ML19276E681
| ML19276E681 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/09/1979 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| 1-039-2, 1-39-2, NUDOCS 7903200251 | |
| Download: ML19276E681 (65) | |
Text
{{#Wiki_filter:r i I' 1 p [ g 4 e '. ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK ARKANSAS 72203 (501)371-4422 March 9, 1979 WILUAM CAVANAUGH ll1 , Vice President Generation & Construction 1-039-2 Director of Nuclear Reactor Regulation ATTN: Mr. R. W. Reid, Chief Operating Reactor Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Subject:
Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51 Proposed Technical Specifications (File: 1511.1, 1511.3) Gentlemen: The proposed technical specifications changes contained in Enclosure 1 are submitted pursuant to Mr. Grimes' letters dated July 11, 1978, and November 15, 1978, and our letter to Mr. Reid dated February 9, 1979. Enclosure 2 contains our reasoning for exceptions taken to general speci-fications. Ne request that upon adoption of the specifications contained in Enclosur-1 that sections 1,2,3,4, and 6 of the Environmental Technical Specifications (ETS) be deleted and replaced with the specifications contained in Enclosure
- 3. The specifications in Enclosure 3 are similar in intent to many of the specifications presently in the ETS, however, much of the " procedure" related material has been removed. With this change the format of the ANO-1 ETS will natch that of the ANO-2 ETS. Justification for these changes is provided in
. inclosure 4.
We also request that implementation of these be delayed up to 90 days after they are issued so that procedures can be rewritten. We request a meeting with the staff to discuss any questions that may arise regarding the content of the proposed specifications. The Offsite Dose Calculation Manual required by these technical specifications will be submitted by April 1, 1979. 790320025( MEMBEF4 M:OOLE SOUTH UTIUTIES SYSTEM
f , hir. R. W. Reid, Chief March 9, 1979
~
Enclosed is a check for $4000 for a Class III amendment as requested in your
' July 11, 1978 letter.
Very truly yours -
/
^
, 4 c'T William Cavt gh III WC: CSP:vb Enclosure
STATE OF ARKANSAS )
) SS COUNTY OF PULASKI )
William Cavanaugh III, being duly sworn, states that he is Vice President, Generation & Construction, for Arkansas Power & Light Cornpany; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this Supplementary Information; that he has reviewed or caused to have reviewed all of the statements contained in such information, and that all such statements mada and matters set forth therein are true and correct to the best of his knowledge, infonna-tion and belief.
, \
, vi / w a William Cava y h III J
SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the County and State above named, this Day of NOMd_/ 1979. ( QAf>L QL/L fx '
/ lNotary Public' '/
My Coninission Expires: m commission Daires 9/J/.81
T i 4 . ENCLOSURE 1 RADIOLOGICAL TECHNICAL SPECIFICATIONS
r , s , 3.5.6 Radiological Liquid Ef fluent Instrumentation Applicability: As shown in table 3.5.6-1. Obiective: To provide instrumentation for radioactive liquid releases. Specification: 3.5.6.1 The setpoints for radioactive liquid effluent moni-toring instrumentation shall be determined as described in the ODCM. 3.5.6.2 The radioactive liquid effluent monitoring instrumen-tation shown in table 3.5.6-1 shall be set such that their alarm / trip setpoints will ensure that the limits of Specification 3.22.1 are not exceeded. Bases: 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. The alarm / trip setpoints for these instruments shall be calculated in accordance with the methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. 53e
~
Table 3.5.6-1 Radioactive Liquid Monitoring Instrumentation Instrument Operable Applicability Action Liquid radwaste ef fluent line Radiation monitor 1 During releases via this pathway A flow monitor 1 During releases via this pathway B m
a , Table 3.5.6-1 (Continued)
- Table Notation Action Description A. With the number of channels OPERABLE less than re-quired by the Minimum Channels OPERABLE require-ment, effluent releases may be resumed provided that prior to initiating a release:
- 1. At least two independent samples are analyzed in accordance with Specification 4. 24.1. 3, and;
- 2. At least two technically qualified members of the Facility Staff independently verify that the computer input data is correct and;
- 3. At least 2 members of the facility Staff in-dependently verify the discharge valve lineup.
B. With the number of channels OPERABLE less than re-guired by the Minimum Channels OPERABLE require-ment, effluent releases via this pathway may con-tinue provided the flow rate is estimated at least once per 4 hours during actual releases. 53g
e
. 3.5.7 Radiological Gaseous Effluent Instrumentation Applicability: Applies to this instrumentation listed in table 3.5.7-1.
Objective: To provide instrumentation for radioactive gaseous releases. Specification: 3.5.7.1 The setpoints for the radioactive gaseous effluent instrumentation shall be determined as described in the ODCM. 3.5.7.2 The radioactive gaseous effluent monitoring instru-mentation shown in Table 5.7-1 shall be set such that their alarm / trip setpoints will ensure that the limits of Specification 3.23.1 are not exceeded. Bases: The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radio-active materials in gaseous effluents during actual or potential releases. The alarm / trip setpoints for these instruments shall be calculated in accordance with methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. S 53h
Table 3.5.7-1 Radioactive Gas Ef fluent Monitoring Instrumentation Instrument Operable Applicability Parameter Action
- 1. Waste Gas hold up system Gas Activity Monitor 1 During releases via Radioac tivi ty A this pathway (DRVTP) rate measurement Effluent System Flowrate 1 DRVTP Sys tem flowrate B measuring device
- 2. Auxiliary Building Ventila-tion system a) Gas Activity Monitor 1 DRVTP Radioactivity rate C m measurement w
H= b) Effluent system flow rate measuring device 1 DRVTP System flow rate B c) Sampler flowrate measuring device 1 DRVTP Sample flow rate B
- 3. Spent Fuel Pool Area When the system is in Ventilation System operation a) Gas Activity Monitor Radioactive rate C Measurement b) Ef fluent System flow rate measuring device 1 System flow rate B c) Sampler flow rate measuring device 1 Sample flow rate B
Table 3.5.7-1 (Continued) Radioactive Gas Effluent Monitoring Instrumentation
- 4. Reactor Building Purge When the system is System in the operation a) Gas Activity Monitor 1 Radioactivity rate C measurement b) Effluent system fl ow 1 System flow rate B rate measuring device c) Sampler flow rate 1 S ample flow rate B measuring device w
W U.
e Table 3.5.7-1 (Continued)
. Table Notation Action Description A. With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE re-quirement, the contents of the tank may be re-leased to the environment provided that prior to initiating the release:
- 1. At least two independent samples of the tank's contents are analyzed, and
- 2. At least two technically qualified members of the Facility Staff independently verify the computer input data and correct discharge valve lineup; B. With the number of channels OPERABLE less than re-quired by the Minimum Channels OPERABLE require-ment, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours.
C. With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE require-ment, effluent releases via this pathway may con-tinue provided grab samples are taken at least once per 24 hours and these samples are analyzed for gross activity within 24 hours. 53k
3.22 Radioactive Liquid Effluents 3.22-1 Concentration Applicability : Applies for every release from the liquid radwaste system. Obiective To ensure that the limits of 10 CFR 20 are met. Specifications: 3.22.1.1 The concentration of radioactive material released at anytime from the site to unrestricted areas (see Figure 5.1-1) shall be limited to the con-centration specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radio-nuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the tptal concentration shall be limited to 2 x 10 uCi/ml. 3.22.1.2 With the concentration of radioactive material released from the site to unrestricted areas exceeding the above limits, immediately re-store concentration within the above limits and provide 30 day notification to the Canmission pursuant to Specification 6.12.3.2. Bases: This specification is provided to ensure that the concentra-tion of radioactive materials released in liquid waste ef fluents 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 radioactive materials in bodies of water outside the site will not result in exposures greater than the Section II ~ A design objectives of Appendix I, 10 CFR Part 50, to an individual. The concentration limit for noble gases is based upon the assumption that Xe-133 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. 66r
e , Radioactive Liquid Effluents 3.22.2 Dose Applicability: Applies to releases from the liquid radwaste system. Objective: To ensure that the dose limits of 10 CFR 50 Appendix I Section IV A are met. Specifications: 3.22.2.1 a. The dose or dose commitment to an individual from radioactive material in liquid ef fluents released from ANO-1 to unrestricted areas should be 13 mrem to the total body and i 10 mrem to an organ during any calendar year.
- b. When the calculated dose from release of radio-active materials in liquid ef fluents exceeds the above limits the licensee shall make an investigation to identify the causes for such release rates.
3.22.2.2 a. The dose or dose commitment to an individual from radioactive materials in liquid ef fluents released from ANO-1 to unrestricted areas shall be limited to; 1 1.5 mrem to the total body and 15 mrem to any organ f or any calendar quarter.
- b. When the calculated dose from release of radio-active materials in liquid effluents exceeds the limit in Specification 3. 22. 2. 2a the licensee shall:
- 1) Make in investigation to identify the causes for such release rates;
- 2) Define and initiate a program of correc-tive action to reduce such release rates to within the values of specification 3.22.2.1.a; and;
- 3) Report the above actions to the Region IV Office of Inspection and Enforcement, U. S. Nuclear Regulatory Commission, with-in 30 days from the end of the quarter during which the release occurred.
66s
e , Bases: Specification 3.22.2.1 implements the design guides set f orth in Section II A of Appendix I to 10 CFR 50. Speci-fication 3. 22. 2. 2 implements the Limiting - Condition for Operation as set forth in Section IV A of Appendix I. The specifications 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 release of radioactive material in liquid ef fluents will be kept "as low as is reasonably achievable". 66t
Radioactive Liquid Ef fluents 3.22.3 Waste Treatment Applicablity: Applies when liquid radioactive waste must be discharged. Objective: To assure that the amount of radioactive material in liquid ef fluents will be "as low as reasonably achievable." Specifications: 3.22.3.1 The appropriate parts of the liquid radwaste treat-ment system shall be used to reduce the radioactive materials in liquid waste prior to their discharge when it appears that the cumulative dose during a calendar month due to liquid effluent releases to unrestricted areas, as calculated in specification
- 4. 24.2.1 would exceed .25 mrem to the total body or
.83 mrem to any organ.
