Text

Part 2 of 4, Millstone Nuclear Power Station, Unit 1, 2 and 3, 2001 Radioactive Effluent Release Report,Section III, Radiological Effluent Controls
	ML021280082
Person / Time
Site:	Millstone
Issue date:	04/30/2002
From:	; Dominion Nuclear Connecticut
To:	; NRC/FSME
References
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SECTION III MILLSTONE UNIT I RADIOLOGICAL EFFLUENT CONTROLS DOCKET NO. 50-245 Revision 20 January 25, 2001

REMODCM Unit One Controls Revision 20 MILLSTONE STATION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTION II: MILLSTONE UNIT ONE RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS SECTION PAGE NO.

TABLE OF CONTENTS 11-i III.A. INTRODUCTION H.A-1 m.B. DEFINITIONS l1I.B-1 lI.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation m.C-1

2. Radioactive Gaseous Effluent Monitoring Instrumentation Ill.C-6

3. Section reserved Ill.C- 11

4. Section reserved re.C-12

5. High Range Stack Noble Gas Monitor III.C-13 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

1. Radioactive Liquid Effluents III.D-1

a. Radioactive Liquid Effluents Concentrations II1.D-1

b. Radioactive Liquid Effluents Doses ITl.D-2

2. Radioactive Gaseous Effluents m.D-3

a. Radioactive Gaseous Effluents Dose Rate III.D-3

b. Radioactive Gaseous Effluents Noble Gas Dose IIl.D-4

c. Radioactive Gaseous Effluents

- Doses from Radionuclides Other Than Noble Gas Doses III.D-5 Ll.E TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS Ifi.E-1 III.F. BASES III.F-1 III-ii

REMODCM Unit One Controls Revision 20 MILLSTONE STA TION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTIONIII: MILLSTONE UNIT ONE RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS (Cont'd)

Table Number Table Name Page II.C-1 Radioactive Liquid Effluent Monitoring Instrumentation III.C-2 III.C-2 Radioactive Liquid Effluent Monitoring Instrumentation III.C-4 Surveillance Requirements M.C-3 Radioactive Gaseous Effluent Monitoring Instrumentation III.C-7 i.C-4 Radioactive Gaseous Effluent Monitoring Instrumentation III.C-9 Surveillance Requirements Figure Number Figure Name Page HI.D-1 Site boundary 111.13-6 III-ii

REMODCM Unit One Controls Revision 20 III.A. INTRODUCTION The purpose of this section is to provide the following for Millstone Unit One:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions.

IlI.A-1

REMODCM Unit One Controls Revision 20 III.B. DEFINITIONS The defined terms of this sub-section appear in capitalized type and are applicable throughout Section III.

B.1 ACTION - that part of a Control that prescribes remedial measures required under designated conditions.

B.2 INSTRUMENT CALIBRATION - the adjustment, as necessary, of the instrument output such that it responds within the necessary range and accuracy to know values of the parameter that the instrument monitors. The INSTRUMENT CALIBRATION shall encompass those components, such as sensors, displays, and trip functions, required to perform the specified safety function(s). The INSTRUMENT CALIBRATION shall include the INSTRUMENT FUNCTIONAL TEST and may be performed by means of any series of sequential , overlapping, or total channel steps so that the entire channel is calibrated.

B.3 INSTRUMENT FUNCTIONAL TEST - the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify that the instrument is OPERABLE, including all components in the channel, such as alarms, interlocks, displays, and trip functions, required to perform the specified safety function(s). The INSTRUMENT FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested.

B.4 INSTRUMENT CHECK - the qualitative determination of operability by observation of behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.

B.5 OPERABLE - An instrument shall be OPERABLE when it is capable of performing its specified functions(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).

B.6 REAL MEMBER OF THE PUBLIC - an individual, not occupationally associated with the Millstone site, who is exposed to existing dose pathways at one particular location. This does not include employees of the utility or utilities which own a Millstone plant and utility contractors and vendors. Also excluded are persons who enter the Millstone site to service equipment or to make deliveries. This does include persons who use portions of the Millstone site for recreational, occupational, or other purposes not associated with any of the Millstone plants.

B.7 SITE BOUNDARY - that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

B.8 SOURCE CHECK - the qualitative assessment of channel response when the channel is exposed to radiation.

B.9 RADIOACTIVE WASTE TREATMENT SYSTEMS - Radioactive Waste Treatment Systems are those liquid, gaseous, and solid waste systems which are required to maintain control over radioactive materials in order to meet the controls set forth in this section.

111.1-1

REMODCM Unit One Controls Revision 20 III.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation CONTROLS The radioactive liquid effluent monitoring instrumentation channels shown in Table III.C-1 shall be OPERABLE with applicable alarm/trip setpoints set to ensure that the limits of Control III.D.1 .a are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II.

APPLICABILITY As shown in Table II1.C-1 ACTION:

1. In the event of a control requirement for operation and/or associated action requirement cannot be satisfied, this shall not require unit shutdown or prevent a change in operational modes.

2. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above control, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

3. With the number of channels less than the minimum channels OPERABLE requirement, take the action shown in Table III.C-1. Exert best efforts to restore the inoperable monitor to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the INSTRUMENT CHECK, INSTRUMENT CALIBRATION, INSTRUMENT FUNCTIONAL TEST, and SOURCE CHECK operations at the frequencies shown in Table II1.C-2.

Ill.C- 1

REMODCM Unit One Controls Revision 20 TABLE III.C-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Alarm Minimum # Setpoints Instrument Operable Required Applicability Action

1. Gross Radioactivity Monitors Providing Automatic Termination Of Release

a. Liquid Radwaste 1 Yes

A Effluent Line

2. Gross Radioactivity Monitors Not Providing Automatic Termination Of Release

a. Service Water 1 Yes

B Effluent Line

3. Flow Rate Measurement Devices

a. Liquid Radwaste 1 No

C

b. Dilution water **

No

NA Flow

At all times - which means that channels be OPERABLE and in service on a continuous, uninterrupted basis, except that outages are permitted, within the time limit of the specified ACTION statement, for the purpose of maintenance and performance of required test, checks and calibrations.

- Dilution water flow is determined by the use of condenser cooling water and service water pump status. Only those pumps actually discharging to the quarry at the time of the release are included. Pump status is only reviewed for purpose of determining flows.

NA - Not Applicable Ill.C- 2

REMODCM Unit One Controls Revision 20 TABLE II1.C-1 (Continued)

ACTION STATEMENTS Action A With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

1. At least two samples of the tank to be discharged are analyzed in accordance with Controls III.D.1.a and;

2. The original release rate calculations and discharge valving are independently verified by a second individual.

Action B With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that daily grab samples are collected and analyzed for gross radioactivity (beta or gamma) at the effluent LLD of 5 x 10-7 uCi/gm.

Action C With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases. Pump performance curves may be used to estimate flow.

Ill.C- 3

REMODCM Unit One Controls Revision 20 TABLE Ii1.C-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Instrument Instrument Instrument Functional Source Instrument Check Calibration Test Check

1. Gross Radioactivity Monitors Providing Alarm And Automatic Termination Of Release

a. Liquid Radwaste D(1) R(2) Q(3) P Effluent Line

2. Gross Radioactivity Monitors Providing Alarm But Not Providing Automatic Termination Of Release

a. Service Water D(1) R(2) Q(3) Q Effluent Line

3. Flow Rate Measurement Devices

a. Liquid Radwaste D(1) R Q(5) NA Effluent Line

b. Dilution Water Flow P(4) NA NA NA D = Daily M = Monthly P = Prior to each batch release R = Once every 18 months Q = Once every 3 months NA = Not Applicable III.C- 4

REMODCM Unit One Controls Revision 20 TABLE II1.C-2 (Continued)

TABLE NOTATION (1) Instrument Check shall consist of verifying indication of radiation or flow readings during periods of discharge. Instrument check need only be performed daily when discharges are made from this pathway.

(2) Calibration shall include the use of a radioactive solid source, the activity of which can be traced to an NIST source. The radioactive source shall be in a known, reproducible geometry.

(3) The INSTRUMENT FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

1. Instrument indicates measured levels above the alarm/trip setpoint.*

2. Instrument indicates a downscale failure or circuit failure.

3. Instrument controls not set in operate mode.

Automatic isolation shall also be demonstrated for the liquid radwaste effluent line.

(4) Pump status should be checked.

(5) The quarterly functional test for the liquid radwaste flow monitor shall consist only of a comparison of the calculated volumes discharged by using the measured flow rate versus the tank level decrease. This surveillance is not required if no waste was discharged during the quarter.

Ill.C- 5

REMODCM Unit One Controls Revision 20 III.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION (Cont'd)

2. Radioactive Gaseous Effluent Monitoring Instrumentation CONTROLS The radioactive gaseous effluent monitoring instrumentation channels shown in Table II1.C-3 shall be OPERABLE with applicable alarm/trip setpoints set to ensure that the limits of Control III.D.2.a are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Sections II.F.3 and II.F.4.

Applicability: As shown in Table III.C-3.

Action:

a. With a radioactive gaseous effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Control, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels operable requirements, take the action shown in Table II1.C-3. Exert best efforts to restore the inoperable monitor to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radiological Effluent Release Report why the inoperability was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the INSTRUMENT CHECK, INSTRUMENT CALIBRATION, INSTRUMENT FUNCTIONAL TEST, and SOURCE CHECK operations at the frequencies shown in Table III.C-4.

Ill.C- 6

REMODCM Unit One Controls Revision 20 TABLE III.C-3 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum # Alarm Instrument Operable Setpoints Applicability Action MP1 Main Stack (a) Noble Gas Activity Monitor 1 Yes

C (b) Iodine Sampler 1 No

D (c) Particulate Sampler 1 No

D (d) Stack Flow Rate No

E Monitor 1 (e) Sampler Flow Rate Yes

E Monitor At all times - which means that channels be OPERABLE and in service on a continuous, uninterrupted basis, except that outages are permitted, within the time frame of the specified ACTION statement, for the purpose of maintenance and performance of required test, checks and calibrations.

III.C-7

REMODCM Unit One Controls Revision 20 TABLE III.C-3 (Continued)

ACTION STATEMENTS Action A RESERVED Action B RESERVED Action C With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Action D With the number of samplers OPERABLE less than required by the Minimum number OPERABLE requirement, effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that samples are continuously collected with auxiliary sampling equipment for periods of seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after the end of the sampling period.

Action E With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

III.C-8

REMODCM Unit One Controls Revision 20 Table III.C-4 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Instrument Instrument Instrument Functional Source Instrument Check Calibration Test Check MP1 MAIN STACK (a) Noble Gas Activity D(3) R(6) Q(7) M Monitor (b) Iodine Sampler W NA NA NA (c) Particulate Sampler W NA NA NA (d) Stack Flow Rate Monitor D R NA NA Monitor (e) Sampler Flow Rate D R NA NA Monitor D = Daily W = Weekly M = Monthly R = Once every 18 months Q = Once every 3 months NA = Not Applicable III.C-9

REMODCM Unit One Controls Revision 20 Table II1.C-4 (Continued)

TABLE NOTATION (1) RESERVED (2) RESERVED (3) Instrument check daily only when there exist releases via this pathway.

(4) RESERVED (5) RESERVED (6) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to an NIST source. These sources shall be in a known reproducible geometry.

(7) The INSTRUMENT FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

1. Instrument indicates measured levels above the alarm/trip setpoint.

2. Instrument indicates a downscale failure.

3. Instrument controls not set in operate mode.

11I.C- 10

REMODCM Unit One Controls Revision 20 HI.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION (Cont'd) 3.Section reserved Ill.c- 11

REMODCM Unit One Controls Revision 20 III.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION (Cont'd)

4. Section reserved 1.

III.C- 12

REMODCM Unit One Controls Revision 20 III.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION (Cont'd)

5. High Range Stack Noble Gas Monitor CONTROLS The MP1 stack high range noble gas effluent monitor shall be OPERABLE.

APPLICABILITY:

At all times which means that the monitor shall be OPERABLE on a continuous basis, except that outages are permitted, within the time frame of the specified action statement, for the purpose of maintenance and performance of required tests, check and calibrations.

ACTION:

If the stack high range noble gas monitor is not OPERABLE then initiate a preplanned alternate method of monitoring noble gas effluents within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and either restore the inoperable monitor to OPERABLE status within 7 days or prepare and submit a special report to the Commission within 14 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the monitor to OPERABLE status.

SURVEILLANCE REQUIREMENT The monitor shall be demonstrated OPERABLE by performance of a CHANNEL CHECK on a monthly frequency and performance of a CHANNEL CALIBRATION once per refueling cycle.

IlI.C- 13

REMODCM Unit One Controls Revision 20 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

1. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations CONTROLS The concentration of radioactive material released from the site (see Figure IlI.D-1) shall not exceed the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radionuclides.

APPLICABILITY: At all times.

ACTION:

With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration within the above limits within 15 minutes.

SURVEILLANCE REQUIREMENT

1. Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I.

2. The results of the radioactive analysis shall be used in accordance with the methods of Section 11to assure that the concentrations at the point of release are maintained within the limits of Control III.D.1.a.

III.D-1

REMODCM Unit One Controls Revision 20 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

1. Radioactive Liquid Effluents (Cont'd)

b. Radioactive Liquid Effluents Doses CONTROLS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 1 released from the site (see Figure Ill.D-1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and,

b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents during the remainder of the current calendar quarter and the calendar year so that the cumulative dose or dose commitment to any REAL MEMBER OF THE PUBLIC from such releases during the calendar year is within 3 mrem to the total body and 10 mrem to any organ.

SURVEILANCE REQUIREMENTS

1. Dose Calculations. Cumulative dose contributions from liquid effluents shall be determined in accordance with Section II once per 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

Ill.D-2

REMODCM Unit One Controls Revision 20 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate CONTROLS The instantaneous dose rate offsite (see Figure Ill.D-1) due to radioactive materials released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and,

b. The dose rate limit for Iodine-131, Iodine-133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

APPLICABILITY: At all times.

ACTION:

With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Control III.D.2.a within 15 minutes.

SURVEILLANCE REQUIREMENTS

1. The instantaneous release rate corresponding to the above dose rate shall be determined in accordance with the methodology of Section II.

2. The instantaneous release rate shall be monitored in accordance with the requirements of Table Ill.D-4.

3. Sampling and analysis shall be performed in accordance with Section I to assure that the limits of Control III.D.2.a are met.

Ill.D-3

REMODCM Unit One Controls Revision 20 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

2. Radioactive Gaseous Effluents (Cont'd)

b. Radioactive Gaseous Effluents Noble Gas Dose CONTROLS The air dose offsite (see Figure IIl.D-1) due to noble gases released in gaseous effluents from Unit 1 shall be limited to the following:

a. During any calendar quarter, to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;

b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY: At all times.

ACTION:

With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents during the remainder of the current calendar quarter and the calendar year so that the cumulative dose during the calendar year is within 10 mrad for gamma radiation and 20 mrad for beta radiation.

SURVEILLANCE REQUIREMENTS

1. Dose Calculations - Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

Ill.D-4

REMODCM Unit One Controls Revision 20 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

2. Radioactive Gaseous Effluents (Cont'd)

c. Gaseous Effluents - Dose from Radionuclides Other than Noble Gas CONTROLS The dose to any REAL MEMBER OF THE PUBLIC from Tritium and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 1 (see Figure Ill.D-1) shall be limited to the following:

a. During any calendar quarter to less than or equal to 7.5 mrem [to any organ];

b. During any calendar year to less than or equal to 15 mrem [to any organ].

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of Tritium and radioactive materials in particulate form exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases during the remainder of the current calendar quarter and during the remainder of the calendar year so that the cumulative dose or dose commitment to any REAL MEMBER OF THE PUBLIC from such releases during the calendar year is within 15 mrem to any organ.

SURVEILLANCE REQUIREMENTS

1. Dose Calculations - Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

Ill.D-5

REMODCM Unit 1 Controls Revision 20 I

1) 0--c 0w V

- 1,o C, 0'

/ -

6

.1 f,

Z.

.3

-D Figure IIi.D-1 Site Boundary for Liquid and Gaseous Effluents III.D-6

REMODCM Unit One Controls Revision 20 III.E. TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS CONTROLS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which is limited to less than or equal to 75 mrem) over a period of 12 consecutive months.

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls IIl.D.l.b, III.D.2.b, or IIl.D.2.c prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR Part 190 Standard.

If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days.

III.E-1

REMODCM Unit One Controls Revision 20 III.F. BASES Section III.C.1 - Radioactive Liquid Effluent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The alarm/trip setpoints for these instruments shall be calculated in accordance with the approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

Section III.C.2 - Radioactive Gaseous Effluent Monitorinq Instrumentation The Site Stack is the only gaseous pathway currently requiring radiation monitoring for Unit 1.

Most of the operability and surveillance requirements for stack gaseous monitoring instrumentation are contained in Units 2 and 3 Technical Specifications. Requirements for a sampler flow rate alarm and noble gas monitor functional alarm testing when controls are not set in operate mode are unique Unit I requirements which need to be specified in the REMODCM.

Ill.F-1

REMODCM Unit One Controls Revision 20 Section III.D.1.a - Radioactive Liquid Effluents Concentrations This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II. This instantaneous limitation provides additional assurance that the levels of radioactive materials in bodies of water outside the site will result in exposures within: (1) the Section I.A design objectives of Appendix 1, 10 CFR Part 50, to an individual and (2) the limits of 10 CFR 20.106(e) to the population. The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-1 35 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

Section III.D.1.b - Radioactive Liquid Effluents Doses This control is provided to implement the requirements of Sections II.A, Ill.A, and IV.A of Appendix I, 10 CFR Part 50. The control implements the guides set forth in Section II.A of Appendix I. The Action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable".

The dose calculations in the ODCM implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I is to be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977, and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I,"

April 1977.

Section Ill.D.2.a - Radioactive Gaseous Effluents Dose Rate This control is provided to ensure that the dose rate at anytime from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for all areas offsite.

The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table II. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual offsite to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR 20.106(b)). For individuals who may, at times, be within the site boundary, the occupancy of that individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the site boundary. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual at or beyond the site boundary to less than or equal to 500 mrem/year to the total body or to less than or equal to 3000 mrem/year to the skin.

These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to an infant via the cow-milk-infant pathway to less than or equal to 1500 mrem/year for the nearest cow to the plant.

Ill.F-2

REMODCM Unit One Controls Revision 20 Section III.D.2.b - Radioactive Gaseous Effluents Noble Gas Dose This control is provided to implement the requirements of Sections ll.B., III.A and IV.A of Appendix I, 10 CFR Part 50. The control implements the guides set forth in Section II.B of Appendix I. The action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section IIL.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109, "Calculational of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977.

The ODCM equations provided for determining the air doses at the site boundary were based upon utilizing successively more realistic dose calculational methodologies.

More realistic dose calculational methods are used whenever simplified calculations indicate a dose approaching a substantial portion of the regulatory limits. The methods used are, in order, previously determined air dose per released activity ratio, historical meteorological data and actual radionuclide mix released, or real time meteorology and actual radionuclides released.

lIl.F-3

REMODCM Unit One Controls Revision 20 Section III.D.2.c - Radioactive Gaseous Effluents Radio-iodines, Particulates, and Gas Other Than Noble Gas Doses These controls is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix 1, 10 CFR Part 50. The controls are the guides set forth in Section II.C of Appendix I. The action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section III.A of Appendix I that conformance with the guides for Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methods for calculating the doses due to the actual release rates of the subject materials will to be consistent with the methodology provided in Regulatory Guide 1.109, "Calculating of Annual Dose to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

Revision I, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision I, July 1977. These equations provide for determining the doses based upon either conservative atmospheric dispersion and an assumed critical nuclide mix or using real time meteorology and specific nuclides released. The release rate specifications for radio-iodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man. The pathways which are examined in the development of these calculations are: 1) individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man.

Section III.E - Total Radioloqical Dose from Station Operations This control is provided to meet the reporting requirements of 40 CFR Part 190. For the purpose of the Special Report, it may be assumed that the dose commitment to any REAL MEMBER OF THE PUBLIC from other fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 5 miles must be considered.

III.F-4

SECTION IV MILLSTONE UNIT 2 RADIOLOGICAL EFFLUENT CONTROLS DOCKET NO. 50-336 Revision 20 January 25, 2001

REMODCM Unit Two Controls Revision 20 MILLSTONE STA TION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTION IV: MILLSTONE UNIT TWO RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS SECTION PAGE NO.

TABLE OF CONTENTS IV-i IV.A. INTRODUCTION IV.A-1 IV.B. DEFINITIONS IV.B-1 IV.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation IV.C-1

2. Radioactive Gaseous Effluent Monitoring Instrumentation IV.C-7 IV.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

1. Radioactive Liquid Effluents IV.D-1

a. Radioactive Liquid Effluents Concentrations IV.D-1

b. Radioactive Liquid Effluents Doses IV.D-2

2. Radioactive Gaseous Effluents IV.D-3

a. Radioactive Gaseous Effluents Dose Rate 1V.D-3

b. Radioactive Gaseous Effluents Noble Gas Dose IV.D-4

c. Radioactive Gaseous Effluents IV.D-5

- Doses from Radionuclides Other Than Noble Gas IV.E. TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS IV.E-1 IV.F. BASES IV.F-1 IV- i

REMODCM Unit Two Controls Revision 20 MILLSTONE STA TION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTIONIV: MILLSTONE UNIT TWO RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS (Cont'd)

Table Number Table Name Page IV.C-1 Radioactive Liquid Effluent Monitoring Instrumentation IV.C-2 IV.C-2 Radioactive Liquid Effluent Monitoring Instrumentation IV.C-5 Surveillance Requirements IV.C-3 Radioactive Gaseous Effluent Monitoring Instrumentation IV.C-8 1V.C-4 Radioactive Gaseous Effluent Monitoring Instrumentation IV.C-l 0 Surveillance Requirements Figure Number Figure Name Page IV.D-1 Site boundary IV.D-6 IV- ii

REMODCM Unit Two Controls Revision 20 IV.A. INTRODUCTION The purpose of this section is to provide the following for Millstone Unit Two:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions.

IV.A-1

REMODCM Unit Two Controls Revision 20 IV.B DEFINITIONS The defined terms of this sub-section appear in capitalized type and are applicable throughout Section IV.

B.1 ACTION ACTION shall be those additional requirements specified as corollary statements to each principal control and shall be part of the control.

B.2 OPERABLE - OPERABILITY An instrument shall be OPERABLE or have OPERABILITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation, controls, normal and emergency electrical power sources, or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).

B.3 CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to know values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

B.4 CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

B.5 CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY including alarm and/or trip functions.

B.6 SOURCE CHECK A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.

B.7 MEMBER(S) OF THE PUBLIC MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.

IV.B-1

REMODCM Unit Two Controls Revision 20 B.8 SITE BOUNDARY The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

B.9 UNRESTRICTED AREA An UNRESTRICTED AREA shall be any area at or beyond the site boundary to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the site boundary used for residential quarters or industrial, commercial, institutional and/or recreational purposes.

B.10 DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microCurie/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Regulatory Guide 1.109 Rev. 1, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluent for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I.

IV.B-2

REMODCM Unit Two Controls Revision 20 IV.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS FOR OPERATION The radioactive liquid effluent monitoring instrumentation channels shown in Table IV.C-1 shall be OPERABLE with applicable alarm/trip setpoints set to ensure that the limits of Specification IV.D.I.a are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II.

APPLICABILITY As shown in Table IV.C-1 ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels OPERABLE requirement, take the action shown in Table IV.C-1. Exert best efforts to restore the inoperable monitor to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

Releases need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C-2.

IV.C-1

REMODCM Unit Two Controls Revision 20 TABLE IV.C-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Alarm Minimum # Setpoints Instrument Operabile Required Applicability .ction

1. Gross Radioactivity Monitors Providing Automatic Termination Of Release

a. Clean Liquid Radwaste 1 Yes A Effluent Line

b. Aerated Liquid Radwaste 1 Yes A Effluent Line

c. Steam Generator Blowdown 1 Yes B Monitor

d. Condensate Polishing Facility 1 Yes A Waste Neut Sump

2. Gross Radioactivity Monitors Not Providing Automatic Termination Of Release

a. Reactor Building Closed Cooling 1 Yes C Water Monitor

3. Flow Rate Measurements

a. Clean Liquid Radwaste 1 No D Effluent Line

b. Aerated Liquid Radwaste 1 No D Effluent Line

c. Condensate Polishing Facility 1 No

D

d. Dilution Water Flow ## No NA

e. Steam Generator Blowdown line ### No NA IV.C-2

REMODCM Unit Two Controls Revision 20 TABLE IV.C-1 (Continued)

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Table Notes At all times - which means that channels shall be OPERABLE and in service on a continuous, uninterrupted basis, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.

- Deleted.

Modes 1-6 when pathway is being used except that outages are permitted, for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.

Modes 1-4, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.

Since the only source of service water contamination is the reactor building closed cooling water, monitoring of the closed cooling water and conservative leakage assumptions will provide adequate control of service water effluents.

1. The dilution water is determined by the use of condenser cooling water and service water pump status. Only those pumps actually discharging to the quarry at the time of the release are included. Pump status is only reviewed for purpose of determining flows.

1. 1. Determined by the use of valve curves and/or make up flow rates for the purpose of determining flows only.

NA Not Applicable IV.C-3

REMODCM Unit Two Controls Revision 20 TABLE IV.C-1 (Continued)

ACTION STATEMENTS Action A With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

1. At least two independent samples are analyzed in accordance with the first Surveillance Requirement of Specification IV.D.1 .a and;

2. The original release rate calculations and discharge valving are independently verified by a second individual.

Action B With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, either:

1. Suspend all effluent releases via this pathway, or

2. Make best efforts to repair the instrument and obtain grab samples and analyze for gross radioactivity (beta or gamma) at a lower limit of detection of at least 3 x 10.7 uCi/mI;

a. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the specific activity of the secondary coolant is greater than 0.01 uCi/gm DOSE EQUIVALENT 1-131.

b. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the specific activity of the secondary coolant is less than or equal to 0.01 uCi/gm DOSE EQUIVALENT 1-131.

Action C With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months grab samples of the service water effluent are collected and analyzed for gross radioactivity (beta or gamma) at a lower limit of detection of at least 3 x l0e ptCi/gm.

Action D With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases.

Pump performance curves may be used to estimate flow.

IV.C-4

REMODCM Unit Two Controls Revision 20 TABLE IV.C-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Instrument Check Check Calibration Test

1. Gross Radioactivity Monitors Providing Alarm And Automatic Termination Of Release

a. Clean Liquid Radwaste D* P R(1) Q(2)

Effluent Line

b. Aerated Liquid Radwaste D* P R(1) Q(2)

Effluent Line

c. Steam Generator Blowdown D* M R(1) Q(2)

Monitor

d. Condensate Polishing Facility D* P R(1) Q(2)

Waste Neut Sump

2. Gross Radioactivity Monitors Providing Alarm But Not Providing Automatic Termination Of Release

a. Reactor Building D* M R(1) Q(2)

Closed Cooling Water

3. Flow Rate Measurement Devices

a. Clean Liquid Radwaste Line D* NA R Q

b. Aerated Liquid Radwaste Line D* NA R Q

c. Condensate Polishing Facility D* NA R Q Waste Neut Sump Line

d. Dilution Water Flow D(4) NA NA NA

e. Steam Generator Blowdown D(4) NA NA NA line D = Daily M = Monthly P = Prior to each batch release R = Once every 18 months Q = Once every 3 months NA = Not Applicable IV.C-5

REMODCM Unit Two Controls Revision 20 TABLE IV.C-2 (Continued)

TABLE NOTATION During releases via this pathway and when the monitor is required OPERABLE per Table IV.C-1. The CHANNEL CHECK should be done when the discharge is in progress.

