ML21132A226

Public Comment Resolution Table for RG 1.21 Rev 3 - DG-1377

ML21132A226
Person / Time
Issue date:	09/13/2021
From:	Steven Garry NRC/NRR/DRA/ARCB
To:
Song K
Shared Package
ML21132A170	List: ML21132A226 ML21132A291 ML21197A156 ML21197A158 Regulatory Guide 1.21
References
RG 1.21 Rev 3; DG 1377
Download: ML21132A226 (19)

Text

Response to Public Comments on Draft Regulatory Guide (DG)-1377 Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste Proposed Revision 3 of Regulatory Guide (RG) 1.21 On January 5, 2021, the NRC published a notice in the Federal Register (86 FR 326) that Draft Regulatory Guide, DG-1377, (Proposed Revision 3 of Regulatory Guide (RG) 1.21), was available for public comment. The public comment period ended on Feburary 19th, 2021. The NRC received comments from the organizations and people listed below. The NRC has combined the comments and the staff responses in the following table.

Anonymous commenter Janet Schlueter Nuclear Energy Institute (NEI),

Comments #1 to #4 below: Sr. Advisor, Fuel, LLW and Radiation Safety ADAMS Accession No. ML21050A440 1201 F Street, NW, Suite 1100 Washington, DC 20004 Comments #5 to #31 below.

ADAMS Accession No. ML21050A441

Commenter Section of Specific Comments NRC Resolution DG-1377 Anonymous Related Comment #1.1. Comment #1.1 accepted:

Guidance Consider adding the following (RG 1.184) to Related RG 1.184 has been added to the Related Guidance Guidance section. section of RG 1.21.

Comment #1.2. Comment #1.2 not accepted:

RG 1.184 for decommissioning. Section 8 (3rd paragraph) This comment pertains to changes to RG 1.184 (i.e.,

implies that continued use of Appendix I is discretionary, not to RG 1.21).

which may conflict with some of the language in the draft RG 1.21.

Anonymous Related Comment #2. Comment #2 accepted:

Guidance Consider adding the following to Related Guidance section: NUREG-0133 has been added to the Related NUREG-0133, as it has staff positions on methodologies for Guidance section of RG 1.21.

estimating exposure due to release of effluents Anonymous Related Comment #3. Comment #3 accepted:

Guidance Consider adding the following to Related Guidance section: NUREG-0543 has been added to the Related NUREG-0543, as it describes methods for complying with Guidance section of RG 1.21.

total dose requirement of 40 Code of Federal Regulations (CFR) 190 Anonymous General Comment #4.1. Comment #4.1 accepted:

Comment on existing version of RG 1.21 (Rev. 2): The text in Section 1.10 has been revised as follows There are references to the 10 percent of total dose criteria Licensees are responsible for evaluating any of Regulatory Position C in Regulatory Guide 1.109 in new significant exposure pathway and the resultant several places in Reg Guide 1.21. Neither RG 1.109 or RG radiological hazards associated with the return of 2

Commenter Section of Specific Comments NRC Resolution DG-1377 1.21 clarifies what the total dose reference value is. The radioactive material to the operating facility and its concept is to make sure that significant exposure pathways subsequent discharge to the environment. For are included in the total dose and to provide a criterion for purposes of estimating dose during operations or exempting or including a pathway. If total dose, in this decommissioning, a new significant exposure pathway context, was equated to the annual dose limits of Appendix is any pathway that contributes dose that exceeds 10%

I, then 10 percent would far exceed normal operational of the dose criteria in 10 CFR 50 Appendix I, Section doses, or the licensing phase Appendix I doses, as both are II (such that the dose from a new exposure pathway is typically very small fractions of the As Low As Reasonably unlikely to be substantially underestimated). Bounding Achievable (ALARA) dose limits taken from 10CFR50, dose assessments as described in Section 5.1 of this Appendix I. Operational doses are a moving target and may RG may be used in evaluating any new significant get smaller over time, especially during major phases of exposure pathway.

decommissioning, however a total dose reference value could be derived from a representative operational period. It The text in Section 5.7 has also been revised as is suggested that RG 1.21 be clarified to provide guidance follows:

on using operational doses or the Licensing phase Appendix I analysis doses to derive a 10 percent reference total dose. For purposes of demonstrating compliance with dose criteria for limiting dose to a member of the public in unrestricted areas in accordance with Technical Specifications conforming to 10 CFR 50, Appendix I, the exposure pathways and routes of exposure identified in RG 1.109 should be considered.

