ML20246L255

Forwards Review of Rev 3 to Odcm.Rev Submitted as Attachment 7 to Semiannual Effluent Rept for Jan-June 1988.Methodology Meets All Requirements of NUREG-0133 & Acceptable

ML20246L255
Person / Time
Site:	Perry
Issue date:	04/26/1989
From:	Simpson F EG&G IDAHO, INC.
To:	Meinke W Office of Nuclear Reactor Regulation
Shared Package
ML20246L261	List: ML20246L255 NUREG-0133, Safety Evaluation Accepting Licensee Rev 3 to ODCM for Plant Through Temporary Change 4.Rev Meets Criteria of NUREG-0133 & Other Guidance. Guidance
References
RTR-NUREG-0133, RTR-NUREG-133 NUDOCS 8905180278
Download: ML20246L255 (9)

Text

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ENCL 0SURE I

lNEA idehe National Engineering Lsboratory i

April 26, 1989 Mr. Wayne Meinke Radiation Protection Branch Mail Stop 1]D23 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 FINAL LETTER REVIEW OF THE PERRY ODCM REVISION 3 - SIM-53-89

Dear Mr. Meinke:

Attached is the review of ODCM Revision 3 for Perry Nuclear Power Plant -

(PNPP) submitted by The Cleveland Electric Illuminating Company (CEI). '

• Revision 3 was submitted as Attachment 8 to the Licensee's semiannual

. effluent report for Jan-Jun 1988. This submittal was apparently in

' partial response to a letter from the NRC requesting that a new revision of the ODCM be submitted incorporating temporary changes to Revision 2 and addressing the items identified in the Conclusions. section of the Technical Evaluation Report (TER), EGG-PHY-8032, concerning Revision 2.

The Licensee's response to the items identified in the review TER were transmitted to the NRC separately from the revised ODCM, with a letter from A. Kaplan (CEI) to Document Control Desk (NRC), dated September 20, 1988. The Licensee's responses to these items were considered when preparing the discussions in the attached review of ODCM Revision 3. The ODCM Revision 3 reviewed was updated through Temporary Change No. 4, submitted with the Licensee's semiannual effluent report for the Jul-Dec 1988 period. Changes to the ODCM made in response to the items identified in the review TER were submitted as part of Temporary Change No. 4 to ODCM Revision 3.

The only additional changes that appear to be needed in the ODCM are discussed under " Major Discrepancies (#2)" and " Additional Discrepancies

(#9)" in the attachment. The first involves addition of a small amount of information to the ODCM, and the second involves specification of a milk sampling control location in the environmental monitoring program.

Very trul yours, 6 h 'Nrp)ppyw

. B. Simpson Nu lear Sciences TEY/lkw Attachments N cc: G. L. Jones, DOE-ID l As stated 1

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EVALUATION OF PERRY ODCM UPDATED THROUGH REVISION 3 - SIM-53-89

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The Cleveland Electric Illuminating Co. (CEI), the Licensee for Perry Nuclear Power Plant, Unit 1 (PNPP) submitted a complete ODCM for PNPP, updated through Revision 3 and Temporary Changes 1 and 2 (TCN-1 and TCN-2) to the NRC with the Semiannual Radioactive Effluent Release Report for Jan-Jun 1988, with a letter from A. Kaplan (CEI) to Document Control Desk (NRC), dated August 30, 1988. The updated ODCM included some changes made in response to a letter from T. Colburn (NRC) to A. Kaplan (CEI), dated March 9, 1988. Specifically, TCN-1 through TCN-8 to Revision 2 of the ODCM were incorporated in Revision 3. Also, a number of radiological environmental monitoring locations were added by Revision 3, including sevetal in addition to those required by Technical Specification Table 3.12.1-2. Except for these two types of additions, Revision 3 was essentially unchanged from Revision 2. Therefore, no additional deficiencies were identified due to the issuance of Revision 3.

The NRC letter of March 9,1988 also requested that CEI address the items identified in the Conclusions section of the Technical Evaluati.on Report (TER), EGG-PHY-7731, which consisted of a review of the complete PNPP ODCM, updated through Revision 2 and TCN-1 through TCN-5. The Licensee's specific response, addressing each item in the Conclusions section of the

• review TER, was transmitted to the NRC separately from ODCM Revison 3,

• with a letter from A. Kaplan (CEI) to Document Control Desk (NRC), dated

• September 20, 1988. A copy of the Licensee's response, which includes verbatim copies of the recommendations from the review TER, is attached for convenient reference. This response was reviewed by EG&G at the INEL and the results of the review were transmitted to the NRC wjth a letter from W. Serrano (EG&G) to W. Meinke (NRC), dated October 13, 1988.

