ML15113A079

Safety Evaluation Supporting Amends 125,125 & 126 to License DPR-38,DPR-47 & DPR-55,respectively

ML15113A079
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Site:	Oconee
Issue date:	01/16/1984
From:	Office of Nuclear Reactor Regulation
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NUDOCS 8402030065
Download: ML15113A079 (41)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE-OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 125TO FACILITY OPERATING LICENSE NO. DPR-38 AMENOMENT NO. 125TO FACILITY OPERATING LICENSE NO.

DPR-47 AMENDMENT NO. 122TO FACILITY OPERATING LICENSE NO. DPR-55 DUKE POWER COMPANY OCONEE NUCLEAR STATION, UNITS NOS. 1, 2 AND 3 DOCKETS NOS. 50-269, 50-270 AND 50-287

1.0 INTRODUCTION

To comply with Section V of Appendix I of 10 CFR Part 50, the Duke Power Company.has filed with the Commission plans and proposed tech ial -specificatons-developed for the purpose of keeping releases of radioactive materials to unrestricted areas during normal operations, including expected operational occurrences, as low as is reasonably achievable.

The Duke Power Company filed this information with the Commission by letter dated February 9, 1983, which requested changes to the Technical Specifications appended to Facility Operating License Nos.

DPR-38, DPR-47, and DPR-55 for Oconee Nuclear Station. Units Nos, 1,-2 and 3. The proposed technical specifications update those portions of the technical specifications addressing radioactive waste management and make them consistent with the current, NRC staff positions as expressed in NUREG-0472.

These revised technical specifications would reasonably assure compliance, -in radioactive waste management, with the provisions of 10 CFR Part 50.36a, as supplemented by Appendix I to 10 CFR Part 50, with 10 CFR Parts 20.105(c), 106(g), and 405(c); with 10 CFR Part 50, Appendix A, General Design Criteria 60, 63, and 64; and with 10 CFR Part 50, Appendix B.

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2.0 BACKGROUND

AND DISCUSSION 2.1 Regulations 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities", Section 50.36a, "Technical Specifications on Effluents from Nuclear, Power Reactors", provides that each license authorizing operation of a nuclear power reactor will include technical specifications that (1) require compliance with applicable provisions of Part 20.106, "Radioactivity in Effluents to Unrestricted Areas"; (2) require that operating.procedures developed for the control of effluents be established and followed; (3) require that equipment installed in the radioactive waste system be maintained-and used; and (4) require the periodic submission.of reports to the NRC specifying the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents, any quantities of radioactive materials released that are significantly above desi-gn objectives, and such other information as may be required by the Commission to estimate maximum potential radiation dose to the public resulting from the effluent releases.

10 CFR Part 20, "Standards for Protection Against Radiation," paragraphs 20.105(c),.20.106(g), and 20.405(c), require that nuclear power plant and other licensees comply with 40 CFR Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations" and submit reports to the NRC when the 40 CFR Part 190 limits have been or may be exceeded.

-3 10 CFR Part 50, Appendix A - General Design Criteria for Nuclear Power Plants, contains Criterion 60, Control of releases of radioactive materials to the environment; Criterion 63, Monitoring fuel and waste storage; and Criterion 64, Monitoring radioactivity releases.

Criterion 60 requires that the nuclear power unit design include means to control suitably the release of radioactive materials in gaseous and liquid.

effluents and to handle radioactive solid, wastes produced during normal reactor operation, including anticipated operational occurrences.

Criterion 63 requires that appropriate systems be provided in radioactive waste systems and associated handling areas to detect conditions that may result in excessive radiation levels and to initiate appropriate safety actions. Criterion 64 requires that means be provided for monitoring effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences and postulated accidents.

10 CFR Part 50, Appendix B, establishes quality assurance requirements for nuclear power plants.

10 CFR Part 50, Appendix I, Section IV, provides guides on Technical Specifications for limiting conditions for operation for light-water cooled nuclear power reactors licensed under 10 CFR Part 50.

I*

-4 2.2 Standard Radiological Effluent Technical Specifications NUREG-0472 provides radiological effluent technical specifications for pressurized water reactors which the NRC staff finds to be an acceptable standard for licensing actions. Further clarification of these accept able methods-is provided in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants."

NUREG-0133 describes methods found acceptable to the staff of the NRC for the cal culation of certain key values required in the preparation of proposed radiological effluent technical specifications for 1 i ght-water-cooled nuclear power plants.. NUREG-0133 also provides guidance to licensees in preparing requests for changes to existing radiological effluent technical specifications for operating reactors.

It also describes.

current staff positions on the methodology for estimating radiation exposure due to the release of radioactive materials in effluents and on the administrative control of radioactive waste treatment sytems.

The. above NUREG documents address all of the radiological effluent technical specifications needed to assure compliance with the guidance and requirements provided by the regulations previously cited.

However, alternative approaches to the preparation of radiological effluent technical specifications and alternative radiological effluent technical specifications may be acceptable if the staff determines that the alternatives are in compliance with the regulations and with the intent of the regulatory guidance.

-5 The standard radiological effluent technical specifications can be grouped under the following categories:

(1) Instrumentation (2) Radioactive effluents (3) Radiological environmental monitoring (4) Design features.

(5) Administrative controls.

Each of the specifications under the first three categories is comprised of two parts: the limiting condition for operation and the surveillance requirements.

The limiting condition for operation provides a statement of the limiting condition, the times when it is applicable, and the actions to be taken in the event that the limiting condition is not met.

In general, the specifications established to assure compliance with 10 CFR Part 20 standards provide, in the event the limiting conditions of operation are exceeded, that without delay conditions are restored to within the limiting conditions. Otherwise, the facility is required to effect approved shutdown procedures. In general, the specifications established to assure compliance with 10 CFR Part 50 provide, in the event the limiting conditions of operation are exceeded, that within specified times corrective actions are to be taken, alternative means of operation are to be employed, and certain reports are to be submitted to the NRC describing these conditions and actions.

-6 The specifications concerning design features and administrative controls contain no limiting conditions of operation or surveillance requirements.

Table 1 indicates the standard radiological effluent technical specifications that are needed to assure compliance with the particular provisions of the regulations described in Section 1.0.

3.0 EVALUATION The enclosed report (TER-C5506-103/104/105) was prepared for us by Franklin Research Center (FRC) as part of our technical assistance con tract program. Their report provides their technical evaluation of the compliance of the Licensee's. submittal with NRC provided criteria.

The NRC staff has reviewed this TER and agrees with the evaluation.

In addition, as a result of the August 18-19, 1982 meeting with Duke Power

Company, FRC, and the NRC staff, the issue of explosive gas limitations and monitoring was deferred and will be handled as a separate issue following completion of the ongoing Duke and NRC studies of system requirements.

Pending completion of these studies the licensee is required, and has committed via discussions on January 5, 1984, to submit a proposed technical specification for NRC review addressing explosive gas limitations and monitoring within 90 days of receipt of the RETS package addressed herein.

