SNRC-2179, Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl

From kanterella
(Redirected from ML20072P981)
Jump to navigation Jump to search
Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl
ML20072P981
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 09/01/1994
From: Bortz A
LONG ISLAND POWER AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LSNRC-2179, NUDOCS 9409090044
Download: ML20072P981 (24)


Text

'

l

., Long Shoreham Nuclear Power Station s Island P.O. Box 628

% Power North Country Road Authonty Wading River. N.Y.11792 SEP 011994 LSNRC-2179 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Shoreham Decommission Project Application of Soil Release Criteria to Other Bulk Material:

Analysis of Reconcentration Potential and Possible Exposure Pathways Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Ref: (1) Long Island Power Authority letter LSNRC-2133, dated January 10, 1994; subject: Termination Survey Plan - Revision 2 (2) U.S. Nuclear Regulatory Commission letter dated December 16,1993, Clayton L. Pittiglio, Jr. (NRC/NMSS) to L. M. Hill (LIPA); subject: Review and Comments of Termination Survey Plan (3) U.S. Nuclear Regulatory Commission letter dated July 18,1994, Clayton L. Pittiglio, Jr. (NRC/NMSS) to A. J. Bortz (LIPA); subject: Review of the Shoreham Decommissioning Project Termination Survey Plan, Revision 2, Section 3.1 (4) U.S. Nuclear Regulatory Commission, " Draft Proposed Rule on Radiological Criteria for Decommissioning", SECY-94-150, May 31, 1994.

Ladies and Gentlemen:

The Long Island Power Authority (LIPA) proposed that the release criterion for soil be applied to certain other bulk materials which will remain at the Shoreham facility upon completion of decommissioning. This proposal was first outlined in the second revision of the Shoreham Decommissioning Project Termination Survey Plan (Reference 1) wherein LIPA described the application of the 8 pCi/gm criterion to materials (concrete rubble, sewage sludge, tank bottoms and sediments, and bulk charcoal) other than soil. The unrestricted use limit of 8 pCi/gm for residual Co-60 in soil was specified by the NRC in Reference 2 and reiterated in Reference 3. LIPA 9409090044 940901 ,

0 0\

PDR ADOCK 0500o322 1 t

l W PDR

LSNRC-2179 Page 2 of 2 proposed the application of this release criterion to these materials principally because other release criteria limits (e.g., surface contamination and gamma exposure rate l guidelines) are not readily applicable given the volumetric nature of the residual l contamination in the materials. The NRC requested additionalinformation (Reference i

3) in order to evaluate LIPA's proposal. Specifically, the NRC stated that an additional I evaluation of the potential for Co-60 in the various materials to be reconcentrated l through recycling or incineration was necessary. The NRC also recommended that an analysis of potential exposure pathways be included in the evaluation.

LIPA has completed an exposure pathway analysis, forwarded as Enclosure 1 to this letter. The analysis was based on the peak concentration of radionuclides in the specific bulk materials found at the Shoreham facility. The attached dose pathway analysis results show a calculated Total Effective Dose Equivalent (TEDE) of 9.3 mrem per year from the combined effect of all four materials under consideration. This annualized dose compares favorably to the dose limit of 15 mrem / year TEDE for residual radioactivity mentioned in the draft proposed rule on " Radiological Criteria for Decommissioning" (Reference 4). The analysis provided in the enclosure also describes the expected impact of reprocessing the materials, and concludes that in all cases the resultant dose would be no higher than that calculated for the materials in their present locations. These materials are also subject to other appropriate survey requirements of the Shoreham Termination Survey Plan, including measurements for total surface activity, removable surface activity and gamma exposure rate determinations.

Please do not hesitate to contact me if there are additional questions or if further information is required in this matter.

Very truly yours, 2 AR c /28 A. J. Bortz Resident Manager

'~nclosures: (1) Analysis of Bulk Material Reconcentration Potential and Possible Exposure Pathways cc: L. Bell C. L. Pittiglio T. T. Martin R. Nimitz D. Fauver Mr. Robert Bernero, Director Office of Nuclear Material Safety and Safeguards

i 1

I LSNRC -2179 ENCLOSURE 1 Analysis of Bulk Material Reconcentration Potential and Possible Exposure Pathways l

l 1

l J

Analysis of Bulk Material Reconcentration Potential and Possible Exposure Pathways An analysis of the reconcentration potential and possible exposure pathways was performed for the bulk materials (other than soil) at the Shoreham site. The specific bulk materials were: (1) contaminated concrete rubble generated by removal of certain internal walls of the Radwaste Building; (2) contaminated charcoal which was utilized as part of the gaseous radwaste treatment system; (3) contaminated sewage sludge; and (4) contaminated silt and/or biological material in the facility radwaste discharge tunnel. The suitability of allowing for the unrestricted release of a site containing these materials is addressed individually by conservative dose pathway analyses which are based on the peak activity concentration findings reported in the applicable Termination Survey Unit Release Record. The survey unit release records which report results for the above materials include:

SUO20, Sanitary Sewage (sewage sludge)

RWO59, Condensate Demineralizer Filters Corridor (concrete rubble)

RWO60, "A - H" Condensate Demineralizer Room (concrete rubble)

SUO44, Radwaste Offgas (contaminated charcoal)

SUO45, Circulating Water (silt and biological material)

The results of dose pathway analyses are provided in Attachments 1 through

! 4 and summarized in Table 1. The summary table also includes a comparison to the Draft NRC Criteria for Decommissioning, namely 15 mrem /yr. The pathway analyses presented are all based on the residential use scenario developed for NUREG/CR-5512.

These analyses are highly conservative and include assumptions which envelope the effect of potential reconcentration of radionuclides within the materials. The major l component exposure pathways analyzed for each material include direct external

exposure to the volumetric source, inhalation of airborne material, and ingestion of contaminated foods. As shown in Table 1, the exposures from each of the additional j

materials are allless than the NRC Draft Guidance value of 15 mrem /yr, ranging from l

0.0013 mrem per year for charcoal to 7.85 mrem per year due to sitt in the discharge tunnel. The combined dose for all four additional materials is 9.3 mrem per year.

l The conservative nature of these exposure estimates, again which use the generic residential use scenario of NUREG/CR-5512, can be readily seen by comparison to dose assessments performed in a manner similar to the NRC-generated

" Generic Dose Assessment For Disposal of incinerator Ash in a Landfill", dated January,1994. As listed in Table 1, the maximum public dose impact as determined by a RESRAD analysis for the combined four additional bulk materials are 0.68 mrem per year vs. 9.3 mrem yr. based on the NUREG/CR-5512 scenario.

l l

Pa0e 1 of 4 l

Analysis of Bulk Materials Reconcentration Potential and Possible Exposure Pathways Each of the attachments (1 through 4) also provide an estimate of the reconcentration effects necessary to raise projected pathway doses to a value equivalent to the NRC Draft Guidance value of 15 mrem /yr. These reconcentration factors range from 1.91 to 11,200. Evaluation of the impact of reconcentration of these small amounts of radioactive materialin the specific bulk materials listed above is based primarily upon a review of two NRC documents. The first is NUREG/CR-5814, " Evaluation of Exposure Pathways to Man from Disposal of Radioactive Materials into Sanitary Sewer Systems", and the second document is the NRC-  ;

generated " Generic Dose Assessment For Disposal of incinerator Ash in a Landfill",

dated January,1994. The first reference states that a volume reduction of sewage sludge as a result of incineration is 95%, or providing a reconcentration ratio of 20:1.

