ML20084C013
| ML20084C013 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/29/1983 |
| From: | Sunny Chen, Pandey S Franklin Research Ctr |
| To: | Congel F, Willis C Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20084C016 | List: |
| References | |
| CON-NRC-03-81-130, TAC 8106, TAC 10906 TER-C5506-85-86, NUDOCS 8304070498 | |
| Download: ML20084C013 (34) | |
Text
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TECHNICAL EVALUATION RE.DORT l SPECIFICATION I RADIOLOGICAL EFFLUENT TECHNICAL CAROLINA POWER AND LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 u
li l NRCTACNO.
imC COCKET NO. 50-324, 50-325 FRC PROJECT C550G 8106, 10906 FRC AGSIGNMENT 4 NRC CCNTRACT NO. NRC43-81-130 FRC TASKS 85, 86 Prepared by Frasiklin Research Center Author:
S. Chen 20th and R:co Stroots Philadelphia, PA 19103 FRC Group Leader:
S. Pandcy Prepared for Nuclear Regulatory Commission Washington, D.C. 20S$5 Load NRC Engineer:
I'. Congol C. Will.is March 29, 1983 This report was prepared as an account of werk sponsorod by an agency of the United States Governmert. Neither the United States Government nor any agericy tneroof, or any of their empfoyens, makeA ar.y warranty, expressed cr implied, or assumes any legal fiscalty or responsibility for any ih:rd party's use, or th+ reso!ts of such use, of any infocmation, acca-ratus, product or prc,ess disclosed in th:s report, or re: resents that hs use by such third carty would not infrince crivatsiv ewned rights.
yA Copy Has Been sent to PDR W%
nI i
l n ! L Franklin Research Center A Division of The Franklin Institute W.e Seryarn.n F anklio Femwev. Pnna-. Pa.13iG3 (215) 448.t 000
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TECHNICAL EVALUATION REPORT RAD:OLOGICAL EFFLUENT TECHNICAL SPECIFICATION IMPLEMENTATION (A-2)
CAROLINA POWER AND LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 NRC DOCKET NO. 50-324, 50-325 FRC PROJECT C5506 NRC TAC NO. 8106, 10906 FRC ASSIGNMENT 4 NRC CONTRACT NO. NRC-03-81-130 FRC TASKS 83, 86 Prepared by Franklin Research Center Author:
S. Chen 20th and Race Streets Philadelphia, PA 19103 FRC Group leader:
S. Pandey Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer:
F. Congel C. Willis March 29, 1983 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any t5ird party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its ute by such third party would not infringe privately owned rights.
Pre ared by:,
Reviewed by:
Approved by:
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/ Principal Author Group Leader D'epartment Dfect6)M 3 Date:_ O ' 2 9 3
Date:
03 Date:
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_ Franklin Research Center A Division of The Franklin Institute The Bengman FrankJin Parkwiy, Phila.. Pa 19103(215)448 1000
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TER-C550 6-85/86 CONTENTS Se ction Title Page 1
INTRODUCTION 1
1.1 Purpose of Review.
1 1.2 Generic Background.
1 1.3 Plant-Specific Background.
3 2
REVIEW CRITERIA.
5 3
TECHNICAL EVALUATION 7
3. l~
General Description of Radiological Effluent System 7
3.2 Radiological Effluent Technical Specifications.
10 3.3 offaite Dose Calculation Manual 18 3.4 Process Control Program 21 4
CONCLUSIONS.
22 5
REFERENCES.
23 nklin Research Cendr A Dhasson of The Frenten W
TER-C550 6-85/8 6 FIGURES Nunber Title Page 1
Liquid Radwaste Treatment Systems, Effluent Paths, and Controls for Brunswick Steam Electric Plant Units 1 and 2 8
^
2 Gaseous Radwaste Treatment Systems, Ef fluent Paths, and Controls for Brunswick Steam Electric Plant Units 1 and 2 9
TABLE Ne mber Title Page 1
Evaluation of Proposed Radiological Effluent 'Ibchnical Specifications (RETS), Brunswick Steam Electric Plant Units 1 and 2.
23 nklin Research Center A OMeson of The FrankAn insatute l
TER-C5506-85/86 FORI!NORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical c.csistance in support of NRC operating reactor licensing actions. 'Ihe technical evaluation was conducted in accordance with criteria established by th3 NRC.
6 nklin Research Center A Otamon of The Frenen inessune 6...
TER-C5506-85/86 1.
INTRODUCTION 1.1 PURPOSE OF REVIEW The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Brunswick Steam Electric Plant Units 1 and 2 with regard to Radiological Effluent Technical Specifications (RETS), the Of fsite Dane Calculation Manual (ODCM),
, and the Process Control Program (PCP).
The evaluation uses criteria proposed by the NBC staff in the Model Tectinical Specifications for boiling water reactors (BWRs), NUREG-0473 (1].
