ML080870117

Request for Additional Information Regarding Nuclear Energy Institute Topical Report Number 07-09, Generic Final Safety Analysis Report Template Guidance for Offsite Dose Calculation Manual Program Description, Revision 1 (Project No. 689;

ML080870117
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/28/2008
From:	William Reckley NRC/NRO/DNRL
To:	Bell R Nuclear Energy Institute
Burrows, S A, NRO/DNRL/NRGA, 415-6086
References
TAC MD6753
Download: ML080870117 (14)

Text

April 28, 2008 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:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NUCLEAR ENERGY INSTITUTE TOPICAL REPORT 07-09, GENERIC FINAL SAFETY ANALYSIS REPORT TEMPLATE GUIDANCE FOR OFFSITE DOSE CALCULATION MANUAL PROGRAM DESCRIPTION, REVISION 1 (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. The staff has determined that additional information is necessary to complete its review. On March 14, 2008, an electronic copy of the enclosed request for additional information (RAI) was transmitted to Ralph Andersen of NEI. Although this RAI has already been provided to you electronically, we will not expect a response until 30 days following date of issuance of this letter; therefore, please let me know if you will not be able to provide your written reply within that time period.

If you have any questions or comments regarding this matter, please contact Ms. Sheryl A. Burrows by telephone at (301) 415-6086 or by e-mail at Sheryl.Burrows@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

As stated cc: See next page

April 28, 2008 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:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NUCLEAR ENERGY INSTITUTE TOPICAL REPORT 07-09, GENERIC FINAL SAFETY ANALYSIS REPORT TEMPLATE GUIDANCE FOR OFFSITE DOSE CALCULATION MANUAL PROGRAM DESCRIPTION, REVISION 1 (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. The staff has determined that additional information is necessary to complete its review. On March 14, 2008, an electronic copy of the enclosed request for additional information (RAI) was transmitted to Ralph Andersen of NEI. Although this RAI has already been provided to you electronically, we will not expect a response until 30 days following date of issuance of this letter; therefore, please let me know if you will not be able to provide your written reply within that time period.

If you have any questions or comments regarding this matter, please contact Ms. Sheryl A. Burrows by telephone at (301) 415-6086 or by e-mail at Sheryl.Burrows@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

As stated cc: See next page ADAMS ACCESSION NO.: ML080870117 OFFICE PM:DNRL/NRCA LA:DNRL BC:DCIP/CHPB OGC BC:DNRL/NRCA NAME SBurrows/ rxr4 DClarke TFrye MSpencer WReckley DATE 03/31/08 04/01/08 04/01/08 04/14/08 04/28/08 OFFICIAL RECORD COPY

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING TOPICAL REPORT NUMBER NUCLEAR ENERGY INSTITUTE 07-09, GENERIC FINAL SAFETY ANALYSIS REPORT TEMPLATE GUIDANCE FOR OFFSITE DOSE CALCULATION MANUAL PROGRAM DESCRIPTION, REVISION 1 (PROJECT NO. 689; TAC MD6753)

Distribution:

PUBIC RidsNroDcipChpb NRCA R/F RidsNroDnrlNoep SBurrows, NRO RidsNroDnrlNge1 DClarke, NRO RidsNroDnrlNge2 RidsNroDnrlNrga RidsNroDnrlNwe1 RidsOgcMailCenter RidsNroDnrlNwe2 RidsNroDnrl RidsNroDnrlNmip RidsAcrsAcnwMailCenter

Combination Mailing List:

cc: (page 1)

Mr. Laurence Parme Mr. Charles Brinkman Manager, GT-MHR Safety & Licensing Westinghouse Electric Co.

