ML17352A109

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Proposed Tech Specs to Ensure Consistency W/New 10CFR20 Requirements & Re Radiological Effluent Release Rept Frequency
ML17352A109
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 07/20/1993
From:
FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17352A107 List:
References
NUDOCS 9307280083
Download: ML17352A109 (54)


Text

ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS Marked-Up Technical Specifications Pages, XX3.3.3.

1-3 1-5 1-6 3/4 3-50 3/4 3-54 3/4 11-1 3/4 11-16 3/4 11-18 5-1 5-2 6-16 6-18 6-19 6-22 6-23 6-24 B 3/4 11-1 B 3/4 11-2 B 3/4 11-3 B 3/4 11-4 B 3/4 11-5 B 3/4 11-6 B 3/4 11-7 9307280083 930720 PDR ADOCK 05000250 P PDR

INDEX ADMINISTRATIVE CONTROLS SECTION 6.5.2 COMPANY NUCLEAR REVIEW BOARD F unction.. ~ ~ ~ ~ ~ ~ r ~ ~ ~ ~ I ~ r ~ ~ ~ 0 ~ ~ ~ ~ ~ 6-8 Composition. 6-8 Alternates..... 6-8 Consultants 6-9 Meeting Frequency 6-9 quorum. 6-9 Review. 6-9 Audits 6-10 Records 6-11

6. 5. 3 TECHNICAL REVIEW AND CONTROL Activities........... 6-11 6.6 REPORTABLE EVENT ACTION......,........ ~ . 6-12
6. 7 SAFETY LIMIT VIOLATION...................................... 6-12 6.8 PROCEDURES AND PROGRAMS 6-13
6. 9 REPORTING RE UI REMENTS . 6-15
6. 9. 1 ROUTINE REPORTS 6-15 Startup Report............. 6-15 Annual Reports......................., ~ ~ ~ ~ ~ 6-16 An,~ma. t Annual Radiological Environmental Operating Report. 6-17 Ses~~l Radioactive Effluent Release Report..... 6-18 Monthly Operating Report.................................. 6-19 Peaking Factor Limit Report............................... 6-19
6. 9. 2 SPECIAL REPORTS 6-20
6. 10 RECORD RETENTION. 6-20 TURKEY POINT - UNITS 3 & 4 XX111 AMENDMENT NOS.l37AND l32

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DEF INI7 IONS

%II E 1.12 The, FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

GAS DECAY TANK SYSTEM

1. 13 A GAS DECAY TANK SYSTEM shall be any system designed and installed to reduce radioactive gaseous effluents by collecting Reactor Coolant System off gases from the Reactor Coolant System and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the environment.

IDENTIFIED LEAKAGE 1.14 IDENTIFIED LEAKAGE shall be:

a. Leakage (except CONTROLLED LEAKAGE) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or
b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of Leakage Detection Systems or not to be PRESSURE BOUNDARY LEAKAGE, or
c. Reactor Coolant System leakage through a steam generator to the Secondary Coolant System.

MEMBER(S) OF THE PUBLIC

1. 15 MEMBER(S) OF THE PUBLIC shall g~ 'HI wAy

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~LANI OFFSITE DOSE CALCULATION MANUAL 1.16 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of- gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environ mental Radiological Monitoring Program.

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DEFINITIONS UADRANT POWER TILT RATIO 1.23 QUADRANT POWER TILT RATIO shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector cali-brated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. With one excore detector inoperable, the remaining three detectors shall be used for computing the average.

RATED THERMAL POWER 1.24 RATED THERMAL POWER shall be a total reactor core heat transfer rate to

?he reactor coolant of 2200 MWt.

REPORTABLE EVENT 1.25 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 of 10 CFR Part 50.

SHUTDOWN MARGIN 1.26 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full-length rod cluster assemblies (shutdown and control) are fully inserted except for the single rod cluster assembly of highest reactivity worth which is assumed to be fully withdrawn.

SITE BOUNDARY WQ a.lIA Oe P"~ p @r4-1.27 The SITE BOUNBARY shall hat line beyond which the land is~r~ssssi owned,~sec leased, otherw>se controlled by the licensee.

SOLIDIFICATION 1.28 SOLIDIFICATION shall be the conversion of wet wastes into a form that meets shipping and burial ground requirements.

SOURCE CHECK 1.29 A.SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a source of increased radioactivity.

STAGGERED TEST BASIS 1.30 A STAGGERED TEST BASIS shall consist of:

a ~ A test schedule for n systems, subsystems, trains, or other designated components obtained by dividing the specified test interval into n equal subintervals, and The testing of one system, subsystem, train, or other designated component at the beginning of each subinterval..

