ML20212K425

Suppl to App D to Evaluation of Licensee-Reported Revs to Offsite Dose Calculation Manual, Technical Evaluation Rept

ML20212K425
Person / Time
Site:	FitzPatrick
Issue date:	08/14/1986
From:	CALSPAN CORP.
To:	NRC
Shared Package
ML20210T308	List: ML20210T302 ML20210T310 ML20212K425
References
TER-C5506-591, TER-C5506-591-APP-D, NUDOCS 8608220052
Download: ML20212K425 (12)

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EVALUATION OF LICENSEE-RETORTED REVISICHS TO ODCM f

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[ g FRANKLIN RESEARCH CENTER OlV153ON OF ARVIN/CALSPAN 25L #- "'"^c'55'"^*"'^5

a TER-C5506-591 D.I. EVALUATION OF LICENSEE-REPORTED REVISIONS TO ODCM The Licensee has made several changes to the existing ODCM that was submitted by the Licensee on October 26, 1983 and approved by NRC on May 29, 1985.* These changes appeared in a complete, revised ODCM (Rev. 2) submitted in the Semiannual Radioactive Effluent Release Report as issued by the Licensee in the second 6 months of 1985: no changes were made to the ODCM by the Licensee in the first 6 months of 1985 or during 1984. This revised ODCM has been approved internally by the Licensee's Plant Operating Review

Committee (PORC) en June 28, 1985.

It is this ODCM (Rev. 2, dated June 25, 1985) that has been reviewed for this report. The result of the evaluation is intended to be a stand-alone

-[ document, and is given in the following attachment as Supplement to Appendix D.

D.2. EVALUATION OF LICENSEE-REPORTED REVISIONS TO PCP The Licensee has not made any changes to the PCP that was submitted by the Licensee on April 23, 1985 (Rev. O of April 17, 1985) and approved by NRC on May 29, 1985.* Since there were no changes made to the PCP in the Semiannual Radioactive Effluent Release Reports as submitted by the Licensee i;

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for 1984 and 1985, the existing PCP remained in effect through December 31,

!- 1985 for this review.

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• Letter from H. I. Abelson (NRC/DL) to J. P. Bayne (NPYA), May 29, 1985.

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I SUPPLEMENT ,

. TO APPENDIX D 1

EVALUATION OF LICENSEE-REPORTED REVISIONS TO ODCM I

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[- DM580N OF ARVIN/CALSPAN 20th & RACE STRFETS, PHILADELPHIA.PA 19103

TER-C5506-591

1. INTRODUCTION 1.1 PURPOSE OF REVIEW The purpose of this document is to review and evaluate revisions or updates made to the FitzPatrick Offsite Dose Calculation Manual (ODCM) through December 31, 1985, as reported in the Licensee's Semiannual Radioactive Effluent Release Reports. These changes update the Licensee's ODCM from the one originally submitted on October 26, 1983 [1] and subsequently approved by the NRC by letter dated May 29, 1985 [2].

The ODCM is a supplementary document for implementing the Radiological f Technical Specifications (REIS) in compliance with 10CFR50, Appendix I requirements [3].

1.2 SCOPE OF REVIEW As specified in NUREG-0472 [4] and NUREG-0473 [5], the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the effluent system.

As a minimum, the ODCM should provide equations and methodology for the following topics:

o alarm and trip setpoint on effluent instrumentation o liquid effluent concentration in unrestricted areas o gaseous effluent dose rate at or beyond the site boundary o liquid and gaseous effluent dose contributions T o liquid and gaseous effluent dose projections.

k In addition, the ODCM should contain flow diagrams, consistent with the

[ systems being used at the station, defining the treatment paths and the y components of the radioactive liquid, gaseous, and solid waste management systems. A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

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1.3 PLANT-SPECIFIC BACKGROUND On behalf of James A. FitzPatrick Nuclear Power Plant, the New York Power Authority submitted changes to the existing ODCM [1] in the Semiannual he

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TER-C5506-591 Radioactive Effluent Release Reports issued by the Licensee. The Licensee -

issued Revision 2 of the ODCM in the second 6 months of 1985 [9). No changes were made by the Licensee in 1984 [6, 7) and in the first 6 months of 1985 .

[8).

The Licensee's Semiannual Reports and the changes of the ODCN were q transmitted to an independent review team at the Franklin Research Center (FRC) for review. The review was subsequently conducted by FRC, and the results and conclusions of the ODCM evaluation are presented in Sections 3 and 4 of this document.

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2. REVIEW N TERIA Review criteria for the ODCM were provided by the NRC in three documents:

NUREG-0472 [4), RETS for PWRs NUREG-0473 [5), RETS for BWRs NUREG-0133 [11), Preparation of RETS for Nuclear Power Plants.

In the ODCM review, the following NRC guidelines are used: " General 3 Contents of the Offsite Dose Calculation Manual," Revision 1 [10), and NUREG-0133 [11). Regulatory Guide 1.109 [12) also provides technical guidance for the review. The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.

