ML20023A493

Radiological Effluent Tech Spec Implementation (A-2), Millstone Nuclear Power Station Unit 2, Technical Evaluation Rept

ML20023A493
Person / Time
Site:	Millstone
Issue date:	09/17/1982
From:	Carfagno P, Fernandez C, Pandey S FRANKLIN INSTITUTE
To:	NRC
Shared Package
ML20023A495	List: ML20023A493
References
CON-NRC-03-81-130, CON-NRC-3-81-130 TAC-49588, TER-C5506-99, NUDOCS 8209210332
Download: ML20023A493 (26)

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TECHNICAL EVALUATION REPORT 1 RADIOLOGICAL ~ EFFLUENT TECHNICAL.

SPECIFICATION IMPLEMENTATION (A-2)

NORTHEAST NUCLEAR ENERGY COMPANY .

MILLSTONE POINT NUCLEAR POWER STATION UNIT 2 NRC DOCKET NO. 50-336 FRC PROJECT C5506 NRC TAC NO. 8116 FRC ASSIGNMENT 4 NRC CONTRACT NO. NRC-03-81-130 FRC TASK 99 Preparedby Author: C. Fernandez Franklin Research Center 20th and Race Street FRC Group Leader: S. Pandey Philadelphia, PA 19103 Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NGC Engineer: F. Congel C.. Wil( . 3 September 17, 1982 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.

Prepared by: Reviewed by: Approved by:

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TER-C550 6-99 CONTENTS Section Title Page 1 INTRODUCTION . . . . . . . . . . . . . 1 1.1 Purpose of Review . . . . . . . . . . . 1 1.2 Generic Issue Background . . . . . . . . . 1 1.3 Plant-Specific Background . . . . . . . . . 2 2 REVIEW CRITERIA. . . . . . . . . . . . . 4 3 TECHNICAL EVALUATION .. . . . . . . . . . . 6 3.1 General Description of Radiological Effluent System . . 6 3.2 Radiological Effluent Technical Specifications. . . . 8 3.3 Offsite Dose Calculation Manual . . . . . . . 14 4 CONCLUSIONS. . . . . . . . . . . . . . 18 5 REFERENCES . . . . . . . . . . . . . . 20 nklin Research Center A DMason of N Fe h

TER-C5506-99 FIGURES Number Title Page 1 Liquid Effluent Release Paths, Millstone Chit 2. . . . . 7 2 Gaseous Effluent Release, Paths, Millstone Unit 2 . . . . 9 TABLE humber Title Page 1 Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Millstone Unit 2 . . . . 19 i

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TER-C5506-99 FORl!NORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NBC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.

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

The evaluation used criteria proposed by the NBC staff in the model h chnical Specifications for pressurized water reactors (PNRs) , NUREG-0472 [1] .

This effort is directed toward the NBC objective of implementing RETS which comply with the regulatory requirements, including those of 10CFR50, Appendix I [2].

1.2 GENERIC ISSUE BACKGROUND Since 1970,10CFR50.36a has required licensees to provide Technical Specifications which ensure that radioactive releases will be kept as low as reasonably achievable (ALARA). In 1975, numerical guidince for the ALARA requirement was issued in 10CFR50, Appendix I. The licensees of all operating l reactors were required to submit, no later than June 4,1976 [3], their proposed ALARA Technical Specifications and information for evaluation in accordance with 10CFR50, Appendix I.

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

The model RETS deals with radioactive waste management systems and environmental monitoring. Although the model RETS closely parallels 10CFR50, Appendix I requirements, it includes provisions for addressing some waste management system problema not addressed in Appendix I.

The current NBC position on the model RETS was established in May 1978 when the NRC Regulatory Requirements Review Committee appro'ved the model RETS (NUREG-0472 [1] for PWRs and NUREG-0473 [4] for boiling water reactors (BWRs)).

Copies were sent to licensees in July 1978 with a request to submit proposed l

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TER-C5506-99 site-specific RETS on a staggered schedule over a 6-month period. Licensees responded with requests for clarifications and extensions.

