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Rev. 19 to Section I, Radiological Effluent Monitoring Manual for the Haddam Neck Plant
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Issue date:	12/21/2005
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DEC 2 1 2005 SECTION I RADIOLOGICAL EFFLUENT MONITORING MANUAL For The HADDAM NECK PLANT LDnrkaLNO 2 IJ REMM Revision 19

DECRevision 2 J12005 19 HADDAM NECK PLANT RADIOLOGICAL EFFLUENTMONITORING MANUAL TABLE OF CONTENTS Section Panc.

A. INTRODUCTION AND RESPONSIBILITIES A. l Introduction A-1 A.2 Responsibilities A-2 B. DEFINITIONS B-1 C. LIQUID EFFLUENTS C.1 Liquid Effluents Sampling and C-I Analysis Program C.2 Liquid Radioactive Waste Treatment C-5 C.3/4 Liquid Effluent Controls and Surveillance C-6 Requirements D. GASEOUS EFFLUENTS D.1 Gaseous Effluents Sampling and D-1 Analysis Program D.= Gaseous Radioactive Waste Treatment D-4 D.2/4 Controls and Surveillance Requirements D-5 E. RADIOLOGICAL ENVIRONMENTAL MONITORING E.1 Sampling and Analysis E-1 E.2 Land Use Census E-7 E.3 Interlaboratory Comparison Program E-8 REMM TOC 1 of 2

tJEU 2 1 2005 Revision 19 Section Pano F. REPORT CONTENT F. l Annual Radiological Environmental F-1 Operating Report F.2 Annual Radioactive Effluent Report F-2 F.3 Special Reports F-3 G. TOTAL DOSE G. 1 Total Dose from All Sources G-1 G.2 -Compliance with 40CFR1 90 Limits G-2 G.:3/4 Controls and Surveillance Requirements G-3 H. FIGURES H. l Exclusion Area Boundary and Site H-1 Boundary for Liquid and Gaseous Effluents-H.2 Liquid Waste Treatment System H-2 REMM TOC 2 of 2

DEC ': 1 2005 Revision 19 A. INTRODUCTION AND RESPONSIBILITIES A.' Introduction The purpose of this manual is to provide the sampling and analysis programs that provide input to the ODCM for calculating liquid and gaseous effluent concentrations and offsite doses. Guidelines are provided for opera:ing RADIOACTIVE WASTE TREATMENT SYSTEMS in order that offsite doses are kept As-Low-As-Reasonably Achievable (ALARA).

The Radiological Environmental Monitoring Program outlined within this marual provides confirmation that the measurable concentrations of radioactive material released as a result of plant and ISFSI operations at the Haddam Neck Plant are not higher than expected.

In addition, this manual outlines the information required for submittal to the NRC in both the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Report.

A-1 REMM

DEhC2 12005 Revision 19 A.2 Responsibilities All changes to this manual shall be independently reviewed and approved by the designated manager prior to implementation.

All changes and their rationale shall be documented in the Annual Radioactive Effluent Report in accordance with the Connecticut Yankee Quality Assurance Program (CY QAP).

It shall be the responsibility of the designated manager to ensure that this manual is used in the implementation of the Radiological Effluent Monitoring, Radioactive Effluent Controls, and the Radiological Environmental Monitoring Programs. The designated manager shall ensure that the REMODCM is maintained and controlled in accordance with the CY QAP.

A-2 REMM

DEiC 2 J 2O5 Revision 19 B. DEFINITIONS The defined terms of this section appear in capitalized type and are applicable throughout the REMODCM.

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

B.2 CHANNEL OPERATIONAL TEST A 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 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.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 FREQUENCY NOTATION The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table B.1.

8.6 ISFSI - INDEPENDENT SPENT FUEL STORAGE INSTALLATION Dry storage facility for spent fuel.

B.7 MEMBER(S) OF THE PUBLIC MEMBER(S) OF THE PUBLIC shall include all persons who are not receiving an occupational dose associated with the plant. 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.

