ML20073K413

Proposed Change 83-4 to App a of Ets,Implementing 10CFR50.34a(a),10CFR50.36a,10CFR20,50,App A,Gdc 60 & 64 & 40CFR190

ML20073K413
Person / Time
Site:	Pilgrim
Issue date:	04/15/1983
From:	BOSTON EDISON CO.
To:
Shared Package
ML20073K411	List: ML20073K408 ML20073K413
References
NUDOCS 8304200252
Download: ML20073K413 (78)

Text

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1 PNPS RADIOLOGICAL ENVIRONMENTAL TECHNICAL SPECIFICATIONS SUBMITTAL 1

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Surveillance Page No.

3.7 CONTAINMENT SYSTEMS 4.7 152 A. Primary Containment A 152 B. Standby Gas Yreatment System B 158 C. Secondary Containment C 159 D. Primary Containment Isolation Valves D 160

, 3.8 RADI0 ACTIVE EFFLUENTS 4.8 177 A. Liquid Effluents Concentration A 177 B. Radioactive Liquid Effluent B 178 Instrumentation C.  !.iquid Waste Treatment C 179 D. Gaseous Effluents Dose Rate D 180 E. Radioactive Gaseous Effluent E 181 Instrumentation F. Gaseous Effluent Treatment F 182 G. Main Condenser G 183 H. Mechanical Vacuum Pump H 184 3.9 AUXILIARY ELECTRICAL SYSTEMS 4.9 194 A. Auxiliary Electrical Equipment A 194 B. Operation with Inoperable Equipment B 195 3.10 CORE ALTERATIONS 4.10 202 A. Refueling Interlocks A 202 B. Core Monitoring B 202 C. Spent Fuel Pool Water Level C 203 3.11 REACTOR FUEL ASSEMBLY 4.11 205A A. Ave' rage Planar Linear Heat Generation Rate (APLHGR) A 205A

. B. Linear Heat Generation Rate (LHGR) B . 205A-1 C. Minimum Critical Power Ratio (MCPR) C 205B 3.12 FIRE PROTECTION 4.12 206 A. Fire Detection Instrumentation A 206 B. Fire Suppression Water Syrtem B 206 C. Spray and/or Sprinkler Systems C 206c D. CO2 System D 206d i

E. Fire Hose Stations E 206e F. Penetration Fire Barrier F 206e G. Dry Chemical Systems G 206e-1 H. Yard Hydrants and Exterior Hose Houses H 206e-1 4.0 MISCELIANEOUS RADIOACTIVE MATERIALS SOURCES 206k 4.1 Sealed Source Contamination 206k 4.2 Surveillance Requirements 206k 2061 4.3 Reports 4.4 Records Retention 2061 ii Amendment No. 45

Surveillance Page No.

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~5.0 ' MAJOR DESIGN FEATURES 206m 5.1 Site Features 206m

-5.2. Reactor 206m 5.3 Reactor Vessel 206m

, .5.4 . Containment' 206m-5.5 Fuel Storage - 207 5.6 Seismic Design 207 6.0' ADMINISTP.ATIVE CONTROLS 208 6.1 Responsibility 208 6.2 Organization 208

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-- 16.3 Facility Staff Qualifications- 208 L 6.4 Training .

208a

'6.5 Review and Audit 212 6.6 Reportable Occurrence Action 216 6.7 Safety Limit Violation 216

-6.8 Procedures 216 6.9 Reporting ~ Requirements 217

. 6.10 Record Retention 224 6.11 Radiation Protection Program 226 6.12 (Daleted) 6.13 High-Radiation ~ Area 226 6.14 Fire Protection Program 227 6.15 Environmental _ Quali_fication 228 0PERATIONAL OBJECTIVES 7.0 RADIOLOGICAL-ENVIR0NMENTAL MONITORING PROGRAM 8.0 229 7.1.A Monitoring Program 8.1.A 229 B Land Use. Census _

B' 229p-C Interlaboratory Comparison Program C 229r

-7.2. Dose'- Liquids

- 8.2 230 7.3 Dose - Noble Gases 8.3 231 7.4 Dose - Iodine 131, Radioactive Material 8.4 232 in Particulate Form, and Tritium 7.5 Total Dose 8.5 233

. Amendment No. 45 iii

n 1.0 DEFINITIONS (Continued)

U. SURVEILLANCE FRE0"ENCY Unless otherwise stated in these specifications, periodic surveillance tests, checks, calibrations, and examinations shall be performed, with-in the specified surveillance intervals. These intervals may be adjusted plus 25 percent. The total maximum combined interval time for any three consecutive tests shall not exceed 3.25 times the speci-fied interval. The operating cycle interval is considered to be 18 mo a7d the tolerances stated above are applicable.

V. SURVELLANCE INTERVAL The SURVEILLANCE INTERVAL is tLa calendar time between surveillance tests, checks, calibrations, ano examinations to be performed upon an instrument or component when it is required to be operable. These tests may be waived when the instrument, component, or system is not required to be operable, but the instrument, component, or system shall be tested prior to being declared operable.

W. FIRE SUPPRESSION WATER SYSTEM A FIRE SUPPRESSION WATER SYSTEM shall consist of: a water source (s);

gravity tank (s) or pump (s); and distribution piping with associated sectionalizing control or isolation valves. Such valves shall include 1 hydrant post indicator valves and the first valve ahead of the water flow alarm device on each sprinkler, hose standpipe or spray system riser.

X. STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of: (a) a test schedule for n systems, subsystems, trains, or other designated components ob'.ained by dividing the specified test interval into n equal subintervals; (b) the testing of one system, subsystem, traTn or other designated components at the beginning of each subinterval.

Y. SOURCE CHECK A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.

Z. OFFSITE DOSE CALCULATION MANUAL (ODCM)

AN OFFSITE DOSE CALCULATION MANUAL (0DCM) shall be a manual containing the current methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints, and in the conduct of the Radiological Environ-mental Monitoring Program.

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AA. ACTION ACTION shall be that part of a Specification which prescribes remedial measures required under designated conditions.

BB. MEMBER (S) 0F THE PUBLIC*

MEMBER (S) 0F THE PUBLIC shall include all persons who are not occupa-tionally associated with the plant. This category does not include employees of the utility, its contractors, or vendors. Also excluded from this category are persons who enter the site to service equipment

.or to make deliveries. This category does include persons who use portions of the site for recreational, occupational or other purposes not associated with the site.

CC. SITE BOUNDARY

• The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

DD. UNRESTRICTED AREA

• An URRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY access to which is not controlled by the licensee for purposes of protection of individuals frcm exposure to radiation and radioactive materials and the Pilgrim Station shorefront area used for recreational purposes.

EE. RADWASTE TREATMENT SYSTEM

1. GASE0US RADWASTE TREATMENT SYSTEM The GASE0US RADWASTE TREATMENT SYSTEM is that system identified in Figure 4.8.F.1.

2. LIQUID RADWASTE TREATMENT SYSTEM The LIQUID RADWASTE TREATMENT SYSTEM is that system identified in Figure 4.8.C.1.

• Information regarding radioactive gaseous and liquid effluents, which allows identification of structures and release points as well as definition of UNRESTRICTED AREAS within the SITE BOUNDARY that are accessible to MEMBER OF THE PUBLIC, is as shown in Figure 1.1.

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Site Boundary Protected Area UNRESTRICTED AREAS for MEMBERS OF THE PUBLIC are the access road to and the Shorefront Recreational Area Figure 1.1. Pilgrim Nuclear Power Station Unrestricted Areas for Liquid and Gaseous Effluents 1

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8 RADI0 ACTIVE EFFLUENTS 4.8 RADI0 ACTIVE EFFLUENTS A. Liquid Efficents Concentration A. Liquid Effluents Concentration Applicability 1. The radioactivity content of each batch of radio-At all times. active liquid waste to be discharged shall be deter-

1. The concentration of radio- mined orfor to release by active material released at sampling and analysis in any time from the site to accordance with Table the UNRESTRICTED AREAS 4.8.A-1.

shall be limited to the concentrations specified in 2. The results of pre-release 10 CFR Part 20, Appendix B, analyses shall be used with Table II, Column 2 for calculational methods in radionuclides other than the ODCM to assure that dissolved or entrained th2 concentration at the noble gases. For dissolved point of release is limited or entrained noble gases, to the values in Speciff-the concentration of indi- cation 3.8.A.1.

vidual isotopes shall be limited to 2 x 10-4 uCi/ml.

Action With the concentration of radioactive material re-leased from the site to UNRESTRICTED AREAS exceed-ing the above limits, with-out delay restore concen-tration within the above limits and provide notiff-cation to the Commission pursuant to Specification 6.9.B.1.J.

