Text

LaSalle County, Units 1 and 2 - 2015 Annual Radioactive Effluent Release Report, Including Offsite Dose Calculation Manual, CY-LA-170-301, Revision 6. Part 2 of 9
	ML16120A351
Person / Time
Site:	LaSalle
Issue date:	04/29/2016
From:	; Exelon Generation Co
To:	; Office of Nuclear Reactor Regulation
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ML16120A531	List: ML16120A259; ML16120A351; ML16120A352; ML16120A357; ML16120A358; ML16120A364; ML16120A365; ML16120A385; RA16-017, 2015 Annual Radioactive Effluent Release Report, Including Offsite Dose Calculation Manual, CY-LA-170-301, Revision 6. Part 9 of 9;
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	RA16-017 CY-LA-170-301, Rev. 6
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CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOLOGICAL EFFLUENT CONTROLS LASALLE STATION Units 1and2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.1 DEFINITIONS

NOTE------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Offsite Dose Calculation Manual (ODCM) Controls and Bases. ACTION CHANNEL CALIBRATION CHANNEL CHECK CHANNEL FUNCTIONAL TEST Definition ACTION shall be that part of a control that prescribes remedial measures required under designated conditions.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors.

The CHANNEL CALIBRATION shall encompass the entire channel, including the required sensor, alarm, display, and trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an in-place qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

For specific calibration requirements refer to surveillance requirements section for the applicable instrumentation.

A CHANNEL CHECK shall be a qualitative assessment, by observation, of channel behavior during operation.

This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested. (continued)

Page 1-1.1-1 CY-LA-170-301 Revision 6 Part 1, Radiological Effluent Controls 1.1 DEFINITIONS (continued)

CONTINUOUS SAMPLING DOSE EQUIVALENT 1-131 GASEOUS RADWASTE TREATMENT SYSTEM MEMBERS OF THE PUBLIC MODE OCCUPATIONAL DOSE Uninterrupted sampling with the exception of sampling interruptions of short duration for required surveillances.

That concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table Ill of TIO -14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites"; Table E-7 of Regulatory Guide 1.109, Rev. 1, NRC, 1977; or ICAP 30, Supplement to Part 1, pages 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity." 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 environment.

Any individual, except when that individual is receiving an occupational dose. A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Technical Specifications with fuel in the reactor vessel. The dose received by an individual in the course of employment in which the individual's assigned duties involve exposure to radiation and/or to radioactive material from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person. Occupational dose does not include dose from background radiation, as a patient from medical practices, from voluntary participation in medical research programs, or as a member of the public. (continued)

Page 1-1.1-2

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.1 DEFINITIONS (continued)

OFFSITE DOSE CALCULATION MANUAL (ODCM) OPERABILITY POSITION INDICATION VERIFICATION PROCESS CONTROL PROGRAM (PCP) PURGE -PURGING RATED THERMAL POWER (ATP) The ODCM shall contain the methodology and parameters used in the calculation of off site doses resulting f ram radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Radiological Environmental Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Program and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports. A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified function(s) are also capable of performing their related support function(s).

POSITION INDICATION VERIFICATION shall be the comparison of the physical position of the Slowdown Flow Control Valve (OWLOOS) actuator shaft in percent open to the remote WL002A) Slowdown Flow Control Valve position indication in percent open. The PCP shall contain the current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes shall be accomplished in such a way as to assure compliance with 1 O CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste. PURGE or PURGING shall be 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.

The applicable unit's ATP shall be a total reactor core heat transfer rate to the reactor coolant as defined in Technical Specifications. (continued)

Page 1-1.1-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.1 DEFINITIONS (continued)

RADIOLOGICAL EFFLUENT CONTROL STANDARDS (RECS) SITE BOUNDARY SOLIDIFICATION SOURCE CHECK THERMAL POWER A compilation of the various regulatory requirements, surveillance and bases, commitments and/or components of the radiological effluent and environmental monitoring programs for LaSalle Station. To assist in the understanding of the relationship between effluent regulations, ODCM equations, RECS and related Technical Specification requirements, Table 1-1 provides a matrix that relates these various components, as well as the Radiological Environmental Monitoring Program fundamental requirements.

That line beyond which the land is not owned, leased, or otherwise controlled by licensee as defined in ODCM Part II Figure 1-3. SOLIDIFICATION shall be the conversion of radioactive wastes from liquid systems to a homogeneous (uniformly distributed), monolithic, immobilized solid with definite volume and shape, bounded by a stable surface of distinct outline on all sides standing).

A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source (This could be an external source or known radioactive process stream).

THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. UNRESTRICTED AREA UNRESTRICTED AREA means an area, access to which is neither limited nor controlled by the licensee.

VENTILATION EXHAUST MENT SYSTEM A VENTILATION EXHAUST TREATMENT SYSTEM shall be 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 adsorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust system 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. (continued)

Page 1-1.1-4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.1 DEFINITIONS (continued)

VENTING VENTING shall be 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. DEFINITIONS PECULIAR TO ESTIMATING DOSE TO MEMBERS OF THE PUBLIC USING THE ODCM COMPUTER PROGRAM: a. ACTUAL Refers to using known release data to project the dose to the public for the previous time period. These data are stored in the database and used to demonstrate compliance with the reporting requirements of RECS. b. PROJECTED Refers to using known release data from the previous time period or estimated release data to forecast a future dose to the public. This data is NOT incorporated into the database.