(1) Calibration shall include the use of a known radioactive liquid or solid source which is traceable to an NBS source.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

a. Instrument indicates measured levels above the alarm/trip setpoint.

b. Instrument indicates a downscale or circuit failure.

- Automatic isolation of the discharge stream shall also be demonstrated for this case for each monitor except the reactor building closed cooling water monitor.

(3) Deleted (4) Pump or valve status, as appropriate, should be checked daily for the purposes of determining flow rates.

IV.C-6

REMODCM Unit Two Controls Revision 20 LV.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION (Cont'd)

2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS FOR OPERATION The radioactive gaseous effluent monitoring instrumentation channels shown in Table IV.C-3 shall be OPERABLE with applicable alarm/trip setpoints set to ensure that the limits of Specification IV.D.2.a are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section I1.

Applicability: As shown in Table IV.C-3.

Action:

a. With a radioactive gaseous effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels OPERABLE requirement, take the action shown in Table IV.C-3. Exert best efforts to restore the inoperable monitor to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C-4.

IV.C-7

REMODCM Unit Two Controls Revision 20 TABLE IV.C-3 RADIOACTIVE GASEOUS EFFLUENT INSTRUMENTATION Minimum Alarm Channels Setpoints Instrument Ope rable Required Applicability Action

1. MP2 STACK

a. Noble Gas Activity Monitor 1 Yes*** A

b. Iodine Sampler 1 No B

c. Particulate Sampler 1 No B

d. Stack Flow Rate Monitor 1 No C

e. Sampler Flow Rate Monitor 1 No C

2. MP1 MAIN STACK (a) Noble Gas Activity Monitor 1 Yes*** E (b) Iodine Sampler 1 No B (c) Particulate Sampler 1 No B (d) Stack Flow Rate Monitor 1 No C (e) Sampler Flow Rate Monitor 1 No C

3. Waste Gas Holdup System Noble Gas Monitor Providing Automatic Termination of Release 1 Yes D

During waste gas holdup system discharge.

- At all times which means that channels be OPERABLE and in service on a continuous, uninterrupted basis, except that outages are permitted for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling.

No automatic isolation features.

IV.C-8

REMODCM Unit Two Controls Revision 20 TABLE IV.C-3 (Continued)

ACTION STATEMENTS Action A With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Action B With the number of channels OPERABLE less than required by the Minimum number OPERABLE requirements, effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that samples are continuously collected with auxiliary sampling equipment for periods of seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of initiation of this action statement.

Action C With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Action D With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement:

Releases from the Millstone Unit 2 waste gas system may continue provided that best efforts are made to repair the instrument and that prior to initiating the release:

(a) At least two independent samples of the tank's contents are analyzed; and (b) The original release rate calculations and discharge valve lineups are independently verified by a second individual.

Otherwise, suspend releases from the waste gas holdup system.

Action E With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, Millstone Unit 2 releases via the Millstone Unit 1 stack may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months IV.C-9

REMODCM Unit Two Controls Revision 20 Table IV.C-4 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Instrument Check Check Calibration Test

1. MP2 Stack

a. Noble Gas Activity Monitor D M R(1) Q(2)

b. Iodine Sampler W NA NA NA

c. Particulate Sampler W NA NA NA

d. Stack Flow Rate Monitor D NA R Q

e. Sampler Flow Rate Monitor D NA R NA

2. MP1 MAIN STACK (a) Noble Gas Activity D M R(1) Q(2)

Monitor (b) Iodine Sampler W NA NA NA (c) Particulate Sampler W NA NA NA (d) Stack Flow Rate Monitor D NA R Q(2)

Monitor (e) Sampler Flow Rate D NA R NA Monitor

3. WASTE GAS SYSTEM NOBLE GAS MONITOR D* P R(1) Q(2)

During releases via this pathway and when the monitor is required OPERABLE per Table IV.C-3. The CHANNEL CHECK should be performed when the discharge is in progress.

D = Daily R = Once every 18 months W = Weekly Q = Once every 3 months M = Monthly NA = Not Applicable IV.C-0

REMODCM Unit Two Controls Revision 20 Table IV.C-4 (Continued)

TABLE NOTATION (1) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to an NBS source. These sources shall be in a known, reproducible geometry.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation* occurs if any of the following conditions exist:

a. Instrument indicates measured levels above the alarm/trip setpoint.

b. Instrument indicates a downscale failure.

- Also demonstrate automatic isolation for the waste gas system noble gas monitor.

IV.C41

REMODCM Unit Two Controls Revision 20 IV.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

1. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS FOR OPERATION The concentration of radioactive material released from the site (see Figure IV.D-1) shall not exceed the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 10-4 [1Ci/ml total activity.

APPLICABILITY: At all times.

ACTION:

With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes.

SURVEILLANCE REQUIREMENT

1. Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I.

2. The results of the radioactive analysis shall be used in accordance with the methods of Section II to assure that the concentrations at the point of release are maintained within the limits of Specification IV.D.1 .a.

IV.D-1

REMODCM Unit Two Controls Revision 20 IV.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

1. Radioactive Liquid Effluents (Cont'd)

b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS FOR OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 2 released from the site (see Figure IV.D-1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and,

b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents during the remainder of the current calendar quarter and during the remainder of the calendar year so that the cumulative dose or dose commitment to any REAL MEMBER OF THE PUBLIC from such releases during the calendar year is within 3 mrem to the total body and 10 mrem to any organ.

SURVEILANCE REQUIREMENTS

1. Dose Calculations. Cumulative dose contributions from liquid effluents shall be determined in accordance with Section II.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

IV.D-2

REMODCM Unit Two Controls Revision 20 IV.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS FOR OPERATION The dose rate, at any time, offsite (see Figure IV.D-1) due to radioactive materials released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and,

b. The dose rate limit for Iodine-1 31, iodine-1 33, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

APPLICABILITY: At all times.

ACTION:

With the dose rate(s) exceeding the above limits, decrease the release rate within 15 minutes to comply with the limit(s) given in Specification IV.D.2.a.

SURVEILLANCE REQUIREMENTS

1. The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established above in Specification IV.D.2.a.

The corresponding release rate shall be determined in accordance with the methodology of Section II.

2. The noble gas effluent monitors of Table IV.C-3 shall be used to control release rates to limit offsite doses within the values established in Specification IV.D.2.a.

3. The release rate of radioactive materials in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Section I. The corresponding dose rate shall be determined using the methodology given in Section II.

IV.D-3

REMODCM Unit Two Controls Revision 20 IV.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

2. Radioactive Gaseous Effluents (Cont'd)

b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS FOR OPERATION The air dose offsite (see Figure IV.D-1) due to noble gases released in gaseous effluents from Unit 2 shall be limited to the following:

a. During any calendar quarter, to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;

b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY: At all times.

ACTION:

a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents during the remainder of the current calendar quarter and during the remainder of the calendar year so that the cumulative dose during the calendar year is within 10 mrad for gamma radiation and 20 mrad for beta radiation.

SURVEILLANCE REQUIREMENTS

1. Dose Calculations - Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

IV.D-4

REMODCM Unit Two Controls Revision 20 IV.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

2. Radioactive Gaseous Effluents (Cont'd)

c. Gaseous Effluents - Dose, Radioiodines, Radioactive Material in Particulate Form, and Radionuclides Other than Noble Gases LIMITING CONDITIONS FOR OPERATION The dose to any REAL MEMBER OF THE PUBLIC from Iodine-131, Iodine-1 33, Tritium, and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents from Unit 2 released offsite (see Figure IV.D-l) shall be limited to the following:

a. During any calendar quarter to less than or equal to 7.5 mrem to any organ;

b. During any calendar year to less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases during the remainder of the current calendar quarter and during the remainder of the calendar year so that the cumulative dose or dose commitment to any REAL MEMBER OF THE PUBLIC from such releases during the calendar year is within 15 mrem to any organ.

SURVEILLANCE REQUIREMENTS

1. Dose Calculations - Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

IV.D-5

REMODCM Unit Two Controls Revision 21D Figure IV.D-1 Site Boundary for Liquid and Gaseous Effluents IV.D-6

REMODCM Unit Two Controls Revision 20 IV.E. TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS LIMITING CONDITIONS FOR OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which is limited to less than or equal to 75 mrem) over a period of 12 consecutive months.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specifications IV.D.1.b, IV.D.2.b, or IV.D.2.c, prepare and submit a Special Report to the Commission and limit the subsequent releases such that the dose or dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR Part 190 Standard. If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Surveillance Requirement 1 of Specifications IV.D.I.b, IV.D.2.b, and IV.D.2.c, and in accordance with Section II once per 31 days.

IV.E-1

REMODCM Unit Two Controls Revision 20 IV.F. BASES Section IV.C.1 - Radioactive Liquid Effluent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases. The alarm/trip setpoints for these instruments shall be calculated in accordance with the approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. Monitoring of the turbine building sumps and condensate polishing facility floor drains is not required due to relatively low concentrations of radioactivity possible.

Section IV.C.2 - Radioactive Gaseous Effluent Monitoringq Instrumentation The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases. The alarm/trip setpoints for these instruments shall be calculated in accordance with the approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

Two types of radioactive gaseous effluent monitoring instrumentation, monitors and samplers, are being used at MP2 stack and MP1 main stack. Monitors have alarm/trip setpoints and are demonstrated operable by performing one or more of the following operations: CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST. Samplers are strictly collection devices made of canisters and filters. The CHANNEL CHECK surveillance requirements are met through (1) documented observation of the in-service rad monitor sample flow prior to filter replacement; (2) documented replacement of in-line iodine and particulate filters; and (3) documented observation of sample flow following the sampler return to service. The flow indicator is the only indication available for comparison. These observations adequately provide assurance that the sampler is operating and is capable of performing its design function.

There are a number of gaseous release points which could exhibit very low concentrations of radioactivity. For all of these release paths, dose consequences would be insignificant due to the intermittent nature of the release and/or the extremely low concentrations of radioactivity. Since it is not cost-beneficial (nor in many cases practical due to the nature of the release (steam) or the impossibility of detecting such low levels), to monitor these pathways, it has been determined that these release paths require no monitoring nor sampling.

IV.F- I

REMODCM Unit Two Controls Revision 20 Section IV.D.1.a - Radioactive Liquid Effluents Concentrations This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II. This limitation provides additional assurance that the levels of radioactive materials in bodies of water outside the site will result in exposures within: (1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, to an individual and (2) the limits of 10 CFR 20.106(e) to the population.

The concentration limit for noble gases is based upon the assumption that Xe-1 35 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

Section IV.D.1.b - Radioactive Liquid Effluents Doses This specification is provided to implement the requirements of Sections II.A, Ill.A, and IV.A of Appendix 1, 10 CFR Part 50. The Limiting Condition For Operation implements the guides set forth in Section lI.A of Appendix I. The Action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable". The dose calculations in the ODCM implement the requirements in Section IV.A of Appendix I that conformance with the guides of Appendix I is to be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents will be consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977, and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I,", April 1977.

Section IV.D.2.a - Radioactive Gaseous Effluents Dose Rate This specification is provided to ensure that the dose rate at anytime from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for all areas offsite. The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table I1. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual offsite to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR 20.106(b)). For individuals who may, at times, be within the site boundary, the occupancy of that individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above background to an individual at or beyond the site boundary to less than or equal to 500 mrem/year to the total body or to less than or equal to 3000 mrem/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid or any other organ dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year.

IV.F- 2

REMODCM Unit Two Controls Revision 20 Section IV.D.2.b - Radioactive Gaseous Effluents Noble Gas Dose This specification is provided to implement the requirements of Sections ll.B., III.A and IV.A of Appendix I, 10 CFR Part 50. The Limiting Condition For Operation implements the guides set forth in Section 1.13 of Appendix I. The action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section IIL.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated.

The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109, "Calculational of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977.

The ODCM equations provided for determining the air doses at the site boundary are based upon utilizing successively more realistic dose calculational methodologies. More realistic dose calculational methods are used whenever simplified calculations indicate a dose approaching a substantial portion of the regulatory limits. The methods used are previously determined air dose per released activity ratio, historical meteorological data and actual radionuclide mix released, or real time meteorology and actual radionuclides released.

Section IV.D.2.c - Radioactive Gaseous Effluents Other Than Noble Gas Doses This specification is provided to implement the requirements of Sections II.C, IIL.A and IV.A of Appendix 1, 10 CFR Part 50. The Limiting Conditions For Operation are the guides set forth in Section II.C of Appendix I. The action statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section IIL.A of Appendix I that conformance with the guides for Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methods for calculating the doses due to the actual release rates of the subject materials will to be consistent with the methodology provided in Regulatory Guide 1.109, "Calculating of Annual Dose to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977. The release rate specifications for radioiodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man. The pathways which are examined in the development of these calculations are: 1) individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man.

IV.F- 3

REMODCM Unit Two Controls Revision 20 Section IV.E - Total Radiological Dose from Station Operations This specification is provided to meet the reporting requirements of 40 CFR Part 190. For the purpose of the Special Report, it may be assumed that the dose commitment to any REAL MEMBER OF THE PUBLIC from other fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 5 miles must be considered.

I.E- 4

SECTION V MILLSTONE UNIT 3 RADIOLOGICAL EFFLUENT CONTROLS DOCKET NO. 50-423 Revision 20 January 25, 2001

REMODCM Unit Three Controls Revision 20 MILLSTONE STATION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTION V MILLSTONE UNIT THREE RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS SECTION PAGE NO.

TABLE OF CONTENTS V-i V.A. INTRODUCTION V.A-1 V.B. DEFINITIONS V.B-1 V.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation V.C-1

2. Radioactive Gaseous Effluent Monitoring Instrumentation V.C-6 V.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS I. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations V.C-1

b. Radioactive Liquid Effluents Doses V.C-2

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate V.C-3

b. Radioactive Gaseous Effluents Noble Gas Dose V.C-4

c. Radioactive Gaseous Effluents V.C-5

- Doses from Radionuclides Other Than Noble Gas V.E TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS V.E-1 V.F. BASES V.F-1 V-i

REMODCM Unit Three Controls Revision 20 MILLSTONE STATION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTION V: MILLSTONE UNIT THREE RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS (Cont'd)

Table Number Table Name Page V.C-I Radioactive Liquid Effluent Monitoring Instrumentation V.C-2 V.C-2 Radioactive Liquid Effluent Monitoring Instrumentation V.C-5 Surveillance Requirements V.C-3 Radioactive Gaseous Effluent Monitoring Instrumentation V.C-8 V.C-4 Radioactive Gaseous Effluent Monitoring Instrumentation V.C-10 Surveillance Requirements Figure Number Figure Name Page V.C-1 Site boundary V.C-6 V- ii

REMODCM Unit Three Controls Revision 20 V.A. INTRODUCTION The purpose of this section is to provide the following for Millstone Unit Three:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions.

V.A-1

REMODCM Unit Three Controls Revision 20 V.B DEFINITIONS The defined terms of this sub-section appear in capitalized type and are applicable throughout Section V.

B.1 ACTION ACTION shall be that part of the control which prescribes remedial measures required under designated conditions.

B.2 ANALOG CHANNEL OPERATIONAL TEST AN ANALOG CHANNEL OPERATIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY of alarm, interlock and/or trip functions. The ANALOG CHANNEL OPERATIONAL TEST shall include adjustments, as necessary, of the alarm, interlock and/or trip setpoints such that the setpoints are within the required range and accuracy.

B.3 CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel such that it responds within the required range and accuracy to known values of input. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm, interlock and/or trip functions and may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

B.4CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

B.5 DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microCurie/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133,1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Regulatory Guide 1.109 Rev. 1, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluent for the Purpose of Evaluating Compliance with 10 CFR Part 50 Appendix I.

B.6 MEMBER(S) OF THE PUBLIC MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the licensee, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.

V.B-1

REMODCM Unit Three Controls Revision 20 B.7 OPERABLE - OPERABILITY An instrument shall be OPERABLE or have OPERABILITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation, controls, electrical power, or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).

B.9 SITE BOUNDARY The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise controlled by the licensee.

B.IOSOURCE CHECK A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.

B.1 1 UNRESTRICTED AREA An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the SITE BOUNDARY used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes.

V.B-2

REMODCM Unit Three Controls Revision 20 V.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS FOR OPERATION The radioactive liquid effluent monitoring instrumentation channels shown in Table V.C-1 shall be OPERABLE with their Alarm/Trip setpoints set to ensure that the limits of Specification V.D.1 .a are not exceeded. The alarm/trip setpoints shall be determined in accordance with methodology and parameters as described in Section II.

APPLICABILITY As shown in Table V.C-1 ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel a Alarm/Trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the action shown in Table V.C-1. Exert best efforts to restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST at the frequencies shown in Table V.C-2.

V.C- 1

REMODCM Unit Three Controls Revision 20 TABLE V.C-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Minimum Instrument Operable Applicability Action

1. Radioactivity Monitors Providing Alarm and Automatic Termination Of Release

a. Waste Neutralization Sump Monitor - 1## A Condensate Polishing Facility

b. Turbine Building Floor Drains 1 # B***

c. Liquid Waste Monitor 1 A

d. Regenerate Evaporator Monitor - 1* B Condensate Polishing Facility

e. Steam Generator Blowdown Monitor 1# B

2. Flow Rate Measurement Devices - No Alarm Setpoint Requirements

a. Waste Neutralization Sump Effluents 1 # C

b. Turbine Building Floor Drains # NA

c. Liquid Waste Effluent Line 1 # C

d. Regenerate Evaporator Effluent Line 1* # C

e. Steam Generator Blowdown Effluent Line 1 # C

f. Dilution Water Flow **# NA

NA if the Condensate Polishing Facility Regenerate Evaporator is not in service.

- Flow will be determined by pump status.

NA if the Turbine Building sump is less than MDA.

At all times - which means that channels shall be OPERABLE and in service on a continuous, uninterrupted basis, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.

1. Modes 1-5, and Mode 6 when pathway is being used, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.

V.C- 2

REMODCM Unit Three Controls Revision 20 TABLE V.C-1 (Continued)

ACTION STATEMENTS Action A With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

1. At least two independent samples are analyzed in accordance with the first Surveillance Requirement of Specification V.D.1 .a and;

2. The original release rate calculations and discharge line valving are independently verified by a second individual.

Action B With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided best efforts are made to repair the instrument and that grab samples are analyzed for gross radioactivity (beta or gamma) at a lower limit of detection of no more than 3 x 10"7 microCurie/ml:

1. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the specific activity of the secondary coolant is greater than 0.01 microCurie/gram DOSE EQUIVALENT 1-131, or

2. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the specific activity of the secondary coolant is less than or equal to 0.01 microCurie/gram DOSE EQUIVALENT 1-131.

Action C With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases.

Pump performance curves may be used to estimate flow.

V.C- 3

REMODCM Unit Three Controls Revision 20 TABLE V.C-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Analog Channel Channel Source Channel Operational Instrument Check Check Calibration Test

1. Radioactivity Monitors Providing Alarm And Automatic Termination Of Release

a. Waste Neutralization Sump Monitor D P R(2) Q(1)

Condensate Polishing Facility

b. Turbine Building Floor Drains D M R(2) Q(1)

c. Liquid Waste Monitor D P R(2) Q(1)

d. Regenerate Evaporator Monitor D M R(2) Q(1)

Condensate Polishing Facility (5)

e. Steam Generator Blowdown Monitor D M R(2) Q(1)

2. Flow Rate Measurement Devices

a. Waste Neutralization Sump Effluents D(3) NA R Q

b. Turbine Building Floor Drains D(4) NA NA NA

c. Liquid Waste Effluent Line D(3) NA R Q

d. Regenerate Evaporator Effluent Line (5) D(3) NA R Q

e. Steam Generator Blowdown Effluent Line D(3) NA R Q

f. Dilution Water Flow D(4) NA NA NA D = Daily M = Monthly P = Prior to each batch release R = Once every 18 months Q = Once every 3 months NA = Not Applicable V.C- 4

REMODCM Unit Three Controls Revision 20 TABLE V.C-2 (Continued)

TABLE NOTATION (1) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occur if any of the following conditions exists:

a. Instrument indicates measured levels above the alarm/trip setpoint, or

b. Circuit failure (Alarm only), or

c. Instrument indicates a downscale failure (Alarm only).

(2) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards (NBS) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NBS.

These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used.

(3) CHANNEL CHECK shall consist of verifying indication of flow during periods of release.

CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic, or batch releases are made.

(4) Pump status shall be checked daily for the purposes of determining flowrate.

(5) Surveillance is required only if the monitor is required to be OPERABLE by Table V.C-1.

V.C- 5

REMODCM Unit Three Controls Revision 20 V.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION (Cont'd)

2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS FOR OPERATION The radioactive gaseous effluent monitoring instrumentation channels shown in Table V.C-3 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Specifications V.D.2.a are not exceeded. The Alarm/Trip Setpoints of these channels shall be determined in accordance with the methodology and parameters in Section II.

Applicability: As shown in Table V.C-3.

Action:

a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b. With the number of OPERABLE radioactive gaseous effluent monitoring instrumentation channels less than the Minimum Channels OPERABLE, take the ACTION shown in Table V.C-3. Exert best efforts to restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and ANALOG CHANNEL OPERATIONAL TEST at the frequencies shown in Table V.C-4.

V.C- 6

REMODCM Unit Three Controls Revision 20 TABLE V.C-3 RADIOACTIVE GASEOUS EFFLUENT INSTRUMENTATION Minimum Channels Instrument Operable Applicability Action

1. Millstone Unit 3 Ventilation Vent Stack (Turbine Building)

a. Noble Gas Activity Monitor - 1 A Providing Alarm

b. Iodine Sampler 1

B

c. Particulate Sampler 1

B

d. Stack Flow Rate Monitor 1

C

e. Sampler Flow Rate Monitor 1

C

2. Millstone Unit I Main Stack

a. Noble Gas Activity Monitor - I D Providing Alarm

b. Iodine Sampler 1

B

c. Particulate Sampler 1

B

d. Stack Flow Rate Monitor 1

C

e. Sampler Flow Rate Monitor 1

C

3. Engineered Safeguards Building Monitor

a. Noble Gas Activity Monitor- A Providing Alarm

b. Iodine Sampler 1

B

c. Particulate Sampler 1

B

d. Discharge Flow Rate Monitor 1

C

e. Sampler Flow Rate Monitor 1

C

4. Warehouse No. 5 Vent

a. Noble Gas Monitor 1(1) ** A

b. Iodine Sampler 1(1) A

c. Particulate Sampler 1(1) A Table Notations

At all times - which means that channels shall be OPERABLE and in service on a continuous, uninterrupted basis except that outages are permitted for a maximum of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling.

- When the gross activity of the regenerated waste is greater than 1 x 1 e- microCuries/mI.

(1) This minimum channel requirement may be met with a portable continuous air monitor (Eberline PING-3 or equivalent).

V.C- 7

REMODCM Unit Three Controls Revision 20 TABLE V.C-3 (Continued)

ACTION STATEMENTS Action A With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for radioactivity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Action B With the number of samplers OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that samples are continuously collected with auxiliary sampling equipment for periods of seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after initiation of this ACTION statement.

Action C With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Action D With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, Millstone Unit 3 releases via the Millstone Unit 1 stack may continue provided that best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and analyzed for gross radioactivity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

V.C- 8

REMODCM Unit Three Controls Revision 20 Table V.C-4 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Analog Modes Channel For Which Channel Source Channel Operational Surveillance Instrument Check Check Calibration Test is Required

1. Millstone Unit 3 Ventilation Vent Stack (Turbine Building)

a. Noble Gas Activity Monitor D M R(1) Q(2)

b. Iodine Sampler W NA NA NA

c. Particulate Sampler W NA NA NA *

d. Stack Flow Rate Monitor D NA R Q

e. Sampler Flow Rate Monitor D NA R Q

2. Millstone Unit 1 Main Stack

a. Noble Gas Activity Monitor D M R(3) Q(2)

b. Iodine Sampler W NA NA NA

c. Particulate Sampler W NA NA NA

d. Stack Flow Rate Monitor D NA R Q

e. Sampler Flow Rate Monitor D NA R Q

3. Engineered Safeguards Building Monitor

a. Noble Gas Activity Monitor D M R(1) Q(2)

b. Iodine Sampler W NA NA NA

c. Particulate Sampler W NA NA NA

d. Discharge Flow Rate Monitor D NA R Q

e. Sampler Flow Rate Monitor D NA R Q

4. Warehouse No. 5 Vent

a. Noble Gas Monitor D NA R(3) NA

b. Iodine Sampler D NA R(3) NA

c. Particulate Sampler D NA R(3) NA At all times except when the vent path is isolated.

When the gross activity of the regenerated waste is greater than 1 x 104 microCuries/mi.

D = Daily R = Once every 18 months W = Weekly Q = Once every 3 months M = Monthly NA = Not Applicable V.C- 9

REMODCM Unit Three Controls Revision 20 Table V.C-4 (Continued)

TABLE NOTATION (1) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards (NBS) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NBS.

These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used.

(2) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

a. Instrument indicates measured levels above the Alarm Setpoint, or

b. Circuit failure (not applicable to Unit 1 Stack Monitor), or

c. Instrument indicates a downscale failure.

(3) The CHANNEL CALIBRATION shall include the use of a known source whose strength is determined by a detector which has been calibrated to an NBS source. These sources shall be in know, reproducible geometry.

V.C- 10

REMODCM Unit Three Controls Revision 20 V.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

1. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS FOR OPERATION The concentration of radioactive material released from the site (see Figure V.D-1) shall be limited to the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 1 04 microCurie/ml total activity.

APPLICABILITY: At all times.

ACTION:

With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes.

SURVEILLANCE REQUIREMENT

1. Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I.

2. The results of the radioactive analysis shall be used in accordance with the methods of Section II to assure that the concentrations at the point of release are maintained within the limits of Specification V. D. 1.a.

V.D- I

REMODCM Unit Three Controls Revision 20 V.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

1. Radioactive Liquid Effluents (Cont'd)

b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS FOR OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 3 released from the site (see Figure V.D-1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and,

b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents during the remainder of the current calendar quarter and the remainder of the calendar year so that the cumulative dose or dose commitment to any REAL MEMBER OF THE PUBLIC from such releases during the calendar year is within 3 mrem to the whole body and 10 mrem to any organ.