This effort is directed toward the NBC objective of implementing RETS which comply principally with the regulatory requirements of the Code of Federal Regulations, Title 10, Part 50 (10CFR50), " Domestic Licensing of Production and Utilization Facilities," Appendix I [2]. Other regulations pertinsnt to the control of effluent releases are also included within the scope of compliance.
1.2 GENERIC BACKGROUND Since 1970,10CFR50, Section 50.36a, " Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide
. technical specifications which ensure that radioactive releases will be kept as low as reasonably achievable (ALARA).
In 1975, numerical guidance for the AIARA requirement was issued in 10CFR50, Appendix I (3]. The licensees of all operating reactors were required to submit, no later than June 4,1976, their proposed ALARA Technical Specificatiens and information for evaluation in accordance with 10CFR50, Appendix I.
However, in February 1976, the NaC staff recommended that proposals to modify Technical Specifications be deferred until the NBC completed the model RETS. The model RETS deals with radioactive waste management systems and environmental monitoring. Although the model RETS closely parallels 10CFR50, Appendix I requirements, it also includes provisions for addressing other issues. 4 0000 Franklin Research Center A Dmssen of The Frankan insature
m TER-C550 6-85/8 6 These other issues are specifically stipulated.by the following regulations:
o 10CFR20 [4], " Standards for Protection Against Radiation," Paragraphs 20.10 5 (c), 20.10 6 (g), and 20.40 5 (c) require that nuclear power plants and other licensees comply with 40CFR190 [5], " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NBC when the 40CFR190 limits have been or may be exceeded.
o 10CFR50, Appendix A [6], " General Design Criteria for Nuclear Power Plants," contains Criterion 60 - Control of releases of radioactive materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and Criterion 64 - Monitoring radioactivity releases.
,w
.e o 10CFR50, Appendix B [7], establishes the quality assurance required I, $
for nuclear power plants.
,]
s r
The NBC position on the model RETE was established in May 1978 when the
?,4 %u bf NRC's Regulatory Requirements Review Committee approved the model RETS:
gf NUREG-0473 [1] for BWRs and HUREG-0472 for pressurized water reactors (PWKs)
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[8]. Copies were sent to licensees in July 1978 with a request to submit proposed site-specific RETS on a staggered schedule over a 6-month period.
I '. ' '
x Licensees responded with requests for clarifications and extensions.
,}
The Atomic Industrial Forum (AIF) formed a task force to comment on the F.. T..
j model RETS. NRC staff members first met with the AIF task force on June 17, 4g/g
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1978. The model RETS was subsequently revised to reflect comments from the p;
AIF and other s.
A principal change was the transfer of much of the material lip
. g.
concerning dose calculaticas from the model RETS to a separate ODCM.
fy.M Wbs The revised model RETS was sent to licensees on November 15 and 16,1978
[M with guidance (NUREG-0133 [9]) for preparation of the RETS and the ODCM and a fr[N.
{M.
new schedule for responses, again staggered over a 6-month period.
p.;
..i.f '. 4 Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978.
Subsequently, Revision 2 of the model RETS and J.Q omg additional guidance on the ODCM were issued in February 1979 to each utility T. p ;
at individual meetings. In response to the NRC's request, operating reactor j,5) I A-licensees subsequently submitted initial pcoposals on plant RETS and the ODCM.
7% '
&l~Q Review leading to ultimate implementation of these documents was initiated by
-y. A the NBC in 1981 using subcontracted independent tecms as reviewers.
6 R.i
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4 5%i dd Franklin Research Center Aon=encem r=mn w.
L TER-C 5 50 6-8 5.'8 6 As the RETS review process has progressed since Septemoer 1981, feedback s
from the licensees has led the NRC to believe that modification to some of the guidelines in the current version of Revision 2 is needed to clarify specific t
concerns of the licensees and thus expedite the entire review process.
Starting in April 1902, NRC distributed revised versions of RETS in draf t form to Lhe licensees during site visits.
The new guidance on diese changer, was presented at the AIF meeting on May 19, 1982 [ 10 ).
Some interim changes J
regarding the Radiological Environmental Monitoring Section were issued in
[
August 1982 [11).
Wi th the incorporation of these new changes, NRC issued, in Se ptember 1982, a dr af t version of NUREG-0472, Revision 3 [12], to serve as new guidance for the review t e am s.
Since the equivalent version of NUREG-0473 for BWRs has not been made available by the "9C, the Licensee-submitted BWR L
[
RETS were evaluated largely against the provisions specified by NUREG-0473, r
i Revision 2 [1].
Updated provisions common to both BWRs and PWRs, as specified
[
by Re.erence 12, were also adopted for the review.
In addition, some changes 1
made specifically to BWRs [13] were also included as added guidance.
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g 1.3 PLANT-SPECIFIC EACKGROUND In response to the NBC's request, the Licensee, Carolina Power and Light E
Company (C P & L), submitted a RETS proposal dated May 31, 1979 [14] on behalf of a
Brunswick Steam Electric Plant Units 1 and 2, which was followed by a n
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submittal of the ODCM [ 15 ].
