ML13317B479

Forwards marked-up Draft of Radiological ETS Annotated W/Review Comments from Site Visit.Telcon Suggested to Discuss Comments W/Util,Eg&G & NRC Representative

ML13317B479
Person / Time
Site:	San Onofre
Issue date:	11/24/1982
From:	Serrano W EG&G, INC.
To:	Krieger R SOUTHERN CALIFORNIA EDISON CO.
References
NUDOCS 8212140366
Download: ML13317B479 (100)

Text

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P' if Serr-o DRAFT 2-0 S-Z - Z 04 ACLlorens:4846 08/18/82 PROPOSED SPECIFICATIONS To Appendix A, Section 1.0, Definitions, the following would be added: SOURCE CHECK A SOURCE CHECK is the qualitative assessment of a channel response when the channel sensor is exposed to a radioactive source. OFFSITE DOSE CALCULATION (ODCM) An OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the current methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm/trip setpoints, and in the conduct of the environmental radiological monitoring program. GASEOUS RADWASTE TREATMENT SYSTEM A GASEOUS RADWASTE TREATMENT SYSTEM is any system designed and installed to reduce radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the envi ronment. Do ~ ~ S,5a LZ.~ I~ L/AL-A-

-2 VENTILATION EXHAUST TREATMENT SYSTEM A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal absorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust stream prior to the release to the environment. Such a system is not considered to have any effect on noble gas effluents. Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be Ventilation Exhaust Treatment System components. FREQUENCY NOTATION The FREQUENCY NOTATION is specified in Table 1-1. SOLIDIFICATION SOLIDIFICATION shall be the conversion of wet wastes into a form that meets shipping and burial ground requirements. PURGE-PURGING PURGE or PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is required to purify the confinement.

-3 VENTING VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process. PROCESS CONTROL PROGRAM The PROCESS CONTROL PROGRAM shall contain the current formula, sampling, analyses, tests and determinations to be made to ensure that the processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Part 0, 10 CFR Part 71 and Federal and State regulations and other requirements overning the disposal of the radioactive waste. MEMBER(S) OF THE PUBLIC MEMBER(S) OF THE PUBLIC shall include all idividuals who by virtue of their occupational status have no formal association with the plant. This category shall include non-employees of the licensee who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with plant functions. This category shall not include non-employees such as

-4 vending machine servicemen or postmen who, as part of their formal job function, occasionally enter an area that is controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials. SITE BOUNDARY The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee. UNRESTRICTED AREA An UNRESTRICTED AREA shall be any area at or beyond the site boundary access to which 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. To Appendix A, Specification 3.5, Instrumentation and Control, the following Specifications 3.5.8 and 3.5.9 will be added:

1, kA-u _A 7AoL I

-5 3.5.8 RADIOACTIVE LIQUID EFFLUENT INSTRUMENTATION Applicability: As shown in Table 3.5.8.1 Objective: Monitor and control radioactive liquid effluent releases. Specification: A. The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.5.8.1 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.15.1 are not exceeded. B. Action

1. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than a value which will ensure that the limits of 3.15.1 are met, 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.

-6

2. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels inoperabl) take the ACTION shown in Table 3.5.8.1.

If the inoperable instruments are not returned to OPERABLE status within 30 days, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

3. The provisions of Specification 3.0 and 6.9.2.b(2) are not applicable.

BdSis: 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 are calculated in accordance with NRC approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. ~p S7S 3,. 0,.o4

-7 TABLE 3.5.8.1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE ACTION

1. Gross Radioactivity Monitors Providing Automatic Termination of Release

a. Liquid Radwaste Effluent Line (R-1218)

(1) 1

b. Steam Generator Blowdown(a)

(1)2 Effluent Line (R-1216)

2. Gross Radioactivity Monitors Not Providing Automatic Termination of Release

a. Turbine Building Sumps Effluent Line (1) 3 (Oily Waste Sump Monitor) (R-2101*)

b.

Component Cooling Water System(b) (R-1217) (1) 4

3.

Flow Rate Measurement Devices

a. Liquid Radwaste Effluent Line (1) 5

b.

Circulating Water Outfall** (1)F Do .v..sD

c. Steam Generator Blowdown Effluent**

Line Pump status, valve turns or calculations are utilized to estimate flow. (a) The Steam Generator Blowdown Effluent Line is grab sampled three times weekly to determine activity within the steam generators. (h) Closed loop system. tNew instrumentation - Conformance with Technical Specifications will have to be determined following installation.

TABLE 3.5.3.1 (Continued) TABLE NOTATION ACTION 1 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may continue provided that prior to initiating a release:

1. At least two separate samples which can be taken by a single person are analyzed in accordance with Specification 4 and; 4,

2. At least two technically qualified persons verify the release rate calculations and discharge valving; Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 2 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue, provided grab samples are analyzed for gross radioactivity (beta or gamma) at a lower limit of detection of at least 10-7 microcurie/gr

1.

At least once per 12 hours when the specific activity of the secondary coolant is > 0.01 uCi/gram DOSE EQUIVALENT 1-131.

-9

2. At least once per 24 hours when the specific activity of the secondary coolant is < 0.01 uCi/gram DOSE EQUIVALENT 1-131.

ACTION 3 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that, at least once per 12 hours, grab samples are collected and analyzed for gross radioactivity (beta or gamma) at a lower limit of detection of at least 10-7 microcurie/grqi2 ,,0 ACTION 4 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, determine if there is leakage from the Component Cooling Water System to the Salt Water Cooling System. Sample the Component Cooling Water System to estimate the activity being released via the Salt Water Cooling System. ACTION 5 With tne number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours during actual releases. u e ra

-10 3.5.9 RADIOACTIVE GASEOUS PROCESS AND EFFLUENT MONITORING INSTRUMENTATION Applicability: As shown in Table 3.5.9.1 Objective: Monitor and control radioactive gaseous releases. Specification: A. The radioactive gaseous process and effluent monitoring instrumentation channels shown in Table 3.5.9.1 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.16.1 are not exceeded. B. Action

1. With a radioactive gaseous process or effluent monitoring instrumentation channel alarm/trip setpoint less conservative than a value which will ensure that the limits of 3.16.1 are met, declare the channel inoperable. U~e

2. With ess t n the minimum number of radioactive gaseous process or effluent monitoring instrumentation channels inoperable, take the ACTION shown in Table 3.5.9.1.

tV Or 4LL Ji%~ 14 4 1?dletY cJ~~ L492LtTe1 aV -3 C3q..2rb

Basis: 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 are calculated in accordance with NRC approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20.

TABLE 3.5.9.1 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

1. Stack Monitoring System 1

a. Gross Activity Monitor -

(1) 1 Providing Alarm and Automatic Termination of 'Release. (R-1214)

b.

Noble Gas Activity Monitor (1) 2 (R-1219, 1223*)

c. Iodine Sampler Cartridge (1) 3

d. Particulate Sampler Filter (1) 3

e. Stack Fan Flow Indication (1)

• 4

f.

Sampler Flow Rate Measuring (1) Device

1. Includes the following subsystems:

a) Spent Fuel Building*VentilationAuxiliary Building Ventilation, and Waste Gas Treatment (CVI) Building Ventilation systems. b) Containment Monitoring System. c) Air Ejector System. New instrumentation - Conformance with Technical Specifications will have to be determined following installation. 5

0/.~ /C~ 2L 2 i vo-~ ~Z~i~j, ~'dfv-r'-

-13 TABLE 3.5.9.1 (Continued) TABLE NOTATION

• During releases via this pathway.