Changes to the ODCM made by CEI in response to the items identified in the review of ODCM Revision 2 were transmitted to the NRC as part of TCN-4 to ODCM Revision 3 as an attachment of the Licensee's semiannual eff3uent release report for Jun-Dec 1988 with a letter from A. Kaplan (NRC) to Document Control Desk (NRC), dated March 1, 1989.

The following discussions address items in the Conclusions section of the review TER for ODCM Revision 2 to which the Licensee did not respond essentially as recommended, except those items discussing ODCM methodology that is more conservative than recommended by NUREG-0133, NUREG-0473, and Regulatory Guide 1.109, Revision 1. These discussions include l consideration of the explanations given in the Licensee's response (in the September 20, 1988 letter referenced above) to the points raised in the review TER, and the changes made by TCN-4 to ODCM Revision 3 to correct l

deficiencies identified in the TER.

Maior Discrepancies (1). This item in the review TER (EGG-PHY-7731) for i Revision 2 of the ODCM expressed concern that the inclusion of the factor l

"fma / fact" in Equation 2.1-7 for the liquid effluent radioactivity mondorsetpointmayresultinthepossibilityofinadvertentlyreleasing a tank having higher activity than the intended tank. The Licensee's response stated that " Administrative controls are in place to preclude the chance of inadvertent release of an unintended tank." The Licensee's response also stated that " procedural guidance includes an additional factor of two conservatism by reducing the specified liquid radwaste tank discharge flow I

rate to half the calculated allowable value." This statement apparently means that fmax/ fact is normally 2.0, in which case the radioactivity monitor setpoint in combination with the radwaste flow monitor setpoint would restrict the release rate so the offsite concentration would be no more than 20% of the 10 CFR 20 values. Therefore, the Licensee's methodology insures that the concentration of radioactive materials in liquid effluents does not exceed the limits of Technical Specification 3.11.1.1.

3.11.1.1.Maior Discrepancies (#2). This item concerned the use of the product M F in the denominator of Equations 2.3-1, 2.3-2, and 2.3-3 whereas 10e corresponding equations in NUREG-0133 limit the the use of the equivalent of the product (Mo F) to 1000 cfs except for the potable water pathway. The Licensee's response indicates that the dose calculation methods given in Regulatory Guide 1.109 are used in the Perry ODCM. These methods include use of a " mixing ratio" (M p ) which is the inverse of the

" dilution factor" (M )n used by the Licensee. The Final Environmental Statement (JJH, NUREG-0884, for the Perry plant indicates that the total liquid blowdown for one unit is approximately 50 cfs (although there appears to be some inconsistency in the values in the FES). Using 50 cfs for the value of F and ODCM Table 2.3-10 for the values of M in Equations 2.31,2.3-2,and2.3-3leadstotheconclusionthEtthe . -

Licensee's dose calculation methodology would conform to the

, recommendations of NUREG-0133 if the calculations were rewritten in the format and terminology of that document. However, for clarity and completeness of the ODCM, the value of the flow rate, F, should be given and the values of Mp should be referenced or justified. ,

Maior Discrepancies (#3. #4 and #6). These items expressed concern about parts of the Licensee's methodology in ODCM Sections 3.2.3 and 3.3.3 that allowed some confusion concerning the period of time for which dose rates and doses are calculated. The Licensee's' responses explained how the methodology is applied, and TCN-4 to Revision 3 of the ODCM included minor changes to these sections that make it more clear that the proper dose rates and doses are calculated using the methodology described.

Additional Discrepancies (#4). The discussion for " Major Discrepancies

(#3, #4, and #6)" above apply (i.e., the methodology is slightly confusing on first reading, but the dose rates and doses are being determined correctly).

Additional Discrepancies (#5 and #6). The Licensee realizes that some data tables in the ODCM are duplicates, but prefers to retain the present format so each ODCM section is complete within itself.

Additional Discrepancies (#8). This item concerned lack of a simplified diagram illustrating the solid waste treatment system in the ODCM. The Licensee's response states that all matters pertaining to solidified waste treatment are contained in Perry's Process Control Program (PCP).

