ML19270G439

Requests Revisions to Radiological Effluent Tech Specs. Requests Implementation of Tech Specs After 791201

ML19270G439
Person / Time
Site:	Brunswick
Issue date:	05/31/1979
From:	Utley E CAROLINA POWER & LIGHT CO.
To:	Ippolito T Office of Nuclear Reactor Regulation
References
GD-79-1109, NUDOCS 7906080265
Download: ML19270G439 (67)

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@P&L Carolina Power & Light Company May 31, 1979 FILE: NG-3514(B)

SERIAL NO: GD-79-1109 Office of Nuclear Reactor Regulation ATTN:

Mr. T. A. Ippolito, Chief Operating Reactors Branch No. 3 United States Nuclear Regulatory Commission Washington, D. C.

20555 BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS

Dear Mr. Ippolito:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90 and Part 2.101, and as requested by the Staff's November 15, 1978 letter, Carolina Power & Light Company (CP&L) hereby requests revisions to the Technical Specifications for its Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

These changes are to incorporate Radiological Effluent Technical Specificutions.

Changes to the Tech-nical Specifications are indicated by a vertical line in the right-hand margins of the affected pages which are attached.

This submittal includes the necessary changes to the Standard Technical Specifications in addition to a separate " APPENDIX A.1" for the Radiological Effluent Technical Specifications. Concurrent with implementation of these specifications, the superseded portions of Appendix B of the existing technical specifications should be deleted; this should include Sections 2.5 and 3.5, appropriate Bases paragraph.? and certain tables and figures.

CP&L requests that the NRC not imple-ment the r

.s ements of the attached specifications for BSEP prior to December 1, BSEP's target date for completing changes necessary to implement these 1979; thie specificas s.

t sently anticipate that the Off-Site Dose Calculation Manual (ODCM) requested b, staff will be ready for submittal in June, 1979.

In L. erdance with Footnote 2 of 10CFR170.22, this application is exempt from amendment fees since it resulted from a written Commission request.

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Mr. T. A. Ippolito, Chief May 31, 1979 Should you have any questions on this matter, please contact our staff.

Yours very truly, 6[ c 4 / Z &

E. E. Utley f

Executive Vice President Power Supply JAM /GJO/tl Attachments Sworn to and subscribed before me this 31st day of May, 1979.

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DEFINITIONS SHUTDOWN MARGIN 1.30 SHUTDOWN MARGIN shall be the amount of reactivity by which the reactor would be subtritical assuming that all conte:1 rods capable of inserticn are fully inserted except for the analytically determined highest worth rod wnich is assumed to be fully withdrawn, and the reactor is in the shutdown concition, cold, 68'F, and Xenon free.

STAGGERED TEST BASIS 1.31 A STAGGERED, TEST SASIS snali consist of:

a.

A test schedule fer n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals.

b.

The testing of cne system, subsystem, train or other designated componenc at the beginning of each subinterval.

THERMAL POWER 1.32 THERMAL POWER shall be the total reactor core hea,t transfer rate to the reactor coolant.

TOTAL PEAKING FACTOR 1.33 The TOTAL FEAKING FACTOR (TPF) shall be the ratio of local LHGR for any specific locatien on a fuel red diviced b'y the average LFGR associated with the fuel bundles of tne same type Operating at the core tverage bundle power.

UNIDENTIFIED LEAKAGE 1.34 LNIDENTIFIED LEAKAGE shall be ali leakage which is not IDENTIFIED L EAKAGE.

SOURCE CHECK 1.35 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.

4 s

j 2330 099 n

II I

I 1&2 l BRUNSWICK-UNITS 1-6

DEFINITIONS VENTILATION EXHAUST TREATMENT SYSTEM 1.36 A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed to reduce gaseous radiciodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing lodines or particulates from tne gaseous exhaust stream prior to the release to the environment. Such a system is not considered to have any ef fect on noble gas effluents. Engineered Safety Feature (USF) atmospheric cleanup systerns are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

OFFSITE DOSE CALCULATIONAL M ANUAL 1.37 The OFFSITE DOSE C ALCULATIONAL M ANU AL (ODCM) is a manual which contains the methodology and parameters to be used to calculate of fsite doses resulting from the release of radioactive gaseous and liquid effluents and the methodology to calculate gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints. The requirements of the ODCM are provided in Specification 6.13.

2330 100 BRlCSWICK - UNITS 1&2 1-6a

TABLE 1.1 FREOUENCY NOTATION NOTATION FREOUENCY 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.

A At least once per 366 days.

R At least once per.18 months (550 days).

S/U Prior to each reactor startup.

N.A.

Not applicable.

P Completed prior to each release.

2330 101 BRUNSWICK - UNITS 1&2 1-7

ADMINISTRATIVE CONTROLS PURPOSE (Continued) 1.

The radiological environmental monitoring program and the results thereof at least once per 12 months.

J.

The OFFSITE DOSE CALCUIATION MANUAL and implementing procedures at least once per 24 months.

2330 102 BRUNSWICK - UNITS 1&2 6-12a

ADMINISTRATIVE CONTROLS PROCEDURES (Continued) g.

The on-site portion of the radiological environmental monitoring program implementation.

h.

OFFSITE DOSE CALCULATION MANUAL implementation.

2330 103 BRUNSWICK - UNITS 1&2 6-14a

ADMINISTRATIVE CONTROLS STARTUP REPORT (Continued) completion of startup test program, and resumption or commencement of commercial power operation), supplementary reports shall be submitted at least every three months until all three events have been completed.

I ANNUAL REPORT 5

6. 9.1. 4 Annual reports covering :he activities of the unit or described below during the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to March 1 of the year following initial criticality.

6.9.1.5 Reports required on an annual basis shall include a tabulation of the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mrem /yr and their essociated man rem exposure according to work and job functions,2 c.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling.

The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.6 Routine radiological environmental operating reports covering the operation of the unit during the previous calendar year shall be sub-mitted prior to May 1 of each year.

6.9.1.7 These reports shall include summarized and tabulated results in the format of Table 6.9-1 of all radiological environmental samples taken during the report period. In the event that some results are not available for inclusion within the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible n a supplementary report. The report shall also include the results of the current land use census and a map of all sampling locations keyed to a table giving distances and directions.

1. A single submittal may be made for a multiple unit station. The sub-mittal should combine those sections that are common to all units at the station.

2.

This tabulatien supplements the requirements of 520.407 of 10 CFR Part 20, 2330 104 BRUNSWICK - UNITS 1&2

ADMINISTRATIVE CONTROLS ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT (Continued) 6.9.1.8 The reports shall provide interpretations and stat.istical evalua-tions of the results of the radiological environmental surveillance activities for the report period, including a comparison with operational controls (as appropriate) and an assessment of the observed impacts of the plant opera-tion on the environment. If harmful effects or evidence of irreversible damage are detected by the monitoring, the report shall provide an analysis of the problem and a planned course of action to alleviate the problem.

2330 105 BRUNSWICK - UNITS 162 6-16a

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ADMINISTRATIVE CONTROLS Semiannual Radioactive Effluent Release Report 6.9.1.9 Routine radioactive effluent release reports covering the operation of the unit during the previous six months shall be submitted within 60 days after January 1 and July 1 of each year.

6.9.1.10 These reports shall include the following:

1.

A summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, " Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants" (Revision 1, June 1974) with data summarized on a quarterly basis following the format of Appendix B thereof.

2.

A quarterly summary of the cumulative joint frequency distri-bution of wind speed, wind direction, and atmospheric stability during the report period.

3.

An assessment of radiation doses from the rcdioactive liquid and gaseous effluents released from the unit during each calendar quarter as outlined in Regulatory Guide 1.21.

MONTHLY OPERATING REPORT 6.9.1.11 Routine reports of operating statistics and shutdown experience shall be submitted on a monthly basis to the Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D. C.

