ML20153B794

Technical Evaluation Rept for Evaluation of Offsite Dose Calculation Manual Through Rev 2,Clinton Power Station,Unit 1

ML20153B794
Person / Time
Site:	Clinton
Issue date:	06/30/1988
From:	Bohn T, Freeman A, Serrano W EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20153B798	List: ML20153B794 ML20154G528
References
CON-FIN-D-6034 EGG-PHY-8097, NUDOCS 8808310095
Download: ML20153B794 (26)

Text

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EGG-PHY-8097 TECHNICAL EVALUATION REPORT for the EVALUATION OF ODCM UPDATED THROUGH REVISION 2 CLINT0h POWER STATION, UNIT 1 NRC Docket No. 50-461 NRC LIC2NSE No. NPF-62 T. S. Bohn h^. Serrano .

A. L. Freeman M. R. Winberg i

i Published June 1988

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! Idaho National Engineering Laboratory EG&G Idaho, Inc.

l Idaho Falls, Idaho 83.415 l

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l Prepared for the i U. S. Nuclear Regulatory Comnission Washington, D. C. 20555 Under DOE Contract No. OE AC07-761D01570 FIN No. 06034

>S 3.LG$ $ 0flpp,

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, ABSTRACT The Offsite Dose Calculatior. Manual for the Clinton Power Station, Unit 1 (CPS) contains the cu: rent methodology and parameters used in the calculation of offsite doses <.iue to radioactive gaseous and liquid efficents, in ti,e calculation of gaseous and liquid effluent monitor alare/ trip .tetpoints, and in the conduct of the environmental radiological monitoritig program. Revision 1, dated November 1985, was submitted to the NRC with letter dated December 23,1985 and w3s, in geaeral, approved by the NRC on February 14, 1986. Subsequently, Revision 2 was reported to  :

the NRC in the Semtannual Radioactive Eff!uent Release Report for January-June 1987. The NRC transmitted the ODCM updated through Revision 2 to the Idaho Maticnal Engineering Laboratory (INEL) for review. The ODCMa complete through Revision 2, was reviewed in its entirety by EG&G Idaho St tne INEL and the results of the review are presented in this report. It was determined thut the ODCH updated through Revisica 2 uses '

methods that are, in general, in agreement with the guidelines of NUREG-0133. However, it is recommended that another revision to t.he 00CP be submitted to address the discrepancies identified in the review.

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FOREWORD This report is submitted as partial fulfillment of the "Review of Radiologict) Issues" prcject being contracted by the Idaho National

. Engineering Laboratory for the U. S. Nuclear Regulatory Commission, Office of Nuclear Reactcr Regulation. The U. S. Nuclear Reguistory Consission funded the work under FIN D6034 and NRC B&R Ncmber 20 19 05 93.

This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warrant, 4 expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, appa'ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately-owned rights.

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t CONTENTS Page Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 3

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4

2. ' Review Criteria. . . . . . . . . . . . . . . . . . . . . . . . . 2

3. Evaluattor ........................... 3

4. Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . 17

5. References . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 .

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1. INTRODUCTION Puroose of Review This document reports the review and evaluation of the Offsite Dose Calculation Manual (ODCM), updated through Revision 2, submitted by the Illinois Power Company, the Licenses for the Clinton Power Station, Unit 1 (CPS). The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirements.Ill Plant-Soecific Backaround lhe Illinois Power Company submitted to the Nuclear Regulatory Commission (NRC) on December 23,1985,[2] ODCM Revision 1, dated November 1985 for CPS . The NRC reviewed the ODCM and found it to be, in

- general, acceptable as stated in letter dated February 14,1986.(3) The latest revision, Revision 2, dated October 1986 was submitted to the NRC on August 28, 1987 with the Semiannual Radioactive Effluent Release Report for the first half of 1987.l43 The NRC transmitted all revisions updated through Revisien 2 to the Idaho National Engineering Laboratory (INEL) for review. The ODCM, updated through Revision 2, was reviewed in its entirety by EG1G Idaho at the INEL. The results and conclusions of the review are presented in this report.

