ML20072B114
| ML20072B114 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/03/1983 |
| From: | Cassell A, Pandey S Franklin Research Ctr |
| To: | Congel F, Willis C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20072B118 | List: |
| References | |
| CON-NRC-03-81-130, TAC 8132 TER-C5506-83, NUDOCS 8302090288 | |
| Download: ML20072B114 (31) | |
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TECHNICAL EVALUATION REPORT l
l RADIOLOGICAL EFFLUENT TECHNICAL I
SPECIFICATION IMPLEMENTATION (A-2) i DUSQUESNE LIGHT COMPANY BEAVER VALLEY POWER STATION UNIT 1
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l NRC DOCKET NO. 50-334 FRC PROJECT C5506
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2 NRC CONTRACT NO. NRC-03-81-130 FRC TASK 83 Prepared by Frank!!n Research Center Author:
A. J. Cassell 20th and Race Streets Philadelphia, PA 19103 FRC Group i.eader:
S. Pandey Precared for Nuclear Regulatory Comtnission Wasnington, D.C. 20555 Lead NRC Enginest:
F. Congel, C. Willis February 3, 1983 This report was prepared as an account of work sponsored by an egency of the United States Government. Neither the United States Government nor any agency thereof, or any of tr:cir employees. makes any warranty, expressed or implied. or assumes any legal liability or responsibility for any third party's use, or the results of sucn use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use oy suen :nirr$
party would not inf ringe privateiy owned rights.
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o TECHNICAL EVALUATION REPORT I
! RADIOLOGICAL EFFLUENT TECHNICAL
{ SPECIFICATION IMPLEMNNTATION (A-2) i DUSQUESNE LIGHT COMPANY l
BEAVER VALLEY POWER STATION UNIT 1 I
NRC DOCKETNO. 50-334 FRC PROJECT C5506 NRC TAC NO. 8132 FRC ASSIGNMENT 4 NRC CONTRACT NO. NRC-03-81-130 FRC TASK 83 Prepared by Franklin Research Center Author:
A. J. Cassell 20th and Race Streets Philadelphia, PA 19103 FRC Group Leader:
S. Pandey Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer:
F. Congel, C. Willis February 3, 1983 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 a,1y 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:
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TER-C5506-83 CONTENTS Section Title Page 1
INTRODUCTION 1
1.1 Purpose of Review.
1 1.2 Generic Background.
1 1.3 Plant-Specific Background.
-,3 2
REVIEN CRITERIA.
5 3
TECHNICAL EVALUATION 7
3.1 General Description of Radiological Effluent System 7
3.2 Radiological Effluent Technical Specifications.
12 3.3 Offsite Dose Calculation Manual 18 4
CONCLUSIONS.
21 5
REFERENCES.
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FIGURES Number Title Page 1
Liquid Effluent Discharge Points - Beaver Valley Power Station 8
2 Radioactive Liquid Waste Pr6 cessing System - Beaver Valley Power Station 9
3 Radioactive Gaseous Release Points - Beaver Valley Power Station 10 4
Radioactive Gaseous Waste Processing System -
- Beaver Valley Power Station.
11 TABLE Nurnber Eitle Page 1
Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Beaver Valley
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I TER-C5506-83 FOREWORD 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 NRC operating reactor licensing actions. The technical evaluation was con' ducted in accordance with criteria established by the NRC.
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INTRODUCTION 1.1 PURPOSE OF REVIEW The purpose of this technical evaluation report (TER) is to review and evaluate the, proposed chahges in the Technical Specifications of Beaver Valley Power Station 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 (PWRs), 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 (10CFR50), " Domestic Licensing of Production and Utilization Facilities," Appendix I (2]. Other regulations pertinent to the control of effluent rele.ases are also included within the scope of compliance.
1.2 GENERIC BACKGROUND Since 1970,10CFR50, Section 50.36a, " Technical Specifications,on Effluents from Nuclear Power Reactors," has required licensees to provide technical specifications w'nich ensure that radioactive releases will be kept as low as reasonably achievable (ALARA).
In 1975, numerical guidance for the ALARA requirement 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 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 also includes provisions for addressing other issues.
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TER-C5506-83 1.
i These other issues are specifically stipulated by the following regulations:
10CFR20 [4], " Standards for Protection Against Radiation,"_ Paragraphs o
i 20.105 (c), 20.106 (g), and 20.405 (c) require that nuclear power plants i
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.
10CFR50, Appendix A [6], " General Design Criteria for Nuclear Power o
Plants," contains Criterion 60 - Control of releases of radioactive materials to the environments criterion 63 - Monitoring fuel and waste storage; and Criterion 64 - Monitoring radioactivity releases.