177

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS INSTRUMENTATION 3.8.8 Radioactive Liquid Effluent 4.8.B Radioactive Liquid Effluent Instrumentation Instrumentation Applicability

1. The setpoints for monitoring instrumentation shall be de-As shown in Table 3.8.B-1. termined in accordance with the ODCH.

1. The radioactive liquid efflu-ent monitoring instrumenta- 2. Each radioactive liquid effluent tion channels shown in Table monitoring instrumentation 3.8.B-1 shall be OPERABLE channel shall be demonstrated with their alarm / trip set- OPERABLE at the frequencies points set to ensure that the shown in Table 4.8.3-2.

limits of Specification 3.8.A.1 are not exceeded during periods when liquid wastes are being discharged.

Action

a. With a radioactive liquid effluent monitoring instrumentation channel alarm / trip setpoint less conservative than a value which will ensure that the limits of 3.8.A.1 are met, without delay suspend the l release of radioactive liquid effluents mon- )

itored by the affected channel and declare the channel inoperable.

b. With one or more radio-

active liquid effluent monitoring instrumenta-tion channels inoperable, take the ACTION shown in 1 Table 3.6.B-1. l i

i 178

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TABLE 3.8.B-1 RADI0 ACTIVE LIQUID EFFLUENT. MONITORING INSTRUMENTATION i

i i Minimum-Channels j Instrument Operable Applicability Action

< 1. Gross Radioactivity Monitors i Providing Automatic Termination of Release I a. Liquid Radwaste Effluent During actual discharge Line (1) of liquid wastes 1

2. Flow Rate Measurement Davices

, a. Liquid Radwaste Effluent (1) During actual discharge 2 Line of liquid wastes y b. Discharge Canal

• NA During actual discharge g of liquid wastes

• Flow will be estimated based on the design flow rate of the operating Circulating Water Pumps

. and/or the operating Salt Service Water Pumps.

TABLE NOTATION ACTION 1 With the number of channels OPERABLE less than required by the Minimum Channels

OPERABLE requirement, effluent releases may be resumed provided that prior to initiating a release

I 1. At least two independent samples are analyzed in accordance with l Specification 4.8.A.1, and:

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2. An independent verification of the release rate calculations is performed and, t

{ 3. An independent verification of the discharge valving is performed.

f ACTION 2 With the number of channels OPERABLE less than required by the Minimum Channels

! OPERABLE requirement, effluent releases via this pathway may continue provided the minimum flow rate is verified at least once per 4 hrs during actual releases.

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TABLE 4.8.A-1 RADI0 ACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM l i I I I I l l l l l Lower Limit l l l l Minimum l Type of lof Detection l l l Sampling l Analysis l Activity I (LLD) l l Liquid Release Type l Frequency I Frequency l Analysis l(uC1/ml)(a) l l l l l l l l l l l l l l A. Batch Wa l Each Batch l Prior to l Principal 15 x 10-7(b) l l Tanksfe)ste Release l I Release I Gamma l l l l l Each Batch l EmittersIf) l l l l l l l 1 I I I I I I i 1. Neutralizer l l I I-131 11 x 10-6 l l Sumps l l l l l l l l l l l l l l l Dissolved 11 x 10-5 l l 'and l l l and Entrain- l l l l l l ed Gases l l l l l l l l l l l l l l l 2. Radwaste Tanks l Composite l l H-3 11 x 10(-5) l l l from Each l Monthly I l l l Batch l Composite (c)l I Gross alpha 11 x 10-7 I I I I I I I l I I I I i l l Composite  ! l Quarterly Composite (c)l Sr-89, Sr-90 15 x 10(-8) l l from Each l l l l l l Batch l l Fe-55 11 x 10-6 l l , I I I I l B. Continuous Releasestd)I l g  ; l l l l l 1 I I 1 1. Discharge Canal l Continuous l Monthly l Principal 15 x 10-7 l l l l Composited l Composite I Gamma l l l l l sample l I Emitters l l l l l l l I-131 Il x 10-6 l l l l l Dissolved 11 x 10-5 l l l l l and Entrain- l l l l l l ed Gases l I I I I I (Gamma l I I l l l Emitters) l l l l l l l l l l Continuous ! Quarterly l 15 x 10-8 l l l l Composited l Composite l H-3 11 x 10-6 l l Sample l l l l l 1 I I I l 2. Salt Service l Weekly l Weekly l Principal 15 x 10-7b l l Water l grab samplel l Gamma l 1 l l l l Emitters l l l l l l l l l i

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4.8. A-1 (Continued)

TABLE NOTATION

a. Refer to 0DCM for LLD definition.

b. Refer to ODCM for LLD exceptions.

c. 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 which is representative of the liquids released.

d. To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected continuously.

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 release.

e. A batch release is the discharge of liquid wastes of a discrete volume.

f. Refer to 0DCM for the principal gamma emitters for which the LLD specifica-tion applies.

178c

TABLE 4.8.B-2 i

RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS

, Channel Instrument Source Channel Functional Instrument, Check,_ Check Calibration Test

! 1. Gross Beta or Gamma Radioactivity i Monitors Providing Alarm and Auto-matic Isolation 3

a. Liquid Radwaste Effluents Line

• N.A. Once per Quarterly 1 operating

! cycle

. 2. Flow Rate Measurement Devices 4

a. Liquid Radwaste Effluent Line

• N.A. Once per Quarterly t;

operating gg cycle i

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• During or prior to release via this pathway.

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS RADI0 ACTIVE EFFLUENTS 3.8.C Liquid Waste Treatment 4.8.C Liquid Waste Treatment Applicability 1. Doses due to liquid releases to UNRESTRICTED AREA shall be At all times projected at least once per 31 day period in accordance

1. The liquid radwaste treatment with the ODCM.

system shall be maintained and used to reduce the radio- 2. The liquid radwaste treatment active materials in liquid system schematic is shown in wastes prior to their dis- Figure 4.8.C.1.

charge when the dose due to liquid effluent releases to UNRESTRICTED AREAS when averaged in a 31 day period would exceed 0.06 mrem to the total body or 0.20 mrem to any organ.

Action

a. With radioactive liquid waste being discharged without treatment and in excess of the above lim-its, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, a Special Report which 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 inoper-ability.

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

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

179

4 HIGH PURITY Discharge W M SY REM

or Recycle 2

Clean Waste Mixed' Bed Treated Water Tanks Ionex Tanks 4

LOW PURITY . Discharge y g

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Chemical Waste Tanks I DETERGENT U Discharge (Decon Areas) m- p 1

j Misc Waste Tanks i

1 Figure 4.8.C.1. Liquid Effluent Treatment System Schematic

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS-RADI0 ACTIVE EFFLUENTS 3.8.D Gaseous Effluents Dose Rate 4.8.D Gaseous Effluents Dose Rate Applicability 1. The instantaneous dose rate due to noble gases in At all times. gaseous efffluents shall be determined continuously *

1. The instantaneous dose to be within the limits of rate due to radioactive 3.8.D.1.a in accordance with materials released in the ODCM.

gaseous effluents from the site to areas at and beyond 2. The instantaneous dose rate the SITE B0UNDARY (see Figure due to iodine-131, tritium, 1.1 page Sc) shall be limited and all radionuclides in to the following: particulate form with half-lives greater than 8 days in

a. For noble gases: Less gaseous effluents shall be deter-than or equal to 500 mined to be within the above mrem /yr to the total body limits in accordance with the and less than or equal to 0DCM by obtaining representa-3000 mrem /yr to the skin, tive samples and performing and analyses in accordance with the sampling and analysis program

b. For iodine-131, for trit- specified in Table 4.8.E-1.

ium, and for all radionu-clides in particulate form with half livcs *By utilizing the Noble Gas greater than 8 days: Activity Monitors and their Less than or equ'al to appropriate setpoints.

1500 mrem /yr to any organ.

Action With the instantaneous dose rate (s) exceeding the above limits, without delay restore the release rate within the above limits (s).

180

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS I INSTRUMENTATION 3.8.E Radioactive Gaseous Effluent 4.8.E Radioactive Gaseous Effluent Instrumentation Instrumentation Applicability 1. The setpoints shall be deter-mined in accordance with ODCM.

As shown in Table 3.8.E-1.

2. Each radioactive gaseous

1. The radioactive gaseous pro- process or effluent monitor-cess and effluent monitoring ing instrumentation channel instrumentation channels shown shall be demonstrated OPERABLE in Table 3.8.E-1 shall be at the frequencies shown in OPERABLE with their alarm / trip Table 4.8.E-2.

setpoints set tc ensure that the limits of Specification 3.8.D.1 are not exceeded.