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2. REVIEW CRITERIA Review criteria for the ODCM were provided by the NRC in two documents:

NUREG-0473, RETS for BWRs[5]

NUREG-0133, Preparation of RETS for Nuclear Power Plants.[6]

The following NRC guidelines were used also used in the ODCM review:

"General contents of the Offsite Dose Ct.lculation Manual,"

Revisien 1,[7] and Regulatory Guide 1.109, Revision 1.[8]

As specified in NUREG-0473, the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and to maintain the operability of the radioactive effluent systems. As a minimum, the ODCM should provide equations and methodology for the following:

. Alarm and trip setpoints on effluent instrumentation.

. Liquid effluent concentrations in unrestricted areas.

. Gaseous effluent dose rates at or beyond the site boundary.

. LiquM and gaseous effluent dose contributions.

. Liquid and gaseous effluent dose projections.

l In addition, the ODCH shovid contain flow diagrams that define the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management, systems. These flow diagrams should be consistent with the systens being used at the plant. A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

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3. EVALUATION The Clinton Power Station, Unit 1 is a BWR located on the Clinton Power Station site. The ODCM contains the current methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm / trip setpoints, and in the conduct of the environmental radiological monitoring program.

In the transition between Revision 1 and Revision 2 of the ODCM, the following administrative errors were detected in the copy of Revision 2 received by the reviewer:

. Scme of the page revisions identified in the "List of Effective Pages" is incorrect.

. The last portion of Section 2.4 is missing in Revision 2 beginning with the definition of the quantity Ajj.

. Deletion pages are included in Revision 2 for Table 2.6-1; however, the table is still included.

. Table 3.4-1, Revision I was expanded f vm one to three pages in Revision 2; however, the page numbering following this table does not reflect this change.

. Pages 2-25, 3-15 and 3-18 are missing from Revision 2 of the ODCM.

. Section 3.7.1 of Revision 2 is missing down to and including the definition of the quantity Fj.

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. Table 3.5-29, which contains the teen-vegetation pathway dose rate factors was missing and a copy of the child-vogetation pathway dose rate factors from Table 3.5-28 was inadvertently substituted in its place.

Liauid Fffluent Pathways CPS is located in Harp Township, DeWitt County, approximately six miles east of the city of Clinton in east-central Illinois. Lake Clinton, a reservoir formed by the construction of a dam downstream from the confluence of Salt Creek and the North Fork of Salt Creek, supplies water to the once-through circulating water system, service water, and dilution i water for the liquid radwaste discharge.

The liquid waste management systems collect, monitor, and process for reuse or disposal all potentially radioactive liquid wastes in a controlled manner. The wastes are collected, treated and disposed of

• according to demands n' each of the following subsystems:

Equipment Drain Subsystem Floor Drain Subsystem Chemical Waste Subsystem Laundry Waste Subsystem.

Once the wastes are collected, they are processed by the appropriate liquid waste treatment subsystem and are eitner discharged or reused. The ODCM infers that simultaneous releases are not permitted and the waste is batch released from one of the following ts.nks:

Wasta Sample Tank A Waste Sample Tank B Waste Sample Tank C According to Figure 2.5-1 of the ODCM (Figure 1 of this report), all 4

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9 LIQUID RADWASTE TREA'INENT SYSTEM

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• Monitors required by CPS TECHNICAL SPECIFICATIONS 1VT015 T1oor Drain OVZO1P Chem. Vat. 2WT04T T1oor Drain Okt02TA,3, and C Vaste Evcporator Evap. Tank Pump Evaporator TarJc Samp. Vi Pumps 2VT01S T1cor Drain OVE01FA,B, and C OVZO1T Chem. Vaste OVE017A and 3 Excess Evcporator Vasta Tilters Evaporator Tank Water Tanks OV 0!S Chemical 0VIO1DA,B, and C 1VT04P Fir. Drn. OVE0lPA and 3 Excess VOste Evaporator Vaste Domins Evap. Tank Pump Water Tank Pumps 1k'T04T Floor Drain OVIO2TA,B, and C 2VT04P Tir. Drn< 1PR036 Service Evcporator Tank Vaste Sample Tks. Evap. Tank Pump Vater PM 1PR040 Liquid kW Figure 1. Clinton Power Station Unit I liquid radwaste Discharge PM treatment system. (Taken from . Figure 2.5-1

'of the Clinton' ODCM, Rev. 2 dated October 1986,) Rev.2-10/86 5

.I liquid radwaste meant for release, passes through the monitored Liquid Radwaste Discharge Line. The liquid radwaste effluent flow combines with Plant Service Water flow and Plant Circulating Water flow in the Seal Well prior to entering the 3.4 mile discharge fiume to Lake Clinton. A simplified flow diagram of the solid radwaste treatment system is missing in the ODCM and should be included.

