ML18030B051

Proposed Tech Specs Changing Requirements for Taking Milk Samples from Four to Three Farms

ML18030B051
Person / Time
Site:	Browns Ferry
Issue date:	01/30/1986
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18030B050	List: ML18030B049 ML18030B051
References
TAC-60679, TAC-60680, TAC-60681, NUDOCS 8602100086
Download: ML18030B051 (24)

Text

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20-

3. Tcrres tria1 >fonitorin

a. Soil shall be collected at least once every three years from en area near the atmospheric monitors mentioned in paragraph 4.2.1.a, ao indlcoted in Table 4.2-1 and Figures 4.2-1 and 4.2-2. Each aample sha11 be analyzed for at least 10 gamma-emitting radio-nuclides, ~Sr and Sr.

b. Hilk shall be collected monthly when animals are off pasture, from at least (3) farms in the vicinity of the plant and analyzed as indi.cated in Table 4.2-1 and Figure 4.2-1.

During the seasons that animals producing milk for human consumption are on pasture, samples of fresh milk wiU. be obtained* from these animals at representative locations that may be significantly affected by emissions from the Brovns Ferry Nuclear plane, and analyzed for their radioiodine content, calculated as iodine-131.

Analysis vill be carried out within eignt days (one I-1'31 halE life) of sampling. Suitable analytical procedures will bc used to determine the radioiodine concentration to a sensitivity of 1.5 picocurie per liter of milk at the tire of sampling. For activity levels et or above 1.5 picocurie per liter, overall error of tbe analysis wi11 be within +25Z. Results will bc reported as picocuries of 7-131 per iiter of milk at the tire of sampling, in accordance wirh Reporting Requirements Eor Environmental Radiological Monitoring.

Zf the census of animals producing milk for human consumption indicates th"= an animal exists in an area where the calculated dose is >45 mrem/yr (for the site) and the owner of the animal will not sell the milk to TVA for analysis, green leafy vegetables or other vege-tation will be obtained from that location for analysis for I-131. The analysis and subsequent calculations will determine the dose to the individuals consuming the mi~k.

A cersus o en'"als producing nU.k for human consumption shall be conducted et the beZin" ng and at the middie uf the grazing season to deter ire the'r location and number with respect to the site.

The census sheii be conducted under the folio"ing conditions.

1. ti'ithin a 1-m'le rad'us Ero= the plant site cr within tbe 45 mrem/yr isodose line (for the three reactors onsite), whichever is larger, enumeration by a door-to-door or equivalent counting technique.

2. '-'.:.in T.1w'i C 5-m"~ r- t-s - cows r. Eor goa"s, "n -aration oy usirg referenced in&rmaticn fro" county agridultural agercs or other re'iable sources.

>'ilk s maples will be co11cc ed end analyzed meekly in Q eas g+ere calculated dose to a chi1d's thyroid exceecs 15 mrem/year/reactor.

Sampling and analysis will be conducted semimonthly in areas where the dose is calculated to be <15 nrem/year reactor. The calculational model as published in Regulatory Guide 1.109 and Regulatory Guide 1.111 shall be used.

8602100086 860130 PDR ADOCN 05000259 P PDR

If it is learned fiom this census that animals are present at a location which yields a calculated thyroid dose greater than Ezom previously sampled animals, the new location shall be added to the surveillance program as soon as. practicable if the farmer is willing to participate in the pxogram. The sampling location having the lowest calculated dose may then be dropped from the surveillance program at the end of the grazing season during which the census was conducted. Also any location from which milk can no longer be obtained may be dropped fzom the surveillance program. The HRC shall be notified in writing that milk-producing animals are no longer present at that location. An additional milk sampling location will then be added to the program, with sampling frequency baaed on calculated ides dose.

c..Vegetation shall be collected at least quarterly from at least 3 of the farms mentioned in the preceding paragraph (see Figure 4.2-1) .

Each sample is analyzed for at least ten specific gamma-emitting radionuc1 .

d.: Food crops shall be collected annually within a 10-mile zadius.

