ML20235J800

Technical Evaluation Rept for Evaluation of Offsite Dose Calculation Manual,Rev 4

ML20235J800
Person / Time
Site:	Limerick
Issue date:	05/31/1987
From:	Bohn T, Serrano W EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20235J802	List: ML20235J800
References
CON-FIN-D-6034 EGG-PHY-7712, NUDOCS 8707150732
Download: ML20235J800 (20)

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TECHNICAL EVALUATION REPORT for the EVALUATION OF ODCM REVISION 4 .

PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION NRC Docket NO. 50-352 NRC LICENSE NO. NPF-39 W. Serrano T. S. Bohn Published May 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415

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Prepared for the U. S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570

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. FIN..No.~.D6034

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ABSTRACT The Offsite Dose Calculation Manual for the Limerick Generating Station contains current methodology and parameters for calculation of offsite doses due to radioactive liquid and gaseous effluents, gaseous and liquid effluent monitoring alarm / trip setpoints, and in the conduct of the Initially, the manual was environmental radiological monitoring program.

Changes to .

approved by the NRC prior to implementation by the licensee.

the approved version of the manual are reported to the NRC in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made effective. The' NRC submitted Revision 0 (the approved version of the manual) and subsequent changes (Revisions 1, 2, 3, and 4)

The INEL to the Idaho National Engineering Laboratory (INEL) for review.

reviewed the manual through Revision 4 as a whole, and the results of the review are contained in this report. It was determined that the manual through Revision 4 uses methods that are, in general, consistent with the guidelines of NUREG-0133. However, it is recommended that another revision be submitted by the licensee to address and correct the discrepancies identified in the review.

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e FOREWORD This report is submitted as partial fulfillment vofewthe of "Re i Radiological Issues for BWRs" project being econducted Idaho by th National Engineering Laboratory for the the U Commission, Office of Nuclear Reactor Regulation. S. Nuclear Regula The U. S. Nuclear Regulatory Commission funded the work under FIN D6034 (P roject 1) and NRC B&R Number 20 19 10 12 2.

This report was prepared as an account of work sponsored b y an agency of the United States Government.

Neither the United States Government n any agency thereof, nor any of their employees, makes any warra ,

expressed or implied, or assumes any legal liability or responsibil ty for any third party's use, or the results of such use, of any on, informati apparatus, product or process disclosed in this report

, or represents that its use by such third party would not infringe privatel y-owned rights.

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' i CONTENTS. l

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c-Page Abstract. . . . . ... . . . . . . . . . . . . . . . . .. . . . i Foreword. . . . . . . . . ... . . . . .. ............ 11

1. Introduction. . . . . . . . . . . . . . . . . . . . . . . 1

2. Review Criteria . . . . . . . . . . . . . . . . . . . . . 2

'3. Evaluation. . ... . . . . . . . . . . . . . . . . . . . . 3

4. Co n cl u s i o n s . . . . . . . . . . . . . . . . . . . . . . . . 10

5. References. . . . . . . . . . . . . . . . . . . . . . . . 14 0

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1.

INTRODUCTION Purpose of Review This document reports the review and evaluation of a recent version of l the Offsite Dose Calculation Manual (ODCM) submitted by the Philadelphia Electric Company (PEC), the licensee for the Limerick Generating Station (LGS) Units 1 and 2. The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirements.E13 Plant-Specific Backoround The Philadelphia Electric Company (PEC) submitted ODCM Revision 0 to the Nuclear Regulatory Comission (NRC) with letter dated September 14, 1984[2]. The NRC reviewed the ODCM and provided notification of approval of the ODCM to PEC with letter dated October 3, 1984.E33

- However, the NRC approval letter referred to the ODCM as Revision 2 -

instead of Revision 0. Subsequent revisions to the ODCM were submitted to the NRC. Revision 1 was submitted with the Semiannual Effluent Release l Report for the second half of 1984E43 and incorporates a number of

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technical changes and a completely new format; Revision 2 was submitted j with the Semiannual Effluent Release Report for the first half of 1985[5]; Revision 3 was submitted with the Semiannual Effluent Release Report for the second half of 1985[6]; and Revision 4 containing numerous typographical corrections was submitted with the Semiannual l Effluent Release Report for the first half of 1986[73 The licensee's ODCM and all revisions were rubmitted to an independent review team at the Idaho National Engineering Laboratory (INEL) for review. The INEL team l reviewed the ODCM through Revision 4 as a whole, and the results and conclusions of the review are presented in this report.