SURVEILANCE REQUIREMENTS

1. Dose Calculations. Cumulative dose contributions from liquid effluents shall be determined in accordance with Section I1.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

V.D-2

REMODCM Unit Three Controls Revision 20 V.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS FOR OPERATION The dose rate, at any time, offsite (see Figure V.D-1) due to radioactive materials released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and,

b. The dose rate limit due to inhalation for Iodine-131, Iodine-133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

APPLICABILITY: At all times.

ACTION:

With the dose rate(s) exceeding the above limits, decrease the release rate within 15 minutes to comply with the limit(s) given in Specification V.D.2.a.

SURVEILLANCE REQUIREMENTS

1. The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established in Specification V.D.2.a. The corresponding release rate shall be determined in accordance with the methodology of Section II.

2. The noble gas effluent monitors of Table V.C-3 shall be used to control release rates to limit offsite doses within the values established in Specification V.D.2.a.

3. The release rate of radioactive materials in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program, specified in Section I. The corresponding dose rate shall be determined using the methodology given in Section II.

V.D-3

REMODCM Unit Three Controls Revision 20 V.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

2. Radioactive Gaseous Effluents (Cont'd)

b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS FOR OPERATION The air dose offsite (see Figure V.D-1) due to noble gases released from Unit 3 in gaseous effluents shall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation, and

b. During any calendar year: Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY: At all times.

ACTION:

a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents during the remainder of the current calendar quarter and during the remainder of the calendar year so that the cumulative dose during the calendar year is within 10 mrad for gamma radiation and 20 mrad for beta radiation.

SURVEILLANCE REQUIREMENTS

1. Dose Calculations - Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

V.D-4

REMODCM Unit Three Controls Revision 20 V.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS (Cont'd)

2. Radioactive Gaseous Effluents (Cont'd)

c. Gaseous Effluents - Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS FOR OPERATION The dose to any REAL MEMBER OF THE PUBLIC from Iodine-1 31, Iodine-1 33, Tritium, and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 3 released offsite (see Figure V.D-1) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrem to any organ and,

b. During any calendar year: Less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases during the remainder of the current calendar quarter and during the remainder of the calendar year so that the cumulative dose or dose commitment to any REAL MEMBER OF THE PUBLIC from such releases during the calendar year is within 15 mrem to any organ.

SURVEILLANCE REQUIREMENTS

1. Dose Calculations - Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2. Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

V.D-5

REMODCM Unit Three Controls Revision 2()

Figure V.D-1 Site Boundary for Liquid and Gaseous Effluents V.D-6

REMODCM Unit Three Controls Revision 20 V.E. TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS LIMITING CONDITIONS FOR OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from the Millstone Site shall be limited to less than or equal to 25 mrem to the whole body or any organ (except the thyroid, which shall be limited to less than or equal to 75 mrem) over a period of 12 consecutive months.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specification V.D. 11.b, V.D.2.b, or V.D.2.c prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR Part 190 Standard. If the estimated dose(s) exceeds the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Surveillance Requirement 1 of Specifications V.D.I.b, V.D.2.b, and V.D.2.c, and in accordance with Section II once per 31 days.

V.E-1

REMODCM Unit Three Controls Revision 20 V.F. BASES Section V.C.1 - Radioactive Liquid Effluent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in Section II to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. The purpose of tank level indicating devices is to assure the detection and control of leaks that if not controlled could potentially result in the transport of radioactive materials to UNRESTRICTED AREAS.

Section V.C.2 - Radioactive Gaseous Effluent Monitorinq Instrumentation The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in Section II to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

The sensitivity of any noble gas activity monitors used to show compliance with the gaseous effluent release requirements of Specification V.C.2.a shall be such that concentrations as low as 1 x 10-6 uCi/cc are measurable.

Section V.D.1.a - Radioactive Liquid Effluents Concentrations This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II. This limitation provides additional assurance that the levels of radioactive materials in bodies of water outside the site will result in exposures within: (1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, to an individual and (2) the limits of 10 CFR 20.106(e) to the population.

The concentration limit for noble gases is based upon the assumption that Xe-1 35 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

Section V.D.1.b - Radioactive Liquid Effluents Doses This specification is provided to implement the requirements of Sections IL.A, IlI.A, and IV.A of Appendix I, 10 CFR Part 50. The control implements the guides set forth in Section II.A of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable." The dose calculation methodology and parameters in Section II implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I is to be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The equations specified in Section II for calculating the doses due to the actual release rates of radioactive materials in liquid effluents will be consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man V.F-I

REMODCM Unit Three Controls Revision 20 from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977, and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

Section V.D.2.a - Radioactive Gaseous Effluents Dose Rate This specification is provided to ensure that the dose rate at any time from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for all areas offsite. The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table II. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual offsite to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR 20.106(b)). For individuals who may, at times, be within the SITE BOUNDARY, the occupancy of that individual will usually be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the SITE BOUNDARY. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body or to less than or equal to 3000 mrem/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid or any other organ dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year.

Section V.D.2.b - Radioactive Gaseous Effluents Noble Gas Dose This specification is provided to implement the requirements of Sections ll.B., III.A and IV.A of Appendix 1,10 CFR Part 50. The Limiting Conditions of Operation implements the guides set forth in Section II.B of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated. The dose calculation established in Section II for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109, "Calculational of Annual Doses to Man from Routine Releases of Reactor Effluent for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977.

The Section II equations provided for determining the air doses at the site boundary are based upon utilizing successively more realistic dose calculational methodologies. More realistic dose calculational methods are used whenever simplified calculations indicate a dose approaching a substantial portion of the regulatory limits. The methods used are, in order, previously determined air dose per released activity ratio, historical meteorological data and actual radionuclide mix released, or real time meteorology and actual radionuclides released.

V.F-2

REMODCM Unit Three Controls Revision 20 Section V.D.2.c - Radioactive Gaseous Effluents for Radionuclides Other Than Noble Gas This specification is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix I, 10 CFR Part 50. The Limiting Conditions of Operations are the guides set forth in Section II.C of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The Section II calculational methods specified in the surveillance requirements implement the requirements in Section III.A of Appendix I that conformance with the guides for Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The Section II calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, "Calculating of Annual Dose to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision I, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision I, July 1977. The release rate specifications for radioiodines, radionuclides in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man. The pathways that are examined in the development of these calculations are: 1) individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man.

Section V.E - Total Radiological Dose from Station Operations This specification is provided to meet the dose limitations of 40 CFR Part 190. For the purpose of the Special Report, it may be assumed that the dose commitment to any REAL MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 5 miles must be considered.

V.F-3

Millstone REMODCM Revision 21

SECTION I RADIOLOGICAL EFFLUENT MONITORING MANUAL (REMM)

FOR THE MILLSTONE NUCLEAR POWER STATION UNIT NOs. 1, 2, & 3 DOCKET NOs. 50-245, 50-336, 50-423 Revision 21 January 26, 2001

REMM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFF-SITEDOSE CALCULATION MANUAL (REMODCM)

PAGE CHANGE

SUMMARY

Pare Rev Date Page Rev Date Page Rev Date I.A-I 21 II.A-1 20 1/25/01 I11.A-1 18 1/03/00 1.B-I 20 1/25/01 1I.B-1 20 1/25/01 I11.B-1 18 1/03/00 I.C-1 20 1/25/01 I1.C-1 20 1/25/01 11I.C-1 19 6/15/00 I.C-2 21 II.C-2 20 1/25/01 1II.C-2 21 I.C-3 19 6/15/00 II.C-3 19 6/15/00 I1I.C-3 19 6/15/00 I.C-4 21 I1.C-4 21 III.C-4 21 I.C-5 21 I.C-5 19 6/15/00 II.C-5 19 6/15/00 1.C-6 19 6/15/00 II.C-6 18 1/03/00 III.C-6 19 6/15/00 I.C-7 19 6/15/00 II.D-1 21 III.C-7 21 I.C-8 21 I1.D-2 21 III.C-8 21 1.C-9 19 6/15/00 II.D-3 21 III.C-9 21 I.C-10 19 6/15/00 II.D-4 21 I1I.C-10 21 I.C-11 21 II.D-5 21 III.C-11 19 6/15/00 I.C-12 20 1/25/01 II.D-6 21 III.C-12 19 6/15/00 I.C-13 18 1/03/00 II.D-7 21 III.C-13 21 I.C-14 18 1/03/00 II.D-8 21 III.D-1 19 6/15/00 I.C-15 18 1/03/00 II.D-9 21 II1.D-2 18 1/03/00 I.D-1 20 1/25/01 I1.D-10 21 III.D-3 21 I.D-2 21 II.D-11 21 III.D-4 18 1/03/00 I.D-3 21 II.D-12 21 III.D-5 19 6/15/00 I.D-4 21 II.D-13 21 III.D-6 18 1/03/00 I.D-5 21 II.D-14 21 III.E-1 18 1/03/00 I.D-6 21 II.D-15 21 III.F-1 21 I.D-7 21 1I.D-16 Deleted III.F-2 18 1/03/00 I.D-8 21 II.E-1 20 1/25/01 I11I.F-3 18 1/03/00 I.D-9 20 1/25/01 II.E-2 18 1/03/00 I1I.F-4 18 1/03/00 I.D-10 20 1/25/01 II.E-3 20 1/25/01 I.D-11 18 1/03/00 11.E-4 18 1/03/00 I.D-12 21 II.E-5 18 1/03/00 I.D-13 21 II.E-6 20 1/25/01 I.E-1 18 1/03/00 II.E-7 20 1/25/01 I.E-2 20 1/25/01 I1.E-8 19 6/15/00 I.E-3 21 II.E-9 19 6/15/00 I.E-4 21 I1.F-1 21 I.E-5 21 1I.F-2 21 I.E-6 21 II.F-3 21 I.E-7 21 II.F-4 20 1/25/01 I.E-8 21 App I1.A-1 20 1/25/01 I.E-9 21 App I1.A-2 20 1/25/01 I.E-10 21 I.E-I1 21 I.E-12 21 I.E-13 21 1.F-1 18 1/03/00 1.F-2 20 1/25/01 I-,i

REMM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFF-SITEDOSE CALCULATION MANUAL (REMODCM)

PAGE CHANGE

SUMMARY

PaZe Rev Date Pae Rev Date IV.A-1 20 1/25/01 V.A-I 20 1/25/01 IV.B-1 20 1/25/01 V.B-1 20 1/25/01 IV.B-2 20 1/25/01 V.B-2 20 1/25/01 IV.C-1 20 1/25/01 V.C-I 20 1/25/01 IV.C-2 20 1/25/01 V.C-2 21 IV.C-3 20 1/25/01 V.C-3 20 1/25/01 IV.C-4 20 1/25/01 V.C-4 20 1/25/01 IV.C-5 20 1/25/01 V.C-5 21 IV.C-6 21 V.C-6 20 1/25/01 IV.C-7 20 1/25/01 V.C-7 21 IV.C-8 21 V.C-8 21 IV.C-9 21 V.C-9 21 IV.C-10 21 V.C-10 21 IV.C-11 21 V.D-1 20 1/25/01 IV.D-1 20 1/25/01 V.D-2 20 1/25/01 IV.D-2 20 1/25/01 V.D-3 20 1/25/01 JV.D-3 20 1/25/01 V.D-4 20 1/25/01 IV.D-4 20 1/25/01 V.D-5 20 1/25/01 IV.D-5 20 1/25/01" V.D-6 20 1/25/01 IV.D-6 20 1/25/01 V.E-1 20 1/25/01 IV.E-1 20 1/25/01 V.F-1 21 IV.F-I 21 V.F-2 20 1/25/01 IV.F-2 20 1/25/01 V.F-3 20 1/25/01 IV.F-3 20 1/25/01 IV.F-4 20 1/25/01

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REMM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFFSITEDOSE CALCULA TION MANUAL (REMODCM)

SECTION I: RADIOLOGICAL EFFLUENTMONITORING MANUAL (REMM)

TABLE OF CONTENTS SECTION PAGE NO.

PAGE CHANGE

SUMMARY

........................................................................ I-i TABLE OF CONTENTS ............................................................................... I-ii I.A. INTRODUCTION .................................................. I.A-i I.B. RESPONSIBILITIES ............................................................................. I.B-1 I.C. LIQUID EFFLUENTS I. Liquid Effluents Sampling And Analysis Program ...................................... I.C-1

2. Liquid Radioactive Waste Treatment ...................................................... I.C-11

3. B ases ............................................................................................ I.C -12 I.D. GASEOUS EFFLUENTS

1. Gaseous Effluents Sampling And Analysis Program .................................... I.D-1

2. Gaseous Radioactive Waste Treatment .................................................. I.D-9

3. B ases ............................................................................................ I.D -10 I.E. RADIOLOGICAL ENVIRONMENTAL MONITORING

1. Sampling And Analysis ...................................................................... I.E-I

2. Land Use Census .............................................................................. I.E-12

3. Interlaboratory Comparison Program ...................................................... I.E-13

4. Bases ............................................................................................ I.E-13 I.F. REPORT CONTENT

1. Annual Radiological Environmental Operating Report ................................ I.F-1

2. Radioactive Effluent Release Report ....................................................... I.F-2 I- iii

REMM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM)

SECTION 1: RADIOLOGICAL EFFLUENT MONITORING MANUAL (REMM)

TABLE OF CONTENTS (Cont'd)

Table No. Table Name Page I.C-1 Radioactive Liquid Waste Sampling and Analysis Program - Millstone Unit I I.C-2 I.C-2 Radioactive Liquid Waste Sampling and Analysis Program - Millstone Unit 2 I.C-5 I.C-3 Radioactive Liquid Waste Sampling and Analysis Program - Millstone Unit 3 I.C-8 I.D-I Radioactive Gaseous Waste Sampling and Analysis Program - Millstone Unit I I.D-2 I.D-2 Radioactive Gaseous Waste Sampling and Analysis Program - Millstone Unit 2 I.D-4 I.D-3 Radioactive Gaseous Waste Sampling and Analysis Program - Millstone Unit 3 I.D-7 I.E- 1 Millstone Radiological Environmental Monitoring Program I.E-3 I.E--2 Environmental Monitoring Program - Sampling Locations I.E-4 I.E-3 Reporting Levels for Radioactivity concentrations in Environmental Samples I.E-9 I.E-4 Maximum Values for Lower Limits of Detection (LLD) I.E-10 Figure No. Fizure Name Page I.C-I RESERVED I.C-13 I.C-2 Simplified Liquid Effluent Flow Diagram - Millstone Unit 2 I.C-14 I.C-3 Simplified Liquid Effluent Flow Diagram - Millstone Unit 3 I.C-15 I.D-l RESERVED I.D- 11 I.D-2 Simplified Airborne Effluent Flow Diagram - Millstone Unit 2 I.D-12 I.D-3 Simplified Airborne Effluent Flow Diagram - Millstone Unit 3 I.D-13 I.E- 1 Inner Air Particulate and Vegetation Monitoring Stations I.E-6 I.E-2 Outer Terrestrial Monitoring Stations I.E-7 I.E-3 Aquatic Sampling Stations I.E-8 I-iv

REMM Revision 21 I.A. INTRODUCTION The purpose of Section I of this manual is to provide the sampling and analysis programs which provide input to Section II for calculating liquid and gaseous effluent concentrations and offsite doses. Guidelines are provided for operating radioactive waste treatment systems in order that offsite doses are kept As-Low-As-Reasonably-Achievable (ALARA).

The RadiologicalEnvironmentalMonitoringProgram outlined within this manual provides confirmation that the measurable concentrations of radioactive material in the environment as a result of operations at the Millstone Site are not higher than expected.

In addition, this manual outlines the information required to be submitted to the NRC in both the Annual RadiologicalEnvironmentalOperatingReport and the RadioactiveEffluent Release Report.

L.A-1

REMM Revision 21 I.B. RESPONSIBILITIES All changes to the Radiological Effluent Monitoring Manual (REMM) shall be reviewed and approved by the Site Operations Review Committee prior to implementation.

All changes and their rationale shall be documented in the Radioactive Effluent Release Report.

It shall be the responsibility of the Senior Vice President and CNO - Millstone to ensure that this manual is used as required by the administrative controls of the TechnicalSpecifications. The delegation of implementation responsibilities is delineated in the Millstone RadiologicalEffluent ProgramReference Manual (MP-13-REM-REFO1).

I.B-1

REMM Revision 21 I.C. LIQUID EFFLUENTS

1. Liquid Effluent Sampling and Analysis Program Radioactive liquid wastes shall be sampled and analyzed in accordance with the program specified in Table I.C-I for Millstone Unit No. 1, Table I.C-2 for Millstone Unit No. 2, and Table 1.C-3 for Millstone Unit No. 3. The results of the radioactive analyses shall be input to the methodology of Section II to assure that the concentrations at the point of release are maintained within the limits of Radiological Effluent Controls (Section III D.l.a for Millstone Unit No. 1,Section IV.E.I.a for Millstone Unit No. 2, and Section V.E. .a for Millstone Unit No. 3).

.I.C- 1

REMM Revision 21 Table I.C-1 MILLSTONE UNIT 1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANAL YSIS PROGRAM Lower Limit Sample Type and Minimum of Detection Liquid Release Source Frequency Analysis Type of Activity (LLD)A Frequency Analysis (piCi/ml)

A. Batch ReleaseB Principal Gamma 5 x 10 Prior to Each Batch Emittersc Waste Sample Release Tanks, Floor Drain Ce-144 5 x 10 Sample Tank Grab Sample and Prior to Each Batch 1 x 10-5 Release Monthly H-3 Decontamination Solution Tank CompositeE Gross alpha I x 10."

Quarterly Sr-89, Sr-90 5 x 10" CompositeE Fe-55 I x 10 NOTE: Service Water sample not required when the RBCCW System is removed from service. I B. Continuous Release Principal Gamma Weekly Grab Weekly Emittersc 5 x 10.'

CompositeE SampleD*

Ce-144 5 x 10-6 Reactor Building Service Water Weekly Grab or Monthly H-3 l x 105 CompositeE CompositeE Gross alphaF I x 10.7 Weekly Quarterly Sr-89F, Sr-90V 5 x 10"'

1x0-6 CompositeEF

C CompositeE'E Fe-55F*

There is a Conditional Action Requirement associated with this notation.

I.C- 2

REMM Revision 21 TABLE I.C-1 (Cont'd.)

TABLE NOTATIONS INFORMATIONAL NOTES:

A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66 Sb E- V. 2.22 x 106 .Y. exp (-' X At) where:

LLD is the lower limit of detection as defined above (as piCi per unit mass or volume)

Sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)

E is the counting efficiency (as counts per transformation)

V is the sample size (in units of mass or volume) 2.22 x 106 is the number of transformations per minute per microcurie Y is the fractional radiochemical yield (when applicable)

X is the radioactive decay constant for the particular radionuclide At is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors will be identified and recorded on the analysis sheet for the particular sample.

B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed in this table. Prior to the sampling, each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided.

C. The LLD will be 5 x 10-7 pCi/ml. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, and Cs-137. Ce-144 shall be measured, but with an LLD of 5 x l0" gCi/ml.

This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

I.C- 3

REMM Revision 21 TABLE I.C-1 (Cont'd.)

E. A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.

Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.

CONDITIONAL ACTION REQUIREMENTS:

D. IF a weekly sample identifies the presence of gamma activity greater than or equal to 5 x 10-7 PCi/ml, THEN the sample frequency shall be increased to daily until the gamma activity is less than 5 x 10-7

[tCi/ml. Daily grab samples shall be taken at least five times per week.

7 F. IF a weekly gamma analysis does not indicate a gamma activity greater than 5 x 10- tCi/ml, THEN these analyses (gross alpha, Sr-89, Sr-90, Fe-55) are not required.

I.C- 4

REMM Revision 21 Table I.C-2 MILLSTONE UNIT 2 RADIOACTIVELIQUID WASTE SAMPLING AND ANAL YSIS PROGRAM Lower Limit Sample Type Minimu m of Detection Liquid Release and Analysis Type of Activity (LLD)A Source Frequency Frequency Analysis (piCi/ml)

A. Batch ReleaseB Principal Gamma 10 Prior to Each EmittersC 5x

1. Coolant Waste Batch Release 1-131 1x 10-6 Monitor Tank, Ce-144 5 x 10-6 Aerated Waste Monitor Tank Dissolved and Entrained GasesK I x 1x "

and Steam Grab Sample Generator Prior to Each Bulk Batch Release Monthly H-3 I x 10.

7 Gross alphaD 1x 10.

2. Condensate CompositeFG Polishing Facility

- Waste Neutralization Sr89D Sr_90D _5 x10 Qu arte r ly_

S u m pE Fe_55D 1 x 10-6 CompositeFG B. Continuous Release Principal Gamma Weekly Emittersc 5x 10-7 Daily Grab

1. Steam Generator Sample' CompositeF'G 13 I- x11 BlowdownH Ce-144 5 x 10" Monthly Grab Monthly Dissolved and Entrained I x 1

2. Service Water Sample GasesK1 Effluent Weekly Grab or Monthly H-3 1 x 10-5

3. Turbine Building Composite Composite'G Gross alphal.L I X l0.

,M SumpsH

*5xI" Weekly Quarterly Sr-89* , Sr-901 5 x lO Composite CompositeF.G Fe-55'* 1 X 10-6

"* There is a Conditional Action Requirement associated with this notation.

i.C- 5

REMM Revision 21 TABLE LC-2 (Cont'd.)

TABLE NOTATIONS INFORMATIONAL NOTES:

A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66 Sb E- V- 2.22 x 106 .Y. exp (- X At) where:

LLD is the lower limit of detection as defined above (as IlCi per unit mass or volume)

Sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)

E is the counting efficiency (as counts per transformation)

V is the sample size (in units of mass or volume) 2.22 x 106 is the number of transformations per minute per microcurie Y is the fractional radiochemical yield (when applicable)

?, is the radioactive decay constant for the particular radionuclide At is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and recorded on the analysis sheet for the particular sample.

B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed in this table. Prior to the sampling, each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided. If the steam generator bulk can not be recirculated prior to batch discharge, samples will be obtained by representative compositing during discharge.

C. The LLD will be 5 x 10.7 gaCi/ml. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, and Ce-141. Ce-144 shall also be measured, but with an LLD of 5 x 10"-tCi/ml. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.

Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

I.C- 6

REMM Revision 21 TABLE .- 2 (Cont'd.)

TABLE NOTATIONS F. For Batch Releases and Steam Generator Blowdown only, a composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.

G. Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.

I. Daily grab samples shall be taken at least five days per week. For service water, daily grabs shall include each train that is in-service.

K. LLD applies exclusively to the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138.

This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

CONDITIONAL ACTION REQUIREMENTS D. For the Condensate Polishing Facility (CPF) waste neutralization sump and steam generator bulk:

IF the applicable batch gamma activity is not greater than 5 x 10- 7 ýtCi/ml, THEN these analyses (gross alpha, Sr-89, Sr-90, Fe-55) are not required.

E. For the Condensate Polishing Facility (CPF) waste neutralization sump:

IF there is no detectable tritium in the steam generators, THEN tritium sampling and analyses are not required.

IF the steam generator gross gamma activity (sampled and analyzed three times per week per Table 4.7-2 of the Technical Specifications) does not exceed I x 10-5 pCi/ml, THEN the sampling and analysis schedule for all principal gamma emitters, 1-131, Ce-144, noble gases, gross alpha, Sr-89, Sr-90 and Fe-55 are not required.

H. For the Steam Generator Blowdown and the Turbine Building Sump:

IF there is no detectable tritium in the steam generators, THEN tritium sampling and analysis of the Turbine Building Sump is not required.

IF the steam generator gross gamma activity (sampled and analyzed three times per week as per Table 4.7-2 of the Safety Technical Specifications)does not exceed 5 x 10-7 pCi/ml, THEN the sampling and analysis schedule for all principal gamma , 1-131, Ce-144, noble gases, gross alpha, Sr-89, Sr-90 and Fe-55 are not required.

7 J. For the Service Water: IF a weekly gamma analysis does not indicate a gamma activity greater than 5 x10-pCi/ml, THEN these analyses (gross alpha, Sr-89, Sr-90, Fe-55) are not required.

L. For the Turbine Building Sump: IF the release pathway is directed to yard drains, THEN the LLD for 1-131 shall be 1.5 x 10-7 pCi/ml and for gross alpha 1 x 10-8 pCi/ml.

M. IF the Turbine Building Sump is directed to radwaste treatment, THEN sampling is not required.

.I.C- 7

REMM Revision 21 Table I.C-3 MILLSTONE UNIT 3 RADIOACTIVE LIOUID WASTE SAMPLING AND ANAL YSIS PROGRAM Lower Sample Type Minimum Limit Liquid Release Source and Analysis Type of Activity of Frequency Frequency Analysis Detection (LLD)A (p.Ci/ml)

A. Batch ReleaseB Principal Gamma Emittersc Prior to Each

1. Condensate Polishing Facility - Batch Release 1-131 1 x 10.6 Waste Ce-144 5 x 10-6 Neutralization Grab Sample Dissolved and Entrained GasesK 10 SumpE* Prior to Each Batch Release Monthly H-3 1 x 10.6 x 10-7 Composite 'G Gross alphaD*

2. Waste Test Tanks Low Level Waste Drain Tank, Boron Test Tanks Sr-89D Sr_90D and Steam Generator Bulk Quarterly Composite' Fe-55D*

B. Continuous Release Principal Gamma Emittersc 5 x 10-7 Daily Grab Weekly

1. Steam Generator Sample' CompositeFG IL* I X 10-6 Sample' 1-13 1 BlowdownH Ce-144 5 x 10.

Monthly Grab Monthly Dissolved and Entrained 5 Sample Gases*K x 10

2. Service Water Effluent I Weekly Grab or Monthly H-3 I x 10.5 7

Composite CompositeFG Gross alphaj ,L I X 10-

3. Turbine Building *5*1" Sups ,M*

SUMPSHM Weekly Quarterly Sr-89' Sr-90' 5 x 10 Composite CompositeF'0 Fe-55J X 10-6 SThere is a Conditional Action Requirement associated with this notation.

I.C- 8

REMM Revision 21 TABLE I.C-3 (Cont'd.)

TABLE NOTATIONS INFORMATIONAL NOTES:

A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95%

probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66 S, E. V- 2.22 x 106 -.Y. exp (- XAt) where:

LLD is the lower limit of detection as defined above (as JiCi per unit mass or volume)

Sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)

E is the counting efficiency (as counts per transformation)

V is the sample size (in units of mass or volume) 2.22 x 106 is the number of transformations per minute per microcurie Y is the fractional radiochemical yield (when applicable)

? is the radioactive decay constant for the particular radionuclide At is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and recorded on the analysis sheet for the particular sample.

B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed in this table.

Prior to the sampling, each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided. If the steam generator bulk can not be recirculated prior to batch discharge, samples will be obtained by representative compositing during discharge.

C. The LLD will be 5 x 10-7 gtCi/ml. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, and Ce-141.

Ce-144 shall also be measured, but with an LLD of 5 x 10"6 jCi/ml. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

I.C- 9

REMM Revision 21 TABLE I.C-3 (Cont'd.)

TABLE NOTATIONS F. For Batch Releases and Steam Generator Blowdown only, a composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.

G. Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.

I. Daily grab samples shall be taken at least five days per week. For service water, daily grabs shall include each train that is in-service.

K. LLD applies exclusively to the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138.

This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

CONDITIONAL ACTION REQUIREMENTS D. For the Condensate Polishing Facility (CPF) waste neutralization sump and steam generator bulk:

IF the applicable batch gamma activity is not greater than 5 x 10-7 jtCi/ml, THEN these analyses (gross alpha, Sr-89, Sr-90, Fe-55) are not required.

E. For the Condensate Polishing Facility (CPF) waste neutralization sump:

IF there is no detectable tritium in the steam generators, THEN tritium sampling and analysis is not required.

IF the steam generator gross gamma activity (sampled and analyzed three times per week as per Table 4.7-1 of the Safety Technical Specifications) does not exceed 1 x 10-5 pCi/ml, THEN the sampling and analysis schedule for all principal gamma emitters, I-131, Ce-144, noble gases, gross alpha, Sr-89, Sr-90 and Fe-55 are not required.

H. For the Steam Generator Blowdown and the Turbine Building Sump:

IF there is no detectable tritium in the steam generators, THEN tritium sampling and analysis of the Turbine Building Sump is not required.

IF the steam generator gross gamma activity (sampled and analyzed three times per week as per Table 4.7-1 of the Safety Technical Specifications) does not exceed 5 x 10-7 jCi/ml, THEN the sampling and analysis for all principal gamma, I-131, Ce-144, noble gases, gross alpha, Sr-89, Sr-90 and Fe-55 are not required.

Steam Generator Blowdown samples are not required when blowdown is being recovered.

J. For Service Water:

IF a weekly gamma analysis does not indicate a gamma activity greater than 5 x 10.7 PCi/mI, THEN these analyses (gross alpha, Sr-89, Sr-90, Fe-55) are not required.

L. IF the Turbine Building sump release is directed to yard drains, THEN the LLD for 1-131 shall be 1.5 x 10-7 pCi/ml and for gross alpha 1 x 10.8 pCi/ml.

M. IF the Turbine Building Sump is directed to radwaste treatment, THEN sampling is not required.

I.C- 10

REMM Revision 21 I.C. LIQUID EFFLUENTS (Cont'd)

2. Liquid Radioactive Waste Treatment

a. Dose Criteria for Equipment Operability Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit.

1. IF the radioactivity concentration criteria for the Unit 3 steam generator blowdown is exceeded with blowdown recovery not available to maintain releases to as low as reasonably achievable; or, IF any of the other radioactive waste processing equipment listed in Section b are not routinely operating, THEN doses due to liquid effluents from the applicable waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.C.5.

2. IF any of these dose projections exceeds 0.006 mrem to the total body or 0.02 mrem to any organ, THEN best efforts shall be made to return the inoperable equipment to service, or to limit discharges via the applicable waste stream.

3. IF an actual dose due to liquid effluents exceeds 0.06 mrem to the total body or 0.2 mrem to any organ, AND the dose from the applicable waste stream exceeds 10% of one of these limits, THEN prepare and submit to the Commission a Special Report within 30 days as specified in Section c.

b. Required Equipment for Each Millstone Unit Best efforts shall be made to return the applicable liquid radioactive waste treatment system equipment specified below for each unit to service or to limit discharge via the applicable waste stream if the projected doses exceed any of the doses specified above.

1. Millstone Unit No. I Waste Stream Processing Equipment Waste collector Filtration Waste demineralizer A or B Floor drains Filtration/ion exchanger OR Waste collector equipment (filtration and demineralizer)

2. Millstone Unit No. 2 Waste Stream Processing Equipment Clean liquid Deborating ion exchanger (TI 1) OR Purification ion exchanger (TOA or TIOB) O.RR Equivalent ion exchanger Primary demineralizer (T22 A or B) OR Equivalent demineralizer Secondary demineralizer (T23) O.R Equivalent demineralizer Aerated liquid Demineralizer (T24) OR Equivalent demineralizer

3. Millstone Unit No. 3 Waste Stream Processing Equipment or Radioactivity Concentration High level Demineralizer filter (LWS-FLT3) and Demineralizer (LWS-DEMN2)

OR Demine'ralizer (LWS-DEMN 1) and Demineralizer filter (LWS-FLT1)

Boron recovery Cesium ion exchanger (DEMN A or B)

Boron evaporator (EV- 1)

Low level High level processing equipment Steam generator blowdown Blowdown recovery when total gamma activity exceeds 5E-7 ACi/ml or tritium activity exceeds 0.02 pCi/ml.

I.C- 11

REMM Revision 21 I.C.2 Liquid Radioactive Waste Treatment (Cont'd)

C. Report Requirement For All Three Millstone Units If required by Section a(3), prepare and submit to the Commission a Special Report within 30 days with the following content:

"* Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability,

"* Action(s) taken to restore the inoperable equipment to OPERABLE status, and

"* Summary description of action(s) taken to prevent a recurrence.

3. Basis for Liquid Sampling. Analysis and Radioactive Treatment System Use Paragraph (a)(2) of Part 50.36a provides that licensee will submit an annual report to the Commission which specifies the quantity of each of the principal radionuclides released to unrestricted areas in liquid effluents during the past 12 months of plant operation. The indicated liquid surveillance programs (as directed by surveillance requirements for Radiological Effluent Controls in Sections III.D. L.a, IV.D. L.a, and V.D. L.a) provides the means to quantify and report on liquid discharges from all major and potential significant release pathways. This information also provides for the assessment of effluent concentrations and environmental dose impacts for the purpose of demonstration compliance with the effluent limits of 10 CFR 20, and dose objectives of 10 CFR 50, Appendix I. The required detection capabilities' for radioactive materials in liquid waste samples are tabulated in terms of Lower Limits of Detection (LLDs) and are selected such that the detection of radioactivity in effluent releases will occur at levels below which effluent concentration limits and off-site dose objectives would be exceeded. The LLDs are listed in Table 4.11-1 of NUREG-1301 except for the LLD for Ce-144 which is contained in Footnote (3) of Table 4.11 -1 ofNUREG-1301.

The indicated liquid radwaste treatment equipment for each Unit have been determined, using the GALE code, to be capable to minimize radioactive liquid effluents such that the dose objectives of Appendix I can be met for expected routine (and anticipated operational occurrence) effluent releases. This equipment is maintained and routinely operated to treat appropriate liquid waste streams without regards to projected environmental doses.

If not already in use, the requirement that the appropriate portions of the liquid radioactive waste treatment system for each Unit be returned to service when the specified effluent doses are exceeded provides assurance that the release of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This condition of equipment usage implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR 50, and the design objective given in Section II.D of Appendix I to 10 CFR Part 50. The specified dose limits governing the required use of appropriate portions of the liquid radwaste treatment system were selected as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR 50 for liquid effluents following the guidance given in NUREG-1301.

I.C- 12

REMM Revision 21 FIGURE RESERVED FIGURE I.C-1

.I.C- 13

Containment Leakoff Primary ease Drians Degassifier Tank (T17) Coolant Waste Coolant Waste Aux. Bldg. Leakoff Receiver . nx Monitor Tanks (TI4A/B) I .,,11"l Tanks (T I SA/)

RCPs Bleedoff Equipment Drain Sump '. -" /".==-,,.

Enclosure Bldg. Tank (075)

Equipment Leakofl Clean Liouid Rad Monitor Condensate I(M19 hTO Primary Coolant Polishing FacilityI A Letdown l ...... ./ I Volume To Primary V¢aste Neut. Sump

)0CotrolCoolant Loop TaTank(121 Rad Monitor (CND245)

t Bowdon Stam Gneraor urbine Bldg floordr ns normaly S/G o or Blowdown Quench Tank C.. *Genera F S0(T45)

I-I 00 RBCCW HX S/*

"*'"%NiCoanticLoop Sump G Blowdown Rad Monitor (RM4262)

Sampling Drains Piping & Aerated Waste toeterrawest temnsttom Equipment Drains Drains Tanks t Monitor (T20A/B) 1;;'==""==:.ITank 0`'21)

Decontamination ................

.erated Liquid Rad Monitor Turbine Bldg. Floor Drains* iatcBy (RM9116)

. .. .. . , . , .. . , .., .. .. ,. ........., ., , ... . . . .. ,. ,.... . . ... ., .. , ........ ........... o.. . . .

o..

- Turbine Bldg floor drains normally to storm drains.

Quarry Drains may be diverted to the radwaste treatment, system.

S= Component included in radwaste treatment equipment requirement

,,. , ,.Circulating Water System Containment Bldg Sump*

Aux Bldg Sump* High Level eWaste Waste Drain Evaporator Waste Test - ...... ,

Reactor Plant Sample Sinks (LWS-EVI) Tank - ,, ,,;t:-)//;,

(Lws-T ) (LWS-TK3A/B) '1 ..

Lab Wastes*

Tank I,, Misc High-Level Waste To Primary 4

Via Reactor Plant Aerated Drain System Grade Water Reactor Coolant Bleed to Boron Recovery Chemical & Degassifier Test Tank Boron Filter 0 Volume Control (GWS-GRUI) (BRS-TK2AB) Demineralizer (BRS-FLT3) -

System (BRSDEMN2AIB)

(DEMNIA/B)

Reactor Plant Gaseous Drian rv~e'.pnhnvato TA T

10 Regenerant

Regenerant Chemicals Evaporator in (TKI0111) 3LWS-RE70 R

Miscellaneous Low-Level W8aste Low-Level Waste Drain Filter Turbine Plant Leakage to Su rip** Tank Flter (3SSR-RE,8)

(LWS-TK4A/B) (LWS-FLT2A/B)

R Steam Generator Blowdown (Open Cycle) enionet

_ Component included in

"**Normally discharged directly to environment. t = radwaste treatment equipment requirement

REMM Revision 21 I.D. GASEOUS EFFLUENTS

1. Gaseous Effluent Samplin2 and Analysis Program Radioactive gaseous wastes shall be sampled and analyzed in accordance with the program specified in Table I.D-I for Millstone Unit No. I, Table I.D-2 for Millstone Unit No. 2, and Table I.D-3 for Millstone Unit No. 3. The results of the radioactive analyses shall be input to the methodology of Section II to assure that offsite dose rates are maintained within the limits of Radiological Effluent Controls (Section III.D.2.a for Millstone Unit No. 1,Section IV.E.2.a for Millstone Unit No. 2, and Section V.E.2.a for Millstone Unit No. 3).

I.D- 1

REMM Revision 21 Table ID-1 MILLSTONE UNIT I RADIOACTIVE GASEOUS WASTE SAMPLING AND ANAL YSIS PROGRAM Lower Limit Gaseous Release Sample Type Minimum Analysis of Detection and Frequency Type of Activity (LLD)A Point or Source Frequency Analysis (jICilcc)

NOTE: Sampling and analysis requirements for Unit 1 releases to the Millstone Stack are in Table I.D-2 and will remain in effect as long as Unit I has releases to the Millstone Stack.

NOTE: Spent Fuel Pool Island (SFPI) Vent requirements not applicable until SFPI Vent monitor is operable.

-r - - r I A. Spent Fuel Pool Monthly"* Monthly Kr-85 I x 10" Island Vent Gaseous Grab Sarnnle H-3 1 x 10-"

Principal Particulate ContinuousB Every two weeks Gamma Emittersc Particulate (with half lives greater than Sample 8 days)

Continuous" Quarterly Composite Sr-89, Sr-90 1 x 10"'

Particulate Gross alpha Sample ContinuousB Continuous Monitor Kr-85 Ix 10"° ClnhceGa NOTE: Balance of Plant (BOP) Vent requirements not applicable until BOP Vent sampler is operable.

Principal Particulate B. Balance of Every two weeks Gamma Emittersc - 1 x 10"-1.

Plant Vent ContinuousB (with half lives greater than Particulate 8 days)

Sample Quarterly Composite Sr-89, Sr-90 1 x 10"11 Gross alpha

There is a Conditional Action Requirement associated with this notation. I I.D- 2

REMM Revision 21 TABLE I.D-1 (Cont'd.)

TABLE NOTATIONS A. The lower limit of detection (LLD) is defined in Table Notations,Item a, of Tables C-I, C-2, or C-3.

B. The ratio of the sample flow rate to the sampled stream flow rate shall be known.

C. For particulate samples, the LLD will be 1 x 10-11 pCi/cc. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn-54, Co-60, Zn-65, Cs-134, Cs-137, and Ce-144. The list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

CONDITIONAL ACTION REQUIREMENTS:

D. IF there is an unexplained increase of the SFPI Vent noble gas monitor of greater than a factor of two, THEN sampling and analysis shall also be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

I.D- 3

REMM Revision 21 Table ID-2 MILLSTONE UNIT 2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANAL YSIS PROGRAM Lower Limit Gaseous Release Point or Source Sample Type and Frequency Minimum Analysis Frequency Type of Activity Analysis of Detection (LLD)A I

A. Batch Release

1. Waste Gas Gaseous Grab Each Tank Discharge Principal Gamma IX Storage TankH Prior to Each and Emitters?

2. Containment Waste Gas Tank Containment Purge H-3 I x 106 Purge Discharge and

3. Containment Containment Purge Weekly for Venting and Weekly for C*

Containment Containment Venting Venting' NOTE: Millstone Stack sampling for Unit 2 releases will be from the Wide Range Gas Monitor (RM-8169) when it becomes operable. Sampling of Unit I releases to the Millstone Stack must continue until Unit 1 terminates releases to the stack.

Principal Gamma 1 x 10-4 B. Continuous Release Monthly - Gaseous Monthlyc* EmittersB

1. Vent Grab Samplec H-3G H-3 IxlO

2. Millstone ContinuousD Weekly 1-131 - 1 x 10"-1 Stack Charcoal Sampler

___________

1-133 1 x 10"10 Principal Weekly Particulate Gamma I x 10"1 ContinuousD EmittersB Particulate (1-131, others with

half lives greater Sampler than 8 days)

ContinuousD Monthly Composite Gross alpha 1 x 10"1 Particulate Sample ContinuousD Quarterly Composite Sr-89, Sr-90 1 x 10"11 Particulate Sample ContinuousDNoble Continuous Monitor Noble Gases - 1 x 10-6 Gas Gross Activity

There is a Conditional Action Requirement associated with this notation.

I.D-4

REMM Revision 21 TABLE I.D-2 (Cont'd.)

TABLE NOTATIONS INFORMATIONAL NOTES:

A. The lower limit of detection (LLD) is defined in Table Notations,Item a, of Tables C-1, C-2, or C-3.

B. For gaseous samples, the LLD will be 1 x 104 gtCi/cc and for particulate samples, the LLD will be I x 10 11iCi/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emission and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, 1-131, Cs-134, Cs-137, Ce-141, and Ce-144 for particulate emissions. The list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

D. The ratio of the sample flow rate to the sampled stream flow rate shall be known.

E. RESERVED H. Waste Gas Storage Tanks are normally released on a batch basis. However, for the purpose of tank maintenance, inspection, or reduction of oxygen concentration, a waste gas tank may be continuously purged with nitrogen provided the following conditions are met:

(1) The previous batch of radioactive waste gas has been discharged to a final tank pressure of less than 5 PSIG.

(2) No radioactive gases have been added to the tank since the previous discharge.

(3) Valve lineups are verified to ensure that no radioactive waste gases will be added to the tank.

(4) After pressurizing the tank with nitrogen, a sample of the gas in the tank will be taken and analyzed for any residual gamma emitters and tritium prior to initiation of the nitrogen purge.

The measured activity will be used to calculate the amount of activity released during the purge.

1.D-5

REMM Revision 21 TABLE .LD-2 (Cont'd.)

TABLE NOTATIONS CONDITIONAL ACTION REQUIREMENTS:

C. IF there is an unexplained increase of the Millstone Stack or Unit 2 Vent noble gas monitor of greater than 50%, after factoring out increases due to changes in THERMAL POWER levels, containment purges, or other explainable increases, THEN sampling and analysis shall also be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing.

For Unit 2 vent only:

IF reactor coolant Dose Equivalent 1-131 samples, which are taken two to six hours following a THERMAL POWER change exceeding 15% of RATED THERMAL POWER in one hour, show an increase of greater than a factor of 5, THEN special sampling and analysis of iodine and particulate filters shall also be performed. These filters shall be changed following such a five-fold increase in coolant activity and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter until the reactor coolant Dose Equivalent 1-131 levels are less than a factor of 5 greater than the original coolant levels or until seven days have passed, whichever is shorter. Sample analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. The LLDs may be increased by a factor of 10 for these samples.

G. IF the refueling cavity is flooded and there is fuel in the cavity, THEN grab samples for tritium shall be taken weekly. The grab sample shall be taken from the Millstone Stack or vent where the containment ventilation is being discharged at the time of sampling.

1. IF the containment air radioactivity increases or decreases by a factor of two compared to the radioactivity at the time of the weekly air sample based on a trend of Radiation Monitors RM8123 and RM8262 gas channels, THEN a new containment air sample shall be taken.

I.D-6

REMM Revision 21 MILLSTONE UNIT 3 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Gaseous Release Sample Type Minimum Analysis Type of Activity of Detection Frequency Analysis (LLD)A Source or Point and Frequency (gCi/cc)

A. Batch Release

1. Containment Gaseous Grab Principal Gamma 1 x 10-4 Prior to Each Each Purge or EmittersB Hogger Drawdown Hogger Drawdown H-3 I x 10-6

2. Containment Purge or Purge Hogger Drawdown NOTE: Requirements for Sampling of Unit 3 releases to the Millstone Stack will be effective when the SLCRS radiation monitor becomes operational as the stack effluent monitor.

B. Continuous Release Monthly - Monthlyc Principal Gamma I x 10 Gaseous EmittersB 1x1 H-3G I x 1O, Grabc

1. Unit 3 Ventilation Vent 1-131 1X 10-12 ContinuousD Weekly Charcoal 1-133 1 x 10"10 SampleF

2. Engineered Principal Particulate Safeguards Continuous Weekly Gamma Emitters - 1 x I0"1l Building Particulate (1-13 1, others with half lives greater than 8 SampleF SampleF_ _ _ days)

3. Millstone Stack via SLCRS ContinuousD Monthly Composite Gross alpha 1 x I0"1, Particulate Sample ContinuousD Quarterly Composite Sr-89, Sr-90 I x I 011 Particulate Sample Noble Gases - Gross I x 10-6 ContinuousD Continuous Monitor Noble Gas Activity

There is a Conditional Action Requirement associated with this notation.

L.D-7

REMM Revision 21 TABLE LD-3 (Cont'd.)

TABLE NOTATIONS INFORMATIONAL NOTES:

A. The lower limit of detection (LLD) is defined in Table Notations,Item a, of Tables C-1, C-2, or C-3.

B. For gaseous samples, the LLD will be I x 104 1tCi/cc and for particulate samples, the LLD will be 1 x 10"1 ptCi/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emission and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, 1-131, Cs-134, Cs-137, Ce-141, and Ce-144 for particulate emissions. The list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

D. The ratio of the sample flow rate to the sampled stream flow rate shall be known.

E. RESERVED H. RESERVED CONDITIONAL ACTION REQUIREMENTS C. IF there is an unexplained increase of the Unit 3 ventilation vent or SLCRS noble gas monitor of greater than 50%, after factoring out increases due to changes in THERMAL POWER levels, containment purges, or other explainable increases, THEN appropriate sampling and analysis shall also be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing.

IF reactor coolant Dose Equivalent 1-131 samples (which are taken two to six hours following a THERMAL POWER change exceeding 15% of RATED THERMAL POWER in one hour per Table 4.4-4 of the Safety Technical Specifications"show an increase of greater than a factor of 5, THEN special sampling and analysis of iodine and particulate filters shall also be performed. These filters shall be changed following such a five-fold increase in coolant activity and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter until the reactor coolant Dose Equivalent 1-131 levels are less than a factor of 5 greater than the original coolant levels or until seven days have passed, whichever is shorter. Sample analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing the filters. The LLDs may be increased by a factor of 10 for these samples.

G. IF the refueling cavity is flooded and there is fuel in the cavity, THEN grab samples for tritium shall be taken weekly from the ventilation vent.

I.D-8

REMM Revision 21 I.D GASEOUS EFFLUENTS (Cont'd)

2. Gaseous Radioactive Waste Treatment

a. Dose Criteria for Equipment Operability Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit.

I. IF any of the radioactive waste processing equipment listed in Section b are not routinely operating, THEN doses due to gaseous effluents from the untreated waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.D.4. For each waste stream, only those doses specified in Section II.D.4 need to be determined for compliance with this section.

2. IF any of these dose projections exceed 0.02 mrad for gamma radiation, 0.04 mrad for beta radiation or 0.03 mrem to any organ due to gaseous effluents, THEN best efforts shall be made to return the inoperable equipment to service.

3. IF actual doses exceed 0.2 mrad for gamma radiation, 0.4 mrad for beta radiation or 0.3 mrem to any organ AND the dose from a waste stream with equipment not continuously operating exceed 10% any of these limits, THEN prepare and submit to the Commission a report as specified in Section c.

b. Required Equipment for Each Millstone Unit Best efforts shall be made to return the gaseous radioactive waste treatment system equipment specified below for each unit to service if the projected doses exceed any of doses specified above. For the Unit 2 gas decay tanks, the tanks shall be operated to allow enough decay time of radioactive gases to ensure that the Radiological Effluent Control dose limits are not exceeded.

1. Millstone Unit No. I Waste Stream Processing Equipment None specified None required

2. Millstone Unit No. 2 Waste Stream Processing Equipment Gaseous Radwaste Treatment System Five (5) gas decay tanks One waste gas compressor Ventilation Exhaust Auxiliary building ventilation HEPA filter (L26 or L27)

Treatment System Containment purge HEPA filter (L25)

Containment vent HEPA/charcoal filter (L29 A or B)

3. Millstone Unit No. 3 Waste Stream Processing Equipment Gaseous Radwaste Treatment System Charcoal bed adsorbers One HEPA filter Building Ventilation Fuel building ventilation filter

c. Report Requirement For All Three Millstone Units If required by Section I.D.2.a.3, prepare and submit to the Commission a Special Report within 30 days with the following content:

Explanation of why gaseous radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability,

Action(s) taken to restore the inoperable equipment to OPERABLE status, and

Summary description of action(s) taken to prevent a recurrence.

1.D-9

REMM Revision 21 1.D GASEOUS EFFLUENTS (Cont'd)

3. Basis for Gaseous Samplin2, Analysis, and Radioactive Treatment System Use Paragraph (a)(2) of Part 50.36a provides that licensee will submit an annual report to the Commission which specifies the quantity of each of the principal radionuclides released to unrestricted areas in gaseous effluents during the past 12 months of plant operation. The indicated gaseous surveillance programs (as directed by surveillance requirements for Radiological Effluent Controls in Sections III.D.2.a, IV.D.2.a, and V.D.2.a) provides the means to quantify and report on radioactive materials released to the atmosphere from all major and potential significant release pathways. This information also provides for the assessment of effluent dose rates and environmental dose impacts for the purpose of demonstration compliance with the effluent limits of 10 CFR 20, and dose objectives of 10 CFR 50, Appendix I. The required detection capabilities for radioactive materials in gaseous waste samples are tabulated in terms of lower limits of detection (LLDs) and are selected, based on NUREG- 1301, such that the detection of radioactivity in releases will occur at levels below which effluent offsite dose objectives would be exceeded. The indicated liquid radwaste treatment equipment for each Unit have been determined, using the GALE code, to be capable to minimize radioactive liquid effluents such that the dose objectives of Appendix I can be met for expected routine (and anticipated operational occurrence) effluent releases. This equipment is maintained and routinely operated to treat appropriate liquid waste streams without regards to projected environmental doses.

If not already in use, the requirement that the appropriate portions of the liquid radioactive waste treatment system for each Unit be returned to service when the specified effluent doses are exceeded provides assurance that the release of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This condition of equipment usage implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR 50, and the design objective given in Section 1I.D of Appendix I to 10 CFR Part 50. The specified dose limits governing the required use of appropriate portions of the liquid radwaste treatment system were selected as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR 50 for liquid effluents following the guidance in NUREG-1301.

I.D-1O

REMM Revision 21 FIGURE RESERVED FIGURE I.D-1 ID-1I

REMM Revision 21 U

0 0D

-0 j

co

..14

0

-o 0..

FIGURE I.D-2 SIMPLIFIED AIRBORNE EFFLUENT FLOW DIAGRAM MILLSTONE UNIT TWO I.D-12

REMM Revision 21 Atmosphere Reactor Plant

'entilation Vent K<R Ventilation Vent Rad Monitor (3HVR*RE 1OB)

Atmosphere Containment Pug Structure Secondary HEPA & SLCRS Containments Charcoal Rad Monitor (HVR-19B)

(SLCRS) (3HIVR*

FLT3A/B)

FIGURE I.D-3 SIMPLIFIED AIRBORNE EFFLUENT FLOW DIAGRAM MILLSTONE UNIT THREE I.D-13

REMM Revision 21 I.E. RADIOLOGICAL ENVIRONMENTAL MONITORING

1. Sampling and Analysis The radiological sampling and analyses provide measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from plant operation. This monitoring program thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways. Program changes may be made based on operational experience.

The sampling and analyses shall be conducted as specified in Table I.E-1 for the locations shown Table I.E-2. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment or other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period.

All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental OperatingReport pursuant to Section I.F.1. It is recognized that, at times, it may not be possible or practicable to continue to obtain samples of the media of choice (excluding milk) at the most desired location or time. In these instances suitable alternative media and locations may be chosen for the particular pathways in questions and appropriate substitutions made within 30 days in the radiological environmental monitoring program.

If milk samples are temporarily unavailable from any one or more of the milk sample locations required by Table I.E-2, a grass sample shall be substituted during the growing season (Apr. - Dec.)

and analyzed for gamma isotopes until milk is again available. Upon notification that milk samples will be unavailable for a prolonged period (>9 months) from any one or more of the milk sample locations required by Table I.E-2, a suitable replacement milk location shall be evaluated and appropriate changes made in the radiological environmental monitoring program. Reasonable attempts shall be made to sample the replacement milk location prior to the end of the next sampling period. Any of the above occurrences shall be documented in the Annual Radiological Environmental Operating Report which is submitted to the U. S. Nuclear Regulatory Commission prior to May I of each year.

Changes to sampling locations shall be identified in a revised Table I.E-2 and, as necessary, Figure(s)

I.E-I through I.E-3.

If the level of radioactivity in an environmental sampling medium at one or more of the locations specified in Table I.E-2 exceeds the report levels of Table 1.E-3 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days from the end of the affected calendar quarter, a Special Report which includes an evaluation of any release conditions, environmental factors or other aspects which caused the limits of Table 1.E-3 to be exceeded. When more than one of the radionuclides in Table 1.E-3 are detected in the sampling medium, this report shall be submitted if:

concentration(1) concentration(2) + > 1.0 reportinglevel (1) reportinglevel (2)

I.E-I

REMM Revision 21 I.E. RADIOLOGICAL ENVIRONMENTAL MONITORING (Cont'd)

When radionuclides other than those in Table I.E-3 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to an individual is equal to or greater than the appropriate calendar year limit of the RadiologicalEffluent Controls (Sections III.D.1.b, 1II.D.2.b, or III.D.2.cfor Unit 1; Sections IV.E. lb, IV.E.2.b, or IV.E.2.c for Unit 2; and Sections V.E.J.b, V.E.2.b, or V.E.2.cfor Unit 3). This report is not required if the measured level of radioactivity was not the result of plant effluents, however, in such an event, the condition shall be reported and described in the Annual RadiologicalEnvironmentalOperatingReport.