The second reference assumes that for one generator, the dilution of incinerator ash by mixing with soil would provide a dilution ratio of 1:50. Thus, a disposal scenario for the bulk materials of concern which involves incineration and disposal of the ash by mixing with soil, as might be hypothesized for disposal of the sewage sludge, silt, or charcoal, would result in a net dilution ratio of 1:2.5, or a dilution factor of 0.4.

By comparing this factor to the reconcentration factors for Shoreham specific materials, it is apparent that disposal of the bulk materials represents a minirnal dose effect.

l Direct recycling of these materials (e.g., use of the sludge as fertilizer, use of the silt as fill or surface overlay, or reuse of the charcoalin various products) without incineration would likely result in the dispersion of the radionuclides, or at least no reconcentration, as there are no other volume reduction processes which would l typically be applied to the sludge, silt or charcoal. The concrete rubble must be l regarded as at least the equal of soil in terms of the lack of potential for reconcentration of contaminating radionuclides. Concrete rubble is rarely processed for volume reduction, it is much more credible to assume that the rubble would be used as fill material, where it would retain its essential volume and content except for minor surface wear during handling and placement. Thus in all probable disposal scenarios of these various materials, the dose estimate would be equal to or less than the doses provided in Table 1.

l As a further analysis, Section 8.1 of the generic dose assessment for the disposal of incinerator ash states that only certain radionuclides which are potentially in incinerator ash may represent significant radiological risks to the public and may approach the public dose limits of 10 CFR 20.301, based on the assumptions rnade in that generic assessment. The radionuclides found in the bulk materials at Shoreham, which are predominantly Co-60, but also include Cs-137, Zn-65, and Mn-54, are not among the suspect nuclides of the generic assessment. These suspect nuclides include C-14, Cl-36, TI-204, Ag-208m, Al-26, Tc-99, Nb-94, H-3,1-129, P-32, S-35, Tc-99m, Fe-59, and Ca-45 depending upon disposal and exposure characteristics. The generic assessment recommends that for other than these suspect nuclides, disposal be based on meeting the concentrations given in 10 CFR Part 20, Appendix B, Table ll, Column 2 by converting Ci/mi to Ci/gm and assuming 1 ml of water is equivalent to 1 gm of ash. ln applying the Appendix B values for l

Page 2 of 4 l

S REFERENCES (For Attachments 1 through 4)

1) LIPA Memorandum NLR 94-0146 dated July 13,1994; NRC Exit Meeting Record
2) USNRC letter dated July 18,1994; subject: Review of the Shoreham Decommissioning Project Termination Survey Plan, Revision, 2, Section 3.1
3) Shoreham Decommissioning Project Termination Survey Release Record Report for Survey Unit SUO20 - Sanitary Sewage; Termination Survey Final Report, Phase 1
4) Shoreham Decommissioning Project Termination Survey Release Record Report for Survey Unit SUO59 "A - H" Condensate Demineralizers Room; Termination Survey Final Report, Phase 111
5) Shoreham Decommissioning Project Termination Survey Release Record Report for Survey Und SUO60 - Condensate Demineralizer Filters Corridor; Termination Survey Final Report, f nase 111
6) Shoreham Decommissioning Project Termination Survey Release Record Report for Survey Unit SUO44 - Radwaste Off-Gas System; Termination Survey Final Report, Phase ll1
7) Shoreham Decommissioning Project Termination Survey Release Record Report for Survey Unit SUO45 - Circulating Water System; Termination Survey Final Report, Phase IV
8) NUREG/CR-5512, " Residual Radioactive Contamination From Decommissioning"; Pacific Northwest Laboratory - Final Report, October 1992 - Volume 1
9) NUREG/CR-5512, " Residual Radioactive Contamination From Decommissioning"; Pacific Northwest Laboratory - Draft Report, January 1990
10) LILCO Calculation NO. CCI-039221, " Pathway and TEDE Doses for Shoreham Post-Decommissioning Dose Pathway Analysis", Rev. 0 - 3/6/92
11) Shoreham Nuclear Power Station Post-Decommissioning Dose Pathway Analysis Report Draft Repon, November 1991
12) USNRC Report " Generic Dose Assessment For Disposal of incinerator Ash in A Landfill", Draf t Report, January 1994
13) NUREG/CR-5814, " Evaluation of Exposure Pathways to Man From Disposal of Radioactive Materials into Sanitary Sewer Systems", Pacific Northwest Laboratory, May 1992
14) Title 10 Code of Federal Regulations Part 20, Appendix B - Concentrations in Air and Water Above Natural Background, Table 11, Column 2
15) LIPA Shoreham Decommissioning Project Termination Survey Plan, Revision 2
16) LIPA Shoreham Nuclear Power Station Offsite Dose Calculation Manual, LIPA Rev. 2
17) USNRC, " Radiological Criteria for Decommissioning of NRC-Licensed Facilities: Enhanced l Participatory Rulemaking, Availability of the Staff's Draft of the Rule:, Federal Register, i February 2,1994, 4688 -4869.
18) USNRC, Draf t Proposed Rule on Radiological Criteria for Decommissioning, SECY-94-150, May 31,1994 l i

Page 4 of 4 l

1

Analysis of Bulk Materials Reconcentration Potential and Possible Exposure Pathways multiple nuclides, the sum of the fractions approach is suggested, with the sum to be less than 100%. Table 1 provides the results of such an analysis for each of the four bulk materials. The summation of the MPC fractions from all of the four materials gives 24.86% assuming peak concentration values, and 7.81 % using average material concentration values. Similarly, the benchmark values of 8 pCi/gm of Co-60 in soil represents an MPC fraction of 26.67%. Therefore even by this method of analysis, the bulk materials are shown to be less than the benchmark and less than typically accepted limits for disposal.

Page 3 of 4

f TABLE 1-BULK MATERIALS DOSE PATHWAY ANALYSIS RESULTS T.S.U. No. SUO20 RWO59 SUO44 SUO45 l

& RWO60 )

Bulk Material Sludge Concrete Charcoal Silt Radionuclide Co-60 Co-60 Cs-137 Co-60 Peak 6.52E-02 2.19E-01 3.85E+00 1.54E+00 Concentration pCl/gm pCi/gm pCl/gm pCi/gm Total 6.17E-01 2.62E-01 2.79E+01 6.95E+01 Activity uCi uCi uCi uCi l t Residential Direct 3.32E-01 1.12E+00 1.07E-03 7.85E+00 Exposure mrem /yr mrem /yr mremlyr mremlyr .