The Atomic Industrial Forum (AIF) formed a task force to comment on the model RETS. NRC staff members first met with the AIF task force on June 17, 1978. The model RETS was subsequently revised to reflect comments from the AIF and others. A principal change was the transfer of the parameters and methodology used in dose calculations from the model RETS to a separate document, the ODCM.

The revised model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133) [5] for preparation of the RETS and the ODCM and a new schedule for responses, again staggered over a 6-month period.

Regional seminars on the RETS were conducted by the NBC staff during November and December 1978. Subsequently, Revision 2 of the model RETS, additional guidance on the ODCM, and a Process Control Program (PCP) were issued in February 1979, to each utility at individual meetings.

1.3 PLANT-SPECIFIC BACKGROUND In conformance with the requirements of Section V.B of 10CFR50, Appendix I, the Northeast Nuclear Energy Company (NNECO) filed two documents with the NBC: (1) " Demonstration of Compliance with 10 CFR Part 50, Appendix I, Part 1, Volume 1, Millstone Units 1 and 2" [6] , and (2) " Demonstration of Compliance with 10 CFR Part 50, Appendix I, Part 2B, Millstone Unit 2" [7].

These submittals provided the necessary information to permit evaluation of Millstone Unit 2 in accordance with the requirements of Sections II.A, II.B, and II.C of Appendix I.

NNECO submitted proposed changes to the Technical Specifications for Millstone Unit 2 [8-12] . The proposed changes in the September 19, 1979 submittal [8] followed the format of NUREG-0472 for PWRs. On October 1, 1981,  ;

Franklin Research Center (FRC), selected as an independent task review team, initiated a review and evaluation of the September 19, 1979 submittal comparing it with the model RETS (NUREG-0472) . Additional guidance was provided by clarification letters and branch positions [13-18) .

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TER-C550 6-9 9 Subsequent to the initial review by FRC, draft review reports were prepared and delivered to the NRC.

Discussions with the Licensee at a site visit by the FRC review team on {

November 11, 1981 and subsequent correspondence resolved most of the deviations found in the RETS and ODCM submittals.

On August 12, 1982 and August 20, 1982, the Licensee resubmitted to the NRC a revised proposed RETS [19] and ODCM [20] incorporating FRC comments and agreements. These submittals are the subject of review and evaluation in this report.

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2. REVIEN CRITERIA l

Review criteria for the RETS were provided by the NBC in three documents:

NUREG-0472, RETS for Pressurized Water Reactors [1]

NUREG-0473, RETS for Boiling Water Reactors [4]

NUREG-0133, Preparation of RETS for Itaclear Power Plants [5] .

1 Twelve essential criteria are given for the RETS and ODCM

l. All significant releases of radioactivity shall be controlled and monitored.

2. Offsite concentrations of radioactivity shall not exceed the 10CFR20, Table 2 limits.

3. Offaite radiation doses shall be ALARA.

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'4. Equipment shall be maintained and used to keep offsite doses ALARA.

5. Radwaste tanks inventories shall be limited so that failures would not cause offsite doses exceeding 10CFR20 limits.

6. Waste gas concentrations shall be controlled to prevent explosive mixtures. ,

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

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

9. '1he radwaste management program shall be subject to regular audits and reviews.

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

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

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

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s TER-C5506-99 subs'equent to NUREG-0472' and NUREG-0473, the SRC staff instied c!,arifica-tions and branch haitions [13-18] estab ishing a polfcy that requires'che ,

licensees of operating reactors to meet the intent, if not the letter, of the model;RETS requirements. The NBC branch potitions issued,.7 nce i the RETS implementation review began have changed the model RETS, requirements applicable

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to cperating reactors. These changes have been incorporated in all reviews.

. Review of the ODCM was Ddsed on the gui<eline provided by the MRC staff in a branch position, " General Content of thi Offsite Dose Calculation Manual"

[21]. The format for the ObCM is lef t to the licensee and may be simplified by tables and grid printouts.

