ML17055B754

Forwards Rev 1 to Offsite Dose Calculation Manual,Per 860502 Request.Sections Containing Equations & Methodology Significantly Expanded to Clarify Source of Equations. Franklin Research Ctr Comments Also Encl

ML17055B754
Person / Time
Site:	Nine Mile Point
Issue date:	06/05/1986
From:	Mangan C NIAGARA MOHAWK POWER CORP.
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML17055B756	List: ML17055B754 ML18038A167
References
(NMP2L-0733), (NMP2L-733), NUDOCS 8606110212
Download: ML17055B754 (30)

Text

REQUL45gRY INFORNATIQN -DISTRIBUT~ SYSTEl'f. (R IDS>

'I ACCESSION NBR: 8606110212 DOC. DATE: 86/06/05 NOTARIZED: YES DOCKET ¹ FACIL: 50-410 Nine Nile Point Nuclear Station~ Unit 2~ Niagara Noha 05000410 AUTH. NAIVE AUTHOR AFFILIATION MANQAN, Q. V. Niagara Nohatok Poeer Corp.

RECIP. MANE RECIPIENT AFFILIATION ADENSANp E". Q. BAR Prospect DirectoY ate 3

SUBJECT:

Forwards Rev 1 to oFFsite dose calculation manual>'per 860502 request. Sections containing equations 5 methodology signiFicantlg expanded to clariFg source oF equations.

Franklin Research Ctr comments also encl.

DISTRIBUTION CEDE: *GCBD CDPIEB RECEIVED: LTR TITLE: OR/Licensing Submittal: Appendix I l ENCL g SIZE:

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0 UM'QHAWK NIAGARA MOHAWK POWER CORPORATION/300 ERIE BOULEVARD WEST, SYRACUSE, N.Y. 13202/TELEPHONE (315) 474-1511 June 5, 1986 (NMP2L 0733)

Ms. Elinor G. Adensam, Director BWR Project Directorate No. 3 U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Washington, DC 20555

Dear Ms. Adensam:

Re: Nine Mile Point Unit 2 Docket No; 50-410 I

The enclosed Revision 1 to the Nine Mile Point Nuclear Station Unit 2 Offsite Dose Calculation Manual (ODCM) is submitted in response to your request of May 2, 1986. The general requirements of the Request for Additional Information as well as the specific comments provided by Franklin Research Center have been addressed in revision 1 of the Offsite Dose Calculation Manual, as summarized below and in the attachment to this letter.

The seventeen specific references to the Technical Specifications listed in paragraph 2 of the Request for Additional Information have been included as a cross-reference in the Table of Contents. Specific references to the Technical Specifications are also included within each section. The sections containing equations and methodology have been significantly expanded to clarify the source of the equations, and examples are given for many of them.

The referenced tables, Table 2.1 for liquid effluent monitors and Table 3.1 for offgas, have been provided as representative values. Sections 2.1.3, for liquid monitors and 3.1.3, for gaseous monitors, have been provided to discuss periodic calibration to confirm these values.

Section 6 has been added to provide the discussion of several table notations which resulted from the development of the Environmental Monitoring Program specifications.

Figure 5.1.3-1 of the Technical specifications has been provided in addition to the maps showing envrionmental sampling locations.

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Ms. Elinor G. Adensam Page 2 Attachment 1 of this letter is an item-by-item response to the comments provided by Franklin Research Center.

Additional information and further clarification has been provided to produce a complete and comprehensive Offsite Dose Calculation Manual. Your further suggestions for improvements will receive our immediate attention.

Very truly yours, C. V. Mangan Senior Vice President NLR:saa Enclosure 1684G xc: R. A. Gramm, NRC Resident Inspector Project File (2)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Niagara Mohawk Power Corporation ) Docket No. 50-410 (Nine Mile Point Unit 2) )

AFFIDAVIT C. V. Man an , being duly sworn, states that he is Senior Vice President of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

Subscribed and sworn to before me, a Notary ublic in and for the State of New York and County of' thi s day of 1986.

Notary Public in and for linen 'ounty, New York My Commission expires:

CHRISTINE AUSTIN Notary Public in the Qate of Neo Yorit uaiihed in Onondaga Co. No. 478768g Ex <<ea March 30, lou

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ATTACHMENT 1 Franklin Research Center ODCM Comments (Unit 2)

Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sub'ect Pa e Number Comments ~Res onse ~PII b Table of Contents 'he Licensee should provide a A table of contents table of contents for the ODCM. has been provided.

Liquid Radwaste The Licensee should specify the The units (cpm) are Effluent Monitor units for the alarm setpoints. given in Section 2.1.2.1.

