Text

Revised Selected Licensee Commitment Manual Sections Containing Relocated Radiological Effluent Tech Specs
	ML20081L561
Person / Time
Site:	Mcguire, McGuire
Issue date:	05/31/1991
From:	; DUKE POWER CO.
To:	;
Shared Package
ML20081L559	List: ML20081L557; ML20081L561;
References
	PROC-910531-01, NUDOCS 9107050164
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t U.S. Nuclear Regulatory Commission ATTN: Document Control Desk February 7. 1990 Attachment No. 6 McGuire Nuclear Station Selected Licensee Commitment Manual Sections Containing Relocated RETS 9107050164 910624 POR P

ADOCK 05000369 pop

(j 16.3 _DJE[NLTJONS The definitions in the McGuire Technical Specifications apply to defined terms used herein. The following additional defined terms appear in capitalized type and are applicable throughout this Selected Licensee Commitment document:

16.3-1 AMSAC (ATWS Mitigation System Activation Circuitry) The Westinghouse system for mitigating ATWS events.

16.3-2 ATWS (Anticipated Transient Without Scram) An ATWS is an expec'ted l operational transient (such as loss of feedwater, loss of '

condenser vacuum, or loss of off site power) which is accompanied by a failure of the reactor trip system to shut down the reactor.

16.3-3 SOLIDIFICATION shall be the immobilization of wet radioactive wastes such as evaporator bottoms, spent resins, sludges, and reverse osmosis concentrates as a result of a process of thoroughly mixing the waste type with a SOLIDIFI-CATION agent (s) to form a free standing monolith with chemical and physical characteristics specified in the l Process Control Program (PCP). 1 l

, a 16.3-1

t 16.11 RADIOLOGICAL EFFLUENT CONTROLS 16.11-1 LIQUID EFFLUENTS CONCENTRATION ~

COMMITMENT The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 16.11-1) shall be limited to the concentrations specified in 10 CFR Part 20, Appendix 8. Table II, 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 /mi total activity.

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 con-centration to within the above limits.

TESTING REQUIREMENTS:

Radioactive liquid wastes shall be sampled and analyzed according to the sampling and 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 stateG above.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. International Commission on Radiological Prot tion (ICRP)

Publication 2 BASES:

This commitment 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, Column 2. This limitation provides additional assurance that the levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will result in exposures within: (1) the Section II. A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) the limits of n 10 CFR Part 20. 106(e) to the population. The concentration limit for dis-(-) solved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its MPC in air (submersion) was converted to 16.11-1

\

i an equivalent concentration in water using the methods described in Interna-tional Commission on Radiological Protection (ICRP) pubitcation 2.

This commitment applies to the release of liquid effluents from all reactors at the site.

l 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," Anal. Chem, 40, 586-93 (1968), and Hartwell, J. K., "Detec-tion Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-5A-215 (June 1975).

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tj 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 ACTIVIT.Y (LLD)

TYPE FREQUENCY FREQUENCY ANALYSIS (pCi/ml)( )

1. Batch Waste P P Release (4)

Each Batch Each Batch Principaf6 gamma 5x10' Tanks Emitters I-131 1x10~'

(Waste Monitor P M Dissolved and 1x10 '

Tanks and One Batch /M Entrained Gases Recyle (Gamma emitters)

Monitor Tank)

I P M H-3 1x10"'

Each Batch Composite (2) __

Gross Alpha 1x10 '

P Q Sr-89, Sr-90 5x10~'

Each Batch Composite 2)

Fe-55 1x10~'

2. W 5x10~'

Continuous Releases (5) Continuous (3) Composite (3) Principaf6 gamma Emitters I-131 1x10~'

(Containment Ventilation M M Dissolved and 1x10 '

Unit Grab Sample Entrained Gases Condensate .

(Gamma Emitters)

Orain Tank Discharge and Conventional M H-3 1x10~'

Waste Water Continuous ( ) Composite ( )

Treatment

~

Gross Alpha 1x10 '

System Outlet) Q Sr-89, Sr-90 5x10' Continuous (3) Composite (3)

Fe-55 1x10~'

16.11-3

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TABLE 16.11-1 (Paae__2 of 3)

N]J TABLE NOTATION (1) The LLD is. defined, for purposes of t'iese commitments, as the smallest concentration of radioactive materi,1 in a sample that will yield a net count, above system background, that will be detected with 95% proba-bility 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 x 10' . Y exp (-lat)

Where:

LLD is the "a priori" lower limit of detection as defined above (as microcurie per unit mass or volume),

s b is the standard deviation of the background counting rate or of tne counting rate of a blank sample as appropriate (as counts per minute),

')

E is the counting efficiency (as counts per disintegration),

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

2.22 x 10' is the number of disintegrations per minute per micro-Curie, Y is the fractional radiochemical yield (when applicable),

i 1 is the radioactive decay constant for the particular radionuclide, and At is the elapsed time between midpoint of sample collection and time of counting (for plant ef fluents, not environmental samples).

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 syste, and not, as an a posteriori (af ter the fact) limit for a particular measurement.

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16.11-4 l

I TABLE 16.11-1 (Page 3 of 3)

TABLE NOTATION (2) 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.

(3) To be representative of the quantities and concentrations of radioactive materials in liquid effluents, samples shall be collected continuously or intermittently in proportion to the rate of flow of the effluent stream.

Prior to analyses, all samples taken for the composite shall be thor-oughly mixed in order for the composite sample to be representative of the effluent release.

(4) 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.

(5) A continuous release is the discharge of liquid wastes of a nondiscrete volume, e.g., from a volume of system that has an input flow during the continuous release.

O (6) The principal gamma emitters for which the LLD specification applies V exclusively are the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-90, Cs-134, Cs-137, and Ce-141. The LLD for Ce-144 is 5x10

pCi/ml. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identi-fiable, together with the above nuclides, shall be identified and reported in the Semiannual Radioactive Effluent Release Report, i

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16.11-5 '

1 16.11 RADLO_ LOGICAL EFFLUENT CONTROLS INSTRUMENTATION 16.11-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION COMMITMENT 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 meth-odology and parameters in the OFFSITE DOSE CALCULATION MANUAL (00CM).

APPLICABJLITY: At all times.

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 ef fluents monitored by the affected channel, or declare the channel inoperable.

b. With less than the minimum number of radioactive liquia effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 16.11-2. Restore the inoperable instrumentation to OPER-ABLE status within the time specified in the ACTION or, in lieu of a Licensee Event Report, explain in the next Semiannual Radioactive Effluent Release Report why this inoperability was not corrected within the time specified.

TESTING REQUIREMENTS:

Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, a CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST operations at the frequencies shown in Table 16.11-3.

REFERENCES:

1. McGuire Offsite Oose Calculation Manual

2. 10 CFR Part 20

3. 10 CFR Part 50, Appendix I BASES:

i The radioactive liquid ef fluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid 16.11.6

9

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O effluents during actual or potential releases of liquid effluents. The Alarm /

Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters 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 require-ments of General Design Criteria 60, 63, and 54 of Appendix A to 10 CFR Part

50. The purpose of tank level indicating devices is to assure the detection and control of leaks that if not controlled could potentially result in the transport of radioactive materials to UNRESTRICTED AREAS. .