An evaluation of other exposure pathways (not included in dose assessments) should be performed and maintained for purposes of demonstrating compliance with the staff position on significant exposure pathways. Calculational procedures should be based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. A new exposure should be included in the demonstration of compliance if the calculated dose from that exposure pathway exceeds 10 percent of the 10 CFR 50 Appendix I, Section II numerical guides on design objectives.

3

Commenter Section of Specific Comments NRC Resolution DG-1377 Comment #4.2. Comment #4.2 not accepted:

Additionally, it would be of value to distinguish release The terminology of a release pathway is not used.

pathways from exposure pathways, and to note whether the Instead, the terminology of a exposure pathway is 10% criteria applies to a new release (sic) (exposure) used in lieu of a release pathway. The glossary pathway. defines a less-significant release point, a significant release point, and exposure pathways. Sections 1.3 and 1.4 provides guidance on monitoring significant release points, and less-signficaint release points.

There are several references to exposure pathways and examples given in the RG.

Janet Section C.6 Comment #5. Comment #5 not accepted.

Schlueter Page 39, Section 6. Solid Radioactive Waste Shipped for NRC established precedence RG 1.21, Rev. 1, dated Processing or Disposal - Paragraph 1, last sentence should June 1974. The historical guidance is that the volume be edited to read: The data reported should.from a to be reported is the volume shipped (see plant site for waste disposal (i.e., shipments directly to explanation below).

disposal and waste processor shipments to disposal).

RG 1.21, Rev. 1 (1974) in Appendix A, Section C stated: The total curie quantity and radionuclide composition of the solid waste shipped offsite (emphasis added) should be determined.

Currently, NRC Standard Technical Specifications (NUREG-1430, 1431, 1432, and 1433) provide guidance that licensees should report solid waste released from the unit.

The 1992 NRC Health Physics position (HPPOS-291) further documents the NRC position on reporting solid waste released from the site. NRCs position has been 4

Commenter Section of Specific Comments NRC Resolution DG-1377 that the volume of waste leaving the licensees facility should be reported.

https://www.nrc.gov/about-nrc/radiation/protects-you/hppos/hppos291.html Janet Section C.6 Comment #6. Comment #6 not accepted.

Schlueter Page 39, Section 6. Solid Radioactive Waste Shipped for See response to Comment # 5 above.

Processing or Disposal - Paragraph 5 should be deleted in its entirety as it is not risk-informed nor does it reflect the accepted practice of off-site processing of such wastes.

Janet Section Comment #7. Comment #7 not accepted.

Schlueter C.9.3 Page 45, Section 9.3 Solid Waste Shipments - Paragraph See response to Comment # 5 above.

1 should be edited to read: Appendix A, Table A-3, provides an acceptable.report the waste shipped for direct disposal (without offsite processing) and waste processor shipments of waste to disposal.

Janet Appendix A- Comment #8. Comment #8 partially accepted and partially not Schlueter 5 accepted.

Appendix A, Page A-5, Table A-3 should be deleted in its entirety and replaced with Table A-3, Low Level Waste Accepted: The reporting of waste classification has from Revision 2 (sic) (1) of RG 1.21. been removed from Table A-3.

Explanation:

Waste classification is a requirement for characterizing waste upon burial, not when shipped for off-site processing. Waste being sent to a processor is not in final form and therefore cannot be 5

Commenter Section of Specific Comments NRC Resolution DG-1377 classified until after processing when in final form for waste disposal.