B-1 REMM

DES 21 2005 Revision 19 B.8 OPERABLE - OPERABILITY A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function(s) are also capable of performing their related support function(s).

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 material in order to meet the Controls set forth in the REMODCM.

B.10 RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM)

A RADIOLOGICAL EFFLUENT MONITORING MANUAL (REMM) shall be a manual containing the site and environmental sampling and analysis programs for measurements of radiation and radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures to individuals from station operation. An OFFSITE DOSE CALCULATION MANUAL (ODCM) shall be a manual containing the. methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring instrumentation Alarm/Trip Setpoints. Requirements of the REMODCM are provided in the CY QAP.

B.11 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.12 SOURCE CHECK A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a source of increased radioactivity.

B.13 ALL APPLICABLE LIQUID RADIOACTIVE WASTE TREATMENT SYSTEMS ALL APPLICABLE LIQUID RADIOACTIVE WASTE TREATMENT SYSTEMS is defined as that equipment applicable to any waste stream responsible for greater than ten percent (10%) of the total projected dose. The liquid radioactive waste treatment system equipment at the Haddam Neck Plant consists of: filters, ion exchangers and various tanks (as required). The liquid radioactive waste treatment system is depicted in Figure H-2 Liquid Radwaste System.

B-2 REMM

FIC1 2o Revisiol 19 B.14. ALL APPLICABLE GASEOUS RADIOACTIVE WASTE TREATMENTS SYSTEMS ALL APPLICABLE GASEOUS RADIOACTIVE WASTE TREATMENT SYSTEMSP is defined as that equipment applicable to a waste stream responsible for greater than ten percent 10% of the total projected dose. The gaseous radioactive waste treatment equipment at the Haddam Neck Plant consists of ventilation sys-:em HEPA.

B-3 REMM

DEC, ?fflq5 Revision 19 TABLE B.1 FREQUENCY NOTATION

NOTATION FREQUENCY S At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

D At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

W At least once per 7 days.

B At least once per 14 days (biweekly)

M At least once per 31 days.

Q At least once per 92 days.

SA At least once per 184 days.

R At least once per 18 months.

P. Prior to each release.

N.A. Not applicable.

Each surveillance requirement shall be performed/completed within the specified surveillance interval with a maximum allowable extension not to exceed 25% of the specified interval B-4 REMM

AEC 2 12 3005 Revision 19 C. LIQUID EFFLUENTS C.1 Liquid Effluents Sampling and Analysis Program Radioactive liquid wastes shall be sampled and analyzed in accordance with the program specified in Table C-1 for the Haddam Neck Plant.. The results of the radioactive analyses shall be input to the methodology of the ODCM to assure that the concentrations at the point of release are maintained within the Controls of the REMODCM.

C-1 REMM

DEC., ej i 2005 Revisicn 19 Table C-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum of DetectiDna Sampling Analysis Type of Activity (LLD)

Liquid Release Type Frequency Frequency Analysis (giCi/cc" A. Batch Releaset Prior to Prior to Principal Gamma 5.OOE-07 Each Batch Each Batch Emittersd From these sources: Release Release Monthly Gross Alpha 1.00E-07 Temporary Tanks9 Compositeb C H-3 1.OOE-05 Quarterly Sr-90 5.OOE-011 CompositebC Fe-55 1.00E-06O B. Continuous Release Daily Grab Weekly Principal Gamma 3.00E-08, Samplee Compositec Emitters Groundwater Treatment H-3 2.OOE-OE; System Discharge Monthly Gross Alpha 5.OOE-OE CompositebC Quarterly Sr-90 3.OOE-09 Compositeb c Fe-55 5.OOE-07 C-2 REMM

DEC2' 1 2005 Revision 19 TABLE C-1 (Continued)

TABLE NOTATIONS

a. The lower limit of detection (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):

4 66 LLD= . Sb X SAF E *V *(2.22E + 06) -Y -exp(-AAt) where:

LLD is the lower limit of detection as defined above (microcuries per unit volume)

