Text

Forwards marked-up Radiological Effluent Tech Specs,Revised for Consistency W/Preproof & Review Tech Specs,Per Fd Anderson Request
	ML20082Q563
Person / Time
Site:	Wolf Creek
Issue date:	12/06/1983
From:	Koester G; KANSAS GAS & ELECTRIC CO.
To:	Harold Denton; Office of Nuclear Reactor Regulation
References
	KMLNRC-83-160, NUDOCS 8312120255
	Download: ML20082Q563 (80)
	v • d • e

l KANSAS GAS AND ELECTRIC COMPANY TPE ELECTRC COMPANY GLENN L sLOESTER wct pets.ormy. pouctaan December 6,1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 KMLNRC 83-160 Re:

Docket No. STN 50-482 Ref:

Letter SLNRC 83-0050 dated 9/7/83 from NAPetrick, SNUPPS, to HRDenton, NRC Subj: Radiological Effluent Technical Specifications

Dear Mr. Denton:

The Referenced letter transmitted draft Wolf Creek Radiological Effluent Technical Specifications. Per the request of Mr. F. D. Anderson (NRC Technical Specifications reviewer), these Radiological Effluent Technical Specifications have been revised to be consistent with those in the

" pre-proof and review" copy of the Wolf Creek Technical Specifications.

Transmitted herewith are five copies of the revised Wolf Creek Radio-logical Effluent Technical Specifications. The information in this submittal should replace the previously submitted Wolf Creek Radiological Effluent Technical Specifications.

Yours very truly,

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O GLK:cks Attach cc: JHolonich (2)

WSchum/ASmith 8312120255 831206 b

PDR ADOCK 05000482 I{

A PDR 201 N. Market - Wictuta, Kansas - Mail Address: RO. Box 208 i Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451

t OAT!' OF AFFIRMATION STATE OF KANSAS

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COUNTY OF SEDGWICK )

I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and affirm that I am Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal, know the contents thereof, and that all statements contained therein are true.

KANSAS GAS AND ELECTRIC COMPANY ATTEST:

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Vice President - Nuclear MchardD.Terrill,Secretarh 4

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STATE OF KANSAS

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COUNTY OF SEDGWICK )

BE IT REMEMBERED that on this 6th day of December, 1983

, before me, Evelyn L. Fry, a Notary, personally appeared Glenn L. Koester, Vice President - Nuclear of Kansas Gas and E3 ectric Company, Wichita, Kansas, I-who is personally known to me and who executed the foregr !ng' instrument, and he duly acknowledged the execution of the same for at. on behalf of ar.d as the act and deed of said corporation.

i IN WITNESS WilEREOF, I have hereunto set my hand and affixed my seal the date and year above written.

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..a.~y' em r um 4 ~u y WOLF CREEK SPECIFIC RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS i

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DEFINITIONS OFFSITE DOSE CALCULATION MANUAL 1.17 The 0FFSITE DOSE CALCULATION MANUAL (00CM) shall contain the methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm / Trip Setpoints, and in the conduct of the Environ-mental Radiological Monitoring Program.

OPERABLE - OPERABILITY 1.18 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when i,t is capable of performing its specified function (s),

and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function (s) are also capable of performing their related support function (s).

OPERATIONAL MODE - MODE 1.19 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination af core reactivity condition, power level', and average reactor coolant temperature specified in Table 1.2.

PHYSICS TESTS 1.20 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the core and related instrumentation: (1) described in Chapter 14.0 of the FSAR, (2) authorized under the provisions of 10 CFR 50.59, or (3) otherwise approved by the Commission.

PRESSURE BOUNDARY LEAKAGE 1.21 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator tube leakage) through a nonisolable fault in a Reactor Coolant System componcat body, pipe wall, or vessel wall.

PROCESS CONfROL PROGRAM e PROCESS CONTROL PROGRAM shall contain the current formula, sampling.

analyses, tes terminations to be made to ensure that the

'g and packaging of solid ra io tes based on d processing of 55ec actual or simulated wet solid wastes w' ished in such a way as to 5C" sert assure compliance with 1 0, 10 CFR Part 71 an nd State I

regulation ground requirements, and other requirements governin

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PURCE - PURGING 1.23 PURGE or PURGING shall be any controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, in such a manner that replacement air or gas is required to purtfy the confinement.

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WOLF CREEK - UNIT 1 1-4

Id5ECT I Process Control Program (PCP) 1.22 The PROCESS CONTROL PROGRAM is the sampling, tests, analyses, and formulation determination by which SOLIDIFICATION of radioactive vastes from liquid systems is assured.

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I SPECIFICATION 1.22 JUSTIFICATION:

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The proposed definition is a more concise and understandable explaination and does not compromise or alter the intent of the original It is understood the program defined will be formulated to definition.

assure compliance with appropriate Title 10 to assure Code of Federal Regulations. General Design Interim and Objectives. Regulatory Guides u

Adding requirements and reference to basic landindustrypractices.

definitions will not enhance the overall program objectives and makes j

, understanding the basic intent of the definitions more difficult.

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DEFINITIONS SOURCF CHECK 1.32 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a source of increased radioactivity.

STAGGERED 1EST BASIS 1."33 A STAGGERED TEST BASIS shall consist of:

a.

A test schedule for n systems, subsystems, trains, or other designated components obtained by dividing the specified test interval into n equal subintervals, and D.

The testing of one system, subsystem, train, or other designated component at the beginning of each subinterval.

THERMAL POWER J

1.34 THERMAL POWER shall be the total core heat transfer rate to the reactor coolant.

TRIP ACTUA'*ING DEVICE OPERATIONAL TEST 1.35 A TRIP ACTUATING DEVICE OPERATIONAL TEST shall consist of operating the Trip Actuating Device and verifying OPERABILITY of alarm, interlock and/or trip functions.

The TRIP ACTUATING DEVICE OPERATIONAL TEST shall include adjustment, as necessary, of the Trip Actuating Device such that it actuates at the raquired Setpoint within the required accuracy.

UNIDENTIFIED LEAKAGE 1.36 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE.

UNRESTRICTED AREA 1.37 An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY access to which is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area l

within the SITE BOUNDARY used for residential quarters or for industrial, com-merr,ial, institutional, and/or recreational purposes.

VENTILATION EXHAUST TREATMENT SYSTEM 1.38 A VENTILATION EXHAUST TREATMENT SYSTEM is any system designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through ct.o.ccol adsorbers and/or-HEh4 filters for the purpose of removing lodines or partic-ulates from the gaseous exhaust stream prior to the release to the. environment.

Such a system is not considered to have any effect on noble gas ef'luents.

f Engineered Safety Features (ESF) Atmospheric Cleanup Systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

WOLF CREEK - UNIT 1 1-6 Y

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SPECIFICIATION 1.38 l

JUSTIFICATION Although charcoal adsorbers and HEPA filters are the most common filterc used today, other filters may also be used for this purpose.

Deleting the words " charcoal" and "HEPA" would allow the use of other filters should better ones become available.

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OEFINITIONS VENTING 1.39 VENTING shall be any controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING.

Vent, used in system names, does not

.ipply a VENTING process.

WASTE GAS HOLOUP SYSTEM 4

i 1.40 A WASTE GAS HOLDUP SYSTEM shall be any system designed and installed to reduce radioactive gaseous effluents by collecting Reactor Coolant System off-gases from the Reactor Coolant System and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the environment.

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ESERT-02 "LIOUID RADWASTE TREAIMENT SYSTEM" 1.41 A LIQUID RADWASTE TREATMENT SYSTEM is any system designed r

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and installed to reduce radioactive materials in liquid effluents by systematic collection, retention and processing

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through filtration, evaporation, separation and/or ion exchange treatment.

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i SPECIFICATION 1.41 JUSTIFICATION This definition is added to define terminology used in Specification 3.11.1.3 and 4.11.1.3.2 which was previously I

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Technical Specification 3.3.3.1 Table 3.3-6 Table 4.3-3 Technical Specification 3.3.3.1 and its meanciated tables have been included as a portion of the Radiological Effluent Technical Specifications (RETS) as opposed to the Standoni Technical Spect'fications (STS) in order to provide consistency with similar instrumentation tables in Technical Specification 3.3.3.10.

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INSTRUMENTATION 3/4.3.3 MONITORING INSTRUMENTATION RADIATION MONITORING FOR PLANT OPERATIONS LIMITING CONDITION FOR OPERATION s

3.3.3.1 The radiation monitoring instrumentation channels for plant operations shown in Table 3.3-6 shall be OPERABLE with their Alarm / Trip Setpoints within the specified limits.

APPLICABILITY: As shown in Table 3.3-6.

ACTION:

With a radiation monitoring channel Alarm / Trip Setpoint for plant a.

operations exceeding the value shown in Table 3.3-6, adjust the Setpoint to within the limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or declare the channel inoperable.

b.

With one or more radiation monitoring channels for plant operations inoperable, take the ACTION shown in Table 3.3-6.

The provisions of Specifical:ans 3.0.3 and 3.0.4 are not applicable.

c.

SURVEILLANCE REQUIREMENTS 4.3.3.1 Each radiation monitoring instrumentation channel for plant operations shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST operations for the MODES and at the frequencies shown in Table 4.3-3.

WOLF CREEK - UNIT 1 3/4 3-39 e

5 TABLE 3.3-6 7,

RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS g

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MINIMUM CHANNELS CHANKELS APPLICABLE ALARM / TRIP FUNCTIONAL UNIT TO TRIP / ALARM OPERABLE MODES SETPOINT ACTION e

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Containment e

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Containment Atmosphere Radioactivity-High 1

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Centain :.t "u;;c Exh =t " di:::tivity-

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20 c.

Gaseous Radioactivity-RCS Leakage Detection N.A.

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29 wg

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Particulate N.A.

1 1,2,3,4 N.A.

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Radioactivity o

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TABLE 3.3-6 (Continued)

TABLE NOTATION or

With fuel in the fuel storage areas of fuel building.

- With irradiated fuel in the fuel storage areas E' fuel building.

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Must satisfy Specification 3.11.2.1 requirements.

ACTION STATEMENTS

'AC' TION 26 - With less than the Minimum Channels OPERABLE requirement, opera-tion may continue provided the containment purge valves are main-tained closed.

ACTION 27 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months isolate the Control com Ventilation System and initiate operation of the Control Cme.yce VentilationSystem/intherecirculationmode.

Roo or ACTION 28 - With less than the Minimum Channels OPERABLE requirement, opera-tion may continue for up to 30 days provided an appropriate portable continuous monitor with the same Alarm Setpoint is provided in the fuel pool area.

Restore the inoperable monitors to OPERABLE status within 30 days or suspend all operations involving fuel movement in the fuel building.

ACTION 29 - Must satisfy the ACTION requirements for Specification 3.4.6.1.

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WOLF CREEK - UNIT 1 3/4 3-41 1

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RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS SURVEILLANCE REQUIREMENTS O

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E CHANNEL MODES CHANNEL CHANNEL OPERATIONAL REQUIRING Q

FUNCTIONAL UNIT CHECK CALIBRATION TEST w

SURVEILLANCE 1.

Containment Containment Atmosphere a.

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Gaseous Radioactivity-

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RCS Leakage., Detection S

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Particulate g

Radioactivity -

RCS Leakage Detection S

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Radioactivit -High S

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b.bfCriticality-High Radiation Level S

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Control Room Air Intake Radioactivity-

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With fuel in the fuel storage areas or fuel building.

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(1) Monitor instrument numbers were incorporated to clarify site specific changes.

(2) Specific references deleted were based primarily on the fact that related actuation logic and relays associated with contairnent purge, fuel building isolation, and control room ventilation, are surveilled per Technical Specification 3.3.2.

Specification 3.9.12 tests the actuation logic associated with high radiation in the spent fuel pool.

Specification 3.7.6 also tests the logic associated with the automatic functions of the control room ventilation.

This change continues to assure operability of the radiation monitoring instrumentation and ensures appropriate initiating signals which will result in appropriate systet actuation levels.

This change also reduces redundant specification requirements which must be tracked to assure operability.

INSTRUMENTATION RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENT _ATION LIMITING CONDITION FOR OPERATION 3.3.3.10 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specification 3.11.1.1 are not exceeded. The Alarm /

Trip Setpoints of these channels shall be determined :nd adju;ted in accordance with the methodology and parameters in the 0FFSITE DOSE CALCULATION MANUAL (ODCM).

APPLICABILITY:

At all times.

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With a radioacti liquid effluent monitoring instru entation channel Alarm / Trip Setppint less conservative than required y the above specification,fi;;;dictcly suspend the release of r dioactive liquid effluents monitored by the affected channel, or declare the channel inoperable.

b.

With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown

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in Table 3.3-12.

Restore the inoperable instrumentation to OPERABLE status within the time specified in the ACTION, or explain in the next semiannual Radioactive Effluent Release Report, pursuant to Specification 6.9.1.7, why this inoperability was not corrected within the time specified.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

c.

SURVEILLANCE REQUIREMENTS 4.3.3.10 Each radioactive liquid 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 4.3-8.

WOLF CREEK - UNIT 1 3/4 3-63

SPECIFICATION 3.3.3.9 JUSTIFICATION:

Immediately is a term subject to interpretation and if taken literally it is unlikely that any of the required action could be accomplished within the required time frame. The wording "without delay" is proposed since it more clearly communicates 4

the time frame of the required action.

The proposed wording in regard to changing the setpoint is justified since it is an action that can reasonably be accomplished and if implemented would result in a condition that is in compliance with the specification.

The term "and adjusted" has been deleted as it is not the purpose of the ODCM to instruct on the adjustnent of setpoints, but rather in the calculation of setpoints. Setpoint adjustment will be made in accordance with the applicable plant procedures.

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RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION 2

MINIMUM El CHANNELS t

INSTRUMENT OPERABLE ACTION G mss Si

1. A Radioactivity Monitors Providing ".!c c; :nf 1

Automatic Termination of Release g,

a.

Liquid Radwaste Discharge Monitor (RE-18) 1 31 gg,

b.

SteamGeneratorBlowdownDischa[peMonitor('RE-52) 1 32 c.

Turbine Building Drain Monitor ('RE-59) 1

-32 33 M9 d.

Secondary Liquid Waste System Monitor l'RE-45) 1 4HF 14 2.

Flow Rate Measurement Devices

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Liquid Radwaste Discharge Lira l

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1) Waste Monitor Tank A Discharge Line 1

4F4 35

2) Waste Monitor Tank B Discharge Line 1

4F& 3 5

'a.

Steam Generator Blowdown Discharge Line 1

4WL 35 c.

Secondary Liquid Waste System Discharge Line 1

34-3 5 d.

Cesling Tower Olewdv.n Line 1

34 4

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WOLF CREEK TABLE 3.3-12 JUSTIFICATION The generic standard tech spec tables do not reflect the Wolf Creek The table has been revised to reflect actual site Plant, design.

specific design in regard to release pathways and liquid effluent radioactivity monitors.

Liquid effluent Radioactivity monitors are identified and described in Section 11.5.2.2.3 of the SNUPPS FSAR. Table The 3.3-12 has been revised to incorporate these monitors.

monitors listed cover all actual aad potential liquid effluent release pathways during normal plant operations.

Since Wolf Creek does not have effluent Radioactivity monitors that provide alarm but not automatig termination of the release, no monitors in this category were listed.

Continuous composite samplers and sampler flow monitors are not included in the Wolf Creek Plant design. Online radioactivity monitors provide the capability for real time assessment and l

control of liquid effluents being discharged and are considered more desirable than only composite samplers which provide only an after the fact sample. Since online monitors with automatic isolation features are provided in lieu of composite samplers for the indicated pathways, the composite sampler category is deleted.

Flow rate measurement devices are listed as required by the standard RETS.

Radioactivity recorders are not applicable to Wolf Creek since monitor set points are not based upon record-controller devices.

Therefore, this cate',ory is not included in Table 3.3-12.

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TABLE 3.3-12 (Continued) t ACTION STATEMENTS ACTION 31 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided that prior to initiating a release.

a. At least two independent samples are analyzed in accordance with Specification 4.11.1.1.1, and

b. At least two technically qualified members of the facility staff independently verify the release rate calculations and discharge line valving; Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 32 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided grab samples are analyzed for radioactivity for up to 30 days at a lower limit of detection of r.: mere th:n-10 7 microcurie /ml:

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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, or

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 microcurie / gram DOSE EQUIVALENT I-131.

ACTION 33 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this Id5 N 0

~~ 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 analyzed for radioactivity at a lower limit of detection of ac =cre than 10 7 d

!=u t microcurie /ml.

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ACTION 34 - With the number of channels OPERABLE less than required by the 36 Minimum Channels OPERABLE requirement, effluent releases via this l

l 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 during actual releases. Pump l

performance curves generated in place may be used to estimate flow.

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1 INSERT 03 Action 33 "while a release is occurring INSERT - 04 Action 34 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may continue for up to 30 days provided that prior to initiating a release:

At least two independent samples are a,

analyzed in accordance with Specification 4.11.1.1.3, and b.

At least two technically qualified members of the Facility Staff independently verify the release rate calculations and discharge line valving; Otherwise, suspend release of radioactive effluents via this pathway.

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TABLE 3.3-12 TABLE NOTATION JUSTIFICATION:

(1)

Action 33 was modified to clarify the fact that the sa=pling requirement is applicable only while releases are occurring.

(2)

The new Action 34 was incorporated because the 30 day release interval and the sampling and analysis requirements are the most appropriate action for the Secondary Liquid Waste System since this is a batch type release of either non-radioactive or at the most very low level radioactive wastes.

(3)

Deletie...f Acti n 32 -

The criginal f. :ica 32 is as: applicati : the pr pssed Revised Table 3.3 12 5 : use radicactivity rc : dcrc nr: net included in the CNUT?S "lant d::ign.

TABLE 4.3-8 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Q

ANALOG A

CHANNEL 75 CHANNEL SOURCE CHANNEL OPERATIONAL INSTRUMENT CHECK CHECK CALIBRATION TEST E

cerew oak er (mm y

1.