Not accepted:

The report described in Table A-3 on solid waste shipments is required by Technical Specifications (e.g., see NUREG-1431, Rev. 4, Section 5.6.2 (

solid waste released from the unit.)

Janet Section Comment #9.1. Comment #9.1 accepted:

Schlueter C.1.6 Section C.1.6 of the draft guide clarifies requirements for The text has been revised in Section B, Reason for drinking water I-131 sampling. This section does not specify Revision as follows:

a receptor age group. The section should specify all ages to be considered, just adult age group, etc. It appears from

• Clarifies the existing guidance in NUREG-1301 and initial calculations that the infant age group actually appears NUREG-1302 that environmental monitoring for to be the highest dose factor for the iodines and about 3 iodine (I) -131 in drinking water should be times higher than adults for I-131. Recommend a basis be performed if a prospective dose evaluation of the included for having only adult dose factors. The critical age annual thyroid dose from I-131 to a person in any group varies by nuclide, with infant apparently age group from the drinking water route of predominating the drinking water pathway alone and either exposure is greater than one mrem.

adult or child predominating the combined drinking water and ingestion pathways. Recommend some clarification in The text has been revised in Section C.1.6 as follows:

Section 1.6 to specify that it is considering doses projected to be >1 mrem to the thyroid for any age group over a period NUREG-1301 and NUREG-1302 provide of one year. guidance on the Radiological Environmental Monitoring Program. Table 3.12-1 therein provides guidance on implementing the environmental monitoring program, including I-131 sampling and analysis on each composite of drinking water.

6

Commenter Section of Specific Comments NRC Resolution DG-1377 If a drinking water exposure pathway exists, a prospective dose evaluation should be performed based on I-131 in effluent discharges to determine the maximum likely annual I-131 thyroid dose to a person in any age group. The purpose of the prospective dose evaluation is to determine the environmental sampling and and analysis requirements.

Comment #9.2. Comment #9.2 accepted:

Clarification of the different analyses for I-131 being Text has been revised as follows:

discussed. Specifically, two different I-131 analysis requirements are involved. I-131 is analyzed in effluents to a If the likely dose from I-131 is greater than 1 mrem level of 1E-6 Ci/ml (per NUREG-1301/2 Table 4.11-1) and per year, a composite sample should be collected over the effluent concentration is used in calculating doses a 2-week period and an I-131 analysis performed with (NUREG-1301/2 SR 4.11.1.2) and projecting doses an LLD of 1 pCi/liter. If the likely dose from I-131 is (NUREG-1301/2 SR 4.11.1.3.1). The REMP analysis less than or equal to 1 mrem per year, a monthly requirement in NUREG-1301/2 Table 3.12-1 3.c. is what is composite sample should be collected, and an I-131 being clarified. There are a few things that may be worth analysis performed with an LLD of 15 pCi/liter.

elaborating on in the Reg Guide.

Comment #9.3. Comment #9.3 accepted:

Specifically, the wording is dose calculated for the Text has been added as follows:

consumption of the water, which implies that the other dose contributor (specifically, freshwater fish ingestion in this Note: Freshwater fish ingestion is not included in the case) is not considered in the determination (it should be prospective dose evaluation of I-131 from the drinking noted that depending on the nuclide and age group, fish water route of exposure.

ingestion by far dominates the combined dose factor). Many sites just follow the NUREG-0133 guidance to include the adult, combined drinking water and fish dose parameter for 7

Commenter Section of Specific Comments NRC Resolution DG-1377 Ai and may not currently be determining the drinking water-only doses.

Comment #9.4. Comment #9.4 accepted:

A second consideration is that the other projected dose The following text has been added to Section 1.6:

requirements from NUREG-1301/2 are 31-day dose projections, while this is an annual dose projection; more In addition, Standard Technical Specifications discussion/highlighting of this difference may be require determination of the projected dose worthwhile. contributions from radioactive effluents at least every 31 days, and determination of the cumulative dose contributions for the current calendar quarter and current calendar year.