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

E is the counting efficiency (counts per transformation)

V is the sample size (volume) 2.22E+06 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 (when applicable)

At is the elapsed time between sample collection (or midpoint of sample collection) and lime of counting (when applicable)

SAF self absorption factor (when applicable)

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.

b. 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 liquid released.

c. 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.

d. The principal gamma emitters for which the LLD specification will apply are exclusively the following nuclides: Mn-54, Co-60, Zn-65, Cs-134 and Cs-137. This does not mean that only these nuclides are to be reported. Other nuclides that are identified shall be 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 an a priori L.LD being higher than required, the reasons shall be documented in the Annual Radioactive Effluent Report.

C-3 REMM

DEC 2 1 2005 Revision 19

e. A grab sample will be obtained daily at least five (5) days per week, when discharges are in progress.

f. Prior to sampling, each batch shall be isolated; at least two tank volumes shall be recirculated or equivalent mixing provided.

g. Releases can be made from other sources (e.g., temporary tanks) as long as these have met the programmatic requirements including, but not limited to release rate determination action statements, etc.

C-4 REMM

2 i 05 2EC Revision 19 C.2 Liquid Radioactive Waste Treatment Monthly doses due to liquid effluents to unrestricted areas shall be projected at least once per 31 days only if one or ALL APPLICABLE LIQUID RADIOACTIVE WASTE TREATMENT SYSTEMS will not be routinely operated. When the projected monthly dose due to liquid effluents exceeds 0.06 mrem to the total bDdy or 0.2 mrem to any organ, ALL APPLICABLE LIQUID RADIOACTIVE WASTE TREATMENT SYSTEMS will be operated.

With radioactive liquid waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission, within 30 days, pursuant to Subsection F.3, a special report that includes the following information:

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

b. Actions taken to restore the inoperable equipment to OPERABLE status; and

c. Summary description of actions taken to prevent a recurrence.

Figure H-2, "Liquid Radwaste System" represents how the liquid radwaste system is configured at the time of this revision. Since the plant is undergoing decommissioning, tanks will be abandoned and dismantled. Temporary tanks may be used to replace them. This will not require a change to this figure (REMODCM) prior to use of these. This figure will be updated, if required, to reflect the current configuration of the liquid radwaste system, each time the REMODCM is revised.

.- 5 REMM

ne, 2,1 2005 Revisioi 19 C.3/4 LIQUID EFFLUENT CONTROLS AND SURVEILLANCE REQUIREMENTS CONCENTRATION CONTRDLS C.3.1 The concentration of radioactive material released from the site (see Figure H-1) shall riot exceed the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 (pre 1994 version).

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 REQUIREMENTS C.4.1.1 Radioactive liquid wastes shall be sampled and analyzed in accordance with the sampling and analysis program specified in Section I of the REMODCM.

C.4.1.2 The results of the radioactive analysis shall be used in accordance with the methods of Section II of the REMODCM to assure that the concentration of the point of release are maintained within the limits of Control C.3.1.

C-6 REMM

[EC 2 I 2005 Revision 19 RADIOACTIVE EFFLUENTS BASIS C.3/4 LIQUID EFFLUENTS C.3/4.1 CONCENTRATION 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, Column 2 (pre 1994 version). 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 lI.A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) the limits of 10 CFR 20.106(e) to the population.

C-7 REMM

U iL2G l 005 Revision 19 RADIOACTIVE EFFLUENTS DOSE t.IQUIDS CONROLS C.3.2 The dose or dose commitment to any MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from the site (see Figure H-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, pursuant to Control F.3, 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 MEMBER OF THE PUBLIC from such release during the calendar year is within 3 mrem to the total body and 10 mrem to any organ.

$URVEIJEANCE REQUIREMENTS C.4A2.1 Cumulative dose contributions for the current calendar quarter and current calendar year from liquid effluents shall be determined in accordance with Section II of the REMODCM once every 31 days.

C.4.2.2 Relative accuracy or conservatisms of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I of the REMODCM.