3.22.3.2 The provision of Specification 3. 22.3.1 does not apply to the laundry tanks due to their incom-patability with the radwaste system. 3.22.3.3 Uith radioactive liquid waste being discharged wi thout treatment and in excess of the above limits, prepare and submit to the Commission within 3 0 days, pursuant to Specification 6.12.3.2, a report which includes the f ollow-ing information:
- a. Why the releases were made without tre a tme nt.
- b. Summary description of action (s) taken to prevent recurrence.
Bases: The requirements that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable. " The specified limits governing the use of appropriate portions of the liquid radwaste treatment system were specified as a suit-able fraction of the guide set forth in Section II A of Appendix I, 10 CFR Part 50, for liquid effluents. The values of .25 mrem and .83 mrem are' the equivalent of the the yearly design objectives on a monthly basis. The yearly design objectives are given in specification 10 CFR 50 Appendix I Section II. 66u
. Radioactive Gaseous Effluents 3.23.1 Dose Rate Applicability: Applies for each radioactive gaseous release.
Objective: To ensure that the dose rate, at the unrestricted area boundary, from gaseous effluents will be within the annual dose limits of 10 CFR 20. Specifications: 3.23.1.1 The dose rate, at any time, in the unrestricted areas due to radioactive materials released in gaseous effluents from the site shall be limited to the following values:
- a. The dose raie limit for noble gases shall be 1 500 mrem /yr to the total body and < 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 11500 mrem /yr to any organ.
3.23.1.2 Uith the dose rate (s) exceeding the above limits, immediately decrease the release rate to comply with the limit (s) given in Specification 3.23.1.1 and provide notification to the Commission pursuant to Specification 6.12. 3. 2. Bases: This specification is provided to ensure that the dose rate at anytime at the exclusion area boundary for gaseous ef-fluents 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 concen-trations 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 expo-sure of an individual in an unrestricted area, to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b) }. For individuals who may at times be within the exclusion area boundary, the occupancy of the individual will be suffi-ciently low to compensate for any increase in the atmospheric diffusion factor above that for the exclusion area boundary. The specified release rate limi ts restrict, at all times, the 66v
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, all times, the corresponding thyroid dose rate above background to an infant via the cow-milk-infant pathway to 1500 mrem / year for the nearest cow to the plant. This specification applies to the release of gaseous eff-luents from all reactors at the site. 66w
4 Radioactive Gascous Effluents 3.23.2 Dose - Noble Gases Applicability: Applies at all times for radioactive gaseous releases. Objective: To ensure that the doso limits of 10 CFR 50 Appendix I Section IV A are met. Specifications: 3.23.2.1. a. The air dose in unrestricted areas (see figure 5.1-1) due to noble gases in gaseous effluents should be 1 10 mrad gamma radiation and 1 20 mrad for beta radiation during any calendar year.
- b. Uhen the calculated dose from release or radio-active moble gases in gaseous effluents exceeds the above limits the licensee shall make an in-vestigation to identify the causes f or such release rates.
3.23.2.2 a. The air dose in unrestricted areas due to noble gases released in gaseous effluents shall be 15 mrad for gamma radiation and 110 mrad for beta radiation for any calendar quarter.
- b. When the calculated dose from release of radioactive noble gases in gaseous ef fluents exceeds the limit in Specification 3. 23. 2. 2a the licensee shall:
- 1) Make an investigation to identify the causes for such release rates;
- 2) Define and initiate a program of corrective actions to reduce such release rates to within values of Specification 3.23.2.la and;
- 3) Submit a report containing the above actions to the Region IV Office of Inspection and Enf orce-ment, U. S. Nuclear Regulatory Commis sion, within 30 days from the end of the quarter during which the released occurred.
66x
Bases: Specification 3. 2 3. 2.1 utilizes the design guides specified in 10 CFR 50 Appendix I section II B. Specification 3.23.2.2 implements the limiting condition for operation as set forth in Section IV A of Appendix I. The Specifications provide the required operating flexibility and at the same time implement the guides set f orth in Section IV A Appendix I assure that the releases of radioactive material in gaseous ef fluents will be kept "as low as is reasonably achievable." O 66y
Radioactive Gaseous Ef fluents 3.23.3 Dose - Radiciodine and Particulates Applicability: Applies at all times for radioactive gaseous releases. Objective: To ensure that the dose limits of 10 CFR 50 Appendix I Section IV A are met. Specifications: 3.23.3.1 a. The dose to an individual from radiciodines, radioactive materials in particulate form, and radionuclides other than noble gases with half-lives greater than 8 days in gaseous effluents released to unrestricted areas (see Figure 5.1-1) should be less than 15 mrem to any organ during any calendar year.
- b. When the calculated dose from the release of radiciodines, radioactive materials in parti-culate form, or radionuclides other than noble gases in gaseous effluents exceeds any of the above limits the licensee shall make an investi-gation to identify the causes for such release rates.
3.23.3.2 a. The dose to an individual from radiciodines, radioactive materials in particulate form, nuclides other than noble gases with half-lives greater than 8 days in gaseous effluents released to unrestricted areas ( see Figure 5.1-1) shall be <7.5 mrem to any organ; dur-ing any calendar quarter.
- b. When the calculated dose from the release of radi ciodines, radioactive materials in parti-culate form, or radionuclides other than noble gases in gaseous effluents exceeds the limit in Specification 3.23.2.2a the licensee shall:
- 1) Make an investigation to identify the causes for such release rates;
- 2) Define and initiate a program of corrective action to reduce such release rates to with-in the values of specification 3. 23. 3. la; and
- 3) Report the above actions to the Region IV Office of Inspection and Enforcement, U. Sc Nuclear Regulatory Commission, with-in 30 days from the end of the quarter dur-ing which the release occurred.
66z
0 0 Basesi Specification 3.23.3.1 utilizes the design guides set forth in 10 CFR 50 Appendix I, Section II C. Specification 3.23.3.2 implements the limiting conditions f or operation as set forth in Appendix I, Section IV A. The Specifications 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 ef fluents will be kept "as low as is reasonably achievable." 66aa
3.24.4 Gaseous Radwaste Treatment
. Applicability: Applies when gaseous radioactive ef fluents must be discharged.
Objective: To assure that the amount of radioactive material in gaseous effluents is "as low as reasonably achievable." Snecifications: 3.23.4.1 The auxiliary building ventilation exhaust treat-ment system shall be used until the beginning of the next calendar month to reduce radioactive materials in the systems effluents prior to their discharge when calculations indicate that the doses due to radiciodines and particulates in gaseous effluent releases to unrestricted areas would exceed 1.25 mrem to any organ for any cal-endar month. 3.23.4.2 Uhen degasifying the reactor coolant systen, the waste gas system will be utilized to process the degassing effluent until the beginning of the next calendar month when calculations indicate that the dose due to all noble gases released to the unrest-ricted area for the present calendar month would exceed .83 mrad for gamma radiation of 1.6 mrad for beta radiation. 3.23.4.3 With gaseous waste being discharged for more than 31 days without treatment and in excess of the above limits, prepare and submit to the Commis-sion within 30 days, pursuant to Specification 6.13.3.2, a report which includes the follow-ing information:
- a. Why the ro) eases were being made without treat-ment.
- b. Summary description of action (s) taken to prevent a recurrence.
Bases: The requirement that the appropriate portions of these systems be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." 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. The values .83 mrad, 1.6 mrad, and 1.25 mrem are the equivalent of the yearly design objectives on a monthly basis. The yearly design objectives are given in specifications 3.23.2.la and 3.23.3.la. 66bb
Radioactive Gaseous Effluents 3.23.5 Gas Storage Tanks Applicability: Applies at all times to the tanks in the gaseous radwaste holdup system. Obiective: To restrict the snount of activity in a radioac tive gas holdup tank. Specifications: i 3.23.5.1 The quantity of radioactivity contained in each gas storage tank shall be limited to 15480 curies noble gases (Xe-133 equivalent) . . 3.23.5.2 With the quantity of radioactive material in any gas storage tank exceeding the above limit, immediately suspend all additions of radio-active material to the tank and within 4 8 hours either reduce the tank contents to with-in the limit or provide prcmpt notification to the Commission pursuant to Specification 6.12.3.2. The written followup report shall include a description of' activities planned and/or taken to reduce the tank contents to within the above limit. Bases: Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tanks contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not be excessive. 66cc
4.24 Radioactive Liquid Effluents 4.24.1 Concentration Applicability: Applies for every release from the liquid radwaste system. Objective: To ensure that the limits of specification 3.22.1 are met. Specifications: 4.24.1.1 The concentration of radioactive material in liquid effluents released from the site shall be monitored in accordance with Table 3. 5. 6-1. 4.24.1.2 The liquid effluents continuous monitors having provisions for automatic termination of liquid releasou shall be used to limit the concentra-tion of radioactive :..aterial released fran the site to unrestricted areas to the values given in Specification 3. 22.1. 4.24.1.3 The radioactivity content of each batch of radio-active liquid waste to be discharged shall be determine prior to release by sampling and analyses in accordance with Table 4. 24.1. The results of pre-release analyses shall be used with the calculational me thods in the ODCM to assure that the concentrations at the point of release are limited to the values in specification 3.22.1.1. 4.24.1.4 The Semiannual Radioactive Effluent Release Report shall include the inf ormation specified in Specification 6.12.2.5 Bases: This specification is provided to ensure that the concentra-tion or radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentzution 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 outside the site will not result in exposures greater than the Section II A design objectives of Appendix I, 10 CFR Part 50, to an individual. The concentration limit for noble gases is based upon the assumption that Xe-133 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. 110x
T_ABLE 4.24-1 RADIOACTIVE LIQUID UASTE SAMPLING AND ANALYSES PROGRAM Lower Limit S ampling Minimum Type of Activity of Detection Liquid Release Frequency Analyses Analyses (LLD) {,) Type Frequency (uCi/ml) P P fisotopic(e) -7 (b) A. Batch Uaste Each Batch Each Batch 5 x 10 Release
-6 Tank s (d) I-131 1 x 10
-5 Dissolved and 1 x 10 Entrained Gases
-5 P H-3 1 x 10 Each Batch M Composi te( c ) -7 Gross Alpha 1 x 10
-8 P Sr-89, Sr-90 5 x 10 Each Batch Q Coaposite llQr
TABLE 4.24.1 (Continued)
, TABLE NOTATION
- a. The lower limit of detection (LLD) is defined in Table Notation a. of Table 4. 26-2 of Specification 4. 26.1.1.