TURKEY POINT - UNITS 3 & 4 1-5 AMENDMENT NOS. 137AND

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DEFINITIONS THERMAL POWER

1. 31 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

TRIP ACTUATING DEVICE OPERATIONAL TEST 1.32 A TRIP ACTUATING DEVICE OPERATIONAL TEST shall consist of operating the Trip Actuating Device and verifying OPERABILITY of alarm, interlock and/or trip functions. The TRIP ACTUATING DEVICE OPERATIONAL TEST shall include adjustment, as necessary, of the Trip Actuating Device such that at the required setpoint within the required accuracy.

it actuates UNIDENTIFIED LEAKAGE 1.33 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE.

UNRESTRICTED AREA

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1. 34 An UNRESTRICTED AR shall Y fACf~tt wi-thethe-R-'FE-BOUNBA I4 VENTILATION EXHAUST TREATMENT SYSTEM 1.35 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 st~eam prior to the release to the environment. Such a system is not considered to have any effect on noble gas effluents. Engineered Safety Features Atmospheric Cleanup Systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING 1.36 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 pro-vided or required during VENTING. Vent, used in system names, does not imply a VENTING process.

DIGITAL CHANNEL OPERATIONAL TEST 1.37 A DIGITAL CHANNEL OPERATIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY of alarm, interlock, and/or trip functions.

TURKEY POINT " UNITS 3 4 4 AMENDMENT NOS. 140AND 135

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INSTRUMENTATION RADIOACTIVE LI UID EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.5 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-7 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Specification 3. 11. 1. 1 are not exceeded. The Alarm/

Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (OOCM).

APPLICABILITY: At all times, except as indicated in Table 3.3-7.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above spe-cification, immediately suspend the release of radioactive liquid effluents monitored by the affected channel or declare the channel inoperable, or change the setpoint so it is acceptably conservative.
b. With'ess than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-7. Restore the inoperable instrumentation to OPERABLE status w thin 30 days and, if unsuccessful, explain in the next to Specifica-6emeeaeaR Radioactive Effluent Release Report pursuant

>on . . .4 why this inoperability was not corrected in a timely manner.

C. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE UIREMENTS 4.3.3.5 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-5.

TURKEY POINT - UNITS 3 8( 4 3/4 3-50 AMENDMENT NOS. 137AND132

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INSTRUMENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION

3. 3. 3. 6 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-8 shall be OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of Specification 3.11.2.1 and 3. 11.2.5 are not exceeded.

The Alarm/Trip Setpoints of these channels meeting Specification 3. 11.2. 1 shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 3.3-8 ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm/Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable or change the setpoint so conservative.

it is acceptably

b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-8. Restore the inoperable instrumentation to OPERABLE w'n 30 days and, if. unsuccessful explain in the next status t>on 6...4 ttt why tt tfft ttt tt tt this inoperability was tt not corrected in a tt ttt timely manner.

C. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE UIREMENTS 4.3.3.6 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-6.

TURKEY POINT - UNITS 3 8( 4 3/4 3-54 AMENDMENT NOS. 137ANO 132

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3/4. 11 RADIOACTIVE EFFLUENTS 3/4. 11.1 LI UID EFFLUENTS CONCENTRATION LIMITING CONDITION FOR OPERATION 3.11.1.1 The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 5. 1-1) shall limited to the concentrations specsf1ed sn 10 CFR Part 20, Appendix B, Tabl , Column 2 or radsonuclsdes other than dissolved or entrained noble gases. or dissolved or entrained noble gases, the concentration shall be limited to 2 x 10-4 microCurie/ml total activity.

APPLICABILITY: At all times.

ACTION:

With the concentration of. radioactive material released in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, immediately restore the concen-tration to within the above limits.

SURVEILLANCE RE UIREMENTS 4.11. 1. 1.1 Radioactive liquid wastes shall be sampled and analyzed accor'ding to the sampling and analysis program of Table 4. 11-1.

4. 11. 1. 1. 2 The results of the radioactivity analyses shall be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits of Specification
3. 11. 1. 1.

TURKEY POINT - UNITS 3 8 4 3/4 11-1 AMENDMENT NOS. 137AND 132

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RADIOACTIVE EFFLUENTS GAS DECAY TANKS LIMITING CONDITION FOR OPERATION 3.11.2.6 The quantity of radioactivity contained in each gas decay tank shall be limited to less than or equal to 70,000 Curies of noble gases (con-sidered as Xe-133 equivalent).

APPLICABILITY: At al 1 times.

ACTION:

With the quantity of radioactive material in any gas decay tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank contents to within the limit d describe the events leading to this condition in the next SeaeeaaeA adioactiv Effluent Release Report, pursuant to Specification 6. . .4.

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b. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE UIREMENTS

4. 11.2.6 The quantity of radioactive material contained in each gas decay tank shall be determined to be within the above limit at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when radioactive materials are being added to the tank and the Reactor Coolant System total activity exceeds the limit of Specification 3.4.8.

