ML17317B057
| ML17317B057 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/27/1979 |
| From: | INDIANA MICHIGAN POWER CO. |
| To: | |
| Shared Package | |
| ML17317B056 | List: |
| References | |
| NUDOCS 7904050205 | |
| Download: ML17317B057 (94) | |
Text
EFFLUENT TECHNICAL "SPECIFICATIONS INDIANA 8( l1ICHIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNIT NOS.
1 BRIDGMAN, MICHIGAN 00cket tea->r~
Control S >to SS~~<~~
at Ihcumenb RM Docket Nos.
50-315 and 50-316 License Nos.DPR-58 and DPR-74 g g04050 +~
The attached Effluent Technical Specification for the Oonald C.
Cook Nuclear Plant is based on existing Unit 1 Appendix A Paragraphs.
For Unit 2 Technical Specifications, use the following cross-reference list.
Unit 1
Technical Specification Number Corresponding Unit 2 Technical Specification Number 3/4.3.3.8
~ Table 3.3-11 Table 4.3-11 3/4.3.3.9 Table 3.3-12 Table 4.3-12 Bases 3/4.3.3.8 Bases 3/4.3.3.9 3/4.3.3.9 Table 3.3-12 Table 4.3-12 3/4.3.3.10 Table 4.3-13 Table 4 '-13 Bases 3/4.3.3.9 Bases 3/4.3.3.10
1.0 OEFINITIONS CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that is responds with the necessary range and accuracy to known values of the parameter which the channel monitors.
The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alrm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST.
The CHANNEL CALIBPATION may be performed by any series of sequential, over-lapping or total channel steps such that the entire channel is calibrated.
CHANNEL CHECK 1.1O A CHAl)ilEL CHECK shall be -the qualitative assessment of channel be-havior during operation by observation.
This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter.
CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TESTS shall be:
a.
Analog channels
- the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY including alarm and/or trip functions.
b.
Bistable channels
- the injection of a simulated signal into the sensor to verify OPERABILITY including alarm and/or trip functions.
SOURCE CHECK 1.27 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.
1.0 DEFINITIONS (Continued)
OFFSITE DOSE CALCULATION MANUAL ODCM) 1.28 An OFFSITE DOSE CALCULATION MANUAL (ODCM) shall be
- a. manual contain-ing the methodology and parameters to be used in the calculation of off-site doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring instrumentation alarm/trip setpoints.
Requirements of the ODCM are provided in Specification 6.15.
GASEOUS RAD3IASTE TREATMENT SYSTEM 1.29 A GASEOUS RAD'llASTE TREATMENT SYSTEM is any system designed and in-stalled 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.
VENTILATION EXHAUSE TREATMENT SYSTEM 1.30 A VENTILATION EXHAUST. TREATMENT SYSTEM is any system designed and installed to reduce gaseous radioiodine or radioactive material in parti-culate form in effluents by passing ventilation or vent exhaust gases through charcoal absorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust stream prior to the release to the environment.
Such a system is not considered to have any effect on noble gas effluents.
Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST. TREATMENT SYSTEM components.
TABLE 1.2 FRE UENCY NOTATION NOTATION SA S/U N.A.
FRHRUENCY At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
At least once per 7 days.
At least once per 31 days.
At least once per 92 days.
At least once per 184 days.
At least once per 18 months.
Prior to each reactor startup.
Completed Prior to each release.
Not applicable.
INSTRUMENTATION RAOIOACTIVE LI UIO EFFLUENT INSTRUMENTATION LIMITING COND ITIGN FOR OPERATION 3.3.3.8 The radioactive liquid effluent montoring "instrumentation channels shown in Table 3.3-11 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.11.1.1 are not exceeded.
APPLICABILITY:
As shown in Table 3.3-11.
ACTION'.
With a radioactive liquid effluent monitoring instirumentation channel alarm/trip setpoint less conservative than a value which will ensure that the limits of 3.11.1.1 are met, imme-diately suspend 'the release of radioactive liquid effluents monitored, by the affected channel or declare the channels in-operable.
b.
c ~
With one or more radioactive liquid effluent monitoring in-strumentation channels inoperable, take the applicable ACTION shown in Table 3.3-11.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4.3.3.8.1 The setpoints shall be determined in accordance with methodology as described in the OOCM and shall be recorded in the Technical Oata Book.
4.3.3.8.2 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations during the MOOES and at the frequencies shown in Table 4.3-11.
4.3.3.8.3 Records - Auditable records shall be maintained, in accordance (ith aaetho~do ogyin the 00Civi, of all radioactive liquid effluent monitoring instrumentation alarm/trip setpoints, Setpoints and setpoint calculations shall be available for review to ensure that the limits of Specification 3.11.1.1 are met.
TABLE 3.3-11 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION INSTRUMENT 1.
Gross Radioactivity Monitors Providing Automatic Termination of Release HINIMUM CHANNELS OPERABLE APPLICABILITY ACTION a.
Liquid Radwaste Effluent Line (1) b.
Steam Generator Blowdown (1)
Line c.
Steam Gen.
Blowdown Trt. Effluent (1) 2.
Gross Radioactivity Monitors Not Providing Automatic Termination of Release a.
Service Water System Effluent Line At times of release At times of release During primary to secondary leakage At all times 23 3.
Flow Rate Measurement Devices*
a.
Liquid Radwaste Effluent Line b.
Discharge Pipes*
c.
Steam Generator Blowdown Trt.
Effluent (1)
(1)
(1)
At times of release At all times During primary to secondary leakage 26 26
- Pump curves, and valve settings may be utilized to estimate flow; in such cases, action statement 26 is not required.
TMLE 3.3-ntinued)
RADIOACTIVE LI UID EFFLUENT MONITORING INSTRUMENTATION INSTRUMENT t1IN I NUM CIIANNELS OPERABLE APPLICABILIT Y ACTION
- 4. Continuous Composite Samplers a.
Turbine 8uilding Sumps Effluent Line (I)
At all times 25
TABLE 3.3-11 (Continued)
TABLE NOTATION ACTION 23 >lith, the number of channels OPERABLE less than required by the Minimum Channels 8PERABLE requirement, effluent releases may be resumed for up to 14 days, provided that prior to initiating a release:
l.
At least two independent amples are analyzed in accordance with Specification 4.11.1.1.3, and; 2.
At least two technically qualified members of the Facility Staff independently verify the discharge valving.
Otherwise, suspend release of radioactive effluents via this pathway.
ACTION 24 With the number of channels OPERABLE less than required by The Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided grab samples are analyzed for gross radioactivity (beta or gamma) at a limit of detection of at least 10-7 uCi/gram; l.
At least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when the specific activity of the secondary coolant is >0.01 pCi/gram OOSE EQUIVALENT I-131.
2.
At lease once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the specific activity of the secondary coolant is
< 0.01 pCi/gram OOSE E(UIVALENT I-131.
ACTION 25 Mith the numbers of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided that at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> grab samples are collected and analyzed for gross radioactivity (beta or gamma) at a lower limit of detection of at least 10-" pCi/ml.
ACTION 26 lilith the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for'p to 14 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases.
TABLE 4.3-1l RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE RE UIREMENTS INSTRUMENT CHANNEL SOURCE CHANNEL CIIECK CHECK CALIBRATION CHANNEL FUNCTIONAL TEST 1.
Gross Beta or Gamma Radioactivity Monitors Providing Alarm and Auto-matic Isolation.
a.
Liquid Radwaste Effluents Line b.
Steam Generator Blowdown Effluent Line Steam Generator Blowdown Trt.
