ML20128G870

Forwards Comments on Offsite Dose Calculation Manual Submitted by .Revised Manual Resolving Staff Comments Requested

ML20128G870
Person / Time
Site:	Perry
Issue date:	05/20/1985
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8505300338
Download: ML20128G870 (13)

Text

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IAAY 2 01985 l Docket Nos.: 50-440 and 50-441 Mr. Murray R. Edelman, Vice President Nuclear Operations Group The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 l

Subject:

NRC Staff Coments on the Offsite Dose Calculation Manual for the Perry Nuclear Power Plant, Unit 1 The staff hcs completed its initial review of the Offsite Dose Calculation Manual (0DCM) submitted by your letter dated February 28, 1985 and its specific comments on the ODCM are enclosed. It is requeste'd that your staff submit a revised ODCM that resolves the staff's comments. Should your staff wish to discuss the enclosed comments, please advise the Perry Project Natiager, John Stefano, accordingly so that appropriate arrangements can be scheduled.

Sincerely, B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing

Enclosure:

As stated cc: See next page DISTRIBUTION:

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MAY 2 01S85 Docket Nos.: 50-440 J and 50-441 l

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f Mr. Murray R. Edelman,-Vice' President Nuclear Operations Group The Clevelarid Electric Illuminating Company

, P.-0. Box 5000 Cleveland, Ohio 44101

Subject:

NRC Staff Coments on the Offsite Dosa Calculation Manual i _ for the Perry Nuclear Power Plant,- Unit 1

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[ The staff has completed its initial review of the Offsite Dose Calculation Manual (0DCM) submitted by your letter dated February 28, 1985 and_its spacific

, . consents 'on the ODCM are enclosed. It is requested that your staff submit a revised ODCM that. resolves the staff's comments. Should your staff wish to discuss the enclosed comments, please advise _the Perry Project Manager, John Stefano, accordingly so that appropriate arrangements can be scheduled.

Sincerely, g/4. w;ba B. J. Youngblood, Chief Licensing Branch No. I Division of Licensing

Enclosure:

As stated cc: See next page c .

PERRY-

[($y p g ,

Mr. Murray R. Edelman, Vice President Muclear Operations Group

_The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101 cc: Jay Silberg, Esq. . Mr. Larry O. Beck Shaw, Pittman, & Trowbridge The Cleveland Electric 1800 M Street, N. W. Illuminating Company Washington, D. C. 20006 P. O. Box 97 E-210 Perry, Ohio 44081 Donald H. Hauser, Esq.

The Cleveland Electric Illuminating Company P. O. Box 5000 Cleveland, Ohio 44101-Resident Inspector's Office U. S. Nuclear Regulatory Commission Parmly at Center Road Perry, Ohio 44081 Regional Administrator y

U. S. NRC, Region III-799 Roosevelt Road Glen Ellyn, Illinois 60137 Donald T.' Ezzone, Esq.

Assistant Prosecuting Attorney 105 Main Street l Lake County Administration Center

[_

Painesville, Ohio 44077 I

Ms. Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, Ohio 44060 Terry J. Lodge, Esq.

618 N. Michigan Street Suite 105 Toledo, Ohio 43624

-John G. Cardinal, Esq.

Prosecutir.g Attorney Ashtabula County Courthouse Jefferson, Ohio 44047-

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ENCLOSURE COMMENTS ON THE PERRY UNIT 1 i 0FFSITE/ DOSE CALCULATION-MANUAL (REV. 0)

Section ~ ,

Comm'ent

2.0 Provide in section 2 a flow diagram of the liquid radioactive waste treatment systems, ir.cluding the discharge point and the Radwaste Discharge. Radiation Monitor. This

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should be a simple diagram with'as little extraneous detail at possible.

2.0/2.2 All potential release points from the PNPP are not batch releases. Some can-be continuous. They include:

(1) Emergency Service Water Loops; (2) Liquid radwaste discharge, sanitary discharge; and (3) Underdrain system ODCM should contain a discussion of these release points.

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2 2.1.2 - From pg 11.2-20 of the FSAR it would appear.that mdf=10,000 rather than 30,000 gpm..

2.1.3L Use of the factor of 1.25 in Equation 2.1-5 is inappropriate. This section does not address how the-Applicant will establish the alarm trip setpoint. -

Suggest reference to other 0DCM's that have been approved. Alarm / trip setpoint should account for effluents such as tritium which are not gamma'or X-ray emitting and would not be seen by gamma scintillation detector..

s Setpoints are usually established based upon the maximum possible flow.

The method presented in Section 2.1.3 would always be based upon the concentration in the release tank and would not be sensitive to changes in release rates.

