ML20053A062
| ML20053A062 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/31/1982 |
| From: | NORTHEAST UTILITIES |
| To: | |
| Shared Package | |
| ML20053A059 | List: |
| References | |
| TAC-48383, NUDOCS 8205240504 | |
| Download: ML20053A062 (10) | |
Text
Docket Nos. 50-245 50-336 Millstone Nuclear Power Station, Unit Nos. 1 and 2 Proposed Revisions to Environmental Technical Specifications Liquid Waste Effluents May, 1982 8205240504 820514 PDR ADOCK 05000245 P
2.4 Radioactive Effluents 2.4.1 Liquid Waste Effluents 2.4.1.1 Objective To define the limits of conditions for the controlled release 4
of radioactive materials in liquid effluents to the environs to ensure that these releases are as low as practicable.
2.4.1.2 Specification A.
The concentration of radioactive materials released in liquid waste effluents from all reactors at the site shall not exceed the values specified in 10 CFR Part 20, Appendix B, Table II, Column 2, for unrestricted areas.
If this limit cannot be met, radioactive effluents shall not be released.
B.
The equipment installed in a particular liquid radio-active waste stream shall be maintained and shall be operated to process radioactive liquid wastes prior to their discharge when the projected quarterly in-dividual dose due to liquid effluent releases from that particular waste stream would exceed 0.1 MREM to the whole body or 0.3 MREM to any organ.
C.
If the quarterly dose to an individual from a unit's liquid effluents exceeds 1.0 MREM to the whole body or 3.0 MREM to any organ, the licensee shall make an investigation to identify the causes of such releases, define and initiate a program of action to reduce such releases to design objective levels and report these actions to the Commission within 30 days from the end of the quarter during which the release occurred.
l D.
The dose to an individual from a unit's liquid effluents shall not exceed 1.5 MREM to the whole body or 5 MREM to any organ during a calendar quarter.
l E.
The dose to an individual from a unit's liquid effluent shall not exceed 3.0 MREM to the whole body or 10 MREM to any organ in any 12 consecutive months.
F.
Except as specified in 2.4.1.3.C, during release of l
radioactive wastes, the effluent control radiation monitor shall be set to alarm and to initiate the automatic closure of each vaste isolation valve prior to exceeding the limits specified in 2.4.1.2.A.
G.
The maximum radioactivity that may be contained in any of the following tanks shall not exceed 10 Ci, excluding tritium and dissolved gases:
l 2.4-1 i
F.
The radioactivity in the steam generator blowdown and condensate polishing evaporator distillate from Unit 2 shall be monitored and recorded. Whenever the blowdown or distillate monitors are inoper-I able, any unmonitored blowdown flow shall be diverted to the waste management system or the condensate polishing waste neutralizing sumps respectively, and the direct release to the environment terminated.
G.
Plant records shall be maintained of the radioactive concentration and volume before dilution of liquid waste intended for discharge, and the average dilution flow and length of tine over which each discharge occurred.
11.
Failure to comply with Sections 2.4.1.3.A through 2.4.1.3.G re-quires prompt reporting as specified in Section 5.6.2.a. (1).
I.
Dose calculations to ensure compliance with Specifications 2.4.1.2.B through 2.4.1.2.E will be performed using measured curie releases and the NRC computer code LADTAP. These calculations shall be performed within 30 days from the end of each quarter, unless more than 1 curie (excluding tritium and dissolved gases) of activity was released from a particular unit during a month, in which case they will be performed within 10 dayt from the end of the month for that unit.
Bases The release of radioactive materials in liquid waste to unrestricted areas shall not exceed the concentration limits specified ind 10CFR Part 20 and snould be as low as practicable in accordance with the require-ments of 10CFR Part 50.36a.
To ensure that the releases of radioactive material above background to unrestricted areas will be as low as prac-ticable as defined in Appendix I to 10CFR Part 50, the following design objective has been applied:
A.
