ML20246M629
| ML20246M629 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/03/1989 |
| From: | Simpson F EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | Ruth L NRC |
| Shared Package | |
| ML20246M633 | List: |
| References | |
| CON-FIN-D-6034 SIM-30-89, NUDOCS 8903270214 | |
| Download: ML20246M629 (24) | |
Text
ENCLOSURE
/NEA unho m o nets w a m March 3, 1989 Mr. L. Ruth Technical Assistance Management Branch Mail Stop IIH22 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 LETTER REVIEW OF ODCM REVISION 10 FOR THE HOPE CREEK GENERATING STATION -
SIM-30-89 l
)
Dear Mr. Ruth:
l Attached is the final Letter Report containing EG&G Idaho's evaluation of the Offsite Dose Calculation Manual (ODCM) updated through Revision 10 for the Hope Creek Generating Station.
This Letter Raport is being transmitted under the provisions of Project 5 of FIN D6034, " Review of Radiological Issues." A draft of this Letter Report was provided earlier for NRC review and coments and found to be sicceptable.
l Yours very truly, l F. B. Simpson Nuclear Sciences ikw
Attachment:
As stated cc: W. Meinke, NRC G. L. Jones, DOE-ID l
hEmm a r.o. saa um ideho venn,so a rs t - - - - - - - _ - - - - - - - - - _ - - - - - _ _ _ _ PJ
m 1
, s, ,,
- oDen EVALUATION OF HOPE CREEK UPDATED THROUGH REVISION 10 - SIM-30-89 l 3 q Public Service Electric and Gas Co. (PSE&G), the Licensee for Hope Creek (
Generatiry Station (Hope Creek) transmitted a complete CDCM for Hope Creek, l
, updated through Revision 10, to the NRC with a letter from S. E.
Miltenberger (PSE&G) to Document Control Desk (NRC) with a letter dated January 6, 1989.: Revision 10 of the 00CM was submitted in response to a letter from G. W. Rivenbark (NRC) to S.. E. Miltenberger (PSE&G) dated June 28, 1988. This letter requested that PSE&G address the points raised in the Conclusions section of the Technical Evaluation Report (TER),
EGG-PHY-7897, which consisted of a review of the complete Hope Creek 00CM, updated through Revision 8.
Between the time of the review of Revision 8 and the submittal of Revision 10, the Licensee submitted 00CM Revision 9, dated September, 1988 with the semi-annual Radioactive Effluent Release Report for Hope Creek for the first six months of 1988. Revision 9 included changes in environmental monitoring. locations and the format for reporting environmental monitoring locations, revised maps, and changes in the data used to determine liquid effluent monotor setpoints. These changes in data effected a change from <
using ANSI Standards to using historica releasees of radionuclides in ,
liquid effluents as the basis for calculating default setpoints for liquid effluent monitors.
~
Changes made by Revision 10 concerned only the points raised in ths' Conclusions of the review TER referenced above.. An attachment to the Licensee's transmittal letter dated January 6,1989 contained discussions of all concerns raised in the TER and described the response by PSE&G. Most of the concerns were addressed in a manner consistent with the recommendations in the TER. Copies of the' Conclusions section of the TER and the Licensee's responses are, attached for convenient reference. All responses that did not address the concerns as recommended are discussed below, using the Licensee's identification of the responses.
TER Part 4 - Maior Discrepancies. Item 4: It was requested that the seasonal correction factor (SFp = 0.5) used in Equation 2.11 of the 00CM be " adjusted to agree with the fraction of the quarter when the 0.5 factor is applicable."
The Licensee did not implement this recommendation. The response stated, concerning the current use of the correction factor, "This correction factor was considered adequate in discussions with the Nuclear Regulatory Commission (NRC). This average dose was considered to be within the errors of the dose calculation methods provided in NUREG-0133 and Reg. Guide 1.109." .
The acceptability of the Licensee's response appears to depend on the previous agreement with the NRC referred to above and involves interpretation of 10 CFR 50, Appendix I, Section IV.A. This section indicates that the quarterly exposure is to be " calculated on the same basis as design objective exposure," which is reasonably interpreted to mean that i the seasonal correction factor should be re-evaluated if the calculation i period is a quarter instead of a year. As the calculation is now made, the {
doses will be too high during the November-April period and too low during the May-October period, but should be approximately correct for the year.
1 i
e .
TER Part 4 - Additional Discrepancies. Item 3: It was requested that the definition of the ters CTBD in 00CM Sections 1.4.1 and 1.4.2 be changed from ".. release period" to ".. reporting period."
Using the methodologies described in NUREG-0133 and Regulatory Guide'l.21 as the basis, the L<conses states. 'It is our interpretation the dilution flow during a. liquid release's release period is reported, not the dilution flow over the entire reporting period." The Licensee's interpretation is the usual one. The Licensee also states, "As well, the j dose calculations under this definition would be grossly underestimated and the volume of dil1 tion water reported grossly overestimated." This statement appears to be the result of a misunderstanding as-to what was recomended.
The reason for the request that the definition of the term CTBD be '
changed from ".. release period" to ".. reporting period" was to have dose calculations done in such a way that the NRC could independently check the reported calculated doses. Such an independent calculation could also be made if the Licensee reported the radionuclides concentration, waste flow, and dilution flow for each release. -
The data reported in the Licensee's semi-annual radioactive effluent release reports is, however, sufficient to enable the NRC to perfors dose calculations that would give approximately the same doses calculated by the Licensee, if dilution flows were approximately the same for all releases.
TER Part 4 - Additional Discrepancies. Item 5: In response to the- l recommendation that historic plant average radionuclides distributions be used to determine default setpoints for the gaseous effluent monitors, the Licensee stated that since the plant has been operating at full power only since December 1986 and fuel has been clean (Dose Equivalent Iodine j
[0EI) - 2E-5 pCi/cc) there is not enough historic data for it to be better than the ANSI Standard that is now used. I TER Part 4 - Additional Discrepancies. Item 7: The Licensee explained the omission of the child-vegetation pathway from Table 2-3, thereby )
satisfying the objection indicated in the review. The statement, ".. and I the child age group is controlling for the vegetation pathway." has been removed from Section 2.5.1 in Revision 10 of the Hope Creek 0DCM.