Effluent 2.
Gross Beta or Gama@ Radioactivity Monitors Providing Alarm But Nqt Providing Automatic Isolation L3) a.
Service Mater System Effluent Line D*
D*
D*
M C(l) a(l)
O(2) 3.
Continuous Composite Samplers a.
Turbine Building Sumps Effluent Line N/A
- During releases via this pathway.
TABLE 4.3-1 ntinued)
RADIOACTIVE LI(}UID EFFLUENT MONITORING IN RUMENTATION SURVEILLANCE RE UIREMENTS INSTRUMENT CHANNEL CHECK SOURCE CHANNEL CHECK CALIBRATION CHANNEL FUNCTIONAL TEST 4.
Flow Rate Monitors a.
Liquid Radwaste Effluent b.
Steam Generator Blowdown Treatment Line (q)
D(<)
N.A.
N.A.
TABLE 4.3-11 (Continued)
TABLE NOTATION (1)
The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if the following condition exists:
l.
Instrument indicates measured levels above the alarm/trip setpoint.
(2)
The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if the following condition exists:
l.
Instrument indicates measured levels above the alarm/trip setpoint.
(3)
This requirement is applicable only to systems where the service water system or component cooling water system is discharged to an effluent stream.
(4)
CHANNEL CHECK shall consist of verifying indication of flow during periods of release.
CHANNEL CHECK shall be made at least once daily on any day on which continuous, periodic, or batch releases are made.
INSTRUMENTATION RADIOACTIVE GASEOUS PROCESS AND EFFLUENT 'MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive gaseous process and effluent monitoring instru-mentation channels shown in Table 3.3-12 shall be OPERABLE with their alarm/trip setpoints set to ensure that the limits of Specification 3.11.F 1 are not exceeded.
APPLICABILITY: As shown in Table 3.3-12.
ACTION:
a e C.
With a radioactive gaseous process or effluent monitoring in-trumentation channel alarm/trip setpoint less conservative than a value which will ensure that the limits of 3.11.2.1 are met, declare the channel inoperable.
With one or more radioactive gaseous process or effluent monitoring instrumentation channels inoperable, take the applicable ACTION shown in Table 3.3-12.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4 '.3.9.1 The setpoints shall be determined in accordance with methodology as described in the 00CM and shall be recorded in the Technical Data Book.
4.3.3.9.2 Each radioactive gaseous process or effluent monitoring instrumen-tation channel shall be demonstrated OPERABLE by performance of the CHANNEL
- CHECK, SOURCE
- CHECK, CHANNEL CALIBRATION, AND CHANNEL FUNCTIONAL TEST opera-tions during the MODES and at the frequencies shown in Table 4.3-12.
4.3.3.9.3 Auditable records shall be maintained of the calculhtions
- made, in accordance with methodology in the OCDM, of all radioactive process and effluent monitoring instrumentation alarm/trip setpoints.
Setpoints and setpoint calculations shall be available for review to ensure that the limits of Specification 3.11.2.1 are met.
TABLE 3.3-'12 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION INSTRUMENT 1.
l(aste Gas Holdup System Explosive Gas Monitoring System.
a.
Ilydrogen Monitor b.
Oxygen Monitor MINIMUM CHANNELS OPERABI E APPL ICABILITY (1)
(2)
PARAMETER X Hydrogen I Oxygen ACTION 31 29 2.
Condenser Evacuation System a.
Noble Gas Activity b.
Effluent System Flow Rate Measuring Device Radi oacti vity Rate Measurement System Flow Rate Measurement 27 3.
Auxiliary Building Ventilation System a.
Noble Gas Activity Monitor Radioactivity Rate Measurement 28 b.
Iodine Sampler Cartridge c.
Particulate Sampler Filter d.
Effluent System Flow Rate Measuring Device (1)
(1)
Verify presence of cartridge Verify presence of filter System Flow Rate Measurement 30 30 27 e.
Sampler Flow Rate Measuring Device Sampler Flow Rate Measurement 27
- During release via this pathway
- During waste gas holdup system operation (treatment for primary system gases).
TABLE 3.3-12 (Continued)
TABLE NOTATION ACTION 27 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, for more than 28 days with the flow rate being estimated at least every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, pre-pare a Special Report to the Commission pursuant to Specifica-tion 6'.2. within the next 10 days outlining the cause of the malfunction and plans for restoring the channel to OPERABLE status.
ACTION 28 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement for more than 28 days with grab samples being taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, prepare a Special Report to the Commission pursuant to Specification 6.9.2 within the next 10 days outlining the cause of the malfunction and plans for restoring the channel to OPERABLE status.
ACTION 29 With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement for more than 14 days, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2.
With both channels INOPERABLE for more than 14 days prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2, within the next 10 days outlining the cause of the malfunction and the plans for restoring the channel(s) to operable status.
ACTION 30 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement for more than 28 days with samples being collected for periods on the order of seven (7) days and analyzed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the end of sample collection, prepare 5 Special Report to the Commission pursuant to Specification 6.9.2, within the next 10 days outlining the cause of the malfunction and the plans for restoring the channels to OPERABLE status.
ACTION 31 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement for more than 14 days with grab samples being taken and analyzed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, prepare a Special Report to the Commission pursuant to Specification 6.9.2 within the next 10 days outlining the cause of the malfunction and plans for restoring the channel to OPERABLE status.
TABLE 4. 3 12 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE RE UIREMENTS INSTRUMENT CHANNEL CHECK SOURCE CHANNEL CHECK CALIBRATION CHANNEL FUNCTIONAL TEST l.
Waste Gas Holdup System Explosive Gas Monitoring System a.
Hydrogen Monitor b.
Oxygen Monitor c.
Oxygen Monitor (alternate)
N.A.
N.A.
N.A.
O (3)
R (3)
O (3) 2.
Condenser Evacuation System a.
Noble Gas Activity Monitor
- b. System Effluent Flow Rate D
- N.A.
a(2) 3.
Auxiliary Building Ventilation System a.
Noble Gas Activity Monitor
- b. Iodine Sampler
- c. Particulate Sampler d.
System Effluent Flow Rate Measurement Device e.
Sampler Flow Rate Measurement Device D
- N.A.
N.A.
N.A.
N.A.
N.A.'.A.
a(1)
N.AD N.A.
- During releases via this pathway
"*During waste gas holdup system operation (treatment for primary system offgases)
0
TABLE 4.3.12 TABLE NOTATION (1)
The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if the following condition exist:
1.
Instrument indicates measured levels above the alarm/trip setpoint.
(2)
The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if the following condition'exists:
l.
Instrument indicates measured levels above the alarm/trip setpoint.
(3)
The CHANNEL CALISRATION shall include the use of standard gas samples containing:
Anominal 1.
High purity nitrogen (zero gas)
Air-(span gas)
!3/4.11 RADIOACTIVE EFFLUENTS
'3/4.11
~ 1 LI UID EFFLUENTS
'CONCENTRATION LIHITING CONDITION FOR OPERATION 3.11.1.1 The concentration of readioactive material released at anytime from the site to unrestricted areas (see Figure 3.11-1) shall be limited to the concentrations specified in 10 CFR Part 20, Appendix 8, Table II, Column 2 for radionuclides other than dissolved or entrained noble gases.
For dissolved or entrained noble gases, the concentration shall be limited to 2
X 10-4 pCi/ml total activity.
APPLICABILITY: At all times ACTION:
With the concentration of radioactive material released from the site to unrestricted areas exceeding the above limits, immediately restore con-centrati on within the above limits and provide prompt notificati on to the Commission pursuant to Specification 6.9.1.12.