The detection capabilities required by Table I.E-4 are state-of-the-art for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement. All analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and described in the Annual RadiologicalEnvironmentalOperatingReport.

l.E-2

REMM Revision 21 MILLSTONE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway and/or Number of Sampling and Collection Type and Frequency of Analysis Sample Locations Frequency

1. Gamma Dose - 36(a) Quarterly Gamma Dose - Quarterly I Environmental TLD I

2. Airborne Particulate 8 Continuous sampler - Gross Beta - Weekly weekly filter change Gamma Spectrum - Quarterly on composite (by location), and on individual sample if gross beta is greater than 10 times the mean of the weekly control station's gross beta results

3. Airborne Iodine 8 Continuous sampler - 1-131 - Weekly weekly canister change

4. Vegetation 5 One sample near middle Gamma Isotopic on each sample and one near end of growing season

5. Milk 3 Semimonthly when animals Gamma Isotopic and 1-131 on each are on pasture; monthly at sample; Sr-89 and Sr-90 on Quarterly other times. Composite 5a.Pasture Grass 4 Sample as necessary to Gamma Isotopic and 1-131 substitute for unavailable milk

6. Sea Water 2 Continuous sampler with a Gamma Isotopic and Tritium on each monthly collection at sample. I indicator location.

Quarterly at control location - Composite of 6 weekly grab samples

7. Bottom Sediment 5 Semiannual Gamma Isotopic on each sample

8. Fin Fish-Flounder and 2 Quarterly Gamma Isotopic on each sample one other type of edible fm fish (edible portion)

9. Mussels (edible portion) 2 Quarterly Gamma Isotopic on each sample 10.Oysters (edible portion) 4 Quarterly Gamma Isotopic on each sample 11 .Clams (edible portion) 2 Quarterly Gamma Isotopic on each sample 12.Lobsters (edible 2 Quarterly Gamma Isotopic on each sample portion)

(a) Two or more TLDs or TLD with two or more elements per location.

1.1E-3

REMM Revision 21 TABLE I.E-2 ENVIRONMENTAL MONITORING PROGRAM Sampling Locations The following lists the environmental sampling locations and the types of samples obtained at each location.

Sampling locations are also shown on Figures I.E-A, I.E-2, and I.E-3:

I .nr.,tinn Direction &

Number* Name Distance from Sample Types Release Point**

1-I On-Site - Old Millstone Road 0.6 Mi, NNW TLD, Air Particulate, Iodine, Vegetation 2-I On-Site - Weather Shack 0.3 Mi, S TLD, Air Particulate, Iodine 3-I On-Site - Bird Sanctuary 0.3 Mi, NE TLD, Air Particulate, Iodine 4-I On-Site - Albacore Drive 1.0 Mi, N TLD, Air Particulate, Iodine 5-I MP3 Discharge 0.1 Mi, SSE TLD 6-I Quarry Discharge 0.3 Mi, SSE TLD 7-I Environmental Lab Dock 0.3 Mi, SE TLD 8-I Environmental Lab 0.3 Mi, SE TLD 9-I Bay Point Beach 0.4 Mi, W TLD 10-I Pleasure Beach 1.2 Mi, E TLD, Air Particulate, Iodine 11-I New London Country Club 1.6 Mi, ENE TLD, Air Particulate, Iodine 12-C Fisher's Island, NY 8.7 Mi, ESE TLD 13-C Mystic, CT 11.5 Mi, ENE TLD 14-C Ledyard, CT 12.0 Mi, NE TLD 15-C Norwich, CT 14.0 Mi, N TLD, Air Particulate, Iodine 16-C Old Lyme, CT 8.8 Mi, W TLD 17-I Site Boundary 0.5 Mi, NE Vegetation 18-I Pleasure Beach 1.2 Mi, E Vegetation 21-I Goat Location No. 1 2.0 Mi., N Milk 22-I Goat Location No. 2 5.2 Mi, NNE Milk 24-C Goat Location No. 3 29 Mi, NNW Milk 25-I Fruits & Vegetables Within 10 Miles Vegetation 26-C Fruits & Vegetables Beyond 10 Miles Vegetation 27-I Niantic 1.7 Mi, WNW TLD, Air Particulate, Iodine 28-I Two Tree Island 0.8 Mi, SSE Mussels 29-1 West Jordan Cove 0.4 Mi, NNE Clams 31-I Niantic Shoals 1.8 Mi, NW Bottom Sediment, Oysters 1.5 Mi, NNW Mussels 32-I Vicinity of Discharge Bottom Sediment, Oysters, Lobster, Fish, Seawater 33-1 Seaside Point 1.8 Mi, ESE Bottom Sediment 34-1 Thames River Yacht Club 4.0 Mi, ENE Bottom Sediment 35-I Niantic Bay 0.3 Mi, WNW Lobster, Fish 36-I Black Point 3.0 Mi, WSW Oysters 37-C Giant's Neck 3.5 Mi, WSW Bottom Sediment, Oysters, Seawater 38-I Waterford Shellfish Bed No. 1 1.0 Mi, NW Clams

I = Indicator; C = Control

- = The release points are the Millstone Stack for terrestrial locations and the end of the quarry for aquatic location.

I.E-4

REMM Revision 21 TABLE I.E-2 (cont.)

ENVIRONMENTAL MONITORING PROGRAM Sampling Locations Location Direction &

Number* Name Distance from Sample Types Release Point**

41-I Myrock Avenue 3.2 Mi, ENE TLD 42-I Billow Road 2.4 Mi, WSW TLD 43-I Black Point 2.6 Mi, SW TLD 44-I Old Schoolhouse 0.1 Mi, NNE TLD 45-1 North Access Point 0.5 Mi, NNW TLD 46-1 Old Lyme - Hillcrest Ave. 4.6 Mi, WSW TLD 47-I East Lyme - W. Main St. 4.5 Mi, W TLD 48-I East Lyme - Corey Rd. 3.4 Mi, WNW TLD 49-1 East Lyme - Society Rd. 3.6 Mi,NW TLD 50-I East Lyme - Manwaring Rd. 2.1 Mi, W TLD 51-I East Lyme - Smith Ave. 1.5 Mi, NW TLD 52-1 Waterford - River Rd. 1.1 Mi, NNW TLD 53-1 Waterford - Rt. 156 & Gardiners 1.4 MiNNE TLD Wood Rd.

55-1 Waterford - Magonk Point 1.8 Mi, ESE TLD 56-1 New London - Mott Ave. 3.7 Mi, E TLD 57-I New London - Ocean Ave. 3.6 Mi,ENE TLD 59-1 Waterford -Miner Ave. 3.4 Mi,NNE TLD 60-1 Waterford - Parkway Sout 4.0 Mi,N TLD 61-1 Waterford - Boston Post Rd. 4.3 Mi, NNW TLD

I = Indicator; C = Control.

- = The release points are the Millstone Stack for terrestrial locations and the end of the quarry for aquatic location.

NOTE: Environmental TLDs also function as accident TLDs in support of the Millstone Emergency Plan. The 36 listed locations for TLDs are the number of environmental TLDs required by Table I.E-1. There are additional TLDs deployed in the environment not listed hi this table, including TLDs needed to comply with the Millstone Emergency Plan.

l.E-5

REMM Revision 21

\.a 41I C141 FIGURE I.E-i INNER AIR PARTICULATE AND VEGETATION MONITORING STATIONS I.E-6

REMM Revision 21 FIGURE I.E-2 OUTER TERRESTIAL MONITORING STATIONS I.E-7

REMM Revision 21 z

1 z

(*

4 0

J C)

FIGURE I.E-3 AQUATIC SAMPLING STATIONS I.E-8

REMM Revision 21 TABLE I.E-3 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Airborne Particulate Fish Shellfish(c) Vegetables Water or Gases (pCi/g, (pCi/g, Milk (pCi/g, Analysis (pCi/l) (pCi/m3) wet) wet) (pCi/ wet)

H-3 20,000(a)

Mn-54 1,000 30 140 Fe-59 400 10 60 Co-58 1,000 30 130 Co-60 300 10 50 Zn-65 300 20 80 Zr-95 400 Nb-95 400 Ag-I lOn 8 30 1-131 20(") 0.9 0.2 1 3 0.1 Cs-134 30 10 1 5 60 1 Cs-137 50 20 2 8 70 2 Ba-140 200 300 La-140 200 300 (a) 20,000 pCi/1 for drinking water samples. (This is 40 CFR Part 141 value.) For non-drinking water pathways (i.e., seawater), a value of 30,000 pCi/I may be used.

(b) Reporting level for 1-131 applies to non-drinking water pathways (i.e., seawater). If drinking water pathways are sampled, a value of 2 pCi/l is used.

(c) For on-site samples, these values can be multiplied by 3 to account for the near field dilution factor.

I.E-9

REMM Revision 21 0

MAXIMUM VALUES FOR LOWER LIMITS OF DETECTION (LLD)

Airborne Food Particulate Fish, Shellfish Products Sediment Water or Gas (pCi/kg, wet) Milk (pCi/kg, (pCi/kg, Analysis (pCi/l) (pCi/m 3) (pCiIl) wet) dry) gross beta Ix 10-2 H-3 2000' Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 1-131 15C 7 x 10-2 1 60b 2 15 60 150 Cs-134 15 5 x 10- 130 Cs-137 18 6 x 10.2 150 18 80 180 Ba-140 60c 70 La-140 15c 25 I.E-I0

REMM Revision 21 TABLE IE-4 (Cont'd)

TABLE NOTATIONS

a. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95%

probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

LLD = 4.66 Sb E V- 2.22 .Y. exp (- X At) where:

LLD is the lower limit of detection as defined abpve (as pCi per unit mass or volume)

Sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)

E is the counting efficiency (as counts per transformation)

V is the sample size (in units of mass or volume) 2.22 is the number of transformations per minute per picocurie Y is the fractional radiochemical yield (when applicable)

X is the radioactive decay constant for the particular radionuclide At is the elapsed time between midpoint of sample collection (or end of the sample collection period) and time of counting.

It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified in the Annual Radiological Environmental Operating Report.

b. LLD for leafy vegetables.

c. From end of sample period.

d. If no drinking water pathway exists (i.e., seawater), a value of 3,000 pCi/l may be used.

I.E-11

REMM Revision 21 I.E. RADIOLOGICAL ENVIRONMENTAL MONITORING (Cont'd)

2. Land Use Census The land use census ensures that changes in the use of unrestricted areas are identified and that modifications to the monitoring program are made if required by the results of this census. This census satisfies the requirements of Section IV.B.3 of Appendix Ito 10 CFR Part50. The land use census shall be maintained and shall identify the location of the nearest resident, nearest garden*, and milk animals in each of the 16 meteorological sectors within a distance of five miles.

The validity of the land use census shall be verified within the last half of every year by either a door to-door survey, aerial survey, consulting local agriculture authorities, or any combination of these methods.

With a land use census identifying a location(s) which yields a calculated dose or dose commitment greater than the doses currently being calculated in the off-site dose models, make the appropriate changes in the sample locations used.

With a land use census identifying a location(s) which has a higher D/Q than a current indicator location the following shall apply:

(1) If the D/Q is at least 20% greater than the previously highest D/Q, replace one of the present sample locations with the new one within 30 days if milk is available.

(2) If the D/Q is not 20% greater than the previously highest D/Q, consider direction, distance, availability of milk, and D/Q in deciding whether to replace one of the existing sample locations.

If applicable, replacement shall be within 30 days. If no replacement is made, sufficient justification shall be given in the annual report.

Sample location changes shall be noted in the Annual RadiologicalEnvironmentalOperatingReport.

Broad leaf vegetation (a composite of at least 3 different kinds of vegetation) may be sampled at the site boundary in each of 2 different direction sectors with high D/Qs in lieu of a garden census.

I.E-12

REMM Revision 21 I.E. RADIOLOGICAL ENVIRONMENTAL MONITORING (Cont'd)

3. Interlaboratorv Comparison Program The Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of a quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid.

Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program. A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report.

With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report.

4. Bases for the Radiological Environmental Monitorine Program Federal regulations (10 CFR Parts 20 and 50) require that radiological environmental monitoring programs be established to provide data on measurable levels of radiation and radioactive materials in the site environs. In addition, Appendix I to 10 CFR Part 50 requires that the relationship between quantities of radioactive material released in effluents during normal operation, including anticipated operational occurrences, and the resultant radiation doses to individuals from principal pathways of exposure be evaluated. The Millstone Environmental Radiological Monitoring Program (REMP) has been established to verify the effectiveness of in-plant measures used for controlling the release of radioactive materials from the plant, as well as provide for the comparison of measurable concentrations of radioactive materials found in the environment with expected levels based on effluent measurements and the modeling of the environmental exposure pathways.

The REMP detailed in Table I.E-I provides measurements of radioactive materials or exposures in the environment along all principal exposure pathways to man that could be impacted by plant effluents.

These include direct radiation exposure, inhalation exposure, and ingestion of food products (both aquatic and land grown). In addition, intermediate media such as vegetation and bottom sediments are included as potential early indicators of radioactive material buildup. The selections of sample locations include areas subject to plant effluents that would be expected to exhibit early indication of any buildup of plant related radioactive materials.

The required detection capabilities for environmental sample analyses are tabulated in terms of lower limits of detection (LLDs). Except for Ba-140 and La-140 in milk, the required LLDs are from NUREGs-1301 and 1302. The NUREGs specify an LLD of 15 pCi/l for the parent-daughter combination of Ba-La-140. An LLD of 25 pCi/1 is specified for the daughter La-140 and 70 pCi/I for the parent Ba-140.

Annual reports of environmental radiation monitoring summaries are filed with the NRC in accordance with the requirements of 10 CFR Part 50.36b and the guidance contained in Regulatory Guide 4.8, "EnvironmentalTechnical Specificationsfor Nuclear PowerPlant," and NUREG-0472 (NUREG 0473) Revision 3, "StandardRadiologicalEffluent TechnicalSpecificationsfor PressurizedWater Reactors (Boiling Water Reactors)."

I.E-13

REMM Revision 21 I.F. REPORT CONTENT

1. Annual Radiological Environmental Operatin2 Report The Annual RadiologicalEnvironmentalOperatingReport shall include summaries, interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the report period, including a comparison with previous environmental surveillance reports and an assessment of the observed impacts of the plant operation on the environment. The report shall also include the results of the land use census required by Section I.E.2 of this manual. If levels of radioactivity are detected that result in calculated doses greater than 10CFR50 Appendix I Guidelines, the report shall provide an analysis of the cause and a planned course of action to alleviate the cause.

The report shall include a summary table of all radiological environmental samples which shall include the following information for each pathway sampled and each type of analysis:

I. Total number of analyses performed at indicator locations.

2. Total number of analyses performed at control locations.

3. Lower limit of detection (LLD).

4. Mean and range of all indicator locations together.

5. Mean and range of all control locations together.

6. Name, distance and direction from discharge, mean and range for the location with the highest annual mean (indicator or control).

7. Number of nonroutine reported measurements as defined in these specifications.

In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual report.

This report shall include a comparison of dose assessments of the measured environmental results of the calculated effluent results to confirm the relative accuracy or conservatism of effluent monitoring dose calculations.

The report shall also include a map of sampling locations keyed to a table giving distances and directions from the discharge; the report shall also include a summary of the Interlaboratory Comparison Data required by Section I.E.3 of this manual.

i.F-1

REMM Revision 21 F.2 Radioactive Effluent Release Report The RadioactiveEffluent Release Report (RERR) shall include quarterly quantities of and an annual summary of radioactive liquid and gaseous effluents released from the unit in the Regulatory Guide 1.21 (Rev. 1, June 1974) format. Radiation dose assessments for these effluents shall be provided in accordance with 10 CFR 50.36a and the RadiologicalEffluent Controls. An annual assessment of the radiation doses from the site to the most likely exposed REAL MEMBER OF THE PUBLIC shall be included to demonstrate conformance with 40 CFR 190. Gaseous pathway doses shall use meteorological conditions concurrent with the time of radioactive gaseous effluent releases. Doses shall be calculated in accordance with the Offsite Dose CalculationManual. The licensee shall maintain an annual summary of the hourly meteorological data (i.e., wind speed, wind direction and atmospheric stability) either in the form of an hour-by-hour listing on a magnetic medium or in the form of a joint frequency distribution. The licensee has the option of submitting this annual meteorological summary with the RERR or retaining it and providing it to the NRC upon request. The RERR shall be submitted prior to May I of each year for the period covering the previous calendar year.

The RERR shall include a summary of each type of solid radioactive waste shipped offsite for burial or final disposal during the report period and shall include the following information for each type:

"* type of waste (e.g., spent resin, compacted dry waste, irradiated components, etc.)

"* solidification agent (e.g., cement)

"* total curies

"* total volume and typical container volumes

"* principal radionuclides (those greater than 10% of total activity)

"* types of containers used (e.g., LSA, Type A, etc.)

The RERR shall include the following information for all abnormal releases of radioactive gaseous and liquid effluents (i.e., all unplanned or uncontrolled radioactivity releases, including reportable quantities) from the site to unrestricted areas:

"* total number of and curie content of releases (liquid and gas)

"* a description of the event and equipment involved

"* cause(s) for the abnormal release

"* actions taken to prevent recurrence

"* consequences of the abnormal release Changes to the RADIOLOGICAL EFFLUENTMONITORING and OFFSITEDOSE CALCULATION MANUAL (REMODCM)shall be submitted to the NRC as appropriate, as a part of or concurrent with the RERR for the period in which the changes were made.

I.[F-2

SECTION II OFFSITEDOSE CAL CULA TION MANUAL (ODCM)

FOR THE MILLSTONE NUCLEAR POWER STATION UNIT NOs. 1, 2, & 3 DOCKET NOs. 50-245, 50-336, 50-423 Revision 21 January 26, 2001

ODCM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM)

SECTION II: OFFSITE DOSE CALCULATION MANUAL (ODCM)

TABLE OF CONTENTS SECTION PAGE NO

.lI-i TABLE OF CONTENTS .....................................................................................

IN TR OD U CTIO N .............................................................................................................. II.A -1 II.A .

RESPO N SIBILITIES ........................................................................................................ II.B-1 II.B.

LIQUID DOSE CALCULATIONS ................................................................................... II.C-l II.C.

1. Whole Body Dose from Liquid Effluents ................................................................. II.C-1

a. Method 1 (Applicable to Units 1, 2, and 3) ..................................................... I.C-A

b. Method 2 (Applicable to Units 1, 2, and 3) ..................................................... II.C-2

2. Maximum Organ Dose from Liquid Effluents ........................................................... II.C-2

a. Method I (Applicable to Units 1, 2, and 3) ..................................................... II.C-2

b. Method 2 (Applicable to Units 1, 2, and 3) ..................................................... II.C-2

3. Estimation of Annual Whole Body Dose (Applicable All Units) .............................. II.C-3

4. Estimation of Annual Maximum Organ Dose (Applicable All Units) ....................... II.C-3

5. M onthly Dose Projections .......................................................................................... II.C-4

a. Whole Body and Maximum Organ (Applicable Unit 1 Only) ......................... Il-C-4

b. Whole Body and Maximum Organ (Applicable Units 2 and 3) ...................... Il-C-5

6. Quarterly Dose Calculations for Radioactive Effluent Release Report ...................... II-C-5

7. Bases Whole Body and Maximum Organ Liquid Doses ............................................ II.C-6 GASEOUS DOSE CALCULATIONS ............................................................................... II.D-1 II.D.

1. Site Release Rate Limits ("Instantaneous") ............................................................... II.D-1

a. Method I for Noble Gases Release Rate Limits .............................................. II.D-1

b. Method I for Release Rate Limit.- 1-13 1, 1-133, H-3 and Particulates with Half Lives Greater than 8 Days ....................................................................... II.D-I

c. M ethod 2 ......................................................................................................... II.D -2

2. 10CFR50 Appendix I - Noble Gas Limits ................................. ........................... II.D-3

a. Method 1 Air Dose (Applicable to Units 1, 2, and 3) ................... II.D-3

b. Method 2 Air Dose (Applicable to Units 1, 2, and 3) ..................................... II.D-4

c. Estimation of Annual Air Dose Limit Due to Noble Gases (Applicable to U nits 1, 2, and 3) ............................................................................................. II.D 4

3. 10CFR50 Appendix I - Iodine and Particulate Doses ............................................... I.D-5

a. Critical Organ Doses (Applicable to Unit 1 releases) .................... . ID-5

b. Critical Organ Doses (Applicable to Unit 2 or Unit 3 Releases to the M illstone Stack) .................................................................... II.D-5

c. Critical Organ Doses (Applicable to Units 2 and Unit 3 vent releases) .......... II.D-8

d. Estimation of Annual Critical Organ Dose Due to lodines, Tritium and Particulates (Applicable to Units 1, 2, and 3) .......................... II.D- 1I II-i

ODCM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTION II: OFFSITEDOSE CALCULATION MANUAL (ODCM)

TABLE OF CONTENTS SECTION PAGE NO

4. Gaseous Effluent Monthly Dose Projections ................................................ Il.D-12

a. Unit 1 Projection M ethod ................................................................................ II.D-12

b. Unit 2 Projection M ethod ................................................................................ II.D -13

c. Unit 3 Projection M ethod ................................................................................ II.D -14

5. Quarterly Dose Calculations for Radioactive Effluent Release Report ............. II.D-l 5

6. Compliance with 40CFR190 ...................................................................................... II.D-16

7. Bases for Gaseous Pathway Doses ............................................................................. II.D-16 II.E. LIQUID MONITOR SETPOINT CALCULATIONS ..................................................... II.E-1

1. Unit I Liquid Radwaste Effluent Line ....................................................................... II.E-l

2. RE SER V ED ............................................................................................................... II.E-2

3. Unit 2 Clean Liquid Radwaste Effluent Line ............................................................. Il.E-2

4. Unit 2 Aerated Liquid Radwaste Effluent Line and Condensate Polishing Facility Waste Neutralization Sump Effluent Line ................................................................. II.E-4

5. a. Unit 2 Steam Generator Blowdown ................................................................. II.E-4

b. Unit 2 Steam Generator Blowdown Effluent Concentration Limitation .......... 1l.E-5

6. Unit 2 Condenser A ir Ejector .................................................................................... II.E-5

7. a. Unit 2 Reactor Building Closed Cooling Water .............................................. II.E-5

b. Unit 2 Service Water and Turbine Building Sump Effluent C oncentration Lim it ........................................................................................ II.E-5

8. U nit 3 Liquid Waste M onitor ..................................................................................... II.E-6

9. Unit 3 Regenerant Evaporator Effluent Line ............................................................. II.E-7

10. Unit 3 Waste Neutralization Sump Effluent Line ...................................................... II.E-7

11. a. Unit 3 Steam Generator Blowdown ................................................................. II.E-8

b. Unit 3 Steam Generator Blowdown Effluent Concentration Limit .................. II.E-8

12. a. Unit 3 Turbine Building Floor Drains Effluent Line .................... II.E-9

b. Unit 3 Service Water and Turbine Building Sump Effluent Concentration Lim itation ................................................................................ .II.E-9

13. Bases for Liquid Monitor Setpoints ........................................................................... II.E-9 11-ii

ODCM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENT MONITORING AND OFFSITEDOSE CALCULA TION MANUAL (REMODCM)

SECTION II: OFFSITE DOSE CALCULA TION MANUAL (ODCM)

TABLE OF CONTENTS SECTION PAGE NO II.F. GASEOUS - MONITOR SETPOINT CALCULATIONS .............................................. II.F-I

1. Unit 1 Spent Fuel Pool Island Vent ........................................................................... II.F-I

2. Section reserved ......................................................................................................... II.F-1

3. Unit 2 Wide Range Gas Monitor (WRGM) - RM8169 ............................................. II.F-2

4. Unit 3 SLCR S ............................................................................................................ II.F-2

5. Unit 2 Vent Noble Gas Monitor ................................................................................. II.F-2

6. Unit 2 Waste Gas Decay Tank Monitor ..................................................................... II.F-3

7. Unit 3 Vent Noble Gas Monitor ................................................................................. II.F-3

8. Unit 3 Engineering Safeguards Building Monitor ...................................................... II.F-3

9. Bases for Gaseous Monitor Setpoints ........................................................................ II.F-4 II-iii

ODCM Revision 21 MILLSTONE STATION RADIOLOGICAL EFFL UENT MONITORING AND OFFSITEDOSE CALCULA TION MANUAL (REMODCM)

SECTION II: OFFSITEDOSE CALCULA TION MANUAL (ODCM)

TABLE OF CONTENTS (Cont'd)

APPENDICES APPENDIX II.A REMODCM Methodology Cross-References II-iv

ODCM Revision 21 II.A. INTRODUCTION The purpose of the Off-Site Dose Calculation Manual (Section II of the REMODCM) is to provide the parameters and methods to be used in calculating offsite doses and effluent monitor setpoints at the Millstone Nuclear Power Station. Included are methods for determining maximum individual whole body and organ doses due to liquid and gaseous effluents to assure compliance with the regulatory dose limitations in 10 CFR Part 50, Appendix I. Also included are methods for performing dose projections to assure compliance with the liquid and gaseous treatment system operability sections of the Radiological Effluent MonitoringManual (REMM - Section I of the REMODCM). The manual also includes the methods used for determining quarterly and annual doses for inclusion in the RadioactiveEffluent Release Report.

The bases for selected site-specific factors used in the dose calculation methodology are provided in Reference Manual MP-13-REM-REF02, REMODCM Technical Information.

Another section of this manual discusses the methods to be used in determining effluent monitor alarm/trip setpoints to be used to ensure compliance with the instantaneous release rate limits in Sections Il.D.2.a, IV.E.2.a, and VE.2.a.

This manual includes the methods to be used in performance of the surveillance requirements in the Radiological Effluent Controls of Sections I11,IV, and V. Appendix A, Tables App.A-1 and App.A-2 provide a cross-reference of effluent requirements and applicable methodologies contained in the REMODCM.

Most of the calculations in this manual have several methods given for the calculation of the same parameter. These methods are arranged in order of simplicity and conservatism, Method 1 being the easiest and most conservative. As long as releases remain low, one should be able to use Method 1 as a smnple estimate of the dose. If release calculations approach the limit, however, more detailed yet less conservative calculations may be used At any time a more detailed calculation may be used in lieu of a simple calculation.

This manual is written common to all three units since some release pathways are shared and there are also site release limits involved. These facts make it impossible to completely separate the three units.

II.A-I

ODCM Revision 21 II.B. RESPONSIBILITIES All changes to the Off-Site Dose Calculation Manual (ODCM) shall be reviewed and approved by the Site Operations Review Committee prior to implementation.

