ML083530745

Final Safety Evaluation for NEI 07-09, Revision 4, Generic Final Safety Analysis Report Template Guidance for Offsite Dose Calculation Manual (ODCM) Program Description

ML083530745
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/27/2009
From:	William Reckley NRC/NRO/DNRL/NRGA
To:	Bell R Nuclear Energy Institute
Burrows, S A, NRO/DNRL/NRGA, 415-6086
References
TAC MD6753
Download: ML083530745 (21)

Text

January 27, 2009 Mr. Russell J. Bell, Director New Plant Licensing Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

FINAL SAFETY EVALUATION FOR NUCLEAR ENERGY INSTITUTE TOPICAL REPORT NEI 07-09, GENERIC FINAL SAFETY ANALYSIS REPORT TEMPLATE GUIDANCE FOR OFFSITE DOSE CALCULATION MANUAL PROGRAM DESCRIPTION, REVISION 4 (PROJECT NO. 689; TAC MD6753)

Dear Mr. Bell:

By letter dated September 11, 2007, the Nuclear Energy Institute (NEI) submitted for U.S.

Nuclear Regulatory Commission (NRC) staff review its proposed topical report, NEI 07-09, Generic Final Safety Analysis Report (FSAR) Template Guidance for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 0. In a handout dated November 13, 2007, during a Category 2 public meeting, the NRC staff distributed comments on NEI 07-09, Revision 0. In February 2008, NEI submitted Revision 1 of the ODCM template. In response to the NRC staffs April 28, 2008, request for additional information (RAI), NEI submitted NEI 07-09, Revision 2 on May 30, 2008. In response to comments provided by NRC staff on June 12, 2008, NEI submitted Revision 3 of the ODCM template in August of 2008. NRC staff provided comments on Revision 3 of the template in Category 2 public meetings held in August through October of 2008. In response to these comments, NEI submitted Revision 4 of the ODCM template by letter dated November 14, 2008.

Enclosed is the staffs safety evaluation (SE) which defines the basis for acceptance of NEI 07-09, Revision 4. The NRC staff finds that for combined license (COL) applications, NEI 07-09, Revision 4, provides an acceptable template for assuring that the ODCM program meets applicable NRC regulations and guidance.

Our acceptance applies only to material provided in NEI 07-09, Revision 4. We do not intend to repeat our review of the acceptable material described in the NEI 07-09, Revision 4. When the NEI 07-09, Revision 4 appears as a reference in COL applications, our review will ensure that the material presented applies to the specific application involved. Licensing requests that deviate from NEI 07-09, Revision 4, will be subject to a plant-specific or site-specific review in accordance with applicable review standards.

R. Bell In accordance with the guidance provided on the NRC website, we request that NEI publish the accepted version of NEI 07-09, Revision 4 within three months of receipt of this letter. The accepted version should incorporate this letter and the enclosed SE after the title page. The accepted version should also contain historical review information, including NRCs RAIs and your responses. The accepted versions shall include a "-A" (designating accepted) following the report identification symbol.

If future changes to the NRC's regulatory requirements affect the acceptability of NEI 07-09, Revision 4, NEI will be expected to revise NEI 07-09 appropriately, or justify its continued applicability for subsequent referencing.

If you have any questions, please contact Sheryl A. Burrows at (301) 415-6086 or via email at Sheryl.Burrows@nrc.gov.

Sincerely,

/RA/

William D. Reckley, Chief Rulemaking, Guidance, and Advanced Reactors Branch Division of New Reactor Licensing Office of New Reactors Project No. 689

Enclosure:

Safety Evaluation cc w/encl: See next page

R. Bell In accordance with the guidance provided on the NRC website, we request that NEI publish the accepted version of NEI 07-09, Revision 4 within three months of receipt of this letter. The accepted version should incorporate this letter and the enclosed SE after the title page. The accepted version should also contain historical review information, including NRCs RAIs and your responses. The accepted versions shall include a "-A" (designating accepted) following the report identification symbol.

If future changes to the NRC's regulatory requirements affect the acceptability of NEI 07-09, Revision 4, NEI will be expected to revise NEI 07-09 appropriately, or justify its continued applicability for subsequent referencing.

If you have any questions, please contact Sheryl A. Burrows at (301) 415-6086 or via email at Sheryl.Burrows@nrc.gov.

Sincerely,

/RA/

William D. Reckley, Chief Rulemaking, Guidance, and Advanced Reactors Branch Division of New Reactor Licensing Office of New Reactors Project No. 689

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBIC RidsNroDnrl NRCA R/F RidsNroDnrlNrga SBurrows, NRO RidsOgcMailCenter RRobinson, NRO RidsNroDcip JDehmel, NRO RidsNroDcipChpb ADAMS ACCESSION NO.: ML083530745 *See SER dated 11/21/2008, ML082680007 NRO-002 OFFICE PM:DNRL/NRCA LA:DNRL BC:DCIP/CHPB OGC BC:DNRL/NRCA NAME SBurrows RRobinson TFrye* KWinsberg WReckley DATE 12/31/2008 12/30/2008 11/21/2008 01/26/2009 01/27/2009 OFFICIAL RECORD COPY

FINAL SAFETY EVALUATION BY THE OFFICE OF NEW REACTORS TECHNICAL REPORT NEI-07-09 GENERIC FSAR TEMPLATE GUIDANCE FOR OFFSITE DOSE CALCULATION MANUAL PROGRAM DESCRIPTION, (REVISION 4, NOVEMBER 2008)

NEI PROJECT NO. 689

1. INTRODUCTION By letter dated November 14, 2008, the Nuclear Energy Institute (NEI) submitted for U.S.

Nuclear Regulatory Commission (NRC) staff review, its proposed, Generic Final Safety Analysis Report (FSAR) Template Guidance for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 4 [Reference a)]. NEI designated this program as NEI 07-09, under NEI Project No. 689, in a letter dated August 10, 2007 [Reference b)]. The NEI 07-09 Template was developed by NEI to assist NRC review and approval of combined licenses (COLs) submitted by applicants. Following a series of public meetings, communications and letters, NEI addressed NRC comments and issued the final version of the NEI 07-09 Template

[References c) to f)]. The NEI 07-09 Template describes a generic ODCM, including provisions for standard radiological effluent controls (SRECs), and the elements of a process and effluent monitoring and sampling program.

