ML19263C490

Proposes Specific Mods to App a of License DPR-35 Tech Specs,In Response to NRC Ltrs to All BWR Licensees.Concludes Amend Exempt from Fees.W/Encl License DPR-35 & Tech Specs

ML19263C490
Person / Time
Site:	Pilgrim
Issue date:	02/21/1979
From:	Howard J BOSTON EDISON CO.
To:	Ippolito T Office of Nuclear Reactor Regulation
References
79-45, NUDOCS 7902260325
Download: ML19263C490 (59)

Text

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BOSTON EOsSON COMPANY 000 BOYLGTON STREET D O STO N, MASSACHUSETTc 0219 9 J. EDWARC HOWARD vic e pas...s e.,

e.wc6 san February 21, 1979 BECo. Ltr. #79-45 Proposed Change #79-2 Mr. Thomas A. Ippolito, Chier Operating Reactors Branch #3 Division of Operating Reactors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C.

20555 License No. DPR-35 Docket No. 50-293 Radiological Ef fluent and Environmental Monitoring Technical Specifications

References:

(a) Letter from B. K. Grimes, Assistant Director for Engineering and Projects, USNRC, to All Boiling Water Reactor Licensees, dated July 11, 1978 (b) Letter froa B. E. Crimes, Assistant Director for Engineering and Projects, USNRC, to All Boiling Water Reactor Licensees, dated November 15, 1978.

(c)

Letter from G. C. Andognini to T. A.

Ippolito, dated January 16, 1979.

Dear Sir:

Pursuant to Section 50.59 of the Commission's Rules and Regulations, Boston Edison Company hereby proposes the following modifications to Appendix A of the Operating License Proposed Change Reference is made to Pilgrim Station Operating License No. DPR-35 and the Technical Specifications contained in Appendix A.

The following changes are proposed:

(1) Add to Section 1.0 " Definitions" new definitions for " Source Check",

"Of fsite Dose Calculation Manual (ODCM)", and " Gaseous Radwaste Treatment Systems", in accordance with the use of these terms in the new specifications outlined below.

79022603N

e BOSTON EDISON COMPANY Mr. Thomas A. Ippolito, Chief February 13, 1979 Page 2 (2) Delete condition 5 and references thereto of Facility Operating License No. DPR-35.

(3) Add to Section 6 of the Technical Specifications, new specifications relating to the ODCM and Unique Reporting Requirements.

(4)

Delete in their entirety Technical Specifications 3.8 and 4.8 including 3.8. A, 3. 8.B. 3. 8.D, 3. 8. E, 4. 8. A, 4.8.B, 4.8.D, 4. 8.E and the respective bases for each section.

Add in their entirety new Technical apecification (attached to this letter) 3.8 and 4.8 including 3.8.A through 3.8.L and 4.8.A through 4.8.L and the new bases for each section.

Reason for Change The proposed changes are in direct response to the USNRC's request (references a and b) that Boston Edison amend Pilgrim Station's Operating License.

Safety Considerations The proposed technical specifications are intended to implement the following Federal Regulations; 10CFR50.34a(a), 10CFR50.36a, 10CFR20,10CFR50, Appendix A, General Design Criteria 60 and 64, and 40CFR190.

The public health and safety'is adequately protected by these changes.

These changes have been reviewed by the Nuclear Safety Review and Audit Committee and reviewed and approved by the Operations Review Committee.

Schedule of Change This change will be put into effect upon receipt of approval by the Commission subject to the completion of the ODCM for which a ninety day extension has been requested (see reference c).

Fee Determination The major portion of the proposed change is an extension of the 10 CFR Part 50, Appendix I design study submitted to the USNRC on June 2, 1976, and constitutes completion of the requirements of Appendix I for the submittal of technical specifications. We conclude that this amendment is exempt from any fees defined in 10 CFR Part 170.12(c) since fees were not applicable when the requirements forth by Appendix I to 10 CFR Part 50 became effective, and since submittal put of this information has been delayed pending guidance from the USNRC which was issued in July, 1978 (reference b).

e BOSTON EDISON COMPANY Mr. Thomas A. Ippolito, Chief February 13, 1979 Page 3 If you have any further questions on this matter please feel free to contact us at your convenience.

Very truly yours,

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Attachments 3 signed originals and 37 copies Co=monwealth of Massachusetts)

County of Suffolk

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Then personally appeared before me J. Edward Howard,who, being duly sworn, did state that he is Vice President - Nuclear of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the sub-mittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

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BOSTON EDISON COMPANY (PILGRIM NUCLEAR POWER STATION) b DOCKET NO. 50-293 FACILITY OPERATING LICENSE License No. DPR-35 The Atomic Energy Commission (the Commission) having found that:

a.

Construction of the Pilgrim Nuclear Power Station (the facility) has been substantially completed in conformity.with the application, as amended, the Provisional Construction Permit No. CPPR-49, the provisions of the Atomic Energy _Act of 1954, as amended (the.Act), and the rules and regula-tions of the Commission as set forth in Title 10, Chapter 1, CFR; and b.

The f acility will operate in conformity with ~he application, as amended, the provisions of the Act, and the rules and regulations of the Commission; and There is reasonable assurance (1) that the activities authorized by the c.

operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; and d.

The Boston Edison Company (Boston Edison) is technically and financially qualified to engage in the activities authorized by this operating license; in accordance with the rules and regulations of the Commission; and Boston Edison has satisfied the applicable provisions of 10 CFR Part 140, e.

" Financial Protection Requirements and Indemnity Agr.ements" of the Commission's regulations; and f.

The issuance of this license will not be inimical to the common defence and security or to the health and safety of the public; and In accordance with the requirements of Appendix D to 10 CFR Part 50, the g.

operating license should be issued subject to conditions for protection of tha environment set forth herein.

Facility Operating License no. DPR-35 is hereby issued pursuant to an Order, dated June 1, 1972, by the Atomic Safety and Licensing Board, in accordance with the provisions of the Commission's' regulations in 10 CFR 50, sections 50.57(c) and A.12 of Appendix D to Part 50, to the Boston Edison Company (Boston Edison), to read as follows:

. g 5.

(DELETED) 6.

Pursuant to Section 105c(8) of the Act, the Commission has consulted with the Attorney General regarding the issuance of this operating license. After said consultation, the Commission had determined that the issuance of this license, subject to the conditions set forth in'this subparagraph 6., in advance of consideration of and findings with respect to matters covered in Section 105c of the Act, is necessary in the public interest to. avoid unnecessary delay in the operation of the facility. At the time this operating license is being issued and antitrust proceeding has not been noticed.

The Commission, accordingly, has made no determina-tion with respect to matters covered in Section 105c of the Act, it.cluding conditions, if any, which may be appropriate as a result of the outcome of any antitrust proceeding.

On the basis of its findings made as a result of an antitrust proceeding, the Commission may continue this license as issued, rescind this license or amend this license to include such conditions as the Commission deems appropriate.

Boston Edison and others who may be affected hereby are accordingly on notice that the granting of this license is without preju-dice to any subsequent licensing action, including the impo-sition of appropriate conditions, which may be taken by the Commission as a result of the outcome of any antitrust pro-ceeding.

In the course of its planning and other activities, Boston Edison will be expected to conduct itself accordingly.

7.

This license is effective as of the date of issuance and shall expire August 26, 2008.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

Appendix A - Technical Specifications (Radiological)

Appendix B - Technical Specifications (Environmental)

Date of Issuance of Original Operating Lice; se:

June 1, 1972 e

1.0 DEFINITIONS (Continued)

Y.

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

Z.

OFFSITE DOSE CALCULATION MANUAL (ODCM)

AN OFFSITE DOSE CALCULATION MANUAL (ODCM) shall be a manual. containing the methodology and parameters to be used in the calculation of offsite doses due to radioactive, gaseous and liquid ef fluents and in the cal-culation of,aseous and liquid ef fluent monitoring instrumentation alarm /

trip setpoints.

AA.

