ML20235P842
| ML20235P842 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/14/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235P800 | List: |
| References | |
| TAC-62143, TAC-62144, NUDOCS 8707200640 | |
| Download: ML20235P842 (18) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION I
REL4TiWh TO ACCEPTANCE OF THE OFFSITE DOSE CALCUL ATION MANUAL (ODCV) q 1
UPDATED THROUGH DECEMBER 31,'1986 4
GEORGIA POWER COMPANY l'
EDWIN 1. HATCH NUCLEAR PLANT, UNITS 1 AND 2 l
l DOCKET N05. 50-321 AND 50-366-l
1.0 INTRODUCTION
i On' June 28 1985 the staff issued Amendment Nos.110 and 48 to Facility Operat-
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l ing License Nos. DPR-57 and NFP-5 for the Edwin I. Hatch Nuclear Plant, Units 1 and 2.
The' amendments incorporated the Radiological Effluent Technical Speci-fications (RETS) into the Hatch Technical Specifications (TS). Section 6.17 of the TS referenced an Offsite Dose Calculation Manual (DDCH) and prescribed the methods for its change.
i 2.0 EVALUATION I
The docketed submittal on October 1, 1984 by Georgia Power Company (GPC, licensee) of an ODCM for the Edwin I. Hatch Nuclear Plant.: Units 1 and 2, received NRC approval by letter dated June 28, 1985~.from George Rivenbark to the licensee. On March 24, 1986 GPC submitted a-reformatted copy of the Hatch ODCM with each page marked " HATCH ODCM, REV 1 5/11/84".
On Se'tember 2, 1906 p
i GPC provided corrections to two of the ODCM pages., This reformatted ODCM,
. updated.to December 31, 1986, has been reviewed for us by EG&G Idaho Incorpo-
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rated (EG8G) as part of our technical assistance contract program. Their Technical Evaluation Report (TER), the enclosed section from EGG-PHY-7418, provides their' technical evaluation of the compliance of the Licensee's l
mennnnun ew? n a ^^ ~ "- ~ ' '
j submittal with NRC criteria.
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The staff has reviewed this report, and a9rees with the evaluation that the s
Hatch ODCM, Revision 1, updated to December 31 L1986, uses documented end approved methods that are generally consistent with the methodology and guide-lines in NUREG-0133. Therefore, we conclude that this CDCM is an acceptable reference for use with Hatch TS 6.17.
However, as referenced in the TER, simplified flow diagrams for the gaseous radwaste and gaseous cffluent flow pathways, as well as for the solid waste treatment system should be included in the next revision to the ODCM.
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3.0 CONCLUSION
S The Hatch ODCM, Revision 1 updated to December 31, 1986, is acceptable. The changes incorporated since the NRC approval of June 28, 1985 are in compliance -
with Hatch 1 and 2 TS 6.17.1.
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EGG-PHY-7418 APPENDIX D Evaluation of Changes to the ODCM (Ed, tin I. Hatch Nuclear Plant Units 1 and 2) 1 t-l 1
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0.1 EVALUATION OF CHANGES TO THE ODCM The Georgia Power Company (GPCo), the Licensee for the Hatch Nuclear 1
Power Plant Units 1 and 2, prepared an Offsite Dose Calculation Manual (ODCM) for both units at the site. Normally changes to the ODCM are i
submitted by the Licensee in the Semiannual Effluent Release Reports.
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However, Revision 1 to the ODCM was submitted to the NRC with letter dated March.24,1986.[13 Revision 1 was a complete ODCM and superceded the previous version of the ODCM.
Follow-on changes to Revision I were
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reported by the Licensee in the Semiannual Radioactive Effluent Release Reports for January-June 1986[2], and for July-December 1986.[33 The ODCM Revision 1 and the reported changes were transmitted by the NRC to the Idaho National Engineering Laboratory (,'NEL) for review.
l The ODCM Revision 1 and the reported changes were reviewed as a whole. The result of the evaluation is intehded to be a stand-alone document and is given in Supplement 1 to Appendix 0.
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-i D.4 REFERENCES' I
1.
Letter from L. T. Gucwa (GPCo) to D. Muller (NRC),
Subject:
Edwin'I.
Hatch Nuclear Plant Units 1, 2 Offsite Dose Calculation Manual and
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Process Control Program Revisions, SL-445 2113B, March 24, 1986.
I 2.
Letter from L. T. Gucwa (GPCo) to J. N. Grace (NRC),
Subject:
Semiannual Radioactive Effluent Release P.eport, January-June 1986, September 2, 1986.
3.