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

NUREG-0472, RETS for PWRs[8]

NUREG-0473, RETS for BWRs[93 NUREG-0133, Preparation of RETS for Nuclear Power Plants.[10]

The following NRC guidelines were also used in the.0DCM review: "Gensral Contents of the Offsite Dose Calculation Manual," Revision 1E113,'and Regulatory Guide 1.109.[12]

As specified in NUREG-0472 and NUREG-0473, 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 radioactive effluent systems. As a minimum, the ODCM should provide equations and methodology for the following:

o Alarm and trip setpoints on effluent instrun,entation o Liquid effluent concentrations in unrestricted areas o Gaseous effluent dose rates at or beyond the site boundary o Liquid and gaseous affluent dose contributions o Liquid and gaseous effluent dose projections.

In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management 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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3. EVALUATION l

UnitThe 2. ODCM for the LGS is identified as the 00CM for both Unit 1 and However, only Unit 1 is presently operational-and Unit 2 is not expected to be operational for several years. The liquid and gaseous effluent discharge points for' Unit 1 are the same discharge points for Unit 2 and both units share common radwaste treatment systems. Therefore, the 00CM is a manual common to both units.

Liouid Effluent pathways Condenser cooling for the LGS is provided by water circulated through-natural draft cooling towers.

The LGS.is located by the Schuylkill River which supplies.make-up water to the circulating water system and receives decant from the cooling tower via the cooling tower blowdown line.

According to Unit l' Technical Specification 3.3.7.11, there are three monitored liquid effluent pathways for Unit 1:

a. Liquid Radwaste Effluent Line

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Residual Heat Removal (RHR) Service Water Effluent Line Service Water Effluent Line. '

Although there are three monitored pathways, only the liquid radwaste effluent is released directly to the cooling tower blowdown for immediate discharge offsite to the Schuylkill River. The service water return flow discharges to the cooling tower and the RHR Service water return flow discharges to.the spray pond or the cooling tower. Thus, only releases from the liquid radweste system need be considered for assuring compliance to the concentration and the dose limit technical specifications for radioactivity released in liquid effluents.

Since both units share a common liquid radwaste treatment system, the liquid radwaste discharges includes releases from both units. Figure IX.A.1 Rev. 1 in the ODCM is a sinylified diagram for the liquid radwaste treatment system for Units 1 and 2.

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Liquid Effluent Monitor SetpointsSection VII.A of the ODCM contains the method used to determine setpoints for the liquid effluent monitors. The monitors for the liquid , i radwaste and the RHR service water discharges provide both alarm and automatic termination of release whereas the monitor for the service water l discharges provide alarm function only. The setpoints for the RHR service l

water and the service water monitors are set to alarm just above background. Minor discrepancies for this section are identified in the Conclusion section of this report. The methodology described in Section VII.A to determine the setpoint for the liquid radwaste effluent monitor is, in general, in agreement with the guidelines of NUREG-0133 to provide reasonable assurance that the concentration limits of Technical Specification 3.11.1.1 will not be exceeded.

Gaseous Effluent Pathways ,

According to Unit 1 Technical Specification 3.3.7.12, there are four monitored gaseous effluent pathways for Unit 1:

South Stack ,

North Stack Main Condenser Offgas Pre-Treatment Hot Maintenance Shop Ventilation Exhaust The south stack houses the Unit 1 duct and the Unit 2 duct which exhaust ventilation air from the following sys'tems:  !

I Unit 1 Duct Unit I reactor enclosure exhaust Unit I reactor enclosure equipment compartment exhaust Unit 1 side of refueling floor exhaust 4

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Unit 2 Duct Unit 2 reactor enclosure exhaust Unit 2 reactor enclosure equipment compartment exhaust.

Unit 2 side of refueling floor exhaust The north stack is shared by Units 1 and 2 and exhausts the following systems:

Unit 1 turbine Unit 2 turbine Radwaste building Unit I recombiner Unit 2 recombiner Standby gas treatment enclosure Unit 1 battery compartment .

Unit 2 battery compartment Orywell purge Offgas treatment Equipment serviced. in the hot maintenance shop is expected to be contaminated with residual particulate radioactivity and small quantities of radiciodine. No radioactive gases are expected to be present.

Since the main condenser offgas is released to the atmosphere via the north stack, then only releases from the south stack, the north steck, and the hot maintenance shop need be considered for assuring compliance to the technical specifications for radioactivity released in gaseous effluents.

Simplified flow diagrams for the south stack and the north stack are included in the ODCM as Figures IX. A.2 Rev.1 and IX.A,3 Rev.1, respectively.