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3. EVALUATION i

The Licensee has followed the methodology of NUREG-0133 (11] to determine the alarm and trip setpoints for the liquid and gaseous effluent monitors, which ensures that the maximum permissible concentrations (MPC), as specified in 10CFR20, will not be exceeded by discharges from various liquid or gaseous release points. To augment conservatism in the case of simultaneous releases, the Licensee has introduced conservative safety factors for liquid and gaseous effluent setpoint calculations. The Licensee's method for setpoint calculations meets the guidelines of NUREG-0133. However, for the stack monitor setpoint, the Licensee has not considered the dose rate component from elevated finite plume for the calculation.

The Licensee demonstrated the method of calculating the radioactive liquid concentration by describing in the ODCM the means of collecting and analyzing representative samples prior to and after releasing liquid effluents into the circulating water discharge. The method provides for added assurance of compliance with 10CFR20 for liquid effluent releases, and thus satisfies the guidance specified by NUREG-0133.

Methods are also included for showing that dose rates at or beyond the l

site boundary due to noble gases, iodine-131, iodine-133, tritium, and particulates with half-lives greater than B days are in compliance with 10CFR20. In this calculation, the Licensee has considered effluent releases from the elevated stack for condenser offgas releases and ground-level vent for the combined discharges of the reactor building, turbine building, radwaste building, and refuel floor vent. The Licensee has made a commitment to use the highest annual average values of relative concentration (X/Q) and relative deposition (D/Q) to determine the controlling locations. The revised values for (X/Q) at the site boundary are 2.97 x 10 (sec/m ) at the

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north sector for ground-level releases, and 3.8 x 10-0 (sec/m ) at the east sector for the elevated releases. However, the Licensee again has not considered the component of elevated finite plume for dose rate calculation.

The Licensee, however, has cited different (X/Q) values in Equations 4.4 and 4.5 of the submittal. u r '

The Licensee intends to use the maximally exposed individual and the critical organ as the reference receptor. The Licensee has considered the path-D-6

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TER-C5506-591 way from inhalation. The Licensee has demonstrated that the described methods and relevant parameters have followed the conservative approaches provided by NUREG-0133 and Regulatory Guide 1.109 for gaseous effluent dose rate calcula-I tions. The Licensee, however, has not provided a method to estimate the release of iodine-133, an isotope included in Licensee's newly implemented Technical Specification 3.2 (which went into effect on July 1, 1985).

Evaluation of the cumulative dose is to ensure that the quarterly and 5 annual dose design objectives specified in RETS are not exceeded.

For liquid releases, the Licensee has identified several pathways, includ-E ing potable water and fish consumption, as the viable pathways. In the calcu-lation, the Licensee has provided tables containing dose conversion factors for various pathways and for all age groups. As in the case of dose rate calcula-tion, the Licensee has used the maximally exposed individual as the reference receptor. To correctly assess the cumulative dose, the Licensee intends to estimate the dose once per 31 days. These approaches to liquid dose'calcula-tions satisfy the guidance specified by NUREG-0133. However, one discrepancy was found in the Licensee's approach to liquid dose calculations:

o Although the Licensee stated that the method was based on NUREG-0133, I the methodology for dosas from several pathways, such as swimming, boating, and shoreline deposit, is not contained in NUREG-0133.

Thus, the Licensee should provide equations for all the pathways used.

Evaluation of the cumulative dose from noble gas releases includes both

' beta and gamma and air doses at and beyond the site boundary. The critical organs under consideration are the total body and skin for gamma and beta

$ radiation, respectively. Again, discrepancies were found in the (X/Q) values t used by the Licensee. Also, the Licensee has not considered the component from the elevated stack plume in assessing the noble gas exposures.

II . For iodine-131, iodine-133, tritium, and particulates with half-lives greater than 8 days, the Licensee has provided a method to demonstrate that

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} cumulative doses calculated from the release meet both quarterly and annual design objectives. The Licensee has demonstrated a method of calculating the Y dose using maximum annual average (X/Q) values for the inhalation pathway and

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, has included (D/Q) values for the food and ground-plane pathways. The Licensee's approaches are consistent with the methodology of NUREG-0133.

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TER-C5506-591 The Licensee has demonstrated a procedure to project the monthly dose and to ensure that the design objectives for the liquid radwaste system and the ventilation exhaust system are not exceeded, as specified by the Licensee's Technical Specifications 2.4 and 3.6, respectively.

Adequate flow diagrams. defining the effluent paths and components of the .

radioactive liquid and gaseous waste treatment systems have been provided by the Licensee. Radiation monitors specified in the Licensee-submitted RETS are also properly identified in the flow diagrams. The information provided by the Licensee has satisfactorily met the guidance of NUREG-0133.