ACTION 1 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement effluent releases may continue if instruments 1b, c and d are operable, otherwise take ACTION shown for 1b, c or d. ACTION 2 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of a waste gas tank may be released to the environment provided that prior to initiating the release:

1. At least two separate samples which can be taken by a single person of the tank's contents are analyzed; and

2. At least two technically qualified persons verify the release rate calculations and discharge valve lineup; Otherwise, suspend release of radioactive effluents via this pathway.

All other effluent releases via this pathway may continue provided grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity within 24 hours.

-14 ACTION 3 With-the of channels OPERABLE L an requi red by the Minimum Channels OPERABE rement, effluent releases via the effected pathw ay continue provided samples--. oected every ACTION 4 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the flowrate is estimated at least once per 4 hours. AA2

-15 3.15 RADIOACTIVE LIQUID EFFLUENTS 3.15.1 Liquid Effluents Concentration Applicability: At all times Objective: Maintain the concentration of radioactive liquid material released from the site below 10 CFR 20 limits. Specification: A. The concentration of radioactive material released in z C61PS liquid effluents to unrestricted areas (see Figure 3.15.1.1) 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 be limited to 2 x 10-4 uCi/ml. B. Action: With the concentration of radioactive material released in liquid effluents to unrestricted areas exceeding the above limits, without delay restore the concentration to within the-above limits.

0.

(-)4t

-16 Basis: This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas 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 willcj result in exposures within (1) the Section II.A design obiectives of 0-or-7H& J,?0~c Appendix I, 10 CFR Part 50, to - 4n indiidtal, and (2) the limits of 10 CFR Part 20.106(e) to the population. The concentration limit for noble gases is based upon the assumption that Xe-135 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. 3.15.2 Liquid Effluent Dose Applicability: At all times Objective: Maintain the release of radioactive liquid effluents from the site as low as is reasonably achievable.

-17 C,9P Specification: A. The dose or dose commitment to a member of the public from radioactive materials in liquid effluents released to 41 35 unrestricted area (see Figure 3.15.1.1) shall be limited:

1. During any calendar quarter to < 1.5 mrem to the total body and to < 5 mrem to any organ, and.

2. During any calendar year to < 3 mrem to the total body and to < 10 mrem to any organ.

B. Action:

1. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3, a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

2. The provisions of Specification 3.0 are not applicable.

-18 Basis: This specification is provided to implement the requirements of Sections II.A and IV.A of Appendix I, 10 CFR Part 50. Specification A implements the guides set forth in Section II.A of Appendix I. Specification B provides the required operating flexibility and at the same time implements 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." 3.15.3 Liquid Waste Treatment Applicability: At all times Objective: Maintain radioactive releases from the site as low as is reasonably achievable by use of the liquid radwaste treatment system. Specification: A. The liquid radwaste treatment system shall be used to reduce the radioactive materials in liquid wastes prior to their ischarge when the projected dose due to the liquid L'V-San 0". #'e a.,1-I effluent, to unrestricted areas (see Figure 3.15.1.1) would exceed 0.06 mrem to the total body or 0.2 mrem to any organ in a 31 day period. Cotal

-19 B. Action: With radioactive liquid waste being discharged without treatment and in excess of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3, a Special report that includes the following information:

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

2. Action(s) taken to restore the inoperable equipment to OPERABLE status.

3.

Summary description of action(s) taken to prevent a recurrence. The provisions of Specification 3.0 are not applicable.

-20 Basis: The OPERABILITY of the liquid radwaste treatment system ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirements that the appropriate portions of this system be used when specified provides assurance that tne releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR Part 50.36a and design objective Section II.0 of Appendix I to 10 CFR Part 50. The specified limits governing, the use of appropriate portions of the liquid radwaste treatment system were specified as a suitable fraction of the guide set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

-21 3.16 RADIOACTIVE GASEOUS EFFLUENTS 3.16.1 Dose Rate Applicability: At all times Objective: Maintain the dose rate at the exclusion area boundary from radioactive gaseous effluents within 10 CFR 20 limits. Specification: A. The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 3.15.1.1) shall be limited to the following values:

1. The dose rate limit for noble gases shall be < 500 mrem/year to the total body and < 3000 mrem/year to the skin, and A.-13 3

1-I33.

2.

The dose rate limit for iodine-131, for tritium and for all radionuclides in particulate form with half lives greater than 8 days shall be < 1500 mrem/year to any organ.

-22 B. Action: With the dose rate(s) exceeding the above limits, without delay restore the release rate to within the above limit(s. Basis: This specification is provided to ensure that the dose rate at anytime at the exclusion area boundary from gaseous effluents will be within the annual.dose limits of 10 CFR Part 20 for unrestricted areas. 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 Rn -+dfr+4ual in an unrestricted aea, either within or outside the exclusion area boundary, to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b)). For.4 4.4.is who may at times be within the exclusion area boundary, the occupancy of the idividual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the exclusion area boundary. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an-ndtivtTatlat or beyond the exclusion area boundary to < 500 mrem/year to the total

-23 body or to < 3000 mrem/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to &A-44+tt via the,

Qw-m

-=4feet-pathway to < 1500 mrem/year fe be r

-Cow otlpbzz 3.16.2 Dose, Noble Gases. Applicability: At all times Objective: Maintain the dose due to noble gases in gaseous effluents as low as is reasonably achievable. Specification: A. The air dose due to noble gases r leased in gaseous effluents, fr-"r @ t-c W i to areas at and beyond the SITE BOUNDARY (see Figure 3.15.1.1) shall be limited to the following:

1. During any calendar quarter: < 5 mrad for gamma radiation and < 10 mrad for beta radiation;

2. During any calendar year:

< 10 mrad for gamma radiation and < 20 mrad for beta radiation.

-24 B. Action:

1. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3, a Special Report that identifies the cause(s) for exceeding the limit(s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

2. The provisions of Specification 3.0 are not applicable.

Basis: This specification is provided to implement the requirements of Sections II.B and IV.A of Appendix 1, 10 CFR Part 50. Specification A implements the guides set forth in Section II.B of Appendix I. Specification B provides the required operating flexibility and at the same time implements 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 reasonable achievable."

-25

3. 13 3

3.16.3 Dose, Iodine-131, Tritium and Radionuclides Applicability: At all times Objective: Maintain the dose due to radioiodines, radioactive material in particulate form and radionuclides other than noble gases in gaseous effluents as low as is reasonably achievable. Specification: A. The dose to a MEMBER OF THE PUBLIC from 1-131 from '-1 tritium and from all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from the-4e' to areas at and beyond the SITE BOUNDARY (see Figure 3.15.1.1) shall be limited to the following:

1. During any calendar quarter:

< 7.5 mrem to any organ; and

2. During any calendar year: < 15 mrem to any organ.

-26 B. Action:

1. With the calculated dose from the release of 1-131, tritium and radionuclides in particulate form with half lives greater than 8 days, in gaseous effluents exceeding any of the above limits in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3, a Special Report that identifies the cause(s) for exceeding the limit and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

2. The provisions of Specification 3.0 are not applicable.

Basis: This specification is provided to implement the requirements of Sections II.C and IV.A of Appendix 1, 10 CFR Part 50. Specification A is the guide.set forth in Section II.C of Appendix I. Specification B provides the required operating flexibility and at the same time implements 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."