Action

a. With a radioactive gaseous process or effluent moni-toring instrumentation channel alarm / trip set-points less conservative than a value which will ensure that the limits of 3.8.D.1 are met, declare the channel inoperable.

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b. With one or more radio-active gaseous process or effluent monitoring in-l strumentation channels inoperable, take the ACTION shown in Table 3.8.E-1.

181

l TABLE 3.8.E-1

.RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument Operable Applicability Parameter Action

1. Main Stack Effluent Monitoring System

a. Noble Gas Activity Monitor . (1)

• Radioactivity Rate Measurement 3

b. Iodine Sampler Cartridge (1)

• Collect Halogen Sample 4

c. Particulate Sampler Filter (1)

• Collect Particulate g Sample 4

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d. Effluent System Flow Rate Measuring Device (1)

• System Flow Rate Measurement 2

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e. Sampler Flow Rate Measuring Device (1)

• Sampler Flow Rate Measurement 2

2. Reactor Building Ventilation Effluent Monitoring System

a. Noble Gas Activity Monitor (1)

• Radioactivity Rate Measurement 3

b. Iodine Sampler Cartridge (1)

• Collect Halogen

Sampie 4

c. Particulate Sampler Filter (1)

• Collect Particulate Sample 4 1

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TABLE 3.8.E-1 (Continued)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument Operable Applicability Parameter Action

2. Reactor Building Ventilation Effluent Monitoring System (Continued) 4

d. Effluent System Flow Rate Measurement Device (1)

• System Flow Rate Measurement 2

e. Sampler Flow Rate Measurement (1)

• Sampler Flow Rate

Device Measurement 2 i $b

3. Steam Jet Air Ejector Radioactivity j Monitor

a. Noble Gas Activity Monitor (1) *** Noble Gas Radio-l (Providing alarm and auto- activity Rate j isolation of stack) Measurement 1

4. Augmented Offgas Treatment

System Explosive Gas Monitoring

a. Hydrogen Monitor (1) ** Hydrogen Concentration 5 Measurement i

1

TABLE 3.8.E-1 (Continued)

TABLE NOTATION,

• During releases via this pathway.

• • During augmented offgas treatment system operation.

• • • During operation of the steam jet air ejector.

ACTION 1 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, gases from the steam jet air ejector may be released to the offgas system for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided:

a. The augmented offgas treatment system is not bypassed, and

b. The offgas delay system noble gas activity effluent (downstream) monitor is OPERABLE; otherwise, be in at least HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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 />.

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 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 .

activity 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 Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days, provided samples are continuously collected with auxiliary sampling equipment as required in Table 4.8.E-1.

ACTION 5 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, operation of this waste gas holdup system may continue provided grab samples are collected 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 analyzed within the following 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> i and proper function of the recombine, is assured by monitoring recombiner temperature.

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181c

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TABLE 4.8.E-1 RADIOACTIVE GASE0US WASTE SAMPLING AND ANALYSIS PROGRAM l l l l l l l l Minimum IType of l (a) ll l l Sampling l Analysis lActivity I (LLD) l l Gaseous Release Type l Frequency l Frequency l Analysis l (uCi/ml) l i i I l l l l l l l Principal I l l l Monthly l l Gamma l l l l Grab l Monthly lEmmiters (b) I 1 x 10-4 l l l Sampie l l l l l l l lH-3 l 1 x 10-6 l l Main Stack l l l l l Continuous (d) lI WeeklyCharcoal(c) 1I-131 l 1 x 10-12 l[

l and l l Sample l l l l l l 1 I I l Rx Bldg. Vent l Weekly l l l l l Continuous (d) l l Particulate (c)l Principal l l l l l Sample l Gamma l l l l lEmmiters(b) l 1 x 10-11 ll l l l l(I-131, I l l l l l others) l l l l Monthly l l l l Continuous (d) ll Particulate Igross alpha l 1 x 10-11l l l l l Sample l l l l l l 1 I I l l Quarterly l l l l Continuous I (d) l Particulate ISr-89, Sr-90 l 1 x 10-11l l l l l Sample l l l l l l l l l l l l l l l l Continuous l(d) l Continuous Noble Gas l Noble Gases I (g) l l l l Monitor IGross Gamma l 1 x 10-0 l TABLE NOTATION (4.8.E-1)

a. Refer to ODCM for LLD definition.

b. Refer to 0DCM for LLD exceptions.

c. When the average daily gross radioactivity release rate increases by 50 percent (after factoring out power level changes) over the previous day, the fodine and particulate filters shall be analyzed to determine the release rate for iodines and particulates.

d. The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specifications 3.8.D.

e. For the Xe-133 isotope as determined by using a solid source equivalent to a volume gaseous source.

181d

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j TABLE 4.8.E-2

RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Instrument

Instrument Source Instrument Functional Instrument Check Check Calibration Test

1. Main Stack Effluent Monitoring System

a. Noble Gas Activity Monitor Daily

• Monthly Once per Quarterly (Two channels) operating cycle

b. Iodine Sampler Cartridge N.A. N.A. N.A. N.A.

} c. Particulate Sampler Filter N.A. N.A. N.A. N.A.

g d. Effluent System Flow Rate _

Once per Quarterly g Measuring Device Daily

• N.A. operating

. cycle 2

e. Sampler Flow Rate Measuring Once per Quarterly i Device Daily

• N.A. operating

cycle

2. Reactor Building Ventilation 4 Effluent Monitoring System

a. Noble Gas Activity Monitor Daily

• Monthly Once per Quarterly

operating

cycle l b. Iodine Sampler Cartridge N.A. N.A. N.A. N.A.

c. Particulate Satnpler Filter N.A. N.A. N.A. N.A.

d. Effluent System Flow Rate Once per Quarterly Measuring Device Daily

• N.A. operating cycle I

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TABLE 4 S.E-2 (Continued)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Instrument Instrument Source Instrument Functional Instrument Check Check Calibration Test

e. Sampler Flow Rate Measuring Once per Quarterly Device Daily

• N.A. Operating cycle

3. Steam Jet Air Ejector Radioactivity Monitor i

a. Noble Gas Activity Monitor Daily *** N.A. Once per Quarterly operating cycle j Es t; 4. Augmented Offgas Treatment System Explosive Gas Monitoring System

a. Hydrogen Monitor Daily ** N.A. Quarterly Monthly

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• During releases via this pathway.

• • During augmented offgas treatment system operation.

• • • During operation of the Steam Jet Air Ejector.

J

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS RADI0 ACTIVE EFFLUENTS 3.8.F Gaseous Effluent Treatment

• 4.8.F Gaseous Effluent Treatment

• Applicability 1. Doses due to gaseous re-leases from the site shall Within 4 hrs after placing be projected at least once the Reactor Mode Switch to per 31 day period in accord-

"Run" position. ance with the ODCM.

1. The gaseous effluent treatment *The gaseous effluent treat-system shall be maintained ment schematic is shown in and used to reduce radioactive Figure 4.8.F.1.

materials in gaseous wastes prior to their discharge when the estimated gaseous effluent air doses due to gaseous effluent releases to UNRE-STRICTED AREAS when averaged over 31 days would exceed 0.2 mrad for gamma radiation and 0.4 mrad for beta radiation.

Action

a. With gaseous effluents being discharged for more

, than 31 days without treat-

! ment and in excess of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, a Special Report which includes the following information:

l l 1. Explanation of why gaseous radwaste was l

being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability.

l l

182

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS 3.8.F (Continued) 4.8.F (Continued)

2. Action (s) taken to restore the non-operable equipment

-to OPERABLE STATUS, and

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

2. The concentration of hydrogen 2. The concentration of hydrogen in the augmented offgas treat- in the augmented offgas treat-ment system shall be limited ment system shall be determined to less than or equal to to be within the above limits 2 percent by volume at the by continuously monitoring the outlet of the recombiner. waste gases in the augmented offgas treatment system with Action the hydrogen monitor required OPERABLE by Table 3.8.E-1.

i a. With the concentration of hydrogen in the augmented offgas treatment system I- greater than 2 percent by volume but less than or equal to 4 percent by i volume, restore the con-centration of hydrogen to i within the limit within 48 hr or be in a cold shutdown condition within 24 hrs.

l

3. Whever the augmented offgas '

l treatment system is bypassed, minimum dilution air flow to

the stack shall be maintained.

i i

182a

....,_.,-...,___._,,.,.____,,_.,-.___.,,.._,y_ ~ _ . , . _ , ,,.,,,_r...,.-,_n-,,ym. ,,,,m_--,...mm.__,m .m . .m_,._,, ,.,- .-,.w,-

- from to Stack Main .