- b. 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 radionuclides using observed ratios with those radionuclides which are measurabic.
- c. A composite sample is one in which the quantity of liquid sampled is proportional 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. A batch release is the discharge of liquid wastes of a discrete volume.
- e. The principal gamma emitters for which the LLD specification will apply are exclusively the fol-lowing radionuclides: Mn54, Fe59, CoS8, Cc60, Zn65, Mc99, Cc134, Csl37, Cel41, and Cel44.
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 re-ported. 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 reasons shall be docu-mented in the semiannual Radioactive Effluent Release Report. D Daily P Prior to Release M Monthly Q Quarterly R Every 19 Months 110z
Radioactive Liquid Effluents 4.24.2 Dose Applic sbility: Applies to radioactive liquid releases. Objective: To ensure that the dose or dose commit-ment to an individual frcm radioactive , liquid effluents is calculated. (See Specification 3.22.2) Specifications: 4.24.2.1 Cunulative dcsc contributions from liquid ef-fluents shall be determined in accordance with the Offsite Dose Calculation Manual (ODCM) for each release. 4.24.2.2 The Semiannual Radioactive Effluent Release Reporta shall include the information specified in Specification 6.12. 2.5. Bases: The dose calculations in the ODCM implement the requirements in Section III A of Appendix I. Section III requires 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 appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents 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, Oc tober 197 7, and Regulatory Guide 1.113, " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. 110aa
. Radioactive Liquid Effluents 4.24.3 Easte Trea tment Applicability: Applies to the parts of the liquid radioactive waste treatment system which are normally used to process liquid radwaste.
Objective: To ensure that the liquid radwaste treat-ment system is operational . Specifications: 4.24.3 The appropriate parts of the liquid radwaste system shall be demonstrated operational quarterly unless they have been utilized to process radioactive liquid ef fluents during the previous quarter. Bases: The operational status of the liquid radwaste treatment system ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the envi-ronment. 110bb
=
Radioactive Gaseous Effluents 4.25.] Dose Rate Applicability : Applies for each radioactive gaseous releases. Objective: To ensure that the dose rate, at any time, at the unrestricted area bound-ary from gaseous effluents will be within the annual dose limits of 10 CFR 20. Specifications: 4.25.1.1 The release rate, a t a ny time , of ncble gases in gaseous effluents shall be controlled by the offsite dose rate as established in Specifica-tion 3.23.1.1. 4.25.1.2 The gas effluent continuous monitors having provisions for the automatic termination of gaseous release shall be used to limit off-site doses so that the values established in Specification 3. 23.1 are not exceeded. 4.25.1.3 The does 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 analyses program, specified in Table 4.25-1, in performing the calculations of dose rate in unrestricted areas. 4.25.1.4 The Semiannual Radioactive Effluent Release Report shall include the information speci-fied in Specification 6.12.2.5. Bases: This specification provides f or sampling and analyses to ensure that Specification 3.23.1 is met. 110cc
TABLE 4.25-1 , RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSES PROGRAM Minimum Lower Limit of Gaseous Release Type S ampling Analyses Type of De tec tiop^ j LLD) Frequency Frequency Activity Analyses (uCi/ml) A. Waste Gas Each Tank Each Tank Principal Gamma Emmitters(e) 1 x 10
-4 (b)
Storage Tank Grab S ample H-3 -6 1 x 10 B. Reactor Bldg. Each Purge Each Purge Principal Gamma Emitters e) 1 x 10-4 (b) Purge Grab Sample H-3 -6 1 x 10 C. Unit Vents W,(c) W Principal Gamma Emitters (e) -4 (b) 1 x 10 s ( Auxiliary Bldg. ) Grab H -6 O (Spent Fuel Pool Sample H-3 1 x 10 g Area Ventilation) W -12 W(d) I-131 1 x 10 Charc oal Sample I-123 1 x 10 -10 W W(d) Pa r tic ula te Principal Gamma Emitters (e) Sample (I-131, O the rs) 1x 10 -11 W M Gross alpha -11 1 x 10 Particulate Sample W SR-89, Sr-90 -11 Q 1x 10 Composite Pa r tic ula te Sample
TABLE 4.25-2 (Continued) TABLE NOTATION
- a. The Lower Limit of Detection (LLD) is defined in Table Notation a. of Table 4.26-2 of Specification 4.26.1.1.
- b. For certain radionuclides with low gamma yield or low energies, or for certain radionuclide mixtures, it may not be possible to measure radionuclides in concentra-tions near the LLD. Under these circumstances, the LLD maybe increased inversely proportional to the magnitude of the gamma yield (i.e,. 1 x 10-4/I, where I is the photon abundance expressed as a decimal fraction), but in no case shall the LLD, as calculated in this manner for a specific radionuclide, be greater than 10% of the MPC value specified in 10 CFR 20, Appendix B, Table II, Column 1.
- c. Tritium grab samples shall be taken at least once per 7 days when the refueling canal is flooded.
- 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 calculation made in accordance with Specification 3.11.2.1, 3.11.2.2 and 3.11. 2. 3.
- e. The principal gamma emmitters for which the LLD speci-fication will apply are exclusively the f ollowing radionuclides: Kr-88, Xe-133, Xe-133m, Xe-235, and Xe-138 for gaseous emissions and Mn-54, Fe-59, C0-58, C0-60, Zn-65, M0-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and identifiable, t o-ge ther 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 f or that nuclide. Uhen unusual circumstances result in LLD's higher than required, the reasons shall be documented in the semiannual effluent report. D. Daily P Prior to Release U Ucekly M Monthly 0 Quarterly
. R Every 18 Months 110ee
Radioactive Gaseous Effluents 4.25.2 Dose, Noble Gaseous Applicability: Applies at all tbnes for radioactive gaseous releases. Objective: To ensure that the requirements of 10 CFR 50 Appendix I Section III A are met, and that the cumulative gaseous dose contributions ! are calculated. Specifications: 4.25.2.1 Cumulauive noble gas dose contributions for the total time period shall be determined in accord-ance with the Offsite Dose Calculation Manual (ODCM) for each release and at least once per month for continuous releases. 4.25.2.2 The semiannual Radioactive Ef fluent Release Report shall include the information specified in Specifi-cation 6.12.2.5. Bases: The Surveillance Requirements implement the requirements in Section III A of Appendix I that conform with the guides of Appendix I to be shown by calculational procedures based on models and data such that the actual exposure of an indivi-dual through the appropriate pathways is unlikely to be substantially underestimated. 110ff
Radioactive Gaseous Effluents 4.25.3 Dose, Iodine and Particulates Applicability: Applies at all times for radioactive gaseous releases. Objective: To ensure that the requirements of 10 CFR 50 Appendix I Section III A, are met and that the cumulative dose contributions of iodine and particulates are calculated. Specifications: 4.25.3.1 Cumulative dose contributions from iodine and parti-culates in gaseous ef fluents for the total time period shall be determined in accordance with the ODCM for each batch release and at least monthly for continuous releases. 4.25.3.2 The semiannual Radioactive Ef fluent Release Report shall include the information specified in Specification 6.12.2.5. Bases: The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section III A of Appendix I that conf ormance 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 nethods approved by NRC f or calculating the doses due to the actual release rates of the subject materials are required to be consistent with the ne thodology provided in Regulatory Guide 1.109, " Calculating of Annual Doses to Man fran Routine Releases or Reactor Effluents f or the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision I, October 1977 and Regulatory Guide 1.111, "Me thods 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 deter-mining the actual doses based upon the historical average atmospheric conditions. 110gg
Radioactive Gaseous Effluents 4.25.4 Gaseous Radwaste Treatment Applicability: Applies to the parts of the radioactive-waste treatment and plant ventilation filtration systems which are nornally used to process gaseous wastes. Objective: To ensure that the gaseous radwaste treatment and ventilation filtration syster.s are operational. Specifications: 4.25.4 The appropriate parts of the gaseous radwaste system shall be demonstrated operational quarterly unless the appropriate systen has been utilized to process radioactive gaseous ef fluents during the previous quarter. Bases: The operational status of the gaseous radwaste treabaent system and the ventilation exhaust treatment systems ensures tha t the systems will be available for use whenever gaseous effluents re-quire treatment prior to release to the environment. 110hh
Radioactive Gaseous Effluents 4.25.5 Gas Storage Tanks Applicability: Applies to the tanks in the gaseous radwaste holdup system. Obiective: To ensure meeting the requirements of specification 3.23.5. Specifications: 4.25.5 The quantity of radioactive material contained in each gas storage tank shall be determined to be within the limits of specification 3. 23.5.1 when radioactive materials are being added to the tank. Bases: This specification is provided so that the requirements of specification 3. 23. 5.1 are me t. 110ii
Radiological Environmental Monitoring 4.26.1 Monitoring Program Applicability: Applies at all times. Objective: To provide information on the radiological effects of station operation on the u.viron-ment. Specifications: 4.26.1.1 The radiological environmental monitoring samples shall be collected pursuant to Table 4.26-1 and shall be analyzed pursuant to the requirements of Tables 4.26-1 and 4.26-2. The sample locations shall be shown on a figure in the ODCM. 4.26.1.2 a. With the radiological environmental monitoring program not being conducted as specified in Table 4.26-1, prepare and submit to the Commission in the Annual Radiological Environmental Report, a descrip-tion 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 not obtainable due to haz-ardous conditions, seasonal unavailability, or to malfunction of 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 speci-fied in Table 4.26-1 exceeding the limits of Table 4.26-3 when averaged over any calendar quarter, pre-pare and submit to the Canmission within 30 days from the end of the affected calendar quarter, a report which includes an evaluation of any release condit-ions, environmental factors or other aspects which caused the limits of Table 4.26-3 to be exceeded.