20555, with a copy to the Regional Office, to arrive no later than the fifteenth of each month following the calendar month covered by the report.

In addition, any changes to the ODCM shall be submitted as part of this report within 90 days in which the change (s) was made effective.

REPORTABLE OCCURRENCES 6.9.1.12 The REPORTABLE OCCURRENCES of' Specifications 6.9.1.13 and 6.9.1.14 below, including corrective actions and measures to prevent recurrence, shall be reported to the NRC. Supplemental reports may be 2330 107 BRUNSWICK - UNITS 1&2 6-16c

ADMINISTRATIVE CONTROLS required to fully describe final resolution of occurrence. In case of corrected or supplemental reports, a licensee event report shall be com-pleted and reference shall be made to the original report date.

PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP 6.9.1.13 The types of events listed below shall be reported within 24 l

hours by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Director of the Regional Office, or his designate no later than the first working day following the event, with a written followup report within two weeks. The written followup report shall include, as a minimum, a completed copy of a licensee event report form. Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.

a.

Failure of the reactor protection system or o;her systems subject to limiting safety system settings to initiate the required pro-tective function by the tJme a monitored parameter reaches the setpoint specified as the limiting safety system setting in the technical specifications or failure to complete the required pro-tective function, b.

Operation of the unit or affected systems when any parameter or operation subject to a limiting condition for operation is less conservative than the least conservative aspect of the limiting condition for operation established in the technical specifications.

c.

Abnormal degradation discovered in fuel cladding, reactor coolant pressure boundary, or primary containment, d.

Reactivity anomalies involving disagreement with the predicted value of reactivity balance under steady state conditions during power operation greater than or equal to 1%

a k/k; a calculated reactivity balance indicating a SHUTDOWN MARCIN less con-servative than specified in the technical specifications; short-term reactivity increases that correspond to a reactor period of less than 5 seconds or, if subcritial, an unplanned reactivity insertion of more than 0.5% a k/k; or occurrence of any unplanned criticality.

2330 108 6-17 BRUNSWICK - UNITS 1&2

ADMINISTRATIVE CONTROLS PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP (Continued) e.

Failure or malfunction of one or more components which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems (s) used to cope with accidents analyzed in the SAR.

f.

Personnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems raquired to cope with accidents analyzed in the SAR.

g.

Conditions arising from natural or man-made events that, as a direct result of the event require plant shutdown, operation of safety systems, or other protective measures required by technical specifications, h.

Errors discovered in the transient or accident analyses or in the methods used for such analyses as described in the safety analysis report or in the bases for the technical specifications that have or could have permitted reactor operation in a manner less conservative than assumed in the analyses.

1 Performance of structures, systems, or components tMMequires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the safety analysis report or technical specifications bases; or discovery during plant life of conditions not specifically considered in the safety analysis report or technical specifications that require remedial action or corrective measures to prevent the existence or development of an unsafe condition.

THIRTY DAY WRITTEN REPORTS 6.9.1.14 The types of events listed below shall be the subject of written l

reports to the Director of the Regional Office within thirty days of occurrence of the ' event. The written report shall include, as a minimum, a completed copy of a licensee event report form. Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.

2330 109 6-18 BRUNSWICK - UNITS 1&2

ADMINISTRATIVE CONTROLS THIRTY DAY WRITTEN REPORTS (Continued) a.

Reactor protection system or engineered safety feature instru-ment settings which are found to be less conservative than those established by the technical specifications but which do not prevent the fulfillment of the functional requirements of affected systems, b.

Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation, c.

Observed inadequacies in the implementation of administrative or procedural controls which threaten to cause reduction of degree of redundancy provided in reactor protection systems or engineered safety feature systems.

d.

Abnormal degradation of systems other than those specified in 6.9.1.13.c above designed to contain radioactive material j

resulting from the fission process, e.

An unplanned offsite release of 1) more than 1 curie of radio-active material in liquid effluents, 2) more than 150 curies of noble gas in gaseous effluents, or 3) more than 0.05 curies of radiciodine in gaseous effluents. The report of such an unplanned offsite release of radioactive material shall include the following information:

1.

A description of the event and equipment involved.

2.

Cause(s) for the unplanned release.

3.

Actions taken to prevent recurrence.

4.

Consequences of the unplanned release.

f.

Measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting level values of Table 6.9-2 when averaged over any calendar quarter sampling period. When more than one of the radionuclides in Table 6.9-2 are detected in the sampling medium, this report shall be submitted if:

2330 110 BRUNSWICK - UNITS 1&2 6-18a

ADMINISTRATIVE CONTROLS THIRTY DAY WRITTEN REPORTS (Continued) concemration (1)

+

concentration (2) +... > 1.0 reporting level (1) reporting level (2)

When radionuclides other than those in Table 6.9-2 are detected and are the result of plant effluents, this report shall be submitted if the potential calendar year dose to an individual is equal to or greater than the following limits:

1.

3 mrem to the total body or 10 mrem to any organ from non-airborne radionuclides.

2 15 mrem to any organ from airborne radiciodines or radioparticulates.

If the measured level of radioactivity is not a result of plant effluents, this report is not required; however, the condition shall be reported and described in the Annual Radiological Environmental Operating Report,

g.

Exceeding the limits of Specifications 1.1.2.1 and 1.2.2.1 in Appendix A.1.

The report shall include the following information:

1.

The cause(s) for exceeding the limit (s).

2 The action (s) taken to restore the release of radioactive effluents to be within the limit (s).

3.

A summary description of action (s) taken to prevent a similar recurrence in the future.

h.

Exceeding the limits of Specifications 1.1.3.1(a),1.2.3.1(a), or 1.2.4.1(a) in Appendix A.1.

The report shall include the following information:

1.

The cause(s) for exceeding the limit (s). If the cause(s) is/are related to the unavailability of components in the appropriate radwaste treatment system, the unavailable equipment or subsystems shall be identified.

BRUNSWICK - UNITS 1&2 6-18b

ADMINISTRATIVE CONTROLS THIRTY DAY WRITTEN REPORTS (Continued) 2.

The action (s) taken to reduce the releases of radioactive effluents during the remainder of the current calendar year such that the limits of Specifications 1.1.3.1(b),1.2.3.1(b),

or 1.2.4.1(b), Appendix A.1, are not exceeded. The action (s) taken to restore the unavailable equipment to its available status shall be described as applicable.

3.

A summary description of action (s) taken to prevent a similar recurrence in future calendar quarters.

1.

Exceeding the limits of Specifications 1.1.3.1(b),1.2.3.1(b), or 1.2.4.1(b) in Appendix A.1.

In lieu of any other report, this report shall include the following information:

1.

The cause(s) for exceeding the limit (s). If the cause(s) is/are related to the unavailability of components in the appropriate radwaste treatment system, the unavailable equipment or subsystems shall be identified.

2.

A summary description of action (s) taken to prevent a similar recurrence in future calendar years. The action (s) taken to restore the unavailable equipment to its available status shall be described as applicable.

2330 112 6-18e llRUNSWICK - UNITS 162

TABLE G.9-2 5

REPORTIllG LEVELS FOR RADI0ACTIVllY C0itCEllTRATIO!(S Ill EilVIR0fE!E!!TAL SAMPLES E

12 Reporting Levels Water-Airborne Particulate Fish 1111k Food Products g

Analysis (pCl/1) or Gases (pCl/ra )

(pCl/Kg,uct)

(pCl/1)

(pC1/Kg, wet) 3 b

II-3 3 x 104 3

4 11n-54 1 x 10 3 x 10 2

4 Fe-59 4 x 10 1 x 10 4

Co-58 1 x 10 3 x 10 4

Co-60 3 x 10

.1 x 10 2

4 i

Zn-65 3 x-10 2 x 10 a"

2 Zr-lib-95 4 x 10 2

1-131 2

0.9 3

1 x 10 3

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

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

2

[

Da-La-140 2 x 10 3 x 10 u

CD e

s ADMINISTRATIVE CONTROLS 6.13 OFFSITE DOSE CALCUIATION MANUAL (ODCM)

FUNCTION 6.13.1 The ODCM shall describe the methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring instrumentation alarn/ trip setpoints consistent with the appli-cable LCO's contained 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 and shall be subject to review and approval by the Commission prior to implementation.