, Residential

! Inhalation 6.27E-06 2.11 E-05 5.41E-05 1.48E-04

! Exposure mrem /yr mrem /yr mrem /yr mrem /yr Residential ingestion 3.25E-06 1.09E-05 2.13E-04 7.68E-05 Exposure mrem /yr mrem /yr mrem /yr mrem /yr TEDE 3.32E-01 1.12E+00 1.34 E-03 7.85 E+00 mrem /yr mrem /yr mrem /yr mrem /yr <

Percentage of NRC Draft Criteria 2.21 % 7.47% 0.009 % 52.33 %

Percentage of MPC based on Peak Concentration 0.22 % 0.73 % 19.25 % 4.66 %

Avg. Concentration 0.22 % 0.36 % 5.65 % 1.58 %

l Sum of TEDEs for all bulk materials = 9.30E+00 l mrem /yr Sum of MPC fractions for bulk materials using peak concentration = 24.86 %

Sum of MPC fractions for bulk materials using avg. concentration = 7.81 %

Comparison with Generic Dose Assessment for incinerator Ash RESRAD (Public) 3.75E-03 1.26E-02 5.74 E-01 8.86E-02 mrem /yr mrem /yr mrem /yr mrem /yr IMPACTS (Max Ind) 4.27E-02 1.44 E-01 2.20E-01 1.01 E+00 mrem /yr mrem /yr mrem /yr mrem /yr I l Combined sum of RESRAD doses for materials 6.79E-01 l mrem /yr l l

i

ATTACHMENT 1 Page 1 of 4 Termination Survey Unit - SUO20: SANITARY SEWAGE - [ SLUDGE]

LOCATION LOCATION Co-60 Lc (LLD)* >Lc Lr + >Lr MASS Co-60 NUMBER DESCRIPTION [pCilgm] [pCi/gm] [pCi/gm] [gms] [uCi]

1 Ejec. Pump < LLD 1.86E-02 6 2 Sump Pump < LLD 1.11 E-02 6 3 Septic Tank < LLD 1.64 E-02 6 4 Septic Tank 6.52E-02 4.12E-03 X 6 9.46E+06 6.17E-01 5 Leach Pool < LLD 1.17E-02 6 6 Leach Pool < LLD 1.77E-02 6 7 Leach Pool < LLD 1.32E-02 6 8 Leach Pool < LLD 9.96E-03 6 9 Leach Pool < LLD 1.59E-02 6 10 Septic Tank inaccessible N/A N/A 11 Septic Tank < LLD 1.37E-02 6 12 Septic Tank < LLD 1.59E-02 6 13 Leach Pool < LLD 1.86E-02 6 14 Leach Pool inaccessible N/A N/A

-9 QC Replicate < LLD 1.32E-02 6 Peak Activity Concentration Co-60 6.52 E-02 9.46E+06 6.17E-01 l pCi/gm gms uCi

  • Lc represents decay corrected LLD for identified isotope (s).

+ tr represents 75% of the release limit (8 pCilgm) for total activity in soil, sediment, and special samples.

Co-60 : Reaulatory Limits / Commitments Co-60 Activity Concentration Values SOURCE LIMIT REFERENCE 10CFR20 MPC 3E-05 uCi/ml 10 CFR Part 20, App.B. Table il Col.2 TERM SURVEY BE-06 uCi/gm TSP Sec.5.2.3 (an NRC Criterion)

ODCM LLD SE-07 uCi/ml ODCM Table 4.11.1.1.1-1 REMP LLD 1.5E-08 uCi/mi ODCM Table 4.12.1-1 VS.

SEWAGE l 6.52E-08 uCilgm (SUO20 Term Survey Release Record Rpt.

MPC Fraction 0.22% Peak & Avg. l l For determining the suitability of using the soil free-release limit of 8 pCi/gm to other bulk material, the peak activity (6.52E-02 pCi/gm) will be used. LILCO Calculation No. CCl-039221, " Pathway and TEDE Doses for Shoreham i Post Decommissioning Dose Pathway Analysis'shows that of the four scenarios, Building Renovation, Building Occupancy, Drinking Water and Residential Use; Residential Use results in the highest TEDE.

Furthermore, of the major component pathways for the residential use scenario, External Exposure is the l most significant followed by ingestion and inhalation in that order, with groundwater not even being a credible i pathway in the case of Shoreham.

l ATTACHMENT 1 Page 2 of 4 j Residential Use Scenario I The major component exposure pathways to be considered for this scenario include:

A) Direct External Exposure to Soil Volume Sources; B) Inhalation of Airborne Materials; C) Ingestion of Contaminated Food. l Groundwater related exposure pathways are not credible at the Shoreham site for two reasons;  ;

1) This pathway is predicated on the presence of buried contaminated rubble 1 left in place after decommissioning with the contamination allowed to leach i into the groundwater where it would be picked up and transported to sources  !

l of domestic water supply. There is no buried contaminated rubble currently l at the Shoreham site nor does the LIPA Decommissioning Plan allow for any '

as part of the decommissioning process.  ;

2) Groundwater drainage at the site is north to the Long Island Sound. the three onsite wells which are used for drinking water are located south of the actual '

l Plant site and hence, no public or site drinking water supplies could be affected by any site activity.

( A) Direct External Exposure to Soil Volume Sources l

l The fundamental relationship for calculating radiation dose rates to people from any radionuclide in an exposure pathway is given by:

! R (i.p) = C (i.p) X U (p) X D (i,p) [Ref. 9}

l Where R (i,p) = The radiation dose equivalent or committed radiation dose equivalent from radionuclide i via exposure pathway p,in mrem /yr; 1

l C (i.p) = The concentration of radionuclide iin the media of exposure in pathway p, in pCilgm (Bg/gm) for volume contamination in buildings l

and soil; l = 6.52E-02 pCi/gm [Ref. 3)

U (p) = The usage parameter (exposure rate) associated with exposure pathway p, in br/yr for external exposure. For residential scenario, the equivalent number of direct (unshielded) exposure = 1800 hrs outdoors (actually 1700 hrs outdoors + 100 hrs gardening) + 4380 hrs indoors X 0.33 (Home Shielding Factor); [Ref 8,9]

= 3245 hrs D (i,p) = The committed effective dose equivalent factor for radionuclide i and exposure pathway p, used to convert the concentration and usage parameters to the committed effective dose equivalent in mrem /hr per pCl/gm.

= 1.57E-03 mrem /hr per pCilgm for Co-60 [Ref. 8)

Therefore, R (i,p) = 6.52E-02 pCi/gm X 3245 hrs X 1.57E-03 mrem /hr per pCilgm

=l 3.32E-01 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption

[ of essentially infinite extent at the maximum possible concentration.