Alarm Setpoint (Sec. 2.1.2.1) 'nthe factor the equation for k

the setpoint, is not clearly The factor has been set at 0.8 in Section 2.1.2.1 defined. The Licensee may apply the laboratory experience to introduce an appropriate safety factor for the setpoint calculation: the factor should be a specific number.

1, 2 'he Licensee should provide The nominal flow rates are 7 nominal flow rates for the provided in Section 2.1.3.1.

effluent line (f) and the dilution flow (F). Also, the sources of dilution water should be identified.

Service Water A and B 'ame as above, specify the The units (cpm) are given 5 and Cooling Tower units for alarm setpoint. in Section 2.1.2.3.

Blowdown Radiation Detector Alarm Setpoint (Sec. 2.1.2.2)

0 Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sub'ect Pa e Number Comments ~Res ense Pa e Number

'ame as above, specify the The factor hs been set at 5 factor k. 0.8 in Section 2.1.2.3.

Service Hater A and 8 Specify the nominal flow rates The nominal flow rates are 10 and Cooling Tower for service water A and 8, and provided in Section 2.1.3.2.

Blowdown Radiation the cooling tower blowdown.

Detector Alarm Setpoint (Sec. 2.1.2.2) 'he Licensee has not considered Provision for setting the simultaneous releases from Radwaste Monitor set point more than one effluent line in concurrent with the setpoint calculation. contamination of a dilution stream are provided in Liquid Effluent Detectors Responses

't is not clear to what types of radiation (gamma, beta, or both)

Section 2.1.2.2.

Liquid Effluent Detector discussion provides this 6

(Table 2-1) the detector responses provided info. in Section 2.1.3.1 in Table 2-1 are related.

'hat is the justification for Response of the detector 6 considering only the isotopes to liquid samples from listed in the tables? Are other appropriate waste streams isotopes ignored? is described in Section 2.1.3.1.

Liquid Concentration 'o demonstrate that the Licensee's Technical Liquid Effluent 12 Concentration will be Specification 3.11.1.1 is met, calculated and compared to the surveillance requirements MPC in accordance with the specify that the sampling and equation of Section 2.2 for analysis program be implemented all effluent streams for all according to Table 4.11-1 of the periods of release. This RETS. According to the NRC Branch summation will therefore Technical Position, the Licensee account for combined should: discharges to the same release point.

Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sub ect Pa e Number Comments ~Res ouse ~PN b "Provide the equations and methodology to be used at the station or unit for each liquid release point according to the Specification 3.11.1.1. For systems with continuous or batch releases, and for systems designed to monitor and control both continuous and batch releases, provide the assumptions and parameters to be used to compare the output of the monitor with the liquid concentration specified. State the limitations for combined discharges to the same release point.

In addition, provide the Section 2.5 addresses 15 method and assumptions for sample representativeness.

obtaining representative The results of sampling samples from each batch and and analysis in accordance describe the previous with Table 4.11-1 provide post-release analyses or the concentration data composite sample analyses used in Section 2.2.

used to meet the specification."

Liquid Effluent Dose Liquid pathways are not clearly All efflluents are 28, 13 Dose Calculation identified for the dose calculation. discharged via the same Methodology (Sec. 2.2) pathway. See figure 2-9 and Section 2.3 for discussion of the dose pathways to be included in dose calculation.

Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sub ect Pa e Number Comments ~Res ouse ~PII I

'quations for the dose factor Section 2.4 provides the 14 A;t should be provided in the ODCM. equation from NUREG 0133 Section 4.3.1 which was referenced in Rev. 0.

Table 2-2 The Licensee should explain why Section 2.4 explains why 15 the table provides data only only the isotopes listed for the isotopes listed. were provided and describes the action to be taken if nuclides are encountered in addition to those provided in Table 2-2.

Stack Noble Gas Detector Alarm Setpoint

'nits for the alarm setpoint not The units (uCi/sec) are 30 specified. given in Section 3.1.2.1.

(Sec. 3.1.2.1)

'he factor k used for the The factor has been set at 31 setpoint equation is not defined 0.8 in Section 3.1.2.1.

or specified.

Hhat is the height of the stack The elevated releases 33 and the level of effluent releases discharged from the stack (elevated vs. ground level)? (8 131 meters) are discussed in Section 3.1.3.

Vent Nobel Gas 'ame comments as stated for stack The units (uCi/sec) are 31 Detector Setpoint monitor above. given in Section 3.1.2.2.

(Sec. 3.1.2.2)

The factor has been set 31 at 0.8 in Section 3.1.2.2.

Rev. 0 Rev. 0 Rev. 1 Rev. 1

~sub'ecc Pa e Number Comments ~Res onse ~PN N The vent is considered a 33, 58, ground level or combined 59 elevated/ground level release, as discussed in Sections 3.1.3, 3.4.5 and 3.4.6.