6.13.2 Any changes to the ODCM shall be made by the following method:

Changes to the ODCM may be made by the Licensee to become effective af ter review by PNSC and approval by the Plant Manager.

Such changes shall be submitted to the Commission by inclusion in the Monthly Operating Report within the 90-day period after the change (s)

(were) made and shall contain sufficiently detailed information was to support the rationale for the change. Information submitted shall consist of a package of the revised ODCM pages with each page numbered.

2330 114 6-22 BRUNSWICK - UNITS 1&2

APPENDIX A.1 RADIOLOGIC AL EFFLUENT TECHNIC AL SPECIFIC ATIONS FOR THE BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS. 1 AND 2 2330 115

Brunswick Table of Contents Section Title Page 1.1 Liquid Effluents Al-I 1.1.1 Radioactive Liquid Effluent A.1-1 Instrumentation 1.1.2 Liquid Effluents Concentration A.1-5 1.1.3 Liquid Effluents Dose A.1-10 1.2 Gaseous Effluents A.1-13 1.2.1 Radioactive Gaseous Etfluent A.1-13 Instrumentation 1.2.2 Gaseous Effluents Dose Rate A.1-21 1.2.3 Gaseous Effluents Dose, Noble Gases Al-27 1.2.4 Gaseous Effluents Dose, Radiciodines Al-29 and Radioactive Materials In Particulate Form 1.3 40 CFR 190 A.1-32 1.3.1 Effluents Dose A.1-32 1.4 Main Condenser Air Ejector Radioactivity A.1-33 1.4.1 Main Condenser Air Ejector A.1-33 Instrumentation 1.4.2 Radioactivity Release Rate A.1-35 1.5 Drywell Purges A.1-37 1.5.1 Drywell Purges Mark II Containment A.1-37 Condition For Operation 1.6 Radiological Environmental Monitoring A.1-38 Program l.6.1 Monitoring Program A.1-38 1.6.2 Land Use Census A.1-45 List of Tables A.1-il List of Figures A.1-lii 2} }lf A.1-1 BRUNSWICK UNITS 1 & 2

Brunswick List of Tables Table Number Title Page 1.1-1 Radioactive Liquid Effluent Monitoring A.1-3 Instrumentation 2.1-1 Radioactive Liquid Effluent Monitoring A.1-4 Instrumentation Surveillan.ce Requirements 2.1-2 Brunswick Radioactive Liquid Waste A.1-7 Sampling and Analysis Program 1.2-1 Radioactive Gaseous Effluent Monitoring A.1-15 Instrumentation 2.2-1 Radioactive Gaseous Effluent Monitoring A.1-19 Instrumentation Surveillance Requirements 2.2-2 Brunswick Radioactive Gaseous Waste A.1-24 Sampling and Analysis Program 2.4-1 Main Condenser Air Ejector Instrumentation A.1-34 Surveillance Requirements 1.6-1 Brunswick Radiological Environmental A.1-40 Monitoring Program 2.6-1 Maximum Values For the Lower Limits of A.1-43 Detection (LLD) " 2330 117 BRUNSWICK UNITS 1 & 2 A.1-ii

Brunswick List of Figures Figure Number Title Page 1.1-1 Unrestricted Area Boundaries for Implementation A.1-9 of 10CFR20 for Liquids for Brunswick Steam Electric Plant 1.2-1 Unrestricted Area Boundaries for implementation A.1-23 of 10CFR20 for Gases for Brunswick Steam Electric Plant 2330 118 O BRUNSWICK UNITS 1 & 2 A.1-iii

1/21.1 ~ LIQUID EFFLUENTS 1/21.1.1 RADIOACTIVE LIQUID EFFLUENT INSTRUMENTATION LIMITING CONDITION FOR OPERATION 1.1.1.1 The radioactive liquid effluent monitoring instrumentation channels shown in Table 1.1-1 shall be OPERABLE with their alarm / trip setpoints set to ensure that the limits of Specification 1.1.2.1 are not exceeded. APPLICABILITY: As shown in Table 1.1-1. ACTION: With a radioactive liquid effluent monitoring instrume..tation channel a. monitor alarm / trip setpoint less conservative than a value which will ensure that the limits of Specification 1.1.2.1 are met, immediately suspend the release of radioactive liquid effluents monitored by the affected channel or declare the channel inoperable. b. With one or

mcce radioactive liquid effluent monitoring instrumentation channels inoperable, take the ACTION shown in Table 1.1-1.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. c. SURVEILLANCE REQUIREMENTS 2.1.1.1 The setpoints shall be determined in accordance with procedures as described in the ODCM. 2.1.1.2 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST at frequencies shown in Table 2.1-1. 2330 119 BRTNSWICK INITS 1 & 2 A.1-1

BASES The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents de-ing actual or potential releases of liquid effluents. The alarm / trip setpoints for these instruments shall be calculated in accordance with the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. The OP-ERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, and 64 of Appendix A to 10 CFR Part 50. 2330 120 BRUNSWICK UNITS 1 & 2 A.1-2

TABLE 1.1-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Release Pathway Action

1. Liquid Radwaste Effluent Line a.

Monitor With the monitor inoperable, efflu-(D12-RM-K604) ent releases may be resumed for up to 14 days, provided that prior to initiating a release: 1. At least two independent samples are analyzed in accordance with Specification 2.1.2.3, and; 2. At least two members of the facility staff independently verify the release rate cal, culations. b. Flow Rate Measurement With the flow rate measurement de-Device Jice inoperable, effluent releases (HIC-R038) via this pathway may continue for up to 14 days provided the flow rate is estimated at least once per 4 hours during actual releases. 2330 12i BRUNSWICK UNITS 1 & 2 A.1 -3

TABLE 2.1-1 RADIOACTIVE LIQUl') EFFLUENT MONITORING INSTRUMENTATION SURVE'LLANCE REQUIREMENTS Channel Channel Source Channel Functional Release Pathway Check Check Calibration Test 1.' Liquid Radwaste Effluent Line (1) (2) (3) a. l'onitor D M R Q (D12-RM-K604) b. Flow Rate Measurement (1) (4) Device D N. A. R N. A. (HlC-R038) Table Notation

1. During releases via this pathway.

2. The Channel Calibration for radioactivity measurement instrumentation shall be performed using one or more reference standards.

3. 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 set point.