The generic ODCM Program Description presented in the NEI 07-09 Template commits an applicant to NRC regulatory requirements, guidance and acceptance criteria listed in Regulatory Guide (RG) 1.206 [Reference g)] and Section 11.5 of the Standard Review Plan (SRP) (NUREG-0800, March 2007) [Reference h)]. The NEI template identifies text and table entries that a COL holder will provide as information or modify the generic information with plant and site-specific features before fuel load. This information is identified in the NEI 07-09 Template with double parentheses. Such information may include the definition of specific equations; terms to equations; nomenclature of plant specific system, equipment, and instrumentation; types of release points; pathway specific dose conversion factors; among others. As a result, the NEI 07-09 Template complies with applicable NRC regulations and guidance and may be used for COL applications submitted under the requirements of Subpart C of Title 10 of the Code of Federal Regulations, Part 52 (10 CFR Part 52). If a COL is issued, the licensee must develop operational programs by their implementation milestones, as required prior to fuel load, under regulatory requirements specified in Section 13.4 of applications, license conditions, and design certifications (DC). A COL holder is required to make available for NRC inspection and verification a plant and site-specific process and effluent monitoring and sampling program, consisting of the following elements:

(a) SRECs, (b) an ODCM, and (c) a radiological environmental monitoring program (REMP).

Enclosure

Finally, under the requirements of SECY 05-197 [Reference i)], the implementation of operational programs, including the elements identified in NEI 07-09 Template, does not necessitate inspections, tests, analyses, and acceptance criteria (ITAAC) in a DC or COL application.

2. REGULATORY EVALUATION The staff reviewed NEI 07-09 Template in accordance with the guidance and acceptance criteria provided in SRP Section 11.5, Process and Effluent Radiological Monitoring Instrumentation and Sampling Systems (NUREG-0800). Full descriptions of all applicable regulatory requirements and acceptance criteria are identified in SRP Section 11.5. The following listing identifies the major regulatory requirements:

• 10 CFR Part 20, Standards for Protection against Radiation.

• 10 CFR Part 20.1301, Dose Limits for Individual Members of the Public.

• 10 CFR Part 20.1302, Compliance with Dose Limits for Individual Members of the Public.

• 10 CFR Part 20, Appendix B, Annual Limits on Intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage.

• 10 CFR Part 50.34a, Design Objectives for Equipment to Control Releases of Radioactive Material in EffluentsNuclear Power Reactors.

• 10 CFR Part 50.36a, Technical Specifications on Effluents from Nuclear Power Reactors.

• 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents.

• Generic Letter (GL) 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program (Generic Letter 89-01), January 31, 1989. [GL 89-01 is included as Appendix C in NUREG-1301 and NUREG-1302.]

The relevant requirements of the regulations identified above are met by using regulatory positions and guidance contained in the following key RGs and industry standards. Full descriptions of all applicable SRP Section 11.5 acceptance criteria and regulatory guidance are identified in SRP Section 11.5. The following listing identifies key regulatory guidance documents and acceptance criteria of SRP Section 11.5:

a) RG 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants.

b) RG 1.33, Quality Assurance Program Requirements (Operation).

c) RG 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I.

d) RG 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors.

e) RG 1.112, Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Light-Water-Cooled Power Reactors.

f) RG 1.113, Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I.

g) RG 1.143, Design Guidance for Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants.

h) RG 1.206, Combined License Applications for Nuclear Power Plants (LWR Edition).

i) RG 4.1, Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants.

j) RG 4.8, Environmental Technical Specifications for Nuclear Power Plants.

k) RG 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination) - Effluent Streams and the Environment.

l) RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable.

m) American National Standards Institute (ANSI)/ Health Physics Society (HPS) N13.1-1999, Sampling and Monitoring Releases of Airborne Radioactive Substances from the Stacks and Ducts of Nuclear Facilities.

n) ANSI N42.18-2004, Specification and Performance of On-Site Instrumentation for Continuously Monitoring Radioactivity in Effluents, 2004.

o) NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants.

p) NUREG-0543, Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40 CFR Part 190). [The implementation of this Environmental Protection Agency (EPA) standard is addressed under 10 CFR Part 20.1301(e).]

q) NUREG-0800, SRP Section 11.5, Process and Effluent Radiological Monitoring Instrumentation and Sampling Systems, March 2007.

r) NUREG-1301, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors. [This NUREG includes GL 89-01.]

s) NUREG-1302, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors. [This NUREG includes GL 89-01.]

t) Radiological Assessment Branch Technical Position (BTP), Revision 1, November 1979.

[Contained in Appendix A of NUREG-1301 and NUREG-1302].

u) Inspection and Enforcement (IE) Bulletin No. 80-10, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment, May 6, 1980.

v) IE Information Notice No. 91-40, Contamination of Nonradioactive System and Resulting Possibility for Unmonitored, Uncontrolled Release to Environment, June 19, 1991.