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3. TECHNICAL EVALUATION d

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3.1 ' GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEM This section briefly describes the radwaste liquid and gaseous effluent treatment and control systems installed at Millstone Nuclear Power Station Unit 2.

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The liquid radioactive waste system has the capability to collect, treat, store, and dispose of all radioactive liquid wastes. Liquid wastes are collected in sumps and drain tanks in the various buildings, then transferred to the appropriate tanks in the radwaste building for further treatment, temporary storage, and disposal. Final discharge of processed liquid wastes involves return to the chemical and volume control system or disposal at the discharge structure. Batches with a low radioactivity concentration are discharged through a distribution pipe and diluted in the quarry prior to release into the ocean.

A diagram of the liquid radwaste system showing the location of the

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liquid effluent monitors is shown in Figure 1. The processed liquid radwaste originating 'from the primary and equipment drain tanks is monitored by the clean liquid radwaste effluent line monitor. The steam generator blowdown and condensate polishing waste effluents are monitored by the steam generator blowdown monitor and the condensate polishing facility waste neutralizing sump discharge line monitor, respectively. The processed liquid waste that originates at the aerated waste drain tank is monitored by the aerated liquid radwaste effluent line monitor. These monitors are all provided with automatic termination of release upon a high-concentration alarm signal.

3.1.2 Gaseous Effluents Airborne particulates and gases vented from process equipment and build-ing ventilation exhaust air are the normal sources of radioactive gaseous effluents from the plant. The major source is the waste gas processing system which contains six decay tanks and a HEPA filtsr to ensure that releases are l

ALARA.

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4 TER-C5506-99 Prknary Draine Q RM Doomsmer - Denmereuzer - Evaporneor N *** l eququnene ormene e  %

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Figure 1. Liquid Effluent Release Paths, Millstone Unit 2 4 UhhU Franklin Research Center A DMoon of The Franen insam,ne

TER-C5506-99 A diagram showing the location of radioactive gaseous effluent monitors is shown in Figure 2. Wastes originating from the following sources are discharged throagh the Unit 1 stack and monitored by the Unit 1 main stack monitor main condenser / air ejector, containment purge, and waste gas processing system. The waste gas processing system is equipped with a process noble gas radiation monitor and an oxygen monitor to detect the presence of an explosive gas nixture. The turbine building ventilation exhaust and the steam generator blowdown tank vent are normally released without monitoring. Figure 2 also shows the location of HEPA filter and charcoal adsorber units.

3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)

The evaluation of the Licensee's proposed specifications to meet the requirements of 10CFR50, Appendix I'was based on the followings (1) a review of information provided in the Licensee's September 19, 1979 submittal [8],

(2) a site visit on November 12-13,1981, and (3) a review of the Licensee's August 12, 1982 RETS submittal [19] and August 20, 1982 ODCM submittal [20].

A detailed review and evaluation of the Licensee's submittal (19] are contained in the supplementary technical review report [22]. A summary of the findings follows.

I 3.~2.1 Effluent Instrumentation 3.2.1.1 Radioactive Liquid Effluent Monitoring Instrumentation In Section 3/4.3.3.9 of the Licensee's submittal, a commitment is made to monitor and control all significant liquid effluent release paths. The follow-ing monitors are provided: clean liquid radwaste effluent line monitor, l aerated liquid radwaste effluent line monitor, stear. ;enerator blo'down w monitor, and condensate polishing facility waste neutralizing sump discharge line monitor. These monitors have appropriate alarm / trip setpoints and are j demonstrated to be operable by performance of surveillance operations consistent with the model RETS [1] . Flow rate measurements are provided for

, the effluent lines in order to determine total radioactivity released through each liquid pathway. The steam generator blowdown line and the turbine 1 Ax 1 000branklin Research Center l A Dmeson of The Frenten hemme

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Unit 1 Salt O RM westeGao e Decay HEPA I 4 ""

Processeng i Tante Main Condenser /

Air Eiector Conenmment Purge l HEPA Charcoal HEPA I

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l HEPA Auxdiary Building i Root Vent Turonne Budding i Root Vent Steem Generator i '

Slowdown AM = Radiation Monitor Figure 2. Gaseous Effluent Release Paths, Millstone Unit 2 4

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TER-C5506-99 building sump effluent line are adequately sampled, but continuous composite samplers are not provided. There are no liquid radwaste holdup tanks outside plant buildings that require tank level indicating devices. Figure 1 shows the location of the liquid effluent radiation monitors.