A Radioactivity Monitors Providing Alarm and Automatic Termination g

of Release g,

Liquid Radwaste Discharge Monitor (! -18)

RE D

P R(2)

Q(1) a.

b.

Steam Generator Blowdown Discharge D

M R(2)

Q(1)

Monitor (RE-52) ax-c.

Turbine Building Drain Monitor

(%eRE-59)

D M

R(2)

Q(1)

R y

d.

Secondary Liquid Waste System D

M-R(2)

Q(1) g Monitor (RE-45)

P ar-2.

Flow Rate Measurement Devices a.

Liquid Radwaste Discharge Line

-0(3)

N A.

R Q

b.

Steam Generator Biowdown Discharge Line D(3)

N.A.

R Q

c.

Secondary Liquid Waste System D(3)

N.A.

R Q

Discharge Line

_ d.

Cocling Tower Clowdown Linc D(3)

NA R

Q (O vade A e.d., %L A % d..y L.4 b(3)

M A.

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%A B D;ub. W bO)

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TABLE 4.3-8 (Continued)

TABLE NOTATIONS l

(1) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this pathwaydmi control room alarm annunciation occur if ad /or - any of the following conditions exists:

(wuw ei h InstrumentindicatesmeasuredlevelsabovetheAlarm/TripSetpoint!'or a.

Amter

[ Circuit failure (A orah,m eq ),

b.

c.

Instrument indicates a downscale failure (alarm only), or d.

Instrument controls not set in operate mode (alarm only).

(2) TW ial CHANNEL CALIBRATION shall be performed using one o o

the referen dards certified by the National B Standards (NBS) or using stan a W ave been from suppliers that

$ sert O!I Participate in measurement as tivities with NBS.

These standards shall permit calib e system over i ded range of energy and measur gne.

For subsequent CHANNEL CALIBRA rces that have n related to the initial calibration shall be used.

(3) 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 made.

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WOLF CREEK - UNIT 1 3/4 3-67

rAsEe.T-of CHANNEL CALIBRATION shall be performed using:

a.

One or more standards traceable to the National Bureau of Standards, or b.

Standards obtained from suppliers that participate in measurement assurance activities with the National Bureau of Standards, or i

c.

Standards related to previous calibrations performed using (a) or (b) above.

l l

TABLE 4.3-TABLE NOTATION JUSTIFICATION (1) The changes to notation (1) were made to reflect the designed capabilities and characteristics of the SNUPPS effluent monitoring system. Although the monitors will provide an alarm indication when each of the 4 specified conditions exist, alarm and isolation will occur only when the Alarm / Trip set-point is exceeded.

(2) Table notation (2) was deleted since there are no monitors in the table which have alarm functions only and, therefore, is not referenced by the table.

(3) In reference to table notation (3) -

These monitors are calibrated by the manufacturer using NBS traceable standards for principal radionuclide energies and concentrations.

(Calibration of these monitors is addressed in FSAR Section 11. 5. 2.1. 5. ) In view of this fact, the alternate wording is proposed to clarify CHANNEL CALIBRATION reference standard requirements and is directed towards calibrations to be performed concurrent with and subsequent to initial plant startup. The proposed wording is consistent with Reg. Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environ =ent and the intent of the original footnote.

INSTRUMENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.11 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-13 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specification 3.11.2.1 are not exceeded. The Alarm / Trip Setpoints of these channels shall be determined :nd 2dju:ted in accordance with the methodology and parameters in the 00CM.

APPLICABILITY: As shown in Table 3.3-13.

'II d

6 ACTION:

jlk*#

1 a.

With a radioactive ga eous effluent monitoring instru entation channel Alarm / Trip Sq point less conservative than re uired by the above specification,M diately suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the chanc.el inoperable.

b.

With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE take the ACTION shown in Table 3.3-13.

Restore the inoperable instrumentation to OPERABLE status within the time specified in the ACTION, or explain in the next semiannual Radioactive Effluent Release Report, pursuant to Specifica-tion 6.9.1.7, why this inoperability was not corrected within the time specified.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

c.

SURVEILLANCE REQUIREMENTS 4.3.3.11 Each radioactive gaseous affluent 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 frequencias shown in Table 4.3-9.

l l

1 i

WOLF CREEK - UNIT 1 3/4 3-68 m

, 2 -....

SPECIFICATION 3.3.3.10 JUSTIFICATION:

Immediately is a term subject to interpretation and if takeq literally it is unlikely that any of the required action could be accomplished within the required time frame. The wording "without delay" is proposed since it more clearly communicates the time frame of the required action.

The proposed wording in regard to changing the setpoint is justified since it is an action that can reasonably be accomplished and if implemented would result in a condition that is in compliance with the specification.

The term "and adjusted" has been deleted as it is not the purpose of the ODCM to instruct on the adjustment of setpoints, but rather in the calculation of setpoints. Setpoint adjustment will be made in accordance with the applicable plant proccdures.

e w

, ~ ~ -. - - - -. -

i I

TABLE 3.3-13 RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMdM CHANNELS Q

A INSTRUMENT OPERABLE APPLICABILITY ACTION n

l 1.

WASTE GAS HOLDUP SYSTEM Explosive Gas E

Monitoring System Z

a.

Hydrogen Monitor 1/recombiner 42, **

g M

M b.

Oxygen Monitor 2/recombiner 2.

Unit Vent System (C< CE 2i) 40 a.

Noble Gas Activity Monitor

^ u -;Ji.,3 1

lsr;;; (RE -21)

Iodine?,cthlif[Mcr. iter (RE-21) 43' 44 1

R b.

43 't4 ParticulateAc$5ft["o-iter (RC21) 1

'y c.

7 ss d.

now nt: "=itar 1=-

i 39 e.

Sampler Flow Rate Monitor 1

Containment Purge System (cT *)-2 2, 3.

or -ac - n, cv - gc.

,6 r - at - st l

a. Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Release 41 (RE-22, RE-33, RE 31, RE 32)-

1 l

l q

b. Icd;o e Samp u

}

I c. a -htJ e s, pte<

i 44 i

n.

e i.

M,

.l ~

g c

g M

tr.J h <

g G. S,w ler Fica R~ic e

TABLE 3.3-13 (Continued)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Q

MINIMUM CHANNELS g

INSTRUMENT OPERABLE APPLICABILITY ACTION n

4.

Radwaste Building Vent System rtcalce (&ti- #c - s e)

Eq a.

Noble Gas Activity Monitor - Providing Alarm and Automatic Termination of Wade. Go M -p 3pk.w g

Release W 10) 1 38, 40 W 44 b.

Iodine Activity Monitor (RE-10) 1 c.

Particulate Activity Monitor (RE-10) 1 EP M d.

n s.; h!.2 ";., iter 1

33 e.

Sampler Flow Rate Monitor 1

39

. I T

4 y

l

+

s I

l 1

TABLE 3.3-13 JUSTIFICATIONi The generic standard tech spec table does not reflect the SNUPPS Plant design. The table has been revised to reflect actual site specific design in regard to gaseous effluent monitoring instrumentation.

Explosive gas monitoring instrumentation is provided on the hydrogen recombiners for the Waste Gas Holdup System. Since SNUPPS design has two recombiners, which can be operated independently, a number /recombiner format is used to specify the minimum channels operable requirement. By system design, only the inlet hydrogen monitor for each recombiner provides controlling functions. However, a process hydrogen monitor on the recombiner outlet will alarm and alert operators to conditions of potentially high hydrogen concentrations.

Provided one of the hydrogen monitors is functional, sufficient on-line monitoring is provided to measure and control hydrogen concentrations and ensure safe operation of the Waste Gas Holdup System.

Airborne effluent radioactivity monitors are identified and described in Section 11.5.2.3.3 of the SNUPPS FSAR.

Table 3.3-13 has been revised to incorporate these monitors. In addition to the Unit Vent and Radwaste Building Vent instrumentation, the Containment Purge System monitor has been included in the table since these monitors have pathway isolation functions which will automatically terminate a containment purge.

Containment integrity is not required to be maintained during modes 5 & 6 with the exception of Core Alterations during mode 6.

The proposed change deletes surveillance and operability require-ments in modes where initiating signals from these monitors are not required to function or to be operable.

u

TABLE 3.3-13 (Continued)

TABLE NOTATIONS

At all times.

- During WASTE GAS HOLDUP SYSTEM operation.

alle d c'u u + 1' z,3,4 and durinO en. ACTION STATEMENTS ACTION 38 - 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 release rate calculations and discharge valve lineup.

g

,g Otherwise,suspendreleaseofdadioactiveeffluentsviathis pathway.

ACTION 39 - 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 40 - With the number of channels GPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for radioactivity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 41 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, immediately suspend PURGING of radioactive effluents via this pathway.

l ACTION 42 -

e number of channels OPERABLE one less than required b Minimum OPERABLE requirement, operation of s em may continue provi samples are tak analyzed at least be

,M5"+ k every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . With both c operable, operation may continue proviced r es are ta analyzed at least every 4 ho

. Ing degassing operation and a every 24 uring other operations.

% %^ 7__

3 ACTION A3'- With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases'via the effected pathway may continue for up to 30 days provided sakples are continuously collected with auxiliary sampling equipment as required in Table 4.11-2.

-ACTION " - With the neder of channch CPERABLE n: le:: th:n require W the-Mini::: Chann:h OPERASLE r;;;irc::nt:, ::: pended :::ygen :upply to the rece9iner WOLF CREEK - UNIT 1 3/4 3-71

INSERT - Ol0 42.

ACTION 39 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, addition of waste gas-to the Waste Gas Holdup System may costinue provided grab samples are collected from che on-service gas decay tank and analyzed:

(a) At least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during primary coolant system degassing operations.

(b) At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during other operations.

The provisions of Technical Specification 3.11.2.5 are applicable.

f e

e

g.,.------,--.-,-,+------,--w.--,

e-,

INSERT 07 ACTION 43 - With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, except for testing, isolate the oxygen supply to the, affected recombiner. With no' channels OPERABLE, -

addition of waste gas to the Waste Gas Holdup System may continue provided a grab sample is taken from the on-service waste gas decay tank and analyzed:

(a) At least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during primary coolant system degassing operaticas.

(b) At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during other operations.

The provisions of Technical Specification 3.11.2.5 are applicable.

i y

r----a-4

-w.-p-..w.9y

_y

_g.,--_-.,

__,y

,-.~9

-,_y..ip, y-

_,g _y w, -

,y.,,,,,yy,,,

,,,yy.--,.

,,-,y.w--,

p,-,.ey_,,

-,4

TABLE 3.3-13 TABLE NOTATION JUSTIFICATION (1) ACTION 42.1[.43 Specification 3.11.2.5 provides for the continued safe operation of the WASTE GAS HOLDUP SYSTEM. The proposed sampling and analysis frequencies reflect the period when the maximum amount of Gaseous Radwaste is being added to the system and are therefore designed to detect increases in the hydrogen / oxygen content.

Additionally, due to the large increase in the volume of Caseous Radwaste generated following a shutdown, it would be inadviseable to require that the unit be in at least HOT STANDBY vithin 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

(2) ACTION //#

At4C ACTION 44 has been incorporated into the proposed ACTION VJ.

a

TABLE 4.3-9 tp RADI0ACTIVEGASEOUSEFFLUENTMONITORINGINSTRUMENTATIONSURVEILLANCEREQUIREAENTS n

g ANALOG g

CHANNEL MODES IN WHICH 7c CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST REQUIRED Ey 1.

WASTE GAS HOLDUP SYSTEM Explosive Gas Monitoring System g

a. Inlet Hydrogen Monitor D

N.A.

Q(4)

M

b. Outlet Hydrogen Monitor D

N.A.

Q(4)

M

c. Inlet Oxygen Monitor D

N.A.

Q(5)

M b

d. Outlet Oxygen Monitor D

N.A.

Q(5)

M R

2.

Unit Vent 4yrAem Mr., dice ( C-r ite_ - u)

+

y

a. Noble Gas Activity Monitor-D M

R(3)

Q(2) j y

Previding ^12.rm (RE-21)

b. Iodine ^.ctivity M nitor (RE-21)

W N.A.

N.A.

c. Particulate A.ctivity Meniter (RE-21)

W N.A.

N.A.

-d.

Fl;w Rate Manitor G

N.A.

R Q

e. Sampler Flow Rate Monitor D

N.A.

R Q

i 3.

Containment Purge System A\\cidlw (Gv.et-z2, Gr - m c - 4 3, c, r -,cc - s i, c-r et- -u )

4. Noble Gas Activity Monitor -

I Providing Alarm and Automatic Termination of Release

'3 (RE-22-RE---33, RE-31, RE-32)

D P

R(3)

Q(2)

- 4*

f

b. La.%

5... pt w W

g4 c. 4.

N 4.

g I

ec.. u oc s. p..-

w s a.

p.4 nA.

4 i

e.

a. n_ u,s. e e

. a.

s.

e. %.31.-

Fic o R.Jc (Ac. i hr D

.gA.

a f

TABLE 4.3-9 (Continued) 6 RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS r-n 9

ANALOG N

CHANNEL MODES IN milch CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE INSTRUMENT CHECK CHECK CALIBRATION TEST REQUIRED E

M 4.

Radwaste Building Vent System N Afor (s a-as -scs g

a. Noble Gas Activity Monitor -

D, P MP R(3)

Q(1)

Providing Alarm and Automatic Termination of Release (RE 10) msic k ilaasp sp4<- c%ty b.IodineNYliTyMoniter(RE10)

W N.A.

N.A.

St7 pte <

c. Particulate Act vity Menite. ( RE-le-)- W N.A.

N.A.

i, R

d_ rieg 03te geniter 9

a, n

g u

s Y

e. Sampler Flow Rate Monitor D

N.A.

R Q

1 0

if

,I i

i

9 TABLE 4.3-18 JUSTIFICATION:

The generic standard technical specification table does not reflect the SNUPPS Plant design. The table has been revised to reflect actual site specific design in regard to gaseous effluent monitoring instrumentation.

Containment integrity is not required tc i-1 maintained during modes 5 & 6 with tie exception of Core Alterations during mode 6.

The proposed change deletes surveillance and operability requirements in modes where initiating signals from these monitors are not required to function or to be operable.

4

.,,.a

-,-n

,,.,,,-.g-.

e

TABLE 4.3-9 (Continued)

TABLE NOTATIONS

At all times.

- During WASTE GAS HOLDUP SYSTEM operation.

o re.

aAden 444 t, t, s,4, ud ds3 (1) The ANALOG CHANNEL OPERATIONAL TEST shall also demonstrate that automatic isolation of this pathwayjand control room alarm annunciation occur if y p ' any of the following conditions exists:

, g,..

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

(# %)

b.

Circuit failure A,or Instrument indicates a downscale failure (alarm only),or c.

d.

Istrument controls not set in operate mode (alarm only).

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

Instrument indicates meastred levels above the Alarm Setpoint, or a.

b.

Circuit failure, or c.

Instrument indicates a downscale failure, or d.

Instrument controls not set in operate mode.

(3)

itial CHANNEL CALIBRATION shall be performed using one or rM the refere ndards caertified by the National B tandards (NBS) or using stan a t have been o rom suppliers that 5" p participate in measurement ass ivities with NBS.

These standards M"

shall permit calibt e system over 1 ed range of energy and measurem ge.

For subsequent CHANNEL CALIBRATIO, =

Q have d

. bee related to the initial calibration shall be used.

(4) The CHANNEL CALIBRATION shall include the use of standard gas sat'les containing a nominal:

One volume percent hydrogen, balance nitrogen, and a.

b.

Four volume percent hydrogen, balance nitrogen.

(5) The CHANNEL CALIBRATION shall include the use of standard gas ramples containing a nominal:

One volume percent oxygen, balance nitrogen, and a.

b.

Four volume percent oxygen, balance nitrogen.

Gu.

GscA C9

---7 WOLF CRt2K - UNIT 1 3/4 3-74

ItMEET 08 1

(3) CHANNEL CALIBRATION shall be performed using:

a.

One or more standards traceable to the National Bureau of Standards, or b.

Standards obtained from suppliers that participate in measurement assurance activities with the National Bureau of Standards, or c.

Stan'dards related to previous calibrations using (a) or (b) above.

g INsezT 09 Q

The CHANNEL CALIBRATION shall include the use of standard gas samples containing a nominal:

10 ppm by volume oxygen, balance nitrogen, and a.

b.

80 ppm by volume oxygen, balance nitrogen..

I

TAELE 4.3-)I TABLE NOTATION JUSTIFICATION:

(1)

The changes to notation (1) were made to reflect the designed capabilities and characteristics of the subject monitoring system. Although the monitors will provide an alarm indication when each of the 4 specified conditions exist, alarm and isola-tion will occur only when the Alarm / Trip setpoint is exceeded.

(2)

In reference to table notation (3) -

These monitors are calibrated by the manufacturer using NBS traceable standards for principal radionuclide energies and concentrations.

(Calibration of these monitors is addressed in FSAR Section 11.5.2.1.5.)

In view of this fact, the alternate wording is proposed to clarify CHANNEL CALIBRATION reference standard requirements and is directed towards calibratiens to be performed concurrent with and subsequent to initial plant startup. The proposed wording is consistent with Reg. Guide 4.15. Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment and the intent of the original footnote.

(3)

A table notation (6) was added to address the range and specific calibration requirements of the outlet oxygen monitor. Readout of this monitor is in ppm vice %.

The calibration concentrations specified for CHANNEL CALIBRATION cover both high and low points of the monitor response.

.- ~..

3/4.11 RADI0 ACTIVE EFFLUENTS 3/4.11.1 LIQUID EFFLUENTS CONCENTRATION

.?

LIMITING CONDITION FOR OPERATION 3.11.1.1 The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 5.1-4) shall be limited to the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Coluran 2. for radionuclides other than dissolved or entrained noble gases.

For dissolveo or entrained noble gases, the concentration shall be limited to 2 x 10 4 microcurie /ml total activity.