10CFR50, Appendix B [7], establishes the quality assurance required o
for nuclear power plants.
The current NBC position on the model RETS was established in May 1978 l
when the NRC's Regulatory Requirements Review Connaittee approved the model RETS: NUREG-0472 for PWRs [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.
j Licensees responded with requests for clarifi:ations and extensions.
I The Atomic Industrial Forum (AIF) formed a task. force to comment on the model RETS.
NBC staff members first met with the AIF task force on June 17, 1978.
The model RETS was subsequently revised to reflect comments from the t.
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.
Pour regional seminars on the RETS were conducted by the NBC staff during November and December 1978. Subsequently, Revision 2 of the model RETS snd l
addl lonal 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 MRC's request, operation reactor licensees subsequently submitted initial proposals on plant RETS and the ODCM. Review leading to ultimate l'
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TER-C5506-83 implementation of these documents was initiated by the NRC in 1981 using subcontracted independent teams as reviewers.
As the RETS review process has progressed since September 1981, feedback from the licensees has led the NBC to. believe that modification to some of the guidelines in the current sersion of Revision 2 is needed to clarify specific concerns of the licensees and thus expedite the entire review process.
Starting in April 1982, NRC distributed revised versions of RETS in draft form to the licensees during the site visits. The new guidance on these changes
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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, the NRC issued in September 1982, 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 conformance with the 1975 directive [3], Duquesne Light Company (DLC),
l the Licensee of Beaver Valley Power Station Unit 1, submitted "Information for
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10CFR50, Appendix I Evaluation," dated June 4, 1976 [13], which was followed by four updates [14-17] through 1977. These submittals showed the capability for compliance witn Appendix I, but did not propose a new RETS.
The RETS was addressed in the next submittal by the Licensee to the NRC, dated March 15, 1979 and revised April 6,1979 [18], which was in response to the November 15-16, 1978 NBC request. This icWaittal followed the format of NUREG-0472 for PWRs. On August 3,1981 FrM11n Research Center (FRC),
3 selected as an independent task revlaw team, initiated a review and evaluation of the revised March 15, 1979 submittal. The submittal was compared with the model RETS [1] and assessed for compliance with the requirements of 10CFR50, Appendix I.
A draft review report, dated September 18, 1981 [19), was prepared and delivered to tne NRC and the Licensee prior to a site visit. The site visit was arranged for the purpose of discussing and resolving questions raised in the draft review report.
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.o TER-C5506-83 During the site visit, the Licensee presented an updated proposed RETS
[21] which, together with technical discussions, resolved many of the issues identified in the draf t review report. A trip report [22] was prepared and delivered to the NBC following the site visit.
On December 7,1981, the Licensee's revised RETS proposal [23] was received by the review team. On December 29, 1981, a telephone conference
[24] took place involving NRC, FRC, and Licensee representatives to discuss FRC's response to the Licensee's resubmittal.
A corrected draf t of the Beaver Valley Power Station RETS [25] was received by the review team on April 27, 1982. The submittal was reviewed, and on May 6,1982, all of the open items were resolved in a telephone conference call with the Licensee [26].
On June 28, 1982, the Licensee issued another draf t copy of the RETS
[27), which incorporated draf t NUREG-0472 Revision 3 guidelines [28]. The draft RETS copy was reviewed to evaluate changes affecting the April 7,1982 submittal.
The final submittal of the proposed RETS for the Beaver Valley Power Station, to amend Operating License DPR-66 RETS, was dated October 22, 1982 (29]. Final comparison of this document was detailed in the comparison report
[30] which used the draf t version of NUREG-0472, Revision 3 (12] to evaluate the Licensee's submittal.
The proposed ODCM, suomitted by the Licensee with the proposed RETS, was reviewed in conjunction,with the RETS review. A technical review comparison
[19] was delivered to the Licensee and the NRC,in order to resolve the problem l
areas in the ODCM.
Resolution of the problems was to be conducted at a site j
meeting [20]. An updated ODCM dated May 1982 [27] was received by the review l
teams following review of the submittal, the Licensee was contacted in order to resolve two minor problems. Final submittal [31] of the ODCM was received, reviewed, and found to be satisfactory.
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TER-C5506-83 2.
REVIEW CRITERIA Review criteria for the RETS and ODCM were provided by the NRC in three documents:
NUREG-0472, RETS for PWRs NUREG-0473, RETS for BWRs NUREG-0133, Preparation of RETS for Nuclear Power Plants.
Twelve 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 snall be ALARA.
4.
Equipment shall be maintained and used to keep offsite doses ALARA.
5.
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-use census, shall be implemented.