General Atomics Company Washington Operations P.O. Box 85608 12300 Twinbrook Pkwy., Suite 330 San Diego, CA 92186-5608 Rockville, MD 20852 Mr. David Lochbaum, Nuclear Safety Engineer Mr. Joseph D. Hegner Union of Concerned Scientists Lead Engineer - Licensing 1707 H Street, NW, Suite 600 Dominion Generation Washington, DC 20006-3919 Early Site Permitting Project 5000 Dominion Boulevard Mr. Paul Gunter Glen Allen, VA 23060 Nuclear Information & Resource Service 1424 16th Street, NW, Suite 404 Mr. Edward L. Quinn Washington, DC 20036 Longenecker and Associates Utility Operations Division Mr. James Riccio 23292 Pompeii Drive Greenpeace Dana Point, CA 92629 702 H Street, NW, Suite 300 Washington, DC 20001 Mr. Paul Leventhal Nuclear Control Institute Mr. Adrian Heymer 1000 Connecticut Avenue NW Nuclear Energy Institute Suite 410 Suite 400 Washington, DC 20036 1776 I Street, NW Washington, DC 20006-3708 Mr. Jay M. Gutierrez Morgan, Lewis & Bockius, LLP Mr. George Alan Zinke 1111 Pennsylvania Avenue, NW Project Manager Washington, DC 20004 Nuclear Business Development Entergy Nuclear Mr. W. Edward Cummins M-ECH-683 AP600 and AP1000 Projects 1340 Echelon Parkway Westinghouse Electric Company Jackson, MS 39213 P.O. Box 355 Pittsburgh, PA 15230-0355 Ms. Marilyn Kray Vice President, Special Projects Mr. Gary Wright, Manager Exelon Generation Office of Nuclear Facility Safety 200 Exelon Way, KSA3-E Illinois Department of Nuclear Safety Kennett Square, PA 19348 1035 Outer Park Drive Springfield, IL 62704

Combination Mailing List:

cc: (page 2)

Mr. Brendan Hoffman Ms. Vanessa E. Quinn, Chief Research Associate on Nuclear Energy Radiological Emergency Public Citizens Critical Mass Energy and Preparedness Branch Environmental Program Nuclear and Chemical Preparedness 215 Pennsylvania Avenue, SE and Protection Division Washington, DC 20003 Department of Homeland Security 1800 South Bell Street, Room 837 Mr. Lionel Batty Crystal City-Arlington, VA 22202 Nuclear Business Team Graftech Mr. Ron Simard 12300 Snow Road 6170 Masters Club Drive Parma, OH 44130 Suwanee, GA 30024 Mr. Ian M. Grant Ms. Sandra Sloan Canadian Nuclear Safety Commission Areva NP, Inc.

280 Slater Street, Station B 3315 Old Forest Road P.O. Box 1046 P.O. Box 10935 Ottawa, Ontario Lynchburg, VA 24506-0935 K1P 5S9 Ms. Anne W. Cottingham Mr. Glenn H. Archinoff Assistant General Counsel AECL Technologies Nuclear Energy Institute 481 North Frederick Avenue 1776 I Street, NW, Suite 400 Suite 405 Washington, DC 20006 Gaithersburg, MD 20877 Mr. David Repka Mr. Ed Wallace, General Manager Winston & Strawn LLP Projects 1700 K Street, NW PBMR Pty LTD Washington, DC 20006-3817 PO Box 9396 Centurion 0046 Mr. Robert E. Sweeney Republic of South Africa IBEX ESI 4641 Montgomery Avenue Mr. Dobie McArthur Suite 350 Director, Washington Operations Bethesda, MD 20814 General Atomics 1899 Pennsylvania Avenue, NW, Suite 300 Mr. Eugene S. Grecheck Washington, DC 20006 Vice President Nuclear Support Services Carlos Sisco Dominion Energy, Inc Senior Paralegal 5000 Dominion Blvd.

Winston & Strawn LLP Glen Allen, VA 23060 1700 K Street NW Washington, DC. 20006

Combination List:

cc: (page 3)

E-Mail:

tom.miller@hq.doe.gov tom.miller@ nuclear.energy.gov mark.beaumont@wsms.com sfrantz@morganlewis.com ksutton@morganlewis.com jgutierrez@morganlewis.com sandra.sloan@areva.com mwetterhahn@winston.com gcesare@enercon.com whorin@winston.com erg-xl@cox.net steven.hucik@ge.com david.hinds@ge.com chris.maslak@ge.com mgiles@entergy.com patriciaL.campbell@ge.com bob.brown@ge.com jim@ncwarn.org pshastings@duke-energy.com ronald.hagen@eia.doe.gov murawski@newsobserver.com Cary.Fleming@constellation.com tansel.selekler@nuclear.energy.gov trsmith@winston.com James.Beard@gene.ge.com george.stramback@gene.ge.com david.lewis@pillsburylaw.com paul.gaukler@pillsburylaw.com john.o'neill@pillsburylaw.com matias.travieso-diaz@pillsburylaw.com maria.webb@pillsburylaw.com roberta.swain@ge.com cee@nei.org jcurtiss@winston.com