'  ; w ,

- SJAE Condancer Recombiner Condenser Drier Charcoal from to Stack

.Turbina 7  ;

GIAND Glind Seals SEALS 1.7-minute Holdup *

'from to Stack Main w MECHANICAL

, Ccndanser VACUUM PUMP I

from to Vent Rccctor > REACTOR Bldg BUILDING from to Vent Drywall -

> DRYWELL R:dw2.ste to Vent RADWASTE E

BUILDING from to Vent Turbina  ; TURBINE Bldg BUILDING

• Na significant effect in reducing offsite doses when compared to transit time required for releases to reach site Boundary.

Figure 4.8.F.1. Gaseous Effluent Treatment System Schematic l 182b l

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS RADI0 ACTIVE EFFLUENTS 3.8.G Main Condenser 4.8.G Main Condenser Applicability 1. The gross radioactivity (beta and/or gamma) rate At all times when steam is of noble gsses from the available to the air ejectors. steam jet air ejector shall be determined to be within

1. The gross radioactivity (beta the limit of 3.8.G,1 at the and/or gamina) release rate of following frequencies by per-noble gases measured at the forming an isotopic analysis steam jet air ejector shall of a representative sample of be limited to 500,000 uCi/sec gases taken at the discharge (referenced to a 30 minute (prior to dilution and/or dis-hol dup) . charge) of the steam jet air ejector:

Action

a. At least once per 31 days.

With the gross radioactivity (beta and/or gamma) rate of b. When the average daily noble gases at the steam jet gross activity release air ejector exceeding 500,000 rate increases by 50 per-uCi/sec (referenced to a cent over the previous 30 minute holdup), restore day.

the gross radioactivity rate to within its limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

183

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

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS l 3.8.H Mechanical Vacuum Pump 4.8.H Mechanical Vacuum Pump

1. The mechanical vacuum pump At least once during each shall be capable of being operating cycle verify auto-isolated and secured on a matic securing and isolation signal of high radioactivity of the mechanical vacuum pump.

in the steam lines whenever the main steam isolation valves are open.

2. If the limits of 3.8.H are not met, the vacuum purap shall be isolated.

i 184

BASES 3.8.A LIQUID EFFLUENTS CONCENTRATION and 4.8.A This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II. This limitation provides additional assurance that the levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will not result in exposures within (1) the Sectirn

. II.A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC and (2) the limits of 10 CFR Part 20.106(e) to the population.

1 1 185

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

BASES 3.8.B RADI0 ACTIVE LIQUID EFFLUENT INSTRUMENTATION and 4.8.B 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 in accordance with NRC approved methods in the ODCM to ensure that the 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, 63 and 64 of Appendix A to 10 CFR Part 50.

l i

I l

l i 186 i

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

j BASES 3.8.C m. 'D EFFLUENT TREATMENT and 4.8.C The requirements 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 specification implements the requirements of 10 CFR Part 50.36a, General Design Criteria 60 of Appendix A to 10 CFR Part 50 and design objective Section II.D of Appendix I to 10 CFR Part 50.

The specified limits governing the use of appropriate portions of the liquid radwaste treatment system were specified as a suitable fraction of the guide set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

l 187

BASES 3.8.D GASECUS EFFLUENTS DOSE RATE and 4.8.D This specification is provided to ensure that the dose rate at anytime at and beyond the SITE BOUNDARY from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20. The annual dose limits are the doses associated with the concentration of 10 CFR Part 20, Appendix B, Table II. These limits provide reasonable assur-ance that radioactive material discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC either within or outside the SITE BOUNDARY to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b)).

For MEMBERS OF THE PUBLIC who may at times be within the SITE BOUNDARY, the occupancy of the individual will usually be sufficiently low to com-pensate for any increase in the atmospheric diffusion factor above that for the SITE B0UNDARY. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates aboto background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to < 500 mrem /

year to the total body or to < 3000 mrem / year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to an infant via the cow-milk-infant pathway to

< 1500 mrem / year for the nearest cow to the plant.

188

9 BASES 3.8.E RADI0 ACTIVE GASEOUS PROCESS AND EFFLUENT MONITORING INSTRUMENTATION and 4.0.E The radioactive gaseous effluent instrumentation is provided to monitor

. nd control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous efflu-ents. The alarm / trip setpoints for these instruments shall be calculated in accordance with NRC approved methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20.

The process monitoring instrumentation includes provisions for monitor-ing (and controlling) the concentrations of potentially explosive gas mixtures in the main condenser offgas treatment system. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

189

BASES 3.8.F GASE0US EFFLUENT TREATMENT and 4.8.F The requirement thdt the appropriate portions of these syste.ns be used when specified provides reasonable assurance that the releases of radio-active materials in gaseous effluents will be kept "as icw as is reason-ably achievable." This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and design objective Section IID of Appendix I to 10 CFR Port

50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the guide set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

Maintaining the concentration of hydrogen below it's flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criteria 60 of Appendix A to IDCFR Part 50.

d 190 l

l l . _ -.

BASES 3.8.G MAIN CONDENSER and 4.8.G Restricting the gross radioactivity rate of noble gases from the main condenser provides reasonable assurance that the total body exposure to a MEMBER OF .THE PUBLIC at and beyond the SITE BOUNDARY will not exceed a small fraction of the limits of 10 CFR Part 100 in the event this effluent is inadvertently discharged directly to the environment without treatment.

This specification implements the requirements of General Design Criteria 60 and 64 of Appendix A to 10 CFR Part 50.

I 191

BASES i 3.8.H MECHANICAL VACUUM PUMP and g 4.8.H The purpose of isolating the mechanical vacuum pump line is to limit the release of activity from the main condenser. During an accidient, fission products would be transported from the reactor through the main steam lines to the condenser. The fission product radioactivity would be sensed by the main steam line radioactivity monitors which initiate i solation.

192

l THIS PAGE INTENTIONALLY LEF1 BLANK l

l 193

L

.f. Review of facility operations .to detect potential safety hazards.

g. Performance of special reviews and investigations and reports thereon as requested by the NSRAC Chairman.

h. Review of the Station Security Plan and implementing procedures and changes to the plan and procedures,

i. Review of the Emergency Plan and implementing procedures and changes -to the plan and procedures.

j. Review of changes to:the OFFSITE DOSE CALCULATION MANUAL (0DCM).

k. . Review of every unplanned onsite release of radioactive material

.to the environs including the reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence to the Vice President - Nuclear and to the Nuclear Safety Review and Audit Committee (NSRAC).

7. AUTHORITY The ORC shall:

a. Inform'the Nuclear Operations Manager in writing their approval or disapproval of items considered under 6.5.A.6(a) through (d)

, above.

> b. Render determinations in writing with regard to whether or not

• each item considered under 6.5.A.6(a) through (e) above consti-tutes an unreviewed safety question.

c. Provide immediate written notification to the Nuclear Operations Manager and the Nuclear Safety Review and Audit Committee of disagreement between the ORC members and the ORC Chairman. The Nuclear Operation Manager shall have responsibility for resolu-tion for such disagreements pursuant to 6.1 above.

8. RECORDS The ORC shall maintain written minutes of each meeting and copies shall be provided to the Nuclear Operations Manager and NSRAC Chairman.

B. NUCLEAR SAFETY REVIEW AND AUDIT COMMITTE (NSRAC)

.1. FUNCTION The NSRAC shall function to provide independent review and audit of I designated activities in the areas of:

i 213 l

O

1. nuclear power plant operations;

2. nuclear engineering;

3. ~ chemistry and radiochemistry;

4. metallurgy;

5. instrumentation and control;

6. radiological safety;

7. mechanical and electrical engineering;

8. quality assurance practices;

9. fire protection.

2. COMPOSITION The NSRAC Chairman and other members shall be appointed by the Vice President - Nuclear, or such other person as he shall designate. NSRAC members shall collectively possess experience and competence required to review and audit the designated areas noted in 6.5.B.1.

t l

l 1

i 213a

, . - . , - . - - - - ~ . - _ , 4,m- , pwy.. -n-4,+,,,,,e , - ,,-m.,-, , .---,..,y,-, -

, - . , , - - -y-- , ,,, . - , - - --, - , -, ,, -n, , , ,- , , , - e , , a.~, -

g. All events which are required by regulation or Technical Speci-fications to be reported to the NRC in writing within 24 hrs.

h. Any other matter involving safe operation of the nuclear plant which NSRAC deems appropriate for consideration or which is referred to NSRAC by the onsite operating organization or by other functional organizational units within Boston Edison.

i. Reports and meeting minutes of the Operations Review Committee.