2. Circuit failure.

3. Instrument indicates a downscale failure.

4. The 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. 2330 122 BRUNSifICK UNITS 1 & 2 pg1_4

1/21.1.2 LIQUID EFFLUENTS CONCENTRATION LIMITING CONDITION FOR OPERATION 1.1.2.1 The concentration of radioactive material released at any time from the site to unrestricted areas (see Figure 1.1-1) shall be limited to the con-centrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radio-nuclides other than dissolved or entrained noble gases. [or dissolved or entrained noble gases, the concentration shall be limited to 2 x 10' pCi/mi total activity. APPLICABILITY: At all times. ACTION: a. With the concentration of radioactive material released from the site to unrestricted areas exceeding the above limits, restore concen-tration of the effluent to unrestricted areas within the above limits and provide notification to the Commission pursuant to Specification 6.9.1.14. b. The provisions of 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.1.2.1 The concentration of radioactive material at any time in liquid ef-fluents released from the site shall be continuously monitored in accordance with Table 1.1-1. 2.1.2.2 The liquid effluent continuous monitors having provisions for automatic termination of liquid releases, as listed in Table 1.1-1, shall be used to limit the concentration of radioactive material released at any time from the site to unrestricted areas to the values given in Specification 1.1.2.1. 2.1.2.3 The radioactivity content of each batch of radioactive liquid waste to be discharged shall be determined prior to release by sampling and analysis in accordance with Table 2.1-2. The results of pre-release analyses shall be used with the calculational methods in the ODCM to assure that the concentration at the point of release is limited to the values in Specification 1.1.2.1. 2330 123 BRtWSWICK UNITS.1 & 2 A.1-5

2.1.2.4 Post-release analyses of samples from batch releases shall be per-formed in accordance with Table 2.1-2. The results of the post-release analyses shall be used with the calculational methods in the ODCM to assure that the concentrations at the point of release are limited to the values in Specification 1.1.2.1. BASES This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II. This limitation provides additional assurance that the levels of radio-active materials in bodies of water ou side the site will not result in exposures within (1) the Section II.A design objectives of Appendix I,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 methods described in International Commission on Radiological Protection (ICRP) Publication 2. 2330 124 BRUNSWICK UNITS 1 & 2 A.1-6

TABLE 2.1-2 BRUNSWICK RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Sampling Minimum Analysis Type of Activity Lower Limit Liquid Release Type Frequency Frequency Analysis of Detection (LLD) (gCi/ml)a, e P P A. Sample Tank & Each Batch Each Batch Mn-54, Fe-59, 5 x 10-7 b,d Detergent Drain Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-1416 Ce-144 P W -6 Each Batch Composite I-131, Ba-La-140 1x 10 One Batch /M M Dissolved and lx 10-3 Pntrainod Gasos P M c Each Batch Composite Gross a 1x 10~ -5 H-3 1x 10 Rr-R9 5x 10~ P Q Each Batch Composite Sr-90 5 x 10~ 2330 125 BRUNSWICK UNITS 1 & 2 -A.1-7

TABLE 2.1-2 (continued) TABLE NOTATION The detectability limits for activity analysis are based on technical feasi-a. bility limits and on the potential significance in the environment of the quantities released. For some nuclides, lower detection limits may be readily achievable, and when nuclides are measured below the stated limits, they should also be reported. b. When operational or other limitations preclude specific gamma radionuclide analysis of each batch, gross radioactivity measurements shall be made to estimate the quantity and concentrations of radioactive material released in the batch, and a weekly sample composited from proportional aliquots from each batch released during the week shall be analyzed for principal gamma-emitting radionuclides. c. A composite sample is one in which the quantity of liquid sampled is propor-tional to the quantity of liquid waste discharged. d. For certain mixtures of gamma emitters, it may not be possible to measure radionuclides in concentrations near their sensitivity limits when other nuclides are present in the sample in much greater concentrations. Under these circumstances, it.will be more appropriate to calculate the concentration of such nuclides using measured ratios with those radionuclides which are routinely identified and measured. e. The lower limit of detection (LLD) is determined according to the methodology in the ODCM. 2330 126 BRUNSWICK UNITS 1 & 2 A.1-8

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lw. / 3\\[N-O %g / 'h g N / / f v u 1 \\, g \\ 'g; s / / "~' \\s x /= r- ~ s ,\\ UNRESTRICTED AREA BOUNDARY FOR LIQUIDS \\ \\ 's AT DISCHARGE PUMP STRUCTURE . - - _./. / CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT rs ) UNITS 1 & 2 LA LM Q FIGURE 1.1-1 UNRESTRICTED AREA 3OUNDARIES FOR N lMPLEMENTATION OF 10CFR20 FOR LIQUIDS FOR BRUNSWICK STEAM ELECTRIC PLANT

1/21.1.3 LIQUID EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION 1.1.3.1 The dose commitment tu an individual from radioactive materials in liquid effluents released to unrestricted areas (see Figure 1.1-1) shall be limited: During any calendar quarter to 5 3 mrem to the total body and to a. 510 mrem to any organ, and i b. During any calendar year to 5 6 mrem to the total body and to g 20 mrem to any organ. -The liquid radwaste treatment system shall be used to reduce the radioactive-materials in liquid effluent streams, which the treatment system was designed to process, prior to their discharge when the sum of the cumulative dose commitment to date for the quarter and the projected dose commitment for the remainder of the quarter would result in doses exceeding 25% of the limits of Specification _ 1.1.3.1(b). APPLICABILITY: At all times. ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding Limiting Condition For Operation 1.1.3.1, prepare and submit to the Commission pursuant to Section IV.A of Appendix I of 10CFR50 and Specification 6.9.1.14, a Special Report, in lieu of any other report which identifies the causes(s) for exceeding the limit (s) and defines the corrective acti)ns to be taken to reduce the releases of radioactive materials in 1. quid effluents during the remainder of the current calendar quarter and during the remaining quarter (s) of the calendar year so that the average dose commitment to an individual from such releases during the calendar year is within 6 mrem to the total body and 20 mrem to any organ. b. With radioactive liquid waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission pursuant to Section IV.A of Appendix 1 of 10CFR50, a Special Report which includes the following information: 2330 128 BRUNSWICK UNITS 1 & 2 A.1-10

1. Identification of equipment or subsystems not available and the reason for the unavailability. 2. Action (s) taken to restore the unavailable equipment to available status. 3. Summary description of action (s) taken to prevent a recurrence. c. The provisions of Specification 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.1.3.1 Dose Calculations Cumulative dose contributions and dose projections from liquid ef fluents shall bc determined as required and in accordance with the Offsite Dose Calculation Manual (ODCM) at least once per 31 days as noted in Table 1.1. BASES This specification is provided to implement the requirements of Sections II.A, Ill.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 Appendix I. The ACTION state-ments provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I of 10 CFR Part 50 to assure that releases of rac'ioactive material in liquid effluents will be kept "as low as is reasonably achievable." The availability of the liquid radwaste treatment system provides assurance that this system will be available for use whenever liquid ef-fluents require treatment prior to release to the environment. The requirements that the appronriate portions of this system be used provides assurance that the release of raaicactive materials in liquid effluents will be kept "as low as is reasonably achievable" and within the guidelines of Section II.A of Appendix I of 10 CFR Part 50. This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and design objective Sec. ion II.D of Appendix I to 10 CFR Part 30. The dose calculations in the ODCM implement the requirements in Section III.A of Appendix 1 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 equations specified in the ODCM for calculating tne doses due to the actual release rates of radioactive 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 Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 2330 129 BRUNSWICK UNITS 1 & 2 AI-II

1.113, " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.113. 2330 130 BRUNSWICV.[ NITS 1 & 2 A.1-12

1/21.2 G ASEOUS EFFLUENTS 1/21.2.1 RADIOACTIVE G ASEOUS EFFLUENT INSTRUMENTATION LIMITING CONDITION FOR OPERATION 1.2.1.1 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 1.2-1 shall be OPERABLE with their alarm / trip setpoints set to ensure that the limits of Specification 1.2.2.1 are not exceeded. APPLICABILITY: As shov n in Table 1.2-1. ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel monitor alarm / trip setpoint less conservative than a value which will ensure that the limits of Specification 1.2.2.1 are met, declare the channel inoperable. b. With one or more radioactive gaseous effluent monitoring instrumentation channels inoperable, take the ACTION shown in Table 1.2-1. The provisions of Specification 3.0.3 and 3.0.4 are not applicable. c. SURVEILLANCE REQUIREMENTS 2.2.1.1 The setpoints shall be determined in accordance with the methodology as described in the ODCM. 2.2.1.2 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CAllBRATION, and CHANNEL FUNCTIONAL TEST ' and at the frequencies shown in Table 2.2-1. 2330 131 BRUNSWICK UNITS 1 & 2 A.1-13

BASES The radioactive gaseous effluent instrumentation is provided to monitor and con-trol, 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 accordance with 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, and 64 of Appendix A to 10 CFR Part 50. 2330 132 BRUNSWICK UNITS 1 & 2 A.1_14

TABLE 1.2-1 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Release Pathway Action

1. Main Stack Effluent a.

Noble Gas Activity Monitor With both channels inoperable, ef-(D12-RM-K600 (A&B)) fluent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross noble gas activity. b. Iodine Sampler Cartridge With the collection device inopera-ble, effluent releases via this pathway may continue for up to 28 days provided greb samples are taken and analyzed daily for gross activity. c. Particulate Sampler Filter With the collection device inoper-able, effluent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross activ-ity. d. System Ef fluent Flow Rate Measurement Device With the flow rate measurement (VA-FE-3359) device inoperabic effluent releaseu via this pathway may continue for up to 28 days provided the flow rate is estimated at least once per 8 hours. 2330 133 BRUNSWICK UNITS 1 & 2 A.1 -15

TABLE 1.2-1 (Continued) RADIOACTIVE CASEOUS EFFLUENT MONITORING INSTRUMENTATION Release Pathway Action

1. e.