In addition, discharge from the Plant Service Water, which is normally non-radioactive, has a finite possibility of becoming contaminated. The Plant Service Water discharges continuously and a Process Radiation Monitor (PRM) is set to alarm at three times tha background. The map in figure 2.1-1 of the ODCM showing the unrestricted area boundary for liquid effluents is illegible and should be replaced.

J.iguid Effluent Monitor Setoointi

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Sections 2.3.1 and 2.3.2 of the ODCM contain the methodology used to determine the setpoints for the liquid radwaste and Plant Service Water monitors in compliance with Technical Specification 3.3.7.11. There is an automatic termination of release function for the Liquid Radwaste Di: charge monitor as indicated in the instrumentation Surveillance Technical Specification Table 4.3.7.11-1.

i Setpoints for the Liquid Radwaste Discharge Line are based on the radionuclides identified in each batch of liquid waste prior to its release. If weekly grab sample analysis of the Plant Service Water indicates contamination above backgrcund, then the methodology used to determine the setpoint for the Liquid Radwaste Discharge Line are used to determine the Plant Service Water monitor setpoints.

In Section 2.3.1.1, it is stated that the concentration of alpha emitters and tritium in the liquid radwaste will be as determined from the monthly analysis of a composite sample. However, Technical Specification Table 4.11.1-1 states that the analysis is made on a quarterly basis. If 6

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the data are only available on a quarterly basis, then the Licensee should reconsider the comitment in Section 2.3.1.1.

In Section 2.3.1.1 of the 00CM, the reference to the CPS RETS should be Table 4.11.1-1 instead of Table 4.11-1.

Sections 2.3.1 and 2.3.2 contain the methodologies for determining the alarm setpoints for the Liquid Radwaste Discharge and Plant Service Water monitors. The methodologies are, in general, in agreement with the guidelines of NUREG-0133 and are considered acceptable. ,

Gaseous Effluent Pathways i

According to Surveillance Technical Specification Table 4.11.2-1, +

there are two gaseous environmental release points at CPS:

i Common Station HVAC Stack Standby Gas Treatment Systeni (SGTS) Stack.

The SGTS is an engineered safety feature filter system utilized only following an accident to reduce iodine and particulate activity in gases leaking from the primary containment and which are potentially present in the secondary containment. The heights of these stacks (each stack is 61 meters high) are such that all gaseous effluent releases are treated as mixed mode ground releases. Gaseous effluents from CPS are released on i both a batch and continuous basis. Gaseous effluents are normally discharged on a long term basis. High volume continuous containment purge and mechanical vacuum pump discharges are considered short-term releases.

l The Comon Station HVAC Stack receives process, and ventilation i exhaust from the following inputs:

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e Continuous Containment Purge

. Containment Building Ventilation l

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. Turbine Building Ventilation

. Radwaste Building Ventilation

. Auxiliary Building Ventilation

. Fuel Building Ventilation

. Auxiliary Building Refrigerant purge

. Laboratory Ventilation System

. Counting / Equipment Decon Rooms Ventilation

. Steam Packing Exhauster

. Mechanical Vacuum Pump

. Drywell Purge Technical Specification 4.11.2.5.2 requires that the Ventilation Exhaust Treatinent System shall be operable and shall be used to reduce radioactive materials in gaseous waste prior to their discharge as necessary to meet the requirements of Technical Specifications 3.11.2.1 and 3.11.2.2 or 3.11.2.3. After processing, the gaseous effluents are routed to the HVAC stack for release to the environment. Figure 3.3-1 in the ODCM is a diagram of the gaseous radwaste treatment system. Figure 2 of this report is a reproduction of this diagram.