Request for Additional Information on the Generic Final Safety Analysis Report Template Guidance for Offsite Dose Calculation Manual Program Description, Nuclear Energy Institute 07-09 Rev. 1, Feb. 2008 The following presents a request for additional information (RAI) on Nuclear Energy Institute (NEI) Template No. NEI 07-09, entitled Generic Final Safety Analysis Report (FSAR) Template Guidance for Offsite Dose Calculation Manual (ODCM) Program Description, Rev. 1, February 2008. The listed RAIs address technical and regulatory clarifications based on the staffs review of the template against U. S. Nuclear Regulatory Commission (NRC) regulatory and technical requirements and guidance. The RAIs are tied to specific sections of the NEI template. In some instances, the RAIs include suggested modifications to the existing text for the purpose of exemplifying the technical issue identified by the staff, but the staff recognizes that other approaches may be used in achieving the same objectives. Accordingly, the suggested modifications are presented for the purpose of conveying a clearer understanding of technical issues identified by the staff and facilitate NEIs effort in revising the ODCM template.

The comments do not address editorial and formatting topics.

1. Section 1, Introduction The last paragraph on p.1 should be edited to include a sentence directing the reader to the reference section for additional information on NRC regulatory requirements and guidance.

2. Section 6.2.2, Liquid Monitoring Instrumentation The bullets used under item a.2., p.7, should be replaced with a numbering system, such as (i) or (a) in facilitating internal references to each topic. This comment applies to all subsequent ODCM sections as well.

3. Section 6.2.4, Liquid Waste Management System Citation of systems, such as the Liquid Waste Management System in item a.1., p.9, should be made in lower caps since the template is a generic document. For the full ODCM, all system designations will be expected to reflect the exact nomenclature of each system, as defined in the FSAR. Note this comment applies here and throughout the entire template for all listed systems.

4. Section 6.3.1, Gaseous Effluent Dose Rate Limitation In the note located on p.11, the reference to dose factors is inconsistent with Attachment 5.

The total body, skin, and air dose factors do not apply here. Given that item c.2 addresses itself to radioiodines, tritium, and particulates, the dose factor should refer only to inhalation dose factors listed in Attachment 5.

5. Section 6.3.2, Gaseous Monitoring Instrumentation Under item d.1., p.12, the note should refer to the summation of doses from all release points Enclosure

For consistency with Section 6.2.2, p.8, insert the following parenthetical text at the end of this section, p.12, to read:

((Provide flow schematics of airborne effluent radioactivity release points from all building ventilation systems and plant process vents))

6. Section 6.3.3, Noble Gas Effluent Air Dose Limit In the notes located on p.13 and 14, the references to dose factors are inconsistent with . The total body, skin, and air dose factors do not apply here. Given that item c.

addresses itself to gamma radiation and beta radiation, the dose factors should refer only to gamma air dose factors for the note on p.13 and beta air dose factors for the note on p.14, as listed in Attachment 5.

7. Section 6.3.4, I-131, I-133, H-3, & Radionuclides in Particulate Form Effluent Dose Limit Under item c., Dose Calculations, p.14, the first sentence should be rewritten as follows:

Gaseous releases associated with anticipated operational occurrences and unplanned and unmonitored releases shall be included in the determination of a release.

The note on p.15 should refer the reader to Attachment 8 for the associated dose factors.

8. Section 6.3.5, Gaseous Waste Management System As described at the top of p.16, the requirements are incomplete working definitions of gamma, beta, and public dose projections. The following revisions are believed to provide the necessary clarifications:

a. Proposed modified Text 1 for item c.

Determine the projected 31-day gamma air dose using the equation derived under Section 6.3.3.c for gamma radiation and the ratio of estimated gaseous effluent radioactivity in the current 31-day period to that released in the previous 31-day period.

b. Proposed modified Text 2 for item d.

Determine the projected 31-day beta air dose using the equation derived under Section 6.3.3.c for beta radiation and the ratio of estimated gaseous effluent radioactivity in the current 31-day period to that released in the previous 31-day period.

c. Proposed modified Text 3 for item e.