8. AUDITS Audits of facility activities shall be performed under the cognizance of the NSRAC. These audits shall encompass:

a. The conformance of f acility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per year.

b. The training and qualifications of the entire facility staff at least once per year.

c. The results of all actions required by deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per six months.

d. The performance of all activities required by the Quality Assur-ance Program to meet the criteria of Appendix B,10 CFR 50, at least once per two years.

e. The Emergency Plan and implementing procedures at least once per two years.

f. The Station Security Plan and implementing procedures at least once per two years.

g. Any other area of facility operation considered appropriate by NSRAC or the Vice President - Nuclear.

h. The Fire Protection Program and implementing procedures at least once per two years.

i. The Radiological Environmental Monitoring Program and the results thereof at least once every 12 months.

J. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.

9. AUTHORITY The NSRAC shall report to and advise the Vice President - Nuclear on those areas of responsibility specified in Section 6.5.B.7 and 6.5.B.8.

215

10. RECORDS Records of NSRAC activities shall be prepared, approved and distrib-uted as indicated below:

a. Minutes of NSRAC meeting shall be prepared, approved and forwarded to the Vice President - Nuclear, NSRAC members, and others the Chairman may designate, within 14 days following each meeting.

a

{

4

}

l 1 215a '

.a

• Note: Item i is intended to provide for reporting of potentially generic problems. j

j. Offsite releases or radioactive materials in liquid and gaseous i

effluents that exceed the limits of Specification 3.8.A and 3.8.D.

2. THIRTY DAY WRITTEN REPORTS

, The reportable occurrences discussed below shall be the subject of written reports to the Director of the appropriate Regional Office within thirty days of occurrence of the event. The written report shall include, as a minimum, a completed copy of a licensee event report form. Information provided on the licensee event report form shall be supplemented, as needed,. by additional narrative material to provide complete explanation of the circumstances surrounding the event.

a. Reactor protection system or engineered safety feature instru-ment settings which are found to be less conservative than those established by the technical specifications but which do not prevent the fulfillment of the functional requirements of affected systems.

b. Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation.

Note: Routine surveillance testing, instrument calibration, or preventative maintenance which require system configurations as described in items 6.9.B.2.a and 6.9.B.2.b need not be reported except where test results themselves reveal a degraded mode as described above.

c. Observed inadequacies in the implementation of administrative or procedural controls which threaten to cause reduction of degree of redundancy provided in reactor protection systems or engineered safety feature systems.

d. Abnormal degradation of systems other than those specified in item 6.9.B.1.c above designed to contain radioactive material resulting from the fission process.

I Note: Sealed sources or calibration sources are not included under this item. Leakage of valve packing or gaskets within the limits for identified leakage set forth in technical specifi-cations need not be reported under this item.

e. Any changes in corporate or station organization as described in Section 6.2.

1 222

l l

1 J-C. UNIQUE REPORTING REQUIREMENTS

1. RADIOACTIVE EFFLUENT RELEASE REPORT i

A report shall be submitted to the Commission within 60 days after t

January,1 and July,1 of each year specifying the quantity of each  ;

of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents during the previous 6 months. The format and content of the report shall be in accordance with Regu-latory Guide 1.21 (Revision 1) dated June,1974.

2. ENVIRONMENTAL PROGRAM DATA Annual Radiological Environmental Monitoring Report. A report on the radiological environmental surveillance program for the previous calendar year of operation shall be submitted to the Director of the NRC Regional Office with a copy to the Director, Office of

- Nuclear Reactor Regulation) as a separate document prior to May 1 i of the year. The reports shall include summaries, interpretations, and statistical evaluation of the results of the radiological environ-mental surveillance activities for the report _ period, including a comparison (as appropriate) with preoperational studies, operational controls and 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 any land use surveys which affect the choice of sample locations. If harmful effects or evidence of irreversible damage are detected by

. the monitoring, the licensee shall provide an analysis of the problem and a proposed course of action to alleviate the problem.

The Annual Radiological Environmental Monitoring Reports shall include j a summary of 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 anal- '

yses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

In the event that some results are not available prior to May 1 of the year, 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 report 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;

• 0ne map shall cover stations near the site boundary; a second shall include the more distant stations.

223

the results of licensee participation in the Interlaboratory Com-parison Program, required by Specification 7.1.C discussion of all deviations from the sampling sch dule of Table 8.1.A-1 and discussion of all analyses in which the LLD required by Table 8.1.A-4 was not achievable.

OFFSITE DOSE CALCULATION MANUAL (ODCM)

3. Any changes to the ODCM shall be submitted to the Commission within 90 days from which the change (s) was made effective.

l l

223a

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

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.0 Radiological Environmental .8. 0 Radiological Environmental Monitoring Program Monitoring Program Applicability: 8.1 Monitoring Program A. The radiological environ-At all times. mental monitoring samples shall be collected pursu-7.1 Monitoring Program ant to Table 8.1. A-1 from A. An environmental monitoring the specific locations program shall be conducted given in the table and to evaluate the effects of figure (s) in the ODCM station operation on the and shall be analyzed environs and to verify the pursuant to the require-effectiveness of the ments of Table 8.1. A-1, and source controls on radio- the detection capabilities active materials. required by Table 8.1.A-4.

The radiological environ- (1) Cumulative dose con-mental monitoring program tributions for the shall be conducted as current calendar specified in Table 8.1. A-1 year from radionu-clides detected in environmental samples Action: shall be determined in accordance with

1. . With the radiological the methodology and environmental monitoring parameters in the program not being conduct- ODCM. These results ed as specified in Table will be reported in 8.1.A-1, in lieu of a the Annual Radiolog-Licensee Event Report, ical Environmental prepare and submit to the Monitoring Report.

Commission, in the Annual l

Radiological Environmental Monitoring Report required by Specification 6.9.C.2, a description of the i reasons for not conducting l

the program as required and the plans for prevent-c ing a recurrence.

2. With the level of radio-

j. activity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 7.1.A when averaged over any calendar quarter, in 229

i OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.1 (Continued)

, lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, a Spacial Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce radioactive efflu-ents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year limits of Specifications 7.2. A, 7.3.A-and 7.4.A. When more than one of the radionuclides in Table 7.1.A are detected in the sampling medium, this report shall be submitted if:

concentration (1) + concentration (2) + . . 2. 1. 0 reporting level (1) reporting level (2) l When radionuclides other than those in Table 7.1.A 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 is equal to or greater than the calendar year limits of Specifications 7.2.A, 7.3.A, and 7.4.A. This I report is not required if the measured level of radioactivity was not the result of plant efflu-ents; however, in such an

! event, the condition -

shall be reported and described in the Annual Radiological Environmental Monitoring Report.

l 229a

OPERATIONAL OB.1ECTIVES SURVEILLANCE REQUIREMENTS I 1

7.1 (Continued)

3. With milk or fresh leafy vegetable samples unavail-able from one or more of the sample locations required by Table 8.1.A-1, identify locations for obtaining replacement samples and add them to the Radiological Environ-mental Monitoring Program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitor-ing program.

In lieu of a Licensee .

Event Report and Pursu-ant to Specification 6.9.C.2, identify the cause of the unavailabil-ity of samples and ident-ify the new location (s) obtaining replacement samples in the next Annual Environmental Radiation Monitoring Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

a 229b

.i TABLE 7.1.A REPORTING LEVELS FOR RADI0 ACTIVITY CONCENTRATIONS IN ENVIRONENTAL SAWLES Reporting Levels Water Airborne Particulate Fish Milk Vegetables Analysis (pCi/L) or Gases (pCi/MJ) (pCi/Kg, wet) (pCi/1) (pCi/Kg, wet)

, H-3 2 x 104 Mn-54 1 x 103 3 x 104 Fe-59 4 x 102 1 x 104 Co-58 1 x 103 3 x 104 g Co-60 3 x 102 1 x 104 i e Zn-65 3 x 102 2 x 104 Z r-95 4 x 102 I-131 2 0.9 3 1'x 102 l

i Cs-134 30 10 1 x 103 60 1 x 103 Cs-137 50 20 2 x 103 70 2 x 103 Ba-140 2 x 102 3 x 102

TABLE 8.1.A-1 i

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Locations Exposure Pathway (Direction-Distance) Sampling and Type and Frequency or Sample Type from Reactor Collection Frequency of Analysis AIRBORNE Particulates 11 (See Table 8.1. A.2) Continous sampling over Gross beta radioactivity one week at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after filter change. (a) Quar-terly composite (by location) for gamma isotopic. (b)

Radioiodine 11 (See Table 8.1.A-2) Continuous sampling with Analyze weekly for I-131.

canister collection weekly pg DIRECT 40 (See Table 8.1. A-3) Quarterly Gamma exposure quarterly. (i) e

" Plymouth Beach and Priscilla/ White Horse Annually (Spring) Gamma exposure survey (i)

Beach WATERBORNE Discharge Canal Continuous Composite Gamma isotopic (b) monthly; j (Surface Water) Sample and composite for H-3 Bartlett Pond Weekly grab sample analysis quarterly, (c).