Comment #9.5. Comment #9.5 accepted.

Finally, clarification that the projected doses are based on The text has been clarified as described in Comment #

the I-131 concentration in effluents seems like it would be 9.2 above, i.e., projected dose contributions from helpful. These are things that are easy to read past after you radioactive effluents.

have been doing this work for a while, but will be helpful in clarifying the requirement further and making it more useful for new program owners and for others who are less familiar with the intricacies of the regulatory guidance.

Janet General Comment #10. Comment #10 not accepted:

Schlueter Recommend that the abnormal release definition be changed The use of the terms discharge and release as back to revision 1 terminology (i.e. offsite, change abnormal described are more accurate and descriptive. The term discharge to onsite release, and change the unplanned discharge describes that portion of an effluent that release and discharge to match the abnormal terminology.) enters the offsite general environment outside the The swap in Rev 2 changing Abnormal Release to be an licensed area (i.e., the unrestricted area); whereas the 8

Commenter Section of Specific Comments NRC Resolution DG-1377 onsite release seems to be confusing people. Many sites term release is used to describe an effluent emitted have not adopted Rev 2, and Licensing procedures seem to from the plant to either the onsite or offsite environs.

be written.

Janet Appendix A Comment #11.1 Comment #11 accepted.

Schlueter (General)

Editorials: Pages have been renumbered.

• Appendix A - Tables, Page A-1 occurs on the pages with Tables A-1, A-1A, A-2, A-2A, A-4, and A-5.

• Appendix A, several of the Tables are difficult to read.

Specifically, Tables A-1 and A-2 should be formatted to make grouping clearer. An example of one approach is shown in Table A-4.

Comment 11.2 Tables A-1 has been revised to delete the average

• Tables A-1 and A-2, % of limit rows should be deleted or release rate and the % of limit. Table A-2 has been explained (i.e. the fraction of the MPC, fraction of dose revised to delete the average concentration and the limit, etc.) Recommend an explanation be given in Section 9  % of Limit. These criteria have been revised to % of about how to determine the percentages. dose limit in Tables A-4 and Table A-5.

See detailed response in comment #14 below which justifies and explains why the percent of the limit refers to the percent of the Appendix I dose values instead of an average release rate, average concentration, and % of limit.

• Table A-4 is missing data in the second column. It appears Table A-4, second blank column has been removed.

that it would normally hold units; however, the units are provided with the limits across the rows, so the blank column may be able to be deleted.

9

Commenter Section of Specific Comments NRC Resolution DG-1377 Janet Section Comment #12. Comment #12 accepted.

Schlueter C.5.5 Section 5.5 (pg. 35), These limits apply to doses resulting The statement in Section 5.5 regarding dose limits is from licensed and unlicensed radioactive material In this correct based on 10 CFR 20.1001(b) (i.e., dose limits case, it seems that unlicensed material would be essentially include doses from both licensed and unlicensed due to activity that had previously been released following material regardless of the year of discharge).

licensing requirements. It would be helpful to clarify this, since plants do not dose calculations based on releases from The text is Section 5.5 and 5.6 has been previous years. Similar clarification would be helpful for revised to clarify tht dose limits include contribution Section 5.6; given that plants do not calculate doses based to public doses from (1) current-year effluents, on previous years effluents that have built up in the (2) current-year direct radiation from the facility, and environment (for example tritium built up in a lake, or (3) accumulated radioactivity from prior-year nuclides built up in sediment around the discharge line, etc.). effluents. The Technical Specifications establish the Some of the dose calculations already include the Radioactive Effluent Controls Program and the assumption of buildup over a 15 (or 20 or 30) year period; Environmental Monitoring Program, which consist for example, ground plane release from gaseous effluents establish effluent control methods sufficient to and shoreline sediment from liquid effluents use a buildup demonstrate of compliance with the NRC public dose factor for 1/2 of plant life. The ground plane doses will be limits in 10 CFR 20.1301(a).

accounted for using TLDs. The whole concept of calculating doses based on previous years releases is outside of the A footnote (9) has been added to explain the normal dose calculation methodologies given in RG-1.109. following:

Doses from accumulated radioactivity from prior-year effluents do not need to be included in demonstration of compliance with the NRC and EPA dose limits unless the reporting levels in the environmental monitoring program associated with 10 CFR 50, Appendix I are exceeded.

