ML20072T444

Selected Licensee Commitments

ML20072T444
Person / Time
Site:	Catawba
Issue date:	08/31/1994
From:	Dover G DUKE POWER CO.
To:
Shared Package
ML20072T428	List: ML20072T427 ML20072T444
References
NUDOCS 9409150211
Download: ML20072T444 (76)

Text

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FORM 01190(R3-92) FORM 901.1/REV 89 DISPOSITION OF THE ORIGINAL W

PRIOllTT RUSH -

ggy $gy MtE. QUAUTY CHECKED J B LEss nEcePsENT is OTHEnwesE IDENTIFIED BELOW.

DUKE POWER COMPANY (113875 M H HAZELTINE EC13G DATE.

08/31/94 (215302 M J BRADY OPS SUPPORT CN020P DOCUMENTTRANSMITTAL FORM oOCUMENT TRANSMITTAL s '

pt3759,:U S~ NUCLEAR REG WASH?DC" (4)0085 G A COPP EC050 (513538 P M ABRAHAM EC081 (6) 2268 L E LOUCKS EC07F GA CONOmON ]YES @ NO (710297 REGION ADMINISTRATIOR REG II

REFERENCE:

(s) 5512 ' 2 L TAYLOR-CNOIRC ,

OTHER ACMNOWLEDGEMENT REQUsRED YES (9) 3945 M J UEBSTER CT01 A CATAUBA NUCLEAR STATION IF GA OR O1HER ACKNOWLEDGEMENT REQUIRED PLEASE (1c)2310 CNS CHEMISTRY HI-RI CNO3CH SELECTED LICENSEE COMMITMENTS ACKNOWLEDGE RECEIPT BY RETURNING THIS FORM OR DPC (1110582 R R ST CLAIR EC08G car d. Nuci.as si.uon (1211402 R L BROUN MG03C1 4aoo Concord Road (13)2188 L M ROBERTS-QV ECOSN y,y,,y,c$<^uUs7Is (14)4406 PANELA PALMER EC06H (15:1648 T P Ht 'ALL CNO3MA (1610486 T E CRAWFORO SYS ENG CNO3SE R.cu e, oat.

(1710276 0 J PHILLIPS CN05SR '

(1811121 M S SILLS CN04SG PAGE 1 0F 7 DOCUMENT NO. COND u?D I 1 2  % 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 TOTA.

LOEP 1-9 NA 08/01/94 CADM-03 J1 V1 V10V1 V1 J1 V1 V1 V1 V1 V1 V1 V1 V1 V1 J1 V1 U1 96 NA 08/01/94 CADM-03A 31 '

SLC 16.11 (PGS 1-63) NA 08/01/94 CADM-03 J1 V1 V10V1 V1 11 VI V1 V1 V1 V1 V1 V1 V1 V1 11 V1 U1 96 NA 08/01/94 CADM-03A

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REMARKS:

D L REHN VICE PRESIDENT CATAUBA NUCLEAR SITE G C 00VER CN01RC GCD/MCU q l HY .

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,Fg DUKE POWER COMPANY

(/ SELECTED LICENSEE COMMITMENTS MANUAL List of Effective Pages j k

LOEP 1 08/01/94 l LOEP 2 06/20/94 LOEP 3 06/20/94 LOEP 4 01/01/93 LOEP 5 06/20/94 LOEP 6 08/01/94 j LOEP 7 08/01/94 l LOEP 8 08/01/94  !

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DUKE POWER COMPANY

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SELECTED LICENSEE COMMITNENTS MANUAL j List of Effective Pages 16.11-64 08/01/94 16.11-65 08/01/94 Tab 16.12 '

Tab 16.13 i

16.13-0 12/90 16.13-1 12/90 Tab 16.14 Tab 16.15 O Accendix Compliance Function Area Manual, Section 3.8

" Selected Licensee Commitments" O Page 9 08/01/94

i 11 1 I DukeIbwer Company D. L Rt.xs Catauba Noelear Generatton Department Voce i+esident i 4800 ConcordRoad (803)[Il3205 Office York, SC29745 (803)UI3426 Fax q --- j l

l U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 - i

Subject:

Catawba Nuclear Station Docket No. 50-413,-414  :

Selected Licensee Commitments Manual (SLC)

Gentlemen:  !

Pursuant to 10 CFR 50.4 and 50.71, please find attached 10 copies of the latest revisions to the Catawba Selected Licensee Commitments Manual. The SLC Manual is l Chapter 16.0 to the Catawba FSAR. This manual is meant to contain commitments and ,

lg other station issues that we believe warrant higher control, but are not appropriate in the Technical Specifications (TS). Instead of being updated with the annual FSAR Update, i the SLC Manual will be updated monthly as needed during the year. ,

! Very truly yours, I l D. L. Rehn i >

l GCD l Attachment l xc: S. D. Ebneter Regional Administrator, Region II R. E. Martin, ONRR R. J. Freudenberger, Catawba Senior Resident Inspector O

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< 16.11 RADIOLOGICAL EFFLUENTS CONTROLS ,

s  :

RADIOACTIVE EFFLUENTS 3

16.11-1 LIQUID EFFLUENTS i j CONCENTRATION 4  ;

COMMITMENT -

The concentration of radioactive material released in liquid effluents to UNRESTRICTED  ;

3 AREAS (see Figure 16.11-1) shall be limited to ten times the effluent concentrations specified -  :

in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be

limited to 2 x 10 microcurie /ml total activity.

-l ,

APPLICABILITY: At all times.

REMEDIAL ACTION:

With the concentration of radioactive material released in liquid effluents to UNRESTRICTED ,

AREAS exceeding the above limits, immediately restore the concentration to within the above limits.

4 TESTING REQUIREMENTS:

, Radioactive liquid wastes shall be sampled and analyzed according to the sampling and i analysis program of Table 16.11-1.

The results of the radioactivity analyses shall be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are-maintained within the limits of SLC 16.11-1.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual ,

2. 10 CFR Part 20, Appendix B i

BASES:

The basic requirements for Selected Licensee Commitments conceming effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent Selected Licensee Commitments will keep average annual releases of radioactive materialin effluents to small percentages of the limits specified in the old 10 CFR 20.106 (new-10 CFR 20.1302). These requirements further indicate that operational flexibility is allowedi compatible with considerations of health and safety, which may temporarily result in releases p higher than such small percentages, but still within the limits specified in the old 10 CFR '

(") 20.106 which references Appendix B, Table 11 concentrations (MPCs). These referenced concentrations are specific values which relate to an annual dose of 500 mrem. It is further 16.Il-1 08/01/94

T indicated in 10 CFR 50.36a that when using operational flexibility, best efforts shall be exerted i

to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix 1.

As stated in the introduction to Appendix B of the new 10 CFR 20, the liquid effluent concentration (EC) limits given in Appendix B, Table 2, Column 2, are based on an annual l dose of 50 mrem. Since a release concentration corresponding to a limiting dose rate of 500 mrem / year has been acceptable as a SLC limit for liquid effluents, which applies at all times as an assurance that the limits of 10 CFR 50, Appendix i are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of 10.

Operational history at Catawba has demonstrated that the use of the concentration values associated with the old 10 CFR 20.106 as SLC limits has resulted in calculated maximum individual doses to a MEMBER OF THE PUBLIC that are small percentages of the limits of 10

, CFR 50, Appendix 1. Therefore, the use of concentration values which correspond to an i

annual dose of 500 mrem (ten times the concentration values stated in the new 10 CFR 20, Appendix B, Table 2, Column 2) should not have a negative impact on the ability to continue l

to operate within the limits of 10 CFR 50, Appendix I and 40 CFR 190.

l Having sufficient operational flexibility is especially important in establishing a basis for effluent

monitor setpoint calculations. As discussed above, the concentrations stated in the new 10 l CFR 20, Appendix B, Table 2, Column 2, relate to a dose of 50 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem / year. This low value is impractical upon which to base effluent monitor setpoint calculations for many liquid effluent release situations when monitor background, monitor sensitivity, and monitor performance

, must be taken into account.

! l Therefore, to accommodate operational flexibility needed for effluent releases, the limits l l associated with SLC 16.11-1 are based on ten times the concentrations stated in the new 10 l CFR20, Appendix B, Table 2, Column 2, to apply at all times. The multiplier of ten is proposed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix B, Table 11, Column 2, are based, is a factor of 10 higher than annual dose of 50 mrem, upon which the concentrations in the new 10 CFR 20, Appendix B, Table 2, Column 2, are based. Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. The concentration limit

for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the I controlling radioisotope and its MPC in air (submersion) was converted to an equivalent ,

concentration in water using the methods described in International Commission on 1 Radiological Protection (ICRP) Publication 2.

l This commitment applies to the release of radioactive materials in liquid effluents from all units

! at the site.

The required detection capabilities for radioactive materials in liquid waste samples are tabulated in terms of the lower limits of detection (LLDs). Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually),

Currie, L. A., " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry," Annal Chem. 40,586-93 (1968), and Hartwell, J. K., " Detection Limits for

( Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). .