3. TECHNICAL EVALUATION In evaluating the content, organization, and level of detail of the NEI 07-09 Template, the staff followed SRP Section 11.5 for guidance (as referenced above) and three supporting documents. The documents are NUREG-0133, NUREG-1301, NUREG-1302, as referenced above. NUREG-0133 presents guidance for the preparation of radiological effluent technical specifications (RETS). NUREG-0133 presents definitions and staff positions, special considerations on supporting technical and regulatory topics, and methodology with which to comply with the dose requirements and effluent concentration limits of 10 CFR Part 20, and as low as reasonably achievable (ALARA) design objectives and numerical guides of Appendix I to 10 CFR Part 50. Other sections of the document present methods to derive alarm set-points for instrumentation used to provide an alert of conditions or terminate releases when liquid and gaseous effluent concentrations exceed established levels, define limiting conditions for operations, and specifications for limiting the amounts of radioactivity in liquid containing tanks and gas decay tanks. NUREG-1301 for pressurized-water reactors (PWRs) and NUREG-1302 for boiling-water reactors (BWRs) present guidance in developing ODCMs, including controls and surveillance requirements for instrumentation, radioactive effluents, radiological environmental monitoring, and technical and regulatory bases for such requirements. Also, each document provides, under GL 89-01, the option of consolidating the prior RETS to the ODCM in fulfillment of a Commission policy in improving the implementation of technical specifications. Also, GL 89-01 redefines the RETS as standard radiological effluent controls (SREC). This modification to the prior RETS involves only changes in procedural details and presentation format. This modification does not change any of the regulatory or reporting requirements.

The staffs review also evaluated whether the format and content of NEI 07-09 Template was generally consistent with the requirements of GL 89-01 and guidance of NUREG-1301 for PWR plants or NUREG-1302 for BWR plants and NUREG-0133 for either type of plant;

RGs 1.21, 1.33, 4.1, 4.8, and 4.15; and Radiological Assessment BTP (Revision 1, November 1979).

Given the above regulatory requirements and guidance, the staffs review focused in identifying the elements of the NEI 07-09 Template that address the programmatic elements of an ODCM, while recognizing that the specific elements of a plant and site-specific process and effluent monitoring and sampling program will be developed under the requirements of a license condition and made available to the NRC for verification and inspection before fuel load. The milestones for the development and implementation of a plant and site-specific process and effluent monitoring and sampling program are addressed in FSAR Section 13.4 of COL applications and DCs, and include a COL commitment in safety analysis reports (SARs)

(Section 11.5).

Accordingly, the staffs review focused on confirming that NEI 07-09 Template (i.e., generic SREC, ODCM, and REMP) complies with the requirements of:

a) 10 CFR Part 50.34a and 10 CFR Part 50.36a; b) Sections II to IV of Appendix I to 10 CFR Part 50 ALARA design objectives and numerical guides; c) liquid and gaseous effluent concentration limits of Appendix B (Table 2) to 10 CFR Part 20; d) dose limits of 10 CFR Part 20.1301 and 20.1302 for members of the public; and e) 10 CFR Part 20.1301(e) for assessing total dose from all sources of radioactivity and radiation.

The requirements of General Design Criteria (GDC) 60, 63, and 64 [References j) to l)] from Appendix A to 10 CFR Part 50 are not identified here as they are included in the staffs review of the design bases of related plant systems presented in DCs or, alternatively, are evaluated if identified as supplemental information or as departures in a COL application for specific plant systems. In such instances, the staff will conduct a separate review and evaluation to determine if the inclusion of supplemental information or departures might impact any elements of the process and effluent monitoring and sampling program described in NEI 07-09 Template.

3.1 Overview of NEI 07-09 Template Program Description The NEI 07-09 Template describes a generic ODCM, including the elements of a process and effluent monitoring and sampling program. A review of the information presented in the NEI 07-09 Template indicates that it is based on the ODCM of a currently operating PWR. The plant and site specific information were removed and left as generic place holders, with changes made accordingly to the nomenclature and terminology. The NEI 07-09 Template is organized in seven sections and 13 attachments. The first four sections include an introduction, purpose, scope, and definitions. The fifth section addresses organizational responsibilities, including training, operational programs, and quality assurance. The responsibilities reference specific sections of the SAR where these functions are described as

commitments. The sixth section describes the elements of a process and effluent monitoring and sampling program. This section identifies sampling and monitoring criteria, liquid and gaseous effluent controls, monitoring instrumentation, dose limits, effluent sampling, waste management, controls for effluent releases, total dose limits for members of the public, radiological environmental monitoring, and record keeping. Section 7 lists references on regulatory requirements, technical and regulatory guidance, and includes industry standards.

Supporting information is presented in 13 attachments. The attachments identify for the COL holder the type of plant and site-specific information that must be included in the operational version of the ODCM for submission to the NRC before fuel load. This information is identified in the NEI 07-09 Template with double parentheses. In summary, the attachments identify requirements in describing the type and performance of radiological instrumentation used to monitor liquid and gaseous effluents, instrumentation and equipment surveillance requirements, sampling and analysis requirements, provisions to list dose conversion factors by specific exposure pathways, minimum requirements for the REMP, provisions to list sampling locations, description of detection and reporting levels by type of environmental media, and place holders for the evaluation of meteorological data, and considerations in evaluating exposures to members of the public due to liquid and gaseous release pathways.

3.2 NEI 07-09 Template Details The staff review and evaluation of the NEI 07-09 Template is organized into five functional areas, organization, SREC, ODCM, REMP, and implementation responsibilities of a COL applicant/COL holder and NRC staff. This approach is consistent with the review process identified in the Section 11.5 of the SRP.

3.2.1 Organization of NEI 07-09 Template The NEI 07-09 Template follows the guidance of NUREG-1301 for PWR plants or NUREG-1302 for BWR plants; NUREG-0133 for either type of plant; and Radiological Assessment BTP (Revision 1, November 1979). The key supporting references listed in the NEI 07-09 Template are also generally consistent with those identified as regulatory requirements, acceptance criteria, and regulatory guidance in SRP Section 11.5. The NEI 07-09 Template identifies organizational responsibilities, including training, operational programs, and quality assurance.