GASEOUS RADWASTE TREATMENT SYSTEM A GASEOUS RADWASTE TREATMENT SYSTEM is any s,9 tem designed r.ad installed to reduce radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing for delay or hold-up for the purpose of reducing the total radioactivity prior r.o release to the environment.

e 4

5b

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.2 RADIOACTIVE EFFLUENTS 4.8 RADIOACTIVE EFFLUENTS A. Liquid Ef fluents Concentration A.

Liquid Ef fluents Concentration

1. The concentration of radio-

1. The concentration of radio-active material e] eased at active material at any time any time from the site to in liquid effluents released the unrestricted areas shall from the site shall be con-be limited to the concentra-tinuously monitored in ac-tions specified in.10 CFR cordance with Table 3.8.A-1.

Part 20, Appendix B, Table II, Column 2 for radionu-

2. The liquid effluent continu-clides other than dissolved ous monitors having provisions or entrained noble gases.

for automatic termination of For dissolved or entrained liquid releases, as listed in noble gases, the concentra-Table 3.8. A-1, shall be used tion shall be limited to 2 x to limit the concentration of 10-4 uCi/ml total activity.

radioactive material released at any time from the site to Applicability unrestricted areas to the values given in Specification At all times.

3.8.A.1.

Action 3.

The radioactivity content of each batch of radioactive With the concentration of liquid waste to be discharged radioactive material re-shall be determined prior to leased from the site to release by sampling and an-unrestricted areas exceed-alysis in accordance with ing the above limits, Table 4.8.A-1.

The results immediately restore con-of pre-release analyses shall centration within the be used with the calculational above limits and provide methods in the 00CM to assure notification to the Com-that the concentration at the mission pursuant to point of release is limited Specification 6.9.B.1 and to the values in Specification 10CFR20.403.

3.8.A.1.

4. Post-release analyses of samples from batch releases shall be performed in accord-ance with Table 4.8.A-1.

The results of the post-release an-alyses shall be with the calcu-lational methods in the ODCM to assure that the concentrations at the point of release are limited to the values in Specification 3.8.A.1.

J

5. Reports - The semiannual Radioactive Effluent Release Report shall include the in-formation specified in Spec-ification 6.9.C.1.

178

9 TABLE 3.8.A-1 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument Operable Applicability Action 1.

Gross Radioactivity Monitors Providing Automatic Termin-ation of Release a.

Liquid Radwaste Effluent Line (1)

At all times 1

2.

Flow Rate Measurement Devices tj a.

Liquid Radwaste Effluent go Line**

(1)

At all times 2

b.

Discharge Canal **

(1)

At all times 2

3.

Radioactivity Recorders a.

Liquid Radwaste Effluent Line (1)

At all times 3

• • Pump curves may be utilized to estimate flow; in such cases, action statement 2 is not required.

O s

TABLE 3.8.A-1 (Continued)

TABLE NOTATION ACTION With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may be resumed for up to 15 daya, provided that prior to in'.tiating a release:

1.

At least two independent samples are analyzed in accordance with Specification 4.8.A.3, and; 2.

At least two technically qnalified members of the Facility Staff independently verify the release rate calculations and discharge valving; Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 2 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases.

ACTION 3 With the number of channels OPERABLE less than required by the Mini-mum Channels OPERABLE requirement, effluent releases via the affected pathway may continue for up to 14 days provided the gross radioacti-

'v level is recorded at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual release.

178b

TABLE 4.G.A-1 RADIOACIIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit

• Minimum of Detection Liquid 711 ease Type Sampling Analysis Type.of Activity (LLD)

Frequency Frequency Analysis

,,(uci/al)s P

P

.A.

Batch Waste Re-Each Batch Each Batch Principal Gamma 5 2 10-7 b lease Tanks

• Emitteraf I-131 1 x 10-6 P

One Batch /M M

Dissolved and 1 x 10-5 Entrained Gases P

H-3 1 x 10-5 Each Batch M

c Composite Gross a 1 x 10-7 P-32 1 x 10-6 P

Each Batch Q

Sr-89, Sr-90 5 x 10-8 c

Composite Fe-55 1 x 10-6 178c

o 4.8.A-1 (Continuedl TABLE NOTATION a.

The lower limit of detection (LLD) is defined in Table Notation a. of Table 4.8-0 of Specification 4. 8. 0.1.

b.

For certain radionuclides with low gamma yield or low energies, or for cer-tain radionuclide mixtures, it may not be possible to measure radionuclides in concentrations near the LLD.

Under these circumstances, the LLD may be increased invey/I, where I is the photon abundance expressed as a decimal (i.e., 5 x 10- sely proportionally to the magnitude of the gamma yield fraction), but in no case shall the LLD, as calculated in this manner for a specific radionuclide, be greater thr.n 10% of the MPC value specified in 10 CFR 20, Appendix B, Table II, Coulumn 2.

c.

A composite sample is one in which the quantity of liquid sampled is propor-tional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids

released, d.

To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected continuously in proportion to the rate of flow of the effluent stream.

Prior to analyses, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluent release.

e.

A batch release is the discharge of liquid wastes of a discrete volume, f.

The principal gamma emitters for which the LLD specification will apply are exclusively the following radionuclides:

Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144.

This list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in LLD's higher than required, the reasona shall be documented in the semiannual Radioactiva Effluent Release Report.

178d

TABLE 4.8.A-2 FREQUENCY NOTATION FOR TABLES IN SPECIFICATIONS 3.8. A-L AND 4.8. A-L Notation Frequency S

At least once per 12 ho uns.

D At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

W At least once per 7 days.

M At least once per 31 days.

Q At 1, east once per 92 days.

SA At least once per 184 days.

R At least once per 18 months.

S/U Prior to each reactor startup.

P Completed prior to each release.

N.A.

Not applicable.

s 178e

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS INSTRUMENTATION 3.8.B Radioactive Liquid Effluent 4.8.B Radioactive Liquid Effluent Instrumentation Instrumentation

1. The radioactive liquid efflu-

1. The setpoints for monitoring ent monitoring instrumentation instrumentation shall be de-channels shown in Table 3.8.A-1 termined in accordance with shall be OPERABLE with their procedures as described in the alarm / trip setpoints set to ODCM and shall be recorded in ensure that the limits of station procedures.

Specification 3.8.A.1 are not exceeded.

2. Each radioactive liquid effluent monitoring instrumentation chan-Applicability nel shall be demonstrated OPERABLE at the frequencies shown in Table As shown in Table 3.8.A-1.

4.8.B-1.

Action

3. Records - Auditable records shall be maintained of all radioactive a.

With a radioactive liquid effluent monitoring instru-liquid effluent mon-mentation alarm / trip setpoints.

itoring instrumentation Setpoints and setpoint calcula-channel alarm / trip set-tions shall be available for point less conservative review to ensure that the limits than a value which will of Specification 3.8.A.1 are met, ensure that the limits of 3.8.A.1 are met, im-mediately suspend the release of radioactive liquid effluents mon-itored by the affected channel or declare the channel inoperable.

b.

With one or more radio-active liquid effluent monitoring instrumenta-tion channels inoperable, take the ACTION shown in Table 3.8.A-1.

179

TABLE 4.8.B-1 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Instrument Check Check Calibration Test 1.

Gross Beta or Gamma Radioactivity Monitors Providing Alarm and Auto-matic Isolation a.

Liquid Radwaste Effluents Line D*

N.A.

R(2)

Q(1) 2.

Flow Rate Measurement Devices a.

Liquid Radwaste Effluent Line D(3)*

N.A.

R Q

s 3

3.

Activity Recorders m

a.

Liquid Radwaste Effluent Line N.A.

N.A.

R Q

T ABLE 4. 8. B-1 (Continued) t TABLE NOTATION

• During releases via this pathway.

(1)

The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if any of the following conditions exist:

1.

Instrument indicates measured levels above the alarm / trip setpoint.

2.

C1'rcuit failure.

3.

Instrument indicates a dovnscale failure.

4.

Instrument controls not set in operate mode.

(2) CHANNEL CALIBRATION for radioactivity measurement instrumentation shall be per-formed according to established calibration procedures.

(3)

CHANNEL CHECK shall consist of verifying indication of flow during periods of release.

CHANNEL CHECK shall be made at least once daily on any day on which continuous, periodic, or batch releases are made.