-27 3.16.4 Gaseous Radwaste Treatment Applicability: At all times Objective: Maintain radioactive gaseous releases from the site as low as is reasonably achievable by use of the gaseous' radwaste and ventilation exhaust treatment systems. Specification: A. The gaseous radwaste treatment system and the ventilation exhaust treatment system-shall be used to reduce radioactive materials in gaseous waste prior to their discharge when the projected gaseus effluent air doses due to gaseous effluent releases from thet4@ se-to areas at and beyond the SITE BOUNDARY (see Figure 3.15.1.1) would exceed 0.2 mrad for gamma radiation and 0.4 mrad for beta radiation over 31 days. The ventilation exhaust treatment system shall be used to reduce radioactive materials in gaseous waste prior to their discharge ten the project-, doses due to gaseous effluent releases from to areas at and beyond the SITE BOUNDARY (see Figure 3.15.1.1) would exceed 0.3 mrem to any organ over 31 days.

-28 B. Action:

1. With gaseous waste being discharged without treatment and in excess of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.3, a Special Report which includes the following information:

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

b. Action(s) taken to restore the inoperable equipment to OPERABLE status.

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

2. The provisions of Specification 3.0 are not applicable.

-29 Basis: The OPERABILITY of the gaseous radwaste treatment system and the ventilation exhaust treatment system ensures that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR Part 50.36a, and design objective Section II.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the guide set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents. 3.16.5 Gas Storage Tanks Applicability: At all times Objective: Limit the amount of radioactivity contained in gas storage tanks. Specification: A. The-quantity of radioactivity contained in each gas storage tank shall be limited to < 56,000 curies noble gases (considered as Xe-133).

-30 B. Action: With the quantity of radioactive material in any gas storage tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank and within 48 hours reduce the tank contents to within the limit. 7r/-a '4 2,.0 3.16.6 Explosive Gas Mixture Applicability: At all times Objective: Limit the amount of explosive gases contained in the gas storage tanks. Specification: A. The concentration of oxygen in the waste gas holdup system shall be limited to less than or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume. B. Action:

1. With the concentration of oxygen in the waste gas holdup system greater than 2% by volume but less than or equal to 4% by volume, restore the concentration of oxygen to within the limit within 48 hours.

-31

2. With the concentration of oxygen in the waste gas holdup system greater than 4% by volume.and the hydrogen concentration greater than 2% by volume, immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or equal to 2% by volume without delay.

3. The provisions of Specification 3.0 are not applicable.

Basis: This specification is provided to ensure that the concentration of potentially explosive gas mixtures contained in the waste gas holdup system is maintained below the flammability limits of hydrogen and oxygen. Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50. 3.17 DOSE Applicability: At all times Objective: Maintain the dose due to the release of radioactive materials within specified limits.

-32 Specification: A. The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC, due to releases of radioactivity and 7 radiation, from uranium fuel cycle sources shall be limited to < 25 mrem to the total body or any organ (except the thyroid, which shall be limited to < 75 mrem). B. Action:

1. With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specifications 3.15.2.A, 3.16.2.A or 3.16.3.A, calculations should be made to determine whether the above limits of Specification 3.17 have been exceeded. If such is the case, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days pursuant to Specification 6.9.3 a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits.

This Special Report, as defined in 10 CFR Part 20.405c, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the

-33 calendar year that includes the release(s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations. If the estimated dose(s) exceeds the above limits, and if the release condition resulting in violation of 40 CFR Part 190 has not already been corrected, 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.

2. The provisions of Specification 3.0 are not applibable.

Basis: This specification is provided to meet the reporting requirements of 40 CFR 190. In complying with 40 CFR 190, nuclear fuel cycle facilities over five miles away are not considered to contribute to the dose assessment.

-34 3.18 RADIOLOGICAL ENVIRONMENTAL MONITORING 3.18.1 Monitoring Program Applicability: At all times Objective: Monitor exposure pathways for radiation and radioactive material. Specification: A. The radiological environmental monitoring program shall be conducted as specified in Table 3.18.1 B. Action:

1. With the radiological environmental monitoring program not being onducted as specified in Table 3.18.1, in lieu of ft6:2 prepare and submit to the Commission, in the Annual Radiological Operating Report, a description of the reasons for not conducting the program as required and tne plans for preventing a recurrence.

2. With the level of radioactivity in an environmental sampling medium exceeding the reporting levels of Table 3.18.2 when averaged ov ran calendar quarter, i~n I

-f-

-35 <hdG2j prepare and submit to the Commission within 30 days from the end of the affected calendar quarter a Report pursuant to Specification 6.9.3. When more than one of the radionuclides in Table 3.18.2 are detected in the sampling medium, this report shall be submitted if: concentration (1) + concentration (2) +... > 1.0 hTm6 level (1) m e lv el()

• >1.

When radionuclides other than those in Table 3.18.2 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to E ad49idurj is equal to or greater than the calendar year limits of Specifications 3.15.2, 3.16.2 and 3.16.3. 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 Radiological Environmental Operating Report.

3.

With fresh leafy vegetable samples or fleshy vegetable samples unavailable from one or more of the sample locations required by Table 3.18.1, n lieu of any ot report r ed by Sp ication .9.2, repare no su mit the C m ion wi in days, pur nt

-36 to S c leation 6 9 3, a Speci Rep rt whic id tifi s the c use of the availa ility f sam le 6n iden ifie location or obtainin eplacement ( mples. he locations from which samples were unavailable may then be e e o er ed by T le 3.18 ,rovided the oca ions f-rom w ich t e r placeme t sam les were btained are adde to t e e vironm ntal mo itor' g program a rep cement 1 cati ns. Q

4. The provisions f Specification 3.0 are.not applicable.

Basi radiological monitoring program required by this specification provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides, which lead to the highest potential radiation exposures o indiiuula resulting from the station 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. The initially specified monitoring program will be effective for at least the first three years of commercial operation. Following this period, program changes may be initiated based on operational experience.

-37 The detection capabilities required by Table 3.18.1 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 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 interferring 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. 3.18.2 Land Use Census Applicability: At all times Objective: Monitor the unrestricted area surrounding the site for potential changes to the radiological monitoring program as necessary.

TABLE 3.18.1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Number of Samples Sampling and and/or Sample and Sample Locationsa Collection Freguencya Type andFrequency Analyses

1.

AIRBORNE Samples from at least 5 Continuous operation of Radioodine cartridge. Analyze at Radioiodine and locations sampler with sample collection least once per 7 days for 1-131. Particulates 3 samples from offsite loctions as required by dust loading Particulate sampler. Analyze for (in different sectors) of the but at least once per 7 gross beta radioactivity > 24 highest calculated annual days.d hours following filter chnge. average ground level D/Q. Perform gamma isotopicb analysis on each sample when gross beta I sample from the vicinity of a activity is > 10 times the yearly community having the highest mean of confol samples. Perform calculated annual average gamma isotopic analysis on ground level D/Q. composite (by location) sample at least once per 92 days. 1 sample from a control location 15-30 km (10-20 miles) distant and in the least prevalent wind direction.c

2. DIRECT At least 30 locations including At least once per 92 days.

Gamma dose. At least once per -RAT4-sape an inner ring of stations in 92 days. the general area of the site yboundary and an outer ring approximately in the 4 to 5 mile range from the site with a station in each sector of each ring. The balance of the station are in special interest areas such as population centers, nearby residences, schools, and in 2 or 3 areas to serve as control stations.