Figure 2 of the PCP is a simplified diagram of the solid waste processing system. -

Additional Discrepancies (#9). This item in the review TER erroneously referred to REMP Location #28 instead of #29. The particular discrepancy 2

4 intended to be noted (the omission of Location #29 from ODCM Table 5.1-1) has been corrected in the ODCM. However, the previous milk control location (REMP Location #33) was deleted by TCN-3 to ODCM Revision 3 and no other control location was designated. A control location should be designated, as required by Technical Specification Table 3.12.1-2. (One of the milk sampling locations, REMP Location #51, very nearly meets the criteria for the required control location since it is located at 9.2 miles [14.8 kilometers), whereas the requirement for the control location is that it be between 15 and 30 kilometers).

Successions (#2). The Licensee noted the suggestion thut.the bioaccumulation factor of 1.0E+05 for phosphorous be replaced by 3.0E+03, but stated that identification of the source of the lower value would be  !

appreciated. The reference for the lower value is: E. F. Branagan, C. R.

Nichols and C. A. Willis, "Importance of P-32 in Nuclear Reactor Liquid Effluents, " Health Physics Society Annual Meeting, June 1982.

Successions (#3). This item concerned the dilution ratios given in ODCM Table 2.3-10 for liquid effluents, and noted that it may be possible to eliminate this table if the ODCM inethodology for dealing with the dilution i of liquid effluents were changed somewhat. The Licensee prefers to retain the present methodology for calculations relating to dose wmmitments due. .

to releases of radioactive material in liquio effluents. The subject of dilution of liquid effluents is discussed under " Major Discrepancies (#2)"

' above.

In general, the methodology used in the Licensee's ODCM updated through TCN-4 to Revision 3 meets all the requirements of NUREG-0133 and other NRC guidance. The only changes that may be needed are the miner additions recommended under " Major Discrepancies (#2)" and " Additional Discrepancies

(#9)" above. ,

This review was performed by T. E. Young.

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, ATTACHMENT 1 PY-CEI/NRR-0912L RESPONSE TO NRC REVIEV C0KMEhTS ON TEE FNPP OFFSITE DOSE CALCULATION MANUAL i

Major Discrepancies

1. In Section 2.1.1.4, it is' uncertain if the ratio f -to-f should be included in the e::pression for determining the IIIpoint act If the ratio is not included, then the monitor could guard against inadvertently releasing an incorrect tank. If the ratio is included, it may be possible to inadvertently release a tank having higher activity than the intended tank and still be within the limiting radiation setpoint calculated for the intended tank.

Response: ODCH Section 2.1.1 4 Honitor Alarm Setpoint.

Determination, was written and is. implemented to ensure Technical Specification 3.11.1.1 (10 CFR Part 20, Appendix B) compliance.

Furthermore, ODCH calculations limit liquid radvas+e releases to . .

1/10 of these Technical Specification limits. The primary means

, of limit control is provided by the liquid radvaste discharge flov monitor alarm setpoint (for which procedural guidance includes an additional factor of two conservatism by reducing the specified liquid radvaste tank discharge flow rate to, half of the calculated allovable value.) The f -to-f factor was includedintheliquidradvastedisE$arger$0ationmonitor setpoint as an adjustment factor (to account for the difference between the actual radvaste discharge flow rate to be used and the maximum allovable radvaste discharge flow rate) in order to allow operational flexibility, i.e., minimization of setpoint changes, and to eliminate spurious alarms. Administrative controls are in place to preclude the chance of the inadvertent release of an unintended tank.

2. 'The product M F in the denominator of Equations 2.3-1, 2.3-2, and l 2.3-3shouldEereplacedwithF,whereFisdefinedastheaverage dilution flov during the reporting period times an adjustment I

factor.

I Response: The evaluation section of the Technical Evaluation Report for the Evaluation of ODCH Revision 2, discusses agreement of liquid dose calculation methodologies between the ODCH and NUREC-0133. The F term used in our ODCH includes the actual dilution flow provided by the Service Vater and Emergency Service Vater Systems during the period of liquid radvaste release. This term does not exceed the 1000 cfs limit included in NUREG-0133.

The H term (as outlined in Regulatory Guide 1.109) accounts for thedilution'thatoccursoncetheeffluentleavestheareaofthe plant discharge structure, as covered in Section 4.3.1 of NUREG-0133 (term y D of the dose factor equation).

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ATTACHMENT 1 PY-CEI/NRR-0912L

3. The definition for 0 3in Section 3.2.3 should be defined as the average release rate based on the analysis of charcoal and particulate samplers that are collected on a weekly basis as required by Technical Specification Table 4.11.2.1.2-1 instead of being defined as the annual average release rate.