ATTACHMENT 1 Page 3 of 4 B) Inhalation of Airborne Materials The general equation for estimating the committed effective dose rate equivalent by inhalation receitted by individuals for radionuclide i is given by:

H (inh,1) = V X t X C (d) X C (w,1) X DF(inh,1) [Ref. 9)

Where H (inh,1) = The committed effective dose equivalent from a 1 year intake of radionuclide i by inhalation, in mrem /yr; V= The ventilation rate of the individual, in m'3/hr;

= 1.0 [Ref. 8,9]

t= The duration of exposure for the individual,in hr/yr;

= 4380 hrs Indoors + 1700 hrs Outdoors + 100 hrs Gardening [Ref. 8,9)

C (d) = The concentration of respirable dust in air,in gm/m'3;

= Indoors = SE-05, Outdoors = 1E-04, Gardening = SE-04 [Ref. 8,9) i C (a,l) = The concentration of radionuclide iin the contaminated material,in pCi/gm;

= 6.52E-02 pCi/gm [Ref. 3)

DF (inh,1) = The committed effective dose from inhalation of radionuclide i,in mrem /pCl.

= 2.19E-04 mrem /pCi for Co-60 [Ref. 8)

Therefore, H (inh,i) = 1 m'3/hr X (4380*5E-05+1700*1E-04+100*5E-04) hr-gm/yr-m'3 X 6.52E-02 pCi/gm X 2.19E-04 mrem /pCi

=l 6.27E-06 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

RESRAD incinerator Ash Dose (to the public) i Dose = DSR(i,tmax)[ mrem /yr per pCilgm] X Peak Concentration [pCilgm] [Ref.12)

= 5.75E-02 X 6.52E-02

=l 3.75E-03 mrem /yr l l IMPACTS Incinerator Ash Dose (to the max. Individual) [Ref.12) l Dose = DSR(i,trans)[ mrem /yr per pCilgm] X Peak Concentration [pCi/gm]

l = 6.554E-01 X 6.52E-02

=l 4.27E-02 mrem /yr l l

[

l

ATTACHMENT 1 Page 4 of 4 C)Incestion of Contaminated Food This pathway is based upon the assumption that a certain fraction of food consumed by site residents is grown in tho soil onsite which contains residual acyivity concentrations. Assuming the same dietary commitments as NUREGICR-5512 (25% of total diet as defined in R.G.1.109) allows one to take the values for specific nuclides directly from NUREGICR-5512, which are based on 1 pCilgm concentrations and multiply by the value to be used for soil volume concentrations.

The simplified form of the equation is given by: I H (ing,1) = FD (ing,1) X C (1,p) [Ref. 9]

Whsre H (ing,1) = The committed effective dose equivalent from a 1 year intake of radionuclide i by ingestion, in mremlyr; l FD (ing,1) = The food ingestion effective doss equivalent factor for the most sensitive organ for radionuclide i, in mrem /pCl, assuming 1 pCi/gm and the dietary input listed below: ,

l a) 47.5 Kglyr of vegetable produce, b) 27.5 Uyr of milk, j c) 19.2 Kglyr of meat (beef, pork, poultry)  :

d) 4.8 Kglyr of eggs. [Ref. 9]

= 4.99E-05 mrem /pCi for Co-60 for LLI wall. (@ 1 pCilgm soil activity) [Ref. 8) )

C (i,p) = The soit volume activity, for radionuclide i, in pCi/gm

= 6.52E-02 pCi/gm for Co-60 [Ref. 3] I Therefore, H (ing,1) = 4.99E-05 mrem /pCi per pCi/gm X 6.52E-02 pCi/gm

=l 3.25E-06 mremlyr l l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

I Residential Use Scenario - Total Effective Dose Eauivalent l

I  !

Direct Exposure + Inhalation Exposure + Food Ingestion Exposure l

l 3.32E-01 mrem /yr + 6.27E-06 mrem /yr + 3.25E-06 mrem /yr l TEDE = 3.32E-01 mremlyr l Rsconcentration Factor required to raise projected pathway dose to Draft NRC Criteria Value =

l RF= 4.52E+01 l

ATTACHMENT 2 Page 1 of 4 Termination Survey Unit - RWO59: "A-H" COND. DEMIN. RM. - [ CONCRETE]

Termination SURVEY Survey Unit - RWO60: COND. DEMIN. FLTRS COR. - [ CONCRETE]

DRUM l.D. Co-60 CONCRETE POINT Co-60 NUMBER [ pct /gm] [gm]

  • 247/248 {uCi) 93-DRM-142 < 1.48E-02 251/252 93-DRM-148 <1.36E-02 253/254 93-DRM-150 < 1.42E-02 255/256 93-DRM-153 < 1.30E-02 257/258 93-DRM-154 <1.13E-02 259/260 93-DRM-162 <8.79E-03 261/262 93-DRM-170 < 1.19E-02 263/264 93-DRM-171 < 1.28E-02 265/266 93-DRM-172 < 1.15E-02 269/270 93-DRM-174 < 9.61E-03 273/274 93-DRM-139 3.53E-02 4.88E+05 1.72 E-02 347/348 94-DRM-191 < 1.45E-02 353/354 94-DR M-249 <1.03E-02 355/356 94-DRM-235 8.18E-02 4.88 E+05 4.00E-02 357/358 94-DRM-234 2.19E-01 4.88E+05 1.07E-01 1 387/388 94-DRM-248 < 1.38E-02 391/392 'A' 1.07E-01 4.BBE+05 5.23E-02 393/394 94-DRM-241 < 1.39E-02 397/398 *B' < 1.21 E-02 403/404 94-DRM-189 9.42E-02 4.88E+05 4.60E-02 405/406 'C' < 1.50E-02 407/408 94-DRM-261 < 1.09E-02 411/412 "D" < 6.02E-03 415/416 *E' < 8.69E-03 l PEAK 2.19E-01 SUM l 2.62E-01 pCi/gm uCi
  • Specific volumes not known typically 65% - 85% full (55 gal. drum). Assume full. Density @ 2.35 gm/cm'3.

Co-60 : Regulatory Limits / Commitments Co-60 Activity Concentration Values SOURCE LIMIT REFERENCE 10CFR20 MPC 3E-05 uCi/mi 10 CFR Part 20 App.B, Table il Col.2 TERM SURVEY BE-06 uCi/sm TSP Sec.5.2.3 (an NRC Criterion)

DDCM LLD SE-07 uCi/mi ODCM Table 4.11.1.1.1-1 REMP LLD 1.5E-08 uCi/ml ODCM Table 4.12.1-1 00NCRETE Peak 2.19E-07 uCilgm RWO59&D60 Term Survey Release Record Apts.

