ML20237B216

Proposed Tech Specs,Amending Semiannual Radioactive Effluent Release Rept Requirements to Allow Use of Historical Annual Average Meteorological Data to Determine Doses

ML20237B216
Person / Time
Site:	Farley
Issue date:	12/09/1987
From:	ALABAMA POWER CO.
To:
Shared Package
ML20237B198	List: ML20237B196 ML20237B216
References
NUDOCS 8712160099
Download: ML20237B216 (7)

Text

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ATTACHMENT 1 l l

Proposed Changes to Technical Specification Pages ,

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Unit 1 Revision )

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I Unit 2 Revision {

l Page 6-18 Replace {

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8712160099 871209 PDR ADOCK 050 g 8 P ,

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ADMINISTRATIVE CONTROLS

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6.9.1.9 The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 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,"

Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The radioactive effluent release report to be submitted 60 days after January 1 of each year shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing of wind speed, wind direction, and atmospheric stability, and precipitation (if measured) on magnetic tape, or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability. This same report shall include an assessment of the radiation dosee due to the radioactive liquid and gaseous effluents released from the unit or stat-lon during the previous calendar year. The historical annual average meteorology or the meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents (as determined by sampling frequency and measurement) shall be used for determining the gaseous pathway )

doses. The assessment of radiation doses shall be performed in accordance with )

the OFFSITE DOSE CALCULATION MANUAL (0DCM).

The radioactive effluent release report to be submitted 60 days after January 1 of each year shall also include an assessment of radiation doses to the likely most exposed member of the public from reactor releases and other nearby uranium fuel cycle sources (including doses from primary effluent pathways and direct radiation) for the previous 12 consecutive months to show conformance with 40CFR190, Environmental Radiation Protection Standards for Nuclear Power Operation.

The radioactive effluents release shall include the following information for each type of solid waste shipped offsite during the report period:

a. Container volume, a

b. Total curie quantity (specify whether determined by measurement or estimate),

c. Principal radionuclides (specify whether determined by measurement or estimate), j i

d. Type of waste (e.g. , spent resin, compacted dry waste, evaporator I bottoms),

V FARLEY-UNIT 1 6-18 AMENDMENT NO.

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ADMINISTRATIVE CONTROLS

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6.9.1.9 The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 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,"

Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The radioactive effluent release report to be submitted 60 days after January 1 of each year shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing of wind speed, wind direction, and atmospheric l stability, and precipitation (if measured) on magnetic tape, or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability. This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. The historical annual average meteorology or the meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents (as determined by sampling frequency and measurement) shall be used for determining the gaseous pathway l doses. The assessment of radiation doses shall be performed in accordance with the OFFSITE DOSE CALCULATION MANUAL (0DCM).

l The radioactive effluent release report to be submitted 60 days after January 1 l of each year shall also include an assessment of radiation doses to the likely l most exposed member of the public from reactor releases and other nearby uranium fuel cycle sources (including doses from primary effluent pathways and direct radiation) for the previous 12 consecutive months to show conformance with 40CFR190, Environmental Radiation Protection Standards for Nuclear Power Operation.

The radioactive effluents release shall include the following information for each type of solid waste shipped offsite during the report period:

l l a. Container volume,

b. Total curie quantity (specify whether determined by measurement or estimate),

c. Principal radionuclides (specify whether determined by measurement or estimate),

I l d. Type of waste (e.g. , spent resin, compcced dry waste, evaporator bottoms),

5 FAR;.EY-UNIT 2 6-18 AMENDMENT NO.

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. 4 ATTACHMENT 2 SIGNIFICANT HAZARDS CONSIDERATION EVALUATION PURSUANT TO 10CFRSO.92 FOR THE PROPOSED CHANGE TO THE TECHNICAL SPECIFICATION i ADMINISTRATIVE CONTROLS SEMIANNUAL RADI0 ACTIVE EFFLUENT REPORT l

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Proposed Change:

l Revise Technical Specification 6.9.1.9 for Farley Nuclear Plant (FNP) Unit 1 and Unit 2 to allow the use of historical annual average meteorology as an alternative to using meteorological conditions concurrent with the time of the release of radioactive gaseous effluents for determining the gaseous pathway doses submitted with the routine semiannual radioactive effluent release report. j

Background:

Technical Specification 6.9.1.8 requires that routine radioactive effluent release reports covering the operation of the units during the previous six months of operation be submitted within 60 days after January 1 and July 1 of each year. Technical Specification 6.9.1.9 requires that the radioactive effluent release report submitted 60 days after January 1 of each year include an assessment of the radiation doses due to the radioactive liquid and gaseous ef fluents released from the units during the previous calendar year. The gaseous pathway doses are to be determined using the meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents (as detennined by sampling frequency and measurement).

However, Sections 3.3, 6.2.1, and 6.3.1 of NOREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," state  !

the use of historical annual average meteorological conditions is acceptable for calculating doses due to routine gaseous effluent releases. In fact, Section 3.3 of NUREG-0133 opens with the following statement:

l "The Standard Technical Specifications consider the historic annual average atmospheric dispersion condition rather than real time dispersion conditions in determining the LCO for radioactive materials in gaseous ef fluents."