Determine the projected maximum exposed member of the public using the equation derived under Section 6.3.4.c and the ratio of estimated effluent radioactivity due to radioiodines, tritium, and particulates radionuclides with half-lives greater than

8 days in the current 31-day period to that released in the previous 31-day period.

9. Section 6.4.1, Liquid Waste Batch Release Permits In the parenthetical text, p.16, rather than stating "List examples of batch releases," the text should say instead "List all systems with expected batch releases." Apply related fixes to Section 6.4.2 and Section 6.4.5.

For consistency with Section 6.4.5, there is a need to address the potential for releases other than planned releases, see suggested text for Section 6.4.5 (item 10 below). The following paragraph should be inserted in Section 6.4.1, p.16, after the parenthetical text:

Liquid releases associated with anticipated operational occurrences and unplanned and unmonitored releases shall be characterized by using sampling and analytical procedures for the purpose of assessing the amounts of radioactivity that were released or are being released to the environment and for determining doses to offsite receptors.

10. Section 6.4.5, Miscellaneous Gaseous Release Permit The entire paragraph, p.17, should be rewritten as follows for clarity:

Gaseous releases associated with anticipated operational occurrences and unplanned and unmonitored releases shall be characterized by using sampling and analytical procedures for the purpose of assessing the amounts of radioactivity that were released or are being released to the environment and for determining doses to offsite receptors.

11. Section 6.4.6, Radioactive Liquid and Gaseous Release Controls The header for item g., p.17, should be edited to read "Site implementing procedures control in initiating the release and identify..." so as to be consistent with item h. that follows in addressing the termination of a release.

12. Section 6.6.2, Land Use Census Under item b.2., p.21, the 25 percent requirement in reporting doses should be edited and left as a parenthetical requirement for the development of the full ODCM. The following is suggested for this sentence: dose commitment (via the same exposure pathway) ((specify percentage)) greater than at a location from

13. Section 6.6.3, Interlaboratory Comparison Program The sentence under item a. on p.21 should be edited to stipulate that the analyses for radioactive materials should be conducted for environmental media identified in Attachment 9 to read: shall be analyzed, given the environmental media identified in Attachment 9.

14. Section 6.7.2, Annual Radioactive Effluent Release Report Under item a.3., p.23, the text should be revised to read description of unplanned and/or unmonitored releases from the site so as to capture the range of all possible types of releases that must be reported to the NRC.

Under item b.3., bottom of p.23, the end of the sentence should read as follows: shall be used to determine gaseous, radioiodines, tritium, and particulates, with half-lives greater than 8 days, pathway doses.

Under item b.3., the parenthetical text on top of p.24 should refer to Attachment 13 for details on site specific meteorological conditions used for gaseous effluents dose pathways.

15. Section 6.7.4, Changes to the ODCM The parenthetical text under item a., p.24, should be revised to read: ((Identify the functional organization and define the level review and approval)).

The word Documented. under item b., p.24, seems extraneous. It should be deleted.

16. Section 6.7.5, Groundwater Protection Initiative Under item a.2., p.25, the third line from the bottom should be edited to read ... and having the potential to reach groundwater or surface water that is or could be used as a source of drinking water. This change makes this requirement consistent with NEI 07-07, see subsection b.i., top of p.9.

17. Deleted Section 7, Records The previously deleted Section 7, Records, should be reinstated in the ODCM and include the following sentence: The licensee shall maintain all records associated with the implementation of the ODCM in accordance with the site records management system.

18. References The following references should be added to the listing of current citations:

a. NUREG/CR-4013, LADTAP IITechnical Reference and User Guide, NRC, April 1986.

b. NUREG/CR-4653, GASPAR IITechnical Reference and User Guide, NRC, March 1987.

c. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation).

d. ANSI/HPS N13.1-1999, Sampling and Monitoring Releases of Airborne Radioactive Substances from the Stacks and Ducts of Nuclear Facilities, 1999.

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

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

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

h. 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.

i. 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.

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

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

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

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

n. 10 CFR 20.2202, Notification of Incidents.

o. 10 CFR 20.2203, Reports of Exposures, Radiation Levels, and Concentrations of Radioactive Material Exceeding the Constraints or Limits.

p. 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors.

q. 10 CFR 50.73, Licensee Event Report System.