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TABLE 16.11-2 (Page 1 of 2)

RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE ACTION

1. Radioactivity Monitors Providing Alarm And Automatic Termination of Release

a. Waste Liquid Ef fluent Line (EMF-49) I per station I

b. Containment Ventilation Unit Condensate Line (EMF-44) 1 3

- 2. Radioactivity Monitors Providing Alarm But Not

{ Providing Automatic Termination of Release 5 Conventional Wastewater Treatment Line (EMF-31) 1 2

3. Continuous Composite Samplers And Sampler Flow Monitor

a. Containment Ventilation Unit Condensate Line 1 per station 3

b. Conventional Wastewater Treatment Line 1 per station 3

4. Flow Rate Measurement Devices

a. Vaste Liquid Effluent Line 1 per station 4

b. Discharge Canal Minimum Flow Interlock

1 per station 4

c. Containment Ventilation Unit Condensate Line 1 4 l I

d. Conventional Wastewater Treatment Line I per station 4

Minimum flow is assured by an interlock terminating waste liquid releases if minimum dilution flow is not available.

e TABLE 16.11-2 (Pace 2 of 2)

ACTION STATEMENTS ACTION 1 - With the number of channels OPERAB'l less than required by the Minimum Channels OPERABLE requirement, effluent releases may continue for up to 14 days provided that prior to initiating a releese: ,

a. At least two independent samples are analyzed in accor-dance with SLC 16.11-1, and is . At lesst two technically qualified members of the facility staff independently verify the discharge line valving:

1) The manual portion of the computer input for the release rate calculations performed on the computer, or

2) The entire release rate calculations if such calcula-tions are performed manually.

Otherwise, suspend release of radioactive effluents via this pathway.

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 grab samplos are analyzed for radioactivity for up to 30 days at a lower limit of detec-tion of at least 10 ' microcurie /ml;

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

b. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when the specific activity of the secondary coolant is less than or equal to 0.01 micro-Curie / gram DOSE EQUIVALENT I-131.

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 that, at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , grab samples are collected and ana-lyzed for radioactivity at a lower limit of detection of at least 10 ' microcurie /ml.

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 the flow (3 rate is estimated at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual Q releases. Pump performance curves generated in place may be used to estimate flow.

16.11-9 l

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TABLE 16.11-3 (Page 1 of 2)

RADIDACTIVE LIQUID EFFLUENT MGNITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS ANALOG CHANNEL CHANNEL SOURCE CHANNEL OPERATIONAL CHECK CHECK CALIBRATION TEST INSTRUMENT

1. Radioactivity Monitors Providing Alarm And Automatic Termination of Release Waste Liquid Effluent Line (EMF-49) D P R(3) Q(1) a.

b. Containment Ventilation Unit M R(3) Q(1)

D Condensate Line (EMF-44)

- 2. Radioactivity Monitors Providing Alarm But P' Not Providing Automatic Termination of Release C D M R(3) Q(2)

J. Conventional Wastewater Treatment Line c'

(EMF-31)

3. Continuous Composite Samplers and Sampler Flow Monitor

a. Containment Ventilation Unit N.A. R Q Condensate Line D(4)

D(4) N.A. R Q

b. Conventional Wastewater Treatment Line

4. Flow Rate Measurement Devices U(4) N.A. R Q

a. Waste Liquid Effluent Line D(4) N.A. N.A. Q

b. Discharge Canal Minimum Flow Interlock

c. Contaiment Ventilation Unit Condensate N.A. R Q Line D(4)

D(4) N.A. R Q

d. Conventional Wastewater Treatment Line

TABLE 16.11-3 (Page 2 of 2)

TABLE NOTATION (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:

a. Instrument indicates measured levels above the Alarm / Trip Se'tpoint; 1

b. Circuit failure (alarm only); and,

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

b. Circuit failure;

c. Instrument indicates a downscale f ailure; and, (3) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Bureau of Standards O (NBS) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These stan-dards shall permit calibrating the system 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.

(4) CHANNEL' CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on days on which continuous, periodic, or batch releases are i made. ,

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16.11-11

1 16.11 RA0!0 LOGICAL EFFLUENT CONfROLS RADI0 ACTIVE EFFLVENTS 16.11-3 OOSE CO*!TMENT e

The dose or dose commitment to a MEMBER OF THE PUBLIC-from radioactive mate-rials in liquid effluents released, from each unit, to UNRESTRitit!D 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 total 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 total body and to less_than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With the calculated dose from the release of radioactive materials.in liquid

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ef fluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within_30 days,_a Special Report which identifies the cause(s) for exceeding the limit (s) and defines the cor- i rective actions to be taken to reduce the releases _and the proposed corrective actions to be-taken to assure that subsequent releases will-be in compliance , 3 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 drinking water supplies with regard to the requirements of 40 CFR 141, Safe Drinking Water Act,* '

TESTING REQUIREMENTS: ;

Cumulative dose contributions from liquid effluents for the-current calendar -i quarter and the current calendar year shall-be determined in accordance with the methodology and parameters in the 00CM at least once per 31 days.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 40 CFR Part 141, Safe Orinking Water Act l

3. 10 CFR Part 50, Appendix I- '

These requirements are applicable only-if the drinking water supply is taken-from the river 3 miles downstream of the plant discharge.

16.11-12

BASES:

This commitment is provided to implement the requirements of Sections II.A.

III.A and IV.A of Appendix I, 10 CFR Part 50. The commitment implements the guides set forth in Section II.A of Appendix 1. The REMEDIAL ACTION state-ments provide the required operating flexibility and at the same time imple-ment the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED 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 concentrations in the finished drinking water that are in excess of the requirements of 40 CFR Part 141. The dose calcula-tion methodology and parameters in the 00CM implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix ! 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. Tha equations specified in the 00CM for calculating the doses due to the actual release rates of radioactive l materials in liquid effluents are consistent with the methodology provided ic Regulatory Guide 1.109, " Calculation of Annual Dose > 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 Heleases for the Purpose of Implementing Appendix 1," April 1977.

This commitment applies to the release of liquid effluents from each unit at the site. For units with shared Radwaste Treatment Systems, the liquid effluents from the shared system are to be proportioned among the units sharing that system in at.cordance with the guidance given in NUREG-0133, Chapter 3.1.

O 16.11-13

e 16.11 RADIOLOGICAL EFFLUENT CONTROLS RADI0 ACTIVE EFFLUENTS 16.11-4 LIQUID RADWASTE TREATMENT SYSTEM COMMITMENT The Liquid Radwaste Treatment System shall be OPERABLE and appropriate por-tions 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 total body or 0.2 mrem to any organ in a 31-day period.

APPLICABILITY: At all times.

REMEDIAL ACTION:

Vith 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, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days 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.

TESTING REQUIREMENTS:

Doses dte 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 water systems are being released without being processed by its Radwaste Treatment System.

The installed Liquid Radwaste Treatment System shall be demonstrated OPERABLE by meeting SLC 16.11-1 and 16.11-6.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 50

3. 10 CFR Part 50, Appendix I i 16.11-14 l

() BASES:

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 specification 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 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 dose design objectives set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

This commitment applies to the release of liquid ef fluents from each reactor at the site. For units with shared Radwaste Treatment Systems, the liquid effluents from the shared system are to be proportioned among the units sharing that system in accordance with the guidance given in NUREG-0133, Chapter 3.1.

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16.11-15

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16.11 RADIOLOGICAL EFFLUENT CONTROLS 3A_010 ACTIVE EFFLUENT}

16.11-5 CHEMICAL TREATMENT PONOS COMMITMENT j 1

1 The quantity of radioactive material conta1Hed in each chemical treatment pond shall be limited by the following expression:

A 26.4 .