APPLICABILITY:

At all times.

ACTION:

JJh6" a.With the concentration of radioactive material eleased in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, #

diotelj restore the concen-tration to within the above limits.

b. %c pechens of sp*>c@cdh s W ad 3.c4 are nef Apple'cdle.

SURVEILLANCE REOUIREMENTS 4.11.1.1.1 Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program of Table 4.11-1.

4.11.1.1.2 The results of the radioactivity analysis shall be used in accordance with the methodology and parameters in the ODCM to assure that the concentrations at the point of release are maintained within the limits of Specification 3.11.1.1.

WOLF CREEK - UNIT 1 3/4 11-1

SPECIFICATION 3.11.1.1 JUSTIFICATION:

(1)

The Nchie ga; concentret-ica limit of 2.0E-4-ue4/cc-was-taken-f rom-NuRe g-0472 r-Rev-2Aad iolog i cal-E f f-luen t-Techn ical-Spe ci-

.ficatiene fer PE*.':.

S.i: ::: ceaverted from i.h Xc-135 EC for-air-usin;; ICPJ 2 : th :'clogy.

(2)

The provisions of Specification 3.0.3 and 3.0.4 are not applic-able to Specification 3.11.1.1.

(3)

The W erence-to-Specificatt u v. J.. Ar-was-changed-to-6.9r1Tilb-to-correspond-with-the-proposed-Section-frz0 of-Callaway and-Wolf Greek-Specs.

E w

T r

p w.

w--

-..--y

TABLE 4.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALY3IS PROGRAM 4

LOWER LIMIT MINIMUM OFDETECTgg LIQUID RELEASE SAMPLING ANALYSIS TYPE OF ACTIVITY (LLD)

TYPE FREQUENCY FREQUENCY ANALYSIS (pCi/ml)

Q. Batch Waste P

P 7

Releag)

Each Batch Each Batch Princip gamma 5x10 Tanks Emitters

-6 I-131 1x10

a. Waste Monitor

-5 Tanks P

M Dissolved and 1x10 One Batch /M Entrained Gases (Gamma Emitters)

b. Secondary Liquid

-5 Waste Moni-P M

H-3 1x10 tor Tank Each Batch Composite (4)

_7 Gross Alpha 1x10 P

Q Sr-89, Sr-90 gx10 E5ch Batch Composite (4)

-6 Fe-55 1x10 J

Composite [

Principk3 gamma W

5x10 2.Continuogg) g i

Releases Centi =cus Emitters

-D

""bS"P'

-6 I-131 1x10 q, Steam Generator

-5 Blowdown M

M Dissolved and 1x10 L..i c.

Grab Sample Entrained Gases (Gamma Emitters) b idi"3

-5 Conti=0;M) Composite %

M H-3 1x10 D' "; 5

~7 Diub y V

Gross Alpha 1x10 Lin4-G..L bek l@

-8 Q

Sr-89, Sr-90 5x10 N

Composite

-6 P-"

b Fe-55 1x10 i

G rea b p c WOLF CREEK - UNIT 1 3/4 11-2

=

TABLE ~4.ll-1 JUSTIFICATION:

(1)

The table was revised to incorporate the SNUPPS liquid release types and site specific system terminology. Since the SNUPPS Plant design does not include continuous composite samplers on the steam generator blow down, daily grab samples while the release is occurring is proposed as an acceptable alternative.

(2)

LLD FOR LIQUID BATCH RELEASES FOR Sr-89, Sr-90 As the total activity should be greater for the liquid batch releases vs. the liquid continuous releases, the potential for decreased sensitivity is also greater. It would be impractical to expect that the detection limit (LLD) would increase (become more sensitive) under the conditions of increasing overall activity, therfore, it is proposed that the LLD for liquid batch releases be the same value as that for liquid continuous release.

The proposed value is a factor of 6 below the most restrictive MPC (Sr-90) (10CFR20, Appendix B. Table II, Column 2) and should therefore provide for the detection of sufficiently low l

levels of activity to ensure that releases to Unrestricted Areas are well below legal limits.

J f

TABLE 4.11-1 (Continued)

TABLE NOTATIONS (1)The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

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

4.66 sb E

V 2.22 x 108 Y

exp (-Aat)

Where:

LLD = the "a priori" lower limit of detection (microCuries per un,t mass or volume),

b = the standard deviation of the background countir.g rate or of s

tne counting rate of a olank sample as appropriece (counts per minute),

E = the counting efficier.cy (counts per disintegration),

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

2.22 x 108 = the nt;mber of disintegrations per minute per microcurie, Y = the fractional radiochemical yield, when applicable, A = the radioactive decay constant for the particular radionuclide (s 1), and at = the elapsed time between the midpoint of sample collection and the time of counting (s).

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

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

(2)A batch release is the discharge of liquid wastes of a discrete volu.ne.

Prior to sampling for analyses, each batch shall be isolated, and then thoroughly mixed by a ;;thed d::cM b:d '- th: 0001 to assure representative sampling.

WOLF CREEK - UNIT 1 3/4 11-3

TABLE 4.11-1 (Continued)

TABLE NOTATIONS (Continued)

(3)The principal gamma emitters for which the LLD specification applies include the following radionuclides:

Mn-54, Fe-59, Co-58, Co-60, wen-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the semiannual Radioactive Effluent Release Report h.suant to Specification 6.9.1.7, in the format cutiined in "eguioivry pur

,_,o,

_2.

....., nyrouw..

u, nov.. -.ui.

2, vuo=

22,,.

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

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

(5)T be repre:entativ: Of the quantitic: and cene:ntration: Of r:dicactive materials in liquid effluents, samples : hall b; celic;ted continucu;iy 'r propertien to the rat: Of ficw of th: Offluent :tr :m.

Prior t :nciy::s, all ::mp? : t ktr f r th mpo:it: :h:'l be thercughly -ixed i Order for th : mposite ::mpic to-bc repre::ntative of the effluent reica:.

I WOLF CREEK - UNIT 1 3/4 11-4

.r WOLF TABLE 4.11-1 TABLE NOTATION CREEK JUSTIFICATION (1)

Footnote 3 :

Zn-65 was deleted since Zn-65 analyses are primarily applicable to BWR's with admiralty metal condenser tubes. Per FSAR 4.5.1.1, the primary system does not contain any zine based steel alloys; therefore there is no zine to be activated to Zn-65.

The reference to specification 6.9.1.12 was changed to 6.9.1.7 to correspond to the equivalent section of the proposed section b.0 of the Wolf Creek Tech Specs.

(2)

Footnote 6:

This section was deleted since it is applicable to continuous composite samplers which are not included in the Wolf Creek plant design.

(3)

Footnote 1:

"by a method described in the ODCM" was deleted since the ODCM does not describe a method for mixing tanks.

s l

l m

es.

+

r w--

+ - _ -

g m-e-

-w,.-

y

+r--

y-y

- - - =

w

RADI0 ACTIVE EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION an LdNMd 3.11.1.2 The dose or dose commitment to,te MEMOEP, OF THE PUSLIC from radioactive materials in liquid effluents released, from each unit, to UNRESTRICTED AREAS (see Figure 5.1-4) shall be limited:

a.

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

During any calendar year to less than or equal to 3 mremt to the whole body and to less than or equal to 10 mremy to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuaat to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions that have been taken to reduce the reieases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. This Special Report shall also include:

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

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.2 Cumulative dose contributions from liquid effluents for the current l

calendar quarter and the current calendar year shall be determined in accordance l

with the methodology and parameters in the ODCM at least once per 31 days.

The requirements of ACTION a.(1) and (2) are applicable only if drinking water l

supply is taken from the receiving water body within 3 miles of the plant dis-charge.

In the case of river-sited plants this is 3 miles downstream only.

i l

WOLF CREEK - UNIT 1 3/4 11-5

SPECIFICATION 3.11.1.2 JUSTIFICATION (1) The term " MEMBER OF THE PUBLIC" has been replaced with the term

" Individual" in that:

(a) 10CFR20 and 10CFR50 Appendix I, require that Radioactive Effluent Concentrations, Doses and Dose Rates be calculeted for Individuals at or beyond the SITE BOUNDARY and/or in UNRESTRICTED AREAS. These regulations neither expressly or implicitly require that these calculations be performed for persons, real or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

(b) The use of the term " MEMBER OF THE PUBLIC" as defined in Specification 1.16, is inconsistent with the requirements of the Specification that doses be calculated for UNRESTRICTED AREAS.

Therefore, its use would c ause the Specification to be internally ir. consistent.

(c) As ststed in the bases, the purpose of this Specification is to, provide for co=pliance with 10CFR20 and 10CFR50, Appendix 1, limits. The use of " MEMBER OF THE PUBLIC" is inconsistent

~

with the stated purpose of this Specification.

(d) The design of the Callaway Plant is such that it precludes the possibility of exposure to an individual within the SITE BOUNDARY from liquid effluents.

Therefore, the use of the term " MEMBER OF THE PUBLIC" is inconsistent with the expressed purpose of the Specification and requires inconsistency on the part of the Licensee in complying with the Specification. Additionally, there are no legal requirements for its use in this specification.

Thus, the use of the term ") EMBER OF THE PUBLIC", while appropriate for specifications implementing 40CFR190 requirements, is inappropriate in this Specification, and should be deleted in favor of the term

" Individual".

(2)

As sieted in ACTION s, a Liccaccc Etent Repart ic act required, thereferc, Spccificctic: 5.9.1.11 ic net applicable.

RADI0 ACTIVE EFFLUENTS LIQUID RADWASTE TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION 3*.11.1.3 The Liquid Radwaste Treatment System shall be OPERABLE and appropriate portions of the system shall be used to reduce releases of radioactivity when the projected doses due to the liquid effluent, from each unit, to UNRESTRICTED AREAS (see Figure 5.1-4) would ext :d 0.05 mr ; t; the wh:10 body er 0.2. rrc to.

ny cr;;;n in: 31 day ;: cried. Whm away(c

da35, wedd emed 4

ou (12-or c.

m or m 4e c.13 mece' io %

total bedy cay c <f o.

APPLICABILITY:

At all times.

ACTION:

a.

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

1.

Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability, 2.

Action (s) taken to restore the inoperable equipment to OPERABLE status, and 3.

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

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

I SURVEILLANCE REQUIREMENTS l

4.11.1.3.1 Doses due to liquid releases from each unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM.

4.11.1.3.2 The installed Liquid Radwaste Treatment System shall be considered OPERABLE by meeting Specifications 3.11.1.1 and 3.11.1.2.

l WOLF CREEK - UNIT 1 3/4 11-6

SPECIFICATION 3.11.1.3 JUSTIFICATION _

(1) The interval specified for dose projections is too short to accurately assess Liquid Radwaste Treatment System operations. Dose projections averaged over a 3 month period would be a more valid indication of the need to treat liquid radwaste prior to discharge.

A futher restriction to monthly limits is not warranted required by regulation.

at

.(2) As -stated--in-ACTION

. - Licensee-Event-Report-is not--requiredr-therefore-Spesificativu 6.971T1-1-is tot

eppl-icable.

s o

l f

I l

l l

l

RADIOACTIVE EFFLUENTS LIQUID HOLDUP TANKS LIMITING CONDITION FOR OPERATION 3,.11.1.4 The quantity of radioactive material contained in each of the following unprotected outdoor tanks shall be limited to less than or equal to 150 Curies, excluding tritium and dissolved or entrained noble gases.

a.

Reactor Makeup Water Storage Tank, b.

II; fueling Water Starage Tang, b..e.

Condensate Storage Tank, und - A,;q g;4 of cod m,J p,;.~g b sucoace, loa e) 3 e,,4 Outside temporary anks -ex4eding 'iner; being u::d t: : lidify

__, m e, + u.... -

3 A'y enh ha <. A f ind'ic l.

E'di" b

APPLICABILITY: At all times.

receMn$ rcAcube, ACTION:

a.

With the quantity of radioactive material in any of the above listed tanks exceeding the above limit, immediately suspend all additions of radioactive material to the tank, within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months reduce the tank contents to within the limit, and describe the events leading to this condition in the next semiannual Radioactive Effluent Release Report, pursuant to Specification 6.9.1.7.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.4 The quantity of radioactive material contained in cach of the above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents et 'eert once p /,7 days when racioactive materials are being added to the tank.

U"'

hwe. been WOLF CREEK - UNIT 1 3/4 11-1 1

7 _..

SPECIFICATION 3.11.1.4 JUSTIFICATION:

(1) The eclecti:n :f 150 :: 10: 2:

t: h ::tivity limit 1: 52::d

- - - e r s c a-r qr----- e f -aj e r -

.mper celcul-tfaae perfae-A

a

.r: dice:tive ten' rupturer (FSAR SMUPPS Site Addendum Section 244,12.1-: d 2. ':.13. 3). Re sults-of-tha-g roundwa ter-transpor t-calculation: indi :t: th t 150 curier ir a rufficiently rreLL-fraction of the tank ;;tivity Ic.cle rcquired tu cxceed MPC-eensentratiens et th- ---reet groundeater dieck-rge 1ccatienr.

(2) The SNUPPS Plants have 3 permanent outside storage tanks which have the possibility of receiving radioactive materials:

Refueling Water Storage Tank (RWST) (Ref: FSAR Section a.

6.3.2.2 and FSAR Table 3.2-1 (Sheet 5)).

Although the RWST has the greatest probability of con-taining significant levels of radioactivity, it is a Seismic Category I structure, with overflows to the liquid radwaste system. It should therefore be exempt from this Specification.

b.

Condensate Storage Tank (CST) (Ref: FSAR Section 9.2.6)

The CST is not a Seismically designed structure, but under normal operations, it will contain no radioactivity. Only in the event of a primary-to-secondary system leakage due to a steam generator tube leak, is it possible that the CST would contain radioactive materials. Therefore, the CST should be exempt from the sampling and analysis require-ments of this Specification until such time as it is possible for it to contain radioactive materials.

Reactor Makeup Storage Tank (RMWST) (FSAR Section 9.2.7.2.1 and c.

and FSAR Table 3.2-1 (Sheet 8)

The RMWST is not a Seismically designed structure and, under normal operations, has the possibility of containing extremely low levels of radioactivity. It should therefore be included as part of this Specification.

Modification of the LCO as proposed ensures applicability of the Specification to the SNUPPS Plant design, while maintaining the intent and purpose of the Specification.

43) --ACnOLb: As indicated-in-ACHOba,-events-exceeding-the-LCO-ar d--~ ^ ' d - -- the-Se miannual-Rad ioa c tive-E f fluent

-Releere Repert, ther fere, Specificat4c 5.9.1.11 i; ;;

appl-icable,

(4) Surveillance Requirements 4.11.1.4 Due to the lov level of activity available for addition to these tanks, a sample every 7 days is adequate if only additions have been made. The wording provided by the Standard Tecil Specs would require a separate sample for each addition to the tank -- no matter how small. This restriction is not warranted on these outside tanks.

a i

=

.-...,.r

.,,,_._,_,.,,,-__,,,.--,.,,_.,,,,,_.w.,

RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS DOSE RATE LIMITING CONDITION FOR OPERATION 3.11.2.1 The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to the following:

a.

For noble gases:

Less than or equal to 500 mrems/yr to the whole body and less than or equal to 3000 mrems/yr to the skin, and b.

For Iodine-131 and 133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days:

Less than or equal to 1500 mrems/yr to any organ) frem -h c. ;whd.dion b eq enl.

y APPLICABILITY: At all times.

ACTION:

Whed E'h a.Withthedoserate(s)exceedingtheabovelimits,df::diatelyrestorethe release rate to within the above limit (s).

b.7hc prevn;e n s ef Spd6cchs na d 3 C 4 rwe ref ^plin Uc.

3.c,3 SURVEILLANCE REQUIREMENTS 4.11.2.1.1 The dose rate due to noble gases in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM.

4.11.2.1.2 The dose rate due to Iodine-131 and 133, tritium, and all radio-nuclides in particulate form with half-lives greater than 8 days in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM by ootaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 4.11-2.

WOLF CREEK - UNIT 1 3/4 11-8 m

+

-m-

~-

~

.nm,-+an-wm-w-

c a

SPECIFICATION 3.11.2.1 JUSTlFICATION (1)

This specification implements 10CFR20 concentration limits st the unrestricted boundary. The MFC values specified in 10CFR20 were determined using ICRP 2 methodology and are therefore based on the inhalation pathway only. It is therefore only appropriate that doses ca',culated to verify compliance with this specifica-tion consider only the inhalation pathway.

The provision of Specifications 3.03 and 3,04 are not applicable (2) to Specification 3.11.2.1., therefore the proposed wording has been added.

O e

-=

-r---w...

,w

,-,7

--i,---

,.,,,-c

-y---yyy, v-

-y---y-

WOLF k

CREEK l

TABLE 4.I1-2 (NLy JUSTIFICATION This table was marked up to reflect site specific Wolf Creek plant desgin.

L3)

Footnote p for Containment Purge and the Unit Vent was repositioned from the " Sampling Frequency" column to

" Principle Gamma Emitters" to indicate that only a radio-isotopic analysis is required for a 15% power change.

Analyzing only for gn=mm emitters (fission products) following a power change is appropriate since it is unlikely that tritium levels would be greatly affected by changes in reactor power.

"or Carma" was deleted for the Noble Gas Monitor since the detectors for the gas monitors are beta sensitive, plastic scintillators (FSAR Section 11.5.2.3.1.3).

The Radwaste Building Ventillation is a potential release point for H-3 therefore we have included the H-3 analysis in the table for Radwaste Building Venti 11ation.

t l

l l

..___.,,.,-,_.m

TABLE 4.11-2 5

G RADI0 ACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM E

m E

MINIMUM LOWER LIMIT OF DETECTION (LLD)(I) i SAMPLING ANALYSIS TYPE OF g

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

P P

~4 PrincipaIGammaEmitters(2)

~

2x10 1.

Waste Gas Decay Each Tank Each Tank Tank Grab Sample N

EachPURGb PrinciphGammaEmitters

- N 2x10~4 2.