16 11-2 08/01/94

A. TABLE 16.11-1 (Page 1 of 3)

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM LOWER LIMIT MINIMUM OF DETECTION LIQUID RELEASE SAMPLING ANALYSIS TYPE OF ACTIVITY (LLD)(1)

TYPE FREQUENCY FREQUENCY ANALYSIS ( Ci/ml)

1. Batch Waste P P Release Each Batch Ea .h Batch Principle Gamma 5x10-7 Tanks (2) Emitters (3) ,

1-131 1x10-6 Any tank which discharges P M Dissolved and 1x10-6 liquid wastes One Batch /M Entrained Gases by either liquid (Gamma emitters) effluent moni-tor, EMF-49 or EMF-57 P M H-3 1x10-6 Each Batch Composite (4)

Gross Alpha .1x10-/

P Q Sr-89, Sr-90 5x10-6 Each Batch Composite (4)

Fe-55 1x10-6

2. Continuous W Principal Gamma 5x10-/

Releases (5) Continuous (6) Composite (6) Emitters (3) l-131 1x10-6

a. Conventional Waste Water M M Dissolved and 1x10-5 Treatment Grab Sample Entrained Gases Line (Gamma Emitters)

b. Turbine Building Sump M H-3 1x10-5 i

Demineralizer Continuous (6) Composite (6)

Skid, EMF-31* Gross Alpha 1x10-7 O Sr-89, Sr-90 5x10-6 Continuous (6) Composite (6)

Fe-55 1x10-6 O

l V *During use of demineralizer (use of EMF-31 in off-normal mode).

l 16.I1-3 08/o1/94

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/3 TABLE 16.11-1 (Page 2 of 3) i b l TABLE NOTATIONS (1) The LLD is defined, for purposes of these commitments, as the smallest concentration of radioactive materialin a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of faisely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

I 4.66 s b

LLD = E V 2.22 x 106 Y . exp (-AAt) i Where:

LLD = the "a priori" lower limit of detection (microcurie per unit mass or volume),

l sb = the standard deviation of the background counting rate or of the counting

,. rate of a blank sample as appropriate (counts per minute),

V E = the counting efficiency (counts per disintegration),

l i

V = the sample size (units of mass or volume),

2.22 x 106= the number of disintegrations per minute per microcurie, Y = the fractional radiochemical yield, when applicable, A = the radioactive decay constant for the particular radionuclide (sec -1), and l At = the elapsed time between midpoint of sample collection and time of counting I (sec).

Typical values of E, V, Y and At shall be used in the calculation.

It .should be recognized that the LLD is defined as an a priori (before the fact) limit l representing the capability of a measurement system and not as an a posteriori(after l the fact) limit for a particular measurement.

(2) A batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed to assure  !

representative sampling.

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i p TABLE 16.11-1 (Page 3 of 3)

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TABLE NOTATIONS (Continued)

(3) The principal gamma emitters for which the LLD specification applies include the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, and Ce-141. The LLD for Ce-144 is 5x10-6 Ci/ml. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual l Racuactive Effluent Release Report pursuant to Technical Specification 6.9.1.7 in the fom.s! outlined in Regulatory Guide 1.21, Appendix B, Revision 1, June 1974.

(4) A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen that is representative of the liquids released.

(5) A continuous release is the discharge of liquid wastes of a nondiscrete volume, e.g.,

from a volume of a system that has an input flow during the continuous release.

(6) To be representative of the quantities and concentrations of radioactive materials in liquid effitents, samples shall be collected continuously in proportion to the rate of flow of the effluent stream. Prior to analyses, all samples taken for the composite shall be '

thoroughly mixed in order for the composite sample to be representative of the effluent O release. l b '

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g] 16.11 RADIOLOGICAL EFFLUENTS CONTROLS l v INSTRUMENTATION 16.11-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION COMMITMENT l

l The radioactive liquid effluent monitoring instrumentation channels shown in Table 16.11-2 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of SLC 16.11-1 are not exceeded. The Alarm / Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

APPLICABILITY: At all times.

I l REMEDIAL ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel Alarm / Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable,

b. With less than the minimum number of radioactive liquid effluent monitoring O instrumentation channels OPERABLE, take the ACTION shown in Table 16.11-2.

Cl Restore the inoperable instrumentation to OPERABLE status within the time specified in the ACTION, or explain in the next Annual Radioactive Effluent

[

Release Report pursuant to Technical Specification 6.9.1.7 why this inoperability was not corrected within the time specified. 1 TESTING REQUIREMENTS: I i Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated l

OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL  !

CAllBRATION and ANALOG CHANNEL OPERATIONAL TEST operations at the frequencies  !

l shown in Table 16.11-3.

REFERENCES:

j 1. Catawba Offsite Dose Calculation Manual

2. 10 CFR Part 20

3. 10 CFR Part 50, Appendix A

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BASES:

The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The Alarm / Trip Setpoints for these instruments shall be calculated and 2

adjusted in accordance with the methodology and parameters in the ODCM to ensure that the j Alarm / Trip will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, j 63, and 64 of Appendix A to 10 CFR Part 50.

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TABLE 16.11-2 (Page 1 of 2)

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE ACTION

1. Radioactivity Monitors Providing Alarm And Automatic Termination of Release ,

a. Waste Liquid Discharge Monitor (Low Range - EMF-49) 1 per station 1

b. Turbine Building Sump Monitor (Low Range - EMF-31) 1 3

c. Deleted

d. Monitor Tank Building Liquid Discharge Monitor (EMF-57) 1 per station 1

2. Continuous Composite Samplers And Sampler Flow Monitor

a. Conventional Waste Water Treatment Line 1 per station 3

b. Turbine Building Sump 1 per station 3*

3. Flow Rate Measurement Devices

a. Waste Liquid Effluent Line 1 per station 2

b. Conventional Waste Water Treatment Line 1 per station 2

c. Low Pressure Service Water Minimum Flow Interlock 1 per station 2

d. Monitor Tank Building Waste Liquid Effluent Line 1 per station 2

e. Turbine Building Sump Demineralizer Skid Totalizer 1 per station 2*

16. I l-8 08/01/94

TABLE 1611-2 (Page 2 of 2)

%)

TABLE NOTATIONS

• During use of demineralizer (EMF-31 in off-normal mode)

ACTION STATEMENTS l

ACTION 1 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided that prior to initiating a release:

a. At least two independent samples are analyzed in accordance with SLC 16.11-1; and,

b. At least two technically qualified members of the facility staff independently verify:

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1) The discharge line valving; and,

! 2) The manual portion of the computer input for the release rate I calculations performed on the computer, or the entire release rate I

calculations if such calculations are performed manually.

Otherwise, suspend release of radioactive effluents via this pathway.

l ACTION 2 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. Pump performance curves generated in place may be used to estimate flow.

ACTION 3 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided grab samples are analyzed for radioactivity at a lower limit of detection of no more than 10-7 microcurie /ml:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the secondary coolant is greater than 0.01 microcurie / gram DOSE EQUIVALENT l-131, or

b. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the specific activity of the secondary

, coolant is less than or equal to 0.01 microcurie / gram DOSE EQUIVALENT l-131.

ACTION 4 - Deleted l

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TABLE 16.1 Dage 1 of 2)

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS ANALOG CHANNEL CHANNEL SOURCE CHANNEL OPERATIONAL INSTRUMENT CHECK -CHECK CALIBRATION TEST

1. Radioactivity Monitors Providing Alarm and Automatic Termination of Release .

a. Waste Liquid Discharge Monitor D P R(2) Q(1)

(Low Range - EMF-49)

b. Turbine Building Sump Monitor D M R(2) Q(1)

(Low Range - EMF-31)

c. Deleted ,.

d. Monitor Tank Building Liquid Discharge D P R(2) Q(1)

.i Monitor (EMF-57)

2. Continuous Composite Samplers and Sampler i Flow Monitor  ;

a. Conventional Waste Water Treatment D(3) N.A. R N.A.

Line

b. Turbine Building Sump D(3) N.A R N.A.

3. Flow Rate Measurement Devices

a. Waste Liquid Effluent Line D(3) N.A. R N.A.

b. Conventional Waste Water Treatment D(3) N.A. R .N.A.

Line

c. Low Pressure Service Water Minimum D(3) N.A R Q Flow Intertock

d. Monitor Tank Building Waste Liquid D(3) N.A. R Q Effluent Line

e. Turbine Building Sump D(3) N.A. R N.A.

Demineralizer Skid Totalizer 16.11-10 08/01/94

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TABLE 16.11-3 (Page 2 of 2)

TABLE NOTATIONS *

(1) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic ,

isolation of this pathway and control room alarm annunciation

• occur if any of the following conditions exists; ,

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a. Instrument indicates measured levels above the Alarm / Trip Se,tpoint; or, -  ;

b. Circuit failure (alarm only); or,

c. Instrument indicates a downscale failure (alarm only).

(2) The initial CHANNEL CALIBRATION shall be performed using one or more of the-reference standards certified by the National Bureau of Standards (NBS) or using standards that have been obtained from suppliers that participate in measurement -

assurance activities with NBS. These standards shall permit calibrating the system j over its intended range of energy and measurement range. For subsequent CHANNEL

• CALIBRATION, sources that have been related to the initial calibration shall be used.

, (3) CHANNEL CHECK shall consist of verifying in'dication of flow during periods of l release. CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on days on  ?

which continuous, periodic, or batch releases are made.

J l

l

• For EMF-57, the alarm annuciation is in the Monitor Tank Building Control Room and on the C MTB Control Panel Remote Annunciator panel.

16.11-11 08/01/94

l (~'s 16.11 RADIOLOGICAL EFFLUENTS CONTROLS l L) j RADIOACTIVE EFFLUENTS 16.11-3 DOSE l i l

! COMMITMENT 1 l

? 1 l The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in l i

liquid effluents released, from each unit, to UNRESTRICTED AREAS (see Figure 16.11-1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the whole body and to less than or equal to 5 mrem to any organ, and

b. During any calendar year to less than or equal to 3 mrem to the whole body and l l

to less than or equal to 10 mrem to any organ.

l APPLICABILITY: At all times.

REMEDIAL ACTION:

With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to O

Technical Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. This Special Report shall also include: (1) the results of  ;

radiological analyses of the drinking water source, and (2) the radiological impact on finished l drinking water supplies with regard to the requirements of 40 CFR Part 141, Safe Drinking Water Act.* ,

I l TESTING REQUIREMENTS: I

( Cumulative dose contributions from liquid effluents for the current calendar quarter and the 1 l current calendar year shall be determined in accordance with the methodology and paramett.rs I in the ODCM at least once per 31 days.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

2. 40 CFR Part 141

3. 10 CFR Part 50, Appendix I 4

p *The requirements of REMEDIAL ACTION (1) and (2) are applicable only if drinking water (j supply is taken from the receiving water body within 3 miles downstream of the plant discharge.

i

16. I l-12 08/0I/94

I Q BASES:

V This commitment is provided to implement the requirements of Sections ll.A Ill.A and IV.A of Appendix 1,10 CFR Part 50. The Limiting Condition for Operation implements the guides set I forth in Section ll.A of Appendix 1. The REMEDIAL ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix ! to assure that the releases of radioactive material in liquid effluents to UNRE-  ;

STRICTED AREAS will be kept "as low as is reasonably achievable" Also, for fresh water '

sites with drinking water supplies that can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentra-tions in the finished drinking water that are in excess of the requirements of 40 CFR Part 141.

