ML20059C290

Application for Amend to License NPF-42,revising Radiological Tech Specs & Ets,Per Generic Ltr 89-01, Implementation of Programmatic Controls for Radiological Effluent Tech Specs in Administrative Controls Section..

ML20059C290
Person / Time
Site:	Wolf Creek
Issue date:	08/24/1990
From:	Rhodes F WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059C293	List: ML20059C290 ML20059C298
References
ET-90-0087, ET-90-87, GL-89-01, GL-89-1, NUDOCS 9008310172
Download: ML20059C290 (16)

Text

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L W$LF CREEK NUCLEAR OPERA 11NG CORPORATION l I Forrest T. Rhodes Vm.Pr.emum tasia ins a w iew n.a=

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August 24,1990  :

l ET.90-0087 .

'U. S. Nuclear Regulatory Commission j ATTN: Document Control Desk Mail Station Pl-137 .J Washington, D. C. 20555 )

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Subject:

Docket No. 50-482: Revision of Radiological and )

Environmental Technical Specifications in Accordance j with Generic Letter 89-01 l i

Gentlemen l The purpose of this letter to to transmit an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS) in accordance with the guidance provided in Nuclear Regulatory  !

Conunis sion '"ItC ) Generic Letter 89-01. Generic Letter 89-01, '!

u " Implementation of _ Progransnatic Controls for Radiological Effluent Technical j

!: . Specifications in the Administrative Controls Section of, the Technical  ;

Specifications and. the Relocation of Procedural Details of RETS to,the Offsite Dose calculation Manual or to the Process Control Program", provided '

guidance to. licensees for the preparation of license amendment requests

. adding programmatic restrictions to the Administrative Controls ,section- of the Technical Specifications to satisfy existing regulatory requirements for Radiological Efflaont Technical Specifications-(RETS). The guidance in the generic letter also provided for the relocation of procedural details.

currently contained in the RETS, to the Offsite Dose Calculation Manual ,

(ODCM) or Process Control Program (PCP) as appropriate. Such a license J amendment simplifiws the existing RETS while continuing to meet applicable i regulatory requirements, consistent with the Conunission's Interim Policy Statement on Technical Specification Improvements. .,l l

Attachment I provides a description of the amendment along with a Safety j Evaluation. Significant Haaards Consideration Determination and Environmental Impact Determination supporting the requested change.  ;

i- Attschment II provJdes a cross reference of the proposed location of those

-sections of the RETS wt# h will be moved to the ODCH or PCP. The specific changes proposed are cootained in Attachment III as marked up Technical  ;

Specification pages. As requested in Enclosure I to the generic letter, a complete copy of the revised ODCH is provided in Attachment IV. i 1101S y .-

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PO, Ekm 411/ Burlingkm, KS 66839 / Phone: (316) 364-8831 \

An Equal opporturvey Etnpey.r MS/He/ VET

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-Page 2-RT 90-0087-In accordance'with 10. CFR 50.91, a copy of this application, with attachments is being provided to the designated Kansas State Official. This

-proposed revision to the WCGS'. Technical Specifications will be fully

'impleme'ited within 30 days of formal Nuclear Regulatory Comunission approval.

If you have any questions concerning this matter, please contact me or Mr.

H. K. Chernoff of niy staff.

o Very truly yours, f I'. O Forrest T. Rhodes L

L Vice President Engineering & Technical S'srvices L. FTR/jra Attachments- I - Safety Evaluation. Significant Haaards Consideration Determination and Environmental Impact Determination II - Cross Reference for Relocated Technical Specifications,.

-Notes on Relocated Technical Specifications and Explanation = of Changes to Current RETS ' Procedural Requirements III - Technical' Specification Changes IV.- Offsite Dose Calculation Manual cci G. W. Allen (KDHE), w/a R. D. Martin-(NRC), w/a D. V. Pickett (NRC), w/a M. E. Skow (NRC), w/a' I-. J. S. Wiebe (NRC), w/a i

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STATE OF KalllSAS )

) SS COURTY OF COFFEY )

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Forrest T. Rhodes, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering and- Technical Services of Wolf Creek Nuclear Operating Corporations that he has read the foregoing document and knows the content thereof that he has executed that same for and on behalf of said Corporation with full power and authority to do so and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

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By Forrest T. Rhodes Vice President Engineering & Technical Services a...