Containment purge Each PURGE 0- =nt Grab

-6 Sample M

H-3 1x10

~4 3.a. Unit Vent MN,I4I Princip$hGammaEmittersN G8N 1x10 Grab M

-6 Sample H-3 1x1'O R

b. Radwaste Building N

Trim.iphr Gamma Emii.i.er[

iniG i

Vent C+d S--!:

4-

-6 M

- ii-3 1x10

~4 Princip h Gamma Emitters (2) 1x10 M

i Grab Sample M

9

-12 N ")

ON I-131 1x10 W

4.

All Release Types Continuous

'1x10 10 as listed in )(2,and Charcoal Sample I-133

-l'1 N

Princip h Gamma Emitters (2) 1x10 Continuous W

)

Particulate Sample

~II Continuous N 3 M

Gross Alpha 1x10 Co:nposite Particulate Sample

-11 NN Q

Sr-89, Sr-90 1x10 Continuous Composite Particulate Sample e c.. h..t.c.., l'> ) peue 6ss N.ler p nt

(..so (.<>s o.is t x to ~'-

Table 4.11-2 JUSTIFICATION In Item 4 of Table 4.11-2, the Waste Gas Decay Tank and the Radwaste Building Vent have been deleted. The Waste Gas Decay Tanks have been deleted because they are monitored through the Radwaste Building Vent System. The Radwaste Building Vent has been deleted since the existing footnote should not apply. A change in the I-131 and I-133 concentrations due to 15% power changes will have been considerably diluted and/or decayed by the time they reach the Radwaste Building Vent.

e 1

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. ~.

i.

TABLE 4.11-2 (Continued)

TABLE NOTATIONS (1)The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

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

4*

'b LLD =

E V

2.22 x 10s y, exp (-AAt)

Where:

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

b = the standard deviation of the background counting rate or of s

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

E = the counting efficiency (counts per disintegration),

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

2.22 x 10s = the number of disintegrations per minute per microcurie, Y = the fractional radiochemical yield, when applicable, A = the radioactive decay constant for the particular radionuclide (s 1), and i

at for plant effluents is the elapsed time between the midpoint of sample collection and the time of counting (s).

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

It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and l

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

l WOLF CREEK - UNIT 1 3/4 11-10 l

t

TABLE 4.11-2 (Continued)

TABLE NOTATIONS (Continued)

G (2)TheprinciphgammaemittersforwhichtheLLDspecificationapplies include the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-136 in noble gas releases and Mn-54, Fe-59, Co-58. Co-60, 2*HHir, Mo-99, I-131, Cs-134, Cs-137, Ce-141, and Ce-144 in iodine and particulate releases. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the semiannual Radioactive Effluent Release Report pursuant to Specification 6.9.1.7.................. i n d in ":gul:t:ry Cui d 1.21, app;ndin B, "r.i;ien 1, June 1^74.

(3) Sampling and analysis shall also be performed following shutdown, STARTUP, or a THERMAL POWER change exceeding 15% of RATED THERMAL POWER within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

w.b n dh:<-

(4) Tritium grab samples shall be taken a4-4etc;t-enee pe - 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when thebr per 1 clap h eA o.a d a+

l'u+

c.u rMefelinkcanalisfloodedca.d.1 is 4tud*A.

ceh t,$

e, (5)Tritiun greb ;;..pl;; :h:11 b; tek:n et-k::t n:: p:r d:y: 'r= the

=ntil:ti n : h:c;t 'r;.T. th: :p:nt f;;' p 01 cr::, 2:n:=r : pent fuel is

-in th; : pent fu;l peel.

(80 Fr)The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation

.made in accordance with Specifications 3.11.2.1, 3.11.2.2, and 3.11.2.3.

(@ 47-} Samples shall be changed at least once per 7 days 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.

Sampling shall also be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for at least j

7 days following each shutdown, STARTUP or THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a 1-hour period, and analyses shall be condpleted within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are analyzed, the corresponding LLDs may be increased by a factor of 10.

This requirement does not apply if:

(1) analysis shows that the DOSE EQUIVALENT I-131 concentration in the reactor coolant has not increased more than a factor of 3, and (2) the noble gas monitor,shows that effluent activity has not increased more than a factor of 3.

l WOLF CREEK - UNIT 1 3/4 11-11

9e-3-

yp.--

-g.s 3,.

~w-,

_-e,

--.,._,-._y g

,gg w

--w,w

,e.m

,cy-.-w emeo ee---w-w

-s w w w-

---wwe-asNw-w-r

-w e+W-.---r-e-wm

W-s m

GEEK TABLE 4.11-1 TABLE NOTATION WLY I

JUSTIFICATION (1)

Footnote 1: Zn-65 was deleted since Zn-65 analyses are primarily applicable to BWR's with admiralty metal condenser tubes. Per FSAR 4.5.1.1 the

~

primary system does not contain any sinc based steel alloys; therefore there is no sinc to be activated to Zn-65.

The reference to specification 6.9.1.12 was changed to 6.9.1.7 to correspond to the equivalent section of the proposed section 6.0 of the Wolf Creek Tech Specs.

(2)

Footnote 4: The extended tritium sampling frequency is justified since airborne tritium levels are not subject to rapid variations or fluctuation because tritium levels are relatively stable after initidl flooding of the canal.

The proposed sampling requirements ensure

.. equate monitoring and surveillance of airborne tritium concentration.

(3)

Footnote 6'.:

It is proposed thaththe normal tritium sampling of the Unit Vent is sufficient to monitor the tritium concentration in the fuel pool area ventillation exhaust.

The Wolf Creek Plant is designed such that the Fuel Building ventillation exhaust is discharged through the Unit Vent. Therefore the routine tritium sampling of the Unit Vent also monitors the Fuel Pool area exhaust (FSAR Section 9.4.2.2.3).

~

The Spent Fuel Pool Cooling System (FPCS) (FSAR Section 9.1.3.2.3.1) provides constant removal of decay heat, maintaining the water temperature below 135 F.

The FPCS is a Seismic Category I It system with separate and redundancy loops.

therefore provides reasonable assurance of relatively constant Fuel Pool temperatures at.d thus relatively constant tritium levels from fuel pool water evaporation. It is therefore reasonable that the tritium sampling frequency be extended as proposed.

Protection of personnel who may bewworking in the vicinity of the spent fuel pool is partially provided by the Fuel Building HVAC, which takes a suction on the areas above the spent fuel pool (FSAR Section 9.4.2.2.3) and is ensured by they tritium sampling performed as part of the Radiation Work Permit Program.

. r----

-+r-m-----------,e-----------m-.--e-ww-w-v---e,--r-rer,--c.-

-*r---,--+e.

ww-r mv

=w w*-e,e-p sv+ e---*m,

--,,.,<,--y-v,

-e w--w.e,-.

RADI0 ACTIVE EFFLUENTS DOSE - NOBLE GASES LIMITING CONDITION FOR OPERATION 3.11.2.2 The air dose due to noble gases released in gaseous effluents, from each unit,- to areas at 2nd beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to the following:

a.

During any calendar quarter:

Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation, and 1

b.

During any calendar year:

Less than or equal to 10 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

APPLICABILITY: At all times.

l ACTION:

a.

With the calculated air dose 1 rom radioactive noble gases in gaseous i

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

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURV5ILLANCE REQUIREMENTS l

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

l l

1 i

l l

WOLF CREEK - UNIT 1 3/4 11-12 l

_-_m._ _. _,.. -

RADIOACTIVE EFFLUENTS DOSE - 10 DINE-131 AND 133, TRITIUM, AND RADI0 ACTIVE MATERIAL IN PARTICULATE FORM LIMITING CONDITION FOR OPERATION IndMchd 5

2n 3.11.2.3.The dose to : MEMOER OF THE PL'SLIC from Iodine-131 and 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to the following:

a.

During any calendar quarter:

Less than or equal to 7.5 mrems to any organ, and b.

During any calendar year:

Less than or equal to 15 mrems to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated dose from the release of Iodine-131 and 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance 4

with the above limits.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.3 Cumulative dose contributions.for the current calendar quarter and current calendar year for Iodine-131 and 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days shall be determined in accordance with the mythodology and parameters in the ODCM at least once per 31 days.

WOLF CREEK - UNIT 1 3/4 11-13

.. ~

~~ SPECIFICATION ~3.11.2.3 JUSTIFICATION (1) The term " MEMBER OF THE PUBLIC" has been replaced with the ters'

" Individual" in that:

(a) ' 10CFR20 and 10CFR50, Appendix I, require that Radioactive Effluent Concentrations, Doves and Dosa Rates be calculated for Individuals at or beyond the SITE BOUNDARY and/or in UNRESTRICTED AREAS. These regulations neither expressly or implicitly require that these calculations be performed for persons, real or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

(b) The use of the term " MEMBER OF THE PUBLIC" as defined in Specification 1.16, is inconsistent with the requirements of the Specification that doses be calculated at the SITE BOUNDARY. Therefore, its use would cause the Specification to be internally inconsistent.

(c) As stated in the bases, the purpose of this Specification is to provide for compliance with 10CFR20 and 10CFRSO, Appendix I, limits. The use of " MEMBER OF THE PUBLIC" is inconsistent with the stated purpose of this Specification.

Therefore, the use of the term "MEMIER OF THE PUBLIC" is inconsistent with the expressed purpose of the Specification and requires inconsistency on the part of the Licensee in complying with the Specification. Additionally, there are no legal requirements for its use in this specification.

Thus, the use of the term " MEMBER OF THE PUBLIC", while appropriate for specifications implementing 40CFR190 requirements, is inappropriate in this Specification, and should be deleted in favor of the term

" Individual".

f2)

.. :::ted in.^.CT:CN :., = LL:::::: E:::: E:p=:t i; : : : qui;;d,.

rther:f :c, Specific :i;= 6.9.1.11 1: ::: applicabic.

e

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

1 RADI0 ACTIVE EFFLUENTS GASEOUS RADWASTE TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION i

4.

l 3.11.2.4 TheVENTILATIONEXHAUSTTREATMENTjYSTEMandtheWASTEGASHOLDUP SYSTEM shall be OPERABLE and appropriate pomons of these systems shall be used to reduce releases of radioactivity when the projected doses in 31 d:y;in 97 day due to gaseous effluent releases, from each unit, to areas at and beyond the SITE BOUNDARY (see Figure 5.1-3) would exceed:

C. k a.

4}ME mrad to air from gamma radiation, or t. 2.

b.

4r4 mrad to Air from beta radiation, or c.9 c.

Gr3 mrem to any organ of a MEMBER OF THE PUBLIC.

APPLICABILITY: At all times.

ACTION:

a.

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

1.

Identification of any inoperable equipment or subsystems, and the reason for the inoperability, 2.

Actions (s) taken to restore the inoperable equipment to OPERABLE status, and 3.

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

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.4.1 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 wt:n Ce:::::

Redweste Treatmer.t Systems are not being fully utfif: d.

c-Asce as RAow Asm. rror.weer sqsnm 4.11.2.4.2 The installed NENTILATION EXNAUST TREATMENT SYSTEM and WASTE CAS MOLOUP SYSTEM shall be considered OPERABLE by meeting Specification 3.11.2.1 and 3.11.2.2 or 3.11.2.3.

WOLF CREEK - UNIT 1 3/4 11-14

SPECIFICATION 3.11.2.4 JUSTIFICATION (1)

The interval specified for dose projections is too short to accurately assess gaseous radwaste treatment systems operations.

Dose projections averaged over a 3 month period would be a more valid indication of the need to treat gaseous radwastes prior to discharge. A further restriction to monthly limits is not warranted or required by, regulation.

(2)

Ae etsted 1-ANIOP.

M eeseee Ezent Repert le net required, therefore._ Specification 6.9.141-is--not-applicable.

I i

l l

RADIOACTIVE EFFLUENTS EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION e

. 1.2.5 The coacentration of oxygen in the WASTE GAS HOLDUP SYSTEM shall be lim d to less than or equal to 2% by volume whenever the hydrogen concentrati exceed 4% by volume.

At all times.

APPLICABILI

$cc ACTION:

1C"' 4 a.

With the con tration of oxygen in the WASTE GA OLDUP SYSTEM

[C greater than volume but less than or eq to 4% by volume, reduce the oxygen ncentration to the abov limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

b.

With the concentration oxygen in WASTE GAS HOLDUP SYSTEM greater than 4% by volume d the drogen concentration greater than 4% by volume, immediate spend all additions of waste gases to the system and reduce the o entration of oxygen to less than or equal to 4% by volume, t take ION a. above.

c.

The provisions of S cifications 3.0.3 d 3.0.4 are not applicable.

SURVEILLANCE REQUIRE TS 4.11.2.5 he concentrations of hydrogen and oxygen in the WASTE GA OLDUP SYSTE shall be determined to be within the above limits by c'ot'nuous mo ~ oring the waste cases in the WASTE GAS HOLDUP SYSTEM wit.- the hydrog d oxygen monitors required OPERABLE by Table 3.3-13 of Specific; tion 3.3.

1.

WOLF CREEK - UNIT 1 3/4 11-15

-e-w n

,y

INSERT 10 3.11.2.5 The concentration of oxygen in any Waste Gas Decay Tank.

shall be limited to less than or equal to 2% by volume whenever.th'e concentration of hydrogen in that Waste Gas Decay Tank exceeds 4%

by volume.

APPLICABILITY: At all times.

ACTION:

Whenever the concentration of hydrogen in any Waste Gas Decay Tank is greater than or equal to 4% by volume, and:

a.

The concentration of oxygen in that Waste Gas Decay Tank is greater than 2% by volume, but less than or equal to 4% by volume, without delay begin to reduce the oxygen and/or hydrogen concentration to within its limit.

b.

With the concentration of oxygen in that Waste Gas Decay Tank greater than 4% by volume and the hydrogen concentration greater than 4% by volume, immediately suspend additions of waste gas to that Waste Gas Decay Tank and without delay begin to raduce the oxygen and/or hydrogen concentration to within its s

limit.

~

t The provisions of Specifications 3.0.3 and 3.0.4 are l

c.

not applicable.

l SURVEILLANCE REOUIREMENTS 4.11.2.5 The concentrations of hydrogen and oxygen in the inservice Waste Gas Decay Tank shall be monitored with the hydrogen and oxygen l

l monitors required OPERABLE by Specification 3.3.3.10 or by I

sampling in accordance with Specification 3.3.3.10 if the hydrogen and/or oxygen monitors are inoperable.

l 1

1 1

SPECIFICATION 3.11.2.5 JUSTIFICATION:

The proposed substitution is designed to reflect the site spe;cific design of the SNUPPS Plant in that:

(a)

The hydrogen and oxygen monitoring instrumentation monitor the the inletH2/02 and outlet H2/02 of the recombiner, therefore only the in service Waste Gas Decay Tank is monitored with installed instru:sentation.

(b)

The SNUPPS Plant WASTE GAS HOLDUP SYSTEM is designed with a total of eight Waste Gas Decay Tanks, only one of which can be in service at any one time. Theproposed substitution allows the operation of the system using one of the other tanks, while necessary actions are being taken to reduce the oxygen level in the affected tank.

(c)

As described in FSAR Section 11.3.6, a minimum of 5 volume percent oxygen is required to support combustion of 4 volume percent hydrogen. The SNUPPS Plant System is designed for alarm at 3 volume percent oxygen and alarm and isolation of oxygen feedgas at 3 volume percent oxygen. These values are well below the necessary 5 volume percent oxygen and the Specification 3.11.2.5 limit of 4 volume percent oxvsen.

(d)

The requirement to be within limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months la ACTION a is inconsistent with the requirements of ACTION b.

Additionally, in the event of recombiner failure, it would become necessary to vent the affected tank to the atmosphere in order to be in compliance with the Specification. Such an action could possibly result in a violation of Specification 3.11.2.2, 3.11.2.3, and 3.11.2.4.

The propc, sed wording however, would afford the operational lattitude to vent the tank slowly over a longer period and perhaps allow the utilization of more favorable meterology to reduce doses and dose rates.

RADI0 ACTIVE EFFLUENTS GAS STORAGE TANKS LIMITING CONDITION FOR OPERATION

-t 3'11.2.6 'The quantity of radioactivity contained in each gas storage tank shall be limited to less than or equal to 4-x-105 Curies of noble gases (con-sidered as Xe-133 e;ri;:1:nt).

2.5 APPLICABILITY

At all times.

ACTION:

a.

With the quantity of radioactive material in any gas storage tank. m.;ilic t dd exceeding the above limit, immediately suspend all additions of,

'bep n 4e radioactive material to the tank and, withia ^9 heerst-Teouce the tank contents to within the limit. end describe the e'fente leadiag t thi; condition in the next : ri:nnu:1 Radi ::tive Effluent

-Rele::: Rep rt, pur:::nt t: S;:cificati:n S.9.1.7, b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.6 The quantity of radioactive material contained in each gas storage tank shall be determined to be within the above limit at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when radioactive materials are being added to the tank and have.

3 renter fa. led

-lu.l.

i%

or i

e l

WOLF CREEK - UNIT 1 3/4 11-16

.. ~.

,.n---

i SPECIFICATION 3.11.2.6 JUSTIFICATION:

NUREG 0133 (October 1978) Section 5.6.1 provides Tank Centent:

(1) the following equation for determining the maximum curie limit in each gas storage tank:

- 1. Y#

I Q e

g (X/Q)DBA (**** **"!"

I'}

8

~

10 pCi/Ci IK i

3 2.0 E-04 sec/ meter (Callaway) FSAR Table 15 A-2

'(X/Q)pgg

=

1.5 E-04 Nolf Creek)

FSAR Table 15.7-3 identifies Xe-133 (59%) and Kr-85 (36%)

=

as the principal activities assumed to be released in the event of a vaste gas decay tank rupture.