C-8 REMM

DEC 21 2005 Revision 19 RADIOACTIVE EFFLUENTS C.3/4 LIQUID EFFLUENTS C.3/4.2 DOSE, LIQUIDS This Control is provided to implement the requirements of Sections II.A, III.A, and IV.A of Appenc'ix I, 10 CFR Part 50. The Limiting Condition for Operation 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 the REMODCM 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 a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the REMODCM 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 Rcutine Releases of Reactor Effluents for the Purpose of Evaluating .Compliance with 10 CFR FPart 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.

C-9 REMM

DEC 2 i 2005 Revision 19 INSTRUMENTATION RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION CONITROLS_

C.3.3 The radioactive liquid effluent monitoring instrumentation channels shown in Table C.3.3 shall be OPERABLE with applicable settings to ensure that the limits of Control C.3.1 are not exceeded. The settings shall be determined in accordance with methodology find parameters described in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

APPLICABILITY: At all times.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel 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 settings so it is acceptably conservative.

b. With the number of channels less than the minimum channels OPERABLE requirement, take the ACTION shown in Table C.3.3. Exert best efforts to restore the inoperable monitor to OPERABLE status within 30 days, and, if unsuccessful, explain in the next Annual Effluent 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 C.4.3 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION, at the frequencies shown in Table C.4.3.

C-1 0 REMM

PiEC 2 12005 Revision 19 INSTRUMENTATION BA-SES-C.3/4.3FRADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION The radioactive liquid effluent instrumentation *isprovided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents. The setpoints for this instrument shall be calcubated and adjusted in accordance with the methodology and parameters in the 00CM to ensure compliaince with limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirem ants of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 60.

C-1Il REMM

OEC 2 l 2005 Revision 19 RA-l OCT.I .E LQUIID EFF LUENT ARIAI.0TsRIAG NSV T1ruVE 5 1 T.-A TION MINIMUM #

INSTRUMENT OPERABLE ACTION

1. FLOW RATE MEASUREMENT

a. Temporary Tank I 46 Discharge Line C-1 2 REMM

UEC' 2 1 2005 Revision 19 TABLE C.3.3 (Continued)

ACTION STATEMENTS ACTION 46 - 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.

C-1 3 REMM

)EC '1 i20t0h Revision 19 TABLE C.4.3 RAnD!O.4TI1A'F I 1 IQUn EFFL IIEAIT flf~llfT~ iA IANI^ITNI 1ll^1A T^,as *"s '*w^**

_. .. ._- WE %. Vs ~4 ._**k§ be I AWIVIZIV 1 1 mpl

VrIL U - IVIr L.LIVLt REQUIREMENTS CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL INSTRUMENT -CHECK CHECK CALIBRATION TEST

1. FLOW RATE MEASUREMENT

a. Temporary Test Tank D(1) N.A. R N.A.

Discharge Line C-14 REMM

EDES 2 I 20 05 Revisio-i 19 TABLE C.4 3 (Continued)

TABLE NOTATIONS (1)CHANNEL CHECK need only be performed daily when discharges are made from this pathway. The CHANNEL CHECK should be done when the discharge is in process.

C-. 5 REMM

Sic-¢ onl 192O Revision 20011 D. GASEOUS EFFLUENTS D.1 Gaseous Effluents Sampling and Analysis Program Radioactive gaseous wastes shall be sampled and analyzed in accordance with the program specified in Table D-1 for the Haddam Neck Plant. The results of the radioactive analyses shall be input to the methodology of the ODCM to assure that the offsite dose rates are maintained within the Controls of the REMODCM.

