ML20069H861
| ML20069H861 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/08/1982 |
| From: | Sunny Chen FRANKLIN INSTITUTE |
| To: | Congel F NRC |
| Shared Package | |
| ML17320A377 | List: |
| References | |
| CON-NRC-03-81-130, CON-NRC-3-81-130 TAC-8138, TER-C5506-89-90, NUDOCS 8210200044 | |
| Download: ML20069H861 (27) | |
Text
!
1 TECHNICAL EVALUATION REPORT t :
RADIOLOGICAL EFFLUENT TECHNICAL [j SPECIFICATION IMPLEMENTATION (A-2) ;
INDIANA AND filCHIGAN ELECTRIC C0iiPANY T l DONALD C, COOK NUCLEAR PLANT UNITS 1 AND 2 z- , m .,n~ = .. z .= :. m . ,
, ; ' + -= :. : w ..a ++-. =a..= n?= =:= wnss NRC DOCKET NO. 50-315, 50-316 FRC PROJECT C5506 NRC TAC NO. 8138, 8139 FRC ASSIGNMENT 4 FRC TASKS 89, 90
!. NRC CONTRACT NO. NRC-03-81-13 p
i Author: -
Chen Preparedby .
Franklin Research Center FRC Group Leader: S. Pandey 20th and Race Street Philadelphia, PA 19103 Prepared for Nuc! car Regulatory Comrnission Lead NRC Engineer: F. Congel Washington, D.C. 20555 C. Willis October 8, 1982 Revised October 22, 1982 This report was prepared as an account of werk 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 fegal liability or responsibility for any third party's use, or the results of such use, of any information, a::p,a-ratus, product or process disclosed in this report, or represents that its use by such third party would not inf ringe privately owned rights.
Prepared b'y: Reviewed by: Approved by:
4/ AMAL A My 7
_ Principal Author: Group Leader ppt sf. &.. v Department Director j
lo/7/82 y o - t-2%
Date: N/YlfL Date: Oate:
Copy Has Been Sent to POg O Franklin Research Center !
{4
/
A Division of The Franklin Institute n., m,,,mn nonen en. y. rn.:..r isic3 <::33 44s.icco l (pigzooo W -
1 D J -
, _ _t
i TER-C5506-89/90 ]
a 1
2 3
CONTENTS t
Section Title Pace 1 INTRODUCTION . . . . . . . . . . . . . 1 1.1 Purpose of Review . . . . . . . . . . . 1 1.2 Generic Background. . . . . . . . . . . 1 1.3 Plant-Specific Background . . . . . . . . . 3 2 REVIEW CRITERIA. . . . . . . . . . . . . 5 3 TECHNICAL EVALUATION . . . . . . . . . . . 7 3.1 General Description of Radiological Ef fluent System . . 7 3.2 Radiological Effluent Technical Specifications. . . . 10 3.3 Offsite Dose Calculation Manual . . . . . . . 14 4 CONCLUSIONS . . . . . . . . . . . . . . 17 5 REFERENCES . . . . . . . . . . . . . . 19 f.'%___.
c
.J.' . =Fradin
>,.co a Research n . r, .x.m-Center u.
TER-C5506-89/90 :
l FIGURES Nu n.ber Title Page 1 Liquid Radwaste Treatment Systems, Ef fluent Paths, and Controls for Donald C. Cook Units 1 and 2 . . . . . . 8 2 Gaseous Radwaste Treatment Systems, Ef fluent Paths, and Controls for Donald C. Cook Units 1 and 2 . . . . . . 9 TABLE Number Title Page 1 Evaluation of Proposed Radiological Ef fluent Technical Specifications (RETS), Donald C. Cook Units 1 and 2 . . . . . . . . . . . . . 18 l
l l
l l iv l
1 L% -
._'.'. Frank':n Research Cen:er a o v. o, a m F,.-u.n rs . _i.
TER--C 550 6-89/90 ,I FOREACRD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Com:nission (Office of
!?aclear Reactor Regulation, Livision of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.
l 1
t 4
l l
l 1
l l
l I
l
.. L Fran' a c~,.= din s n . Research..
r,,-$.n .w. Center
a
(
TER-C5506-39/90 f, M
- 1. INTRODUCTION 1.1 PURPOSE OF REVIEW The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Donald C.
Cook Naclear Plant Units 1 and 2 with regard to Radiological Effluent Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM) .
The evaluation uses criteria proposed by the NRC staff in the Model Technical Specifications for pressurized water reactors (Bias) , NUREG-0472 [1].
This effort is directed toward the NRC objective of implementing RETS which comply principally with the regulatory requirements of the Code of Federal Regulations, Title 10, Part 50 (10 CFR50) , " Domestic Licensing of Production and Utilization Faci'.ities," Appendix I [2]. Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.