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. 8 Gaseous Effluent Monitor Setpoints i

Section VII.B of the ODCM contains the methodology used to determine j the setpoints for the noble gas effluent monitors. Minor discrepancies in this section are identified in the Conclusion section of this report. The methodology is, in general, in agreement with the guidelines of NUREG-0133 to provide reasonable assurance that the noble gas dose rate limits of l 4

Technical Specification 3.11.2.1.a will not be exceeded. l I

l Section VII.B.B1.b in the ODCM identifies iodine monitors for the )

north and south stack vents. It should be noted that Unit 1 Technical Specification 3.3.7.12 specifies iodine samplers only and does not specify iodine monitors. The purpose for the iodine monitors as indicated in Section VII.B.81.b is to provide alarm when the 10 CFR 20[13] dose rate limit has been reached at the site boundary. The setpoints for these monitors are based on the radiciodine release rate that results in a dose rate of 1500 mrems per year to the child's thyroid via the inhalation pathway. The methodology for determining setpoints for the iodine monitors is within the guidelines of NUREG-0133.

In summary, the licensee has followed the methodology of NUREG-0133 to determine the setpoints for the liquid and gaseous effluent monitors to provide reasonable assurance that the concentration limits for liquid effluencs and the noble gas dose rate limits will not be exceeded.

l Concentrations in t.icuid Effluents .

Section II.A of the ODCM contains the methodology for determining the discharge release rates for liquid effluents to provide reasonable assurance that the concentrations at the point of release are maintained within the limits of Technical Specification 3,11.1.1. However, the value '

for A, the cooling tower blowdown flow, should be clearly defined as the actual value at the time of discharge. Other minor discrepancies are identified in the Conclusion..section. With the exception of the definition for A, the methodology should provide reasonable assurance that the concentrations at the point of release are maintained within the limits.

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0,ose Rates in Gasecus EffluentsSection III.A.1 of the ODCM contains the methodology for determining the dose rate from radioactive noble gas releases to provide reasonable assurance that the dose rate to an individual at the location of highest dose is maintained within the limits of Technical Specification 3.11.2.1.a. In. general, the methodology is within the guidelines of NUREG-0133 with the exception of minor discrepancies identified in the Conclusion section.

Section'III.A.2 of the ODCM contains the methodology for determining ,

the dose rate due to I-131, I-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days. The methodology is, in general, within the guidelines of NUREG-0133 to provide reasonable assurance that the dose rate to a child's thyroid at the location of highest calculated annual average relative concentration is maintained within the limits of Technical Specification 3.11.2.1.b.

Dose due to Liquid EffluentsSection II.B of the ODCM contains the method for determining the dose to the maximum exposed member of the public due to radionuclides identified in liquid effluents to demonstrate compliance with the limits of Technical Specification 3.11.1.2. Both the drinking water and fish consumption pathways are included in the data listed in Table II.A.1. The Licensee should strongly consider another definition for F1 which includes . . ,,

an adjustment factor for near-field dilution in the receiving body of water, i.e., the Schuylkill River. For the dose calculations only (not for compliance with 10 CFR 20), NUREG-0133 permits an adjustment factor to increase the dilution term in F1 to 1000 cfs during the reporting period as long as the receiving body can support the dilution. This adjustment is permitted for plants not having a once-through condenser cooling system. Without this adjustment factor, it is likely that the calculated dose limits will be exceeded. Other minor discrepancies are identified in

. the Conclusion section. With the exception of the definition for F1, the 7

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I methodology for calculating doses due to the release of radioactivity in liquid effluents is, in general, ir agreement with the guidelines of  !

NUREG-0133. i 1

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Dose due to Gaseous Effluents , _ _

Section III.B of the ODCM contains the method for determining the q maximum air dose due to th'e' release of noble gases to show complinnce with  !

the dose limits of Technical Specification 3.11.2.2. The highest calculated average relative concentrations X/Q from vent releases for any area at or beyond the site boundary are used. Minor discrepancies in this i section are identified in the Conclusion section. The methodology for calculating the maximum dose to air due to the release of radioactive noble gases is, in general, in agreement with the guidelines of NUREG-0133 and should provide reasonable assurance that the dose limits of Technical Specification 3.11.2.2 will not be exceeded.

Section III.C of the ODCM contains the method for determining the maximum dose to an individual from I-131, I-133, tritium, and radioactive materials in particulate form, other than noble gases, with half-lives greater than eight days in gaseous effluents released to areas at and beyond the site boundary to show compliance with the dose limits of Technical Specification 3.11.2.3. The methodology only includes the grass-goat-milk ingestion pathway. It is not clear why the inhalation, meat, and vegetation pathways are not included. A dispersion value of 1.82E-09/m2 is used in the calculation and it is not clear if this is the maximum value. Therefore, it is uncertain if the methodology for calculating the maximum dose to an individual due to the release of the above radionuclides provides reasonable assurance that the dose limits of Technical Specification 3.11.2.3 will not be exceeded.