! (SE-1.7 mi.)

Powder Point Weekly grab sample (NNW-7.8 mi.) (d)

AQUATIC Shellfish Discharge outfall Quarterly (at approximate Gamma isotopic (b); also (clams, mussels Duxbury Bay 3 month intervals) see note (f).

or quahogs as Mananet Pt.

available) Plymouth or Kingston i

Harbor Marshfield (d)

TABLE 8.1.A-1 (Ccntinu:d)

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Locations Exposure Pathway (Direction-Distance) Sampling and Type and Frequency 1

or Sample Type from Reactor Collection Frequency of Analysis Lobster Vicinity of discharge Four times per season Gamma isotopic (b) on

, point edible portions Offshore (d) Once per season l Fish Vicinity of discharge Quarterly (when particular Gamma isotopic (b) on

, point species available), Groups edible portions (e)

Offshore (d) I and II (e) In season, i

i Groups III and IV (e)

Annually, each group Sediments Rocky Point Semi-annually Gamma isotopic (b) y Plymouth Harbor (c), see also note (g) y Duxbury Bay Plymouth Beach Manomet Pt.

Marshfield INGESTION 2

(Terrestrial)

Milk Plymouth County Farm

• Semi-monthly during Gamma isotopic (b); radio-(W-3.5 mi) (h) Whitman periods when animals are iodine analysis all samples.

l Fam (NW-21 mi.) (d) on pasture, otherwise i

monthly Cranberries Manomet Pt. Bog At time of harvest Gamma isotopic (b) on edible (SE-2.6 mi.) portions.

Bartlett Rd. Bog (SSE/S-2.8 mi.)

Pine St. Bog (WNW-17 mi.) (d)

• When available.

TABLE 8.1.A-1 (Continued)

OPERATIONAL RADIOLOGICAL ENVIRONENTAL MONITORING PROGRAM Locations Exposure Pathway (Direction-Distance) Sampling and Type and Frequency or Sample Type from Reactor Collection Frequency of Analysis Tuberous and green Plymouth County Farm At time of harvest Gamma isotopic (b) on edible leafy vegetables (W-3.5 min.) (h) portions.

! Bridgewater Farm (W-20 mi.) (d)

Beef Forage Plymouth County Farm Annually Gamma isotopic (b)

(W-3.5 mi.) (h)

Whitman Farm (NW-21 mi)

(d).

i l3 l

}

J 1

I i

a

TABLE 8.1.A-1 (Continued)

NOTES (a) If gross beta radioactivity is greater than 10 times the control value, gamma isotopic will be performed on the sample.

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

(c) If integrated gamma activity (less K-40) is greater than 10 times the control value (less K-40), strontium-90 analysis will be performed on the sample.

(d) Indicates control location.

(e) Fish analyses will be performed on a minimum of 2 sub-samples, consisting of approximately 400 grams each from each of the following groups:

I. Bottom Oriented II. Near Bottom III. Anadromous iV. Coastal Distribution Migratory Winter flounder Tautog Alewife Bluefish Yellowtail founder Cunner Rainbow smelt Atlantic herring Atlantic cod Striped bass Atlantic menhaden Pollock Atlantic mackerel Hakes (f) Mussel samples from four locations (immediate vicinity of discharge outfall, Manomet Pt., Plymouth or Kingston Harbor, and Green Harbor in Marshfield) will be analyzed quarterly as follows:

One Kilogram wet weight of mussel bodies, including fluid within shells will be collected. Bodies will be reduced in volume by drying at about 100*C.

Sample will be compacted and analyzed by Ge(Li) gamma spectrometry or alter-nate technique, if necessary, to achieve a sensitivity ** of 5 pCi/kg for Cs-134, Cs-137, Co-60, 2n-65 and Zr-95 and 15 pCi/kg for Ce-144.

The mussel shell sample from one location will be analyzed each quarter.

One additional mussel shell sample will be analyzed semi-annually.

Unscrubbed shells to be analyzed will be dried, processed, and analyzed similarly to the mussel bodies.

N* Sensitivity values are to be determined in accordance with a 95% confidence level on Ka ; 50% confidence level on Kg (See HASL-300 for definitions).

2299

TABLE 8.1.A-1 (Continued)

NOTES-Because of the small volume reduction in pre-processing of shells, sensi-tivities attained will be less than that for mussel bodies. The equipment 4

and counting times to be employed for analyses of shells will be the same or comparable to that employed for mussel bodies so that the reduction in sensi-tivities (relative to those for mussel. bodies) will be strictly limited to the effects of poorer geometry related to lower sample volume reduction.

Shell samples not scheduled for analysis will be reserved (unscrubbed) for possible later analysis.

If radiocesium (Cs-134 and Cs-137) activity exceeds 200 pCi/kg (wet) in mussel bodias, these samles will be analyzed by radiochemical separation, electrodeposition, and alpha spectrometry for radioisotopes of plutonium, with a sensitivity of 0.4 pCi/kg.

(g) Sediment samples from four locations (Manomet Pt. , Rocky Pt. , Plymouth i Harbor, and head of Duxbury Bay) will be analyzed once per yecr (preferably early summer) as follows:

Cores will be taken to depths of 30-cm, minimum depth wherever sediment conditions permit by a hand-coring sampling device. If sediment conditions do not permit 30-cm deep cores, the deepest cores achievable with a hand-coring device will be taken. In any case, core depths will not be less than 14-cm. Core samples will be sectioned into 2-cm increments, and surface and alternate increments analyzed, other reserved. Sediment sample volumes (detennined by core diameter and/or number of individual cores taken from any single location) and counting technique will be sufficient to achieve sensitivities of 50 pCi/kg dry sediment for Cs-134, Cs-137, Co-60, Zn-65, and Zr-95 and 150 pCi/kg for Ce-144. In any case individual core diameters will not be less than 2 inches.

The top 2-cm section from each core will be analyzed for Pu isotopes (Pu-238, Pu-239,240) using radiochemical separations, electrodeposition, and alpha spectrometry with target sensitivity of 25 pCi/kg dry sediment. Two additional core slices per year (mid-depth slice from two core samples) will be similarly analyzed.

l (h) These locations may be altered in accordance with results of surveys discussed in paragraphs 8.1. A-3 and 8.1. A-4.

j (i) Minimum sensitivities for gamma exposure measurements are as follows:

! Gamma exposure - 1 R/hr average exposure rate.

l Gamma exposure survey - 1 R/hr exposure rate.

229h

_ _ _ _.. _ . _ . . _ .__-_..~._._.._.-_.___.____._-_______.__.__t.

TABLE 8.1.A-2 AIR PARTICULATES, GASEOUS RADI0 IODINE AND S0IL SURVEILLANCE STATIONS Sampling Location Distance and (Sample Designation) Direction from Reactor Offsite Stations East Weymouth (EW)* 21 miles NW*

Plymouth Center (PC) 4.0 miles W-WNW Monomet Substation (MS) 2.5 miles SE Cleft Rock Area (CR) 0.9 miles S Onsite Stations Rocky Hill Road (ER) 0.8 miles SE Rocky Hill Road (WR) 0.3 miles W-WNW Overlook Area (0A) 0.03 miles W Property Line (PL) 0.34 miles NW Pedestrian Bridge (PB) 0.14 miles N East Breakwater (EB) 0.35 miles ESE Warehouse (WS) 0.03 miles SSE r

l

• Control Station 2291

,,,_.+nn-, , .-,.--.-m - , - ,- -- -,- , - , . , --e-- , - - - , -,-,v-r- . - - - - , - -w-n-- -ar-ve-=-- +s-~A- -

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TABLE 8.1.A-2 EXTERNAL GAMMA EXPOSURE SURVEILLANCE STATIONS (TLD)

Distance and Dosimeter Location (Designation) Direction from Station ONSITE STATIONS Property Line (D) 0.17 miles NNW Property Line (F) 0.12 miles NW Property Line (I) 0.14 miles W Property Line (G) 0.20 miles WSW Rocky Hill Road (A) 0.12 miles SW

