuclide Ci
s. Co-58 13.351 9.78E00 Number of Shipments *** 24 j Co-60 32.331 2.37E+01 Mode of Transportation Sole Use Vehicle Cr-51 1.581 1.17E00 Destination Barnwell, S.C.

Cs-134 2.375 1.74E00 Cs-137 3.995 2.92E00 Sb-124 1.455 1.06E00 Fe-55 22.315 1.63E+01 B. IRRADIATED FUEL SHIPMENTS (Disposition)

Ni-63' 8.045 5.89E00 H-3 11.815 8.65E00 Number of Shipments 0 Others' 2.771 2.03E00 Mode of Transportation NA Destination NA

b. Co-53 4.785 1.05E00 Co-60 4.261 9.39E-01 Cs-134 6.185 1.36E00 Cs-137 7.595 1.68E00 Fe-55 68.215 1.50E+01 NI-63 3.575 7.87E-01 H-3 4.065 8.95E-01 Others ** 1.255 2.98E-01
  1. Others incaude: Ag-110m, Co-57, Mn-54, 1-131, Kb-95, Sb-125, Sr-89, Pu-241, C-14, Te-125m, X2-131m, Fe -59,- Cs-136, Sr-90, Cm-242, Xe-133, Zr-95, Zn-65, Sn-113, Tc-99, Ce-141, Ce-144, Pu-238, Pu-23'!, /m-241, Cm-244, 1-129.
    • Others include: Ag-110s, Co-57, Cr-51, Mn-54, 1-131, Nb-95, Sb-124, Sb-125, Sr-89, C-14, Ts-125m, Xe-131m, Fe-59, Sn-113, Zr-95.
  1. Se The sum of the number of shipments in Section 1 does not equal the number of shipments in Section 3, due to two mixed waste shipments.

to Sarialt RNPD/86-3790 Page 16 of 27 VI. CHANCES TO ODCM PACE NO. COHMENTS FOR CHANCES IN ODCM REV. 1 Page i Repagination of Section 3.3 and added the existing Section 6.5 to the Table of Contents.

Page ii Repagination of Tables 3.2-1, 3.2-2, 3.2-3, and 3.2-4.

Page iv Repagination of Figures 4-1 and 4-2.

Page 1-1 The ODCM based on NUREG-0472, Revision 3, Draft 6, has been changed to NUREG-0472, Revision 3, Draft 7, as per guidance received from the NRC October 4, 1984. Monitor setpoints have been changed from standing orders (Standing Order Number 4) to the Plant Operating Procedures (OHM-014).

Subsequently, the ODCM reflects this change in Section 1.0.

Page 2-1 and Editorial change, " procedure" to " methodology" in first Page 3-1 sentence.

Page 2-2 In response to EC&C/NRC comment dated October, 1983, the value of 1.0E-7 pCi/ml for an unknown mix has been changed to the  !

most conservative MPC of the radionuclides to this path and

" visible" to RMS-18, RM-19, and RMS-37. The worst case assumption is that I-131 is the only nuclide being discharged. This is appropriate according to Footnote 3a of 10CFR20, Appendix B.

Page 2-3 Steam generator blowdown flow rates have increased, and an additional potential release pathway has'been added (Condensate Polisher Liquid Waste) as a result of the Steam Generator Replacement outage. This also changed the liquid discharge allocation fractions.

Page 2-4 Additional clarification has been added to define the term Ci (added non gam'ma emitters) in Section 2.1.2.1. This compliments the Nuclear Data Effluent Management software programs and 10CFR20. Added Condensate Polisher Liquid Waste Monitor (RMS-37) to Section 2.1.2.

Page 2-5 and Flow rates of Steam Generator Blowdown and Condensate Polisher Page 2-14 Liquid Waste have been added to Section 2.1.2.3 and 2.2.1, respectively. See page 2-3 for justification.