SURVEILLANCE RE(}UIREHENTS 4.11.1.1.1 The concentration of radioactive material at any time in liquid effluents releasedfrom the site shall be continuously monitored in accordance with Table 3.3-11.
- 4. 11. 1.1.2 The liquid effluent continuous monitors having provisions for automatic termination of liquid releases, as listed in Table 3.3-11, shall be used to limit the concentration of radioactive material released at any time from the site to unrestricted areas to the values given in Speci-fication 3.11.1.1.
4.11.1.1.3 The radioactivity content of each batch of radioactive liquid caste to be discharged shall be determined prior to release by sampling nd analysis in accordance withTable 4. 11-1.
The results of pre-release analyses shall be used with the calculational methods in the ODCH to assure that the concentration at the point of release is limited to the values in pecification 3.11.1.1.
. 11.1,1.4 Release analyses of samples from batch release shall e performed in accordance with Table 4.11.-1.
The results of the post-elease analyses shall be used with the calculational methods in the ODCH to ssure that the concentrations at the point of release are limited to he values in Specification 3.11.1,1.
SURVEILLANCE RE UIRE/1ENTS (Continued 4.11.1.1.5 The radioactivity concentration of liquids discharged from continuous relase points'shall be determined by collection and analysis of samples in accordance with Table 4.11-1.
The results of the analyses shall be used with the calculational methods in the OOCM to assure that the concentrations at the point of release are limited to the values in Specification 3.11.1.1.
6.11.1.1.6
~Re orts.
The seniannual Radioactive Effluent Release Report shall include the information specified in Specification 6.9.1.9.
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TABLE 4.11-1(Continued}
TABLE NOTATION a.
The lower limit of detection (LLD) is defined in Table Notation a. of Table 4.12-1 of Specification 4.12.1.1.
b, For certain radionuclides with low gamma yield or low energies, or for certain radionuclide mixtures, it may not be possible to measure radio-nuclides in concentrations near the LLD.
Under these circumstances, the LLD may be increased inversely proportionally to the magnitude of the gamma yield (i.e.
5 X 10
/ I, where I is the photon abundance expressed as a decimal fraction), but in no case shall the LLD, as calculated in this manner for specific radionuclide, be greater than 10Ã of the HPC value specified in 10 CFR 20, Appendix, B,
Table II, Column 2.
c.
A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is repre-sentative of the liquids released.
d.
A batch release is the discharge of liquid wastes of a discrete volume.
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 will apply are exlusively in the following radionuclides:
Mn-54, Fe-59, Co-58, Co-60, Zn-65, tlo-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 which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level.
When unusual circumstances reult in LLD's higher than required, the reasons shall be documented in the semiannual Radioactive Effluent Release Report.
RADIOACTIVE EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION 3.11.1.2 The dose or dose commitment to an individual from radioactive material in liquid effluents released to unrestricted areas (see Figure 3.11-1) shall be limited:
v a.
During any calendar quarter to
< 1.5 mrem to the total body and to 5 mrem to any organ, and b.
During any calendar year to
< 3 mrem to the total body and to
< 10 mrem to any organ.
APPLICABILITY: At all times ACTION:
a.
With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report which identifies the cause(s) for exceed-ing the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents during the remainder of the current calendar quarter and during the subsequent three calendar quarters so that the average dose or dose commitment to an individual from such releases during these four calendar quarters is within 3 mrem to the total body and 10 mrem to any organ.
This Special Report shall also include (1) the results of radiological analyses of the drinking water
- source, and (2) the radiological impact on finished drinking water supplies with regard to the requirements of 40 CFR 141, Safe Drinking Water Act.
(Applicable only if drinking water supply is taken from the receiving water body.)
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4.11.1.2
~ 1 Dose Calculations
. Cumulative dose contributions from liquid effluents shall be determined in accordance with the Offsite Dose Calcu-lation Manual (ODCM) at least once per 31 days.
4.11.1.2.2.
~Re orts.
The semiannual Radioactive Effluent Release Report shall include the information specified in Specification 6.9.1.9.
Figure 3.1l-l 00J-4 0 I It I II I IIIIIi 9 II I'II I Ill I
( II I
III I
) II I
4 0 0 Plant Discharge(unrestricted area) 0 0
Planl North goth+
o Plant Intake
RADIOACTIVE EFFLUENTS LIQUID WASTE TREATHENT LIHITING CONDITION FOR OPERATION 3.11.1.3 The liquid radwaste treatment system shall be OPERABLE.
The system shall be used to reduce the radioactive materials in liquid wastes prior totheir discharge when the projected dose due to liquid effluent releases to unrestricted areas (see Figure 3.11-1) when averaged over 31 days would exceed 0.25 mrem to the total body or 0.8 mrem to any organ.
APPLICABiLITY At all times.
ACTION:
a
~
With radioacti ve liquid waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a
Special Report which includes the following information:
l.
Identification of equipment or subsystems not OPERABLE and
~ the reason for inoperability.
2.
Action (s) taken to restore the inoperable equipment to OPERABLE status.
3.
Summa'ry description of action(s) taken to prevent a recurrence.
b.
The provisions of Specification 3.0.3 and 3.0.4 are not applicable; URVEILLANCE RE UIREHENTS 4.11.1.3.1 Doses due to liquid release to unrestricted areas shall be projected at least once per 31
- days, w'henever liquid release are being made ithout being processed by the liquid radwaste treatment system.
4.11.1.3.2 The liquid radwaste system shall be demonstrated OPERABLE at lease once per 92 days unless the liquid radwaste system has been utilized to process radioactive liquid effluents during the previous 92 days.
't RADIOACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS DOSE RATE LIMITING CONDITION FOR OPERATION 3.11.2.1 The dose rate, at any time, in the unrestricted areas (see Page 3/4 12-6)due to radioactive materials released in gaseous effluents from the site shall be limited to the following values.
a.
The dose rate limit for noble gases shall be <500 mrem/yr to the total body and
< 3000 mrem/yr to the skin, and b.
The dose rate limit for all radioiodines and for all radioactive materials in particulate form and radionuclides other than noble gases with half lives greater than 8 days shall be
< 1500 mrem/yr to any or gan.
APPLICABILITY: At all times.
ACTION:
With the dose rate(s) exceeding the above limits, immediately decrease the release rate to comply with the limit(s) given in Specification 3.11.2.1 and provide prompt notification to the Commission pursuant to Specifica-tion 6.9.1.12.
SURVEILLANCE RE UIREi4IENTS 4.11.2.1.1 The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established above in Specification 3.11.2.1.
4.11.2.1.2 The noble gas effluent continuous moni tors having provisions for the automatic termination of gaseous
- release, as listed in Table 3.3-12, shall be used to limit offsite doses within the values established in Specification 3.11.2.1 when monitor setpoint values are exceeded.
- 4. 11.2.1.3 The release rate of radioacti ve materials, other than noble
- gases, in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program, specified in Table 4.'il-2.
SURVEILLANCE REOUIREHENTS
'4.11.2.1.4 The dose rate in unrestricted
- areas, due to radioactive materials other than noble gases released in gaseous effluents, shall be determined to be within the required limits by using the results of the sampling and analysis program, specified in Table 4.11-2, in performing the calculations of dose rate in unrestricted areas.
4.11.2.1.5
~Re orts The semiannual Radioactive Effluent Release Report shall include the information specified in Specification 6.9.1.9.