9.
The 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.
Of fsite dose calculations shall be performed using documented and approved me thods cc nsistent with NRC methocology.
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TER-C5506-83 4
Subsequent to the publication of NUREG-0472 and NUREG-0473, the NBC staff issued guidelines [31, 33], clarifications [34, 35], and branch positions [36, 37, 38] establishing a policy that requires the licensees of operating reactor.s to meet the intent, if not the letter, of th'e model RETS guidelines. The NRC branch positions issued since the RETS implementation review began have clarified the model RETS implementation 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" (39]; NUREG-0133 [9]; and Regulatory Guide 1.109 [40]. The ODCM forma't is left to the licensee and may be simplified by tables and grid printouts.
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i TER-C5506-83 1
- 3., TECHNICAL EVALUATION 3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEM This section briefly describes the radwaste liquid and gaseous of fluent treatment systems, release paths, and control systems installed at Beaver Valley Power Station.
3.1.1 Radioactive Liquid Ef fluent The majority of water required for the operation of Beaver Valley Unit 1 is taken from Ohio River and returned to the river, evaporated, consumed by the station personnel, or discharged to a septic tank.
Small amounts of well water and liquid effluent are discharged to the Ohio River.
Flow diagrams showing discharge points, flow paths, holdup tanks, test tanks, filtering systemE, and monitoring stations are presented as Figures 1 and 2.
The system is designed so that all liquid effluent release points are monitored, using systems which have automatic isolation capability. The radioactive liquid effluent discharged to the cooling tower blowdown line is monitored by radiation monitors RW-LW-104 and RW-LW-ll6.
3.1.2 Radioactive Gaseous Effluents The gaseous effluent discharge points are shown in Figure 3.
The discharge points are the process vent, an elevated release, located at the top of the cooling tower; the ventilation vent located on top of the auxiliary building; and the containment vent located on top of the containment building, providing ground and mixed-mode releases. All of these release points are continuously monitored.
Radiation monitors GW-108A and B automatically isolate the process vent if the monitors detect a high level of radioactivity. Figure 4 depicts the gaseous radwaste processing system at the Beaver Valley plant.
As shown in Figure 4, the only (elevated) release point for gaseous effluents is through the cooling tower process vent. The three decay holdup tanks have sufficient capacity to contain the gaseous radioactive effluents in the waste processing system, under normal operation. The other release points are As ONnklin,w,_ arch Center Rese n.-
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Radioactive Gaseous Release Points - Beaver Valley Power Station
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Radioactive Gaseous Waste Processing System -
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TER-C5506-83 monitored by RM-VS-101A and B, auxiliary building ventilation. system monitors, and RM-VS-107A and B, reactor building / supplementary leak collection and release system monitors.
3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS The evaluation of the Licensee's proposed RETS against the provisions of NUREG-0472 included the followings (1) a review of information provided in the Licensee's March 15, 1979 (revised April 6,1979) submittal (18], (2) the resolution of problem areas in that submittal when compared to NUREG-0472 by means of a site visit (20], (3) a review of the Licensee's November 25, 1981 submittal [22], (4) a telephone conference on December 29, 1981 (24], (5) review of the Licensee's draf t final RETS dated April 7,1982 (25], (6) resolution of two problem areas following a draf t final review via a telephone conference call on May 6,1982 (26], and (7) the final submittal of the Beaver Valley RETS dated October 22, 1982 (29].
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.
3.2.1.1 Radioactive Liquid Effluent Monitoring Instrumentation The Licensee has provided radiation monitors with automatic isolation capabilities for major liquid effluent lines.
For less important effluent i
lines, such as the steam generator blowdown line and turbine building sump, l
the Licensee has made a commitment to use a grab sample program in lieu of the l
radiation monitors. This action was agreed to by the NRC staff at the site l*
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TER-C5506-83 visit.
It is thus determined that the Licensee's proposal on liquid effluent monitoring instrumentation has satisfied the intent of NUREG-0472 [1.- 12].
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3.2.1.2 Radioactive Gaseous Effluent Monitoring Instrumentation Since all gaseous effluents are routed to the environment through the process vent stack, auxiliary vent, and containment vent, where radiation monitors are installed, the substreams of these release points are not required to be equipped with radiation monitors. The stack monitor, according to the Licensee, prev' ides both an alarm and automatic isolation of d2e, major effluent
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stream if the prescribed release limit is reached. The Licensee provided this information at the site meeting and also stated in the RETS that existing area monitors and process monitors are capable of identifying the contamination and that corrective actions will be taken to mitigate the release should high level radiation be detected. Supported by the plant's historically low release record, the Licensee's proposed specifications on monitoring instrumentation were accepted by the NRC staff as meeting the intent of NUREG-0472.
