ML18141A757

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Safety Evaluation Supporting Amends 97 & 96 to Licenses DPR-32 & DPR-37,respectively
ML18141A757
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Site: Surry  
Issue date: 06/19/1984
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Office of Nuclear Reactor Regulation
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NUDOCS 8406280352
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 97 TO FACILITY OPERATING LICENSE NO. DPR-32 AND AMENDMENT NO. 96 TO FACILITY OPERATING LICENSE NO. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT NOS. *1 AND 2 DOCKET NOS. 50-280 AND 50-281

1.0 INTRODUCTION

To comply with Section V of Appendix I of 10 CFR Part 50, the Virginia Electric and Power Company has filed with the Commission plans and pro-posed technical specifications developed for the purpose of keeping releases of radioactive materials to unrestricted areas during nonnal operations, including expected operational occurrences, as low as is reasonably achievable.

The Virginia Electric and Power Company made application with the Commission by letter dated May 4, 1983, as supplemented September 23, 1983, and January 11 and February 3, 1984, which requested changes to the Technical Specifications appended to Facility Operating License Nos. DPR-32 and DPR-37 for Surry Power Station Unit Nos. 1 and 2.

The proposed Technical Specifications update those portions of the Technical Specifications addressing radioactive waste management and make them consistent with the current staff positions as expressed in NUREG-0472.

These revised Technical Specifications would reasonably assure compliance, in radioactive waste management, with the provisions of 10 CFR Part 50.36a, as supplemented by Appendix I to 10 CFR Part 50, with 10 CFR Parts 20.105(c),

106(g), and 405{c); with 10 CFR Part 50, Appendix A, General Design Criteria 60, 63, and 64; and with 10 CFR Part 50, Appendix B.

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2.0 BACKGROUND

AND DISCUSSION 2.1 Regulations 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities", Section 50. 36a, 11Technical Specifications on Effluents from Nuclear Power Reactors", provides that each license authorizing operation of a nuclear power reactor will include technical specifications that (1) require compliance with applicable provisions of Part 20.106, "Radioactivity in Effluents to Unrestricted Areas"; (2) require that operating procedures developed for the control of effluents be established and followed; (3) require that equipment installed in the radioactive waste system be maintained and used; and (4) require the periodic submission of reports to the NRC specifying the quantity of each of the principal radionuclides relepsed to unrestricted areas in liquid and gaseous effluents, any quantities of radioactive materials released that are significantly above design objectives, and such other information as may be required by the Commission to estimate maximum potential radiation dose to the public resulting from the effluent releases.

10 CFR Part 20, "Standards for Protection Against Radiation, 11 paragraphs 20.lOS(c), 20.106(9), and 20.405(c), require that nuclear power plant and other licensees comply with 40 CFR Part 190, 11Environmental Radiation Protection Standards for Nuclear Power Operations 11 and submit reports to the NRC when the 40 CFR Part 190 limits have been or may be exceeded.

  • 10 CFR Part 50, Appendix A - General Design Criteria for Nuclear Power Plants, contains Criterion 60, Control of releases for radioactive materials to the environment; Criterion 63, Monitoring fuel and waste storage; and Criterion 64, Monitoring radioactivity releases. Criterion 60 requires that the nuclear power unit design include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences.

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

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

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

  • 2.2 Standard Radiological Effluent Technical Specifications NUREG-0472 provides radiological effluent technical specifications for pressurized water reactors which the staff finds to be an acceptable standard for licensing actions. Further clarification of these accept-able methods is provided in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants." NUREG-0133 describes methods found acceptable to the staff of the NRC for the cal-culation of certain key values required in the preparation of proposed radiological effluent technical specifications for light-water-cooled nuclear power plants. NUREG-0133 also provides guidance to licensees in preparing requests for changes to existing radiological effluent technical specifications for operating reactors. It also describes current staff positions on the met~odology for estimating radiation exposure due to the release of radioactive materials in effluents and on the administrative control of radioactive waste treatment sytems.

The above NUREG documents address all of the radiological effluent technical specifications needed to assure compliance with the guidance and requirements provided by the regulations previously cited. However, alternative approaches to the preparation of radiological effluent technical specifications and alternative radiological effluent technical specifications may be acceptable if the staff determines that the alternatives are in compliance with the regulations and with the intent of the regulatory guidance *

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

(1)

Instrumentation (2) Radioactive effluents (3)

Radiological environmental monitoring (4) Design features (5) Administrative controls.

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

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

In general, the specifications established to assure compliance with 10 CFR Part 20 standards provide, in the event the limiting conditions of operation are exceeded, that without delay conditions are restored to within the limiting conditions. Otherwise, the facility is required to effect approved shutdown procedures.

In general, the specifications established to assure compliance with 10 CFR Part 50 provide, in the event the limiting conditions of operation are exceeded, that within specified times corrective actions are to be taken, alternative means of operation are to be employed, and certain reports are to be submitted to the NRC describing these conditions and actions *

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

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

3.0 EVALUATION The enclosed report {TER-C5506-113/114) was prepared for us by Franklin Research Center {FRC) as part of our technical assistance contract program.