Avg. 1.07E-07 uCilgm VPC Fraction 0.73%! 0.36%, Peak l Avg.

Or determining ine suitability of using the soil free-release limit of 8 pCi/gm to other bulk material, the peak
or. centration found (2.19E-01 pCilgm of Co-60) represents the most conservative value and will be used in he dose pathway analysis. LILCO Calculation No. CCl-039221, " Pathway and TEDE Doses for Shoreham

'ost Decommissioning Dose Pathway Analysis'shows that of the four scenarios, Building Renovation, 3uilding Occupancy, Drinking Water and Residential Use; Residential Use results in the highest TEDE.

'urthermore, of the major component pathways for the residential use scenario, External Exposure is the nost significant followed by ingestion and inha!ation in that order, with groundwater not even being a credible

.athway in the case of Shoreham.

r ATTACHMENT 2 Page 2 of 4 Residential U.Se Scenario l

The major component exposure pathways to be considered for this scenario include:

A) Direct External Exposure to Soil Volume Sources; B) Inhalation of Airborne Materials; l

C) Ingestion of Contaminated Food. l Groundwater related exposure pathways are not credible at the Shoreham site for two reasons;

1) This pathway is predicated on the presence of buried contaminated rubble l left in place after decommissioning with the contamination allowed to leach I into the groundwater where it would be picked up and transported to sources of domestic water supply. There is no buried contaminated rubble currently at the Shoreham site nor does the LIPA Decommissioning Plan allow for any l

, as part of the decommissioning process.

l 2) Groundwater drainage at the site is north to the Long Island Sound. the three l onsite wells which are used for drinking water are located south of the actua!

l plant site and hence, no public or site drinking water supplies could be affected by any site activity.

A) Direct External Exoosure to Soil Volume Sources The fundamental relationship for calculating radiation dose rates to people from any radionuclide in an exposure pathway is given by:

R (i.p) = C (i,p) X U (p) X D (i,p)

(Ref. 9]

l Where l R (i.p) = The radiation dose equivalent or committed radiation dose equivalent from radionuclide i via exposure pathway p, in mrem /yr; C (i,p) = The concentration of radionuclide iin the media of exposure in pathway p, in pCi/gm (Bg/gm) for volume contamination in buildings and soil;

= 2.19E-01 pCi/gm [Ref. 4,5)

, U (p) = The usage parameter (exposure rate) associated with exposure pathway p, in hr/yr for external exposure. For residential scenario, the equivalent l number of direct (unshielded) exposure = 1800 hrs outdoors (actually l 1700 hrs outdoors + 100 hrs gardening) + 4380 hrs indoors X 0.33 (Home '

Shielding Factor); [Ref. 8,9]

l = 3245 hrs l D (i,p) = The committed effective dose equivalent factor for radionuclide i and exposure pathway p, used to convert the concentration and usage parameters to the committed effective dose equivalent in mrem /hr per pCi/gm.

= 1.57E-03 mrem /hr per pCi/gm for Co-60

[Ref. 8]

Therefore, R (1,p) = 2.19E-01 pCi/gm X 3245 hrs X 1.57E-03 mrem /hr per pCilgm l

= l1.12E+00 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any j consideration of re-concentration within the bulk materialltself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

i l

I

ATTACHMENT 2 Page 3 of 4 ,

l B) Inhalation of Airbome Materials l

The general equation for estimating the committed effective dose rate equivalent by inhalation recsived by individuals for radionuclide i is given by:

H (inh,1) = V X t X C (d) X C (w,1) X DF(inh,1) [Ref. 9)

Where H (inh,1) = The committed effective dose equisalent from a 1 year intake of radionuclide i by inhalation, in mrem /yr; V= The ventilation rate of the individual,in m'3/hr; l

i = 1.0 [Ref. 8,9]

l t= The duration of exposure for the individual,in hr/yr;

= 4380 hrs Indoors + 1700 hrs Outdoors + 100 hrs Gardening [Ref. 8,9)

C (d) = The concentration of respirable dust in air,in gm/m'3;

= Indoors = SE-05, Outdoors = 1E-04, Gardening = SE-04 [Ref. 8,9]

C (w,i) = The concentration of radionuclide iin the contaminated material,in pCilgm;

= 2.19E-01 pCi/gm [Ref. 4,5)

DF (inh,i) = The committed effective dose from inhalation of radionuclide i,in mrem /pCi.

= 2.19E-04 mrem /pCi for Co-60 [Ref. 8)

Therefore, j H (inh,1) = 1 m'3/hr X (4380*SE-05+1700*1E-04+100*SE-04) hr-gm/yr-m'3 X

! 2.19E-01 pCi/gm X 2.19E-04 mrem /pCi

= l 2.11E-05 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any l

considsration of re-concentration within the bulk materialitself. This primarily refers to the assumption

! of essentially infinite extent at the maximum possible concentration.

i RESRAD Incinerator Ash Dose (to the public)

Dose = DSR(i,tmax)[ mrem /yr per pCi/gm) X Peak Concentration [pCilgm] [Ref.12]

= 5.75E-02 X 2.19E-01

= l 1.26E-02 mrem /yr l l

l lMPACTS Incinerator Ash Dose (to the max. individual) [Ref.12]

l l

Dose = DSR(i,trans)[ mrem /yr per pCi/gm] X Peak Concentration [pCilgm)

= 6.534E-01 X 2.19E-01

= l 1.44E-01 mremlyr j

ATTACHMENT 2 Page 4 of 4 C)Inaestion of Contaminated Food This pathway is based upon the assumption that a certain fraction of food consumed by site residents is grown in the soil onsite which contains residual acyivity concentrations. Assuming the same dietary commitments as NUREG/CR-5512 (25% of total diet as defined in R.G.1.109) allows one to take the values for specific nuclides directly from NUREG/CR-5512, which are based on 1 pCi/gm concentrations and multiply by the value to be used for soit volume concentrations.

The sirnplified form of the equation is given by:

H (ing,1) = FD (ing,i) X C (i,p) [Ref. 9]

Whers H (ing,i) = The committed effective dose equivalent from a 1 year intake of radionuclide i by ingestion, in mrem /yr; FD (ing,1) = The food ingestion effective dose equivalent factor for the most sensitive organ for radionuclide I, in mrem /pCl, assuming 1 pCi/gm and the dietary input listed below: [Ref. 9]

a) 47.5 Kglyr of vegetable produce, b) 27.5 Uyr of milk, c) 19.2 Kglyr of meat (beef, pork, poultry) d) 4.8 Kglyr of eggs.