Page 1-1.1-5 Regulation 10 CFR 50 1. Appendix I 2. 3. 10 CFR 20 1. 40 CFR 190 1. (now by reference, 2. also part of 10 CFR 20) Technical

1. Specifications

2. 3. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table 1-1 (Page 1 of 2) COMPLIANCE MATRIX Dose Component Limit Gamma air dose and beta air dose due to airborne radioactivity in effluent plume. a. Whole body and skin dose due to airborne radioactivity in effluent plume are reported only if certain gamma and beta air dose criteria are exceeded.

b Projected doses due to gaseous release, when averaged over 31 days, exceed 0.3 mrem to any organ. c Projected doses due to liquid release, when averaged over 31 days, exceed 0.06 mrem to the total body or 0.2 mrem to any organ. COE for all organs and all four age groups due to iodines and particulates in effluent plume. All pathways are considered.

COE for all organs and all four age groups due to radioactivity in liquid effluents.

TEDE, totaling all deep dose equivalent components (direct, ground and plume shine) and COE (all pathways, both airborne and liquid-borne).

COE evaluation is made for adult only using FGR 11 database.

Whole body dose (ODE) due to direct dose, ground and plume shine from all sources at a station. Organ doses (COE) to an adult due to all pathways. "Instantaneous" whole body (DOE), skin (SOE), and thyroid (COE) dose rates due to radioactivity in airborne effluents.

For the thyroid dose, only inhalation is considered. "Instantaneous" concentration limits for liquid effluents.

Radioactive Effluent Release Report Page 1-1.1-6 ODCM Technical Equation RECS Specification 4-4 12.4.2 5.5.4.h 4-5 4-2 N/A N/A 4-8 N/A 12.4.5 5.5.4.f N/A 12.3.3 5.5.4.f 4-14 12.4.3 5.5.4.i 3-3 12.3.2 5.5.4.d 5-3 12.4.9 5.5.4.c 5-2 12.4.7 5.5.4.j 3-3 4-8 4-9 12.4.1 5.5.4.g 4-10 4-6 3-5 12.3.1 5.5.4.b N/A 12.6.2 5.6.3 (continued)

Regulation 10CFR50 Appendix I Section IV.B.2 10CFR50 Appendix I Section IV.B.3 10CFR50 Appendix I Section IV.B.2 10CFR50 Appendix I Section IV.B.2 and Technical Specifications

1. 1. 1. 1. Table 1-1 (Page 2 of 2) COMPLIANCE MATRIX Dose Component Limit Implement environmental monitoring program. Land Use Census lnterlaboratory Comparison Program Annual Radiological Environmental Operating Report Page 1-1.1-7 CY -LA-170-301 Revision 6 Part I, Radiological Effluent Controls ODCM RECS Technical Eauation Scecification N/A 12.5.1 N/A N/A 12.5.2 N/A N/A 12.5.3 N/A N/A 12.6.1 5.6.2 CY-LA-170-301 Revision 6 Part I, Radiological EHluent Controls 1.0 USE AND APPLICATION

1.2 Logical

Connectors PURPOSE BACKGROUND EXAMPLES The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in ODCM to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies.

The only logical connectors that appear in ODCM are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings.

Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number and by successive indentations of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

The following examples illustrate the use of logical connectors. (continued)

Page 1-1.2-1 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 1.2 Logical Connectors EXAMPLES (continued)

EXAMPLE 1.2-1 ACTIONS CONDITION A. Control not met. REQUIRED ACTION A.1 Verify ... A.2 Restore ... COMPLETION TIME In this example, the logical connector AND is used to indicate that, when in Condition A, both Required Actions A.1 and A.2 must be completed. (continued)

Page 1-1.2-2 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 1.2 Logical Connectors EXAMPLES (continued)

EXAMPLE 1.2-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control not met. A.1 Trip ... OR A.2.1 Verify ... AND A.2.2.1 Reduce ... OR A.2.2.2 Perform ... OR A.3 Align This example represents a more complicated use of logical connectors.

Required Actions A.1, A.2 and A.3 are alternate choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement.

Any one of these three Action may be chosen. If A.2 is chose, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

Page 1-1.2-3 CV-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.3 Completion

Times PURPOSE BACKGROUND DESCRIPTION The purpose of this section is to establish the Completion Time convention and to provide guidance for its use. ODCM Radiological Effluent Controls (RECs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with a REC state Conditions that typically describe the ways in which the requirements of the REC can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times. The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the REC. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the REC Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single REC (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition.

Once a Condition has been entered, subsequent divisions, subsystem, components or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition. (continued)

Page 1-1.3-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times DESCRIPTION (continued)

EXAMPLES However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.

To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either: a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extension does not apply to those RECs that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this entry. These exceptions are stated in individual RECs. The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per a hours," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery

... " Example 1.3-3 illustrates one use of this type of Completion Time. The 1 O day Completion Time specified for Condition A and B in Example 1.3-3 may not be extended.

The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions. (continued)

Page 1-1.3*2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1 .3-1 ACTIONS CONDITION REQUIRED ACTION B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. B.2 Be in MODE 4. COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered. The Required Actions of Condition Bare in to be in MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) is allowed for reaching MODE 4 from the time that Condition B was entered. If MODE 3 is reached within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the time allowed for reaching MODE 4 is the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months because the total time allowed for reaching Mode 4 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If Condition B is entered while in MODE 3, the time allowed for reaching MODE 4 is the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . (continued)

Page 1-1.3-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1 .3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One monitor A.1 Restore monitor to 7days inoperable.

OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a monitor is declared inoperable, Condition A is entered. If the monitor is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Action B.1 and B.2 start. If the inoperable monitor is restored to OPERABLE status after Condition B is entered, Condition A and Bare exited, and therefore, the Required Actions of Condition B may be terminated.

When a monitor pump is declared inoperable while the first monitor is still inoperable, Condition A is not re-entered for the second monitor. REC 12.0.3 is entered, since the ACTIONS do not include a Condition from more than one inoperable monitor. The Completion Time clock for Condition A does not stop after REC 12.0.3 is entered, but continues to be tracked from the time Condition A was initially entered. While in REC 12.0.3, if one of the inoperable monitors is restored to OPERABLE status and the Completion Time for Condition A has not expired, REC 12.0.3 may be exited and operation continued in accordance with Condition A. (continued)

Page 1-1.3-4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

While in REC 12.0.3, if one of the inoperable monitors is restored to OPERABLE status and the Completion Time for Condition A has expired, REC 12.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired. On restoring one of the monitors to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first monitor was declared inoperable.