Type and number of samples will vazy according to availab'lity (See Subsection 4.2.4).

e. Wall water is collected automatically and analyzed monthly from the well most likely to be affected by the plant. (See Table 4.2-1 and Figure 4.2-1) A well remote Erom the plant ls sampled monthly as a background. The samples shell be analyzed for at least ten gaauna-emi t ting radionuclides.

f. Samples of potable surface water supplies shaLl be collected monthly from the locations in Table 4.2-4. The samples shall be analyzed Eor tritium, and at least ten speciEic gamma-emitting zadionuclides.

4. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditio is, seasonal unavailability or to malfunction of automatic sampling equipment. IE the latter, every effort shall be made to complete corrective action prior to the end of the next sampl'ng period. All deviations Ezom the sampling schedule shall be described in the annual report.

Bases ope ational envizonmental monitoring progr.im is based upon a which is described in Section 2.6 of the FSAR. Sample collection preoperationa'zogz'am and analysis were initiated in ApriL 1968, and will continue indefinitely.

Evaluations after plant startup will be made on the basis of baselines, con-sidering geography and tMe of year where these factors are applicable, and by compaz'isons to control stat'ons where the concentration of station effluents is expected to be negligible.

The reference samples provide a running background which wCLL make to distinguish significant radioactivity introduced into the environment by it possible the operation of the station from that introduced by nuclear detonations and other sources.

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Table 4.2-1 (Continued)

Exposure Pathway Number of Samples Sampling and Type and Frequency and/or Sam le and Locations Collection Fre uenc of Anal sis 131 3 samples from dairy farms Meekly or semimonthly (vhen I analysis veekly o in the immediate vicinity animals arc on pasture) semimonthly vhen cattle of the plant depend'ng on calculated are on pasture doses.<< Monthly vhen animals a .-

off pasture.

1 sample from control Ganrna scan, Sr, and Sr location monthly Fish 1 sample each of a corrmercial and & game species in Guntersville Reservoir above the plant 1 sample each of a conrnrercial Semiannually Gamma scan semiannually.

and & game species in Wheeler Reservoir near the plant 1 sample each of a commercial and a game species in Wilson Reservoir belov the plant i

Ve get at on 3 samples from the dairy Quarterly Canna scan, (Pasturage farms from vhich milk is and Grass) obtained

<<Milk samples viU. be collected and analyzed vee/1y in areas vhere the calculated dose toa chil)'s thyroid exceeds 15 mrem/year. Sampling and analysis vill be conducted semimonthly in areas vhere the dose is calculated to be cl5 mrern/year.

TAELE 4.2-5 Detection Capabilities for Environmental Sam le hnalysis I

hominal Lower Limit of Detection (LLD)

Airborne Particulate Fish, Heat,

~Anal nln Mater

~CI/I or Ga]

Ci/m <Cr* 60 .07 200 240 IslZ 15* . Ol* 50>> an a 70>>

iooRu* 30 .04 150 150 LsIICs>> 10 .Ql 40 50

>svC

• 10 01 40

~ 10 50 120

" 2r-Nb>> 10 .Ol 40 50 soC 15 .02 55 . 70 s Hn* 10 .02 40 5Q osZn>> 15 .02 70 75 Co* 10 .'Ol 30 40 II OK>>

100 .10 400 500 ooa-La>> 15 .02 150 15 145 nnsn 10 .OQ5 10 "Sr 2 . 001 150 These measurements are performed by gamma spectroscopy. The LLD values are calculated the method of pastcrnack ard Harlcy as discussed in HASL-300. The original method was published in Hucl. Instr. byHcthods 91, 533-40 (1971).

Th se LLD values are expected to vary depending the activities of components in thc samples. These figures will be rarely, if ever, attainable. Mater is counted in a 3.5 liter Harinelli 'ocaker. Vegetation is counted in a 1-pint container as dry weight, then corrected to wet weight using an average moisture conrent of 807; Average dry weight is 125 grams. Fish, meat, and poultry are counted in a I-pint contairer as dry weight, then corrected to wet weight using an average moisture content of 707.. Average dry weight is 250 grams. Air Particulate Filters are counted in a well crystal. Thc counting system consists of a multichannel analyzer and cithcr a 4" 4" ~>id hal crystal or a 4 II x 5 I Hal well crystal. The counting time is 4,000 seconds.