This report is not required if the measured level of radioactivity was not the result of plant efflu-ents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Report.
- c. With milk or fresh leafy vegetable samples un-available from any of the sample locations required by Table 4.261, prepare and submit to the Commission within 30 days, pursuant to Specification 6.12.2.3 a report which identifies the cause of the unavail-110jj
ability of samples and identifies locations for obtaining replacement samples. The locations from which samples were unavailable may then be deleted from Table 4.26-1 provided the locations from which the replacement samples were obtained are added to the environmental monitoring program as replacement locations, if available. 4.26.1.3 The results of analyses performed on the radio-logical environmental monitoring sanples shall be summarized in the Annual Radiological Environmental Report. The Annual Radiological Environmental Report may be submitted with or as a part of the Annual Environmental Report required by Environ-mental Technical Specification 5.6.1. Bases: The radiological monitoring progran required by this specifi-cation provides measurements of radiation and of radio-active materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from the station operation. This monitoring program thereby supplements the radiological ef fluents monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radia-tion are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure path-ways. The initally specified monitoring program will be ef fective for at least the first three years of commercial operation. Following this period, program changes may be initiated based on operational experience. The detection capabilities required by Table 4.26-2 are state-of-the-art for routine environmental measurements in industrial laboratories. The LLD's for drinking water meet the requirements of 40 CFR 141. 110kk
TABLE 4.26-1 - RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Sampling and Type and Frequency and/or Sample Sample Locations
- Collection Frequency of Analyses
- 1. AIRBORNE
- a. Radiciodine (Locations 1-7) Continuous operation of Radiciodine canister.
and Partic- sampler with sample col- Analyze at least once ulates lection as required by pe r 7 days for I-132. dust loading but at least once per 7 days. Particulate sampler. Analyze for gross beta radioactivity > 24 hours H following filter change. $ Perf orm gamma isotopic [ analysis on each sample when gross beta activity is > 10 times the mean of control sample. Per-form gamma isotopic anal-sis on canposite (by loca-tion) sample at least once per 92 days.
- 2. DIRECT RADIATION (Locations 1-7) At least once per 92 Gamma dose. At least 2 dosime ters days. once per 92 days.
- Sample locations are shown in the Of fsite Dose Calculation Manual (ODCM).
~
~
TABLE 4.26-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Sampling and Type and Frequency and/or Sample Sample Locations
- Collection Frequency Of Analyses
- 3. WATERBORNE
- a. Surface (Location 8 and 10) Monthly grab sample Gamma isotopic analysis collected once per of each sample by : loca-31 days, tion. Tritium analysis of composite sample at least once per 92 days.
- b. Ground (Location 11 and 13) At least once per 92 days. Gamma isotopic and tritium analyses of each sample.
Z c. Drinking (Locations 14) Monthly grab sample I-131 analysis of each f sample ; and Gross beta and gamma isotopic analyses of each sample. Tritium analysis of composite sample at least once per 92 days.
- d. Sediment (Location 8, 10) At least once per 184 days. Gamma isotopic analysis f r om of each sample Shoreline
- Sample locations are shown in the ODCM.
TABLE 4.26-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pa thway Sampling and Type and Frequency and/or Sample Sample Locations
- Collection Frequency of Analyses
- 4. INGESTION
- a. Milk (Locations 19, 20, 23, At least once per 31 days Gamma isotopic and I-131
- 26) when animals are on analyses of each sample.
pasture.
- b. Fish (Locations 8 and 10 ) One sample in season, Gamma isotopic analysis or at least once per on edible portions.
184 days if not seasonal. One sample of each of the f ollowing species: p 1. Catfish g 2. Crappie
- c. F o od * * (Locations 30, 31, 32) At time of harvest. One Gamma isotopic analysis Products sample of each of the on edible portion following classes of food products:
- 1. Fruits
- 2. Flowering Vege table
- 3. Tubular Vegetable (Location 33) At time of harvest. One I-131 analysis.
sample of broad leaf vege ta tion .
- Sample locations are shown in the ODCM
**If these food products are available.
TABLE 4.26-2 MAXIMUM VALUES OF TIIE LOWER LIMITS OF DETECTION (LLD Water Airborne Particulate Analyses (pCi/1) Fish Milk Food Products Sediment or Gag) (pCi/m ( pCi/ kg , we t) (pCi/l) ( pCi/ kg , we t) (pCi/kg, dry) gross beta 4(b) 1x 10 -2 II 2000 (100b) 54 g 15 130 59 30 260 Fe o 58,60 15 130 Co 65 30 260 Zn 95 15 Zr-Nb
-2 131 1
1* 7x 10 1 60(c)
-2 134,137 ), 18 1x 10 130 15 80 Cs 15(10 Ba-I>a 140 15 15 *For Monthly grab samples
TABLE 4.26-2 (Continued) TABLE NOTATION a - The LLD is the smallest concentration or radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal. For a particular measurement system (which may include radio-chemical separation): LLD = 4.66 sw E- V. 2.22- Ye exp (- A o t) 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 appro-priate (as counts per minute) E is the counting efficiency (as counts per transfor-mation) V is the sample size (in units of mass or volume) 2.22 is the number of transformation per minute per picocurie Y is the fractional radiochemical yield (when appli-cable) x is the radioactive decay constant for the particular radionuclide a t is the elapsed' time between sample collection (or end of the sample collection period) and time of count-ing The value of sb used in the calculation of the LLD for a detec-tion system shall be based on the actual observed variance of the background counting rate or of the counting rate of the blank samples (as appropriate) rather than on an unverified theoretically predicted variance. In calculating the LLD for a radionuclide determined by gamma-ray spectrometry, the back-ground shall include the typical' contributions of other radio-nuclides normally present in the samples (e.g., potassium-40 in milk samples). 110cp
TABLE 4.26-2 (Continued) TABLE NOTATION Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing f actors will be identified and described in the Annual Radiologi-cal Environmental Operating Report, b - LLD for drinking. c- LLD for leafy vegetables. 110gg
s TABLE 4.26-3 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Reporting Levels Water Analyses (pCi/l) Airborne Particulage or Gases (pCi/m ) Fish Milk Vegetables (pCi/kg , wet) (pCi/l) (pCi/kg, wet) H-3 3 x 10 4 Mn-54 1 x 10 3 3 x 10 4 Fe-59 4 x 102 1 x 10 4 Co-58 1 x 10 3 3 x 10 4 Co-60 3 x 10 1 x 10 4 H $ Zn-65 3 x 102 2 x 10 4 Zr-Nb-95 4 x 10 2 I-131 2 0.9 2 3 1 x 10 Cs-134 30 10 1 x 10 60 1 x 10 3 Cs-137 50 20 2 x 10 3 70 2 x 10 3 2 Ba-La-140 2 x 10 3 x 10 2
, Radiological Environmental Monitoring 4.26.2 Land Use Census Applicability : Applies at all times.
Objective: This specification will identify changes in use of the unrestricted areas. Specifications: 4.26.2.1 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 of the 16 meteorological sec-tors within a distance of five miles from the ANO-1 reactor building.
4.26.2.2 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. 4.26.2.3. a. With a land use census identifying a loca-tion (s) which yields a calculated dose or dose commitment greater than the values currently being calculated in Specification 4.25.3.1, prepare and submit to the Commis-sion within 3 0 days, pursuant to Specifica-tion 6.12.2.3, a report which identifies the new location (s).
- b. With a land use census identifying a loca-tion (s) which flelds a calculated dose or dose commitment (via the same exposure path-way) greater than at a location from which samples are currently being obtained in accor-dance with Specification 4.26.1.2a prepare and submit to the Commission within 30 days, pursuant to Specificatior. 6.12.3.2, a report which identifies the new location. The new location shall be added to the radiological environmental monitoring program within 30 days, if possible. The s ampling location having the lowest calculated dose or dose c ommi tmen t (via the same exposure pathway) may be deleted from this monitoring program after (October 31) of the year in which this land use census was conducted.
4.26.2.4 The results of the land use census shall be included in the Annual Radiological Environmental Report.
- Broad leaf vegetation sampling may be performed at the site boundary in the direction sector with the highest D/O in lieu of the garden census.
110ss
Bases: This specification is provided to ensure that changes in the use of unrestricted areas are identified and that modi-fications to the monitoring program are made if required by the results of this census. This census satisfies the re-guirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 500 square feet provides assurance that significant exposure pathway via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26k9/ year) of leafy vegetables assumed in Regula-tory Guide 1 109 for consumption by a child. To determine this minimum garden size, the following assumptions 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.