Janet Section Comment #13. Comment #13 accepted.

Schlueter C.3.2 Section 3.2 first paragraph needs editorial clarification The text has been revised as follows:

regarding the wording for long-term annual average 10

Commenter Section of Specific Comments NRC Resolution DG-1377 atmospheric dispersion values. Recommend aligning The use of long-term annual-average meteorological wording within first paragraph of the section with the conditions based on 5 or more years of data to wording in the last paragraph of the section and change, the determine /Q and D/Q is appropriate for continuous use of long-term (5-year) annual-average to read, the releases and for establishing instantaneous release rate use of long-term (5 or more years) annual-average set points.

Janet Appendix A Comment #14. Comment #14 accepted.

Schlueter Appendix A, Page A-1, Tables A-1 and A-2. The row, % of Previously, Tables A-1 and A-2 requested data on the limit is believed to be a typo which should have been average release rate and the % of limit.

deleted going from revision 1 to revision 2 of this Reg The average release rate and % of limit are Guide. The directions to populate this row were present in unnecessary because a much more restrictive revision 1 but removed in revision 2. It is unclear what the requirement is imposed on the instantaneous release Reg Guide is requesting in this row, i.e. what limit is rate through Technical Specifications (see criteria in being referenced. Recommend to delete the row % of NUREG-0133). The NUREG-0133 instantaneous limit. criteria is implemented by establishing an instantaneous concentration limit for liquid effluents, and an instantaneous dose rate limit for gaseous effluents. Therefore, the instantaneous limit very conservatively assures that the annual-average concentration limits in 10 CFR 20, Appendix B will be met.

Furthermore, instantaneous radioactive effluent monitoring alarm and trip setpoint (s) are established by NUREG-0133 in Section 4.1.1 for liquid effluents and Section 5.1.1 for gaseous effluents. The NUREG-0133 guidance that radioactive effluent monitoring alarm and trip setpoint (s) provides correspond to a safe margin of assurance that instantaneous release limits not be exceeded.

11

Commenter Section of Specific Comments NRC Resolution DG-1377 Finally, the % of limit deletion was intended for removal in RG 1.21, Rev. 2 which established two new dose reporting Tables A-4 and Table A-5 to explicitly report and demonstrate compliance with dose limits. Table A-4 is used to report compliance with dose limits in Technical Specifications conforming to 10 CFR 50, Appendix I. Table A-5 is used to report compliance with dose limits required by Technical Specificatons and EPA 40 CFR 190.

Janet Section C.6 Comment #15. Comment #15 accepted.

Schlueter and 9.3 Sections 6 and 9.3 appear to be inconsistent for reporting Section 9.3 has been revised to include the exceptions potentially contaminated DAW, green is clean. to reporting requirements for solid waste shipped as Specifically, section 6.0 discusses shipments that do not listed in Section 6, which includes green-is-clean need to be reported such as potentially contaminated DAW, waste.

green as clean; however, 9.3 lists DAW shipments as reportable.

Recommend to change Section 9.3, to clarify that potentially contaminated DAW green as clean shipments are not required to be reported.

Janet Section C.6 Comment #16. Comment #16 accepted.