, Property Line (H) 0.21 miles SSW Public Parking Area (PA) 0.07 miles N-NNE Pedestrian Bridge (PB) 0.1 miles NE Overlook Area (0A) 0.03 miles W East Breakwater (EB) 0.26 miles ESE Property Line (C) 3.3 miles ESE-SE Property Line (HB) 0.34 miles SE Rocky Hill Road (B) 0.26 miles SSE Microwave Tower (MT) 0.38 miles S Emerson Road (EM) 0.68 miles SE-SSE White Horse Road (WH) 0.89 miles SE-SSE Property Line (E) 0.75 miles SSE-S Rocky Hill Road (WR) 0.3 miles W-WNW Property Line (J) 1.36 miles SSE-S

! Property Line (K) 1.42 miles SSE-S Rocky Hill Road (ER) 0.8 miles SE Property Line (L) 0.40 miles E j

229j

- . - = - ' - = -

-w =- - r- - - - *---~-% '- --=+ --- - -v--*-*-- - --**-- ' ' - -

TABLE 8.1.A-2 (Continued)

EXTERNAL GAMMA EXPOSURE SURVEILLANCE STATIONS (TLD)

Distance and Dosimeter Location (Designation) Direction from Station ONSITE STATIONS (Continued)

Warehouse (WS) 0.1 miles SE Property Line (PL) 0.3 miles W 0FFSITE STATIONS Duxbury (SS) 6.25 miles SSW-SW Kingston (KS) 10 miles WNW North Plymouth (NP) 5.5 miles WNW Plymouth Center (PC) 4.0 miles W-WNW South Plymouth (SP) 3 miles WSW Bayshore Drive (BD) 0.7 miles W-WNW Cleft Rock Area (CR) .0.9 miles S Manomet (MP) 2.25 miles ESE-S Manomet (ME) 2.5 miles SE Manomet (MS) 2.5 miles SSE Manomet (MB) 3.5 miles SE-SSE College Pond (CP) 6.5 miles SSW-SW Sagamore (CS) 10 miles SSE-S Plymouth Airport (SA) 8 miles WSW East Weymouth (EW)* 21 miles NW Saquish Neck (SN)** 4.6 miles NNW

• Control Station

• • TLD's for this location will be provided to a third party and will be analyzed for gamma exposure whenever returned to BECo.

229k

TABLE 8.1.A-4 MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION (LLD)a Airborne Particulate Water or Gas Wet Solids Milk Food Products Dry Solids Analysis (pCi/kg) (pCi/m3) (pCi/kg, wet) (pCi/kg) (pCi/kg, wet) (pCi/kg, dry) gross beta 4b 1 x 10-2 3H 2000 54Mn 15 130 59pe 30 260 g 58,60C0 15 130 50 w

65Zn 30 260 50 95Z r 15 50 b

131; l 7 x 10-2 1 60c 134,137Cs 15, 18 1 x 10-2 130 15 60 50 140Ba d d 15 15 144Ce 150 TABLE NOTATION l a. Refer to ODCM for LLD definition.

b. LLD for surface water.

l

c. LLD for leafy vegatables.

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l Green Harbor a

ce Cape Cod Bay y

Dunbury

• • Y .

e t 2 3 4 s t 0t Mymouth Harbor ***

Mocky Peinr Warren A Cove 0 eb uanomerww stare U peinrs

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O SOFTSHELL CLAMS Harbor e MUSSELS A SEDIMENT E QUAHOGS Figure 8.1.A-1 Typical Mollusc, Algae and Sediment Sampling Stations 229m

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I LEGEND l 1 PROPERTY LINE (D) 13 ROCKY HILL ROAD (B) l 2 PROPERTY LINE (F) 14 MICROWAVE TOWER (MT)

! 3 PROPERTY LINE (I) 15 EMERSON ROAD (EM) 4 PROPERTY LINE (G) 16 WHITE HORSE ROAD (WH) 5 ROCKY HILL ROAD (A) 17 PROPERTY LINE (E) 6 PROPERTY LINE (H) 18 ROCKY HILL ROAD (WR) l 7 PUBLIC PARKING AREA (PA) 19 PROPERTY LINE (J) 8 PEDESTRIAN BRIDGE (PB) 20 PROPERTY LINE (K) 9 OVERLOOK AREA (0A) 21 ROCKY HILL ROAD (ER) 10 EAST BREAKWATER (EB) 22 PROPERTY LINE (L) 11 PROPERTY LINE (C) 23 WAREHOUSE (WS) 12 PROPERTY LINE (HB) 24 PROPERTY LINE (PL) 0 00SIMETER (TLD) i A AIR PARTICULATES AND DOSIMETERS (TLD) i Location of Onsite Monitoring Stations Figure 8.1.A-2 229n l

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LEGEND 1 DUXBURY (SS) 9 MANOMET (E) 2 KINGSTON (KS) 10 MAN 0ET (MS) 3 NORTH PLYMOUTH (NP) 11 MAN 0ET (MB) 4 PLYK)UTH CENTER (PC) 12 COLLEGE POND (CP) 5 SOUTH PLYMOUTH (SP) 13 SAGAK)RE (CS) 6 BAYSHORE DRIVE (BD) 14 PLYMOUTH AIRPORT (SA) 7 CLEFT ROCK AREA (CR) 15 EAST WEYMOUTH (EW) 8 MAN 0ET (W) 16 SAQUISH NECK (SN) l l Figure 8.1.A-3 Location of Offsite Monitoring Stations 2290

l

_ OPERATIONAL OBJECTIVES' SURVEILLANCE REQUIREMENTS 7.1 (Continued) 8.1 (Centinued)

B. Land Use Census B. Land Use Census A land use census shall be The land use census shall be conducted and shall identify conducted during the growing within a distance of 8 km season at least once per 12 (5 miles) the location in months using that information each of the 16 meteorological that will provide the best sectors of the nearest milk results, such as by a door-to-animal, the nearest residence door survey, aerial survey, and the nearest ggrden* of or by consulting local agri-greater than 50 m4 (500 ft2) culture authorities. The producing broad leaf vegeta- results of the land use census tion. (For elevated releases shall be included in the Annual as defined in Regulatory Radiological Environmental Guide 1.111, Revision 1, Monitoring Report.

July 1977, the land use census shall also identify within a Broad leaf vegetation sampling distance of 5 km (3 miles) the of at least three different locations'_in each of the 16 kinds of vegetation may be meteorological sectors of all performed at the SITE B0UND-milk animals and all gardens ARY in each of two different of greater than 5D iH2 produc- direction sectors with the ing broad leaf vegetation. highest predicted D/Qs in lieu of the garden census. Speci-Action fications for broad leaf vege-tation sampling in Table (1) With a land use census 8.1.A-1 shall be followed, identifying a location (s) including analysis of control that yields a calculated samples.

dose or dose commitment greater than the values currently being calculated in Specification 8.4.A, in lieu of a Licensee Event Report, identify the new location (s) in the next Annual Environmental Radiological Monitoring Report.

(2) With a land use census identifying a location (s) that yields a calculated 229p

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.1 (Continued) dose or dose commitment (via the same exposure pathway) 20 percent great-er than at a location from which samples are current-ly being obtained in accordance with Specifi-cation 7.1, add the new location (s) to the Radio-logical Environmental Monitoring Program within 30 days. The sampling location (s), excluding the control station location, having the lowest calcu-lated dose or dose commit-ment (s), via the same exposure pathway, may be deleted from this monitor-ing program after (Octo-ber 31) of the year in which this land use census was conducted. In lieu of a Licensee Event Report, identify the new location (s) in the next Annual Environ-mental Radiological Moni-toring Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new loca-tion (s).

229q

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

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.1 (Continued) 8.1 (Continued)

C. Interlaboratory Comparison C. Interlaboratory Comparison Program Program Analyses shall be performed on A summary of the results radioactive materials supplied obtained as part of the above as part of an Interlaboratory required Interlaboratory Comparison Program that has Comparison Program and in been approved by the Commis- accordance with the metho-sion. dology and parameters in the ODCM shall be included in Action the Annual Radiological Environmental Monitoring (1) With analyses not being Report.

performed as required above, report the correc-tive actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Monitoring Report.