To date the engineering study portion of Duke's Waste Gas Study has been completed and several options regarding proposed modifications are being evaluated.

The Oconee waste gas system presently operates with a hydrogen.gas concentration at or below 2%

and a presently existing program of monitoring and administrative

Table 1. Relation Between Provisions of the Regulations and the Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors and Boiling Water Reactors Standard Radiological Effluent Technical Specifications Instru-Radioactive Effluents nenta-Gaseous Rad. Envir.

Design Administrative Control tion iqui PWR/8BRWR BWR Monitoring features Cn Ln 0

Indicate the specifications that are needed o 5 et s to assure compliance with the identified a

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50.36a Technical specifications on effluents from nuclear power reactors Remain within limits of § 20.1060 S

Establish an r

follow procedures to control effluents Maintain and use radioactive waste system a

(0)S(@0 equipment Submit reports, semi-annual and other 0

• @4116@@SS661S@S@0 0 0_

H§ 26.105(c). 20.106(g), 20.405(c) Compliance with 5

40 CFR 190 Part 50 Appendix A - General Design Criteria Criterion 60- Control of releases of radioactive 0bc e(

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( rmaterials to the environment Criterion 61 Fuel storage and handling and radioactivity control Criterion 63 - Monitoring fuel and waste storage 0 0 Criterion 64-Monitoring radioactivity releases AR"_)

()

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Part 50 Appendix B - Quality Assurance Criteria

__g

_ g Part 50 Appendix I - Guides to Meet "As Low As Is Reasonably Achievable (ALARA)"

Maintain releases within design objectives Establish sureillance & monitoring program to provide data on:

(1) quantities of rad. mat is. in effluents0 0 (2) radiation & rad. matis. in the environment 01 0

(3) changes in use of unrestricted areas0 Exert best efforts to keep releases "ALARA"

@5 0

0 00 Submit report if calculated doses exceed the design objective Dem ronstrate conform. to des. obp b catc.9roced.

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-8 controls imposes an allowable upper limit of 3% for hydrogen.

If the 3% limit is exceeded (determined by analysis), the licensee activates a nitrogen overblanket feature of the waste gas system to prevent the hydrogen concentration from reaching the 4% regulatory limit.

Not withstanding the above controls, if a postulated explosion of the waste gas system were to occur the total contribution from the system to offsite dose concentrations is predicted to be 0.1 mrem, which is well vithin Appendix I criteria. Pending receipt and evaluation of the proposed TS, the staff finds this acceptable.

3.1 SAFETY CONCLUSIONS The proposed radiological effluent technical specifications for Oconee Nuclear Station Units 1, 2, and' 3 have been reviewed, evaluated, and found to be in compliance with the requirements of the NRC regulations and with the intent of NUREG-0133 and NUREG-0472 (the Oconee Nuclear Station is comprised of three pressurized water reactors) and thereby fulfill all the requirements. of the regulations related to radiological effluent technical specifications.

The proposed changes will not remove or relax.any existing requirement needed to provide reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner.

4.0 ENVIRONMENTAL CONSIDERATION

We have determined that the amendments would not authorize a significant change in the types, or a significant increase in the amounts, of effluents or in the authorized power level, and that the amendments will not result in any significant environmental impact.

Having made these determinations, we have further concluded that the amendments involve an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR Part 51.5(d)(4), that an environmental impact statement, or negative declaration and environ mental impact appraisal need not be prepared in connection with the issuance of these amendments.

5.0 GENERAL CONCLUSION We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the>

Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Dated:

January 16, 1984 The following NRC staff personnel have contributed to this Safety Evaluation:

W. Meinke, F. Congel, C. Willis and J. Suermann.

TECHNICALEVALUATION REPORT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATION IMPLEMENTATION (A-2)

DUKE POWER COMPANY OCONEE NUCLEAR STATION UNITS 1 2, AND 3 NRC DOCKET NO. 50-269, 50-270, 50-287 FRC PROJECT C5506 NRC TAC NO. 8119, 8120, 8121 FRCASSIGNMENT4 NRC CONTRACT NO. NRC-03-81-130 FRCTASKS

103, 104 105 Prepared by Franklin Research Center Author:

C. Fernandez 20th and Race Streets Philadelphia, PA 19103 FRC Group Leader:

S. Pandey Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer: F. Congel C. Willis May 24, 1983 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, appa ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.

Prepared by:

Reviewed by:

Approved by:

Principal Author Department Dir tor Date:

C Date: ___2______Date:_

Franklin Research Center A Division of The Franklin Institute The Benjamin Franklin Parkway. Phila.. Pa. 19103 (215) 448.1000

TER-C5506-103/104/105 CONTENTS Section Title Page 1

INTRODUCTION 1

1.1 Purpose of Review 1

1.2 Generic Background.

1 1.3 Plant-Specific Background 3

2 REVIEW CRITERIA.

5 3

TECHNICAL EVALUATION 7

3.1 General Description of Radiological Effluent System 7

3.2 Radiological Effluent Technical Specifications.

12 3.3 Offsite Dose Calculation Manual 19 4

CONLUSIONS.

23 5

REFERENCES 25 UtI[Iranklin Research Center A Division atThe Frankidn institute

TER-C550 6-103/104/105 FIGURES Number Title Page 1

Liquid Radwaste Treatment Systems, Effluent Paths, and Controls for Oconee Nuclear Station Units 1 and 2 8

2 Gaseous Radwaste Treatment Systems, Effluent Paths, and Controls for Oconee Nuclear Station Units 1 and 2 10 TABLE Number Title Page 1

Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Oconee Nuclear Station Units 1 and 2.

24 iv Urnkiin Research Center A Division of The Franlin instute

TER-CS50 6-103/104/10 5 FOREWORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.

U Franklin Research Center A Daiv n d The Franidn insubte

TER-C550 6-103/104/105

1.

-INTRODUCT ION 1.1 PURPOSE OF REVIEW The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Oconee Nuclear Station Units 1, 2, and 3 with regard to Radiological Effluent Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM).

The evaluation uses criteria proposed by the NFC staff in the Model Technical Specifications for pressurized water reactors (PWRs), NUREG-0472 [1].

This effort is directed toward the NRC objective of implementing RETS which comply principally with the regulatory requirements of the Code of Federal Regulations, Title 10, Part 50 (10CFR50), "Domestic Licensing of Production and Utilization Facilities," Appendix I [2].

Other regulations pertinent to

.the control of effluent releases are also included within the scope of compliance.

1.2 GENERIC BACKGROUND Since 1970, 10CFRS0, Section 50.36a, "Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide technical specifications which ensure that radioactive releases will be kept as low as reasonably achievable (ALARA). In 1975, numerical guidance for the ALARA requirement was issued in 10CFR5O, Appendix I. The licensees of all operating reactors were required [3] to submit, no later than June 4, 1976, their proposed ALARA.Technical Specifications and information for evaluation in accordance with 10CFR50, Appendix I.