110tt
=
Radiological Environmental Monitoring 4.26.3 Interlaboratory Comparison Program Applicability: Applies to the off-site radiochemistry laboratory. Obiective: To provide independent checks on the accuracy of the measurements of radioactive material in environmental s ample s. Specifications: 4.26.3.1 Analyses shall be performed on radioactive materials supplied as part of Interlaboratory Comparison Pro-gram which has been approved by NRC. 4.26.3.2 With analyses not being performed as required above, report the corrective actions taken to prevent a re-currence to the Commission in the Annual Radiological Environmental Report. 4.26.3.3 The results of analyses performed as part of the above required Interlaboratory Canparison Program shall be included in the Annual Radiological Envi-ronmental Report pursuant to Specification 6.12.2.4. Bases: The requirement for participation in an Interlaboratory Canpari-son Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of a quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid. 110uu
4.27. Radioactive Effluent Instrumentation 4.27.1 Liquid Applicability: Applies to the instrumentation in the liquid radwaste system that is used to limit the amount of radioactivity released to the environs. Objective: To provide surveillance specifications for the instruments required in Specification 3.5.6. Specifications: 4.27.1.1 Each radioactive liquid effluent monitoring instru-mentation channel shall be demonstrated operable by performance of the channel check, source check, channel calibration, and channel test at the frequencies shown in Table 4.27.1-1. 4.27.1.2 Auditable records shall be mai ntained, of all radio-active liquid ef fluent monitoring instrumentation alarn/ trip setpoints. Bases: To ensure that the instrumentation for the liquid radwaste systen is operable. 110vv
Table 4.27.1-1 Radioactive Liquid Ef fluent lionitoring Instrumentation Surveillance Requirement Channel Source Channel Channel Instrument Check Check Calibration Test Liquid radwaste effluent line Radiation monitor D* P** R Q Flow monitor D* NA R Q Notation
*During releases via this pathway r, **A source check is not required if the background activity is greater than the activity
[ of the check source k D Daily P Prior to release
?! Monthly 0 Quarterly R Every 18 months
9 4.27.2 Gaseous Applicability: Applies to the instrumentation in the gaseous radwaste system that is used to limit the amount of activity released to the environs. Objective: To provide surveillance specifications for the instruments listed in Specification 3.5.7. Specifications: 4.27.2.1 Each radioactive gaseous effluent monitoring instru-mentation channel shall be demonstrated operable by perf ormance of the channel check, source check, channel calibration, and channel test at the frequencies shown in Tabic 4.27.2-1. 4.27.2.2 Auiditable records shall be maintained of the calcu-lations made, in accordance with the OCDM, of all radioactive ef fluent monitoring instrumentation alarm / trip setpoints. Bases: To ensure that the instrumentation for the gaseous radwaste system is operable. 110xx
Table 4.27.2-1 ' Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Channel Channel Source Channel Functional Ins trume n t Check Check Calibration Test
- 1. Haste Gas Holdup System
- a. Noble Gas Activity monitor P* P R Q
- b. Iodine Sampler Cartridge D*(l) N/A N/A N/A
- c. Particula te Sampler Fil ter D* (l) N/A N/A N/A
- d. System Ef fluent Flow Rate Measuring Device P* N/A R Q
- e. Sampler Flow Rate Measuring D* N/A R Q
- 2. Auxiliary Building Ventila-tion System
- a. Noble Gas Activity D* M R Q Monitor
- b. System Effluent Flow Rate Measurement Device D* N/A R Q
- c. Sampler Flow Rate Measurement Device D* N/A R Q
Table 4.27.2-1 (Cont'd) - nnainactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Channel Channel Source Channel Functional Instrument Check Check Calibration Test
- 3. Spent Fuel Pool Area Ventilation Sys tem
- a. Gas Activity D* M R Q Monitor
- b. System Ef fluent Flow Rate Measure-ment Device D* N/A R Q
- c. Sampler Flow Rate Measurement Device D* N/A R Q U
O
- 4. Reactor Building Purge System
- a. Ga s Ac tivi ty Monitor D* M R Q
- b. System Ef fluent Flow Rate D* N/A R Q
- c. Sampler Flowrate Measurement Device D* N/A R Q
*During releases via this pathway.
P Prior to release D Daily M Monthly 0 Quarterly R 18 Months NA Not Applicable (1) Verify presence of cartridge of filter only.
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FIGURE 5.1-1 MAXIMUM AREA BOUNDARY FOR RADIOACTIVE RELEASE CALCULATIONS (gases - 1046 meter radius) (liquids - end of discharge canal (Point A)) ARKANSAS-UNIT 1 llla
- g. Review of f acility operations to detect potential nuclear safe ty hazards.
- h. Performance of special reviews, investigations and
, reports thereon as requested by the General Manager.
- i. Review of the Plant Security Plan and implementing procedures and shall submit recommended changes to the General Managor.
- j. Review of the Emergency Plan and implementing pro-cedures and shall submit recommended changes to the General Manager,
- k. Review of every unplanned release of radioactive material to the environs; evaluate the event; specify remedial action to prevent recurrence; and document the event description, evaluation, and corrective action and the disposition of the corrective action in the plant records.
- 1. Review of all changes to the offsite dose calcula-tion manual.
AUTHORITY 6.5.1.7.1 The Plant Safety Committee shall:
- a. Recommend to the General Manager written approval or
. disapproval of items considered under 6.5.1.6(a) through (d) above.
- b. Render determinations in writing with regard to whether or not each iten considered under 6.5.1.6(a) through (c) above constitutes an unreviewed safety question.
6.5.1.7. 2 In the event of a disagreement be tween the recommenda-tions of the Plant Safety Committee and the actions contemplated by the General Manager, the course determined by the General Manager to be more conserva-tive will be followed. Records of the disagreement will be sent for review to the Director, Generation Operations, or Manager, Nuclear Operations and the Chairman of the Safety Review Committee by the General Manager on the next working day. RECORDS 6.5,1.8 The Plant Safety Committee shall maintain written minutes of each meeting and copics shall be provided to the Chairman of the Safety Review Committee by the General Manager. 6.5.2 Safety Review Committee (SRC)
-123-Amendment No. 37
FUNCTION
. 6.5.2.1 The Safcty Review Committee shall function to provide independent review and audit of designated activities in the areas of:
- a. nuclear power plant operations
- b. nuclear engineering
- c. chemistry and radiochemistry Amendment No. 37 -123a-
REVIEU 6.5.2.7 The SRC shall review:
- a. The safe ty evaluatiens f or 1) changes to procedures equipment or systems and 2) tests or experiments ccmpleted under the provision of Section 50.59, 10 CFR, to verify that such actions did not con-stitute an unreviewed safety question.
- b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as de-fined in Section 50.59, 10 CFR.
- c. Proposed tests or experiments which involve an un-reviewed safety question as defined in Section 50.59, 10 CFR.
- d. Proposed changes in Technical Specifications or licenses.
- c. Violations of applicable statutes, c ode s , regu-lations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety signifi-Cance.
- f. Significant operating abnonnalities er devia-tions from normal and expected perf ormance of plant equipment that affect nuclear safety.
- g. Reportable occurrences requiring 24 hour noti-fication to the Commission.
- h. Reports and meeting minutes of the PSC.
- i. Changes to the ODCM.
AUDITS 6.5.2.8 Audits of f acility activities shall be perf ormed under the cognizance of the SRC. These audits shall en-compass:
- a. The conf ormance of f acility operation to pro-visions contained within the Technical Speci-fications and applicable license conditions at least once per year.
- b. The perf ormance and retraining of all members of the plant management and operations staff, and the perf ormance, training, and qualifications of new members of the entire plant staff at least once per year.
Amendment No. 34 -125-
- f. The Facility Security Plan and implementing proce-dures at Icase once per two years.
- g. Any other area of f acility operation considered appropriate by the SRC or the Vice-President, Generation & Construction (VPG&C).
- h. The radiological environmental monitoring program and the results thereof at least once per 12 months.
- i. The OFFSITE DOSE CALCULATION MANUAL and implemen-ting procedures at least once per 24 months.
6.5.2.9 Soecial Inspections and Audits A. An independent fire protection and loss prevention program inspection and audit shall be perf ormed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire pro-tection firm. AUTHORITY 6.5.2.10 The SRC shall report to and advise the Vice-President, Generation and Construction (VPG&C) within 30 days following each meeting. RECORDS 6.5.2.11 Records of SRC activities shall be prepared, a p-proved and distributed as indicated below:
- a. Minutes of each SRC meeting shall be pre-pared, approved and forwarded to the Vice-President, Generation & Construction (VPG&C) within 30 days following each meeting.
- b. Reports of reviews encompassed by Section 6.5.2.7.e, f, g and h above, shall be prepared, approved and forwarded to the Vice-President, Generation and Construction, (VPG&C) within 30 days following comple tion of the review,
- c. Audit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Vice-President, Generation & Construction (VPG&C) and to the management positions responsible for the areas audited within 30 ' af ter completion of the audit.
6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken for Reportable Occurrences:
-126-
- a. The Commission shall be notified and/or a report
, submitted pursuant to the requirements of Specifi-cation 6.12.
- b. Each Reportable Occurrence requiring 24 hour notifi-
- cation to the Commission shall be reviewed by the PSC and submitted to the SRC and the Manager, Nuclear Operations by the General Manager.
6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
- a. The facility shall be placed in at least hot shutdown within one hour.
- b. The Nuclear Regulatory Commission shall be notified and a report submitted pursuant to the requirements of 10 CFR 50.36 and Specification 6.12.3.1.
6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:
- a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.
- b. Refueling operations.
- c. Surveillance and test activities of safety related equipment.
- d. Security Plan implementation.
- e. Emergency Plan implementation.
- f. Fire Protection Program implementation.
- g. Offsite Dose Calculation Manual Implementation at the site.
6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed by the PSC and approved by the General Manager prior to implementation and reviewed periodi-cally as set forth in administrative procedures. 6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:
- a. The intent of the original procedure is not altered.
- b. The change is approved by two members of the plant staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
- c. The change is documented, reviewed by the PSC and approved by the General Manager within 14 days of implementation.