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Dose projections?

Section II.C describes the method used to project doses due to the expected release of radioactive liquids to determine required use of the liquid radwaste treatment system as required in Technical _ _

Specification 3.11.1.3. .The projections are based on the methodology (previously reviewed in this report).to calculate doses due to radioactive liquid. effluents contained in Section II.B of the ODCM.

Section III.D describes the method used to project doses due to the expected release of radioactive gaseous effluents to determine required use of the ventilation exhaust treatment system as required in Technical Specification 3.11.2.4. The projections are based on the methodology (previously reviewed in this report) to calculate doses due to radioactive gaseous effluents contained in Sections III.B and III.C of the ODCM.

Diagrams of Effluent Pathways .

The ODCM contains simplified diagrams illustrating the treatment paths

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and major components of the radioactive liquid radwaste treatment system for both units in Figure IX.A.1 Rev.1. Simplified diagrams illustrating the treatment paths and major components of the gaseous radwaste treatment systems for the south stack and the north stack are shown in Figures IX.A.2 Rev.1. and IX.A.3 Rev. 1, respectively. A simplified diagram illustrating the solid waste treatment system is not included in l the ODCM.

Total Dose,Section IV.B describes the method used to determine the direct ,

radiation from the site to demonstrate compliance with 40 CFR 190. It is not clear why the " Effluent contribution to dose" is included in the statement for determining dose from direct radiation. l 1

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- Environmental Monitoring program Section VI.C in the ODCM identifies specific parameters of distance and the direction sector'from the site and additional information for the

. samples identified in Environmental Monitoring Table 3.12.1-1 of Technical Specification 3.12.1. Information is included for all samples with the exception of the locations of the milk samples. The locations of the farms are not listed due to a long-standing agreement with the farmers involved. In return for being allowed to sample and analyze the milk, PECO has agreed not to divulge the location of the farms.

- Summary The Licensee's ODCM, as revised, uses documented and approved methods that are, in general, consistent with the methodology and guidance in NUREG-0133. However, it is recommended that the NRC request another revision to address the major and other discrepancies identified in this review.

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. 4. CONCLUSIONS The licensee's ODCM, including all revisions through Revision 4, for the Limerick Generating Station was reviewed. It was determined that the ODCM uses methods that are, in general, consistent with the guidelines of NUREG-0133. However, it is recommended that another revision to the ODCM be submitted to address and correct the numerous discrepancies identified in the review.

The following are considered to be major discrepancies:

o Section II.A. the value for A, the cooling tower blowdown flow, should be defined as the actual value at the time of discharge.

o Section II.B, the definition for F1 must be modified to read

.... Defined as the ratio of the maximum undiluted liquid waste flow during release to the average dilution flow during the reporting period." The average dilution flow can be adjusted to 1000 ft 3/sec as allowed in Section 4.3 of NUREG-0133 as long as the Schuylkill River can maintain the dilution flow during the reporting period. The adjustment is allowed for plants with cooling towers to consider the effects of near-field dilution in the receiving body of water. Without this adjustment the calculated doses could exceed the dose limits of the technical specifications for liquid radwaste releases.

o Section III.C of the ODCM only includes the grass-goat-milk ingestion pathway. It is not clear why the inhalation, meat, and vegetation pathways are not included.

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l The following are additional discrepancies:

o Section II.A, the dilution factor expression does not contain the concentration variable Cj. The definition should specify

" undiluted concentration" instead of " activity".

o Section II.A, it is not clear why the value of "1E-07 uti/ml" for unidentified concentrations is used instead of "3E-08 uCi/ml" as stated in Note 2d of 10 CFR 20 Appendix B.

o TABLE II.A.1: The bone dose factor for Mn-54 should be deleted since no dose factor is given in Regulatory Guide 1.109.

o Section II.B the expression for D0 should be:

I f i=1f A , dt g C$g g F 00=fR $

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o Section II.B, the word "first" should be deleted from the

. definition of dtl.

l o Section III.A.1.a the Qiy is missing in the expression for l Ds. The definition for Ds should state " dose rate" instead of dose".

o Section III.A.I.a, the units for Li and Mi should be l ^' pCi/h3instead of uCi/m3 ,

o ?ection III.B.2, the definition for DB should be included, i.e.  !