179b

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFL'JENTS 3.8.C Dose 4 8.C Dose 1.

The dose or dose commitment 1.

Dose Calculations - Cumulative to an individual from radio-dose contributions from liquid active materials in liquid effluents shall be determined effluents released to un-in accordance with the Offsite restricted areas shall be Dose Calculation Manual (ODCM) linited:

at least once per 31 days.

a.

During any calendar 2.

Reports - The semiannual Radio-quarter to i 1.5 mrem active Effluent Release Report to the total body and shall include the information to 3 5 mrem to any organ, specified in Specification and 6.9.C.1.

Applicability At all times.

Action a.

With the calculated dose from the release of radio-active materials in liquid effluents exceeding any of the above limits,,

prepare and submit to the Commission within 30 days, following the end of the calendar quarter, pursuant to Specification 6.9.B.2, a Special Report which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken.

4 180

LI1!ITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.D Liquid Waste Treatment 4.8.D Liquid Waste Treatment 1.

The liquid radwaste treat-1.

Doses due to liquid releases ment system shall be used to unrestricted areas shall and maintained as deter-be projected at least once mined in the ODCM. The sys-per 31 days.

tem shall be used to reduce the radioactive materiais in liquid wastes prior to their discharge when the projected dose due to liquid effluent releases to unrestricted areas when averaged over 31 4

days would exceed 0.25 mrem to the total body or.83 mrem to any organ.

Applicability At all times Action a.

With radioactive liquid waste being discharged without treatment and in excess of the above limits, prepare and sub-mit to the Commission within 30 days, pursuant to Specification 6.9.B.2, a Special Report which includes the following information:

1.

Identification of equipment or sub-systems not OPERABLE and the reason for nonoperability.

2.

Action (s) taken to restore the nonop-erable equipment to OPERABLE status.

3.

Summary description of action (s) taken to prevent a recurrence.

181

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.E Gaseous Effluents Dose Rate 4.8.E Gaseous Effluents Dose Rate 1.

The dose rate at any time 1.

The release rate at any time in the unrestricted areas of noble gases in gaseous due to radioactive mater-effluents shall be controlled ials released in gaseous by the offsite dose rate as effluents from the site established above in Specifica-shall be limited to the tion 3.8.E.1.

following values:

2.

The noble gas effluent con-a.

The dose rate limit for tinuous monitors having noble gases shall be provisions for the automatic i 500 mrem /yr to the termination of gaseous re-total body and 3 3000 leases,' as listed in Table mrem /yr to the skin, 3.8.E-1, shall be used to and limit offsite doses within the values established in Specifi-b.

The dose rate limit for cation 3.8.E.1 when monitor all radioiodines and for setpoint values are exceeded.

all radioactive materials in particulate form and 3.

The release rate of radioactive radionuclides other than materials, other than noble noble gases with half gases, in gaseous effluents lives greater than 8 shall be determined by obtain-days shall be 31500 ing representative samples and mrem /yr to any organ.

performing analyses in accord-ance with the sampling and Applicability analysis program, specified in Table 4.8.E-1.

At all times 4.

The dose rate in unrestricted Action areas, due to rrdioactive materials other than noble With the dose rate (s) ex-gases released in gaseous ceeding the above limits, effluents, shall be de* ermined immediately decrease the to be within the required limits release rate to comply by using the results of the with the limit (s) given sampling and analysis program, in 3.8.E.1 and provide specified in Table 4.8.E-1, in prompt notification to the performing the calculations of Commission pursuant to 10 dose rate in unrestricted areas.

CFR 20.403.

5.

Reports - The semiannual Radio-active Effluent Release Report shall include the information specified in Specification 6.9.C.1 182

TABLE 3. 8. E-1 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument Operable Applicability Parameter Action 1.

Main Stack Ef fluent Monitoring System a.

Noble Gas Activity Monitor (1)

Radioactivity Rate Measurement 6

b.

lodine Sampler Cartridge (1)

Verify Presence of Cartridge 7

ol c.

Particulate Sampler Filter (1)

Verify Presence of D'

Filter 7

d.

Effluent System Flow Rate Measuring Device (1)

System Flow Rate Measurement 5

c.

Sampler Flow Rate Measuring Device (1)

Sampler Flow Rate Measurement 5

2.

Reactor Building Ventilation Ef fluent Monitoring System a.

Noble Gas Activity Monitor (1)

Radioactivity Rate Measurement 6

b.

Iodine Samp? er Cartridge (1)

Verify Presence of Cartridge 7

c.

Particulate Sampler Filter (1)

Verify Presence of Filter 7

d.

Effluent System Flow Rate Measurement Device (1)

System Flow Rate Measurement 5

TABLE 3.8.E-1 (Continued)

RADI0 ACTIVE CASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument Operable Applicability Parameter Action 2.

Reactor Building Ventilation Ef fluent Monitoring System (Continued) e.

Sampler Flow Rate Measurement Sampler Flow Rate Device (1)

Measurement 5

3.

Candenser Air Ej ector Radioactivity Monitor g

en Noble Gas Radioactivity 5

Ncble Gas Activity Monitor (1) a.

Rate Measurement 4

TABLE 3.8.E-1 (Continued)

TABLE NOTATION

• During releases via this pathway.

• • During main condenser offgas treatment system operation.

• • • During operation of the main condenser air ejector.

ACTION 4 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, gases from the main condenser air ejector may be released to the offgas system for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided grab samples are taken at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and analyzed for gross activity within the ensuing 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

ACTION 5 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 28 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

ACTION 6 With the number of channels OIERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 28 days provided grab samples are taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and these samples are analyzed for activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 7 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 28 days, provided samples are continuoulsy collected with auxiliary sampling equipment for periods on the order of seven (7) days and analyzed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the end of the sampling period.

182c

TABLE 4.8.E-1 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Sampling Minimum Type LLD("

Gaseous Release Type Frequency Analysis of Activity (nCi/ml)

Frequency Analysis Main Stack M

Principal Gam-

~4 Rx Bldg. Vent Grab M

ma Emitters (b) 1X10 Sample R3 1X10-0

-12 Continuchs CharSoa{c)

I-131 IX10 Main Stack Sample I-133

~11 tYt0 Rx Bldg. Vent Continu$ud W (c)

Principal Gam-

~1 Particulate ma Emitters (b) 1X10 Samole (I-131. others) d M

-11 Continuo (us) Particulate gross a 1X10 Sample Continuo (d)

-11 us Particulate Sr-89, Sr-90 1X10 Sample Table Notation (a) Lower Limit of Detection (b)

The principal gamma emitters for which the LLD specification will apply are exclusively the following reaionuclides:

Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissiong and Mn-54, Fe-59, Co-58, Co-60, 2n-65, no-99, Cs-134, Cs-137, Ce-141 and Ce-144 for par-ticulate emissions. This list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD should not be reported as being present et the LLD level for that nuclide, When unusual cir-cumstances result in LLD's higher than required, the reasons shall be documented in the semi-annual effluent report.

(c) When the average daily gross radioactivity release rate increases by 50% (after factoring out power level changes) over the previous day, the iodine and particulate filters shall be analyzed to determine the release rate for iodines and particulates.

(d) The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calcula-tion made in accordance with Specifications 3.8.E.

182d

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.F Dose, Noble Cases 4.8.F Dose, Noble Cases 1.

The air dose in unrestricted 1.

Dose Calculations -

areas due to noble gases re-Cummulative dose contributions leased in gaseous effluents for the total time period shall shall be limited to the be determined in accordance following:

with dhe Offsite Dose Calcula-tion Manual (ODCM) at least a.

During any calendar once every 31 days.

quarter, to 3 5 mrad for gamma radiation 2.

Reports - The semiannual and i 10 mrad for beta Radioactive Effluent Release radiation; Report shall include the information specified in Specification 6.9.C.1.

Applicability At all times Action a.

With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, following the end of the calendar quarter pursuant to Specification 6.9.B.2, a Special Report which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken.

O 183

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.G.

Dose, Radioiodines_t Radioactive 4.8.G.