= 4.99E-05 mrem /pCi for Co-60 for LLI wall. (@ 1 pCi/gm soil activity) [Ref. 8]

C (i,p) = The soil volume activity, for radionuclide i, in pCi/gm

= 2.19E-01 pCilgm for Co-60 [Ref. 4,5)

Therefore, H (ing i) = 4.99E-05 mrem /pCi per pCilgm X 2.19E-01 pCi/gm

= l1.09E-05 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

Residential Use Scenario - Total Effective Dose Equivalent Direct Exposure + inhalation Exposure + Food Ingestion Exposure 1.12E+00 mremlyr + 2.11E-05 mrem /yr + 1.09E-05 mremlyr l TEDE = 1.12E+00 mrem /yr l Reconcentration Factor required to raise projected pathway dose to Draft NRC Criteria Value =

l RF= 1.34E+01 l

. _ _ _ _ -.__m -

ATTACHMENT 3 Page 1 of 4 Termination Survey Unit - SUO44: RADWASTE OFFGAS - [ CHARCOAL]

CHARCOAL Co-60 Mn-54 Zn-65 Cs-134 Cs-137 Cs-137 CHARCOAL CHARCOAL TANK

[gms] [pCL/gm] [pCilgm] [pCilgm] [pCi/gm] [pCilgm] [uCi] [gms] libs]

No.

<0.026 <0.011 3.850 1.96 5.10E+05 1,125

-045A 5.10E+05 <0.015 <0.009

<0.011 3.450 1.76 5.10E+05 1,125

-045B 5.10E+05 <0.014 <0.010 <0.026

<0.019 2.550 20.13 7.89E+06 17,400

-047A 7.89E+06 <0.029 <0.019 <0.058

<0.019 0.472 3.73 7.89E+06 17,400 i

-0478 7.89E+06 <0.031 <0.019 <0.053

-047C 7.89E+06 <0.014 <0.008 <0.024 <0.009 <0.008 f 1

-0470 7.89E+06 <0.019 <0.011 <0.034 <0.011 <0.011

-047E 7.89E+06 <0.019 <0.010 <0.032 <0.012 <0.011

<0.013 0.036 0.28 7.89 E+06 17,400

-048A 7.89E+06 <0.018 <0.014 <0.049 i

-048B 7.89E+06 <0.014 <0.008 <0.025 <0.009 <0.024

-048C 7.89E+ 06 <0.016 <0.009 <0.004 <0.010 <0.009

-048D 7.89E+06 <0.011 <0.007 <0.027 <0.007 <0.007

-048E 7.89E +06 <0.008 <0.007 <0.021 <0.005 <0.006 SUM 27.86 2.47E+07 54,450 Peak Conc. = 3.85 pCilgm : Avg. Conc. = 1.13 pCi/gm CS-137 : Regulatory Limits / Commitments I

Cs-137 Activity Concentration Values SOURCE LIMIT REFERENCE 10 CFR Part 20, App.B, Table il Col.2 l 10CFR20 MPC 2E-05 uCi/ml TERM SURVEY BE-06 uCilgm TSP Sec.5.2.3 (an NRC Criterion)

ODCM LLD SE-07 uCi/ml ODCM Table 4.11.1.1.1-1 REMP LLD 1.8E-08 uCi/mi ODCM Table 4.12.1-1 VS.

CHARCOAL 3.85E-06 uCilgm Peak - SUO44 Term Survey Release Record Rpt.

1.13E-06 uCi/gm Avg. - SUO44 Term Survey Release Record Rpt.

MPC Fraction 19.25 % Peak 5.65 % Avg.

1 For determining the suitability of using the soil free-release limit of 8 pCilgm to other bulk material, the entire source term (27.86 uCi of Cs-137) will be considered and the Peak Conc. will be used for the dose pathway analysis. Use of the peak concentration (which was found in the smallest tank) will be extremely conservative for the dose pathway analysis. LILCO Calculation No. CCl-039221. " Pathway and TEDE Doses for Shoreham Post Decommissioning Dose Pathway Analysis' shows that of the four scenarios, Building Renovation, Building Occupancy, Drinking Water and Residential Use; Residential Use results in the highest TEDE.

Furthermore, of the major component pathways for the residential use scenario, External Exposure is the most significant followed by ingestion and inhalation in that order, with groundwater not even being a credible pathway in the case of Shoreham.

ATTACHMENT 3 Page 2 of 4 Residential USe Scenario The major component exposure pathways to be considered for this scenario include: l A) Direct External Exposure to Soil Vo:ume Sources; B) Inhalation of Airborne Materials; C) Ingestion of Contaminated Food.

l Groundwater related exposure pathways are not credible at the Shoreham site for two reasons;  ;

1) This pathway is predicated on the presence of buried contaminated rubble I left in place after decommissioning with the contamination allowed to leach into the groundwater where it would be picked up and transported to sources of domestic water supply. There is no buried contaminated rubble currently

{

at the Shoreham site nor does the LIPA Decommissioning Plan allow for any as part of the decommissioning process.

2) Groundwater drainage at the site is north to the Long Island Sound. the three onsite wells which are used for drinking water are located south of the actual plant site and hence, no public or site drinking water supplies could be affected by any site activity.

A) Direct External Exposure to Soil Volume Sources The fundamental relationship for calculating radiation dose rates to people from any radionuclide in an Gxposure pathway is given by:

R (i.p) = C (i.p) X U (p) X D (i.p) [Ref. 9]

Where R (i.p) = The radiation dose equivalent or committed radiation cose equivalent from radionuclide i, via exposure pathway p,in mremlyr; C (i,p) = The concentration of radionuclide iin the media of exposure in pathway p, in pCi/gm (Bg/gm) for volume contamination in buildings and soil;

= 3.85E+00 pCilgm [Ref. 6)

U (p) = The usage parameter (exposure rate) associated with exposure pathway p, in hr/yr for external exposure. For residential scenario, the equivalent number of direct (unshielded) exposure = 1800 hrs outdoors (actually 1700 hrs outdoors + 100 hrs gardening) + 4380 hrs indoors X 0.33 (Home Shielding Factor); [Ref. 8,9] l

= 3245 hrs l l

D (i.p) = The committed effective dose equivalent factor for radionuclide i and exposure pathway p, used to convert the concentration and usage parameters to the committed effective dose equivalent in mrem /hr per pCi/gm. j

= 8.53E-08 mrem /hr per pCi/gm for Cs-137 [Ref. BJ l

Therefore, I R (i.p) = 3.85E+00 pCilgm X 3245 hrs X 8.53E-08 mrem /hr per pCi/gm

= l1.07E-03 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentia!!y infinite extent at the maximum possible concentration.

l

ATTACHMENT 3 P:ge 3 of 4 B) Inhalation of Airt>orne Materials The general equation for estimating the committed effective dose rate equivalent by inhalation j rscelved by individuals for radionuclide i is given by:

H (inh,i) = V X t X C (d) X C (w,1) X DF(inh,1) [Ref. 9) l Wh;re l H (inh,1) = The committed effective dose equivalent from a 1 year intake of radionuclide l by inhalation,in mrem /yr; l

l V= The ventilation rate of the individual,in m*3/hr; l = 1.0 [Ref. 8,9]

l t'= The duration of exposure for the individual,in hr/yr;

= 4380 hrs indoors + 1700 hrs Outdoors + 100 hrs Gardening [Ref. 8,9]

C (d) = The concentration of respirable dust in air,in gm/m'3;

= Indoors = SE-05, Outdoors = 1E-04, Gardening = SE-04 [Ref. 8,9]

l C (w,1) = The concentration of radionuclide iin the contaminated material, in pCl/gm;

= 3.85E+00 pCi/gm [Ref. 6} ,

DF (inh,i) The committed effective dose from inhalation of radionuclide i, in mrem /pCl.  !