The Licensee subsequently submitted in August
[
1982 an updated dr af t version of both the RETS [16] and ODCM [17].
In this lattet RETS submit tal, the Licensee followed the model RETS format r
f
( NUREG-0 473 ) for BWRs.
In an initial evaluation by the Franklin Reseach I
Center (FRC), an independent review team, the Licensee 's RETS and ODCM submittals were evaluated against the model RETS ( NUREG-0 4 73, Revision 2) and b
assessed for compliance with the stipulated provisions.
Copies of the draf t review, dated SeptemPer 15, 1982 (18, 19), were delivered to the NRC and the
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Licensee prior to a site visit by the reviewer s, b
The site visit was conducted on October 5, 19 82 by the reviewers with th e participation of plant personnel and the N RC s taf f.
Discusr. ions focu: d on 5
m
' U Franklin Research Center i
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A o.m.oa or he FrerWdin Ir.seture F
e, TER-C550 6-85/8 6 the initial review of the proposed changes to the RETS and on the tech.ical approaches for an ODCM. The deficiencies in the Licensee's proposed !(ETS were considered, deviations from NBC guidelines were pointed out, many differences were clarified, and only a few items remained unresolved pending justification
~~
by the Licensee. Wese issues are summarized in Reference 20.
The final versions of the Brunswick RETS [21] and ODCM [22], dated recember 13, 1962, were cubmitted to the NBC and transmitted to the FBC reviewers together with justifications provided by the Licensee. Also included in the submittal is the PCP [23]. W e documents were subsequently reviewed.
The PCP was reviewed against NBC guidelines dated January 7, 1983 [24]. Final evaluation of RETS was detailed in a comparison report [25] which used NUhEG- 0473, Revision 2 [1], the updated generic provisions specified by the draf t version of NUREG-0472, Revision 3 (12], and provisions specific to BWRs
[13] to evaluate the Licensee's submittal.
The comparison report also incorporates NRC comments [26] which serve as additional guidelines regarding plant-specific issues.
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nklin Research Center A Dumon of The Frar*mn %
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TER-C550 6-85/8 6 2.
REVIEW CRITERIA Review criteria for the RETS and ODCM were provided ')y the NRC in three documents:
NUREG-0472, RETS for PWRs NUREG-0473, RETS for BWRs NUREG-0133, Preparation of RETS for Nuclear Power Plants.
Twolve essential criteria are given for the RETS and ODCM:
1.
All significant releases of radioactivity shall be controlled and monitored.
2.
Of fsite coacentraticas of radioactivity shall not exceed the 10CFR20, Appendix B, Table II limits.
3.
Offsite doses of radioactivity shall be ALARA.
s 4.
Equipment shall be maintained and used to keep of fsite doses ALARA.
5.
Radwaste tank inventories shall be limited so that failures will not cause offsite doses exceeding 10CFR20 limits.
6.
Waste gas concentrations shall be controlled to prevent explosive mixtures.
7.
Wastes shall be processed to shipping and burial ground criteria under a documented program, subject to quality assurance verificatien.
8.
An environmental monitoring program, including a land-use census and an interlaboratory comparison program, shall be implemented.
9.
The radwaste management program shall be subject to regular audits and reviews.
10.
Procedures for control of liquid and gaseous effluents shall be maintained and followed.
11.
Periodic and special reports on environmental monitoring and on C
releases shall be submitted.
12.
Offsite dose calculations shall be performed using documented and approved methods consistent with NRC methodology.
' 4' 00Teronxiin Re..rch cente, J
A Duman of The Frankan insatute
TER-C550 6-85/86 Subsequent to the publication of NUREG-0472 and NUREG-0473, the NBC staff issued guidelines [27, 28), clarifications [29, 30], and branch positions [31, 32, 33, 34] establishing a policy that guides the licensees of operating reactors to meet the intent, if not the letter, of the anodel RETS provisions.
l We NBC branch positions issued since the RETS implementation review began have clarified the model RETS implementation for operating reactors.
Review of the ODCM was based on the followhg NBC guidelines Branch Technical Position, " General Content of the Offsite Dose Calculation Manual"
^
[35]; NUREG-0133 [9]; and Regulatory Guide 1.109 [36). We ODCM format is left to the licensee and may be simplified by tables and grid printouts.
Review of the, PCP was based on the NBC guidelines (24]. He PCP is not intended to coittain a set of detailed procedures; rather, it is the source of basic criteria for the detailed procedures to be developed by the Licensee.
4 anklin Insetute Re
~~-.s_earch Laboratory,Inc.,
TER-C550 6-85/8 6
.h 3.
TECHNICAL EVALUATION 3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEM This section briefly describes the liquid and gaseous ef fluent radwaste treatment systems, release paths, and control systems installed at Brunswick Steam Electric Plant Units 1 and 2; both units are BWPs.