1.2 GENERIC BACKGROUND Since 1970, 10CFR50, Section 50.3 6a, " Technical Specifications on Ef fluents from Naclear Power Reactor s," has required licensees to provide technical specifications which ensure that radioactive releases will be kept as low as reasonably ach.evable ( ALARA) . In 1975, numerical guidance for the ALARA equirement was issued in 10CFR50, Appendix I. The licensees of all operating reactors were required [3] to submit, no later than June 4, 1976, their proposed ALARA Technical Specifications and information for evaluation in accordance with 10CFR50, Appendix I.
However, in February 1976, the NRC staff recommended that proposals to modify Tbchnical Specifications be deferred until the NRC completed the model RE TS . The model RETS deals with radioactive waste management systems and environmental monitoring. Although the model RETS closely parallels 10CFR50, Appendix I requirernents, it also includes provisions for addressing other issues.
These other issues are specifically stipulated by the following regulations:
_1 .
....' Fran'dn Research Center 40,,-an-rm onsu a
l TER-C5506-89/90 j
. l o 10CFR20 [4], " Standards for Protection Against Radiation," Paragraphs 2 l '
20.105(c), 20.106(g) , and 20.4 05(c) require that nuclear power plants and other licensees comply with 40CFR190 [5], " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40CFR190 limits have been or may be exceeded.
o 10CFR50, Appendix A [6], " General Design Criteria for Nuclear Power Plants," contains Criterion 60 - Control of releases of radioactive materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and Criterion 64 - Monitoring radioactivity releases.
o 10CFR50, Appendix B [7], establishes the quality assurance required
, for nuclear power plants.
The current NRC position on the model RETS was established in May 1978 1 when the NRC's Regulatory Requirements Review Committee approved the model RETS: NUREG-0472 for PRRs [1] and NUREG-0473 [8] for boiling water reactors (BWRs) . Copies were sent to licensees in July 1978 with a request to submit proposed 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, j 1978. The model RETS was subsequently revised to reflect comments from the AIF and others. A principal change was the transfer of much of the material I concerning dose calculations from the model RETS to a separate ODCM.
The revised model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133 [9]) for preparation of the RETS and the ODCM and a new schedule for responses, again staggered over a 6-month period.
Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subsequently, Revision 2 of the model RETS and additional guidance on the ODCM and a Process Control Program (PCP) were issued in February 1979 to each utility at individual meetings. In response to the NRC's request, operation reactor licensees have subsequently submitted initial proposals on plant RETS and the ODCM. Review leading to ultimate implementation of these documents was initiated by the NRC in 1981 using subcontracted independent teams as reviewers.
. ; Fran'dn Research Cen:er arm,one4 den.-en m ue
'q1111lll u TER-C5506-89/90 1
4 As the RETS review process has progressed since September 1981, feedback $
from the licensees has led the NRC to believe that modification to some of the requirements in the current version of Revision 2 is needed to better clarify specific concerns of the licensees and thus expedite the entire review process. Starting in April 1982, NRC distributed revised versions of RETS in draf t form to the licensees during the site visits. The new guidance on these changes was presented in the AIF meeting on May 19, 1982 (10]. Some interim changes regarding the Radiological Environmental Monitoring Section were issued in August 1982 (11]. With the incorporation of these new changes, NRC issued, in September 19 82, a draf t version of NUREG-0472, Revision 3 (12), to serve as new guidance for the review teams.
1.3 PLANT-SPECIFIC BACKGROUND In response to the NRC's request, the Licensee, Indiana and Michigan Electric Company (IMEC), submitted a RETS proposal dated March 27, 1978 (13 ]
on behalf of Donald C. Cook Nuclear Plant Units 1 and 2. This proposal also included the ODCM (14] . In the RETS submittal, the Licensee closely followed the mcdel RETS format (NUREG-0472) for PWRs. In an initial evaluation by the l Franklin Reseach Center (FRC) , an independent review team, the Licensee's RETS and ODCM submittals were compared with the model RETS (NUREG-0472, Revision 2) i and assessed for compliance with the stipulated requirements. Copies of the draf t review, dated March 30, 1982 (15, 16), were delivered to the NRC and the Licensee prior to a site visit by the reviewers.
The site visit was conducted on April 27-28, 1982 by representatives of the NRC, the reviewers, and the Licensee. Discussions focused on the initial review of the proposed changes to the RETS and on the technical requirements for an ODCM. The deficiencies in the Licensee's proposed RETS were considered, deviations from NRC requirements were pointed out, many differences were clarified, and only a few items remained unresolved, pending justification by the Licensee. These issues are summarized in Reference 17.
On July 30, 1982, the Licensee's revised RETS proposal (18] and ODCM (19 ]
were received for review. On August 9,1982, a telephone conference took place involving NRC, IMEC, and independent reviewers of FRC to discuss the i
TER-C5506-89/90 4
response to IMEC's resubmittal. A summary of that telephone conference was d I forwarded to the NRC and IMEC on August 12, 1982.