3.2.1.2 Radioactive Gaseous Effluent Monitoring Instrumentation In Section 3/4.3.3.10 of the Licensee's submittal, a commitment is made to monitor and control all significant gaseous effluent release paths. The following monitors are provided for this purpose: MP2 stack monitor, MP1 main stack monitor, and the waste gas holdup system noble gas monitor. These monitors are demonstrated to be operable by performance of surveillance operations consistent with the model RETS [1] . Figure 2 shows the location of the gaseous c? fluent radiation monitors and the substreams monitored by each.

3.2.2 Radicactive Effluent Concentrations 3.2.2.1 Liquid Ef fluent Concentration ,

In Section 3/4.11.1.1 of the Licensee's submittal, a commitment is made to maintain .the concentration of radioactive liquid effluents released frem the site to within established limits at all times. All batches of j radioactive liquid effluents and continuous releases from steam generator blowdown and service water effluents are sampled periodically in accordance with a sampling and analysis program which meets the intent of the model RETS l

[1]. Automatic termination of excessively radioactive liquid effluent streams is provided.

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3.2.2.2 Gaseous Effluent Dose Rate i

In Section 3/4.11.2.1 of the Licensee's submittal, a commitment is made to maintain the offsite dose rate from radioactive gaseous effluenta to within l the established limits at all times. The offsite dose rate limits used are:

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a. 500 mres/yr (total body) and 300 mrem /yr (skin) for noble gase.m l

b. 1500 mrem /yr (any organ) for inhalation of iodine-131, iodine-133, j and particulates with half-lives greater than 8 days, l

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TER-C550 6-99 The Licensee.also provides a radioactive gaseous waste sampling and analysis program which meets the intent of the model RETS [1] .

3.2.3 offsite Doses from Radioactive Effluents In Sections 3/4.11.1.2, 3/4.11.2.2, 3/4.11.2.3, and 3/4.11.4 of the Licensee's submittal. a commitment is made to implement the requirements of Sections IIA, IIB,.and IIC of 10CFR50, Appendix I and the requirements of 40CFR190, respectively. The Licensee has committed to perform the dose calculations following ODCM guidelines. The dose calculations are performed in accordance with Regulatory Guides 1.109 and 1.113.

3.2.4 Ef fluent Treatment Systems 3.2.4.1 Liquid Radwaste Treatment System In Section 3/4.11.1.3 of the Licensee's submittal, a commitment is made to have the degasifier, clean liquid primary domineralizer, boric acid evaporator, clean liquid secondary domineralizer,'and the aerated waste domineralizer operable and'used prior to discharge of liquid waste when projected doses are exceeded. The appropriate liquid radwaste subsystems are demonstrated operable and projected doses are performed once per 31 days as I

required in the model RETS [1] .

3.2.4.2 Gaseous Radwaste Treatment System In Section 3/4.11.2.4 of the Licensee's submittal, a commitment is made to have the following subsystems operable: two or more waste gas decay tanks, the waste gas filter, one waste gas compressor, the auxiliary building ventilation HEPA filter, and the containmer t purge HEPA filter. These components are used.to reduce radioactive gaseous effluents when projected doses are exceeded. The appropriate gaseous radwaste treatment system components and/or ventilation exhaust treatment system components are demonstrated operable and projected doses are performed once per 31 days as required in the model RETS [1] .