= 3.20E-05 mrem /pCi for Cs-137 [Ref. 8]

Therefore.

H (inh,1) = 1 m'3/hr X (4380*SE-05+1700*1E-04+100'5E-04) hr-gm/yr-m*3 X 3.85E+00 pCilgm X 3.20E-05 mrem /pCi

= l 5.41E-05 mremlyr l l

The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

RESRAD incinerator Ash Dose (to the public) l Dose = DSR(1,tmax)[ mrem /yr per pCilgm] X Peak Concentration [pCilgm] [Ref.12]

= 1.49E-01 X 3.85E+00

=l 5.74 E-01 mrem /yr j

.lMPACTS Incinerator Ash Dose (to the max. Individual) [Ref.12)

'I Dose = DSR(i,trans)[ mrem /yr per pCilgm] X Peak Concentration [pCi/gm] 4 l = 5.71E-02 X 3.85E+00

=l 2.20E-01 mremlyr l I l

I

ATTACHMENT 3 Page 4 of 4 C)Inoestion of Contaminated Food l

This pathway is based upon the f.6r.umption that a certain fraction of food consumed by site residents is grown in the soil onsite which contains residual activity concentrations. Assuming the same dietary commitments as NUREG/CR-5512 (25% of total diet as defined in R.G.1.109) allows one to take the values for specific nuclides directly from NUREG/CR-5512, which are based on 1 pCi/gm concentrations and multiply by the value to be used for soil volume concentrations.

The simplified form of the equation is given by:

H (ing,1) = FD (ing,1) X C (i.p) [Ref. 9]

1 Where H (ing,l) = The committed effective dose equivalent from a 1 year intake of radionuclide i by ingestion, in mrem /yr; FD (ing,1) The food ingestion effective dose equivalent factor for the most sensitive organ for radionuclide i, in mrem /pCl, assuming 1 pCi/gm and the dietary input listed below: [Ref. 9]

a) 47.5 Kglyr of vegetable produce, b) 27.5 Uyr of milk, c) 19.2 Kglyr of meat (beef, pork, poultry) d) 4.8 Kg/yr of eggs.  !

= 5.54E-05 mrem /pCi for Cs-137 for Adrenals. (@ 1 pCl/gm soil activity) [Ref. 8)

C (1,p) = The soit volume activity, for radionuclide i, in pCi/gm ,

= 3.85E+00 pCl/gm for Cs-137 [Ref. 6] l Therefore, I H (ing,1) = 5.54E-05 mrem /pCi per pCi/gm X 3.85E+00 pCi/gm

= l 2.13E-04 mrem /yr l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

Residential Use Scenario - Total Effective Dose Equivalent '

Direct Exposure + inhalation Exposure + Food Ingestion Exposure 1.07E-03 mrem /yr + 5.41E-05 mrem /yr + 2.13E-04 mrem /yr TEDE = 1.34E-03 mrem /yr Rsconcentration Factor required to raise projected pathway dose to Draft NRC Criteria Value =

RF= 1.12E+04

ATTACHMENT 4 Page 1 of 4 Termination Survey Unit - SUO45: CIRCULATING WATER - [ SILT)

LOCATION LOCATION Co-60 Cs-137 Mn-54 Zn-65 NUMBER DESCRIPTION [pCilgm] [pCl/gm) [pCilgm) [pCilgm]

Silt Volume = 1000 cu.ft.

1 Upstream 1.79E-01 <1.18E-02 1.68E-02 <2.85E-02 Si!! Density = 1.6 gm/cm'3 Top of Weir Silt Activity = Mass X A.C.

Mass = 4.51E+07 gms 2 Downstream 1.26E-01 <1.24 E-02 <1.20E-02 <2.81 E-02 A.C. = 1.54E+00 pCi/gm Top of Weir ISitt Activity = 6.95E+01 )

l UCI ,

3 Downstream 1.10E-01 <1.05E-02 <1.18 E-02 <2.10E-02 Wall  !

4 Upstream 1.29E+00 2.82E-02 3.30E-02 1.86 E-01 incline Wall l Peak activity concentrations as given for Location #4 l SUM = 1.54E+00 pCi/gm Co-60 / CS-137 / Mn-54 / Zn-65 : Regulatory Limits / Commitments Co-60 / Cs-137 / Mn-54 / Zn-65 Activity Concentration Values SOURCE LIMIT REFERENCE MPC Co-60 3E-05 uCi/ml 10 CFR Part 20, App.8, Table il Col.2 Cs-137 2E-05 uCi/ml Mn-54 1E-04 uCi/ml Zn-65 1E-04 uCi/ml TERM SURVEY BE-06 uCi/gm TSP Sec.5.2.3 (an NRC Criterion)

ODCM LLD SE-07 uCi/mi ODCM Table 4.11.1.1.1-1 REMP LLD Co-60 1.5E-08 uCi/ml ODCM Table 4.12.1-1 Cs-137 1.8E-08 uCi/mi M n-54 1.5E-08 uCi/m!

Zn-65 3.0E-08 uCi/mi VS.  !

Peak Cone Ava Conc )

SILT Co-60 1.29E-06 4.26E-07 uCilgm SUO45 Term Survey Release Record Rpt.

Cs-137 2.82E-08 1.57E-08 uCilgm Mn-54 3.30E-08 1.84E-08 uCilgm Zn-65 1.86E-07 6.59E-08 uCi/gm

% of MPC Co-60 4.30 % 1.42%

Cs-137 0.14 % 0.08 %

Mn-54 0.03 % 0.02 %

Zn-65 0.19 % 0.07 %

SUM 4.66 %, 1.58 %

For deiermining the suitability of using the soil free-release limit of 8 pCi/gm to other bulk material, the combined peak source activity (1.54E+00 pCilgm) will be considered as Co-60. This is not only conservative but also will simplify the dose pathway analysis. LILCO Calculation No. CCl-039221, ' Pathway and TEDE Doses for Shoreham Post Decommissioning Dose Pathway Analysis" shows that of the four scenarios, Building Renovation, Building Occupancy, Drinking Water and Residential Use: Residential Use results in the highest TEDE.