Their report provides their'technical evaluation of the compliance of the

-Licensee's May 4, 1983 submittal with NRC provided criteria.

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

The proposed radiological effluent technical specifications for Surry Power Station Unit Nos. 1 and 2 have been reviewed, evaluated, and found to be in compliance with the reauirements of the NRC regulations and with the intent of NUREG-0133 and NUREG-0472 {the Surry Power Station is comprised of two pressurized water reactors) and thereby fulfill all the requirements of the regulations related to radiological effluent technical specifications.

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

  • Table &1at1on Between Provisions of the Regulations and the Sta,1

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§ 50.36a Technical specifications on effluents from nuclear power reactors Remain within limits of§ 20.106 Establish anJ follow procedures to control effluents Maintain and use radioactive waste system equipment Submit reports. semi-annual and other B 20.I05(cJ, c:u.l06(gJ, 20.405(cJ Compl1ance w1th 40 CFR 190 Part 50 Appendu A - General Design Cr1ter1a Criterion 60 - Control of releases of radioactive *

  • materials to the environment Criterion 61 - fuel storage and handling and radioactivity control Criterion 63 - Monitoring fuel and waste storage *
  • Criterion 64 - Monitorino radioactivitv releases *
  • Part 5U Aooendix B - Qualitv Assurance Criteria.-.

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

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

(1) quantities of rad. malls. in effluents (2) radiation & rad. ~alls. in the environment (J) changes in use of unrestricted areas Exert best efforts to kee~ releases "ALARA" Submit report if calculated doses exceed the design objective Demonstrate conform. to des. obj, bv calc. oroced.

1Parl 100

  • Note:

Needed to fully Implement other specifications.

I I

  • 4.0 Environmental Consideration This amendment involves a change in the irstallation or use of a facility component located within the restricted area.

The staff has determined that the amendment involves no significant increase in the amounts of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupation radiation exposure.

The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.

Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sec 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendmer,~.

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

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission 1s regulations and the issuance of this amendments will not be inimical to the common defense and security or to the health and safety of the public.

Dated: June 19, 1984 Principal Contributor:

W. Meinke

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

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC DOCKET NO. 5 0-280, 50-28:L NRC TAC NO. 8102, 8103 NRC CONTRACT NO. NRC-03-81-130 Prepared by Franklin Research Center 20th and Race Streets Philadelphia, PA 19103 Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 June 15, 1983 FRC PROJECTC5506 FRC ASSIGNMENT 4 FRCTASKS 113, 114

.Author(*- A. Cassell-

, s. 'ch~~

  • FRC Group Leader: s. Pandey Lead NRC Engineer: F. Congel C. Willis This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.
,Principal Author Date
h#5 /.? 3 Reviewed by:

Approved by:

-~P~d Group Leader Date:

6 / 15fQr;}>

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~nklin ReSearch Center A Division of The Franklin Institute The Benjamin Franklin Park'!llay, Phila., P11. 19103 (215) 448-1000

I I

TER-C5506-113/114 CONTENTS Section Title Page 1

INTRODUCTION 1

1.1 Purpose of Review.

1 1.2 Generic Background.

1 1.3 Plant-Specific Background.

3 2

REVIEW CRITERIA.

5 3

TECHNICAL EVALUATION 7

3.1 General Description of Radiological Effluent Systems 7

3.2 Radiological 3.3 Offsite 4

CONCLUSIONS.

5 REFERENCES.

~nklin Research Center A Division of The Franklin institute Dose Effluent Technical Calculation Manual iii Specifications.

10 17 21 23

TER-C5506-113/114 Number 1

2 Number 1

FIGURES Title Liquid Radwaste Treatment Systems, Effluent Paths, and Controls for Surry Power ~tation Units 1 and 2

  • Gaseous Radwaste Treatment Systems, Effluent Paths, and Controls for Surry Power Station units 1 and 2
  • TABLE Title Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Surry Power Station Units 1 and 2

~nklin Research Center A Division of The Franklin Institute iv 8

9 22

TER-C5506-113/114 FOREWORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions.

The technical evaluation was conducted in accordance with criteria established by the NRC *

~nklin Research Center A Division of The Franklin Institute V

TER-C5506-113/114

1.

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

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

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

Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.

1.2 GENERIC BACKGROUND Since 1970, 10CFRSO, Section 50.36a, "Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide technical specifications which ensure that radioactive releases will be kept as low as reasonably achievable (ALARA).

In 1975, numerical guidance for the ALARA requirement was issued in 10CFRSO, Appendix I.

The licensees of all operating reactors were required [3] to submit, no later than June 4, 1976, their proposed ALARA Technical Specifications and information for evaluation in accordance with 10CFRSO, Appendix I.

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

The model RETS deals with radioactive waste management systems and environmental monitoring.