However, Section 2.5.1 should be revised to require irclusion of doses to the controlling age group by all existing pathways, and consequently the inhalation pathway for the infant age group should be added to Table 2-3.
TER Part 4 - Additional Discrepancies. Item 9: It was recommended that the words " Hope Creek" be replaced by " Salem" in the second paragraph of ]
Section 3.2. Instead, " Sales" was replaced by " Hope Creek." This leaves the total dose discussion with no mention of how the dose contribution from Salem is to be accounted for.
TER Part 4 - Additional Discrepancies. Item 13: Tha Licenses will l' contact the NRC to get a reference document before changing the phosphorus bioaccumulation factor for saltwater invertebrates, as required by agreements with the NRC.
2
3 ..,
TER part 4 - Additional Discrepancies. Item 18: 'The Licensee added I-133 to all pages and checked several dose factors in Table 2 4, as requested.
Nearly all of the factors were corrected or determined to be correct as they appear in the 00CM. The Licensee stated that those corrected in the 00CM were detemined to be correct in the computer program.actually used for the calculation of doses. The Licensee's correction and verification of values appears correct except in the case of the dose factors for Co-141 via the vegetation pathway to a child. These dose factors for Ce-141 should be re-checked, since some of the terms used in the Licensee's response are'for Ce-144 instead of Ce-141.
TER Part 4 - Additional Discrepancies. Items 19 and 20: The Licensee either explained the use of parameters questioned in these two items or discussed the complete replacement of data. Table A-1, containing MPC values and expected releases of liquid effluents, has been extensively revised since ODCM Revision 8. The estimate of radionuclides released that is included in Revision 10 is based on historical releases (1987 releases) instead of calculated values from the FSAR which were used in Revision 8.
The MPC values are directly from Appendix B of 10 CFR 20, with the default value of 3.0E-06 used for radionuclides not included in 10 CFR 20.. In-response to a question in the review TER, the Licensee states that they conservatively use the smaller of the soluble and insoluble concentration limits from Table II in Appendix B of 10 CFR 20 when calculating setpoints for the liquid effluent monitors.
Minor discrepancies seem to exist between the releases reported in the semiannual effluent release reports for 1987 and the tabulation of these releases in Table A-1, (i.e., The Table A-1 value for Sr-89 is about 2/3 of the amount reported in the semiannual reports, and Co-143 and Ce-144 are shown as releases in the table but not in the semiannual reports.) These minor discrepancies might be due to updates of analysis or use of recent effluent releases. (Note. The identification of some radionuclides reported to be in the liquid affluent by the semiannual reports and included in ODCM Table A-1 should be verified; e.g., Tc-100, Hg-203, and Ba-139.)
TER Part 4 - Additional Discrepancies. Item 21: This item noted the absence of Co-58 and Co-60 from Table B-1. These radionuclides were added to the Table B-1 in Revision 9, but the table was apparently inadvertently omitted from Revision 10.
TER Part 4 - Additional Discrepancies. Item 23: The Licensee corrected the values of Xe-135 and Xe-135m noted as being erroneous in Table C-1, but did not correct the value of N,ff for Kr-88.
TER Part 4 - Additional Discrepancies. Item 24: The Licensee added tritium to the definition of Q3 on page D-3 for the equation on page D-2, as requested. Howeve this change will cause problems by giving a calculated doseasmuchas10{4 times the dose due to I-131. Tritium releases should therefore be accounted for in a separate part of the equation on page D-2.
3
- i TER Part 4 - Additional Discrepancies. Item 26: This item questioned whether the air monitors identified in Table E-1 of 00CM Revision 10 satisfy the requirements of Technical Specification Table 3.12-1. In Revision 9, the Licensee removed two air monitor locations'and added three.
The Licensee's response to the questions raised in the" review of Revision 8 reasons that the present locations (5SI - 1.0 mi E, 501 - 3.5 mi E, and 16El - 4.1 at NNW) fulfill the requirements of Technical Specification Table 3.12-1 because of the isolation of the site. (The site is surrounded by United States Wetlands and the Delaware River.) The nearest resident is 3.4 miles east of the site, and there is an air sampler in that vicinity as well as one at the site boundary in the same direction. Another sampler is across the Delaware River at about the same distance as the nearest residences in that direction Although these sampler locations seem to be located so as to indicate possible exposures to members of the public, they may not satisfy the technical specification requirement that three samplers be located "close to the site", depending on the definition of "close." It seems that sampling locations should be added to fulfill the requirements of Technical Specification Table 3.12-1, or the table should be changed to permit the samplers to be located in the vicinities of the nearest residences instead of close to the site.
TER Part 4 - Additional Discrepancies. Item 27: This ites concerns the locations at which sampling is done to detect water-related contamination.
The Licensee either identified locations as satisfying the requirements of Technical Specification Table 3.12-1 or explained that samples were not taken because no such samples exist; i.e., there are no downstream drinking water sources or crops irrigated from the water in which liquid wastes have been discharged. It would be instructive to have this information included in the ODCM.
TER Part 4 - Successions. Item 1: This suggestion concerned changes of various symbols used in the 00CM. In Revision 10 of the 00CM, Cg is used for concentrations and Ci for curies, thereby eliminating the confusion of using Ci for both meanings as was done in Revision 8. The Licensee notes that most of the other symbols questioned were adapted directly from the Addendum to NUREG-0133, and states that these are considered satisfactory with slight changes in definitions.
Of the questions raised in the review 1ER only the problems discussed under
' Major Discrepancies, Item 4" and " Additional Discrepancies, Item 26" above may require significant additional changes. The first of these concerns the of 0.5 in the grass-cow-milk dose use of aequations pathway seasonal correction for quarterly factor (SFln)d the second concerns doses, locat air monitoring stations. Some other items above recommend changes that should be made, but would not require significant effort to accomplish.