, RADIOACTIVE EFFLUENTS
- DOSE, NOBLE GASES LIMITING CONDITION FOR OPERATION 3.11.2.2 The air dose in unrestricted areas (see Page 3/4 12-6)due to noble gases released in gaseous effluents shall be limited to the following:
a.
During any calendar quarter, to
< 5 mrad for camma radiation and
< 10 mrad for beta radiation; b.
During any calendar year, to
< 10 mrad for gamma radiation and
< 20 mrad for beta radiation.
APPLICABILITY: At all times.
ACTION:
a.
With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits. oreoare and submit to the Commission within 30 davs.
oursuant to Soeci-fication 6.9.2, a Special"Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents during the remainder of the current calendar quarter and during the subsequent three calendar quarters so that the average dose during these four calendar quarters is within (10) mrad for gamma radiation and (20) mrad for beta radiation.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4.11.2.2.1 Dose Caculations Cumulative dose contributions for the total time period shall be determined in accordance with the Offsite Dose Calculation Manucal (ODCM) at least once every 31 days.
4.11.2:2.2
~Re orts The Semiannual Radioactive Effiuent Re1ease Report shall include the information specified in Specification 6.9.1.9.
RADIOACTIVE EFFLUENTS
- DOSE, RADIOIODINES, RADIOACTIVE t1ATERIAL IN PARTICULATE FORM, AND RADIONUCLIDES OTHER THAN NOBLE GASES LIi~1ITING CONDITION FOR OPERATION 3.11.2.3 The dose to an individual from radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases with half-lives greater than 8 days in gaseous effluents released to unrestricted areas (see Pa9e 3/14 12-6)hall be limited to the following:
a.
During any calendar quarter to
< 7.5 mrem to any organ; b..
During any calendar year to
< 15 mrem to any organ.
APPLICABILITY: At all times ACTION:
a.
With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than nobles gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission with-in 30 days, pursuant to Specification 6.9.2, a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases of radioiodines, radioactive materials in particu-late form, and radionuclides other than noble gases with half-lives greater than 8 days in gaseous effluents during the remainder of the current calendar quarter and during the subsequent three calendar quarters so that the average dose or dose commitment to an individual from such releases during these four calendar quarters is within ( 15) mrem to any organ.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.11.2.3.1 Dose Calculations Cumulative dose contributions for the total p id~ii di 4
ih h
OC every 31 days.
4.11.2.3.2
~Re orts The semiannual Radioactive Effluent Release Report shall include the information specified in Specification 6.9.1.9.
TABLE 4.11-2 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Gaseous Release Type A.
Waste Gas Storage B.
Containment Purge C. Air Ejector Frequency
!t P
Each Tank Grab Sam le P
Each Purge rab Mc Grab Sample Mlmlmum Analysis Frequency P
Each Tank P
Each Purgec Type of Activity Analysis Princi al Gamma Emitters.
H-3 Principal Gamma Emitters" H-3 f
Principal Gamma Emitters H-3 Lower Limit of Detection (LLD)
Ci ml a
1 X 10-4b 1X10 1X10 1
X 10-6 1
X 10 4b 1
X 10-6 D.
Auxi 1 iary Building Vent Continuous Continuous Continuouse Continuouse Charcoal Sample Particulate Sample M
Composite Par ticul ate Sample Composite Particulate Sample I -131 I-133 f
Principal Gamma Emitters (I-131, Others)
Gross alpha Sr-89, Sr-90 1
X 10-12 1X10 1 xlo 1X10 1 xlo
TABLE 4.11-2 Conti nued)
TABLE NOTATION The lower limit of detec'tion (LLD) is defined in Table Notation a. of Table 4.12-1 of Specification 4.12.1.1.
For certain radionuclides with low gamma yield or low energies, or for certain radionuclide mixtures, it may not be possible to measure radionuclides in conentrations near the LLD.
Under these circum-
- stances, the LLD may be increased inversely proportionally to the magnitude of the gamma yield (i.e.,
1 X 10 4 /I, where I is the photon abundance expressed as a decimal fraction), but in no case shall the LLD, as calculated in this manner for speci'fic radionuclide, be greater than 10Ã of the MPC value specified in 10 CFR 20, Appendix B, Table II, Column l.
Analyses shall also be performed following shutdown, startup, or similar operational occurrence which has altered the mixture of radionuclides as indicated by RCS analysis.
Analyses shall also be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for 7 days following each shutdown, startup or similar operational occurrence which lead to significant increases or decreases in radioiodine in the Reactor Coolant System.
Samplers shall also be changed and analy'ze'd 'at th'e intervals in Specifications 3.11.2.1 and.2.11.2.3.
When samples collected for 24 hourt are anlayzed, the corresponding LLD's may be increased by a factor of 10.
The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specifications 3.11.2.1, 3.11.3.3 and 3.11,3.3.
The principal gamma emitters for which the LLD specification will apply are exclusively the following radionuclides:
KR-87, KR-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissions and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate -missions.
This list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide.
When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the semi-annual effluent report.
RAOIOACTIVE EFFLUENTS
'GASEOUS RADNASTE TREATMENT LIMITING CONOITION FOR OPERATION 3.11.2.4 The gaseous radwaste treatment system and the venti'lation exhaust treatment system shall be OPERABLE.
The gaseous radwaste treatment system shall be used to reduce radioactive materials in gaseous waste prior to their discharge when the projected gaseous effluent air doses due to gaseous effluent releases to unrestricted areas (see Page 3/4 12-6) when averaged over 31 days would exceed 0.8 mrad for gamma radiation and 1
6 mrad for beta radiation and ventilation exhaust treatment system shall be used to reduce radioactive materials in gaseous waste prior to their dicharge when the projected doses due to gaseous effluent releases to unrestricted areas (see Page 3/4 12-. 6) when averaged over 31 days would exceed 1.25 mrem to any
- organ, APPLICABILITY: At all times.
ACTION:
a.
With gaseous waste being discharged for more than 31 days without treatment and in excess of the. above limits, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report which includes the following information:
l.
Identification of equipment of subsystems not OPERABLE and the reason for inoperability.
2.
Action(s) taken to restore the inoperable equipment to OPERABLE STATUS.
3 ~
Summary description of action(s) taken to prevent a re-currence.
b.
The provisions of Specification 3.0.3 and 3.0.4 are not appl i cab 1 e.
SURVEILLANCE RE UIREMENTS 4.11.2.4.1 Ooses due to gaseous releases to unrestricted areas shall be projected at least once per 31 days, whenever the gaseous waste treatment system or ventilation exhaust treatment system is not in operation.
4.11.2.4.2 The appropriate systems shall be demostrated OPERABLE at least once per 92 days unless the appropriate system has been utilized to process radioactive gaseous effluents during the previous 92 days.
RADIOACTIVE EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION I 3.11.2.5 The dose or dose commitment to a real individual 'from all
-'ranium fuel cycle sources is limited to
< 25 mrem to the total body or
- . any organ (except the thyroid, which is limited to
< 75 mrem) over a
'eriod of 12 consecutive months.
APPLICABILITY:
At, all times
" ACTION:
i a.
With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specifications 3.11.1.2.a, 3.11.1.2.b, 3.11.3.3.a F 11.2.2.b, 3.11 '.3.a, or 3.11..2.3.b, prepare and submit a
Special Report to the Commission pursuant to Speciication 6.9.2 and limit the subsequent releases such that the dose or dose commitment to a real individual from all uranium fuel cycle sources is limited to
< 25 mrem to the total body or any organ (except thyroid, which is limited to
< 75 mrem); over 12 consecutive months.