Although the model RETS closely parallels 10CFRSO, Appendix I requirements, it also includes provisions for addressing other

  • issues *

~nklin Research Center A Division of The Franklin Institute TER-CSS06-113/114 These other issues are specifically stipulated by the following regulations:

o 10CFR20 [4], nstandards for Protection Against Radiation,n Paragraphs 20.lOS(c), 20.106(9), and 20.40S(c) require that nuclear power plants and other licensees comply with 40CFR190 [SJ, "Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40CFR190 limits have been or may be exceeded.

o 10CFRSO, Appendix A [6], "General Design Criteria for Nuclear Power Plants,n contains Criterion 60 - Control of releases of radioactive materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and Criterion 64 - Monitoring radioactivity releasese.

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

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

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

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

Licensees

  • responded with requests for clarifications and extensions.

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

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

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

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

The revised model RETS was sent to licensees on November 15 and 16, 1978 with.guidance (NUREG-0133 [9]) for preparation of the RETS and the ODCM and a new schedule for responses, again staggered over a 6-month period.

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

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

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

Review leading to ultimate

~nklin Research Center A Division of The Franklin Institute

  • TER-C5506-113/114 plementation of these documents was initiated by the NRC in 1981 using subcontracted independent teams as reviewers.

As the RETS review process has progressed since September 1981, feedback from the licensees has led the NRC to believe that modification to some provisions in the current version of Revision 2 is needed to better clarify specific concerns of the licensees and thus expedite the entire review process.

Starting in April 1982, NRC distributed revised versions of RETS in draft form to the licensees during the site visits.

The new guidance on these changes was presented_ in the AIF meeting on May 19, 1982 [10].

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

With the incorporation of these new changes, NRC issued, in September 1982, a draft version of NUREG-0472, Revision 3 [12], to serve as new guidance for the review teams.

1.3 PLANT-SPECIFIC BACKGROUND In response to the NRC's request, the Licensee, Virginia Electric and Power Company. (VEPCO), submitted a RETS proposal dated March 15, 1979 [13] on behalf of Surry Power Station Units 1 and 2, which was followed by a submittal of the ODCM (14].

In an initial evaluation by the Franklin Reseach Center (FRC), an independent review team, the Licensee's RETS and ODCM submittals were evaluated against the model RETS (NUREG-0472) and assessed for compliance with the stipulated provisions. Copies of the draft r~view, dated April 26, 1982

[15, 16], were delivered to the NRC and the Licensee prior to a site visit by the reviewers.

The site visit was conducted on May 12-14, 1982 by the reviewers with the participation of plant personnel and the NRC staff.

Discussions focused on the initial review of the proposed changes to the RETS and on the technical approaches for an ODCM.

The deficiencies i~ the Licensee's proposed RETS were considered, deviations from NRC guidelines were pointed out, many differences were clarified, and only a few items remained unresolved pending justification

~

the Licensee.

These issues are sununarized in Reference 17.

~nklin Research Center A Division of The Franklin Institute TER-C5506-113/114 On November 12, 1982, the Licensee submitted an updat.ed draft version of both the :RETS [18] and ODCM [19].

The submittals were reviewed by the reviewer (FRC), and deficiencies were identified to the NRC [20).

These deficiencies were transmitted to the Licensee with comments by the NRC staff

[21)

  • The final versions of the Surry :RETS [22] and ODCM [23], dated May 4, 1983, were submitted to the NRC and transmitted to the FRC reviewers together with justifications provided by the Licensee.

However, the submittal did not include the PCP.

The submitted documents were subsequently reviewed.

Final evaluation of :RETS was detailed in a comparison report [24] which used NUREG-0472, Draft Revision 3 [12] to evaluate the Licensee's submittal.

The comparison report also incorporates NRC comments [25) which serye as additional guidelines regarding plant-specific issues.

~nklin Research Center A Division of The Franklin institute

  • TER-C5506-113/114
2.

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

NUREG-04 72, RETS for PWRs NUREG-0473, RETS for BWRs NUREG-0133, Preparation of RETS for Nuclear Power Plants.

Twelve essential criteria are given for the RETS and ODCM:

1. All significant releases of radioactivity shall be controlled and monitored.
2. Offsite concentrations of radioactivity shall not exceed the 10CFR20, Appendix B, Table II limits.
3. Offsite radiation doses shall be ALARA.
4.

Equipment shall be maintained and used to keep offsite doses ALARA *

5.

Radwaste tank inve~tories shall be limited so that failures will not cause offsite doses exceeding 10CFR20 limits.

6.

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

7.

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

8.

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

9.

The radwaste managemen~ program shall be subject to regular audits and reviews.

10.

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

11.

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

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

-s-

~nklin Research Center A Division of The Franklin Institute

TER-C5506-113/114 Subsequent to the publication of NUREG-0472 and NUREG-0473, the NBC staf issued guidelines (26, 27], clarifications [28, 29], and branch positions (30, 31, 32, 33] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS provisions.

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

Review of the ODCM was based on the following NBC guidelines:

Branch Technical Position, "General Content of the Offsite Dose Calculation Manual" (34]; NUREG-0133 [9]; and Regulatory Guide 1.109 (35].

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

Since the Licensee has not submitted a PCP, the review does not include this specific document.