The dose calculation methodology and parameters in the ODCM implement the requirements in Section Ill.A of Appendix l that conformance with the guides of Appendix l be shown by calculational procedurcs based on models and data, such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1," Revision 1, October 1977 and Regulatory Guide 1.113. " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of implementing Appendix 1," April 1977.

This commitment applies to the release of radioactive materials in liquid effluents from each unit at the site. When shared Radwaste Treatment Systems are used by more than one unit O' on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the Radwaste Treatment System. For determining conformance to commitments, these allocations from shared Radwaste Treatment Systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit.

O 16 11-13 08/01/94 l

/~}

v 16.11 RADIOLOGICAL EFFLUENTS CONTROLS RADIOACTIVE EFFLUENTS 16.11-4 LIQUID RADWASTE TREATMENT SYSTEM COMMITMENT The Liquid Radwate Treatment System shall be OPERABLE and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see Figure 16.11-1) would exceed 0.06 mrem to the whole body or 0.2 mrem to any organ in a 31-day period.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With radioactive liquid waste being discharged without treatment and in excess of the above limits and any portion of the Liquid Radwaste Treatment System not in operation, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2 a Special Report that includes the following information:

1. Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability,

2. Action (s) taken to restore the inoperable equipment to OPERABLE status, and

3. Summary description of action (s) taken to prevent a recurrence.

I TESTING REQUIREMENTS-l Doses due to liquid releases from each unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM when Liquid Radwaste Treatment Systems are not being fully utilized.

The installed Liquid Radwaste Treatment System shall be considered OPERABLE by meeting SLC 16.11-1 and 16.11-3.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix A

3. 10 CFR Part 50, Appendix !

n U

16 11-14 08/01/94

BASES: 1 The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environ-  !

ment. The requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable" This commitment implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objective given in Section ll.D of Appendix I to 10 CFR Part 50. The specified limits goveming the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section ll.A of Appendix 1,10 CFR  ;

Part 50, for liquid effluents.

This commitment applies to the release of radioactive materials in liquid effluents from each ,

unit at the site. When shared Radwaste Treatment Systems are used by more than one unit -

on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity  ;

concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the Radwaste Treatment System. Fcr determining conformance to LCOs, these allocations from shared Radwaste Treatment Systems are to be added to the releases specifically attributed to each unit to obtain the total  :

releases per unit.

O l O

16.11-15 08/01/94

A 16.11 RADIOLOGICAL EFFLUENTS CONTROLS l )

RADIOACTIVE EFFLUENTS 16.11-5 CHEMICAL TREATMENT PONDS COMMITMENT The quantity of radioactive material contained in each chemical treatment pond shall be limited by the following expression:

A 264 I l < 1,0 V j (Cj x 10) excluding tritium and dissolved or entrained noble gases, Where:

Aj = pond inventory limit for single radionuclide "j", in Curies; Cj = 10 CFR 20, Appendix B, Table 2 Column 2, concentration for single radionuclide "j", microCuries/ml; l IO V

V = design volume of liquid and slurry in the pond, in gallons; and 264 = conversion unit, microCuries/ Curie per milliliter / gallon.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With the quantity of radioactive materialin any of the above listed ponds exceeding the above limit, immediately suspend all additions of radioactive material to the pond and initiate corrective action to reduce the pond contents to within the limit.

l TESTING REQUIREMENTS:

The quantity of radioactive material contained in each batch of resin / water slurry to be transferred to the chemical treatment ponds shall be determined to be within the above limit by analyzing a representative sample of the batch to be transferred to the chemical treatment ponds and shall be limited by the expression:

c I l < 0.006 j (Cj x 10)

Il

%d

(

l l 16.11-16 08/01/94 l

b 1

Where

v 1 radioactive resin / water slurry concentration for radionuclide "j" entering the i

, cj = UNRESTRICTED AREA chemical treatment ponds, in microCuries/ milliliter; and i  :

Cj = 10 CFR 20, Appendix B, Table 2, Column 2, concentration for single radionuclide  ;

, "j", in microCuries/ milliliter.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

2. 10 CFR Part 20, Appendix B

3. 10 CFR Part 50, Appendix I BASES:

The inventory limits of the chemical treatment ponds (CTP) are based on limiting the consequences of an uncontrolled release of the pond inventory. The expression in this commitment assumes the pond inventory is uniformly mixed, that the pond is located in an uncontrolled area as defined in 10 CFR Part 20, and that the concentration limit in Note 1 to i Appendix B of 10 CFR Part 20 applies.

The batch limits of resin / water slurry transferred to the CTP assure that radioactive material'

\

transferred to the CTP are "as low is reasonably achievable"in accordance with 10 CFR

. 50.36a. The expression in SLC 16.11-6 assures no batch will be transferred to the CTP unless the sum of the ratios of the activity of the radionuclides to their respective concentration limitation is less than the ratio of the 10 CFR Part 50, Appendix 1, Section ll.A, total body dose level to the instantaneous whole body dose rate limitatioc, vi that:

4 c

I _.i < 3 mrem /vr = 0.006 i(Cj x 10) 500 mremlyr

Where:

radioactive resin / water slurry concentration for radionuclide "j" entering the cj = UNRESTRICTED AREA CTP,in microCuries/ milliliter; and, j Cj = 10 CFR Part 20 Appendix B, Table 2, Column 2, concentration for single radionuclide "j", in microCuries/ milliliter.

The filter /demineralizers using powdered resin and the blowdown demineralizer are backwashed or sluiced to a holding tank. The tank will be agitated ' obtain a representative sample of the resin inventory in the tank. A known weight of the v tt drained resin (moisture content approximately 55 to 60%, bulk density of about 58 pount 5 ti cubic foot) will then be O counted. The concentration of the resin slurry to be pumped to th - tem; cal treatment ponds Q/ will then be determined by the formula l

l 16.11-17 08/01/94

i t

l OW

(^))

% cj = i R VT

! Where: '

Oj = concentration of radioactive materials in wet, drained resin for radionuclide "j",

excluding tritium, dissolved or entrained noble gases, and radionuclides with less than an 8-day half-life. The analysis shallinclude at least Ce-144, Cs-134, Cs-l 137, Co-58 and Co-60,in microCuries/ gram. Estimates of the Sr-89 and Sr-90 batch concentration shall be included based on the most recent monthly composite analysis (within 3 months);

j WR = total weight of resin in the storage tank in grams (determined from chemistry logs

procedures); and, VT = total volume of resin water mixture in storage tank to be transferred to the

chemical treatment ponds in milliliters.

The batch limits provide assurance that activity input to the CTP will be minimized, and a means of identifying radioactive material in the inventory limitation of this commitment.

(d 10 V

16. I l-l 8 08/01/94

16.11 RADIOLOGICAL EFFLUENTS CONTROLS RADIOACTIVE EFFLUENTS l

16.11-6 GASEOUS EFFLUENTS l DOSE RATE COMMITMENT The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (sa': Figure 16.11-1) shall be limited to the following:

a. For noble gases: Less than or equal to 500 mrem /yr to the whole body and less than or equal to 3000 mrem /yr to the skin; and,

b. For lodine-131, for lodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrem /yr to any organ.

APPLICABILITY: At all times.

REMEDIAL ACTION:

[ With the dose rate (s) exceeding the above limits, immediately restore the release rate to within C the above limit (s).

TESTING REQUIREMENTS:

The dose rate due to noble gases in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM.

The dose rate due to lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 16.11-4.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

2. 10 CFR Part 20, Appendix B

3. 10 CFR Part 20 O

16.11-19 08/01/94

l BASES.

The basic requirements for Selected Licensee Commitments concerning effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent Selected Licensee Commitments will keep average annual releases of radioactive materialin effluents to small percentages of the limits specified in the old 10 CFR 20.106 (new  !

10 CFR 20.1301). These requirements further indicate that operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10 CFR  ;

20.106 which references Appendix B, Table il concentrations (MPCs). These referenced  !'

concentrations are specific values which relate to an annual dose of 500 mrems. It is further.

indicated in 10 CFR 50.36a that when using operational flexibility, best efforts shall be exerted i to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix 1.  ;

I As stated in the Introduction to Appendix B of the new 10 CFR 20, the gaseous effluent concentration (EC) limits given in Appendix B. Table 2, Column 1, are based on an annual dose of 50 mrems for isotopes for which inhalation or ingestion is limiting or 100 mrems for ,

isotopes for which submersion (noble gases)is limiting. Since release concentrations  !

corresponding to limiting dose rates less than or equal to 500 mrems/ year to the whole body, i 3000 mrems/ year to the skin from noble gases, and 1500 mrems/ year to any organ from  ;

lodine-131, lodine-133, tritium and all radionuclides in particulate form with half-lives greater j than eight days at the site boundary has been acceptable as a SLC limit for gaseous effluents to assure that the limits of 10 CFR 50, Appendix i and 40 CFR 190 are not likely to be i l

O exceeded, it should not be necessary to restnct the operational flexibility by incorporating the dose rate associated with the EC value for isotopes based on inhalation / ingestion (50 mrems/ year) or the dose rate associated with the EC value for isotopes based on submersion j

i (100 mrems/ year).

Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations. As discussed above, the concentrations stated in the new 10 '

CFR 20, Appendix B, Table 2, Column 1, relate to a dose of 50 or 100 mrems in a year. When ,

applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100 mrems/ year.  !