I _f < 1'0 V

j C) excluding tritium and dissolved or entrained noble gases, Where:

A3 = pond inventory limit for single radionuclide "j", in Curies; C) = 10 CFR 20, Appendix B, Table !!, Column 2, concentration for single radionuclide "j", microCuries/ml; 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 cuantity of radioactive material in any of the above listed ponds exceeding the above limit, immediately suspend all additions of radioactive material to the poni and initiate corrective action to reduce the pond con-tents to within the ilmit.

TESTING REQUIREMENTS:

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

pCi/am I

j b C

< 6'0 x 10' _pCi/ml 3

Where:

Q3 = concentration of radioactive materials in wet, drained slurry (used p powdex resin) for radionuclide "j", excluding tritium, dissolved or i entrained noble gases, and radionuclides with less than an 8 day half-life. The analysis shall include at least Ce-144, Cs-134, Cs-137, Co-58 and Co-60, in picoCuries/ gram. Estimates of the Sr-89 16.11-16

and Sr-90 batch concentration shall be included based on the most recent monthly composite analysis (within 3 months); and C) = 10 CFR 20, Appendix B, Table II, Column 2, concentration for single radionuclide "j", in microcuries/ milliliter.

REFERENCES:

1. McGuire Offsite Dose Calcolation Manual .

2. 10 CFR 20 Appendix B

3. 10 CFR 50 Appendix I, Section II.A

4. 10 CFR 20.105

5. 10 CFR 50.36 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 SLC 16.11-5 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 Appendix 8 of 10 CFR Part 20 applies.

The batch limits of slurry to the chemical treatment ponds assure that radio-active material in the slurry transferred to the CTP are "as low as is rea-sonably achievable" in accordance with .0 CFR Part 50.36a. The expression in SLC 16.11-b assures no batch of slurry 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, Ap-pendix I,Section II,A, total body dose level to the 10 CFR Part 20.105(a),

whole body dose limitation, or that:

g i 3 mrem /yr j C) < 500 mrem /yr = 0.006 .

Where:

c) = radioactive slurry concentration for radionuclide "j" entering the unrestricted area CTP, in microcuries/ milliliter C) = 10 CFR Part 20, Appendix B, Table II, Column 2, concentration for single radionuclide "j", in microcuries/ milliliter.

For the design of filter /demineralizers using powder resin, the slurry wash volume and the weight of resin used per batch is fixed by the cell surface area, and the slurry volume to resin weight ratio is constant at 100 milli-O liters / gram of wet, drained resin with a moisture content of approximately 55 to 60% (bulk density of about 58 pounds per cubic feet). Therefore, 16.11 -.- .

C j I C i~j 3

I OJ C3 (108 ml/gm)(10' pei/pci) < 0.006, and g 9.1 < 6 x 10' pei/cm j C uci/mi 3

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 SLC 16.11-5. ,

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() 16.11 RADIOLOGICAL EFFLUENT CONTROLS RADIDACTIVE EFFLUEU'S 16.11-6 GASEOUS EFFLUENTS 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 (see 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 Iodine-131 and 133, for tritium, and for all radioactive mate-rials 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 the above limit (s).

TESTING REQUIREMENTS:

a. 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 00CM,

b. The dose rate due to radioactive materials, other than noble gases, in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters of the 00CM by obtaining representative samples and performing analyses in ac-cordance with the sampling and analysis program specified in Table 16.11-4.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 20, Appendix B 3, 10 CFR Part 20 0

16.11-19

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BASES:

. This commitment is provided to ensure that the dose at any time at and beyond j the SITE BOUNDARY from gaseous effluents from all units on the site will be ,

within the annual dose limits of 10 CFR Part 20 to UNRESTRICTED AREAS. The I annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table II, Column 1. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, ,

either within or outside the SITE BOUNDARY, to annual average concentrations J 3xceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(b)). For MEMBERS OF THE PUBLIC will usually be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the SITE BOUNDARY.. Examples of calculations for such MEMBERS OF THE PUBLIC, with the appropriate occupancy factors, shall be given in the 00CM.

The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MENBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal-to 500 mrem / year to the whole body or to less than or equal to 3000 mrem / year to the 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 gaseous effluents from all reactors at the site.

The required detection capabilities for radioactive materials in gaseous waste samples are tabulated in terms of the lower limits of detection (LL0s), De-tailed discussion of the LLO, 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 Radio-chemistry," 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 16.I1-20

O O O~~~ .

TABLE 16.11_.4 (Page 1 of 4)

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM LOWER LIMIT OF SAMPLING ANALYSIS TYPE OF GASEOUS RELEASE TYPE FREQUENCY FREQUENCY ACTIVITY ANALYSIS (pCi/ml)g{' D)

DETECTION P P -

1. Waste Gas Storage Each Tank Each Tank Principal Gamma Emitters (7) 1x10 '

Tanks Grab Sample Each Purge I2)

2. Containment Purge Each Purge (2) Principal Gamma Emitters (7) 1x10

Grab -

Sample M H-3 1x10 5

3. Unit Vent W I ')'I )*I ) W I3 Principal Gamma Emitters I7) 1x10

7 Grab -

U Sample H-3 1x10 '

Principal Gamma Emitters I7)

4. a. Radwaste W W 1x10 '

Facility Grab -

Vent Sample H-3 1x10 '

b. Vaste Handling ,

Building

c. Equipment Staging Building 6

" " ~ ' ' ' - " ' I

. _ . - . . . _..,-_...e..-. . ...

O O O

~~

~

.I TABLE 16.11-4 (Page 2 of 4)

RADIDACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM LOWEA LIMIT OF SAMPLING ANALYSIS TYPE OF DETECTION D)

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

5. All Release Types Continuous (6) D I4) I-131 1x10 21

, as listed in 3. Charcoal and 4. above. I-133 Sample 1x10 '

Continuous (6) D I4) Principal Gamma Emitters (7) 1x10 **

Particulate (I-131, Others)

Sample Continuous (6) M Gross Alpha I8) 1x10

7 Composite m Particulate Sample Continuous (6) Q Sr-89, Sr-90 1x10 *'

Composite Particulate i

Sample

TABLE 16.11-4 (Page 3 of 4)

TABLE NOTATION (1) The LLD is defined, for purposes of these commitments, as the smallest concentration of radioactive material in a sample that will yield a net count, above syst6m background, that will be detected with 95% proba-bility 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 l'O " E V 2.22 x 1 ' Y exp (-Kat)

Where:

LLD is the "a priori" lower limit of detection as defined above (ss microcurie per unit mass or voluine),

sh is the standard deviation of the background counting rate or ot tne counting rate of a blank sample as appropriate (as counts per minute),

E is the counting efficiency (as counts per disintegration),

V is the sample size (in units of mass or volumt),

2.22 x 10' is the number of disintegrations per minute per micro-Curie, Y is the fractional radiochemical yield (when applicable),

1 is the radioactive decay constant for the particular radionuclide, and at is the elapsed time between midpoint of sample collection and time of counting (for plant effluents, not environmental samples).

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

It should be recognized that the LLO 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 particuiar measurement.

O 16.11-23

TABLE 16.11-4-(Paoe 4 of 4)

TABLE NOTATION (2) Sampling and analysis shall also be performed following shutdown, START-UP, or a THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a 1-hour period. '

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

(4) Samples shall be changed at least once per 24_ hours and analyses shall be completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing,-or after removal from sampler.

(5) Tritium grab samples shall be taken at least once per 7 days from the ventilation exhaust from the spent-fual pool area, whenever spent fuel is in the spent fuel pool.