D-1 REMM

DEGY 2 1 200700 Revisioi 19 TABLE D-1 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum of Detection Sampling Analysis Type of Activity (LLD)'

Gaseous Waste Type Frequency Frequency Analysis (PCi/cc)

A. Miscellaneous Pointsd Weekly` Weekly H-3 1EZ Gaseous Grab For example:

Alternate Containment Access E Continuousb Weekly Principal Gamma 1.00E-1

Tented Enclosures . dc

.Particulate Emittersc Monthly Gross Alpha 1.OOE-1 I Particulate Composite

. Quarterly. Sr-90e 1.OOE-1 I

. Particulate Composite D-2 REMM

-1rC is,1 200 5 Revisioi 19 Table [U (Continued)

TABLE NOTATIONS

a. The lower limit of detection (LLD) is defined in Table Notations of Table C-1.

b. The ratio of the sample flow rate to the actual or estimated sampled stream flow rate shall be known for the time period covered by'each dose or dose rate calculation made in accordance with REMODCM.

c. The principal gamma emitters for which the LLD specification will apply are exclusively the following radionuclides: Mn-54, Co-60, Zn-65, Cs-134, and Cs-137. The list does not mean that only these nuclides'are to be detected and reported. Other nuclides, which are identified, shall be reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD. When unusual circumstances result in an a priori (before the fact) LLD being higher than required, the reasons shall be documented in the Annual Radioactive Effluent Report.

d. Release points included in this category are added if the radiological evaluation of the job or building indicates a potential for significant airborne radioactivity. This evaluation shall be performed in accordance with applicable radiological engineering programs.

e. Sr-90 analysis only required if Gross Beta is identified. -

f. Tritium is only required for the Spent Fuel Building exhaust monitoring point, until the bulk Spent Fuel Pool liquid is drained D-3 REMM

EC 2 205 Revision 19 D.2 Gaseous Radioactive Waste Treatment Monthly doses due to gaseous effluents to unrestricted areas shall be projected at least once per 31 days only if one or ALL APPLICABLE GASEOUS RADIOACTIVE WASTE TREATMENT SYSTEMS will not be routinely operated.

When the projected monthly dose due to gaseous effluents exceeds 0.3 mrem to any organ due to gaseous particulate effluents, ALL APPLICABLE GASEOUS RADIOACTIVE WASTE TREATMENT SYSTEMS will be operated.

With radioactive gaseous waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission, within 30 days, pursuant to Subsection F.3, a special. report that includes the following information:

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

b. Actions taken to restore the inoperable equipment to OPERABLE status; and C. Summary description of actions taken to prevent a recurrence.

0-4 REMM

Revision 19 D.3/4 GASEOUS EFFLUENT CONTROLS AND SURVEILLANCE REQUIREMENTS DOSE RATE MCNTR0 LS D.3.1 The dose rate, at any time, offsite (see Figure H-1) due to radioactive materials released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit due to inhalation for 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 Control D.3.1.

SURVEII LANCE REQUIREMENTS D.4.1.1 The release rate of radioactive materials in gaseous effluents shall.be determined by obtaining representative samples land performing analyses in accordance with ihe sampling and analysis program specified in Section I of the REMODCM (Table D-1).

The corresponding dose rate shall be determined using the methodology and parameters given in the ODCM (Section II of the REMODCM).

Tritium is only required until the bulk SFP liquid is drained.

D-5 REMM

Revision 19 -

RADIOACTIVE EFFLUENTS MaESS D.3/4 G-ASEOUS EFFLUENTS D.3/4.1 DOSE RATE This Control is provided to ensure that the dose rate at anytime from gaseous effluents from 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 (pre 1994 version).

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 lmits specified in Appendix B, Table II (pre 1994 version) 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 sufficienily 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 mrern/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 other organ dose rate above background to a child to less than or equal to 1500 mrem/year from inhalation.

D-6 REMM

U2 I _0 DS Revision 19 RADIOACTIVE EFFLUENTS DOSE, RADIOACTIVE MATERIAL IN PARTICULATE FORM AND RADIONUCLIDES OTHER THAN NOBLE GASES CONITROLS D.3.2 The dose to any MEMBER OF THE PUBLIC from tritium and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite (see Figure H-I) shall be limited to the following:

El. 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 radionuclides, 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, pursuant to Control F.3, 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 MEMBER OF THE PUBLIC from such releases during the calendar year is within 15 mrem to any organ.