TABLE 3.18.1 (Continued) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Number of Samples and/or Sample and Sample Locationsd apin n an/o Srile__ an SmleLoatonaCollection Freguencya Type and Frequency Analyses

3.

WATERBORNE

a. Ocean 4 Locations At ie+ once per month and Gamma isotopic analysis of each compositedf quarterly monthly sample.

Tritium analysis of composite sample at least once per 92 days.

b. Drinking 2 Locations Monthly at each location.

Gamma isotopic and tritium analyses of each sample.

c. Sediment 4 Locations At least once per 184 days.

Gamma isotopic analysis of each from sample. Shorelaimne

d. Ocean 5 Locations At least once per 184 days.

Gamma isotopic analysis of each Bottom sample. Sediments

TABLE 3.18.1 (Continued) RADIOLOGICAL ENVIRONMENTAL-MONITORING PROGRAM Exposure Pathway Number of Samples and/or Sample and Sample Locationsa Smln n an/o aml adSapl octonaCollection Freguencya Type and -Frequency Analyses

4. INGESTION

a. Nonmigratory 3 Locations One sample in season, or at Gamma isotopic analysis on Marine least once per 184 days if not edible portions.

Animals seasonal. One sample of each of the following species:

1. Fish-2 adult species such as perch. or sheepshead.

2. Crustaceae-such as crab or lobster.

3. Mollusks-such as limpets or seahares.

b. Local Crops 2 Locations Representative vegetables, Gamma isotopic analysis on normally 1 leafy and 1 fleshy edible portions semiannually collected at harvest time. At an 1-131 analysis for leafy least 2 vegetables collected crops.

semiannually from each location.

5.

LOCAL VEGETAION 3 Locations Monthly Monthly gamma isotopic analysis.

TABLE 3.18.1 (Continued) TABLE NOTATION

a. Sample locations are indicated in the ODCM.

b. Gamma isotopic analysis mens the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

c. The purpose of this sample is to obtain background information.

If it is not practical to establish control locations in accordance with the distance and wind direction criteria, other sites which provide valid background data may be substituted.

d. Canisters for the collection of radioiodine in air are subject to channeling.

These devices should be carefully checked before operation in the field or several should be mounted in series to prevent loss of iodine. e.' Regulatory Guide 4.13 provides minimum acceptable performance criteria for thermoluminescence dosimetry (TLD) systems used for envi ronmfental monitoring. One or more instru ments, such as a pressurized chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. For the purpose of this table, a thermoluminescent dosimeter may be considered to be one phosphor and two or more phosphors in a packet may be considered as two or more dosimeters. Film badges should not be used for measuring direct radi ati on.

f.

Composite samples should be collected with equipment (or equivalent) which is capable of collecting an aliquot at time intervals which are very short (e.g., hourly) relative to the compositing period (e.g., monthly).

g.

2 samples should be from the nearest offsite locations of highest calculated annual average ground level D/Q. The third sample should be of similar vegetation characteristics and grown 15-30 km distance in the least prevalent wind di rection.

-42 III) TABLE 3.18.2 RONEORTING LEVELS FOR RADIOACTIVITY Reporting Levels Airborne Water Particulate Ana lysi s ,or Gases (pCi/1) (pC/m3Marine Animals /2 x 1 0 4 ( a ) ( P C I / K g, w e t ) (0 a / C r o e t ) Mn-541 x 103 Fe-59 4 x 102 3 x 104 Co-5 8 1 x 103 1 x 104 Co-6 0 3 x 102 3 x 104 Zn-65 3 x 102 1 x 104 Nb-95 4 x 102 2 x 104 -131 2 0.9 Cs-134 30 10 1 x 102 Cs-137 50 201 x 1031x10 Ba-La-140 2 x 102 2 x 103 2 x 103 ()Fr drinkin (a) For drinking water samples* Thi s is 40 CFR Part 141 value.

-43 Specification: A. A land use census shall be conducted and shall identify the location of the nearest milk animal, the nearest residence and the nearest garden* of greater than 500 square feet.produGing fresh leafy vegetables in each of the 16 meteorological sectors within a distance of five miles. For elevated releases as defined in Regulatory Guide 1.111, Revision 1, July 1977, the land use census shall also identify the locations of all milk animals an all gardens of greater than 500 square feet producing fresh leafy vegetables in each of the 16 meteorological sectors within a distance of three miles. B. Action:

1. With a land-use census identifying a location(s) which yields a calculated dose or dose commitment greater than the values currently being calculated in Specification Brifr~4 in lieu of any-h r-purL required by S cification 6.9.,

repare and submi to th Commission with 30 days, pursuant Specif ation 6.9.3, a Spe al Report which ide fies the new loc ion(s). z

• Broad leaf vegetation sampling may be performed at the site boundary in the direction sector with the highest D/Q in lieu of the garden census.

- 44

2. With a land use census identifying a location(s) which yields a calculated dose or dose commitment via the same exposure pathway 20 percent greater than at a location from which samples are currently being obtained in accordance with Specification 3.18.1 in lieu 6f any other rport equired by Sp ifi ation

6..2, prepare d submi to the Cormm'ssion ithin 30 ays, pursua to Speci ication 6.9, aS ecial Report w *ch identifi s the new 1 cation The nw hall be add d to radiologi al environmental monitoring program within 30 days.

The sampling location, excluding the control station location, having the lowest calculated dose or dose commitment via the same exposure pathway may be deleted from this monitoring program after October 31, of the year in which this land use census was conducted.

3. The provisions of Specificatio 3.0.3 are not applicable.

Basis: This specification is provided to ensure 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. The best survey information

-45 from the door-to-door, aerial or consulting with local agricultural authorities shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 500 square feet provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were used, (1) that 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and (2) a vegetation yield of 2 kg/square meter. 3.18.3 Interlaboratory Comparison Program Applicability:- At all times Objective: To ensure laboratory analysis of radiological environmental monitoring samples is correct and accurate. Specification: A. Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program which has been approved by the Commission.

-46 B. Action:

1. 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.

2. The provisions of Specification 3.0.3 are not applicable.

Basis: The requirement for participation in an Interlabory 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 the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid. 0I

-47 3.19 Solid Radioactive Waste Applicability: At all times Objective: Specification: A. The solid radwaste system shall be used in accordance with a PROCESS CONTROL PROGRAM to process wet radioactive wastes to meet shipping and burial ground requirements. B. Action:

1.

With the provisions of the PROCESS CONTROL PROGRAM not satisfied suspend shipments of defectively processed or defectively packaged solid radioactive wastes from the site.

2. The provisions of Specification 3.0 and 6.9.2b(2) are not applicable.

Basis: This specification implements the requirements of 10 CFR Part 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50. The process parameters included in establishing the PROCESS CONTROL PROGRAM may include, but are not limited to waste type, waste pH, waste/liquid/ solifification agent/catalyst ratios, waste oil content, waste principal chemical constituents, mixing and curing times.

-48 4.1.2 Radioactive Liquid Effluent Instrumentation Applicability: As shown in Table 4.1.2.1 Objective: To specify the minimum frequency and type of surveillance to be applied to the radioactive liquid instrumentation. Specification: A. The setpoints shall be determined in accordance with procedures as described in the 00CM. B. Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL TEST operations at the frequencies shown in Table 4.1.2.1. Basis: 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 are calculated in accordance with NRC approved methods in the ODCM to ensure that the,alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20.