Page 2-6 Corrected minor typographical error. Allocation has been changed for Steam Generator Blowdown and new fraction added for Concensate Polisher Liquid Waste. See Page 2-3 for justification.

Page 2-11 Methodology to base monitor setpoint on I-131 was included in Section 2.2.1. See page 2-2 for justification.

. to Ssriels RNPD/86-3790 Page 17 of 27

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L Page 2 (1) Page 2-12 requires no change in response to EC&G's/NRC i 4 Page 2-18 coment s . Concentrations are to be compared to 10CFR20. In - 's Section 2.2, it is both implied aad understood that pre and post-release concentrations must be compared to 10CFR20, Appendix B, Table II, and Column 2 in order to determine ~ ~ /

whether HBR is in compliance. Furthermore, this is stated on' s page 3-13 in the pre-release section. For the sake of clarity,,

it is also added in the post-release section (page 2-16). m (2) Equation (2.3-1) the cogeEti n fact r f r the transit time r for radionuclide decay (e i p) has been removed to be compatible with the Nuclear Data software. This is more conservative, simpler, and follows the guidance of NUREC-0135 4 , ,

instead of Reg. Guide 1.109. 't g Page 2-20 In response to EC&G comments, the 31 day dose projection ,!< '

methodology was clarified.

Page 2-24 Table 2.3-2 " Values of e - i'p for liquid dose calculations" '

has been deleted. Sec page 2-16 for justification.

Page 3-3 and The typo has been deleted in paragraph 3.1.1.5 as per EC&C/NRC Page 3-4 cor::ments. The fuel handling building flow rate has been added  ;

in Sec'tien 3.1.1.4, since it is a potential release pathway.

Page 3-6 AP'has been changed to AP c

. TC has been changed to Tt . 0*C =

273*K has been added as per EG&G/NRC comments.

I Correction for K* has been provided in the respective procedures used for calculation of the flow rates from containment and from the gas decay tanks.

Page 3-7 Formula for "C" has been changed for clarity as per EC&C/NRC g J

, comments to:

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fl C = C; (pCi/cc) x monitor efficiency (cpm /pci/cc) =} cpm F

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Page 3-10 Table 3.1-1, " Caseous Scurce. Terms," Condenser Vacuum' Pump Vent 'l had two typographical errors: Xe - 133 = 1.8E + 1 Ci/yr, not a

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r 1.8E-1 Ci/yr and Xe-135 = 2.0E + 1 Ci/yr, not 2.0E-1 Ci/yr s

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Page 3-2 and Sample analys;is has been added in Section 3.1.1.1 (page 3-2) .s 3-13 and page 3-13 to be used as source terms in monitor setpoint '

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calculations and dose rate calculations. Typo "n" has been s corrected to "in". These changes were in response to EC&C/NRC N comments.

Page 3-14 and Section 3.2.2 has been revised to cover the inh'alation H 3-15 pathway only. This is in response to EC&C/NRC comments and is consistent with Technical Specificacions. .N

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Enclosura 1 to Ssrialti RNPD/86-3790 Page 18 of 27 ',

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, i Page 3-16 The responsej r.o EC E/N3C relative to Table 3.2-1 is that, as N

i.ndicated by che faotnote, the source was determined by the CALE code. ,

, i Page 3-19 *Ihe Fi + valyes listed in Table 3.2-4 are not necessarily meant to'be exhaustive but representative of the radionuclides isually observed ik releases and usually expected based on

) Source Terms.f Should other radionuclides be observed, the data from Reg. Guide 1.109 will be used to establish dose factors for these radionuclides.

' 1 Page 3-21 In response to EGEC'/NRC 2ditorial changes have been made as s follows "for harposes of this document, only long-term R/Q t y values wi'll be used since this is a more conservative approach

'l than usin'g short-term R/Q values for dose estimation. Should J E the calculated' dose exceed 10CFR50 limits, recalculation of

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-dose may be performed using 'short-term E/Q values for batch'

-l releases."