TURKEY POINT - UNITS 3 & 4 3/4 11-16 AMFNDHENT NOS.137 AND 132

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RADIOACTIVE EFFLUENTS 3/4.11.4 TOTAL DOSE LIMITING CONDITION FOR OPERATION 3.11.4 The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mrems to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems.

APPLICABILITY: At all times.

ACTION:

a. With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specifi-cation 3. ll. 1.2am 3. 11. l. 2b., 3. 11. 2. 2a., 3. 11. 2. 2b., 3. 11. 2. 3a., or s
3. 11.2.3b., calculations shall be made including direct radiation contributions from the units to determine whether the above limits of Specification 3. 11.4 have been exceeded. If such is the case, prepare and submit to the Commission within 30 days, pursuant to Specification 6. 9. 2, a Special Report that defines the cor rective action to be taken to reduce subsequent releases to prevent recur-rence of exceeding the above limits and includes the schedule for achieving conformance wi h he above limits. This Special Report,

. Z2+B(C d- s defined in 10 CFR 20. shall include an analysis that st>mates e.ra sa son exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that, includes the release(s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations. If the estimated dose(s) exceeds the above limits, and if the release condition result-ing in violation of 40 CFR Part 190 has not already been corrected, the Special Report shall include a request for a variance in accor-dance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

b. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE UIREMENTS 4.11.4.1 Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with Specifications 4.11.1.2, 4.11.2.2, and 4.11.2.3, and in accordance with the methodology and parameters in the ODCM.

4. 11. 4.2 Cumulative dose contributions from direct adiat from the units and the methodology used shall be indicated in the SeneanauQ Radioactive Effluent Release Report. This requirement is applica e on y under conditions set forth in ACTION a. of Specification 3.11.4.

TURKEY POINT UNITS 3 E 4 3/4 11-18 AMENDMENT NOS337 AND 132

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5.0 DESIGN FEATURES

5. 1 SITE EXCLUSION AREA 5.1.1 The Exclusion Area shall be as shown in Figure 5.1-1.

LOW POPULATION 20NE

5. 1.2 The Low Population 7one shall be as shown in Figure 5. 1-1.

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MAP DEFINING UNRESTRICTED AREAS AND SITE BOUNDARY FOR RADIOACTIVE GASEOUS AND L U U N 5.1.3 Information regarding radioactive gaseous and liquid effluents, which will al'low identification of tructures and release oint 11 be as shown in Figure 5.1"2. U RiSTIIICTED AREA SITE BOUNDARY 4k&

EH shall be as own sn Figure 5. 1-1.

5. 2 CONTAINMENT a.n.d CONFIGURATION 5.2.1 The con'tainment building is a steel-lined, reinforced concrete building of cylindrical shape, with a dome roof and having the following design features:
a. Nominal inside diameter = 116 feet.
b. Nominal inside height = 170.5 feet.
c. Minimum thickness of concrete walls = 3.75 feet.
d. Minimum thickness of concrete roof = 3.25 feet.
e. Minimum thickness of concrete floor pad = 10.5 feet.
f. Nominal thickness of steel liner = 0.25 inches.
g. Nominal net free volume = 1 550 000 cubic feet.

DESIGN PRESSURE AND TEMPERATURE 5.2.2 The containment building is designed and shall be maintained for a maximum internal pressure of 59 psig and a temperature of 283'F. The con-tainment building is also structurally designed to withstaMn an internal vacuum of 2.5 psig.

TURKEY POINT - UNITS 3 8 4 S-1 AMENDMENT NOS.137 AND I3-

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TURKEY POINT - UNITS 3 8 4 5-2 NENDHENT NOS.137 AND 132

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AOMINISTRAT I YE CONTROLS STARTUP REPORT (Continued),

The report shall address each of the tests identified in the FSAR and shall in general include a description of the measured values of the operating conditions of characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional speci fic details required in license conditions based on other commitments shall be included in this report. Subsequent Startup Reports shall address startup tests that are necessary to demonstrate the acceptability of changes and/or modifications.

Startup Reports shall be submitted within: (I) 90 days following completion of the Startup Test Program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover all three events (i.e., initial criticality, completion of Startup Test Program, and resumption or commencement of commercial operation), supplementary reports shall be submitted at least every 3 months until all three events have been completed.

ANNUAL REPORTS*

Fol laJkowh ~~y~ 'pot"t %$ 4JcLs Y"6+44l ~4 6.9.1.2 Annual Reports covering the activities of th unit as described below for the previous calendar year shall be submitted pri r to March 1 of each ear.

Reports required on an annual basis shall includ away) +leep desw

a. A tabulation on an annual basis of the numb r of statio utility and other personnel (including contractors) receiving exposures greater than 100 mrem/yr and their associated man-rem exposure according to work and job functions*" (e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling).