-49 TABLE 4.1.2.1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL SOURCE CHANNEL CHANNEL I N S T R U M E-T C H E C K C H E C K C A L I B R A T I O N T E S T

1. Gross Beta or Gamma Radioactivity Monitoring Providing Alarm and Automatic Isolation

a. Liquid Radwaste Effluents Line (R-1218)

D P R(3) Q(1)

b. Steam Generator Blowdown Effluent Line (R-1216)

D* M R(3) Q()

2. Gross Beta or Gamma Radioactivity Monitors Providing Alarm But Not Providing Automatic Termination of Release

a. Turbine Building Sumps Effluent Line (Oily Waste Sump Monitor) (R-2101*)

D M R(3) Q(2)

b. Component Cooling Water System (R-1217)

D M R(3) Q(2)

3. Flow Rate Monitors Liquid Radwaste Effluent Line D(4)

N/A R Q Sinstruntiation - Conformance with Technical Specifications will have to be determined fol lowing installation.

-50 TABLE 4.1.2.1 (Continued) TABLE NOTATION

• During releases via this pathway.

(1) The CHANNEL TEST also demonstrates the following:

1. Automatic isolation of this pathway and control room alarm annunciation occurs when the instrument indictes measures levels above the alarm/trip setpoint.

2. Local annunciation in the event of a circuit failure.

3.

Local annunciation when the instrument indicates a downscale failure.

4.

Control room alarm annunciation when the instrument controls are not set in the operate mode. (2) The CHANNEL TEST also demonstrates the following:

1. Control room alarm annunciation occurs when the instrument indicates measured levels above the alarm/trip setpoint.

2. Local annunciation in the event of a circuit failure.

3. Local annunciation when the instrument indicates a downscale failure.

4. Control room alarm annunciation when the instrument controls are not set in the operate mode.

-51 TABLE 4.1.2.1 (Continued) TABLE NOTATION (3) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with 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. (Operating plants may substitute previously established calibration procedures for this requirement.) (4) CHANNEL CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once daily on any day on which continuous, periodic, or batch releases are made.

-.52 4.1.3 Radioactive Gaseous Process and Effluent Monitoring Instrumentation Applicability: As shown in Table 4.1.3.1 Objective: To specify the minimum frequency and type of surveillance to be applied to the radioactive gaseous monitoring instrumentation. Specification: A. The setpoints shall be determined in accordance with procedures as described in the ODCM. B. Each radioactive gaseous process or effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL TEST operations at the frequencies shown in Table 4.1.3.1. Basis: The radoioactive 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 serpoints for these instruments are calculated in accordance with NRC approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20.

cA 7~L4-{p

3. £. c~

( 4rL~ A&a~e~) ~ /C/e4~c) 7 rWtJ A 6 ~ 4W t ~ 0 S

-53 TABLE 4.1.3.1 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS INSTRUMENT CHANNEL SOURCE CHANNEL CHANNEL CHECK CHECK CALIBRATION TEST

1. Stack Monitoring System

a. Gross Activity Monitor (R-1214)

P P R(2) Q(1) b.. Noble Gas Activity Monitor D M R(2) (R-1219, 1223*) Q(1)

c.

Iodine Sampler Cartridge W N/A N/A N/A

d.

Particulate Sampler Filter W N/A N/A N/A P

e.

Stack Fan Flow Indication D N/A Q [Kf. Sampler Flow Rate Measuring Device W N/A SA Q New instrumentation - Conformance with Technical Specifications will have to be determined following installation. Al' 44i Gl ~ ~ 6-0 M 12 -2i

) -54 TABLE 4.1.3.1 (Continued) TABLE NOTATION

• During releases via this pathway.

(1) The CHANNEL TEST also demonstrates the following:**

1. Automatic isolation of this pathway and control room alarm annunciation occurs when the instrument indicates measured levels above the alarm/trip setpoint.

2. Local annunciation in the event of a circuit failure.

3. Local annunciation when the instrument indicates a downscale failure.

4.

Control room alarm annunciation when tne instrument controls are not set in the operate mode. (2) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with 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. (Operating plants may substitute previously established calibration procedures for this requirement.)

-55 In Appendix A, Specification 4.5, Radioactive Liquid Waste Release, will be replaced by the following: 4.5 RADIOACTIVE LIQUID EFFLUENTS 4.5.1 Liquid Effluents Concentration Applicability: At all times Objective: To verify that discharge of radioactive liquid material to unrestricted areas is maintained below 10 CFR 20 limits. Specification: A. Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analyses program of lable 4.5.1.1. B. The results of the radioactivity analyses shall be used in accordance with the methods in.the 00CM to assure that the concentrations at the point of release are maintained within the limits of Specification 3.15.1. 0J

-56 Basis: This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas 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 not 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 Part 20.106(e) to the population.

-57 TABLE 4.5.1.1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum of Detection Sampling Analysis Type of Activity (LLD) Liquid Release Type Frequency Frequency Analysis (uCi/ml)a P A. Batch Waste Each Batch Each Batch Principal Gamma 5 x 10-7 Release Tanksb Emittersc (1) Holdup Tanks 1-131 1 x 10-6 (2) Monitor Tanks P One Batch/M M Dissolved and 1 x 10-5 trained Gase P b"'W.. Each Batch M H-3 1 x 10-5 Composited 0 Gross Alpha 1 x 10-7 Each Batch Q Sr-89, Sr-90 5 x 10-8 Composited Fe-55 1 x 10-6 Ce h 1; tj0. i R~eVewse 3 x W W B. en o Grab Sample Compositef Principal Gamma 5 x 10-7 Blow and Emittersc Was Sum) ( e,,erI..v Gel 1-131 1 x 10-6 0, M Grab Sample M Dissolved and 1 x 10-5 3xtrained Gasq, 3 x W Grab Sample W H-3 1 x 10 3 x W Grab Sample Compositef Gross Alpha 1 x 10-7 3 x W Grab Sample Q Sr-89, Sr-90 5 x 10-8 Composite Fe-55 1 x 10-5

-58 TABLE 4.5.1.1 (Continued) TABLE NOTATION

a. The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count (above system background) that will be detected with 95% probability with only 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 s b ELD *E V

• 2.22 x 10
• Y exp(-

t)

where, LLD is the "a priori" lower limit of detection as defined above (as microcuries 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 disintegration),

-59 TABLE 4.5.1.1 (Continued) TABLE NOTATION V is the sample size (in units of mass or volume), 2.22 is the number of disintegrations per minute per picocurie, Y is the fractional radiochemical yield (when applicable), is the radioactive decay constant for the particular radionuclide, t for plant effluents is the elapsed time between the midpoint of sample collection and time of counting, Typical values of E, V, Y and t should be used in the calculation. 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 batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed to assure representative sampling.

-60 TABLE 4.5.1.1 (Continued) TABLE NOTATION

c. The principal gamma emitters for which the LLD specification will-apply are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. This list does not mean that only these nuclides are to be detected and reported.

Other peaks that are measurable and identifiable, together with the above nuclides, shall also be identified and reported.

d. A composite sample is one which results in a specimen that is representative of the liquids released.

e. A continuous release is the discharge of liquid wastes of a nondiscrete volume, e.g., from a volume of a system that has an input flow during the continuous release.

f. Prior to analyses, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluent release.