{ s p'ge3-22 D, has been revised t pg 'as per EC&C/NRC comments.

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g Page 3-23 InresponsetoEC&C/NRC,[statementhasbeenincludedwhich

) describes how dose projections will be perfor' mad and when the i gaseous radwaste treatment system will be operated.

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In response to EC&C/NEC, a olus ("+") has beenjinserted in

,' Pa,p f 3-25, 3-26,- ' Equation 3.3-8 and>has been expanded to include milk and meat

. & 3-27 pathways, and the new* tern.t have been defined t

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- !, Page 3-28 In response to EC&G/NRC, it is pr/eferred to leave the grazing i r period as based on YJREC ,0133 in the text of the ODCM.

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j gaseous radwaste treatment system will be operated.,

- ? Page 4-2, Editorial added the compass degrees to the first seven sample

,f 4-3, & 4-9 stations and relocated sample Station 7 one mile further out

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because the existing location is no longer available for our use. Station 7 also relocated on map on page 4-9.

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Enclosura 1 to Ssricit RNPD/86-3790 Page 19 of 27 Page 4-6 In response to EC&C/NRC, li-3 analysis is performed monthly rather than quarterly since H-3 levels are usually much higher than the LLD, and the Plant wishes to monitor H-3 more closely in both surface and ground water. In addition, an editorial change was made in Section b, groundwater. Each unit has more.

than one well, and only one well is generally used at a time.

Sampling will be performed only on the operating well.

Page 4-7 In response to EC&C/NRC, the frequency for sampling fish has been changed to semiannually. Also, the control location for fish has two ponds to choose from due to drainage. of May Lake for dam repairs which resulted in a major fish kill. Food products (leafy vegetables) location numbers were changed.

Auburndale Plantation's Milk and a milk control station were added.

, Page 4-8 Changed Footnote 8 due to Land-Use census.

Page 6-1, In response to EC&C/NRC comments, the following changes were 6-2, & 6-3 made: 6.2.(1) Actual doses will be utilized rather than assuming the dose to be < 1 mrem /yr since the actual dose data will be readily available; 6.2.(4) The intent in this section is not to be conservative but to make an approximation  ?

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of the real dose to a MEMBER OF THE PUBLIC as realistically as possible.

Also added headers to 6.1 and 6.2 for consistency.

Some of the verbiage from 6-1 carried over to 6-2 as a result of adding headers to page 6-1 and, likewise, with page 6-2 to page 6-3.

Page A-4 Title had typo (sec/cm3); changed to (sec/m3 ),

Page A-5 Title had typo (sec/cm3); changed to (sec/m3 ),

Page A-7 Title had typo (sec/cm3); changed to (sec/m3 ).

Page A-8 Title had typo (sec/cm3); changed to (sec/m3 ),

Page A-21 Title had typo (m2-); changed to (m-2),

Page B-11 Ri has been changed to Ri B, and F,has been changed m

i to Fg as per EC&G/NRC comments.

Page B-12 F,has been changed to Fg as pt EC&C/NRC comments.

Enclosura 1 to Ssricli RNPD/86-3790 Page 20 of 27 i Page 8-13  : A plus ("+") has been inserted in Equation B.2-7 as per EC&C/NRC conunents.

Page D-1 Added Condensate Polisher Liquid Waste Monitor. See page 2-3 for additional justification.

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Enclosura 1 to Ssriait RNPD/86-3790 Page 21 of 27 JUSTIFICATION FOR CHANGE IN ODCM REVISION 2 Prior to implementing the Caseous portion of the Radiologic 31 Effluent Technical Specification, the setpoint Section (3.1) of the ODCM was upgraded and additional clarification made as follows:

A. All batch releases are to be sampled and analyzed for setpoint source term calculations.

B. All continuous releases have the following source term setpoint options:

1. Using a conservative Cale Code distribution.
2. Using detectable nuclide distribution from the sample analysis.
3. Using the calculated LLD values for Xe-133 and Kr-85.