From Reg. Guide 1.109. Table B-1:

2.94 E +02 (arem/yr) per (vCi/m')

Kg (Xe-133)

=

g (Kr-85) = 1.61 E + 01 K

IQ 2.5 E+05 Curies per tank (Callaway) 3.3 E+05 Curies per tank (Wolf Creek) iT FSAR_Section 11.3.2.1 states. " Operation of the system is such that fission gases are distributed throughout the six Seperation of the Gaseous normal operation gas decay tanks.

Radwaste System gaseous inventory in several tanks assures that the allowable site boundry dose will not be exceeded in the event of a gas decay tank rupture."

--m

--w, p-

SPECIFICATION 3.11.2.6 JUSTIFICATION (Continued) 3 (2) Depending on operating conditions at the ~ time, it may prov.e -

inadviseable to place restrictions on the length of time given to accomplish the activity reduction.

The proposed wording allows the operator to assess the various parameters and to make a reasonable decision, balancing the risks involved (e.g.. excessive dose vs.

possibility of tank rupture).

The restriction to a finite time limitation could result in circunstances whereby the Specification is in direct oposition to the satisfaction of other Specification (s).

The proposed wording is also consistent with the proposed modification to Specification 3.11.2.5.

e U

I i

I

_..,m

.__m-.,..,,- _.. -,

e SPECIFICATION 4.11.2.6 JUSTIFICATION:

FSAR Section 15.7.1 describes the analysis of a postulated I.

Waste Gas Decay Tank failure and its projected radiological This evaluation utilized the fission product.

consequences.

accumulation and release assumptions identified in Regulatory Guide 1.24.

Some of these assumptions are:

(a) The maximum amount of waste gases stored in any one tank occurs after a refueling shutdown, at which time the Waste Gas Decay Tanks store the radioactive gases stripped from the reactor collant.

(b) The accumlated activity in the gaseous vaste processing system after 40 years' operation and immediately following plant shutdown (with zero decay) assumed to be in the Waste Gas Decay Tank, is based on 1% failed fuel, which is 8 times -

greater than that assumed under normal operating conditions.

All noble gas activity has been removed from the reactor coolant system and transferred to the Waste Gas Decay Tank that is postulated to fail.

The calculated maximum activity in the Waste Gas Decay Tank under these conditions is presented in Table 15.7-3, and is approximately 2.1 E04 Curies.

The caluclated whole body dose to an individual at the Exclusion.A_aa Boundary (EAR) is presented in Table 15.7-4, and is 33 mrem (Callaway) and l

25 mrem (volf Creek).

From the aforementioned analysis, we can conservatively establish the following conclusions:

1.

The maximum amount of activity in a Waste Gas Decay Tank during normal operations is the result of primary system degassing operations.

2.

The maximum amount of activity in the primary collant system, and thus the Waste Gas Decay Tank, occurs during periods of i

1% or greater feiled fuel, i

3.

The maximum Waste Gas Decay Tank activity, af t.er 40 years of operation with 1% failed fuel and immediately following total primary coolant system degassing, is conservatively estimated as approximately 6% of the limit calculated using NUREG 0133 methodology.

4.

The projected whole body dose to an individual at the EAB, using the limiting short-term X/Q, is conservately estimated as approximately 7% of the 500 mrem NUREG 0133 objective and approximately 1% of the 10 CFR 100.11 limit.

5.

Due to the relatively low amount of activity available to be added to the Waste Gas Decay Tank under normal operations, sampling is unwarranted until such time as the conditioa of 1% failed fuel is, encountered.

II. It is the expressed purpose of 10CFR20 (10CFR20.l(c)) that radiation exposures and releases of radioactive materials in effluents to un-

~

restricted areas be maintained ALARA. It is not in keeping with the concept of ALARA to require sampling and analysis activities which result in unnecessary occupational radiation exposure and releases of radioactive materials to the environment.

The proposed sampling and analysis requirements serve to implement good ALARA principles and thus reduce the expended man-rem, both occupationally and to the public.

III. The intent of Specification 3.11.2.6 as stated in the Bases, is to provide assurance that in the event of an uncontrolled release of the Waste Gas Decay Tank's contents, the resulting whole body dose to an individual at the nearest EAB will not exceed 500 mrem, which is substantially belcw the dose limits of 10CFR 100 for a postulated event.

The analysis of a postulated Waste Gas Decay Tank repture, conducted in accordance with Nuclear Regulatory Commission Guidelines and recommendations, using greatly conservative assumptions, conclusively demonstrates that the proposed surveillance requirements maintain a significant margin of safety with respect to the expressed objective of Specification 3.11.2.6 thus assuring that the limits of 10CFR 100 are not approached.

1 w

w.

_..-.%..c,.,

m.

.-,,.,m

,_w

,,geg-c.--

..--y.

RADI0 ACTIVE EFFLUENTS SOLID ? ? f W into.WW 3/4.11.3 inmn

,,,,m, LIMITING CONDITION FOR OPERATION 3.11.3 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.

ACTION:

With SOLICIFICATION or dewatering not meeting disposal site and a.

shipping aad transportation requirements, suspend shipment of the inadequately 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 perforaed 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, The provisions of Specifications 3.0.3 and 3.0.4 are not appl.icable.

c.

SURVEILLANCE REQUIREMENTS 4.11.3 SOLIDIFICATION of at least one representative test specimen from at least every tenth batch of each type of wet radioactive wastes (e.g., filter sludges, spent resins, evaporator bottoms, boric acid solutions and sodium sulfate solutions) shall be verified in accordance with the PROCESS CONTROL PROGRAM:

If any test specimen fails to verify SOLIDIFICATION, the SOLIDIFICATION a.

of the batch under test shall be suspended until such time as additional test specimans can be obtained, alternative SOLIDIFICATION parameters can be determined in accordance with the PROCESS CONTROL PROGRAM, and a subsequent test verifies SOLIDIFICATION. SOLIDIFICATION of the batch may then be resumed using the alternative SOLIDIFICATION parameters determined by the PROCESS CONTROL PROGRAM; b.

If the initial test specimen from a batch of waste fails to verify SOLIDIFICATION, the PROCESS CONTROL PROGRAM shall provide for the collection and ttsting of representative test specimens from each consecutive batch of the same type of wet waste until at least three consecutive initial test specimens demonstrate SOLIDIFICATION. The PROCESS CONTROL PROGRAM shall be modified as required, as provided in Specification 6.13, to assure SOLIDIFICATION of subsequent batches of waste; and With the installed equipment incapable of meeting Specification c.

3.11.3 or declared out cf-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.

WOLF CREEK - UNIT 1 3/4 11-17 ummum

%w,-

,,,.-,.,7,-

+-_wg-

---.e,--,

,-s--=p v-

,e-

RADI0 ACTIVE EFFLUENTS 3/4.11.4 TOTAL DOSE LIMITING CONDITION FOR OPERATION 3.11.4 The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mreas to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 areas.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specification 3.11.1.2a., 3.11.1.2b., 3.11.2.2a., 3.11.2.2b.,

3.11.2.3a., or 3.11.2.3b., calculations should be made including direct radiation contributions from the units and from outside storage tanks to determine whether the above limits of Specification 3.11.4 have been exceeded.

If such is the case, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, 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 20.405c, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and

(

direct radiation, for the calendar year that includes the release (s) covered by this report.

It shall also describe levels of radiation l

and concentrations of radioactive material involved, and the cause of the exposure levels or concentrations.

If the estimated dose (s) exceeds the above limits, and if the release condition resulting in t

violation of 40 CFR Part 190 has not aiready been corrected, the f

SpecialReportshallincludearegg,estforavarianceinaccordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS l

l 4.11.4.1 Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with Specifications 4.11.1.2, 4.11.2.2, and l

4.11.2.3, and in accordance with the methodology and parameters in the 00CM.

4.11.4.2 Cumulative dose contributions from direct radiation from the units and from radwaste storage tanks shall be determined in accordance with the methodology and parameters in the ODCM. This requirement is applicable only under conditions set forth in ACTION a. of Specification 3.11.4.

WOLF CREEK - UNIT 1 3/4 11-18

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

-w.-,_,m-_,..._

,,y_

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,n,m-m_

_,,__,--,-yw-o-.,,

3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM LIMITING CONDITION FOR OPERATION 3.12.1 The Radiological Environmental Monitoring Program shall be conducted as specified in Table 3.12-1.

APPLICABILITY: At all times.

ACTION:

With the Radiological Environmental Monitoring Program not being a.

conducted as specified in Table 3.12-1, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Specification 6.9.1.6, a description of the reasons for not conducting the program as required and the plans for preventing a.

recurrence.

b.

With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified locttion exceeding the reporting levels of Table 3.12-2 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and 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 Specifications 3.11.1.2, 3.11.2.2, or 3.11.2.3.

When more than one of the radionuclides in Table 3.12-2 are detected in the sampling i

medium, this report shall be submitted if:

concentration (1) concentration (2)

+ * * * > 1. 0 -

reporting level (1) reporting level (2) l When radionuclides other than those in Table 3.12-2 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose

to A MEMBER OF THE PUBLIC from all radio-nuclides is equal to or greater than the calendar year limits of Specifications 3.11.1.2, 3.11.2.2 or 3.11.2.3.

This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Specification 6.9.1.6.

c.

Wih-milk._gr fresh leafy vegetable samples unavailable fr

, dentify spe-

$$ce.

more of the sampie iuu&tfere reouired b T

gg,,t.

cific locations for obtain meni 5;:?'ac and add them within 30 days to ogical Environmental Monitoring Program given_.in__.

p "The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report.

I WOLF CREEK - UNIT 1 3/4 12-1 I

6

,,,,,p__

RADIOLOGICAL ENVIRONMENTAL MONITORING

~

LIMITING CONDITION FOR OPERATION ACTION (Continued) ecific locations from which samples were unavailable may th

. delete monitoring program.

Pursuant to Specif n 6.14, submit in the next ual Radioactive Effl ease Report 51,*

documentation for a change n ng a revised figure (s) 33"##g and table for the ODCM refle e ne ion (s) with supporting A4 information identif e cause of the unavailao samples and justi e selection of the new location (s) for obtal '

s.

d.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.1 The radiological environmental monitoring samples shall be collected pursuant to Table 3.12-1 from the specific locations given in the table and figure (s) in the ODCM, and shall be analyzed pursuant to the requirements of Table 3.12-1 and the detection capabilities required by Table 4.12-1.

4 WOLF CREEK - UNIT 1 3/4 12-2

--r y

x.t WOLF CREEK l

S Insert AA With milk or fresh leafy vegetable samples temporarily unavail-able from a routine sampling location, a sample from an alter-native location (identified in the ODCM) will be substituted, noting the reason for the unavailability in the Annual Radio-When changes in aa'm logical Enviroirnental Operating Report.the sampling schedule in the ODCM will

~

locations are permanent, be updated to reflect the new routine and alternative sampling locations', and this revision will be described in the Annual Radiological Environmental Operating Report.

e w,.. -_._, __

'~*'

-m,

K-wcx.r Specification 3.12.1.c Cm2X Justification -

Preoperational monitoring experience shows that,' because samples are marginally available at some milk or leafy vegetable loca-tions, it is a frequent occurrence for samples to be unavailable for a month or two, but not on a permanent basis.

Reporting "new" locations within 30 days when samples are unavailable (only to have to change locations back again when samples are once more available at the old locations) is an unnecessary waste of effort, since this could occur many times in a year.

The licensee will instead identify an additional " alternate" sampling location in the ODCM for milk and leafy vegetable path-ways; if a sample is temporarily unavailable at one of the re-quired locations, the substitute sample will be used fe r that sampling period, noting the reason for the substitution in the Annual Radiological Environmental Operating Report.

When changes in sampling locations are known to be permanent, the ODCM will be updated to reflect the new routine and alternative sampling locations, and this revision will be described in the Annual Radiological Environmental Operating Report.

Finally, any r'eporting concerning the Radiological Environmental Monitoring Pr6 gram will appear in the Annual Radiological Envi-ronmental Operating Report, not in the Semiannual Radioactive Effluent Release Report.

t i

i i

,m.,,.

TABLE 3.12-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM q;

n R

NUMBER OF 52 REPRESENTATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY Iy)

COLLECTION FREQUENCY OF ANALYSIS AND/0R SAMPLE SAMPLE LOCATIONS c:

1. Direct Radiation (2)40 routine monitoring stations Quarterly.

Gamma dose quarterly.

-4 E'

citt.er with two or more dost-meters er r!th ne instru::nt ad enth loca+4ea5 fer ::::ur'r.; crd -ecording dere r t centint:::1y, placed as follows:

k agon.v.aW1 An inner ring of stations, one in each meteorological sector in the general area of the SITE BOUNDARY M

An outer ring of stations, one in R'

each meteorological sector in J,

the " ' ^ ' y[\\ge from the an site 3 4= 5 mile.

The balance of the stations to be placed in special interest areas such as population canters, nearby residences, schools, and in one or two areas to serve as control stations.

2 e

9 4

w

1 TABLE 3.12-1 (Continued)

I 6

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM r-NUMBER OF i

Q REPRESENTATIVE N

EXPOSURE PATHWA(

SAMPLES AND SAMPLING ANO

. TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS (1)

COLLECTION FREQUENCY OF ANALYSIS e

e

2. Airborne i

2 j

Q Radiolodine and Samples from five locations Continuous sampler Radioiodine Cannister:

Particulates operation with sample I-131 analysis weekly.

p

]

samples from close collection weekly, or see the three 80 locations, more frequently if A

-f#

in differen f the required by dust-Particulate Sampler:

66 highes a culated annua e

loading.

Gross beta radioactivity l

-gr61ind level D/Q.

analysis following filter change; Wand g) 1 One sample from the vicinity gamma isotopic analysis i

of a community having the highest of composite (by t'

calculated annual average ground-location) quarterly.

1evel D/Q.

w l

'?

One sample from a control loca-tion, as for example 15 t: 30 h m 4, 2n en distant and in the t preva-J 1ent wind direction l

3. Waterborne N

gt

e. Surf;ce Or.e ;

1; up;tre:.

site s

.4*

Gamma isotopic analysis l

c c.

ed 52 ;?: d:=;tre =.-

monthly. Composite for tritium analys quarterly.

i

b. Ground Samples from one or two source Quarterly.

Gamma isotopic and tritium only if likely to be affected.

analysis quarterly.

.er--Drinking 1n sample of each of one osite sample b 431 analysis on each g

t-th the nearest r

over eek pe compoQtewhenthedo po i

Dp supplies hat co Jd e when I-13 alysis calcula~ d for the onsump-is affected by ischarge.

I arformed,montlQy tion of th wat year.gater Com-c mposite otherwise.

tt'an 1 mres j

On ample from a contro posite f gross etaag

ocation, gamma otopic anal s

~

mo ly.

Composite fo itium analysis quarterl.

1 I

4

.i

A-g WOLF CREEK CNLY l

Insert BB Three samples near the site Boundary in the three sectors having the highest calculated annual average D/Q.

Insert CC norehly grab sanple a.

91rface one aanple upstrean (g) one sample ownstream Insert ED cme sanple fran the mnthly ocmtosite ID m nthly gross beta N

c.

Drinking nearest drinkirg and ganna isotopic water supply that analyses of camposite could be affected sample; quarterly tritium analysis by eff1 cent discharge of 3-enonth ccrnposite one sar.,le fran a control location s

l l

(

TABLE 3.12-1 (Continued) 6 q;

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM g

NUMBER OF g

REPRESEN1ATIVE EXPOSURE PATHWAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY III AN0/0R SAMPLE SAMPLE LOCATIONS COLLECTION FREQUENCY OF ANALYSIS Eq

3. Waterborne (Continued) g

d. Sediment One sample from downstream area Semiannually.

Gamma isotopic analysis k from with existing or potential semiannually.

]

shoreline recreational value.

4. Ingestion

a. Milk les from milking animal Semimonthly when Gamma isotopic and I-131 in ee locations within animals are on analysis semimonthly when h distanc aving the hi st pasture, monthly at animals are on pasture; w

I"5* l dose potent If ere are other times.

monthly at other times.

)

EE none, then, one sple from h

milking anim in ch of u'

three are between 5 8 km dista where doses are ca u-la g)hegreaterthan1mr One ::--!: 'r:; milkh; ;..:_L sc.np c Oem l

e a control location 1; L 20 L; p.e(e.cMy to 1 20 mlc5 distant and in the least prev-alent wind direction;,,. g one sa,,, it ef reu)h kh g(,

O

)

b. Fish end One sample of d h cc- :.c.i$11y S: p?: '

_., w, v Gamma isotopic ar.alysis I.-..c h M recre:th.elly important Semiannually if-they on edible portions.

4 beates spee4es in vicinity of plant are net-:::cen:1.

discharge. area.

One62mTUeY':

cpe !:s in j

areas not influenced by plant discharge.

~

K-I wcgy CREK CNLY Insert EE Three milk samples as available from locations within 5 miles of the site representing the highest annual avera'ge D/Q.

e 9

e 0

e P

l

,y,en

y

,m,,-

.,,.,,mg,--

- -r

-m,

,- - 4

,c---w.,

,o,,

e-

-,-----.,----.w,--

TABLE 3.12-1 (Continued)

G RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM E

NUMBER OF lU REPRESENTATIVE EXPOSURE PATHWAY SAMPLES ANO SAMPLING AND TYPE AND FREQUENCY II)

AND/OR SAMPLE SAMPLE LOCATIONS COLLECTION FREQUENCY OF ANALYSIS E

Z 4.

Ingestion w

(Continued)

c. Food ample of each princ "t ti;;;; cf harvest.(10) i =vi.vv i u analyses (5)

^

Products class o rod from any

.ona dible p rtfee.

area that is by water in wh iquid plant wa been discharged.

Gammaisotopic&~O Samples Of ih n: differ;at kird; Monthly when and I-131 of broad leaf vegetation grown available.

analysis.

w1 c,1 -Ike s, t n-er-'t :;;.'.-.T-i. d iffeceet

-ff:!te ?er:tisn: Ofahighest A.,a..) ;. is t.

s7 0* de.-

eth -hc predicted annual average ground-1evel D/Q if milk sampling is not i

performed.