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ED and sworn to before me this cH, day of (lue

, 1990.

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i ATTACBERT I ,

1 SAFETY ETALUATION, ,

SIGNIFICANT marA M 00NSIDEt& TION DETEININATION AND ENVIROMENTAL IMPACT DETEmmeATION <

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Attachment I to ET 90 0087 Page 1 of 4 i

SAFETY EVALUATION, SIMIFICANT mananna CONSIDERATION DNTEEbffnATION AND '

ENYInnensufAL IMPACT DNTERMINATION l

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1. PROPOSED CRANGE  ;

This license amendment request proposes to implement Technical Specification changes as described in NRC Generic Letter 89-01, 'Lmplementation of.

Programmatic Controls for Radiological Effluent Technical Specifications in i

~t he Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation i Manual or the Process Control Program.'

[ This amendment request affects those sections of Technical Specifications j dealing with the control of radiological effluents, including those sections dealing with gaseous effluents. -liquid effluents, solid waste, and environmental monitoring. Associated Technical. Specifications addressing-definitions, administrative cont: sis and reporting are also affected. ,

Specific Technical Specification sections affected by this amendment request 1 are listed in Attachment II. The purpose of these specifications is to ]

assure compliance with regulatory requirements governing radioactive i effluents, including 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR 50.

In accordance with the guidance of Generic Letter 89-01, this proposed change adds new programmatic requirements governing radioactive effluents and radiological environmental monitoring to the Administrative Controls section of the Technical Specifications. Existing Technical Specifications containing procedural decalls on radioactive effluents, solid radioactive wastes, environmental monitoring, and associated reporting requirements are  ;

concurrently being deleted. The procedural details which are to be deleted are being incorporated into the Offsite Doso Calculation Manual (ODCH) or i Process Control Program (PCP) as appropfiate. The Technical Specification  !

l= definitions of the ODCM and PCP are also revised to reflect these changes.

This amendment request is being proposed as an improvement to the existing Technical Specifications as recommended by Generic Letter 89-01 and consistent with the Commission's Policy Statement for Technical Specifications improvements.

II. SAFETY KVALUATION The proposed changes to the Technical Specifications are administrative in nature and affect only the format and location of procedural details relative to the control of radioactive effluents, solid radioactive waste, and radiological environmental monitoring. The proposed changes do not involve physical modifications to plant equipment or changes in the operation of the plant.

s Attachment I to ET 90-0087 Page 2 of 4 Although procedural detail is being removed from the Technical Specifications, this information is being relocated to the ODCM or PCP as appropriate. Additional administrative controls are being added_ to the Technical Specifications (6.13 and 6.14) to ensure that the ODCM and PCP will maintain compliance with applicable regulatory requirements. For example, per proposed Technical Specification 6.13, future changes to the ODCM will be reviewed to ensure that such changes will ' maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR Part 190 10 CFR 50.36a, and Appendix I to 10 CFR'50 and not adversely. impact the L accuracy or reliability of effluent, dose, or setpoint calculations.

L Similar controls are applied to changes in the PCP.

A table has been provided in Attachment II which includes a listing of-Technical Specification sections which are proposed for deletion and their ,

L new location within the ODCM or PCP. Any changes to the relocated material, other than editorial, are identified and explained in Attachment II. As specified in Enclosure 1 to the generic letter, such changes have been l

reviewed against tho' requirsments of proposed specification 6.13 and 6.14' and found to meet the specified criteria.

L A limited number of changes to the ODCM are included in this revision which h are not directly related to the relocation of material from the Technical L Specifications. These changes are also discussed in Attachment II. As  :

1 specified in Enclosure I to the generic letter, such change, are identified l- by vertical bars in the margins of the ODCM which is provided as Attachment  ;

IV.