The dose assignments to various duty functions may be estimated based on pocket dosimeter, thermoluminescent dosimeter (TLO), or film dec.p badge measurements. Small exposures totalling less than 20K of the Ote $ g individual total dose need not be acc nted for. In t.'he aggregate, at least 80K of the total received from external

<qadi u a. l ewer sources should be assigned to speci ic major work functions;

b. The results of specific activity analyses in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded

{in graphic and tabular forma0); (2) Fuel burnup by core region; (3) Clean-up flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) History of degassing operations, if any, starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prio~ to the first sample in which the limit was exceeded; and (5) The time duration when the specific activity of the primary coolant exceeded 1.0 microcurie per gram OOSE EQUIVALENT I-131.

~g t t y p d f itipi it ti . Tp p i << i should combine those sections that are common to all units at the station.

.""This tabulation supplements the requirements of 5 20. of 10 CFR Part 20.

POINT - UNITS 3 8 4 6-16 2.2.~t'URKEY NDMENT NOS337 ANO 132

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ADMINISTRATIVE CONTROLS ANNUAL RADIOACT EFFLUENT RELEASE REPORT" m A~tftdL.

6.9. 1.S > Radioactive Ef 1 nt Release Reporecovering the operation of the unit during the previous +months of operation shall be submitted of each year.

p ) Q A nsee] Radioactive Effluent Release Report@shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix 8 thereof. For solid wastes, the format for Table 3 in Appendix 8 shall be supplemented with three additional categories: class of solid wastes (as defined by 10 'CFR Part 61),

type of container (e.g., strong tight package, Type A, Type B) and LIDIFICATION agent or absorbent (e.g., cement).

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Th~il i i Eff1 R1 Rp t t t it d of each year shall include an annual summary o hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured),

or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability."" This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar yqar. This same report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY {Figure 5.1-1) during the'report period. All assump-tions used in making these assessments, i.e., specific activity, exposure time, and location, shall be included in these reports. The meteorological condi-tions concurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, sha'll be used for determining the gaseous pathway doses. Approximate and conservative methods may be used in lieu of actual meteorological measurements. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

sing e su mittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

""In lieu of submission with the Semi+nn~ Radioactive Effluent Release Report, the licensee has the op ion o retaining this summary of required meteorological data on site in a fi e that shall be provided to the NRC upon request.

TURKEY POINT - UNITS 3 E 4 6" 18 AMENDMENT NOS 137 AN0132

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AOMINISTRATI VE CONTROLS NNUAL RAOIOACTIVE EFFLUENT RELEASE REPORT (Continued) Apv)'1 he 'adioactive of each Effluent Release Report to be submitte withe year shall also include an assessment o ra >a-lon oses o e y most exposed MEMBER OF THE PUBLIC from reactor releases from the previous calendar year and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to show conformance with 40 CFR Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operation." Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are iven in Regulatory Guide 1. 109, Revision 1, October 1977.

A~~< The miennue1 Radioactive Effluent Release Reportgshall include a list and descrip son o unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the report-ing period.

Th 5esnanau st Radioactive Effluent Release Report@shall include any c anges the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE DOSE CALCULATION MANUAL (ODCM), pursuant to Specifica-tions 6. 13 and 6. 14, respectively, as well as any major change to Liquid, Gaseous, or Solid Radwaste Treatment Systems pursuant to Specification 6.15.

It shall also include a listing of new locations for dose calculations and/or environmental monitoring identified by the Land Use Census pursuant to Specifi-cation 3.12.2.

The 5e~baaaual Radioactive Effluent Release Report@shall also include'the following: an exp anation as to why the inoperability of liquid or gaseous effluent monitoring instrumentation was not corrected within the time specified in Specification 3. 3.3. 5 or 3. 3. 3.6, r'espectively; and description of the events leading to liquid holdup tanks or gas storage tanks exceeding the limits of Specification 3. 11. 1.4 or 3. 11.2.6 MONTHLY OPERATING REPORTS

6. 9. 1. 5 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or safety valves, shall be sub-mitted on a monthly basis to the U.S, Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC, no later than the 15th of each month following the calendar month covered by the report.