However, in February 1976, the NRC staff recommended that proposals to modify Technical Specifications be deferred until the NRC completed the model RETS.

The model RETS deals with radioactive-waste management systems and environmental-monitoring. Although the model RETS closely parallels 10CFR50, Appendix I requirements, it also includes provisions for addressing other issues.

-1 IFranidin Research Center A Dision of The Frnildin instute

TER-C550 6-103/104/105 These other issues are specifically stipulated by the following regulations:

o 10CFR20 [4], "Standards for Protection Against Radiation," Paragraphs 20.105(c),

20.106(g),

and 20.405(c) require that nuclear power plants and other licensees comply with 40CFR190 [5],

"Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40CFR190 limits have been or may be exceeded.

o 10CFR50, Appendix A (6], "General Design Criteria for Nuclear Power

Plants, contains Criterion 60 - Control of releases of radioactive materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and Criterion 64 -

Monitoring radioactivity releases.

o 10CFR50, Appendix B [7], establishes the quality assurance required for nuclear power plants.

The NRC position on the model RETS was established in May 1978 when the NRC's Regulatory Requirements Review Committee approved the model RETS:

NUREG-0472 for PWRs [1] and NUREG-0473 (8] for boiling water reactors (BWRs).

Copies were sent to licensees in July 1978 with a request to submit proposed site-specific RETS on a staggered schedule over a-6-month period.

Licensees responded with requests for clarifications and extensions.

The Atomic Industrial Forum (AIF) formed a task force to comment.on the model RETS.

NRC staff members first met with the AIF task force on June 17, 1978.

The model RETS was subsequently revised to reflect comments from the AIF and others.

A principal change was the transfer of much of the material concerning dose calculations from the model RETS to a separate ODCM.

The revised model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133 (9])

for preparation of the RETS and the ODCM and a new schedule for responses, again staggered over a 6-month period.

Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978.

Subsequently, Revision 2 of the model BETS and additional guidance on the-ODCI and a Process Control Program (PCP) were issued in February 1979 to each utility at individual meetings.

In response to the NRC's request, operating reactor licensees have subsequently submitted initial proposals.on plant RETS. and the ODCM.

Review leading to ultimate

-2 UUranklin Research Center A Divsion of The Freniin Insdutue

TER-C550 6-103/104/10 5 implementation of these documents was initiated by the NRC in 1981 using subcontracted independent teams as reviewers.

As the RETS review process has progressed since September 1981, feedback from the licensees has led the N1C to believe that modification to some provisions in the current version of Revision 2 is needed to better clarify specific concerns of the licensees and thus expedite the entire review process. Starting in April 1982, NRC distributed revised versions of RETS in draft form to the licensees during the site visits. The new guidance on these changes was presented in the AIF meeting on May 19, 1982 [10].

Some interim changes regarding the Radiological Environmental Monitoring Section were issued in August 1982 (11].

With tkie incorporation of these new changes, NRC issued, in September 1982, a draft version of NUREG-0472, Revision 3 (12],

to serve as new guidance for the review teams.

1.3 PLANT-SPECIFIC BACKGROUND In conformance with the 1975 directive [3],

Duke Power Company, the Licensee for Oconee Nuclear Station Units 1, 2, and 3, submitted information for 10CFR50, Appendix I Evaluation, dated June 4, 1976 [13].

The RETS and ODCM were addressed in the next submittal by the Licensee, dated March 29, 1979 [14].

The submittal was a response to the November 15-16, 1978 NRC request and followed the format of NUREG-0472 for PWRs.

On June 7, 1982, Franklin Research Center (FRC), selected as an independent reviewer, initiated a review and evaluation of the RETS and ODCM submittals.

These submittals were compared to the model RETS [1] and to the general provisions for the ODCM [15] which were given to each operating reactor (OR) as guidelines for preparing the RETS and the ODCM. The Licensee's RETS and ODCMsubmittals were assessed for compliance with the requirements of 10CFR50, Appendix I, and the "General Design Criteria," 10CFR50, Appendix A.

Copies of the draft review reports dated July 30, 1982 [16, 171 were delivered to the NRC and to the Licensee prior to a site visit to the Oconee Nuclear Station in Oconee County, SC.

Te purpose of the site visit was to resolve questions raised in the.draft review reports.

120raIWnklin Research Center A Dion dThe Franklin institm

TER-C5506-103/104/105 The site visit was conducted on August 18-19, 1982.

Discussions were held with Duke Power and Oconee Station personnel to review the RETS and ODCM reports. Agreement was reached on most items dicussed at the meetings, at which time the Licensee made a commitment to resubmit drafts of the RETS and ODCM by November 15, 1982. A trip report was prepared and delivered to the NBC on September 20, 1982 [18].

The report included the resolutions reached, as well as "open items' to be resolved by the NBC with the Licensee.

On February 16, 1983, revised draft copies [19] of the Licensee's BETS were received by the FRC review team and the final review was initiated.

Under a cover letter dated February 9, 1983, Duke Power company delivered their final ptoposed BETS [20] to the NRC. Copies of this submittal were delivered to FRC on February 25, 1983. The proposed BETS was reviewed and evaluated based on the draft model BETS, NUREG-0472, Revision 3 [12], and comments on the proposed RETS were supplied to the NBC on March 16, 1983

[21].

On May 17, 1983, copies (22] of the Licensee's final ODCM Appendix A submittal (23] were received by the FRC BETS review team for evaluation..

Appendix A of the ODCM submittal contains Oconee site-specific information and is supplemented by the generic ODCM [24], which applies to all Duke nuclear power plants. The generic ODCM, which has been approved by the NRC staff as part of the McGuire Nuclear Station submittal, and the site-specific Appendix A were included in the ODCM evaluation. The proposed ODCM submittal was evaluated according to the existing guidelines specified by NUREG-0133

[9].

A process control program has not been submitted with the BETS and ODCM submittals.

Details of the BETS review are documented in the comparison copy [25],

which contains resolutions on open items received from the NBC (26].

-4 U Franklin Research Center A DMsion of The Franklin insubte

TER-C550 6-103/104/105

2.

REVIEW CRITERIA Review criteria for the RETS and ODCM were provided by the NRC in three documents:

NUREG-0472, RETS for PWRs NUREG-0473, RETS for BWRs NUREG-0133, Preparation of RETS for Nuclear Power Plants.

Twelve essential criteria are given for the RETS and ODCM:

1.

All significant releases of radioactivity shall be controlled and monitored.

2. Offsite concentrations of radioactivity shall not exceed the 10CFR2O, Appendix B, Table II limits.

3. Offsite radiation doses shall be ALARA.

4. Equipment shall be maintained and used to keep offsite doses ALARA.

5.- Radwaste tank inventories shall be limited so that failures will not cause offsite doses exceeding 10CFR20 limits.

6. Hydrogen and/or oxygen concentrations in the waste gas system shall be controlled to prevent explosive mixtures.

7. Wastes shall be processed to shipping and burial ground criteria under a documented program, subject to quality assurance verification.