The final versions of the Donald C. Cook Nuclear Plant RETS [20] and ODCM
[21] were submitted to Che NRC on September 17, 1982. Copies of the submittal were transmitted to the FRC reviewers on September 23, 1932. Final evaluation of both documents was detailed in the comparison copies [22, 23] which used the draf t version of tiUREG-0472, Revision 3 [12] to evaluate the Licensee's submittal.
q 5
l l
i l
l 1
! I i
i
TER-C5506-89/90 .
'l 1
- 2. REVIEW CRITERIA Review criteria for the RETS and ODCM were provided by the NRC in three documents:
NUREG-0472, RETS for FARs NUREG-0473, RETS for BWas NUREG-0133, Preparation of RETS for Nuclear Power Plants.
Tselve essential criteria are given for the RETS and ODCM:
- 1. All significant releases of radioactivity shall be controlled and monitored.
- 2. Offsite concentrations of radioactivity shall not exceed the 10CFR20, Appendix B, Table II limits.
- 3. Offsite doses of radioactivity shall be ALARA.
- 4. Equipment shall be maintained and used to keep offsite doses ALARA.
S.
Radwaste tank inventories shall be limited so that failures will 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-ase census, shall be implemented.
- 9. The radwaste management program shall be subject to regular audits and reviews.
- 10. Procedures for control of liquid and gastous 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.
_c_
D
--.. FrankJin hserch Center e m man.r.- ,m.v.
4 TER-C5506-89/90 j 4
i Subsequent to the publication of NUREG-0472 and NUREG-0473, the NRC staf f '
issued guidelines [24, 25), clarifications [26, 27], and branch positions [28, 29, 30] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS requirements. The NRC branch positions issued since the RETS implementation review began have clarified the model RETS i:tplementation for operating reactors.
The review of the ODCM was based on the following NRC guidelines: Branch Technical Position, " General Content of the Offsite Dose Calculation Manual"
[31]; NUREG-0133 [9); and Regulatory Guide 1.109 [32}. The ODCM format is lef t to the licensee and may be simplified by tables and grid printcuts.
[
4 t
k
! eiw
{ Re
, . .. FurMn,n 43.e search r .,.: o Center
- ,a .
e e
TER-C5506-89/90 !
~5
- 3. TECENICAL EVALUATION I
} 3.1 GENERAL DESCRIPTICN OF RADIOLOGICAL EFFLUENT SYSTEM This section briefly describes the radwaste liquid and gaseous effluent treatment systems, release paths, and control systems installed at Donald C.
Ccok Units 1 and 2.
3.1.1 Racioactive Licuid Ef fluent The liquid waste treatment system for the Donald C. Cook plant is common to both Units 1 and 2 (see Figure 1) . The liquid waste is collected primarily in the clean waste holdup tank (CKHT) and the station drainage waste holdup tank (SDWHT) before being processed by the waste evaporator, which has a capacity of 30 gpm. The processed liquid is stored in two monitor tanks which are sampled before release. 2he release line, i.e. , the radwaste effluent line, has a radiation monitor (R-lS) with alarm and automatic isolation
~
capability.
Each unit has a separate steam generator blowdown line (monitored by R-19), steam generator blowdown treatment line (monitored by R-24) , and service water line (monitored by R-20 and R-28) . Both R-19 and R-24 have the capability of automatic isolation.
l I
All the ef fluent lines described above share a common discharge through i
the tunnels leading to Lake Michigan.
Ef fluent f rom the turbine building sump is discharged separately to an absorption pond in the dune area near the site. This effluent line is monitored by a composite sampler.
i 3.1.2 Radioactive Gaseous Ef fluent The gaseous waste treatment system for the Donald C. Cook plant is also commen to both units (see Figure 2) . The waste gas is collected in waste decay tanks (four tanks per unit) before being discharged to the atmosphere through the auxiliary building vent system. The containment purge, fuel
.. . Franklin Reser-h Center u, a n e rv.:, .-w a f
_ . . . . ~ . . - -
I
,e .
b ya3 a 3b 25 -
e .e., o,e= e .d., _
.J 'n . L.wwe,ry us and,
- d
, i, c4. s ,r.an -
iu 7y Dersy 5. sass I.at '.y
' :r I i
EA g,...,
s, .. .a c s .- A St.sson Dr.ui.
En,i, n. . , _ _ p. em .I _
v arik Unwe I e,d I
+
c, o.
C3.e* Weel hsome n
+ n=+,. r 'I _p rm. J, N 2.'.4 woe ~ aw, ., _S , , , , , ._, .
te.,
g e.
-, c.-.e.
_ r=- i sa .w , m . , . ,
oe I
to a
mee ns n.,
~
n 5.eem O a.e.t. Di.ed.me' X~ R 'O Tee.im.at E.R rel 0 '
'meds as.e ei elser n
S.e.e G.s.es.l., D6eed.ee E te% eat O i n3
.6er.e
. . . eie
. e. e .e.e ,
v ... a ,
n s.,*. n.i- : '
c a.