This Special Report shall include an analysis which demonstrates that radiation exposures"to all real individuals from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are less than the, 40 CFR Part 190 Standard.
Otherwise, obtain a variance from the Commission to permit releases which exceeds the 40 CFR Part 190 Standard.
b.
The provisions of Specification 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4.11.2.5.1 Dose Calculations Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with.Specifi-cations 3.11.1.2.a, 3.11.1.2.b, 3.11.2.2.a, 3.11.2.2.b, 3.11.2,3.a, and 3.11.2.3.b, and in accordance with the Offsite Dose Calculation Manual (ODCM).
4.11.2.5.2
~Re orts Specia1 Reports sbal1 be subiaitted as required under Specification 3.11.2.5.a.
RAOIOACTIVE EFFLUENTS
,EXPLOSIVE GAS MIXTURE (Systems not designed to withstand a hydrogen explosion)
(
LIMITING CONPITON FOR OPERATIO 3.11.2.6 The concentration of oxygen in the waste gas holdup system shall be limited to 2% by volume if the hydrogen'in the system is 4% by volume.
APPLICABILITY: At al 1 times.
ACTION:
a.
With the concentration of oxygen in the waste gas holdup system
> 2% by volume but <
4% by volume and containing 4% hydrogen, restore the concentration of oxygen to< 2/or reduce the hydrogen concentration to 4% within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
b.
With the concentration of oxygen in the waste gas holdup system or tank
>4% by volume and>4% hydrogen by volume immediately suspend all addi tions of waste gases to the system or tank and reduce the concentration of.oxygen to 2% or the concentration of hydrogen to 4% within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in the system or tank.
c.
/he provisons of Specification 3.0.3 and 3.0.4 are not applicable.
URVEILLANCE RE UIREMENTS
.11,2.6 The concentrations of oxygen in the waste gas holdup system shall be determined to within the above limits. by continuously monitoring the waste gases in the waste gas holdup system with the oxygen monitors required OPERABLE by Table 3.3-12 of Specification 3.3.3.9.
RADIOACTIVE EFFLUENTS GAS STORAGE TANKS Lli4lITING CONDITION FOR OPERATION 3.11.2.7 The quantity of radioactivity contained in each gas storage tank shall be limited to
< 438,000 curies noble gases (considered as Xe-133).
APPLICABILITY: At al 1 times ACTION:
a.
With the quantity of'adioactive material in any gas storage tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank and within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> either reduce the tank contents to within the limit or provide prompt notification to the Commission pursuant to Specification 6.9.1.12.
The written followup report shall include a description of activities planned and/or taken to reduce the tank contents to within the above limit.
be The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREf1ENTS 4 ~ 11,2
~ 7 The quantity of radioactive material contained in each gas storage tank sha',1 be determined to be within the above limit at least once per 4 days by analysis of the Reactor Coolant System noble gases.
3/4.12 RAOIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM LIMITING CONOITION FOR OPERATION 3.12.1 ducted The radiological environmental monitoring program shall be con-as specified in Table 3.12-1.
APPLICABILITY: At all times ACTION:
a.
b.
c ~
d.
With the radiological environmental monitoring program not being conducted as specified in Table 3.12-1, prepare and submit, to the Commission, in the Annual Radiological Operating Report, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.
(Oeviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavail-ability, or to malfunction of automatic sampling equipment. If the latter, every effort shall be made to complete corrective action prior to the end of the next sampling period.)
With the level of radioactivity in an environmental sampling medium at one or more of the locations specified in Table 3.12-1 exceeding the limits of Table 6'.2 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days from the end of the affected calendar quarter, a Special Report which includes an evaluation of any release conditions, environmental factors or other aspects which caused the limits of Table 6.9-2 to be exceeded.
This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report.
0 With milk or fresh leafy vegetable samples unavailable from any of the sample locations required by Table 3.12-1, prepare and submit to the Commission within 30 days, pursuant to Specifi-cation 6.9.2, a Special Report which identifies the cause of the unavailability of samples and identifies locations for obtaining replacement samples.
The locations from which samples were un-available may then be deleted from Table 3.12-1 provided the locations from which the replacement samples were obtained are added to the environmental monitoring program as replacement locations, if available.
The provisions of Specifications 3.0.3 and 3.0.4 are not appl i cab 1 e.
SURYEILLANCE RE UIRB1ENTS
!14.12.1.1 The radiological environmental monitoring samples shal 1
be collected pursuant to Table 3.12-1 from the locations shown on Figure 3.12-1 and shall be analyzed pursuant to the requirements of Tables 3.12-1 and 4.12-1.
4.12.1.2
~Re orts The results of analyses performed on the radio logical environmental monitoring samples shall be summarized in th;.
annual Radiological Environmental Operating Report, pursuant to Specification 6.9.1.6.
TABLE 3.12-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway
/~s Sam le Locations**
Sampling and Collection Fre uenc Type and Frequency of Anal sis 1.
AIRBORNE A. Radioiodine and Particulates 2.
DIRECT RADIATION Al-A6 NBF, SBN,
- DOW, COL Al-A6 NBF, SBN,
- DON, COL
- Continuous operation of sampler" with sample col-lection as required by dust loading but at least once per 7 days.
At least once per 92 days Radioiodine canister.
Analyze at least once per 7 days for I-131 Particulate sampler.
Analyze for gross beta radioactivity >24 hours following filter change.
Perform gaoma isotopic analysis on each sample when gross beta activity is
> 10 times the mean of control sample.
Perform gamm<
isotopic analysis on com-posite (by location) sample at least once per 92 days.
Gamma dose. At least once per.92 days.
- Direct radiation TLD badges located with each air sampler
- Sample locations are shown on Figure 3.12-1.
TABLE 3.12-1 continued RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway and/or Sam le Sampling and Collection Fre uenc Type and Frequency of Anal sis 3.
WATERBORNE a.
Surface b.
Ground c.
Drinking Wl -W7 St.
Joseph Lake Township New Buffalo Composite
- sample collected over a period of <
31 days.
At least once per 92 days Composite* sample collected over a period of < 31 days.
Gamma isotopic analysis of each composite sample by location. Tritium analy-sis of composite sample at least once per 92 days.
Gamma'isotopic and tritium analyses of each sample.
Gross beta and gamma isotopic analysis of each composite sample.
Tritium analysis of composite sample at least once per 92 days.
d.
Sediment from L2, L3 Shoreline 4 ~
INGESTION 2/year Gamma isotopic analysis of each sample.
Milk Stevensvi lie Bridgman Galien Dowagiac South Bend At least once per 15 days when animals are on pasture; at least once per 31 days at other times.
Gamma isotopic and I-131 analysis of each sample.
Composite samples shall be collected by collecting an aliquot at intervals not exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
- Sample Locations are shown on Figure 3.12-1.
TABLE 3.12-1 Continued RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway
~d/
~Sam le Locations **
Sampling and Collection Fre uenc Type and Frequency of Anal sis 4.
INGESTION (cont.)
- b. Fish Plant site Off-Site 2/year Gamma isotopic analysis on edible portions.
c.
Food Products At time of harvest.
One sample Plant Si te of each of the following classes Off-Site (approx.
20 miles)of food products:
~ 1.
Grapes Gaoea isotopic analysis on edible portion.
Plant Site At time of harvest.
One sample of broad leaf vegetation.
Gamma isotopic analysis.
- At least 5 miles from plant centerline.
- Sample locations are shown on Figure 3.12-1.
Figure 3,'i2-1A
- Air, Precipitation, TLD Stations
- Lake Mater Sample Stati ons
- Milk Sample Stations 20 MILES~,
I196 Col om llati.i 194 BENTON HARBOR ST.