C. The R-14 setpoint calculations (monitors Plant vent and isolates releases from Waste Gas Decay Tanks) in Revision 1 of the ODCM did not take into account dilution (60,000 cfm) from the Plant vent. Therefore, a revision was made to calculate R-14 setpoint using the weighted average concentration based on maximum flow rates.

D. The monitors RMS-11 and RMS-12 (particulate and noble gas monitors) ,

provide isolation for CV Pressure Reliefs and Purges. These monitors i can sample from the Containment Vessel or the Plant Vent. The ODCM was revised to calculate weighted average concentrations for RMS-ll, RMS-12, and RMS-14 setpoint determinations based on their respective source terms and flow rate.

E. The concept of PDRR (Projected Dose Rate Ratio) was incorporated in the calculation of setpoints and release rates. This is consistent with algorithm used in vendor software.

F. The statistical variance in the background count rate on gaseous effluent monitors was included in the high/ trip alarm setpo nts to prevent inadvertent high/ trip alarms due to the. random counts on the monitors.

C. Ten R i tables were added to the ODCM (all age groups) for gracs-cow-milk, grass-cow-meat, and vegetation pathways consistent with the guidance in NUREC-0133 and vendor software.

H. The algorithm for converting the monitor setpoint from pCi/cc to cpm was revised to accept non-linear monitor efficiency relationships.

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l Ecclosura 1 to Sarials RNPb/86-3790 Page 22'of 27 l

PACE NO. COMMENTS FOR CHANCES IN ODCM REVISION 2 i

Title Page Changed Revision 1 to Revision 2 and changed date.

l i Added Section 3.4 to Table of Contents.

1 ii Added ingestion dose R factors to List of Tables 3.4-1 through 3.4-10. (See justification C.)

3-1 Minor editorial changes; added RMS-20 in Section 3.1.1 as an additional potential release pathway, reference to use of l Cale Code when determining high-alarm setpoint for gas monitors RMS-14, RMS-15, RMS-20; removed batch release of

containment parge via the Plant Vent, batch release for t containment pressure. relief via the Plant Vent, and batch release of Waste Gas Decay Tanks via the Plant Vent. (See justifications A, B, C, & D.)

3-2 . Removed 3.1.1.la determination of source term since , ale Code is used for source term in calculating the rate in Section 3.1.1 for average X/Q values for batch ground releases and for batch mixed mode releases in Section 3.1.1.2. (See justifications A & B.) 1 1 3-3 Maximum concentration calculation modified to include j

Engineering safety factor 0.5.

3-4 Revised airflow in fuel handling building.from 10,800 CFM to <

10,200 CFM as referenced in the system description; added definition of SF in Equation'3.1-4. Modified Equation i

3.1-6. (See justifications F.)

j 3-5 Added definition of statistical variance; modified Equations 3.1-4 and 3.1-6; minor editorial change; added four additional operational conditions when determining high alarm setpoint'with prior sample analysis and maximum acceptable flow rate; and added Equation 3.1-7. (See justification parts A, E, & F.)

3-6 & Revised Ci definition.

(See justifications C & D.)

4 3-7 3-8 Maximum flow rates (f) for all pathways were re-evaluated and upgraded; revised Section 3.1.2.2 to include calculation of skin dose rate and monitor setpoints. (See justifications C & D.)

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Enclosure 1 to Sarial: RNPD/86-3790 Page 23 of 27.

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4 3-9 Defined (2/Q) values in Equation 3.1-8 for continuous mixed mode release and continuous ground release. (See justifications A and B.)

3-10 Defined Equations 3.1-10 and 3.1-11 to determine projected dose rate ratio for total body and skin; defined Equation

1. 3.1-12 and 3.1-13 to determine the maximum monitor setpoint concentration for total body and skin; replaced Section 3.1.2.3, " Determine the monitor alarm setpoint based on the skin dose rate," with Section 3.1.2.2.e, " Determine the maximum monitor setpoint for total body and skin." (See justification E.)