As discussed above there are no physical changes to the plant or changes in plant operation associated with this proposed amendment. Therefore, there I is no increase in the probability of occurrence or the consequence of an '

L accident or malfunction of equipment important to safety nor is the possJbility for an accident or malfunction of a different type than any  ;

previously evaluated in the safety analysis report created. The amendment -

request is administrative in nature and is' consistent with NRC guidance in Generic Letter 89-01. New administrative controls are incorporated into the Technical Specifications which ensure that the relocated procedural detail is controlled in a manner which provides for continued compliance with applicable regulatory requirements. Therefore there is no degradation of the level of control provided over radioactive effluente, solid radioactive 3 '

waste, or radiological environmental monitoring and no reduction of the margin of safety as defined in the basis for any technical specification.

[ - III. SIGNIFICANT BAEARD6 CONSIDERATION DETERM MATIDW t

This proposed change has been reviewed per the standards provided in 10 CFR 50.92 and determined not to involve a significant hat.:ds consideration.

Each standard is discussed separately below.

Standard 1 - Involves a Significant Increase in the Probability or conesquences of an Accident Previously Evaluated.

• This proposed change alters only the format and location of procedural detail and administrative controls relative to radioactive effluents,

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Attachment I"to ET 90-0087 7 ' Page 3 of 4  ;

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L solid' radioactive s wastw, and radiological environmental monitoring. The-0 ' change is administrative in nature and does not involve any change to-.the-I configuration or operation of plant equipment.- Therefore, this proposed

~ change does not increase-the probability or consequences on any_ previously- ,

- evaluated accident. l Standard 2 J Create the Poeelbility of a New or Different Eind of Accident

From any Previonely Evaluated.

Since this proposed change does not involve any change to the configuration

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D or ' method of operation of -any- plant equipment,- it does not create =the- '!

possibility of a new or different kind from those previously evaluated. j

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V Standard'3'- Involve a significant Reduction in the Margin of Safety.

This ' proposed change: relocates procedural detail from the Technical Specifications-to tha ODCM or;PCP. However, new administrative ~ controls are j ' added.to the TecPhloal Spacifications which assure the proper control- and l

maintenance of ttn>i documents and provides an equivalent, level of assurance that' activities invctving radioactive effluents, solid radioactive waste, and radiological .environmentaltmonitoring are= conducted in full compliance-with regulatory requ'rements. Therefore, there is -no red ction in the margin of safety.

o The proposed- change- does not involve any actual change in the methodology ,

b used in the. control of radioactive effluents, solid radioactive waste,. .or )

radiological environmental monitoring, This change' provides for the d f relocation'of procedural detail outside of.the Technical Specifications but  :

H adds appropriate administrative controls to-provide continued assurance of l- compliance to applicable regulatory requirements. This proposed change.

complies-with the guidance provided by NRC in Generic Letter 89-01.

Therefore, based on the above considerations, WCN00 has determined that this 1 change does not involve a significant hazards consideration, a

IV.' ENVIROIREETAL IMPACT DETERMINATION

't 10 CFR 51.22(b) specifies the criteria for categorical exclusions from the requirement for a specific environmental assessment per 10 CFR 51.21.

1 l' This amendment request meets the criteria specified in 10' CFR 51.22(c)(9).

K - Specific criteria contained in this section are discussed below. I 1- n (i) the amendment involves no significant hazards consideration, i l:

As demonstrated in tne previous section, this proposed snendment dces not involve any significant hazards considerations. I 1

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e iAtthchment"I To ET 90-0087 1Page_4 of?45 4 n .

D (11)L:there is no significant change in the types or significant increase  ;

in the amounts of any effluents that may be released offsite, '

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This amendme'nt-is administrative in nature and involves only the format- and. ~

locatior. of procedural. details and administrative controls relative to y

radioactive effluents' . No changes to the. actual- methods of controlling andi .:

monitoring off; radioactive. effluents are made by this action. Contin'ed~

u f compliance with regulatory requirements relative to radioactive effluents is- 1 assured by. specific administrative controls which are added to the Technical-

h. Specifications. Therefore, .there will be no change in-types or increase in

.the amounts of-any effluents released offsite.

N (iii)_ there is no.significant increase in individual or ctusulative occu-pational radiation' exposure.'

This proposed change will not result in ' changes

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ir. the operation _or configurationwof. the facility and, as oiscussed-abave, there~will be no change in the-level of controls- or methodology used for . processing sof j radioactive effluents, handling of solid radioactive twste, or radiological [

l environmental. monitoring. Therefore, there will be no increase in individual'or cumulative' occupational radiation exposuce resulting from.this "

j change.'