The Licensee has provided a description of the revised sampling locations in the ODCM and has identified them in Table H-1 and in Figures H-1 and H-2 of the revised versions. Discrepancies in sample locations were found in the Licensee's Table H-1, on comparison with the locations provided in the ODCM submittal of Nine Mile Point Unit 2.* The discrepancies include fewer sample locations for the FitzPatrick plant, missing identifications for some collec-tion sites, and variations in the descriptions of sample locations (distance and direction). In addition, the legibility of these maps should be improved.

The Licensee has provided a method to demonstrate compliance with the total dose (40CFR190) requirement, including direct radiation from the uranium fuel cycle sources, as specified by the Licensee's Technical Specification 5.0.

In summary, the Licensee's ODCM and the revised changes use documented and approved methods that are generally consistent with the methodology and guidance in NUREG-0133, and therefore is an acceptable reference.

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• The FitzPatrick plant is located at the same site as Nine Mile Foint Units 1 and 2.

l The environmental sampling programs, by agreement between the respec- l tive licensees, are meant to be identical for these plants.

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4. CONCLUSIONS The Licensee's Revision 2 (dated June 25, 1985) to the existing Offsite Dose Calculation Manual [1], as submitted by the Licensee in the existing Semiannual Radioactive Effluent Release Reports for the period of January 1, 1984 through December 31, 1985, uses documented and approved methods and is consistent with the criteria of NUREG-0133, except for the following discrepancies:

o The Licensee has not considered the elevated noble gas plume release

[ from the stack for calculation of the following subjects: gaseous

[ setpoint for stack monitor, noble gas dose rate, and noble gas cumulative air dose at the site boundary.

f o The Licensee's Table M-1 of Appendix C indicates that the maximum (X/Q) values are 2.9 x 10-7 (sec/m3 ) at the northern sector (225 m) for the ground-level releases and 3.8 x 10-8 (sec/m3 ) at the I eastern sector (950 m) for the elevated releases. In several places of the submittal, such as Equations 4.4 and 4.5, the Licensee, however, cites different values for maximum (X/Q).

o Although the Licensee has provided data for liquid pathways, such as swimming, boating, and shoreline deposit, that are not considered in 3 NUREG-0133, the Licensee did not provide a methodology for the derivation of these data.

o The Licensee's Technical Specification 3.2 for gaseous dose rates has

[ included iodine-133 for dose determination. Since iodire-133 is not 3 included in the Licensee's gaseous waste sampling and analysis program (Table 3.2-1 of Licensee's RETS), a method should be provided in the ODCM to estimate the release of iodine-133. This method is I currently not included in the Licensee's submittal.

o The Licensee's environmental sample locations described in Table H-1 (E of the submittal are found to be inconsistent with those submitted by Nine Mile Point Unit 2. Not only did the Licensee's submittal contain fewer locations, but also some of the locations are not identified, and the precise descriptions (direction and distance) for the locations also differ.

o The maps (Figures H-1 and H-2) of the submittal for the environmental sample locations are not legible; better maps should be provided.

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TER-C5506-591 5 .' REFERENCES 1

1. Offsite Dose Calculation Manual for James A. FitzPatrick Nuclear Power Plant ]

New York Power Authority 5 NRC Docket No. 50-333 -

Submittal with Letter Dated October 26, 1983

, 2. H. I. Abelson (NRC/DL)

Letter to J. P. Bayne (NYPA)

Subject:

NRC/DL Approval of James A. FitzPatrick ODCM NRC Docket No. 50-333 May 29, 1985

3. Title 10, Code of Federal Regulations, Part 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, 'As Low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents"

4. " Radiological Effluent Technical Specifications for Pressurized Water ,

Reactors," Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS prcposals for operating reactors NRC, September 1982 NUREG-0472

5. " Radiological Effluent Technical Specifications for Boiling Water 3

Reactors," Rev. 3, Draft", intended for contractor guidance in reviewing RETS proposals for operating reactors NRC, September 1982 NUREG-0473 I'

6. " Semiannual Radioactive Effluent Release Report - January 1 through June j 30, 1984," James A. FitzPatrick Nuclear Power Plant, New York Power Authority NRC Docket No. 50-333

7. " Semiannual Radioactive Effluent Release Report - July 1 through December ,

31, 1984," James A. FitzPatrick Nuclear Power Plant, New York Power Authority WRC Docket No. 50-333

8. " Semiannual Radioactive Effluent Release Report - January 1 through June ,

30, 1985," James A. FitzPatrick Nuclear Power Plant, New York Power Authority NRC Docket No. 50-333

9. " Semiannual Radioactive Effluent Release Report - July 1 through December 31, 1985," James A. FitzPatrick Nuclear Power Plant, New York Power  !

Authority NRC Docket No. 50-333 D-10

TER-C5506-591 y 10. " General Contents of the Offsite Dose Calculation Manual," Revision 1 Branch Technical Position, Radiological Assessment Branch l NRC, February 8, 1979

" Preparation of Radiological Effluent Technical Specifications for l

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Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications" NRC, October 1978 NUREG-0133

12. " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR50, Appendix I" NRC, October 1977 Regulatory Guide 1.109, Rev. 1 l

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