4 ' 3-11 Provided Plant specific ~ values for Tm as used in Equations 3.1-12 and 3.1-13; added Section 3.1.2.2.e, " Determine the maximum monitor setpoint for total body and skin" and included term for monitor statistical variance. (See justification F.)

Page 3-12 Defined terms in-Equations 3.1-14 and 3.1-15. (See justification F and H.)

Page 3-13 Caseous scarce terms, changed Xe-135 value from 2.0E+1 to a 2.0E+0. . . Typo. Footnote 1 - deleted reference to RMS-20. . . Plant vent release. . . values are used to determine the monitor alarm setpoints for the Plant vent gas monitor. Footnote 3 - added to. values for gas decay tanks -

"these values are used to determine the monitor alarm i setpoint for the fuel handling basement exhaust monitor j (RMS-20)." >

Page 3-17 Editorial change.

Added "and tritium" to heading of section describing dose rate equation - consistent with Technical Specifications.

Page 3-26 Added projemted dose from this release "DB" to 31 day dose i projection in Equation 3.3-7.

Page 3-27 Corrected typo.

Page 3-32 Added projected dose from this release "DB" to 31 day dose projection in Equation 3.3-11.

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Page 3 ; Page 3-52 Added reference to Reg. Guide 1.109 to tables.

! (See justification C.)

Page 3-53 Added ingestion dose R factors grass-cow-milk pathway (infant). (See justification C.)

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Enclosura 1 to Sarisit RNPD/86-3790 Page 24 of 27 Page 3-54 Added ingestion dose R factors grass-cow-milk pathway (child). (See justificaticn C.) .

Page 3-55 Added ingestion dose R factors grass-cow-milk pathway (teen).

(See justification C.)

Page 3-56 Added ingestion dose R factors grass-cow-milk pathway (adult). (See justification C.)

Page 3-57 Added ingestion dose R factors grass-cow-meat pathway (child). (See justification C.)

Page 3-58 Added ingestion dose R factors grass-cow-meat pathway (teen).

(See justification C.)

Page 3-59 Added ingestion dose R factors grass-cow-meat pathway (adult). (See justification C.)

Page 3-60 Added ingestion dose R factors vegetation pathway (child).

(See justification C.)

  • Page 3-61 Added ingestion dose R factora vegetation pathway (teen). ,

(See justification G.) -

Page 3-62 Added ingestion dose R factors vegetation pathway (adult).

(See justification C.)

Page 4-1 Editorial change.

Page 5-1 Added that results of environmental samr.e analyses comparison program would be included in the annual radiological environmental operating report. Deleted "the results will be provided to the NRC upon request."

Page B-6 Editorial change of Appendix B.2 Title by adding "Following Reg. Guide 1.109 Methodology" for calculation of Rt .

(Justification: added reference.)

Added (in description) to include reference to 1.109.

(Justification: added reference.)

Page B-18 Added " calculation of R following NUREC-0133 methodology."

(See justification C.) t Page B-19 Added grass-cow-milk pathway. .

(See justifica' tion C.)

Page B-20 Added grass-cow-meat pathway.

(See justification C.)

Enclosura 1 to Smrials RNPD/86-3790 Page 25 of 27 Page B-21 Added vegetation pathway.

(See justification C.)

Page B-22 Provided documentation of maximum flow rate of CV pressure relief as provided by CP&L Nuclear Fuels Section. '

(See justification D.)

Page 2-20 Equation 2.3-8, added " projected dose for the current release to the total projected dose for previous releases." Define term "DB". (Justification: DB definition was inadvertently omitted.)

Page 3 Page 3-65 Added section 3.4 describing the setpoint methodology for RMS-il. (See justification D.)

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