~nklin Research Center A Division of The Fianklln Institute TER-C5506-113/114

3.

TECHNICAL EVALUATION 3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEMS This section briefly describes the liquid and gaseous radwaste effluent systems, release paths, and control systems installed at Surry Power Station Units 1 and 2~ both are PWRs.

3.1.1 Radioactive Liquid Effluent The liquid waste treatment system for the Surry plant is common to both Units 1 and 2 (Figure 1).

Two systems currently exist for treating liquid wastes.* These are the boron recovery system and the liquid waste treatment system.

The boron recovery system treats effluents collected in primary drain tanks and letdown from the primary coolant that is diverted from the chemical and volume control system (CVCS).

The liquid waste treatment system processes

~e liquid waste originating from containment, auxiliary building, and

~contamination building sumps, *and from laboratory drains.

These effluents are all*released in batches, which join to form the liquid radwaste effluent line, providing ultimate discharges to the bay via the discharge tunnel.

Other liquid lines that also lead to the discharge tunnel for release are the service water and the condensate polishing chemical waste, which are discharged on a continuous basis.

Other than the above effluent release pathways, the turbine building (floor drain) sump discharges effluents directly to the station storm drain system.

3.1.2 Radioactive Gaseous Effluent The gaseous waste treatment system for the Surry plant is also common to both Units 1 and 2 (Figure 2).

The process effluent from the eves is stored in the decay tank, from which the effluents are released with other streams into the process vent,

~nklin Research Center A Division of The Franklin Institute I

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TER-C5506-ll3/ll4 where releases are considered as mixed mode.

Substreams such as the containment vacuum system, the vent and drain system, and the relief valve discharge also lead to the process vent for release.

The ventilation vent system services the containment purge system, the auxiliary building, the decontamination building, and the fuel building.

Effluents from the condenser air ejectors (Units land 2) are discharged separately to the atmosphere.

Both releases from the ventilation vent system and the air ejectors are considered at ground level.

The steam generator blowdown does not form an effluent pathway since it is a closed loop system and is recirculated through the condensate polisher for processing.

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

~

o a review of information provided by the Licensee in the 1979. proposed submittals [13, 14) o resolution of problem areas in that submittal by means of a site visit

[17) o review of the Licensee's November 12, 1982 draft submittals [18; 19) o review of the Licensee's May 4, 1983 final submittals [22, 23).

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

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

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

~nklin Research Center A Division of The Franklin Institute.

TER-C5506-113/114

.2.1.1 Radioactive Liquid Effluent Monitoring Instrumentation A radiation monitor (LW-108) has been installed for the liquid radwaste effluent line (Figure 1), which provides automatic isolation in the event that an excessive level of-radioactivity is detected.

The Licensee has also provided a monitor (SW-107) for the service water and two monitors (SW-120, 220) for the discharge tunnel.

The Licensee has committed to install composite samplers and flow rate recorders in the storm drain effluents, to which the turbine building sumps discharge.

The Licensee indicated that such equipment has been installed and will be maintained according to station procedures.

However, this monitoring equipment is not included in the Licensee's RETS submittal.

The Licensee has provided justification that the turbine building sumps effluent line is not a normal radioactive effluent pathway.

Further, steps have been taken to eliminate normally radioactive systems from discharging into the turbine building sump.

A recent design change, nnel sump effluents into the radwaste building sump contamination.

for instance, has rerouted the piping system, thus precluding the turbine It is determined that the Licensee's proposed RETS submittal and supporting justifications on liquid effluent monitoring instrumentation have satisfied the provisions set forth in the model RETS and thus meet the intent of NUREG-0472.

3.2.1.2 Radioactive Gaseous Effluent Monitoring Instrumentation The plant process vent is provided with a monitoring system capable of monitoring noble gases, iodines, and particulates.

The noble gas monitor (GW-102) has the capability of automatically isolating the releases from the waste gas decay tank and the containment vacuum system.

Radiation monitors are also installed at the condenser air ejectors; monitor SV-111 for Unit 1 and monitor SV-211 for Unit 2 both have the automatic isolation capability on the discharges.

Radiation monitor VG-110 monitors the effluent releases through the ventilation vent *

~nklin Research Center A Division or The Franklin Institute TER-C5506-ll3/ll4 The proposed monitoring capabilities provided by the Licensee. meet the intent of NUREG-0472 for radioactive gaseous effluent monitoring ins.trumen-tation.

3.2.2 Concentrations and Dose Rates of Effluents 3.2.2.l Liquid Effluent Concentration In Section 3.11.A.l of the Li~ensee's submittal, a commitment is made to maintain the concentration of radioactive liquid effluents released from the site to the unrestricted areas to within 10CFR20 limits, and if the concentration of liquid effluents to the unrestricted area exceeds these limits, it will be restored without delay to a value equal to or less than the MPC values specified in 10CFR20.

Both batch and continuous releases are sampled and analyzed periodically in accordance with a sampling and analysis program (Table 4.9-1 of the Licensee's submittal), which meets the intent of NUREG-04 72.