These low values are impractical upon which to base effluent monitor setpoint calculations for l many gaseous effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account. l Therefore, to accommodate operational flexibility needed for effluent releases, the limits  ;

associated with gaseous release rate SLCs will be maintained at the current instantaneous '

dose rate limit for noble gases of 500 mrems/ year to the whole body and 3000 mrems/ year to the skin; and for lodine-131, for lodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days, an instantaneous dose rate limit of 1500 mrems/ year to any organ.

Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix i and 40 CFR 190. Operational history at Catawba has demonstrated that the use of the dose rate values listed above (i.e.,500 mrems/ year, 3000 mrems/ year, and 1500 mrems/ year) as SLC limits has resulted in calculated maximum O, individual doses to MEMBERS OF THE PUBLIC that are small percentages of the limits of 10 l- CFR 50, Appendix i and 40 CFR 190. For MEMBERS OF THE PUBLIC who may at times be I 16.11-20 08/olN4 1

I within the SITE BOUNDARY, the occupancy of that MEMBER OF THE PUBLIC will usually be l sufficiently low to compensate for any increase in the atmospheric diffusion factor above that l for the SITE BOUNDARY. Examples of calculations for such MEMBERS OF THE PUBLIC, l with the appropriate occupancy factors, shall be given in the ODCM. The specified release l rate limits restrict, at all times, the corresponding gamma and beta dose rates above back-ground to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or l equal to 500 mrem / year to the whole body er to less than or equal to 3000 mrem / year to the l skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem / year.

This commitment applies to the release of radioactive materials in gaseous effluents from all units at the site.

The required detection capabilities for radioactive material in gaseous waste samples are tabulated in terms of the lower limits of detection (LLDs). Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually), _

Currie, L.A., " Limits for Qualitative Detection and Quantitative Determination - Application to - ,

Radiochemistry," Anal. Chem. 40.586-93 (1968), and Hartwell, J.K., " Detection Limits for Radioanalytical Counting Techniques", Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

O I

l l

l

! i O

16.11-21 08/01/94 i

. - - - - . - _ , . - - . . . . _ _ . - ~ _ . . _ . _ . - - _ . _ . . . . _ , ..__ _ _ ._. _ - , _ . _ -.- . .. - , . . .

TABLE 16.f^-$ (Page 1 of 4) . '

RADIOACTIVE GASEOUS WAST! iMPLING AND ANALYSIS PROGRAM ,

MINIMUM LOWER LIMIT OF SAMPLING ANALYSIS TYPE OF DETECTION (LLD)(1)

GASEOUS RELEASE TYPE FREQUENCY FREQUENCY ACTIVITY ANALYSIS (pCi/ml)

P P

1. Waste Gas Storage Each Tank Each Tank Principal Gamma Emitters (2) 1x10-4 Tank Grab Sample ,

P P

2. Containment Purge Each PURGE (3) Each PURGE (3) Principlai Gamma Emitters (2) 1x10-4 Grab Sample M . H-3 (oxide) . 1x10-6

3. Unit Vent W(3) (4) w(3) ' Principal Gamma Emitters (2) 1x10-4 Grab Sample H-3 (oxide) 1x10-6

4. Containment Air D(3) (5) D(3)(5) principal Gamma Emitters (2) 1x10-4 Release and -

Addition System Grab Sample M H-3 (oxide) ' 1x10-6

5. All Release Types Continuous (6) D(7) 1-131 1x10-11 as listed in 3 Charcoal above. Sample .- l-133 1x10-9 Continuous (6) D(7) Principal Gamma Emitters (2) 1x10-10 Particulate Sample Continuous (6) 'M Gross Alpha (8).

1x10-11 Composite Particulate Sample Continuous (6) O Sr-89, Sr-90 1x10-11 Composite Particulate Sample 16.1I-22 08/0I/94 i

._ _-____.____._.__._________________m,._. _ _., , _ _ . , , . . - , , , , . , _ , . ~ . . . _ - , , _ , . , , . _ , , . . . , < , , , , . _ . . . , . _ _ _ _ _ , _ . ., , , _ . , ,

O O O 1 TABLE 16.11-4 (Page 2 of 4)

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM LOWER LIMIT OF -+

MINIMUM SAMPLING ANALYSIS TYPE OF DETECTION (LLD)(1)>

GASEOUS RELEASE TYPE FREQUENCY FREQUENCY ACTIVITY ANALYSIS (pCi/ml)

6. Waste Monitor W W Principal Gamma Emitters (2) 1x104

' Tank Building Grab Sample Ventilation H-3 (oxide) - 1x10-6 Exhaust Continuous (6) w l_131 1x10-11 Charcoal i Sample 1-133 1x10-9 Continuous (6) w. Principal Gamma Emitters (2) 1x10-10 Particulate

Sample i Continuous (6) M Gross Alpha 1x10-11 i Composite

Particulate Sample Continuous (6) . O Sr-89, Sr 1x10-11 Composite Particulate Sample '

1 1

16.I1-23 08/0I/94

_ . . . _ - _ - _ _ _ _ _ - _ - _ _ _ . _ . _ _ . - . . . - - - . . - _ . - . . -. . . ~ - ~ . - - - . , . . . . , - . - . . . . --

,q

, TABLE 16.11-4 (Page 3 of 4)

O TABLE NOTATIONS (1) The LLD is defined, for purposes of these commitments, as the smallest concentration of radioactive materialin a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding l

that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

4.66 s b

LLD = E V 2.22 x 106 . Y exp (-Aat) l Where:

LLD = the "a priori" lower limit of detection (microcurie per unit mass or volume);

! sb = the standard deviation of the background counting rate or of the counting l ,

rate of a blank sample as appropriate (counts per minute);

l /

( E = the counting efficiency (counts per disintegration);

I V = the .tample size (units of mass or volume);

2.22 x 106 = the number of disintegrations per minute per microcurie; Y = the fractional radiochemical yield, when applicable; A = the radioactive decay constant for the particular radionuclide (sec-1); and, l At = the elapsed time between midpoint of sample collection and time of counting l (sec).

l l Typical values of E, V, Y and At shall be used in the calculation.

It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori(after the fact) limit for a particular measurement.

r lO l

16. I l-24 08/0IN4 l --

1

i.  !

l \

t l l

l

~

l f TABLE 16.11-4 (Page 4 of 4) I i  !

\.

TABLE NOTATIONS (Continued) i (2) The principal gamma emitters for which the LLD specification applies include the  !

following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 in noble gas releases and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99,1-131, Cs-134, Cs-137, l and Ce-141 in todine and particulate releases. The LLD for Ce-144 is 5x10-9 Ci/ml.  !

This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be  !

analyzed and reported in the Annual Radioactive Effluent Release Report, pursuant to l

Technical Specification 6.9.1.7, in the format outlined in Regulatory Guide 1.21, Appendix B, Revision 1, June 1974.

(3) Sampling and analysis shall also be performed following shutdown, startup, or a  ;

THERMAL POWER stabilization (power level constant at desired power level) after a THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a 1-hour period, for at least one of the three gaseous release types with this notation.

(4) Tritium grab samples shall be taken at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the refueling canal .

j is flooded. l l

(5) Required sampling and analysis frequency during effluent release via this pathway.

A k (6) The ratio of the sample flow volume to the sampled stream flow volume shall be known ,

l for the time period covered by each dose or dose rate calculation made in accordance l l with SLCs 16.11-6,16.11-8, and 16.11-9.

(7) Samples shall be changed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and analyses shall be completed I within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing, or after removal from sampler.  !

(8) The composite filter (s) will be analyzed for alpha activity by analyzing one filter per week to ensure that at least four filters are analyzed per collection period.

{

l l

l

16. I l-25 08/01/94

,- ~ y g --,-

l l

l 16.11 RADIOLOGICAL EFFLUENTS CONTROLS l

lNSTRUMENTATION

, 16.11-7 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION l

l COMMITMENT _

The radioactive gaseous effluent monitoring instrumentation channels shown in Table 16.11-5 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of SLC 16.11-6 are not exceeded. The Alarm / Trip Setpoints of these channels meeting SLC 16.11-6 shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 16.11-5.

REMEDIAL ACTION:

l a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm / Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable.

b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 16.11-5.

i l V O Restore the inoperable instrumentation to OPERABLE status within the time specified in the ACTION, or explain in the next Annual Radicactive Effluent l

Release Report pursuant to Technical Specification 6.9.1.7 why this inoperability was not corrected within the time specified.

l TESTING REQUIREMENTS:

i Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CAllBRATION, and ANALOG CHANNEL OPERATIONAL TEST operations at the frequencies shown in Table 16.11-6.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

2. 10 CFR Pad 20 BASES:

, The radioactive gaseous effluent instrumentation is provided tc monitor and contal, as l applicable, the releases of radioactive materials in gaseous eff,uents during actual or potential

! releases of gaseous effluents. The Alarm / Trip Setpoints for these instrumems ; hall be

!p calculated and adjusted in accordance with the methodology a id parameters h the ODCM to l ensure that the alarm / trip will occur prior to exceeding the limite c,f 10 CFR Pas 20. The l OPERABILITY and use of this instrumentation is consistent with the requhments of General 16 11-26 OwoI/94 l

i 1

l i ^

! l

! Design Critena 60,63, and 64 of Appendix A to 10 CFR Part 50. The sensitivity of any noble

x gas activity monitor used to show compliance with the gaseous effluent release requirements of SLC 16.11-8 shall be such that concentrations as low as 1 x 10-6 pCi/cc are measurable.

l l

l l

l l

t i

1 16.1I 27 og/oIj94

p O ['\

bl U TABLE 16.11-5 (Page 1 of 4)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

1. WASTE GAS HOLDUP SYSTEM

a. Noble Gas Activity Monitor-Providing Alarm and Automatic Termination of Release (Low

• Range - EMF-50) 1 per station 1

b. Effluent System Flow Rate Measuring Device 1 per station 2

2. CONDENSER EVACUATION SYSTEM 1 1,2,3,4,# 6 NOBLE GAS ACTIVITY MONITOR (LOW RANGE - EMF-33)

3. VENT SYSTEM

a. Noble Gas Activity Monitor 1 3 (Low Range - EMF-36)

b. lodine Sampler (EMF-37) 1 5

c. Particulate Sampler (EMF-35) 1 5

d. Flow Rate Monitor 1 2

e. Sampler Flow Rate Monitor 1 2

16. I l-28 08/0I/94

O O O i

TABLE 16.11-5 (Page 2 of 4) i t

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS

~

INSTRUMENT OPERABLE APPLICABILITY ACTION l 4. CONTAINMENT PURGE SYSTEM  !

