ML20140D072

Forwards Rev 11 to Sections 7.2 & 8.0 of Offsite Dose Calculation Manual.Rev Incorporates Changes Made in Response to NRC Comments.Responses to Comments Encl

ML20140D072
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/20/1986
From:	Leblond P COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20140D075	List: ML20140D072 ML20140D076
References
1157K, NUDOCS 8601290116
Download: ML20140D072 (10)

Text

[ \\ Commonwealth E'Ison

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(v")'J Addr:ss Reply to-Post Offica Box 767

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One First National Plaza. Chicago. Ilknois O

Chicago, Illinois 60690 January 20, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Zion Station Units 1 and 2 Offsite Dose Calculation Manual Revision 11, June 1985 NRC Docket Nos. 50-295 and 50-304

Dear Mr. Denton:

Enclosed are 39 copies of Zion Station's Offsite Dose Calculation Manual, Sections 7.2 and 8.0, Revision ll, June 1985.

Revision 11 incorporates changes made in response to NRC comments and reviewed by Commonwealth Edison personnel. A copy of the CECO responses to NRC comments is enclosed in addition to a copy of the specific changes made.

Zion's ODCM Revision 11 han been reviewed and found acceptable by onsite and offsite review.

It was determined that the changes will not reduce the accuracy or reliability of dose calculations.

If any questions arise concerning this matter, please contact this office.

Very truly yours, P. C. LeBlond Nuclear Licensing Administrator im cc:

J. A. Norris - NRR Resident Inspector - Zion f

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p 1157K

i OFFSITE DOSE CALCULATION MANUAL ZION SECTIONS 7.2 and 8.0 REVISION 11 Summary of Changes to be Submitted in the Monthly Operating Report Revision 11 SECTION/PAGE CHANGE Table 7.2-1/

UW value (water usage) has ieen changed to the 7.2-1 value 0.083 liters /hr upon NRC reviewer's request to provide agreement with Reg. Guide 1.109.

Figure 7.2-1 Unrestricted area boundary has been moved to the shore line since no control can be exerted on the lake.

8.1/8.1-1 With NRC concurrence assumption b has been revised so that a constant radionuclide mix based on isotopic release data averaged over seven years (1977 through June 1984) is now used.

8.1/8.1-4 Mis-typed valves RV0001, RV0002, RV0003, and RV0004 were corrected.

8.1/8.1-4 To add more specificity, the phrase "through valves RV0005 and RV0006." was added to the last sentence of paragraph one.

8.1/8.1-5 A discussion of the service building ventilation monitoring system has been added per NRC reviewer's request.

Table 8.1-1/8.1-8 The composition of the mix noted on page 8.1-1 was added.

Table 8.1-2/8.1-9 Corrected mis-typed valve RV0004.

Figure 8.1-1 Figure was added per NRC reviewer's request to clarify release pathway.

Figure 8.2-1 Figure was added per NRC reviewer's request to clarify release pathway.

Table 8.4-1, Item 2/8.4-3,8.4-4 TLD locations have now been listed explicity for clarification.

o SFCTION/PAGE CHANGE Table 8.4-1, Item 3/8.4-4 Per agreement with NRC staff, surface water (public water supply) analysis to only require gamma isotopic and tritium analysis.

Table 8.4-1, Item 3/8.4-5 Addition of tritium analysis for cooling water sample to this section based on NRC reviewer's request.

Table 8.4-1, Item 3/8.4-5 The sediment sample collection frequency was revised to match Tech Spec frequency.

Table 8.4-1, Item 4/8.4-5 Per agreement with NRC staff, milk collection changed to semi-monthly during grazing season.

Table 8.4-1 Item 4/8.4-6 Addition of collection and analysis of food products when milk sampling is not performed per NRC request.

Table 8.4-1/8.4-6 Footnotes to table revised to read correctly at NRC reviewer's request.

Table 8.4-3/8.4-7 Reporting level table has been revised to be made consistent with Tech Specs.

Table 8.4-2/

8.4.8 through 8.4-10 LLD table has been revised to be consistent with Tech specs per NRC reviewer's request.

Figure 8.4-1 Figure has been updated to show water and milk sample locations.

Figure 8.4-2 Figure has been revised to reflect TLD numbering revision.

Figure 8.4-3 Figure has been revised to include water and fish sampling locations.