Reference 20 should be edited by adding to it the following text, as implemented under 10 CFR Part 20.1301(e).

References 15 and 23 should be edited by adding to each the following text, as contained in NUREG-1301 and NUREG-1302.

For reference 14, change the publication date to September 1984 as the correct date for this citation.

For reference 18, change the citation to read: Report of the ICRP Committee II on Permissible Dose for Internal Radiation (1959).

For reference 25, edit the reference for consistency as the cited section is only a subsection of FSAR Chapter 17.

Reference 32 should be edited by adding to it the following: Note: Given that this template is based on the North Anna Unit 1 & 2 ODCM, it may be useful to review its approach and methods applied in deriving doses, dose projections, and in determining radiation monitoring instrumentation alarm set-points in developing a plant-specific ODCM.

Comment: It is suggested that all references be reordered by decreasing order of importance, such as first by regulations and then by generic letters, regulatory guides, NUREGs, standard review plan, other types of guidance documents, etc.

19. Attachment 5 A review of the dose factors listed in Attachment 5, p.33, indicates that the Pi dose factor for inhalation is not tabulated, nor defined. See Attachment 5, p.3 of 3 of the North Anna ODCM.

Accordingly, revise the tabulation of Attachment 5 to include the Pi inhalation dose factor and add its definition to those already listed under the second note of p.33.

The heading of the tabulation on p.33 should be revised to read: Gaseous Effluent Radioiodines, Tritium, and Particulate Dose Factors.

20. Attachment 6 Delete the second note and the definition of the Pi organ dose factor as this is already addressed in Attachment 5.

21. Attachment 8 A review of the dose factors listed in Attachment 8, p.36, indicates that the RMivv and RMipv dose factors for critical organs are not defined when compared to Attachment 5, p.33.

Accordingly, revise the tabulation of Attachment 8 to include the RMivv and RMipv dose factors for critical organs under a note. See Attachment 5 format for consistency.

The radiological units listed in the tabulation should be revised to read: mrem/yr per Curie/sec.

22. Attachment 9 The following changes should be made to this attachment so as to make it consistent with generic NRC programs of NUREG-1301 and NUREG-1302:

a. Assign (NOTE 1) to the title heading of Attachment 9.

b. For direct radiation, the number of TLD locations should read Forty routine monitoring

c. In item 2) for direct radiation, change text to read: within 6 to 8 km range

d. For waterborne media, qualify that grab sampling is based on a composite sample.

e. For drinking water, qualify that composite samples need to be collected bi-weekly when I-131 is present.

f. For drinking water, the scope of the radiological analysis must include I-131 when present.

g. For milk, specify that the collection and radio-analytical frequencies are semi-monthly when animals are on grazing pastures and monthly at other times.

h. For fish, specify that the collection frequency is seasonal for the listed species and semiannually if not seasonal.

i. For food products, specify that the samples must include three different kinds of broad leafy vegetables, and that food products subject to irrigation should be included when irrigated with irrigation water impacted by plant liquid effluent discharges.

j. For NOTE 1, p.40, the following text should be inserted after the first sentence:

See Table 3.12-1 of NUREG-1301 or NUREG-1302 for specific guidance on the scope and elements of the program, including qualifying notations on radiological analysis, determination of up and downstream sampling locations from discharge points, composite sampling, groundwater sampling when groundwater is a source of drinking water, and sampling of food products during harvest times.

23. Attachment 10 Add the following notes, p.42, to the tabulation:

Note: Add descriptive qualifiers to each sample media as required.

Note: Provide a map showing the points of all identified sampling locations around the plant.

24. Attachment 11 The existing note, p.43, should be revised to read: and qualifying conditions, including measurable and identifiable radionuclides other than tabulated above.

A new footnote should be added for water samples identifying conditions whenever drinking water pathways exist. Add on p.43, the following footnote: See NRC guidance on LLDs when a drinking water pathway exists.

25. Attachment 12 In Attachment 12, p.44, add the following note for water samples whenever drinking water pathways exist: See NRC guidance on reporting levels when a drinking water pathway exists.

26. Attachment 13 The parenthetical text included in Section 2.2 and after Section 3.1 should be edited to read:

((Describe analysis methodology and model assumptions and parameters)).