3.2.2 Concentration and Dose Ra tes of Ef fluents 3.2.2.1 Liquid Ef fluent Concentration In Section 3.11.1.1 of the Licensee's submittal, a commitment is,made to maintain the concentration of radioactive liquid effluents released from the site to within 10CFR20 limits at all times, and if the concentration of liquid effluents exceeds these limits, the concentration will be reduced immediately to a value equal to or less than the MPC specified in 10CFR20. All batches of radioactive liquid effluents from the waste test tanks are sampled and analyzed in accordance with a sampling and analysis program which ' meets the intent of NUREG-0472.
The liquid radwaste effluent line monitor is provided with both an alarm and automatic termination of release capability to prevent the release of liquid effluents with a high concentration of radioactive material. This also meets the intent of NUREG-0472.
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TER-C5506-83 3.2.2.2 Gaseous Effluent Dose Rate In Section 3.11.2 of the Licensee's submittal, a commitment is made to
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maintain the offsite dose rate from radioactive gaseous effluents to within 10CFR20 limits at all times, and if the concentration of gaseous effluents exceeds these limits, the concentration will be reduced immediately to a value equal to or less than these limits. The offsite dose rate limits used ares a.
500 mrea/yr (total body) and 3000 meen/yr (skin) for noble gases b.
1500 meenVyr (any organ) for inhalation of iodine-131, iodine-133, tritium, and particulates with half-lives greater than 8 days.
The radioactive gaseous waste sampling and analysis program (Table 4.11-2 i
of the Licensee's submittal) provides adequate sampling and analysis of the i
process vent, the containment vent, and the auxiliary building vent, and therefore meets the intent of NUREG-0472.
3.2.3 offsite Doses from Ef fluents The objective of the RETS with regard to offsite doses from effluents is to ensure that offaite doses are kept ALARA 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 II.A of Appendix I,10CFR50; (2) restrict the air doses for beta and gamma radiation in unrestricted areas as specified in 10CFR50, Appendix I, Section'II.B; (3) maintain the dose level to a member of the public from I
release of iodine-131, iodine-133, tritium, and radioactive particulates with j
half lives greater than 8 days within the design objectives of 10CFR50,
)
Appendix I,Section II.C; and (4) limit the annual dose from the facility releases to a member of the public within the requirements of 40CFR190.
In l
each pertinent section, the Licensee has made a commitment to perform dose
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calculations in accordance with methods given in the ODCM. This satisfies the intent of NUREG-0472.
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3.2.4 Effluent Treatment The objectives of the RETS with regard to effluent' treatment are to ensure that wastes are treated to keep releases ALARA and to satisfy the requirement 3
for Technical Specifications governing the maintenance and use of radwaste treatment equipment. The Licensee has made a commitment to use the liquid (Section 3.11.1.3) and gaseous (Section 3.11.2.4) radwaste treatment systems when the estimated doses averaged over 31 mays exceed 25% of the annual dose design objectives, prorated monthly. It has been determined that the Licensee's proposal meets the intent of 10CFR50, Appendix I, Section II.D.
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 than the limits set in 10CFR20 for non-occupational exposure. The i
Licensee has set a limit of 10 curies on all outside liquid tanks, including temporary tanks (Section 3.11.1.4), and has made a commitment to perform surveillance. This limit excludes tritium and dissolved or entrained noble gases. For gas storage tanks, a limit of 5.2 x 10 curies has been sec for noble gases (Section 3.11.2.5). The Licensee's commitment to comply with tank inventory limits has satisfied the intent of NUREG-0472.
3.2.6 Explosive 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 (Section 3.11.2.5) to maintain a safe concentration of oxygen in the waste gas holdup system by a constant 02.m nitoring, using two channels (Table 3.3-13, # 4a) as specified by' NUREG-0472. The plant does not have either of the two hydrogen monitors specified in NUREG-0472, Table 3-3.13, Section 2B, for systems not designed to withstand a hydrogen explosion. The Licensee stated the system is hydrogen-enriched and does not fall below 96%
hydrogen enrichment at any time.
In accordance with the NRC staff position,
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TER-C550 6-83 the present monitoring system is acceptable on an' interim basis, as discussed with the Licensee at the site visit.
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. Specification 3.11.3 of NUREG-0472 states that the Licerese should establish a PCP, or the equivalent, to show compliance with this objective. The Licensee has made a commitment (Section 3.11.3) to Jaclude a PCP which will become a part of the station operating procedures.
This meets the intent of NUREG-0472.