The technical specifications identify noble gas monitors, iodine and particulate samplers, and effluent flow measuring devices to monitor gaseous effluent releases. The stack effluents are continuously surveyed during release of noble gases. The iodine and particulate samplers are routinely analyzed in accordance with Technical Specification Table 4.11.2-1.

In Section 3.2.2 of the ODCM the text indicates that the PRM (Process Radiation Monitoring) detector configuration for the SGTS stack utilizes nine channels, however, only six are listed.

Gaseous Effluent Monitor Setooints Sections 3.7.1 and 3.7.2 of the ODCM contains the methodology used to 8

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't MAIN CONDENSER OFF-GAS TRENIMENT SYSTEM

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Contairment Exhaust

• Monitors required by CPS TECHNICAL SPECIFICATIONS 1CD01A Main OCA01TA CV 1N6630105 Cooler 1N66D013 1PR355 Off-Gas l C: denser Separator Tank A Condenser B Charcoal Adsorber Post Treatment PR.

I 1CA01AA Steam Jet OCA01T3 CV 1N662003A IN66D016 HIPA 1PR415 Off-Cas Air Ejector A Separator Tank 3 Dessicant Dryer A Pilter Post Treatment PR' l 1CA01A3 Steam Jet 1N66D00$A 1N6620035 OPR01S HVAC 1P1003 Scandby Ga l Air Ejector 3 Recombiner A Dessicant Dryer B Stack PRM #1 Treatment PRM bCA01PACondenser 1N66D005B 13665011 Gas 0P1025 HVAa. 1P1004 Standby Ga Vccuum (CV) Pump A Recombiner B Cooler Stack PAM #2 Treatment PRM CCA0178 CV Pump B IN663010A Cooler IN66D012 171345 Off-Cas Condenser A Charcoal Adsorber Pretreatment PRM Figure 2. Clinton Power Station, Unit 1 gaseous radwaste treatment system. (Taken from Figure 3.3.-1 of

-the Clinton ODCH, Re'v. 2 dated October 1986.) Rev.2-10/86 9

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.I determine the setpoints for the noble gas effluent monitors as required by Technical Specification 3.3.7.12. Table 3.3.7.12-1 of the technical specifications identify noble gas monitors for the HVAC and SGTS stacks.

The monitors for releases from the HVAC and SGTS stacks have no automatic control functions but annunciate in the main control room and the radiation protection office.

Sections 3.7.1 and 3.7.2 contain the methodologies for determining the setpoints for the HVAC and SGTS stack monitors. The calculated total body and skin maximum acceptable concrntration setpoints are compared and the more restrictive setpoint is used. In Section 3.7.2, in the definition of Lj, the units should be mrem /yr per pCi instead of mrad /yr per yCi.

The map in Figure 3.1-1 of the 00CM showing the CPS site boundary for gaseous effluents is illegible and should be replaced.

The methods for determining the setpoints for the noble gas effluent 1 monitors are in agreement with the guidelines of NUREG-0133 and are considered acceptable.

Oncentrations in liauid Effluents Section 2.3.1.1 contains the methodology for determining the radioactivity concentrations in liquid effluents, as required by Surveillance Technical Specification 4.11.1.1.2. The methodology is within the guidelines of NUREG 0133 and is considered acceptable.

Dose Rates in Gaseous Effluent _s Section 3.4.1 contains the method for determining the noble gas dose rates to the total body and skin as required by Surveillance Technical l Specification 4.11.2.1.1. The method is in agreement with the guidelines of NUREG 0133 and is considered acceptable.

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i Section 3.4.2 contains the method for determining the dose rate due to the release of tritium, iodine-131, iodine-133 and all radionuclides in particulate form with half lives greater than 8 days as required by Surveillance Technica) Specification 4.11.2.1.2.

In Section 3.4.2, Equation (3), which determines the organ dose rates due to radiciodines (I-131, I-133), particulates with half-lives greater than 8 days and tritium should be summed only over the index 1. Also, the symbol indicating rate ( ) should be over the quantity Q g instead of (X/Q) . Also, the units for Mg should be defined as mrad /yr per pCi/m instead of mrem /yr per pCi/m3 , .