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i Based on the above it is concluded there will' be no _ impact on ;the 4 environment resulting from: this change and'the change meets the criteria specified in 10 CFR.51.22 for a categorical exclusion from the requirements' q i

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of 10 CFR 51.21' relative to specific environment -assessment by the Commission, q

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[b. ATTACIBGElrf II~

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CROSS REFERENCE FOR RELOCATED TECHNIC &L' SPECIFICATIONS..

, ^t NOTES 05 RELOCATED TECENICAL SPECIFICATI0Its . i>

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'I EIPI.4EATION OF CHANGES-TO CURRENT RET 8 PROCEDURAL REQUM6 i

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W <. ' , '; Attachment sII e to ET 90-0087:

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- CROSA REFERENCE FCE RELOCATED TEGRIICAL SPECIFICATIONS s- .

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• -Current Technical Snecification NEW ODN or PCP Location

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• F , 1.17'.l'.22 Retained in Technical l Specifications

c. 1.31 PCP Section 2.2;6 4L -

. 3 / 4. 3. 3.10 '- ODCM'Section'2.4 6 .3/4.3.3.11, 0DCH Section 3.4 1

. 3/4.11.1.1 ODCM Section 2.1-

1. 'i 3/4.11.1.2 ODCM Section 2.2 i

% ODCH Section'2.3~

3/4.11.1.3 P 3/4.11.1.4 Retained in. Technical Specifications 1

'M 3/4.11.2.1 ODCM Section-3.1 c' 3/4.11.2.2 ODCM Section 3.2.1'.

.!! ' , 4 3/4.11.2.3- CDCM Section 3.2.2 w 3/4.11.2.4 ODCM Sectionc3.3' Retained in Technical' Specifications -.

3/4.11.2.5 ,

3/4.11.2.6 Retained in Technical Spe'cifications-

,3/4.11.3' PCP Section-3.1-  !

3/4.11.4. ODCM Section-'4io, ODm ;Sedtion 5.4.2 il 3/4.12.1 -i

'i 3/4.12.2- ODCM Section 5.2'  :

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3/4.12.3 ODCM Section 5.3 and 7.1- El

• ' 5.1.3 Retained in'Technidal Specifications- j

';g 6.9.1.6 ODCM Section 7.1 .

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.6.9.1.7 ODCM SectionT7.21and PCP Section 3.2.1.

6.13 Retained but Simplified' 6.14 Retained but, Simplified, W '6.15 PCP Section 3.2'.2'and ODCM Section 7.2'

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Attachment IILto ET 90-0087 Page 2 of.7L 'l o

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NOTES ON RELOCATED' TECHNICAL SPECIFICATIONS-g 3.12.1 (als Paragraph (a) was deleted since the requirement to include in

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, . annual report ... reasons-for not conducting the program as required by-Section 5.1....' is repeated in Section 7.1, third paragraph.

3.12.1 (b): This requirement is incorporated in ODCH Section 5;4.2, except [

for the last sentence which is incorporated in Sectioni7.1, third paragraph.. .

3.12.1 (c) - This requirement is not repeated verbatim in.the ODCH., .but isi incorporated in Notes 1 and 9 to Table 5-1.

The wording has been clarified-

, -- ands the ; requirement'~ hasL been expanded _to allow additional alternate locations to- be used when. samples of milk or broadleaf vegetation are temporarily unavailable from the primary locations (Table ~5-1. Note 9).

_ As-previously mentioned, permanent unavailability of, samples would require that ,.

replacement locations be identified 'and added to the program within thirty  !

days-(Table 5-1, Note 1).