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-2.2.1 . Equation 2.2-1 should have f as the ,,

maximum possible discharge rate from the given tank.

2.2 Inequations(2.2-2)and(2.2-4),

use of the limiting MPC$ of 10 CFR 20 Appendix B, Table II, Column 2 should be specified.

2.3.1 The ODCM should contain sufficient information to enable calculation of doses for the necessary pathways.

For use in section 2.3.1, additional site specific information should be

. provided. Provide a listing of the points of exposure, the points of withdrawal of drinking water and the points of harvest of aquatic food, identifying the location and the dilution factor Mp for each. Provide i

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. in the ODCM a map showing the locations .

of-the closer-drinking water intakes.

J 2.3.1 -In section 2.3.1, the period of time of exposure bt ,f is set at 15 years.

This should be.the period.to the midpoint'of plant life; if plant life is to be 40 years, then t b

- should be 20 years.

2.3.2 Section 2.3.2 indicates that the Applicant will perform an. analysis of possible impacts through the drinking water pathway with regard '

to the requirements of 40 CFR 141.

Include an explanation of how that analysis will be performed. Provide the necessary site specific data.

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.3.0- . - With section 3.0 Gaseous Effluents, provide flow diagrams of gaseous radioactive Whste treatment systems leading to each of the four environ-mental release points. Show the location of each radioactivity release monitor for gaseous effluents.

Provide the location and a brief description of each release vent point, including whether the vent is equipped with deflector.

3.0/3.1 The steam packing exhauster should be added to this section as a potential release point.

3.1 The determination of the set point seems to imply that each monitor

', - may be allowed to go above.the 500

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6 mrem and 3000 mrem skin limits.

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. Releases should be apportioned to -*

each release point such that the total from all release points is less than 500 mrem whole body and less than 3000 mrem skin.

3.1 Initial estimates of the gaseous source terms for section 3.1.1.

should be provided, especially the

" mix" 1.e., the selection of radio-nuclides and their relative propor-tions.

3.2- In section 3.2, provide a map of the site showing clearly the Site Boundary and the boundary to the Unrestricted Area. Show the compass directions and a scale of distance, such as provided in Figure 5.1-2.

. 3.2.3 In Section 3.2.3, at the bottom of page 37 reference is made to Table n,..__,__.__-__.._... .. .... .. _. _._

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3.2-15 which-is for the average individual. Table 3.2-14, for the maximum indiv'idual, should be referenced here instead.

3.2.3 The abbreviation "ft" for feet should be used throughout, rather than "f". Use of "f" is confusing

- because it is also used for the flowrate; in section 3.2.3 it is used both ways in one definition.

3.2 Pages 51 through 58 appear to be duplicates of pages 14 through 21.

Duplication within the ODCM is not necessary.

4.1 In the third paragraph of Section 4.1, the applicant proposes to seek a variance if it is discovered that' PNPP operations have violated the 40 CFR 190 standard. The intent of the

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- variance provision is to permit continued operation while a problem which might' lead to a violation-is corrected. The variance provision is not a device to expunge a violation which has already occurred..

5.1 In Table 5.1-1, under the Locations column, in addition to the sampling point number, a -brief description should be provided, giving the principal characteristics appropriate for locations for each specific type of sample medium listed. Such infor-mation complements the information

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provided in Table 5.1-4. ,

5.1 Drinking water sampling (Table 5.1-1)

- should also include the Lake County supply for which the intake is located about 1.5 miles west of PNPP.

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In Table 5.1-4, the sample location descriptions should not rely on "-

markers such as, in Nc. 8, the

- rusted manure spreader which may not be sufficiently permanent.

5.1 Figures 5.1-1 and 5.1-2 are not clear enough. Provide either large, clear foldouts or supplement clear versions of these figures with clear figures giving more detail of the vicinty of sampling locations or groups of locations.

- 5.2 Provide a copy of the_ latest Land Use Census, used to determine the locations for. collecting milk and produce samples and to deternine

_ receptor locations'for dose calcula-tions for various pathways. Include the date the data was gathered.

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APPENDIX A -

PAGES80/81[dentifyTf (a figure or algorithm woul'd suffice) and provide a reference.

PAGE 80 Identify the level of measurement for u (presumably the wind speed at the 10m level).

PAGE 80 Provide the value of-He*

PAGE 80 Provide either a figure indicating the relationship of dl2 to stability and downwind distance or an appropriate reference (e.g. , Regulatory Guide 1.111).

PAGE 80 The description of the information contained in Tables A-2 through A-5 should specify the data base by identifying "the three FSAR years of meteorological data."

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APPENDIX B In the last paragraph of Appendix B, correct the references to tables.

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