This Completion Time may be extended if the monitor restored to OPERABLE status was the first inoperable monitor. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months extension to the stated 7 days is allowed, provided this does not result in the second monitor being inoperable for > 7 days. (continued)

Page 1-1.3-5

1.3 Completion

Times EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS CONDITION A. One Function X subsystem inoperable.

B. One Function Y subsystem inoperable.

c. One Function X subsystem inoperable.

AND One Function Y subsystem inoperable.

A.1 B.1 C.1 OR C.2 CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION COMPLETION TIME Restore Function X 7days subsystem to OPERABLE status. AND 10 days from discovery of failure to meet the Control Restore Function Y 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystem to OPERABLE status. AND 10 days from discovery to meet Control Restore Function X 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months subsystem to OPERABLE status. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Restore Function Y subsystem to OPERABLE status. (continued)

Page I* 1.3*6 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition B are concurrently applicable.

The Completion Times for Condition A and Condition B are tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A). The Completion Times of Conditions A and Bare modified by a logical connector, with a separate 1 O day Completion Time measured from the time it was discovered the REC was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the REC. The separate Completion Time modified by the phrase "from discovery of failure to meet the Control" is designed to prevent indefinite continued operation while not meeting the REC. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the associated Condition was entered. (continued)

Page 1-1.3-7 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months instruments inoperable.

instruments(s) to OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2 Be in MODE4. A single Completion Time is used for any number of instruments inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per instrument basis. Declaring subsequent instruments inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times. Once one of the instruments has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first instrument was declared inoperable.

The Completion Time may be extended if the instrument restored to OPERABLE status was the first inoperable instrument.

The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provided this does not result in any subsequent instrument being inoperable for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . If the Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (plus the extension) expires while one or more instruments are still inoperable, Condition Bis entered. (continued)

Page 1-1.3-8 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-5 ACTIONS ------------------------------------------------NOTE----------------------------------------------

Separate Condition entry is allowed for each inoperable instrument.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more instruments A.1 Restore 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable.

instrument(s) to OPERABLE status. B. Required Action and B.1 Be in MODE3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. ANO 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 8.2 Be in MODE4. The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table. The Note allows Condition A to be entered separately for each inoperable instrument, and Completion Times tracked on a per instrument basis. When an instrument is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent instruments are declared inoperable, Condition A is entered for each instrument and separate Completion Times start and are tracked for each instrument.

If the Completion Time associated with an instrument in Condition A expires, Condition B is entered for that instrument.

If the Completion Times associated with subsequent instruments in Condition A expire, Condition B is entered separately for each instrument and separate Completion Times start and are tracked for each instrument.

If a instrument that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that instrument.

Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply. (continued)

Page 1-1.3-9 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1 .3-6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One channel Perform RSR 12.x.x.x.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable.

OR Reduce THERMAL POWER to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 50% ATP. B. Required Action and B.1 Be in MODE3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per RSA 12.0.2 to each performance after the initial performance.

The initial 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be completed within the first 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval.

If Required Action A.1 is followed and the Required Action is not met within the Completion Time (plus the extension allowed by RSR 12.0.2), Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is not met, Condition B is entered. If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A. (continued)

Page 1*1.3-10 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.3 Completion Times EXAMPLES (continued)

IMMEDIATE COMPLETION TIME EXAMPLE 1.3-7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem A.1 Verify affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable.

subsystem isolated.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Restore subsystem to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status. B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND B.2 Be in MODE4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter" interval begins upon performance of Required Action A.1. If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval from the previous performance (plus the extension allowed by RSA 12.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired. When "Immediately" is used as a Completion Time, the Required Action should be pursued without delay and in a controlled manner. Page 1-1.3-11 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.4 Frequency

PURPOSE DESCRIPTION The purpose of this section is to define the proper use and application of Frequency requirements.

Each ODCM Radiological Effluent Surveillance Requirement (RSR) has a specified Frequency in which the Surveillance must be met in order to meet the associated ODCM REC. An understanding of the correct application of the specified Frequency is necessary for compliance with the RSR. The "specified Frequency" is referred to throughout this section and each of the Requirements of Section 12.0, ODCM Surveillance Requirement (RSA) Applicability.

The "specified Frequency" consists of the requirements of the Frequency column of each RSA, as well as certain Notes in the Surveillance column that modify performance requirements.

Sometimes special situations dictate when the requirements of a Surveillance are to be met. They are "otherwise stated" conditions allowed by RSA 12.0.1. They may be stated as clarifying Notes in the Surveillance, as part of the Surveillance, or both. Example 1.4-4 discusses these special situations.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated REC is within its Applicability, represent potential RSR 12.0.4 conflicts.

To avoid these conflicts, the ASA (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed.

With a ASA satisfied, RSA 12.0.4 imposes no restriction.

The use of "met" or "performed" in these instances conveys specified meanings.

A Surveillance is "met" only when the acceptance criteria are satisfied.

Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met." "Performance" refers only to the requirement to (continued)

Page 1-1.4-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.4 Frequency

DESCRIPTION (continued)

EXAMPLES specifically determine the ability to meet the acceptance criteria.

RSA 12.0.4 restrictions would not apply if both the following conditions are satisfied:

a. The Surveillance is not required to be performed; and b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed. The following examples illustrate the various ways that Frequencies are specified.

In these examples, the Applicability of the REC (REC not shown) is MODES 1, 2, and 3. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of RSR most often encountered in the ODCM. The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval.

Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by RSR 12.0.2 for operational flexibility.

The measurement of this interval continues at all times, event when the RSA is not required to be met per RSA 12.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the REC). If the interval specified by RSA 12.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the REC, (continued)

Page 1-1.4-2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.4 Frequency

EXAMPLES EXAMPLE 1.4-1 (continued) and the performance of the Surveillance is not otherwise modified (refer to Examples 1.4-3 and 1.4-4), then RSA 12.0.3 becomes applicable.

If the interval as specified by RSA 12.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the REC for which performance of the RSA is required, the Surveillance must be performed within the Frequency requirements of RSA 12.0.2 prior to entry into the MODE or other specified condition.

Failure to do so would result in a violation of RSA 12.0.4. EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE Verify flow is within limits. FREQUENCY Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 25% ATP 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter Example 1.4-2 has two Frequencies.

The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level< 25% ATP 25% ATP, the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . (continued)

Page 1-1.4-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.4 Frequency

EXAMPLES EXAMPLE 1.4-2 (continued)

The use of *once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND"). This type of Frequency does not qualify for the extension allowed by RSA 12.0.2. "Thereafter" indicates future performances must be established per RSA 12.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example).

If reactor power decreases to< 25% ATP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% ATP. EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE

NOTE---------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 25% ATP. Perform channel adjustment.

FREQUENCY 7days The interval continues whether or not the unit operation is < 25% ATP between performances.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the "specified Frequency." Should the 7 day interval be exceeded while operation is< 25% ATP, this Note allows 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after power reaches 25% ATP to perform the Surveillance.

The Surveillance is still considered to be within the "specified Frequency." Therefore, if the Surveillance were not performed within the 7 day interval (plus the extension allowed by RSA 12.0.2), but operation was< 25% ATP, (continued)

Page 1-1.4-4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION

1.4 Frequency

EXAMPLES EXAMPLE 1.4-3 (continued) it would not constitute a failure of the RSR or failure to meet the REC. Also, no violation of RSR 12.0.4 occurs when changing MODES, even with the 7 day Frequency not met, provided operation does not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with power RTP. Once the unit reaches 25% RTP, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months would be allowed for completing the Surveillance.

If the Surveillance were not performed within this 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval, there would then be a failure to perform a Surveillance within the specified Frequency, and the provisions of RSR 12.0.3 would apply. EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

NOTE---------------------------

Only required to be met in MODE 1. Verify leakage rates are within limits. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Example 1.4-4 specifies that the requirements of this Surveillance do not have to be met until the unit is in MODE 1. The interval measurement for the Frequency of this Surveillance continues at all times, as described in Example 1.4-1. However, the Note constitutes an "otherwise stated" exception to the Applicability of this Surveillance.

Therefore, if the Surveillance were not performed within the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval (plus the extension allowed by RSR 12.0.2), but the unit was not in MODE 1, there would be no failure of the RSR nor failure to meet the REC. Therefore, no violation of RSA 12.0.4 occurs when changing MODES, even with the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency exceeded, provided the MODE change was not made into MODE 1. Prior to entering MODE 1 (assuming again that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency were not met), RSR 12.0.4 would require satisfying the RSR. Page 1-1.4-5 1.0 USE AND APPLICATION 1.5 REC and RSA Implementation CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The ODCM provides those limitations upon plant operations which are part of the licensing basis for the station but do not meet the criteria for continued inclusion in the Technical Specifications.

It also provides information which supplements the Technical Specifications by implementing the requirements of Technical Specification Sections 5.5.1, 5.5.4, 5.6.2, and 5.6.3. RECs and RSRs are implemented the same as Technical Specifications (see 12.0 Applicability).

However, RECs and RSRs are treated as plant procedures and are not part of the Technical Specifications.

Therefore the following exceptions apply: a. Violations of the Action or Surveillance requirements in a REC are not reportable as conditions prohibited by, or deviations from, the Technical Specifications per 10 CFR 50.72 or 10 CFR 50.73. b. Power reduction or plant shutdowns required to comply with the Actions of a REC are not reportable per 10 CFR 50.72 or 10 CFR 50.73. Page 1-1.5-1

2.0 through

11.0 NOT USED CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls INTENTIONALLY BLANK Sections 2.0 through 11.0 are not used in the ODCM in order to maintain the Original ODCM numbering convention Page 1-2.0-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.0 ODCM RADIOLOGICAL EFFLUENT CONTROL (REC) APPLICABILITY REC 12.0.1 REC 12.0.2 REC 12.0.3 REC 12.0.4 RECs shall be met during the MODES or other specified conditions in the Applicability, except as provided in REC 12.0.2. Upon discovery of a failure to meet a REC, the Required Actions of the associated Conditions shall be met, except as provided in REC 12.0.5. If the REC is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. When a REC is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to: a. Implement appropriate compensatory actions as needed; b. Verify that the plant is not in an unanalyzed condition or that a required safety function is not compromised by the inoperabilities; and c. Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , obtain Shift Operations Superintendent or designee approval of the compensatory actions and the plan for exiting REC 12.0.3. Exceptions to this REC are stated in the individual RECs. Where corrective measures are completed that permit operation in accordance with the REC or ACTIONS, completion of the actions required by REC 12.0.3 is not required.

REC 12.0.3 is only applicable in MODES 1, 2, and 3. When a REC is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified (continued)

Page 1-12.0-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.0 REC APPLICABILITY REC 12.0.4 (continued)

REC 12.0.5 REC 12.0.6 condition in the Applicability for an unlimited period of time. This REC shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. Exceptions to this REC are stated in the individual RECs. REC 12.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3. Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment.

This is an exception to REC 12.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

RECs, including associated ACTIONS, shall apply to each unit individually, unless otherwise indicated.

Whenever the REC refers to a system or component that is shared by both units, the ACTIONS will apply to both units simultaneously.