Dose, Radioiodines, Radioactive Material in Particulate Form, Material in Particulate Form

~and Radionuclides Other Than and Radionuclides Other Than Noble Gases Noble Gases 1.

he dose to an individual 1.

Dose Calculations -

from radiciodines, radio-Cumulative dose contributiens active materials in par-for the total time period ticulate form, and radio-shall be determined in ac-nuclides other than nob 1r cordance with the ODCM at gases with half-lives least once every 31 days.

greater than 8 days in gaseous effluents released 2.

Reports - The semiannual to unrestricted areas shall Radioactive Effluent be limited to the following:

Release Report shall include the information specified a.

During any calendar in Specification 6.9.C.1.

quarter to < 7.5 mrem; b.

During any calendar year to ( 15 mrem; (The dose design objective shall be reduced based on predicted carbon-14 releases if effluent sampling is not provided.)

Applicability At all times Action a.

With the calculated dose from the release of radiciodines, radioac-tive materials in particulate form, or radionuclides other than noble gases in gaseous effluents ex-ceeding any of the above limits, prepare and sub alt to tre Commie; ion within 30 days, pursuant to Specification 6.9.B.2 l

a Special Report which identifies the cause(s) i for exceeding the limit and defines the correc-tive actions to be taken to reduce the releases of radiciodines, radio-184

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.G.1 (Continued) active materials in particulate form, and radionuclides other than noble gases with half-lives greater than 8 days in gaseous effluents during the remainder of the cur-rent calendar quarter and during the subse-quent three calendar quarters so that the average dose or dose commitment to an in-dividual from such releases during these four calendar quarters is within (15) arem to any organ.

184a

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIR'OfENTS INSTREMENTATION 3.8.H Radioactive Gaseous Ef fluent 4.8.H Radioactive Gaseous Effluent Instrumentation Instrumentation 1.

The radioactive gaseous 1.

The setpoints shall be process and effluent mon-determined in accordance itoring instrumentation with procedures as described channels shown in Table in the ODCM and shall be re-3.8.E-1 shall be OPERABLE corded in station procedures, with their alarm / trip setpoints set to ensure 2.

Each radioactive gaseous that the limits of Spec-process or effluent moottor-ification 3.8.E.1 are not ing instrumentation char.nel exceeded.

sha.11 be demonstrated OPERABLE at the frequencies shown in

, Applicability Table 4.8.H-1.

As shown in Table 3.8.E-1.

3.

Auditable records shall be maintained of gaseous efflu-Action ent monitoring instrumentation alarm / trip setpcints.

Set-a.

With a radioactive points and setpoint calcula-gaseous process or tions shall be available for effluent monitoring review to ensure.that the instrumentation chan-limits of Specification nel ala.r-/ trip set-3.8.E.1 are met.

points less conserva-tive than a value which will ensure that the limits of 3.8.E.1 are met, declare the channel inoperable.

b.

With one or more radio-active gaseous process or effluent monitoring instrumentation channels inoperable, take the ACTION shown in Table 3.8.E-1.

s 9

185

. TABLE 4. 8.11-1 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Instrument Check Check Calibration Test 1.

Main Stack Ef fluent Monitoring System a.

Noble Gas Activity Monitor D*

M R(3)

Q(2) b.

Jodine Sampler Cartridge D*

N.A.

N.A.

N.A.

c.

Particulate Sampler Filter D*

N.A.

N.A.

N.A.

d.

Effluent System Flow Rate Measuring Device D*

N.A.

R Q

e.

Sampler Flow Rate Measuring Device D*

N. A.

R Q

2.

Reactor Building Ventilation Ef fluent Monitoring System a.

Noble Gas Activity Monitor D*

M R(3)

Q(2) b.

Iodine Sampler Cartridge D*

N.A.

h.A.

N.A.

c.

Particulate Sampler Filter De N.A.

N.A.

N.A.

d.

Ef fluent System Flow Rate Measuring Device D*

N.A.

R Q

e.

Sampler Flow Rate Measuring Device D*

N.A.

R Q

i

TABLE 4. 8.H-1 (Continued)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Instrument Check Check Calibr.stion Test 3.

Condenser Air Ej ector Radioactivity Monitor a.

Noble Gas Activity Monitor D**

N.A.

R(3)

Q(1) b.

Noble Gas Activity Recorder D**

N.A.

R Q

e

TABLE 4.8.H-1 (Continued)

TABLE NOTATION

• During releases via this pathway.

• • • During operation of the main condenser air ej ector.

(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if any of the following conditions exist:

1.

Instrument indicates measured levels above the alarm / trip setpoint.

2.

Circuit failure.

3.

Instrument indicates a downscale failure.

4.

Instrument controls not set in operate mode.

(2)

The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm an-nunciation occurs if any of the following conditions exist:

1.

Instrument indicates measured levels above the alarm / trip setpoint.

2.

Circuit failure.

3.

Instrument indicates a downscale failure.

4.

Instrument controls not set in operate mode.

(3)

CHANNEL CALIBRATION for radioactivity measurement instrumentation shall be per-formed according to established calibration procedures.

185c

FREQUENCY NOTATION FOR TABLE 4.8.H-1 Notation Frequency S

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

D At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

W At least once per 7 days.

M At least once per 31 days.

Q At least once per 92 days.

SA At least once per 184 days.

R At least once per 18 months.

S/U Prior to each reactor startup.

P Completed prior to each release.

N.A.

Not applicable.

185d

LIMITING CONDITION FOR OPERATION SURVEILLANCE REOUIREMENTS RADIOACTIVE EFFLUENTS 3.8.I Gaseous Radwaste Treatment 4.8.I Gaseous Radwaste Treatment 1.

The gaseous radwaste 1.

Doses due to gaseous re-treatment system shall leases to unrestricted be operated and main-areas shall be projected tained as determined at least once per 31 days.

in the ODCM. The sys-tem shall be used to 2.

The appropriate systems reduce radioactive shall be demonstrated materials in gaseous OPERABLE at least once per wastes prior to their 92 days unless the appropriate discharge when the system has been utilized to projected gaseous process radioactive gaseous effluent air doses effluents during the previous due to gaseous efflu-92 days.

eut releases to un-restricted areas when averaged over 31 dnys would exceed.83 mrad for gnrma radiation and 1.6 mrad for beta radiation.

Applicability At all times Action a.

With. gaseous wastes being e

discharged for more than 31 days without treatment and in excess of the above limits, prepare and submit to the Commission within 30 days, pursuant to Spec-T-

ification 6.9.B.2, a Special Report which in-cludes the following information:

1.

Identification of equipment of sub-systems not OPERABLE and the reason for non-operability.

186

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.I (Continued) 2.

Action (s) taken to restore the non-operable equipment to OPERABLE STATUS.

3.

Sumary description of action (s) taken to pre-vent a recurrence.

e 186a

LIMITING CONDITION FOR OPERATION SURVEILLANCE REOUIREMENTS RADIOACTIVE EFFLUENTS 3.8.J

! bin Condenser 4.8.J Main Condenser 1.

The gross radioactivity 1.

The gross radioactivity (beta and/or gamma) rate (beta and/or gamma) rate of noble gases measured of noble gases from the at the main condenser air main condenser air ejector ej ector shall be limited shall be determined to be to 850,000 uC1/sec.

within the above limit at the following frequencies Applicability by performing an isotopic analysis of a representa-At all times.

tive sample or gases taken 3

at the discharge (prior to Action dilution and/or discharge) of the main condenser air With the gross radioactivity ejector:

(beta and/or gamma) rate of noble gases at the main con-At least once per 31 days.

denser air ejector exceeding 850,000 uCi/sec., restore b.

Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following the gross radioactivity rate an increase, as indicated to within its limit within by the Condenser Air 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least Ej ector Noble Gas Activity HOT STANDBY within the next Monitor, of greater than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

50%, after factoring out increases due to changes in THERMAL POWER level, in the nominal steady state fission gas release from the primary coolant.

187

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.K Environmental Monitoring Program 4.8.K Environmental Monitoring Program

/m environmental monitoring pro-An environmental monitoring pro-gram shall be conducted to gram shtl1 be conducted as evaluate the effects of station follows:

operation on the environs and to verify the effectiveness of the 1.