Schlueter and 9.3 Sections 6.0 and 9.3 appear to be inconsistent regarding the The waste category shipment categories have been categories of shipments that should be reported. Specifically, generalized as follows:

Section 6.0 states that the following shipments must be 1. wet radioactive waste, reported: 1. spent resins, filters, evaporator bottoms, etc., 2. 2. dry radioactive waste, dry active waste, 3. irradiated components, and 4. other 3. activated or contaminated metal or waste. However, Section 9.3 states that the following equipment, and shipments must be reported: 1. spent resins, filter sludges, 4. other radioactive waste (bulk waste, soil, evaporator bottoms, etc., 2. dry active waste, contaminated rubble, etc., not excepted from reporting).

12

Commenter Section of Specific Comments NRC Resolution DG-1377 equipment, etc., 3. irradiated components, and 4. other waste. Section 9.3 includes contaminated equipment; The generalized waste categories above are consistent however, Section 6.0 does not include this type of shipment. with the waste forms listed in previous guidance as If a contaminated equipment shipment is required to be described in Sections 6 and 9.3.

reported, clarification is needed, e.g., disposal of contaminated equipment only versus transport for decontamination, or transfer to another site for their use, etc.

Also, would this include a shipment of activated but not necessarily contaminated equipment?

Janet Section B Comment #17. Comment #17 accepted.

Schlueter Page 12, compliance with the effluent reporting A footnote has been added to 10 CFR 36a as a pointer requirements of 10 CFR 50.36a. to Section 9.0 which provides guidance on ISFSI effluent reporting requirements under 10 CFR Comment - Deleted text related to 10 CFR 72.44(d) ISFSI 72.44(d).

effluent reports. Does that mean there is going to be another format or guidance provided for that? If so, should that be referenced here?

Janet Section Comment #18. Comment #18 accepted.

Schlueter C.1.2 Page 15, 6. the unrestricted area, which may be defined Item #6 has been removed and changed to a clarifying separately for liquid effluents, gaseous effluents, and, if footnote as follows:

appropriate, other radiological controls such as direct radiation. The boundaries of the unrestricted areas may be Comment - Is this really meant to be an item 6, it appears to defined separately for liquid effluents, gaseous be a clarification of what restricted area is, (described under effluents, and if appropriate, for other radiological

1. Section C.1.2.3.c). controls such as direct radiation..

13

Commenter Section of Specific Comments NRC Resolution DG-1377 Janet Section Comment #19. Comment #19 not accepted.

Schlueter C.1.5 Page 16 and 17, e.g., refer to the environmental LLDs in The example provides useful guidance on where NUREG-1301 and NUREG-1302, Table 4.12-1, Detection licensees can find acceptable LLD values and also Capabilities for Environmental Sample Analysis, or LLDs offers the alternative of determining LLD values determined by using the methodology outlined in NUREG- based on NUREG-1576, Multi-Agency Radiological 1576. Additionally, licensees should apply plant-process- Laboratory Analytical Protocols Manual.

system knowledge when evaluating leaks and spills.

Comment - Delete the (following) example e.g., refer to the environmental LLDs in NUREG-1301 and NUREG-1302, Table 4.12-1, Detection Capabilities for Environmental Sample Analysis, or LLDs determined by using the methodology outlined in NUREG-1576. Additionally, licensees should apply plant-process-system knowledge when evaluating leaks and spills.)

Janet Section Comment #20. Comment #20 accepted.

Schlueter C.1.5 Page 17, Although prompt remediation is not a requirement Response:

(Ref. 54), remediation should be evaluated and implemented, as appropriate, based on licensee evaluations EPRI Reports No. 1021104 "Groundwater and Soil and risk-informed decision making. Evaluation factors Remediation Guidelines for Nuclear Power Plants," (a should include (1) the location and accessibility, (2) the proprietary document) and Report 1023464, concentrations of radionuclides and extent of the residual Groundwater and Soil Remediation Guidelinse for radioactivity, (3) the efficacy of monitored natural Nuclear Power Plants (a public document) have been attenuation, (4) the volume of the release, (5) the mobility of added as references.

the radionuclides, (6) the depth of the water table, and (7) whether significant residual radioactivity (see glossary) is expected at the time of decommissioning.