The following inhalation pathway dose rate factors, Pjj, need to be corrected in Table 3.4-2:

Cu-64 Lung change 9.58E-OS to 9.58E-05 mrem /yr per pCi/m3 Br 85 T. Body 2.53E+01 " 2.40E+01 Y-91m Bone 5.07E-01 " 507E-01 The methodology for determining the dose rates due to the release of tritium, iodine-131, iodine-133 and all radionuclides in particulate form with half lives grnater than 8 days is, in general, in agreement with the guidelines of NUREG 0133 and is considered acceptable.

h u.Due to Liauid Effluents Section 2.4 contains the methodology for determining the dose due to radioactive material released in liquid effluents as required by Surveillance Technical Specification 3.11.1.2.

Doses to the members of the public due to radionuclides identified in the liquid effluents will be calculated at least once per 31 days to show compliance to surveillance Technical Specificatiot 4.11.1.2. CPS identifies the fish consumption and potable water pathways for the dose

! calculations assuming that the aoult is the maxin.om exposed individual.

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.I In Section 2.4, in the definition of the quantity Dj in Equation (8) for the cumulative dose, the dose to the total body was omitted.

In Section 2.4, in the quantity Fj, the near field average dilution factor, should be defined as the ratio of the average undiluted liquid radwaste flow during the release to the product of the average flow from the discharge structure (during the reporting period, i.e. quarter or year) to the unrestricted receiving water and Z. ,

In Section 2.4, the units are missing in the definition of DFj.

Also, in the definition of U , wthe annual water consumption by the maximum adult should be 730 liters /yr.

In Table 2.4-2, the Licensee th')uld be aware that the latest NRC recommended value for the bioaccumulation factor for freshwater fish for phosphorus is 3.0E+03 (pCi/kg)/(pCi/1) instead of 1.or105 (pCi/kg)/(pC1/1), the value in Table A-1 of Regulatory Guide 1.109, Rev. 1.

In Table 2.4-1 the following adult ingestion dose commitment factors, Ajj need to be corrected:

Liver Zr-95 change 5.50E-02 to 7.69E-02 mrem /hr per pCi/ml Lung Ba-139 3.90E 04 to 1.40E 01 GI-LLI Ba-139 1.70E+00 to 4.00E+02 Also, dose factors fi 0P 7" all organs need recalculation due to the latest HRC *ecommended va"..:. tur the bioaccumulation factor for phosphorus.

In Table 2.4-3, the adult ingestion dose factor for 1 133 liver is 2.47E 06 instead of 2.47E 05 arem/pC1.

The methodology for calculating the dose due to the release of 12

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radioactivity in liquid effluents is, in general, in agreement with the

) guidelines of NUREG-0133. liowever, because of the definition of dilution flow, the projected doses could be extremely conservative, consequently the Licensee should strongly consider modifying the definition of the dilution flow.

I Dose Due to Gaseous Effluent.1 r

Section 3.5.1 contains the methodology for calculating the cumulative gamma and beta air doses due to the release of radioactive noble gases as required by Surveillance Technical Specification 4.11.2.2 In Section 3.5.1.2 the quantities (X/C)m and (x/q)m are defined without units.

-s The methods for calculacing the air dose due to the releare of radioactive noble gases are in agreement with the gcidelines of NUREG-0133 and are considered acceptable.

Section 3.5.2 contains the methodology for caiculating the cumulative dose due to the relense of I-131, I-133, tritium, and radionuclides in particulate form with half-lives greater than eight days as required by Surveillance Technical Specificatiu 4.11.2.3.

In Section 3.5.2 the units in the def(nitien of the quantity gjn should be pCi instead of Ci.

The following enrrections need to be made in the inhalation dose a' factors. (DFAj)a, in Tables 3.5-1 through 3.5-4:

Infant Bone P 32 change 1.4EE-03 to 1.45E-05 mrem per ps.

[/? Liver Zr-95 "

1.25E-03 to 1.25E-05

'k I-133 1.37E-05 to 1.87E-05 Cs-137 4.375 04 to 4.37E-05 J

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Kidney Ba-139 4.23E-13 to 4.73E-13 "

Child Thyroid Cr-51 "

2.31E-08 to 2.81E-08 " " "

Adult Lung Zn-69 "

1.15E-07 to NO DATA " " "

in Section 3.5.2.1.3, the quantity Ys in Equation (9) is not defined.