In addition, the bases for Technical Specification 3/4.11.2, " Gaseous )

Effluents," refer to historical average atmospheric conditions in calculating l doses due to gaseous ef fluents. The bases for Specification 3/4.11.2.2, i

" Dose-Noble Gases," state that the ODCH equations provided for detennining the l air doses at the site boundary are based upon the historical average atmospheric )

conditions. Also, the bases for Specification 3/4.11.2.3, " Dose-Radiciodines, Radioactive Materials in Particulate Form and Radionuclides Other Than Noble i Gases," state that the ODCM calculational methods provide for determining the '

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ATTACHMENT 2 Page 2 actual doses based upon the historical average atmospheric conditions. These statements are consistent with current Westinghouse Standard Technical Specifications. In f act, NUREG-0133 states that annual average atmospheric dispersion conditions were used as the basis for the Standard Technical Specifications. Furthermore, the existing ODCM for the Farley Nuclear Plant, which has been approved by the Commission, already contains the methodology for calculating doses due to gaseous effluents based on historical average atmospheric conditions.

The proposed change is also consistent with Section 2.3.5 of the Standard Review Plan (SRP) (NUREG-0800). Paragraph III.4 of Section 2.3.5 of the SRP states that the NRC Staff in their assessment of the consequences of routine airborne radioactive releases will use annual average relative concentration (X/Q) and relative deposition (D/Q) values.

According to NUREG-0133, determination of doses due to long-term releases should use the historical annual average relative concentration based on summarized meteorological data, as recommended in Regulatory Guide 1.111. "Long-term" releases are defined in NUREG-0133 as generally continuous and stable in release rate with some anticipated variation (i.e., less than 50%, based on a running monthly average) in release rate. "Short-term" releases are defined as intermittent in radionuclides concentrations or flow and occurring for a total of 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> or less in a calendar year but not more than 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> in any q ua rte r. Determination of doses due to short-term releases can use the annual average relative concentration (long-term) if it can be demonstrated that past short-term releases were sufficiently random in both time of day and duration (e.g., the short-term release periods were not dependent solely on atmospheric conditions or time of day) to be represented by the annual average dispersion conditions. Otherwise, the short-term relative concentration value should be calculated in accordance with guidelines provided in NUREG-0324 for short-term release. Historical radioactive effluent release data from Farley Nuclear Plant  !

does demonstrate that the routine operational short-term releases (i.e., less I than 500 hrs./yr., but no more than 150 hrs./qtr.) do meet the NUREG-0133 criteria of being random in time of day and duration. Even though the proposed change will allow the use of annual average atmospheric dispersion conditions, i Specification 6.9.1.9 will continue to require that an hourly summary of i meteorological data be included in the semiannual radioactive effluent release i report.

An additional consideration relevant to the proposed change has to do with potential input errors associated with the present use of meteorological l conditions concurrent with the time of release. Normally, meteorological data l processing and dose calculation is done by computer. However, in the event of a malfunction in the data link between the computer which processes the meteorological data and the computer which calculates the doses, data entry must be accomplished manually. This introduces a potential for error which would be eliminated if the proposed change is implemented, resulting in enhanced reliability of the calculated doses due to routine radioactive ef fluent releases.

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l ATTACHMENT 2 4 Page 3 l The proposed change also corrects a typographical error. The letter "r" was  !

omitted from the word "or" in the fif th line of the second paragraph of page {

6-18 of both the Unit 1 and Unit 2 Technical Specifications. ]

l Analysis:

I Alabama Power Company has reviewed the requirements of 10CFRSO.92 as they relate to the proposed change to 1nclude the option of using historical annual average ,

meteorological conditions to determine doses due to routine radioactive gaseous I releases and considers the proposed change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

(1) The proposed change will not increase the probability or consequences of an accident previously evaluated. The gaseous pathway doses that are reported in the routine radioactive effluent release reports are the result of routine normal operation of the plant. The methodology used to calculate these doses is not related to any accident analyses. Therefore, the proposed change, which would allow the use of historical annual average meteorological conditions in calculating l gaseous pathway doses, is administrative in nature and will not increase the probability or consequences of an accident previously evaluated.

(2) The proposed change will not increase the possibility of a new or different kind of accident from any previously evaluated because neither the plant design nor plant operation will be changed. The proposed change only affects the meteorological input used in calculating the gaseous pathway doses due to routine radioactive ef fluent releases. Therefore, the proposed change cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) The proposed change will not involve a reduction in a margin of safety because the proposed change is consistent with the guidance provided in NUREG-0133, Regulatory Guide 1.111, and the Standard Review Plan.

As stated above, the proposed change only involves a change in the meteorological input (i.e., annual average as opposed to real time) used in calculating gaseous pathway doses. An annual summary of hourly meteorological data will still be provided as required by l

Specification 6.9.1.9. Therefore, this change will not involve a j reduction in margin of safety. '

ATTACHMENT 2 Page 4 i

Conclusion:

Based upon the analysis provided herein, Alabama Power Company has determined that the proposed change to the Technical Specifications will not increase the I probability or consequences of an accident previously evaluated, create the possibility of a new or dif ferent kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety. Therefore, Alabama Power Company has determined that this proposed cnange meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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