-61 4.5.2 Liquid Effluent Dose Applicability: At all times Objective: To verify that doses due to the release of radioactive liquid effluents are as low as reasonably achievable. Specification: Cumulative dose contributions from liquid effluents shall be determined in accordance with the Offsite Dose Calculation Manual (00CM) at least once per 31 days. Basis: This specification is provided to implement the requirements of Section III.A of Appendix I, 10 CFR Part 50. The dose calculations in the ODCM implement the requirement 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.

-62 4.5.3 Liquid Waste Treatment Applicability: At all times Objective: To verify the operability and potential use of the liquid radwaste treatment system. Specification: Doses due to liquid releases shall be projected at least once per 31 days in accordance with the ODCM. Basis: The OPERABILITY of the liquid radwaste treatment system ensures that this sytem will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirements that the appropriate portions of tnis system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR Part 50.36a and design objective Section II.0 of Appendix I to 10 CFR Part 50. The specified limits governing the use of ap4rtprriate porLions of one liquid radwaste treatment system were specified as a suitable fraction of the guide set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

-63 Appendix A, Specification 4.6, Radioactive Gaseous Waste Release, will be replaced by the following: 4.6 RADIOACTIVE GASEOUS EFFLUENTS 4.6.1 Dose Rate Applicability: At all times Objective: To verify the dose rate due to the discharge of radioactive gaseous effluents is maintained within 10 CFR 20 limits. Specification: A. The dose rate due to noble gases in gaseous effluents shall be determined to be within the above limits in accordance with the methods and procedures of the ODCM. B. The dose rate due to iodine-131 tritium and all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents shall be determined to be within the above limits in accordance with the methods and procedures of the ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 4.6.1.1.

-64 Basis: This specification is provided to ensure that the dose rate at anytime at the exclusion area boundary from gaseous effluents will be within the annual dose limits of 10 CFR Part 20 for unrestricted areas. 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 in an unrestricted area, either within or outside the exclusion area boundary, to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b)). For individuals who may at times be within the exclusion area boundary, the occupancy of the individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the exclusion area 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 exclusion area boundary to < 500 mrem/year to the total body or to < 3000 mrem/year to the skin. These release rate no us also restrict, at all times, the corresponding tnyrcid dose rate above background to an infant via the cow-milk-infant pathway to < 1500 mrem/year for the nearest cow to the plant.

-65 TABLE 4.6.1.1 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum of Detection Sampling Ana lysi s Type of Activity (LLD) 64: Release Type Frequency Frequency Analysis (uCi/m L)a P P A. Waste Gas Each Tank Each Tank Principal Gamma 1 x 10-4 Storage Tank Grab Emittersb Sample P r B. Containment Each Purgec Each Purgec Principal Gamma 1 x 10-4 Purge Grab Emittersb Sample H-3 I x 10-6 C. Plant Stack Continuousf W9 1-131 1 x 10-12 Charcoal Sample Continuousf W9 Principal Gamma 1 X 10-11 Particulate Emittersb Sample (1-131, Others) Continuousf M Gross Alpha 1 x 10-11 Composite Particulate Sample Continuous U Sr-89, Sr-90 1 X 10-11 Composite Particulate Sample Continuousf Noble Gas Noble Gases I X 10-6 Monitor Gross Beta or Gamma ( 4-f-A Sa~I, 143 /0

• -66 TABLE 4.6.1.1 (Continued)

TABLE NOTATION

a. The LLO is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count (above system background) that will be detected with 95% probability with only 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 10 Y exp(-

t)

where, LLD is the "a priori" lower limit of detection as defined above (as microcuries per unit mass or volume),

s 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 disintegration),

-67 TABLE 4.6.1.1 (Continued) TABLE NOTATION V is the sample size (in units of mass or volume), 2.22 is the number of disintegrations per minute per picocurie, Y is the fractional radiochemical yield (when applicable), is the radioactive decay constant for the particular radionuclide, t for plant effluents is the elapsed time between the midpoint of sample collection and time of counting, Typical values of E, V, Y and At should be used in the calculation. 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. 'he prircipal g.amma emitters for which the LLD specification applies are clusively the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135 Xe-135m and Xe-138 for gaseous emissions and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions. 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.

-68 TABLE 4.6.1.1 (Continued) TABLE NOTATION

c. Sampling and analysis shall also be performed following shutdown, startup, or a THERMAL POWER ehaTrgrexceeding 15 percent of RATED THERMAL POWER within one hour unless (1) analysis shows the DOSE EQUIVALENT 1-131 concentration in the primary coolant has not increased more than a factor of 3; and (2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3.

d. Tritium grab samples shall be taken at least once per 24 hours when the refueling canal is flooded.

e. Tritium grab samples shall be taken at least once per 7 days from the ventilation exhaust from the spent fuel pool area, whenever spent fuel is in the spent fuel pool.

f. The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specifications 3.16.1, 3.16.2 and 3.16.3.

24 -7 44 0if 7L~~T1 A1.$ 4 ~ 4~4~4~JZ Al 4 01-X 4 4 4-I-L L L) 4','

-69 4.6.2 Dose Noble Gases Applicability: At all times Objective: To verify the dose due to noble gases in radioactive gaseous effluents is maintained as low as is reasonably achievable. Specification: Cumulative dose contributions for noble gases for the current calendar quarter and current calendar year shall be determined in accordance with the 00CM at least once per 31 days. Basis: This specification implements the requirements in Section III.A of Appendix I, 10 CFR Part 50, that conform with the guides of Appendix I to 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 00CM equations provided for determining the air doses at the exclusion area boundary will be based upon the historical average atmospheric conditions.

-70 4.6.3 Dose, Iodine-131, Tritium and Radionuclides Applicability: At all times Objective: To verify the dose due to radiolodines,,radioactive material in particulate form and radionuclides other than noble gases is maintained as low as is reasonably achievable. Specification: Cumulative dose contributions for the current calendar quarter and current calendar year for iodine-131, tritium and radionuclides in particulate form with half-lives greater than 8 days shall be determined in accordance with the ODCM at 0 least once per 31 days. Basis: Tnis specification implements the requirements in Section III.A of Appendix I, 1U CFR Part 50, 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 appropriate pathways is unlikely to be substantially underestimated. The ODCM equations provided for determining the actual doses are based upon the historical average atmospheric conditions. The release rate specifications for radioiodines, radioactive material in particulate form and radionuclides other than

-71 noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area. 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. 4.6.4 Gaseous Radwaste Trea-tment Applicability: At all times Objective: To verify the operability and potential use of the gaseous radwaste treatment system and the ventilation exhaust treatment system. Specification: Doses due to gaseous releases from A te-s t?"shall be projected at least once per 31 days in accordance with the ODCM. Basis: The OPERABILITY of the gaseous radwaste treatment system and the ventilation exhaust treatment systems ensures that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment. The

-72 requirement that the appropriate portions of these systems be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR Part 50.36a and design objective Section II.D of Appendix I to 10 CFR.Part 50. 4.6.5 Gas Storage Tanks Applicability: At all times Objective: To verify the quantity of radioactive material contained within the gas storage tanks. Specification: The quantity of radioactive material contained in each gas storage tank shall be determined to be within the limit specified in Specification 3.16.5 at least once per 24 hours when radioactive materials are..being added to the tank. Basis: Restricting the quantity of radioactivity contained in each gas storage tank provildes assurance that in the event of an uncontrolled release of the tanks contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem. This is consistent with Standard Review Plan 15.7.1, "Waste Gas System Failure."