The NEI 07-09 Template addresses the programmatic elements of a generic ODCM, while recognizing that specific elements of a plant and site-specific process and effluent monitoring and sampling program will be developed under the requirements of license conditions and submitted to the NRC for review and approval before fuel load. This information is identified in the NEI 07-09 Template with double parentheses. The milestones for the development and implementation of a plant and site specific process and effluent monitoring and sampling program are addressed in FSAR Section 13.4 of COL applications and include a COL commitment in FSAR Section 11.5. Finally, under the requirements of SECY-05-0197

[Reference i)], the implementation of operational programs, including the elements identified in the NEI 07-09 Template, do not necessitate ITAACs in either a DC or COL application.

3.2.2 Standard Radiological Effluent Controls For the sections of the NEI 07-09 Template addressing the generic elements of SREC, the template follows the provisions of GL 89-01 and NUREG-1301 for PWR plants or NUREG-1302 for BWR plants. The procedural and programmatic elements of the generic SREC are based on NRC guidance described in SRP Section 11.5. This approach is consistent with Technical Specifications (TS) (i.e., Section 5.0, Administrative Controls, and Section 5.5, Programs and Manuals) cited in Section 16.0 of DCs and COL applications [References m) and n)]. This review revealed that the scope and elements of the SREC program identified in the NEI Template 07-09 are consistent with the requirements identified in NRC regulations and guidance. The NEI 07-09 Template identifies surveillance requirements and controls; operational conditions of radiation monitoring and sampling equipment; required number of operational channels, conduct and frequencies of channel checks, source checks, channel calibrations, and channel functional checks; compliance with action statements and remediation whenever the number of operational channels and applicability are less than the required minimum; sampling and analysis programs for continuous and batch mode releases, including provisions for the collection of grab and composite samples; and derivations of lower limit of detections by categories of effluents or radionuclides and types of radiological analyses.

Where plant and site-specific SREC information is not available, the NEI 07-09 Template identifies the information by using double parenthetical entries [e.g., ((release point noun description))] as place holders for such information in the main section and attachments of the template. The NEI 07-09 Template commits the COL holder to provide this information in fulfillment of the license condition, which specifies the submission to and approval, prior to fuel load, by the NRC of a plant and site-specific set of SREC, as part of the process and effluent monitoring and sampling program. The implementation milestones of license conditions are described in Section 13.4 of each DC and COL application.

The staff concludes that the generic SREC describing administrative and operational programs associated with its implementation is consistent with the requirements of GL 89-01 and guidance of NUREG-1301 for PWR plants or NUREG-1302 for BWR plants. The staff concludes that the NEI 07-09 Template sufficiently describes the programmatic elements and operational objectives to enable a reasonable assurance finding of acceptability for issuance of a combined license, followed with verification of the implementation of a plant-specific SREC through the inspection process before fuel load.

3.2.3 Offsite Dose Calculation Manual For the sections of the NEI 07-09 Template addressing the generic elements of an ODCM, the template follows the provisions of GL 89-01 and NUREG-1301 for PWR plants or NUREG-1302 for BWR plants and NUREG-0133 for either type of plant. The procedural and programmatic elements of the generic ODCM are based on NRC guidance described in SRP Section 11.5.

The NEI 07-09 Template includes provisions for identifying liquid and gaseous effluent release points; and lists place holders for information with which to calculate doses, define release rates, and establish alarm set points. The information place holders include a listing of the types and locations of radiological instrumentation used to monitor and control effluent releases; parameters used to derive effluent release rates and establish alarm set-points; dilution factors for liquid effluents (in-plant and beyond the point of release); atmospheric

dispersion (X/Q) and deposition (D/Q) factors for gaseous and particulate effluents; locations of offsite dose receptors and the basis for their selection using the results of annual land use census surveys; criteria to determine the operability of waste treatment systems and requirements in conducting dose projections, such as whenever treatment systems are not fully utilized, or in assessing monthly, quarterly, and yearly doses; and administrative and operational procedures associated with the implementation of the ODCM.

The template endorses calculation methods using the guidance of RG 1.109 for dose calculations, RG 1.111 for estimating atmospheric dispersion and deposition parameters at downwind locations, and RG 1.113 for estimating aquatic dispersion for routine releases beyond the point of discharge, and corresponding computer codes (e.g., LADTAP II (NUREG/CR-4013) and GASPAR II (NUREG/CR-4653)) used to calculate doses to members of the public. The template identifies other computational tools and guidance, such as NUREG/CR-3332 on radiological assessment, NUREG-0543 in demonstrating compliance with 10 CFR Part 20.1301(e), NUREG-4007 in deriving lower limits of detection for radiation monitoring equipment, ANSI/HPS N13.1-1999 for guidance in sampling and monitoring radioactive materials from plant stacks and vents, and ANSI N42.18-2004 when using continuous radiation monitoring instrumentation.

Where plant and site specific ODCM information is not available, the NEI 07-09 Template identifies the information by using double parenthetical entries [e.g., ((define equations, define equation terms))] as place holders for such information in the main section and attachments of the template. The NEI 07-09 Template commits the COL holder to provide this information in fulfillment of a license condition, which specifies the submission and approval, prior to fuel load, by the NRC of a plant and site-specific ODCM, as part of the process and effluent monitoring and sampling program. The implementation milestones of license conditions are described in Section 13.4 of each DC and COL application.