3.2.2.2 Gaseous Effluent Dose Rate In section 3.11.B.1 of the Licensee's submittal, a commitment is made to maintain the offsite gaseous dose rate from the site to areas at and beyond the site boundary to within 10CFR20 limits, and if the concentration of gaseous effluents exceeds these limits or the equivalent dose values, it will be restored without delay to a value equal to or less than these limits.

The radioactive gaseous waste sampling and analysis program (Table 4.9-2 of the Licensee's submittal) provides adequate sampling and analysis of the vent discharges, including the substreams, and therefore meets the intent of NUREG-0 4 72

  • 3.2.3 Offsite Doses from Effluents The objective of the RETS with regard to offsite doses from effluents is to ensure that offsite doses are kept ALARA, are in compliance with the dose specifications of NUREG-0472, and are in accordance with 10CFR50, Appendix I,.

~nklin Research Center A Division of The Franklin Institute TER-C5506-113/114 40CFR190.

The Licensee has made a commitment to (1) meet the quarterly and yearly dose limitations for liquid effluents, per Section 3.11.1.2 of NUREG-0472 [l]7 (2) restrict the air doses for beta and gamma radiation in unrestricted area.s as* specified in 10CFRSO, Appendix I,Section II. B7 (3) maintain the dose level to the maximally exposed member of the public from releases of iodine-131, tritium, and particulates with half-lives greater than 8 days within the design objectives of 10CFR50, Appendix I,Section II.c, and (4) limit the annual dose to the maximally exposed member of the public due to releases of radioactivity and radiation from uranium fuel cycle sources to within the requirements of 40CFR190.

This satisfies the intent of NUREG-0472.

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

The Licensee has made a commitment to use the liquid and gaseous.. radwaste ~reatment.system when the projected doses averaged over 31 days exceed 25% of the annual dose design objectives, prorated monthly.

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

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

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

This also meets the intent of NUREG-0472.

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

Citing the overflow protection of outside tanks and the absence of potable water supply downstream of station effluents, the Licensee does not anticipate the necessity of having such a specification for liquid storage tanks.

For gas

~torage tanks, a curie limit of 24,600 curies has been

~nklin Research Center A Division of The Franklin Institute

-13..;

set for noble gases

TER-C5506-113/114 which are considered to be represented by xenon-133.

The Licensee has proposed to perform surveillance of the gas storage tank at least once per month when radioactive materials are being added to the tank.

The proposed surveillance frequency is less frequent than the once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> specified by the model RETS~ however, the Licensee stated in the cover letter of the submittal [22] that the frequency will be increased to once per day when the specific activity of the coolant is greater than or equal to 2.20 x 103

µci/gm dose equivalent xenon-133. *The Licensee's justification and commitment to comply with tank inven.tory limits have satisfied the intent of NUREG-0472.

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

The Licensee has stated that the waste gas holdup system is designed to withstand a hydrogen/oxy~en explosion.

The Licensee has made a commitment to maintain a safe concentratio.

in this system.

The Licensee. has also proposed a hydrogen monitor and an oxygen monitor to fulfill this commitment, which is consistent with the provisions of NUREG-0472.

3.2.7 Solid Radwaste System The objective of the RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged before it is shipped to a burial site, in accordance with 10CFR71 and Specification 3.11.3 of NUREG-0472.

The Licensee has made a commitment to establish a PCP to show compliance with this objective.

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

3.2.8 Radiological Environmental Monitoring Program The objectives of the RETS with regard to environmental monitoring are to ensure that (1) an adequate full-area-coverage (land and water inclusive)

~nklin Research Center A DMsion al The Franklin Institute

  • TER-C5506-113/114 onitoring program exists; (2) the requirements of 10CFRSO, Appendix I for technical specifications on environmental monitoring are satisfied; and (3) the Licensee maintains both a land-use census and interlaboratory comparison program.

In all cases, the Licensee has followed NUREG-0472 guidelines, including the Branch Technical Position dated November 1979 [31), and has provided an adequate number of sample locations for pathways identified.

The Licensee's methods of analysis and maintenance of yearly records satisfy the NRC guidelines and meet the intent of 10CFRSO, Appendix I. The Licensee has also made a commitment to document the environmental monitoring sample locations in the ODCM, which meets the intent of NUREG-0472.

The specification for the land use census satisfies the provisions of Section 3.12.2 of NUREG-0472** by providing for an annual census in the specified areas.

The Licensee participates in an interlaboratory comparison program approved by the NRC and reports the results in the Annual Radiological Environmental Operating Report,

.ich also meets the intent of. NUREG-04 72.

3.2.9 Audits and Reviews The objective of the RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring programs are properly conducted.

The Licensee's administrative structure designates the station nuclear safety and operating committee (SNSOC) and the quality assurance department (QA) as the two groups responsible for reviews and audits, respectively.

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

The two committees encompass the responsibility for reviews and audit; this meets the intent of NUREG-0472.

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

~ecords in relation to the environmental monitoring program and certain QA

~nklin Research Center A Division of The Franklin Institute TER-C5506-ll3/ll4 procedures.