Sampler Flow Rate Measurement Device With the flow rate measurement (P/0 P001) device inoperable, offluent releases via this pathway may continue for up to 28 days provided the flow rate is estimated at least once pe: 8 hours.

2. Reactor Building Ventilation Effluent a.

Noble Cas Activity Monitor With the monitor inoperable, efflu-((162) CAC-AQH-1264) ent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross noble gas activity. b. Iodine Sampler Cartridge With the collection device inopera-ble, effluent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross activ-ity. c. Particulate Sampler Fil t:. r With the collection device inopera-ble, effluent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross activ-ity. 2330 134 BRUNSWICK UNITS 1 & 2 A.1-16

TABLE 1.2-1 (Continued) RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Release Pathway Action

2. d.

System Effluent Flow Rate Measurement With the flow rate measurement (VA-FE-3356) device inoperable, effluent releases via this pathway may continue for up to 28 days provided the flow rate is estimated at least once per 8 hours. e. Sampler Flow Rate Measurement Device With the flow rate measurement (PR-21) device inoperable, effluent re-leases via this pathway may continue for up to 28 days provided the flow rate is estimated at leasc once per 8 hours.

3. Turbine Building Ventilation Effluent a.

Noble Gas Activity Monitor With the monitor inoperable, efflu-((162) VA-AQH-3215) ent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross noble gas activity. b. Iodine Sampler Cartridge With the collection device inope rable, effluent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross activity. c. Particulate Sampler Filter With the collection device inoperable, effluent releases via this pathway may continue for up to 28 days provided grab samples are taken and analyzed daily for gross activity. '2330 i35 BRUNSWICK UNITS 1 & 2 jg,y_y7

TABLE 1.2-1 (Continued) RADIOACTIVE CASEOUS EFFLUENT MONITORING INSTRUMENTATION Release Pathway Action

3. d.

System Effluent Flow Rate Measurement Device With the flow rate measurement (VA-FE-3358) device inoperable, effluent releases via this pathway may continue for up to 28 days provided the flow rate is estimated at least once per 8 hours. e. Sampler Flow Rate Measurement Device With the flow rate measurement de-(PR-21) vice inoperable, ef fluent releases via this pathway may continue for up to 28 days provided the flow rate is estimated at least once per 8 hours. 2330 136 BRUNSWICK UNITS 1 & 2 A.1-18

TABLE 2.2-1 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIRE 1ENTS Channel Channel Source Channel Functional Release Pathway Check Check Calibration Test

1. Main Stack Effluent

a. Noble Gas Activity (1)

(2) (3) Monitor D M R Q (D12-RM-K600(A&B))

b. Iodine Sampler (1)

Cartridge W N. A. N. A. N. A.

c. Particulate (1)

Sampler Filter W N. A. N.A. N.A.

d. System Effluent Flow Rate (1)

Measurement Device D N. A. R N.A. (VA-FE-3359)

c. Sampler Flow Rate (1)

Measurement Device W N. A. N.A. N. A. (P/0 P001)

2. Reactor Building Ventilation Effluent

a. Noble Gas Activity (1)

(2) (3) Monitor D M R Q ((162) CAC-AQH-1264)

b. Iodine Sampler (1)

Cartridge W N. A. N.A. N. A

c. Particulate (1)

Sampler Filter W N. A. N.A. N.A

d. System Effluent Flow Rate (1)

Measurement Device D N. A. R N.A. (VA-FE-3356) 2330 137 BRUNSWICK UNITS.1 & 2 /4.1-19

TABLE 2.2-1 (Continued) RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Release Pathway Check Check Calibration Test

2. e. Sampler Flow Rate -

(1) Measurement Device W N.A. N.A. N. A. (PR-21)

3. Turbine Building Ventilation Effluent

a. Noble Gas Activity (1)

(2) (3) Monitor D M R Q ((l&2) VA-AQH-3215)

b. Iodine Sampler (1)

Cartridge "W N. A. N.A. N.A.

c. Particulate (1)

Sampler Filter W N. A. N.A. N.A.

d. System Effluent Flow Rate (1)

Measurement Device D N.A. R N.A. (VA-FE-3358)

e. Sampler Flow Rate (1)

Measurement Device W N. A. N.A. N. A. (PR-21) Table Notation

1. During releases via this pathway.

2. The Channel Calibration for radioactivity measurement instrumentation shall be performed using one or more reference standards.

3. The channel Functional Test shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

1. Inst rument indicates measured levels above the alarm / trip setpoint.

2. Circuit failure.

2330 138

3. Instrument indicates a downscale failure.

BRUNSWICK UNITS 1 & 2 /\\.1-20

1/21.2.2 GASEOUS EFFLUENTS DOSE RATE LIMITING CONDITION FOR OPERATION 1.2.2.1 The release rate at any time in the unrestricted areas (see Figure 1.2-

1) due to radioactive materials released in gaseous effluents from the site shall be limited to the following rates:

The dose rate limit for noble gases shall be $500 mrem /yr to the a. total body and 5 3000 mrem /yr to the skin, and b. The dose rate limit for all radiciodines and for all radioactive materials in particulate form and radionuclides other than noble gases with half lives greater than 8 days shall be $1500 mrem /yr to any organ. APPLICABILITY: At all times. ACTION: With the dose rate (s) exceeding the above limits, decrease the release a. rate to comply with the limit (s) given in Specification 1.2.2.1 and provide prompt notification to the Commission pursuant to Specification 6.9.1.14. b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.2.2.1 The release rate at any time of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established above in Specification 1.2.2.1. 2.2.2.2 The noble gas effluent continuous monitors having provisions for the automatic termination of gaseous releases, as listed in Table 1.2-1 shall be used to limit offsite doses within the values established in Specification 1.2.2.1 when monitor setpoint values are exceeded. 2330 139 BRUNSWICK UNITS 1 & 2