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All calculations nrc performed by

.r program ALPIIA-H Thc assumption is made that ail samples arc analy=cd within .'omp o col'ccticn.

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LOCA% MONITORING SECTIONS BROWNS FERRY NUCLEAR PLANT Figure 4:2-1 ATHENS US HWY 72 BFN ALA. HWY 20 Legend 0 Air Monitor DECATUR 6 Air Monitor 8 TLD Station N TLD Station A AUtomatic Well Sampler Scale H Dairy Farm 0 I 2 3 4 5 Miles

PROPOSED CHANGES UNIT 2

20-

3. Tczrcs trial Honi. torin

a. Soil shall be collected at least once every three years fzpm an area near the atmospheric monitors mentioned in paragraph 4.2.3..a, ao indicated in Table 4.2-1 and Figures 4.2-1 and 4.2-2. Each eample shall be ana3.yaed foz nt least 10 gamma-emitting zadio-nuclides, Sr and Sr.

b. Milk shall be collected monthly when animals are off pasture, from at, least (3) farms in the vicinity of the plant and analyzed as indicated in Table 4.2-1 and.,Figure 4.2-1.

During, the seasons that animals producing milk for human consumption aze on pasture, samples of fresh milk wiU. be obtained* from these animals at representative locations that may be significantly affected by emissions from the Brovns 'Ferry Nuclear plant, and analyzed for their radioiodine content, calcuLated as iodine-131.

Analysis vill be carried out within eight days (one I-l'31 half 1ife) of sampling. Suitable analytical procedures vill be used to determine the radioiodine concentration to a sensitivity of 1.5 picocurie per liter of milk at the time of sampling. Foz activity levels at or above 1.5 picocurie per liter, overall error of the analysis vill be within -252. Results vill be reported as picocuzies of X-131 per liter of milk at the tire of sampling, in accordance with Rnpozting Requirements for Environmental Radiological Nonitoring.

4 lf the census of animals indicates th"= an animal producing milk for exists in an area human consumption where the calculated dose is >45 mrem/yr (for the site) and the owner of the animal vill not sell the milk to TVA for analysis, green leafy vegetables or other vege-tation vill be obtained fzom that location for analysis for I-131. The analysis and subsequent calculation" viii determine the dose to the ind'viduais consuming the cd'k.

A census of an'=ais producing "nQk foz human consumption shall be conducted at th bcZin"~ng and at thc middie of the gracing sc son to deter:iirc their 1ccat on and nunbcr with respect to the site.

The census sheii be conducted under thc follovirq conditions:

1. 4ithin a l-r.ile zad'us fzo= the piant site cr vithin i in tbc 45 mrem/

emyr sodose lane (for the three reactors onsite),

0 whichever is larger, enumeration by a door-to-door or equivalent counting technique.

2 Lit..in - 0-e c za-ius -" c"vs r. fo- g-""s "n"-.-z"--'-~ '

usirg referenced inior':ation fro= county agriduicural agents or other re'abie sources.

<<l'ilk samples viii be co'lec.cd end analyzed vcekly in,areas vhczc calculated dose to a chile,'s thyroid exceeds 15 mrem/year/reactor.

Sampling and analysis will be conducted semimonthly in areas where the dose is calculated to be <15 nrem/year reactor. The calculational model as published in Regulatory Guide 1.109 and Regulatory Guide 1.111 shall be used.

e If it is learned from this census that animals are present at a location which yields a calculated thyroid dose greater than from previously sampled animals, the new location shall be added to the surveillance program as soon as practicable if the farmer is willing to participate in the program. The sampling location having the lowest calculated dose may then be dropped from, the surveillance program at the en'd of the grazing season during which the census was conducted. Also any location from vhich milk can no longer be obtained may be dropped from the surveillance program. The NRC shall be notified in writing that milk-producing animals are no longer present at that location. An additional milk sampling location vill then be added to the program, with sampling frequency based on calculated dose.

c. Vegetation shall be collected at least quarterly from at least 3 of the farms mentioned in the preceding paragraph (see Figure 4.2-1) .