Page 1-12.0-2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.0 ODCM RADIOLOGICAL EFFLUENT SURVEILLANCE REQUIREMENT (RSR) APPLICABILITY RSR 12.0.1 RSA 12.0.2 RSA 12.0.3 RSRs shall be met during the MODES or other specified conditions in the Applicability for individual RECs, unless otherwise stated in the RSA. Failure to meet a RSA, whether such failure is experienced during the performance of the RSA or between performances of the RSA, shall be failure to meet the REC. Failure to perform a RSA within the specified Frequency shall be failure to meet the REC except as provided in RSA 12.0.3. RSRs do not have to be performed on inoperable equipment or variables outside specified limits. The specified Frequency for each RSA is met if the RSA is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per ... " basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this RSA are stated in the individual RSRs. If it is discovered that a RSR was not performed within its specified Frequency, then compliance with the requirement to declare the REC not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the RSA. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed. If the RSA is not performed within the delay period, the REC must immediately be declared not met, and the applicable Condition(s) must be entered. When the RSA is performed within the delay period and the RSA is not met, the REC must immediately be declared not met, and the applicable Condition(s) must be entered. (continued)

Page 1-12.0-3 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.0 RSA APPLICABILITY (continued)

RSR 12.0.4 RSA 12.0.5 Entry into a MODE or other specified condition in the Applicability of a REC shall not be made unless the REC's RSRs have been met within their specified Frequency.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. RSA 12.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, and 3. ASAs shall apply to each unit individually, unless otherwise indicated.

Page 1-12.0-4 12.1 NOT USED CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls INTENTIONALLY BLANK Page 1-12.1-1 CY-LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.2 INSTRUMENTATION 12.2.1 Radioactive Liquid Effluent Monitoring Instrumentation.

REC 12.2.1 The Radioactive Liquid Effluent Instrumentation channels in Table R 12.2.1-1 shall be OPERABLE with their alarm/trip setpoints to ensure that the limits of REC 12.3.1 are not exceeded.

APPLICABILITY:

When pump flow is present in the system. For Slowdown, when the Slowdown Flow Control Valve is >0% open and the Slowdown line is not otherwise isolated.

ACTIONS ----------------------------------------------------NOTE-----------------------------------------------------

1. Separate Condition entry is allowed for each instrument channel. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Suspend the release of Immediately instrument channels radioactive liquid effluents inoperable due to its monitored by the alarm/trip setpoint less instrument channel. conservative than required.

OR A.2 Enter the Condition referenced Immediately in Table R12.2.1-1 for the instrument channel. 8. One or more required 8.1 Enter the Condition referenced Immediately instrument channels In Table R12.2.1-1 for the inoperable for reasons instrument channel. other than Condition A. (continued)

Page 1-12.2.1-1 ACTIONS CONDITION

c. As required by Required C.1 Action A.2 or 8.1 and referenced in Table R12.2.1-1.

AND C.2 AND C.3 C.4 D. Required Action and D.1 associated Completion Time of Condition C not met. E. As required by Required E.1 Action A.2 or 8.1 and referenced in Table R12.2.1-1.

AND E.2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION COMPLETION TIME Perform RSA 12.3.1.1 on at Prior to each release least two independent samples of the tanks contents.

Verify the release rate Prior to each release calculations and discharge valve line-up independently with at least two qualified members of the technical staff. Return instrument channel to 30 days OPERABLE status. OR Place Administrative Control 30 days Clearance order to Lock-Closed OWF201, AW DSCH Tank River DSCH Valve, to remove the ability to conduct a Liquid Radwaste Discharae.

Suspend release of radioactive Immediately effluents via this pathway. Analyze affected effluent grab Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months samples for principal gamma emitters and 1-131 at an LLD as specified in Table R12.3.1-2.

Restore the instrument channel 30 days to OPERABLE status. (continued)

Page 1-12.2.1-2 ACTIONS CONDITION F. As required by Required Action A.2 or B.1 and referenced in Table A12.2.1-1.

G. -----------NOTE-------------

Required Action G.1 shall be completed if this Condition is entered. --------------------------------

Required Action C.3 or C.4, or E.2 and associated Completion Time not met. REQUIRED ACTION CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls COMPLETION TIME F.1 ----------------NOTE------------------

Pump curves for instrument 3.a, or known valve positions for instrument 3.b, may be used to estimate flow. --------------------------------------------

Estimate the flow rate for the Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months release in progress via the affected pathway. F.2 With remote position indication Prior to each release. for OWLOOS (BDFCV) not available, verify valve position locally. G.1 Explain why the inoperability In accordance with was not corrected in a timely Technical manner in the next Radioactive Specification

5.6.3. Effluent

Release Report. Page 1-12.2.1-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.2.1.1 Perform SOURCE CHECK. Prior to each release RSA 12.2.1.2 Perform CHANNEL FUNCTIONAL

-TEST. Prior to each Release RSA 12.2.1.3 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RSA 12.2.1.4 Perform SOURCE CHECK. 31 days RSA 12.2.1.5 Perform CHANNEL FUNCTIONAL TEST. Except for 92 days Instrument 3.b, the test shall also demonstrate that the instrument indicates measured levels above the alarm/trip setpoint and that the control room alarm annunciates and the affected pathway automatically isolates, as applicable, under the following conditions:

a. Loss of power, b Downscale failure, or c. Controls not set in Operate or High Voltage mode. RSA 12.2.1.6 Perform CHANNEL CALIBRATION.