2.2.2.3 The release rate of radioactive materials, other than noble gases, in gaseous effluents shall be determined by obtaining representative samples and performing analyses in ac. c' dance with the sampling and analysis program, spec-ified in Table 2.2-2. 2.2.7.4 The dose rate in unrestricted areas, due to radioactive materials other than noble gases released in gaseous effluents, shall be determined to be within the required limits by using the results of the sampling and analysis program, specified in Table 2.2-2 in performing the calculations of dose iate in unrestricted areas. BASES This specification is provided to ensure that the dose rate at anytime from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for unrestricted areas. The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table 11. These limits provide reasonable assurance that radioactive material discharged in gaseous c'!!uents will not result in the exposure of an individual in an unrestricted area, either within or outside the exclusion area boundary, to annual average concen-trations exceeding the limits specified in Appendix B, Table !! of 10 CFR Part 20 (10 CFR Part 20.106 (b)). For individuals who may at times be within the restricted area boundary, the occupancy of the individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the unrestricted area. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual in unrestricted areas to 5 (500) mrem / year to the total body or to 5 (3000) mrem / year to the skin. These release rate limits also restrict at all times, the corresponding thyroid dose rate above background to an individual receptor via the cow-milk-receptor pathway to 51500 mrem / year. 2330 140 S BRUNSWICK UNITS 1 & 2 A.1-22

d. lh / I I %.7 [ I UNR ESTRICTED /grar.,4ARE.Ou~oARv p,

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TABLE 2.2-2 BRUNSWICK RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Sampling Minimum Analysis Type of Activity Lower Limit Gaseous Release Type Frequency Frequency Analysis of Detection (LLD) ( Ci/ml)^ ' P P A. Drywell Purge Each Purge Each Purge Kr-8 7, Kr-8 8, 1 x 10-4 c Grab Xe-133, Xe-133m, Sample Xe-135, Xe-138, Mn-54, Fe-59, Co-58, Co-60, Mo-9 9, Zn-65, Cs-134, Cs-137, Ce-141 & Ce-144 H-3 1 x 10-6 M M B. Environmental Grab Gas Kr-87, Kr-8 8, -4 b,c Release Points Sample Sample Xe-133, Xc-133m, 1 x 10 Xe-135, Xe-138, Mn-54, Fe-59, Co-58, Co-60, Mo-99, Zn-65, Cs-134, Cs-137, Cc-141, & Ce-144 H-3 1 x 10-6 -12 c ' d e Charcoal I-131 1 x 10 Sample W W ~ Particulate Mn-5 4, Fe-59, 1 x 10-11 c,d e Sample Co-58, Co-60, Zn-65, IV 3-99, I-131, Ba-La-140, Cs-134, Cs-137, Cc-141 & Ce-144 BRINSWICK UNITS 1 & 2 A.1-24

TABLE 2.2-2 (Continued) BRUNSWICK RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Sampling Minimum Analysis Type of Actis ity Lower Limit Gaseous Release Type Frequency Frequency Analysis of Detection (LLD) (p C1/ml) 'I B -, Environmental M M I-133, I-135 1 x 10-10 Release Points Charcoal (Continued) Sampic M M ~ ' ', Composite Gross a & Sr-89 1x~ Particulate Sample Q Q ~ Composite

• Sr-90 1 x 10 Particulate Sample 2330 143 BRUNSWICK UNITS 1 & 2 A.1-25

TABLE 2.2-2 (continued) TABLE NOTATIONS a. The detectability limits for activity analysis are based on technical feasibility and on the potential significance in the environment of the quantitie released. For some nuclides, lower detection limits may be readily achievable and when nuclides are measured below the stated limits, they will also be reported. b. Analyses shall also be performed following each refueling startup or similar operational occurrence which could alter the mixture of radionuclides as determined by the criteria in Specification 2.4.1.1. For certain mixtures of gamma emitters, it may not be possible to measure c. radionuclides at levels near their sensitivity limits when other nuclides are present in the sample at much higher levels. Under these circumstances, it will be more appropriate to calculate the levels of such radionuclides using observed ratios with those radionuclides which are measurable. d. When the steady-state gross radioactivity release rate increases by 50% over the previous corresponding power level steady-state release rate, the iodine and particulate collection device shall be removed and analyzed to determine the change in iodine-131 and particulate (with half-lives greater than eight days) release rate. The analysis shall be done daily following such change until it is shown that a pattern exists which can be used to predict the release rate; af ter which it may revert to weekly sampling frequency. To be representative of the average quantities and concentrations of radio-e. active materials in particulate form released in gaseous effluents, samples should be collected in proportion to the rate of flow of the effluent stream. f. The lower limit of detection (LLD) is determined according to the methodology in the ODCM. 2330 144 BRUNSWICK UNITS 1 & 2 A.1-26

1/21.2.3 G ASESOUS EFFLUENTS DOSE, NOBLE GASES LIMITING CONDITION FOR OPER.S. TION 1.2.3.1 The air dose at the site boundary (see Figure 1.2-1) due to noble gases released in gaseous effluents shall be limited to the following: During any calendar quarter, to 510 mrad for gamma radiation and a. 5 20 mrad for beta radiation; During any calendar year, to 5 20 mrad for gamma radiation and b. 5 40 mrad for beta radiation; APPLICABILITY: At all times. ACTIONS: With the calculated air dose from radioactive noble gases in gaseous a. effluents exceeding Limiting Condition For Operation 1.2.3.1, prepare and submit to the Commission pursuant to Section IV.A of Appendix I of 10 CFR Part 50 and Specification 6.9.1.14, a Special Report, in lieu of any other report which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents during the remainder of the current calendar quarter and during the remaining quarter (s) of the calendar year so that the average dose during the calendar year is within (20) mrad for gamma radiation and (40) mrad for beta radiation. b. The provisions of Specification 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.2.3.1 Dose Calculations Cumulative dose contributions for the total time period shall bTdetermined as required and in accordance with the Offsite Dose Calculation Manual (ODCM) at least once every 31 days as noted in Table 1.1. 2330 145 BRUNSWICK UNITS 1 & 2 A.1-27

BASES This specification is provided to implement the requirements of Sections II.B and IV.A of Appendix 1,10 CFR Part 50. The ACTION implements the guides set forth in Section ll.B of Appendix I. sta plement the guides set forth in Section IV.A of Appendix I assure that the releases of radioactive materials in gaseous ef fluents will be kept "as low as is reasonable achievable." The Surveillance Requirements implement the requirements in Section III.A of Appendix 1 that conformance with the guides of Appendix I is to be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be sub-The dose calculations established in the ODCM for stantially underestimated. calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology pro Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1," Revision 1, October 1977 and Regulatory Gu The ODCM Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. equations provided for determing the air doses in the unrestricted area will be NUREG-0133 based non the historical annual average atmospheric conditions. provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.111. 2330 146 BRUNSWICK UNITS 1 & 2 A.1-28

1/21.2.4 GASEOUS EFFLUENTS DOSE RADIOIODINES AND RADIOACTIVE M ATERIALS IN PARTICULATE FORM LIMITING CONDITION FOR OPERATION 1.2.4.1 The dose commitment to an individual from radiciodines and radio-active materials in particulate form with half-lives greater than 8 days in gaseous effluents released to unrestricted areas (see Figure 5.1-1) shall be limited to the following: During any calendar quarter to 515 mrem; a. b. During any calender year to q 30 mrem; -The VENTILATION EXHAUST TREATMENT SYSTEM shall be used to reduce the ~ radioactive materials in gaseous effluents, which the treatment system was designed to process, prior to their discharge when the sum of the cumulative dose commitment to date for the quarter and the projected dose commitment for the remainder of the quarter would result in a dose commitment exceeding 25% of _ Specification 1.2.4.1 (b). APPLICABILITY: At all times. ACTION: With the calculated dose commitment from the release of radio-a. iodines and radioactive materials in particulate form, in gaseous effluents exceeding Limiting Condition For Operation 1.2.4.1, prepare and submit to the Commission pursuant to Section IV.A of Appendix I of 10 CFR Part 50 and Specification 6.9.1.14, a Special Report, in lieu of any other report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases of radiciodines and radioactive materials in particulate form, with half-lives greater than 8 days in gaseous effluents during the remainder of the current calendar quarter and during the re-maining quarter (s) of the calendar year so that the average dose commitment to an individual from such releases during the calendar year is within (30) mrem to any organ. b. With gaseous wastes being discharged for more than 31 days without treatment and in excess of the above limits, prepare and submit to 2330 147 BRUNSWICK UNITS 1 & 2 A.1-29

the Commission pursuant to Section IV.A of Appendix I of 10 CFR Part 50, a Special Report which includes the following information: 1. Identification of equipment or subsystems not available and the reason for its or their unavailability. 2. Action (s) taken to restore the non-cperable equipment to available status. 3. Summary description of action (s) taken to prevent a recurrence. c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. SURVEILLENCE REQUIREMENTS 2.2.4.1 Dose Calculations Cumulative dose contributions and dose projections shall be determined as required and in accordance with the ODCM at least once every 31 days as noted in Table 1.1. BASES This specification is provided to implement the requirements of Section II.C, III.A and IV.A of Appendix I,10 CFR Part 50. The Limiting Conditions for Operation are the guides set forth in Section II.C of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Seciton 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 !!I.A of Appendix I that conformance with the guides of Appendix ! 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 for calculating the doses due to the actual release rates of the subject materials are required to be consistent with the methodology provided in Regulatory Guide 1.109, " Calculating of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate specifications for radiolodines and radioactive material in particulate form am dependent on the existing radionuclide 2330 148 BRUNSWICK UNITS 1 & 2 A.1-30

pathways to man, in the unrestricted area. The pathways which are examined in the development of these calculations are:

1) individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man,3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man.