Noble Gas Activity Monitor- ,

Providing Alarm and Automatic 1 4 Termination of Release (Low Range - EMF-39) ,

~

5. CONTAINMENT AIR RELEASE AND ADDITION SYSTEM i

• Noble Gas Activity Monitor- 1 1 Providing Alarm (Low Range - EMF-39)  !

6. MONITOR TANK BUILDING HVAC

! a. Noble Gas Activity Monitor- 1 per station 3 Providing Alarm (EMF-58)

b. Monitor Tank Building 1 per station 2 Effluent Flow Rate.

Measuring Device ,

l t

d

16. I i-29 08/0I/94

. . . . - .~ . - . . . - -

TABLE 16.11-5 (Page 3 of 4)

TABLE NOTATIONS

• At all times except when the isolation valve is closed and locked. i

" At a!! times.

1. Apply _ Action 68 in Modes 5 and 6 ACTION STATEMENTS ACTION 1 - With the number of channels OPERABLE less than required the Minimum Channels OPERABLE requirement, the contents of the tank (s) may be released to the environment for up to 14 days provided that prior to initiating the release either:

a. Vent system noble gas activity monitor providing alarm and auto'natic r termination of release (Low Range - EMF-36) has at least one channel OPERABLE;. or, i

b. At least two independent samples of the tank's contents are analyzed, and at least two technically qualified members of the O' facility staff independently verify:

{

j 1. The discharge valve lineup; and .

l

2. The manual portion of the computer input for the release rate calculations performed on the computer, or the entire release j rate calculations if such calculations are performed manually.

Otherwise, suspend release of radioactive effluents via this pathway.

I ACTION 2 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this  ;

pathway may continue for up to 30 days provided the flow rate is J estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. I ACTION 3 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this  ;

pathway may continue for up to 30 days provided grab samples are taken l at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for  ;

radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,

ACTION 4 - With the number of channels OPERABLE less than required by the l Minimum Channels OPERABLE requirement, immediately suspend j PURGING of radioactive effluents via this pathway.

16.11-30 08/01/94

2 3

4 TABLE 16.11-5 (Page 4 of 4)

TABLE NOTATIONS 1

ACTION 5 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via the affected pathway may continue for up to 30 days provided samples are continuously collected with auxiliary sampling equipment as required in Table 16.11-4.

ACTION 6 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement:

A. Effluent release v_ia the CSAE System (ZJ) may continue for up to 30 days provided grab samples are taken at least once per.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and B. Gaseous effluent releases via the BB system atmospheric vent valve (BB27) in the off normal mode may continue for up to 30 days provided grab samples of steam generator water are analyzed for radioactivity at a lower limit of detection of no more than 1E ,

microcurie /ml: '

l

( a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the l secondary coolant is greater than 0.01: microcurie / gram DOSE EQUIVALENT l-131, or j

b. - At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the specific activity of the ,

secondary coolant is less than or equal to 0.01 microcurie /

gram DOSE EQUIVALENT l-131.

l O

16.11-31 08/0I/94

(v \ 0 V

._)

TABLE 16.11-6 (Page 1 of 3)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS ANALOG MODES FOR CHANNEL WHICH ,

CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

1. Waste Gas Holdup System

a. Noble Gas Activity Monitor-Providing Alarm and Automatic Termination of Release (Low Range - EMF-50) P P(4) R(3) Q(1)

b. Effluent System Flow Rate Measuring Device P N.A. R N.A.

2. Condenser Evacuation System Noble Gas Activity Monitor (Low Range - EMF-33) D M(4) R(3) O(1) 1,2,3,4

3. Vent System

a. Noble Gas Activity Monitor (Low Range - EMF-36) D M(4) R(3) O(2)

b. lodine Sampler (EMF-37) W N.A. N.A. N.A.

c. Particulate Sampler (EMF-35) W N.A. N.A. N.A.

d. Flow Rate Monitor D N.A. R N.A.

e. Sampler Flow Rate Monitor D N.A. R N.A.

16.11-32 08/01/94

. . . . . . . _ _ . . _ . . . . . . . _ . _ . _ . . _ _ _ _ _ - . _ _ _ _ - . . _ . . . ~ . _ . . . . . . . _ . . ...m_..__._... . . . . . . . _ _ . _ . .

L O O O TABLE 16.11-6 (Page 2 of 3) ,

! RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS 1

ANALOG MODES FOR 1 CHANNEL' WHICH '

CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE

, INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

4. Containment Purge System

~

Noble Gas Activity Monitor-Providing Alarm and Automatic Termination of Release (Low Range - EMF-39) D P(4) R(3) O(1) t

5. Containment Air Release and Addition System Nob!o Gas Activity Monitor-Providing Alarm (Low Range - EMF-39) D P(4) R(3) . Q(1)

6. Monitor Tank Building HVAC L

a. Noble Gas Activity Monitor-Providing Alarm (EMF-58) D M R(3) Q(2) i i b. - Discharge Flow Instrumentation ;D N.A. R N.A.

b l

16. I l-33 08/01/94 4

- - - _ . . - -- - _ . . . - . . - - . . _ _ _ - - . - - . _ _ _ _ - . _ . - - - - - - - .n- - - . . . ., , . - -- _ . - - .-- .

TABLE 16.11-6 (Page 3 of 3)

!qGI TABLE NOTATIONS At all times except when the isolation valve is closed and locked.

At all times.

1. The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurif any of the

! following conditions exists:

l

a. Instrument indicates measured levels above the Alarm / Trip Setpoint; or,

b. Circuit failure (Alarm only); or,

! c. Instrument indicates a downscale failure (Alarm only).

2. The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that control room alarm annunciation # occurs if any of the following conditions exists:

a. Instrument indicates measured levels above the Alarm Setpoint; or,

b. Circuit failure; or,

, w]

c. Instrument indicates a downscale failure.

l

3. The initial CHANNEL CALIBRATION shall be performed using one or more of the l reference standards certified by the National Bureau of Standards (NBS) or using I standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards shall permit calibrating the system l over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used.

I

4. A source check for these channels shall be the qualitative assessment of channel response when the channel sensor is exposed to a light emitting diode.

l l

l p #For EMF-58, the alarm annunciation is in the Monitor Tank Building Control Room and on the

() MTB Control Panet Remote Annunciator Panel.

l&l1-34 08/01/94

(~N 16.11 RADIOLOGICAL EFFLUENT CONTROLS d RADIOACTIVE EFFLUENTS 16.11-8 DOSE - NOBLE GASES COMMITMENT The air dose due to noble gases released in gaseous effluents, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-1) shall be limited to the following;

a. During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrad for beta radiation; and,

b. During any calendar year. Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY:. At all times.

REMEDIAL ACTION:

With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the

/9 D

limit (s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

TESTING REQUIREMENTS:

Cumulative dose contributions for the current calendar quarter and current calendar year for noble gases shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

REFERENCES:

1

1. Catawba Offsite Dose Calculation Manual l

2. 10 CFR Part 50, Appendix l l BASES:

)

This commitment is provided to implement the requirements of Sections ll.B. Ill.A and IV.A of Appendix 1,10 CFR Part 50. The Limiting Condition for Operation implements the guides set forth in Section ll.B of Appendix 1. The REMEDIAL ACTION statement provides the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix i to assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable" The Testing y Requirements implement the requirements in Section Ill.A of Appendix l that conformance with the guides of Appendix I be shown by calculational procedures based on models and data 16.11-35 08/01/94

BASES: (cont'd) such that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The dose calculation methodology and parameters established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109," Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1,"

Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977. The ODCM equations provided for determining the air doses at and beyond the SITE BOUNDARY are based upon the historical average atmospheric conditions.

This commitment applies to the release of radioactive materials in gaseous effluents from each unit at the site. When shared Radwaste Treatment Systems are used by more than one unit on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effiuent releases may be allocated equally to each of the radioactives waste producing units sharing the Radwaste Treatment System. For determining conformance to commitments, these allocations from shared Ra'dwaste Treatment Systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit.

i J

16. I l-% 08/01/94

l l

16.11 RADIOLOGICAL EFFLUENT CONTROLS  ;

C l RADIOACTIVE EFFLUENTS l 16.11-9 DOSE - IODINE-131, IODINE-133, TRITIUM, AND RADIOACTIVE MATERIAL I IN PARTICULATE FORM l

COMMITMENT '

The dose to a MEMBER OF THE PUBLIC from lodine-131, lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-1) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrem to any organ; and,

b. During any calendar year: Less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With the calculated dose from the release of lodine-131, lodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents exceeding any of

/7 the above limits, prepare and submit to the Commission within 30 days, pursuant to Technical b Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

TESTING REQUIREMENTS:

Cumulative dose contributions for the current calendar quarter and current calendar year for  ;

lodine-131, lodine-133, tritium and radionuclides in particulate form with half-lives greater than ;

8 days shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days. l l

REFERENCES:

l i

1. Catawba Offsite Dose Calculation Manual l

2. 10 CFR Part 50, Appendix !