Comment - Suggest adding reference to EPRI Report No.

1021104 "Groundwater and Soil Remediation Guidelines for 14

Commenter Section of Specific Comments NRC Resolution DG-1377 Nuclear Power Plants," Electric Power Research Institute, Palo Alto, CA, December 2010.

Janet Section Comment #21. Comment #21 accepted.

Schlueter C.1.6 Page 18, NUREG-1301 and NUREG-1302 provide The text in C.1.6 has been revised as follows:

guidance on implementing the environmental monitoring program for I-131 analysis on each composite of drinking NUREG-1301 and NUREG-1302 provide water. The sampling and analysis of a drinking water guidance on the Radiological Environmental composite sample should be performed when the projected Monitoring Program. Table 3.12-1 therein provides annual thyroid dose from I-131 in drinking water is greater guidance on implementing the environmental than 1 mrem. monitoring program, including an I-131 sampling and analysis on each composite of drinking water.

Comment - Is the projection of annual thyroid dose based on the liquid effluent concentration? Is information on how to If a drinking water exposure pathway exists, a do this projection provided in another regulatory guide? prospective dose evaluation should be performed based on I-131 in effluent discharges to determine the maximum likely annual I-131 thyroid dose to a person in any age group from the drinking water pathway.

The purpose of the prospective dose evaluation is to determine the environmental sampling and analysis requirements for drinking water. Note: Freshwater fish ingestion is not included in the prospective dose evaluation of I-131 from the drinking water route of exposure.

If the likely dose from I-131 is greater than 1 mrem per year, a composite drinking water sample should be collected over a 2-week period and an I-131 analysis performed with an LLD of 1 pCi/liter. If the likely dose from I-131 is less than or equal to 1 mrem per year, a monthly composite sample should be 15

Commenter Section of Specific Comments NRC Resolution DG-1377 obtained, and an I-131 analysis performed with an LLD of 15 pCi/liter.

Janet Section Comment #22. Comment #22 not accepted.

Schlueter C.1.8 Page 19, This RG introduces the term principal The guidance as stated in the draft RG was correct in radionuclide in a risk-informed context. A licensee may use of the word may because there may be other evaluate the list of principal radionuclides for use at a acceptable methods of determining principal particular site. The principal radionuclides may be radionuclides developed by licensees (if technically determined based on their relative contribution to (1) the justifiable).

public dose compared to the 10 CFR Part 50, Appendix I, design objective doses ..

Comment - Saying "may be determined... or" makes it sound like there is a choice. Where in fact, a principal radionuclide is determined if it is either of these things. May want to use "and" instead of "or" here? It is clearer when the 1% rule is provided in the paragraph below. There the use of the term "or" is appropriate.

Janet Section Comment #23. Comment #23 accepted.

Schlueter C.1.9 Page 21, Estimation of Carbon-14 in Nuclear Power Plant The report number has been corrected 1021106.

Gaseous Effluents, Technical Report 1011106 (Ref. 60).

Comment - Needs to be changed to 1021106 Janet Section Comment #24. Comment #24 accepted.

Schlueter C.2.2 Page 23, (ASTM) D 3370-07 and ASTM D 3370-095A, The reference number has been updated to Standard Practices for Sampling Water from Closed ASTM D3370 - 18.

Conduits (Ref. 62)

Comment - These standards appears to be superseded by D3370-18.

16

Commenter Section of Specific Comments NRC Resolution DG-1377 Janet Section Comment #25. Comment #25 accepted.

Schlueter C.3.6 Page 28, (Number) 6. The groundwater monitoring results This formatting error involving paragraph number (6) should be used in the development and testing of a has been corrected by deleting paragraph number (6) conceptual site model to predict radionuclide transport in with the text reformatted as the next sequential groundwater. The conceptual site model is generally paragraph.

considered adequate when it predicts the results of monitoring (sometimes called a calibrated model).