3.2.8 Radiological Envircnmental Monitoring Program The objectives of the RETS with regard to environmental monitoring are to ensure that an adequate and full-area-coverage environmental monitoring program exists and that the 10CFR50, Appendix I requirements for technical specifica-tions on environmental monitoring are satisfied. The Licensee has in most cases followed NUREG-0472 guidelines, including the Branch Technical Position for a radiological environmental monitoring program (37] dated November 1979.
The Licensee's methods of analysis and maintenance of yearly records satisfy the requirements and meet the intent of 10CFR50, Appendix I.
The specification for the land use census satisfies the provisions 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 and reports the results in the Annual Radiological Environmental Operating Report; this meets the intent of NUREG-0 472.
3.2.9 Audits and Reviews l
The objective of the RETS with regard to audits and reviews is to ensure i
that audits and reviews of the radwaste and environmental monitoring programs are properly conducted. The Licensee's admin 19'.rative structure designates i
~
l the Of fsite Review Committee (ORC) and Cnsite Safety Commit *ee (OSC) as the j
two groups responsible for the review and audit of the radiological environ-nklin Rese
-_ arch C_ enter l
_ in e
v I
TER-C5506-83 mental monitoring program, the ODCM, the PCP, and the quality assurance (QA) program necessary to meet"'the criteria of Appendix B of 10CFR50. The ORC is responsible for auditing those four programs, with the frequency of review to be equal to or greater than dbat required under NUREG-0472. The OSC is-responsible for reviewing every unplanned release of radioactive material; the review is to include an event description, remedial action to prevent recurrence, and corrective action. The OSC also reviews any changes in the ODCM and the PCP.
3.2.10 Procedures The objective of the RETS with regard to procedures is to establish guidelines for implementing the ODCM, the PCP, and the QA program. The Licensee'has made a commitment to establish, implement, and maintain written procedures for the P;P, the ODCM, and the QA program which meets the intent of NUREG-0472.
3.2.11 Repnets and Records 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.
3.2.11.1 Routine Reportr In Sections 6.9.1.10 and 6.9.1.11 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. The report also includes the results of the land use census required by Specification 3.12.2.
In Section 6.9.1.12 of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent release reports which include a summary of radioactive liquid and gaseous effluents released, meteorological data, an assessment of offsite doses, a summary of radioactive solid waste shipped off-site, and any Licensee-initiated changes to the ODCM.
Major changes to
~. -.
TER-C5506-83 radioactive liquid, gaseous, and solid waste treatment systems are included in the annual 10CFR50.59 report. These reporting commitments meet the provisions -
of NURBG-0472.
3.2.11.2 Non-Routine Reports In Section 6.9.1.8 of the Licensee's submittal, a commitment is made to provide prompt notification with written followup when offsite release rate limits specified in 3.11.1.1 and 3.11.2.1 are exceeded.
In Section 6.9.1.9 of the Licensee's rubmittal, a commitment is made to provide a 30-day written report for each of the following:
An unplanned offsite release exceeding NRC specified limits.
o o Exceeding the curie content limit specified for storage tanks listed in Specifications 3.11.1.4 and 3.11.2.5.
o Measured levels of radioactivity in environmental samples exceeding the reporting level values given in Table 3.12-2.
3.3 OFFSITE DOSE CALCULATION MANUAL (ODCM)
As specified in 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, the ODCM should provide equations and methodology for the following topics:
l o alarm and trip setpoint on effluent instrumenta' tion i
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.
In addition, the ODCM should contain flow diagrams defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems. These diagrams should be consistent with the systems being used at the station. A description and location of samples in support of the environmental monitoring program are a.so needed in the CDCM.
M' Franklin Research Center
)
A Drwman of The Frarmhn msoeute
~
TER-C5506-83 3.3.1 Evaluation
~
The Licensee has followed the methodology of NUREG-0133 to determine the alarm and trip setpoints for the liquid an,d gaseous effluent monitors. A conservative factor of 1/10th the calculated value is used for all the setpoints, which ensures that the MPC limit will be maintained even in the case of simultaneous effluent releases. The Licensee demonstrated the methodology of calculating the liquid concentration by describing in the ODCM the meant of collecting and analyzing representative samples. Continuous releases of liquid effluents do not presently occur at Beaver Valley Unit 1, but if they should occur, the equations for calculating concentrations have been included.
The dose rate at or beyond the site boundary due to gaseous effluent release is calculated in accordance with NUREG-0133. There are three gaseous effluent release points, and conservative value's of relative concentration and relative deposition rates for the average atmospheric dispersion conditions are used by the Licensee. For each of the three release modes, as described in the Beaver Valley Unit 100CM, 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's calculations consider the inhalation, ground plane, cow milk, cloudshine from process vent, and goat milk pathways, although the inhalation pathway is the most significant one.