BASES:

This commitment is provided to implement the requirements of Sections ll.C, Ill.A and IV.A of i Appendix 1,10 CFR Part 50, and are the guides set forth in Section ll.C of Appendix 1. The l q REMEDIAL ACTION statements provide the required operating flexibility and at the same time Q implement the guides set forth in Section IV.A of Appendix i to assure that the releases of radioactive materials in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as l I

l

16. I l-37 08/01/94

l

(~T BASES: (cont'd)

O is reasonably achievable" The ODCM calculational methods specified in the Surveillance Requirements iraplement the requirements in Section Ill.A of Appendix I that conformance with )

the guides of Apaendix I be shown by calculational procedures based on models and data, such that the ac:ual exposure of a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials  ;

are consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of i Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1," Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate commitments for lodine-131, lodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days are dependent upon the existing radionuclide pathways to man in the areas at and beyond the SITE BOUNDARY. The pathways that were examined in the development of the calculations were: (1)individualinhalation of airbome radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat-producing animals graze with consumption of the milk and meat by man, and (4) deposition on the ground with subsequent exposure of man.

This commitment applies to the release of radioactive materials in gaseous effluents from each OV unit at the site. When shared Radwaste Treatment Systems are used by more than one unit on a site, the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the Radwaste Treatment System. For determining conformance to commitments, these allocations from shared Radwaste Treatment Systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit. l

16. I l-38 08/01/94

C 16.11 RADIOLOGICAL EFFLUENT CONTROLS

!]N RADIOACTIVE EFFLUENTS 16.11-10 GASEOUS RADWASTE TREATMENT SYSTEM 1

COMMITMENT l The VENTILATION EXHAUST TREATMENT SYSTEM and the WASTE GAS HOLDUP SYSTEM shall be OPERABLE and appropriate portions of these systems shall be used to reduce releases of radioactiv;ty when the projected doses in 31 days due to gaseous effluent releases, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 16.11-1) would exceed either: '

a. 0.2 mrad to air from gamma radiation; or,  ;

b. 0.4 mrad to air from beta radiation; or,

c. 0.3 mrem to any organ of a MEMBER OF THE PUBLIC.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With radioactive gaseous waste being discharged without treatment and in excess of the V above limits, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that includes the following information:

1. Identification of any inoperable equipment or subsystems, and the reason for the inoperability;

2. Action (s) taken to restore the inoperable equipment to OPERABLE status; and,

3. Summary description of action (s) taken to prevent a recurrence.

TESTING REQUIREMENTS:

Doses due to gaseous releases from each unit to areas at and beyond the SITE BOUNDARY shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM when Gaseous Radwaste Treatment Systems are not being fully utilized.

The installed VENTILATION EXHAUST TREATMENT SYSTEM and WASTE GAS HOLDUP SYSTEM shall be considered OPERABLE by meeting SLCs 16.11-6,16.11-8, or 16.11-9.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual (m)

2. 10 CFR Part 50, Appendix I 16.I1-39 08/01/94

i I l

4 i

i ~

"T BASES:

l (Q) i

{ The OPERABILITY of the WASTE GAS HOLDUP SYSTEM and the VENTILATION EXHAUST ,

[ TREATMENT SYSTEM ensures that the systems will be available for use whenever gaseous

! effluents require treatment prior to release to the environment. The requirement that the j appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low l as is reasonably achievable" This commitment implements the requirements of 10 CFR l 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and the design objectives given in Section ll.D of Appendix l to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections ll.B and ll.C of Appendix 1,10 CFR Part 50, for gaseous effluents.

This commitment applies to the release of radioactive materials in gaseous effluents from each unit at the site. When shared Radwaste Treatment Systems are used by more than one unit on a site,' the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g., flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units sharing the Radwaste Treatmect System. For i determining conformance to commitments, these allocations from shared Radwaste Treatment Systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit. .

O  !

O 161 l-40 08/01/94

. - -- - = _. . - . - -

1

- l i

16.11 RADIOLOGICAL EFFLUENT CONTROLS l RADIOACTIVE EFFLUENTS 16.11-11 SOLID RADIOACTIVE WASTES 1 COMMITMENT ,

Radioactive wastes shall be solidified or dewatered in accordance with the PROCESS CONTROL PROGRAM to meet shipping and transportation requirements during transit, and disposal site requirements when received at the disposal site.

APPLICABILITY: At all times. ,

REMED:AL ACTION:

a. With SOLIDIFICATION or dewatering not meeting disposal site and shipping and-transportation requirements, suspend shipment of the inadequately processed wastes and correct the PROCESS CONTROL PROGRAM, the procedures and/or the Solid Radwaste System as necessary to prevent recurrence.

b. With SOLIDIFICATION or dewatering not performed in accordance with the ,

PROCESS CONTROL PROGRAM, test the improperly processed waste in each container to ensure that it meets burial ground and shipping requirements and l take appropriate administrative action to prevent recurrence. '

SURVElLLANCE REQUIREMENTS:

SOLIDIFICATION of at least one representative test specimen from at least every tenth batch of each type of wet radio' active wastes (e.g., filter sludges, spent resins, evaporator bottoms, ,

boric acid solutions and sodium sulfate solutions) shall be verified in accordance with the PROCESS CONTROL PROGRAM:

a. If any test specimen fails to verify SOLIDIFICATION, the SOLIDIFICATION of the l batch under test shall be suspended until such time as additional test specimens i

can be obtained, alternative SOLIDIFICATION parameters can be determined in accordance with the PROCESS CONTROL PROGRAM, and a subsequent test verifies SOLIDIFICATION. SOLIDIFICATION of the batch may then be resumed using the alternative SOLIDIFICATION parameters determined by the PROCESS

! CONTROL PROGRAM; l b. If the initial test specimen from a batch of waste fails to verify SOLIDIFICATION, the PROCESS CONTROL PROGRAM shall provide for the collection and testing of representative test specimens from each consecutive batch of the same type of wet waste until at least three consecutive initial test specimens demonstrate SOLIDIFICATION. The PROCESS CONTROL PROGRAM shall be modified as required, as provided in Technical Specification 6.13, to assure SOLIDIFICA-TION of subsequent batches of waste; and,

(

16. I l-41 08/01/94 I

1 4

, p c. With the installed equipment incapable of meeting SLC 16.11-11 or declared 4

Q inoperable, restore the equipment to OPERABLE status or provide for contract capability to process wastes as necessary to satisfy all applicable transportation and disposal requirements.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix A

3. 10 CFR Pad 50 BASES:

This commitment implements the requirements of 10 CFR 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50. The process parameters included in establish-ing the PROCESS CONTROL PROGRAM may include, but are not limited to waste type, waste pH, waste / liquid / SOLIDIFICATION agent / catalyst ratios, waste oil content, waste

principal chemical constituents, and mixing and curing times.

1 1

7s 4

I 1

r 4 *\

\

16 Il-42 08/0I/94 J

I 16.11 RADIOLOGICAL EFFLUENT CONTROLS O 1 RADIOACTIVE EFFLUENTS l

16.11-12 TOTAL DOSE I COMMITMENT l

The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due l to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to 1 less than or equal to 25 mrem to the whole body or any organ, except the thyroid, which shall I be limited to less than or equal to 75 mrem.

APPLICABILITY: At all times.

REMEDIAL ACTION:

l l With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of SLCs 16.11-3a,16.11-3b,16.11-8a,16.11-8b,16.11-9a, l or 16.11-9b, calculations shall be made including direct radiation contributions from the units and from outside storage tanks to determine whether the above limits of this commitment have been exceeded. If such is the case, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that defines the corrective action to i be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits

[D and includes the schedule for achieving conformance with the above limits. This Special b Report, as defined in 10 CFR 20.405c, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for the calendar year that includes the release (s) covered by this report. It shall also describe levels of radiation and concentrations of radio-active materialinvolved, and the cause of the exposure levels or concentrations. If the estimated dose (s) exceeds the above limits, and if the release condition resulting in violation of j 40 CFR Part 190 has not already been corrected, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is )

complete. l TESTING REQUIREMENTS:

Cumulative dose contributions from liquid and gaseous effluents shall be determined in

accordance with SLCs 16.11-3,16.11-8 and 16.11-9, and in accordance with the methodology l and parameters in the ODCM.

Cumulative dose contributions from direct radiation from the units and from radwaste storage tanks shall be determined in accordance with the methodology and parameters in the ODCM.

This requirement is applicable only under conditions set forth in the REMEDIAL ACTION of this commitment.

'% l 16.11-43 08/01/94

l

REFERENCES:

o I

b 1. Catawba Offsite Dose Calculation Manua!

2. 10 CFR Part 20

3. 40 CFR Part 190 BASES:

i This commitment is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Part 20 by 46 FR 18525. The commitment requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radio-activity and to radiation from uranium fuel cycle sources exceed 25 mrem to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem.

For sites containing up to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dase limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of Appendix 1, and if direct radiation doses from the units and from outside storage tanks are kept small. The Special Report will describe a course of action that should result in the limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits. For the purposes of the Special Report, it may be assumed that the dose commitment to the MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other

,. nuclear fuel cycle facilities at the same site or within a radius of 8 km must be considered. If

(" the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release l conditions resulting in violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 and 10 CFR 20.2203(a)(4), is considered to be a timely request and fulfills the requirements of 40 CFR Part 190 until NRC staff action is completed. The variance only relates to the limits of 40 CFR Part 190, and does not apply in l any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in SLC 16.11 1 and 16.11-6. An individualis not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel i cycle. l l

l l l l

l x

! 16. I l-44 08/01/94 1

k 16.11 RADIOLOGICAL EFFLUENT CONTROLS RADIOLOGICAL ENVIRONMENTAL MONITORING

16.11-13 MONITORING PROGRAM COMMITMENT The Radiological Environmental Monitoring Program shall be conducted as specified in Table

16.11-7 APPLIC/,BILITY

At all times.