The following corrections need to be nade in the organ ingestion dose factors, (DFLj)c, in Tables 3.5-6 through 3.5-9:

Child Kidney Te-127 change 1.34E-06 to 1.34E-04 mrem per pCi Ce-144 3.97E-08 to 8.97E-08 "

1.30E-08 to 1.80E-08 "

Teen Liver Zr-95 "

Adult T. Body Y-93 7.40E-11 to 6.40E-11 " " "

i In Section 3.5.2 and Tables ".5-13 through 3.5-31, the quantity Raij is alternately referred to as a dose factor, pathway factor, and as a dose rate factor. NUREG 0133 refers to R,;j as a pathway factor and it is recomended that this convention be followed. Corrections need to be made in the inhalation pathway factors, Raij, in Tables 3.5-13 through 3.5-16:

Infant T. Body 1-134 changa 6.65E+02 to 6.65E+04 mram/hr per pCi/mi Liver Ba-141 1.08E-04 to 1.08E-14 Child T. Body Br 84 5.84E+02 to 2.19E-14 Liver Rb-89 3.45E+02 to 2.90E+02 i Teen Bone Sr-89 4.34E+05 to 4.3d".-05 GI-LLI 7 93 5.79E+06 to 5.79E+05 Lung Nb-93 7.51E+01 to 7.51E+05 Adult Kidney Tc .101 "

1.08E-03 to 1.08E-13 Kidney I-135 4.48E+04 to 4.48E+05 The reviewer was unable to reproduce a large number of the pathway factors in Tables 3.5-17 through 3.5-30. In particular the pathway factors for the nuclides: C-14, Nb-95, 2n-69, Cs 138 Ba-139 ano La-142 .

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4 for all age groups and organs were not reproducable.

The methodology for calculating tha cumulative dose due to the release of I-131,1-133, tritium, and radionuclides in particulate form with half-lives greater than eight days is, in general, in agreement with the guidelines of Regulatory Guide 1.109, Revision 1 and NUREG-0133. However, because the pathway factors in Table J.5-17 through 3.5-31 cannot be reproduced, it is uncertain if the dose calculations will result in values that can be used to compare with the dose limits of Technical Specification 3.11.2.3.

Dose Pro.iections Section 2.5 of the 00CM describes the method used to project doses due to the expected release of racloactive liquid effluents to determine when the liquid radwaste treatment sy:, tem should be opeuted as required in Surveillance Technical Specification 4.11.1.3.1. The methodology for determining the dose projection due to liquid radwaste effluents is in agreement with NUREG-0133 and is considered acceptable.

Section 3.6 of the 00CM describes the method used to project do;es due to the expected release of r:dioa:tive gases to determine when the ventilation exhaust treatment system should be operated as required in Surveillance Technl:a1 Specification ~4.11.2.5.1. The methodology for determining the dose projection due to gaseous radwaste effluents is in agreement with Nt! REG-0133 and is considered acceptable.

Total Ugn Section 4.0 of the ODCM contains tbt methodology for calculating the

total dose contributions including direct radiation as required by Technical Specifications 4.11.4.1. The methodology is in agreement with the requirements of the technical specifications and is c.onsidered

! acceptable.

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Environmental Monitorina Prooram Section 5.0 of the 00CM contains specific parameters of distance and the direction sector from the site and additional information for each and every sample identified in Environmental Monitoring Table 5.0-1 for CPS in compliance with Technical Specification 4.12.1. The environmental program ,

is in compliance with Technical Specification Table 3.12-1 and is considered acceptable.

Summary In summary, the Licensee's ODCM uses documented and approved methods that are, in general, consistent with the methodology and guidance in NUREG 0133 and Ragulatory Guide 1.109, Revision 1. However, it is recommended that the NRC request another revision to address the discrepancies.

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4. CONCLUSIONS The Licensee's ODCM updated through Revision 2 for CPS was reviewea.

It was determined that ths ODCM uses methods that are. in general, consister.t with the guidelines of NUREG 0133. Tiie methodology in most sections of the ODCii is acceptable foi* use in demonstrating compliance to the radiological effluent technical specifications. However, it is recor.inended that another revision to the ODCM be submitted to address the discrepancies identified in the review.