...l Reporting the cause of unavailabi?- and justification for new locations'is still in accordance with Technica,. Specification 6.14 ("0DCH Changes'),-

however the statement ' . . . including a revised figure (s) and table: for the . '

ODCH reflecting the new location (s)..." was not- _specifically repeated in - 'i Note 1 to Table 5-1, since such revisions would be implicitly required in an-adequate ODCH revision.

j 4.12.1: Requirements are reworded-and incorporated into ODCH Sections 5.0 and 5.1. j Table 3.12-1. 3 Wording from the previous Technical Specification and ODCH a tables have been combined in the.new ODCH Table 5-1.> The order of: the i Direct Radiation and- Airborne pathway subsections have been-reversed from J' the previous Technical Specification table.

s Table 3.12-1 (1) (DIRECT RADIATION): Reference to an "

... instrument for measuring and recording ' dose rate continuously..." was deleted since TLDs are:used exclusively for monitoring this pathway. The description' of )

dosimeter- placement was simplified, deleting the reference to placing the "

ll inner ring of stations "....in the general area of the site boundary...';  ;

actual placement of the inner ring of TLDs is at approximately three miles j because (1) this distance more accurately reflects actual resident locations 1 and'- (2) nearer placement than this would be over water in all but about i three sectors. The control location description was'made more specific. i Table 3.12-1 (2) AIRBORNE: Wording revised to improve clarity. Control location description was made more specific by changing '...as for example 15 to 30 km (10 to 20 miles) distant and in the least prevalent wind direction..." to '

.. 10 to 20 miles distant in a low D/Q sector...' t combined with the specific loc'ition reference.

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Lr Attachment II to RT 90-0087

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Table 3.12-1 (31- WATERBORNE:

(a). Surface water and (b) Ground' waters more detailed..

e site-specific location descriptions were provided.

(c) Drinking water: Wording revised'for clarity and' to add site-specific description. Words "...one to three of the nearest water supplies that could be affected by its discharge..." have been replaced by a description of- the most conservative downstream sampling locations additional downstream locations _would not be as likelyfto be affected, lha

- requirement to increase sampling frequency to every two weeks (when doset of

. greater than one millirem per year are projected from drinking water) 'has-been relocated.to Note 8 of ODCH Table.5-1.

nt from shorelines sampling location description is made core site Table 3.12-l'(4, INGESTION:

(a) Milk: Due to the la aber of available milk sampling locations in the area, the indicator samps location description has been-broadened to require samples from the thrse highest D/Q locations =within 5 r 1es (rather than 3 miles)of the site. (This makes,the ODCM requirement-8

.. e estrictive than the previous Technical Specification). The words

...in the least prevalent wind direction..." were removed from the control location description for.the same reason (i.e., to help assure that sampling locations could be identified, given the fact that so few locations are available). Finally, the sample collection frequency.of *... semimonthly.

when animals are on pasture..." has been Anterpreted as applying during the months of April-through. November based on local agricultural practice, c

(b) Fish: 'more detail hae'bein provided on sample.ccliection

' locations.

Also, since the species of fish collected are generally-available all year, the sample collection frequency has been simplified to i: ' Semiannually".

(c) Food products: (the order of irrigated crops and broadleaf vegetables have been reversed from the previous Technical Specification)

Indicator and control broadleaf vegetation sampling. locations have been made more conservative by removing the stipulation "...if milk sampling is not performed...", (i.e., broadleaf vegetation sampling is performed regardless of whether or not milk sampling is performed). The requirement for the control location to be "...in the least prevalent wind direction..'.' was modified to "...in a low D/Q sector...". The current control location is in a low D/Q sector (although not technically the lowest), at a distance of 15 miles from the site, and in approximately the same location as the control air sampler.

In addition, the separate I-131 analysis for broadleaf vegetation samples has been removed since required I-131 detection limits are achievable by gamma isotopic analysis.

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<+ LAttachmentNIII to ET/ 90-0087 L -,

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,Finallys.Lthe sample-location description for irrigated crops hasibeen made (

, more site-specific.

, t t-1 Table 3.12-1 TABLE NOTATIONS: ' Table notations have'b'een reordered'from the "

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4 previous Technical specifications as follows: -

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f,r.pylous' Technical Soecification # ODCH f 9 w 2 .4

4. , . 5 y , .- -

3 11-4- 2 .

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5- 3 L- 6- 5 l' :7- 7 y

8. 6

.-9 '8 (drinking water only) 10 10 t (none)- 9 (now note) y Revisions' to individual VAstions are as : follows:

. . Table 3.12-1. -NOTE 1: The first sentence was deleted since the table'and' 4

. figure specified have been incorpocated in the ODCH.g The description-'of t

) reporting:-.0DCH changes at the end~of the note-was modified to correspond to.

t the now: Technical Specification wording.