PEAKING FACTOR LIMIT REPORT 6.9. 1.6 The W(Z) function(s) for Base-Load Operation corresponding to a iZX band about the target flux difference and/or a i3X band about the target flux difference, the Load-Follow function FZ(Z) and the augmented surveillance turnon power fraction, PT, shall be provided to the U.S. Nuclear Regulatory Commission, whenever PT is <1.0. In the event, the option of Baseload Operation (as defined in Section 4.2.2.3) will not be exercised, the submission of the W(Z) function is not required. Should these values (i.e., W(Z), FZ(Z) and pT) change requiring a new submittal or an amended submittal to the Peaking TURKEY PO.'NT - UN:TS 3 8 4 6-19 AM NOMENT NQ5.137 ANO 132

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ADMINISTRATIVE CONTROLS RADIATION PROTECTION PROGRAM Continued) maintained, and adhered to for all ope t s involvi rsonnel radiation exposure. mv-e~('gv' ~q P~ e~ tZ >w,)

6.12 HIGH RADIATION AREA, lQo )(c.) .teat (g.)

6.12.1 Pursuant to paragraph 20. of 0 CFR Part 20 lieu of the "control device" or 'alarm signal requ red by paraqraph 20. 03 c each high radiation area, as defined in 10 CF P rt 20 i >c the in enssty of radia-tion is equal to or less than 1000 from the radiation source or from any surface which t e ra sa on pene ra es shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shali be controlled by requiring issuance of a Radiation York Permit (NP). Indi-viduals qualified in radiation protection procedures (e.g., Health Physics Technician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their h 10 ~

assigned duties in high radiation areas with exposure rates equal to or less provided they are otherwise following plant radiation protec-tion procedures for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

/

mm~/k< a. A radiation monitoring device which continuously indicates the radiation dose rate in the area; or

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been estab-lished and personnel have been made knowledgeable of them; or An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for pro-viding positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Health Physics Shift Supervisor in the IMP.

6.12. 2 In addition to the requirements of Specification 6.12.1 bi t p 1 fth df ti I 1 g t th from the radiation source or from any surface which the r lalO~ o pene r es shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the stdft supervisor on duty and/or health physics supervision. Ooors shall remain locked except during periods of access by personnel under an approved NP which shall specify the dose rate levels in the iaeediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection proce-dures to provide positive exposure control over the activities being performed within the area.

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AOHINISTRATIYE CONTROLS HIGH RADIATION AREA Continued)

For individual high radiatio r as accessible to personnel with radia-tion levels of greater than 100 that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

6. 13 PROCESS CONTROL PROGRAM PCP)
6. 13. 1 The PCP shall be reviewed by the PNSC prior to implementation.
6. 13.2 Licensee-initiated changes to the PCP: A~iAcL i
a. Shall be submitted to the Commission in the Ma4a~w Radioactive Effluent Release Report for the period in whse e c ange(s) was made. This submittal shall contain:

(1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information; (2) A determination that the change did not reduce the overall conformance of the solidified waste product to existing crite-ria for solid wastes; and (3) Documentation of the fact that the change has been reviewe'd and found acceptable by the PNSC.

b. Shall become effective upon review and acceptance by the PNSC, 6.14 OFFSITE DOSE CALCULATION MANUAL OOCM 6.14.1 The OOCM shall be approved by the Commission prior to implementation.
6. 14.2 Licensee-initiated changes to the OOCM: A~~ua. t
a. Shall be submitted to the Commission in the 1 Radioactive Effluent Release Report for the period in whic t e c ange(s) was made effective. This submittal shall contain:

(1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information. Information submitted should consist of a package of those pages of the OOCM to be changed with each page numbered, dated and containing the revision number, together with appropriate analyses or evaluations justifying the change(s);

TURKEY POINT - UNITS 3 6 4 6-23 AMENDMENT NOS. 137AND 132

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(2) A determination that the change wi 11 not reduce the accuracy or reliability of dose calculations or Setpoint determinations; and (3) Documentation of the fact that the change has been reviewed and found acceptable by the PNSC.

b. Shall become effective upon review and acceptance by the PHSC.
6. 15 MAJOR CHANGES TO LI UID GASEOUS ANO SOLID RAOWASTE TREATMENT SYSTEMS"
6. 15. 1 Licensee-initiated major changes to the Radwas T ent Systems

{liquid, gaseous, and solid): A~~ 1

a. Shall be reported to the Commission in the Seariatvwel Radioactive Effluent Release Report for the period in whic e evaluation was reviewed by the PNSC. The discussion of each change shall contain; (1) A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; (2) Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information; (3) A detailed description of the equipment, components, and processes involved and the interfaces with other plant systems; (4) An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously pre-dicted in the License application and amendments thereto; (5) An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the License application and amendments thereto;

{6) A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the change is to be made;

{7) An estimate of the exposure to plant operating personnel as a result of the change; and (8) Documentation of the fact that the change was reviewed and found acceptable by the PNSC.

b. Shall become effective upon review and acceptance by the PHSC.