4 3.1.1 Radioactive Liquid Ef fluent Major releases of liquid effluents from the Brun wick plant are discharged via the liquid radwaste effluent line (Figure 1). This eifluent path handles the majority of the radioactive discharges; the effluents are normally collected, processed, and monitored before being released in batches. Other potential effluent lines are the main service water line, the stabilization pond, and the circulating water pit (turbine building sump).
The Licensee plans to install the augmented offgas treatment (ACG) system for the main condenser effluents and has identified the service water from the AOG precooler as a potential effluent line. The Licensee has also identified a potential release from the reactor building component cooling water (service water). Wis includes the effluents froc residual beat removal (heat exchangers A and B), reactor building closed cooling water heat exchangers, Division I residual heat removal pump seal coolers, and Division II heat removal pump seal coolers.
The liquid radwaste effluents are joined with service water and circulating water before b(.ing discharged to the Atlantic Ocean through the discharge canal.
Ef fluent.s from the stabilization pond, on the other hand, lead separately to the canal intake as batch releases.
m 3.1.2 Radioactive Gaseous Ef fluent A gaseous radwaste system is provided for each unit of the Brunswick plant. We processed gases from each unit are routed to the plant main stack
~
(100 m tall) for dilution and elevated releace to the atmosphere (Figure 2).
The radwaste treatment system includes the 30-minute delay line and HEPA As branklin Research Center A Chaman ed The Fr6 huetute
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5 Waste Waste Condensate i
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,r e, y High Purity Wastes Storage yg (Equipment Drains).
Collector P
Fliter
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Demineralizer ->
Sample P
Tank Tank Tank l
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Solid Wastea Radiation Monitor y
q D12-RM-K604 f$
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MediumI!.ow Purity Floor i
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Inlet
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Wastes y
Drain Filter -
4 Floot Drain 1
Systems (Floor Drains)
Conector n
Sample Tank A Liquid Tank g
Shared Radwaste Elfluent o
oy Units 9
t and 2 (Batch)
Ip Waste Chemical Wastes ->
Neutral!zer Scildi tion lank Circulating co Water 1
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Oily Wastes Centrifuge
-y Filter
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' Radia'lon Monitor DeterQent l D12-RMM Wastes Main Service Water (Continuous)-
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Circulating Water Pit (Turbine Building Sump)/(Batch) p,r te uHet Units t AOG Service Water (Continuous) g and 2 Reactor BuildinD Component Cooling Water (Service Water; Continuous) ww Stabitization Pond (Batch) o Composite intake 8
- Not presently available; a radiation monitor will Sampler
- be installed in future modifications Ncn Figure 1.
Liquid Radwaste Treatment Systems, Effluent Paths, and l
Controls for Brunswick Steam Electric Plant Unit,s 1 and 2 l
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Hydrogen d'
- ! 5-uonitor "g
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Augmented 10li m Air e
Ma6n
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Elector Recombiner g
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Off Treatment ->
Unit t Condenser 2
Radiatio s j
Radiation Monitor (15 min. delay)
Delay spe D12-RM-K601(A&B)
~~j Monitor
,r D12-RM K600 j,
R (A& B)
- r
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hydrogen Monitor Radiation 4"
i Monitor i
Main Air Augmented
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Condenser Elector Recombiner
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Off-gas Treatment b
9 System
- l Radiation 30eln.
Monitor (15 min. delay)
Delay pipe D12 RM K601(A&B)
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Gland Seal
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Exhauster Off1as y
lodine & Particulate 18ein.
Samplers I
Hot Shop Vent Systems Radiation Monitor Separato CAC4QH-1264 for Units 1 and 2 Reactor Building Vent N
y, Radiation Monitor AtmosWee VA-AOH-2215 Turbine Butiding Vent
- Not presently available; monitor (s) h will be installed in future modifications ww Om Figure 2.
Gaseous Radwaste Treatment Systems, Effluent Paths, and 4
Controls for Brur.swick Steam Electric Plant Units 1 and 2
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o TER-C550 6-85/8 6 J
filters for eacn unit. The main condenser AOG treatment system originally installed has been retired and is to be replaced by an improved system. This situation is noted in pertinent sections throughout the Licensee's proposed RETS submittal.
Other effluent lines separate for each unit are from the reactor building vent, the turbine building vent, and the hot shop vent.
N 3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS The evaluation of the Licensee's proposed PETS against the provisions of NUREG-0473 included the following (1) a review of information provided in the Licensee's August 1982 submittal [16,17], (2) the resolution of problem areas in diat submittal by means of a site visit [18,19, 20], and (3) a review of the Licensee's December 1982 RETS, ODCM, and PCP submittals [21, 22, 23].
3.2.1 Ef fluent Instrumentation The objective of the RETS with regard to effluent instrumentation is to ensure that all significant releases of radioactivity are monitored. The RETS specify that all effluent monitors be operable and alarm / trip setpoints be determined to ensure that radioactivity levels do not exceed the maximum permissible concentration (MPC) set by 10CFR20. To further ensure that the instrumentation functions properly, surveillance requirements are needed in the specifications.