This review was perfonned by T. E. Young.
4 1
s
0
- 4. CONCLU1!0N$
The Licensee's 00CM Including all revisions through Revision 8. for the Hope Creek Generating Station was reviewed. It was determined that the 00CM eses methods that are, in general, consistent with the guidelines of NUREG 0133. However it is recomended that another revision to the 00CM be subaltted to address and correct the numerous discrepancies identified in the review.
The following are considered to be major discrepancies:
o In Section 1.4.2 and Appendia B, salt water bloaccum01stion factors must be used instead of fresh water factors in the calculation of the total body default ters.
o In Sections 1.5 and 2.6 it is not stated that the dose projections will take into account effluent releases expected in the next 31 days. ,
o I 133 is missing throughout Table 2 4 and it not mentioned in Section 2.5.1.
e In Equation 2.11 in Section 2.5.1 use of the SF, correction factor of 0.5 for milk and vegetation is ' correct only for the annual dose calculation. The value of 0.5 is not correct for a quarterly dose calculation. The SF, factor for the quarterly dose calculations must be adjusted to agree with that fraction of the quarter that these exposure pathways are applicable.
The following are additional discrepancies:
o in Section 1.2.10 CFR 30 should be changed to 10 CFR 20.
e In Section 1.2.1, the background ters must be in the sh units as the setpoint, i.e., pCl/el, instead of cpm. .
14
e In Sections 1.4.1 and 1.4.t. the definttfon of tern CT80 aust I have " release period' replaced with *caleviation period
- to state the flowrate is averaged over the entire calculation 41 period.
o In Section 2.2.1. the units of *$P' and 'bkg* should be pC1/s.
o In Section 2.2.26 the radionuclides distribution should be based on historic plant aver. ages instead of data from the AN$!. ,
Standard.
o In Section 2.4.2. the definition of M,gg, the value should be 8.1E3 (as calculated in Appendix C) instead of 8.lE2.
o In Section 2.5.1 the last paragraph identifies the ChtId Vegetation pathway as the limiting pathway for the child-which is inconsistent with the information in Table 2 3.
)
o In Section 2.5.2 the RI 131 value is 1.67E12 whereas Table 2 4 lists the value as 1.05E12.
e In Section 3.2. the wording of the second paragraph is l
{
confesing. It appears that words ' Hope Creek' should be *eplaced with ' Salem *.
- )
I e In Table 11 there are several values that are different from those presented in Rev. 6. It can not be detersined which values l are the correct values.
o In Table 12 there are a few values that have been changed free these listed in Rev. 6. The value for V.91a for bone has been changed to 5.72E+2 from 5.72E 2 and C 14 for the $1.Lt! has been
-changed to 2.90E+5 from 2.90E+3. It is not clear which value is correct.
15 l
Je la Table 13, the value for I for saltwater lavertebrates shes1d be 2.5E+01 instead of 2.5E+02.
o In Table 13. the phosphorus bioaccumulation factor of 3.0E+04 for saltwater invertebrates could be replaced with 6.0E+02.
o Figures 21 and 2 2 reference Figures 4.12 and 4.13. Should these references be to Figure 12 and Figure 21 respectively o A staplified diagram illustrating the solid waste treatment system is not included,in the 00CM..
o In Table 21, the units of Mi and Ni should be erad/yr per
3 pC1/m . Also the Mi value for Xe-133 should be 3.53E+02 i instead of 3.35E+02.
o Table 2 2 references Table 3.1 1. This reference should be I changed to be Table 2.1 1. The units of Ci should be 3
pCf/cm and the units of Mi should be srad/yr per pC1/a3 . .
o Table 2 4 aust have 1133 included in all pages of the table to i be consistent with Technical Specification 3.ll.t.3. Within Table 2 4 there are several values that need to be checked for correctness. The nuclides and organs are identified in the following Inst:
Teen Inhalation: Ag 110e Inng. Te Ille lung Child Inhalation: Ab M liver Infant Inhalation: Fe lg Inng Adult Cow Milk: Ab 86 all organs. Ir g5 all organs. Nb g5 all organs.
Teen Cow Milk: 1131 a11 organs la 140 liver Co 141 all organs '
l Child Cow Milk: Y gl all organs "
Child Vegetation: Co 141 all organs.
16
e In Table A 1. the MPC values for P 32 and Cr 51 should be it 5
. and it 3. respectively. In Table A 1 under the expected activity released column, the values for Rh 106 through Sa 139 are incorrect.
e In Table A 4 the Na 24 MPC value should be !! 4. In.additten the expected activities released for Sr 92 and Nb 95 are much larger than those used in Rev. 6. Are those values listed in Rev. 8 the correct values? .
e Table B 1 does not include values for Co 60 and Co 58 which are ,
required according to the text of Appendia B.
I e On page C 3, the table referenced should be Table C 1 instead of B 1. Also en pages C 3 and C 4 the torn 0, should be Og .
o Table C-1 has incorrect Me rg and Neff values for Xe 135 Xe 135m and Kr 88.
o On page 0 3 the definition of Qi aust include M 3.
o Table t 1 of the 00CN does not include 43 direct radiatten stations as required in the Technical Specifications as locations 10F2 and 10G1 are listed twice.
e Table 2.3 of the 00CM states the highest X/Q and C/Q are 0.5 miles N and 4.9 alles W. respectively. These locations are not included in the airborne sampling program listed in Table t 1.
e Table t 1 does not include any drinking water locations nor food product sample stations for crops grown with water affected by the 11guld effluents which are required by Table 3.12.11 of the Technical Specifications. If these pathways de not exist. then the Technical Specifications should be modified. -
i e
Figures E 1 and E 2 are 111gible.