Environmental samples shall be source controls on radioactive selected and analyzed according materials.

to Table 4.8.K-1 at the loca-tions described in Tables 4.8.K-2 and 4.8.K-3 and shown in Figures 4.8.K-1, 4.8.K-2 and 4.8.K-3.

2.

Analytical techniques used shall be such that the detection cap-abilities in Table 4.8.K-4 are achieved.

3.

A census of gardens producing fresh leafy vegetables for human consumption (e.g., lettuce, spinach, etc.) shall be con-ducted near the end of the growing season to determine or verify the location of the garden (available for sampling) yielding the highest calculated thyroid dose.

This census is limited to gardens having an area of 500 square' feet or more and shall be conducted under the following conditions as neces-sary to meet the above require-ments.

a.

Within a 1-mile radius of the plant site, enumeration by a door-to-door, or equivalent counting tech-nique.

b.

If no milk-producing animals are located in the vicinity of the site, as determined by item 4 below, the census described in item 3a above shall be extended to a distance of 5 miles from the site.

If the census indicates the existence of a garden at a location yielding a calculated thyroid dose greater than that from the previously sampled 188

LIMITING CONDITION FOR OPERATION i SURVEILLANCE REQUIREMENTS 3.8.K Environmental Monitoring Program 4.8.K Environmental Monitoring Program (Continued) garden, the new location shall replace the garden previously having the max-Laum calculated iodine con-centration.

Also, any loca-tion from which fresh leafy vegetables can no longer be obtained may be dropped from the surveillance program as long as the NRC is notified in writing, as soon as possible that such vegetables are no longer grown or no longer available at that locr. tion.

4.

A census of animals produ ing milk for human concumption shall be conducted at or near the middle of the grazing season to determine or verify the location yielding the high-est calculated annual average thyroid dose.

The census shall be conducted under the following conditions as necessary to meet th.e above requirements:

a.

Within a 1-mile radius from the plant site or within the 15 mrem /yr. isodose line, whichever is larger, enumeration by a door-to-door or equivalent, counting technique.

b.

Within a 5-mile radi,us for cows and for goats, enum-eration derived from re-ferenced information from county agricultural agents or other reliable sources.

If it is learned from this census that animals are present at a location which yields a calculated thyroid dose greater than from pre-viously sampled animals, the new location shall be added to the surveillance program as soon as practicable.

The sampling location having the lowest calculated dose may then be dropped from the sur-188a

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.K Environmental Monitoring Program 4.8.K Environmental Monitoring Program (Continued) veillance program at the end of the grazing season during which the census was conducted.

Also, any location from which milk can no longer ba obcained may be dropped from the sur-veillance program as long as the NRC is notified in writing, as soon as practicalbe, that milk-producing animals are no longer present, or milk samples are no longer available at that location.

5.

Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability or to malfunction of automatic sam-pling equipment.

In the event of equipment malfunction, every reasonable effort shall be made to complete corrective action prior to the end of the next sampling period.

Any signifi-cant deviations from the sam-pling schedule shall be ex-plained in the annual report.

6.

Detailed written procedures, including applicable check [

lists and instructions, shall be prepared and followed for all activities involved in carrying out the environmental monitoring program. Procedures shall include sampling, data recording and storage, instru-ment calibration, measurenents and analyses, and actions to be taken when anomalous measurements are discovered.

Procedures shall be prepared for insuring the quality of program results, including analytical measurements.

These procedures will identify the responsible organizations, 188b'.

LIMITING CONDITION FOR OPERATION SURVEILLANCE REOUIREMENTS 3.8.K Environmental Monitoring Program 4.8.K Environmental Monitoring Program (Continued) include purchased services (e.g., contractual lab) in-clude independent audits, and include systems (such as participation in IAEA and/or NBS intercalibration exercises and submission of " blind" quality control samples for analyses by the contractors) to identify and correct defi-ciencies, investigate anomalous or suspect results, and review and evaluate program results and reports.

m 188c

TABLE 4. 8. K-1 OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM L'ocations Exposure Pathway (Direction-Distence)

Sampling and Type and Frequency or Sample Type from Reactor Collection Frequency of Analysis AIRBORNE Particulates 11 (See Table 4.8.K.2)

Continuous sampling over Gross beta radioactivity at one week least 24 he"rs after filter change.

(a Quarterly com-s posi (by location) for gamma isotopic.

(b)

Radiciodine 11 (See Table 4.8.K.2)

Continuous sampling with Analyze weekly for I-131.

canister collection weekly DIRECT 20 (See Table 4.8.K.3)

Quarterly Gamma exposure quarterly.

(i)

Plymouth Beach and Priscilla/ White llorse Beach Annually (Spring)

Gamma exposura survey (i)

WATERBORNE Discharge Canal Continuous Composite Sample Gamma isot-pic (b) monthly; Bartlett Pond (SE-1.7 mi.)

Weekly grab sample and composite for 11-3 Powder Point (NNW-7.8 mi.)(d). Weekly grab sample analysis quarterly, (c).

AQUATIC Shellfish Discharge outfall Quarterly (at approximate Gamma isotopic (b); also see Duxbury Bay 3 month intervals) note (f).

Manomet Pt.

Plymouth or Kingston llarbor 5

Marshfield (d)

Lobster Vicinity of discharge Four times per season Gamma isotopic (b) on edible point portions Offshore (d)

Once per season

TABLE 4.8.K-1 (Continued)

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Locations Exposure Pathwa" (Direction-Distance)

Sampling and Type and Frequency or Sample Type from Reactor Collection Frequency of Analysis Fish Vicinity of discharge Quarterly, Groups I and 11 Gamma isotopic (b) on edible point (e)

In season, Groups III portions (e)

Offshore (d) and IV (e) Annually, each group Sediments Rocky Point Semi-annually Gamma isotopic (b) (c), see Plymouth liarbor also note (g)

Duxbury Bay Plymouth Beach 5

Manomet Pt.

7 Marshfield INGESTION (Terrestrial)

Milk Plymouth County Farm Semi-monthly during periods Gamma isotopic (b); radioiodine (W-3. 5 mi. ) (h) Whitman when animals are on pasture, analysis all samples.

Farm (NW-21 mi.)

(d) otherwise monthly Cranberries Manomet Pt. Bog At time of harvest Gamma isotopic (b) on edible

( S E-2. 6 mi. )

portions.

Bartlett Rd. Bog (SSE/S-2.8 mi.)

Pine St. Bog (WNW-17 mi. )

(d)

Tuberous and green Karbott Farm (SSE-2.0 mi.)

At time of harvest Gamma isotopic (b) on edible leaty vegetables (h)

Bridgewater Farm portions.

(W-20 mi.)

(d)

Beef Forage Plymouth County Farm Annually Gamma isotopic (b)

(W-3.5 mi.)

(h)

Whitman Farm

TABLE 4.8.K-1 (Continued)

NOTES (a)

If gross be.ta radioactivity is greater than 10 times the control value, gamma isotopic will be performed on the sample.

(b)

Gamma isotopic means the identification and quantification of gamma-emitting radionuclides that may be attributable to the ef-fluents from the facility.

(c)

If integrated gamma activity (less K-40) is greater than 10 times the control value (less K-40), strontium-90 analysis will be per-formed on the sample.

s (d)

Indicates control location.

(e) Fish analyses will be performed on a minimum of 2 sub-samples, con-sisting of approximately 400 grams each from each of the following groups:

I. Bottom Oriented II. Near Bottom III. Anadromous IV. Coastal Distribution Migratory Winter flounder Tautog Alewife Bluefish Yellowtail flounder Cunner Rainbow smelt Atlantic herring Atlantic cod Striped bass Atlantic menhaden Pollock Atlantic mackerel Eakes (f) Mussel samples from four locations (immediate vicinity of discharge outf all, Manomet Pt., Plymouth or Kingston Harbor, and Green Harbor in Marshfield) will be analyzed quarterly as follows:

One kilogram wet weight of mussel bodies, including fluid within shells will be collected.

Bodies will be reduced in volume by drying at about 100 C.

