PNP 2019-014, 2018 Radiological Environmental Operating Report

2018 Radiological Environmental Operating Report

ML19066A205
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	03/07/2019
From:	Hardy J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
PNP 2019-014
Download: ML19066A205 (15)

Text

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~ Entergy PNP 2019-014 March 7,2019 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert. MI 49043 Tel 269 764 2000 Jeffery A. Hardy Regulatory Assurance Manager 10 CFR 72.44

Subject:

2018 Radiological Environmental Operating Report Big Rock Point Plant Dockets 50-155 and 72-043 License No. DPR-6

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. is submitting the enclosed Radiological Environmental Operating Report for the Big Rock Point Independent Spent Fuel Storage Installation (ISFSI). This report was prepared in accordance with the requirements of 10 CFR 50, Appendix I, Section IV.B, and Defueled Technical Specification 6.6.2. The period covered by the enclosed report is January 1, 2018, through December 31, 2018.

This letter contains no new commitments and no revision to existing commitments.

Respectfully, C)AIAf},

JAH/bed

Enclosure:

Big Rock Point 2018 Annual Radiological Environmental Operating Report : Sample Collection Anomalies : Environmental Sample Schedule and Sample Location Maps : Radiological Environmental Monitoring Program Data for BRP ISFSI CC Administrator, Region III, USNRC BRP ISFSI Inspector, USNRC NMSS Project Manager, USNRC

Enclosure to PNP 2019-014 Big Rock Point 2018 Annual Radiological Environmental Operating Report I.

Introduction The 2018 Big Rock Point (BRP) Annual Radiological Environmental Operating Report provides a summary and data interpretation of the BRP Radiological Environmental Monitoring Program (REMP) as conducted during the 2018 reporting period. Reporting requirements are detailed in the BRP Defueled Technical Specification 6.6.2 and Offsite Dose Calculation Manual (ODCM).

The BRP ODCM contains the requirements for the REMP. The radiological environmental monitoring sampling requirements are greatly reduced from the plant's operating period and now only encompass Independent Spent Fuel Storage Installation (ISFSI) operations.

All samples were collected during the monitoring period with no anomalies.

Tables 1, 2, and 3, of this enclosure, provide a summary of 2018 BRP REMP sample requirements and results.

II.

Discussion and Interpretation of Results A.

TLDs - Gamma Dose The BRP Gamma Dose Assessment Program consists of eleven thermoluminescent dosimeter (TLD) locations: Four at the outside perimeter of the ISFSI (locations: BR-18, BR-19, BR-20, and BR-21), four at the ISFSI protected area fence line (locations: BR-22, BR-23, BR-24, and BR-25), and three control TLDs, approximately 13 miles out (locations: BR-5 Petoskey, BR-6 Boyne City, and BR-7 Ironton). These are the only TLDs required for ISFSI operation. The additional locations are no longer applicable because they no longer exist. Environmental gamma doses are measured quarterly by placement of one TLD badge per designated location. Detailed sample station identification and location information is provided in Attachment 2.

For 2018, the average quarterly gamma readings were:

23.1 millirem for protected area fence TLDs, 19.1 millirem for ISFSI outside perimeter TLDs, and 19.3 millirem for the control TLD locations.

The comparative evaluation of the protected area fence TLDs mean measured in 2018 is slightly less than that of 2017. The 2018 quarterly TLD mean of the ISFSI outside perimeter and control TLDs is slightly greater than those of 2017. All values are within the statistical standard deviation.

Page 1 of 5

A comparative evaluation was also completed of the 2018 offsite control TLD data to the ISFSI outside perimeter TLD data. There was excellent correlation between the off-site control TLDs and the ISFSI outside perimeter TLDs. There was no significant difference between the 2017 and 2018 control data.

Each TLD badge contains a 4-chip TLD that meets ANSI N545-1975 requirements.

B.

Air Samples The BRP REMP no longer requires that airborne surveillance be conducted.

c.

Milk The BRP REMP no longer requires that milk samples be collected.

D.

Lake Water The BRP REMP no longer requires that lake water samples be collected.

E.

Drinking Water The BRP REMP no longer requires that drinking water samples be collected.

F.

Crops The collection of food crops/vegetation is not required by the BRP REMP.

G.

Sediment The BRP REMP no longer requires that well water samples be collected.

H.

Aquatic Biota The collection of aquatic biota (algae and periphyton) is no longer required by the BRP REMP.

III. Assessment of BRP ISFSI Operational Environmental Impact Review and comparison of the 2018 BRP radiological environmental monitoring data to previous data shows that the parameters analyzed support the conclusion that ISFSI operations have had minimal environmental impact.

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Table 1. Sampling and Analysis Summary Number of Samples Freguenc~ of Medium Description Location(s)

T~pe of Anal~sis Collected Anal~sis TLD BR-5, BR-6, BR-7, 18-25 BRP, 5-PT, Gamma Isotopic 44 Quarterly a BR-18-25 6-BC,7-IR Lake Water 1 gallon composite 1-ST

Tritium, 0

No Longer Required Gamma Isotopic Well Water 1 gallon Site Well

Tritium, 0

No Longer Required grab/composite Gamma Isotopic Monitoring Wells 1 gallon grab MW 1-9

Tritium, 0

No Longer Required Gamma Isotopic Sediment Grab 1-ST,24-STS, Gamma Isotopic 0

No Longer Required 25-STN,26-LP Fish Grab 1-ST Discharge Gamma Isotopic 0

No Longer Required Table Notes a Only quarterly TLDs are required per Big Rock Point ODCM Page 3 of 5