JOSEPH Stevensvil e
D. C.
COOK PLANT Q,/
Bridgma M
33 Eaulaire Berrien Springs M140 L
New Buffalo A
MICHIGAN CITY I94 US 12 MECHIGAH 17lDTFiiA New Carlisle Niles US20 US20r IND 2
'SOTH BlD Scale of Miles 10 20
TRUE PLANT NORTH NORTH~ Ill Al UNRESTRICTED AREA
~ PROPERTY LINF ROADS
)
Ll SHORE LINE L2 I]4 f ~E-V~
r PLANT q N.S PLANT C H2 I
(l!.
765 KV YARD 345 KV YARD CHESAPEAKE a OHIO R.R.
2,000 FOOT RADIUS INTERSTATE 94 SCALE I,GOO 2,000 3,000 4,000 FEET A - Air, Preci pitati on, TLD Stati ons W - tlell Water Sample Stations I. - Lake Water Sample Stations M - Milk Sample Stations
TABLE 4.12-1 MAXIMUM VALUES FOR Tllf LOWER LIMITS OF DETECTION (LLD)
Analysis Water (pCi/1)
Airborne Particulate or Gas (pCi/m3)
Fl sb (pCi/kg,wet)
Mi 1 k (pCi/1)
Food Products (pCi/kg, wet)
Sediment (pCi/kg,dry) ross beta 3ll 54Mn 59FFe 58,60CCo Zn Zr-Nb 1311 134,137 Cs 140Ba-La 4b 2000 (1000
)
15 30 15 30 15(10b),18 15 1X102 7
X 10"2 1X102 130 130 260 130 15 15 60 80 150
TABLE 4.12-1 (Continued)
TABLE NOTATfON.
a The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95/ probability with 55 probability of falsely concluding that a blank observation represents a "real" signal.
For a particualr measurement system (which may include radio-chemical separation):
where LLD =
4.66 s
E ~ V
- 2. 22
~ Y exp(-Rat)
LLD is -the lower limit of detection as defined above(as pCi per unit mass or volume) s is the standard deviation of the background counting rate ok of the counting rate of a blank sample as appropriate (as counts per minute)
E is the counting efficiency (as counts per transformation)
V is the sample size
( in units of mass or volume) 2.22 is the number of tansformation per minute per
- curie, is the fractional radiochemical yield (when applicable)
A i s the radi oacti ve decay cons tant for the parti cul ar radionuclide at is the elapsed time between sample collection (or end of the sample collection period) and time of counting.
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 predi cted variance.
In calculating the LLD for a radionuclide determined by gamma-ray spectrometry, the background shall include the typical contributions of other radionuclides normally present in the samples
( e.g.,
potassium-40 in mil,k samples).
TABLE 4.12-1 Continued)
TABLE NOTATION Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations,
.unavoidably small sample sizes, the presence of interferring nuclides, or other uncontrollable cir-cumstances may render these LLDs unachievable.
In such cases, the contributing factors will be identified and described in the Annual Radiological Environmental Operating Report.
LLD for drinking water.
LLD for leafy vegetables.
l RADIOLOGICAL ENVIRONMENTAL MONITORING
,'3/4.12.2 LAND USE CENSUS LIMITING CONDITION FOR OPERATION 3.12.2 A land use census shall be conducted and shall identify the loca-tiori of the nearest milk animal, the nearest residence and the nearest garden* of greater than 500 square feet producino fresh leafy vegetables in each of the 9 land covering meterological sectors within a distance of five miles.
APPLICABILITY: At all times.
ACTION:
a.
With a land use census identifying a location(s) which yields a calculated dose or dose. commitment greater than the values currently being calculated in Specification 4.11.2.3.1, pre-pare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report which identifies the new location(s).
b With 5 land use census identifying a location(s) which yields a calculated dose or dose commitment (via the same exposure pathway) greater than at a location from which samples are currently being obtained in accordance with Specification 3.12.1, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report which identifies the new location.
The new location shall be added to the radiological environmental monitoring program within 30 days, if possible.
The sampling location having the lowest calculated dose or dose commitment (via the same exposure pathway) may be deleted from this monitoring program after -(October 31) of the year in which this land use census was conducted.
c.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4.12.2.1 The land use census shall be conducted at least once per 12 months between the dates of June 1
and October 1, by door-to-door survey, aerial survey, or by consulting local agriculture authorities.
4.12.2.2
~Re orts The results of the land use census shall be included in the Annual Radi ologi ca 1 Environmental Operating Report.
Broad leaf vegetation sampling may be performed at the site boundary in the direction sector with the highest 0/g in lieu of the garden census.
INSTRUMENTATION
.BASES
'RAOIOACTIVE LI UIO EFFLUENT INSTRUMENTATION 3/4.3.3.8 The radioactive liquid effluent instrumention is provided to monitor and control, as applicable, the releases of radioa'ctive materials in liquid effluents during actual or potential releases.
The alarm/trip setpoints for these instruments shall be calculated in accordance with NRC approved methods in the OOCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20.
The OPERABILITY and use of this instrumentation is consistent with the requirements of General Oesign Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.
3/4.3.3.9 RAOIOACTIVE GASEOUS EFFLUENT INSTRUMENTATION 3/4.3.3.9 The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases.
The alarm/trip setpoints for these intruments shall be calculated in accordance with NRC approved methods in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20.
This instrumen-tation also includes provisions for monitori ng the concentrations of potentially explosive gas mixtures in the waste gas holdup'ystem.
The OPERABILITY and use of this instrumentation is consistent with the requirements of General Oesign Criteria 60,63, and 64 of Appendix A to 10 CFR Part 50.
3/4.11 RADIOACTIVE EFFLUENTS BASES.
3/4.11.1 LI UID EFFLUENTS 3/4.11.1.1 CONCENTRATION.
This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified in 10 CFR Part 20, Appendix 8, Table II.
This limitation provides additional assurance that the levels of radioactive materials in bodies of water outside the site will not result in exposures within (1) the Section II.A design objec-tives of Appendix I, 10 CFR Part'0, to an individual and (2) the limits of 10 CFR Part 20,106(e) to the population.
The concentration limit for noble gases is based upon the assumption that Xe-135 is the controlling radioisotooe and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protec-tion
( ICRP) Publication 2.
3/4.11.1.2 DOSE.
This specification is provided to implement the requirements of Sections II.A, III;Aand IV.A of Appendix I, 10 CFR Part 50.
The Limiting Condition for Operation implements the guides set forth in Section II.A of Appendix I.
The ACTION statements provide the required operating flexi6ilityand at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable".
Also, for fresh water sites with drinking water supplies which can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR 141.
The dose calculations in the ODCM implement the requirements in Section III.Aof Appendix I that conformance with the guides of Appendix I is to be shown by cal-culational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially under-estimated.
The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents will be con-sistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I." Revision 1, October
- 1977, and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I,"
April 1977.
NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.113.
PHR-STS-1
RADIOACTiVE EFFLUENTS BASES This specification applies to the release of liquid effluents from
,each reactor at the site.
The liquid effluents from the shared system are proportioned among the units sharing the system.
3/4.11.1.3 LIAUID HASTE TREATMENT.
The OPERABILITY of the liquid radwaste
~treatment system ensures that this system will be available for use whenever
- liquid effluents require treatment prior to release to the environment.
The
';requirements that the appropriate portions of this sytem be used when speci-
.fied provides assurance that the releases of radioactive materials in liquid
'.effluents will be kept "as low as is reasonably achievable."