The NEI 07-09 Template does not include provisions for specifying maximum radioactivity levels in tanks and tank radioactivity monitoring program as these requirements are addressed separately in Section 16.0, TSs (i.e., Section 5.0, Administrative Controls, and Section 5.5, Programs and Manuals) of DCs and COL applications [References m) and n)]. Accordingly, these requirements are not repeated in NEI 07-09 Template given that they are mandated by plant TSs.

The staff concludes that the generic ODCM describing the methodology and parameters used for calculating offsite liquid and gaseous effluent concentrations and doses to members of the public, and administrative and operational programs associated with its implementation is consistent with the requirements of GL 89-01, and guidance of NUREG-1301 for PWR plants or NUREG-1302 for BWR plants, NUREG-0133 for either type of plant; RGs 1.21, 1.33, and 4.15; and Radiological Assessment BTP (Revision 1, November 1979). The staff concludes that the NEI 07-09 Template sufficiently describes the programmatic elements and operational objectives to enable a reasonable assurance finding of acceptability for issuance of a COL, followed with verification of the implementation of a plant and site-specific ODCM through the inspection process before fuel load.

3.2.4 Radiological Environmental Monitoring Program For the sections of the NEI 07-09 Template addressing the generic elements of a REMP, the template follows the provisions of GL 89-01 and NUREG-1301 for PWR plants or NUREG-1302 for BWR plants and NUREG-0133 for either type of plant, and Radiological Assessment BTP (Revision 1, November 1979). The NEI 07-09 Template provides the means to monitor and quantify radiation and radioactivity levels in the environs of a plant associated with gaseous and liquid effluent releases and contribution of direct external radiation from contained sources of radioactive materials in tanks, equipment and buildings. The procedural and programmatic elements of the generic REMP are based on NRC guidance described in SRP Section 11.5.

The generic REMP describes a process and methods for monitoring, sampling, and analyzing environmental samples representative of expected radionuclide distributions and concentrations in environmental media and associated exposure pathways. The generic REMP provides place holders to indentify types, numbers, and sampling locations, and sampling and analytical frequencies of environmental samples. Samples include milk and milk products, surface and ground water, drinking water, fish and invertebrates, vegetables and leafy vegetables, food products potentially impacted by irrigation, sediments and soils, and air. The selection of sampling locations and types of samples, including control sample locations, are based on the results of a yearly land use census to ensure that changes in exposure pathways are identified and that modifications are made to the monitoring program to reflect such changes. In assessing direct external radiation exposures, the generic REMP identifies types of measurement methods and locations of monitoring stations around plant facilities, including those used to monitor doses to nearest receptors. The Template includes provisions to control releases of radioactive materials caused by spills and leaks that may impact ground and surface water and identifies reporting requirements consistent with the guidance of RG 1.143 and NEI Industry Ground Water Protection Initiative (NEI 07-07) [Reference o)]. The generic REMP includes provisions for detection limits and reporting levels for expected radionuclides and environmental samples and external radiation monitoring methods. The generic REMP describes participation in an inter-laboratory comparison program to assess the precision and accuracy of measurements of radioactivity in environmental samples as part of a quality assurance program.

Where plant and site-specific REMP information is not available, the NEI 07-09 Template identifies the information by using double parenthetical entries [e.g., ((define frequency, media, and analysis to be performed))] as place holders for such information in the main section and attachments of the template. The NEI 07-09 Template commits the COL holder to provide this information by a time specified in a license condition, making available for NRC inspection and verification prior to fuel load, a plant and site-specific REMP, as part of the process and effluent monitoring and sampling program. The implementation milestones of license conditions are described in Section 13.4 of each DC and COL application.

The staff concludes that the generic REMP describes the means to monitor and quantify radiation and radioactivity levels in the environs of a plant associated with gaseous and liquid effluent releases and assess the contribution of direct external radiation from contained sources of radioactive materials in tanks, equipment and buildings. The description of the implementation of its administrative and operational programs is consistent with the

requirements of GL 89-01, and guidance of NUREG-1301 for PWR plants or NUREG-1302 for BWR plants, and NUREG-0133 for either type of plant; RGs 1.21, 1.33, 4.1, 4.8, and 4.15; and Radiological Assessment BTP (Revision 1, November 1979). The staff concludes that the NEI 07-09 Template sufficiently describes the programmatic elements and operational objectives to enable a reasonable assurance finding of acceptability for issuance of a COL, followed with verification of the implementation of a plant and site-specific REMP through the inspection process before fuel load.

4. IMPLEMENTATION Before the implementation of the plant and site-specific ODCM, the NRC staff will inspect the elements of ODCM following the NRC Construction Inspection Program defined in IMC 2504.

The objectives of these inspections are to determine the readiness of the programs to perform their intended objectives. The inspection will confirm that the administrative programs and operational procedures implementing the standard radiological effluent controls, offsite dose calculation manual, and radiological environmental monitoring program are consistent with regulatory requirements of 10 CFR Part 20 and 10 CFR Part 50, and GL 89-01; NUREG-1301 for PWR Plants or NUREG-1302 for BWR plants and NUREG-0133 for either type of plant; RGs 1.21, 1.33, 4.1, 4.8, and 4.15; NRC guidance of Radiological Assessment BTP (Revision 1, November 1979); and industry guidance of ANSI/HPS N13.1 and ANS N42.18.