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~ Table"3 12-1.

. NOTE 5 (now NOTE 31: -Reference to the ' mixing ' zone' vas

' deleted.asl inapplicable to, Wolf Creek-Cooling Lake.

J Table'3.12-1. NOTE 7: Theiexample of.a-short time' interval was changed from3

' hourly"'to "every two hours" to more accurately. reflect the limitations. of j the current sampling equipment. it Table 3.12-1. NOTE 9 (now NOTE 8): 'The previous Technical Specification '

note was combined with the requirement.to increase.'. sampling frequency and-add 'I-1S?. analysis of drinking water samples indicating a potential dose of '

t, over.one millirem per year (this requirc int was former~r in the body of J

@ Table -3.12-1). This note no longer applies to milk campling due to revisions to the milk sampling portion of the table.

i New' NOTE 9 of Table 5-1 (not in orininal Technical Snecification): New note

, added to explain the use of alternste sampling locations, which have been ['

, found useful in decreasing the number of missed samples and which are being g incorporated in this ODCM revision. '

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!.ittachment II to ET 90-0087 ~ g

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& l Tab 1'e 3.12-2: .No revisions were made to this table . which is now Table 5-4' s

( l- in the ODCM.  ;

,T,g)J e 4,4d.L ;Now. Table 5-3'in ODCH: note at bottom of.page was' moved to l y '

' TABLE.NOT2TIONS" page,-following.

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.. Table 4.N-1. TABLE NOTATIONS References in Notes 1 and~ 3 were made_

k , con *istent with new- revision. Note previously at bottom of Table 4.12 l

. c.ided as new Note 4'to ODCM Table 5-3.  !

3.12.2:- This sentence was reworded for, clarity and is now the first "

sentence of ODCM section'5.2.-

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I 3.12.2- (a): Locations used for previous Technical Specificat!.on 4.11.2.3 dose calculation are highly conservative (exclusion area boundary- for d

i airborne pa thway ',- circulating water discharge point for liquid pathway).  !

Since there are no resident locations with a higher . dose potential', this  ;

1 paragraph was deleted from the ODCH.

q Incorporated ~in Section 5.2, second paragraph, of new ODCM..

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3.12.2 (b):

The wording of.the last sentence was modified to make it consistent with the-revised documentation requirements. The October 31- date for dropping

. deleted sampling locations from the monitoring' program .was considered.

unnecessary and removed.. j 4.12$2: Ini:luded in ODCM as' Section 5.2, first and third paragraphs. [

' Requirement for conducting the Interlaboratory Comparison Program 3.12 . 3 : - '

is now in revised Technical Spacification 6.8.4.f.3) and is not. repeated in the ODCH.

'3.12.3 (a): Reporting of corrective actions is contained in revised '0DCM Section 7.1, third paragraph.

4.12.3: Description of the Interlaboratory Comparison Program is in ODCM Section_5.3 reporting requirements are listed in ODCM Section 7.1,

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third paragraph. ,

6.9.1.6: The. Annual Radiological Environmental Operating Report is now listed in Technical Specification 6.9.1.3 and ODCM Sections 5.4.1 and 7.1. ,

Referenccs were changed to match the new revisions. The requirement for the ~

report to. contain "...at least two legible maps..." of sampling locations '

was simplified to '... legible maps...". (The requirement for legibility will ~ dictate the appropriate number of maps and will not reduce the 1 effectiveness of the report)- .

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Attochm:nt! II1to ET:90 0087 1

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' I EEFtAEATION OF CBABGES 70 ADtRENT RETS PROCEDURAL REQUIREltENTS g.

Listed belov are changes'which have been made to the procedura1L details: .of' L

the RETS'when they were-relocated-to the:0DCM. -These changes have been~made; .;

to clarify- items which were considered as, inconsistencies within the-o Technical Specifications.