All changes and their rationale shall be documented in the RadioactiveEffluent Release Report.

It shall be the responsibility of the Senior Vice President and CNO - Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications. The delegation of implementation responsibilities is delineated in the Millstone Radiological Effluent Program Reference Manual (MP- 13-REM-REFO 1).

II.B-I

ODCM Revision 21 II.C. LIQUID DOSE CALCULATIONS The determination of potential doses from liquid effluents to the maximum exposed member of the public is divided into two methods. Method I is a simplified calculation approach that is used as an operational tool to ensure that effluent releases as they occur are not likely to cause quarterly and annual offsite dose limits to be exceeded. Effluent doses are calculated at least once every 31 days. Method 2 is a more detailed computational calculation using accepted computer models to demonstrate actual regulatory dose compliance.

Method 2 is used whenever the Method I estimation begins to approach a regulatory limit, and for preparation of the Radioactive Effluent Release Report which includes the quarterly and annual dose impacts for all effluents recorded discharged to the environment during the year of record.

1. Whole Body Dose from Liquid Effluents Radiological Effluent Controls (Sections III, IV, and V) limit the whole body dose to an individual member of the public to 1.5 mrem per calendar quarter and 3 mrem per year from liquid effluents released from each unit. (See Appendix A, Tables App.A-1 and App.A-2 for cross-reference effluent control requirements and applicable sections in the REMODCM which are used to determine compliance). In addition, installed portions of liquid radwaste treatment system are required to be operated to reduce radioactive materials in liquid effluents when the projected whole body dose over 31 days from applicable waste streams exceeds 0.006 mrero. This part of the REMODCM provides the calculation methodology for determining the whole body dose from radioactive materials released into liquid pathways of exposure associated with routine discharges. This includes the liquid pathways which contribute to the 25 mrem annual total dose limit (40 CFR1 90) to any real individual member of the public from all effluent sources (liquids, gases, and direct).

a. Method 1 (Applicable to Units 1, 2, and 3)

For Unit 1:

Dw = 2.5 CF + 5.6 x 10"7 CH For Units 2 and 3:

Dw = 2 x 10-2 CF + 5.6 x 10-7 CH Where:

Dw = The estimated whole body dose to a potentially maximum exposed individual (in nirem) due to fission and activation products released in liquid effluents during a specified time period.

CF = total gross curies of fission and activation products, excluding tritium and dissolved noble gases, released during the period of interest.

CH = total curies of tritium released during the period of interest.

If Dw, within a calendar quarter is greater than 0.5 mrem, go to Method 2.

II.C-1

ODCM Revision 21 I1.C. LIQUID DOSE CALCULATIONS (Cont'd)

b. Method 2 (Applicable to Units 1. 2, and 3)

If the calculated dose using Method I is greater than 0.5 mrem within a calendar quarter, or if a more accurate determination is desired, use the NRC computer code LADTAP II, or a code which uses the methodology given in Regulatory Guide 1.109, to calculate the liquid whole body doses. Method 2 (LADTAP II) is also used in the performance of dose calculations for the Radioactive Effluent Release Report. The use of this code is given in Engineering Procedure RAB B-11, Liquid Dose Calculations- LADTAPIL Additional information on LADTAPII is contained in the REMODCM Technical Information Manual (MP- 13-REM REF02).

2. Maximum Organ Dose from Liquid Effluents Radiological Effluent Controls (Sections III, IV, and V) limit the maximum organ dose to an individual member of the public to 5 mrem per calendar quarter and 10 mrem per year from liquid effluents released from each unit. (See Appendix A, Tables App.A-l and App.A-2 for cross reference effluent control requirements and applicable sections in the REMODCM which are used to determine compliance). In addition, installed portions of liquid radwaste treatment system are required to be operated to reduce radioactive materials in liquid effluents when the projected maximum organ dose over 31 days from applicable waste streams exceeds 0.02 mrem. This part of the REMODCM provides the calculation methodology for determining the maximum organ dose from radioactive materials released into liquid pathways of exposure associated with routine discharges.

This includes the liquid pathways which contribute to the 25 mrem annual organ (except 75 mrem thyroid) dose limit (40 CFR190) to any real individual member of the public from all effluent sources (liquids, gases, and direct).

a. Method I (Applicable to Units 1. 2. and 3)

For Unit 1:

Do = 2.1 CF For Units 2 and 3:

Do = 0.2 CF Where:

Do = The estimated maximum organ dose to the potentially maximum exposed individual (in mrem) due to fission and activation products released in liquid effluents during a specified time period.

Cr = total gross curies of fission and activation products, excluding tritium and dissolved noble gases, released during the period of interest - same as Section H.C. .a.

If Do, within a calendar quarter is greater than 2 mrem, go to Method 2.

b. Method 2 (Applicable to Units 1, 2, and 3)

If the calculated dose using Method I is greater than 2 mrem, or if a more accurate determination is desired, use the NRC computer code LADTAP II, or a code which uses the methodology given in Regulatory Guide 1.109, to calculate the liquid maximum organ doses. Method 2 (LADTAP II) is also used in the performance of dose calculations for the Radioactive Effluent Release Report. The use of this code and the input parameters are given in Engineering Procedure RAB B-11, Liquid Dose Calculations- LADTAP IH.

Additional information on LADTAPII is contained in the REMODCM Technical Information Manual (MP- 13-REM-REF02).

II.C-2

ODCM Revision 21 II.C. LIQUID DOSE CALCULATIONS (Cont'd)

3. Estimation of Annual Whole Body Dose (Applicable to All Units)

An estimation of annual (year-to-date) whole body dose (Dyw) from liquid effluents shall be made every month to determine compliance with the annual dose limits for each Unit. Annual doses will be determined as follows:

Dyw = I Dw where the sum of the doses include the whole body dose contribution from all effluent releases for each Unit recorded to-date. For estimation of the Total Dose requirements of 40CFRI90, the effluent releases from all three Units combined are used.

The following shall be used as Dw:

(0) If the detailed quarterly dose calculations required per Section II.C.6 for the Radioactive Effluent Release Report are completed for any calendar quarter, use that result.

(2) If the detailed calculations are not complete for a particular quarter, use the results as determined in Section II. C. 1.

(3) If the annual dose estimate, Dyw, is greater than 3 mrem and any Dw determined as in Section II.C. I was not calculated using Method 2 (i.e., LADTAP II computer code or a Regulatory Guide 1.109 code), recalculate Dw using Method 2 if this could reduce DYw to less than 3 mrem.

4. Estimation of Annual Maximum Organ Dose (Applicable to All Units)

An estimation of annual (year-to-date) maximum organ dose (Dyo) from liquid effluents shall be made every month to determine compliance with the annual dose limits for each Unit. Annual doses will be determined as follows:

Dyo = I Do where the sum of the doses include the maximum organ dose contribution from all effluent releases for each Unit recorded to-date. For estimation of the Total Dose requirements of 40CFRI90, the effluent releases from all three Units combined are used.

The following guidelines shall be used:

(1) If the detailed quarterly dose calculations required per Section HI. C.6 for the Radioactive Effluent Release Report are completed for any calendar quarter, use that result.

(2) If the detailed calculations are not complete for a particular quarter, use the results as determined in Section H.IC.2.

(3) If different organs are the maximum for different quarters, they may be summed together and Dv 0 can be recorded as a less than value as long as the value is less than 10 mrem.

(4) If Dv 0 is greater than 10 mrem and any value used in its determination was calculated as in Section II. C.2, but not with Method 2 (i.e., LADTAP II computer code or a Regulatory Guide 1.109 code), recalculate that value using Method 2 if this could reduce Dy 0 to less than 10 mrem.

II.C-3

ODCM Revision 21 II.C. LIQUID DOSE CALCULATIONS (Cont'd)

5. Monthly Dose ProjectionsSection I.C.2.a of the REMM requires that certain portions of the liquid radwaste treatment equipment be used to reduce radioactive liquid effluents when the projected doses for each Unit (made at least once per 31 days) exceeds 0.006 mrem whole body or 0.02 mrem to any organ. The following methods are applied in the estimation of monthly dose projections:

a. Whole Body and Maximum Organ (Applicable to Unit 1 Only)

The projected monthly whole body dose (Unit 1) is determine from:

DE v = D'MW

R 1

F The projected monthly maximum organ dose is determine from:

DEmo = D'Mo

R,

F Where:

D'MW = the whole body dose from the last typical (see Notes below) previously completed month as calculated per the methods in Section II.C.1.

D'mo = the maximum organ dose from the last typical (see notes) previously completed month as calculated per the methods in Section IH.C.2.

Ri = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month.

F = the factor to be applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers). NUREG-0016 or past experience shall be used to determine the effect of each form of treatment which will vary.

F = 1 if there are no expected differences.

Notes:

I. The last typical month should be one without significant operational differences from the projected month.

2. If there were no releases during last month, do not use that month as the base month if it is estimated that there will be releases for the coming month.

3. If the last typical month's doses were calculated using LADTAP II (or similar methodology), also multiply the LADTAP doses by R 5 where R5 = total dilution flow from LADTAP run divided by estimated total dilution flow.

II.C-4

ODCM Revision 21 II.C. LIQUID DOSE CALCULATIONS (Cont'd)

b. Whole Body and Maximum Or2an (Applicable to Units 2 and 3)

The projected monthly whole body dose (Units 2 or 3) is determined from:

DEMw = D'MW [(I - F1 ) R1 R 4 F2 + F1 R 2R 3]

The monthly projected maximum organ dose (Units 2 or 3) is determined from:

DEMO = D'Mo [(I - FI) R, R4 F2 + FI R 2 R3]

Where:

D'mw= the whole body dose from the last typical* previously completed month as calculated per the methods in Section IT.C.1.

D'Mo = the maximum organ dose from the last typical* previously completed month as calculated per the methods in Section II.C.2.

Note: See notes in Section II.C.5.a.

R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month.

R2 = the ratio of estimated volume of steam generator blowdown to be released in present month to the volume released in the past month.

F, = the fraction of curies released last month coming from steam generator blowdown calculated as:

curies from blowdown curies from blowdown + curies from batch tanks R3 = the ratio of estimated secondary coolant activity for the present month to that for the past month.

R4 = the ratio of estimated primary coolant activity for the present month to that for the past month.

F2 the factor to be applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers). NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.

6. Quarterly Dose Calculations for Radioactive Effluent Release Report Detailed quarterly dose calculations required for the Radioactive Effluent Release Report shall be done using the NRC computer code LADTAP II, or a code which uses the methodology given in Regulatory Guide 1. 109,. The use of this code, and the input parameters are given in Engineering Procedure,RAB B-11, Liquid Dose Calculations- LADTAP H1. Additional information on LADTAPII is contained in the REMODCM Technical Information Manual (MP-13-REM-REF02).

II.C-5

ODCM Revision 21 II.C. LIQUID DOSE CALCULATIONS (Cont'd)

7. Bases for Liquid Pathway Dose Calculations The dose calculation methodology and parameters used in Section II of the REMODCM implement the requirements in Section III.A of Appendix I (10CFR50) which states that conformance with the dose objectives of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a member of the public through appropriate pathways is unlikely to be substantially underestimated. The dose estimations calculated by both Method 1 and Method 2 are based on the liquid models presented in Regulatory Guide 1.109, Rev.1; "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR Part 50, Appendix I". These equations are implemented via the use of the NRC sponsored computer code LADTAP II. Input parameter values typically used in the dose models are listed in Reference Manual, "REMODCMTechnical Information Document (MP-13-REM-REF02).

This same methodology is used in the determination of compliance with the 40CFR190 total dose standard for the liquid pathways.

The conversion constants in the Method I equations are based on the maximum observed comparison of historical effluent releases for each unit and corresponding whole body or critical organ doses to a maximum individual. The dose conversion factors are calculated based on the ratio of the observed highest dose (whole body and organ) and the curies of fission and activation products released during the period. This ratio results in the Method I equation conversion factor in mrem/Ci released. This same approach was repeated separately for tritium (as a different radionuclide class) discharged in liquids wastes. Reference Manual MP-13-REM-REF02 describes the derivation of the Method I constants and list the historical whole body and maximum organ doses calculated for each unit operation.

II.C-6

ODCM Revision 21 II.D. GASEOUS DOSE CALCULATIONS The determination of potential release rates and doses from radioactive gaseous effluents to the maximum off-site receptor are divided into two methods. Method 1 provides simplified operational tools to ensure that effluent releases are not likely to cause quarterly and annual off-site dose or dose rate limits to be exceeded. Effluent doses are calculated at least once every 31 days. Method 2 provides for a more detailed computational calculation using accepted computer models to demonstrate actual regulatory compliance. Method 2 is used whenever the Method 1 estimation approaches a regulatory limit, and for preparation of the Radioactive Effluent Release Report which includes the quarterly and annual dose impacts for all effluents recorded discharged to the atmosphere during the year of record.

1. Site Release Rate Limits ("Instantaneous")

Radiological Effluent Controls (Sections III. IV, and V) for each unit require that the instantaneous off-site dose rates from nobles gases released to the atmosphere be limited such that they do not exceed 500 mrem/year at any time to the whole body or 3000 mrem/year to the skin at any time from the external cloud. For iodine 131, 133, tritium, and particulates (half-lives > 8 days), the inhalation pathway critical organ dose rate from all units shall not exceed 1500 mrem/year at any time. These limits apply to the combination of releases from all three Units on the site, and are directly related to the radioactivity release rates measured for each Unit. By limiting gaseous release rates for both classes of radionuclides (i.e., noble gases; and iodines, tritium, and particulates) to within values which correlate to the above dose rate limits, assurance is provided that the Radiological Effluent Controls dose rate limits are not exceeded.

a. Method 1 for Noble Gas Release Rate Limits The instantaneous noble gas release rate limit from the site shall be:

When Unit 1 is discharging to the Millstone Stack (without SFPI vent):

9 Qls/1,100,000 + Q2v/ 2 9 0,000 + Q3v/ 2 0,000 < I When Unit 1 is discharging to the Millstone Stack (with SFPI vent):

29 QISll,100,000 + Qiv /90,000+Q2v/ 2 9 0,000 + Q3v/ 0,000 < 1 When Unit 1 is not discharging to the Millstone Stack:

29 Qiv /90,000 +Q2s/560,000 + Q2v/290,000+Q3s /560,000 + Q3v/ 0,000< 1 Where: Qjs = Noble gas release rate from Millstone Stack (lgCi/sec)

Qjv = Noble gas release rate from Spent Fuel Pool Island Vent (pCi/sec)

Q2s = Noble gas release rate from MP2 to Millstone Stack (gCilsec)

Q2v = Noble gas release fate from MP2 Vent (pCi/sec)

Q3s = Noble gas release rate from MP3 to Millstone Stack (PtCi/sec)

Q3v = Noble gas release rate from MP3 Vent (liCi/sec)

As long as the above is less than or equal to 1, the doses will be less than or equal to 500 mrem to the total body and less than 3000 mrem to the skin. The limiting factor for the Unit 1 SFPI vent of 90,000 is based on the skin dose limit of 3,000 mrem/year, while all the other factors are based on the whole body dose limit of 500 mrem/year.

b. Method IRelease Rate Limit 131, 1-133, H-3 and Particulates Half Lives Greater Than 8 Days With releases satisfying the following limit conditions, the dose rate to the maximum organ will be less than 1500 mrem/year from the inhalation pathway:

(1) The site release rate limit of 1-131, 1-133, and tritium (where the thyroid is the critical organ for these radionuclides) shall be:

DRthy, + DRthy2 + DRthy3 < 1 II.D- 1

ODCM Revision 21 Where the contribution from each Unit is calculated from:

When Unit I is discharging to the Millstone Stack:

Unit 1 (without SFPI vent): DRhyl= 5.5 x 10"431QIs + 1.33 x 10.4 133Q]s + 4.4 x 10.8 QHIS Unit 1 (with SFPI vent): DRhy1=5.5 x 10-4131QIs + 1.33 x 10.4 1QIS + 4.4 x 10" QHIS +9.36 x 10-6 QHJv Unit 2: Dlhy2= 5.1 X 10.2 13Q12zv+ 1.25 x 10.2 133Q12V + 4.2 x 10-6 QHmv Unit 3: DRhy3 =5.1 x 10.2 131Qi3v + 1.25 x 10.2 133Q13V + 4.2 x 10.6 QH3V When Unit 1 is not discharging to the Millstone Stack:

Unit 1: DRbyl= 9.36 x 10-6 QHIv Unit 2: DRy2= 5.1 x 10"213Qi 2v+2.38 x 10.31Q12S+ 1.25 x 10"2 33Q,2v+5.75 x 10 133Q12s+

4.2 x 10-6QH2v+1.9 x 10.7 QRs Unit 3: DR'y 3 =5.1 x 10"2 131Q13v + 2.38 x 103 131Q13s+ 1.25 x 10.2 133Q13V +5.75 x 10-4433Q3s+

4.2 x 10-6 QH3v +l.9x 10-7 QH3S (2) The site release rate limit of particulates with half-lives greater than 8 days and tritium (where the critical organ is a composite of target organs for a mix of radionuclides) shall be:

DRorgi + DR.g + DRorg 3 < 1 Where the contribution from each Unit is calculated from:

When Unit I is discharging to the Millstone Stack:

Unit I (without SFPI vent): DR&, = 5.5 x 104 Qpis + 4.4 x 10" QHs Unit I (with SFPI vent): DR&gl = 5.5 x 104 Qpis + 4.4 x 10-8 QmHs+ 1.05 x 10"' Qpiv +9.36 x 10-6 QH1v Unit 2: DRo&g = 5.1 x 10.2 QP2v+ 4.2 x 10'6 QH2V Unit 3: DRog 3 = 5.1 x 10.2 QP3v + 4.2 x l0"6 QH3V When Unit 1 is not discharging to the Millstone Stack:

[NOTE: Contribution from Unit I BOP vent not required until BOP sampler becomes operational.]

Unit 1: DR&,g, =1.05x 10l [QPlv+QP]B]+9.36x l06 QHiv Unit 2: DRorg2 = 2.38 x 10-3 Qp2s + 5.1 x 10"2 QP2v + 1.9 x 10-7 QH2S + 4.2 x 10"6 QH2V Unit 3: DRog 3 =2.38x 10-3 QP 3s+ 5.1 x 10-2 QP3v+ 1.9x 10-7 QH3S + 4 . 2 x 10-6 QH3V Each of the release rate quantities in the above equations are defined as:

131QIs = Release rate of 1-131 from the Millstone Stack (pCi/sec) 133QIS = Release rate of 1-133 from the Millstone Stack (ptCi/sec)

I3Q12v= Release rate of 1-131 from MP2 Vent (hICi/sec)*

131QI2S= Release rate of 1-131 from MP2 to Millstone Stack (jiCi/sec) 133Q12v = Release rate of 1-133 from MP2 Vent (p.Ci/sec)*

133Q12 = Release rate of 1-133 from MP2 to Millstone Stack (pCi/sec) 131Q13v = Release rate of 1-131 from MP3 Vents (Normal and ESF) (,iCi/sec)*

131Q13S= Release rate of 1-131 from MP3 to Millstone Stack (pCi/sec) 133Q13v = Release rate of 1-133 from MP3 Vents (Normal and ESF) (plCi/sec)*

133Q13s= Release rate of 1-133 from MP3 to Millstone Stack (lpCi/sec)

QHjs = Release rate of tritium from the Millstone Stack (pCi/sec)

QHV - Release rate of tritium from the Spent Fuel Pool Island Vent (jiCi/sec)

QHmv = Release rate of tritium from MP2 Vent (pCi/sec)*

QHs = Release rate of tritium from MP2 to Millstone Stack (pCi/sec)

QH3V = Release rate of tritium from MP3 Vents (Normal and ESF) (pCi/sec)*

QH3S = Release rate of tritium from MP3 to Millstone Stack (ptCi/sec)

Qpjs =Release rate of total particulates with half-lives greater than 8 days from the Millstone Stack (pCi/sec)

Qplv= Release rate of total particulates with half-lives greater than 8 days from the Spent Fuel Pool Island Vent (tCi/sec)

Qpli = Release rate of total particulates with half-lives greater than 8 days from the Balance of Plant Vent (pCi/sec)

II.D- 2

ODCM Revision 21 QP2v = Release rate of total particulates with half-lives greater than 8 days from the MP2 Vent (pCi/sec)

QP2s = Release rate of total particulates with half-lives greater than 8 days from MP2 to Millstone Stack (fLCi/sec)

QP3v = Release rate of total particulates with half-lives greater than 8 days from the MP3 Vents (Normal and ESF) (gCi/sec)

QP3S = Release rate of total particulates with half-lives greater than 8 days from MP3 to Millstone Stack

([tCi/sec)

includes releases via the steam generator blowdown tank vent.

c. Method 2 The above Method 1 equations assume a conservative nuclide mix. If necessary, utilize the GASPAR, or a code which uses the methodology given in Regulatory Guide 1.109, code to estimate the dose rate from either noble gases or iodines, tritium, and particulates with half-lives greater than 8 days. The use of the code is described in Engineering Procedure RAB-B12, GaseousDose Calculations - GASPAR. Additional information on GASPAR is contained in the REMODCM Technical Information Manual (MP-13-REM REF02).

II.D- 3

ODCM Revision 21

2. 10 CFRS0 Appendix I - Noble Gas Limits Radiological Effluent Controls (Sections III, IV, and V) limit the off-site air dose from noble gases released in gaseous effluents to 5 mrad gamma and 10 mrad beta for a calendar quarter (10 and 20 mrad gamma and beta, respectively, per calendar year). Effluent dose calculations are calculated at least once every 31 days. In addition, installed portions of the gaseous radwaste treatment system are required to be operated to reduce radioactive materials in gaseous effluents when the projected doses over 31 days from the applicable waste stream exceed 0.02 mrad air gamma or 0.04 mrad air beta. (See Appendix A, Tables App.A-1 and App.A-2 for a cross reference of effluent control requirements and applicable sections of the REMODCM which are used to determine compliance.) This part of the REMODCM provides the calculation methodology for determining air doses from noble gases.

a. Method I Air Dose* (Applicable to Units 1, 2. and 3)

When Unit I is discharging to the Millstone Stack:

For Unit I (without SFPI vent): DGI = 9.3 x 105 CNIs*

DBI = 9.3 x 10"7 CNIS*

For Unit I (with SFPI vent): DGI = 9.3 x 10"5 CNIs+ 3.3 x 10- CNIv*

DBI = 9.3 x 10-7 CNIs+ 1.49 x 10-3 CNIV

For Unit 2: DG2 = 6.3 x 104 CN2V*

DB2 = 1.7 x 10-3 CN2V

For Unit 3: DG3 = 6.3 x 104 CN3v*

DB3 = 1.7 x 10-3 CN3v*

When Unit I is not discharging to the Millstone Stack:

For Unit 1: Do 1=3.3x 10-6 CNIV*

DBI = 1.49 x 10-3 CNIV*

For Unit 2: Do2 = 6.3 x 104 CN2V+l.81 x 10-4 CN2S

DB2 = 1.7 x 10-3 CN2v+ 1.81 x 10-6 CN2S*

For Unit 3: DG3 = 6.3 x 104 CN3V+ 1.81 X 104 CN3S*

DB3 = 1.7 x 10"3 CN3v+ 1.81 x 10-6 CN3S

If DGI, DG2, or DG3 are greater than 1.6 mrad or DBI, DB2, or DB3 are greater than 3.3 mrad within a calendar quarter, go to Method 2 below.

Where:

DGI = The gamma air dose from Unit I for the period of interest (mrad).

DBI = The beta air dose from Unit Ifor the period of interest (mrad).

DG2 = The gamma air dose from Unit 2 for the period of interest (mrad).

DB2 = The beta air dose from Unit 2 for the period of interest (mrad).

DG3 = The gamma air dose from Unit 3 for the period of interest (mrad).

DB3 = The beta air dose from Unit 3 for the period of interest (mrad).

CNIS = The total curies of noble gas released from Millstone Stack during the period of interest.

CNIv= The total curies of noble gas released from Spent Fuel Pool Island Vent during the period of interest.

CN2v = The total curies of noble gas released from Unit 2 Vent during the period of interest. Include containment releases to Unit 2 Vent CN2S = The total curies of noble gas released from Unit 2 to Millstone Stack during the period of interest.

CN3v = The total curies of noble gas released from Unit 3 vents during the period of interest. Include containment releases to Unit 3 Vent and ESF Building Vent.

CN3S = The total curies of noble gas released from Unit 3 to Millstone Stack during the period of interest.

See the REMODCM Technical Information Document (MP-13-REM-REF02), Section 4.2, for the derivation of air dose Method 1 factors.

II.D- 4

ODCM Revision 21

b. Method 2 Air Dose (Applicable to Units 1, 2, and 3)

Millstone Stack: For dose calculations for releases from the Millstone Stack, use the AIREM computer code to determine the critical location air doses.

The 3rd quarter 1980 joint frequency data shall be used as input for the AIREM code. The reason for this is given in the REMODCM Technical Information Document (MP-12-REF02), Section 4.2.

If the calculated air dose exceeds one half the Radiological Effluent Control limit, use meteorology concurrent with time of release.

All other releases: For dose calculations for releases from release points other than the Millstone Stack, use the GASPAR computer code, or a code which uses the methodology given in Regulatory Guide 1.109, to determine the critical site boundary air doses.

For the Special Location, enter the following worst case quarterly average meteorology based on the Unit 2 vent eight-year history:

X/Q = 8.1 x 10-6 sec/m3 D/Q = 1.5 x l0-7 m-1 (See the REMODCM TechnicalInformation Document MP-12-REM-REF02),Attachment 5)

If the calculated air dose exceeds one half the quarterly Radiological Effluent Control limit, use meteorology

.concurrent with time of release.

c. Estimation of Annual Air Dose Limit Due to Noble Gases (Applicable to Units 1. 2 and 3)

An estimation of annual (year-to-date) beta and gamma air doses (DyB and DyG, respectively) from noble gases released from Units 1, 2 and 3 shall be made every month to determine compliance with the annual dose limits for each Unit. Annual air doses will be determined as follows:

Unit I Unit 2 Unit 3 DyG0 = ZDGI DYG2 = EDG2 DyG3 = EDG3 DyB = XDBI DYB2 = YDB2 DYB3= ZDB3 where the sums are over the first quarter (i.e., summation of the all release periods within the quarter) through the present calendar quarter doses.

Where: DyGI, DYG2, DyG3, DyBI, DYB2 and DYB3 = gamma air dose and beta air dose for the calendar year for Unit 1, 2, or 3.

The following shall be used as the quarterly doses:

(1) If the detailed quarterly dose calculations required per Section II.D.5 for the Radioactive Effluent Release Report are complete for any calendar quarter, use those results.

(2) If the detailed calculations are not complete for a particular quarter, use the results as determined above in Sections 11.D.2.a or 11.D.2.b.

If Dyo1, YG2 or YG3 are greater than 10 mrad or DyB ,YB2 or YB3 are greater than 20 mrad and any corresponding quarterly dose was not calculated using Method 2 (Section II. D.2.b), recalculate the quarterly dose using meteorology concurrent with time of release.