Sample will be compacted and analyzed by Ge(Li) gamma spectrometry or alternate technique, if necessary, to achieve a sensitivity ** of 5 pCi/kg for Cs-134, Cs-137, Co-60, Zn-65 and Zr-95 and 15 pCi/kg for Ce-144.

The mussel shell sample from one location will be analyzed each quarter.

One additional mussel shell sample will be analyzed semi-annually. Unscrubbed shells to be analyzed will be dried, processed, and analyzed similarly to the mussel bodies.

• • Sensitivity values are to be determined in accordance with a 95% confidence level on Ka ; 50% confidence level on Kp (See HASL-300 for definitions).

188f

TABLE 4.8.K-1 (Continued)

NOTES Because of the small volume reduction in pre-processing of shells, sensitivities attained will be less than that for mussel bodies.

The equipment and counting times to be employed for analyses of shells will be the same or comparable to that employed for mussel bodies so that the reduction in sensitivities (relative to those for mussel bodies) will be strictly limited to the effects of poorer geometry related to lower sample volume reduction. Shell samples not scheduled for analysis will be reserved (unscrubbed) for possible later analysis.

If radiocesium (Cs-134 and Cs-137) activity exceeds 200 pC1/kg (wet) in mussel bodies, these samples will be analyzed by radio-chemical separation, electrodeposition, and alpha spectrometry for radioisotopes of plutonium, with a sensitivity of 0.4 pCi/kg.

(g)

Sediment samples from four locations (Manomet Pt., Rocky Pt., Ply-mouth Harbor, and head of Duxbury Bay) will be analyzed once per year (preferably early summer) as follows:

Cores will be taken to depths of 30-cm, minimum depth wherever sediment conditions permit by a hand-coring sampling device.

If sediment conditions do not permit 30-cm deep cores, the deepest

~

cores achievable with a hand-coring device will be taken.

In any case, core depths will not be less than 14-cm.

Core samples will be sectioned into 2-cm increments, and surface and alternate increments analyzed, others reserved.

Sediment sample volumes (determined by core diameter and/or number of individual cores taken from any single location) and counting technique will be sufficient to achieve sensitivities of 50 pC1/kg dry sediment for Cs-134, Cs-137, Co-60, 2n-65, and Zr-95 and 150 pCi/kg for Ce-144.

In any case individual core diameters will not be less than 2 inches.

The top 2-cm section from each core will be analyzed for Pu iso-topes (Pu-238, Pu-239, 240) using radiochemical separations, elec-trodeposition, and alpha spectrometry with target sensitivity of 25 pC1/kg dry sediment.

Two additional core slices per year (mid-depth slice from two core samples) will be similarly analyzed.

(h)

These locations may be altered in accordance with results of sur-veys discussed in paragraphs 4.8.K-3 and 4.8.K-4.

188g

TABLE 4,8.K-2 AIR PARTICULATES, GASEOUS RADI0 IODINE AND SOIL SURVEILLANCE STATIONS Sampling Location Distance and (Sample Designation)

Direction from Reactor Offsite Stations East Weymouth (EW)*

23 miles IN*

Plymouth Center (PC) 4.5 miles W-WNW Manomet Substation (MS) 2.5 miles SE Cleft Rock Area (CR) 0.9 miles S Onsite Stations Rocky Hill Road (ER) 0.8 miles SE Rocky Hill Road (WR) 0.3 miles W-WNW Overlook Area (OA) 0.03 miles W Property Line (PL) 0.34 miles NW Pedestrian Bridge (PB) 0.14 miles N East Breakwater (EB) 0.35 miles ESE Warehouse (WS) 0.03 miles SSE

• Control Station 188h

TABLE 4.8.K-3 EXTERNAL GAMMA EXPOSURE SURVEILLANCE STATIONS (TLD)

Distance and Dosimeter Location (Designation)

Direction from Station Offsite Stations East Weymouth (EW)*

23 miles NW*

Kingston (KS) 10 miles WNW Sagamore (CS) 10 miles SSE-S Plymouth Airport (SA) 8 miles WSW North Plymouth (NP) 5.5 miles WNW Plymouth Center (PC) 4.5 miles W-WNW South Plymouth (SP) 3 miles WSW Manomet (MS) 2.5 miles SSE Manomet (ME) 2.5 miles SE Manomet (MP) 2.25 miles ESE-S Clef t Rock Area (CR) 0.9 miles S Sequish Neck (SN)**

4.6 miles NNW Onsite Stations Rocky Hill Road (ER) 0.8 miles SE Microwave Tower (MT) 0.38 miles S Rocky Hill Road (WR) 0.3 miles W-WNW Rocky Hill Road (B) 0.26 miles SSE Property Line (H) 0.21 miles SSW Property Line (I) 0.14 miles W Public Parking Area (PA) 0.07 miles N-NNE Overlook Area (OA) 0.03 miles W

• Control Station

• • TLD's for this location will be provided to a third party and will be analyzed for gamma exposure whenever returned to BECo.

1881

)

sy d r i d.

0 0

0 0

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5 5

5 5

Sk 1

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~

yi rC D p

(

s) t t ce uw d

og rk P/

i dC op c

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0 0

F 6

8 e,

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)

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L kk L

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(

ii d

MC 1

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)

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d e E

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2 2

A n

(

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0 0

0 o

1 1

1 M

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r x

x x

M i

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1 7

1 XAM

)

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1 k

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ei 0

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5 0

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t C 0

1 3

1 3

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ha

r TABLE 4.8.K-4 (Continued)

TABLE NOTATION a-The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability.

For a particular measurement system (which may include radiochemical separation):

4.66 sb LLD =

E V

2.22 Y

exp (-Aat) where LLD is the lower limit of detection as defined above (as pCi per unit mass or volume) sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)

E is the counting efficiency (as counts pe transformation)

V is the sample size (in units of mass or volume) 2.22 is the number of transformation per minute per pi,cocurie Y is the fractional radiochemical yield (when applicable)

A is the radioactive decay constant for the particular radionuclide sh is the elapsed time between sample collection (or end of the sample collection period) and time of counting.

The value of sb used in the calculation of the LLD for a detection system shall be based on the actual observed variance of the back-ground counting rate or of the counting rate of the blank samples (as appropriate) rather than on an unverified theoretically pre-dicted variance.

In calculating the LLD for a radionuclide deter-mined by gamma-ray spectrometry, the background shall include the typical contributions of other radionuclides normally present in the samples (e.g., potassium-40 in milk samples).

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluc tuations, unavoidably small sample sizes, the presence of inter-fering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors will be identified and described in the Annual Radiological Environ-mental Operating Report.

b-LLD for surface water.

c-LLD for leafy vegetables.

188k

_ TABLE 4.8.K-4 (Continued)

TABLE NOTATION 140 d-The Ba LLD and concentration can be determined by the analysis 140 of its short-lived daughter product La subsequent to an 8 day period following collection.

The calculation shall be predicted on the normal ingrowth equacions for a parent-daughter situation 140 a in the sample would and the assumption that any uraupported L

have decayed to an insignificant amount (at least 3.6 percent of its original value).

The ingrowth equations will assume that the 140 supported La activity at the time of collection is 0.

e-If the measured concentration is three sigma greater than the specified LLD, the sample does not have to be analyzed to meet the specified LLD.

1881

4 Green Harbor O

Oe Cape Cod a

Bay O'

Ouxbury Bay 0

1 2

3 4

S Kingston Plymouth Harbor A

Rocky Point Warren a

O Co

.4 Manomet and Stage U

Points i

LEGEND C IRISH MOSS O E//isvi//e O SOFTSHELL CLAMS Harbor e MUSSELS A SEDIMENT E QUAHOGS Figure 4.8.K-1 Typical Mollusc, Algae and Sediment Sampling Stations 188m

A 15 N

'N MILgg

'O MILgg Caoe Cod Bay 0MI l Lg 1

g o

Plymouth 56 Bay 30 4

W O

8 50 6 A 7

90 A

10 0 14 O

11 0 12 O OCSIMETER iTLD) f A AIR P ARTICULATES ANO 13 0 DOSIMETERS (TLD)

S LEGEND 1 QUX 8URY (SSl

• 9 MANOMET iMEl 10 MANOMET iMS) 2 KINGSTON iKS) 11 MANOMET (MS)*

3 NORTH PLYMOUTH INP) 12 COLLEGE PONO (cpl

• 4 PLYMOUTH CENTER (PC)

S SOUTH PLYMOUTH (SP) 13 SAGAMCRE (CSi 6 SAYSHORE ORIVE (80i*

14 PLYMOUTH AIRPORT (SA) 7 CLEFT ROCK AREA IC91--

15 EAST WEYMOUTH IEW) 8 MANOMET tMPI

16. Saquish Neck (SN)

• additional stations n0t required by Specification 4.8 K.1 Figure 4.8.K-3 Locat1On of Offsite Monitoring Stations 188o

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.L Dose 4.8.L Dose 1.