The Licensee has demonstrated that conservative values have been used in the calculations.
The dose evaluation of pathways associated with the release of
. radioactive material in liquid effluents is based on the maximum exposed individual. The 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 noble gases released to the atmosphere includes both beta i
and gamma air doses at the site boundary and total body and skin doses at the
_nklin Resear_ch _ Center
o TER-C5506-83 nearest residence. For radioiodine and particulates released to the environment, the Licensee has demonstrated that the method used in the ODCM for calculating releases to the unrestricted areas will meet the design objectives for maintaining the annual dose commitment not to exceed 15 mrem to any organ of the maximum exposed individual ~. The Licensee has demonstrated the method used to calculate the dose using X/Q values for the inhalation pathway, the finite plume method for elevated releases (sky shine), and D/Q values for ground plane, cow's milk, and goat's milk pathways.
4 The Licensee has committed to performing dose projections at least once a month for both liquid and gaseous effluent treatment system releases 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 provided by the Licensee in the ODCM. The information supplied is consistent with the Beaver Valley Unit 1 Final Safety Analysis Report.
The Licensee has provided a complete description of sample locations in the ODCM Figures 3.0-l' through 3.0-9.
This description is consistent with the sampling locations specified in the Licensee's RETS Table 3.12-1 on environ-mental monitoring. Table 3.0-1 in the Licensee's ODCM provides the site number identification, sector location, distance from station center, sample point description, sampling and collection frequencies, and type and frequency of analysis. Table 3.0-1 covers all of the Licensee's committed sampling exposure pathways in accordance with the Licensee's Table 3.12-1, RETS Environmental Monitoring Program.
J p branklin Research Center Acum.aaas n. rr.n. n m.m
t TER-C5506-83 4.
CONCLUSIONS Table 1 summarizes the results of the final review and evaluation of the Beaver Valley Power Station proposed Radiological Effluent Technical Specifications (RETS). The following conclusions have been reached:
1.
The Licensee's proposed RETS meets the intent of the NBC staff 's current standard, " Radiological Effluent Technical Specifications,"
2.
The Licensee's Offsite Dose Calculation Manual (ODCM) uses documented and approved methods that are consistent with the criteria of NUREG-013 3.
~ A Udd Franklin Research Center a c on n. Fr.non ww.
Tat le 1.
Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Beaver Valley Power Station Unit 1 IL E5 Technical Specifications k
3 NHC Staff Model Replaces or 4pdates l 25 RETS NUREG-0472 Licensee Proposal Existing Tech. Spec.
E3 imni Hequirement (Sect ion) *
(section)
(section)
Evaluation
$5?
{0 7
Effluent Instrumentation 3/4.3.3.3.10, 3/4.3.3.3.9, 2.4.1.4, 2.4.1.5, Meets the intent
'y 3/4.3.3.3.11 3/4.3.3.3.10 2.4.2.5, 2.4.4.3, 2.4.4.4 of NaC criteria
- r (Appendix B) gA Ek Radioactive Effluents 3/4.11.1.1, 3/4.11.2.1 3/4.11.1.1, 3/4.11.2.1 2.4.1.1 thru 2.4.1.9, Meets the intent y
2.4.3.1, 2.4.3.2, 2.4.3.3 of NRC criteria (Appendix B)
Offsitu l>usess 3/4.11.1.2, 3/4.11.2.2 3/4.11.1.2, 3/4.11.2.2 2.4.1, 2.4.3 (Appendix B)
MeetIs the intent 3/4.11.2.3, 3/4.11.4 3/4.11.2.3, 3/4.11.4 of NRC criteria Efttuent Treatment 3/4.11.1.3, 3/4.11.2.4 3/4.11.1.3, 3/4.11.1.4 2.4.1 (Appendix B)
Meets the intent of NRC criteria to j2 Tank Inventory Limits 3/4.11.1.4, 3/4.11.2.6 3/4.11.1.4, 3/4.11.2.5 2.4.1.7, 2.4.3.5 Meets the intent (Appendix B) of NRC criteria Explosive Gas Mixtures 3/4.11.2.5 3/4.11.2.6 2.4.3 (Appendix B)
Meets the intent of NRC criteria in the interin Solid itadioactive Waste J/4.11.3 3/4.11.3 2.4.5 (Appendix B)
Meets the intent of NRC criteria e
Environmental Monitoring 3/4.12.1 3/4.12.1 3.2 (Appendix B)
Meets the intent of NRC criteria Audits and Reviews 6.5.1, 6.5.2 6.5.1, 6.5.2 5.3 (Appendix B)
Meets the intent of NRC criteria Procedures 6.8 6.8 5.5 (Appendix B)
Meets the intent of NRC driteria og te Reports and Records 6.9, 6.10 6.5.2.10, 6.9 5.6, 5.7 (Appendix B)
Meets the intent of NRC criteria Ln tn a
J%
S
- Sect ion numbering sequence is according to NUREG-0472, Rev. 2 (26).