1) ODCM Sections 2.3 and -3.3- have .been changed =.to incorporate 1-the requirements of current Technical-Specifications 3.11.1.3 and 3.11.2.4,-

The old revision of;the ODCH was vague. .specifying:that

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only:a methodology.for calculating dose would be used and not specifyingi j

, ,: -an. equation to be used for projecting dose. To be more specific and to '

clearly. define how these requirements are being met, the' following-equation.has been added to the ODCM. g

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37 - A X 31 l T .i

.. 'i This is considered to be a clarification rather than a change which is 1"

,being made to be more specific by'providing the equation in thi ODCH..

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2)' ODCM Table 3.1 corresponds to Table 4~.11-2 of the current Technical' Specificationn This table has been revised to include sampling:of the Radwaste< Bui' ding" Vent for tritium as part of_the Radioactive Gaseous Waste Sampling and - Analysis Program. This requirement is not included 1 in Table 4.la-2 of-the current Technical Specifications. The tritium-i sampling of the Radwaste; Building Vent has routinely been performed ,at 1 Wolf Creek GeneratingfStation in .the past even though it was.not-required by' Technical Specifications. This sampling requirement. is being'added to the ODCM for? consistency.

3) Table 4.11-2 of the current: Technical Specifications requires continuous sampling of all release points listed. Of the items lioted.1 through.5, only items 3 and 5 are actually . release points for Iodine -and particulates at WCGS. The other items, '1) Gas Decay Tank, 2)  :

Containment- Building and 4) Spent Fuel Building Exhaust, represent-unfiltered waste streams. At some plants these waste streams- 'are

' discharged directly to the atmosphere and would require monitoring,for ,

particulates and Iodine. At WCGS these three waste streams are filtered '

and combined with other waste streams prior to discharge. i The unit vent is continuously monitored and any particulate or Iodine activity detected .at this final release point is utilized in calculations of doses to ensure the discharge limits are not exceeded.

This change to Table 4.11-2 of the Technical Specifications does not represent a change in our current sampling program but rather clarifies the sampling requirements as they apply to our plant design, s

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ttachment II to ET 90-0'087'

,, Page 7: of ;7 ~ .. )

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i te 4)'.0DCM Section 2.4:has been revised to incorporate Technical'Specificationi 3/4.3.3.10- and Tables 3.3-12 tand 4.3 8. The currentL .Technicali L Specificationo requirements .being (relocated Eto 'Section 2.4_are being' mi revisod'to add 1-HF-RE.95, the: secondary liquid waste influent discharge.

to the waste wr.ter treatment facility radiation monitor.-

WCNOC hass recently : incorporated into the' plant design anladditional

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j Ewaste water treatment facility (WWTF). .The. new. facility- chemically- n!

neutralizes waste waters from,the Makeup Domineralized Water system,:the  ;{

Condensate Domineralizer System, the SecondaryLLiquid' Waste System, 'the.

Water Treatment Plant acid and caustic drains,.the Water-Treatment Plant.

chemicaltspill' catch basin, and the WWTF -chemical' spill catch-< basin-

= prior,to discharge to the VCGS cooling lake. The WWTF has in its design Lbasis1 provisions for. radiation monitoring and isolation-capabilities'for i

the1 . discharge iline 7 from the Secondary Liquid WasteLSystem_to'the'WWTF i

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- which'is- in accordance with NUREG l' 78, . in order _to prevent inadvertent radioactive discharges._ -Radiation monitor 1-HF-RE-95, a-fixed volume  ;

detector assembly,; monitors-both high and low total-' dissolved- solide~

(TDS). waste waters: upstream of the discharge' isolation valve, prior to a andlduring discharges to the WWTF. .A high radioactivity indication ~from j

1-HF-RE-95 closes the discharge isolation valve, 1-HF-RV-95,- to prevent  ;

the discharge of radioactive _ effluent.1 ]

1 The addition of 1-HF-RE-95 to this ODCH section will ' ensure , reliable l continuousi monitoring and termination of effluent-discharge to the WWTFl  !

should the high or low.TDS wastes become radiologically contaminated. 1 In? the event that these ' wastes- become radioactive they; shall be: ';

prs ,assed through.the Secondary Liquid Vaste ,Systemi as described in ~,

tion 10.4.10 of the Updated Safety Analysis Report.- .

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