8. An environmental monitoring program, including a land-use census, shall be implemented.

9. The radwaste management program shall be subject to regular audits and reviews.

10.

Procedures for control of liquid and gaseous effluents shall be maintained and followed.

11. Periodic and special reports on environmental monitoring and on releases shall be submitted.

12-Offsite dose calculations shall be performed using documented and approved methods consistent with NRC methodology.

-5 TJUVFranklin Research Center A Disoanf The Frm inIsitone

TER-C550 6-103/104/105 Subsequent to the publication of NUREG-0472 and NUREG-0473, the NRC staff issued guidelines [27, 28], clarifications [29, 30],

and branch positions [31, 32, 33] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS provisions.

The NRC branch positions issued since the RETS implementation review began have clarified the model RETS implementation for operating reactors.

Review of the ODCM was.based on the following NRC guidelines:

Branch Technical Position, "General Content of the Offsite Dose Calculation Manual" 115]; NUREG-0133

[9]; and Regulatory Guide 1.109 [34].

The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.

1UUranklin Research Center A Diision of The Franidin insitute

TER-C550 6-103/104/105

3. TECHNICAL EVALUATION 3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEMS This section briefly describes the liquid and gaseous radwaste effluent systems, release paths, and control systems installed at Oconee Nuclear Station Units 1, 2, and 3; all three are PWRs.

3.1.1 Radioactive Liquid Effluent The liquid radwaste treatment system, which is common to all three units, has the capability to collect, treat, store, and dispose of most radioactive liquid wastes.

The wastes are collected in sumps and drain tanks in the various buildings and are then transferred to the appropriate tanks in the radwaste building for further treatment, temporary storage, and disposal.

The processed liquid wastes are either returned to the chemical and volume control system or released to the environment through the Hartwell Discharge Canal.

Slightly radioactive spent powdered resin backflush water from the demineral izer system for the control of secondary water purity is placed in the chemical treatment ponds prior to release.

Batches of radioactive liquid waste are discharged to the environment if the concentration of radioactive materials is within the allowable limits.

A diagram of the liquid effluent release paths indicating the location of the liquid effluent monitors is shown in Figure 1. The radioactive liquid wastes originating from the primary drains, high level process drains, and contaminated drains are processed through evaporators and demineralizers prior to release, and the laundry drains are processed through a filter prior to discharge.

These wastes are monitored and controlled by liquid effluent.

radiation monitors (1RIA-33 and 1RIA-34).

The radioactive liquid wastes originating from chemical wastes and turbine building floor drains are placed in the No. 3 chemical treatment pond prior to release.

The turbine building floor drains are monitored by IRIA-54 and 3RIA-54 prior to being discharged to the chemical treatment pond and the service water system effluents are monitored by RAI-35.

A continuous composite sampler is provided for

-7 FIrrankiin Research Center A Division at The Franklin insiute

Chemical and Reactor Coolant Volume Bleed Control System Evaporator A

recycle 4*

.Misc.

Waste Condensate Primary Drains Holdup Tank Waste TestTank High Activity Condensate IRIA-33 (low range)

High Level Waste Tank iWB Monitor Tanks 1RIA-34 (high range)

Process Drains Waste Evaporator Demineralizer M

Haritwell Discharge Low Activity Contaminated Waste Tank Drains Laundry Flter Drains Chemical Waste 1RIA-54 Composite No. 3 Chemical Sampler (I

Unita I and 2 Turbine Treatment Pond Building Drain 0

T 3RIA-54 Unit 3 Turbine Building Drain RIA-35.

Service ILake Keowee Water Discharge teach unit)

RIA Radiation Monitor l

Figure 1.

Liquid Radwaste Treatment Systems, Effluent Pathso and Controls for Oconee Nuclear Station Units 1, 2, and 3

TER-C5506-103/104/105 discharges from the No. 3 chemical treatment pond. As a safety measure, the liquid radwaste effluent radiation monitor and turbine buidling floor drain monitors are provided with automatic termination of release upon a high concentration alarm signal.

3.1.2 Radioactive Gaseous Effluent Airborne particulates and gases vented from process equipment and building ventilation exhaust air are the normal sources of radioactive gaseous effluents from the Oconee, site.

The major source from each unit is the process gas system which contains decay tanks, prefilters, REPA filters, and charcoal adsorbers to ensure that effluent releases are ALARA.

A diagram of the radioactive gaseous effluents showing the location of effluent radiation monitors and process treatment equipment is shown in Figure

2.

Each of the three units has a plant-ventTmixed mode model used for dispersion) which is a combined release point for the major sources of gaseous effluents for that unit.

Other combined gaseous effluent releases (ground level model used for dispersion) from the site are rooftop releases from the turbine building, interim radwaste builidng, and the hot machine shop.

Releases from the interim radwaste building are monitored by 3RIA-53 and releases from the hot machine shop are sampled; releases from the turbine building are unmonitored.

The Unit 1 plant vent is comprised of the following effluent substreams, each of which is equipped with a process radiation monitor as indicated: Unit 1 containment purge (lRIA-49),

Unit 1 condenser air ejector (1RIA-40),

Units 1 and 2 process gas (1RIA-37), and auxiliary building (lRIA-32).

The effluent radiation monitor for the Unit 1 plant vent is 1RIA-45.

The Unit 2 plant vent is comprised of the following effluent substreams, each of which is equipped with a process radiation monitor as indicated:

Unit

2. containment purge (2RIA-49),

Unit 2 condenser air ejector (2RIA-40), Units 1 and 2 spent fuel pool area (2RIA-41),

and auxiliary building (2RIA-32).

The effluent radiation monitor for the Unit 2 plant vent is 2RIA-45.

The Unit 3 plant vent is comprised of the following effluent substreams, each of.which is equipped with a process radiation monitor as indicated:

-9 UVVLWanklin Research Center ADivsion of The Franklin Instute

TER-C550 6-103/104/10 5 Unit 1 Plant Vent 1ARIA-49 I1RIA-45 Unit 1 Containment Prefilter

-7HEPA Charcoal Purge.