Response: The Og term in ODCH Equation 3.2-1 is the release rate of radionuclides i in uCi/s. The actual values used for calculations are those of the actual release period. For the purpose of calculating an annual dose rate, the release rates for the sample period are assumed to continue at the respective Icvels for a year, hence the wording " annual average" release rate.

4. The equations in Sections 3.3.3.a and 3.3.3.b calculate air dose rate in mrad / year instead of dose in mrad. A time factor must be included in the equations to calculate the monthly dose.

.s Response:_ Sections 3.3.3.a and 3.3.3.b calculate gamma and beta air dose to evaluate 10CFR50 Appendix I compliance. 10CTR50 Appendix I limits are based on an ennual period, i.e., dose -

• limits are iri the units of mrad per year. (Per 10CFR50, Appendix -

. I, quarterly values one half the annual limits require written notification.) These equations are written to evaluate this annual limit. Doses are actually calculated for the period of release, using meteorological conditions concurrent vjth that release and the duration of release, and that dose is then compared to the annual limit. These calculations are performed at least monthly, as required by Technical Specifications. The-  ;

equations are written, however, to tvaluate the annual limits.

5. X/0 in Sections 3.3.3.a and 3.3.3.b is defined as the normal relative dispersion factor which is the product of the highest ,

annual average X/0 for the point of concern times the occupancy  :

factor. For these calculations, the occupancy factor must be set to 1 to calculate the maximum dose to air. Therefore, the X/0 term must be redefined as the highest annual average relative dispersion factor.

Response: The X/0 term in Sections 3.3.3.a and 3.3.3.b is defined as "the normal relative dispersion factor". These X/0 values are )

calculated using conditions present during the period of release. l as stated in the response to the preceding discrepancy.

Occupancy factors are not applied here. Confusion, related to I occupancy factors, may have been caused by the discussion in Section 4.3, Dose to Hembers of the Public vhile Onsite, where a

" relative X/0* term is used. The " relative X/0" used in Section 4.3 calculations, which incorporates an occupancy factor correction to an ennual average X/0. is not the same X/0 as that j

used in Section 3.3.3.a and 3.3.3.b calculations. The X/0 term used in Sections 3.3.3.a and 3.3.3.b is the X/0 term that is defined in Appendix A. A reference to Appendix A vill be added to the Section 3.3.3a and b. X/0 terms, to clarify this point. )

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ATTACHMENT 1 PY-CEI/NRR-0912L' ,

6. In Section 3.3.3, the method for time integration should be explained for converting dose rate to dose for I-131, I-133, tritium and radionuclides in particulate form with half-lives greater than 8 days. ,

Response: Annual dose rates resulting from the release of I-131, I-133, tritium and radionuclides in particulate form with half-lives greater than 8 days, as well as noble gas gamma and beta air dose, are calculated using the equations specified in the text. Dose values are obtained by applying the dose rates over the appropriate surveillance or sampling period. The ODCM is in the process of being revised to reflect this wording.

Additional Discrepancies

1. Figure 3.0-1 (probably page 29) shoving the gaseous effluent release

. points is missing from the ODCM.

Response: As noted in the NRC cover letter forwarding this TER, -

Figure 3.0-1 was found by the NRC and was reviewed. The NRC ~

requested that this complex figure be replaced with a simplified '

block diagram. This figure has therefore been redrafted, for

% inclusion in the ODCH, to improve clarity. This redrafted figure is enclosed for your information as Attachment 2 to this letter.

2. Section 3.2.2 states that the controlling location for the dose rate limit due to the release of I-131 I-133, tritium, and radionuclides in particulate form with half-lives greater than eight days is a function of the highest relative depos,ition, D/0. Since the dose rate is via the inhalation pathway as. stated in the bases statement for Technical Specification 3.11.2.1.b then the dose rate is dependent on the X/0 and not D/0.

Response: Dose rate calculations for the release of I-131, I-133, tritium, and radionuclides in particulate form with half-lives greater than eight days include contributions from several pathways. Per ODCM Table 3.2-3: these pathvays include ground shine, vegetables, meat, milk and inhalation. Calculations for all pathvays other than inhalation use D/0; inhalation pathvay calculations use X/0. Section 3.2.2 o' the ODCM is in the process of being revised to include X/O in this discussion.

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3. Section 3.2.2 contains Equation (3.2-1), a general equation for the dose rate via several pathvays. The section vould be considerably simpler, if the dose rate calculation vere limited to the child's thyroid via inhalation pathvay for consistency with the bases 1 statement of Technical Specification 3.11.2.1.  !