R 29 e
i, : i.
A rpel.a P.pd c ,,,,.n, %
a D3
- o Figure 1. Liquid Radwaste Treatment Systems, Ef fluent Paths, and A Controls for Donald C. Cook Units 1 and 2 $
o m
8 O2 O
\
w O
- e. ase s
Requen to CVCs Hoadup 4-Tank a e
. . Red 6ahon Monster e
r,3 ' ,6 ven, Ir**' "ce*'
p ;;,[ ,
nom., s,.I.m., -.
,I. c.s comgeso,s -,
ja o='s
- ><a- -> ner.
' a'-----
,s of,ag,;, , 2 t ')
R4.
.rn 4
.#- s . ,.. . s n...d c.s .n.I,,e, N ta, tinits 1 and 2 '
/, n
, .r ch.ms.: Deen Tank vens ;
.: n ce ea ca nd,, .ne .w s-. v.n. ;
ft cae.n som, T.n. ve, :
r sio, sos.,ea v. :
Stat 60n Deannage Tank Vent :
Containanent P rGe >
I l
, Radiation Monitor 4 33 To Aemosphere Gland Seas E.hausi V
3RaJ6eison Monito, RSS A
, To .imosphere Condense, Evacuation $, stem y
sapenate $yslerns tus unlis I and 2 i
$leam Generelos Diondown I3bP To.imosphere Flash Tenk 7 d
t4 J3 Normat To Treatmens A.
u Flash Tank No Gaseous
- S,siem W Reteese o m
c!,
w N
e Figure 2. Gaseous Radwaste Treatment Systems, Effluent Paths, and o Controls for Donald C. Cook Units 1 and 2
_.u.
TER-C5506-89/90 storage vent, and various tank vents also use this vent system. This effluent line has radiation monitors (R-25 and R-26) capable of automatically isolating the releases from the gas decay tanks. Each unit has a separate condenser evacuation offluent line and gland seal exhaust with radiation monitors R-15 >
and R-33, respectively.
d 3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS The evaluation of the Licensee's proposed RETS against the requirements of NUREG-0472 included the following: (1) a review of ir' .mation provided in the Licensee's 1978 submittal (13,14), (2) the resolution of problem areas in that submittal by means of a site visit [15], (3) a review of the Licensee's July 21, 1982 submittal [18, 19), (4) a telephone conference of August 9,1982 to discuss the review, and (5) a review of the Licensee's September 17, 1982 revised submittal (20, 21].
3.2.1 Effluent Instrumentation The objective of the RETS with regard to effluent instrumentation is to ensure that all significant releases of radioactivity are monitored. The RETS require that all effluent monitors be operable and alarm / trip setpoints be determined to ensure that radioactivity levels do not exceed the maximum permissible concentration (MPC) set by 10CFR20. To further ensure that the instrumentation functions properly, surveillance requirements are needed in the specifications. Although the Licensee does not have a monitor for the discharge from the steam generator flash tank (Figure 2), the Licensee has made a commitment to determine the release of iodine-131 via the flash tank vent in accordance with the ODCM, which is considered an acceptable alternative under NUREG-013 3 [9] . The Licensee's proposed RETS submittal thus
{
met all these requirements and t 'us satisfies the intent of NUREG-0472.
I 3.2.2 Concentration and Dose Rates of Ef fluents l
The objective of the RETS with regard to effluent concentrations and dose rates is to ensure that of fsite ef fluent concentrations do not exceed the MPC established by 10CFR20, Appendix B, Table II, Columns 1 and 2. The Licensee 4
.i FranMin Resemch Certer 4 S.as en cd S e F se .rstate
TER-C 5 50 6-8 9/9 0 -
has state.d tha't the concentration of radioactive material will be monitored "at all times," and if the concentration of liquid effluents exceeds the 10CFR20 values, it will be reduced without delay to a value equal to or less than the .vfC specified in 10C!R20.
The monitoring systems are equipped to automatically terminate effluents. Should concentrations be found to exceed the MPC specified in 10CFR20, based on monitoring setpoint values, release rates will be decreased without delay. To demonstrate compliance with gaseous dose-rate limits, the Licensee is using the inhalation pathway for radioiodine and for particulate radioactive material and radionuclides other than noble gases with half-lives greater than 8 days. These provisions satisfy the intent of NUREG-0472.
3.2.3 Of fsite Doses from Ef fluents The objective of the RETS with regard to offsite doses from effluents is to ensure that of fsite doses are kept ALARA, comply with the dose requirements of NUREG-0472, and are in accordance with 10CFR50, Appendix I, and 40CFR190.