Letter from L.'T. Gucwa (GPCo) to J. N. Grace (NRC),
Subject:
J Semiannual Radioactive Effluent Release Report, June-December 1986, February 27, 1987.
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8 SUPPLEMENT 1 to l
APPENDIX D EVALUATION OF CHANGES TO THE ODCM l
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INTRODUCTION Purpese of Review The purpose of this document is to report the review and evaluation of
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Revision I r# the Offsite Dose Calculation Manual (ODCM) s.nd a subsequent
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change to Revision 1 submitted by the Georgia Power Company (GPCo), the Licensee for the Hatch Nuclear Power Plant Units 1 and 2.
The ODCM is a 1
l supplementary document fcr implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix IEI3 requirements.
Scope of Review 1
.1 As specified in NUREG-0472f23 and NUREG-0473[3], the ODCM is to be l
developed by the Licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the radioactive l
effluent systems. As a minimum, the ODCM should provide equations and
-J methodology for the following topics:
o Alarm and trip setpoints on effluent instrumentation 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 1
l the systems being used at the station, defining the treatment paths and l
l the components of the radioactive liquid, gaseous, and solid waste L
management systems. A description and the location of samples in support l
of the environmental monitoring program are also needed in the ODCM.
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' Plant-Specific Background i
On behalf of Hatch Nuclear Power Plant (HNP), the Georgia Power Company submitted Revision 1 of the HNP ODCM to the NRC with letter dated March 24,1986.[43 Subsequent changes to Revision 1 were reported by
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the Licensee in the Semiannual Radioactive Effluent Release Reports for January-June 1986[5], and for July-December 1986.[6] The' revised ODCM and the reported changes were transmitted to an independent review team at; the Idaho National Engineering Laboratory (INEL) for review. A review of 1
the ODCM Revision 1 and the reported changes were conducted and the results and conclusions of the review are presented in this supplement.
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REVIEW CRITERIA i
Review criteria for.the ODCM were provided by the NRC in three documents:
NUREG-0472, RETS for PWRs[23 NUREG-0473, RETS for BWRs[33
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l NUREG-0133, Preparation of RETS for Nuclear Power Plants.[7]
i In the ODCM review, the following NRC guidelines were also used
" General Contents of the Offsite Dose-Calculation Manual,"
Revision 1[83, and Regulatory Guide 1.~109.[93 The ODCM format is Ir.ft l
to the Licensee and may be simplified by tables and grid printouta.
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i EVALUATION l
I The Licensee has followed the methodology of NUREG-0133[6] to determine the alarm and trip setpoints for the liquid and gaseous effluent monitors, to provide reasonable assurance that the maximum permissibic 1
concentrations (MPCs), as specified in 10 CFR 20,[10] will not be exceeded by discharges from various liquid or gaseous release points.
4 The HNP is located on the Altamaha River which supplies make-up water to the circulating water systems and receives decant from the cooling towers. Each of the two units on the site is served by its own liquid radwaste system which releases each unit's liquid radwaste to separate discharge lines from the circulating. water systems. Therefore, each unit has separate radwaste systems, independent liquid effluent radiation monitors, and separate dilution streams.
Since each unit is served by a i
separate dilution stream, liquid radwaste releases may be made l
independently from each of the two units.
i Although there are but two radioactive liquid release points, there l
are three liquid release pathways monitored for radioactivity at the two-unit site: discharges from the Unit I radwaste treatment system, dischargei from the Unit 2 radwaste treatment system, and discharges from the service water system.
Effluents from each unit's radwaste treatment systems are released to each unit's cooling tower blowdown before release offsite to the Altamaha River.
Effluents from the plant service water system are released onsite to the main condenser circulating flume or to a unit's cooling tower blowdown when needed for additional dilution. The monitors for the radwaste discharges provide both alarm and automatic
' termination of release whereas the monitor for the service water discharge provides alarm function only. Simplified flow diagrams for the liquid radwaste treatment systems for Units 1 and 2 are shown in Figures 1.5-1 and 1.5-2 of the ODCM, respectively. The Licensee's methodology described in Section 1.1 of the ODCM to determine the setpoints for the liquid
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effluent monitors is in general in agreement with the guidelines of NUREG-0133 to provide reasonable assurance that the concentration limits of 10 CFR 20 will not be exceeded.
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There are four radioactive gaseous effluent release pathways for the two-unit site: the 120 meter main stack which serves both units, the Unit I reactor building vent stack, the Unit 2 reactor building vent stack, and the Unit I recombiner building vent. The Unit 2 recombiner is located in the Unit 2 turbine building and the turbine building effluents are monitored at the Unit 2 reactor building vent. The main stack serves as the discharge point for the mechanical vacuum pumps, the off-gas system, the gland seal exhaust, and the standby gas treatment system through which drywell purges are discharged, and discharges from the waste gas treatment building.