1 The following are not discrepancies in the 00CN but are' suggestions-that should be brought to the attention of the Licensee:
o It is recomended that use of Cl be Ilmited to the accepted use as the unit for curie and that another symbol be used for l concentrations throughout the document. Also the use of the l
terns e and C should be reviewed to determine if better terms j could be used to avoid confusion, e.g., see Equation 1.1.
o la Section 1.2.1 the definition for Ci should state that it is i the diluted concentration. .
o on pages C 2 and C 3 the meaning of 'ds' is not clear in the definition of the terms ft and Mt.
o A low level alarm setpoint should be considered for the 11guld effluent monitor.
o for consistency with the requirements of Technical Specification 4.11.2.5.1. it should be stated in the 00CM that the dose projection for anticipated gaseous releases is only required when the ventilation exhaust treatment systes is not being utilized.
l l
l e
14 l
l
9 4
ATTACEMBUT 1 TER PART d - MM ot DISCRIPANCIBS ITEILA. ,.
- It was stated that in'section 1.4.2 and Appendix 3, salt water bioaccumulation factors must be used instead of fresh water factors in the calculation of the total body default term.
Revision 9 (7/29/87) reanalysed Section 1.4.2 and Appendix 3 et the 00cn and the saltwater bioaccumulation factors were used in the calculation of the total body default term.
IIDLI.
It was noted that Hope Creek ODCN Sections 1.5 and 2.6 did not state dose projections will take into account effluent releases expected in the next 31 days.
The requirement of the 31 day dose projection is described in NUREG-0133, page 19, second paragraphp 8.. the licenses must project the cumulative liquid effluent releases over the ensuing 31 days." It is our interpretation that.we need to predict what the dose due to liquid and gaseous effluents will be over the - >
next 31 days. However, NUREG-0133 does not provide an equation as to how this prediction should be performed.
Hope Creek CDCM Equations 1.9,1.10, 2.17, 2.18 and 2.19 were developed as our best means to predict the next 31 day dose.
These equations take the total dose to date in a calender guarter and divide by the number of days to date in the current calender quarter. The result is an average dose per day for liquid and gaseous releases. This average dose per day number is multiplied times 31 days. This number is our prediction of what the total dose at the end of the next 31 days will be.
IIIILA.
It was noted the 1-133 dose conversion factors were missing throughout Table 2-4 and is not mentioned in Section 2.5.1.
Revision 10 of the Nope Creek 000( now includes I-1'32 in Sections 2.3.3 and 2.5.1. and Table 1-4 all pathways.
The dose conversion factors listed in the ODat are esed in the Effisent Management software (ENS) computer program at Rope creek. The EMS program is used for effluent release permits and generating the semi-annual report. A check was made to see if the 1-133 dose conversion factors were inadvertently omitted from the ems code. The I-133 dose conversion factors were in the progras, so, while the CDCM did not list the dose conversion factor the factors were available and being used in the EMS program. ,
1 bope creek
- - - _ . . - - - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ s
'O bh
'# It was requested that the '8rp' seasonal correction factor (0.8) used in Equation 311 of the ODQt be .' adjusted to agree with that fractnen of a quarter When the 0.5 factor is applicable.'~ q The purpose of the 8FP f actor is to adjust for that half of the .
yearzvhen allch animals are provided feed from stored vegetation.
During this half of a year (November thru April) the milch animals do not grase. So as not to grossly overestimate the dose from the possible release of radioiodines and particulate during this non-grazing time period, the average dose is calculated.
The srp factor provides the means for an average dose for the grass-cow-milk and vegetation pathways throughout the year.
i
'This correction factor was considered adequate in discussions with the Nuclear Regulatory commission. This average dose was -
considered to be within the errors of the dose calculation methods provided in NUREG-0133 and Reg. Guide 1.109.
We feel the srp correction factor is adequate and that no adjustment is necessary to Equations 3.11 knd 3.12 of the Rope creek 00CM.
TER PART 4 = ADDITIONAI, DISCREPANCIES 1 TEM 1 It was noted in Section 1.3,10 CFR 30 should be changed to 10 CFR 30.
l This correction had been mag + in Revision 9 of the Hope Creek 000t.
IIZIL2 It was noted in section 1.3.1 the background term must be in the same units as the setpoint (uci/a1 instead of spa).
In Revision 10 of the ODCN the "bkg* term has been corrected to uC1/al.
ZZEL2 The definition of the term CTBD in f 90ths 1.4.1 and 1.4.3 was requested to be changed froa "..relec p jeriod" to a.. calculation periode to state the flowrate is averaged over the entire calculational period. ,
NUREG-0133 describes the equivalent (dilution
- flow) 3 bope creek as
a, e .
r m s t - t'd1 es 'the near field average dilution factor during any 11guld effluent release.' RegAverage. Guide 1 31 re rting regulrements define the ters as the stream f ow during periods of release..o (notes we consider our stream flaw as the cooling tower not the Delaware River). The determination of the average dilution flow is calculated over the time of the release or release period. So, the tens calculation period and release period has the same meaning.
0133 Reg. Oulde 1 31 Based the use on ourterm of the interpretation of NuReg
" release period
- is ap,propriate as currently written.
ITEM 4.
It was noted the units of " spa and 'bkg* in section 3.2.1 should be uCi/s. ,
The correct terms for the calculation of the gasecus alarm setpoint is uci/cc. This is based on the unit analysis of the terms in squation 2.3 (section 2.2.1). The units for " spa are correct. The units for 'bkg" were incorrect and have been -
corrected from cpa to uCi/cc in Revision 10 of the 00cN.
132H 1 It was noted in section 2.2.2 the radionuclides distribution used for default dose calculations should be based on historic plant averages instead of data from an ANSI standard.
It is agreed that the radionuclides distribution should be based on plant operating history. Novaver, Rope Creek station has been operating at full power since December of 1986. Thus it is a new plant with ne history.
To date the operation of Hope creek has haan excellent. The current Dose Equivalent Iodine (Dt!) levels in reactor water has averaging 25-5 uci/al. This means fuel integrity is excellent with very small amounts of fission products being produced and thus released. So, to date there is still no historie radionuclides distribution to fall back because no identifiable noble gases have been detected.
ITEM d. [
It was noted in section 2.4.2 the value of N should be 3.153 (as determined in Appendix C) instead of 8.1 Revision 10 of the Hope Creek CDCM has ade this correction.