Cc 3rel one sample of similar Monthly when Gamma isotopic nd I-131 broad leaf vegetationJurown available.

analysis.

go 1. ze ;tes 15 t; 3^ S;; distant in the least prevalent wind direction if milk f" g#"'

'/

sampling is not performed.

i V

0 e

A cube f

CREEK K-2, CNLY Table 3.12-1 Justification -

1.

Direct Radiation:

The changes from the NRC version are mainly for clarification (specific location identifier numbers will be in the ODCM and distances are measured,in miles); also, the reference to a continuous dose rate measuring instrument has been dropped since KG&E has decided to use TLDs for this pathway.

2.

Airborne:

Rewritten for clarity.

3 Waterborne:

Surface water - Due to large dilution volume of the a.

cooling lake, monthly grab samples will provide adequate represet.tation of average liquid concentrations of radionuclides for this pathway.

Drinking water - Table 5.2-5 of the Wolf Creek Environ'-

c.

mental Report (Operating License Stage) shows that the maximum expected exposure to an individual from the drinking water pathway would be 0.08 mrem /yr to the liver of a child (not including radioactive decay, which would substantially reduce this valhe).

Since this is much lower than the 1 mrem /yr described in NUREG-0472, I-131 analysis of 2-week composites has been deleted from the Wolf Creek Technical Specifications.

4.

Ingestion:

Milk - Rewritten to remove ambiguities from the method a.

of determining milk sampling locations.

b.

Fish - Invertebrate sampling is not necessary since this is not a major ingestion pathway at freshwater locations.

Due to the impracticality of obtaining samples of non-abundant species, fish sampling will be limited to abundant species of game snd rough fish, which will be the most significant contributors to the ingestion pathway.

Food Products - It cannot be specified in advance how c.

many types of broadlear vegetation will be available from a garden; different types of broadleaf vegetation will be sampled on a rotating basis as they are available.

Water will not be taken from the Wolf Creek cooling lake for irrigation, therefore, this sample has been deleted.

9 n-

TABLE 3.12-1 (Continued)

TABLE NOTATIONS (1) Specific parameters of distance and direction sector from the centerline of one unit, and additional description where pertinent, shall be provided for

, each and every sample location in Table 3.12-1 in a table and figure (s) in the ODCM.

"efer t; N"aiC-0133, "Pr:p;r;tien Of hdi:1:gi::1 Ef'luent T & ft:1 Sp::ific ti:n: f r Mu;ie:r P u:r P1:nt:,"

t:b r 1978, and t: hdielegical s,it Asses;; nt ",r:n:h T; d nic:1 P::ition, h vi:fon 1, McVed er 19 ". Deviations e

s 'I

r p: --itted from the required sampling schedule 44jstec1 mens are unoDt31nable due to hazardous conditions, seasonal unavailability, malfunction of aut matic sampling equipment, and other legitimate reasons.

If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operation Report pursuant to Specification 6.9.1.6.

It is' recognized that, at times, it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location or time.

In these instances suitable specific. alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions 4

made within 30 days in the Radiological Environmental Monitoring Program 9 *on i

- th: ^^CM.

-Purce:nt te Spe:f'f : tion 0.11, :ub-it '- the next centannual.

Radie::tive, Effluent "eicese "ep;rt de:uneatetien fen e chenge in the 00CM Se c.

including revised figure (s) and teble for the 00CM ieflecting the new p.t le tien(s) with cupporting '-fe- :ti% !dentifying the : ese of the g

.un v flabi'ity of :: ple: fer that FA w;;y :nd j;;tifying th: : le -t4en-of 1

-th: n:w 1:0:ti:n(:) for Obt:fr'ng ' 7 0:.

(2)h: Or ;;r: in:trum:nt;, :uch :: ; prc::;ri::d i:n ch::b:r, f r ::::uring and M Ording d::: r:t: ::ntinu:::1y ::y bc ::d ' p!::: ef, er '- additica to, int gr ting d::iteter.

For the purposes of this table, a thermoluminescent dosimeter (TLD) is considered to be one phosphor; two or more phosphors in a packet are considered as two or more dosimeters.

S*'- b:d; : :h:1' n t be m::d :: d::ie:t:r: f r ::::ur'n; direct r:diation The 40 stations is not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations; e.g., et :n ::::r :fte.,

t scme sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the cnaracteristics of the specific system used and rAeeM wil\\

be selected to obtain optimum dose information with minimal fading.

(3)Th; purp;s: of thi; semple is to obtain ba dgr;und informati:n If it i act pre:tical to establish centrol le:etiens in a;;;rd:n : with the di;tance

nd wind dirc ti:n crit:ri, Other :ite; th:t pr vide V: lid bi:kground det

.may be substituted-l (3) (4) Airborne particulate sample filters shall be analyzed for gross beta radio-activity 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 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples.

WOLF CREEK - UNIT 1 3/4 12-7

...e- -.

-...... - - = = - = = -.....

e-

= = = = - -

~

pg,,--,

,----,n

-,,,,--,-,-e,-

r-----,--,,-,-,--s.

-~---,-eese--

---o

-m--

Znsert - ll of fursuant le Spec lNe<%

g g.g.b 1he cause unavails.bihG of sarnples b

$ha+ pathway an d locAfien (s fr ob+aininy replacemen t samples idenWhed )in %s ut A,,nud Radioloju*c< l heironnenla 1ht new still k,s Ofc<alin fafcrt.A revised fjur4) anc{

-in %

A u- %

nea locaWon(s) u;ll

&No b e y re e d le d 0De M ce[ht}ing 4e.

in b reprt.

l l

l

.m-

.w,

TABLE 3.12-1 (Continued)

~

TABLE NOTATIONS (Continued)

(4)(4) Gamma isotopic analysis means the identification and quantification of gamma-

. emitting radionuclides that may be attributable to the effluents from the facility.

@(+)The"upstreamsample"shallbetakenatadistancebeyondsignificantinfluence of the discharge. The " downstream" sample shall be taken in an area beyond but near the mixing zone.

'!Upstree;" ::=pic; in n ::tuary :::t b: t:ker far l

enough upstream te be beyend the~pient influence.

Seit water shall be sampled j

enly wh:n th 7:::ising unter i: utt'ized for recreation 1 :thf ties.

eendant wer % 54.* ping F c i

i) (-7-)A composite sample is one in which the quantity (a t) of liquid sampled is propertional to the q ntity Of 'le9ng 'f quid %nd in which the method of sampling employed results in a specimen that is representative of the liquid censhd f4w.

In this program compsite sample aliquots shall be collected at time intervals that are very short (e.g., hourly) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sample.

(6) (4.) Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas wherf the hydraulic gradient or recharge properties are suitable for contamination.

(0)The de:2 thall be calculated f;r the : xf=um crgan and :g group, using the

~

LethGdGlGgi Gnd par;Geter in th; 00CM.

(10)If hersest eccurs scre than ence a y;;r, :: pling ch:!' be performed during

ch di:cretc harvc:t.

If harvest occur; continuously, ::=pling-shall bc

,GOnthly. AttentiGn 5 hell bs paid 10 $uulud$ng sampica vi iu'ciuum and suut u

TGGd products.

L WOLF CREEK - UNIT 1 3/4 12-8

K-2

[

WOLF CNIX

)

Table 3.12-1, Table Notation k _,

Justifications -

(last sentence):

To be consistent and to use time and effort (a) more ef fectively, all information about the Radiologic'al Environmental Monitoring Program will be put in a sing'le document (the Annual Radiological Environmental Operating Report).

CL)

There are presently no plans for using pressurized ion chambers or film badges, so references to these have been l

removed.

Rewritten to reflect Wolf Creek site characteristics.

(5)

This note was modified due to the impracticality of obtaining (7) samples proportional to the flow of the Neosho River, which may be highly viable, and because samples which are propor-tional to average liquid concentrations during the sampling period will more accurately reflect quantities of ingested radionuclides.

Previous note Ig" - Milk sampling is performed continuously, therefore, this note is not applicable.

I Previous note 'ho)" - This note is deleted because the sample it refers to is deleted from the table.

es e me e

e

. ~ -,

y--

-7,

-..n

TABLE 3.12-2 4;

REPORTING LEVELS FOR RADI0 ACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES k

REPORTING LEVELS E

WATER AIRBORNE PARTICULATE FISH MILK F000 PRODUCTS E

ANALYSIS (pCi/1)

OR GASES (pCi/m )

(pCi/kg, wet)

(pCi/f)

(pC1/kg, wet) 3 H-3 20,000*

Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 s

me.

v.

<vo cv,vvv Ua Zr-Nh-95 400 1-131 2

0.9 3

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

For drinking watei..mples.

This is 40 CFR Part 141 value.

If no drinking water pathway exists, a value of 30,000 pCI/E may be used.

e i

I

(

i TABLE 4.12-1 h

)

G DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS LOWER LIMIT OF DECTECTION (LLD) M U) '

WATER AIRBORNE PARTICULATE FISH MILK F000 PRODUCTS SEDIMENT 8

ANALYSIS (pC1/2)

OR GAS (pCi/m )

(pCi/kg, wet) (pCi/1)

(pCi/kg, wet)

(pCi/kg, dry)

Gross Beta 4

0.01 2

H-3 2000*

Mn-54 15 130 i

l Fe-59 30 260 Co-58,60 15 130 Zi, 05 3G 26G my Zr-Nb-95 15 I4)

I-131 I

0.07 1

60 i

Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 l

A Ba-La-140 15 15

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

l

+a

K-t WOLF Table 3.12-2 CREEK

[

Table 4.12-1 st,y V

Justification -

G.

Deletion of Zn-65:

Wolf Creek's primary system does not co$ntain zinc-based steel alloys (see SNUPPS FSAR, Section 4.5.1.1-); there-fore, there is no zine available for activation to En-65.

O e

e i

e

e

--y_-

7-..-,

.,y--_,,.,-_

,..,y.r.._y, m

,r

,,e-_

,.,,w g -.-,-,,,,, _,,- _.,-

4:--

TABLE 4.12-1 (Continued)

TABLE NOTATIONS (1)This list does not mean that only these nuclides are to be considered.

.e Other peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological

Environmental Operating Report pursuant to Specification 6.9.1.6.

k n...~ J d (2)Rege4+ed detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

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

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

D LLD =

E V

2.22 Y

exp (-Aat)

Where:

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

b = the standard deviation of the background counting rate or of s

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

E = the counting efficiency (counts per disintegration),

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

l 2.22 = the number of disintegrations per minute per picocurie, l

l Y = the fractional radiochemical yield, when applicable, l

A = the radioactive decay constant for the particular radionuclide (s 1), and at = the elapsed time between sample collection, or end of the sample collection period, and time of counting (s).

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

WOLF CREEK - UNIT 1 3/4 12-11 e

y m eme

.m-,,

-.,. ~,.

TABLE 4.12-1 (Continued)

TABLE NOTATIONS (Continued)

It should be recognized that the LLD is defined as an a priori (before

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

Analyses shall be performed in such a manner that the stated LLDs will be

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

In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report pursuant to Specification 6.9.1.6.

(4)LLD for drinking water samples.

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

WOLF CREEK - UNIT 1 3/4 12-12 6

9

.--yr

,e r

-- - - - - - - - -1 r

-- -.- - -- s

K WCLF CREEK Table 4.12-1, Table Notation

( On.Y Justification -

(2) Modified to reflect the fact that Regulatory Guides are not requirements but guidelines.

I e

9 6

l t

I l

V v'--'-

rw

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.2 LAND USE CENSUS LIMITING CONDITION FOR OPERATION 3.12.2 A Land Use Census shall be conducted and shall identify within a distance of S-Am-(5 miles)-the locagion in each of the 16 meteorological sectors of the nearest milk animal % the nearest residence.:nd th: n::re:t

rd

n* Of gr;;ter then 50 m' (500 ft') preducing breed leaf vegetatica.

APPLICABILITY: At all times.

ACTION:

a.

With a Land Use Census identifying a 'ocation(s) that yields a calculated dose or dose commitment greater than the values currently i

being calculated in Specification 4.11.2.3, identify the new location (s) in the next semiannual Radioactive Effluent Release Report, pursuant to Specification 6.9.1.7.

b.

With a Land Use Census identifying a location (s) that yields a calcu-lated dose or oose commitment (via the same exposure pathway) 2D% greater than at a 1ccation from which samples are currently being obtained in accordance with Specification 3.12.1, add the new location (s) within 30 days to the Radiological Environmental Monitoring Program given in the ODCM. The sampling location (s), excluding the control station location, having the lowest calculated dose or dose commitment (s), via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this Land Use Census was con-ducted. -Pursuant to Specification S.14, :ubmit in the next ::=fannual Radies;tive Cffluent Relee;e Repert de:seentetien fer & henge in the ODCM including : revi::d 'igure(:) :nd table (c) fer th: 00CF reflecting d60djg the ner lec:ti n( ) with 'nfers tien : ppert.ing th ch:nge in :: pling

=

i 2-43;;;;;a3, I

c.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.2 The land use census shall be conducted du ' g ;r; f ng ;;;; n at least once per 12 months using that information that 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 t

I included in the Annual Radiological Environmental Operating Report pursuant to Specification 6.9.1.6.

Broad leaf vegetation sampling of at 1; ov6(able:t ths;; di'f:r:nt kind; cf vegetation dll aey be performed at the SITE BOUNDARY in each of two different direction ike sectorg with the highest predicted D/Qs in lieu of the garden census.

Specifications for broad leaf vegetation sampling in Table 3.12-1, Part 4.c.

shall be followed, including analysis of control samples.

I WOLF CREEK - UNIT 1 3/4 12-13 M

w

,,,_.__-.,_,_y,

,,_...__.m

1 Inse,t - / Z-Aunat if h

S ueshkori 69.I.&, idt,d 6 41.c ri<<a j

Rakeic hll aw. <c,y~~l -I lecc Heno) in t1 c ned

.4 as.au I include. '3 L

np,k anci aise 6jwc.. tin Refec t f

a nd -G t te f.-

ye e,,y n a

(c ea u A41c'gu,-ds) n c ea lectriico (cj,

rc fk e-nry (j

e

K-1 QEac an.y specification 3.12.2 Justifications -

Parenthetical statement removed because all releases from Wolf Creek are ground releases.

ACTION b.

Revised because any reporting concerning the

~

Radiological Environmental Monitoring Program will appear in the Annual Radiological Environmental Operating Report, not in the Semiannual Radioactive i

Effluent Release Report.

The footnote to Specification was modified because samples from the site boundary in the highest D/Q sector are deemed to be sufficient.

i e

a e

I l

t I

l l

l

\\

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM LIMITING CONDITION FOR OPERATION 3.12.3 Analysesshallbeperformedonradioactivematerialssupp$edaspart of an Interlaboratory Comparison Program that has been approved by the ih Commissionf ef ccenspend -le sc 3)tts regeived

12) Tak. 3. i z. - l.

APPLICABILITY: At all times.

ACTION:

a.

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

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.3 The Ir.teristeret ry 0;.4;ri;;., "regr= : hall be d : ribed in th: 00CM.

A summary of the results obtained as part of the above required Interlaboratory Comparison ProgramNhall be included in the Annual Radiological Environmental Operating Report p'rsuant to Specification 6.9.1.6.

d c, I Me C1*wl ::.is lcd:e ca.kr i5 tt l

in %

ciw..cm,.,.J J aedien Ac.u,{a.4iei cca) clesignalien c(ess c h e c k.

{wey nm, -i k' 6*

c e-l i

l WOLF CREEK - UNIT 1 3/4 12-14 1

wolf K-l y

s atu specification 3.12.3 Justifications -

A description of the 'interlaboratory cross check program is not included in the ODCM since this function is performed by the analysis laboratory contracted by KG&E.

Adding the option to report the EPA progress code designation eliminates duplication of effort and allows KG&E greater flexi-bility in its program.

e

'----m

.. L: :.....

~ ^

^

^ - - ^

edis_,

2 i

INSTRUMENTATION 8 SES A

't'h 3/4.3.3.7 FIRE DETECTION INSTRUMENTATION OPERABILITY of the fire detection ins umentation ensures *that ' adequate warning capability is available for the ompt detection of fires and that fire suppression systems, that are as*4=ssed by fire detectors, will discharae extinguishing agent in a timely manner. Prompt detection and suppression of fires will reduce the potential for damage to safety-related equipment and is an integral element in the overall facility fire protection program.

Fire detectors that are used to actuate fire suppression systems represent a iore critically important component of a facility's fire protection program than detectors that are installed solely for early fire warning and notification.

Consequently, the minimum number of OPERABLE fire detectors 4

must be greater.

The loss of detection capability for fire suppression systems, actuated by fire detectors, represents a significant degradation of fire protection for any area. As a result, the establishment of a fire watch patrol must be initiated at an earlier stage than would be warranted for the loss of detectors that provide only early fire warning. The establishment of frequent fire patrols in the affected areas is required to provide detection capability until the inoperable instrumentation is restored to OPERABILITY.

3/4.3.3.8 LODSE-PART DETECTION INSTRUMENTATION l

l The OPERABILITY of the loose part detection instrumentation ensures that sufficient capability is available to detect loose metallic parts in the l

Reactor Coolant System and avoid or mitigate damage to Reactor Coolant System components. The allowable out-of-service times and Surveillance Requirements are consistent with the recommendations of Regulatory Guide 1.133, " Loose-Part Detection Program for the Primary System of Light-Water-Cooled Reactors," May 1981.

-. 3 /4. 3. 3. 9 RADI0 ACTIVE LIOUID EFFLUENT MONITORING INSTRUMENTATIO The radioactive liquid effluent instrumentation is provided to monitor i

and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The alarm /

trip setpoints for these instruments shall be calculated and 2djutted 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 tKe requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.- Thc -

_pu pere of t:-' !:::1 'ndi:: ting d:vic:: i: t: :::ure th: detectier, and cent vi ef !c L that i' net-contec!!:d ceu!d petentially recult '- the tr;nspert of teri44: t: 'Jh'EEET9ICTEC

EEf E

-radierctie:

CALLAWAY - UNIT 1 2 3/4 3-5

-y t-t

.-y----cr----w,,--

--'y-we emw-----r-- - - -,

e, w-se--*-v-,-w-----e,----,---

,----w e----,

-w--

i BASES -- - - -,---

B3/4.3.3.9 JUSTIFICATION Tables 3.3-12 and 4.3-12 do not include any tank level indicating device..This statement is there-fore not applicable.