The VENTILATION EXHAUST TREATMENT SYSTEM will be used to provide reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable" and that the requirements of Section II.C of Appendix ! of 10 CFR Part 50 are met. This specification implements the requiements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 30, and design objective Section II.D of Appendix I to 10 CFR Part 50. 2330 149 BRIINSWTCK UNITS 1 & 2 A.1-31

1/21.3 40 CFR 190 1/21.3.1 EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION 1.3.1.1 The dose or dose commitment to a real individual from all uranium fuel cycle sources is limited to < 25 mrem to the total body or any organ (except the thyroid, which is limited to- < 75 mrem) over a period of 12 consecutive months. APPLICABILITY: At all times. ACTIONS: a. With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Spec-ifications 1.1. 3.1.a, 1.1.3.1.b, 1.2.3.1.a, 1.2.3.1.b, 1.2.4.1.a, or 1.2.4.1.b, prepare and submit to the NRC, information necessary to assess compliance with 40 CFR 190. b. The provisions of Specification 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.3.1.1 Dose Calculations Cumulative dose contributions from liquid and gaseous effluents from Brunswick Steam Electric Plant shall be determined in accordance with Specifications 1.1.3.1.a, 1.1.3.1.b, 1.2.3.1.a, 1.2.3.1.b, 1.2.4.1.a, and 1.2.4.1.b, and in accordance with the Offsite Dose Calculation Manual (ODCM). Only uranium fuel cycle sources within five miles of the Brunswick Steam Electric Plant will be considered. BASES This specification is provided to meet the reporting requirements of 40 CFR 190. 2330 150 BRLHSk'ICK UNITS 1 & 2 A.1-32

1/2 1.4 MAIN CONDENSER AIR EJECTOR RADI0 ACTIVITY 1/2 1.4.1 MAIN CONDENSER AIR EJECTOR INSTRUMENTATION LIMITING CONDITION FOR OPERATION 1.4.1.1 The main condenser air ejector monitoring instrumentation channels shall be OPERABLE with their alarm / trip setpoints set to provide reasonable assurance that the total body exposure to an individual at the exclusion botadary shall not exceed 2.5 rem. APPLICABILITY: During releases via this pathway. ACTION: With both main condenser air ejector monitoring instrumentation channels inoperable, gases from the main condenser offgas system may be released to the environment for up to 72 hours; afterwards, be in at least HOT SIANDBY within the following 12 hours. SURVEILLANCE REQUIREMENTS

2. 4.1.1 The setpoints shall be determined in accordance with procedures as described in the ODCM.

2.4.1.2 Each main condenser air ejector monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST and at the frequencies shown in Table 2.4-1. BASES The main condenser air ejector monitoring instrumentation channels are provided to monitor and control gross radioactivity removed from the main condenser. The alarm / trip setpoint for this monitor shall be calculated in accordance with NRC approved methods to provide reasonable assurance that the potential total body accident dose will not exceed a fraction of the limits specified in 10CFR100. 2330 151 BRUNSWICK UNITS 1 & 2 A.1-33

TABLE 2.4-1 MAIN CONDENSER AIR EJECTOR MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Channel Source Channel Functional Release Pathway Check Check Calibration Test Condenser Air Ejector

a. Noble Gas (l')

(2) (3) Activity Monitor D M R R ((162) D-12-RM-K601(A&B)) Table Notation

1. During releases via this pathway.

2. The Channel Calibration for radioactivity measurement instrumentation shall be performed using one or more reference standards.

3. 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:

a. Instrument indicates measured levels above the alarm / trip setpoint. b. Circuit failure. c. Instrument indicates a downscale failure. 2330 152 BRUNSWICK UNITS 1 & 2 A.1-34

1/21.4.2 MAIN CONDENSER AIR EJECTOR RADIOACTIVITY RELEASE RATE LIMITING CONDITION FOR OPERATION 1.4.2.1 The gross radioactivity (beta and/or gamma) rate of. noble gases 6 measured at the main condenser air ejector shall be limited to 5 5.9 x 10 pCi/sec. APPLICABILITY: At all times. ACTION: With the gross radioactivity (beta and/or gamma) rate of noble gases at the main condenser air ejector exceeding 5.9 x 106 F Ci/sec, restore the gross g radioactivity rate to within its limit within 72 hours or be in at least HOT STANDBY within the next 12 hours. SURVEILLANCE REQUIREMENTS 2.4.2.1 The gross radioactivity (beta and/or gamma) rate of noble gases from the main condenser air ejector shall be determined to be within the above limit at the following frequencies by performing an isotopic analysis of a representative sample of gases taken at the discharge (prior to dilution and/or discharge) of the main condenser air ejector: a. At least once per 31 days. b. Within 72 hours following an increase, as indicated by the Condenser Air Ejector Noble Gas Activity Monitor, of greater than 50%, af ter factoring out increases due to changes in THERMAL POWER level, in the nominal steady state fission gas release from the primary coolant. 2330 153 BRUNSWICK UNITS 1 & 2 A,l_33

BASES 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 sinall fraction of the limits of 10 CFR Part 100. This specification implements the requirements of General Design Criteria 60 and 64 of Appendix A to 10 CFR Part 50. 2330 154 BRUNSWICK UNITS 1 & 2 A.1-36

1/21.5 DRYWELL PURGES 1/21.5.1 MARK I CONTAINMENT CONDITION FOR OPERATION LIMITING CONDITION FOR OPERATION 1.5.1.1 The drywell shall be purged through the Standby Gas Treatment System, or released to the environment at a rate in conformance with Specification 1.2.2.1. APPLICABILITY: Whenever the drywell is vented / purged. pCTION: With the requirements of the above specification not satisfied, a. suspend all venting / purging of the drywell, b. The provisicns of Specifications 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.5.1.1 A sample analysis, as defined in Table 2.2-2, shall be performed prior to each drywell purge to provide reasonable assurance that releases from drywell purging operations will not exceed the annual dose limits of 10 CFR Part 20 for unrestricted areas. BASES This specification provides reasonable assurance that releases from drywell purging operations will not exceed the annual dose limits of 10 CFR Part 20 for un-restricted areas. 2330 155 BRUNSWICK UNITS 1 & 2 A.1.37

