ML19254E819

Discusses Compliance W/Radiological Impact Requirements in Response to 790917 Ltr.Summary of Tera Corp Oct 1976 Rept Findings Encl.Radiological Release Assessments Will Be Taken Quarterly

ML19254E819
Person / Time
Site:	Calvert Cliffs
Issue date:	10/30/1979
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Gammill W Office of Nuclear Reactor Regulation
References
NUDOCS 7911020357
Download: ML19254E819 (3)

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B ALTIMORE G AS AND ELECTRIC COMPANY P.O. BO X 147 5 B ALTIMO R E. M A R YL AN D 21203 AnTHun C. LUN DVALL,JR.

V'CC Pets otm?

h eet, October 30, 1979 Mr. William P. Gammill Director for Operating Reactor Projects Division of Operating Reactors Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Gamill:

In response to your letter dated September 17, 1979, regarding conformance with the provisions of 40 CFR Part 190, this letter will demonstrate how we will show compliance with these provisions.

In October 1976, Tera Corporation submitted a report to Baltimore Gas &

Electric Company on the radiological impact of Calvert Cliffs with regard to Appendix I requirements. This report was subsequently submitted to the Nuclear Regulatory Commission as our response for Appendix I. This report shows that the radiological impact of the plant will conform with the pro-visions of 40 CFR Part 190. Table 1 shows a sumary of the findings of the report.

Although we feel no further action is required, we will have a radiological assessment of our releases performed on a quarterly basis. This quarterly assessment will be sumed for a twelve month period enabling us to evaluate the dose comitment to any real individual over 12 consecutive months.

Methodology employed in calculating doses from both liquid and gaseous ef-fluents is that prescribed in USNRC Regulatory Guide 1.109, as embodied by the Comission's LADTAP and GASPAR computer codes. Both codes were origi-n?lly developed to evaluate annual doses from nuclear power plants, based on 07tal yearly emissions, for the purposes of evaluating compliance with Appendix I to 10 CFR 50. The same methodology can be applied to the eval-uation of doses from radioactive materials released over a shorter period of time, under the assumption that isotopes released will be present in equilibrium concentrations in all components of each exposure pathway over the release period. For some pathways, components, and isotopes this repra-sents a conservative assumption, since equilibrium throughout a pathway may

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not be reached. Bioaccumulation factors, consumption and usage rates, transport times, and dose conversion factors to be utilized are those presented in Regulatory Guide 1.109.

Dilutfor. factors (x/Q's) for batch releases will be calculated for each location for each release, based on actual meteorological data taken dur-ing the release period. An hourly x/Q value will be calculated for a given location for each hour during which gaseous effluents are vented.

A zero value is assigned when the hourly wind blows in a sector of no interest. An average x/Q for the location for the release period will be calculated by suming the hourly x/Q values and dividing by the num-ber of hu rs in the release period in which venting took place.

Continuous releases will be sumed and the isotope infomation based on weekly periods. Therefore, for each week during this period, weekly average x/Q values for the receptor points of interest will be calculated.

These values will then be adjusted to reflect the possibility of /umigation.

For hours with winds blowing towards a sector of no interest, a zero value will be assigned.

All gama imersion doses will be calculated based on submersion in a semi-infinite cloud with uniform concentrations based :m g-ound level x/Q values, regardless of whether the meteorological data is indicative of ground level, elevated or mixed mode releases.

Doses from liquid releases will be calculated for fish and invertebrate ingestion and shoreline exposure pathways. A dilution factor of 5 will be used for all pathways, and no credit will be taken for radioactive de-cay in transit from the outfall structure to the point of exposure. A circulating water flow of 1.231 x 106 gpm will be used for all calculations.

If you have any further questions regarding this mattar, please do not hesitate to contact us.

Sincerely, '

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,;, y -C W - IN 9 185 Arthur E. Lundvall, Jr.

Vice President - Supply AEL/LBR/PTC/ nib Attachment

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N TABLE 1 Comparison of Appendix 1 (May 5.1975) and The Staff's Proposed Appendix I (RM 50-2, February 1974) to Calculated "Miximum Individual" 00ser Calvert Citffs Calvert Cllffs Flevated Case U RejrIse GrnundLevel(3)

Release Case Appendix ! RH 50-2 5 mrem / site (total 0.004 mrem 0.004 mrem Sec II.A Lf auld Effluents (Total Cody) 3 mrer/ reactor body or any organ) 5 Cf/ reactor 0.007 mrem (Ilver) 0.007 mrem (1tver)

(Any Organ) 10 mrem / reactor (All Pathways) 0.62 Curies / reactor 0.62 Curfes/ reactor 10 mrad y/ reactor 10 mrad y/sfte 0.06 mrad 1.2 mrad Sec II.B.1 Gaseous Effluents (AirDose) 4.9 mrad 20 mrad B/ reactor 20 mrad B/ site 0.24 mrad (Air Dose)

O' 5 mrerr/stte 0.02 mrem 0.37 mrem Gaseous Ef fluents(2) (Total Body) 5 mrem / reactor Sec II.B.2 15 meem/ site 0.09 mrem 1.7 mrem (Skin) 15 mrem / reactor 15 mrem / site 0.65 mrem T.2 mrem lodine and Particulates (Any Organ) 15 mrem / reactor Sec II.C 0.01 C1/ reactor 0.01 01/ reactor (All Pathways) 1 C1/ reactor 1-131 (1) Excluding tritium and dissolved noble gases.

(2) Higher quantitles may be pennitted if assured that doses to any individual in an unrestricted area will be less than hese value (3) Calculated doses are for two-unit opeations. .

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