REMEDIAL ACTION:

i 4 a. With the Radiological Environmental Monitoring Program not being conducted as i specified in Table 16.11-7, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Technical Specification 6.9.1.6, a descnption of the reaso'ns for not conducting the program as required and the plans for preventing a recurrence.

b. With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table

. 16.11-7 when averaged over any calendar quarter, prepare and submit to die

. Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the a

corrective actions to be taken to reduce radioactive effluents so that the potential annual dose

• to a MEMBER OF THE PUBLIC is less than the calendar year limits of SLC 16.11-3,16.11-8, and 16.11-9. When more than one of the radio-nuclides in Table 16.11-7 are detected in the sampling medium, this report shall

! be submitted if:

concentration (1) concentration (2) reporting level (1) + reporting level (2) + ..> 1.0 When radionuclides other than those in Table 16.11-7 are detected and are the

, result of plant effluents, this report shall be submitted if the potential annual dose

• to A MEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of SLC 16.11-3,16.11-8 and 16.11-9. This report is not required if the measured level of radioactivity was not the result of

plant effluents, however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Technical Specification 6.9.1.6.

"The methodology and parameters used to estimate the potential annual dose to a MEMBER

OF THE PUBLIC shall be indicated in this report.

v 16 Il-45 08/01/94 I l

REMEDIAL ACTION: (cont'd) p b c. With milk or fresh leafy vegetation samples unavailable from one or more of the sample locations required by Table 16.11-7, identify specific locations for obtaining replacement samples and add them within 30 days to the Radiological Environmental Monitoring Program given in the ODCM. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Pursuant to Technical Specification 6.14, submit in the next Annual l Radioactive Effluent Release Report documentation for a change in the ODCM including a revised figure (s) and table for the ODCM reflecting the new location (s) with supporting information identifying the cause of the unavailability of samples and justifying the selection of the new location (s) for obtaining samples.

TESTING REQUIREMENTS:

The radiological environmental monitoring samples shall be collected pursuant to Table 16.11-7 from the specific locations given in the table and figure (s)in the ODCM, and shall be analyzed pursuant to the requirements of Table 16.11-7 and the detection capabilities required by Table 16.11-8.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual

{

1 2. 10 CFR Part 50 Appendix 1 V

BASES:

The Radiological Environmental Monitoring Program required by this commitment provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the plant operation. This monitoring program implementsSection IV.B.2 of Appendix 1 to 10 CFR Part 50 and thereby supplements the Radiological Effluent Monitoring Program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways. Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring. The initially specified monitoring program will be effective for at least the first 3 years of commercial operation. Following this period, program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table 16.11-8 are considered optimum for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

V 16.I1-46 08/0l/94

l BASES: (cont'd)

I Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL 300 (revised annually), Currie, L.A., " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry," Anal Chem. 40, 586-93 (1968),

and Hartwell. J. K., " Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

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16.11.-17 ogfo g j9.g

O O O TABLE 16.11-7 (Page 1 of 8)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM f

NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

1. Direct Radiation (2) Forty routine monitoring stations Quarterly. Gamma dose quarterly.

either with two or more dosimeters.

or with one instrument for measuring and recording dose rate continuously, placed as follows:

An inner ring of stations, one in each meteorological sectorin the general area of the SITE BOUNDARY; An outer ring of stations, one in ,

each meteorological sector in -

the 6- to 8-km range from the site; and, The balance of the stations to be placed in specialinterest areas such as population centers,

, nearby residences, schools, and in one or two areas to serve as control statons.

I6.1 l-48 08/0I/94

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TABLE 16.11-7 (Page 2 of 8)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 1 i NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY ,

AND/OR SAMPLE SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS  ;

2. Airbome Radiciodine and Samples from five locations. Continuous sampler Radiciodine Cannister:

Particulates operation with sample 1-131 analysis weekly.

collection weekly, or more frequently Three samples from close if required by dust to the three SITE BOUNDARY loading. Particulate Sampler locations, in different sectors, Gross beta radio-of the highest calculated activity analysis annual average ground- following filter level D/O;' change;(3) and gamma isotopic One sample from the analysis (4) of vicinity of a community composite (by -

having the highest calculated location) quarterly.

annual average ground-level -

D/Q; and One sample from a control -

location, as for example 15 to 30 km distant and in the least prevalent wind direction.

a

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O O O .

TABLE 16.11-7 (Page 3 of 8) ,

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM  !

NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

3. Waterbome

a. Surface (5) One sample upstream. Gamma isotopic Composite 1-month period. samp(le 6) over analysis (4) monthly.

One sample downstream.

Composite for tritium  ;

analysis quarterly.

b. Ground Samples from one or two Quarterly. Gamma isotopic (4) sources onl and tritium analysis affected(7) y if likely to be quarterly.

c. Drinking One sample of each of one Composite sam le over 1-131 analysis on each to three of the nearest water 2-week period ( ) composite when the dose supplies that could be when 1-131 analysis is calculated for the con-affected by its discharge. performed; monthly sumption of the water is composite otherwise. greater than 1 mrem per One sample from a control year (8). Composite for location. gross beta and gamma isotopic analyses (4) monthly. Composite for tritium analysis quarterly.

d. - Sediment One sample from downstream Semiannually. Gamma isotopic from area with existing or potential analysis (4) semiannually.

Shoreline recreational value.

16.11-50 08/01/9F ,

C\ O J V U TABLE 16.11-7 (Page 4 of 8)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF i

REPRESENTATIVE '

EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

4. Ingestion

a. Milk Samples from milking animals Semimonthly when Gamma isotopic (4) and in three locations within 5 km animals are on pasture; l-131 analysis semi-distance having the highest monthly at other times. monthly when animals dose potential. If there are are on pasture; monthly none, then one sample from at other times.

milking animals in each of three areas between 5 to 8 km Giant where doses are calculated 1 mrem pertoyear.be g(reater

8) One than sample from milking animals at a controllocation 15 to 30 km distant and in the least prevalent wind direction.

b. Fish and One sample each of a Sample'in season, or Gamma isotopic Invertebrates predatory species, a bottom semiannually if they are analysis (4) on edible feeder and a forage species not seasonal. portions.

in vicinity of plant discharge area.

One sample each of a predatory species, a bottom feeder and a forage species in areas not influenced by plant discharge.

16.11-51 owotna

_. _ _ _ . . . _ _ . . - . _ _ . . _ . . . ~ _ . . _ _ . _ . _ . _ . _ _ _ . . . . . - . . _ _ _ _ _ _ . _ _ . _ . - _ . _ _ _ . - _ . ~ . _ .

O O O TABLE 16.11-7 (Page 5 of 8)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

, e NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND TYPE AND FREQUENCY EXPOSURE PATHWAY AND/OR SAMPLE SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS

'4. Ingestion (Continued)

c. Food One sample of each principal At time of harvest (9). Gamma isotopic Products class of food products from analyses (4) on edible any area that is irrigated by portion.

water in which liquid plant wastes have been discharged.

Samples of three different Monthly, when available. Gamma isotopic (4) and 1-131 analysis.

kinds of broad leaf vegetation grown nearest each of two different offsite locations of .

highest predicted annual average ground level D/Q if milk sampling is not performed.

One sample of each of the Monthly, when available. Gamma isotopic (4) and similar broad leaf vegetation 1-131 analysis.

grown 15 to 30 km distant in the least prevalent wind direction if milk sampling is not performed.

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TABLE 16.11-7 (Page 6 of 8) r O

V TABLE NOTATIONS l 1. Specific parameters of distance and direction sector from the centerline of the station, and additional description where pertinent, shall be provided for each and every sample location in Table 16.11-7 in a table and figure (s) in the ODCM. Refer to NUREG-0133,

" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," ,

October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to circumstances such as hazardous conditions, seasonal unavailability, and malfunction of automatic sampling equipment. If specimens are unobtainable due to sampling equipment malfunction, effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological i Environmental Operating Report pursuant to Technical Specification 6.9.1.6. It is recognized that, at times, it may not be possible or practicable to continue to obtain 4 samples of the media of choice at the most desired location or time. In these instances

suitable altemative media and locations may be chosen for the particular pathway in 4

question and appropriate substitutions made within 30 days in the Radiological Environmental Monitoring Program. In lieu of any Licensee Event Report required by Technical Specification 6.9.1 and pursuant to Technical Specification 6.9.1.7, identify the cause of the unavailability of samples for that pathway and identify the new location (s) for obtaining replacement samples in the next Annual Radioactive Effluent

,T l

[d Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

I

2. One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. For the purposes of this table, a thermoluminescent dosimeter (TLD)is j considered to be one phosphor; two or more phosphors in a packet are considered as

, two or more dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation. (The 40 stations is not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographicallimitations; e.g.,

at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information within miriimal fading.)

3. Airbome particulate sample filters shall be analyzed for gross beta radioactivity 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples.

4. Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

4.

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16.I1-53 08/0I/94

TABLE 16.11-7 (Page 7 of 8) 10 V TABLE NOTATIONS (Continued)

5. The " upstream sample" shall be taken at a distance beyond significant influence of the discharge. The " downstream" sample shall be taken in an area beyond but near the mixing zone. " Upstream" samples in an estuary must be taken far enough upstream to be beyond the plant influence. Salt water sha!! bs sampled only when the receiving water is utilized for recreational activities. ,

6. A composite sample is one in which the rate at which the liquid sampled is uniform and in which the method of sampling employed results in a specimen that is representative of the time averaged concentration at the location being sampled. In this program composite sample aliquots shall be collected at time intervals that are very short (e.g.,

hourly) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sample.

7. Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

8. The dose shall be calculated for the maximum organ and age group, using the methodolpgy and parameters in the ODCM.

t 9. If harvest occurs more than once a year, sampling shall be performed during each

' discrete harvest. If harvest occurs continuously, sampling shall be monthly. Attention shall be paid to including samples of tuberous and root food products.