Medium or Pathway Sampled (Units)

Direct Radiation:

TLD - Protected Area (mR)

Fence TLD - ISFSI Outside (mR)

Perimeter Waterborne:

Lake Water (pCi/L)

Well Water (pCi/L)

Lake Sediment:

Sediment (pCi/g dry)

Biota:

Fish (pCi/g wet)

Crayfish (pCi/g wet)

Table Notes:

Analysis Evaluated Versus Total Number Analyses Performed TLD (quarterly) de 16/16 TLD (quarterly) de 16/16 Sample not required Sample not required Sample not required Sample not required Sample not required Table 2. Sample Data Summary a Lower Limit of Detection (LLD) b 1.0 1.0 All Indicator Locations Mean C (Range) 16/16 16/16 23.1 (16-34) 19.1 (14-25)

• Values for sample locations with the greatest annual mean are provided in Table 3.

All Control Locations Mean c (Range) 12/12 12/12 19.3 (15-23) 19.3 (15-23) b Nominal LLD as defined in the Big Rock Offsite Dose Calculation Manual Section I, Table 1-3 and vendor analytical capabilities.

C Mean and range data reported are based upon detectable measurements.

d Quarterly TLD results are normalized for 91 days net.

• Quarterly TLDs are read quarterly. Quarterly measurements are compared to control measurements to evaluate compliance with 10 CFR 72.104.

The results for the ISFSI TLDs and the average of the control TLDs measured in 2018 are summarized in the Table.

Page 4 of 5 Nonroutine Measurements None None

Table 3. Reporting Results Greatest Mean Sampling Location Medium Type of Analysis Location High Low Mean TLD - Protected Area Fence TLD (Quarterly) a b BRP-23 34 25 30.5 (mR)

TLD - ISFSI Outside Perimeter TLD (Quarterly) a b BRP-20 25 19 21.8 (mR)

Lake Water No Longer Required (pC ilL)

Well Water No Longer Required (pCilL Sediment No Longer Required (pCi/g dry)

Fish No Longer Required (pCi/g wet)

Crayfish No Longer Required (pCi/g wet)

Table Notes:

a Quarterly TLD results are normalized for 91 days net.

b Quarterly TLDs are read quarterly. Quarterly measurements are compared to control measurements to evaluate compliance with 10 CFR 72.104. The results for the ISFSI TLDs and the average of the control TLDs measured in 2018 are summarized in the Table.

Page 5 of 5 Sample Collection Anomalies LOCATION TYPE REASON NONE TO REPORT Page 1 of 1 Environmental Sample Schedule and Sample Location Maps TABLE 1-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Number of Representative Samples Sampling and and/or Sample and Sample Locations a Collection Frequency

1.

Direct Radiation b 11 monitoring stations either with two Quarterly or more TLDs or one instrument for measuring and recording dose rate continuously, placed as follows c:

a) Balance of stations (3) placed to serve as control stations b) Outside perimeter of ISFSI (4)d c) ISFSI protected area fence line (4)d Type and frequency of Analysis Gamma dose quarterly

a.

Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report pursuant to the Reporting Requirements of ODeM. Alternative media and locations may be chosen for any particular pathway if designated locations or media are not available, and appropriate substitutions are made within 30 days in the radiological environmental monitoring program.

b.

One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. The background dosimetry requirement also may be met through use of dosimeters shared with another facility, or from data provided by another entity, such as the State of Michigan, as appropriate for this site.

c.

For the purposes of this table, a TLD is considered to be one phosphor; two or more phosphors or phosphor readout zones in a packet are considered as two or more dosimeters.

d.

TLDs designated for ISFSI only operation.

Page 1 of 3

W Big Rock Point Environmental Sample Location Map N

BR.BR-21 BR-"EJ.. "

BR-23 BR-24 @

BR.BR-20 Page 2 of 3 E

BIG ROCK POINT CONTROL TLD LOCATIONS BR*7 (JR)

IRONTON Page 3 of 3 Radiological Environmental Monitoring Program (REMP) Data for Big Rock Point (BRP) Independent Spent Fuel Storage Installation (ISFSI) 4 Pages Follow

MIRION TECHNOLOGIES Global Dosimetry Solutions Environmental Report Account 89567 RSCS Location OOOOODPT M~nitoriflg Period 1/112018 PrOcess 0238304 Badge Numbe.r Name I Exposure mR* I CONTROL I

15 I 1

BR-5 21 2

BR-6 I

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3 BR-7 I

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BR-18 18 5

BR-19 I

21 6

BR-20 I

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BR-22 I

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Page 1 of 4

MIRION TECHNOLOGIES Global Dosimetry Solutions Environmental Report A~,"Q!!.~L ',:., _. __. 89567 RSCS Location OOOOODPT rJlonltoi'ing.perJod 4/1/2018 Proce~s 0239285 I Badge NlImiJer Name Exposure mR* I L

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+ - Unusual element result observed.

0 - Element damaged and cannot be evaluated.

Page 1 Clf 1 REP41G9_0 Page 2 of 4

MIRION TECHNOLOGIES Global Dosimetry Solutions Environmental Report A~coiJl'it_. ___... _ 89567 RSCS Location OOOOODPT Mopltorlng Peri~tct 7/112018 Process 0240274 Bad9~ Numb~~

Name Exposure mR*

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+

• Unusu31 element result observed.

D* Element damaged and cannot be evaluated.

Page 1 of 1 REP4109_0 Page 3 of 4

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