The Licensee has made a commitment to establish, implement, and maintain written procedures for the PCP, the ODCM, and the QA program.

The Licensee intends to retain the records of the radiological environmental monitoring program, as well as the records of quality assurance activities, for *the duration of the facility operating license. It is thus determined that the Licensee has met the intent of NUREG-0472.

3.2.11 Reports

  • In addition to the reporting requirements of Title 10, Code of Federal Regulations (10CFR), the objective of the RETS with regard to administrative controls is to ensure that appropriate periodic and special reports are submitted to the NRC.

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

1.

Annual Radiological Environmental Operating Report.

In Section 6.6.l.b of the Licensee's submittal, a commitment is made to provide an annual radiological environmental operating report that includes summaries, interpretations, and statistical evaluation of the results of the environmental surveillance program.

The report also includes the results of land use censuses, and participation in an inter-laboratory comparison program specified by Specification 3.l2a3 of NUREG-0472.

2.

Semiannual Radioactive and Effluent Release Report.

In Section 6.6.l.c of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent and solid waste release reports which include a summary of radioactive liquid and gaseous effluents and solid waste released, an assessment of offsite doses, and a.list of unplanned releases. Listing of new location for dose calculations identified by the land use census as well as any changes to ODCM, PCP, and major changes to radioactive waste treatment systems are also included in the report.

3.

Special Report.

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

0 exceeding liquid effluent dose to the proposed Specifications

~nklin Research Center A Division of The Franklin Institute and concentration limits according 3.11.A-2 and 3.11.A-l, respectively~

TER-C5506-113/114 o

exceeding gaseous effluent dose and dose rate limits according to the proposed Specifications 3.11.B-2, 3.11.B-1, and 3.11.B-3, respectively o

exceeding the projected monthly dose limits without treating the radioactive liquid or gaseous waste according to the proposed Specifications 3.11.A-3 and 3.11.B-4, respectively o

exceeding total dose limits according to the proposed Specification 3.11.C o

exceeding the reporting levels of proposed Table 4.9-4 for the radioactivity measured in the environmental sampling medium.

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

3.2.12 Implementation of Major Programs One objective of the. administrative controls is to ensure that implemen-tation of major programs, such as the PCP, ODCM, and major changes to the radioactive waste treatment system, follows appropriate administrative ocedures.

The Licensee has made a commitment to review, report, and mplement major programs such as the PCP, ODCM, *and major changes to the radioactive waste treatment system.

This commitment meets the intent of NUREG-0 4 72

  • 3.2.13 Design Features The objective of the RETS with regard to design features is to provide a map of the site area defining the site boundary and unrestricted areas within the site boundary, as well as defining points of release for liquid and gaseous effluents and points where liquid effluents leave the site.-:

The Licensee has provided an acceptable Figure 5.1-1, except that a scale should be provided for the figure.

3.3 OFFSITE DOSE CALCULATION MANUAL (ODCM)

As specified in NUREG-0472, the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and

~nklin Research Center A Division of The Franklin Institute TER-C5506-113/114 maintain the operability of the effluent system.

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

o alarm and trip setpoint on effluent instrumentation 0

liquid effluent concentration in unrestricted areas 0

gaseous effluent dose rate at or beyond the site boundary 0

liquid and gaseous effluent dose contributions 0

liquid and gaseous effluent dose projections.

In addition, the ODCM should contain flow diagrams, consistent with systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems.

A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

3.3.1 Evaluation the The Licensee has followed" the methodology of NUREG-0133 [91 to determine the alarm and trip setpoints for the liquid and gaseous effluent monitors.

To ensure that the MPC, as specified in 10CFR20, will not be exceeded even in the case of simultaneous discharge, the Licensee will adjust the setpoints according to the apportionment of the radioactivity released from each respective effluent line.

The Licensee has demonstrated the method of calculating the radioactive liquid concentration by describing in the ODCM the means of collecting and analyzing representative samples prior to and after releasing liquid effluents into the circulating water discharge.

The method provides added assurance of compliance with 10CFR20 for liquid releases.

Methods are also included for showing that dose rates at or beyond the site boundary due to noble gases, iodine-131, tritium, and radionuclides in particulate form with half-lives greater than 8 days are in compliance with 10CFR20.

In this calculation, the Licensee has considered effluent releases from the process vent, the ventilation vent, and condenser air ejectors,

~nklin Research Center A Division of The Franklin institute

  • TER-C5506-113/114 leases from the process vent are treated as mixed mode, and releases from the ventilation vent and air ejectors are treated as ground level.

In all cases, the Licensee has used the highest annual average values of relative concentration (X/Q) ahd relative deposition (D/Q) to determine the controlling locations.

The Licensee intends to use the maximally exposed individual and the critical organ as the reference receptor.

For noble gases, the Licensee has considered the total body dose and the skin dose resulting from gamma and beta radiation, respectively.

For *iodine-131, tritium, and particulates, the Licensee has considered the inhalation pathway for estimating the doses.

The Licensee has demonstrated that the described methods and relevant parameters have followed the conservative approaches provided by NUREG-0133 and Regulatory Guide 1.109.