3 hope creet
o O
unL2 -
It was questioned as to why Table 3-3 does not identify the ch!!d-vegetation pathway as discussed in sectica 2.51, last paragraph. -
The last paragraph of section 3.5.1 statess *For evaluating the mariaua exposed individual, the infant age group is controlling for the milk pathway and the child age group is controlling for the vegetation pathway. -Only the controlling age group and pathway as identified in Table 3-3 need be evaluated for compliance with Technical Specification 3.11.3.3.*
In Table 3-3 the pathways listed for radiolodines and-particulate are the infant-milk and ground pathway for an
. unrestricted area -(residence / dairy) and the child-inhalation pathway at the site boundary.
These locations and pathways are taken from the Environmental ~
8tatement for Hope Creek Generating station, Feb. 1974, Table 5.5 -
(frqp U,s. Atomic Energy Commission). This report considered the maximum exposed individual for the unrestricted area to be the infant-milk Pathway from a cow gramine location 4.8 alles NNE of the vent, since there are no vegetation nor cow-milk pathways near the 31YE 300NDARY, the maximum exposed individual at the gggg goggoARY would be the child-inhalation pathway.
In summary, the child-vegetation pathway is not included in Table 2-3 because it is not the limiting dose pathway for Nope. ]
Creek's site boundary or unrestricted area. The limiting pathways J are the child-inhalation at the site boundary and infant-allk for the unrestricted area. There are no vegetatnen nor allk pathways at the site boundary. The statements *.. and the child age group is controlling for the vegetation pathway." has been removed from section 3.5.1 in Revision 10 of the Rope creek ODCN.
IIDLA.
It was noted in section 3.5.3 the 5t!-131 value is 1.67E13 whereas Table 3-4 lists the value as 1.05E13.
Revision to of the Nope Creek ODCN corrected the value la Section 3.5.3 to 1.05E13.
IIM.A.
It was noted in section 3.3 of the Rope creek 00CN the words
" Hope Creek' should substitute the word " Sales".
Revision 10 of the Hope Creek ODCN makes thir, correction.
4 bope creek
. < \
It was noted that in Rope Creek ODet Revision 8 Table 1-1 there are several values that are different from those presented la Revision 6. It was also stated that there was me determination of which values are correct.,
Table 1-1 of the ODCM provides a listing of default alarm setpoints for the liquid radwaste monitors. These default alarm setpoints are based on historical radionuclides release information. At the time of Revision 6 of the ODcN there was no historical information available because Eope Creek was not operational. By Revision 8 there was historical information and data changed information in Table 1-1. It was also noted that in Revision s there were typo errors on correct monitor reference numbers which were corrected by Revision s.
1 TEM 11 It was noted in Table 1-2 that a few values had been changed from those listed in Revision 6. The values of T-91m for bone and C-14 i'or the Gi-LLI were specifically sentioned.
The above sentioned numbers were incorrect in Revision 4 and were corrected in Revision s of the Hope Creek 00 cst.
ITEM 12 It was noted in Table 1-3 of the CDCM the value for I should be 2.5E+01 instead of 2.5E+02.
Table 1-3 of the ODCM lists the bioaccumulation factors used in dose calculations. In Revision 9 of the Eope Creek ODCSI lists the bleaccumulation factors The for iodine next as 1.0E+01 isotope listed for is fish and Cs 5.0E+01 for invertebrates.
(cesium) with bioaccumulation factors of 4.0E+01 for fish and
. 2.st+01 for invertebrates. All et these numbers are from .
Regulatory Guide 1.109 Table A-1 and were reviewed and determined to be correct. No change is required to the 50pe Creek 00C3t.
12EIL11 It was noted in ODC3t Table 1-3 the phosphorous bioaccumulation factor of 3.0E+04 for salt water invertebrates could be replaced with 6.0E+02.
It is our understanding that verbal communications between RG60 and the NRC justified the change in the bioaccumulation factor.
However, based on agreements with the NRC and PSE&G ve would need a reference document to justify the change. In the near future we vill be in contact with the NRC to get the needed references.
Meanwhile no change has bsen made in Revision.1# of the CDCM.
5 bepe creek
(
12E.31' There was some confusion caused by references la Figures 3-1 and 3 3. These figures referenced Figures 413 and 4 4-3.
since there does not exist any Figures 4.13 and 4.1-3 these references have been removed in Revision 10 of the 000t.
ITEN 15.
It was noted a simplified diagram of the solid waste treatment system was not provided.
In Revision to of the Hope Creek ODC3t a simplified diagram of the solid waste treatment system is provided as Figure 1-3.
4 rga 1s.
- -should It wasbenoted arad/yrin per Table 3-1 o( the CDCN the units of Nand the value uci/m
- 3. 51E+ 03 not 3. 3 5E+ 03.*
The units of Table 3-1 for Ni were corrected from arad per uC1/m3 to arad/yr per uci/m3 The units for Ng did not need to be corrected as they were arad/yr per uC1/m3 in Revision 9 of the CDCK.
The value for Xe-133 was corrected from 3.35E+03 and 3.53E+03 in Revision 10 of the CDCN.
ITEM 17. - .
2t was noted Table 2-3 references of Table 3.1-1 should be to changed to Table 3-1. It was also notp the units of Ng and Ci should be changed to arad/yr per uci/a and eC1/cm3 respectively.
The references and the unit corrections have been corrected in Revision 10 of the Mope Creek ODcN. i ITEM 18.
It was noted that Table 3-4 needed 1-133 included in all pages to be consistent with Technical Specification 3.11.3.3.
As noted la !?EN 3 above, these additions hav3 been made in Revision 10 of the Hope Creek ODC38.
It also was noted that some dose conversion factors within Table 2-4 of the Hope Creek CDCN needed to be checked for correctness.
The noted values were recalculated using NuReg-0133 and Reg Guide 1.10s and compiled below. There were some discrepancies 4
hope creek
tent it feant 41 -
between the ODCst and the correct values. The latest revision of the ODC38 reflects the corrections to these discrepensies.