Filter Adsorbers Unit1 Condenser Air Eector Utsad2 4D Conrlay cneNcer tto nt

,2 n

UI I I rak i Rs ansPeferrHP 1RIA-37 1IRIA low ran ahigh range Unit I nd 2 4 Dcay EPACharcoal Process Gas TnsPeitrFilter Adsorbers 1RIA-32 Auxiliary Building Unit2 Plant Vent 2AIA-49

);.2RIA 45 Unit 2 Containment PurgePreffilter HEPA Charcoal PurgeFilter

.Adsorbers 2RIA-40 Unit 2 Condenser Air Ejector 2AIA-41 Units 1 and 2 Spent Fuel Pool Area Filter2RIA-32 Auxilitary Building RIA= Radiation Monitor Figure 2. Gaseous Radwaste Treatment Systems, Effluents Paths, and Controls for Oconee, Nuclear Station Units 1, 2, and 3

-10 Franklin Research Center A Divsion of The Franidin Instute

TER-C550 6-103/104/105 Unit3 Plant Vent 3RIA-49 3RIAA45 Unit 3 Containment Prefiter HEPA Chre PeIter 3RIA-40 Unit 3 Condenser Air EVector 3RIA-37 3RIA-38 Iow range. high range Unit3' 3Decay

.rfltrHEPA Charcoal Process Gas Tanks rfle Filter Adsorbers 3RIA*41 Unit 3 _Spent Fuel Pool Area HEPA-Filter 3RIA-32 Auxiliary Building Roof Vent Turbine BuPldingp (Units 1, 2,Iand 3)

(Unmonitored) 3RIA-53 RoofVent Interim Radwaste Building Roof Vent PS Is Hot Machine Shop HP Prefilter EP Filter RIA=- Radiation Monitor PS - Particulate Sampler IS

- Iodine Sampler Figure. 2 (Cont.)

Franlin Research Center A Divisio of The Franklin institute

TER-C5506-103/104/105' Unit 3 containment purge (3RIA-49), Unit 3 condenser air ejector (3RIA-40),

Unit 3 process gas (3RIA-37), Unit 3 spent fuel pool area (3RIA-41), and the auxiliary building (3RIA-32).

The effluent radiation monitor for the Unit 3 plant vent is 3RIA-45.

3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS The evaluation of.the Licensee's proposed RETS against the provisions of NUREG-0472 included the following:

o a review of information provided by the Licensee in the 1979 proposed RETS. submittal (14].

o resolution of problem areas in that submittal by means of a site visit

[18]

o reviewof the Licensee's February 9, 1983 final RETS submittal [20].

3.2.1 Effluent Instrumentation The objective of the RETS with regard to effluent instrumentation is to ensure that all significant liquid and gaseous effluent releases are-monitored.

The RETS specify that all effluent monitors be operable and that alarm/trip setpoints be determined in order to ensure that radioactive levels do not exceed the maximum permissible concentration (MPC) set by 10CFR20.

To further ensure that the instrumentation functions properly,.surveillance requirements are also needed in the specifications.

The Licensee has provided radiation monitors for potential liquid or gaseous effluent lines. In addition, automatic isolation is provided for major effluent lines such as the liquid radwaste effluent, the turbine building sump effluent, and the gaseous waste decay tank effluent.

The.Licensee has provided gaseous process monitors for all of the major gaseous substreams of the plant vent effluent release points. Effluent radiation monitors have also been provided for releases from the interim.

radwaste building and particulate and iodine samplers for releases from the hot machine shop. The Licensee has established an ongoing sampling and

-12 UUranklin Research Center A Division of The Franidin instte

TER-C5506-103/104/105 analysis program for the batch release tanks as well as for continuous releases, as described in the Licensee's final submittal.

Since there are no steam generator blowdown effluent releases directly to the atmosphere, the alternative provisions discussed in NUMEG-0133 for the steam generator blowdown vent are not applicable.

The Licensee has also established a. sampling and analysis program for effluents released from the waste gas storage tank, unit vent sampling, and the reactor building.

The Licensee's proposed RETS submittal on liquid and gaseous effluent monitoring instrumentation has satisfied the provisions set forth in the model RETS and thus meets the intent of NtREG-0472.

3.2.2 Concentration and Dose Rates of Effluents 3.2.2.1 Liquid Effluent Concentration In Section 3.9.1 of the Licensee's submittal, a commitment is made to maintain the concentration of radioactive liquid effluents released from the site to the unrestricted areas to within 10CFR20 limits, and if the concentration of liquid effluents to the unrestricted area exceeds these limits, it will be restored without delay to a value equal to or less than the MPC values specified in 10CFR20.

.Both batch and continuous releases are sampled and analyzed periodically in accordance with a sampling and analysis program (Table 4.1-3 of the Licensee's submittal), which meets the intent of NUREG-0472.

Technical specifications are given to limit the radioactive inventory of the chemical treatment ponds so as to control the concentration of radioactive liquid effluent releases.

These technical specifications are consistent with and meet the intent of NUREG-0472.

3.2.2.2 Gaseous Effluent Dose Rate In Section 3.10.1 of the Licensee's submittal, a commitment is made to maintain the offsite gaseous dose rate from the site to areas at and beyond the site boundary to within 10CFR20 limits, and if the concentration of gaseous-effluents exceeds these limits or the equivalent dose values, it' will be restored without delay to a value equal to or less than these, limits.

-13 UUUFranklin Research Center A DMson at The Frankdln Intute

TER-C550 6-103/104/105 The radioactive gaseous waste sampling and analysis program (Table 4.1-3 of the Licensee's submittal) provides adequate sampling and analysis of the vent discharges, including the substreams, and therefore meets the intent of NUREG-0472.

3.2.3 Offsite Doses from Effluents.

The objective of the RETS with regard to offsite doses from effluents is to ensure that offsite-doses are kept ALARA, are in compliance with the dose specifications of NUREG-0472, and are in accordance with 10CFR5O, Appendix I, and 40CFRl90.

The Licensee has made a commitment to (1) meet the quarterly and yearly dose limitations for liquid effluents, per Section 3.11.1.2 (12];

(2) restrict the air doses for beta and gamma radiation in unrestricted areas as specified in 10CFR50, Appendix I, Section II.B; and (3) maintain the dose level to the maximally exposed member of the public from releases of radioiodines, tritium, and particulates with half-lives greater than 8 days within the design objectives of 10CFR5O, Appendix I,Section II.C. The dose commitment limits proposed by the Licensee for the common Oconee technical specifications are three times the design objectives contained in Appendix I for one unit. The Licensee has stated that there exists no positive means to separate the releases on a per unit basis because of the shared treatment equipment and release points; therefore, the dose commitment limits are given on a per site basis. The Licensee has made a commitment to limit the annual dose to the maximally,exposed member of the public due to releases of radioactivity and radiation from uranium fuel cycle sources to within the requirements of 40CFR190. These offsite dose specifications satisfy the intent of NUREG-0472.

3.2.4 Effluent Treatment The objective of the PETS with regard to effluent treatment is to ensure that wastes are treated to keep releases ALARA and to satisfy the provisions for Technical Specifications governing the maintenance and use of radwaste treatment equipment.

The Licensee has made a commitment to use the liquid and gaseous radwaste treatment system when the piojected doses averaged over 31

-14 LUranklin Research Center A Dvision o The Frankidn lnsaste

TER-CS50 6-103/104/105 days exceed 25% of the annual dose design objectives, prorated monthly.

Due to shared radwaste treatment.systems common to the three units, the projected dose limits used are three times the design objective limits for one unit.

The Licensee has also made a commitment to use the ventilation exhaust treatment system if the monthly projected dose exceeds the limits prescribed in NUREG-0472.