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TER-C5506-99 3.2.5 Tank Inventory Limits In Section 3/4.11.2.6 of the Licensee's submittal, a commitment is made to limit the radioactive gas inventory in each gas storage tank to 9.92 x 4

10 curies of noble gases. This curie limit ensures that a tank failure does not result in an offsite dose which exceeds the limits in 10CFR20 for  ;

non-occupational exposures. The Licensee has committed to a sampling program j of the waste gas tanks to monitor the activity content of the tanks. The Licensee does not have any outside liquid holdup tanks and thus has not addressed this section of the model RETS [1].

3.2.6 Explosive Gas Mixtures Proposed Specification 3/4.11.2.5 and portions of other specifications relating to the waste gas holdup system oxygen monitor have been deleted from

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the August 12, 1982 submittal. The current instrumentation does not meet the intent of the model RETS requirements. It is the Licensee's understanding that the NRC staff is currently evaluating the requirements for waste gas holdup system explosive gas mixture monitoring. The, Licensee intends to include an appropriate technical specification change upon resolution of the monitoring requirements.

3.2.7 Solid Radioactive Waste In Section 3/4.11.3 of the Licensee's submittal, a commitment is made to solidify radioactive waste in accordance with a process control program (PCP) and to have a solid radwaste system to ensure meeting the shipping requirements for radioactive waste. The solid radwaste system is demonstrated operable and the solidification of at least one representative sample from every ten batches will be verified in accordance with the PCP. The PCP ensures that radwaste will'be properly processed and packaged before it is shipped to the burial site.

3.2.8 Radiological Environmental Monitoring Program In Section 3/4.12.1 of the Licensee's submittal, a commitment is made to have an environmental monitoring program which closely follows the requirements 4 MJ Franklin Research Center A mmon w n= r wm w.u. .

TER-C5506-9 9 given in Branch Technical Position, Rev. 1, entitled "An Acceptable Radiological Environmental Monitoring Program." The sample locations are indicated in the ODCM as required. A land use census is conducted which identifies the location of the milk animals in each of the 16 meteorological sectors within a distance of 5 miles. The Licensee participates in an interlaboratory comparison program approved by the NRC and reports the results in the Annual Radiological Environmental Operating Report.

3.2.9 Audits and Reviews In Section 6.5.4.8 of the Licensee's submittal, a commitment is made to perform periodic audits of the ODCM, PCP, radiological environmental monitoring program, and radioactive effluent release and monitoring procedures. The audits are performed by the Site Nuclear Review Board. Changes to the radiological environmental monitoring program, PCP, and ODCM are reviewed by the Plant Operating Review Committee / Site Operating Review Committee.

The audits and reviews in the Licensee's submittal meet the intent of the model RETS [1] . .

i 3.2.10 Procedures

! In Section 6.8 of the Licensee's submittal, a commitment is made to establish, implement, and maintain written procedures for the quality controls for effluent monitoring, ODCM, and PCP consistent with the requirements of the model RETS [1]. .

3.2.11 Reports 3.2.11.1 Routine Reports In Section 6.9.1.10 of the Licensee's submittal, a commitment is made to provide an annual radiological environmental monitoring report that includes summaries, interpretations, and statistical evaluation of the results of the environmental surveillance program.

In Section 6.9.1.11 of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent release reports which include a

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TER-C5506-99 summary of radioactive liquid and gaseous effluents released, meteorological data, an assessment of offsite doses, a summary of radioactive solid vsste shipped offsite,'and information concerning all unplanned releases of radioactivity from the site. Any changes to the ODCM are also included in the report. The results of the land use census required by Specification 3/4.12.2 are addressed in ths ODCM.

3.2.11.2 Non-Houtine Reports In Section 6.9.1.9 of the Licensee's submittal, a commitment is made to provide a 30-day written report for an unplanned off-site release of (1) more than 1 curie of radioactive material in liquid effluents, (2) more than 150 curies of noble gas in gaseous effluent, or (3) more than 0.05 curies of radioiodine in gaseous effluent.