The Licensee has made a commitment to (1) meet the quarterly and yearly dose limitations for liquid effluents, per Section 3.11.1.2 (1) ; (2) restrict the air doses for beta and gamma radiation in unres tricted areas as specified in 10CFR50, Appendix I, Section II.B; and (3) maintain the dose level to an individual from release of radiciodine and radioactive particulates within the design objectives of 10CFR50, Appendix I, Section II.C. This satisfies the intent of NUREG-0472.
3.2.4 Ef fluent Treatment The objectives of the RETS with regard to effluent treatment are to ensure that wastes are treated to keep teleases ALARA and to satisfy the requirement for Technical Specifications governing the maintenance and use of radwaste treatment equipment. The Licensee has made a commitment to use dae liquid and gasecus radwaste treatment system when the projected doses averaged over 31 days exceed 25% of the annual dose design objectives, prorated mon thly. This i
.neets the intent of 10CFR50, Appendix I, Section II.D. The Licensee has also y } J-- 2nd.D Ee593rCh CeTer j A Nim c4 N As.v .-v v,
TER-C550 6-89/90 j t
i made a commitment to project the monthly dose in accordance with the surveillance requirements of NUREG-0472. This meets the intent o f NURIG-0472.
3.2.5 Tank Inventory Limits The objective of the RETS with regard to tank inventory limits is to ensure that the rupture of a radwaste tank would not cause offsite doses greater dann dae limits set in 10CFR20 for non-occupational exposure. The Licensee has put a curie limit on all outside liquid tanks and has made a commitment to perform surveillance. For liquid holdup tanks, this limit excludes tritium and dissolved or entrained noble gases. For gas storage tanks, a curie limit has been set for noble gases. The Licensee's commitment to comply with tank inventory limits has satisfied the intent of NUREG-0472.
3.2.6 Exolosive Gas Mixtures -
The objective of the RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in waste gas systems. The Licensee has made a commitment to maintain a safe concentration of oxygen in the waste gas holdap system by a constant 02 m nitoring using a minimum of two channels.
However, the plant has only one instead of the two hydrogen monitors required in NUREG-0472, Table 3-3.13, Section 2B, for systems not designed to withstand a hydrogen explosion. In accordance with the Branch Position, the present monitoring system is acceptable on an interim basis, .as discussed with the Licensee at the site visit of April 27-29, 1982.
3.2.7 Solid Radwaste System The objective of the RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged before it is shipped to the burial site. Specificatio'n 3.11.3 of NUREG-0472 requires the Licensee to establish a Process Control Program (PCP) , er the equivalent, to show compliance with this objective. The Licensee has made a commitment to implement such a program, thus providing assurance that the requirements of 10CFR20 and 10CFR71 would be met.
gp .; FranWin Resench Cemer
% ,an r..w.eev..o
A TER-C550 6-39/9 0 F; 1
a i 3.2.8 Radiolocical Environmental Monitorina Procram The objectives of the RETS with regard to environmental monitoring are to t' ensure that an adequate and full-area-coverage environmental monitoring program exists and diat the 10CFR50, Appendix I requirements for technical specifica- ,
tions on environmental monitoring are satisfied. The Licensee has followed .
NUREG-0472 requirements, including the Branch Technical Position dated November 1979. Since the Licensee's land sectors cover only about one half :
j the entire meteorological sectors at the site, the proposed 23 TLD locations satisfy the intent of the Branch Technical Position, which calls for a total ,
of 40 TLD locations if the entire sectors are covered by land. The Licensee's methods of analysis and maintena ce of yearly records satisfy the requirements and meet the intent of 10CFR50, Appendix I. The specification for the land use census satisfies the requirements of Section 3.12.2 of NUREG-0472 by providing for an annual census in the specified areas; The Licensee participates in an interlaboratory comparison program approved by the NRC and reports the results in the Annual Radiological Environmental Operating Report, which also meets the requirements of NUREG-0472.
3.2.9 Audits and Reviews The objective of the RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring programs are properly conducted. The Licensee's administrative structure designates the Plant Nuclear Safety Raview Committee (PNS RC) and bbclear Safety and Design Review Committee (NSDRC) as the two groups responsible for the review and audit of the radiological environmental monitoring program, the ODCM, and the PCP. The proposed quality assuran _
(QA) program has met the criteria of 10CFR50, Appendix B, and, specifically, the requirements of Regulatory Guides
. 1.21 and 4.1. The PNSRC is responsible for auditing those four programs as of ten as or core of ten than required under NUREG-0472. The NSDRC is responsible for a review of every unplanned release of radioactive material, to include an event description, remedial action to prevent recurrence, and cor rective action. The NSDRC also reviews any changes to the ODCM and the PCP.