N/A (No longer applicable per E.C. #360580) ASA 12.2.1.7 Perform CHANNEL CALIBRATION 24 months RSA 12.2.1.8 12 months Perform POSITION INDICATION VERIFICATION Page 1-12.2.1-4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.2.1-1 (page 1 of 2) Radioactive Liquid Effluent Monitoring Instrumentation INSTRUMENT

1. Gamma Scintillation Monitor providing Alarm and Automatic Termination of Release a. Liquid Radwaste Effluents Line 2. Gamma Scintillation Monitors providing Alarm but not providing Automatic Termination of Release a. Service Water Effluent Line (Unit 1) b. Service Water Effluent Line (Unit 2) c. AHR Service Water (Line A) Effluent Line (Unit 1) d. AHR Service Water (Line B) Effluent Line (Unit 1) e. AHR Service Water (Line A) Effluent Line (Unit 2) f. AHR Service Water (Line B) Effluent Line (Unit 2) REQUIRED CHANNELS PER llNSTRUMENT CONDITION REFERENCED FROM REQUIRED ACTION A.2 AND B.1 c E E E E E E SURVEILLANCE REQUIREMENTS RSA 12.2.1.1 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2. u<*> ASA 12.2.1.4 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2. 1. 7!*l ASA 12.2.1.4 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2. u<*l RSA 12.2.1.4 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2.u<*l RSA 12.2.1.4 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2. u<*l ASA 12.2.1.4 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2.1.1<*l RSA 12.2.1.4 RSA 12.2.1.3 RSA 12.2.1.5 RSA 12.2. u<*l (continued)

<a> The initial CHANNEL CALIBRATION shall be performed using one or more of the reference radioactive standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, the initial reference radioactive standards or radioactive sources that have been related to the initial calibration shall be used, in order to demonstrate linearity of the original calibration.

This transfer calibration, combined with signal inputs, satisfies channel calibration and functional test requirements as implemented by station procedures.

Page 1-12.2.1-5 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.2.1-1(page2 of 2) Radioactive Liquid Effluent Monitoring Instrumentation INSTRUMENT

3. Flow Rate Measurement Devices a. Liquid Radwaste Effluent Line b. OWL005 BDFCV Position Indication REQUIRED CHANNELS PER !INSTRUMENT Page 1-12.2.1-6 CONDITION REFERENCED FROM REQUIRED ACTION A.2 AND B.1 F F SURVEILLANCE REQUIREMENTS RSA 12.2.1.2 RSA 12.2.1.3 RSA 12.2.1.7 RSA 12.2.1.8 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.2 INSTRUMENTATION 12.2.2 Radioactive Gaseous Effluent Monitoring Instrumentation REC 12.2.2 The Radioactive Gaseous Effluent Instrumentation channels in Table R12.2.2-1 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of REC 12.4.1 are not exceeded.

APPLICABILITY:

According to Table R12.2.2-1 ACTIONS ----------------------------------------------------NOTE-----------------------------------------------------

Separate condition entry is allowed for each instrument channel. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Suspend the release of Immediately instrument channels radioactive gaseous inoperable due to its effluents monitored by alarm/trip setpoint less the instrument channel. conservative than required.

OR A.2 Enter the Condition Immediately referenced in Table R12.2.2-1 for the instrument channel. B. One or more required B.1 Enter the Condition Immediately instrument channels referenced in Table R12.2.2-1 inoperable for reasons for the instrument channel. other than Condition A. (continued)

Page 1-12.2.2-1 ACTIONS CONDITION

c. As required by Required c. 1 Action A.2 or 8.1 and referenced in Table R12.2.2-1.

D. As required by Required D.1 Action A.2 or 8.1 and referenced in Table AND R12.2.2-1.

D.2 AND D.3 E. As required by Required E.1 Action A.2 or 8.1 and referenced in Table AND R12.2.2-1.

E.2 AND E.3 F. As required by Required F.1 Action A.2 or 8.1 and referenced in Table R12.2.2-1.

AND F.2 CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION COMPLETION TIME Place instrument channel in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months trip. Obtain grab samples. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Analyze grab samples for Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months noble gas emitters.

following each grab sample Restore instrument channel to OPERABLE status. 30 days Obtain grab samples. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Analyze grab samples for Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months noble gas emitters at an LLD following each grab as specified in Table sample R12.4.1-1.

Restore instrument channel 30 days to OPERABLE status. Establish CONTINUOUS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SAMPLING with auxiliary sampling equipment as required in Table A 12.4.1-1.

Restore instrument channel 30 days to OPERABLE status. (continued)

Page 1-12.2.2*2 ACTIONS CONDITION G. As required by Required Action A.2 or B.1 and referenced in Table R12.2.2-1.

H. As required by Required Action A.2 or B.1 and referenced in Table R12.2.2-1.

I. ------------N01"E------------

Required Action 1.1 shall be completed if this Condition is entered. --------------------------------

Required Action and associated Completion 1"ime of Required Action D.3, E.3, F.2, or G.2 or H.4 not met. G.1 AND G.2 H.1 AND REQUIRED ACTION Estimate flow rate. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls COMPLETION TIME Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Restore instrument channel 30 days to OPERABLE status. Verify offgas treatment Immediately system not bypassed.

H.2.1 Verify at least one Immediately Instrument 1.a channel OPERABLE.

OR H.2.2 Verify Required Actions for Immediately Condition D are met. AND H.3 Obtain and analyze grab Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . samples. AND H.4 Restore instrument channel 30 days to OPERABLE status. 1.1 Explain in the next In accordance with Radioactive Effluent Release Technical Report why the inoperability Specification 5.6.3. was not corrected within the time specified.

Page 1-12.2.2-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.2.2.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RSA 12.2.2.2 Perform SOURCE CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months RSA 12.2.2.3 **************-***-------------NOTE:***-*****-************************-

For Instruments 4.b and 4.c, not required to be performed until 7 days after Standby Gas Treatment is placed in operation.