In Section 6.9.2 of the Licensee's submittal, a commitment is made to provide a special report for exceeding specification limits in Sections 3.11.1, 3.11.2, 3.ll.3,' and 3.11.4. A special report is provided for exceeding Section 3.11.1.2. (liquid effluent dose limits) , Sections 3.11.2.2 and 3.11.2.3 (gaseous effluent dose limits) , and Section 3.11.4 (total dose limit.s) . A special report is provided for the extended inoperability of liquid and gaseous radwaste treatment systems and the solid radwaste system.

A special report is also required for measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting level of Table 6.9-1.

3.3 OFFSITE DOSE CALCULATION MANUAL (ODCM)

A brief discussion of the methodology and approach used by the Licensee to calculate offsite dose and to maintain the operability of the effluent treatment system is'provided in this section. The methodology used by the Licensee is evaluated for consistency with the methodology and guidelines set by the NRC staff. As a minimum, it is required tnat the ODCM provide equations and methodology for the following topics:

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o alarm and trip setpoint on effluent instrumentation o liquid effluent concentration in unrestricted areas o gaseous effluent dose rate at or beyond the site boundary I o liquid and gaseous effluent dose contributions o liquid and gaseous effluent dose projections.

In addition, flow diagrams defining the treatment paths and the components of the radioactive solid, liquid, and gaseous radwaste management systems are required. The description and location of environmental samples in support of the radiological environmental monitoring program are also required.

3.3.1 Evaluation The Licensee has provided an ODCM which includes the parameters and methodology to be used in calculating offsite doses and effluent monitor setpoints for Millstone Units 1 and 2. The ODCM follows the methodology of NUREG-0133 and includes sections on:

o Liquid dose calculations - Maximum individual whole body and organ doses for quarterly and annual limits, monthly dose projections for the Units 1 and 2 liquid radwaste treatment systems, and the quarterly dose calculations for the semiannual radioactive effluent report o Gaseous dose calculations - Instantaneous-release rate limits for noble gases and for iodine-131 and particulates with half-lives greater than 8 days, nobic gas whole body gamma and beta air doses for quarterly and annual limits, iodine and particulate maximum organ doses for quarterly and annual limits, monthly projection doses for the gaseous radwaste treatment system, and total dose from the site calculation for compliance with 40CFR190 o Liquid monitor setpoints for ~all effluent monitors included in the Technical Specifications. The following monitors are included:

liquid radwaste effluent line monitor and service water effluent line monitor (Unit 1); clean liquid radwaste effluent line monitor, aerated liquid radwaste effluent line monitor, steam generator blowdown monitor, condenser air ejector monitor, and condensate polishing facility waste neutralizing sump monitor (Unit 2) o Gaseous monitor setpoints for all effluent monitors included in the Technical Specifications. The following monitors are included:

hydrogen monitor, steam jet air ejector offgas monitor, main stack noble gas monitor, and main stack sampler flow rate monitor (Unit 1);

and stack noble gas monitor and waste gas decay tank monitor (Unit 2)

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l TER-C5506-99 o Radiological environmental monitoring program sample locations o Simplified flow diagrams for the liquid and gaseous radwaste treatment systems for Units 1 and 2 o The bases for some of the factors used in the ODCM (included as appendices) .

Most calculations in the ODCM give two or three methods for calculation of the same parameter. These methods are arranged in order of simplicity and conservatism, Method 1 being the easiest and the most conservative. As long as releases are low, Method 1 is used as a simple estimate of the doses. If release calculations approach the Technical Specification limits, less conser-

! vative, more detailed calculations are used.

Setpoint calculations are performed using a safety factor ranging from 2 to

10. Where simultanemas releases are possible, the setpoints include provisions for limiting the total release to within the Technical Specification limits.

Liquid dose calculations are performed using the NBC-approved LADTAP computer code; all significant input parameters are specified in the ODCM.

The projected liquid dose calculations incorporate the use of estimate ratios for waste volume and activity levels.