Comment - When comparing with the previous version, it appears that this is not meant to be #6 but a new paragraph that provides additional information.

Janet Section Comment #26. Comment #26 accepted.

Schlueter C.3.6 Page 28, contaminated material The word contaminated has been replaced with Comment - Suggest using term "radioactive material". licensed (radioactive) material.

Janet Section Comment #27.1. Comment #27.1 accepted.

Schlueter C.5.9 Page 38, contributions from I-131, I-133, tritium, and C-14 is a radioactive gas (mostly in the form of CO2 radionuclides in particulate form. Do the plants not have to and CO). Doses from C-14 are not included calculate doses due to C-14? If so, how should that be Appendix I which specifies limits for I-131, I-133, reported? tritium, and radionuclides in particulate form.

However, doses from C-14 must be included in demonstrating compliance with EPA 40 CFR 190.10 requirements because the EPR regulation specifies dose limits as a result of exposures to planned discharges of radioactive materials, radon and its daughters excepted, .

17

Commenter Section of Specific Comments NRC Resolution DG-1377 Comment #27.2. Comment #27.2 accepted.

EPRI also has a couple of reports on conducting C-14 dose EPRI Report No. 1024827 has been added as a calculations that may be a useful reference. EPRI Report No. reference in Section C.1.9, Carbon-14.

1024827 "Carbon-14 Dose Calculation Methods at Nuclear Power Plants" published April 2012.

https://www.epri.com/research/products/0000000000010248 27 Janet Section Comment #28. Comment #28 accepted.

Schlueter C.9.1 (Section 9.1, Gaseous Effluents) Page 42, fission and C-14 should be included in Tables A-1, and Tables activation gases, iodines/halogens, particulates, tritium, and A-1A through A-1F.

gross alpha.

Comment - Should carbon-14 not be included here (and subsequent tables) also? If not, where should Carbon-14 be reported?

Janet Reference Comment #29. Comment #29 accepted.

Schlueter Page 63, 60. Electric Power Research Institute, Estimation The reference number has been corrected to 1021106.

of Carbon-14 in Nuclear Power Plant Gaseous 196 Effluents, Technical Report 1011106, Palo Alto, CA, December 2010.

Comment - Needs to be corrected to 1021106.

Janet Reference Comment #30. Comment #30 accepted.

Schlueter 18

Commenter Section of Specific Comments NRC Resolution DG-1377 Page 63, 69. EPRI Report No. 1015118, Groundwater The reference to superseded EPRI Report 1015118 Protection Guidelines for Nuclear Power Plants, Electric has been replaced by the revised EPRI Power Research Institute, Palo Alto, CA, November 2007. Report No. 3002000546.

Comment - EPRI Report 1015118 has been superseded by EPRI report 3002000546 Groundwater Protection Guidelines for Nuclear Power Plants: Revision 1 Electric Power Research Institute, Palo Alto, CA., October 2013.

Also suggest adding EPRI Report No. 1021104 "Groundwater and Soil Remediation Guidelines for Nuclear EPRI Report No. 1021104 has been added to Section Power Plants," Electric Power Research Institute, Palo Alto, C.1.5 and included as new Reference No. 58.

CA, December 2010.

Janet Reference Comment #31. Comment #31 accepted.

Schlueter Page 63, Footnote 9 reports may be purchased from Corresponding Footnote No. 11 (on revised page number 66) has been changed as follows:

Comment - Change to "may be obtained from" from EPRI.

Saying it may need to be purchased may cause confusion for Copies of Electric Power Research Institute (EPRI) members who have access to the reports as part of their standards and reports may be obtained from EPRI, membership. Add EPRI website: https://www.epri.com 3420 Hillview Ave., Palo Alto, CA 94304; telephone which is the most convenient way for obtaining reports. (800) 313-3774; https://www.epri.com Also suggested deleted the fax number for simplicity.

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