Perform CHANNEL CHECK. 7days RSA 12.2.2.4 Perform SOURCE CHECK. 31 days RSA 12.2.2.5 Perform CHANNEL FUNCTIONAL TEST. For 92 days Instruments 3.a (log monitor only) and 1.a, the test shall also demonstrate that the control room alarm annunciates and the automatic isolation capability of the affected pathway, as applicable, under the following conditions:

a. Upscale, b. Inoperative, or c. Downscale RSA 12.2.2.6 Perform CHANNEL FUNCTIONAL TEST. The test shall 92 days also demonstrate that the instrument indicates measured levels above the alarm setpoint and that the control room alarm annunciates on a Loss of Counts condition.

RSA 12.2.2.7 Perform CHANNEL CALIBRATION 24 months Page 1-12.2.2-4

1. a. Table R12.2.2-1 (page 1 of 2) CY-LA-170*301 Revision 6 Part I, Radiological Effluent Controls Radioactive Gaseous Effluent Monitoring Instrumentation APPLICABLE MODES OR REQUIRED CONDITION OTHER CHANNELS REFERENCED SPECIFIED PER FROM REQUIRED SURVEILLANCE INSTRUMENral CONDITIONS INSTRUMENT ACTION A.2 AND B.1 REQUIREMENTS Main Condenser Offgas Treatment System Effluent Monitoring System Noble Gas Activity Monitor -(b) 2 C, if only one required RSA 12.2.2.1 Providing Alarm and Automatic channel inoperable RSA 12.2.2.2 Termination of Release RSA 12.2.2.5 (Post-Treat)

D, if both required RSA 12.2.2.7 1" 1 channels inoperable

2. Main Stack Monitoring System a. Noble Gas Activity Monitor (Low or Mid Range WAGM) b. Iodine Sampler (Grab Sampler) c. Particulate Sampler (Grab Sampler) d. Effluent System Flow Rate Monitor e. Sampler Flow Rate Monitor (Low/Mid/Hi) (c) (c) (c) (c) (c) l (a) Equipment Part Numbers (EPN) are provided In Table R12.2.2*2. (b) During effluent releases via this pathway. (c) At all times. E F F G G RSA 12.2.2.1 RSA 12.2.2.4 RSA 12.2.2.6 RSA 12.2.2.7

CONDITIONS INSTRUMENT ACTION A.2 AND B.1 REQUIREMENTS Condenser Air Ejector Radioactivity Monitor (Prior to Input to Holdup System) a. Noble Gas Activity Monitor (f) H RSA 12.2.2.1 RSA 12.2.2.4 RSA 12.2.2.5 RSA 12.2.2.7

FREQUENCv<g> ANALYSIS (LLm<a> CuCi/ml) Prior to each Prior to each release, Principal Gamma 5x10*7 A. Batch Waste release, Each Emitters<n Release Tanks 1 dl Batch Each Batch 1-131 1x10*5 Prior to each 31 days H-3 1 x10*5 release, Each Composite lbl Batch Gross Alpha 1x10*7 Prior to each 92 days Sr-89, Sr-90 5x10*9 release, Each Composite (bl Batch Fe-55 1 x1 o-e Prior to each release, One 31 days Dissolved & Batch per 31 Entrained Gases 1x10*5 days (Gamma Emitters) B. Plant Continuous 7 days 1-131 1x10-e Releases<e> CONTINUOus<c> Cooling Pond Composite (cl Principal Gamma 5x10*7 Slowdown Emitters 1 n 31 days 31 days Dissolved & 1 x10*5 Entrained Gases Grab Sample (Gamma Emitters) CONTINUOUS 1 c> 31 days H-3 1x10*5 Composite<cl Gross Alpha 1 x10*7 CONTINUOus<c> 92 days Sr-89, Sr-90 5x10..a Compositelcl Fe-55 1x10.a Page 1-12.3.1-4 Table R12.3.1-2 (Page 2 of 4) CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION a. The LLD is the smallest concentration of radioactive material in a sample 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: Where: LLD= 4.66Sb E

V

2.22x10 6

Y

e<-A&> LLD= the a priori lower limit of detection (microcurie per unit mass or volume), sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (counts per minute), .JB =-B =background sum (counts) t =count time (minutes)

E =the counting efficiency (counts per transformation), V =the sample size (units of mass or volume), 2.22 x 10 6 =the number of transformations per minute per microcurie, Y = the fractional radiochemical yield, when applicable, A= the radioactive decay constant for the particular radionuclide and for composite samples, and 6t =the elapsed time between the midpoint of sample collection and the time of counting (for plant effluents, not environmental samples). For batch samples taken and analyzed prior to release, 6t is taken to be zero. 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. Typical values of E, V, Y, and 6t shall be used in the calculation. Alternate LLD Methodology An alternate methodology for LLD determination follows and is similar to the above LLD equation: LLD = (2. 71+4.65..fB)

Decay E

q*b

Y

t-(2.22x10

6) Page 1-12.3.1-5 Table R12.3.1-2 (Page 3 of 4) CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION Where: B = background sum (counts) E = counting efficiency q =sample quantity (mass or volume) b = abundance (if applicable)

Y= fractional radiochemical yield or collection efficiency (if applicable) t= count time (minutes) 2.22 x 10 6 =number of disintegrations per minute per microcurie 2.71 + 4.65v'B = k 2 + (2k v'2 v'B), and k = 1.645 (k=value of the t statistic from the single-tailed t distribution at a significance level of 0.95 and infinite degrees of freedom. This means that the LLD result represents a 95% detection probability with a 5% probability of falsely concluding that the nuclide is present when it is not or that the nuclide is not present when it is.) A.= radioactive decay constant (units consistent with .1t, RT and Td) .1t ="delta t", or the elapsed time between sample collection or the midpoint of sample collection and the time the count is started, depending on the type of sample (units consistent with A.) RT = elapsed real time, or the duration of the sample count (units consistent with A.) Td =sample deposition time, or the duration of analyte collection onto the sample media (units consistent with A.) The LLD may alternately be determined using installed radioanalytical software, if available. In addition to determining the correct number of channels over which to total the background sum, utilizing the software's ability to perform decay corrections (i.e. during sample collection, from sample collection to start of analysis, and during counting), this alternate method will result in a more accurate determination of the LLD. It should be recognized that the LLD is defined as a before the fact limit representing the capability of a measurement system and not as an after the fact limit for a particular measurement. Page 1-12.3.1-6 Table R12.3.1-2 (Page 4 of 4) CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOACTIVE LIQUID WASTE SAMPLING ANO ANALYSIS PROGRAM TABLE NOTATION b. A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sample employed results in a specimen which is representative of the liquids released.