Each sample is analyzed for at least ten specific gamma-emitting radionuclides.

d. Food crops shall be collected annually vithin a aO-mile radius.

Type and number of samples will vary according to: availability (See Subsection 4.2.4).

e

e. Mell water is collected automatically and analyzed'onthly from the well most likely to be affected by the plant. (See Table 4.2-1 and Figure 4.2-1) A veil remote from the plant is sampled monthly as a background. The samples shall be analyzed for at least ten gamma-emi t ting radionuclides.

f. Samples of potable surface water supplies shall be collected monthly from the locations in Table 4.2-4. The samples shall be analyzed for tritium, and at least ten specific gamma>>emitting radionuclides.

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4. Deviations are permitted from the required sampling .,chedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability 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. All deviations from the sampling schedule shal] be desc=ibed in the annual report.

Bases The ope ational environmental monitoring progr.im is based upon a preoperational program vhich is described in Section 2.6 of t'ne FSAR. Sample collection and analysis vere ini.tiated in April 1968, and vill continue indef initely.

Evaluations after plant startup vill be made on the basis of baselines, con-sidering geography and t~ne of year vhere these factors are appl'cable, and by comparisons to control stations where the concentration of station effluents is expected to be negligible.

The reference samples provide a running background vhicn to distinguish significant radioactivity introduced vill make it possible nto tth e environment by uce into the operation of the station f om that introduced byy nuc nuc< ear detonat'oas and other sources.

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Table 4.2-1 (Continued)

Exposure Pathvay Number of Samples Sampling and Type and Frequency and/or Sam le and Locations Collection Fre uenc of Anal sis l

131 3 samples from dairy farms Meekly or semimonthly (vhen I analysis veekly or in the immediate vicinity animals arc on pasture) semimonthly vhen cattle of the plant depend'ng on calculated are on pasture doses."'onthly vhen animals are off pasture.

1 sample from contxol Qasxna scan, ~Sr, and ~ Sr location monthly Fish 1 sample each of a commercial and a game species in Guntersville Reservoir above the plant 1 sample each of a commercial Semiannually Gamma scan semiannually.

and a game species in Mheeler Reservoir near the plant 1

1 sample each of a commercial and a game species in Milson Reservoir balov the plant Vegetation 3 samples from the dairy Quarterly Gamma scan, (Pasturage farms from vhich milk is and Grass) obtained

<<Milk samples vill be collected and analyzed veegly in areas vhere the calculated t chil/'s ose toa a e dose hil thyroid exceeds

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15 mrem/year.

cl5 mrem/year.

Sam p li ng and analysis vil1 be conducted semimonthly in areas vhere ere th e d ose is calculated to be

TABLE 4.2-5 Detecrion Capabilities for Environmental Sam le Analysis hominal Louer Limit of Detection (LLD)

Airborne Parciculate Fish, Heat,

~Anni nln 'CA/I Water or Ga~

Ci/m or Poul.try Hilk

(

Vegetation .

Ci/k wet) (

Soil Ci/k d )

gross beta .01

'H 330 1 IIIICe 30 .03 90 115 s'C

• 60 .07 200 240 1 lII 15* ,01* 50>> I 1

~

C J 70>>

<<<Ru* 30 .04 150 150 Cs>> 10 .01 40 50 L )AC 10 01 40

~ 10 50 120 2r-Nb>> 10 ~ 01 40 '0 I "Co>> O 15 ~ 02 55 . 70 I

'.Hn* 10 .02 40 50 c sZn>> 15 .02 70 75 40C 10 .01 30 40

" K>>

100 .10 400 500 l'oga-La>> 15 .02 150 15 145

~ sS 10 .005 40 10 Sr 2 .001 150 These measurements are performed by gamma spectroscopy. The LLD values are calculated by the method of Pasternack and llarlcy as discussed in HASL-300. The original method uas published in llucl. Instr.