(6) The ratio of the sample flow volume to the sampled stream flow volume shall-be known for the time ceriod covered by each dose or dose rate ;j calculation made in accordance with SLCs 16.11-6, 16.11-8 and 16.11-9, (7) 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 re kases and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, I-131, Cs-134,.Cs-137, and Ce-141 in iodine _and particulate releases. The LLD for Ce-144 is 5x10~' pCi/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, shallLalso be analyzed and reported--in-the Semiannual Radioactive Effluent Release Report,

, (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,

~

O 16.11-24

( 16.11 RADIOLOGICALEFFLUENTCONTROL}

INSTRUMENTATION 16.11-7 RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION COMMUMENT 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 shall be determined and adjusted in accordance with the meth-odology and parameters in the ODCM.

APPLICABILITY: As shown in Table 16.11-5.

REMEDIAL ACTION:

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. Restore the inoperable instrumentation to OPER-ABLE status within the time specified in the ACTION or, in lieu of a Licensee Event Report, explain in the next Semiannual Radioactive Effluent Release Report why this inoperability was not corrected within the time specified.

TESTING REQUIREMENTS:

Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST operations at the frequencies shown in Table 16.11-5.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 20

3. 10 CFR Part 50, Appendix A

/

BASES:

(O,) The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The 16.11-25

Alarm / Trip Setpoints for these instruments shall be calculated and adjusted in accordance with the methodology and parameters in the 00CM to ensure that the Alarm / Trip will occur prior to exceeding the limits of 10 CFR Part 20. This instrumentation also includes provisions for monitoring (and controlling) the concentrations of potentially explosive gas mixtures in the WASTE GAS HOLOUP 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.

G O

l l

U, N 16.11-26

, ~ _.

O O O'1 TABLE-16.11-5 (Page 1 of 3)

I RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION i

1. WASTE GAS HOLDUP SYSTEM

a. ; Noble Gas' Activity Monitor - Providing ***

Alarm and Automatic Termination of Release 1 per station 1 (Low Range - EMF-50 or IEMF-36, low-range)

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

2. Condenser Evacuation Syraem

$ # 3 L Noble Gas Activity Monitor (EMF-33) 1 T

3: 3. Vent System

a. ' Noble Gas Activity Monitor. 1 3

-(Low Range - EMF-36)

~

. b. Iodine Sampler 1 5

c. Particulate Sampler 1 5

d. -Flow Rate Monitor 1 2

e. . Sampler Minimum' Flow Device ' 'I 2 14 . Containment Purge System

Noble Gas Activity Monitor - Providing .

4 Alarm and Automatic LTermination of Release 1 (Low Range - EMF-39)

o

~ ~~

O O O .

TABLE 16.11-5 (Page 2 of 3)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION' MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION

5. Auxiliary Building Ventilation System -

Noble Gas Activity Monitor (EMF-41 or 1 3' EMF-36)

6. Fuel Storage Area Ventilation. System Noble Gas Activity Monitor (EMF-42 or EMF-36) 1 3

7. Waste' Storage Building Ventilation System l

"a l a. Noble Gas Activity Monitor (EMF-53) I per station 3

b. Flow Rate Monitor 1 per station 2

.c. Sampler Minimum Flow Device 1 per station 2

8. Radwaste Facility _ Ventilation' System

a. ~ Noble Gas Activity Monitor (EMF-52) I per station 3

b. Flow Rate Monitor 1 per station 2

-c. Sampler Mininium Flow Rate 1 per station ~2

9. Equipment Staging Building Ventilation System.

a. Noble Gas Activity Monitor (EMF-59) 1 . 3

b. Flow Rate Monitor .I ' 2

c. Sampler Minimum Flow Device '

1 2

4

() ~

TABLE 16.11-5 (Pane 3 of-3)

TABLE NOTATION

At all times.

- During WAsfE GAS HOLDUP SYSTEM operation.-

- - During gaseous effluent releases.

When air ejectors are operable.

i.

ACTION STATEMENTS-ACTION 1 - With-the number of channels OPERABLE less than required by 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:

a. At least two independent samples of the tank's contents are analyzed; and,

b. At least two technically qualified members of the facility staff independently verify the discharge valve lineup: ,

1) The manual portion of the computer input-for the releass rate calculations performed on the computer; or, O

i

2) The entire release rate calculations if such-calcula-tions are performed manually.

Otherwise, suspend release of radioactive effluents via this pathway.

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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ACTION 3 - With the number of channels OPERABLE less than required by.the Minimum Channels _0PERABLE requirement, ef flur.nt release via

' this pathway may continue for up_to 30 days provided-grab samples are taken at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for gross radioactivity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 4 - With the number of-channels OPERABLE lets thanl required by the

Minimum Channels OPERABLE requirement, ~ immediately- suspend PURGING or VENTING of radioactive effluents via this pathway.

ACTION 5 - With the number of channels OPERABLE less than required _by the Minimum Channels 0PERABLE requirement, effluent releases via-the effected- pathway .nay continue -for up to 30 days provided =

O samples are continuously collected with auxiliary sampling equipment as required in Table 16.11-4 16.11-29 1

s O O O~~~l *l t

TABLE 16.11-6 (Page 1 of 3)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS }

ANALOG CHANNEL MODES IN WHICH l CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST RF00lRED _

1. WASTE GAS HOLDUP SYSTEM

a. Noble Gas Activity Monitor.-- 1 Providing Alarm and Automatic Termination of Release (Low Range -

EMF-50 or IEMF-36) P P R(3) Q(1) *

b. Effluent System Flow Rate 5

im Measuring Device O N.A. R Q

j

2. Cor: denser Evacuation System ,

. Noble Gas Activity Monitor (EMF-33) . D' M R(3) Q(2) #

3. Vent' System a '. Noble Gas Activity Monitor .0 .M R(3) Q(2) *

(Low Range --EMF-36) !

b. Iodine Sampler W N.A. N.A. N.A. *

c. Particulate Sampler W N.A. N.A. N.A.

i

d. Flow Rate Monitor D: N.A. R' Q

1 i

e. Sampler Minimum Flow Device D N.A. R -Q -a .

i- .

4. Containment Purge System.

i Noble Gas Activity' Monitor - .f Providing' Alarm and Au'tomatic !

Termination of Release'.(Low D: P R(3) Q(1) a Range - EMF-39) !

.j

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

~

~~

O O O TABLE I6.11-6 (Page 2 of 3) .

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS ANALOG CHANNEL MODES IN WHICH-SOURCE CHANNEL OPERATIONAL -SURVEILLANCE CHANNEL CHECK CALIBRATION TEST REQUIRED CHECK INSTRUMENT

5. Auxiliary Building Ventilation System D M R(3) Q(2)

Noble Gas Activity Monitor (EMF-41) or EMF-36)

6. Fuel Storage Area Ventilation System D M R(3) Q(2)

Noble Gas Activity Monitor i (EMF-42 or EMF-36)

> 7. Contaminated Parts Warehouse'

[, Ventilation System l i-D M R(3) Q(2) l

a. Noble Gas Activity Monitor-(EMF-53)

}

D N.A. R Q

9 j

b. Flow Rate Monitor ,

D N.A. R Q

c. Sampler Minimum Flow' Device

,8. Radwaste Facility. Ventilation System D M- R(3) Q(2)

a. -Noble Gas Activity Monitor (EMF-52)

D N.A. R Q

b. Flow Rate Monitor-D' N.A. R Q Sampler Minimum Flow Device

~

c.