The results of the comparison is belows tauntien i for inhalation mathway dose eenversten facters
' y = E(BR) DFA = 156
- ER
- DFA (rof. Numeg-0133 p. 25) ,
where:
P = dose rate conversion factor E = unit conversion = 134 pC1/uC1 ER = breathing rate of group from R.S.1.109 Table 3-5 -
DFA e dose factor from Reg. Guide 1.109 Table E-7 to E-10 PATEW&rt Inhalation l
path -
1331993 ,33 BFA 9 g
- Teen-lung Ag-110m 8000 8.44E-04 6.75E6 6.75E6 Teenblung Te-135a 8000 6.70E-05 5.36ES 5.3635 Child-liver Rb-86 3700 5.36E-05 1.9855 1.9855 -
Infant-lung Fe-59 1400 7.255-04 1.0156 1.0386 Sased on our calculations the numbers in the ODet are correct and do not need to be changed.
tauntion 2 for eew-milk ifood) dose eenversion factorar 0 (U) y . E r --------- F DFL (e( 1" tf)] (ref. NuReg-0133, p. 26)
- ( i+ v) where:
y e dose rate conversion factor K = unit conversion = 156 pCi/uci 0 = cow's consumption rate from R.S.1.109 Table I-3 =50 g = food consumption rate from R.S.1 109 Table 3-5 Y = agricultural productivity from R.S.1.109 Table E-15
= e.1 for grass-cow-milk-man pathway -
F = stable element coefficients from R.S.1.109 Table E=1 r = fraction of deposited activity retained on crops 1 for iodines 0.2 for others from R.S.1.10D Table E-15 DFL = maximum organ in,gestion dose factor from Table E-11 to E-14 g . decay constant for radionuclides of concern (sec*1) d
. decay constant for removal of activity from leak an plant surfaces by weathering = 5.73E-7 see*1 ,,
t = transport time from pasture to cow, milk, person from Table E-15 = 173E5 secs .
7 bope creek
Q tems la teenhedi ,
with all the constants multiplied the above equation for i isotopes other than radio-ledines reduces tot l 1.4337 e (U) e F
- DFL e e*I A*I
, , ............-.-..................'73E8) ..... (Eguation 3)
( g + 5.73E-7) J
\
The above equations were then utilised to calculate the dose factors for the isotopes, pathways and organg listed la the NRC reviews PATEWAY2 Crass-Cow-allk eraan Isotone 1,,,, F ,,g. nFL 9 ODCK_i Adult-Liver Rb-86 4.30E-? 3.0E-2 310 2.115-5 2.59E9 1.35E5 Adult-T.Sody Rb-86 4.30E-7 3.0E-2 310 9.83E-6 1.2129 5.90E4 Adult-GI-LLI Rb-86 4.30E-7 3.0E-2 310 4.16E-6 5.1128 1.66E4.
The conversion factors in the ODCM have been corrected in :
this revision.
Adult-Bone 3r-95 1,22E-7 5.0E-6 310 3.04E-8 9.46E2 1.07E5-Adult-Liver 3r-95 1.22E-7 5.0E-6 310 9.75E-9 3.03E2 3.44E4 Adult-T.SodY 8r-95 1.22E-7 5.0E-6 310 6.60E-9 2.05E2 2.33E4 Adult-Eidney tr-95 1.22E-7 5.0E-6 310 1.53E-8 4.76E2 5.24E4
) Adult-CI-LLI Er-95 1.22E-7 5.0E-6 310 3.095-5 9.6285 1.50E5 The conversion factors in the ODCN have been corrected in this revision.
Adult-Bone Nb-95 2.29E-7 2.55-6 310 6.22E-9 8.25E4 1.41E4 l Adult-Liver Nb-95 2.295-7 2.5E-6 310 3.46E-9 4.5984 7.82E3 Adult-T.pody Nb-95 2.29E-7 2.5E-6 310 1.863-9 2.47E4. 4.21E3 Adult-Kidney Nb-95 2.29E-7 2.5E-6 310 3.428-9 4.5454 7.74E3 Adult-GI-LLI Eb-9 2.295-7 2.55-6 310 2.105-3 2.7958 1.0485 ;
The conversion factors in the ODCN have been corrected in this revision. !
, , PATEWAT Grass-Cow-milk (cont'd) crean 13etant i F .R. DFL 9 90 2 !
Teen-Sone Co-141 2.47E-7 1.0E-4 400 1.33E-8 8.87E3 1.99E4 Teen-Liver
- Co-141 2.47E-7 1.0E-4 400 8.888-9 5.92E3 1.35E4 '
Teen-T. Body Ce-141 2.47E-7 1.0E-4 400 1.02E-9 6.8182 1.53E3 Teen-Eldney Ce-141 2.47E-7 1.0E-4 400 4.18E-9 2.79E3 6.26E3 Teen-GI-LLI Ce-141 2.47E-7 1.0E-4 400
- 2.54E-5 1.69E7 1.20E5 8
hope creek wrr rir i - imi . - . . . . . . . . . . . . . . . . . . . . . . . - _ . . . . . . . . . . . . . . . .
.. ,o.
.o l
Ittst 18'faant'Al The conversion factors in the ODc38 have been oorrected la this revision.
Teen-Liver Sa-140 8.27E-7 4.0E-4 400 3.48E-0 5.9554 5.95E4 Based on our calculations the numbers in the 000t are correct )
and do not need to be changed.