In addressing the requirements of 10 CFR Part 52.80(a), which requires that a DC application contains the proposed ITAACs, the NRC inspection will confirm that the COL holder has performed all applicable ITAACs for liquid and gaseous effluent systems, and process radiation monitoring and sampling systems. The ITAACs are described in DCD Tier 1 of DCs and Section 14.3 of the FSAR in COL applications. The staff will confirm whether the COL holder has addressed all relevant ITAACs, including confirming the descriptions and functional arrangements of systems (as safety and non-safety related subsystems); instrumentation indications of radiation or radioactivity levels, alarms on exceeding set-point values, alarms on inoperative conditions, and initiation of protective actions and isolation or termination of plant processes or effluent releases in demonstrating compliance with 10 CFR Part 20.1301 for doses to members of the public, effluent concentration limits in Table 2 (Columns 1 and 2) of Appendix B to 10 CFR Part 20, and numerical objectives of Appendix I to 10 CFR Part 50. The ITAACs, when completed by the COL holder and verified to meet their respective acceptance criteria, provide reasonable assurance that a plant that incorporates the features described in its DC and establishes operating programs in accordance with the DC will meet the provisions of NRC regulations.

5. CONCLUSION The staff used the provisions of 10 CFR Part 20, 10 CFR Part 50.34a and Part 50.36a, ALARA design objectives and numerical guides of Appendix I to 10 CFR Part 50, and the guidance of SRP Section 11.5 as the bases for evaluating the acceptability of the NEI 07-09 Template. On the basis of the staffs review of the generic SAR Template for ODCM Program Description, the staff concludes that the provisions of the NEI Template 07-09 are generally consistent with the

applicable requirements of 10 CFR Part 20.1301 and 20.1302, 10 CFR Part 20.1301(e),

10 CFR Part 50.34a and 50.36a, and 10 CFR Part 50 Appendix I numerical guides and design objectives. This conclusion is based on the following:

a) The generic SREC, ODCM, and REMP, and associated administrative and operational programs, are found to be consistent with the requirements of GL 89-01; radiological guidance of NUREG-1301 or NUREG-1302 and NUREG-0133; RGs 1.21, 1.33, 4.1, 4.8, and 4.15; and Radiological Assessment BTP (Revision 1, November 1979).

b) The Template addresses provisions in establishing instrumentation alarm set-points for automatic termination of effluent releases and control over discharges, in accordance with 10 CFR Part 50.36a, numerical guides and design objectives of Appendix I to 10 CFR Part 50, 10 CFR Part 20.1301 and 20.1302 dose limits to members of the public, and liquid and gaseous effluent concentration limits of Table 2 in Appendix B to 10 CFR Part 20. The provisions for sampling process and effluent streams and conducting analysis of samples, including a requirement to develop a plant and site-specific analytical program, follow the guidelines in RGs 1.21, 1.33, 4.1, 4.8, and 4.15 for routine plant operation and anticipated operational occurrences. The Template includes requirements for annual reporting requirements describing quantities of radioactive materials released in the environment via liquid and gaseous effluents, and results of radiological assessment in comparing doses to members of the public against the limits of 10 CFR Part 20 and numerical criteria of 10 CFR Part 50. The Template includes provisions for reporting information on meteorological data collection and uses in deriving atmospheric dispersion and deposition parameters and calculating doses to members of the public.

c) The Template includes provisions to consider all sources of radiation and radioactivity in estimating associated doses to members of the public in fulfillment of the EPA generally applicable environmental radiation standards of 40 CFR Part 190, as implemented under 10 CFR Part 20.1301(e).

d) The Template includes provisions to monitor and quantify radiation and radioactivity levels in the environs of a plant associated with gaseous and liquid effluent releases and assess the contribution of direct external radiation from contained sources of radioactive materials.

The Template includes provisions to control releases of radioactive materials caused by spills and leaks that may impact ground and surface water and identifies reporting requirements consistent with the guidance of RG 1.143 and NEI Industry Ground Water Protection Initiative (NEI 07-07). The Template includes requirements for participation in an inter-comparison program, yearly conduct of land-use census, and annual reporting requirements of the results of the REMP.

e) The Template includes administrative measures (e.g., release permits) to control discharges of radioactive materials in the environment, as continuous and batch releases, and releases associated with operational occurrences and unplanned and unmonitored discharges. The provisions include requirements to sample and monitor all appropriate process streams and effluents, characterize such radioactive releases, and assess doses to members of the public. The provisions include reporting and notification requirements, identify a process to make changes to the ODCM, and require that all records associated

with the implementation of the ODCM be maintained in accordance with an established records management system.

f) The Template identifies organizational responsibilities for the implementation of operational programs, with milestones defined under regulatory requirements and license conditions.

The responsibilities and operational programs identified are those of FSAR Section 13.1 (Organization), Section 13.2 (Training), Section 13.4 (Operational Programs), and Section 17 (Quality Assurance).

The staff concludes that the NEI 07-09 Template sufficiently describes the programmatic elements and operational objectives to enable a reasonable assurance finding of acceptability for issuance of a COL, followed with verification of the implementation of a site and plant-specific SREC, ODCM, and REMP through the inspection process before fuel load. The staff concludes that the NEI 07-09 Template is adequate and may be referenced in a COL application, and that the implementation of a plant and site-specific SREC, ODCM, and REMP will be executed by COL holders in accordance to milestones described in COL SAR Section 13.4 and license conditions.

Accordingly, the NEI 07-09 Template fulfills a licensing requirement for submission of a COL application. A license condition will specify the timing for the licensee to make a site and plant-specific ODCM available for NRC inspection and verification prior to fuel load. Finally, under the requirements of SECY 05-0197, the implementation of operational programs identified in the NEI 07-09 Template does not necessitate ITAACs in a DC or COL application.