. II.D- 5

ODCM Revision 21

3. 10 CFR50 Appendix I - Iodine and Particulate Doses Radiological Effluent Controls (Section II, IV, and V) limit the off-site dose to a critical organ from radioiodines, tritium, and particulates with half-lives greater than 8 days released in gaseous effluents to 7.5 mnrem for a calendar quarter (15 mrem per calendar year). Effluent dose calculations are performed at least once every 31 days. In addition, installed portions of the gaseous radwaste treatment system are required to be operated to reduce radioactive materials in gaseous effluents when the projected doses over 31 days from the applicable waste stream exceed 0.03 mrem. (See Appendix A, Tables App.A-1 and App.A-2 for a cross reference of effluent control requirements and applicable sections of the REMODCM which are used to determine compliance.) This part of the REMODCM provides the calculation methodology for determining critical organ doses from atmospheric releases of iodines, tritium and particulates.

a. Critical Organ Doses (Applicable to Millstone Stack and Unit 1 releases)

(1) Method 1 - Millstone Stack and Unit 1 Releases Calculate organ doses for DTs and Dos:

When Unit 1 is discharging to the Millstone Stack (without SFPI vent):

DTS = 1.22 x 102131C1s+ 1.13 133CIS + 2.0 x 10"5CHs Dos = 42.3Cps + 2.0 x 10"5CHs If either dose is greater than 2.5 mrem within a calendar quarter go to Method 2a below When Unit 1 is discharging to the Millstone Stack (with vent release):

[NOTE: Contribution from Unit I BOP not required until BOP sampler becomes operational]

DTS = 1.22 x 10213 CIS + 1.13 133Cis +2.0 x 10 5Cns+ 1.97 x 10-3 CHv Dos = 42.3Cps + 94 .8[Cpv + CpB ] + 2.0 x I 0"5Cns+ 1.97 x 10-3 CHV If either dose is greater than 2.5 mrem within a calendar quarter go to Method 2a below When Unit 1 is not discharging to the Millstone Stack (applicable to Units 2 or 3 only):

DTS = 947 131C1 s + 8.77 133CIs +1.58 x 104 CnS Dos = 328Cps + 1.58 x 10-4 CHs Sum critical organ doses from stack with critical organ doses from vent in Section b(1) below:

When Unit 1 is not discharging to the Millstone Stack (applicable to Unit 1 only):

[NOTE: Contribution from Unit 1 BOP not required until BOP sampler becomes operational]

DTs = 1.97 x 10-3 CHV Dos = 94.8[Cpv+ CpB]+ 1.97 x 10-3 Cuv If either dose is greater than 2.5 mrem within a calendar quarter go to Method 2a below Where: DTS = The thyroid dose for the period of release of gaseous effluents.

Dos = The dose to the maximum organ other than the thyroid for the period of gaseous effluent release.

131ClS = The total curies of 1-131 released in gaseous effluents from Unit 2 or 3 to Millstone Stack during the period of interest.

133C]s= The total curies of 1-133 released in gaseous effluents from Unit 2 or 3 to Millstone Stack during the period of interest.

Cps-= The total curies of particulates with half-lives greater than 8 days released in gaseous effluents from Millstone Stack during the period of interest.

Cpv = The total curies of particulates with half-lives greater than 8 days released in gaseous effluents from the SFPI vent during the period of interest.

CPB = The total curies of particulates with half-lives greater than 8 days released in gaseous effluents from the BOP vent during the period of interest.

CHs = The total curies of tritium released in gaseous effluents from Millstone Stack during period of interest.

CHV = The total curies of tritium released in gaseous effluents from the SFPI vent during period of interest.

II.D- 6

ODCM Revision 21 II.D. GASEOUS DOSE CALCULATIONS (Cont'd)

(2) Method 2a - Millstone Stack and Unit 1 Releases Use the GASPAR code, or a code which uses the methodology given in Regulatory Guide 1.109, to determine the maximum organ dose. For the Special Location, enter the following worst case quarterly average meteorology as taken from the REMODCM Technical Information Document (MP-12-REM-REF02), Attachment 5:

3 X/Q = 6.1 x 10-8 sec/rM D/Q = 5.9 x 10-9 m- 2 (Milk and Vegetation) and/or D/Q = 1.4 x 10.9 m2 (If 1983-1987 D/Q data is acceptable for existing milk locations. If not, see guidance in the REMODCM Technical Information Document (MP-12-REM-REF02),Section 4.2.)

Use the Inhalation, Milk and Vegetation pathways (if applicable) in totaling the dose.

When Unit 1 is discharging to the Millstone Stack:

If the maximum organ dose is greater than 3.8 mrem within a calendar quarter go to Method2b.

When Unit 1 is not discharging to the Millstone Stack:

Sum critical organ doses from stack with critical organ doses from vent in Section b(2) below.

(3) Method 2b - Millstone Stack and Unit 1 Releases Use the GASPAR code, or a code which uses the methodology given in Regulatory Guide 1.109, with actual locations, real-time meteorology and the pathways which actually exist at the time at those locations. When Unit 1 is not discharging to the Millstone Stack, sum critical organ doses from stack with critical organ doses from vent in Section c(5) below.

b. Critical Or2an Doses (Applicable to Units 2 and 3 vent releases)

(1) Method I - Unit 2 and Unit 3 releases For Unit 2 and Unit3, separately, calculate organ doses DT and DO:

Dav = 3.1 X 103 131CIV + 29.53 133CIv + 2.6 X 10-3 CHV Dov= 1.1 X 103 Cpv + 2.6 x 10"3 CHv Sum with organ doses for releases from the stack from Section b(l):

DT = DTS + DTV Do = Dos + Doe If either dose is greater than 2.5 rmiem within a calendar quarter go to Section a(2) and recalculate any organ dose greater than 2.5 mrem for releases from the stack and go to Section b(2) below and recalculate any organ dose greater than 2.5 mrem for releases from the vent, where:

DT= The total thyroid dose for the period of gaseous effluents releases.

Do= The total dose to the maximum organ other than the thyroid for the period of gaseous effluent releases.

DTv= The thyroid dose for the period of gaseous effluents releases from the vent.

Do v= The dose to the maximum organ other than the thyroid for the period of gaseous effluent releases from the vent.

13 1C1 v= The total curies of 1-131 in gaseous effluents from Unit 2 other than to the Millstone Stack (Unit 2 Vent, containment releases to vent, and Steam Generator Blowdown Tank Vent*) or from Unit 3 other than to the Millstone Stack (Unit 3 Vent, ESF Building Vent, containment releases to vent, Steam Generator Blowdown Tank Vent*, and Containment Drawdown using the hogger**) during the period of interest.

II.D- 7

ODCM Revision 21 133C1v = The total curies of 1-133 in gaseous effluents from Unit 2 other than to the Millstone Stack (Unit 2 Vent, containment releases to vent, and Steam Generator Blowdown Tank Vent*) or from Unit 3 other than to the Millstone Stack (Unit 3 Vent, ESF Building Vent, containment releases to vent, Steam Generator Blowdown Tank Vent*, and Containment Drawdown using the hogger **) during the period of interest.

Cpsv= The total curies of particulates with half-lives greater than eight days released in gaseous effluents from Unit 2 other than to the Millstone Stack (Unit 2 Vent and containment releases to vent) or from Unit 3 other than to the Millstone Stack (Unit 3 Vent, ESF Building Vent, containment releases to vent, and Containment Drawdown using the hogger **) during the period of interest.

CHv= The total curies of tritium released in gaseous effluents from Unit 2 other than to the Millstone Stack (Unit 2 Vent and containment releases to vent or from Unit 3 other than to the Millstone Stack (Unit 3 Vent, ESF Building Vent, containment releases to vent, and Containment Drawdown using the hogger **) during the period of interest.

Results from SAI studies in 1982 and 1983 and guidance provided in the R. A. Crandall / E. R.

Brezinski memo to E. J. Mroczka, Millstone Unit 2 Steam Generator Blowdown Tank Releases, NE 83-RA-879, June 15, 1983, indicate that the steam generator blowdown tank vent releases can be estimated by use of a factor of 1/6,000 (a DF of 2000 and a partitioning factor of 1/3). Although Unit 3 normally recycles blowdown, periodically blowdown is released for short periods of time.

These releases should be similar to Unit 2 and until studies can be performed at Unit 3 the same calculation should be performed. Based upon the above, the formula to be used is:

S/G blowdown concentration x S/G blowdown flow rate x 1/6000 x time = integrated activity

- This pathway does not have a effluent monitor.

(2) Method 2a - Unit 2 and Unit 3 releases Use the GASPAR code, or a code which uses the methodology given in Regulatory Guide 1.109, to determine the maximum organ dose. For the Special Location, enter the following worst case quarterly average meteorology as taken from the REMODCM Technical Information Document (MP-12-REM-REF02), Attachment 5:

3 X/Q = 8.1 x 10-6 sec/M D/Q = 1.5 x 10- 7 m-22 (Milk and Vegetation) and/or D/Q = 6.1 x 10-9 m-(If 1983-1987 D/Q data is acceptable for existing milk locations. If not, see guidance in the REMODCM TechnicalInformation Document (MP-12-REM-REF02),Section 4.2.)

As shown in the REMODCM Technical Information Document (MP-12-REM-REF02),

Attachments 4 and 5, the same meteorology can be used for both continuous and batch releases. Therefore, the program need only be run once using the total curies from all releases from Unit 2 or 3 releases.

Use the Inhalation, Milk and Vegetation pathways (if applicable) in totaling the dose.

Sum organ doses for releases from the stack from Section a(2). The maximum organ dose is the greater of DT or Do. If it is greater than 2.5 mrem within a calendar quarter, go to Section a(2) and recalculate any organ dose greater than 2.5 mrem for releases from the stack and go to Section b(3) below and recalculate any organ dose greater than 2.5 mrem for releases from the vent II.D- 8

ODCM Revision 21 I.D. GASEOUS DOSE CALCULATIONS (Cont'd)

(3) Method 2b - Unit 2 and Unit 3 releases Use the GASPAR code, or a code which uses the methodology given in Regulatory Guide 1.109, with the actual locations, real-time meteorology and the pathways which actually exist at the time at these locations. For Unit 2, the code shall be run separately for steam generator blowdown tank vents and ventilation releases, containment purges and waste gas tank releases.

For Unit 3, the code shall be run separately for ventilation, process gas, containment vacuum system, aerated ventilation and containment purges.

c. Estimation of Annual Critical Organ Doses Due to Iodines. Tritium and Particulates (Applicable to Units 1. 2. and 3)

An estimation of annual (year-to-date) critical organ doses (Dyr and Dy0 for thyroid and maximum organ other than thyroid, respectively) from radioiodine, tritium and particulates with half-lives greater than 8 days released from Units 1, 2 and 3 shall be made every month to determine compliance with the annual dose limits for each Unit. Annual critical organ doses will be determined as follows:

Unit 1 Unit 2 Unit 3 Dy 1 =YDTI Dm =ZDT2 Dm =ZDT3 Dyoi =X-Do0 Dyo 2 =_Do2 DY0 3 =-D 0 3 where the sums are over the first quarter (i.e., summation of the all release periods within the quarter) through the present calendar quarter doses.

Where:

DYTI, DYrT, DYT3, Droj, DY0 2 and DY0 3 = thyroid (T) dose and maximum organ (0) dose (other than the thyroid) for the calendar year for Unit 1, 2, or 3.

The following guidelines shall be used for DT and DO:

(1) If the detailed quarterly dose calculations required per Section II.D.5 for the Radioactive Effluent Release Report are complete for any calendar quarter, use those results.

(2) If the detailed calculations are not complete for a particular quarter, use the results as determined above in Section Il.D.3.a or II.D.3.b.

(3) If Dyr and/or Dyo are greater than 15 mrem and quarterly dose was not calculated using Method Ic of Section I.D.3.a or II.D.3.b, recalculate the quarterly dose using Method ic.

(4) If different organs are the maximum organ for different quarters, they can be summed together and Dyo recorded as a less-than value as long as the value is less than 15 mrem. If it is not, the sum for each organ involved shall be determined.

II.D- 9

ODCM Revision 21 ILD. GASEOUS DOSE CALCULATIONS (Cont'd)

4. Gaseous Effluent Monthly Dose ProiectionsSection I.D.2.a of the REMM requires that certain portions of the gaseous radwaste treatment equipment be returned to service to reduce radioactive gaseous effluents when the projected doses for each Unit (made at least once per 31 days) exceed 0.02 mrad gamma air, 0.04 mrad beta air, or 0.03 mrem to any organ from gaseous effluents. The following methods are applied in the estimation of monthly dose projections.

a. Unit 1 Proiection Method None required.

II.D- 10

ODCM Revision 21 II.D. GASEOUS DOSE CALCULATIONS (Cont'd)

b. Unit 2 Projection Method (1) Due to Gaseous Radwaste Treatment System (Unit 2)

Determine the beta and gamma monthly air dose projection from noble gases from the following:

When Unit 1 is discharging to the Millstone Stack:

"DEMG (mrad) = 9.3 x 10i CEN "DEMB (mrad) = 9.3 x 10.7 CEN When Unit 1 is not discharging to the Millstone Stack:

"DEMG (mrad) = 1.81 x 10-4 CEN "DEMB (mrad) = 1.81 x 10-6 CEN Where:

CEN = the number of curies of noble gas estimated to be released from the waste gas storage tanks during the next month.

DEMG = the estimated monthly gamma air dose.

D EMB = the estimated monthly beta air dose.

(The dose conversion factor is from the REMODCM Technical Information Document (MP-12-REM-REF02), Section 4.2, for the Millstone Stack releases since the Unit 2 waste gas tanks are discharged via the Millstone Stack. This factor is conservative because the isotopic mix assumed for the dose conversion factor consists of shorter-lived noble gases which have higher dose conversion factors than the typical mix from Unit 2 waste gas tank discharges.)

(2) Due to Steam Generator Blowdown Tank Vent (Unit 2)

i. Method 1 Determine DEMO which is the estimated monthly dose to the maximum organ from the following:

DEMo = 1/3 R1 x DT For the last quarter of operation, determine DT as determined per Section HI.D.3.b.

Where:

R, = the expected ratio of secondary coolant iodine level for the coming month as compared with the average level during the quarter used in determining DT above.

ii. Method 2 If necessary, estimate the curies expected to be released for the next month and applicable method for dose calculation from Section 11.D.3.b.

-II.D- 11

ODCM Revision 21 II.D. GASEOUS DOSE CALCULATIONS (Cont'd)

(3) Due to Ventilation Releases (Unit 2)**

If portions of the ventilation treatment system are expected to be out of service during the month, determine the monthly maximum organ dose projection (D EMo) from the following:

i. Method 1 Determine DEMO which is the estimated monthly dose to the maximum organ from the following:

DEMO = 1/3 R1 (1.01- R 2) (R3+ 0.01) Do For the last quarter of operation, determine Do as determined per Section I1.D.3-b.

R, = the expected reduction factor for the HEPA filter. Typically this should be 100 (see NUREG-0016 or 0017for additionalguidance).

R 2 = the fraction of the time which the equipment was inoperable during the last quarter.

R3 = the fraction of the time which the equipment is expected to be inoperable during the next month.

ii. Method 2 If necessary, estimate the curies expected to be released for the next month and applicable method for dose calculation from Section II.D.3.b.

- Since dose projections are only required if the treatment specified in Section I.D of the Radiological Effluent Monitoring Manual are not operating, the monthly gamma and beta air dose projections are not required for ventilation releases.

c. Unit 3 Proiection Method (1) Due to Radioactive Gaseous Waste System (Unit 3)

Determine the beta and gamma monthly air dose projection from noble gases from the following:

When Unit 1 is discharging to the Millstone Stack:

"DEMG (mrad) = 9.3 x 10-5 CEN "DEMB (mrad) = 9.3 x 10-7 CEN When Unit 1 is not discharging to the Millstone Stack:

DEMG (mrad) = 1.81 x 10.4 CEN DEMB (mrad) = 1.81 x 10.6 CEN Where:

CEN = the number of curies of noble gas estimated to be released from the reactor plant gaseous vents (the activity from this pathway increases when the process waste gas system is out of service.)

during the next month.

DEMG = the estimated monthly gamma air dose.

D EMB = the estimated monthly beta air dose.

(The dose conversion factor is from the REMODCM TechnicalInformation Document (MP-12-REM-REF02), Section 4.2, for the Millstone Stack releases since the Unit 3 reactor plant gaseous vents are discharged via the Millstone Stack.)

II.D- 12

ODCM Revision 21 II.D. GASEOUS DOSE CALCULATIONS (Cont'd)

(2) Due to Steam Generator Blowdown Tank Vent (Unit 3)

i. Method 1 Determine DEMo which is the estimated monthly dose to the maximum organ.

DEMo = 1/3 R, x DT For the last quarter of operation, determine Dr as determined per Section II.D.3.b.

Where: R 1 = the expected ratio of secondary coolant iodine level for the coming month as compared with the average level during the quarter used in the determining DT above.

ii. Method 2 If necessary, estimate the curies expected to be released for the next month and applicable method for dose calculation from Section II.D.3.b.

(3) Due to Ventilation Releases (Unit 3)**

If portions of the ventilation treatment system are expected to be out of service during the month, determine the monthly maximum organ dose projection (DEMO) from the following:

i. Method I Determine DEMO which is the estimated monthly dose to the maximum organ.

D EMO = 1/3 R, (1.01- R 2) (R 3+ 0.01) Do For the last quarter of operation, determine Do as determined per Section HI.D.3.b.

Where: R, = the expected reduction factor for the HEPA filter. Typically this should be 100 (see NUREG-O016 or 001 7for additionalguidance).

R2 = the fraction of the time which the equipment was inoperable during the last quarter.

R 3 = the fraction of the time which the equipment is estimated to be inoperable during the next month.

ii. Method 2 If necessary, estimate the curies expected to be released for the next month and applicable method for dose calculation from Section II.D.3.b.

- Since dose projections are only required if the treatment specified in Section I.D of the Radiological Effluent Monitoring Manual are not operating, the monthly gamma and beta air dose projections are not required for ventilation releases.

II.D- 13

ODCM Revision 21 lI.D. GASEOUS DOSE CALCULATIONS (Cont'd)

5. Quarterly Dose Calculations for Radioactive Effluent Release Report Detailed quarterly gaseous dose calculations required for the Radioactive Effluent Release Report shall be done using the computer codes GASPAR and AIREM, or codes which use the methodology given in Regulatory Guide 1.109.

6. Compliance with 40CFR190 The following sources shall be considered in determining the total dose to a real individual from uranium fuel cycle sources:

a. Gaseous Releases from Units 1, 2, and 3.

b. Liquid Releases from Units 1, 2, and 3.

c. Direct and Scattered Radiation from Radioactive Material Stored on Site.

d. Since all other uranium fuel cycle sources are greater than 5 miles away, they need not be considered.

The Radiological Effluent Controls in Sections III.E (Unit 1), IV.F (Unit 2), and V.F (Unit 3) contain specific requirements for ensuring compliance with 40CFR190 based on gaseous and liquid doses (sources a and b).

Doses to source c are controlled by design and operations to ensure the off-site dose from each radwaste storage facility is less than one mrem per year. Potential doses from each facility are evaluated in Radiological Environmental Reviews (RER's) where total off-site doses from all sources are considered to ensure compliance with 40CFR190.

II.D- 14

ODCM Revision 21 II.D. GASEOUS DOSE CALCULATIONS (Cont'd)

7. Bases for Gaseous Pathway Dose Calculations The dose calculation methodology and parameters used in Section II of the REMODCM implement the requirements in Section III.A of Appendix I (IOCFR50) which states that conformance with the ALARA dose objectives of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of a member of the public through appropriate pathways is unlikely to be substantially underestimated. Operational flexibility is provided by controlling the instantaneous release rate of noble gas (as well as iodines and particulate activity) such the maximum off-site dose rates are less than the equivalent of 500 mrem/year to the whole body, 3000 mrem/year to the skin from noble gases, or 1500 mrem/year to a critical organ from the inhalation of iodines, tritium and particulates. The dose rate limits are based on the 10CFR20 (pre-1991) annual dose limits, but applied as an instantaneous limit to assure that the actual dose over a year will be well below these numbers.

The equivalent instantaneous release rate limits for Millstone Stack were determined using the EPA AIREM code. For Units 2 & 3, these doses were calculated using the NRC GASPAR code. The AIREM code calculates cloud gamma doses using dose tables from a model that considers the finite extent of the cloud in the vertical direction. Beta doses are calculated assuming semi-infinite cloud concentrations, which are based upon a standard sector averaged diffusion equation. The GASPAR code implements the models of NRC Regulatory Guide 1.109, Rev. 1, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with IOCFR Part 50, Appendix I." Input parameter values typically used in the dose models are listed in the Station Reference Manual, "REMODCM Technical InformationDocument (MP-13-REM-REF02).

This same methodology is used in the determination of compliance with the 40CFR190 total dose standard for the gaseous pathways.

In the determination of compliance with the dose and dose rate limits, maximum individual dose calculations are performed at the nearest land site boundary with maximum decayed X/Q, and at the nearest vegetable garden (assumed to be nearest residence) and cow and goat farms with maximum D/Qs. The conversion constants in the Method I equations for maximum air doses, organ and whole body doses, and dose rates are based on the maximum observed comparison of historical effluent releases and corresponding calculated maximum doses. The dose conversion factors are calculated based on the ratio of the observed highest dose and the curies of fission and activation products released during the period. This ratio results in the Method I equation conversion factor in mrem/Ci released. Reference Manual MP- I3-REM-REF02 describes the derivation of the Method I constants and list the historical maximum doses calculated for the maximum organ.

II.D- 15

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS

1. Unit 1 Liquid Radwaste Effluent Line The trip/alarm setting on the Unit 1 liquid radwaste discharge line depends on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, an alarm/trip setpoint will be determined prior to the release of each batch. The following method will be used:

Determine the allowable discharge flow (F) from:

F=0.1 xRxD Where:

R = Required Reduction Factor = I Z {pCi/ml of nuclide i / MPC of nuclide i}

Based on the tank isotopic analysis and the MPC values for each identified nuclide (including noble gases*) determine to be in the liquid radwaste effluent.

D = The existing dilution flow * (Note: D = # service water pumps x 8,000 gpm)

Note: That discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1.

With this condition on discharge flow rate met, the monitor setpoint can be calculated:

S = 2xACxCa Where:

S = The setpoint of the monitor (cps).

AC = The total measured radwaste effluent concentration (PtCi/ml) in the waste tank.

Ca = The current calibration factor for the radwaste effluent line monitor.

2 = The multiple of expected count rate on the monitor based on the radioactivity concentration in the tank.

This value or that corresponding to 2.1 x 10-5 piCi/ml**, whichever is greater, plus background is the trip setpoint. For the latter setpoint, independent valve verification shall be performed and a minimum dilution flow of 2,500 gpm shall be verified and if necessary, appropriately adjusted.

The allowable discharge flow rate (F) calculated above may be increased by up to a factor of 5 with appropriate administrative controls (e.g., ensure other release points may not cause MPC's to be exceeded).

If necessary, credit for other unit dilution flow can be taken as long as administrative controls are in place to assure MPC's are not exceeded. When using other unit dilution flow, at least one circulating water pump from the other unit shall be operating and the setpoint shall be equal to 8.5 x I04 uCi/ml. The value of 8.5 x 10.4 is based on a maximum discharge flow of 350 gpm, a minimum dilution flow of 100,000 gpm, and an effective maximum permissible concentration of 3 x 10.6. The concentration assumes that Sr-90 is present at 10% of total activity.

- The value of 2.1 x 10- is based on the same parameters as the previous note except minimum dilution flow is 2,500 gpm.

II.E-1

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd) 2a. Unit 1 Reactor Building Service Water Effluent Line The MPI Reactor Building Service Water Monitor is approximately two times the ambient background reading on the monitor in counts per second.

2b. Unit 1 Reactor Building Service Water Effluent Concentration Limitation Results of analysis of service water sample taken in accordance with Table I.C-1 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water to less than the limits in IOCFR20, Appendix B (version prior to January 1, 1994).

3. Unit 2 Clean Liquid Radwaste Effluent Line Similar to the Unit I liquid discharge line, the setpoint on the Unit 2 clean liquid waste effluent line depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, an alarm/trip setpoint will be determined prior to the release of each batch.

The following method will be used:

From the tank isotopic analysis and the MPC values for each identified nuclide (including noble gases*) determine the required reduction factor, i.e.:

For Nuclides Other Than Noble Gases:

R1 = Required Reduction Factor =

Z {f Ci/ml of nuclide i / MPC of nuclide i}

For Noble Gases*:

R2= Required Reduction Factor = I Z {pCi/ml of noble gases / 2 x 104 ýiCi/ml}

= 2x 10-4 / Z (pCi/ml) noble gases

In lieu of determining the required reduction factor for noble gases, conservatism is allowed. For example, calculate the maximum concentration of noble gases that can be discharged from any tank.

Assuming:

Maximum discharge rate = 350 gpm Normal Minimum dilution flow = 200,000 gpm (2 circulatingpumps, less than rated due to bioticfouling))

350 gpm Maximum Noble Gas Concentration x = 2 x0-4 pCi / ml 200,000 gpm Therefore, Maximum concentration= 0.11 pCi/mi II.E-2

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd)

Determine the allowable discharge flow (F) in gpm:

F=0.1 xRxD Where:

D = The existing dilution flow (D): (Note: D = # circulating water pumps x 100,000 gpm + # service water pumps x 4,000 gpm Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1.

The allowable discharge flow rate (F) may be increased by up to a factor of 5 with appropriate administrative controls to ensure other releases concurrent with releases from this pathway would not cause MPC's to be exceeded.

With this condition on discharge flow rate met, the monitor setpoint can be calculated:

R, = 2 x AC x Ca (See Note 1 below.)

Where:

Rset = The setpoint of the monitor (cps).

AC = The total radwaste effluent concentration (jtCi/ml ) in the tank.

Ca = The current calibration factor for the effluent line monitor.

2 = The multiple of expected count rate on the monitor based on the radioactivity concentration in the tank.

This value or that corresponding to 1.7 x 10-4 lICi/ml (Note 2 below), whichever is greater, plus background is the trip setpoint. For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.

Note 1: If discharging at the allowable discharge rate (F) as determined in above, this setpoint would correspond to 20% of the Radiological Effluent Control limit.

Note 2: This value is based upon worst case conditions, assuming maximum discharge flow (350 gpm), normal minimum dilution water flow (200,000 gpm for MP2) and an assumed worst case mix of nuclides (3 x 10.7 131 MPG). This will assure that low level releases are not terminated due to small fluctuations in activity. However, to verify that the correct tank is being discharged when using this value, independent valve verification shall be performed. This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.

II.E-3

ODCM Revision 21 1I.E. LIQUID MONITOR SETPOINTS (Cont'd)

4. Unit 2 Aerated Liquid Radwaste Effluent Line and Condensate Polishing Facility Waste Neutralization Sump Effluent Line Same as II.E.3 for Clean Liquid Monitor and the Condensate Polishing Facility (CPF) Waste Neutralization Sump monitor except the CPF monitor has the capability to readout in CPM or iCi/ml. For the CPF Waste Neutralization Sump monitor, use a default setpoint if no chemistry grab samples are required. This default shall be the lower of: two times background or the value as specified in II.E.3.