The annual dose above background to the total body or any organ of an individual from a reactor shall not exceed 3 mrem or 10 mrem, respectively in an unrestricted areas.
These specifications, while providing reasonable assurance that the resulting annual exposure to the total body or any organ of an individual in an unrestricted area is as low as practicable, permit the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a dependable source of power under unusual operating conditions which may temporarily result in releases higher than the design objective levels but still within tin concentra-tion limits specified in 10CFR Part 20.
It is expected that by using this operational flexibility under unusual operation conditions, and exerting every effort to keep levels of radioactive material in liquid wastes as low as practicable, the annual releases will not exceed a small fraction of the concentration limits specified in 10CFR Part 20.
/
2.4-3
The design objectives have been developed based on operating experience taking into account a combination of variables including defective fuel, i
primary system leakage, and the performance of the various waste treat-ment systems, and are consistent with Appendix I to 10 CFR Part 50.
I Specification 2.4.1.2.A requires the licensee to limit the concentration of radioactive materials in liquid wastes from the site to levels speci-fied in 10 CFR Part 20, Appendix B, Table II, Column 2, for unrestricted areas. This specification provides assurance that :n member of the general public will be exposed to liquid containing radioactive materials in excess of limits considered permissible under the Commission's Rules and Regulations.
Specifications 2.4.1.2.D and 2.4.1.2.E establish the upper limits for the dose due to the release of radioactive materials in liquid effluents.
The intent of these Specifications is to permit the licensee the flexi-bility of operation to assure that the public is provided a dependable source of power under unusual operating conditions which may temporarily result in releases higher than the levels normally achievable when the plant and the liquid waste treatment systems are functioning as designed.
Releases of up to these limits will result in concentrations of radio-active material in liquid wastes at small percentages of the limits specified in 10 CFR Part 20.
Specification 2.4.1.2.F requires that suitable equipment to control and monitor the releases of radioactive materials in liquid wastes are operating during any period these releases are taking place consistent with the requirements of 10 CFR Part 50, Appendix A, Design Criterion 64.
Specification 2.4.1.2.B requires that the licensee maintain and operate the equipment installed in the liquid waste systems to reduce the release of radioactive materials in liquid effluents to as low as practicable consistent with the requirements of 10 CFR Part 50.36a.
Normal use and maintenance of installed equipment in the liquid waste system provides reasonable assurance that the quantity released will not exceed the design objective.
In order to keep releases of radioactive materials as low as practicable, the specification requires, as a minimum, operation of equipment in a particular waste stream whenever it appears that the projected doses due to releases from that particular waste stream will exceed 10% of the design objectives. This specification does not apply to waste streams for which a permanent treatment system is not currently installed, such as the Millstone Unit No. 2 Steam Generator Blowdown.
Specifcation 2.4.1.2.G limits the amount of radioactive material that could be inadvertently released to the environment to an amount that will not exceed the Technical Specification limit.
In addition to these limiting conditions for operation, the reporting requirements of Specification 2.4.1.2.C delineate that the licensee 2.4-4
3 I
shall identify the cause whenever the dose due to release of radioactive materials in liquid wastes exceeds 1.0 mrem to the whole body or 3.0 C
mrem to any organ during any calendar quarter and describe the proposed program of action to reduce such releases to design objective levels on a timely basis. This report must be filed within 30 days following the C
calendar quarter in which the release occurred.
The monitorict requirements given under Specification 2.4.1.3 provide assurance that radioactive materials in liquid wastes are properly controlled and monitored in conformance with the requirements of Design Criteria 60 and 64.
These requirements provide the data for the licensee and the Commission to evaluate the plant's performance relative to radioactive liquid wastes released to the environment. Reports on the qualities of radioactive materials released in liquid wastes are fur-nished to the Commission according to Section 5.6.1 of these Technical Specifications in conformance with Regulatory Guide 1.21.
On the basis of such reports and any additional information the Commisssion may obtain from the licensee or others, the Commission may, from time to time, require the licensee to take such action as the Commission deems appropriate.