Licensees may choose to submit the information called for in this Specifica-tion as part of the annual FSAR update TURKEY POINT - UNITS 3 8 4 6-24 AMEHOMEHT HOS. 137AHO 132

C 3/4. 11 RADIOACTIVE EFFLUENTS BASES 3/4. 11.1 LI UID EFFLUENTS 3/4. 11. 1. 1 CONCENTRATION specification is provided to ensure that the concentration of r 'o-active mate 'eleased in liquid waste effluents to UNRESTRICTE S will be less than the c tration levels specified in 10 CFR P , Appendix 8, Table II, Column 2. This 'tation provides additio ssurance that the levels of radioactive materials odies of w in UNRESTRICTED AREAS will result in exposures within: (1) the o ves of Appendix I, 10 CFR Part 50, to a MEMBER population.

OF THE based upon the assu The concentra

'mit PUBLIC, and (2 that e limits for dissolved o CFR Part 20. 106(e) to the Xe-135 is the controlling ra ained noble gases is otope and its MPC in air b rsion) was converted to an equivalent concentrati 'ater using ethods described in International Commission on Radiological

't (ICRP) Publication 2.

This specification applies to the release of radioactive materials in liquid effluents from all u th site.

><sea.w A (Hap.g) equire e ec ion cap s for radioactive materials in waste sample tabulated in terms of the lower limits ' of on (LLDs).

Detailed discussion e LLD, and other detectio s can be found in Curr ie, L. A., "Lower Limit tectio nition and Elaboration of a Hartwel 1, Proposed Position for Radiolo NUREG/CR-4077 (Se t ic Richfield 84), in HASL Pro and Environmental Measurements,"

Detection Limits for 'gadioana1ytsc es Manual, HASL-300 and in Hanford Company Report ARH-SA-215 (June nt~sng echniques,"

3/4. 11. 1. 2 DOSE IQsCR.w 3 (HCae3 This specification is provi e to implement the requirements of Appendix I, 10 CFR Part 50. The Limiting Condition for Operation implements the guides set forth in Appendix I. The ACTION statements provide the required operat-ing flexibility and at the same time implement the guides set forth in Appendix I to assure that the re'ieases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achiev-able. " The dose calculation methodology and parameters in the ODCM implement the requirements in Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models 'and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1. 109, "Calculation of Annual Doses to Man from 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.

TURKEY POINT - UNITS 3 8 4 B 3/4 11-1 AMENDMENT NOS.137 AND 132

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L-93-154 INSERT I 3 4.11 RADIOACTIVE EFFLUENTS BASES INTRODUCTION The radioactive effluent controls set forth in the Technical Specifications are designed to allow operational flexibility but still maintain releases and doses "as low as is reasonably achievable"; that is, within the objectives of Appendix I, 10 CFR Part 50 and comply with the limits in 10 CFR 20.1302.

The methods specified in the OFFSITE DOSE CALCULATION MANUAL (ODCM) for calculating doses due to planned or actual releases are consistent with the guidance and methods provided in:

Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Puzpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

Revision 1, October 1977.

Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977.

Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I, " April 1977.

The required detection capabilities for radioactive materials in liquid and gaseous waste samples are tabulated in terms of the lower limits of detection (LDDs). Detailed discussion of the LLD, and other detection limits, can be found in Currie, L. A., "Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements," NUREG/CR-4077 (September 1984), in HASL Pzocedures Manual, HASL-300 and in Hartwell, J. K., "Detection Limits for Radioanalytical Counting Techniques, "

Atlantic Richfield Hanfozd Company Report ARH-SA-215 (June 1975).

L-93-154 INSERT 2 The specification of "10 times the concentration levels specified in 10 CFR Part 20, Appendix B, Table 2,,Column 2" provides the datum against which the liquid effluent monitor setpoints are determined pursuant to Specification 3.3.3.5. In essence, Specification 3.11.1.1 is an instantaneous limits The concentration limit for "dissolved or entrained noble gases" is based upon the assumption that Xe-135 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

Adherence to Specifications 3.11.1.2 and 3.11.1.3 provide assurance that levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will, on the average, be a small fraction of the concentration limits and result in exposures to MEMBERS QF THE PUBLIC within the objectives of Appendix I of 10 CFR Part 50 and 40 CFR 190.

Specification 3.11.1.1 permits the flexibility of operation, compatible with considerations of health and safety, to provide a dependable source of power even under circumstances that temporarily result in elevated releases, but still in 10 CFR Part 20.1302 (b) (2) (ii) .

within the limit as specified

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RADIOACTIVE EFFLUENTS a ta< p p.~~~~ s BASES DOSE {Continued)

This specification applies to the release of radioactive materials in liquid effluents from each unit at the site. For units with shared Radwaste Systems, the liquid effluents from the shared system are to be proportional among the units sharing that system.

3/4. 11. 1.3 LI UID RADWASTE TREATMENT SYSTEM 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 requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as

>q,is reasonably, achievable." This specification implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the objectives given in Section II. D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Appendix I, 10 CFR Part 50 for liquid effluents.