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June 13, 1985 Page 1 of 6 j

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COMMONWEALTH EDISON COMPANY RESPONSE TO NRC REVIEW OF THE ZION ODCM SUBMITTAL l

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June 13, 1985 Page 2 of 6 SECTION/PAGE COMMENT CECO RESPONSE 2.1.1.1.1.2.1/

Section 3.2.2.3 should Rev. 11 (page 2.1-6) has 2.1-5 be section 3.2.2.2 or section correctly. stated

p. 2.1-5.

as 3.2.2.2.

2.1.1.1.2, Reason for inclusion of These sections have been 2.1.1.1.3/

sections 2.1.1.1.2 and revised in Rev. 11 (see 2.1-6 to 2.1-8 2.1.1.1.3 not clear pp. 2.1-8 to 2.1-10 ).

(i.e. calculations not The formulas for whole required).

body and skin dose have been retained to facili-tate station calculation of these quantities when desired.

However, the limits on these doses stated in Rev. 2 have been removed from the text as these limits are not required by the Technical Specificatio.ns.,

2.1.2/2.1-10 Ground plane pathway Equation 2.11 in Rev. 11-not addressed.

(p. 2.1-12) has been modified to include ground planc exposure.

2.1.2.1.1/2.1-5 Tena f in Equation Rev. 11 (p. 2.1-17) changed 2.15sbouldbedefined term ff a

to f nd detined as fraction of year f

as fraction of time a

the animals are animals are grazing on grazing on pasture.

pasture.

Rev. 11 (p. 2.1-20) cor.

2.1.2.1.2/2.1-17 (X/Q) should be (X/0)g.

rectly uses (X/0).g in the equation.

2.1.2.2/2.1-17 ODCM uses adult dose In Rev. 11 (p. 2.1-20),

rate via inhalation the inhalation dose rate to be limiting while to an infant has been NUREG-0472 states substituted for inhalation thyroid dose to child dose rate to an adult.

The via inhalation pathway infant dose rate is compar-is limiting, able in magnitude to the 4

child dose rate.

Because of the nature of existing computer software, a change to an infant receptor can be implemented more readily than a change to a child receptor.

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SECTION/PAGE COMMENT CECO RESPONSE i

2.2/2.2-1 Dose projections for Rev. 11 (p. 2.2-3) includes j

anticipated liquid an added section (2.2.1.2) releases are not which provides a methodology l

I addressed in section fbr projecting doses due 2.2.

to liquid releases.

l 2.2.3/2.2-4 ODCM includes the term Rev. 11 has deleted the

.t /8760 to calculate factor t /8760 from the a8nual average' con-right ha8d side of 1

centration in a potabl0 Equation 2.29.

f water supply.

NUREG-0472 limits concen-trations to instan-taneous values, not annual averages.

3.1.2.2/

Ground plane pathway Rev. 11 includes ground

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3.1-4 not included when plane exposure pathway calculating external in evaluating external i'

dose.

See pp. 2.1-12, dose.

j 2.1-19, and 3.1-4.

i 3.3.1.1/

Equation 3.20 not Rev. 11 (p. 3. -1) includes 3.3-1 clear whether DY (R,G) the variable D (R,0) to shou d be subscripted indicate the d fference as D (R,C) referring between dose from nuclide i j

to g mma air dose due and total dose [D (R,0)]

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to nuclide i.

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Expressions for Rev. 11 (p. 3.'3-4) includes 3.3-3 normalized gamma air added discussion to clarify dose factors S,, V,

how these factors are calcu-g and G should De lated from Equation 3.20.

4 included in ODCM.

j Table 7.2-1/

U value of 0.042 Rev. 11 (p. 7.2-1) uses 7.2-1 liters per hour is the value 0.083 liters /hr approximately one to provide agreement with half the value of Reg. Guide 1.109.

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730 Kg/yr in Reg.

Guide 1.109.

i 8.1/8.1-1 Question as to whether

. sumption b (gaseous there is periodic fluent considered a constant radionuclide mix) verification of i

gaseous effluent being has been revised.

Station i

considered a constant isotopic release data radionuclide mixture averaged over seven years dose based on iso-(1977 through June 1984) is i

topic data reviewed now used.

See Rev. 11, i

for 1978 (assumption

p. 8.1-1.

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,.l Juno 13, 1985 Page 4 of 6 SECTION/PAGE COMMENT CECO RESPONSE i

8.1/8.1-1 Assumption b should Disagree.