3.2.1.1 Radioactive Liquid Ef fluent Monitoring InsF;umentation A radiation monitor (D12-RM-K604) has been installed for the liquid radwaste effluent line (Figure 1), which provides automatic isolation in the event that an excessive 12 Vel of radioactivity is detected. The Licensee has y
also provided a monitor (D12-RN-6 0 5) for the main service water, and plans to install a composite sampler for the stabilization pond. For the latter, the existing -apability is to sample the effluents prior to each release. To
-^
furtner prevent inadverter i releases, the Licensee has made a commitment to
" UOO Franklin Research Center A Dhaman of The Frarden innaeute
TER-C550 6-85/8 6 lock the valve whenever the releases are not being made via the stabilization pond. The circulating water pit (turbine building sump) does not have a monitor or a composite sampler. The Licensee explained that sump effluents normally contain only low-level activities. An alternative proposed by the Licensee is to conduct an extensive sampling program prior to each release and also to provide composite sampling on a monthly basis. The Licensee also plans to install a monitor on each service water line identified for the AOG
~
precooler and for the reactor building component cooling water, as described in Section 3.1.1.
These existing monitoring capabilities and Licensee-proposed alternatives have provided adequate assurance that the provisions of NUREG-0473 for the radioactive liquid effluent monitoring instrumentation are ret.
332.1.2 Radioactive Gaseous Effluent Monitoring Instrumentation The plant main stack is provided with a redundant monitoring system capable of monitoring noble gases, iodines, and particulates. The noble gas monitor is designated as D12-RM-K600 (A and B).
The main condenser air ejector for each unit also has a redundant noble gas monitor (D12-RM-K601, A and B) capable of automatically isolating the discharge from the air ejector.
Radiation monitors are also provided for the reactor building vent (CAC-AQH-12 64) and the turbine building vent (VA-AQH-3215). For the hot shop vent, only iodine and particulate samplers are provided; the Licensee explained that noble gas contamination level in the hot shop is normally too low to warrant concern. The Licensee also plans to have a radiation monitor (identification number to be specified) for the main condenser off-gas
(
treatm@t (A0G) system once the system is installed. This proposed AOG monitor is equipped with an alarm, but not with automatic isolation capability as specified by NUREG-0473.
The existing and proposed monitoring capabilities provided by the Licensee have met the intent of NUREG-0473 for radioactive gaseous effluent monitor instrumentation.
l As branklin Rese_ arch Center
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_ _ _ ~ _ _ _ _ _ _ _ _ _ _____ _ _ _ _ _ _ _ _ _. _ __
t TER-C550 6-85/8 6 3.2.2 Concentration and Dose Rates of Effluents 3.2.2.1 Liquid Ef fluent Concentration In Section 3.11.1.1 of the Licensee's submittal, a commitment is made to
~
maintain the concentration of radioactive liquid effluents released to unrestricted areas to within 10CFR20 limits, and, if the concentration of liquid effluents exceeds these limits, the concentration will be restored I
without delay to a value equal to or less than the MPC specified in 10CFR20.
i
=
All batches of radioactive liquid effluents from the release tanks including
.a sample tanks, detergent drain tank, salt water release tanks, and circulating water pit are sampled and analyzed in accordance with a sampling and analysis program which meets the intent of NUREG-0473. Continuous releases are from
~
the stabilization pond and service wa*.er effluent discharges.
'15e Licensee j
l proposed to sample the principal gamma emitters (Table 4.11.1-1 ot the Licensee's submittal) for the stabilization pond and service water oischarg es.
If these samples indicate concentrations of any gamma-emittir.g
-6 radionuclides greater than the value of 5 x 10 Ci/ml (10 times the j
LLD), then a more extensive sampling will be followed (Table 4.11.1-2 of the Licensee's submittal). It was determined that the Licensee-proposed 1
alternative meets the intent of NUREG-0473.
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3.2.2.2 Gaseous Ef fluent Dose Rate
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In Section 3.11.2.1 of the Licensee's submittal, a commitment is made to
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- t 14aintain the offsite dose rate from radioactive gaseous effluents to areas at
- 4 'ife a y
h._ ' s and beyond the site boundary within 10CFR20 limits, or the equivalent dose k
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rate values prescribed by Section 3.11.2.1 of NUREG-0473.
If the dose rate of d$$*,..J l h
gaseous effluents exceeds these limits, it will be restored without delay to a
'k
, fi.h Y ey value equal to or less tilan these limits. This commitment satisfies the pd.Jf l.i p
k.:.N L 4
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provisions of NUREG-0473.
The radioactive gaseous waste sampling and analysis program (Table 4.11.2-1 of the Licensee's submAttal) provides adequate sampling and analysis of the vent discharges, including the substreams, and therefore meets the intent of NUREG-0473.