Hcthods 91 533-40 (197 )

Th sc LLD values are expected to vary depending the accivities of components in the sanples. These figures 'will be rarely, if ever, attainable. Water is counted in a 3.5 iiter Marinelli beaker. Vegetation is counted in a 1-pint container as dry ueight, then corrected to wet weight using an average moisture content of 80'I.; Average weight is 125 grams. Fish, ment, and poultry are counted in a 1-pint contaircr as dry ucight, then corrected dry uet >>eight using an average moisture content of 70I. Average dry weight is 250 grams. Air Particulate filtersto are counted in a well crystal. The counting system consists of a multichannel analyzer and ci er a 4" x 4" I>id either haI crystal or a 4 I I x 5 I I llaI ucll crystal. The counting time is 4,000 seconds. All calculations are performedsoliby '.

the least-squares comp .'r program ALPllA H The assumption is nadc that all samples are analy:cd within orc week o'ollection.

~ C LOCAL MONITORING S ACTIONS BROWNS FERRY NUCLEAR PLANT Figure 4;2-1 ATHENS US HWY 72 BFN ALA. HWY 20 Legend 0 Air Monitor DECATUR 6 Air Monitor 8 TLD Station TLD Station AUtomatic Well Sampler Scale H Dairy Farm 0 I 2 S 0 5 Miles

PROPOSED CHANGES UNIT 3

C 20-

3. Tcrrea trial Honitorin

a. Soil shall be collected at least once every three years from an area near the atmospheric monitors mentioned in paragraph 4.2.1.a, aa indicoted in Table 4.2<<1 and Figures 4.2-1 and 4.2-2. Each aample shaU. be analyzed for at lease, 30 gamma-emitting radio-nuclides, 4~Sr and ~ oSr.

b- Nilk shall be collected monthly when animals are off pasture, from at least (3) farms in the vicinity of the plant and analyzed as indicated in Table 4.2-1 and.Figure 4.2-1.

During the seasons that animals producing milk for are on pasture, samples of fresh milk wiU. be h~

obtained*

consumption from these animals at representative locations that may be significantly affected by emf.ssions from the Browns Ferry Nuclear Plane, and analyzed for thei radioiodine content, calculated as iodine-131.

Analysis will be carried out ~ithin eignt days (one I-l'31 halE life) of sampling. Suitable analytical procedures trill be used to determine the radioiodine concentration to a sensitivity of 1.5 picocurie per liter of milk at the time of sampling. For activity 3.evels at or above 1.5 picocurie per liter, overall error of the analysis will be within +25Z. Results will be reported as picocuries of I-131 per liter of milk at the tire of sampling, in accordance with Reporting Requirements for Environmental Radiological i~onitoring.

Xf the census of animals producing milk for human consumption indicates th": an animal exists in an area where 'the calculated dose is >45 mrem/yr (for the site) and the owner of the animal will not sell the milk to TVA for analysis, green leafy vegetables or other vege-tation will be obtained from that location for analysis for E-131. The analysis and subsequent calculations wii.l determine the dose to the ind'viduals consuming the mi'k.

A cer.sus of an'"als producing 'nQ.k for human consumption shall be conducted et th beZin" ~ng and at the q:iddle of the grazing sc-son to deter-ine their iccat'on and nunber kith respect to the site.

The census shall be conducted under the following conditions:

3.. liithin a l-r.'le:ad'us fro= the plant site cr within tbu 45 mrem/yr isodose line (for the three reactors onsite), whichever is larger, enumeration by a door-to-door or equivalent counting technique.

2. ' .n'r.'. )-n e rc-ius -"- c-ws "r.- fo= g ats, "n "aration oy using referenced informa ion fro" county agridulcu'al agents or other re'iable sources.

~3'ilk samples will be colloc ed and analyzed weekly in a"eas uyeru calculated Cosa to a child s thyroid exceecs 35 mrem/year/reactor.

Sampling and analysis will be conducted semimonthly in areas where the dose is calculated to be <15 nrem/year reactor. The calculational model as published in Regulatoiy Guide 1.109 and Regulatory Guide 1.111 shall be used.