This meets the intent of 10CFR50, Appendix I, Section II.D.

The Licensee has also made a commitment to project the monthly doses' in accordance with the ODCM.

This also meets the intent of NUREG-0472.

3.2.5 Tank Inventory Limits The objective of the RETS with regard to tank inventory limits is to ensure that the rupture of a radwaste tank would not cause offsite doses greater than the limits set in 10CFR20 for non-occupational exposure.

The Licensee has put a curie limit-o 10-curtes-on all outside liquid tanks listed in the specifications and has made-a commitment to. perform surveillance according to the provisions of NUREG-0472.

This limit excludes tritium and dissolved or entrained noble gases.

For gas storage tanks, a curie limit of 380,000 curies has been set for noble gases which are considered to be represented by xenon-133.

The Licensee's commitment to comply with tank inventory limits has satisfied the intent of NUREG-0472.

3.2.6 Explosive Gas Mixtures The objective of the RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in the waste gas systems.

The Licensee has stated that "The resolution of the technical specification regarding explosive gas mixtures in the waste gas system will be delayed until the various modifica tions proposed as part of the Waste Gas Study can be evaluated and any necessary modifications implemented."

In the interim, until modifications are completed, an adequate sampling program should be provided to monitor concentration of explosive gas mixtures in the waste gas system.

The omission of technical specifications on explosive gas mixtures does not meet the intent of NUREG-0472.

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Franidin Research Center A Ovismon of The Franklin Instute

TER-C5506-103/104/105 3.2.7 Solid Radwaste System The. objective of the RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged before it is shipped to a burial site, in accordance with 10CFR71 and Specification 3.11.3 of NUREG-0472. The Licensee has made a commitment to establish a PCP, or the equivalent, to show compliance with this objective.

The Licensee has provided assurance that 10CFR20 requirements will also be met, thereby satisfying the intent of NUREG-0472.

3.2.8 Radiological Environmental Monitoring Program The objectives of the RETS with regard to environmental monitoring are to ensure that (1) an adequate full-area-coverage (land and water inclusive) monitoring program exists; (2) the requirements of 10CFR50, Appendix I for technical specifications on environmental monitoring are satisfied; and (3) the Licensee maintains both a land-use census and interlaboratory comparison program.

The Licensee has followed NUREG-0472 guidelines, including the Branch

Technical Position dated November 1979 [32], and has provided an adequate number of sample locations for pathways identified.

The 40 thermoluminescent dosimeter (TLD) monitoring stations proposed by the Licensee satisfy the specification of NUREG-0472.

The Licensee's-method of analysis and maintenance of the monitoring program satisfies the require ments of Appendix I, 10CFR50.

The Licensee has also made a commitment to describe the specific sample locations in the ODCM.

This meets the intent of NUREG-0472..

The commitments to a yearly land-use census within NUREG-0472 specifica tions and to an ongoing interlaboratory comparison program equivalent to the model RETS guidelines on environmental monitoring.meet the intent of NUaEG-0472.

-16 U liFranklin Research Center AD~vsian ofThe Eranidin institute

TER-CS506-103/104/105 3.2.9 Audits and Reviews The objective of the RETS with regard to audits and reviews is to ensure that audits and reviews of the radwast and environmental monitoring programs are properly conducted. The Licensee's administrative structure designates the station safety review group (SSRG) and the nuclear safety review board (NSRB) as the two groups responsible for reviews and audits, respectively.

Their responsibilities also include the. ODCM, PCP, and QA program.

The two committees encompass the total responsibility for reviews and audits as specified in NUREG-0472.

3.2.10 Procedures and Records The objective of the RETS with regard to procedures is to satisfy the, provisions for written procedures for implementing the ODCM, PCP, and QA program.

It is also an objective of RETS to properly retain the documented records in relation to the environmental monitoring program and certain QA procedures.

The Licensee has made a commitment to establish, implement, and maintain written procedures-for-the PCP, ODCM,-and QA programs which satisfy the provisions of NUREG-0472. The Licensee intends to retain the records of offsite environmental surveys of the radioactive liquid effluent, gaseous effluent, and gaseous process monitoring instrumentation alarm/trip setpoints, as well as the records of quality assurance activities for the duration of the facility operating license. It is thus determined that the Licensee has met the intent of NUREG-0472.

3.2.11 Reports In, addition to the reporting requirements of Title 10, Code of Federal Regulations (10CFR),

the objective of the RETS with regard to administrative controls is also to ensure that appropriate periodic and special reports are submitted to the NBC.

The Licensee has made a commitment to follow applicable reporting requirements stipulated by 10CFR regulations and also the following reports specified by NUREG-0472:

-17 UIUranklin Research Center A Division of The Franlin Instiute

TER-C5506-103/104/105

1. Annual radiological environmental operating report. In Section 6.6.1.5 of the Licensee's submittal, a commitment is made to provide an annual radiological environmental operating report that includes summaries, interpretations, and statistical evaluation of the results of the environmental surveillance program. The report also includes the results of land use censuses, and participation in an inter laboratory comparison program specified by Specification 3.12.3 of NUREG-6472..

2. Semiannual radioactive and solid waste release reports. In Section 6.6.1.4 of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent and solid waste release reports which include a summary of radioactive liquid and gaseous effluents and solid waste released, an assessment of offsite doses, and a list of unplanned releases. Listing of new location for dose calculations identified by the land use census as well as any changes to ODCM are also included in the report.

3. Special report. The Licensee has made a commitment to file a 30-day special report to the NRC under the following conditions as prescribed by the proposed specifications:

o exceeding radioactive liquid effluents limits according to:

Dose, Specification 3.9.2 Liquid Waste Treatment, Specification 3.9.3 Chemical Treatment Ponds, Specification 3.9.4 o exceeding radioactive gaseous effluents limits according to:

Dose, Specification 3.10.2 Gaseous Radwaste Treatment, Specification 3.10.3 o:n exceeding radiological environmental monitoring limits according to:

Program, Specification 4.11.1 Land Use Census, Specification 4.11.2 o

exceeding dose calculation (40CFRI90) limits according to Specification 4.21

4. Thirty-Day Written Reports. The License has made a commitment to file a 30-day written report for:

o an unplanned 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 lIFranidin Research Center A Dision of The Franklin Instute

TER-C550 6-103/104/105 o measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting level values.

These reporting commitments have satisfied the provisions of NUREG-0472.

3.2.12 Implementation of Major Programs One objective of the administrative controls is to ensure that implemen tation of major programs such as the PCP, ODCM, and major changes to the radioactive waste treatment system follow appropriate administrative proce dures. The Licensee has made a commitment to review, report, and implement major programs such as the ODCM but has not included the PCP.

The PCP has been treated as a procedure and not as a major program. This meets the intent of NUREG-0472 on an interim basis.[26].

3.3 OFFSITE DOSE CALCULATION MANUAL (ODCM)

As specified-in NUREG-0472, the ODCM is to be developed by the Licensee to document the, methodology and approaches used to calculate offsite doses and maintain the operability of the effluent system.