The dose or dose commitment 1.

Dose Calculations - Cumulative dose to a real individual from contributions from liquid and gas-Pilgrim Station Unit #1 eous effluents shall be determined sources is limited to (25 in accordance with Specifications mrem to the total body or 3.8.C.1.a, 3.8.C.1.b, 3.8.F.1.a, any organ (except the 3.8.F.1.b, 3.8.G.1.a and 3.8.G.1.b, thyroid, which is limited and in accordance with the Offsite to j[ 75 mrem) over a period Dose Calculation Manual (ODCM).

of 12 consecutive months.

2.

Reports - Special Reports shall be Applicability subritted as required under Spec-ification 3.8.L.1.a.

At all times Action a.

With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specifications 3.8.C.1.a.

3.8.C.1.b, 3.8.F.1.a, 3.8.F.1.b, 3.8.G.1.a, or 3.8.G.1.b, prepare and submit a Special Report to the Commission pur-suant to Specification 6.9.B.2 and limit the subsequent releases such that the dose or dose commitment to a real in-dividual from all uranium fuel cycle sources is limited to <25 mrem to the total body or any organ (except thyroid, which is limited to j[ 75 mrem) over 12 consecutive months.

This Special Report shall include an analysis which demonstrates that radia-tion exposures to all real individuals from all ur-anium fuel cycle sources (including all effluent pathways and direct radia-tion) are less than the 40 CFR Part 190 Standard.

Otherwise, obtain a vari-ance from the Commission to permit releases which exceeds the 40 CFR Part 190 Standard.

188p

BASES 3.8.A

_LIOUID EFFLUENTS CONCENTRATION and 4.8.A This specification is provided to ensure that the concentration of radio-active materials released in liquid waste effluents from the site to un-restricted areas will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II.

This limitation provides additional assurance that the levels of radioactive materials in bodies of water out-side the site will not result in exposures within (1) the Section II.A design objectives of Appendix 1, 10 CFR Part 50, to an individual and (2) the limits of 10 CFR Part 20.106(e) to the population.

The concentration limit for noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the metho s described in d

International Commission on Radiological Protection (ICRP) Publication 2.

3.8.B RADIOACTIVE LIQUID EFFLUENT INSTRUMENTATION and 4.8.B The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. Tb; alarm / trip setpoints for these instruments shall be calculated in.cordance with NRC approved methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20.

The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

3.8.C DOSE and 4.8.C This specification is provided to implement the requirements of Sections II.A, III.A and IV.A of Appendix I, 10 CFR Part 50.

The Limiting Condition for Operation implements the guides set forth in Section II.A of Apppendix I.

The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable". Alternatively, Pilgrim is not a site where plant operations can conceivably affect drinking water so that none of these requirements are intended to assure compliance with 40 CFR 141.

The dose calculations in the ODCM implement the requirements in Section III. A of 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 an individual through appropriate pathways is un-likely to be substantially underestinated.

The equations specified in the ODCM for calculating the doses due to the actual release rates of radio-active materials in liquid effluents will be consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compli-ance with 10 CFR Part 50, Appendix I",

Revision 1, October 1977 and Regulatory Guide 1.113.

189

RhELS

" Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I",

April 1977.

NUREG-0133 provides methods for dose calculations consistent with Regu-latory Guides 1.109 and 1.113.

3.8.D LIQUID WASTE TREATMENT _ _

and 4.8.D The OPERABILITY of the liquid radwaste treatment system ensures that this system will be available for use whenever liquid effluents require treat-ment prior to release to the environment.

The requirements that the appropriate portions of this system be used when specified, provides as-surance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable".

This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Ap-pendix A to 10 CFR Part 50 and design objective 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 guide set fo;th in Section II.A of Appendix 1, 10 CFR Part 50, for liquid effluents.

3.8.E GASEOUS EFFLUENTS DOSE RATE and 4.8.E This specification is provided to ensure that the dose rate at anytime at the exclusion area boundary from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for unre-stricted areas.

The annual dose limits are the doses associated with the concentration of 10 CFR Part 20, Appendix B, Table II.

These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual in an unrestricted area, either within or outside the exclusion area boundary, to annual average concentrations exceeding the limits specified in Ap-pendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b)).

For in-dividuals who may at times be within the exclusion area boundary, the occupancy cf the individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the exclusion area boundary.

The specified release rate limits restric*, at all times, the corresponding gamma and beta dose rates above background to an individual at or beyond the exclusion area boundary to < (500) mrem / year to the total body or to < (3000) mrem / year to the skin.

These release rate limits also restrict, at all times, the corresponding thy-roid dose rate above background to an infant via the cow-milk-infant pathway to 5 1500 mrem / year for the nearest cow to the plant.

This specification applies to the release of gaseous effluents from all reactors at the site.

For units with shared radwaste treatment systems, the gaseous effluents from the shared system are proportioned among the units sharing that system.

3.8.F

. DOSE, NOBLE GASFC,

and 4.8.F This specification is provided to implement the requirements of Sections II.B. III.A and IV.A of Appendix I, 10 CFR Part 50.

The Limiting Con-dition for Operation implements the guides set forth in Seccion II.B of Appendix I.

The ACTION statements provide the required operating flex-ibility and at the same time implement the guides set forth in Section IV.A 190

BASES of Appendix I assure that the releases of radioactive material in gaseous effluents will be kept "as low ar is reasonably achievable".

The Surveil-lance Requirements Luplement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I is to be shown by calcu-lationcl procedures based on models and data such that the actual exposure of an individual through the appropriate pathvays is unlikely to be substan-tially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I", Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Ef fluents in Routine Releases from Light-Water-Cooled Reactors", Revision 1, July 1977. The ODCM equations provided for determining the air doses at the exclusion area boundary will be based upon the historical average atmospheric conditions.

NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.111.

3.8.G DOSE, RADIOIODINES, RADIOACTIVE MATERIAL Ih PARTICULATE FORM AND RADIO-and NUCLIDES OTHER THAN NOBLE GASES 4.8.G This specification is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix I, 10 CFR Part 50.

The Limiting Con-ditions for Operation are the guides set forth in Section II.C of Appendix 1.

The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable".

The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section III. A of 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 an individual through appropriate pathways is unlikely to be substantially underestimated.

The ODCM calculational methods approved by NRC for calculating the doses due to the actual release rates of the subject materials are required to be consistent with the methodology pro-vided in Regulatory Guide 1.109, " Calculating of Annual Doses to Man from Routine Releases of Reactor Ef fluents for the Purpose of Evaluating Com-liance with 10 CFR Part 50, Appendix I", Revision I, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Ef fluents in Routine Releases from Light-Water-Cooled Reactors", Revision 1, July 1977.

These equations also provide for determining the actual doses based upon the historical average atmospheric conditions.

The release rate specifications for radioiodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area.

The pathways which are examined in the development of these calculations

1) individual inhalation of airborne radionuclides, 2) deposition of are:

radionuclides onto green leafy vegetation with subsequent consumption by man, 3) depositien 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.

191

B AS ES_

3.8.H RADIOACTIVE CASEOUS PROCESS AND EFI'LUENT MONITORING INSTRUMENTATION and 4.8.H The radioactive gaseous effluent inattumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents.

The alarm / trip setpoints for these instruments shall be calculated in ac-cordance with NRC approved methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20.