-73 4.6.6 Explosive Gas Mixture Applicability: At all times Objective: Limit the amount of explosive gases contained in the gas storage tanks. Specification: The concentrations of hydrogen and/or oxygen in the waste gas holdup system shall be determined to be within the limits specified.in Specification 3.16.6 by berab samples of the waste gas holdup system contents at the discharge of the mpr Basis: This specification is provided to ensure that the concentration of potentidlly explosive gas mixture contained in the waste gas holdup system is maintained below the flammability limits of hydrogen and oxygen. Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the Eireimens of Ueneral Design Criterion 60 of Appendix Ato 10 CFR Part 50. To Appendix A Specifications 4.17, Dose, and 4.18, Radiological Environmental Monitoring, will be added:

-74 4.17 Dose Applicability: At all times Objective: To verify the doses due to liquid and gaseous effluents are maintained as low as is reasonably achievable. Specification: Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with Specifications 3.15.2.A, 3.16.2.A and 3.16.3.A and in accordance with the Offsite Dose Calculation Manual (ODCM).

-75 Basis: This specification is provided to meet the reporting requirements of 40 CFR 190. Solid Radioactive Waste Applicability: At all times Objective: Speci fi cati on: Basis:

-76 4.18 RADIOLOGICAL ENVIRONMENTAL MONITORING 4.18.1 Monitoring Program Applicability: At all times Objective: Ensure required actions of the radiological monitoring program are being performed. Specification: The radiological environmental monitoring samples shall be collected pursuant to Table 3.18.1 from the locations given in the table and figure in the ODCM and shall be analyzed pursuant to the requirements of Tables 3.18.1 and 4.18.1. Basis: The radiological monitoring program required by this specification provides 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 the station operation. This monitoring program thereby supplements the ra 1gioloical effluent Ionitoring prograIi by verifying tna tie 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. The initially specified monitoring program

-77 will be effective for at least the first three years of commercial operation. Following this period, program changes may be initiated based on the operational experience. The detection capabilities required by Table 4.18.1 are state-of-the-art for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as a a priori (before the fact) limit representing the capability of a measurement system and not as a posteriori (after the fact) limit for a particular measurement. Analyses shall be performed in such a manner that the stated LL~s will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interferring 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.

-78 TABLE 4.18.1 MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION LLD)a,c Airborne Particulate e Water or Gas Marine Animals a Analysis (pCi/1) (pCi/m3) (pi/kg, wet) (pCi/kg, wet) (pCi/kg, dry gross beta 4 1 x 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 lb 7 x 10-2 60 Cs-134 15 5 x 10-2 130 60 150 Cs-137 18 6 x 10-2 150 80 180 Ba-140 60 La-140 15

-79 TABLE 4.18.1 (Continued) TABLE NOTATION

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): 4.66 s LLD = 2.22 10. Y - exp(- t) where: LLD is the "a priori" lower limit of detection as defined above (as picocurie per unit mas 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),

80 TABLE 4.18.1 (Continued) TABLE NOTATION 2.22 is the number of transformation per minute per picocurie, Y is the fractional radiochemical yield (when applicable), is the radioactive decay constant for the particular radionuclide, z5 t is the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not plant effluent samples). The value of sb used in the calculation of the LLD for a detection system shall be based on the actual observed variance of the background counting rate or of the counting rate of the blank samples (as appropriate) rather than on an unverified theoretically predicted variance. In calculating the LLD for a radionuclide determined by gamma-ray spectrometry, the background shall include the-typical contributions of other radionuclides normally present in the samples (e.g., potassium -40 in m ?ik saIples). Typical values of E, V, Y rd t shall be used in the calculations.

TABLE 4.18.1 (Continued) TABLE NOTATION It should be recognized that the LLD is defined as an a priori (before the fact) limit representing capability of a measurement system and not as a posteriori (after the fact) limit for a particular measurement.*

b. LLD for drinking water.

c. Other peaks which are measurable and identifiable, together with the radionuclides in Table 4.12-1, shall be identified and reported.

• For a more compite discussion of the LLD, and other detection limits, see the following:

(1) HASL Procedures Manual, HASL-300 (revised annually). (2) Curries, L. A., "Limits Tor Qualitative Detection and Quantitative Determination - Application to Radiochemistry" Anal. Chem. 40, 586-93 (1968). (3) Hartwell, J. K., "Detection Limits for Radioisotopic Counting Techniques," Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).

-82 4.18.2 Land Use Census Applicability: At all times Objective: Perform the land use census to ensure the monitoring program is appropriate for the surrounding areas. Specification: The land use census shall be conducted at least once per 12 months between the date of June 1 and October 1 using that information which will provide the best results, such as by a door-to-door survey, aerial survey, or by consulting local agriculture authorities. Basis: This specification is provided to ensure 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. The best survey information from the door-to-door, aerial or consulting with local agricultural authorities shall beiused. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50.

-83 4.18.3 Interlaboratory Comparison Program Applicability: At all times Objective: To ensure laboratory analysis of radiological environmental monitoring samples is correct and accurate. Specification: A summary of the results obtained as part of the above required Interlaboratory Comparison Program and in accordance with the ODCM shall be included in the Annual Radiological Environmental Operating Report. Basis: The requirement for participation in an 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 the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid.

-84 4.19 Solid Radioactive Waste Applicability: At all times Objective: Specification: THE PROCESS CONTROL PROGRAM shall be used to verify the SOLIDIFICATION of at least one representative test specimen from at least every tenth batch of each type of wet radioactive waste (e.g., filter sludges, spent resins, evaporator bottoms, boric acid solutions, and sodium sulfate solutions).

a. If any test specimen fails to verify SOLIDIFICATION, the SOLIDIFICATION of the batch under test shall be suspended until such time as additional test specimens can be obtained, alternative SOLIDIFICATION parameters can be determined in accordance with the.PROCESS CONTROL PROGRAM, and a subsequent test verifies SOLIDIFICATION.

SOLIDIFICATION of the batch may then be resumed using the alternative SOLIDIFICATION parameters determined by the PROCESS CONTROL PROGRAM.

-85

b. If the initial test specimen from a batch of waste fails to verify SOLIDIFICATION, the PROCESS CONTROL PROGRAM shall provide for the collection and testing of representative test specimens from each consecutive batch of the same type of wet waste until at least 3 consecutive

.initial test specimens demonstrate SOLIDIFICATION. The PROCESS CONTROL PROGRAM shall be modified as required, as provided in Specification 0i., o assure SOLIDIFICATION of subsequent batches of waste.--, 6 2-Basis: This specification implements the requirements of 10 CFR Part 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50. The process parameters included in establishing the PROCESS CONTROL PROGRAM may include, but are not limited to waste type, waste pH, waste/liquid/ solidification agent/catalyst ratios, waste oil content, waste principal chemical constituents, mixing and curing times. To Appendix A, Section 6.5.1.6, the following will be added:

j.

rkeview of evtry uiplanned onsite release of raioactive material to the environs including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Nuclear Audit Review Committee.

-86

k.

Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL. To Appendix A, Section 6.5.2.8, the following will be added:

k. The radiological environmental monitoring program and the results thereof at least once per 12 months.

1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

In. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.