1/21.6 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 1/21.6.1 MONITORING PROGRAM LIMITING CONDITION FOR OPERATION 1.F.1.1 The radiological environmental monitoring program shall be con-ducted as specified in Table 1.6-1 and the ODCM. The ODCM shall include a map of all sampling locations keyed to a table giving distances and directions from the plant. APPLIC ABILITY: At all times. ACTION: With the radiological environmental monitoring program not being a. conducted as specified in Table 1.6-1, prepare and submit to the Commission, in the Annual Radiological Operating Report, a de-scription of the reasons for not conducting the program as required and the plans for preventing a recurrence. (Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, or to malfunction of automatic sampling equipment. If the latter, every effort shall be made to complete corrective action prior to the end of the next sampling period.) b. With the level of radioactivity in an environmental sampling medium at one or more of the locations specified in the ODCM exceeding the limits of Table 6.9-2 of specification 6.9.1.14 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days from the end of the affected quarter, a Special Report which includes an evaluation of release conditions, environmental factors or other aspects which may have caused the limits of Tabic 6.9-2 to be exceeded. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report. c. With milk or fresh leafy vegetable samples unavailable from any of the sample locations required by the ODCM, prepare and submit to the Commission pursuant to Specification 6.9.1.7, the cause of the unavailability of samples and identify locations for obtaining replacement samples. The locations from which samples were unavailable may then be deleted from the ODCM provided the 2330 156 BRUNSWICK UNITS 1 & 2 A.1-38

locations from which the replacement samples were obtained are added to the environmental monitoring program as replacement locations, if available. d. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 2.6.1.1 The radiological environmental monitoring samples shall be collected pursuant to Table 1.6-1 from the locations defined in the ODCM and shall be analyzed pursuant to the requirements of Tables 1.6-1 and 2.6-1. BASES The radiological monitoring program required by this specification provides measurements of radiation and of radioactive materials in those exposed pathways and for those radionuclides whici. lead to the highest potential radiation exposures of individuals resulting from the station operation. This monitoring program there-by supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways. 2330 F57 BRUNSWICK UNITS 1 & 2 A.1-39

E b TABLE 1.6-1 ms b BRUNSWICK RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM @p m Exposure Pathway Minimum Number Sampling and Type and Frequency s and/or Sample of Sample Stations Collection Frequency of Analysis o' N 1. AIRBORNE 5 Continuous operation of Radiciodine canister. Analyze a. Radiciodine sampler with sample col-at least once per 7 days for and Partic-lection as required by I-131. ulates dust loading but at least once per 7 days. Particulate sampler. Analyze for gross beta radioactivity 2 24 hours following filter change. Perform gamma isotopic analysis on each sample when gross beta activity is >10 times the mean P of control sample. Perform gamma isotopic analysis on composite g (by location) sample at least once per 92 days. 2. DIRECT RADIATION 5 At least once per Gamma dose. At least once per 31 days. 31 days. 2 2 dosimeters or 21 instrument for con-tinuously measuring N and recording dose rate at each location (each TLD chip is con-sidered a dosimeter) CO

E 3 TABLE 1.6-1 (Continued) U h BRUNSWICK RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM E n Exposure Pathway Minimum Number Sampling and Type and Frequency m and/or Sample of Sample Stations Collection Frequer.cy of Analysis u 3. WATERBORNE. 2 Gamma isotopic analysis of each Sample collected over a. Surface composite sample by location. a period of 31 days Tritium analysis of composite sample at least once per 92 days, b. Ground 2 At least once per 92 days. Gamma isotopic and tritium analyses of each sample. c. Sediment from 1 At least once per 184 Gamma isotopic analysis of each Shoreline days. sample. 4. INGESTION 2 At least once per 15 days Gamma isotopic and I-131 analysis

a. Milk when animals are on of each sample.

pasture; at least once per 31 days at other times. b. Fish 2 In season, at least once Gamma isotopic analysis on per 184 days. One edible portions. sample of each of the following: N 1. Fish U 2. Shellfish u CD U7 4

E TABI.E 1.6-1 (Continued) g 7: C BRUNSWICK RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Minimum Number Sampling and Type and Frequency and/or Sample of Sample Stations Collection Frequency of Analysis c. Food Products 1 At time of harvest. Gamma isotopic analysis on Green leafy vegetables edible portion. 1 At time of harvest. One I-131 analysis. sample of broad leaf vegetation. Pr C N LM Ua C 's O

E TABLE 2.6-1 2 5 MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION (LLD)a x Eq m Airborne Par'iculate Water or Gas Fish Milk Faod Products Sediment 3 { Analysis (pCi/1) (pC1/m ) (pCi/kg, wet) (pCi/1) (pC1/kg, wet) (pC1/kg, dry) gross beta 4 1 x 10~ 3, 2000 h 54 15 130 3 59 30 260 Fe ? 58,60 15 130 Co w $5 30 260 Zn 95Zr-Nb 131 1 7 x 10~ b 1 60 7 134,137Cs 15,18 1 x 10~ 130 15 80 150 N 140 15 15 3 Ba,ca ON

TABLE 2.6-1 NOTATIONS a. The LLD will be calculated for the 95% confidence level according to the methods desuibed in the ODCM. The LLD will be based on the actual observed variance in the baseline for a particular detection system rather than on an unverified theoretically predicted variance. Occasionally baseline fluctuations, unavoidably small sample sizes, the presence af interferring radionuclides, or other uncontro!!able circumstances may render the LLD's specified throughout the technical specifications unachievable. In view of the above discussion, environmental analyses will be performed in such a manner that the LLD for each radionuclide specified in Table 2.6-1 will be achieved 2 95% of the time in each calendar year. When unusual circumstances result in exceeding the LLD for any radionuclide in Table 2.6-1 greater than 5% of the time in any calendar year, the reasons for exceeding the LLD(s) will be identified and discussed in the Annual Radiological Environmental Operating Report. b. LLD for leafy vegetables. 2~'30 1o2 BRUNSWICK UNITS 1 & 2 A.1-44

1/21.6.2 LAND USE CENSUS LIMITING CONDITION FOR OPERATION 1.6.2.1 A land use census shall be conducted and shall identify the location of the nearest milk animal, the nearest residence and the nearest garden

• of greater than 500 square feet producing fresh leafy vegetables in each c,f the 16 meteorological sectors within a distance of five miles. (For each elevated release as defined in Regulatory Guide 1.111, March 1976, the land use census shall also identify the locations of all milk animals and all gardens of greater than 500 square feet producing fresh leafy vegetables in each of the 16 metecrological sectors within a distance of three miles.)

APPLICABILITY: At all times. ACTION: With a land use census identifying a location (s) which yields a a. calculated dose or dose commitment greater than the values currently being calculated in Specification 2.2.4.1, prepare and submit to the Commission within 30 days, a Special Report which identifies the new location (s). b. With a land use census identifying a location (s) which yields a cal-culated dose or dose commitment (via the same exposure pathway) greater than at a location from which samples are currently being obtained in accordance with Specificationi.6.1.1, prepare and submit to the Commission withi.i 30 days, a Special Report which identifies the new location. The new location shall be added to the radiological environmental monitoring program within 30 days, if possible. The sampling location having the lowest calculated dose or dose commitment (via the same exposure pathway) may be deleted from this monitoring program af ter October 31 of the year in which this land use census was conducted. c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

• Broad leaf vegetation sampling may be performed at the site boundary in the direction sector with the highest D/Q in lieu of the garden census.

2330 103 BRINSWICK UNITS 1 & 2 A.1-45

SURVEILLANCE REQUIREMENTS 2.6.2.1 The land use census shall be conducted at least once per 12 months between the dates of June 1 and October 1, by door-to-door survey, aerial survey, or by consulting local agriculture authorities. BASES Ihis specification is provided to ensure that changes in the use of unrestricted arcas are identified and that modifications to the monitoring program are made if required by the results of this census. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 300 square feet provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/ year) of leafy vegetables assumed in Regulatory Guide 1.109, Revision i for consumption by a child. To determine this minimum garden size, the fo!!owing a:sumptions were used:

1) that 20% of the garden was used for growing broad leaf vegetation (i.e.,

similar to lettuce and cabbage), and 2) a vegetation yield of 2 kg/ square meter. 2:30 1o4 BRUNSWICK UNITS 1 & 2 A146}}