Monitoring Requriements 2.4.1.3.A through E and G and H. will apply to l
theCondensatePolishingWasteNeutralizingSumpdjschargesonlywhen the steam generator gross activity exceeds 1 x 10 pCi/ml. Discharges from these sumps will be terminated when the Steam Generator or the S.J.A.E. Radiation Monitors alarm, until Monitoring Requirements 2.4.1.3.A through E and G and H are met.
Monitoring Requirements 2.4.1.3.E through H will apply to the condensate polishing evaporator distilla y discharges only when the Steam Generator gross activity exceeds 1 x 10 pCi/ml.
If the monitoring requirements of 2.4.1.3.E through H are not met, discharges from this pathway will be terminated when the Steam Generator Blowdown or the S.J.A.E. Radiation Monitors alarm.
The points of release to the environment to be monitored in Section 2.4.1 include all the monitored release points as provided for in Table 2.4-3.
Monitoring Requirement 2.4.1.3.I ensures that the determination of dose based on measured curie releases is consistent with NRC Regulatory Guide 1.109, Revision 1.
2.4-5
Table 2.4-1 RADI0 ACTIVE LIQUID SAMPLING AND ANALYSIS Liquid Sampling Type of Detectable I
Source Frequency Activity Analysis Concentrations (pci/ml)(3)
-7 (2)
A.
Monitor Tank Releases Each Batch Principal Cacuna Emitters 5 x 10 and/or Condensate
~
I Polishing Veste.Neu-One Batch /Honth Dissolved Cases 10 tralizing Susp Re-II
~
1 leases (7)
Weekly Composite Ba-1.a-140 f-131 10 S.x10 Sr-89 III
~
Monthly Composite H-3 10
~
l Cross Alph's 10 ro II)
-8
- a Quarterly Composite Sr-90 5 m 10 L
?
B.
Deleted l
-7 (2)
Steam Cenerator Blowdown ( } Veekly Principal Casuna Emitters 5 x 10 C.
and/or Condensate Polishing Evaporator Distillate (7)
'10-8 i
Ba-T.a-140. 1-131 l
(Unit 2 Only)
~
One semple /Honth Dissolved Cases 10
-8 Sr-89 5 x 10 Monthly Composite ( I
~
H-3 10 Cross alpha 10~
-8 Quarterly Composite (
Sr-90 5 x 10 9
A
\\
Tabic 2.4-1 (Continued)
(1)
A composite sacplc is :.ne in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged.
(2)
For certrin sixtures of ga:a:ia emittprs, it may not be possibic to measure i
radionuclides in concentrations near their sensitivity limits when other nuclides are tiresent in the sample in much greater concentrations. Under these circunstances, it will be more appropriate to calculate the concentrati:t of such radionuclides using measured racios with those radionuclides which are routinely identified and measured.
(3)
The detectability limits for activity analysis are based on 'the technical feasibility and on the potential significance in the environment of the quantities released. For some nuclides, lover detection limits may be readily achievable and when nuclides are measured below the stated li=its, they shall also be reported.
~
(4)
Deleted (5)
To be representative of the average quantities and concentrations of radio-active materials in liquid effluents, samples should be collected in pro-portion to the rate of flow of the effluent stream., Prior to analyses, all samples
- taken for the cc=posite should be thoroughly mixed in order for the composite.sa=ple to be representative of the average affluent release.
These ana'yses are required when the steam generator gross activity l
(6)
(sa= pled and analyzed 3 times per week as per the Safety Technical Specifications Table 4.7-2) exceeds 1 1.10 7 p Ci/al.
-(7)
Sampling and analysis of the Condensate Polishing Vaste Neutralizing Sumps and the Condensate Polishiig Evapdrator Distillate, for the activity analysis shown in Table 2.4.1, are reguired only when the steam generator gross activity exceeds 1 x 10- pCi/ml.