, b Franklin Research Center A DMason ci The Frarwen insuture m
TER-C550 6-85/8 6 3.2.3 offsite Doses from Effluents The objective of the RETS with regard to offsite doses from effluents is to ensure dhat offsite doses are kept ALARA and are in accordance with 10CFR50, Appendix I, and 40CFR190. The Licensee has made a commitment to (1) meet the quarterly and yearly dose limitations for liquid effluents, per Section II.A of Appendix I,10CFR50; (2) restrict the air dosec for beta and gamma radiation in unrestricted areas as specified in 10CFR50, Appendix I, Section II.B; (3) maintain the dose level at and beyond the site coundary frem release of iodine-131, tritium, and all radionuclides in particulate form with
, half lives greater than 8 days within the design objectives of 10CFR50, Appendix I, Section II.C; and (4) limit the annual dose from radioactive materials from the plant to any member of the public to within the requirements of 40CFR190.
In each pertinent section, the Licensee has made a ccmmitment to perform dose calculations in accordance with methods given in the ODCM. This satisfies the intent of NUREG-0473.
3.2.4 Effluent Treatment a
The objectives of the RETS with regard to effluent treatment are to ensure that wastes are treated to keep releases ALARA and to satisfy the provisions of Technical Specifications governing the maintenance and use of radwaste treatment equipment. The Licensee has made a commitment to use the liquid (Section 3.11.1.3 of the Licensee's submittal) radwaste treatment systems when the projected dose, averaged over 31 days, exceed 25% of the annual dose design objectives, prorated monthly. For gaseous radwaste, the Licensee proposes to treat the effluents by operating the gaseous radwaste treatment system whenever the main condenser air ejector system is in operatien. This effluent treatment system includes the AOG treatment system, which the Licensee plans to install in the near future. The Licensee's existing gaseous radwaste treatment system includes the 30-minute offgas holdup line and the stack filter house filtration. The Licensee has also made a commitment to use the ventilation exhaust treatment system when the projected monthly dose exceeds the limits specified by NUREG-0473. The Licensee has also made a te bd Franklin Research Center A CMseon d The Frm Insature
TER-C 5 50 6-8 5/8 6
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.~~s. g commitment in the ODCM to calculate the projected dose on a monthly basis.
It is determined that the Licensee's proposal meets the intent of NUREG-0473.
A 3.2.5 Radioact iv ity Inventory Limits T
The objective ot the RETS with regard to the liquid tank inventory limits is ts ensure tha t the rupture of a radwaste tank would not cause of fsite doses greater than the limits set in 10CFR20 for non-occupational exposure.
- Also, the gaseous radicactivity release inventory is to be limited to within a rate of 100 microcuries per second per megawatt thermal, during the operation of p, -y&y; p ',.'
a
- r
n
> 3.1ly; ' 'Ti., l the main condenser air ejector.
The Licensee has provided a limit of 10
..p. a,
W.-
g",y;;lf curies for the condensate storage tanks (1 and 2) and any outside temporary
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tank s.
For radioactivity releases from the main condenser air ejector, a M_ f g 3 #7
%:r. hk release rate limit of 243,600 microcuries/sec has been set for noble gases,
.,h..
([yhi '.?
I, which is based on the rated thermal power of 2436 MWt at both Brunswick Units
[.,
1 and 2.
The Licensee's commitment to comply with these radioactivity
. Ah e
+
M?M M inventory and release rate limits satisfies the intent of NUREG-047 3.
d.hD.. 4 p(f2..".9%
- 1 :?.. +
. Jw-i 3.2.6 Eyplosive Gas Mixtures f C
' %.U. U$.',
The ob]ective of the RETS with regard to explosive gas mixtures is to
' dl?-
4
%.'sni 1 3 prevent hydrogen explosions in waste gas systems.
The Licensee claimed tha m f'.'.Q..C
.,4 W' ?
- ' J M ~ %' ic,,i 4 the waste gas system is designed to withstand a hydrogen explosion and has
- O thus made a ccmmitment to maintain a safe concentration of hydrogen in the 7 gg.g
'6.;3M -
main condenser offgas treatment system using redundant hydrogen monitoring F
r.y.%. y systems for recombiner trains A and B once the recombiner trains are installed
? [
and become operational. This commitment satisfie.s the intent of NUREG-0473.
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3.2.7 Solid Radwaste System
@.[,',:.f f. } '
( 'I.Th Y The objective of thc RETS with regard to the solid radwaste system is to Tf i. M 5.[.
1-3 s&&%. -. :
ensure that radwaste will be properly processed and packaged before it is
' I i.' S P.' 5
- 4.. -
m.
shipped to the burial site.
Specification 3.11.3 of NUREG-0473 provides for YQy['.p f8
[
the establishment of a PCP, or the equivalent, to show compliance with th i s objective.