Amendment No. 37 -127-
The does 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 does received from external sources shall be assigned to specific major work functions. 6.12.2.3 Monthly Operating Report Routine reports of operating statistics which include: (1) Average Daily Unit Power Level (2) Operating Date Report (3) Unit Shutdowns and Power Reductions (4) Narrative Summary of Operating Experience (5)* Changes to the Offsite Dose Calculation Manual (ODCM) Shall be submitted on a monthly basis to the Director, Office of Management Information and Program Control, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the appropriate Regional Office, by the fif teenth of each month following the calendar month covered by the report.
+
6.12.2.4 Annual Radiological Environmental Report (a) Routine radiological environmental reports cover-ing the operation of the unit during the pre-vious calendar year shall be submitted prior to May 1 of the year following initial criticality. (b) The annual radiological environmental reports shall include summaries, interpretations, and statistical evaluation of the results of the rarliological environmental surveillance activities for the report period, including a comparison 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 report shall also include the results of the land use census required by Specification 4.26.2. If harmful effects or evidence of irreversible damage are detected by the moni-toring, the report shall provide an analysis of the problem and a planned course of action to alleviate the problem. -
- Changes to the ODCM shall be submitted within 90 days frcm when the change was made ef fective.
*A single submittal may be made f or ANO-1 and ANO-2. The sub-mittal should combine those sections that are common to both units at the station. This submittal may be combined with the report required by Environmental Technical Specifi-cation 5.6.1.
141
The annual radiological environmental reports shall include summarized and tabulated results in the format of Table 6.12-1 of all radiological environmental sampics taken during the report pe ri od . In the event that some results are not available for inclusion with 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 in a supplementary report. The reports shall also include the following: a summary description of the radiological environ-mental monitoring program including sampling methods for each sample type , size and physical characteristics of each sample type, sample pre-paration methods, analytical methods, and measur-ing equipment used; a map of all sampling loca-tions keyed to a table giving distances and direc-tions from one reactor; the result of land use census required by the Specification 4.26.2, and the results of licensee participation in the Interlaboratory Comparison Program required by Specification 4. 26. 3. 6.12.2.5 Semiannual Radioactive Ef fluent Release Report ** (a) Routine radioactive effluent release reports covering the operating of the unit during the previous 6 months of operation shall be sub-mitted within 60 days af ter January 1 and July 1 of each year. The period of the first report shall begin with the data of initial critica-
, l i ty .
(b) The radioactive effluent release reports shall include a summary of the quantities of radio-active liquid and gaseous effluents and solid waste release frcm the unit. The data will be summarized on a quarterly basis f ollowing the f ormat of Regulatory Guide 121, Rev.0 Appendix A. (c) The radioactive effluent release reports shall include the following information for all un-planned releases to unrestricted areas of radioactive materials in gaseous and liquid ef fluents :
**A single submittal may be made f or ANO-1 and ANO-2 141a
. ~
TABLE 6.12.1 ENVIR0tNENTAL RADIOLOGICAL MONITORING PROGRAM
SUMMARY
Name of facility Docket No. Location of Facility Reporting Period (County,Sta te) Type Lower Limits Medium or Pathway of of location with 181ohest Control Locations Sampled Analyses Detectiona AllIndicator(ocations Mean (1) Namo honual(Pcha Mean Mean ( )b
, (Unit of Measurement) Performed (LLD) Range Distanco and Direction Rangeg)b Range g .
D 3 . 5 E i $[c$ pa ) Cr l? E w dNominal b Lower Limits of Detection (LLD) as defined in tablo notation a. of Tablo 4.26-2 Specification 4.26.1, Mean and range based upon detectable measurements only. Traction of detectable measurements at specified locations is indicated in parentheses (1). 8
- 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.
6.12.3 Reportable Occurrences Reportable occurrences, including corrective actions and measures to prevent reoccurrence, shall be reported to the NRC as required below. Supplemental reports may be required to fully describe final resolution of occurrence. In case of corrected or supplemental reports, a licensee event report shall be completed and reference shall be made to the original report date. 6.12.3.1 Prompt Notification With Written Followup The types of events listed below shall be reported as expedi-tiously as possible, but within 24 hours, by telephone and con-firmed by telegraph, mailgram, or facsimile transmission to the Director of the appropriate Regional Office, or his designate no later than the first working day following the event, with a written followup report within two weeks. A copy of the confirmation and the written followup report shall also be sent to the Director, Office of Management Information and Program Control, USNRC. 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 surround-ing the event. (a) Failure of the reactor protection system or other systems subject to limiting safety system settings to initiate the required protective function by the time a monitored parameter reaches the setpoint specified as the limiting safety system setting in the Technical Specifications or failure to complete the required protective function. NOTE: Instrument drift discovered as a result of testing need not be reported under this item but may be reportable under items (e), (f), or 6.12. 3. 2 (a) . 142
(d) Abnormal degradation of systems other than those specified in item 6.12.3.l(c) above designed to contain radioactive material resulting f r om the fission process. NOTE: Scaled sources or calibration sources are not in-cluded under this item. Leakage of valve packing or gaskets within the limits for identified leakage set forth in Technical Specifications need not be reported under this item. (e) An unplanned of fsite release of 1) more than 1 curie of radioactive 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 an unplanned of fsite release of radioactive material shall in-clude the following information:
- 1. A description of the event and equipment in-volved .
- 2. Cause(s) for the unplanned release.
- 3. Actions taken to prevent recurrence.
- 4. Consequences of the unplanned release.
( f) Occurrence of radioactive material contained in liquid or gaseous holdup tanks in excess of that permitted by the limiting condition for operation established in the technical specifications. (g) Any report ( s) required by Specification (s) 3.22, 3.23, 4.24, 4.25, and 4. 26, except those reports described in Specification 6.12.2. (h) Measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting level values of Table 4.26-3 when averaged over any calendar quarter sampling period. When radionuclides other than those in Table 4.26-3 are detected and are the result of plant ef fluents, 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 3.22.2.2, 3.23.2.2 and 3.23.3.2. 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 des-cribed in the Annual Radiological Environmental Report. 145
6.13 Offsite Dose Calculation Manual (ODCM) 6.13.1 The ODCM shall describe the methodology and parameters to be used in the calculation of of fsite doses due to radioactive gaseous and liquid ef fluents and in the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints consistent with the applicable LCO's contained in these Technical Specifications. 6.13.2 Changes to the ODCM made by the licensee shall:
- 1. Be reviewed and found acceptable by the PSC and SRC.*
- 2. Be submitted to the Ccamission by inclusion in the Monthly Operating Report pursuant to Speci-fication 6.12.2.3 within 90 days of the date the change (s) was made effective and shall contain:
- a. suf ficiently detailed inf ormation to totally support the rationale for the change. In-formation submitted should consist of a package of those pages of the ODCM to be changed with each page numbered and provided together with appropriate analyses or evalua-tions justifying the change (s);
- b. A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and
- 3. Shall beccme ef fective upon a date specified and agreed to by both the PSC and SRC following their review and acceptance of the change (s).
- Changes to the locations of environmental sampling stations, required by Specification 4. 26.1, shall not require review by the PSC and SRC prior to implementation.
147
0 0 8 6 ENCLOSURE 2 OBJECTIONS TO GENERAL SPECIFICATIONS
Enclosure 2 Solid Radioactive Wastes Provided in 10 CFR, Part 71 and 49 CFR, Part 173 are requirements which Part 50 licensees must meet to package and transport radioactive wastes off-site for disposal. If these requirements are not met, then legally we (i.e. Part 50 licensees) are in violation of federal codes and regulations which can result in fines and other measures. The Solid Radioactive Waste System provides no measurable increase in the protection of the health and safety of the public. Therefore, its in-clusion in the safety technical specifications is unwarranted. If requirements were to appear in 10 CFR, Part 71, or 49 CFR, Part 173, to require solidification of all radioactive waste to be transported off-site, this would not preclude the licensee from utilizing a solidification system provided by an outside vendor. These regulations would then provide for packaging and transporting of radioactive waste in a solidified form. In-clusion of a redundant technical specification in the license is superfluous and unnecessary. The promoting of a regulatory position (i.e. not a regulation) to a regulation by including it in the Technical Specifications (which are regu-lations which the licensee must conform) to give credence to the said position is unacceptable to us. Meeting all applicable criteria of 10 CFR, Part 71 and 49 CFR, Part 173, precludes any necessity for and makes a moot point of any rationale for including the solidification operability in technical speci-fications. Explosive Gas mixture This specification requires that the hydrogen and/or oxygen concentration in the waste gas holdup system be 14%. The concentration of hydrogen and/or oxygen is to be reduced if the 4% level is exceeded. The only practical method available to us to reduce the concentration of a chemical in one of these tanks is to release the contents of the tank. This seems to directly contradict the reason for which the radioactive gas was put in the tanks - to holdup the radioactive gases for the short-lived isotopes to decay. Based on the above we are not including this specification. Liquid Holdup Tank Our Borated Water Storage Tank (BWST) may fall into this category. However, this tank is not part of the liquid radwaste system, it is part of the Emergency Core Cooling System (ECCS). The way the specification is worded it implies that the entire contents of the tank are assumed to be discharged (i.e. tank rupture) . This tank is a seismically supported tank. Considering that this tank is part of the ECCS, the volume of borated water within the tank is specified, the tank is seismically supported, and that the consequences of a LOCA to the general public could far out weigh the consequences of this tank completely overflowing. We do not think that this specification is necessary.