c. To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected in proportion to the rate of flow of the effluent stream. 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. d. A batch release is the discharge of liquid waste of a discrete volume. Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed to assure representative sampling.

e. A continuous release is the discharge of liquid wastes of a non-discrete volume; e.g., from a volume of system that has an input flow during the continuous release. f. The principal gamma emitters for which the LLD specification applies exclusively are 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, at the 95% confidence level, together with the above nuclides, shall also be identified and reported.

g. The provisions of RSA 12.0.2 and RSA 12.0.3 are applicable to the Radioactive Liquid Waste Sampling and Analysis Program. Page 1-12.3.1-7 12.3 LIQUID EFFLUENTS 12.3.2 Dose from Liquid Effluents CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls REC 12.3.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each reactor unit, from the site shall be limited to: a. :s; 1.5 mrem to the total body and :s; 5.0 mrem to any organ during any calendar quarter; and b. :s; 3.0 mrem to the total body and :s; 10.0 mrem to any organ during any calendar year. APPLICABILITY:

At all times. Page 1-12.3.2-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NOTE------------ A.1 Submit a Report, pursuant to 30 days following the Required Action A.1 shall 1 OCFRSO, Appendix I, Section end of the quarter in be completed if this IV.A, to the NRC that identifies which the release Condition is entered. causes for exceeding limits, occurred radiological impact on finished --------------------------------- drinking water supplies at the Calculated dose not nearest downstream drinking within limits. water source and defines actions to be taken to reduce releases of radioactive materials in liquid effluents during the remainder of the current calendar quarter and during the subsequent three calendar quarters so that the cumulative dose or dose commitment is within the limits of REC 12.3.2.b. B. Calculated dose 8.1 Enter Condition A of REC 12.4.7. Immediately exceeds two times (2x) the limits. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.3.2.1 -----------------------------------NOTE----------------------------------- Only required to be performed if liquid releases have occurred since the last performance of this RSA. Calculate cumulative dose contributions from liquid effluents 31 days in accordance with the ODCM. Page 1-12.3.2-2 CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls 12.3 LIQUID EFFLUENTS 12.3.3 Liquid Radwaste Treatment Systems REC 12.3.3. The Liquid Radwaste Treatment System shall: a. Be OPERABLE; and b. Be used to reduce the radioactive materials in liquid wastes prior to their discharge when the projected doses due to the liquid effluent, from each reactor unit, from the site would exceed 0.06 mrem to the total body or 0.2 mrem to any organ when averaged over 31 days. APPLICABILITY: At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Liquid Radwaste A.1 Restore Liquid Radwaste 31 days Treatment System Treatment System to inoperable. OPERABLE status. B. ------------NOTE------------ B.1 Submit a report to the NRC 30 days Required Action B.1 that includes inoperable shall be completed if this equipment or subsystem Condition is entered. identification and reason, -------------------------------- action taken to restore the Untreated liquid waste inoperable equipment to release in progress. OPERABLE status, and a summary description of the action(s) taken to prevent AND recurrence. Projected dose not within limits. c. ------------NOTE------------ C.1 Submit a report to the NRC 30 days Required Action C.1 that includes inoperable shall be completed if this equipment or subsystem Condition is entered. identification and reason, -------------------------------- action taken to restore the Required Action and inoperable equipment to Associated Completion OPERABLE status, and a time of Condition A not summary description of the met. action(s) taken to prevent recurrence. Page 1*12.3.3-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE RS R 12.3.3.1 -------------------------------NOTE------------------------------- Only required to be performed if liquid releases are planned and RSA has not been performed in the last 38 days 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . FREQUENCY Determine projected doses due to liquid releases in 31 days accordance with the ODCM methods. RSA 12.3.3.2 -------------------------------NOTE------------------------------- Not required to be performed if Liquid Radwaste Treatment System has been used to process radioactive liquid effluents in the last 115 days. Operate the Liquid Radwaste Treatment System equipment for at least 30 minutes. Page 1-12.3.3-2 92 days if a portable (vendor supplied) waste treatment system is being used. 180 days if a portable supplied) waste treatment system is not being used. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.1 Gaseous Effluent Dose Rates REC 12.4.1 The dose rate at or beyond the SITE BOUNDARY due to radioactive materials in gaseous effluents released from the site shall be limited to the following:

a. For noble gases, :s. 500 mrem/year to the total body and :s. 3000 mrem/year to the skin; and b. For iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives

> 8 days, :s. 1500 mrem/year to any organ via the inhalation pathway. APPLICABILITY: At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Dose rate not within limits. A.1 Initiate action to Immediately decrease release rates to maintain dose rates within limits. SURVEILLANCE REQUIREMENTS RSA 12.4.1.1 SURVEILLANCE Verify the dose rates due to noble gases, iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives > 8 days in gaseous effluents is within limits utilizing the methodology and parameters of the ODCM limits by obtaining and analyzing representative samples in accordance with Table R12.4.1-1. Page 1-12.4.1-1 FREQUENCY In accordance with the Radioactive Gaseous Waste Sampling and Analysis Program CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOLOGICAL EFFLUENT CONTROLS LASALLE STATION Units 1and2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 1.0 USE AND APPLICATION