. In the transition between Revision 1 and Revision 2 of the ODCM, 9 the following administrative errors were detected in the copy of Res;sion 2 received by the reviewer:

. Some of the page revisions identified in the "List of Effec'ive Pages" is incorrect.

. The last portion of Section 2.4 is missing in Revision 2 beginning with the definition of the quantity Ajj.

. Deletion pages are included in Revision 2 for Table 2.6-1, however the table is still included.

. Table 3.4-1, Revision 1 was expanded from one to three pages  ;

in Revision 2, however, the page numbering following this table does not reflect t ' change.

l = Pages 2-25, 3-15 and 3-18 are missing from Revision 2 of the 00CM.

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. Section 3.7.1 of Revision 2 is missing down to and including the definition cf the quant.ity Fj.

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. Table 3.5-29, which contains the teen-vegetation pathway facton was missing and a copy of the child-vegetation pathway factors from Table 3.5-28 was inadvertently substituted in its place.

. In Section 2.3.1.1 of the 00CM, the reference to the CPS RETS should be Table 4.11.1-1 instead of Table 4.11-1.

. In Section 2.3.1.1, it is stated that the concentration of alpha emitters and tritium in the liquid radwaste will be as determined from the monthly analysis of a composite sample. However, Technical Specification Table 4.11.1-1 states that the analysis is made on a quarterly basis. If the data are only available on a quarterly basis, then the Licensee should reconsider the commitment in Section 2.3.1.1.

. Figure 2.1-1, which is a map of the unrestr.cted area boundary showing the location of the liquid affluent discharge point is illegible and should be replaced.

In Section 2.4, for the quantity F), the near field average dilution factor, should be defined as the ratio of the average undiluted liquid radwaste flow during the release, to the product of the average flow from the discharge structure (during the reporting period, i.e. quarter or year) to the unrestricted receivinc water and Z.

. A simplified flow diagram of the solid radwaste treatment system is not included in the 00CM.

. In Section 2.4, the units are "issing in the definition of DFt .

. In Section 2.4, in the definitien of U ,w the annual water f consumption by the maximum adult should be 730 liters /yr.

18

..r.

.,,,x.

.)

>4

. In Table 2.4 2, the Licensee should be aware that the latest NRC '

recommended value for the bioaccumulation factor for freshwater fish for phosphorus is 3.0E+03 (p.Ci/kg)/(pCi/1) instead of 1.0x105 (pCi/kg)/(pC1/1), the value in table A-1 of Regulatory .

Guide 1.109, Rev. 1. l

. In Table 2,4-1 the following adult ingestion dose commitment factors, Ajj need to be corrected:

t k

Liver Zr-95 change 5.50E-02 to 7.69E 02 arem/hr per #Ci/mi l Lung Ba-139 3.90E 04 to 1.40F-01 l GI-LLI Ba 139 '

1.70E+00 to 4.00E+02

\

Also, dose factors for P-32 for all organs need recalculation due to the latest NRC recommended value for the bioaccumulation factor for phosphorus.

. In Section 3.2.2, the text states that the PRM detector configuration for the SGTS Stack utilizes nine channels but only ,

j six channels are identified.

i, . In Section 3.4.2, Equation (3), which determines the organ dose  ;

rates due to radiciodines (I-131, 1-133), particulates with l

half-lives greater than 8 days and tritium should be summed only l over the index 1. Also, the symbol which indicates rate (.)

should be over the quantity Qj3 instead of (X/Q) ,. [

. In Section 3.4.2, the units in the definition of Mg should be arad/yr per pCi/m3 instead of mre#yr per #Ci/m3 .

i

. The following inhalation pathway dose rate factors Pjj need to be corrected in Table 3.4 2:

i i

1

) 19

1 e'

Cu-64 Lung chang 6 9.58E-03 to 9.58E-05 mres/yr per pCi/m3 Br-85 T. Body "

2.SSE+01 " 2.40E+01 " '"

Y-91m Bone 5.07E-01 " 507E 01 ,

4 In Section 3.5.1.2 the quantities (X/Q) ,and (x/q),are defined without units.

• The following corrections need to be made in the inhalation dose i

factors, (DFAj)a, in Tables 3.5-1 througn 3.5-4:

Infant Bore P 32 change 1.45E-03 to 1.45E 05 mrem per pCi i Liver Zr-95 "

1.25E-03 to 1.25E-05 I-133 1.37E-05 to 1.87E-05 4.37E-04 to 4.37E-05 "

Cs-137 Kidney Ba-139 "

4.23E-13 to 4.73E-13 "

Child Thyroid Cr-51 "

2.31E-08 to 2.81E-08 Adult Lung Zn-69 1.15E-07 to NO DATA

. In Section 3.5.2 the units in the definition of the quantity -

qj, should be pCi instead of C1.