Response: Dose rates are calculated for several pathways, age  ;

groups, and organs (specified in Tables 3.2-1 through 3.2-3): one combination of which is the thyroid dose rate to child via the inhalation pathvay. By calculating other dose rates, ve are ensuring more complete Technical Specification compliance

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, assessment. This combination was taken from the text of -

NUREG-0473 as part.of an attempt to remain as consistent as possible to wording in that Guide. Dose rate compliance is evaluated for.the above mentioned combination, among others, in

.the calculations outlined in this section. ,

4.- 04 in Sections 3.3.3.a and 3.3.3.b should be defined as the average r61 ease rate of radionuclides i during the reporting period instead of the release rate of radionuclides i.

Response: As stated above, doses, per Sections 3.3.3.a and

' 3.3.3.b. are calculated for the period of release (and concurrent meteorological conditions) and those doses compared to the annual limit. Hence, the actual release rate for isotope "1" is used.

The data in Table 3.2-5 referenced in DFG U in Section.3.2.3.c are 5.

identical to'the data in Table 2.3-9.

.. Response: External dose factors are used for liquid and gaseous -

calculations. Tables of these factors are included in both sections for esse of user reference and to keep each section . .

(liquid and gaseous) separate, yet ' complete entities.

. 6. The data in Tables 3.2110 through 3.2-13 referenced in DTI in Section3.2.3.dareidenticaltothedatainTables2.3-5INough 2.3-8, respectively. It is not clear why two sets of identical tables are included in the ODCH.

Response: See r'esponse to Additional Discrepancy 5.

7. A simplified diagram illustrating the discharge pathways for the radioactive gaseous vaste systems is not included in the ODCH.

See response to Additional Discrepancy 1.

Response

8. A sirnplified diagram illustrating the solid vaste treatment system is not included in the ODCM.

Response: All matters pertaining to solidified vaste treatment (and devatering) are. contained in Perry's Process Control Program (PCP) which has been previously submittad under a separate cover.

9. Table 5.1-1 of the ODCH does not include control location 28 for the milk sample.

Response: REMP Location 28, a vater sample control, is contained in the waterborne sampling media portion of Table 5.1-1.

10. Figures 5.1-1, 5.1-2, and 5.1-3 containing Temporary change 5 to the  !

Environmental' Moni'oring Program map are missing in the ODCM. The )

available maps, updated through Temporary Change 4, do not identify j sample locations 29, 44, 48, 52 S3, 54, 55, and 56. l I

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l ATTACHMENT 1 PY-CEI/NRR-0912L Response: As noted in the NRC cover letter forwarding this TER, Figure.= 5.1-1, 5.1-2, and 5.1-3 vere found by the NRC and have been reviewed. The REMP figures in the current version of the ODCM are up to date and include all locations listed in the REMP tabler. -

Suggestions

1. In Equation 2.3-3 the exponential buildup term 1,neludes a 20 year value for t the period of time for which the sediment is exposed to the contIm,inated vater. The 20 years is a conservative value and could probably be replaced with a lesser value which would be increased 3r the plant ages. ,

Responsc: The twenty year exponential build up term was incorporated at the request of our original NRC (NRR) ODCM revievers. ,

2. In Table 2.3 4, the bioaccumulation factor of 1.0E+05 for phosphorous could be replaced with a lesser value of 3.0E403. , .

'- Response: The bioaccumulation factor of 1.0E405 for phosphorous was taken f rne Regul~atory Guide 1.109 Revision 1, Table A-1,

, f reshre.t e: fish. Ve vere not avare of the 3.0E.03 value and 4 vould(appreciate identification of its source. .

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3. Table 2.3-10 lists current values for the dilution ratios M . If the adjustment f actor allowed by NUREG 0133 is included in Ehe dilution terms in the equations of Section 2.3.1, then Table 2.3-10 can be deleted from the ODCH.

Response: Perry plans to use the dilution ratios specified in Table 2.3-10 for liquid radioactive effluent dose calculations.

See the response to Major Discrepancy 2 for elaboration.

4. If the ne::t revision to the ODCM includes only the inhalation pathvay fe: the dose rate calculation in Section 3.2.3, then a better location for all the dose rate expressions of Section 3.2.3 vould be in Section 3.3 vhere they are used in the dose calculation due to the release of I-131, I-133, tritium and radionuclides in particulate form with half-lives greater than eight days.

Response: Perty opts to use the organs. age groups, and pathvays

~ specified in Tables 3.2-1, 3.2-2, and 3.2-3, respectively, f or dose rate compliance assessment. This approach is considered l more conservative, see the response to Additional Discrepancy 3 for elaboration.

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