For radiip-iodines the factor 1.43E7 in Equation 3 above becomes 7.1457 because the factor r = 1. j PATMWAY: Grass-cow-milk Isotope i F 1 DFL p g oraan -
Teen-Sone I-131 9.97E-7 6.0E-3 400 5.85E-6 5.3858 5'.38E8 Teen-Liver 2-131 9.97E-7 6.0E-3 400 8.19E-6 7.53E8 7.53E8 Teen-T.Sody I-131 9.97E-7 6.0E-3 400 4.40E-6 4.04E8 4.04E8 Teen-Thyroid 2-131 9.97E-7 6.0E-3 400 2.393-3 2.20E11 2.20E11 Teen-Eldney I-131 9.97E-7 6.0E-3 400 1.41E-5 1.30E9 1.30E9 Teen-GI-LLI I-131 9.97E-7 6.0E-3 400 1.43E-6 1.4958 1.49E8 j i
Based on our calculations the numbers in the 000t are correct {'
and do not need to be changed.
child-Sone Y-91 1.36E-7 1.0E-5 330 6.02E-7 3.91E4 9.14E5 child-T.Sody Y-91 1.36E-7 1.0E-5 330 1.61E-8 1.04E3 -2.44E4 child-G1-LLI Y-91 1.36E-7 1.0E-5 330 8.025-5 5.21E6 1.84E5 I
The conversion factors in the 00cM have been corrected in this' revision.
PATEWAY Vegetation oraan _
132199E _ .I E 1 DFL 9 m child-Sono co-141 2.47E-7 1.0E-4 530 2.08E-6 1.37E8 1 27E8-child-Liver ca-141 2.47E-7 1.0E-4 520 6.52E-7 3.98E7 3.98E7 child-T.Sody co-141 2.47E=7 1.0E-4 520 1.11E-7 6.78E6 6.78E6 ,
child-Eldney co-141 2.47E=7 1.0E-4 520 3.618-7 2.21E7 2 21E7 child-01-LLI co-141 2.47E-7 1.0E-4 Sto 1.74E-4 1.04E10 1 04E10 Based on our calculations the numbers in the 0008 are correct and do not need to be changed.
The dose conversion factors listed in the ODCN are used in the Effluent Management System (EMS) computer program at Hope creek. The EMS Program is used for of fluent release permits and 9
bope creek
, *- j term is feant'en generating the semi-annual report. A comparison was also done i betvesa the correct values calculated below and the INS values.
No discrepancies were found. In other words, the r program used to determine dose per the ODCN has had correct dose conversion factors while the Rope Creek ODCSI did ,
not.
None of the isotopes with incorrect dose conversion factors above had been released from Rope Creek.
ITEN 19.
It was noted in Table A-1 the MPC values for P-32 and Cr-51 should be 2E-5 and 2E-3 respectively and that the values for Rh-los and Ba-139 are incorrect.
In Revision 9 of the Mope Creek ODCSI (5/17/88) Table A-1 was .,
extensively revised. Revision 8 of the CDC3( contained expected relgase data from the Hope Creek FSAR. Revision 9 used actual release data from 1987. In Revision 9 P-32 and Rh-106 was not included in Table A-1 as these isotopes were not released in 1987. ne data for Cr-51 and Ba-139 has been checked and considered cL rect.
ITpt 20.
It was noted in Table A-4 (typo, should be A-1) the Na-24 NPC value should be 2E-4. As well it was questioned as 'to whether the values for Sr-92 and Nb-95 were correct.
In order to ensure that no release limits are exceeded the most conservative 10 CFR 20, Appendix 3 Te.ble II, Col. 2 MPC value for an isotope is used. While it is agreed that Na-24 would be mostly in a soluble state the MPC for insoluble Na-24 is more conservative (2E-4 vs. 2E-5) .
In Revision 9 of the Rope Creek ODCM (5/17/88) Table A-1 was extensively revised. Revision 8 of the 000t contained expected release data from the Rope Creek FSAR. Revision 9 used actual release data from 1987. The data for Sr-92 and Nb-95 in this revision is considered to be correct.
12E 21*
It was noted that Table 3-1 does not include values for co-se and Co-58 which are required in Appendix 3.
In Revision 9 of the Hope Creek ODCM (5/17/88) Table 3-1 was extensively revised. Revision 8 of the ODCN contained expected release data from the Hope Creek FSAR. Revision 9 used actual 10 hope creek l
l
A-- , - - - _- _ _ _ _ _ _
1
,,o. 1 ITEtt 11 feant8d1 release data from 1987. Data for Co-58 and Co-60 are included in this revision. , l ITEN 22 It was noted on pa e C-3 the table reference should be Table C-1 f instead of 3-1. A so, on pages C-3 and C-4 the term Dx should be D. g The table reference and the tern Dg was corrected to Table C-1 and D, respectively in Revision 10 of the 50pe Creek ODCN.
ITE3f 22 It was noted in Table C-1 that the values for Xe-135 and Xe-135m '
were incorrect.
The values for Xe-135 and Xe-135m have been corrected in Revision l 10 o,f the CDcN.
IIIIL21 It was noted on page D-3 the definition of Og sust include B-3.
In Revision 10 of the Nope Creek CDCN the definition of Og includes the words tritium.
ITEN 25.
It was noted stations Table E-1 as required did Technical in the not includespecifications 43 direct radiation as locations lors and lost are listed twies.
Nope Creek and sales Stations Unit 1 at:d 8 share the s'ame site of operations. Due to this the Radiological Environnantal Monitoring Program is applicable to both sales and Nope Creek station.
sales Technical specification Table 3.12.1-1 requires 'about 40" TLD stations. Hope Creek Technical specification Table 3.12.1-1 requires "For ty-three' stations. Currently the ODCN lists 41 stations in' Appendix E. There are an additional two TLDs referred to as " site sero" and ' site cal
- that were not listed in Table 3-1. These T18s are used to calculate the in-transit dose j of the TLDs and act as controls.
In Revision 10 of the Hope Creek ODCN these two TLDs are noted in Table E-1 of Appendix 2.
11 bepe creek
.--...--r-.---
- ,, e.
~ ,
3 IEEli.
It was noted Table 2-3 of the ODCN states the highest I/O and R/G are 0.5 sites N and 4.9 miles N respectively and that these locations are not included in the airborne sampling program listed on Table E-1.
Technical specificat R n Table 3.12.1-1, Exposure Pathway 3 requires 5 sampling locationes 3 samples from close to the SITE 30UNDART in ditforent sectors of a blgh calculated annual average D/0, one in the vicinity of a community having a high calculated annual average D/0 and one control station.