This speci-fication implements the requirements of 10 CFR Part 50.36a, General Design
,"Criterion 60 of Appendix A to 10 CFR Part 50 and design objective Section 11.D of Appendix A to 10 CFR Part 50.
The specified limits governing the use
- of appropriate portions of the liquid radwaste treatment system were speci-
- fied as a suitable fraction of the guide set forth in Section 11.A'of
'-Appendix I, 10 CFR Part 50, for liquid effluents.
3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 DOSE RATE.
This specification is provided to ensure that the dose rate at anytime at the site boundary from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for unrestricted areas.
The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table II.
These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual in an unrestricted
- area, to annual average concentrations exceeding the limits specified in Appendix 8, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b)).
For individuals who may at times be within the site boundary, the occupancy
,'of the individual will be sufficiently low to compensate for any increase PHR-STS-1
RADIOACTIVE EFFLUENTS BASES 1
I'.
in the atmospheric diffusion factor above that for the site boundary.
. The specified release rate limits restrict, at all times, the corre-
- sponding gamma and beta dose rates above background to an individual
- - at or beyond the site boundary to
< (500) mrem/year to the total body
- or to
< (3000) mrem/year to the skin.
These release rate limits also
- 'estrict, at all times, the corresponding thyroid dose rate above back-ground to an infant via the cow-milk-infant pathway to
< 1500 mrem/year for the nearest cow to the plant.
~
~
This specification applies to the release of gaseous effluents from all reactors at the site.
The gaseous effluents from the shared system are proportioned among the units sharing that system.
3/4.11.2.2
'DOSE, NOBLE GASES This specification is provided to implement the requirements of Sections II.B, III.A and IY.A of Appendix I, 10 CFR Part 50.
The Limiting Condition for Operation implements the guides set forth in Section II.B of Appendix I'.
The ACTION statements provide the required operating flexibilityand at the same time implement the guides set forth in Section IV.A of Appendix I assure that the releases of radio-active material in gaseous effluents will be kept "as low as is reasonable achievable".
The Surveillance Requirement implement the requirements in Section III.Aof Appendix I that conform with the guides of Appendix I to be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated.
The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, "Methods or Estimating Atmos-pheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-!later-Cooled Reactors,"
Revision 1, July 1977.
The ODCM equations provided for determining the air doses at the exclusion area boundary will be based upon the historical average atmospherical conditions.
NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.111.
3/4.11.2.3
- DOSE, RADIOIODINES, RADIOACTIVE MATERIAL IN PARTICULATE FORA AND RADIONUCLIDES OTHER THAN NOBLE GASES.
This specification is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix I, 10 CFR Part 50.
The Limiting Conditions for Operation are the guides set forth in Section II.C of Appendix I.
i PWR-STS-1
RADIOACTIVE EFFLUENTS BASES The ACTION statements provide the required operating flexi-bility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials gaseous effluents will be kept "as low as is reasonably achievalbe."
The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section III.A of Appendix I that conform-.
ance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to substantially under-estimated.
The ODCH calculational methods approved by NRC for calculating the doses due to the actual release rates of the subject materials are re'quired to be consistent with the methodology provided in Regulatory Guide 1. 109, "Calculating of Annual Doses to Han from Routine Releases of Reactor Effluents for the'Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision I, October 1977 and Regulatory Guide 1.111, "Hethods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors,"
Revision 1, July 1077.
These equations also provide for determinino the actual doses based upon the historical average atmospheric condi tions.
The release rate specifications for radioiodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area.
The pathways which are examined in the development of these calculations are: 1)individual inhalation of airborne radionuclides,
- 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, 3( deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man.
3/4.11.2.4 GASEOUS WASTE TREATMENT The OPERABILITY of the gaseous radwaste treatment system and the venti la-tion exhaust treatment systems ensures that the systems wi 11 be available for use whenever gaseous effluents require treatment prior to release to the environment.
The requirement that the appropriate portions of these systems be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appen-dix A to 10 CFR Part 50, and design objective Section IID of Appendix I to 10 CFR Part 50.
The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the guide set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.
RADIOACTIVE EFFLUENTS 3/4. 11.2. 5 00SE This specification is provided to meet the reporting requirements of 40 CFR 190.
3 4.11.2.6 EXPLOSIVE GAS HIXTURE This specification is provided to ensure that the concentration of potentially explosive gas mixtures contained in the waste gas treat-ment system is maintained below the flammability limits of hydrogen and oxygen mixtures.
Haintaining the concentration of hydrogen or oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Oesign Criterion 60 of Appendix A to 10 CFR Part 50.
3/4.11.2.7 GAS STORAGE TANKS Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tanks contents, the resulting total body exposure to an individual at the nearest site boundary will not exceed o.5 rem.
This is consistent with Standard Review Plan 15.7,1, "4'aste Gas System Failure."
3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING BASES 3/4.12.1 MONITORING PROGRAM The radiological monitoring program required by this specification provides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from the station operation.
This monitoring program thereby supplements the radiological effluent monitoring program by verifying that the measur-able concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways.
The initially specified monitoring program will be effective for at least the first three years of commerical operation.
Following this period, program changes may be initiated based on operational experience.
The detection capabilities requi red by TAble 4.12 '1 are state-of-the-art for routine environmental measurements in indiustrial labora-tories.
The LLD's for drinking water meet the requirements of 40 CFR 141.
3.4.12.2 LAND USE CENSUS This specification is provided to ensure that changes, in the use of unrestricted areas are identified and that modifications to the monitoring program are made if required by the results of this census.
This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50.
Restricting the census to gardens of greater than 500 square feet provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child.
To determine this minimum garden size, the following assumptions ere used,
- 1) that 20/ of the garden was used for growing broad lea vegetation (i.e., similar to lettuce and cabbage),
and 2) a vegetation yield of 2 kg/square meter.
.6. 0 AOHINISTRATIVE CONTROLS 6.1.
RESPONSIBILITY 6.1.1 The plant Manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.
6.2 ORGANIZATION OFFSITE 6.2.1 The offsite organization for facility management and technical support shall be as shown on Fi gure 6.2-1.
FACILITY STAFF 6.2.2 The Facility organization shall be as shown on Figure 6.2-2 and:
a
~
b.
Each on duty shift shall be composed of at least the minimum shift crew composi tion shown in Table 6 '-1.
At least one licensed Operator shall be in the control room when fuel is in the reactor.
c ~
At least two licensed Operators shall be present in the control room during reactor start-up, scheduled reactor shutdown and during recovery from reactory trips.
An individual qualified in radiation protection procedures shall be on si te when fuel is in the reactor.
e.
ALL CORE ALTERATIONS after the initial fuel loading shall be directly supervi sed by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.
A site Fire Brigade of at least 5 members shall be maintained onsite at all times.
The fire Brigade shall not include 3
members of the minimum shift crew necessary for safe shutdown of the unit or any personnel required for other essential functions during a fire emergency.
PRESIDENT AEP, AEPSC, I
S'i'ND OTHER AEP SUBSIDIAR Ic S LEGEND:
ADMINISTRATIVE TECHNICAL SUPERVISION 5 FUNCTIONAL DtRECTION TECHNICAL LIASON EXECUTIVE VICE PRFSIOENT NDI*NA5 MICHIGAN LECTRIC COiVi?ANY I S MPO;";ER CO.
Yice Chairman ENGINEERING 8(
CONSTRUCTION AEPSC VICE PREStDENT INDtANA oi MICHIGAN FLECTRIC COMPANY INDIANA& MICHtGAN POWER COMPANY
. Senior VICE PRFSIDENT CQIiggpi 0 n
'ASSISTANT TO EXEC. V. P.