9. Equ'ipment Staging Building Ventilation System Noble Gas Activity Monitor (EMF-59) _D M' R(3)' Q(2')

ca.

D N.A. R Q

b. Flow' Rate Monttor" D N.A. R Q

c. Sampler Minimum Flow Device

TABLE 16.11-6 (Pace 3 of 3)

TABLE NOTATION

_ *At all times except when the isolation valve is closed and locked.

When air ejectors are operable.

(1) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if any of the following conditions exists:

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

b. Circuit failure (alarm only); and,

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

(2) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate thee control room alarm annunciation occurs if any of the following conditions exists:

a. Instrument indicates measured levels above the Alarm Setpoint;

b. Circuit failure; and,

c. Instrument indicates a downscale failure.

(3) 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 stan-dards shall permit calibrating the system 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.

O 16.11-32

9

() 16.11 RADIOLOGICAL EFFLUENT CONTROLS RADI0 ACTIVE EFFLUENTS 16.11-8 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 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation, ard '

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

('I N-i exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, a Special Report which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be 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:

Dose Calculations Cumulative dose contributions for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the 00CM at least once per 31 days.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix I BASES:

This commitment is provided to implement the requirements of Sections II.8, III.A and IV.A of Appendix I, 10 CFR Part 50. The limiting Condition for Operation implements the guides set forth in Section II.B of Appendix I. 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 I to O, assure that the releases of radioactive material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The TESTING REQUIRE-MENTS implement the requirements in Section III.A of Appendix 16.11-33 l t _ - _ - _ - - - - -

. 4

() 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 under-estimated. The dose calculation methodology and parameters established in the 00CM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the meth-odology 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 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 B0UNDARY are based upon the historical average atmospheric conditions.

This commitment applies to the release of gaseous effluents from each reactor -

at the site. For units with shared Radwaste Treatment Systems, the gaseous effluents from the shared system are to be proportioned among the units sharing that system in accordance with the guidance given in NUREG-0133, Chapter 3.1.

O V

O N

16.11-34

16.11 RADIOLOGICAL EFFLUENT CONTROLS RADICACTIVE EFFLUENTS 16.11-9 00SE - 10 DINE-131 AND 133, TRITIUM AND RADICACTIVE MATERIALS IN PARTICULATE FORM COMMITMENT The dose to a MEMBER OF THE PUBLIC from Iodine-131 and 133, tritium, and all radioactive materials in particulata 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 qua-ter: 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 Iodine-131 and 133, tritium, and radioactive materials in particulate form, with half-lives greater than 8 days, in gaseous ef fluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be 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 the current calendar year for Iodine-131 and 133, tritium, and radionuclides in particu-late form with half-lives greater than 8 days shall be determined in accor-dance.with the methodology and parameters in the 00CM at least once per 31 days.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix I BASES:

This commitment is provided to implement the requirements of Sections :I.C, III.A and IV.A of Appendix I, 10 CFR Part 50. The Limiting Conditions for Operation are the guides set forth in Section II.C_of Appendix I. The 16.11-35

,___.-._.,____._____,-,.-------,--_--,r---.-,-:----------------------- -

4 h REMEDIAL ACTION statements provide 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 materials in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the TESTING REQUIREMENTS implement the requirements in Section III. A of Appendix 1 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 calculat-ional 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 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 Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors,"

Revision 1, July 1977. These equations also provide for determining tne actual doses based upon the historical average atmospheric conditions. The release rate specifications for Iodine-131 and 133, tritium, and radio-nuclidies in particulate form with half-lives greater than 8 days are depen-dent 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 these calculations were: (1) individual inhalation of airborne radio-nuclides; (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man; (3) deposition onto grassy areas where milk 9 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 gaseous effluents from each reactor at the site. For units with shared Radwaste Treatment Systems, the gaseous effluents from the shared system are to be proportioned among the units sharing that system in accordance with the guidance given in NUREG 0133, Chapter 3.1.

s4 9

16.11-36

16.11 RADIOLOGICAL EFFLUENT CONTROLS RADIOACTIVE EFFLUENTS 16.11-10 GASEOUS RADWASTE TREATMENT SYSTEM COMMITMENT The VENTILATION EXHAUST TREATMENT SYSTEM and the WASTE GAS HOLOUP SYSTEM shall be OPERABLE and appropriate portions of these systems shall be used to reduce releases of radioactivity 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:

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

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

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

3. Summary description of actions (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 streams are being released without being processed by its Radwaste Treatment System.

The installed Gaseous Radwaste Treatment System shall be demonstrated OPERABLE by meeting SLCs 16.11-6, 16.11-8, and 16.11-9.

O 16.11-37

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix I

3. 10 CFR Part 50 BASES:

The OPERABILITY of the WASTE GAS HOLOUP 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 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 as is reasonably achiev-able." 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 objectives given in Section 11.0 of Appendix I to 10 CFR Part 50. The speci-fiad limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Section II.B and II.C of Appendix I,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. For units with shared Radwaste Treat-O ment Systems, the gaseous effluents from the shared system are to be propor-tioned among the units sharing that system in accordance with NUREG-0133, Chapter 3.1.

O 16.11-38 ;

16.11 RADIOLOGICAL EFFLUENT CONTROLS A

RADIOACTIVE EFFLUENTS 16.11-11 SOLID RADI0 ACTIVE WASTE 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.

REMEDIAL ACTION:

a. With SOLIDIFICATION or dewatering not meeting disposal site _and shipping and transportation requirements, suspend-shipment of in-adequately processed wastes and correct-the PROCESS CONTROL PROGRAM, the procedures and/or the Solid Waste 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 take appropriate administrative. action to prevent recurrence.

TESTING REQUIREMENTS:

SOLIDIFICATION of at least one representative test specimen from at least every tenth batch of each type of wet radioactive wastes-(e.g., filter ciudges, 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 speciment fai.ls to verify SOLIDIFICATION, the SOLIDI-FICATION of the batch under test shall be suspended until such time as additional test specimens.can be obtained, alternative SOLIDIFI-CATION 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:alterna-tive SOLIDIFICATION parameters determined by the PROCESS CONTROL PROGRAM; R

b. If the initial test speciment 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 16.11-391

) in McGuire Technical Specification 6.13, to assure SOLIDIFICATION of subsequent batches of waste; and,

c. With the installed equipment incapable of meeting SLC 16.11-11 or declared out of service, 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. Process Control Program

2. 10 CFR Part 50

3. 10 CFR Part 50, Appendix I BASES:

This commitment implements the requirements of 10 CFR Part 50.36a and General Design Criterion 60 of Appendix A to 10 CFR Part 50. The process parameters included in establishing 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.

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I h

16.11-40

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/"') 1 (s / 16.11 RADIOLOGICAL EFFLUENT CONTROLS s

RADI0 ACTIVE EFFLUENTS 16.11-12 TOTAL DOSE COMMITMENT The annual (calendar year) dose or dose commitment to any MEMBER OF THE pVBLIC, due to releases of radioactivity and radiation, from uranium fuel cycle sources shall be limited to less than or equal to 25 mrem to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem.

APPLICABILITY: At all times.