The methods for the actual adjustment of monitor setpoints is delineated in plant procedure for the specific equipment vice the ODCM. Therefore, the phrase "and adjusted" is deleted.

s e e O

.y,,

.,_._.,cy

,_c.,

d L.

INSTRUMENTATION

[

BASES 1

3/4.3.3.10 RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION

~

The radioactive gaseous effluent instrumentation is providid to monitor and control, as applicable, the releases of radioactive materials in gaseous affluents during actual or potential releases of gaseous effluents. The alars/

trip s'etpoints for these instruments shall be calculated :r.d :df at:d 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. This instrumentation also includes provisions for monitoring (and controlling) the concentrations of potentially explosive gas mixtures in the waste gas holdup 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.

1

.s

g.

e'

+=

e Y

1 l

' ~

-~.

,c ---,.

, ' ~. *. -

, se,

!e t

CALLAWAY - UNIT 1 2 3/4 3-6

B3/4.3.3.10 JUSTIFICATION The methods for the actual adjustment of monitor setpoints.is delineated in plant procedures for the specific equipnent vice the ODCM. Therefore, the phrase "and adjusted" is deleted.

l f

l

3/4.11 RADI0 ACTIVE EF,LUENTS_

BASES 4

3/4.11.1 LIQUID EFFLUENTS 3/4.11.1.1 CONCENTRATION This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II, Column 2.

This limitation provides additional assurance gn that the levels of radioactive materials in bodies of water in UNRE{TRICTED ynd;,.idal ' AREAS will result in exposures within:

(1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, tov.

..._..............., and (2) the limits of 10 CFR Part 20.106(e) to the population. The concentration limit for dissolved 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 an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2.

This sper!'icetter ;;!ie te the re!:::: Of r:dferetiv: ::teri:15 in liz;id ;ff1; nt: fre; cli unit: t th: :fte.

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

[

3/4.11.1.2 DOSE l

This specification is provided to implement the requirements of Sections II.A. III.A and IV.A of Appendix I, 10 CFR Part 50. The Limiting i

Condition for Operation implements the guides set forth in Section II.A of Appendix I.

The 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 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 calculation methodology and parameters in the ODCM implement the requirements in Section III.A of Appendix I that conformance with the guides WOLF CREEK - UNIT 1 B 3/4 11-1

-,c-,

v.,._-...____

,,,-r.,.mm.-_7,,.-.-ry,,_-,.,_-w,,m.

,_.,7,.y em...__.-m-._,_,.

,,.m-,,

4 BASES 'B3/k.kk.k.1

.TUSTIFICATION (1)' The term " MEMBER OF TH2 PUBLIC" has been replaced with the term

" Individual" in that:

10CFR20 and 10CFR50. Appendix l. require that Radioactive (a)

Effluent Concentrations. Doses and Dose Rates be calculated for Individuals at or beyond the SITE BOUNDARY and/or in These regulations neither expressly or UNRESTRICTEn AREAS.

implicitly require that these calculations be performed for persons, real or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

The use of the term " MEMBER OF THE PUBLIC" as defined in (b)

Specification 1.16, is inconsistent with the requirements of the Specification that concentrations be -calculated for UNRESTRICTED AREAS. Therefore, its use would cause the Specification to be internally inconsistent.

As stated in the bases, the purpose of this Specification (c) is so provide for compliance with 10CFR20 and 10CFR50 ' Appendix The use of " MEMBER OF THE PUBLIC" is inconsistent I, limits.

with the stated purpose of this Specification.

"... shall be demonstrated by 10CFR50. Appendix I. states:

(d) calculational procedures based upon models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated...".

i Therefore, the use of the term " MEMBER OF THE PUBLIC" is inconsistent with the expressed purpose of the Specification and requires inconsistency on the part of the Licensee in complying with the Additionally, there are no legal requirements for its Specification.

use in this specification.

l Thus, the use of the term " MEMBER OF THE PUBLIC". while appropriate for specifications implementing 40CFR190 requirements, is inappropriate l

in this Specification, and should be deleted in favor cf the term

" Individual".

The SNUPPS Plants are single reactor unit sites, therefore, this l

(2) statement is not applicable.

l l

i

~

l

- - - - - - ~.,,__,____j_

i i

j RADI0 ACTIVE EFFLUENTS BASES l

DOSE (Continued)

N of Appendix I be shown by calcula onal procedures based on models and data, such that.the actual exposure of,e "C"0C" Of T"

"""LIC through appropriate l

pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of i

l radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide i

1.113. " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

s specification applies to the release of radioactive materials in 1 qnie effluents ach unit at the site. When shared Radwaste TreatmentJysttms are used by more than nit on a site, the wastes from all uni e mixed for shared treatment; by such

, the effluent relea nnot accurately be ascribed to a specific unit. An te sh e made of the contributions from each unit based on input condi flow rates and radioactivity concentrations, or, if not cable, the trea fluent releases may be allocated equally of the radioactive waste produc nits sharing the Radwaste T nt System.

For determining conformance to LCOs, alloca-ti om shared Radwaste Treatment Systems are to be added to the rele specifically attributed to each unit to obtain the total releases per unit.

3/4.11.1.3 LIQUID RADWASTE TREATMENT SYSTEM j

The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement that the appropriate i

portions of this system be used when specified provides assurance that the l

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 l

i 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 specification applies to the release of radioactive materials liquid e from each unit at the site. When shared Ra st reatment Systems are used by an one unit on a site, t es from all units are xin e fluent releases cannot mixed for shared treatment; by n1 timate should be made of the accurately be ascribed to a s contributions from e based on input conditio flow rates and radioactiv centrations, or, if not practicable, the trea ent s may be allocated equally to each of the radioactive waste produci i

WOLF CREEK - UNIT 1 8 3/4 11-2 i

_,..-_______._..._____.__._..__..~..~~1__..__.E_-__

i BASES 3/4.11.1.2 JUSTIFICATION (1) The term " MEMBER OF THE PUBLIC" has been replaced with the term

" Individual" in that:

10CFR20 and 10CFR50 Appendix I, require that Radioactive (a)

Effluent Concentrations. Duses and Dose Rates be calculated for Individuals at cr beyond the SITE BOUNDARY and/or in UNRESTRICTED AREAS. These regulations neither expressly or implicitly require that these calculations be performed for persons, real or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

The use of the term " MEMBER OF THE PUBLIC" as defined in (b)

Specification 1.16, is inconsistent with the requirements of for UKRESTRICTED the Specification that doses be calculated AREAS.

Therefore, its use would cause the Specification to be internally inconsistent.

As stated in the bases, the purpose of this Specification (c) is to provide for cowpliance with 10CFR20 and 10CFR50, Appendix I, limits. The use of " MEMBER CF THE PUBLIC" is inconsistent with the stated purpose of this Specification.

(d) 10CFR50, Appendix I, states: "... shall be demonstrated by calculational procedures based upon models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated...".

Therefore, the use of the term " MEMBER OF THE PUBLIC" is inconsistent with the expressed purpose of the Specification and requires l

inconsistency on the part of the Licensee in complying with the l

Additionally, there are no legal requirements for its Specification.

use in this specification.

Thus, the use of the term " MEMBER OF THE PUBLIC", while appropriate for specifications implementing 40CFR190 requirements, is inappropriate in this Specification, and should be deleted in favor of the term

" Individual".

(2) Since the SNUPPS Plants are single reactor unit sites, and consequently have no shared radwaste treatment systems, this paragraph is not applicable.

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,.._---..,-_.,._.,.,,,---..--,--...,-,..._,,-.--._n-

BASES 3/4.11.1.3 JUSTIFICATION sli:es, and Since the SNUPPS Plants are single reactor ut. 6 consequently have no shared radwaste treatment systems, this paragraph is not applicable.

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RADIOACTIVE EFFLUENTS BASES LIQUID RADWASTE TREATMENT SYSTEM (Continued) units sharing the Ra w ent System ermining conformance to LCOs, these allocations from tment Systems are to be added to the release y attributed to each unit t

3/4.11.1.4 LIQUID HOLDUP TANKS The tanks listed in this specification include all those outdoor radwaste tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System.

Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations would be less than the limits of 10 CFR Part 20, Appendix B, Table II, Column 2., at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA.

3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 DOSE RATE g&f l

This specification is provide to ensure that the dose at any time at and beyond the SITE BOUNDARY from ga ous effluents from all units on the site l

will be within the annual dose imits of 10 CFR Part 20 to UNRESTRICTED AREAS.

The annual dose limits are th doses associated with the concentrations of 10 CFR Part 20, Appendix B, Tab e II, Column 1.

These limits provide reasonable fi assurance that radioactive /laterial discharged in gaseous effluents will not l

result in the exposure of fa MENSEihefdNE=#UBMG in an UNRESTRICTED AREA, blividual eith;r.;ithir ;r outside the SITE BOUNDARY, to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 m

LtM 20.106(b)).

Fo?'"C"C:Z 07 T Z FC LIC who may at times be within the

%.dn.d I

SITE BOUNDARY, the occupancy of that MENSEE-GMHE4WSWCgwill usually be s sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the SITE BOUNDARY.

E= pl:: :fe alcadat'--

- -h NEMSERS OF THE P'JSLIC, with th: :ppr:prf:te :: up:ncy f::ters, the!' be giv^n ir th: 000M. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a-MEMKipekiME e L<n,sh PW9HC at or beyond the SITE BOUNDARY to less than or equal to 500 mrems/ year to the whole body or to less than or equal to 300 mrems/ 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 arems/ year.

This specificatica applies te the relae=e of "edicactive =ete"fals in g :::e: ef'! :nt: 're :11 units--at-the-site.

WOLF CREEK - UNIT 1 B 3/4 11-3 1

i

l I

RASES 3/4.11.2.1 JUSTIFICATION The term " MEMBER OF THE PUBLIC" has been replaced with the ters" (1)

" Individual" in that:

4 (a) 10CFR20 and 10CFR50, Appendix I, require that Radioactive be calculated Effluent Concentrations Doves and Dosa Rate:

for Individuals at or beyond the SITE BOUNDARY and/or in UNRESTRICTED AREAS. These regulations neither expressly or implicitly require that these calculations be performed for persons, real or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

The use of the term " MEMBER OF THE PUBLIC" as defined in (b)

Specification 1.16, is inconsistent with the requirements of the Specification that doses be calculated at the SITE BOUNDARY. Therefore, its use would cause the Specification to be internally inconsistent.

As stated in the bases, the purpose of this Specification (c) is to provide for compliance with 10CFR20 and 10CFR50, Appendix I, limits. The use of " MEMBER OF THE PUBLIC" is inconsistent

~

with the stated purpose of this Specification.

i (d) 10CFR50, Appendix I, states: "... shall be demonstrated by calculational procedures based upon models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated...".

Therefore, the use of the term " MEMBER OF THE PUBLIC" is inconsistent with the expressed purpose of the Specification and requires inconsistency on the part of the Licensee in complying with the Additionally, there are no legal requirements for its Specificatien.

use in this specification.

Thus, the use of the term " MEMBER OF THE PUBLIC", while appropriate for specifications implementing 40CFR190 requirements, is inappropriate in this Specification, and should be deleted in favor of the term

" Individual".

(2)

As defined in NUREG 0133 (October 1978) and in Technical Specification Definition 1.17 the ODCM is intended to provide the methodology and utilized to perform off-site dose calculations, gaseous and parameters liquid effluent monitor setpoint determinations, and a description of the Environmental Radiological Monitroing Program. The proposed deletion is to ensure that the ODCM remains within its intended scope and does not s

become a forum for justifications and example calculations.

(3)

The SNUPPS Plants are single reactor unit sites, therefore, this statement is not applicable.

i l

RADIOACTIVE EFFLUENTS BASES DOSE RATE (Continued)

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 t

l Radiochemistry," Anal. Chem. 40, 586-93 (1968), and Hartwell, J. K., " Detection l

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

3/4.11.2.2 DOSE - NOBLE GASES f

This specification is provided to implement the requirements of Sections II.B, 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 ACTION statements provide tne required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The cm

-nad%) Surveillance Requirements implement the requirements in Section III.A of x Appendix I that conformance with the guides of Appendix I be shown by N alculational procedures based on modes 1 and data such that the actual exposure of4a=MNSEE-ETM=MSL4C throt;gh appropriate pathways is unlikely to be substantially underestimated. The dose calculation methodology and parameters established in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 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 theairdosesatandbeyondtheSITEBOUNDARYarebaseduponghehistorical l

average atmospheric conditions.

4.dher r\\ cr 'w l -Enc Wisspecificationappliestothereleaseofiadioactivemateria n

gaseous eT ts from each unit at the site. When shared Radw Treatment Systems are use re than one unit on a site, the was rom all units are mixed for shared treatme such mixing, the ef

. releases cannot accurately be ascribed to a spe unit.

timate should be made of the contributions from each unit based on conditions, e.g., flow rates and radioactivity concentrations, or not prac '

le, the treated effluent releases may be allocated ly to each of the ra ive waste producing units sharing the Ra e Treatment System.

For determini nformance to LCOs, these al ions from shared Radwaste Treatment Systems are e added to the r ses specifically attributed to each unit to obtain the total r

es per unit.

WOLF CREEK - UNIT 1 B 3/4 11-4'

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BASES 3/4.11.2.2 JUSTIFICATION r

(1)- The term " MEMBER OF THE PUBLIC" has been replaced with the term

" Individual" in that:

(a) 10CFR20 and 10CFR50,.\\ppendix I, require that Radioactive Effluent Concentrations. Dose 6 and Dosc Rates be calculated

-for Individuals at or beyond the SITE BOUNDARY and/or in UNRESTRICTED AREAS. These regulations neither expressly or implicitly require that these calculations be performed for persons, asal or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

(b) The use of the term " MEMBER OF THE PUBLIC" as defined in Specification 1.16, is inconsistent with the requirements of the Specification that doses be calculated at the SITE BOUNDARY. Therefore, its use would cause the Specification to be internally inconsistent.

(c) As stated in the bases, the purpose of this Specification is to provide for compliance with 10CFR20 and 10CFR50, Appendix

1. limits. The use of " MEMBER OF THE PUBLIC" is inconsistent with the stated purpose of this Specification.

(d) 10CFR50 Appendix I, states:

shall be demonstrated by calculational procedures based upon models and data such that the actual exposure of an individual through appropriate pathways is unlikely te be substantially underestimated...".

Therefore, the use of the term " MEMBER OF THE PUBLIC" is inconsistent 1

with the expressed purpose of the Specification and requires inconsistency on the part of the Licensee in complying with the I

Specification. Additionally, there are no legal requirements for its use in this specification.

Thus, the use of the term '9HEMBER OF THE PUBLIC", while appropriate for specifications implementing 40CFR190 requirements, is inappropriate in this Specification, and should be deleted in favor uf the term

" Individual".

(2)

NUREG 0133 provides for the use of annual average (historical) atmospheric data in the calculation of offsite doses, whereas Regulatory Guide 1.111 provides for the use of hourly measured (real time) values. The bases has therefore been modifed to reflect the acceptability of either method.

(3)

Since the SNUPPS Plants are single reactor unit sites, and consequently have no shared radwaste treatment systems, this paragraph is not applicable.

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1 4

RADI0 ACTIVE EFFLUENTS BASES 3/4.11.2.3 DOSE - 10 DINE-131 AND 133, TRITIUM, AND RADIOACTIVE MATERIAL IN PARTICULATE FORM This specification is provided to implement the requirements of Sections II.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 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 Surveillance Requirements implement the requirements in Section III. A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of : "E"SER OF T" l"JSLIC through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of 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 the actual doses based upo the Ob historical avera g atmospheric conditions. The release rate specificat

[for Iodine-131 and 133, tritium, and radioactive material in particulate form gred hmc with half lives greater than 8 days are dependent upon the existing radionuclide pathways to man, in the areas at and beyond the SITE BOUNDARY. The pathways that were examined in the development of these calculations were:

(1) individual inhalation of airborne radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and (4) deposition on the ground with subsequent exposure of man.

7 his specification applies to the release of radioactive materials i gaseous ents from each unit at the site. When shared Radwast atment Systems are use more than one unit on a site, the wastes all units are by such mixing, the efflu e eases cannot mixed for shared trea accurately be ascribed to a s ic unit. An ate should be made of the contributions from each unit based o onditions, e.g., flow rates and radioactivity concentrations, or, pr able, the treated effluent releases may be allocated e y to each of the active waste producing units sharing the Ra Treatment System.

For determ conformance to LCOs, these all ons from shared Radwaste Treatment Systems o be added to the r es specifically attributed to each unit to obtcin the to'h N re s per unit.

3/4.11.2.4 GASEOUS RADWASTE TREATMENT SYSTEM The OPERABILITY of the WASTE GAS HOLDUP SYSTEM and the VENTILATION EXHAUST TREATMENT SYSTEM ensures that the systems will be available for use whenever gaseous effluents require treatment prior to release to the environment. The WOLF CREEK - UNIT 1 8 3/4 11-5

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i l

BASES 3/4.11.2.3 JUSTIFICATION (1) The term " MEMBER OF THE PUBLIC" has been replaced with the ters

" Individual" in that:

10CFR20 and 10CFR50 Appendix I, require that Radioactive (a)

Effluent Concentrations Doses and Dose Rate = 've calculated for Individuals at or beyond the SITE BOUNDARY and/or in UNRESTRICTED AREAS. These regulations neither expressly or implicitly require that these calculations be performed for persons, real or imaginary, who may occupy areas within the SITE BOUNDARY for some fraction of the time.