The process monitoring instrumentation includes provisions for monitori.sg (and con-trolling) the concentrations of potentially explosive gas m.'xtures in the main condenser offgas treatment system.

The OPERABILIT1 and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

3.8.I CASE 0US WASTE TREATMENT and 4.8.I The OPERABILITY of the gaseous radwaste treatment system and the ventilation exhaust treatment systems 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 whca specified provides reasonable ascurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable". This specification implements the requirements of 10 CFR Part 50.36a, Generel Design Criterion 60 of Ap-pendix A to 10 CFR Part 50, and design obaactive Section IID of Appendix I to 10 CFR Part 50.

The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the guide set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

3.8.J

. MAIN CONDENSER and 4.8.J Restricting the gross radioactivity rate of noble gases from the main condenser provides reasonable assurance that the total body exposure to an individual at the exclusion area boundary will not exceed a small fraction of the limits of 10 CFR Part 100 in the event this effluent is inadvertently discharged directly to the environment without treatment.

This specification implements the requirements of General Design Criteria 60 and 64 ef Appendix A to 10 CFR Part 50.

192

BASES ENVIRONMENTAL MONITORING PROGRAM

3. 8..

and An Environmental radiological monitoring program is conducted to verify 4.8.K the adequacy of in-plant controls on the release of radioactive materials.

The program is designed to detect radioactivity concentrations which could result in radiation doses to individuals not exceeding the levels set forth in 10 CFR 50, Appendix I.

A supplemental monitoring program for sediments and russels has been in-corporated into the basic program (see notes f and g to Table 4.8.1)

's a result of an a3reement with the Massachusetts Wildlife Federation.

This supplemental program is designed to provide information on radioactivity levels at substantially higher sensitivity levels in selected samples to verify the adequacy (or, alternatively, to provide a basis #ne later mod-ifications) of the long-term marine sampling schedules.

au,.ct of the supplemental program, analysis of mussels for isotopes,of plutonium will be performed if radiocesium activity should exceed 200 pCi/Kgm in the edible portions.

The 200 pCi/Kgm radiocesium " action level" is based on calculations which showed that if radiocesium from plant releases reached this level, plutonium could possioly appear at levels of potential interest.* The calculations also showed that the dose delivered from these levels of plutonium would not be a significant portion of the total dose attributable to liquid ef-fluents.

The program was also designed to be consistent, wherever applicable with NUREG 0473.

Groundwater flow at the plant site is into Cape Cod Bay; therefore, ter-restrial monitorik of groundwater is not included in this program.

3.8.L Dose and 4.8.L This specification is provided to meet the reporting requirements of 40 CFR 190.

References:

1.

Wrenn, M.E., " Review of Sr-90 Releases from Pilgrim i Nuclear Plant and a Comparison with Extant Environmental uevels", 1976.

2.

Pilgrim Station Unit #2 PSAR, Appendix 11F, pp. IlFC-ll and 11A, amended June 15, 1976.

• ln measurable quantities having a potential dose (human food chain) significance comparable to other nuclides if present at their detection limits.

193

C.

UNIQUE REPORTING REQUIREMENTS l.

Radioactive Effluent Release Report A report shall be submitted to the Commission within 60 days af ter January, 1 and July, 1 of each year specifying the quantity of er.ch of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents during the previous 6 months.

The format and content of the report shall be in accordance with Regu-latory Guide 1.21 (Revision 1) dated June, 1974.

2.

Environmental Program Data a.

Annual Report.

A report on the radiological environmental sur-veillance program for the previous 12 months of operation shall be submitted to the Director of the NRC Regional Office with a copy to the Director, Office of Nuclear Reactor Regulation) as a separate document whithin 90 days after January 1 of each year.

The reports shall include summaries, interpretations, and sta-tistical evaluation of the results of the radiological environ-mental surveillance activities for the report period, including a comparisca with preoperational studies, operational controls (as appropriate), and previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment.

The reports shall also include the results of any land use surveys which af fect the choice of sample locations.

If harmful effects or evidence of irreversible damage are de-tected by the monitoring, the licensee shall provide an analysis of the problem and a proposed course of action to alleviate the problem.

Resultsofallradiolo[icalenvironmentalsampleschallbesum-marized and tabulated on an annual basis.

In the event that some results are not available within the 90-day period, the report shall be submitted, noting and explaining the reasons for the missing results.

The missing data shall be submitted as soon as possible in a supplementary report, b

The following event shall be the subject of a written report to the Director of the Regional Office within 60 days of the occurrence of the event. Measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting level values of Table 6.9.C-1 when averaged over any calendar quarter sampling period.

When more than one of the radionuclides in Table 6.9.C-1 are detected in the sampling medium, this report shall be submitted if:

concentration (1) concentration (2) limit leve' (1)

+ limit level (2)

+... ?_ l. 0 When radianuclides otner than those in Table 6.9.C-1 are detected and are the result of plant erfluents, this report shall be submitted if the potential annual dose to an individual is equal to or greater than the calendar year limits of Specifications 3.8.C.1, 3.8.F.1 and 3.8.G.I.

This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the con-dition shall be reported and described in the Annual Radiological En-vironmental Operating Report.

223

TABLE 6.9.t-.

REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Reporting Levels Water AirborneParticugate Fish Milk Vegetables Analysis (pCi/1) or Cases (pci/M )

(pCi/Kg, wet)

(pCi/l)

(pci/kg, wet) 0 11-3 3 x 10 3

4 Mn-54 1 x 10 3 x 10 2

4 Fe-59 4 x 10 1 x 10 o

3 4

Co-58 1 x 10 3 x 10 2

4 Co-60 3 x 10 1 x 10 4

Zn-65 3 x 102 2 x 10 2

Zr-Nb-95 4 x 10 2

I-131 2

0.9 3

1 x 10 3

3 Cs-134 30 10 1 x 10 60 1 x 10 3

Cs-137 50 20 2 x 10 70 2 x 10 2

2 Ba-La-140 2 x 10 3 x 10

OFFSITE DOSE CALCULATION MANUAL _ (0DCM) 3.

The ODCM shall describe the methodology and parameters to be used in cal-culation of offsite doses due to radioactive gaseous and liquid ef fluents and in the calculation of gaseous and liquid ef fluent monicoring instru-mentation alarm / trip setpoints consistent with the applicable LCO's con-tained in these Technical Specifications.

Methodologies and calculational procedures acceptable to the Commission are contained in NUREG-0133.

The ODCM shall be submitted to the Commission at the time of proposed Radiological Effluent Technical Specifications and shall be subject to review and appr. oval by the Commission prior to implementation.

Any changes to the ODCM shall be made by either of the following methods:

A.

Licensee initiated changes:

1.

Shall be submitted to the Commission by inclusion in the Monthly Operating Report pursuant to Specification 6.9.A.2 within 90 days of the date the change (s) was made ef fective and shall contain:

a.

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 ODCM to be changed with each page numbered and provided with an ap-proval and date box, together with appropriate analyses or evaluations justifying the change (s);

b.

A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and c.

Documentation of the fact that the change has been reviewed and found acceptable by the (ORC).

2.

Shall become effective upon a date specified and agreed to by the (ORC) following its review and acceptance of the change (s).

B.

Commission initiated changes:

1.

Shall be determined by thc (ORC) to be applicable to the facility after consideration of facility design.

2.

The licensee shall provide the Commission with written notification of their determination of applicability including any necessary revisions to reflect facility design.

223b

4.

Special Reports Special reports shall be submitted as indicated in Table 6.9.1.

6.10 RECORD RETENTION A.

The following records shall be retained for at least five years:

1.

Records of facility operation covering time interval at each power level.

2.

kecords of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

3.

Reportable Occurrence Reports.

4.

Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

5.

Records of reactor tests and experiments.

6.

Records of changes made to Operating Procedures.

7.

Records of radioactive shipments.

8.

Records of sealed source leak tests and results.

9.

Records of annual physical inventory of all source material of record.

B.

The following records shall be retained for the duration of the Operating License:

1.

Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

2.

Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

3.

Records of facility radiation and contamination surveys.

4.

Records of radiation exposure for all individuals entering radiation control areas.

y 224