SURVE[I LANCE REQUIREMENTS D.4.2.1 Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II of the REMODCM once every 31 days.

D.4.2.2 Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in -the REMODCM.

D-7 REMM

Dgf i- 'c) 2005 Revision 19 RADIOACTIVE EFFLUENTS BASES D.3/4.2 DOSE, RADIOACTIVE MATERIAL IN PARTICULATE FORM AND RADIONUCLICES OTHER THAN NOBLE GASES This Control is provided to implement the requirements of Sections II.C, ILI.A and IV.A of Append x I, 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 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 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 Regulatoiy 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 Controls for 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.

D-8 REMM

Lj'h ZOO Revision 19 E. RADIOLOGICAL ENVIRONMENTAL MONITORING E.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 from plant or ISFSI activities. Program changes may be made based on operational experience.

The sampling and analyses shall be conducted as specified in Table E-1 for the locations shown in Appendix G of the ODCM. 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 Operating Report pursuant to Section 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 at the most desired location or time. In these instances suitable alternative media and locations may be chosen for the particular pathways in question and appropriate substitutions made within 30 days in the Radiological Environmental Monitoring Program.

Changes to sampling locations shall be identified in a revised table and figure(s) in Appendix G of the ODCM.

If the level of radioactivity in an environmental sampling medium at one or monr of the locations specified in Table E-1 exceeds the report levels of Table E-2 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 E-2 to be exceeded. When more than one of the radionuclides in Table E-2 are detected in the sampling medium, this report shall be submitted if:

concentration (1) concentration (2) >l 0 reportinglevel (1) reportinglevel (2)-T-E-1 REMM

F13 7 12005

- evision 19 When radionuclides other than those in Table E-2 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 REMODCM. 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 Radiological Environmental Operating Report.

The detection capabilities required by Table E-3 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 LI-Ds unachievable. In such cases, the contributing factors will be identified and described in the Annual Radiological Environmental Operating Report.

E-2 REMM

DEC 2,' I 200055 Revisio.n 19 TABLE E-1 HADDAM NECK RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway and/or Number of Sampling and Collection Type and Frequency of Sample Locations Frequency Analysis

1. Gamma Dose - 20 Quarterly Gamma Dose - Quarterly Environmental TLD I

2. Bottom Sediment 4 Annual Gamma Isotopic

3. River Water ()2 Quarterly Sample - Indicator is Quarterly - Gamma Isotopic

Continuous Composite; Control is and Tritium of continuous Composite of Six Consecutive indicator and control grab Grab Samples collected biweekly. composites.

4. Fish (edible portion) -

bullheads and, when' available, Perch or other 2 Annual Gamma Isotopic - Semiannual i

5.

edible fish (1)

Shellfish (1) 2 Annual *Gamma Isotopic - Semiannual I

(1) Not required after bulk SFP liquid has been released, except for ISFSI related samples.

One final set of canal related discharge samples will be obtained after bulk SFP liquid has been released.

E-3 REMM

113E-, I 20U Revision 19 TABLE E-2 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Reporting Levels Analysis Water Fish Shellfish (pCi/l) (pCi/kg, wet) (pCilkg, wet)

H-3 2.OOE+04 Mn-54 1.OOE+03 3.OOE+04 1.40E+05 Co-60 3.OOE+02 OOE+04 .. 5.OOE+04 Zn-65 3.OOE+02 2.OOE+04 8.OOE+04 Cs-134 3.OOE+01 1.OOE+03 5.00E+03 Cs-137 5.OQE+01 2.OOE+03 8.OOE+03 E-4 REMM

iD1s 2 1 20uR Revisiol 19 TABLE E-3 MAXIMUM VALUES FOR LOWER LIMITS OF DETECTION (LLD)a Analysis Water Fish Sediment (pC/I) (pCi/kg, wet) (pCi/kg, dry)