Enclosure 2 Dose from Uranium Fuel Cycle: This specification limits the dose or dose cmmitment to an individual from all uranium fuel cycle sources. We an con-trol the releases frm Arkansas Nuclear One, however, we cannot control the releases from any other facility. We do not think that this is an appropriate specification to place on any power plant, and have therefore deleted it.
e a e 9 4 ENCLOSURE 3 ENVIRONMENTAL TECHNICAL SPECIFICATIONS
/
1.0 DEFINITIONS Listed below are terms used in these environmental technical specifications that could be considered as having a unique definition as applied to Arkansas Nuclear One-Unit 1 (ANO-1). Standard Methods
" Standard Method for the Examination of Water and Wastewater,"
14th edition, published by the American Public Health Association. Environmental Samples Samples of soil, air, biota, or biological material collected outside of the plant buildings for the purpose of analysis. RTD Resistance Temperature Detector 1-1
2.0 Limiting Conditions for Operation N/A O 2-1
3.0 Environmental Monitoring The aquatic environmental monitoring programs described in sections 3.2 and 3.3 shall commence as specified under each program and continue for five years after initial criticality of ANO-2 unless modified or termi-nated as provided for in subsection 5.7.1 of these ETS. Results of the program, including reports submitted in accordance with specification 5.6.1, will be reviewed as specified in section 5.3. If sampling cannot be performed on scheduled dates due to adverse weather condition or for other justifiable reasons, the basis shall be recorded and sampling shall commence on the first practical date following the scheduled date. 3.1 Plant Discharges 3.1.1 Maximum AT Across Condenser Objective To limit thermal stress to the aquatic ecosystem by limiting the maximum AT across the ANO-l condenser during operation. Monitoring Requirements 3.1.1.1 The temperature differential across the ANO-l con-denser shall be monitored every hour utilizing the computer output of the condenser inlet and the cir-culating water discharge flume temperature measure-ments. If the plant computer is inoperable, the
. ANO-1 condenser AT shall be monitored at least once each shift when the plant is operating at steady state power levels. The ANO-1 condenser aT shall be 3-1
measured within two (2) hours after a change in power level has been stabilized and at least once each shift thereafter. The ANO-1 condenser T shall be deter-mined using measurements at the ANO-1 condenser inlet and in the discharge canal. Action
- a. If the maximum differential temperature across the ANO-l condenser exceeds 15 F during normal operation with all four circulating water pumps in operation; or
- b. If one or two circulating water pumps are out of service at any given time and the maximum ANO-1 condenser BT exceeds 30 F; the licensee shall:
submit a non-routine report to the commission pursuant to specification 5.6.2.b. Bases Maximum T's of 15 0 F with 4 circulating water pumps operating (N1700 cfs flow) and 300F with 2 circulating water pumps operating will ensure that the limits of the applicable water quality criteria will not be exceeded. The difference in temperature readings of the RTD's at the inlet of the condensers and at the circula-ting water discharge flume provides the AT across the condensers. Specification 3.1.1.2 allows' maintenance to be per-formed on circulating water pumps when the Dardanelle Reservoir ambient temperature is such that Specifi-3-2
cation 2.1.2 will not be exceeded. Hydraulic model studies have shown that a 30 F AT at 850 cfs circulating waterflow will not result in adverse changes in the Dardanelle Reservoir isotherms when compared to the isotherms resulting from a 150F AT at 1700 cfs except on the surface of the discharge embayment. 3.1.2 Maximum Discharge Temperature Objective To limit thermal stress to the aquatic ecosystem by limiting the plant's maximum discharge water tempera-ture. Monitoring Requirements 3.1.2.la The ANO-1 condenser discharge water temperature shall be monitored every hour utilizing the average of the computer output of the circulating water discharge flume RTD readings. 3.1.2.lb If the plant computer is inoperable, the ANO-1 con-denser discharge temperature shall be measured at least once each shift. If the condenser inlet tem-perature exceeds 85 F with all four circulating water pumps running or 70 0 F with less than four circulating water pumps running, the circulating water discharge flume temperature shall be monitored every two (2) hours. 3.1.2.2 If the circulating water discharge flume temperature exceeds 105 F, the water temperature from the mouth of the discharge embayment will be monitored every two hours as long as the condenser outlet temperature re-mains above 1050F. 3-3
Action If the ANO-1 condenser discharge water temperature exceeds 105 0 F for more than 2 hours, a non-routine report, as described by ETS 5.6.2.b, and 5.6.2.c, will be submitted to the Commission. Bases The 105 F maximum discharge water temperature limit is set to assure that the Dardanelle Reservoir temperature does not exceed 95 F as established by the applicable water quality criteria. The use of the cir-culating water discharge flume RTD's provides the circu-lating water discharge temperature prior to mixing with the Dardanelle Reservoir water. No credit was taken in the analyses and models of the circulating water system for heat exchange within the discharge embayment even though it is expected that the water temperature will be reduced in the embayment. Thus, the average temperature should be 105 F even when the temperature at the circulating water discharge flume is greater. 3.1.3 Rate of Change of Discharge Temperature Objective T' . , void thermal stress to the aquatic ecosystem due to sudden changes in water temperature. Applicability Specification 3.1.3 applies to planned shutdowns of ANO-1 during the period of November through April. 34
Monitoring Reauirement 3.1.3.la Circulating water discharge flume temperature will be monitored every hour during the power reduction utilizing the average of the computer output of the circulating water discharge flume RTD readings. 3.1.3.lb If the plant computer is inoperable, the circula-ting water discharge flume temperature shall be monitored at least once per hour during the power reduction utilizing the ccndenser temperature recorder. 3.1.3.2 The aquatic environment of the discharge embay-ment will be watched during and immediately af ter planned shutdowns in order to detect any adverse environmental impacts on the embayment, which might occur. A record of the observations made, rate of temperature change, and appropriate data shall be maintained. Action The data required by ETS 3.1.3.2 will be submitted in the report required by ETS 5.6.1. Bases There has been no incidence of adverse environmental impact associated with any operating AP&L power plant. There is also a lack of data or evidence which would support a limiting rate of change of temperature for the specific species that might inhabit the dis-charge embayment. Reducing the thermal stocks to the discharge canal will minimize the ef fects of plant shutdown to aquatic life in the discharge canal . 3-5
3.1.4 Dilution of Discharges
. Objective To assure that the waste streams from ANO-l are diluted before entering the discharge embayment on the Dardanelle Reservoir.
Monitoring Requirement 3.1.4.1 When chemical discharges, are being made during ANO-1 outages, the 1.icensee shall record the number of ANO-1 circulating water pumps in operation. This specifica-tion does not apply to the plant sanitary sewage system. 3.1.4.2 Monthly record of the types and amounts of bulk chemicals used to treat plant water systems shall be kept. Action
- a. A non-routine report, as specified in ETS 5.6.2b, will be submitted if less than 2 circulating water pumps are in operation while releases or discharges, as specified in ETS 3.1.4.1., are being made.
- b. The records required by - .1.4.2 shall be summarized and reporte- 2 report required by ETS 5.6.1.
Bases Dilution of chemical releases from the plant will protect local biota from lethal and sublethal effects of these discharges and will assure that the most 3-6
sensitive uses of the receiving stream by human popu-lations is protected. Documentation of chemical usage will enable the NRC to keep abreast of the types and amounts of chemicals being used at the plant and ensure that the plant is being operated in a manner consistent with that evaluated in the FES. 3-7
e 3.2 Abiotic - Aquatic Biological Monitoring 3,2.1. Thermal Characteristics of Cooling Uater Discharge Environmental Monitoring Requirement The thermal impact of ANO Unit 1 cooling water dis-charge on the temperature profile of Dardanelle Reservoir shall be determined (in accordance with procedures developed by the licensee) . The licensee shall determine horizontal and vertical temperature profiles of Dardanelle Reservoir at stations listed in Table 3-1 and shown in Figure 3-1 on a monthly basis. This monitoring program shall be a continuatien of the Dardanelle Reservoir background survey initiated in 1968. Action The results of the monitoring conducted under this program shall be reported in accordance with Subsection 5.6.1. Bases The purpose of this monitoring program is to fulfill requirements of Arkansas Department of Pollution Control and Ecology (Permit #827) by assuring that the operation of ANO does not create a thermal block in Dardanelle Reservoir. A portion of the reservoir can be dedicated to temperatures exceeding ambient plus 5 F providing that a thernal block is not created that would prevent fish migration. A thermal block 3-8
would be considered te exist if the circulating water discharge created an uninterupted water temperature zone in excess of ambient plus SF extending from bank to bank in the main channel of the reservoir. 3-9
3.2.2 Water Quality Environmental Monitoring Requirement Water Quality data shall be collected to determine the impact of ANO plant operation on Dardanelle Reservoir. Physical parameters listed in Table 3-2 and chemical parameters listed in Table 3-3 shall be evaluated monthly on water samples taken at stations listed in Table 3-1 and shown in Figure 3-2. The licensen shall record for each sampling period the air teinperature, wind speed (mph), general meteoro-logical conditions and reservoir elevation. The collection of samples should coincide to the extent practical with the aquatic biological sampling per-formed according to subsection 3.1.2.a.1-2. Action The results of the monitoring conducted under this program shall be reported in accordance with Sub-section 5.6.1. Bases Physical and chemical water quality data will yield information required for the evaluation of signifi-cant impacts to the reservoir from the operation of ANO Unit 1. This data will also aid in the evaluation of trends suggested by the aquatic biological monitoring observations. 3-10
3.3. General Ecological Survey 3.3.1 Plankton Environmental Monitoring Requirement Phytoplankton and zooplankton shall be sampled to detect and assess any significant changes in species composition and abundance as related to the operation of ANO Unit 1. Phytoplankton and zooplankton shall be identified to the lowest taxon practical and numbers reported as organisms / liter as determined by the strip count method. A Wisconsin net will be used to take plankton samples at stations listed in Table 3-1 and shown in Figure 3-1. Action Results of this monitoring program shall be reported in accordance with Subsection 5.6.1. Bases Preoperational monitoring of population density and species diversity has been conducted since 1968', approximately five years prior to operation of ANO Unit 1. These studies shall serve as a baseline for determining any possible change in plankton communities due to the operation of Unit 1. 3-11
3.3.2 Benthic Macroinverterbrates Environmental Monitoring Requirement Benthic macroinvertebrate populations of Dardanelle heservoir shall be monitored in order to detect and assess the significance of possible changes in species composition and abundance as related to the operation of ANO Unit 1. An Ekman dredge shall be used to take duplicate samples of benthos at stations listed in Table 3-1 and shown in Figure 3-1. Macroinvertebrates shall be identified to the lowest taxon practical and numbers reported as organisms /m2, Action Results of this monitoring program shall be reported in accordance with Subsection 5.6.1. Bases Preoperational monitoring population density and species composition has been conducted since 1968, approximately five years prior to the operation of Unit 1. These studies shall serve as a baseline for determining any possible change in benthic communities due to the operation of ANO Unit 1. 3-12
3.3.3 Fishery Survey Environmental Monitoring Requirement Ichthyofauna will be sampled by the various methods listed below to establish a preoperational and opera-tional population trend in Dardanelle Reservior. Sampling frequencies shall be selected to reflect annual trends in the Reservoir. By comparing pre-operational to cperational data, significant impacts attributable to ANO can be detected. Sampling methodologies that will be utilized include:
- 1. Gill and Trammel Net
- 2. Trawling
- 3. Rotonone
- 4. Shoreline Seine Action Monitoring results shall be reported in the annual report required by Specification 5.6.1.