Each reactor building vent stack serves as the discharge point for each unit's reactor building, refueling floor ventilation, turbine building, and the iadwaste building. Noble gases are monitored at each of the four release points and an administrative factor has been included in the methodology to determine the monitor's setpoints
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to assure that release limits will not be exceeded by simultaneous releases. Simplified diagrams for the two units illustrating the gaseous radwaste treatment systems and the gaseous effluent flow pathways are not included in the ODCM. The Licensee's methodology described in Section 2.1 of the ODCM to determine the setpoints for the gaseous effluent monitors
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is, in general, in agreement with the guidelines of NUREG-0133 to provide reasonable assurance that the dose rate limits of NUREG-0473 will not be exceeded.
The Licensee's ODCM contains the methodology used to assure that the limiting concentrations of 10 CFR 20 Appendix B Table II Column 2 in i
liquid effluents are not exceeded at the point of discharge. The methodology is, in general, in agreement with the guidelines of NUREG-0133.
Noble gas discharges are assured to be within the NUREG-0473 dose rate,
limits of 500 mrems/yr to the total body and 3000 arems/yr to the skin by correctly determining the setpoints for the noble gas tranitors.
Section 2.2.1.b of the CDCM contains the methodology used to determine the dose rate to an organ of a child via the inhalation pathway due to D1-6
4 I-131, I-133, tritium, and all radioactive materials in particulate form with half-lives greater than 8 days. Additionally, Section 2.2.1.b contains the method to assure the combined dose rates due to simultaneous releases will not exceed 1600 mrem per year. The Licensee's Dose Rate Technical Specifications identify I-131 and I-133 whereas Section 2.2.1.b of the ODCM states "radiciodines" which implies all radioiodines. The dose' rate due to the release of I-131,'I-133, tritium, and particulate with half-lives greater than eight days'is assured to be within the NUREG-0473 limit of 1500 mrem per year by calculating the dose rate to any organ of a child via the inhalation pathway using the highest calculated annual average relative concentration X/Q for both the ground and elevated release points. The methodology for the dose rate calculations is, in general', in agreement with the guidelines of NUREG-0133.
Doses to the mar.imum exposed member of the public due to radionuclides identified in liquid effluents are calculated to show compliance with the limits of 10 CFR 50 Appendix 1.
No drinking water is taken from the Altamaha River downstream from the plant and the Licensee identifies the fish consumption pathway for the dose calculations assuming the adult as the maximum exposed individual. The near-field average dilution factor is defined in Section 1.2 as the ratio of the radwaste flow to the dilution flow during the time of releas~. The Licensee should be cautioned that e
the dilution factor should be the ratio of the radwaste flow during the time of release to the average dilution flow during the reporting period.
Additionally the bioaccumulation factor for P-32 in Table 1.2-1 of the ODCM could be 3x103 instead of 2.5x104 pCi/kg per pCi/ liter. The methodology for the dose calculations due to radioactive liquid effluents is, in general, in agreement with the guidelines of NUREG-0133.
Doses resulting from the release of noble gases and'I-131, I-133, tritium, and particulate with half lives greater than eight days are calculated to show compliance with the limits of 10 C'FR 50 Appendix 'I.
The highest calculated annual average relative concentrations X/Q for both
. ground and elevated releases are used to calculate the maximum air doses.
The dose to an individual is calculated and at the Hatch Nuclear Power D1-7 l
Plant the controlling receptor is an infant exposed to the inhalation, the
. ground-plane, and the grass-cow-milk pathways.
Section 2.2.2.b of the ODCM states "radiciodines" which implies all radiolodines, whereas the Licensee's technical specifications identify I-131 and I-133.
The methodology for the dose calculations due to radioactive gaseour effluents is, in general, in agreement with the guidelines of NUREG-0133.:
Methodology, based on dose projections, to determine required use of the liquid radwaste treatment system is described in the ODCM. The projections are based on the calculated dose due to radioactive liquid effluents which satisfy the guidelines in NUREG-0133. Projections are not required for the gaseous radwaste treatment system as the technical l
specifications require the system to be in operation whenever the main conder.scr air ejector system is in operation. Dose projections to
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determine use of a ventilation exhaust treata..nt system are not included in the ODCM since a requirement to use the ventilation exhaust treatment system is not included in the technical specificaticas.