Gaseous dose calculations are performed using the Environmental Protection Agency AIREM computer code and the NRC GASPAR computer code. The AIREM code is used for calculating the maximum individual whole body dose due to the plume from the 375-ft Unit 1 stack. All other doses are calculated using the GASPAR code, including the maximum individual whole body dose due to releases from l

l the Unit 2 enclosure building roof vent and, for Units 1 and 2, the maximum individual organ. doses due to releases of radioiodine and particulates for the food, inhalation, and milk pathways. The AIREM code is used for the noble gas Unit 1 stack releases since the GASPAR code was found to grossly underestimate the maximum individual dose due to the overhead gamma cloud. The AIREM code uses a finite cloud model similar to that in Regulatory Guide 1.109 as opposed to the semi-infinite cloud model used in the GASPAR code. The meteorological dispersion parameters (X/Qs and D/Qs) are the maximum quarterly average values for the years 1976 to 1978.

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TER-C5506-99 The simplified flow diagrams of the liquid and gaseous radwaste treatment systems adequately describe the major components of the systems, the signifi-cant release paths, and the location of the radiation monitors included in the Technical Specifications.

A table and figures showing the locations of the radiological environmental monitoring program samples are given in Section G of the ODCM. However, the Licensee has not provided sample locations for 22 accident TLDs as specified in the radiol.ogical environmental monitoring program.

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4. CONCLUSIONS Table 1 summarizes the results of the final review and evaluation of the Millstone Nuclear Power Station Unit 2 proposed Radiological Effluent Technical' Specifications (RETS). The following conclusions have been reached:

1. The Licensee's proposed RETS meet the intent of the model Technical Specifications, NUREG-0472, with the exception that the Licensee has deleted the technical specifications relating to the waste gas holdup system explosive gas mixture monitoring. The Licensee stated that an appropriate technical specification change will be requested upon resolution of the monitoring requirements by the NBC staff.

2. The Licensee's Offsite Dose Calculation Manual uses documented and approved methods that are consistent with the methodology in NUREG-0133.

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E5E$ Table 1. Evaluation of Proposed Radiological Ef fluent Specifications (RETS), Millstone unit 2 a

j[ Technical Specifications g Ei NRC Staff Model Replaces or Updates pju RETS NUREG-0473 Licensee Proposal Existing Tech. Spec.

yg RETS Requirement . (Section) (Section) (Section) Evaluation

}n Ef fluent Instrumentation 5h 5

3/4.3.3.9, 3/4.3.3.10 3/4.3.3.9, 3/4.3.3.10 2.4.1, 2.4.2 (Appendix B) Meets the intent g f3 . of NRC criteria 5S .

{ Radioactive Effluents 3/4.11.1.1, 3/4.11.2.1 3/4.11.1.1, 3/4.11.2.1, 2.4.1, 2.4.2 (Appendix 8) Meets the intent of NRC criteria Offsite Doses 3/4.11.1.2, 3/4.11.2.2, 3/4.11.1.2, 3/4.11.2.2, 2.4.1, 2.4.2 (Appendix 8) Meets the intent 3/4.11.2.3, 3/4.11.4 3/4.11.2.3, 3/4.11.4 of NRC criteria Effluent Treatment 3/4.11.1.3, 3/4.11.2.4 3/4.11.1.3, 3/4.11.2.4 2.4.1, 2.4.2 (Appendix B) Meets.the intent of MRC criteria

[. Tank Inventory Limits 3/4.11.1.4, 3/4.11.2.6 3/4.11.2.6 2.4.2 (Appendix B) Meets the intent

, j) of NRC criteria Explosive Gas Mixtures 3/4.11.2.5 Not Provided Hot Addressed Meets the intent of HRC criteria in the interim .