0. The performance of activities required by the Quality Assurance Program to meet provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

Appendix A, Section 6.8.1, will be revised as follows: WriLten prucedurzs and adi nistrative policies shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.2 and 5.3 of ANSI N18.7-1976, Administrative Controls for Nuclear Power Plants; Appendix "A" of USNRC Regulatory Guide 1.33, Rev. 1, Quality Assurance Program Requirements (Operation); Paragraph

-87 2.2.1 of Fire Protection Program Review, BTP APCSB 9.5-1, San Onofre Nuclear Generating Station, Unit 1, March 1977; the Offsite Dose Calculation Manual; the PROCESS CONTROL PROGRAM; and Quality Assurance Program for effluent and environmental monitoring using the guidance in Regulatory Guide 1.21 Revision 1 June 1974 and Regulatory Guide 4.1 Revision 1 April 1975; except as provided in 6.8.2 and 6.8.3 below. Wi kLe

d. Annual Radiological Environmental Operating Report*

Routine radiological environmental operating reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year. The annual radiological environmental operating reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with preoperational studies, operational controls (as appropriate), and-previous environmental surveillance reports A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

-88 and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of land use censuses required by Specification 3.18.2. If harmful effects or evidence of irreversible damage are detected by the monitoring, the report shall provide an analysis of the problem and a planned course of action to alleviate the problem. The annual radiological environmental operating reports shall include summarized and tabulated results in the format of Regulatory Guide 4.8, December 1975 of all radiological environmental samples taken during the report period. 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 as soon as possible in a supplementary report. The reports shall also include the following: a summary description of the radiological environmental monitoring program; a map of all sampling locations keyed to a table giving distances and directions from one reactor; and the results of licensee participation in the Interlaboratory Comparison Program, required by Specification 3.18.3.

e. Semiannual Radioactive Effluent Release Report*

Routine radioactive effluent release reports covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 day.s after January 1 and July 1 of each year.

-89 The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Reg ulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix 8 thereof. The radioactive effluent release report to be submitted 60 days after January 1 of each year shall include an annual summary of hourly meteorological data collected over the~previous year. This annual summary may be either in the form of an hour-by-hour listing of wind speed, wind direction, and atmospheric stability, and precipitation (if measured) on magnetic tape, or in the form of 4 4-b444ty. This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. This same report shall also include an assessment of the radiation doses.from radioactive liquid and gaseous effluents to Members of the public due to their activities inside the site boundary C/YP/S during the report period. All assumptions used in making these assessmens 1'.e., specific activity, exposure time and location) shall :e included in these reports. The meteorological conditions concurrent with the time of release-of radioactive materials in gaseous effluents (as determined by sampling frequency and measurement) shall be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the OFFSITE DOSE CALCULATION MANUAL (00CM). 4CX~L i RLA 0 Al-ZA

-90 The radioactive effluent release report to be submitted 60 days after January 1 of each year shall also include an assessment of radiation doses to the likely most exposed member of the public from reactor releases and other nearby uranium fuel cycle sources (including doses from primary effluent pathways and direct radiation) for the previous l uO -wmftt.hs to show conformance with 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operation. Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev. 1. The radioactive effluents release shall include the following information for each type of solid waste shipped offsite during the report period:

a. Container volume,

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

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

d. Type of waste (e.g.

spent resin, compacted dry waste, evaporator bottom),

e.

Type of container (e.g., LSA, Type A, Type B, Large Quantity), and

f. Solidification agent (e.g., cement, urea formaldehyde).

-91 The radioactive effluent release reports shall include unplanned releases C 4 from the site to unrestrictedareas of radioactive materials in gaseous and liquid effluents on a quarterly basis. The radioactive effluent release,reports shall include any changes to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE DOSE CALCULATION MANUAL (ODCM) made during the reporting period. To Appendix A, Section 6.9.2a., the following events will be added:

10. Offsite releases of radioactive materials in liquid and gaseous effluents that exceed the limits of Specification 3.15.1 and 3.16.1.

11. Exceeding the limits in Specification 3.16.5 for the storage of radioactive materials in the listed tanks.

The written followup report shall include a schedule and a description of activities planned and/or taken to reduce the contents to within the specified limits. To Appendix A, Secton 6.9.2.b, the following events will be added:

5.

An unp lqnned offsite release of (1) more than 1 curie of radioactive material in liquid effluents, (2) more than 150 curies of noble gas in gaseous effluents, or (3) more than 0.05 curies of radioiodine in gaseous effluents. The report of an unplanned offsite release or radioactive material shall include the following information:

-92

1. A description of the event and equipment involved.

2. Cause(s) for the unplanned release.

3. Actions taken to prevent recurrence.

4. Consequences of the unplanned release.

To Appendix A, Section 6.9.3, the following will be added:

d. Radiological Effluents (Technical Specifications 3.15.2, 3.15.3, 3.16.2, 3.16.3, 3.16.4 and 3.17).

e. Radiological Environmental Monitoring (Technical Specifications 3.18.1 and 3.18.2).

To Appendix A, the following Sections, 6.12, Process Control Program, 6.13, Offsite Dose Calcul.ation Manual, and 6.14, Major Changes toRadioactive Waste Treatment Systems, will be added: /0( -e J A vJ~ 6.12 PROCESS CONTROL PROGRAM (PCP) 6.12.1 The PCP shall be approved by the Commission prior to implementation. 6.12.2 Licensee initiated changes to the PCP:

1. Shall be submitted to the Commision in the Semiannual Radioactive Effluent Release Report for the period in which the change(s) was made. This submittal shall contain:

a. Sufficiently detailed information to totally support the rationale for the change without benefit of additional or.supplemental information:

b. A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and

c. Documentation of the fact that the change has been reviewed and found acceptable by the OSRC.

2.

Shall become effective upon review and acceptance by the OSRC.

-94 6.13 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6.13.1 The ODCM shall be approved by the Commission prior to implementation. 6.13.2 Licensee initiated changes to the 00CM:

1. Shall be submitted to the Commission in the SemiAnnual Radioactive Effluent Release Report for the perid in which the change(s) was made effective. This submittal shall contain.

a. Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information.

Information submitted should consist of a package of those pages of the ODCM to be changed with each page numbered and provided with an approval and date box, together with appropriate analyses or evaluations justifying the change(s);

b.

A.determination that the change will not reduce the accu.racy or reliability of dose calculations or setpoint determinations; and

c. Documnentation of the fact that the change has been revieied and found acceptable by the OSRC.

2. Shall become effective upon review and acceptance by the OSRC.

-95 W 6.14 MAJOR CHANGES.TO RADIOACTIVE WASTE TREATMENT SYSTEMS (Liquid, Gaseous and solid) 6.14.1 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous and solid):

1. Shall be reported to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the OSRC. The discussion of each change shall contain:

a. A summary of the evaluation that led to the determination-that the change could be made in accordance with 10 CFR 50.59;

b. Sufficient detailed information to totally support the reason for the cnange without benefit of additional or supplemental information;

c. A detailed description of the equipment, components and processes involved and the interfaces with other plant systems; U.

An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto; F S Fr '

-96

e. An evaluation of the change which shows the expected maximum exposures to an individual in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto;

f. A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changesare to be made;

g. An estimate of the exposure to plant operating personnel as a result of the change; and

h. Documentation of the fact that the change was reviewed and found acceptable by the OSRC.

2. Shall.become effective upon review and acceptance by the OSRC.

Appendix B, Technical Specification 3.2, Radiological Environmental, Monitoring, will be deleted. Appendix B, Technical Specification 5.6.1, Routine Reports - Annual, Secton 5.6.1.c, Radiological Environmental Monitoring, will be deleted. Appendix B, Technical Specification 5.6.2, Routine Reports - Semiannual, will be deleted. ACLlorens:4846}}