5a. Unit 2 Steam Generator Blowdown Assumptions used in determining the Alarm setpoint for this monitor are:

a. Total S.G. blowdown flow rate = 700 gpm.

b. Normal minimum possible circulating water dilution flow during periods of blowdown =

200,000 gpm (2 circulating water pumps) = 200,000 gpm.

c. The release rate limit is conservatively set at 10% of the IOCFR Part20 limit for 1-131 (0.1 x 3 x 10-7 iCi/ml = 3 x 10"' tCi/ml)*

d. Background can be added after above calculations are performed.

Therefore, the alarm setpoint corresponds to a concentration of:

Alarm (pCi/ml) = 200,000 x 3 x 10-8 + background** = 8.5 x 10-6 pCi/ml + background 700 The latest monitor calibration curve shall be used to determine the alarm setpoint in cpm corresponding to 8.5 x 10-6 pCi/ml.

This setpoint may be adjusted (increased or decreased) through proper administrative controls if the steam generator blowdown rate is maintained other than 700 gpm and/or other than 2 circulating water pumps are available. The adjustment would correspond to the ratio of flows to those assumed above or:

/m=.16 circulating & service water flow (gpm) 700 200,000 S/G blowdown (gpm)

Background = 3A10-8pCi /mI x.circulating & service water flow (gpm) + Background total S/G blowdown (gpm)

Note: The Steam Generator Blowdown alarm criteria is in practice based on setpoints required to detect allowable levels of primary to secondary leakage. This alarm criteria is typically more restrictive than that required to meet discharge limits. This fact shall be verified, however, whenever the alarm setpoint is recalculated.

In lieu of using the 1-131 MPC value, the identified MPC values for unrestricted area may be used.

- Background of monitor at monitor location (i.e., indication provided by system monitor with no activity present in the monitored system).

II.E-4

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd) 5b. Unit 2 Steam Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I.C-2 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed the concentration limits in 10CFR20, Appendix B (version prior to January 1, 1994).

6. Unit 2 Condenser Air Elector N/A since this monitor is no longer a final liquid effluent monitor.

7a. Unit 2 Reactor Building Closed Cooling Water The purpose of the Reactor Building Closed Cooling Water (RBCCW) radiation monitor is to give warning of abnormal radioactivity in the RBCCW system and to prevent releases to the Service Water system which, upon release to the environment, would exceed allowable limits in IOCFR20.

According to Calculation RERM-02665-R2, radioactivity in RBCCW water which causes a monitor response of greater than the setpoint prescribed below could exceed I 0CFR20 limits upon release to the Service Water system.

SETPOINT DURING POWER OPERATIONS:

To give adequate warning of abnormal radioactivity, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 2,000 cpm.

The monitor background reading shall be the normal monitor reading. If the monitor background reading exceeds 2,000 cpm, the setpoint shall be set at the background reading plus 2,000 cpm and provisions shall be made to adjust the setpoint if the background decreases.

SETPOINT DURING SHUTDOWN:

1. During outages not exceeding three months the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 415 cpm.

If the monitor background reading exceeds 415 cpm, the setpoint shall be set at the background reading plus 415 cpm and provisions shall be made to adjust the setpoint if the background decreases.

2. During extended outages exceeding three months, but not exceeding three years, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 80 cpm. If the monitor background reading exceeds 80 cpm, the setpoint shall be set at the background reading plus 80 cpm and provisions shall be made to adjust the setpoint if the background decreases.

PROVISIONS FOR ALTERNATE DILUTION FLOWS:

These setpoints are based on a dilution flow of 4,000 gpm from one service water train. If additional dilution flow is credited, the setpoint may be adjusted proportionately. For example, the addition of a circulating water pump dilution flow of 100,000 gpm would allow the setpoint to be increased by a factor of 25.

7b. Unit 2 Service Water and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water and turbine building sump samples taken in accordance with Table I.C-2 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water and turbine building sump effluents to less than the limits in 10CFR20, Appendix B (version prior to January 1, 1994).

II.E-5

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd)

8. Unit 3 Liquid Waste Monitor Similar to the Unit I liquid discharge line, the setpoints on the Unit 3 liquid waste monitor depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used:

From the tank isotopic analysis and the MPC values for each identified nuclide (including noble gases*) determine the required reduction factor, i.e.:

For Nuclides Other Than Noble Gases*:

R= Re quired Re duction Factor = 1E/gjCi / ml of nuclide i MPC of nuclide i For Noble Gases:*

t~i / ml of noble gases 2/ mlo R = Re quired ~2 = 1E 2 Re duction Factor x 10-4 PaCi /ml

= 2x10- 4 / E pCi / ml of noble gases R = the smaller of RI or R 2

In lieu of determining the required reduction factor for noble gases, conservatism is allowed.

For example, calculate the maximum concentration of noble gases that can be discharged from any tank.

Assuming:

Maximum discharge rate = 150 gpm Normal Minimum dilution flow = 300,000 gpm (2 circulatingpumps)

Maximum "Allowable" Concentration x 150 gpm = 2 xlAO PCi/ml 300,000 gpm Therefore, Maximum "allowable" concentration = 0.4 VCi/mI Determine the allowable discharge flow (F)

F=0.1 xRxD Where:

D = The existing dilution flow (D): (Note: D = # circulating water pumps x 150,000 gpm + # service water pumps x 15,000 gpm Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1.

The allowable discharge flow rate (F) may be increased by up to a factor of 5 with appropriate administrative controls to ensure other releases concurrent with release from this release pathway would not cause MPC's to be exceeded.

II.E-6

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd)

With this condition on discharge flow rate met, the monitor setpoint can be calculated:

Rse= 2 x AC x Ca (see Note 1)

Where:

.= The setpoint of the monitor (cps).

AC = The total radwaste effluent concentration (p+/-Ci/ml ) in the tank.

Ca = The current calibration factor for the effluent line monitor.

2 = The multiple of expected count rate on the monitor based on the radioactivity concentration in the tank.

This value, or that corresponding to 2 x 104 pCi/ml (Note 2 below), whichever is greater, plus background is the trip setpoint. For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.

Note 1: If discharging at the allowable discharge rate (F) as determined above, this Alarm setpoint would yield a discharge concentration corresponding to 20% of the Radiological Effluent Control limit.

Note 2: This value is based upon worst case conditions, assuming maximum discharge flow (150 gpm), minimum dilution water flow (2 circulating pumps = 300,000 gpm), and an assumed mix of nuclides as specified for an unidentified liquid release in IOCFR20 (I X 10-7 gCi/ml). This will assure that low level releases are not terminated due to small fluctuations in activity. However, to verify that the correct tank is being discharged when using this value, independent valve verification shall be performed. This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.

9. Unit 3 Regenerant Evaporator Effluent Line The MP3 Regenerant Evaporator has been removed from service with DCR M3-97-04 1.

Therefore a radiation monitor alarm is not needed.

10. Unit 3 Waste Neutralization Sump Effluent Line Same as Section lI.E.8. Note that for this monitor, even though grab samples may not be required, setpoints still have to be utilized. In such cases, the default shall be the lower of: two times background or the value as specified in II.E.8.

II.E-7

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd)

Ila. Unit 3 Steam Generator Blowdown The alarm setpoint for this monitor assumes:

a. Steam generator blowdown rate of 400 gpm (maximum blowdown total including weekly cleaning of generators - per ERC 25212-ER-99-0133).

b. The release rate limit is conservatively set at 10% of the IOCFRPart20 limit (0.1 times the 1-131 MPC* for unrestricted areas which equals 0.1 x 3 x 10.7 V Ci/ml).

c. Minimum possible circulating and service water dilution flow during periods of blowdown =

300,000 gpm (2 circulating water pumps) + 30,000 gpm (2 service water pumps) =

330,000 gpm.

d. Background can be added after above calculations are performed.

Therefore, the alarm setpoint corresponds to a concentration of:

Alarm (jiCi /ml) = 330,000 10-8 + background = 2.47 x 10-5 pCi/ml + background 400 This setpoint may be increased through proper administrative controls if the steam generator blowdown rate is maintained less than 400 gpm and/or more than 2 circulating and 2 service water pumps are available. The amount of the increase would correspond to the ratio of flows to those assumed above or:

Alarm (pCi/m) = 2.47 x 10-5 pCi/mI x circulating &service water flow (gpm) x400+

SIG blowdown (gpm) 330,000 Background = 3x 0-8Ci /ml , circulating &service water flow (gpm) + Background total S/G blowdown (gpm)

Note: The Steam Generator Blowdown alarm criteria is in practice based on setpoints required to detect allowable levels of primary to secondary leakage. This alarm criteria is typically more restrictive than that required to meet discharge limits. This fact shall be verified, however, whenever the alarm setpoint is recalculated.

In lieu of using the 1-131 MPC value, the identified MPC values for unrestricted area may be used.

jib. Unit 3 Steam Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I.C-3 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed the concentration limits in 10CFR20, Appendix B (version prior to January 1, 1994).

II.E-8

ODCM Revision 21 II.E. LIQUID MONITOR SETPOINTS (Cont'd) 12a. Unit 3 Turbine Building Floor Drains Effluent Line The alarm setpoint for this monitor assumes:

a. Drinking water is not a real pathway at this site. Therefore, the NRC code, LADTAP or other Regulatory Guide 1.109 code, is used to calculate the dose to the maximum individual.

b. The average annual discharge flow is 1.11 x 10.2 et 3/sec (process flow during sump pump operation is 50 gpm and pump normally operates less than 10% of the time for a conservative average flow of 5 gpm). There is no continuous additional dilution, therefore, there is no dilution prior to discharge.

c. Near field dilution factor = 13,000.

Far field dilution factor = 32,000.

(

Reference:

Millstone 3 FSAR, Section 2.4.13)

d. Isotopic concentrations were taken from the Millstone 3 FSAR, Table 11.2-4 (See column under Turbine Building).

3

e. Each concentration above was multiplied by the total annual flow (9.95 x W09 cm ,

conservatively assuming 5 gpm continuous as discussed in item b).

f. The maximum individual organ dose is set equal to 1% of 75 mrem (40CFR190 limit). The limiting individual is the child; maximum organ is the thyroid. This value is approximately one quarter of the value The setpoint corresponding to 0.75 mrem to the child's thyroid is 3.8 x 10.5 ltCi/ml.

12b. Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water and turbine building sump samples taken in accordance with Table I.C-3 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water and turbine building sump effluents to less than the limits in IOCFR20, Appendix B (version prior to January 1, 1994).

13. Bases for Liquid Monitor Setpoints Liquid effluent monitors are provided on discharge pathways to control, as applicable, the release of radioactive materials in liquid effluents during actual or potential releases of liquid waste to the environment. The alarm / trip setpoints are calculated to ensure that the alarm / trip function of the monitor will occur prior to exceeding the limits of 10 CFR Part 20 (Appendix B, Table II, Column 2), which applies to the release of radioactive materials from all units on the site. This limitation also provides additional assurance that the levels of radioactive materials in bodies of water in Unrestricted Areas will result in exposures within the Section II.A design objectives of Appendix I to 10 CFR Part 50 to a member of the public.

In application, the typical approach is to determine the expected concentration in a radioactive release path and set the allowable discharge rate past the monitor such the existing dilution flow will limit the effluent release concentration to 10% of the MPC limit for the mix. The setpoint is then selected to be only 2 times the expected concentration, or 20% of the MPC limit. As a result, considerable margin is included in the selection of the setpoint for the monitor to account for unexpected changes in the discharge concentration or the contribution from other potential release pathways occurring at the same time as the planned effluent release. For those monitors on systems that are not expected to be contaminated, the alarm point is usually selected to be two times the ambient background to give notice that normal conditions may have changed and should be evaluated.

II.E-9

ODCM Revision 21 I.F. GASEOUS MONITOR SETPOINTS

1. Unit I Spent Fuel Pool Island Monitor The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D. l.a in order to satisfy RadiologicalEffluent ControlsIII.C.2 andIlL.D.2.1.

The alarm setpoint shall be set at or below the monitor reading in liCi/cc corresponding to 29,000 pCi/sec assuming a maximum ventilation flow of 36,000 CFM. The corresponding monitor reading is 1.71E-3 uCi/cc.

The release rate value of 29,000 tCi/sec assumes tat 33% of the site limit for skin dose of 3000 mrem per year is assigned to the Unit 1 Spent Fuel Pool Island vent. If effluent conditions from the Unit 1 Spent Fuel Pool Island vent approach 29,000 uCi/sec, measures shall be taken to ensure that the sum of the allowed individual unit noble gas release rates do not exceed the site skin dose limit.

2. Unit 2 Wide Range Gas Monitor (WRGM) - RM8169 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D. L.a in order to satisfy Units 2 Radiological Effluent Controls IV.C.2 and IV.D.2. 1.

The alarm setpoint shall be set at or below the monitor reading in uCi/cc corresponding to 74,000 pCi/secassuming a maximum ventilation flow of 12,000 CFM. The corresponding monitor reading is 1.3 1E-2 uCi/cc.

The release rate value of 74,000 pCi/sec assumes that 26.4% (80% of 33%) of the site limit is assigned to Unit 2 releases to the Millstone Stack. If effluent conditions from Unit 2 to the Millstone Stack approach 74,000 uCi/sec, measures shall be taken to ensure that the sum of the allowed individual unit noble gas release rates do not exceed the site limit as dictated in Section II.D.1 .a, and described in the REMODCM TechnicalInformation Document (MP-12-REM-REF02),Section 4.2.

II.F-1

ODCM Revision 21 II.F. GASEOUS MONITOR SETPOINTS (Cont'd)

3. Millstone Stack Noble Gas Monitor (not required after Unit 1 terminates discharges to the stack)

The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section ILD.L.a in order to satisfy Units 2 and 3 Technical Specification 3.3.3.10.

The alarm setpoint shall be set at or below the "cps" corresponding to 363,000 [tCi/sec from the Site Stack noble gas monitor calibration curve. The calibration curve (given as PCi/sec per cps) is determined by assuming a maximum ventilation flow of 180,000 CFM.

The release rate value of 363,000 pCi/sec assumes that 33% of the site limit is assigned to the Site Stack. If effluent conditions from the Site Stack approach the alarm setpoint, it may be increased if the MP2 or MP3 vent setpoints are also changed to ensure that the sum of the allowed individual unit noble gas release rates do not exceed the site limit as dictated in Section II.D. L.a, and described in the REMODCM Technical Information Document (MP-12-REM-REF02), Section 4.2.

4. Unit3SLCRS The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D. .a in order to satisfy Unit 3 Radiological Effluent Controls V.C.2 and V.D.2.1.

The alarm setpoint shall be set at or below the monitor reading in uCi/cc corresponding to 74,000 pCi/sec assuming a maximum ventilation flow of 12,000 CFM. The corresponding monitor reading is 1.3 1E-2 uCi/cc.

The release rate value of 74,000 piCi/sec assumes that 26.4% (80% of 33%) of the site limit is assigned to Unit 3 releases to the Millstone Stack. If effluent conditions from Unit 3 to the Millstone Stack approach 74,000 uCi/sec, measures shall be taken to ensure that the sum of the allowed individual unit noble gas release rates do not exceed the site limit as dictated in Section II.D. 1.a, and described in the REMODCM Technical Information Document (MP-12-REM-REF02), Section 4.2.

5. Unit 2 Vent - Noble Gas Monitor The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D. l.a in order to satisfy Radiological Effluent Controls in Sections IV.C.2 and IV.D.2.a.

The alarm setpoint shall be set at or below the "cpm" corresponding to 95,000 VCi/sec from the MP2 vent noble gas monitor calibration curve. The calibration curve (given as piCi/sec per cpm) is determined by assuming the maximum possible ventilation flow for various fan combinations. Curves for three different fan combinations are normally given.

The release rate value of 95,000 jiCi/sec assumes that 33% of the site limit is assigned to the MP2 vent.

If effluent conditions from the MP2 vent approach the alarm setpoint, it may be increased if the Site Stack or MP3 vent setpoints are also changed to ensure that the sum of the allowed individual unit noble gas release rates do not exceed the site limit as dictated in Section II.D. L.a, and described in the REMODCM TechnicalInformation Document (MP-12-REM-REF02), Section 4.2.

II.F-2

ODCM Revision 21 II.F. GASEOUS MONITOR SETPOINTS (Cont'd)

6. Unit 2 Waste Gas Decay Tank Monitor Administratively all waste gas decay tank releases are via the Millstone Stack. Unit 2 has a release rate limit to the Millstone Stack of 74,000 pCi/sec (see the REMODCM TechnicalInformation Document (MP-12-REM-REF02),Section 4.2 for bases).

Batch releases of waste gas shall be limited to less than 10% of the Unit 2 releases to the Millstone Stack release rate limits. Therefore, the waste gas decay tank monitor setpoint should be set not to exceed 7,400 uCi/sec.

The MP2 waste gas decay tank monitor (given pCi/cc per cpm) calibration curve and the tank discharge rate is used to assure that the concentration of gaseous activity being released from a waste gas decay tankdoes not cause the setpoint of 7,400 uCi/sec to be exceeded.

7. Unit 3 Vent Noble Gas Monitor The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a in order to satisfy Radiological Effluent Controls in Sections V.C.2 and V.D.2.a.

The alarm setpoint shall be set at or below a value of 9.5 x 10"4 ItCi/cc for the MP3 vent.

The release rate value of 9.5 x 1 0 4 pCi/cc assumes that 33% of the site limit is assigned to the MP3 vent. This value corresponds to a release rate of 95,000 gCi/sec and a maximum ventilation flow rate of 210,000 CFM (per memo from G. C. Knight to R. A. Crandall, MP-3-1885, July 19, 1989). If effluent conditions from the MP3 vent approach the alarm setpoint, it may be increased if the Site Stack or MP2 vent setpoints are also changed to ensure that the sum of the allowed individual unit noble gas release rates do not exceed the site limit as dictated in Section II.D.l.a, and described in the REMODCM TechnicalInformation Document (MP-12-REM-REF02),Section 4.2.

8. Unit 3 Engineering Safeguards Building Monitor Assuming releases less than 10% of the MP3 FSAR design releases of noble gases (Table 11.3-11, 1.4 x 104 Ci/year which is equal to 450 pCi/sec) assures that less than 1% of the above instantaneous release rate is added by this intermittent pathway (450/290,000 = 0.16%). Assuming a flow rate of 6,500 CFM (3.05 x 106 cc/sec) for this pathway translates this limit to:

0.1x 450/3.05 x106 = 1.5xl0"' pCi/cc The Alarm setpoint shall be set at or below this value.

II.F-3

ODCM Revision 21 II.F. GASEOUS MONITOR SETPOINTS (Cont'd)

9. Bases for Gaseous Monitor Setpoints Gaseous effluent monitors are provided on atmospheric release pathways to control, as applicable, the release of radioactive materials in gaseous effluents to the environment. The alarm / trip setpoints are calculated to ensure that the alarm / trip function of the monitor will occur prior to exceeding the dose rate limits required by the Technical Specifications (Units 2 and 3) or RadiologicalEffluent Controls (Sections III. IV, and V) requirements for each unit. Monitor setpoint selection is based on a conservative set of conditions for each release pathway (as discussed above for each monitor pathway) such that the dose rate at any time at and beyond the site boundary from all gaseous effluents from all units on the site will be within the numerical values of the annual dose limits of 10 CFR Part 20 (the version prior to January 1, 1994) in Unrestricted Areas. Since the Radiological Effluent Controls are constructed such that the numerical values of the annual dose limits of 10 CFR Part 20 be applied on an instantaneous basis (i.e., no time averaging over the year), and the integrated dose objectives of 10 CFR 50, Appendix I provide for corrective actions to reduce effluents if the ALARA dose values are exceeded, assurance is obtained that compliance with the revised annual dose limits of 10 CFR 20.1301 (100 mrem total effective dose equivalent to a member of the public) will also be met. The use of the stated instantaneous release rate values, which equate to the site dose rate limits, also provides operational flexibility to accommodate short periods of higher than normal effluent releases that may occur during plant operations.

II.F--4

ODCM Revision 21 APPENDIX II.A REMODCM METHODOLOGY CROSS-REFERENCES Radiological effluent controls (Sections III, IV, and V) identify the requirements for monitoring and limiting liquid and gaseous effluents releases from the site such the resulting dose impacts to members of the public are kept to "As Low As Reasonably Achievable" (ALARA). The demonstration of compliance with the dose limits is by calculational models that are implemented by Section II of the REMODCM.

Tables App. II.A-1 (Unit 1) and App. II.A-2 (Units 2 & 3) provide a cross-reference guide between liquid and gaseous effluent release limits and those sections of the REMODCM, which are used to determine compliance. It also shows the administrative Technical Specifications which reference the REMODCM for operation of radioactive waste processing equipment. These tables also provide a quick outline of the applicable limits or dose objectives and the required actions if those limits are exceeded. Details of the effluent control requirements and the implementing sections of the REMODCM should be reviewed directly for a full explanation of the requirements.

App. II.A-1

ODCM Revision 21 TABLE App. II.A-1 MILLSTONE UNIT I EFFLUENT REQUIREMENTS AND METHODOLOGY CROSS REFERENCE Radiological REMODCM Effluent Controls Methodology Applicable Limit or and Technical Section Objective Exposure Period Required Action Specfications llI.D.l.a Tables I.C-1, I0CFR20, App. B, Instantaneous Restore concentration to within IV/V.E.I.a I.C-2, and I.C-3 Table II, Column 2, and limits within 15 minutes.

Liquid Effluent 2x10-4 p.Ci/mL for Concentration dissolved noble gases*

III.D. 1.b II.C. 1 <:1.5 mrem T.B. Calendar 30-day report if exceeded. Relative IV/V.E.l.b II.C.2 <5 mrem Organ Quarter** accuracy or conservatism of the Dose-Liquids calculations shall be confirmed by II.C.3 <3 mrem T.B. Calendar Year performance of the REMP in II.C.4 <10 mrem Organ Section 1.

T.S. 5.6.4 (Unit 1) I.C.2 *0.06 mrem T.B. Projected for Return to operation Liquid Waste T.S. 6.16 (Unit 2) II.C.5 *<0.2 mrem Organ 31 days (if system Treatment System.

T.S. 6.14 (Unit 3) not in use)

Liquid Radwaste Treatment lII.D.2.a Tables I.D-1, _5500 mrem/yr T.B. from Instantaneous Restore release rates to within IVIV.E.2.a I.D-2, and I.D-3 noble gases* specifications within 15 minutes.

Gaseous Effluents Dose Rate II.D. .a <3000 mrem/yr skin from noble gases*

II.D.l.b <1500 mrem/yr organ from particulates with T 1/2 > 8d., 1-131, 1-133 and tritium*

I1I.D.2.b l1.D.2 *<5 mrad gamma air Calendar 30-day report if exceeded.

IVIV.E.2.b < 10 mrad beta air Quarter**

Dose Noble Gases

10 mrad gamma air Calendar Year

20 mrad beta air III.D.2.c II.D.3 *7.5 mrem organ Calendar 30-day report if exceeded. Relative IV/V.E.2.c Quarter** accuracy or conservatism of the Dose calculations shall be confirmed by 1-131, 1-133, *15 mrem organ Calendar Year performance of the REMP in Particulates, H-3 Section I.

T.S. 5.6.4 (Unit 1) I.D.2 >0.02 mrad gamma air Projected for Return to operation Gaseous T.S. 6.14 (Unit 2) II.D.4 >0.04 mrad beta air 31 Days Radwaste Treatment System.

T.S 6.16 (Unit 3) >0.03 mrem organ (if system not Gaseous Radwaste in use)

Treatment III.E II.D.6 <25 mrem T.B.* 12 Consecutive 30-day report if Unit 1 Effluent IVN.F .<25mrem organ* Months** Control III.D. 1.2, III.D.2.2, or Total Dose *_75 mrem thyroid* III.D.2.3 or Units 2/3 Effluent Control IV/V.E.l.2, IVIV.E.2.2, or IV/V.E.2.3 are exceeded by a factor of 2. Restore dose to public to within the applicable EPA limit(s) or obtain a variance.

NOTE: T.B. means total or whole body.

Applies to the entire site (Units 1, 2, and 3) discharges combined.

"**Cumulative dose contributions calculated once per 31 days.

App. II.A-2

SECTION III MILLSTONE UNIT I RADIOLOGICAL EFFLUENT CONTROLS DOCKET NO. 50-245 Revision 21 January 26, 2001

REMODCM Unit 1 Controls Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULATION MANUAL (REMODCM)

SECTION III: MILLSTONE UNIT ONE RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS SECTION PAGE NO.

TABLE OF CONTENTS III-i III.A. INTRODUCTION Ill.A-1 III.B. DEFINITIONS II1.B-1 III.C. RADIOACTIVE EFFLUENT MONITORING INSTRUMENTATION

1. Radioactive Liquid Effluent Monitoring Instrumentation III.C-1

2. Radioactive Gaseous Effluent Monitoring Instrumentation III.C-6

3. Section reserved IlI.C- 11

4. Section reserved III.C-12 III.D. RADIOACTIVE EFFLUENTS CONCENTRATIONS AND DOSE LIMITATIONS

1. Radioactive Liquid Effluents III.D-I

a. Radioactive Liquid Effluents Concentrations II.D-I

b. Radioactive Liquid Effluents Doses III.D-2

2. Radioactive Gaseous Effluents IH.D-3

a. Radioactive Gaseous Effluents Dose Rate III.D-3

b. Radioactive Gaseous Effluents Noble Gas Dose III.D-4

c. Radioactive Gaseous Effluents

- Doses from Radionuclides Other Than Noble Gas Doses III.D-5 III.E TOTAL RADIOLOGICAL DOSE FROM STATION OPERATIONS III.E-1 III.F. BASES III.F-1 Ill- i

REMODCM Unit I Controls Revision 21 MILLSTONE STATION RADIOLOGICAL EFFLUENTMONITORING AND OFFSITEDOSE CALCULA TION MANUAL (REMODCM)

SECTION 11: MILLSTONE UNIT ONE RADIOLOGICAL EFFLUENTCONTROLS TABLE OF CONTENTS (Cont'd)

Table Number Table Name Iage III.C-1 Radioactive Liquid Effluent Monitoring Instrumentation III.C-2 III.C-2 Radioactive Liquid Effluent Monitoring Instrumentation II.C-4 Surveillance Requirements III.C-3 Radioactive Gaseous Effluent Monitoring Instrumentation III.C-7 III.C-4 Radioactive Gaseous Effluent Monitoring Instrumentation III.C-9 Surveillance Requirements Figure Number Figure Name Page III.D- 1 Site boundary III.D-6 III- ii

REMODCM Unit 1 Controls Revision 21 III.A. INTRODUCTION The purpose of this section is to provide the following for Millstone Unit One:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions.

III.A-1

REMODCM Unit I Controls Revision 21 III.B. DEFINITIONS The defined terms of this sub-section appear in capitalized type and are applicable throughout Section III.