REMEDIAL ACTION:

With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of SLCs 16.11-3, 16.11-8 or 16.11-9, calculations should 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, in lieu of O a Licensee Event Report, prepare and submit to the Commission within 30 days, a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This Special Report, as defined in 10 CFR Part P.O.405c, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fual cycle sources, including all effluent pathways and direct radia-tion, for the calendar year that includes the release (s) covered by this report. It shall also describe levels of radiation and concentrations of radioactive material involved, and the cause of the exposure levels or con-centrations. If the estimated dose (s) exceeds the above limits, and if the release condition resulting in violation of 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 NRC staff action l 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 l accordance with the methodology and parameters in the ODCH.

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 condi-tions set forth the REMEDIAL ACTION of SLC 16.11-12.

16.11-41 1

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 20

3. 40 CFR Part 190

4. 10 CFR Part 50, Appendix I BASES:

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 speci-fication requires the preparation and submittal of a Special Report whenever the calculated doses from plant generated radioactive effluents and direct radiation 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 dose limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of 10 CFR Part 50, Appendix I, and if direct radiation doses from the units and outside storage tanks are kept small. The Special Report will describe a course of action that should resuit 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 assured 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 varian;e (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 ar. tion is completed. The variance only relates to the limits of 40 CFR Part 190, and does not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in St.Cs 16.11-1 and 16.11-6. 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.

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16.11-42 '

() 16.11 RADIOLOGICAL EFFLUENT MONITORING RADIOLOGICAL ENVIRONMENTAL MONITORING 16.11-13 MONITORING PROGRAM COMMITMENT The Radioactive Environmental Monitoring Program shall be conducted as speci-fied in Table 16.11-7.

APPLICABILITY: At all times REMEDIAL ACTION:

a. With the Radiological Environmental Monitoring Program not being conducted as specified in Table 16.11-7, in lieu of a Licensee Event Report, prepare and submit to the Commission, in the Annual Radio-logical Environmental Operating Report, a description of the reasons for not conducting the program as required and the plans for pre-venting a recurrence.

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

{.

16'11-7 when averaged uver any calendar quarter, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days a Special Report that defines the 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 SLCs 16.11-6, 16.11-8, and 16.11-9. When more than one of the radionuclides in Table 16.11-8 are detected in the sampling medium, this report shall be submitted if:

concentration limit level (1)(1)

concentration limit level (2)(2) + . . 21.0 When radionuclides other than those in Table 16.11-8 are detected and are the result of plant effluents, this report shall be sub-mitted if the potential annual dose" to a MEMBER OF THE PUBLIC is equal to or greater than the calendar year limits' of SLCs 16.11-6, 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; how-ever, in such an event, the condition shall be reported and des-cribed in the Annual Radiological Environmental Operating Report.

The methodology and parameters used to estimate the potential annual dose to

, p. a MEMBER OF THE PUBLIC shall be indicated in this report.

(

16.11-43

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

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REMEDIAL ACTION: (Continued) ,

c. With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 16.11-7, identify locations for obtai_ning replacement samples and add them to the Radiological Environmental Monitoring Program within-30 days.: =The specific locations from which samples _were unavailable may then'be deleted from the monitoring program. In-_ lieu of a Licensee Event Report, identify the cause of the_ unavailability of samples and identify'the new location (s) for obtaining replacement samples in ,

the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s)_and table for the ODCM reflecting the new-location (s).

TESTING REQUIREMENTS:

The radiological environmental monitoring samples shall be collected pursuant to Table 16.11-7 from the lorations given in the table and-figure'in_the ODCM _

and shall be analyzed pursuant to the' requirements of Tables 16.11-7 and the detection capabilities required by Table 16.11-8.

REFERENCES:

.1. McGuire Offsite Dose Calculation Manual l 2. 10 CFR Part 50, Appendix I 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 high-est votential radiation exposures-of MEMBERS OF THE PUBLIC:resulting from the station operation. This monitoring program implements Section. IV.B.2 of Appendix I to 10 CFR Part -50 and thereby supplements the Radiological Effluent Monitoring. Program by verifying that the measurable concentraticns of radio--

active materials and levels of radiation are not_ higher thaa _ 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.

l The initially specified monitoring program will be effective for at least' the -

l first 3 years of commercial operation. Following this' period, program._ changes may be-initiated based on operational experience.

The required detection capabilities for environmental sampleyanalyses are.

~

tabulated in terms of the lower limits _of detection (LL0s). The-LLDs required by Table 16,11-8 are considered optimum for routine environmental-measurements in indus_ trial laboratories. . It should_be recognized that the LLD is. defined ~

as an a priori (before the fact) limit representing the capability _of a_ mea--

surement system and not as an a posteriori (after the fact) limit for.a particular measurement.

Detailed discussion of the '.LD, and other detection limits, can be found in HASL Procedures Manual,_ HASL-300 (revised annually), Currie, L. A. , " Limits 16.11-44 e7--W e-r m- ---

T-- y d e = - - - He +ew 'erwe e n-=-e_ m y e rg w g- -y y w f

for Qualitative Detectier, and Quantitative Determination - Application to Radiochemi stry," 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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O 16.11-45 1 . . - . . ... . - .

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TABLE 16.11-7 (Page 1 of'7)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF l i

REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONSgI) COLLECTION FREQUENCY OF ANALYSIS-

1. Direct Forty routine monitoring stations Quarterly. Gamma dose quarterly.

fp)

Radiation either with two or more dosimeters or with'one instrument for measur-ing and recording dose rate con-

~tinuously, placed as follows:

P An inner ring of stations, one in C each-meteorological sector in'the general area of the SITE BOUNDARY; h

An outer ring of stations, one in

each meteorological sector in the 6- to 8-km range f rom the ' site; and The balance of'the stations be placed in special interest areas such as population centers, nearby residences, schools, and:

--in one or two-areas'to serve as control stations.

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TABLE 16.11-7 (Page 2 of 7)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND- SAMPLING'AND TYPE AND FRE00ENCY II) COLLECTION FRE00ENCY OF ANALYSIS AND/0R SAMPLE SAMPLE LOCATIONS

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

Particulates Three samples from'close to the- operation with sample I-131 analysis weekly.

--three SITE BOUNDARY locations, collection weekly, or in different sectors, of the- more frequently if L

highest. calculated annual required by dust. Particulate Sampler:

[ . average groundlevel D/Q. loading; Gross beta radio-y activity analysis p

followi g

One. sample.from the vicinity of change;gfilter Gamma a community-having the highest isotopic analysis kb) calculated annual average of composite (by'

.groundlevel D/Q. location) quar.terly.

<0ne sample-from a control location, as for example

!. 15-30.:km distant and in the least pre nt wind

' direction

3. Waterborne

a. Surface (6) .One sample upstream. Compositesampigver. Gammaisgpic

-One sample downstream; 1-month period. analysis monthly.

Composite for. tritium.

analysis quarterly.-

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TABLE 16.11-7 (Page 3 of 7)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF ;

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

b. Ground , Samples from one or two sourc Quarterly. Gamma isotopic N I only if likely.to be affected and tritium analysis quarterly.

c. Drinking . One . sample of each of one.to. Composite sam g over .'I-131 analysis on each three of the nearest water 2 week period when ccmposite when the dose cn supplies that could be affected I-131. analysis is calculated for the con--

performed, monthly su:pption of the water is

.g by its discharge.

composite otherwise. grea than I arem per.

year Composite for m One. sample from a control location. grossbeta.andgag isotopic-analyses monthly. Composite for tritium analysis quarterly.

d. Sediment One sample from downstream area Semiannually. lGammaisgpic from -with existing or potential analysis shoreline recreational ~value. semiannually.