6. REFERENCES a) Bell, R. J., NEI, to the NRC, Generic FSAR Template for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 4, November 14, 2008.

b) Bell, R. J., NEI, to the NRC, Generic Templates on Radioactive Wastes and Radiation Protection Programs and Related Content of Final Safety Analysis Reports, August 10, 2007.

c) Bell, R. J., NEI, to the NRC, Generic FSAR Template for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 3, August 2008.

d) Bell, R. J., NEI, to the NRC, Generic FSAR Template for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 2, May 2008.

e) Bell, R. J., NEI, to the NRC, Generic FSAR Template for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 1, February 2008.

f) Bell, R. J., NEI, to the NRC, Generic FSAR Template for Offsite Dose Calculation Manual (ODCM) Program Description, Revision 0, September 2007.

g) RG 1.206, Combined License Applications for Nuclear Power Plants (LWR Edition).

h) NUREG-0800, SRP Section 11.5, Process and Effluent Radiological Monitoring Instrumentation and Sampling Systems, March 2007.

i) SECY-05-0197, Review of Operational Programs in Combined License Applications and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria, February 22, 2006.

j) 10 CFR Part 50, Appendix A, General Design Criterion 60, Control of Releases of Radioactive Materials to the Environment.

k) 10 CFR Part 50, Appendix A, General Design Criterion 63, Monitoring Fuel and Waste Storage.

l) 10 CFR Part 50, Appendix A, General Design Criterion 64, Monitoring Radioactivity Releases.

m) NUREG-1431, Standard Technical Specifications for Westinghouse Plants, Rev. 3, June 2004.

n) NUREG-1434, Standard Technical Specifications for General Electric Plants, BWR/6, Revision 3, June 2004.

o) NEI, Industry Ground Water Protection Initiative - Final Guidance Document, NEI 07-07, August 2007.

DCWG - Combined (All) (Revised 12/15/2008) cc:

Mr. Glenn H. Archinoff Director AECL Technologies Division of Compliance & Inspection 481 North Frederick Avenue Bureau of Radiation Control Suite 405 Texas Department of State Health Services Gaithersburg, MD 20877 1100 West 49th Street Austin, TX 78756-3189 Mr. Ray Aycock Field Supervisor Mr. Eugene S. Grecheck U.S. Fish and Wildlife Service Vice President Mississippi Ecological Services Office Nuclear Support Services 6578 Dogwood View Parkway Dominion Energy, Inc.

Jackson, MS 39213 5000 Dominion Blvd.

Glen Allen, VA 23060 Mr. Richard L. Baker Bechtel Power Corporation Mr. Jay M. Gutierrez 5275 Westview Drive Morgan, Lewis & Bockius, LLP Frederick, MD 21703-8306 111 Pennsylvania Avenue, NW Washington, DC 20004 Scott Bond Callaway Plant Ms. Sophie Gutner P.O. Box 620 P.O. Box 4646 Fulton, MO 65251 Glen Allen, VA 23058 Ms. Michele Boyd Mr. Brian Hastings Legislative Director Public Utility Commission Energy Program William B. Travis Building Public Citizens Critical Mass Energy P.O. Box 13326 and Environmental Program 1701 Noth Congress Avenue 215 Pennsylvania Avenue, SE Austin, TX 78701-3326 Washington, DC 20003 Mr. Tim E. Herrmann Ms. Cindy Brizes Vice President, Nuclear Engineering U.S. Department of Energy AmerenUE P.O. Box A P.O. Box 620 Aiken, SC 29802 Fulton, MO 65251 Mr. Barton Z. Cowan, Esquire Mr. Ronald Kinney Eckert Seamans Cherin & Mellott, LLC South Carolina DHEC 600 Grant Street, 44th Floor 2600 Bull Street Pittsburgh, PA 15219 Columbia, SC 29201

DCWG - Combined (All)

Dr. Regis A. Matzie Mr. Tom Sliva Senior Vice President and Vice President Chief Technology Officer New Plants Project Management Westinghouse Electric Company AREVA, NP, Inc. 3315 20 International Drive Old Forest Road Windsor, CT 06095 P.O. Box 10935 Lynchburg, VA 24506-0935 Mr. Norris McDonald President Mr. David W. Sutherland AAEA Chesapeake Bay Field Office 9903 Caltor Lane U.S. Fish and Wildlife Service Ft. Washington, MD 20744 177 Admiral Cochrane Drive Annapolis, MD 21401 Dr. Masanori Onozuka Mitsubishi Nuclear Energy Systems, Inc. Mr. Robert E. Sweeney 2300 Wilson Blvd. IBEX ESI Suite 300 4641 Montgomery Avenue Arlington, VA 22201-5426 Suite 350 Bethesda, MD 20814 Dr. C. Keith Paulson Mitsubishi Nuclear Energy Systems, Inc. Mr. Ed Wallace 300 Oxford Drive, Suite 301 General Manager - Projects Monroeville, PA 15146 PBMR Pty LTD P. O. Box 9396 PBMR Pty. Limited Centurion 0046 Lake Buena Vista Building Republic of South Africa 1267 Gordon Hood Avenue PO Box 9396 Mr. Gary Wright, Director Centurion 0046 Division of Nuclear Facility Safety Republic of South Africa Illinois Emergency Management Agency 1035 Outer Park Drive Charles Peterson Springfield, IL 62704 Pillsbury, Winthrop, Shaw & Pittman, LLP 2300 "N" Street, NW Washington, DC 20037 Mr. Ernest Reed Living Education Center for Ecology and the Arts P.O. Box 2612 Charlottesville, VA 22902

DCWG - Combined (All)

Email alsterdis@tva.gov (Andrea Sterdis) amonroe@scana.com (Amy Monroe)

APAGLIA@Scana.com (Al Paglia)

APH@NEI.org (Adrian Heymer) awc@nei.org (Anne W. Cottingham) barbara.lee-murphy@constellation.com (Barbara Lee-Murphy) barbara.perdue@unistarnuclear.com (Barbara Perdue) bevans@enercon.com (Bob Evans)

Bill.Moore@luminant.com (Bill Moore) bob.brown@ge.com (Robert E. Brown)