~ 13 ~
4x ---
- v. . Frr-J, Ras arch Center u ,nr, ,-
11111111-4 d
. TER-C550 6-89/9 0 '
l
! I 1
4 3.2.10 Procedures ; ,
I The objective of the RETS with regard to procedures is to establish a !
requirement for implementing the ODCM, the PCP, and the QA program. The Licensee has cocmitted to establish, implement, and maintain written i
procedures for the PCP, ODCM, and QA program. l 3.2.11 Re ports The objective of the RETS with regard to reports is to ensure that appro-priate periodic and special reports are submitted to the NRC, and that these reports meet the requirements of 10CFR50.36a. The Licensee has made a commit-ment to issue annual, semiannual, and monthly reports as required under g Sections 6.9.1.7, 6.9.1.9, and 6.9.1.10, respectively, of NUREG-0472, Rev. 2 (1], as well as special reports (Prcept tbtification) under Section 6.9.1.12 when (1) offsite releases exceed the limits specified under paragraphs 3.11.1.1 and 3.11.2.1 of NUREG-0472 and (2) inventory limits for the storage tanks have exceeded those listed under Sections 3.11.1.4 and 3.11.2.6 of NUREG-0472, Rev. 2 (1] . The Licensee has also made a commitment to submit a I
special report in Section 6.9.2 for pertinent sections referenced in the Technical Specifications, which satisfies the requirements of the Model RETS.
3.3 OFFSITE DOSE CALCULATION MANUAL (ODCM)
As required by NUREG-0472, the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the effluent system. As a minimum, it is required ,
that the ODCM provide equations and methcdology for the follcwing topics:
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 o liquid and gaseous effluent dose contributions o liquid and gaseous effluent dose projections.
I
. . . F.r uR a. R u,n:- h Cen* e -
TER-C550 6-89/9 0 In addition, flow diagrams defining the treatment paths and the I components of the radioactive liquid, gaseous, and solid waste management systems are required and reviewed for consistency against the system being used at the station. A description and location of samples in support of the environmental monitoring program are also required in the ODCM.
3.3.1 Ev alua tion The Licensee has followed the methodology of NUREG-0133 to determine the alarm and trip setpoints for the liquid and gaseous ef fluent monitors. A conservative factor is used for the setpoints, which ensures that the maximum permissible concen tration (Z?C) will not be exceeded even in the case of
' simultaneous ef fluent releases. The Licensee demonstrated the methodology of
! calculating the liquid concentration by describing in the ODCM the means of collecting and analyzing representative samplas. To waive the requirement of a radiation monitor at the steam generator blowdown flash tank vent, the Licensee has adopted me thodology suggested by NUREG-0133 to estimate the release of iodine-131 during the discharge.
The dose rate at or beyond the site boundary due to gaseous effluent release is in compliance with 10CFR20. Gaseous effluents are released from three release points for which the Licensee uses conservative values of relative concen tration (X /Q) and relative deposition (D/Q) for average a tmospheric dispersion conditions. For each of the three release points, as described in the Donald C. Cook ODCM, the highest site boundary X/Q values for each release point are used in conjunction with the radionuclide mix and release rate to determine the controlling location. The Licensee has identified the receptor age, location, and critical organ for dose-rate determination. The Licensee has also considered inhalation, ground-plane, and cow- and goat-milk pathways in the calculations, although only the inhalation pathway is necessary. It has been demonstrated by the Licensee that conservative values were used in the calculations.
The dose evaluation for pathways associated with the release of radioactive material in liquid ef fluents is based on the maximally exposed l
I i j, gm2 s
.. J Ftr'lin R . mh Cer.sr L
. TER-C5506-89/90 .
individual. Dose contributions are calculated once per 31 days. The Licensee has taken a conservative approach to the methodology for dose factors by incorporating a far-field dilution factor well below the total dilution factor.
Evaluation of ncble gases released to the atmosphere includes both beta cnd gamma air doses at the site boundary and total body and skin doses at the residence receiving the highest dose.
For radiciodine and radioa,tive particulates, the Licensee has demon-ctrated that the method used in the ODCM for calculating releases to unrestricted areas meets the design objective of maintaining an annual dose or dose commitment not to exceed 15 mrem to any organ of the maximally exposed I
individual. The Licensee has demonstrated the method of calculating the dose using X/Q values for the inhalation pathway and has included D/Q values for the food and ground-plane pathways. In determining the tritium dose, the parameter for dispersion was based on the food pathway using the same X/Q values. The ground-plane pathway ic not appropciate for tritium.
The Licensee has made a commitment to perform dose projections for both liquid and gaseous effluent releases once every 31 days to determine the use of appropriate portions of the radwaste system.
The flow diagrams defining the treatment paths and components of the radioactive liquid, gaseous, and solid waste management systems are adequately provided by the Licensee in the submitted RSTS.
The Licensee has provided a complete description of sampling locations in the ODCM in Figures IV-1 through IV-3. This description is consistent with the sampling locations specified in the Licensee's 'RETS Table 3.12-1 on environmental monitoring. Table IV-1 in the Lice 1see's ODCM tabulates the cite number identification, sector location, distance from station center, and sample type description, and covers all of the committed sampling exposure pa thways in accordance with the Licensee's Table 3.12-1, RETS Environmental Monitoring Program.