~'

If it is Learned from this census that, anim'als are present at a location which yields a calculated thyroid dose greater than from previously sampled animals, the new location shall be added to the surveillance program as soon as practicable if the farmer is willing, participate to in the program. The sampling location having the lowest calculated dose may then be dropped from the surveillance program at the end oE the grazing season during which the census was conducted. Also any location from which milk can no longer be obtained may be dropped from the surveillance program. The HRC shall be notified in writing that milk-producing animals are no longer present at that location. An additional milk sampling location will then be added to the program, with sampling frequency baaed on calculated dose.

c. Vegetation shall be colLected at least quarterly from at least 3 of the farms mentioned in the 'preceding paragraph (see Figure 4.2-1) .

Each sample'is analyzed for at'least ten specific gamma-emitting radionuclides.

d. Food crops shall be collected an'nually ~ithin a 10-mile radius.

Type and number of samples will vary according to availability (See Subsection 4.2.4) .

e. Moll water is collected automatically and analyzed monthly from the well most likely to be affected by the plant. (See Table 4.2-1 and Figure 4.2-1) A well remote Erom the plant is sampled monthly as a background. The samples shall be analyzed for at least ten gamma-emi t ting radionuclides.

f. Samples of potable surface water supplies shall be collected monthly from the locations in Table 4.2-4. The samples shall be analyzed for tritium, and at least ten specific gaszua-emittf.ng radionuclides.

4. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability 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. All deviations fram the sampling schedule shall be desc=ibed in the annual report.

'ases The operational environmental monitoring progr.im is based upon a preoperational program which is described in Section 2.6 oE the FSAR Sample collection, and analysis were initiated in April 1968, and will continue indef inite'.

Evaluations after plant startup will be made on the basis of baselines, con-sidering geography and t&e of year where these factors are appl'cable, and by comparisons to control stations where the concentration of station e ffLuents is expected to be negligible.

The reference samples provide a running background whicn will make to distinguish significant radioactivity introduced into the environment by it possible the operation of the station from that introduced byy nuc nucleear detonations and other sources.

Table 4.2-1 (Continued)

Exposure Pathvay Number of Samples Sampling and Type and Frequency and/or Sam le and Locations Collection Fre uenc of Anal sis 131 3 samples from dairy farms Meekly or semimonthly (vhen I analysis veckly o.

in the immediate vicinity animals arc on pas ture ) semimonthly when cattle of the plant depend'ng on calculated are on pasture doses." Monthly vhen animals are off pasture.

1 sample from control Gamma scan, Sr, and Sr location monthly Fish 1 sample each of a conmercial and a game species in Guntersville Reservoir above-the plant 1 sample each of a commercial Semiannually Gamma scan semiannually.

and a game. species in Mhecler Reservoir near the plant 1 sample each of a'commercial and a game species in Milson Reservoir belov the plant Vegetation 3 samples from the dairy Quarterly Gamma scan, (Pasturage farms from uhich milk is and Grass} obtained

<<Milk samples vill bc collected and analyzed veegly in areas uhcrc the calculated dose toa chU.g's thyroid exceeds 15 mrem/year. Sampling and analysis vill be conducted semimonthly in areas where the dose is calculated to be

<15 urea/year.

TAELE 4.2-5 Detection Capabilities for Environmental Sam le Anal sis hominal Lover Limit of Detection (LLD)

Airborne Porc icula te Fish, Meat, Mater or Ga~ or Poultry Bilk Vegetation . Soil

~Anni nln ~CA/l Ci/m ( Ci/k vet) ( Ci/k d )

gross beta .01

'8 330 1 ~

ICe~ 30 .03 90 115 "Cr* 60 ..07 200 240

'I 10!Z 15* ~ Ql* 500 4 ~

C J

L0CRU4 30 .04 150 150 10 .01 40 50 10 .01 40 10 50 .

120 "Zr-V

• 10 ~ 01 40 50

$ 0C

• 15 .02 55 . 70 0'Mn* 10 .02 40 50 "Zn* 15 .02 70 75 00C

• 10 .Ql 30 40 AA OK* 100 nl0 400 500 "0Da-La~ 15 .02 150 15 145 "Sr lo ,005 10

%0S 2 . 001 150 These measurements are performed by gamma spectroscopy. The LLD values are calculated by the method of pastarnack ard l!arlay as discussed in HASL-300. The original method vas published in Vucl. Instr. Methods 91, 533-4Q (1971).