Artificial Island (Hope Creeks site) is a man-made peninula on the east bank of the Delaware River. The Island'is characterized mainly by the Delaware River and Say, extensive United States
- tidal marshlands and low-1 ng meadowlands. These lands make up approximately 85% of the 1 area within five miles of the site.,
The 3 sectors close (0.5 miles from vent) to the site boundary .
with, the highest D/Q are NW, WNW, and St. All of these directions would require sample locations in the Delaware River.
The next 3 highest D/0 sectors are W, N, and SSE. The N position is the only direction which could have a sample location not in the Delaware River. However, this would require locating a sample station with an access road and power lines in the protected marshlandt.
Due to the location of Hope Creek Station it is difficult to place air sample stations far enough away (not on site) to obtain a representative sample and still be close to the SITE 80UNDARY.
Currently the three air sample stations considered close to the SITE SOUNDARY are 581 (1.0 31. E of vent), 501 (3.5 mi E of vent) and 1681 (4.1' 31. NNW of vent). S e nearest community with the largest D/0 is 7.0 miles NE of the site. This community has an air sample location (3F1).
gince we are in compliance with Technical Specifloations we feel no revisions to.the Mope Creek 0D08 are required.
IIIlL11' It was poted Table E-1 does not include any drinking water locations nor. food product sample stations for crops grewn with water affected by the liquid effluents. It was also noted that if these pathways did not exist then the Technical Specifications should be nodifi,ed.
The nearest public water supply is more than 30 miles upstreas of the site. We believe the intent of the Technical Specification was to sample drinking water supplies that could be Airectly effected by a nuclear generating station's liquid effluents.
la hope creak
r .. 4
+ .
tTea at teent'di .
The Delaware River, at our discharge point, is brackish water.
There are no direct e op dri supply in and around- $4 of )nking v.pter 1 alen Urrite supplies.
and 3 isThe wellwater water. In the radioi environmental monitoring program there are a well we r 1.0 cations - 501, 3.5 miles B et vent, and 3E1, 4.1 18 . p 'of went. Thus, the well water sample locations fu 'f1T1 the requirements of Technical I specification, Table 3.13-1. I
)
Due to the brackish, wahr,.there.ijs no irrigation downstream of Sales station. TheYe arePhe ' crop samples available which use the Delaware River for irrigation.
]
a c : a m i, :. .- .
ITEN 24 . m. (, . ,
It was noted Figures E-1 and E-2 are illegible.
In Revision 9 of the JPPe. peak CDCM F(gures E-1 and E-2 were -
updated to be more legiby,and are included in Revision 10.
T 7){T. 4, = SUGGESTIONS n SR, ,
ITEN 1.
.., ;ua .. i ,,:
a c / > r p.., i It was recommended that the use of the tern C be limited to the accepted use as Ahp tnit for curies and 3.another symbol be used for cohtbrYtaitons throughout document.
It was also recommended the use of the terms e and C should be reviewed to determine if better terms could be used to avoid confusion in some equations.
We agree that the to 15.'$dge in all ebathns section 1 of the ODCN), 'c' and ~ ' then,1.1) should bethanged to eliminate any con .' JCWell, the terms 828 and 'F' (Equation 11) should also be changed. Novaver, the terms
'c','C','f' and 'F' vers an adapted directly ffps the first equation in the addg'gfpg-0133. 1 To reduce some of the confusion in the terms used in the equation free puReg-0133 we redefined the terms c,f and F in the Sales ODCN. No 84 tver. the tern Ci was adequate enough for defining. r To DCN wo,of uC1/a1 (coEcontration).
change this ters in uld also require revisions to 1tilise .th, same terms. It is our many procedures opinionthatthere;}{ which,Jh55.fef, change tNe ters Cg.
re c os e e- - :,-
.a e d e' . :
i cc 1t. t u l ..
T r e r ,. , .- .
13 bope creek
- 4
. , .y . }
o ITEL2. .
It was suggested that the te m C de the definition of undiluted concentration instest Mohcoistratloa.
- ence .tgur t We'havs included this suggestLon in ision's so that the definition Cg states 'the co8% Wradionnc15de 1 in the undiluted liquid ef fluent .i*y* ea '
k 12ItL2 It was noted the meaning of'8 sM%fl8WDt d %fea'r on@g'eh c-2 and C-3.
The ters 'ds' was a typograpRicdFdf)brC41368 has $ ten xenoved in stem is prov /
Revision 10 of the oDcN.
JTEM 4. .
q It was recommended that a loy'I5ent*Een1%dth. '%eV$aFsPsetpointin'. i t c,r j congidered for the liquid s'fI All the 11guld offluent monitorp, for Bo crec.k atively'seY station have a at 50%
a warning' alarm setpoint whi,tE Ett aVffE I of the alors setpoint. Where' hts _M l H s t a renptr'edne {
feature for effluent monitorgaMo'h5t9:1s3;no doces' ente 8 '
guidelines for a ' low level alars' setpoint. the 810w level alarma or warning setpothts are not included in the None correctecs 1 - r,b o; creek oDCM.
IIElli.
It was' recommended the CDCM shok14 state that the dose pr jection for anticipated gaseous relbaits it* e StegdiredWn th venti-3 lation cal exhaust treatment sydayafb4.11.3.5.1 '/r per;. ucu("ut111 specification
' ." sed'p# Tech The dose projection per the OlX3t is rio ed Rf for each and every fluent 'Hanbgesent gaseous release. This is doMt #
systes computer pr ran used-tteWrdD@ineous affluents provides oction calculation automatically. As well, the 31-day dose y to ensure that To ical specifications are complied, with the dose calculation is performed re s if the exhaust treatment is in service or not. Whileitt&1 e say be ovestyc.d' ihapt4bd. -:en ..?
conservative the calculation:4ti We feel no revision is repiggg#ebe creek ODCN;
<.ot.e dose corr. , - -
- r. -t. l c: ne edet t.c y .- . . ~.x . t esiculates a sr :. ; a n.'- M l
. . There vem,i .; ...
14 G hope creek
\