La e
1 Reactor 0,
- R"Radiologien1 r
5
'REF Efflu ERENCES NRC, July 197 Te hnic l TER-C55 ev.2 ent NUREG-0472 c
9 a
s
.2.'
Guides for DTitle 10, Cod Specifications fo e
r Pr Me t e
of the esign Federal essu iz d Material cri r
terio,Obje tiv Regulatio Wa ter e
c "Effectivtle 10, Codein Light-Wat'As Low As 3
n es t
Ti and ns, Pa t r
er Co led 50, Ap endix o
Re p
aso o
nably Achiev bln itions for 4
e Da te "f Feder l Nuclear Pow Ti s
a Againsttle 10, Code Regulatio er Rea to e, ' for Radioper tio a
~
a c
Radiatio
- Feder l ns, Part r Efflu of 5
Prote tion Stle 40, Code Regulations 50, Appendix Ti e ts" activ n
a n
e I, Se tion V c
of Fede
, Part 6
c ta da ds fo Cesign CritTitle 10, Cod 20, "S n
r ral r NucleaRegulatio tandards fo t
e ns of eria fo Feder l r Pow, Part 7
r Pr tectio 190, "
Ti o
er Oper tions"Envir a
tle 10, Cod r Nucle Regulatio n
Ass a
uranc e
ar Pow onm er Plants"ns, Pa t ental of "Radiologie Criteria foFeder l 8
r Nu lear PowRegulatio 50, Appe dix Radiation r
a Reacto n
r," c l c
a ns, Pa t A,
NUREG-0NBC, July 19Rev. Effluent s
" General r
Te hnic l er Pla ts 50, Appendix 2
c n
4 73 79 ad a
n 9
"Prepara tio Specificati F,u l B
e Repro,es"sinQuality Nu lear Pow c
ons fo c
n Spe ific ti er Plants, logic l r Boiling Wat g Pla ts" of Radio c
n N
a NURE -0133RC, October 1 ons" A
a er GuidancEfflu G
978 ent C. Willis e Manu lTechnic l 10 a
a fo Spe ificati r Us "Summ c
and ers a y of F. Co r
of o
Pr Dr fat ngel (N Standardns for ese ted n
May 19, 1982 the AIF Contr at acto )Guidanc Technic l BC 11 r
a
\\
F. Congel (N Environm e
Me Subje t:o to RAB RC) ental of m
Subc RETS" Inte im Cha )
om ittee Me ti Staff (NRC m
c Specific ti
~
r e
August a
9, 19 ns (RETS) nges in the Mod ng, Washingto o
82 n, DC el Radiologic l a
Effluent Te hnical nklin Res c
. ear h c Center -
. s ar s
h
+,,
,W
--e
.=,m e-
--9r
c o
TER-C5506-83 12.
" Radiological Effluent Technical'Specificar. ions for Pressurized Water Reactors," Rev. 3, Draf t 7, intended for contractor guidance in reviewing RETS proposal for operating reactors NRC, September 1982 NUREG-0472 13.
Letter of transmittal
Subject:
Information for 10CFR50, Appendix I Evaluation Beaver Valley Power Station, June 4,1976 Docket $50-334, License DPR-66 14.
Letter of transmittal
Subject:
Beaver Valley Power Station Appendix I Filing Beaver Valley Power Station, August 26, 1976 Docket #50-334 15.
Letter of transmittal
Subject:
Beaver Valley Power Station Units 1 and 2, Submittal of Appendix I Calculations Beaver Valley Power Station, September 22, 1976 Docket #50-334 16.
Letter of transmittal
Subject:
Appendix I Analysis, Additional Information Beaver Valley Power Station, November 23, 1976 Docket #50-334 17.
Letter of transmittal l
Subject:
Appendix I Pnalysis Beaver Valley Power Station Unit 1, May 6,1977 Docket #50-334 18.
" Radiological Ef fluent Technical Specifications" l
Attachment il Beaver Valley Power Station, March 15, 1979, Revised April 6,1979 Docket #50-334, Licensee No. DPR-66 19.