The use of the term " MEMBER OF THE PUBLIC" as defined in (b)

Specification 1.16, is inconsistent with the requirements of the Specification that doses be calculated at the SITE BOUNDARY. Therefore, its use would cause the Specification to be internally inconsistent.

As stated in the bases, the purpose of this Specification (c) is to. provide for compliance with 10CFR20 and 10CFR50, Appendix The use of " MEMBER OF THE PUBLIC" is inconsistent 1, limits.

with the stated purpose of this Specification.

(d) 10CFR50, Appendix I, states:

... shall be demonstrated by calculational procedures based upon models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated...".

i l

Therefore, the use of the term " MEMBER OF THE PUBLIC" is inconsistent with the expressed purpose of the Specification and requires' inconsistency on the part of the Licensee in complying with the Additionally, there are no legal requirements for its l

Specification.

use in this specification.

Thus,' the use of the term " MEMBER OF THE PUBLIC", while appropriate for specifications implementing 40CFR190 requirements, is inappropriate in this Specification, and should be deleted in favor of the term l

" Individual".

(2)

Since the SNUPPS Plants are single reactor unit sites, and consequently have no shared radwaste treatment systems, this paragraph is not applicable.

l i

i RADIOACTIVE EFFLUENTS

~

BASES requirement that the appropriate portions of this system be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objectives 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.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

is specification applies to the release of radioactive materials gaseous e nts from each unit at the site. When shared Radwas eatment Systems are use re than one unit on a site, the waste a all units are mixed for shared treats b such mixing, the effl releases cannot accurately be ascribed to a sp c unit. An mate should be made of the contributions from each unit based on '

conditions, e.g., flow rates and radioactivity concentrations, or ot pra ble, the treated effluent releases may be allocated y to each of the ra -

tive waste producing units sharing the Ra e Treatment System.

For determin onformance to LCOs, these al ions from shared Radwaste Treatment Systems a be added to the ses specifically attributed to each unit to obtain the tota r

ses per unit.

ga sdw 3/4.11.2.5 EXPLOSIVE GAS MIXTURE a

This specification is provided to ensure at the concentration of a

potentially explosive gas mixtures contained in the WASTE GAS HOLDUP _ SYSTEM _is

maintained below the flammability limits of> hydrogen and oxygenAC'(Automatic control features are included in the system to prevent the hydrogen and oxygen concentrations from reaching these flammability limits. These automatic control features include isolation of the source of hydrogen and/or oxygen.)

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n:::tr: tion 5:10w the f' ---5f'ity '! it:. ) Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion GO of Appendix A to 10 CFR Part 50.

3/4.11.2.6 GAS STORAGE TANKS The tanks included in this specification are those tanks for which the quantity of radioactivity contained is not limited directly or indirectly by another Technical Specification to a quantity that is less than the quantity that provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting whole body exposure to : MEMSER OF THE PL'SL!C an 3:o5d A-at the nearest SITE BOUNDARY will not exceed 0.5 rem, the annual dose limit in 10 CFR Part 20.

Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting whole body exposure to e MEMOCR OF T"E PUOLIC an IF Ah'"k at the nearest SITE BOUNDARY will not exceed 0.5 rem. This is consistent with WOLF CREEK - UNIT 1 B 3/411-6 og g..

me p.6 Om

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B3/4.11.2r4

' JUSTIFICATION Since the SNUPPS Plants are single reactor unit sites and consequently have no' shared radvaste treatment systems, this paragraph is not applicable.

O e

0

B3/4.11.2.5 JUSTIFICATION Since Specification 3.11.2.5 does not require automatic control features on the Waste Gas Bold Up System, the indicated portion was deleted as not applicable.

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i RADI0 ACTIVE EFFLUENTS BASES GAS STORAGE TANKS (Continued)

Standard Review Plan 11.3, Branch Technical Position ETSB 11-5, " Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure " in NUREG-0800, tdde-C'4 het July 1981', ad M FML ca.i& ~+ Aul p -foe A.

%L f ' t urc.

1 3/4.11.3 - SOLID RADIOACTIVE WASTES This specification implements the requirements of 10 CFR 50.36a ana 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 I

ratios, waste oil content, waste principal chemical constituents, and mixing and curing times.

3/4.11.4 TOTAL DOSE This specification is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Fart 20 by 46 FR 18525. The specification requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radioactivity and the radiation from uranium fuel cycle sources exceed 25 mrems to the whole body or any organ, h;g[exceptthethyroid,whichshallbelimitedtolessthanorequalto75mrems.

For sites containing up to four reactors, it is highly unlikely that the resultant oose i~ohdGMBER45=9ME469Wr will exceed the dose limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of Appendix I, and if direct radiation doses from the reactor units and from outside storage tanks are kept small. The Special Report will describe a course of action that should result in the limitation of the annual dose to a-MEMBEfEOF au T&d T+tE4W9tfC to within the 40 CFR Part 190 limits.

For the purposes of the 2

Special Report, it may be assumed that the dose commitment to the MEMBER 4F T.sdMd"I Tit 94W9 HEC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at h dd the same site or within a radius of 8 km must be considered.

If the dose to NMEMBEfbOP=4ME=Ptet96-is estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 and 10 CFR 20.405c, is considered to be a timely request and fulfills the require-ments of 40 CFR Part 190 until NRC staff action is completed. The variance l

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 Specifications 3.11.1.1 and 3.11.2.1.

An individual is not considered ao %dda-MEMBEA-Of-4HE4WedC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle.

WOLF CREEK - UNIT 1 8 3/4 11-7

BASES 3/4.11.2.6

_ JUSTIFICATION (1)

The term " MEMBER OF THE PUBLIC" ha 0133 and 10CFR100.of the term " Individual" to provide onsistency with NUREG (2)

The FSAR accident analysis for a W conducted in compliance with guidanceaste Gas Decay T 1.24, was utilized to a great extent i given by Regulatory Guide specification, and should,':thereforen the development of this

, be part of its Bases.

I

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i I

BASES 3/4.11.4' JUSTIFICATION (1)

" Individual" in that:The term " MEMBER OF as been replaced with the term (a) 10CFR20 and 10CFR53, Appendix I for Individuals at or beyond the SIEfflue 1

ose Rates be calculated UNRESTRICTED AEFAS.

TE BOUNDARY and implicitly require that these calThese regulations neither exp SITE BOUNDARY for some fractionpersons, essly or of the time. occupy areas within the (b)

Specification 1.16, is inconsistThe use of th UBLIC" as defined in the Specification that doses b ent with the requirements of AREAS.

to be internally inconsistentTherefore, its use would ca pecificatio'n (c)

As stated in the bases, the purpo is to provide for compliance with 10se of this Specification I, limits.

with the stated purpose of this Spe ifiThe use of s inconsistent (d) c cation.

10CFR50, Appendix I, states:

that the actual exposure of an i dicalculation o

y e s and data such pathways is unlikely to be substanti llvidual through appr n

a y underestimated...".

with the expressed purpose of the SpTheref ecification and requiresR OF T inconsistency on the part of the Li Specification.

n Additionall use in this specification. y, there are no legal requireme tce n s for its Thus, the use of the term " MEMBER OF T in this Specification, and should be d lfor sp

\\

" Individual".

e eted in favor of the termrequ

(

(2) --Since the-SNUPPS-Plants i

have-no shared radwasre-treatmene s-are-single-reactor-un i

- applicabl..

ysremsT ttris paragraph fruct-onsequently r

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3/4.12 RADIOLOGICAL ENVIRONMENTAL MONIT ORING BASES 4

3/4.12.1 MONITORING PROGRAM specification provides representatiThe Radio ve measurements of radia radioactive materials in those that lead to the highest potexposure pathways and for those r di Section IV.8.2 of Appendix I tPUBLIC resulting s

ential radiation exposures of MEMBER of a

on operation.

onuclides Radiological Effluent Monitori o 10 CFR Part 50 and thereby sup S OF THE than expected on the basis ofconcentrations of ra ng Program by verifying that the ments p ements the the environmental exposure p th the effluent measurements measurable provided by the Radiological Ass a

re not higher ways.

Environmental Monitoring essment Branch Technical Po this period, program changeseffective for at leas The initially specified monito i program is on may be initiated based on operatiy tabulated in terms of the lThe required detection capab Following onal experience.

by Table 4.12-1 are consideredes for environmental sample analy ower limits in industrial laboratories of detection It-showM-h =utine en(vironmental optimum for ro LLDs).

es are weestrr. 4a.m 7 -+y hw per6+teka-eeawremen%.

e pahility nr 3 in HASL Procedures ManualDetailed discussio Radiochemistry," Anal. Chemfor Qualitative Detectio and Quantitative Determination - Ap liannua A., " Limits Company Report ARH-SA-215 (JuLimits for Rad n

40, 586-93 (1968),

p and Hartwell, J cation to ng Techniques," Atlantic Richfield H. K.,

" Detection ne 1975).

3/4.12.2 LAND USE CENSjJS anford is specification is provided t at and be p h required by the res lthe SITE BOUNDARY are identifi Radiological Env o ensure that changes in the use p8 ntal Monitoring Program given in th ed and that modificat of door survey u ts p authorities,shall be used.from aerial surve his census.

e o the The best are made if Section IV.8.3 of Appendix IThis een from con g with local agriculturaltion fro gardens of greater th tisfies the requirements of via 1 CFR Part pathway:

the minimum required to prodvegetables wil provides assuranc.

this si et nificant exposure ables assumed in Regulatory Guid monito inc uce the quantity (26 kg e a garden of 1

e 1.109 for consumption by a childof leafy WOLF CREEK - UNIT 1 B 3/4 12-1 F

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t0010 LOGICAL ENVIRONMENTAL MO NITORING BASES y.

(1) 20% of the garden

,}V to 'ettan end canoage)was use g

3/4.12.3 and (2) a veg. :,,,.,the following assu

^* 3 e =d INTERLABORATORY COMPARISON PROG simile Comparison Program is provided tThe requirem M

o ensure that independent ch and accuracy of the measurements of sample matrices are performed as pa t environmental monitoring in order t radioactive material in environn the pr for the purposes of Section IV r

o demonstrate that the res mental B.2 of Appendix I to 10 CFR Part 5 or valid 0

e i

WOLF CREEK - UNIT 1 B 3/4 12-2

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. Tnsert l3 "This sfeciRceficn is prowded h

insare. that c.hanges in

-th e use.

of areas a.+

and beyond

+he SITE BouUDARY ar.

idenHRed and

-the e

modificancns b

'he radiclognd env/renmenlni n1cosileviny

. (

frejram a re.

made ll reguired by ilie re.1a /fs o f

+ho's census.

.Tnfcrmrhbn hel will jtevn/<.

+ tie btsh resul/s,

Such as by 4.

dw - N ~ dw suevey,

aerirI survey,

or by eensu //ing locs/

ttgricultare au thorifies stall be used.

This census sctksRe.s itse reguirernenfs of See M n

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/DeFK. Rtet 50.

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Uraso 3/4.12.1 Justification -

The deleted sentence duplicates informati in Note 737 to Table 4.12-1.

on previously described

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GEEK nei ONLY Bases 3/4.12.2 Justification --

The second sentence was revised to correspond t'o Specification 4.12.2.

Thelastpartof3/4.12.2wasdeletedbecauseWolfCreek"wkil sample broadleaf vegetation at the site boundary in the sector with the highest D/Q in lieu of including gardens in the annual land use census.

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ADMINISTRATIVE CONTROLS C

ANNUALRADIOLOGICALENVIRONMENTALOPERATINGREPORT[

6.9.1.6 Routine Radiological Environmental Operating Reports covering the operation of the Unit during the previous calendar year shall te submitted q ' May 1 of the year following initial criticality.The initial report sha pr':- 'c May 1 of each year.

by The Annual Radiological Environmental Operating Reports shall include summaries interpretations, and an analysis of trends of the results of the radiological environmental surveillance activites for the report period, including a comparison with preoperational studies with operational controls and with 4

previous environmental surveillance rep, orts, and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results ofvLand Use Census required by Specification 3.12.2.

e.

The Annual Radiological Environmental Operating Reports 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 summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

In the event that some individual results are nct available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.

The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following:

a summary description of the Radiological Environmental Monitoring Program; at least two legible maps **

covering all sampling legations keyed to a table giving distances and directions from the centerline of.dae reactor; the results of licensee participation in the Interlaboratory Comparison Progrjam and the corrective actions being taken if the specifiea program is not being performed as required by Specification 3.12.3; f;r n:t ;;. ducting the "editingi;;l Envirena;ntal "cr4todeg-Program-as

n:

-requir d by Sp;cificati;n 3.12.1 :nd discussion of all deviations from the sampling schedule of Table 3.12-ladb;;;;ien ;f env'r:rt:nt:1 :::ple ::: ur:- -

=nt; tr.;t en;;d the rep;rr ag Ruel; ;f T;bi; 3.12-2 but :re ret the result of plent effluente, pursuant t; Specift::tien 2.12.1; :nd discussion of all analyses in which the LLO required by Table 4.12-1 was not achievable.

reGo,ss b

Se g li g (ccJicns

,w acccedoc <

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p (m d

A single submittei se, be sede fcr -e stritiple U-ititation

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

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WOLF CREEK - UNIT 1 6-17 g-'

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Section 6.9.1.6 Justification -

Changing," prior to" to "by" the Radiological Assessment B conforms with-guidance provided i November 1979 ranch Technical Position n

Since radiological /environm Revision 1, Juatification of Section 6 9 Annual Radiologica ental reporting will be included i ental Operating Report 17),

(see the n the Specification 3.12.2."" revisions to samplin e:

ons in accordance with Adding the option to report th climinates duplication )f efforte EPA program in its program.

code designation and allows KG&E greater fle O

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ADMINISTRATIVE CONTROLS i

SEMIANNUAL RADI0 ACTIVE EFFLUENT REPORT (Continued)

Operation."

liquid and gaseous effluents are given in Regulatory Gui October 1977.

. 1, of unplanned releases from the site to UNRESTRIC materials in gaseous and liquid effluents made during the reporting period.

The Radioactive Effluent Release Reports shall include any chang the reporting period to the PROCESS CONTROL PROGRAM and to the ODCM i Liquid, Gaseous, or Solid Radwaste Treatment Sys pursuant j

tion 6.15.

It tions _.._. _. -. shall also include a listing of new locations for dose calcula-

. _ _... r'tr':;; identified b to Specification 3.12.2.

y the Land Use Census, pursuant I

3 The Radioactive Effluent Release Reports shall also include the follo 1

information:

an explanation as to why the inoperability of liquid or gaseous effluent monitoring instrumentation was not corrected within the time sp in Specifications 3.3.3.10 or 3.3.3.11, respectively; and description of th events leading to liquid holdup tanks of gas storage tanks exceeding the limi e

of Specification 3.11.1.4 or 3.11.2.5, respectively.

MONTHLY OPERATING REPORT 6.9.1.8 including documentation of all challenges to the PORVs U.S. Nuclear Regulatory Commission, Washington, D.C.be

, shall calendar month covered by the report.the NRC Regional Office, n

_ RADIAL PEAKING FACTOR LIMIT REPORT 6.9.1.9 The Fxy limits for RATED THERMAL POWER (F

) shall be provided to the NRC Regional Administrator with a copy to Director of Nuclear Reactor R x

Attention:

Chief, Core Performance Branch, U.S. Nuclear Regulatory Commis Washington, D.C. 20555 for all core planes containing Bank "0" control rod all unrodded core planes and the plot of predicted (F T.P,j) vs Axial Core Height with the limit envelope at least 60 days prior to each cycle initial g

q criticality unless otherwise approved by the Commission by letter.

in the event that the limit should change requiring a new submittal or an In addition, i

60 days prior to the date the limit would become effecti approved by the Commission by letter.

P Any information needed to support F

will be by request from the NRC and need not be included in this report.

SPECIAL REPORTS 1

6.9.2 NRC Regional Office within the time period specified for WOLF CREEK - UNIT 1 6-19 4

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ONLY Section 6.9.1.7 Justification -

All information concerning the Radiological Environmental Monitoring Program will be included in the Annual Radiological Environmental Operating Report to eliminate duplication of effort.

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ADMINISTRATIW CONTROLS RECORD RETENTION (Continued)

Records.of training and qualification for current members of the g.

Unit Staff; h.

Records of in-service inspections performed pursuant to these Technical Specifications; i.

Records of Quality Assurance activities required by the QA Manual; j.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59; k.

Records of meetings of the PSRC and the NSRC; 1.

Records of the service lives of all hydraulic and mechanical snubbers required by Specification 3.7.8 including the date at which the. service life commences and associated installation and maintenance records; Records of secondary water sampling and water quality; and m.

Records of analysis required by the Radiological Environmental n.

Monitoring Program,th:t.;;;1d p:-it evel;;ti;n of th; accuracy of th: :::?y:i: It : 1 ter date. hi: :h !d %:!ude pre dures cff::tiV: :t :p :ifi;d ti::: :nd QA rec;rd; :hr ini; that the;e pr:::dar:: ;=r: f !!r:d.

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent '

with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving perso.7nel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device: or " alarm signal" required b paragraph 20.203(c)(2) of 10 CFR Part 20, each high radiation area, yas defined i

in 10 CFR Part 20, in which the intensity of radiation is equal to or less than l

1000 mR/h at 45 cm (18 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high l

radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP).

Individuals qualified in radiation protection procedures (e.g., Health Physics Technician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mR/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be pro-vided with or accompanied by one or more of the following:

A radiation monitoring device which continuously indicates a.

the radiation dose rate in the area, or

(

l WOLF CREEK - UNIT 1 6-21 l

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K-l 4

Specification 6.10.2.n-Justification -

The " accuracy of the analysis" will be verified by NRC audit functions.

If these audits show the analysis to be reliable, then-only the final reports need to be retained for the duration of the Unit Operating License.

Retention of other documentation would serve no useful purpose.

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ML20082Q563

Text

Dear Mr. Denton:

2.5 APPLICABILITY

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