The Licensee has made a commitment to implement such a program in
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M U Franklin Research Center
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A Dme.oc 4 The Frenen insature
TER-C550 6-85/8 6 accordance with a PCP and to thus ensure that radwaste is properly processed and packaged before it in shipped to the burial site. This meets the intent of NUREG-0473.
3.2.8
,Pfdiological Environmental Monitoring Program The objectives of the RETS with regard to environmental monitoring are to ensure that an adequate and full-area-coverage environmental monitoring program exists and that the 10CFR50, Appendix I requirements for technical specifica-O.
tions on environmental monitoring are satisfied.
In all cases, the Licensee
~
has followed NUREG-0473 guidelines, including the Branch Technical Position dated November 1979 [32), and has provided an adequate number of sample locations for pathways identified. The Licensee's methods of analysis and maintenance of yearly records satisfy the NRC guidelines and meet the intent of 10CFR50, Appendix I.
The Licensee has also made a commitment to document the environmental monitoring sample locations in the ODCM, which meets the
+
intent of NUREG-0473. The specification for the land use census satisfies the provisions of Section 3.12.2 of NUREG-0473 by providing for an annual census in the specified areas. The Licensee participates in an interlaboratory comparison program approved by the NRC and reports the results in the Annual Radiological Environmental Operating Report, wnich also meets the intent of EUREG-0473.
3.2.9 Audits and Reviews The objective of the RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring programs are properly conducted. The Licensee's administrative structure designates the Plant Nuclear Safety Committee (PNSC) and the Performance Evaluation Unit (PEU) of the Corporate Quality Assurance Department as the groups responsible for the review and audit of the radiological environmental monitoring program, j
The PNSC is responsible for reviewing the procedures associated with these programs. The PEU is responsible for auditing the program as of ten as is specified under NUREG-0473.
A Ubd Franklin Research Center A De of The Frankhn Instate P
TER-C550 6-85/8 6 3.2.10 Procedures and Records The objective of the RETS with regard to procedureb is to satisfy the written procedures specified in NUREG-0473 for implementing the ODCM, the PCP, and the quality program (QA) program.
It is also an objective of RETS to properly retain the documented records in relation to the environmental monitoring program and certain QA procedures. The Licensee has made a commitment to establish, implement, and maintain written procedures for the l
PCP, ODCM, and QA program according to the updated provisions of NUREG-0472
[12 ]. The Licensee intends to retain the records of the radiological environmental monitoring program for the duration of the facility operating license. It is determined that the Licensee has met the intent of NUREG-0473.
3.2.11 Reports The objective of the RETS with regard to administrative controls is to ensure that appropriate periodic and special reports are submitted to the NRC, and that these reports meet the requirements of 10CFR50.36a.
3.2.11.1 Routine Reports In Section 6.9.1.7 of the Licensee's submittal, a commitment is made to provide the NRC with an annual radiological environmental operating report that includes summaries, interpretations, and statistical evaluation of the results of the environmental surveillance program. The report also includes a summary of the radiological environmental monitoring program, the results of the land use censuses, and the results of Licensee participation in an interlaboratory comparison program specified by Specification 3.12.3 of NUREG-0473.
In Section 6.9.1.9 of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent release reports to the NRC.
The Licensee proposes to submit semiannual reports for each year according to the following schedule:
(1) within 60 days af ter January 1, (2) within 90 days af ter January 1, and (3) within 60 days af ter July 1.
Schedules 1 and 3 are according to NUREG-0473, and include a summary of the liquid, gaseous, and 000 Franklin Research Center 4 Dmsen of The Frankan insatue
TER-C550 6-85/8 6 solid waste releases with data on a quarterly basis; a report of solid waste shipped offsite during the report period; and a description of the unplanned release from the site. Schedule 2 includes the annual summary of hourly meteorological data and an assessment of the radiation doses during the previous calendar year.
'Ihe extension of 30 days for schedule 2 (as opposed to using schedule 1 which is specified in NUREG-0473) was requested by the Licen ee so that a more adequate review could % conducted. This request was granted by the NIC [26]. These reporting commitments meet the intent of NUREG-0473.
3.2.11.2 Non-Routine Reports In the Licensee's submittal, a commitment is made to provide a special report (according to Section 6.9.2 of the Licensee's submittal) for each of the following in NUREG-0473:
o exceeding liquid effluent dose limits specified in Specifications 3.11.1.2 and 3.11.1.3 o exceeding gaseous effluent dose rate limits specified in Specifications 3.11.2.2, 3.11.2.3, and 3.11.2.4 o exceeding total dose limits specified in Specification 3.11.4 o measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting level of Table 3.12.2.
These reporting commitments meet the intent of NUREG-0473.
3.2.12 Implementation of Major Programs One objective of the administrative controls is to ensure that implementation of major programs such as the ODCM, PCP, and major changes to the radiocctive waste treatment system follow appropriate administrative procedures. The Licensee has made a commitment to review, report, and implement major programs such as the ODCM, PCP, and major changes to the radioactive waste treatment system. This commitment meets the intent of NUREG-0473.