(

i i

229r 1

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.2 Dose - Liquids 8.2 Dose - Liquids Applicability A. Dose Calculations - Cumulative dose contributions from liquid At all times. effluents shall be determined in accordance with the Offsite A. The dose or dose commitment Dose Calculation Manual (0DCM) to a MEMBER OF THE PUBLIC for each calendar month during from radioactive materials which releases occurred.

in 1: quid effluents re-leased to UNRESTRICTED AREAS shall be limited:

1. During any calendar quarter to < 1.5 mrem to the total body and to < 5 mrem to any organ, and-

2. During any calendar year to < 3 mrem to the total body and to < 10 mrem to any organ.

Action (1) With the calculated dose from the release of radio-active materials in liquid effluents exceeding any of the above limits, in lieu of a License Event Report, prepare and submit i to the Commission within 30 days, a Special Report that identifies the l cause(s), corrective actions taken, and correc-tive actions to be taken.

l l

230 I

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.3 Dose-Noble Gases 8.3 Dose-Noble Gases Applicability A. Dose Calculations -

Cumulative dose contributions At all times for the total time period shall.be determined in accord-A. The air dose in areas at and ance with the Offsite Dose beyond the SITE B0UNDARY due Calculation Manual (0DCM) to noble gases released in for each calendar month during gaseous effluents shall be which releases occurred.

limited to the following:

1. During any calendar quar-ter, to < 5 mrad for gamma raTiation and < 10 mrad for beta radiatTon; and

2. During any calendar year, to < 10 mrad for gamna radTation and < 20 mrad for beta radiation.

Action (1) With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, in lieu of a Licensee Event Re-port, prepare and submit to the Commission within 30 days, a Special Report which identifies the cause(s), the correc-tive actions taken, and corrective actions to be taken.

231

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.4 Dose-Iodine 131, Radioactive 8.4 -Dose-Iodine-131, Radioactive Material in Particulate Form, Material in Particulate Form, and Tr1ttum and Tr1ttum Applicability A. Dose Calculations -

Cumulative dose contributions At all times for the total time period shall be determined for iodine-A. The dose to a MEMBER OF THE 131, radioactive material in PUBLIC from iodine-131, radio- particulate form, with half-active materials in particu- lives greater than eight (8) late form, with half-lives days, and tritium in accord-greater than 8 days, and ance with the ODCM for each tritium in gaseous effluents calendar month during which released to areas at and releases occurred, beyond the SITE B0UNDARY shall be limited to the following:

(1) During any calendar quarter to < 7.5 mrem to any organ; and, (2) During any calendar year to < 15 mrem to any organ.

Action (1) With the calculated dose from the release of io- iy dine-131, radioactive

, materials in particulate

! form, or tritium in gaseous effluents exceed-ing any of the above lim-its, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, a Special i Report which identifies the cause(s), corrective actions taken, and the corrective actions to be

taken.

232

~

l I

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.5 Total Dose B.5 Total Dose Applicability A. Dose Calculations - Cumulative dose contributions from liquid At all times and gaseous effluents shall be determined in accordance with A. The dose or dose commitment to Specifications 7.2. A.1, any MEMBER OF THE PUBLIC from 7.2.A.2, 7.3.A.1, 7.3.A.2, Pilgrim Station sources is 7.4.A.1, and 7.4.A.2 and limited to < 25 mrem to the in accordance with the Offsite total body 3'r any organ Dose Calculation Manual (0DCM).

(except the thyroid, which is limited to < 75 (mrem)

.over a period 3'f 12 consecutive months.

Action (1) With the calculated dose from the release of radioactive materials in liquid or gaseous efflu-ents exceeding twice the limits of Specifications 7.2.A.1, 7.2.A.2, 7.3.A.1, 7.3.A.2, 7.4.A.1 or 7.4. A.2 in lieu of a Licensee Event Report, prepare and submit a Special Report to the Commission and limit the subsequent releases such that the dose or dose commitment to any MEMBER OF THE PUBLIC from all uranium fuel cycle sources is limited to < 25 mrem to the total body or any organ (except thyroid, which is limited to < 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures to all MEMBERS OF THE 233

O OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.5 (Continued)

PUBLIC from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are

, less than the 40 CFR Part 190 Standard. Otherwise, obtain a variance from the Commission to permit releases which exceeds the 40 CFR Part 190 Standard.

233a

f BASES 7.1.A ENVIRONMENTAL MONITORING PROGRAM and 8.1.A An Environmental radiological monitoring program is conducted to verify 4

the adequacy of in-plant controls on the release of radioactive materials.

The program is designed to detect radioactivity concentrations which could result in radiation doses to individuals not exceeding the levels set forth in 10 CFR 50, Appendix I.

, A supplemental monitoring program for sediments and mussles has been incorporated into the basic program (see notes f and g to Table 8.1.A-1) as a result of an agreement with the Massachusetts Wildlife Federation.

i This supplemental program is designed to provide information on radio-activity levels at substantially higher sensitivity-levels in selected samples to verify the adequacy (or, alternatively, to provide a basis for later modifications) of the long-term marine sampling schedules. As part of the supplemental program, analysis of mussels for isotopes of plutonium will be performed if radiocesium activity should exceed 200 pCi/Kgm in the edible portions.

The 200 pCi/Kgm radiocesium " action level" is based on calculations which showed that if radiocesium from plant releases reached this level, plutonium could possibly appear at levels of potential interest.* The calculations also showed that the dose delivered from these levels of plutonium would not be a significant portion of the total dose attribut-able to liquid effluents.

t The program was also designed to be consistent, wherever applicable with NUREG 0473.

Groundwater flow at the plant site is into Cape Cod Bay; therefore, ter-restrial monitoring of groundwater is not included in this program.

Detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs in Table 8.1.A-4 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 capa bility of a measurement system and not as an a posteriori (after the

! fact) limit for a particular measurement. --

.1 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 - Appli-cation 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).

r *In measurable quantities having a potential dose (human food chain) significance comparable to other nucl;Jes if present at their detection limits.

t 234

- -.= , , - + , - - , , n ., - - - - ,, - ,,r,n , , ,_,,n,-.,-w,-,,,,, - ,n

- - .-,.,w.n=,- e - , . ,--.,.n_-- - , , --,-n r,wann._,,-------,,, n.w, , - - - - ,

BASES 7.1.8 LAND USE CENSUS and 8.1.8 This section is provided to ensure that changes in the use of areas at and beyond the SITE B0UNDARY are identified and that modifications to the radiological environmental monitoring program 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 agricul-tural authorities shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 QFR Part 50. Restricting the census to gardens of greater than 50 m2 provides assurance that signifi-cant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/ year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were made: 1) 20% of the garden was used for growing broad leaf vegetation (i.e.,2 similar to lettuce and cabbage), and 2) a vegetation yield of 2 kg/m 7.1.C INTERLABORATORY COMPARIS0N PROGRAM and 8.1.C Participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50.

235

)

l BASES 7.2 DOSE - LIQUID and ,

8.2 This section is provided to implement the requirements of Sections l II. A, III. A and IV. A of Appendix I,10 CFR Part 50, to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable." Alternatively, Pilgrim is not a site where plant operations can conceivably affect drinking water so that none of these requirements are intended to assure compliance with 40 CFR 141. The dose calculations in the ODCM implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures 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 will be 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 I," 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 I,"

April 1977. NUREG-0133 provides methods for dose calculations consis-tent with Regulatory Guides 1.109 and 1.113.

236

o BASES 7.3 DOSE-NOBLE GASES and 8.3 This section is provided to implement the requirements of Sections II.B. III. A and IV.A of Appendix I,10 CFR Part 50, to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements imple-ment the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I is to be shown by calculational procedures based on models and data such that the actual exposure of a MEMBER OF THE PUBLIC through the appropriate pathways is unlikely to be substan-tially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be 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 I," Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Trans-port 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 will be based upon the historical average atmospheric conditions.

NUREG-0133 provides methods for dose calculations consistent with Regula-tory Guides 1.109 and 1.111.

237

r O

BASES 7.4 DOSE-IODINE-131, RADI0 ACTIVE MATERIAL IN PARTICULATE FORM AND TRITIUM and 8.4 This section is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix I, 10 CFR Part 50, to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods speci-fled in the surveillance requirements implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures 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 ODCM calculational methods approved by NRC for calculating the doses due to the actual release rates of the subject materials are required to be consistent with the methodology provided in Regulatory Guide 1.109,

" Calculating of Annual Do:es to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Reglatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from LightWater-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 specifications for iodine-131, radioactive material in particulate form with half-lives greater than 8 days and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in areas at and beyond the SITE B0UNDARY. The pathways which are examined in the development of these calculations are: 1) individual inhalation of airborne 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.

i e

238 l

4 e

l BASES 7.5 TOTAL DOSE and 8.5 This section is provided to meet the dose limitations of 40 CFR Part 190 that have now been incorporated into 10 CFR Part 30 by 46 FR 18525.

The specification requires the preparation and submittal of a Special Report whenever the calculated doses from plant radioactive effluents exceed twice the design objective doses of Appendix I. For sites con-taining up to 4 reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the individual reactors remain within the reporting require-ment level. 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 require-ments of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR Part 190.11 and 10 CFR Part 20.405C, 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 any way to the other require-ments for dose limitation of 10 CFR Part 20. An individual is 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 cycle.

l I

239 I