Chief NUCLEAR ENGliNEER AEPSC OTHER ENGINEERING DIV)SIONS AEPSC QUALITY ASSURANCE MANAGER AEPSC AEPSC lwSDRC 1
I J
PLANT MANAGER DONALD C. COOK f4UCLEAR PLANT PI.ANT QUALITY ASSUR ANCE SUPER VISOR li DI NA AND MICHIGAN ELECTRIC COPs PANY "ND INDIANAAND MICHIGAN PO'i'I'ER COM?A"Y
<<<<Responsible for Fire Pro ection Proc,ram.
r IGURE 6.21 Offsite Orcanization far Faciti~ Management arri Technical Suppoa
, PLNT f'NHAG hat.nt<<STIIATIVE SUPE<<VISOA MhINTfNANCF. ~
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- din CIOFI KIIGINEEA upv.
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SGL - sEtllon orEnhTOA LICEIISE oL - opEAATan LlcENsE
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P E n Fa AtkhttCE ENGltIEEA PEAFOAMRtlcE FNOIIIEEA ItlSTAUIAENT IIhttITcttAIICE S 'lny.
CIIO.IIS'T naothTloN PAOT ECTloll Supv.
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'fECIINICIANS AUXILIhnY E0UA'I.IEtlT opEAATOB FlGUBt. 6.2-2 Fttdtlty OTgsnizathn 'onald C. Cook - Unit No. 1
TABLE 6.2-1 MINIMUMSHIFT CREM COMPOSITION LICENSE CATEGORY 1,2,3
& 4 APPLICABLE tdOOES 5
& 6 SOL OL NON-Licensed
~ Ooes not include the licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling, supervising CORE ALTERATIONS after the initial fuel loading.
- Shared with D.
- however, the Plant Manager shall have responsibility for resolution of such disagreements pursuant to 6.1.1 above.
- Head, Nuclear Safety A Licensing Section (Secretarv)
- Encineer, nuclear Safety h Llcensira Section Alternate:
- however, no lmore than-two alternates shall participat as voting members in NSORC activit'es at any one time.
- orders, Technical Specifications, license requirements or of internal procedures or instructions having nuclear safety significance.
- AEPSC, and those areas of responsibility specified in sections 6.5.2.7 and 6.5.2.8.
- a. Minutes of each NSDRC meeting shall be prepared, approved and forwarded to the Vice Chairman, Engineering and Construction, AEPSC, within 14 days following each meeting.
- b. Reports of review encompassed by Section 6.5.2.7
- above, shall be prepared, approved and forward to the Vice
- Chairman, Engineering and Construction, AEPSC within 14 days following completion of the review.
- 6. 7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
- systems, structures, and (3) corrective action taken to prevent recurrence.
- above, and changes
- thereto, shall be reviewed by the PNSRC and approved by the Plant Manager prior to ivplementation and reviewed periodically as set forth in administrative procedures.
- license, (2) amendment to the license involving a planned increase in power level, (3) instaIlation of fuel that has a different design or has been manu-factured by a different fuel supplier, and (4) modifications that may have significani ly altered the nuclear, thermal, or hydraulic perfor-mance of the plant.
- report, the report shall be submitted noting and explaining the reasons for the missing results.
- type, sample preparation methods, analytical
- methods, and measuring equip-ment used;a map of all sampling locations keyed to a table giving distances and directions from one reactor; the result of land use census required by the Specification
- 3. 12.2; and the results of participation in the guality Assurance Program required by Specification 3.12.3.
- systems, the submittal shall specify thd releases of radioactive material from each unit.
- ment, no later than the 15th of each month following the calendar month covered by the report.
- reports, a licensee event report shall be com-pleted and reference shall be made to the original report date.
- elude, as a minimum a completed copy of a license event report form.
- mented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.
- boundary, or primary containment.
- prevent, by itself, the fulfillment of the functional require-ments'of systems required to cope with accidents analyzed in the SAR.
- systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analysis in the safety analysis report or technical specification bases; or discovery during unit life of condi tons not specifically considered in the safety analysis report or technical specifica-tions that require remedial action or corrective measures to prevent the existence or development of an unsafe condition.
- minimum, a completed copy of a licensee event report form.
- 2) more than 150 curies of noble gas in gaseous effluents, or 3) more than 0.05 curies of radioiodine in gaseous effluents.
- however, in such an event, the con-dition shall be reported and described in the Annual Radiological Environmental Operating Report.
- thereto, which are used to
- 2.
Background
and definition of what constitutes
'major changes'o radioactive waste systems
( liquid, gaseous and solid)
~
ADt1INISTRAT IVE CONTROLS A. 'ackground 10 CFR Part 50, Section 50.34a(a) requires that each application to construct a nuclear power reactor provide a description of the equipment installed to maintain control over radioactive material in gaseous and liquid effluents produced during normal reactor operations in-cluding operational occurrences.
2.
3 ~
5.
10 CFR Part 50, Section 50.34a (b) (2) requires that each application to construct a nuclear power reactor provide an estimate of the quantity of radionuclides expected to be released annually to unrestricted areas in liquid and gaseous effluents produced during normal reactor operation.
10 CFR Part 50, Section 50.34 a(3) requires that each application to construct a nuclear power reactor provide a description of the provisions for packaging, storage and shipment offsite of solid waste containing radio-active materials resulting from treatment of gaseous and liquid effluents and from other sources.
10 CFR Part 50, Section 50.34a (c) requires that each application to operate a nuclear power reactor shall in-clude (1) a description of the equipment and procedures for the control of gaseous and liquid effluents and for the maintenance and use of equipment installed in radioactive waste systems and (2) a revised estimate of the information required in (b)(2) if the expected releases and exposures differ significantly from the estimate submitted in the application for a construction permit.
The Regulatory staff's Safety Evaluation Report and amend-ments thereto issued prior to the issuance of an operating license contains a description of the radioactive waste systems installed in the nuclear power reactor and a de-tailed evaluation (including estimated releases of radio-active materials in liquid and gaseous waste and quantities of solid waste produced from normal operation, estimated annual maximum exposures to an individual in the unres-tricted area and estimated exposures to the general popula-tion) which shows the capability of these systems to meet the appropriate regulations.
ADMINISTRATIVE CONTROLS 6.
The Regulatory staff's Final Environmental Statement issued prior to the issuance of an operating license con-tains a detailed evaluation as to the expected environ-mental impact from the estimated releases of radioactive material in liquid and gaseous effluents, Definition "Major Changes" to radioactive waste systems (liquid, gasesous and solid) shall include the following:
1.
Major changes in process equipment, components, structures and effluent monitoring instrumentation from those described in the Final Safety Analysis Report (FSAR) or the Hazards Summary Report and evaluated in the staff's Safety Evalua-tion Report (SER)
( e.g., deletion of evaporators and installation of demineralizers; use of fluidized bed calciner/incineration in place of cement solidifcation systems);
Major changes in the design of the radwaste treatment system (liquid, gaseous and solid) that could significantly alter the characteristics and/or quantities of effluents released
,-or volumes of solid waste stored or shipped offsite from those previously considered in the FSAR and SER (e.g.,
use of asphalt system in place of cement);-
3.
Changes in system design which may invalidate the accident analysis as described in the SER (e,g.
changes in tank capacity that would alter the curies released);
and Changes in system design that could potentially result in a significant increase in occupational exposure of operating personnel (e.g.,
use of skid mounted equipment, use of mobile processing equipment).