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TABLE 16.11-7 (Pane 4 of 7)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAI4 NUMBER OF REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY Iy) OF ANALYSIS AND/0R SAMPLE- SAMPLE LOCATIONS COLLECTION FREQUENCY

4. Ingestion Samples from milking animals Semimonthly when Gamma isotopic (5) and i

a. Milk in three~ locations within-5 km animals are on pasture, I-131 analysis semi-distance having the highest monthly,at other tiaes. renthly when animals are dose potential. If there are on pasture; monthly at is none, then, one sample from' other times.

e milking animals in each of f three areas between 5 to 8 km I distant where doses are calculated to g greater thaa -l 4 mrem per yr .

'.One. sample from milking animals at a control location 15-30 km distant and in the least prevalent wind direction.

b. Fish and One 3mple of each commercially Sample in season, or Gammaisgpic Inverte- and recreationally important~ seafannually if they analysis on edible brates species in vicinity of plant are not seasonal. portions.

discharge area.

One sample of-same species in areas not influenced by plant .

. discharge.

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l j TABLE 16.11-7 (Pace 5 of 7)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

'~

NUMBER OF REPRESENTATIVE-

. EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS (3) COLLECTION FREQUENCY OF ANALYSIS

c. Food One sample of each principal At time of harvest (10) Gamma is pic Products class of food product.s from any on edible portion. analyses area that is it rigated by water in which liquid plant wastes

'have been discharged.

Samples'of three different kinds Monthly when available. , Gamma isotopic (5) and g .of broad leaf vegetation grown I-131 analysis, nearest each of two'different offsite locations of. highest:

predictedzannual average.

groundlevel D/Q if milk sampling is not-performed.

One sample of:each of the' Monthly when'available. Gamma isotopic (5) and l similar broad leaf vegetation I-131 analysis. t grown 15-30 km distant.in the' least prevalent: wind direction. 1 if milk: sampling is not t performed.

a

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TABLE 16.11-7 (Page 6 of 7)

TABLE NOTATION (1) where pertinent, shall be provided for each and every sample location in Table 16.11-7 the 00CM. Refer to'NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Devia-Plants,* October 1978, and to Radiological Assessment Branch Technical Position, Revision I, November 1979.

tions are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, If' specimens seasonal unavailability, malfunctien of automatic sampling equipment and other -legitimate reasons.

are unobtainable due to sampling equipment malfunction, every effort shall_ be~made to complete corrective action to l

.the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual at times, it may not be possible or practica-Radiologoical Environmental Operating Report. ,It is recognized that; In these instances ble to continue to obtain samples of the-media of choice at the most desired' location or time. I suitable alternative media and locations may be chosen for the particular pathway in question and In lieu of a appropriate Licensee Event sub-stitutions made wi. thin 30 days in the Radiological Environmental Monitoring Program.

~

h F Report, identify'the-cause of the unavailability of samples for that pathway and identify the new location (s) for _,

p obtaining replacement samples in the next Semiannual Radioactive Effluent Release Report and also. include in the 1 report a revised figure (s) and table for the ODCM reflecting the new location (s).

y One or more instruments, such as a pressurized ion enamber, for measuring and recording dose rate continuously may (2) be used in place of, or in addition to, integrating'desimeters. For the purposes of this table, a thermolumi-nescent dosimeter (TLD) is considered to be one phosphur; two or more phosphors in a packet are considered 'The. forty assta-two or more dosimeters. Film badges shall'not be used as dosimeters for measuring direct radiation.

The number:of direct radiation monitoring stations may be reduced according to tions is not an absolute number.

geographical _ limitations; e.g., at an ocean site, some sectors will be over water so that the number of dosi ;

may be reduced accordingly.

. tics of the-specific. system used and should be selected to obtain optimum dose information with minimal' fading.

If it is not practical to establish control loca-(3) The purpose of this sample is to obtain background:information.tions in accordance with the distance and w may be substituted.

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TABLE 16.11-7 (Page 7 of 7)

TABl E NOTAliON i

- (4) Airborne particulate sample filters shall be analyzed for grass beta radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more after sampling to allow for radon and , thoron daughter decay. If gross beta activity in air particulate samples is greater than !

ten times the yearly mean of control samples, gamma isotopic analysis shall be performed or the individual samples. i (5) Gamma isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attributable to the effluents from the facility.

(6) The " upstream sample" shall be taken at a distance beyond sionificant 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 enouah upstream to be beyond the plant influence. Salt water shall be sampled only when the receiving water is i utilized for recreational activities.

(7) A composite sample is one in which the quantity (aliosot) of liquid sampled is proportional to the quantity of flowing liquid and in which the method of sampling ec. ployed results in a specimen that is representative of the liquid flow. In this program composite sample aliqunts 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. .

(8) Groundwater samples shall be taken when this sou.ce is tapped for drinking or irrigation purposes in areas where i the hydraulic gradient or recharge properties are suitable for coatamination.

(9) The dose shall be calculated for the maximu organ and age group, using the methodology and parameters in the 00CM.

(10) 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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TABLE 16.11-8 (Page 1 of 4)

REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES REPORTING LEVELS BROAD LEAF WATER AIRBORNE PARTICULATE FISH MILK VECl! A!IC.'.

ANALYSIS (pCi/1) OR GASES (pCi/m') (pCi/KG, wet) (pCi/l) (pCi/Kg, wet)

H-3 2 x 10.(1) N.A. N.A. N.A. N.A.

Mn-54 1 x 10' N.A. 3x 10' N.A. N.A.

R Fe-59 4 x 102 N.A. Ix 10' N.A. N.A.

hg Co-56 1 x 10' N.A. 3x 10' N.A. N.A.

Co-60 3 x 10' N.A. Ix 10' N.A. N.A.

Zn-65 3 x 10 N.A. 2 x 10' N.A. N.A.

Zr-Nb-95 4 x 10 N.A. N.A. N.A. N.A.

I-131 2 1 N.A. 3 1x 10 Cs-134 30 10 1x 10' 60 1 x 10' Cs '37 50 20 2x 10' 70 2x 10' Ba-La-140 2 x 102 N.A. N.A. 3x 102 N.A.

(1) For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 3x 10' pCi/l may be used.

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TABLE 16.11-8(2) (Page 2 of 4)

MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION (LLD)(1),(3)

AIRBORNE PARTICULATE BROAD LEAF WATER OR GAS FISH MILK VEGETATION SEDIMENT ANALYSIS ipci/1) (pCi/a') (pC1/kg, wet) (pC1/1) (pCi/kg, wet) (pC1/kg, dry)

Gross beta 4 N.A. N.A. N.A. N.A. N.A.

H-3 2000* N.A. N.A. N.A. N.A. N.A.

Mn-54 15 N.A. 130 N.A. N.A. N.A.

Fe-59 30 N.A. 260 N.A. N.A. N.A.

Co-58, 60 15 N.A. 130 N.A. N.A. N.A.

$ Zn-65 30 N.A. 260 N.A. N.A. N.A.

t I

Zr-95 15 N.A. N.A. N.A. N.A. N.A.

Nb-95 15 N.A. N.A. N.A. N.A. N.A.

1-131 1(4) 7 X 10 -2 N.A. I 60 N.A.

Cs-134 15 5 X 10 -2 130 15 60 150 Cs-137 18 6 X 10-2 150 18 80 180 Ba-140 15 N.A. N.A. 15 N.A. N.A.

La-140 15 N.A. N.A. 15 N.A. . N.A.

If no drinking water pathway exists, a value of 3000 pCi/1 may be used.