-dCf33
...) FraWn Rese rch Cerwr 4:. r- c. . .
n TER-C5506-39/90 .
! I
- 4. CONCLUSIONS Table 1 surmarizes the results of the final review and evaluation of the Conald C. Cook Nuclear Plant Units 1 and 2 proposed Radiological Effluent Technical Specifications (RETS) . The following conclusions have been reached: '
- l. The Licensee's proposed RETS meets the intent of the NRC staff's current standard, " Rad' alogical Ef fluen,t Technical Specifications," i NUREG-0 47 2.
l l
- 2. The Licensee's Of fsite Dose Calculation Manual (ODCM) uses documented l and approved methods that are consistent with the criteria of NUREG-013 3.
Ii A?E2
...J Frank:- ,n-R mrch C<mNr c e .
l, Table 1. Evaluation of Progosed Radiological Ef fluent Specifications (RETS), Donald C. Cook Unita 1 and 2 11-$
?> Cnli[j; Technical Specifications
'O NIC Staf f h> del Replaces or Updates
[I]
j pg RETS NUREG-0472 Licensee Proposal Existing Tech. Spec.
RETS Pequirceent (Section)* (Section) (Section) Evaluation 10 31 Ef fluent Instrumentation 3/4.3.3.9, 3/4.3.3.10 3/4.3.3.9, 3/4.3.3.10 2.1.1, 2.1.3 (Appendix n)
?3 Meets the intent 2 ;r 2.1.2, 2.1.4 of NIC criteria
- k) Radioac t iv e Effluents 3/4.11.1.1, 3/4.11.2.1 3/4.11.1.1, 3/4.11.2.1 2.1.1, 2.1.3 (Appendix B) Meets the intent 2 !!
4 of NIC criteria of fsite Doses 3/4.11.1.2, 3/4.11.2.2, 3/4.11.1.2, 3/4.11.2.2, 2.1 (Appendia B) Meets the intent 3/4.11.2.3, 3/4.11.4 3/4.11.2.3, 3/4.11.4 of HRC criteria Effluent Treatment 3/4.11.1.3, 3/4.11.2.4 3/4.11.1.3, 3/4.11.2.4 2.1.1, 2.1.3 (Appendix B) Meets the intent of NHC criteria Tank Inventory Limits 3/4.11.1.4, 3/4.11.2.6 3/4.11.1.4, 3/4.11.2.6 2.1.1, 2.1.3 ( Appendix B) Meets the intent i of Nhc criteria H
c) Explosive cas Mixtures 3/4.11.2.5 3/4.11.2.5 e 3/4.6.4 Heets the intent of NHC criteria in the interim Solid Radioactive waste 3/4.11.3 3/4.11.3 2.1.5 (Appendix B) Meets the intent of NRL criteria Environmental Monitoring 3/4.12.1 3/4.12.1 3.1 (Appendix B) Meets the intent of NHC criteria Audit and Review 6.5.1, 6.5.2 6.5.4.7, 6.5.4.8 6.5.1, 6.5.2 Meets the intent of NHC cr iteria Pr uentu r e s 6.8 6.8 6.8 Meets the intent ,
of HNC cr iteria Repor ts and Records 6.9.1.6 - 6.9.1.9 6.9.1.6 - 6.9.1.9 3.1.A, 3.1.B. (Appendix B) Meets the intent >3 6.9.1.12, 6.9.1.13 6.9.1.12, 6.9.1.13 6.9.1.8, 6.9 1.9, 6.9.2, of Nhc criteria h}
6.9.2, 6.10.2 6.9.2, 6.10.2 6.10.2
/
w w
o Section nund>ering sequence is according to NUREG-0472 m Rev. 2 (1) . j, Ns O
.mm, mown ee- ---
. as.. s .
c TER-C5506-89/90 I
A
- 5. REFERENCES
- 1. " Radiological Ef fluent Technical Specifications for Pressurized Water Reactors," Rev. 2 lt NRC, July 1979 i NUREG-047 2
- 2. Title 10, Code of Federal Regulations, Part 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, ' As Low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents"
- 3. Title 10, Code of Federal Regulations, Part 50, Appendix I,Section V,
" Effective Dates"
- 4. Title 10, Code of Federal Regulations, Part 20, "Jtandards for Protection Against Radiation"
- 5. Title 40, Code of Federal Regulations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations"
- 6. Title 10, Code of Federal Regulations, Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants"
- 7. Title 10, Code of Federal Regulations, Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Puel Reprocessing Plants"
- 8. " Radiological Ef fluent Technical Specifications for Boiling Water Reactors," Rev. 2 NRC, July 1979 NUREG-0473
- 9. " Preparation of Radiological Ef fluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Itchnical Specifications" NRC, October 1978 NUREG-0133
- 10. C. Willis and F. Congel (NRC)
" Summary of Draf t Contractor Guidance of RETS" Presented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19, 1982
- 11. F. Congel (NRC)
Mema to RA3 Staff (NRC)
Subject:
Interim Changes in the Model Radiological Effluent Technical Specifications (RETS) l August 9, 1982 l
4 'b mJ Fun' Re a t-. . Jn. s.w.3rch Cerar
i 1
TER-C5506-89/90 j
> ,1
- 12. " Radiological Ef fluent Tuchnical Specifications for Pressurized Water ! i Reactors," Rev. 3, Draf t 7, intended for contractor guidance in reviewing !