As a minimum, the ODCM should provide equations and methodology for the following topics:

o alarm and trip setpoint on effluent instrumentation o

liquid effluent concentration in unrestricted areas o gaseous effluent dose rate at or beyond the site boundary

o. liquid and gaseous effluent dose contributions o

liquid-and gaseous effluent dose projections.

In addition, the ODCM should.contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems. A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

-19 UUUranidin Research Center A Diwuc of The Frankfin but~u te

TER-C5506-103/104/105 3.3.1 Evaluation The Licensee has followed the methodology of NUREG-0133

[9] to determine the alarm and trip setpoints for the liquid and gaseous effluent monitors.

To ensure that the MPC, as specified in 10CFR2O, will not be exceeded even in the case of simultaneous discharge, the Licensee will administratively control the number of releases occurring at one time and/or apportion the release rate among the units.

The Licensee.has demonstrated the method of calculating the radioactive liquid concentration after releasing liquid effluents into the Hartwell discharge canal. The method provides added assurance of compliance with 10CFR20 for liquid releases.

Methods are also included for showing that dose rates at or beyond the site boundary due to noble gases, radioiodines, tritium, and radionuclides in particulate form with half-lives greater than 8 days are in compliance with 10CFR20.

In this.calculation, the Licensee has considered effluent releases from the various release points; releases from the unit vents are treated as mixed level, and releases from the rooftop vents are treated as ground level.

The Licensee has used the highest annual average values of relative concentration (X/Q) and relative deposition (D/Q) to determine the controlling locations.

The Licensee, however, has not provided data for (X/Q) and (D/Q) for ground level releases from the roof vents. The Licensee intends to use the maximally exposed individual and the critical organ as the reference receptor. For noble gases, the Licensee has considered the total body dose and the skin dose resulting from gamma and beta radiation, respectively. For radioiodines, tritium, and particulates, the Licensee has considered the inhalation pathway for estimating.the doses. The Licensee has demonstrated that the described methods and relevant parameters have followed the conservative approaches provided by NUREG-0133 and Regulatory Guide 1.109.

Evaluation of the cumulative dose is to ensure that the quarterly and annual dose design objectives specified in RETS are not exceeded.

For liquid releases, the Licensee has identified drinking water and fish consumption as the two viable pathways. In the calculation, the Licensee has

-20 I

Franklin Research Center A Division of The Frmnidin Instute

TER-C5506-103/104/105 used a near-field dilution factor specific to the plant; all other key parameters follow the suggested values given in Regulatory Guide 1.109. The Licensee has used the maximally exposed adult individual as the reference receptor.

To correctly assess the cumulative dose, the Licensee intends to

'estimate the dose once per 31 days.

Evaluation of the cumulative dose from noble gas releases includes both beta and gamma. and air doses-at and beyond the site boundary.

The critical organs under consideration are the total body and skin for gamma and beta radiation, respectively. Again,. the Licensee has used the maximum (X/Q) values as discussed earlier and has followed the methodology and parameters of NUREG-0133 and Regulatory Guide 1.109.

For radioiodines, tritium, and particulates with half-lives greater than 8 days, the Licensee has provided a method to demonstrate that cumulative doses calculated from the release meet both quarterly and annual design objectives. The Licensee has demonstrated a method of calculating the dose using maximum annual average (C/Q) values for the inhalation pathway and has included (D/Q) values for ingestion pathways. This approach is consistent with the methodology of NUREG-0133.

To comply with the total dose limits specified by 40CRFl90, the Licensee has also included the dose contribution from the direct radiation. However, the Licensee concluded that since direct radiation doses are normally less than 0.01 mrem/yr (a negligible amount), direct radiation doses are not calculated routinely.

Using a simplified methodology for gaseous and liquid dose calculations, the Licensee has demonstrated a procedure to project the monthly dose and to ensure-that the design objectives for the liquid radwaste system and the gaseous radwaste.system are not exceeded.

This simplified method considers the critical populations, critical pathways, and critical radionuclides determined for the Duke nuclear stations. The method is consistent with NUREG-0133.

Adequate flow diagrams defining the effluent paths and components of the radioactive liquid and gaseous waste treatment systems have been provided by

-~

-21 UFranklin Research Center A DMision of The Franklin Institute

TER-C5506-103/104/105 the Licensee. Radiation monitors specified in the Licensee-submitted RETS are also properly identified in the flow diagrams.

The Licensee has provided a description of sampling locations in the ODCM. This description is consistent with the sampling locations specified in the Licensee's RETS Table 4.11-1 on environmental monitoring.

In summary, the Licensee's ODCM submittal addresses the provisions of NUREG-0472,and uses approved methods that are consistent with the methodology and guidance in NUREG-0133; therefore, the ODCM submittal satisfies the intent of these guidelines, except that the Licensee has not provided a set of meteorological data for ground level releases from the rooftop vents.

-22 1UUFranklin Research Center A Dision of The Frmnklin Instite

TER-C5506-103/104/105

4. CONCLUSIONS Table 1 summarizes the results of the final review and evaluation of the submittal from Oconee Nuclear Station Units 1, 2, and 3. The Licensee has made one radiological effluent technical specifications (RETS) submittal for Units 1, 2, and 3 [20], and a thorough review reveals that the RETS are equivalent for all three units.

The offsite dose calculation manual (ODCM) was submitted under separate covers for Units 1, 2, and 3 [23, 24].

The following conclusions have been reached:

1. The-Licensee's proposed RETS submitted February 9, 1983 meets the intent of the NRC staff's "Standard Radiological Effluent Technical Specifications," NUREG-0472, for Oconee Nuclear Station Units 1, 2, and 3 with the following exceptions:

a.

The submittal of the technical specifications for explosive gas mixture monitoring has been deferred to a later date.

In the interim, an adequate sampling program should be provided to monitor concentrations of explosive gas mixtures in the waste gas system.

b. The implementation of major programs such as the process control program has not been addressed in a manner consistent with NUREG-0472.

The process control program is defined as a procedure instead of being defined as a major program.

2. The Licensee's ODCM Appendix A, submitted April 28, 1983 and the generic ODCM, submitted February 28, 1983, use documented and approved methods that are consistent with the criteria of NUREG-0133 and are applicable to Oconee Nuclear Station Units 1, 2, and 3 with the following exception:

a. The Licensee has not provided meteorological dispersion data (X/Q and D/Q) for ground level releases from the roof vents.

-23 ItFranklin Research Center A Division of The Franklin Institute

TER-C550.6-103/104/105 Table 1. Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Oconee Nuclear Station Units 1, 2, and 3 Technical Specifications Replaces NRC Staff or Updates Std. RETS Licensee Existing NUREG-0472 Proposal Tech. Specs.