The ODCM contains simplified flow diagrams illustrating treatment paths and components of the radioactive liquid waste treatment systems for both units in Figures 1.5-1 and 1.5-2.
Comparable diagrams for the gaseous radwaste treatment systems are not included in the ODCM. However, Figure 2.5-1 illustrating the condenser offgas treatment system is included in the ODCM. Also, a simplified diagram illustrating the solid waste treatment system is not included in the ODCM.
Methodology for demonstrating compliance to 40 CFR 190 is described in Section 4.0 of the ODCM.
i Environmental Monitoring Table 3.16.1-1 in Technical Specification 3.16.1 identifies the approxiu, ate number of sample locations for the environmental monitoring program. Table 3.0-1 in the ODCM identifies l
specific parameters of distance and the direction sector from the site and additional information for the available sample locations. The Technical Specification identifies approximately four milk locations with a footnote
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statirg "as available" and only three locations were available. Due to j
the unavailability of samples, the number of milk sample locations has bece further reduced from three to two and one of the two had to be relocated as reported in the Semiannual Radioactive Effluent Release Report for the second half of 1986. The Environmental Monitoring Program
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~ described in the ODCM remains consistent with the requirements of the Licensee's technical specifications.
In summary, the Licensee's ODCM as revised uses documented and approved methodF that are generally consistent with the methodology and l
guidance in N'JREG-0133, and therefore should be considered to be an 1
acceptable reference.
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CONCLUSIONS l
The Licensee's Revision I to the ODCM for Hatch Nuclear Power Plant Units 1 and 2 submitted to the NRC with 1stter dct:d March 24, 1986 and l
l the subsequent change to the ODCM submitted with the Semiannual Radioactive Effluent Release Report for the second half of 1986 uses documented and approved methods that are consistent with the guidelines of NUREG-0133 with the following exceptions:
Simplif ed flow diagrams for the gaseous radwaste and gaseous o
effluent flow pathways are not included in the ODCM.
l A simplified diagram illustrating the solid waste treatment o
system is not included in the ODCM.
The following are not discrepancies in the ODCM, but are suggestions that shculd be brought to the attention of the Licensee.
I The Licensee's Dose Rate Iechnical Specifications identify 1-131 o
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and 1-133 whereas Section 2.2.1.b of the ODCM states "radiciodines" which implies all radiciodines.
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The Licensee should be cautioned that the dilution factor
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o identified in Section 1.2 should be the ratio of the radwaste flow during the time of release to the average dilution flow i
du,rjing the reporting period.
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l A dose projection to determine use of a ventilation exhaust o
treatment system is not included in the ODCM. This is due to the fact that a specification for use of the Ventilation Exhaust Treatment System is not included in the Licensee's Technical H
I specifications.
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The bioaccumulation factor for P-32 in Table 1.2-1 of the ODCM could be changed to 3x103 instead of 2.5x104 pCi/kg per pCi/ liter.
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e The Licensse's dose Technical Specifications identify "I-131 and
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I-133" whereas Section 2.2.2.b of the ODCM states "radiciodines"
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which implies all radiciodines.
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REFERENCES 1.
Title 10 Code _of Federal Regulations. Part 50. Aprendix 1. " 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 Pnwer Reactor Effluents".
2.
" Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors, NUREG-0472, l
September 1982.
3.
" Radiological Effluent Technical Specifiestions for Boiling Water
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Reactors," Rev. 3, Draft 7",
intended for contractor guidance in reviewing RETS proposals for operating reactors, NUREG-0473, September 1982.
4.
Letter from L. T. Gucwa (GPCo) to D. Muller (NRC),
Subject:
Edwin I.
Hatch Nuclear Plant Units 1,2 offsite Dose Calculation Manual and Process Control Program Revisions. SL-445 2113B, March 24, 1986.
5.
Letter from L. T. Gucwa (GPCo) to J. N. Grace (NRC),
Subject:
Semiannual Radioactive Effluent Release Report, January-June 1986, September 2, 198o.
6.
Letter from L. T. Gucwa (GPCo) to J. N. Grace (NRC),
Subject:
l Semiannual Radioactive Effluent Release Report, June-December 1986, February 27, 1987.
7.
" Preparation of Radiological Effluent Technical Specifications for Nuclekt Power Plants, A Guidance Manual for Users of Standard Technical Specifications," NUREG-0133, October 1978.
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" General Contents of the Offsite Dose Calculation Manual," F.evisten 1 Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.
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Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for.the Purpose of Evaluating Compliance with 10 CFR 50 Appendix I," Regulatory Guide 1.109, Rev.1, October 1977.
1 10, Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation."-
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