. The following corrections need to be made in the organ ingestion dose factors, (DFLj)a, in Tables 3.5-6 through 3.5-g:

A 1

Child Kidney Te-127 change 1.34E-06 to 1.34E-04 mrem per pCi Co-144 3.97E-08 to 8.97E-08 Teen Liver Zr-95 1.30E-03 to 1.80E-08 Adult T. Body Y-93 7.40E-Il to 6.40E-11 i

. In Section 3.5.2 and Tab es 3.5-13 through 3.5-31, the quantity ,

, Raij is alternately referred to as a dose factor, pathway factor, and as a dose rate factor. NUREti-0133 refers to R a jj l

i as a pathway factor and it is recoscended that this convention be i

20 W'

• , d*,

4 e

', followed. Corrections need to be made in the inhalat.on pathway 8C M 9

aij, in Tables 3.5-13 through 3.5-16:

4 Infant T. Body 1-134 change 6.65E+02 to 6.65E+04 mrem /hr per pCi/mi Liver Ba-141 "

1.08E-04 to 1.08E-14 "

Child T. Body Br-84 5.84E+02 to 2.19E-14 Liver Rb-89 "

3.45E+02 to 2.90E+02 "

Teen Bone Sr-89 4.34E+05 to 4.34E-05 GI-LLI Y-93 5.79E+06 to 5.79E+05 Lung Nb-93 7.51E+01 to 7.51E+05 Adult Kidney Tc-101 "

1.08E-03 to 1.08E-13 " " "

Kidney 1-135 4.48E+04 to 4.48E+05

• The reviewer was unabic to reproduce a large number of the 4

pathway factors in Tables 3.5-17 through 3.5-30. In particular the pathway factors for the nuclides: C-14, Nb-95, Zn-69, Cs-138, Ba-139 and La-142 for all age groups and organs were not reproducable.

. In Section 3.5.2.1.3, the quantity Ys in Equation (9) is not defined. ,

In Section 3.7.2, in the definition of the quantity Lg, the units should be arem/yr per pCi instead of arad/yr per 801.

. Figure 3.1-1, the map describing the CPS site boundary for gaseous effluents is illegible and should be replaced. l I

4 21 i

. ...o 4

V

5. REFERENCES

1. Title 10, Code of Federal Reaulations, Part 50, Appendix I, "Numerical Guides f:,r Design Objectives and limiting Conditions for Operation to Meet the Criterion, 'As low As 15 Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents."

2. Letter from F. A. $pangenberg (Illinois Power Company) to W. R. Butler -

(NRC),

Subject:

Clinton Power Station, Offsite Dose calculation Manual, December 23, 1985.

3. Letter from W. R. Butler (NRC) to F. A. Spangenberg (Illinois Power Company),

Subject:

Clinton Power Station Unit 1 - Accepta ce of the ODCM, February 14, 1986.

4. Letter from F. A. Spangenberg (Illinois Power Company) to A. B. Davis (NRC),

Subject:

Clinton Power Station, Semiannual Radioactive Effluent Release Reoort, August 28, 1987.

5. "Standard Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in l reviewing RETS proposals for operating reactors, NUREG-0473, September 1982.

i l

6. "Preparation of Radiological Effluent Technical Specifications for l

Nuclear Power Plants, A Cuidance Manual for Users of Standard l

Technical Specifications," NUREG-0133, October 1978.

I

7. "General Contents of the Offsite Dose Calculation Manual," Revision 1 Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.

8. "Calculation of Annual Doses of Evaluating Compliance with 10 CFR 50, Appendix 1," Regulatory Guide 1.109, Rev. 1, October 1977.

I 22

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