• DB = beta air dase, in mrad."

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[ o Section III.C.. the value for R .133I calculated from the expression in Attachment 1 Note 3 is 8.66E09 m 2(mrem /yr) per

]s l I (uci/d e) instead af 8.13E09 m2 (mrem /yr)/(uCi/sec).

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o Section III.C, it is not clear if the dispersion value of 1.82E-09/m2 used in the calculation is the maximum value.

o Section IV.B it is not clear why the " Effluent contribution to dose" is included in the statement for determining dose from direct radiation which is used in demonstrating compliante with 40 CFR 190.

o Section VII.A.A1.a. the expression for Ct requires summation symbols in both the numerator and the denominator. Also, a sumation Ci/MPCi. symbol is required in the definition for the quantity 3

} o Section VII.A.A1.c, the title "c.

omitted. High-hich Alarm Setooint" is Also, titles have been omitted throughout the document o

. Section VII.A.A3.a, the title ".. DETERMINE CR.." should be

" . DETERMINE CRS..". Also the definition is not for "E" required as E is not used in the expression.

O Section VII.B.Bl.a., CT and C t are used interchangeably, o

Section VII.B B3 ' un the F(min) definiti n. FM should be included in o

Section VII.B.B5.a.(1), in the equation for calculating CT the conversion factor 472 uCi/see per CFM to uCi/cc should be in the numerator.

Also the value "1500 mR/hr" should be "1500 mrem /yr" .

o Attachment 1, conversion factors are required to convert pCi to uti in Qt expressions for the whole body and skin dose.

o BasesSection VII Note 1, the section referred to in the first sentence of the first paragraph should be "section II.B" instead of "section III.A".

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> o Bases'Section-VII Note 1, the table referenced in the definition-of Uw should be " Table E-5" instead of." Table 3-5".

o BasesSection VII Note 1, the "8760 hr/yr" factor should be in the denominator of the expression in the definition of KO.

o BasesSection VII Note 2, the conversion factor in the definition of K'should be "1.0E06 pCi/uci" instead of "10E06 pCi/uci".

n BasesSection VII Note 3, the decay constant for radioiodine is missing in the exponential term in the equation for calculating RGi(D/Q).

o Simplified diagrams illustrating the solid waste treatment systems are not included in the ODCM. .

The following are not discrepancies in the ODCM, but are suggestions that should be brought to the attention of the Licens6e.

o Section III.B.2, in the introductory paragraph, the portion in the first sentence reading ".... calculating dose contribution...." should read ".... calculating dose rate contribution....".

o Section VII.B.B4.a.1), the definition for Q should t be reworded to indicate it is the lower of the total relecse rates obtained from either a dose rate calculation of 500 mreas to the total body per year or 3000 mroms to the skin per year.

o Section VII Note 1, in the last paragraph following the definitions, the quantity "D" in the first sentence should be "Dw".

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5. REFERENCES

1. Title 10, Code of Federal Regulations, Part.50, Appendix I, ,

"Numerica? 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 Nucitar Power Reactor Effluents."

2. Letter from E. G. Bauer, Jr. (PEC) to'A. Schwencer (NRC),

Subject:

Limerick Generating Station,-Unit 1 and 2, Docket Nos. 50-352, 50-353, Revision of Offsite Dose Calculation Manual (ODCM), l September 14, 1984. .

3. Letter from A. Schwencer (NRC) to E. G. Bauer ,Jr. (PEC),

Subject:

Approval of Offsite Dose Calculation Manual, October 3, 1984.

4. " Semi-Annual Effluent Releases Report No. 1 July 1, 1984 through l

. December 31, 1984 " Limerick Generating Station Unit 1, .

February 28, 1985. l

. 5. " Semi-Annual Effluent Releases Report No. 2 January 1, 1985 through June 30, 1985," Limerick Generating Station Unit 1, August 29, 1985.

6. " Semi-Annual Effluent Releases Report No. 3 July 1,1985 through ,

December 31, 1985," Limerick Generating Station Unit 1, February 28,'1986.

7. " Semi-Annual Effluent Release Report No. 4 January 1, 1986 through l June 30, 1986," Limerick Generating Station Unit 1, August 29, 1986. )

8. " Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in I reviewing RETS proposals for operating reactors, NUREG-0472, September 1982.

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9. " Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors, NUREG-0473, September 1982.

10. . " preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications," NUREG-0133, October 1978,

11. " General Contents of the Offsite Dose Calculation Manual," Revision 1 Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.

12. Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix 1," Regulatory Guide 1.109, Rev. 1, October 1977.

13. Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation."

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