H-3 2.OOE+03 Mn-54 1.50E+01 1.30E+02 Co-60 1.50E+01 1.30E+02 1.50E+02 Zn-65 3.OOE+01 2.60E+02 Cs-134 1.50E+01 1.30E+02 1.50E+02 Cs-1 37 1.80E+01 1.50E+02 1.80E+02 E-5 REMM

- Revision 19 TABLE E-3 (Continued)

TABLE NOTATIONS

a. The lower limit of detection (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):

4.66Sb LLD=

E *V *2.22 *Y. exp(-At) where:

LLD is the lower limit of detection as defined above (microcuries per unit volume)

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

E isthe counting efficiency (counts per transformation)

V isthe sample size (volume) 2.22 isthe 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 sample collection (or midpoint of sample collection) 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 Dosteriori (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 described in the Annual Radiological Environmental Operating Report.

E-6 REMM

DEC: 2z i 2o00 Revision 19 E.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 I to 10 CFR Part 50.

Due to the current status of the Decommissioning Project the Land Use Census is not expected to change in a manner that would affect the Environme,-tal Monitoring Program. The most recent census shall be in effect until superseded.

During the course of the Decommissioning Project an updated Land Use Census can be obtained at any time as directed by the Site Management. The following information is relative to the performance of the census:

. The Land Use Census shall identify the location of the nearest resident, the nearest milk animal, and the nearest gardentt of greater than 50 m2 (500 ft2) producing broad leaf vegetation in each of the 16 meteorological sectors within a distance of 8 km (5 miles).

The validity of the Land Use Census can be verified 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) that yields a calculated dose or dose commitment (via-the same exposure pathway) 20% greater than at a location from which samples are currently being obtained in accordance with Section E.1, add the new location(s) within 30 days. The sample location(s),

excluding the control location, having the lowest calculated dose or dose commitment(s), via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which the Land Use Census is conducted.

Sample location changes shall be noted in the Annual Radiological Environmental Operating Report.

tt 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/Q in lieu of a garden census.

E-7 REMM

-C 21 20035 Revision 19 E.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.

E-8 REMM

DEC 2 12005 Revision 19 F. REPORT CONTENT F.1 Annual Radiological Environmental Operating Report The Annual Radioactive Environmental Operating Report shall include summaries, interpretations and statistical evaluation of the results of the radiological environmental surveillance activities for the report period, including a comparison with the previous environmental surveillance reports and an assessment of the observed impacts of the plant operation and ISFSI on the environment. The report shall also include the results of the land use census required by Section E.2 of this manual. If levels of radioactivity are detected that result in calculated doses greater than 10 CFR Part 50 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:

a. Total number of analyses performed at indicator locations;

b. Total number of analyses performed at control locations;

c. Lower limit of detection (LLD);

d. Mean and range of all indicator locations together;

e. Mean and average of all control locations together;

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

9. 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 resu'ts.

The missing data shall be submitted in the next annual report.

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 E.3 of this manual.

F-1 REMM

9FEQto I 2OO5 F.2 Annual Radioactive Effluent Report The Annual Radioactive Effluent Report (ARER) 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, 06/74) format. Radiation dose assessments for these effluents shall be provided in accordance with 10 CFR Part 50.36a and the REMODCM. An annual assessment of the, radiation dose from the site to the most likely exposed MEMBER OF THE PUBLIC shall be included to demonstrate conformance with 40 CFR Part 190. A table totaling and comparing doses from liquid and airborne sources to the 40 CFR 190 limit will be provided in the Annual Radioactive Effluent Report and based on ERC-161-3-ER-99-C012, direct dose will not be routinely included in the dose assessment. An evaluation of the direct dose aspect will be discussed in the Annual Environmental Operating Report. This evaluation will include the dose recorded on control TLDs and TL Ds located near residents. Dose shall be calculated in accordance with the OFFSITE DOSE CALCULATION MANUAL. The ARER shall be submitted by May 1 of each year for the period covering the previous calendar year.