" Comparison of Specification NUREG-0472, Radiological Ef fluent Technical l
Specifications for PWRs vs. Licensea Submittal of Radiological Effluent Technical Specifications" (Draf t), and " Technical Review of Offsite Dose Calculation Manual" (Draf t)
Franklin Research Center (FRC), September 18, 1981 20.
Site visit, Beaver Valley Nuclear Station A. J. Cassell, S. Y. Chen, C. Fernandez, S. Pandey (FRC)
Sep tem.ber 24-25, 1981 1
l nklin Research Center l
A w or rh. r,.nnan in.oiui.
a e
f TER-C5506-83 6
21.
Letter of Transmittal
Subject:
Radiological Effluent Technical Specifications, Proposed Revision April 11,1979 22.
Letter of transmittal
Subject:
Attachment A, Complete Marked-Up Copy of BVPS - Environmental Technical Specifications, dated March 15, 1979, revised April 6,1979 Beaver Valley Power Station Unit'1, November 25, 1981 23.
Letter of transmittal
\\
Subject:
Request For Amendment No. 46 To Optratiny License, Attachment A, Proposed Revisions To, Radiological Effluent Technical Specificaticns Submitted Previously on April 11, 1979 ',
Beaver Valley Power Station Unit 1, November 25, 1981 Docket 650-334 i
24.
Telephone conference call-Dennis Chaney (NDC) ; A. J. Cassell,, S. Pandey, and S. Y. Chen (FRC), and K. D. Grada (Beaver Valley Power Station)
December 29, 1981' e
25.
Letter of transmittal
Subject:
Final (Revised) Draf t of Beaver Valley Power Station Radiological Effluent Technical Specification Duquesne Light Company, April 7,1982 1.
DLC File No. NDISLC:
19 7 26.
Telephone conference call NRC, DLC, and FRC Review Team
Subject:
Resolution of the Final Differences Botween the Licensee's April 7,1982 Submittal and FRC Review"of Sabmittal May 6, 1982 27.
E. Grada (Duquesne Light)
Letter of transmittal
Subject:
Amended Radiclogical Effluent Technical Specifications June 28, 1982 NDlSLC 252 28.
Comparison of Revision 2 and Revision 3 of NUREG-0412, Radiological Effluent Technical Specifications for PWRs
Subject:
Draft #3 of NUREG-0472, Rev. 3, dated March 30, 1982 U.S. Nuclear Regulatory Commission, ETS Branch 29.
" Proposed Change Request No. 36, Revision 3 to operating License" Request for Amendment to Appendix A, _Tecnnical Spccifications for Beaver Valley Radiological Ef fluent Technical Specifications October 22, 1982 St!U Franklin Research Center 4 cm.on or Th. Fr.nnan in uc.
I
l
)
TER-C5506-83 30.
Radiological Effluent Technical Specification Implementation Final Comparison Report Franklin Research Center December 2,1982 31.
Letter of Transmittal
Subject:
Offsite Dose Calculation Manual, Beaver Valley Power Station, Unit 1
~
~
December 1, 1982 32.
C. Willis (NRC)
Letter to Dr. S. Pandey (FRC)
Subject Changes to RETS requirements following meeting with Atomic Industrial Forum (AIF)
November 20, 1981 33.
C. Willis (NRC)
Letter to Dr. S. Pandey (FRC)
Subject:
Control of explosive gas mixture in PWRs December 18, 1981 34.
C. Willis and F. Congel (NRC)
" Status of NRC Radiological Ef fluent Technical Specification Activities"
, Presented at the AIF Conference on NEPA and Nuclear Regulations, Washington, D.C.
October 4-7, 1981 35.
C. Willis (NBC)
Memo to P. C. Wagner (NRC)
" Plan for Implementation of RETS for Operating Reactors" November 4, 1981 36.
W. P. Gammill (NRC)
Memo to P. C. Wagner (NRC)
" Current Position on Radiological Effluent Technical Specifications (RETS) Including Explosive Gas Controls" October 7, 1981 37.
"An Acceptable Radiological Environmental Monitoring Program" Branch Technical Position November 1979 38.
Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel l
Cycle Standard (40CFR190)
NRC, February 1980 NUREG-0 54 3 nklin Res
---.,e_ arch Center
TER-C5506-83 t
1 39.
" General Contents of the Offaite Dose Calculation Manual," Revision 1
[
Branch Technical Position, Radiological Assessment Branch February 8, 1979
~
40.
Calculation of Annual Doses to Man from Routine Releases of Reactor j
Effluents for the Purpose of Evaluating Complisnce with 10CFR50, j
Appendix I NBC, October 1977 Regulatory Guide 1.109 I
)
l l
(
pw 00hd Franklin Research Center a W orTherr e m a u.
_ _ _ - _ - _ _.