Bases The purpose of this program is to monitor possibl.e influences by Arkansas Nuclear One on the fishes in Dardanelle Reservoir. The programs shall be established to sample the fishes of the Reservoir to detect any significant changes in nunbers, dis-tribution, size, age, growth or physical characteris-tics. Sample stations shall be selected at various 3-13
points in the area around the site and throughout the Reservoir so that a range of plant influence will be determined. This program will also provide far-field data against which data from other monitoring programs can be com-pared. 3-14
3.3.4 Impingement of Fish Environmental Monitoring Requirement Fish shall be collected from the traveling screens and identified using common names. Mesh size of collection devices shall approximate that of the traveling screens. All sampling and analysis shall be perf ormed in accordance with the precedures prepared by the licensee per Section 5.5 of the ETS. For each s ample , the following physical data shall be provided: number of circulating water pumps operating and intake water temperature. S ample s shall be taken twice each week and analysis per-f orme d . Action Monthly results from this monitoring.shall be sub-mitted to the NRC, Division of Operating Reactors. The reports shall contain the following information: the date of the sample, the species collected, the number or estimated number impinged in 24 hours for each species, the modal length (in mm) for each species, the maximum length (in mm) for each species, the modal weigh t (in g) for each species, and required physical, data. A summary of the impingement results shall be included in the report required by specification 5.6.1. 3-15
Organisms collected from the traveling screens shall be disposed of in a manner consistent with require-ments of appropriate federal, state and local regula-tory agencies. Bases The potential impact to impinged fish is injury and eventual mortality. Data collected shall be geared to assess the number, species, and size of fish taken from Dardanelle Reservoir due to impingement. This data and data from studies outlined in Specifi-cation 3.3.3 will be used to provide a basis for evaluating any significant impact to the fish of the Reservoir due to plant operation. 3-16
e .
/
3.3.5 Entrainment of Ichthyoplankton Environmental Monitoring Recuirement Ichtyoplankton (fish larvac) shall be collected during the months of April through September. Specimens collected shall be identified to the lowest practical taxon. (Collections shall be made in accordance with procedures prepared by the licensee per Section 5.5 of the ETS.) On each sampling day, c ollec tions shall be made so as to identify day-night variation in con-centration of organisms. Samples shall be taken in the intake canal by a me tered plankton net. Action Results of this program shall be summarized, analyzed, interpreted, and reported in accordance with Section 5.6.1. The reports shall include the f ollowing information: intake water temperature, dissolved oxygen and pH, sanpling date, time of day, species or tm<on, number collected, and concentration (number /1000 cubic me ters) . Bases The potential impact to fish larvae due to entrain-ment is mortality. If the numbers are large, depres-sion of populations could result. As the fish larvae
. pass through the plant, death is caused by such 3-17
e
' a factors as temperature increases, chemicals, and mechanical and physical trauma. Data collected shall be geared to assess the number, species, and life stage of the fish larvae taken from Dardanelle Reservoir due to entrainment. This data will be used to access and evaluate any significant impact to the fish of the Reservoir due to plant operation.
the penultimate impact would be the depletion of a species. 3-18
e . TABLE 3-1 AQUATIC SAMPLING LOCATION AND FREQUENCIES SAMPLE TYPE SAMPLE FREQUENCY SAMPLE STATION # Plankton Quarterly - January, April 1, 3, 5, 10, 11, July, October 14, 15, 16, 21 Benthic Organism 7 Quarterly - January, April 1, 3, 5, 10, 11, July, October 14, 15, 16, 21 Gill Ne t Survey 2 sets of 2 net-nights in Areas A, B, C, D each area within 30 days each quarter Trawling Survey Two samples in each area Areas, A, B, C, D every other week March, April, May, June Cove Rotenone Survey Sep tember Areas A, C Shoreline Seing Two samples in each area Areas A, C Survey every other week March, April, May, June Chemical Mon thly 1, 3, 5, 7, 8, 10, 11, 13,14, 15, 16, 17, 21 Physical Monthly 1, 3, 5, 7, 8, 10, 11, 13, 14, 15, 16, 17, 21 3-19
- TABLE 3-2
- . PHYSICAL WATER QUALITY PARAMETERS
- 1. Temperature ( C) - Yellow Springs Instr. Model 54
- 2. Turbidity (JTU) - APHA Standard Method 214, 14 Edition
- 3. Filtrable Residue (Total Dissolved Solids - mg/L) - APHA Standard Method 208C, 14th Edition.
- 4. Non Filtrable Residue (Total Suspended Solids - mg/L)
APHA Standard Method 208D, 14 Edition.
- 5. Depth (Feet) 3-20
9
- 4 TABLE 3-3 CHEMICAL WATER QUALITY PARAMETERS
- 1. Dissolved Oxygen - Yellow Springs Instr. Mod't 54,
- 2. pH - Taylor Color Comparator.
- 3. Iron - APHA Standard Method 310A, 14th Edition.
- 4. Filterable Iron - APRA Standard Method 310A, 14th Edition.
- 5. Manganese - Hach Colorimeter Model DR, Cold Periodate Method.
- 6. Chemical Oxygen Demand - APRA Standard Method 508, 14th Edition.
- 7. Total Hardness - APRA Standard Method 309B, 14th Edition.
- 8. Boron - APHA Standard Method 405A, 14th Edition.
- 9. Sulfate - APHA Standard Method 427C, 14th Edition.
- 10. Chloride - Orion specific ion electrode.
- 11. Total Kjeldahl Nitrogen - APHA Standard Method 421, 14th Edition.
- 12. Nitrite Nitrogen - APHA Standard Method 420, 14th Edition.
Chemical Tests 9-12 shall be performed only on samples from Stations 1, 5, 16, and 21. 3-21
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4.0 SPECIAL STUDIES Deleted - all special studies have been completed. 4-1
4' ENCLOSURE 4 JUSTIFICATION FOR CHANGES TO THE ENVIRONMENTAL TECHNICAL SPECIFICATIONS
Enclosure 4 4' D
. , The present environmental technical specifications (ETS) are hard to follow and are very procedure oriented. Removing the radiological portions of the ETS (as requested in Mr. Grimes' July 11, 1978 letter) is compounding the confusion. We are therefore taking this opporcunity to remove much of the procedure related material from the specifications, to simplify the specifications, and to make the specification format similar to that of ANO-2 ETS. We believe that deleting all of the specifications that are presently in sections 1, 2, 3, 4, and 6 of the ETS and replacing them with the new sections will be much clearer than proposing to delete specific specifications and rewording of other specifications.
Section 1*: Definitions We have deleted all definitions that no longer apply to any of the ETS. Section 2: Limiting Conditions for Operations At our May 25, 1978, meeting with the staff concerning the environmental technical specifications (ETS) for ANO-2, the staff expressed a change in their philosophy regarding the ETS. We were told that the NRC was moving away from setting " Limiting Conditions for Operation" (LCO) on plants in the non-radiological area and was replacing the LCO's with surveillance requirements. The non-radiological limits for items such as; maximim discharge temperature, pH of releases, temperature rise across the condenser, etc. would be controlled by the other various permitting agencies. Based on the above we have converted the present LCOs into the proposed surveillance requirements in section 3.1. Section 3: Design Features and Operating Practice The specifications in this section are redundant to other specifications. The present specifications will be accounted for in the new specifications as iisted below: present specification proposed specification 3.1 3.3.4 3.2 none 3.3 3.1.4 3.4 3.1.3 3.5 None**
- Refers to existing section titles.
** This requirement will not be specifically addressed elsewhere in the ANO-1 ETS, however, it is specification 5.9 of the ANO-2 ETS.
Section 4: Environmental Surveillance The basic nonradiological environmental surveillance program at ANO C ..will remain the same as it is at present. We request deletion of the Trap Net samples and the Fish cage survey that are presently contained within the Fishery Survey. The fish cage survey was actually a caged mussel survey. The mussels were used in the radiological environmental monitoring program. The standardized radiological technical specifi-cations do not require this program. We request deletion of the trap net samples because the fish caught by the trap nets are well represented in the gill net and trammel net samples. The amount of fish caught by the trap net survey does not justify the efforts expanded to catch the fish. The total catch in 1977 was 454 fish, 17 species for the trap net vs. 3716 fish and 27 species for the gill net. We request that fish impingement samples be taken twice a week all year long instead of three times-a-week during the winter and twice-a-week at other times. The three times-a-week study was initiated to develop the characteristic threadfin shad impingement during the winter months. We have gathered the data and have a firm understanding of the character-ination of the threadfin shad impingement. The estimates of the number of fish impinged by twice-a-week samples is not statistically different from the three times-a-week samples. Section 6: Special Surveillance, Research, or Special Activities All of the studies required in this section have been completed, therefore, we request that they be deleted from the specifications.}}