Because of include "and is repre-potential changes in plant sentative of the acti-conditions, it is not vity at the point of p'ossible to state that re' lease."

any specific assumed l

composition will always be representative of the composition at the point of release.

i 8.1/8.1-5 Service building venti-A discussion of the service lation monitoring system building ventilation moni-

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identified in Zion tech toring system has been specs, but not addressec added to Rev. 11 of the 4

in ODCM.

ODCM.

See section 8.1.6 (p. 8.1-5).

8.2/8.2-1 Assumption b should Disagree.

Because of, include "and is.repre-potential changes in plant.

I sentative of the acti-conditions, it is not vity at the point of possible to state that j

release."

any specific assumed composition will always be representative of the composition at the point of release.

i 8.2.2/8.2-4 Question on variables Block diagrams are included j

in Equation 8.3.

in Rev. 11 to clarify the Release pathways not release pathway.

Effluent clear.

from the Waste Water Treatment Facility is i

mixed with circulating water and service water i

in the cribhouse forebay.

The minimum dilution flow rate is 88,000 gpm.

The actual dilution flow rate I

depends on how many circu-"

lating water pumps and i

service water pumps are I

operating.

8.2.2/8.2-4 Block diagrams for Block diagrams are included radioactive liquid and in Rev. 11.

See Figures gaseous release path-8.1-1 Tnd 8.2-1.

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ways.with rad monitors and isolation capa-bilities should be included with ODCM.

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June 13, 1985 Page 5 of 6 SECTION/PAGE COMMENT CECO RESPONSE 8.3/8.3-1 Section 8.3 does not PCP requirements will be include the PCP addressed in a separate requirements.

document.

Table 8.4-1, ODCM implies 40 specia] The statement "plus 40 Item 2/8.4-3 TLD sites for a total other sites..." has been of 53 sites.

deleted from Table 8.4-1, Item 2.

There are 27 other sites for a total of 40.

These 27 additional sites are now listed explicitly.

Table 8.4-1, Footnotes are The footnotes have been Item 2.b/

incorrect.

corrected.

8.4-3,' 8.4-5 Table 8.4-1, Milk collection Agreement has been reached Item 4/8.4-3 required biweekly with the NRC staff to change during grazing season Tech C; > Js and ODCM to in Tech Specs but ODCM colle 't ailk semi-monthly states milk collection durir.y 3 razing season, is weekly.

Table 8.4-1, Surface water samples Agreement has been reached Item 5/8.4-4 analysis and frequency with the NRC staff to are inconsistent change the Tech Specs..and between ODCM and Tech the ODCM to require gdmma i

Specs.

isotopic and tritium anal

• sis.

Beta and separate I-131 will not be required.

Table 8.4-1, The Tech Spec require-This requirement is new ment for tritium includ ed,

Item 6/8.4-4 analysis'for the cooling water sample is not included in the ODCM.

Table 8.4-1, Sediment sample Table 8.4-1 has~been Item 7/8.4-4 frequency is inconsis-revised o make ODCM tent between ODCM and sample ccliection fr?ec.ancy Tech Spec.

consistent with Tech Specs.

Table 8.4-1/

Food products required Agreement has been reached 8.4-2 to 8.4-5 by Tech Specs not with the NRC staff to addressed by ODCM.

change Tech 5;.ccs and ODCM to requira (under the category of foci products) f the collection of I

vegetation for caalysis if milk sampling is. Tot performed.

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e June 13, 1985 Page 6 of 6 SECTION/PAGE COMMENT CECO RESPONSE Table 8.4-2/

LLD table in ODCM Table 8.4-2 (LLD table) 8.4-6 should be deleted or has been made consi' stent consistent with LLD with LLD table in Tech table in Tech Specs.

Specs.

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282 D. Eic nhut Deputy Director office of Nuc. Reac. Reg.

NRC Washington, D. C. 20555 January 3, 1986 Please find attached the latest revision of the Offsite Dose Calculation Manual, Zion Site Specific Sections 7.2 & 8.0 Revision 11.

Please remove and destroy the outdated site specific sections and insert the updated Revision 11 site specific sections.

Please sign, date, and return this control sheet to:

COMMONWEALTH EDISON COMPANY Document Control Desk Nuclear Services Technical 72 W. Adams Room 1248E Chicago, IL 60603 Rick L. Thacker Environmental Health Physicist Extension 4171 SIGNATURE:

DATE:

RLT/1mk/0513E/79