RETS proposal for operating reactors j .
NRC, September 1979 .
I !
- 13. Radiological Effluent Technical Specifications Donald C. Cook Nuclear Plant Units 1 and 2 Indiana and Michigan Power Company, March 27, 1978 NRC Docke t Ibs. 50-315, 50-316
- 14. Of fsite Dose Calculation Manual Donald C. Cook Nuclear Plant Units 1 and 2 Indiana and Michigan Power Company, March 27, 1978 ERC Docket Ibs. 50-315, 50-316
- 15. Comparison of Specification NdREG-0472, Radiological Ef fluent Technical 3pecifications for PNRs, vs. Licensee Submittal of Radiological Ef fluent Technical Specifications for Donald C. Cook Nuclear Plant Units 1 and 2" (Draf t)
Franklin Research Center, March 30, 1982 -
- 16. Tbchnical Review of Of fsite Dose Calculation Manual for Donald C. Cook Units 1 and 2 (Draf t) '
Franklin Research Center, March 30, 1982
- 17. Franklin Research Center Letter of Transmittal to NRC
Subject:
Trip report on site visit to Donald C. Cook Nuclear Plant April 27, 1982 ,
- 18. Radiological Ef fluent Technical Specifications (RETS)
Donald C. Cook Nuclear Plant Units 1 and 2 July 21, 1982 I NRC Docket Nos. 50-315, 50-316
- 19. Of fsite Dose Calculation Manual (ODCM) I I
Donald C. Cook Nuclear Plant Units 1 and 2 July 21, 1982 NRC Docket Nos. 50-315, 50-316
- 20. Radiological Ef fluent Technical Specifications (RETS)
Donald C. Cook Nuclear Plant Units 1 and 2 September 17, 1982 NRC Dccket !bs. 50-315, 50-316 f
- 21. Of fsite Dose Calculation Manual (ODCM)
Donald C. Cook Nuclear Plant Units 1 and 2 September 17, 1982 NRC Decket Nos. 50-315, 50-316 u.u Fruhl;n,
- c. ,
%e tch, C*r.Nr w,<.. , re . !
l l
TER-C5506-89/90 j I
- 22. " Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs, vs. Licensee Submittal of Radiological Ef fluent Technical Specifications for Donald C. Cook Nuclear Plant Units 1 and 2" Franklin Research' Center, September 27, 1982
- 23. " Technical Review of Plant Of fsite Dose Calculation Manual for Donald C.
Cook Nuclear Plant Units 1 and 2" Franklin Research Center, September 27, 1982
- 24. C. Willis (NRC)
Letter to Dr. S. Pandey (FRC)
Subject:
Changes to RETS requirements following meeting with Atomic Industrial Forum (AIF)
November 20, 1981
- 25. C. Willis (NRC)
Letter to Dr. S. Pandey (FRC)
Subject:
Control of explosive gas mixture in PWRs December 18, 1981
- 26. C. Willis and F. Congel (NRC)~
" Status of NRC Radiological Effluent Technical Specification Activities" Presented at the AIF Conference on NEPA and Nuclear Regulations, Wa shing ton, D.C. ,
October 4-7, 1981
- 27. C. Willis (NRC) k Memo to P. C. Wagner (NRC)
" Plan for Implementation of RETS for Operating Reactors" November 4, 1981
- 28. W. P. Gammill (NRC)
Memo to P. C. Wagner (NRC) '
" Current Position on Radiological Ef fluent Technical Specifications (RETS) Including 7'cplosive Gas Controls" October 7, 1981
- 29. "An Acceptable Radiological Environmental Monitoring Program" Branch Technical Position November 1979
N RC , February 1980 l NU REG-0 54 3
- 31. " General Contents of the Of fsite Dese Calculation Manual," Revision 1 Branch Technical Position, Radiological Assessment Branch February 8, 1979
~ ~
-fE :s I
. .'pr'!HRpar-SCerte
TER-C5506-89/90 :
1
- 32. Calculation of -Annual Doses to Man from Routine Releases of Reactor
- Ef fluent's for the Purpose of Evaluating Corapliance with 10CFR50, Appendix I NRC, October 1977 Regulatory Guide 1.109 I
I I
i I
?
I 4, ,
J.sj Fran'Jn Nearch Cenar a c ,, , , t r , r ., . , 9 .,