2.4-16
+
9
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O Docket Nos. 50-245 50-336 Millstone Nuclear Power Station, Unit Nos. 1 and 2 Additional Information Supporting Proposed Changes to the Environmental Technical Specifications i
f I
i l
I l
l May, 1982 6
The following information is provided in support of the proposed changes to the Millstone Unit No. 1 and 2 Environmental Technical Specifications.
A mathematical analysis of the Condensate Polishing Facility (CPF) waste neutralizing sumps indicates that the activity concentrations of these untreated regenerative wastes will be approximately equal to that of the steam generator secondary side for the long and inter-mediate lived isotopes.
Short lived isotope concentrations will be much less than the associated steam generator concentrations.
Ex-perience to date has shown that the activity levels in the untreated regenerant wastes are less than the steam generator secondary side activity. Use of the CPF r Jioactive waste evaporator will typically 4
3 and 10 for iodine and all other yield dose reduction factors of 10 nuclides, respectively. Further dilution will occur in the circulating water discharge to which this effluent is released.
Since the volume and activity concentrations in the CPF radioactive effluent are a factor of 1000 to 10000 less than the corresponding steam generator blowdown values, the activity released to the en-vironment will be due predominately to steam generator blowdown.
In addition, the CPF radioactive waste evaporator effluent is con-tinuously monitored and recorded for activity and flow which will ensure that these discharges are properly accounted for in all offsite release calculations.
NNECO also proposes to revise the current limit on liquid effluent releases from a curie limit to a dose limit. The basis for the present curie limit was to ensure compliance with the design dose objectives of Appendix I to 10CFR50. For liquid releases these objectives are 3 mrem per year to the whole body and 10 mrem per year to any organ.
The curie limits were developed on an industry wide basis with the NRC for a generic type site. For the Millstone site, with immediate dilution and no drinking water pathway, the curie limits currently in place are overly-conservative. They do not afford operational flexibility within the dose guidelines of Appendix I and, as such, do not provide for a dependable source of power compatible with the public health and safety.
Specifically, for Millstone Unit No. 2, station operation will be adversely affected in the near term due to the current overly-conservative liquid effluent limits. This is due to the small primary-to-secondary leakage which currently exists coupled with higher than normal primary system activity levels.
I NNECO proposes to revise the current curie limits on liquid effluents to dose limits consistent with the Radiological Effluent Technical Specifications presently under development for the Millstone site. The revised limits will provide the required operational flexibility within the design dose objectives of Appendix I and at the same time provide reasonable assurance that whole body and organ doses to members of the general public are as low as practicable..The proposed quarterly and nanual dose limits are a small fraction of the limits specified in 10CFR Part 20.
Mandatory operation of liquid effluent treatment systems on a waste stream whenever dose projections due to releases from that stream exceed 10% of design objectives will maintain offsite doses low.
Dose determinations based on curie releases will be accomplished with LADTAP computer code. This is consistent with the requirements of Regulatory Guide 1.109, Revision 1.
Consistent with NNECO's philosophy of maintaining offsite releases as low as practicable, the following actions have been initiated at Millstone Unit No.
2._
Primary system letdown flow has been increased by operating two charging pumps. A deborating ion exchanger has been placed in operation in an effort to reduce primary system activity levels. NNECO is also in the process of designing, procuring, and installing a temporary system to treat the steam generator blowdown.
The design of this system will result in a reduction factor of approximately 50 for iodine releases, which is the predominant nuclide in the blowdown.
A benefit / cost evaluation was performed to assess the impact of this proposed ETS change. There is no real cost increase above the bases of the existing specifications as the bases for the current curie limits was 10CFR50, Appendix 1.
The benefit to be gained is additional operational flexibility within the dose guidelines through removal of artificial limits.
It is estimated that the cost of the insignificant increase in offsite dose resulting from this proposed change is far outweighed by the consequences of a forced outage due to the overly conservative liquid effluent release 'imits.
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