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

TABLE 16 11-8 (Pace 3 of 4)

(ABLE NOTATION (1) The LLD is definsd, for purposes of these commitments, as the smallest concentration of radioauive material in a sample that will yield a net count (above system background) that will be detected with 95% probabil-ity with 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 bl0

E -

V -

2.22 -

Y -

exp(-kat)

Where:

LLD is the "a priori" lower limit of detection as defined above (as picocurie per unit mass or volume),

su is the standard deviation of the background counting rate or of tMe counting rate of a blank sample as appropriate (as counts per minute),

E is the counting efficiency (as counts per disintegration),

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

2.22 is the number of disintegrations per minute per picocurie, Y is the fractional radiochemical yield (when applicable),

1 is the radioactive decay constant for the particular radionuclide, and at is the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not plant effluent samples).

It should be recognized that the LLO is defined as an a priori (before the fact) !imit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a par-ticular measurement. Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.

l Occasionally background fluctuations, unavoidable small sample sizes, the pressence of interfering nuclides, or other uncontrol-lable circumstances may render these LLDs unachievable. In such cases, the contributing factors shall be identified and described in O the Annual Radiological Environmental Operating Report.

l 16.11-55

4 i

TABLE 16,11-8 (Paae 4 of 4)

TABLE NOTATION (2) 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. -

(3) Required detection capabilities for thermoluminescent dosimeters used for environmental measurements shall be in accordance with the recommenda-tions of Regulatory Guide 4.13.

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

O i

O 16.11-56

16.11 RADIOLOGICAL EFFLUENT CONTROLS RADIOLOGICAL ENVIRONMENTAL MON 1IORING 16.11-14 LAND USE CENSUS COMMITMENT A land use census shall be conducted and shall identify 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 m8 (500 ft') producing broad leaf vegetation. (For elevated releases as defined in Regulatory Guide 1.111, Revision 1. July 1977, the land usa census shall also identify within a distance of 5 km (3 miles) the locations in each of the 16 meteorological sectors of all milk animals and all gardens of greater than 50 m8 producing broad leaf vegetation.)

APPLICABILITY; At all times.

REMEDIAL ACTION:

a. With a land use census identifying a location (s) which yields a calculated dose or dose commitment greater than the values currently O

being calculated in SLC 15.11-9, in lieu of a Licensee Event Report, V identify the new location (s) in the next Semiannual Radioactive Effluent Release Report,

b. With a land use census identifying a location (s) which yields a calculated dose or dose commitment (via the same exposure pathway) 20*4 greater than at a location from which samples are currently being obtained in accordance with SLC 16.11-13, add the new location to the Radiological Environmental Monitoring Program. The sampling location (s), excluding the control station location, having the lowest calculated dose or dose commitment (via the same exposure pathway) may be deleted from this montoring program after October 31 of the year in which this land use census was conducted. In lieu of a Licensee Event Report, the next Semiannual Radioactive Effluent Release Report shall contain the following information: (1) the new location (s), (2) revised figure (s) and table (s) for the ODCM re-flecting the new location (s), and (3) if samples cannot be obtained, an explanation of why samples are not obtainable (substitute repre-sentative locations shall be included, if possible).

Broad leaf vegetation sampling of at least three different kinds of vegeta-tion may be performed at the SITE B0UNDARY in each of two different direction sectors with the highest predicted 0/Qs in lieu of the garden census. Speci-fications for broad leaf vegetation sampling in Table 16.11-7.4c-shall be followed, including analysis of control samples.

(

16.11-57

e TESTING REQUIREMENTS:

The land use census shall be conducted during the growing season'at least once per 12 months using that information which will provide the best results, such as by a door-to-door 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.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix I l

BASES:

This commitment is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radio- '

logical Environmental Monitoring Program are made if required by the results of this census. The best information fron the door-to-door survey, from aerial survey, or from consulting with local gricultural authorities shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I-to 10 CFR Part 50. Restricting the census to gardens of greater than 50 m 8 provides assurance that significant 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 O- 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 bruad leaf vegetation (i.e., similar to lettuce and cabbage),

and (2) a vegetation yield of 2 kg/m . 8 4

16.11-58

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

() 16.11 RADIOLOGICAL EFFLUENT CONTROLS RADIOLOGICAL ENVIRONMENTAL ! i!TORING 16.11-15 INTERLABORATORY iPARISON PROGRAM COMMITMENT Analyses shall be performed on radioactive materials, supplied as part of an Interlaboratory Comparison Program that has been approved by the Commission, that correspond to samples required by SLC 16.11-13.

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 Radio-logical Environmental Operating Report.

TESTING REQUIREMENTS:

The Interlaboratory Comparison Program shall be described in the ODCM. A O summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report.

REFERENCES:

1. McGuire Offsite Dose Calculation Manual

2. 10 CFR Part 50, Appendix I BASES:

This requirement for 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 environ-mental monitoring-in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix 1 to 10 CFR Part 50.

O l l

16.11-59

16.11 RADIOLOGICAL EFFLUENT CONTR01.5 REPORTS 16.11-16 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT AND SEMI ANNUAL EFFLUENT RELEASE REPORT COMMITMENT -

16.11-16.1 ANNVAL RADIOLOGICAL ENVIRONMENT 3L OPERATING REPORT

Routine Annual Radiological Environmental Operating Reports covering the operation of the unit during the previous calendar veer shall be submitted prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following initial criticality.

The Annual Radiological Environmental Operating Reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental 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 land use censuses required by SLC 16.11-14.

The Annual Radiological Environmental Operating Raports shall include 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 sum-marized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revi-sion 1, November 1979. In the event that some individual results are not available for inclusinn 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 direc-tions from the centerline of one reactor; the results of licensee participa-tion 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 LLO required by Table 16.11-8 page 2 of 2 was not achievable.

A single submittal may be made for a multiple unit station.

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

16.11-60

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16.11-16.2 SEMIANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT (See Note)

Routine Radioactive Effluent Release Reports covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 days af ter January 1 and July 1 of each year. The period of the first report shall begin with the date of initial criticality.

The Radioactive Effluent Release Reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste-

> tleased from the unit as outlined in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radio-active Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The Radioactive Effluent Release Report to be submitted within 60 days after January 1 of each year e all include an annual summary of hourly meteorological data collected over th( srevious year. This annual summary may be either in the form of an hour-by-nour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of hint frequency distributions of wind speed, wind direction, and atmospheric stability. [In lieu of submission with the first half year Radio-active Effluent Release Report, the licensee has the option of retaining this summary of required meteorological data on site in a file that shall be provided to the NRC upon request.) This same report shall include an assess-f ment o,' the radiation doses due to the radioactive liquid and gaseous '

i ef flus.nts 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 MEMBERS OF THE PUBLIC due to their activities inside the SITE B0UNDARY during the report period. All assumptions used in making these assessments, i.e. , specific activity, exposurp 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 Radioactive Effluent Release Report to be submitted 60 days after January 1 of each year shall also include an assessment of radiation 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 con-formance with 40 CFR Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operation." Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev. 1, October 1977.

The Radioactive Effluent Release Reports shall include the following information for each type of solid waste shipped offsits during the report period:

/O a. Total container volume, in cubic meters, 16.11-61~

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

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

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

e. Number of shipments, and

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

The Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

The Radioactive Effluent Release Reports shall include any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE 00SE CALCULATION MANUAL (00CM), 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 a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate Radwaste Systems, the submittal shall specify the releases of radioactive material from each unit.

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ML20081L561

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ML20081L561

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