'imultaneous releases not Section 3.1.3 includes a 33 considered in the setpoint discussion of simultaneous calculation. release.

Vent Noble Gas 'he resulting unit for the The equation given in 31 Detector Setpoint setpoint equation is not Section 3.1.2.2 yields (Sec. 3.1.2.2) consistent with what it is uCi/sec, as required.

intended for: the end result will read "(m3/cc) (cpm)"

rather than just "(cpm)".

Offgas Pretreatment 'he Licensee has not been The units of Sections 31, 32 Noble Gas Detector consistent in choosing the 3.1 2.2 and 3.1.2.3 are

~

Setpoint (Sec. 3.1.2.3) units for the flow rates: now given in ml/sec and (m3/sec) was used in CFM, corresponding to the Sec. 3.1.2.2 and (cc/min) was two separate systems. It used in Sec. 3.1.2.3. is not desirable to make these the same.

Nobel Gas Detector 'pecify the types of radiation The off-gas monitor 36 Response (Table 3-1) (gamma or beta) for the detector detector is described in responses. Section 3.1.3.3

'rovide justifications for having Section 3.1.3.3 describes 36 only a few isotopes for the table. OG Monitor calibration and addresses Table revision based on isotopic analysis of offgas samples during operation.

Rev. 0 Rev. 0 Rev. 1 Rev.

~Sub 'ct Pa e Number Comments ~Res ense 1

Pa e Number Dose Rate Calculation 10 'he Licensee has not referenced Section 3.2 identifies the 37 Methodology (Sec. 3.2) the dose limits with which Dose Rate limits which compliance is to be demonstrated apply.

for the dose calculations.

12 'he Licensee uses 1.7E-06 (sec/m3) Changed X/Q to 2.0E-6 in 38, 39, for the highest calculated annual Sections 3.2.1 and 3.2.2 to 31 (X/Q), which is lower than 2.0E-06 be consistent with value (sec/m3) provided by the Licensee used for setting alarm in Section 3.1.2.2 (p. 7). Explain point (Section 3.1.2.2) the discrepancy. which is also based on: dose rate at the Site Boundary.

Plume Shine Parameters 13 'he Licensee has not provided a The methodology of 45 (Table 3-2) methodology to calculate the plume calculation is provided shine factors Bi and Vi. in Section 3.4.1.

'he Licensee did not provide any The values have been 62 data for Table 3-2. (The Licensee provided in Table 3-2.

stated that "The values in this table will be provided at a later time".)

Tables 3-4 to 3-21 15 to 32 Provide equations in the ODCM for The equations for 47-58 the parameters calculated in the calculating the parameters tables. for Tables 3-4 to 3-6 are in Section 3.4.3 and those for Tables 3-7 to 3.21 are in Section 3.4.4.

Uranium Fuel Cycle 35 'he Licensee stated that fish The drinking water pathway 90, 91 consumption and shoreline sediment is not significant.

are the pathways used for liquid Methodology for calculating dose calculation. However, the doses from shoreline drinking water pathway is not sediment is provided in considered. Also, the methodology Section 4.1.

to calculate doses from shoreline sediment is not provided in the ODCM.

~Sub'ect Rev. 0 Pa e Number 35 Rev. 0 Comments No methodology is provided to Rev. 1

~Res ouse The methodology using

~b Rev.

92 1

estimate the direct radiation. environmental TLD's is given in Section 4.3.

36 'he equation given for factor R The differences in the 94 is incorrect: some typographic equation given and the errors may have been committed. equations of Sections C-3 and C-4 of Reg. Guide 1.109 are identified in Section 4.4. (X/Q is in units of sec/m3). The equation is correct.

Environmental Honi toring Program 41-43 'nthe nature Table 5.1 for sampling locations, of the locations (such No on-si te moni tori ng locations are required.98-100 as on-site, control, or indicator) Control locations are is not clearly specified for each those located at map location. Since Nine Mile Point locations 30, 31, 38, 43, Units 1 and 2 and the Fitzpatrick 47, 54, 55; all easily plant are located at the same site, distinguished by distance the envrionmental sample locations, and direction. Unit 1 and by agreement between the respective Unit 2 ODCH's now indicate licensees, are supposed to be identical locations; the identical. However, numerous JAF recent revision differences are found between should be the same.

the sample locations of Nine Mile Point Unit 2 and the locations provided in the FitzPatrick ODCM (Rev. 2 dated June 25, 1985). It appears that Nine Mile Point Unit 2 has a complete list of the most up-to-date information on sample locations. However, the differences may reflect lack of coordination between the respective licensees on environmental sample programs.

Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sub'ect Pa e Number Comments ~Res ense Pa e Number Monthly Liquid Oose 'he Licensee did not provide a Section 2.6 was provided 16 Projection (RETS 4.11.1.3.1) section to describe the methodology to address TS 3.11.1.3.

for monthly liquid dose Note that it is expected projection per the Licensee's the liquid radwaste system RETS 3.11.1.3. will be fully utilized at all times, thus negating the need to make such a projection, except in unusual circumstances.

Liquid and Gaseous 'he NRC Branch Technical Position Figures 2-1, 2-2 and 2-3 20, 21, 22 Effluent Flow Oiagrams as issued in 1979 specifies needs define the Low Conduc-for the licensees to provide tivity Liquid Waste effluent flow diagrams to clarify System. Figures 2-4, and explain the operability of the 2-5 and 2-6 define the 23, 24, 25 radwaste treatment systems. The High Conductivity Branch Technical Position states: Liquid Waste System.

"Provide a flow diagram(s) defining the treatment paths and the com- Figures 2-7 and 2-& 26, 27 ponents of the radioactive liquid, define the Regenerant gaseous and solid waste manage- Waste System.

ment systems that are to be main-tained and used, pursuant to f Sol i di i cati on of 10CFR50.36a, to meet Technical waste is addressed Specifications 3.11.1.3, 3.11.2.4 in the Process Control and 3.11.3.1. Subcomponents of Program, separately packaged equipment can be identi- submitted (see TS fied by a list. For operating 3.11.3). The figures reactors whose construction permit provided are from the applications were filed prior to FSAR, Chapter 11.

January 2, 1971, the flow diagram(s) shall be consistent with the information provided in confor-mance with Section V.B.1 of Appendix I to 10CFR50. For OL applications whose construction permits were filed after January 2, 1971, the flow diagram(s) shall be consistent with the information provided in Chapter ll of the Final Safety Analysis Report (FSAR) or amendments thereto."

I Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sob ect Pa e Number Comments ~Res oose Pa e Number Liquid and Gaseous The flow diagrams should also tifiessFigure 2-9 iden-ODCM 28 Effluent Flow Diagram contain information on the the Service (Cont.) effluent monitoring instrumentation Water monitors (RE regarding the setpoint calculation. 146A and RE 146B),

Thus, the information as required by the Cooling Tower the Branch Technical Position Blowdown monitor includes: (RE157), and the Liquid Radwaste "The instrumentation for each alarm Effluent monitor and trip setpoint, including radiation (RE 206).

monitoring and sampling systems and effluent control features, should Figure 3-5 iden- 87 be identified by reference to the tifies the Gaseous FSAR (or Final Hazard Summary). Effluent pathways.

This information should be consis-tent with the recommendations of Figure 3-6 provides 88 Section I of Standard Review Plan a block diagram of 11.5, NUREG-75/087 (Revision 1)." the stack monitor (RE 170). The vent monitor (RE 180) is essentially identical.

Estimation of I-133 The licensee did not provide a Section 3.5 was 59 method to estimate the release of provided to indicate I-133. On estimating the radio- the methods of activity of I-133, the NRC staff estimating I-133 has specific guidance as follows: release.

"Under appropriate conditions, the See Section 3.5 59 l-133 contribution could be impor-tant to the Part 20 dose rates and to the Appendix I doses.

Therefore, Specifications 3/4.11.2.1 and 3/4.11.2.3 should be written as shown in the enclosures.

0 C' Rev. 0 Rev. 0 Rev. 1 Rev. 1

~Sub'ect Pa e Number Comments ~Res ouse Pa e Number Estimation of I-133 These speci fi cati ons wi 1 1 not (Cont.) explicitly require sampling and analysis to determine the I-133 releases. Therefore, Table 4.11-2 need not specify I-133.

Conversely, the Specifications will require accounting for I-133 and the method for so doing must be detailed in the ODCM. Acceptable methods will be addressed in NUREG-0133, Rev. l.

Acceptable approaches to estimating I-133 releases are as follows:

1. Convert the samples for I-133 (as well as I-131) and assume a constant release rate so buildup is proportional to

[1 exp(- At)]/A .

2. Periodically take short-period samples to determine the ratio of I-131 to I-133 activity. Then, use this ratio to estimate I-133 re-leases based on measurements of I-131 releases.

3. In special cases, where a Method 2 or Method 3 59 plant lacks capability for will be used depending measuring I-133, assume that on analytical results the I-133 activity release obtained. Method 1 is is 4 times the I-131 ambiguous; we do not acti vi ty." plan to use it.

t Rev. 0 Rev. 0 Rev. 1

~Seb ect Pa e.Number Comments ~Res onse Estimation of I-133 This requirement is applicable to (Cont.) a BHR such as Nine Mile Point Unit 2, especially since I-133 is not included in the sampling analysis program described in their RETS Table 4.11-2.

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