(Section)*

(Section)

(Section)

Evaluation Effluent 3/4.3.3.3.10 3.5.5/4.1 3.5/4.1, 4.15 Meets the intent Instrumentation 3/4.3.3.3.11 Appendix A of NRC criteria Radioactive 3/4.11.1.1 3.9.1/4.1 3.9, 3.10 Meets the intent Effluents 3/4.11.2.1 3.10.1/

Appendix A of NRC criteria 4.1, 4.21 Offsite Doses 3/4.11.1.2, 3.9.2/4.21 To be added Meets the intent 3/4.11.2.2, 3.10.2/4.21 to Appendix A of NRC criteria 3/4.11.2.3, 3.10.2/4.21 3/4.11.4 4.21.1 Effluent 3/4.11.1.3 3.9.3/4.21 3.9, 3.10 Meets the intent Treatment 3/4.11.2.4 3.10.3/4.21 Appendix A of NRC criteria Tank Inventory 3/4.11.1.4 3.9.5 To be added Meets the intent Limits 3/4.11.2.6 3.10.4 to Appendix A of NRC criteria Explosive Gas 3/4.11.2.5B None None Does not meet Mixtures the intent of NRC criteria Solid Radioactive 3/4.11.3 3.11 To be added Meets the intent Waste to Appendix A of NRC criteria Environmental 3/4.12.1 4.11 4.11 Meets the intent Monitoring of NRC criteria Audits and 6.5.1, 6.5.2 6.1.2, 6.1.3 6.1.2, 6.1.3 Meets the intent Reviews of NRC criteria Procedures and 6.8, 6.10 6.4, 6.5 6.4, 6.5 Meets the intent Records of NRC criteria Reports 6.6 6.6 6.6 Meets the intent of NRC criteria Implementation of 6.13, 6.14, 6.8 To be added Meets-the intent Major Programs-6.15 to Appendix A of NRC criteria in the interim

• Section.number sequence is according to NUREG-0472, Rev. 3 [12].

-24

[

Franklin Research Center A Divsion at The Franklin lastu

TER-C5506-103/104/105

5. REFERENCES

1. "Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 2 NFC, July 1979 NUREG-0472

.2. Title 10, Code of Federal Regulations, Part 50, Appendix I, "Numerical Guides for Design.0bjectives and Limiting Conditions for Operation to Meet the Criterion, 'As Low As Is Reasonably Achievable,'

for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents"

3. Title 10, Code of Federal Regulations, Part 50, Appendix I,Section V, "Effective Dates"

4. Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation"

5. Title 40, Code of Federal Regulations, Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations"

6.

Title 10, Code of Federal Regulations, Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants"

7. Title 10, Code of Federal Regulations, Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"

8. "Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 2 NRC, July 1979 NUREG-0473

9. "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications" NRC, October 1978 NUREG-0133

10.

C. Willis and F. Congel (NRC)

"Summary of Draft Contractor Guidance of RETS" Presented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19, 1982

11.

F. Congel (NEC)

Memo to RAB Staff (NRC)

Subject:

Interim Changes in the Model Radiological Effluent Technical Specifications (RETS)

August 9, 1982.

-25 IJIUIFranklin Research Center A ODsicn of The Franin inadane

TER-C5506-103/104/105

12.

"Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draft 7', intended for contractor guidance in reviewing RETS proposals for operating reactors

NRC, September 1982 NUREG-0472

13.

"Evaluation of Compliance with 10CFR50 Appendix I" Oconee Nuclear Station Units 1, 2, and 3 June 4, 1976

14.

W. 0. Parker (Duke)

Letter to H. Denton (USNRC) with RETS and ODCM attached March 29, 1979

15.

General Contents of the Offsite Dose Calculation Manual," Rev. 1

NRC, 1979

16.

"Radiological Effluent Technical Specification Implementation, Comparison of Plant and Model RETS" Franklin Research Center, Draft dated July 30, 1982

17.

"Radiological Effluent Technical Specification Implementation, Technical Review of Plant-Offsite Dose Calculation Manual" Franklin Research Center, Draft dated July 30, 1982

18.

Trip Report to Oconee Nuclear Power Station Trip Date:

August 18-19, 1982 C. Fernandez/S. Pandey (FRC) to F. Congel/C. Willis/W. Meinke (NRC)

September 20, 1982

19.

Draft Final Oconee RETS Submittal Tranmitted to S. Pandey (FRC) from W. Meinke (NRC)

February 16, 1983

20.

H..B. Tucker (Duke)

Letter of Transmittal to NRC

Subject:

Proposed Radiological Effluent Technical Specifications for the Oconee Nuclear Station February 9, 1983

21.

Informal Technical Communication from C. Fernandez/S. Pandey (FRC) to W. Meinke (NRC)

"RETS Review Questions" March 16, 1983

22.

Draft Final Oconee ODCM Appendix A Submittal Transmitted to S. Pandey (FRC) from W. Meinke (NRC)

May 17, 1983

-26 IFrrankiin Research Center A Diision at The Franklin Asitte

7 0

TER-C5506-103/104/105

23.

H. B. Tucker (Duke)

Letter of Transmittal to NRC

Subject:

Proposed Oconee ODCM Appendix A Submittal April 28, 1983

24.

H. B. Tucker (Duke)

Letter of Transmittal to NRC

Subject:

Revised Offsite Dose Calculation Manual February 28, 1983

25.

"Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs, vs. Licensee Final Submittal of Radiological Effluent Technical Specifications, dated February 9, 1983, for Oconee Nuclear Power Station" Franklin Research Center May 2, 1983

26.

W. Meinke (NRC)

Memo to S. Pandey (FRC)

"NRC Resolutions on Final RETS Submittal" April 26, 1983

27.

C. Willis (NRC)

Letter to S. Pandey (FRC)

Subject:

Changes to RETS requirements following meeting with Atomic Industrial Forum (AIF)

November 20, 1981

28.

C. Willis (NRC)

Letter to S. Pandey (FRC)

Subject:

Control of explosive gas mixture in PWRs December 18, 1981

29. C. Willis and F. Congel (NEC)

"Status of NRC Radiological Effluent Technical Specification Activities" Presented at the AIF Conference on NEPA and Nuclear Regulations, Washington, D.C.

October 4-7, 1981

30.

C. Willis (NRC)

Memo to P. C. Wagner (NRC)

"Plan for Implementation of RETS for Operating Reactors" November 4, 1981

31. W. P..Gammill (NRC)

Memo to P. C. Wagner (NRC)

"Current Position on Radiological Effluent Technical Specifications (RETS) Including Explosive Gas Controls" October 7, 1981

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Franklin Research Center A U~atn oThe Franklin insttute

TER-C5506-103/104/105

32.

"An Acceptable Radiological Environmental Monitoring Program" Radiological Assessment Branch Technical Position, Revision 1 November 1979

33. Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40CFR190)

NRC, February 1980 NUREG-0543

34.

Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR50, Appendix I NRC, October 1977' Regulatory Guide 1.109, Revision 1

-28 Ir~ranklin Research Center A DMiion at The Franlin intbte