BrinkmCB@westinghouse.com (Charles Brinkman) brock.degeyter@energyfutureholdings.com (Brock Degeyter)

Carellmd@westinghouse.com (Mario D. Carelli) carey.fleming@constellation.com (Carey Fleming) chris.maslak@ge.com (Chris Maslak) ck_paulson@mnes-us.com (Keith Paulson) ckpaulson@aol.com (C.K. Paulson)

CumminWE@Westinghouse.com (Edward W. Cummins) cwaltman@roe.com (C. Waltman) dan1.williamson@ge.com (Dan Williamson) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis)

DeLaBarreR@state.gov (R. DeLaBarre) dlochbaum@UCSUSA.org (David Lochbaum) don.lewis@ge.com (Don Lewis) dpoole@luminant.com (David Poole) dwoodla1@luminant.com (Donald Woodlan) ecullington@earthlink.net (E. Cullington) eddie.grant@excelservices.com (Eddie Grant) erg-xl@cox.net (Eddie R. Grant) frank_quinn@comcast.net (Frank Quinn)

Fred.Madden@luminant.com (Fred Madden) garry.miller@pgnmail.com (Garry D. Miller) gcesare@enercon.com (Guy Cesare) gedgar@morganlewis.com (George Edgar) george.honma@ge.com (George Honma) george.wadkins@ge.com (George Wadkins)

GovePA@BV.com (Patrick Gove) greshaja@westinghouse.com (James Gresham) gwcurtis2@tva.gov (G. W. Curtis) gzinke@entergy.com (George Alan Zinke) hickste@earthlink.net (Thomas Hicks) ian.c.rickard@us.westinghouse.com (Ian C. Richard) james.beard@gene.ge.com (James Beard)

DCWG - Combined (All)

JCaldwell@luminant.com (Jan Caldwell)

Jean.Amundson@luminant.com (Jean Amundson) jeff.simmons@energyfutureholdings.com (Jeff Simmons) jgutierrez@morganlewis.com (Jay M. Gutierrez) jim.riccio@wdc.greenpeace.org (James Riccio) jim@ncwarn.org (Jim Warren)

JJNesrsta@cpsenergy.com (James J. Nesrsta) joel.Friday@ge.com (Joel Friday)

John.Conly@luminant.com (John Conly)

John.O'Neill@pillsburylaw.com (John O'Neill) john.sorensen@ge.com (John Sorensen)

Joseph_Hegner@dom.com (Joseph Hegner) joseph_tapia@mnes-us.com (Joe Tapia) joseph_tapia@mnes-us.com (Joseph Tapia) junichi_uchiyama@mnes-us.com (Junichi Uchiyama) karen@seedcoalition.org (Karen Hadden) kcrogers@aol.com (K. C. Rogers)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) lchandler@morganlewis.com (Lawrence J. Chandler) lois@ieer.org (Lois Chalmers) lou.lanese@ge.com (Lou Lanese)

Marc.Brooks@dhs.gov (Marc Brooks) maria.webb@pillsburylaw.com (Maria Webb) marilyn.kray@exeloncorp.com mark.beaumont@wsms.com (Mark Beaumont)

Marvin.Smith@dom.com (Marvin L. Smith) masanori_onozuka@mnes-us.com (Masanori Onozuka) masayuki_kambara@mhi.co.jp (Masayuki Kambara) matias.travieso-diaz@pillsburylaw.com (Matias Travieso-Diaz) maurerbf@westinghouse.com (Brad Mauer) mbowling@numarkassoc.com (Marty Bowling) media@nei.org (Scott Peterson) mgiles@entergy.com (M. Giles) mike.blevins@luminant.com (Mike Blevins) mike_moran@fpl.com (Mike Moran) mlucas3@luminant.com (Mitch Lucas)

MSF@nei.org (Marvin Fertel) mwetterhahn@winston.com (M. Wetterhahn) nirsnet@nirs.org (Michael Mariotte) pareez.golub@ge.com (Pareez Golub) patriciaL.campbell@ge.com (Patricia L. Campbell) paul.gaukler@pillsburylaw.com (Paul Gaukler)

Paul@beyondnuclear.org (Paul Gunter) peter.jordan@ge.com (Peter Jordan)

DCWG - Combined (All) phinnen@entergy.com (Paul Hinnenkamp) pshastings@duke-energy.com (Peter Hastings) rbird1@luminant.com (Bobby Bird) rclary@scana.com (Ronald Clary)

REB@NEI.org (Biff Bradley)

Rebecca.Smith-Kevern@nuclear.energy.gov (Rebecca Smith-Kevern)

RJB@NEI.org (Russell Bell)

RKTemple@cpsenergy.com (R.K. Temple) robert.kitchen@pgnmail.com (Robert H. Kitchen) roberta.swain@ge.com (Roberta Swain) sandra.sloan@areva.com (Sandra Sloan)

SauerB@BV.com (Robert C. Sauer) sfrantz@morganlewis.com (Stephen P. Frantz) shinji_kawanago@mnes-us.com (Shinji Kawanago) shinji_kawanago@mnes-us.com (Shinji Kawanago) sid.kere@dom.com (Sid Kere) steven.hucik@ge.com (Steven Hucik) tgilder1@luminant.com (Tim Gilder) tkkibler@scana.com (Tria Kibler) tom.miller@nuclear.energy.gov (Thomas P. Miller) tomccall@southernco.com (Tom McCallum) trsmith@winston.com (Tyson Smith)

Vanessa.quinn@dhs.gov (Vanessa Quinn)

VictorB@bv.com (Bill Victor) vijukrp@westinghouse.com (Ronald P. Vijuk)

Wanda.K.Marshall@dom.com (Wanda K. Marshall) wayne.marquino@ge.com (Wayne Marquino) whorin@winston.com (W. Horin)