Th"se LLD values are expected to vary depending the activities of components in the samples. These f.igures vill be rarely, if ever, attainabla, Mater is counted in a 3.5 i iter Marinelli 'oaaker. Vegetation is counted in a 1-pint container as dry weight, then corrected to wet weight using an average moisture co'ntent of 807~. Average dry weight is 125 grams. Fish, meat, and poultry are counted in a 1-pint conrairar as dry vaighc, than corrected to wet weight using an average moisture content of 70'A'. Average dry weight is 250 grams. - Air Particulate Filters are counted in a wall crystal. The counting sy tam consists of a multichannel analyzer and either a 4" x 4" so)id t:aI crystal or a 4" x 5" Hal wall crystal. The counting time is 4,000 seconds. hll calculations ara perforred by '.

the least-squares comp ".'r program Alp!>-M The nssunption is nadarthat all samples ara analy:ad uithin ora vaak o'ollection.

0 e

~ ~ y ~ 1 ~

LOCAL MONITORING S'%T(ONS BROWNS FERRY NUCLEAR PLANT Figure 4;2-1 ATHENS US HWY 72 h

ALA. HV/Y 20 Legend 0 Air Monitor DECATUR O Air Monitor 8 TLD Station TLD Station A AUtomatic Well Sampler Scale H Dairy Farm I 2 3 4 Miles

ENCLOSURE 2 Description and Justification Descri tion of Chan e On pages 20, 21, 35 and 42 of Appendix B Environmental Technical Specifications (ETS) for units 1, 2, and 3,'he requirement to collect milk and vegetation samples from four dairy farms has been changed to require samples from three farms since only three have been identified by the most recent land use survey.

Page 40 of the ETS for units 1, 2, and 3 is changed to correct a typographical error. The nominal lower limit of detection (LLD) for strontium 89 in water should be 10 (pCi/1). The current LLD listed in ETS is 3 (pCi/1) which is an error. The LLD should be the same for water as it is for milk, which has an LLD of 10 (pCi/1).

Reason for Chan e As stated above, the reasons for making these changes are that there are only three dairy farms in the vicinity of the plant, as determined by the most recent land use survey conducted in accordance with ETS section 4.2.3.b and to correct an error in the ETS.

Justification for Chan e The operational environmental monitoring program is based upon a preoperational program which is described in Section 2.6 of the FSAR. The reference samples provide a running background which will make it possible to distinguish significant radioactivity introduced into the environment by the operation of the plant from that introduced by nuclear detonations and other sources. These ETS changes will not result in any changes to, or contradictions of the FSAR and obviously have no effect on nuclear safety, Furthermore, since all available dairy farms in the vicinity of the plant are being monitored, the maximum safety and data collections are achieved in this area of concern.

0054B

ENCLOSURE 3 Determination of No Significant Hazards Consideration Descri tion of Amendment Re uest The proposed amendment would change the technical specifications (TS) of the operating license to require taking milk and vegetation samples from three instead of four dairy farms in the vicinity of the plant. The amendment would also correct an error in the nominal lower limit of detection (LLD) of strontium 89 in water. The correct LLD would be the same as that listed for strontium 89 in milk .

Basis for Pro osed No Si nificant Hazards Considerations Determination The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license for a facility involves no significant hazards considerations if operation of the facility in accordance with a proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated: or (?)

create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

A discussion of these standards as they relate to this amendment follows.

1. The probability of the occurrence or the consequences of an accident previously evaluated in the Final Safety Analysis Report (FSAR) has not been affected since the sampling activities involved in the proposed amendment are not considered in determining the probabilities or consequences of an accident.

2. The proposed amendment would not create the possibility of a new or different kind of accident from any previously evaluated since no equipment changes are involved and no new operational conditions are allowed.

3; The margin of safety is not reduced by the proposed changes since one change only corrects an error and is consistent with other existing technical specifications, and because only three dairy farms have been identified in the vicinity of the plant and all of these will be monitored. Finally the proposed technical specification amendment will still be compatible with the environmental monitoring program described in the FSAR.

Based on the above considerations, TVA proposes to determine that the proposed amendment does not involve a significant hazards consideration.

0054B