Solid Radioactive Waste 3/4.11.3 3/4.11.3' 2.4.3 (Appendix B) Meets the intent of HRC criteria Environmental Monitoring 3/4.12.1 3/4.12.1 3.2 (Appendix B) Meets the intent of NRC criteria Audit and Review 6.5.1, 6.5.2 6.5.4.7, 6.5.4.8 6.5.4.7, 6.5.4.8 Meets the intent of NRC criteria Procedures 6.8 6.8 6.8 Meets the intent of MRC criterie P3 Reports 6.9.1.6 - 6.9.1.9 6.9.1.9 - 6.9.1.11 6.9.1.8, 6.9.1.9 Meets the intent 6.9.1.12, 6.9.1.13 6.9.2 6.9.2, 5.6.1 ( Appendix B) of HRC criteria 6.9.2 gn O

0%

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. 1 TER-C5506-99 j

5. REFERENCES

1. Radiological Effluent Technical Specifications for Pressurized Water Reactors, Rev. 2 NBC, February 1980 NUREG-0472 i

2. Title 10 Code of Federal Regulations, Part 50, Appendix I, F*deral Register, Vol. 40, page 19442, May 5,1975

3. Title 10 Code of Federal Regulations, Part 50, Appendix I, Section VB, " Effective Date," for submittal of Thchnical Specifications

4. Radiological Effluent Technical Specifications for Boiling Water Reactors, Rev. 2 NBC, February 1980 NUREG-0473

5. Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications NRC, October 1978 NUREG-0133

6. Mtter of- Transmittal to NRC from NNEW

Subject:

Demonstration of Compliance with 10 CFR Part 50, Appendix I, Part 1, Volume 1, Millstone Units 1 and 2 June 4,1976

7. M tter of Transmittal to NBC from NNECD

Subject:

Demonstration of Compliance with 10 CFR Part 50, Appendix I, Part 2B, Volume 1, Millstone Unit 2 November 15, 1976

8. W. G. Couns'il (NNECO) h tter to D. L. Ziemann and R. Reid (NRC)

September 19, 1979

9. W. G. Counsil (NNECO)

Letter to D. L. Ziemann and R. Reid (NRC)

February 13, 1979

10. W. G. Counsil (NNECO)

Mtter to D. L. Ziemann and R. Reid (NRC)

March 13, 1979

11. W. G. Counsil (NNECO)

Letter to R. Reid (NRC)

May 21, 1979 A 00branklin,_Research . ._.

Center

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TER-C550 6-9 9

12. W. G. Counsil (NNECO)

Letter to D. L. Ziemann and R. Reid (NBC)

June 29, 1979

13. W. P. Gamaill (NRC)

Memo to P. C. Wagner (NRC)

Subject:

Current Position on Radiological Effluent Technical Specifications (RETS) including Explosive Gas Controls October 7,1981

14. "An Acceptable Radiological Environmental Monitoring Program" Branch Technical Position November 1979

15. C. Willis (NRC)

Memo to P. C. Wagner (NBC)

Subject:

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

16. C. Willis (NRC)

Letter to Dr. S. Pandey (FRC)

Subject:

Changes to RETS Requirements following AIF meeting November 20, 1981

17. C. Willis (NBC)

Letter to Dr. S..Pandey (FRC)

Subject:

Control of Explosive Gas Mixture in PWRs December 18, 1981

18. C. Willis and F. Congel (NBC)

" Status of NRC Radiological Effluent Technical Specification

, Activities" l

Presented at the Atomic Industrial Forum Conference on NEPA and Nuclear Regulations, October 4-7 1981, Washington, D.C.

19. W. G. Counsil (NNECO)

Letter to R. A. Clark and D. M. Crutchfield (NRC)

August 12, 1982 20.

W. G. Counsil (NNECO)

Letter to R. A. Clark and D. M. Crutchfield (NRC)

August 20, 1982

21. " General Contents of the Offsite Dose Calculation Manual" Branch Technical Position, Radiological Assessment Branch Revision 1, February 8,1979

22. Radiological Effluent Technical Specification Implementation, Comparison of Plant and Model Radiological Effluent Technical Specifications, Northeast Utilities, Millstone Nuclear Power Plant Unit No. 2, September 17, 1982 A -s b0 Fgigghgter

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