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

For liquid releases, the Licensee has identified fish and inver*tebrate nsumption as the two viable pathways.

In the calculation, the Licensee has used a near-field dilution factor specific to the plant; all other key parameters follow the suggested values given in Regulatory Guide 1.109.

The Licensee has used tjle maximally exposed adult individual as the reference receptor.

To correctly assess the cumulative dose, the Licensee intends to estimate the dose once per 31 days.

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

The critical organs under consideration are the total body and skin for gamma and beta radiation, respectively.

Again, the Licensee has used the maximum (X/Q) values as discussed earlier and has followed the methodology and parameters of NUREG-0133 and Regulatory Guide 1.109.

For iodine-131, tritium, and particulates with half-lives gr~ater than 8 days, the Licensee has provided a method to demonstrate that cumulative doses calculated from the release meet both quarterly and annual design objectives.

The Licensee has demonstrated a method of calculating the dose using maximum

~nual average (X/Q) values for the inhalation pathway and has included (D/Q)

~nklin Research Center A Division al The Franklin Institute,.

TER-C5506-113/114 values for the grass-cow-milk pathway for ingestion, for which the Licensee considered the infant to be the critical age group and thyroid to be the critical organ.

This approach is consistent with the methodology of NUREG-0133.

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

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

Radiation monitors specified in the Licensee-submitted RETS are also properly identified in the flow diagrams.

The Licensee has provided a detailed description of many sampling locations in the ODCM, but has not provided a table and figure{s) containing specific parameters of distance and direction sector from the centerline of the reactor for each and every sample location in RETS Table 4.9-3 on environmental monitoring.

Futhermore, the Licensee's May 4, 1983 ODCM submittal is incomplete, leaving out,.-9)'Stj!'s-;Jcrabs, and fish as well as Figures 13.0, 13.1, and 13.2 provided in the earlier draft submittal.

In summary, the Licensee's ODCM uses documented and approved methods that are consistent with the methodology and guidance in NUREG-0133, and, therefore, is an acceptable reference, except for an incomplete listing and description of samples in the environmental monitoring program.

~nklin Research Center

/\\ Division of The Franklin Institute

  • TER-C5506-ll3/114
4.

CONCLUSIONS The Licensee submitted the same Radiological Effluent Technical Specifications (RETS)' and Offsite Dose Calculation Manual (ODCM) for both Units land 2 of Surry Nuclear Power Station. Table l summarizes the results of the final review and evaluation of the RETS submittal.

Comments apply equally to Units land 2.

The following conclusions were reached:

1.

The Licensee's proposed RETS, submitted May 4, 198_3 (22], meets the intent of the NRC staff's "Standard Radiological Effluent Technical Specifications," NUREG-0472, for Surry Power Station Units land 2.

2.

The Licensee's ODCM, submitted May 4, 1983 (23], uses documented and approved methods that are applicable to Surry Power Station Units l and 2 and* are consistent with the criteria of NUREG-0133.

It is an acceptable reference except for an incomplete listing and description of samples in the environmental monitoring program *

-21:-

~nklin Research Center A Division of The Franklin Institute

)

TER-C5506-113/114 Table 1. Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Surry Power Station Units 1 and 2 Effluent Instrumentation Radioactive Effluents

  • Offsite Doses Effluent Treatment Tank Inventory Limits Explosive Gas Mixtures Solid Radioactive waste Environmental Monitoring Audits and Reviews Procedures and Records Reports Implementation of Major Programs Technical Specifications NRC Staff Std. RETS NUREG-0472 (Section)*

3/4.3.3.3.10 3/4.3.3.3.11 3/4.11.1.1 3/4.11.2.1 3/4.11.1.2, 3/4.11.2.2, 3/4.11.2.3, 3/4.11.4 3/4.11.1.3 3/4.11.2.4 3/4.11.1.4 3/4.11.2.6 3/4.11.2.SB 3/4.11.3

  • 3/4.12.l 6.5.1, 6.5.2 6.8, 6.10 6.9 6.13, 6.14, 6.15 Licensee Proposal (Section)

~.7.E 3.11.A-l 3.11.B-l 3.ll.A-2, 3.11.B-2, 3.11.B-3, 3.11.C 3.11.A-3 3.11.B-4 3.ll.B-6 3.ll.B-5 3.11.E 3.11.D 6.1.C-l 6.1.c-2 6.l.C-3 6.4, 6.5 6.6 6.8, 6.9 Replaces or Updates Existing Tech. Specs.

(Section) 3.7 3.11 To be added To be added To be added To be added To be added 4.9 6.1 6.4 6.6 To be added Evaluation Meets the intent of NRC criteria Meets the intent of NRC criteria Meets the intent of NBC criteria Meets the intent of NBC criteria Meets the inte.

of NBC criteria Meets the intent of NRC criteria Meets the intent of NRC criteria Meets the intent of NRC criteria Meets the intent of NBC criteria Meets the intent of NRC criteria Meets the intent of NRC criteria Meets the intent of NRC criteria

  • Section number sequence is according to NUREG-0472, Rev. 3, Draft 7' [12]. *

~n~in Research Center A Division of The Franklin Institute

-22~

TER-CSSOG-113/114 S

  • REFERENCES
1.

"Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 2

2.
3.
s.

NBC, July 1979 NUREG-0472 Tit.le 10, Code of Federal Regulations, Part SO, Appendix I, "Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, 'As Low As Is Reasonably Achievable,' for Radioactive Material in Light-water-Cooled Nuclear Power Reactor Effluents" Title 10, Code of Federal Regulations, Part SO, Appendix I,Section V, "Effective Dates" Title 10, Code of Federal Regulations, Part 20, "Standards for Protection

' Against Radiation" Title 40, Code of Federal Regulations, Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations" Title 10, Code of Federal Regulations, Part SO, Appendix A, "General Design Criteria for Nuclear Power Plants" Title 10, Code of Federal Regulations, Part SO, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"

8.

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

9. * "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for users of Standard Technical Specifications" NRC, OCtober 1978 NUREG-0133
10.

C. Willis and F. Congel (NRC)

11.

"Summary of Draft Contractor Guidance of RETS" P~esented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19, 1982 F. Congel (NRC)

Memo to RAB Staff (NBC)

Subject:

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

August 9, 1982

~nklin Research Center A Division of The Franklin Institute

12.
13.
14.
15.
16.

TER-C5506-113/114 "Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draft 7', intended for contractor guidance in reviewing RETS proposals for operating reactors NRC, September 1982 NUREG-0472 Amendments to Operating License for Surry Units land 2 "Proposed Technical Specifications, Change No. 73" March 15, 1979 Surry Offsite Dose Calculation Manual (Draft)

Virginia Electric and Power Company, July 30, 1980 NRC Docket Nos. 50-280, 281 "Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs, vs. Licensee Submittal of Radiological Effluent Technical Specifications for Surry Power Station Units 1 and 2° (Draft)

Franklin Research Center, April 26, 1982 Technical Review of Offsite Dose Calculation Manual for Surry Power Station Units 1 and 2 (Draft)

Franklin Research Center, April 26, 1982

17. s. Pandey/A. Cassel (FRC)

Letter of Transmittal tow. Meinke (NRC)

Subject:

Trip report on site visit to Sur_ry Power Station Units 1 and 2 July 6, 1982

18.
19.
20.
21.

Surry Radiological Effluent Technical Specifications (RETS)

Virginia Electric and Power Company, November 12, 1982 NRC Docket Nos. 50-280, 50-281 Surry Offsite Dose Calculation Manual Virginia Electric and Power Company, November 12, 1982 NRC Docket Nos. 50-280, 50-281

s. Pandey/S. Chen (FBC)

Letter of Transmittal tow. Meinke (NRC)

Subject:

Comments on Surry RETS and ODCM Draft Submittals January 10, 1983

w. Meinke (NRC)

Letter of Transmital to s. Pandey (FBC) subject:

Summary of Telecon with the Licensee (VEPCO) on RETS and ODCM Submittals February 1, 1983 ~nklin Research Center A Division of The Franklin Institute

Surry Radiological Effluent Technical Specifications Virginia Electric and Power Company May 4, 1983 NRC. Docket Nos. 50-280, 50-281

23.

Surry Offsite Dose Calculations Manual Virginia Electric and Power Company May 4, 1983 NRC Docket Nos. 50-280, 50~281 TER-C5506-113/114

24.

"Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs, vs. Licensee Submittal of Radiological Effluent Technical Specifications for Surry Power Station Units land 2" Franklin Research Center, June 15, 1983

25. w. Meinke (NRC)

Letter of Transmittal to s. Pandey (FRC)

Subject:

Comments on Plant-Specific Issues Regarding Surry RETS Submittal June 10, 1983

26.

C. Willis (NRC)

Letter to Dr. s. Pandey (FRC)

Subject:

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

November 20, 1981

27.

C. Willis (NRC)

Letter to Dr. s. Pandey (FRC)

Subject:

Control of explosive gas mixture in PWRs December 18, 1981

28. c. Willis and F. Congel (NRC)

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

october 4-7, 1981

29.

C. Willis (NRC)

Memo to P. C. Wagner (NRC)

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

30.

W. P. Gammill (NRC)

Memo to P. C. Wagner (NRC)

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

~nklin Research Center A Division of The Franklin Institute TER-C5506-113/114

31.

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

32.

W. P. Garnrnill/F. J. Congel (NRC)

Memo to ETSB/RAB (NRC)

"Radiological Effluent Technical Specifications (RETS) Provisions for I-133" November 29, 1982

33.

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

NRC, February 1980 NUREG-0543

34.

"General Contents of the Offsite Dose Calculation Manual," Revision 1 Branch Technical Posi~ion, Radiological Assessment Branch February 8, 1979

35. Calculation of Annual Doses to Man from Routine* Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFRSO, Appendix I NRC, OCtober 1977 Regulatory Guide 1.109, Revision 1

~nklin Research Center A Division of The Franklin Institute _J

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