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O O O TABLE 16.11-7 (Page 8 of 8)  ;

REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES REPORTING LEVELS t

WATER AIRBORNE PARTICULATE FISH MILK FOOD PRODUCTS ANALYSIS (pCi/I) OR GASES (pCi/m*) (pCi/kg, wet) (pCill) (pCi/kg, wet)

L H-3 20,000(1)  ;

Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000  ;

Co-60 300 10,000 i c

Zn-65 300 20,000 Zr-Nb-95 400 +

l-131 2 0.9 . 3 100 Cs-134 30 10 1,000 60 1,000-Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300 ~

4 (1)For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCi/l may be J

used.

i 16.11-55' 08/o1/94

O O O 4 4

TABLE 16.11-8 (Page 1 of 3)

DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS (1)(2)

LOWER LIMIT OF DETECTION (LLD)(3) ,

I WATER AIRBORNE PARTICULATE FISH MILK FOOD PRODUCTS SEDIMENT ANALYSIS (pCi/I) OR GASES (pCi/m') (pCi/kg, wet) (pCi/I)_ (pCi/kg, wet) (pCi/kg, dry) ,

Gross Beta 4 0.01 H-3 2000*

Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-Nb-95 15 1-131 1(4) 0.07 1 60 Cs-134 15 0.05 130 15 60 150.

Cs-137 18 0.06 150 18 80 .180 Ba-La-140 15 15 ,

t

! *If no drinking water pathway exists, a value of 3000 pCill may be used.

i 16.11-56 UM/ DIN 4

TABLE 16.11-8 (Page 2 of 3)

TABLE NOTATIONS

1. This list does not mean that only these nuclides are to be considered. Other peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 6.9.1.6.

2. Required detection capabilities for thermoluminescent dosimeters used for environmental measurements shall be in accordanca with the recommendations of Regulatory Guide 4.13.

3. The LLD is defined, for purposes of these commitments, as the smallest concentrations of radioactive materialin a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

4.66 s b

LLD = E . V 2.22 Y exp (-lat)

Where:

LLD = the "a priori" lower limit of detection (picoCuries per unit mass or volume);

sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (counts per minute);

E = the counting efficiency (counts per disintegration);

V = the sample size (units of mass or volume);

2.22 = the number of disintegrations per minute per picocurie; Y = the fractional radiochemical yield, when applicable; A = the radioactive decay constant the particular radionuclide (sec-1); and, At = the elapsed time between environmental collection, or end of the sample collection period, and time of counting (sec).

Typical values of E, V, Y and at should be used in the calculation.

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TABLE 16.11-8 (Page 3 of 3) .;

TABLE NOTATIONS (Continued)

It should be recognized that the LLD is defined as an a priori (before the' fact) limit i representing the capability of a measurement system and not as an a posteriori(after i the fact) limit for a particular measurement.'. Analyses shall be performed in such a i manner that the stated LLDs will be achieved under routine conditions. Occasionally +

background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

in such cases, the contributing factors shall be identified and described in the Annual  ;

Radiological Environmenta! Operating Report pursuant to Technical Specification 6.9.1.6.

I

4. LLD for drinking water samples. If no drinking water pathway exists, the LLD of gamma isotopic analysis may be used.

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16.11 RADIOLOGICAL EFFLUENT CONTROLS RADIOLOGICAL ENVIRONMENTAL MONITORING 16.11-14 LAND USE CENSUS COMMITMENT l l A Land Use Census shall be conducted and shallidentify within a distance of 8 km (5 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence, and the nearest garden

• of greater than 50 m2 (500 't2 ) producing broad leaf vegetation.

APPLICABILITY: At all times.

REMEDIAL ACTION:

a. With a Land Use Census identifying a location (s) that yields a calculated dose or dose commitment greater than the values currently being calculated in SLC 16.11-9, identify the new location (s) in the next Annual Radioactive Effluent l Release Report pursuant to Technical Specification 6.9.1.7.

. b. With a Land Use Census identifying a location (s) that yields a calculated dose or

, dose commitment (via the same exposure pathway) 20% greater than at a loca-

< tion from which samples are currently being obtained in accordance with SLC

[ 16.11-13, add the new location (s) within 30 days to the radiological Environ-k mental Monitoring Program given in the ODCM. The sampling location (s),

l excluding the control station location, having the lowest calculated dose or dose commitment (s), via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this Land Use Census was conducted. Pursuant to Technical Specification 6.14, submit in the next Annual Radioactive Effluent Release Report documentation for a change in the [

ODCM including a revised figure (s) and table (s) for the ODCM reflecting the new 4 location (s), with information supporting the change in the sampling locations.

I i TESTING REQUIREMENTS:

The Land Use Census shall be conducted during the growing season at least once per 12 months using that information that will provide the best results, such as by a door-to-door 1 survey, aerial survey, or by consulting local agriculture authorities. The results of the Land Use Census shall be included in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 6.9.1.6.

i

• Broad leaf vegetation sampling of at least three different kinds of vegetation may be -

pc formed at the SITE BOUNDARY in each of two different direction sectors with the highest ,

. predicted D/Qs in lieu of the garden census. Commitments for broad leaf vegetation l sampling in Table 16.11-7.4.c shall be followed, including analysis of control samples. j

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REFERENCES:

]

1. Catawba Offsite Dose Calculation Manual 1

. 2. 10 CFR Pan 50, Appendix l i 4

. BASES: -

j This commitment is provided to ensure that changes in the use of areas at and beyond the i SITE BOUNDARY are identified and that modifications to the Radiological Environmental

] Monitoring Progam given in the ODCM are made if required by the results of this census. The

best information from the door-to-door survey, from aerial survey or from consulting with local j agricultural authorities shall be used. This census satisfies the requirements of Section IV.B.3 j of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 50 m2 '

provides assuratice that significant exposure pathways via leafy vegetables will be identified i and monitored since a garden of this size is the minimum required to produce the quantify (26 i kg/ year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child.

! To detemine this minimum garden size, the following assumptions were made: (1) 20% of the j garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and j (2) a vegetation yield of 2 kg/m2 i

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I 16.11 RADIOLOGICAL EFFLUENT CONTROLS O

d RADIOLOGICAL ENVIRONMENTAL MONITORING 16.11-15 INTERLABORATORY COMPARISON PROGRAM ,

COMMITMENT i

! Analyses shall be performed on all radioactive materials, supplied as part of an Interlaboratory Comparison Program that has been approved by the Commission, that correspond to samples required by Table 16.11-7.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report pursuant to Technical Specification 6.9.1.6.

l TESTING REQUIREMENTS:

l The interiaboratory Comparison Program shall be described in the ODCM. A summary of the results obtained as part of the above required Intertaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report pursuant to Technical i Specification 6.9.1.6.

REFERENCES-i 1. Catawba Offsite Dose Calculation Manua' I l

2. 10 CFR Part 50, Appendix I BASES:

l The requirement for participation in an approved interfaboratory Comparsion Program is l provided to ensure that independent checks on the precision and accuracy of the measure-I ments of radioactive materialin environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50.

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16.11 RADIOLOGICAL EFFLUENT CONTROLS r

REPORTS 16.11-16 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT AND l ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT l

COMMITMENT 16.11-16.1 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

• Routine Annual Radiological Environmental Operating Reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

The Annual Radiological Environmental Operating Reports shallinclude summarics, interpretations, and an analysis of trends of the results of the radiological environmental l surveillance activities for the report period, including a comparison with preoperational studies, with operational controls as appropriate, and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of the land use census.

The Annual Radiological Environmental Operating Reports shallinclude the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the Table and Figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in l / the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, b] November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following: a summary description of the Radiological Environmental Monitoring Program; at least two legible maps" covering all sampling locations keyed to a table giving distances and directions from the centerline of one reactor; the results of licensee participation in the Interlaboratory Comparison Program, required by SLC 16.11-15; discussion of all deviations from the sampling schedule of Table 16.11-7; and discussion of all analyses in which the LLD required by Table 16.11-8 was not achievable.

)

• A single submittal may be made for the station.

" One map shall cover stations near the SITE BOUNDARY, and a second map shall include the more distant stations.

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16. I i42 08/01/94 l

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16.11-16.2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (see Note) ,

The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The Annual Radioactive

Effluent Release Reports shallinclude a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.

The Annual Radioactive Effluent Release Report shallinclude an annual summary of hourly l meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability. (In lieu of submission  !

with the Annual Radioactive Effluent Release Report, the licensee has the option of retaining l  !

j this summary of required meterological data on site in a file that shall be provided to the NRC j upon request.) This same report shallinclude an assessment of the radiation doses due to the

! radioactive liquid and gaseous effluents released from the unit or station during the previous

. calendar year. This same report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBER OF THE PUBLIC due to their activities inside the SITE BOUNDARY during the report period. All assumptions used in making these assessments, i.e., specific activity, exposure time and location, shall be included in these reports. The meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

The Annual Radioactive Effluent Release Report shall also include an assessment of radiation l

doses to the likely most exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to show conformance with 40 CFR Part 190,

" Environmental Radiation Protection Standards for Nuclear Power Operation" Acceptable i methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev.1, October 1977.

The Annual Radioactive Effluent Release Reports shallinclude the following information for l

each type of solid waste shipped offsite dunng the report period

i i a. Total Container volume, in cubic meters, '

i

b. Total Curie quantity (determined by measurement or estimate),

i

c. Principal radionuclides (determined by measurement or estimate),

d. Type of waste (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms),

16. I l-63 08/0I/94 j

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~

e. Number of shipments, and i (~

2 f. Solidification agent or absorbent (e.g., cement or other approved agents

(media)).

The Annual Radioactive Effluent Release Reports shallinclude a list and description of l

unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

The Annual Radioactive Effluent Release Reports shallinclude any changes made during the l reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE DOSE CALCULATION MANUAL (ODCM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the land use census pursuant to SLC 16.11-14.

Note:

A single submittal may be made for the station. The submittal should combine those sections that are common to both units.

O t l

O 16.1I-64 08/01/94

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t j INTAKE STRUCTURE i

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[ J FIGURE 16.11-1

. 16.11-65 08/01 M CATAWBA - UNITS 1 AND 2 i

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.