Furthermore, of the major component pathways for the residential use scenario, External Exposure is the most significant followed by ingestion and inhalation in that order, with groundwater not even being a credible pathcay in the case of Shoreham, i

ATTACHMENT 4 Page 2 of 4 Residential Use Scenario 4

The major component exposure pathways to be considered for this scenario include:

A) Direct External Exposure to Soil Volume Sources:

B) Inhalation of Airborne Materials; j

C) Irgestion of Contaminated Food.

Groundwater r6!ated exposure pathways are not credible at the Shoreham site for two reasons;

1) This pathway is predicated on the presence of buried contaminated rubble left in place a*ter decommissioning with the contamination allowed to leach into the groundwater where it would be picked up and transported to sources of domestic water supply. There is no buried contaminated rubbio currently at the Shoreham site nor does the LIPA Decommissioning Plan allow for any as part of the decommissioning process.
2) Groundwater drainage at the site is north to the Long Island Sound. the three onsite wells which are used for drinking water are located south of the actual plant site and hence, no public or site drinking water supplies could be affected i

by any site activity.

Al Direct External Eroosure to Soil Volume Sources The fundamental relationship for calculating radiation dose rates to people from any radionuclide in an exposure pathway is given by:

R (i,p) = C (i.p) X U (p) X D (i.p)

Whsre [Ref. 9)

R (i,p) = The radiation dose equivalent or committed radiation dose equivalent from radionuclide i via erposure pathway p, in mrem /yr; C (i,p) = The concentration of rat:ionuclide iin the media of exposure in pathway p, in pCi/gm (Bfgm) for volume contamination in buildings and soil;

= 1.54E+00 pCilgm

[Ref. 7)

U (p) = The usage parameter (exposure rate) associated with exposure pathway p, i in hr/yr for external exposure. For residential scenario, the equivalent

{

number of direct (unshielded) exposure = 1800 hrs outdoors (actually '

1700 hrs outdoors + 100 hrs gardening) + 4380 hrs indoors X 0.33 (Home Shielding Factor);

[Ref. 8,9]

= 3245 hrs D (i,p) = The committed effective dose equivalent factor for radionuclide i and exposure pathway p, used to convert the concentration and usage parameters to the committed effective dose equivalent in mrem /hr per pCi/gm.

= 1.57E-03 mrem /hr per pCi/gm for Co-60 Therefore, [Ref. 8]

l R (i,p) = 1.54E+00 pCilgm X 3245 hrs X 1.57E-03 mrem /hr per pCi/gm

= l 7.85E+00 mremlyr l The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption of essentially infinite extent at the maximum possible concentration.

ATTACHMENT 4 Pepe 3 of 4 B) Inhalation of Airborne Materials

! The general equation for estimating the committed effective dose rate equivalent by inhalation received by individuals for radionuclide i is given by:

H (inh,1) = V X t X C (d) X C (w,1) X DF(inh,1) [Ref. 9) i Where H (inh,1) = The committed effective dose equivalent from a 1 year intake of radionuclide i by inhalation,in mremlyr; l V= The ventilation rate of the individual,in m*3/hr;

= 1.0~ [Ref. 8,9) l t= The duration of exposure for the individual,in Wyr;

! = 4380 hrs Indoors + 1700 hrs Outdoors + 100 hrs Gardening [Ref. 8,9]

l C (d) = The concentration of respirable dust in air,in gm/m*3;

= indoors = SE-05, Outdoors = 1E-04, Gardening = SE-04 [Ref. 8,9]

l C (w,1) = The concentration of radionuclide iin the contaminated material,in pCi/gm; I

= 1.54E+00 pCi/gm [Ref. 7)

{ DF (inh,1) = The committed effective dose from inhalation of radionuciiue i,in mrem /pCl.

= 2.19E-04 mrem /pCi for Co-60 [Ref. 8]

! Therefore, H (inh,1) = 1 m*3/hr X (4380*5E-05+1700*1E-04+100*5E-04) hr-gmlyr-m'3 X l

1.54E+00 pCilgm X 2.19E-04 mrem /pCi

= l 1.4BE-04 mrem /yr l l

The concentration value used above is based on assumptions so conservative as to overwhelm any l consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption l of essentially infinite extent at the maximum possible concentration.

RESRAD incinerator Ash Dose (to the public)

Dose = DSR(i,tmax)[mremlyr per pCilgm] X Peak Concentration [pCilgm) [Ref.12) ,

= 5.75E-02 X 1.54E+00

= 8.86E-02 mremlyr IMPACTS Incinerator Ash Dose (to the max. Individual) [Ref.12]

Dose = DSR(i,trans)[mremlyr per pCi/gm] X Peak Concentration [pCl/gm)

= 6.554E-01 X 1.54E+00

=l 1.01E+00 mrem /yr l

_. .. . _ =

i ATTACHMENT 4 Page 4 of 4 C)Incestion 'of Contaminated Food This pithway is based upon the assumption that a certain fraction of food consumed by site residents is grown in the soil onsite which contains residual acylvity concentrations. Assuming the same dietary commitments as NUREG/CR-5512 (25% of total diet as defined in R.G.1.109) allows one to take the values for specific nuclides directly from NUREG/CR-5512, which are based on 1 pCilgm concentrations and multiply by the value to be used for soil volume concentrations.

The simplified form of the equation is given by:

H (ing,1) = FD (ing,1) X C (i,p) [Ref. 9]

Wh2ra H (ing,I) = The committed effective dose equivalent from a 1 year intake of radionuclide i r by ingestion, in mrem /yr; l

FD (ing,i) = The food ingestion effective dose equivalent factor for the most sensitive organ for radionuclide i, in mrem /pCl, assuming 1 pCi/gm and the dietary input listed below: [Ref. 9]

a) 47.5 Kglyr of vegetable produce, b) 27.5 L/yr of milk,

! c) 19.2 Kg/yr of meat (beef, pork, poultry) d) 4.8 Kg/yr of eggs.

= 4.99E-05 mrem /pCi for Co-60 fos LLI wall. (@ 1 pCi/gm soil activity) [Ref. 8]

C (i.p) = The soil volume activity, for radionuclide i, in pCi/gm

= 1.54E+00 pCi/gm for Co-60 [Ref. 7]

Therefore, H (ing,1) = 4.99E-05 mrem /pCi per pCilgm X 1.54E+00 pCi/gm

= 7.68E-05 mrem /yr The concentration value used above is based on assumptions so conservative as to overwhelm any consideration of re-concentration within the bulk materialitself. This primarily refers to the assumption lof essentially infinite extent at the maximum possible concentration.

Residential Use Scenario - Total Effective Dose Equivalent Direct Exposure + Inhalation Exposure + Food Ingestion Exposure 7.85E+00 mrem /yr + 1.48E-04 mrem /yr + 7.68E-05 mrem /yr l TEDE = 7.85E+00 mrem /yr l Reconcentration Factor required to raise projected pathway dose to Draft NRC Criteria Value =

RF= 1.91 E+00 l

l