The ARER 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:

a. Type of waste (e.g., spent resin, compacted dry waste, irradiated components, etc.);

b. Solidification agent (e.g., cement);

c. Total curies;

d. Total volume and typical container volumes;

e. Principal radionuclides (those greater than 10% of total activity); and

f. Types of containers used (e.g., LSA, Type A, etc.).

The ARER shall include the following information for each abnormal release of radioactive liquid and gaseous effluents from the site to unrestricted areas:

a. Description of the events and equipment involved;

b. Causes for the abnormal release;

c. Actions taken to prevent recurrence; and

d. Consequences of the abnormal release.

Changes to the RADIOLOGICAL EFFLUENT MONITORING AND OFFSITE DOSE CALCULATION MANUAL (REMODCM) shall be submitted to the NRC as appropriate, as part of or concurrent with the ARER for the period in which the changes were made.

F-2 REMM

[IJEG 2 12.005 Revision 19 F.:3 SPECIAL REPORTS Special reports shall be submitted to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the appropriate Regional Office of the NRC, within the time period specified for each report.

F-3 REMM

DEC 'r? 3I 200 Revision 19 G. TOTAL DOSE G. l Total Dose from All Sources In addition to the dose limitations specified in sections C & D of the REMIM, 40 CFR 190 limits the total dose to an individual from all sources (liquid effluents, gaseous effluents, and direct dose from fixed sources) to less than or equal to 25 mrem per year to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem per year.

G-1 REMM

'R visioz 2UU5 G.:2 Compliance with 40CFR190 Limits The following sources should be considered in determining the total dose to a real individual from uranium fuel cycle sources:

a. CY gaseous doses from all release pathways.

b. CY liquid doses from all release pathways.

c. CY direct dose from the site (see Section D.5 in the ODCM).

d. Since all other uranium fuel cycle sources are greater than 20 miles away, they need not be considered.

G-2 REMM

Dn 12 005 Revision 19 G.3/4 TOTAL DOSE CONTROLS AND SURVEILLANCE REQUIREMENTS CONTROLS G.3 The dose or dose commitment from the site to a MEMBER OF THE PUBLIC 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 Specification C.3.2 or D.3.2, prepare and submit a Special Report to Commission pursuant to Control F.3 and limit the subsequent releases such that the dose or dose commitment from the site to any MEMBER OF THE PUBLIC 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 MEMBER OF THE PUBLIC (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 fror 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.

SURVE[IILANCE REQUIREMENTS G.4 Cumulative dose contributions from liquid and gaseous effluents and direct radiation shall be determined in Specifications C.4.2.1 and D.4.2.1 and in accordance with Section II of the REMODCM once per 31 days.

G-3 REMM

DEC 2EI 21,!1 Revision 19 BASES-G.3/4 TOTAL DOSE This specification is provided to meet the reporting requirements of 40 CFR Part 190. For the purposes of the Special Report, it may be assumed that the dose commitment to any MEMEER 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.

m G-4 REMM

Figure H-1. Revision 19 Exclusion Area Boundary and Site Boundary for Liquid and Gaseous Effluents UNRESTRICTED AREA

) / } iE; ~~~~~~~~~~. ii-..--.

. ::-:xsE:

i;..

i i!::.._

r\: m--

sP

.!1... iUNR STRICTI *ED AREA

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/ H N :;: .'. #:.-::-:-::;i: ;; :-':.: i-S:-:.'::: : : . i iE ::';:- :EE:;;SE.-:::P::-' :.l SE i UNRESTRICTEC AREA f ::'...................

a .,:--.:-i:- ' .:i::::

-n':,'.':N

TA

. CONTROLLED.

{: ! . }' \::~~~~~~~~~~Ai

- ,,',..'.;.'i:

: " AREA:,

O4a%.Y_ JUT fVCR CONNECJ Rcuwvm REMM H-1

Ff.: 2, I ?An; Revision 19 Figure H-2 Liquid Radwaste System Canal FRC - Flow Controller FCV - Flow Control Valve REMM H-2 H-2 REMM

ML061280286

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