This specification applies to the release of radioactive materials in liquid effluents from each unit at the site. For units with shared Radwaste Systems, the liquid effluents from the shared system are to be proportioned among the units sharing that system.

TURKEY POINT - UNITS 3 8 B 3/4 11-2 AMENDMFNT NOS. 137AND 132

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RADIOACTIVE EFFLUENTS BASES 3/4. 11.2 GASEOUS EFFLUENTS 3/4. 11. 2. 1 DOSE RATE is specification is provided to ensure that the dose at any time at beyond t SITE BOUNDARY from gaseous effluents from all units on the si will be with'he annual dose limits of 10 CFR Part 20 to UNRESTRIC AREAS, The annual dose 'mits are the doses associated with the concent ions of 10 CFR Part 20, App ix B, Table II, Column I. These limit ovide reason-able assurance that ra 'ctive material discharged in ga not resu'It in the exposure either within or outside the a MEMBER OF THE PUBLIC BOUNDARY, to an

'n us effluents will UNRESTRICTED AREA, average concentrations exceeding the limits specified in endix B, le II of 10 CFR Part 20 (10 CFR Part 20. 106(b)). For MEMBERS OF P' who may at times be within the SITE BOUNDARY, the occupancy of th MBER OF THE PUBLIC will usually be sufficiently low to compensate for y incre in the atmospheric diffusion factor above that for the SITE 0 NDARY. Examp of calculations for such MEMBERS OF THE PUBLIC, wit e appropriate occupan factors, shall be given in the ODCM. The speci 'ed release rate limits restri at all times, the corresponding gamma d beta dose rates above background t MEMBER OF THE PUBLIC at or be d the SITE BOUNDARY to less than or equal to 0 mrems/year to the whol ody or to less than or equal to 3000 mrems/year to skin.

These re ase rate limits also restrict, at all times, the correspon dose rate above background to a child via the inhalation pathway 'hyr 1 s than or equal to 1500 mrems/year.

This specification applies to the release of radioactive materials in gaseous effluents from all u i at t

+ ( t4cRcg s'M5&ww equired det c i n ap radioactive material in waste samp e tabulated in terms of the lower limits ' of on (LLDs).

Detailed discussion LLD, and other detectio s can be found in Currie, L. A., "Lower Limit ' tectio > nition and Elaboration of a Proposed Position for Radiolo and Environmental Measurements,"

NUREG/CR-4077 (Se t b 84), in HASL Pro s Manual, HASL-300 and in Hartwel1 ., Oetection Limits for Radioana'lytica ti~ng echniqoes,"

ic Richfield Hanford Company Report ARH-SA-215 (June 3/4.11.2.2 DOSE - NOBLE GAS i~sr rz.w > (H<ae)

This specification p mp en the requirements of Appendix I, 10 CFR Part 50. The Limiting Condition for Operation implements the guides set forth in Appendix I. The ACTION statements provide the required operat-ing flexibility and at the same time implement the guides set forth in Appendix I to assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially under-estimated. The dose calculation methodology and parameters established TURKEY POINT - UNITS 3 8 4 B 3/4 11-3 AMENDMENT NOS.137 AND132

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'-93-154 Attachment 3 INSERT 4 The specified gamma and beta dose rates, above background, provides the datum against which the gaseous effluent monitor setpoints are determined, using the methods described in the ODCM, pursuant to Specification 3.3.3.6. In essence, Specification 3.11.2.1 is an instantaneous limit.

Adherence to Specifications 3.11.2.2 through 3.11.2.5 provide assurance that levels of radioactive materials in aiz in UNRESTRICTED AREAS will, on the average, be a small fraction of the concentration limits and result in exposures to MEMBERS OF THE PUBLIC within the objectives of Appendix I to 10 CFR Part 50 and 40 CFR 190.

Specification 3.11.'2.1 permits the flexibility of operation, compatible with considerations of health and safety, to provide a dependable source of power even under circumstances that temporazily result in elevated releases, but still in 10 CFR Part 20.1302 (b)(2) (ii) .

within the limit as specified

1 RADIOACTIVE EFFLUENTS

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BASES DOSE-NOBLE GASES {Continued) in the OOCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are 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 for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977. The ODCM equations provided for determining the air doses at and beyond the SITE BOUNDARY are based upon the historical average atmospheric conditions.

This specification applies to the release of radioactive materials in gaseous effluents from each unit at the site. For units with shared radwaste treatment systems, the gaseous effluents from the shared system are proportioned among the units sharing that system.

3/4. 11. 2. 3 DOSE - IODINE-131 IODINE-133 TRITIUM AND RADIOACTIVE MATERIAL N A GULA M x~s<ew c. (Heaeg This spec'ification is provide to >mplemen e requirements of Appendix I, 10 CFR Part 50. The Limiting Conditions for Operation are the guides set forth in Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Appendix I

,to assure that the releases of radioactive materials in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the Surveillance Requirements implement the requirements in Appendix I that conformance with the guides of Appendix I be shown by calculational'procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1. 109, "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 l. 111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light"Water-Cooled Reactors," Revision 1, July 1977. These equa-tions also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate specifications for Iodine-131, Iodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days are dependent upon the existing radionuclide pathways to man in the areas at and beyond the SITE BOUNDARY. .The pathways that were examined in the development of the calculations were: (1) individual inhala-tion 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.

TURKEY POINT - UNITS 3 8 4 B 3/4 11-4 AMENDMENT NOS137 AND 132

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RADIOACTIVE EFF LUENTS BASES DOSE - IODINE-133 TRITIUM AND RADIOACTIVE MATERIAL IN PARTICULATE FORM ont>nued This specification applies to the release of radioactive materials in gaseous effluents from each unit at the site. For units with shared radwaste treatment systems, the gaseous effluents from the shared system are proportioned among the units sharing that system.

3/4. 11.2.4 GASEOUS RADWASTE TREATMENT SYSTEM The OPERABILITY of the GAS DECAY TANK SYSTEM and the VENTILATION EXHAUST TREATMENT SYSTEM ensures that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used, when speci fied, 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 50. 36a, General Design THE% Criterion 60 of Appendix A to 10 CFR Part 50 and the objectives given in

'p~g~g~gection II.D of Appendix I to 10 CFR Part 50. The specified limits governing

%he use of appropriate portions of the systems were specified as a suitable fraction of the dose objectives set forth in Appendix I, 10 CFR Part 50, for gaseous effluents.

This specification applies to the release of radioactive materials in gaseous effluents from each unit at the site. For units with shared radwaste treatment systems, the gaseous effluents from the shared system are proportioned among the units sharing that system.

TURKEY POINT - UNITS 3 8 4 8 3/4 11-5 AMENDMENT NOS.137 AND 132

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I RAD IOACT VE EF F LUENTS BASES 3/4. 11.2.5 EXPLOSIVE GAS MIXTURE This specification is provided to ensure that the concentration of poten-tially explosive gas mixtures contained in the GAS DECAY TANK SYSTEM (as measured in the inservice gas decay tank) is maintained below the flammability limits of hydrogen and oxygen. Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50.

3/4 11.2.6 GAS DECAY TANKS The tanks included in this specification are those tanks for which the quantity of radioactivity contained is not limited directly or indirectly by another Technical Specification. Restricting the quantity of radioactivity contained in each Gas Decay Tank provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting whole body exposure to a MEMBER OF THE PUBLIC at the nearest SITE BOUNDARY will not exceed 0.5 rem.

3/4. 11. 3 SOLID RADIOACTIVE MASTES This specification implements the requirements of 10 CFR 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50. The process parameters included in establishing the PROCESS CONTROL PROGRAM may include, but are not limited to, waste type, waste pH, waste/liquid/SOLIDIFICATION agent/catalyst ratios, waste oil content, waste principal chemical constituents, and mixing and curing times, These requirements apply to dewatering to meet the requirements of the licensed consignee of the shipment.

3/4. 11. 4 TOTAL DOSE go. t3o( (4)

This specification is provided to meet the Part 190 that have been incorporated into 10 CFR d se l' 's CFR The specification requires the preparation and submitta of a Special Report when-ever the calculated doses due to releases of radioactivity and to radiation from uranium fuel cycle sources exceed 25 mrems to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems. For sites containing up to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190

.if the individual reactors remain within twice the dose design objectives of Appendix I, and if di rect radiation doses from the units are kept small. The TURKEY POINT - UNITS 3 8 4 B 3/4 11-6 AMENDMENT N05.1 37 AND 1 32

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Special Report will describe a course of action that should result in the limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits. For the purposes of the Special Report, it may be assumed that the dose commitment to the MEMBER of the PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 8 km must be considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part 190 have not already been c ted), in accordance with the proves>ons of 40 CFR 190. 11 and 10 CFR 20. is considered to be a timely request and fulfills the requirements of 40 R Part 190 until NRC staff action is completed. The variance only relates to the limits of 40 CFR Part 190, and does not apply in any way to the other requ rements for dose limitation of 10 CFR Part 20, as addressed in Specificati ns 3.11.1.1 and 3.11.2.1. An individual is not considered a MEMBER OF TH PUBLIC during any peri od in whi ch he/she is engaged in car rying out any opera ion that is part of the nuclear fuel cycle.

~ ZZc 3 TURKEY POINT - UNITS 3 8 4 8 3/4 11-7 AMENDMENT NOS,137 AND 132

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