N b Franklin Research Center A Ohman of The Frankin insasute
TER-C550 6-85/8 6 3.3 OFFSITE DOSE CALCULATION MANUAL (ODCM)
As cpecified in NUREG-0473, the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate of fsite doses and maintain the operability of the effluent systems. As a minimum, the ODCM should provide equations and methodology for the following topics:
o alarm and trip.setpoint on effluent instrumentation o liquid effluent concentration in unrestricted areas o gaseous effluent dose rate at or beyond the site boundary o liquid and gaseous effluent dose contributions o liquid and gaseous effluent dose projections.
In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems. Of course, these diagrams should be consistent with the systems being used at the station. A description and location of samples in support of the environmental monitoring program are also needed in the ODCM.
3.3.1 Evaluation The Licensee has followed the methodology of NUREG-0133 [9] to determine the alarm and trip setpoints for the liquid and gaseous effluent monitors, which ensures that the maximum permissible concentrations, as specified in 10CFR20, will not be exceeded by discharges from various liquid or gaseous release points. Ib augment conservatism in the case of simultaneous releases, the Licensee has introduced a conservative factor of 10 for liquid effluent setpoint calculations.
For gaseous effluent setpoint calculations, fractional release concentration limits based on the plant experience are assigneda 0.1 for each turbine building vent; 0.2 for each reactor building vent; and 0.4 for the main stack.
The Licensee demonstrated the method of calculating the radioactive I
liquid concentration by describing in the ODCM the means of collecting and As branklin Research Center A Dmsean of The FrankAn insuewte
4 TER-C5506-85/86 cntlysing representative samples prior to and after releasing liquid effluents into the circulating water discharge. The method provides added assurance of
+
compliance with 10CFR20 for liquid effluent releases.
Methods are also included for showing that dose rates at or beyond the cite boundary due to noble gases, radioiodines, tritium, and particulates with hclf-lives greater than 8 days are in compliance with 10CFR20.
In this calculation, the Licensee has considered effl':ent releases from the turbine building, the reactor building, and the main stack; those releases are being treated as ground level, mixed level, and elevated level, respectivaly.
In
, cll cases, the Licensee has used the highest annual average values of relative l
concentration (X/Q) and relative deposition (Q/Q) to determine tr.1 controlling locations. ' For elevated releases from the main stack, the Licensee has also considered the direct radiation contribution from exposure to the finite t
plume. The Licensee intends to use the maximally exposed individual and the critical organ as the reference receptor. The Licensee has also considered pathways from inhalation, food, and ground-plane deposition, although the ingestion pathway from the ground-plane deposition is not strictly required for~ gaseous dose' rate calculations. The Licensee has demonstrated that the d::cribed methods and relevant parameters have followed the conservative approaches provided by NUREG-0133 and Regulatory Guide 1.109.
However, since th2 Licensee has not included iodine-133 in the sampling analysis program, a statement should be added to record the method tc account for iodine-133 ir.
tha dose rate calculation.
Evaluation of the cumulative dose is to ensure that the quarterly and Ennual dose design objectives specified in RETS are not exceeded.
For liquid releases, the Licensee has identified fish and invertebrate consumption as the two viable pathways.
In the calculation, the Licensee has ured near-field and far-field dilution _ factors specific to the plant; all other key parameters follow the suggested values given in 9
'ory Guide 1.109.
As in the case of dose rate calculation, the License used the maximally exposed individual as the reference receptor. To correctly assess the cumulative dose, the Licensee intends to estimate the dose once per 31 i
drys.
ranidin Research Center A Danuen af The Frenten inemene
TER-C550 6-85/S 6 Evaluation of the cumulative dose from noble gas releases includes both beta and gamma and air doses at and beyond the site boundary. The critical organs under consideration are the total body and skin for gamma and beta radiation, respectively. Again, the Licensee has used the maximum (X/Q) values as discussed earlier and has followed the methodology and parameters of NUREG-0133 and Regulatory Guide 1.109.
For radioiodines, tritium, and particulates with half-lives greater than 8 days, the Licensee nas provided a method to demonstrate that cumulative
~
~
doses calculated from the release meet both quarterly and annual design cbjectives. The Licensee has demonstrated a method of calculating the dose using maximum annual average (X/Q) values for the inhair %n pathway and has included (D/Q) values for the food and ground-plane pathtfays, as well as the
~
exposure constant (V) for the gamma radiation from the elevated finite plume, which is consistent with the methodology of NUREG-0133. As in the case for dose rate calculation, the Licensee should also record the method to account for iodine-133 in the dose calculation.
1 Using the existing methodology for gaseous and liquid dose calculations, the Licensee has demonstrated a procedure to determine the monthly dose and to ensure that the design objectives for the liquid radwaste system and the ventilation exhaust system are not exceeded.
Adequate flow diagrams defining the effluent paths and components of the radioactive liquid and gaseous waste treatment systems have been provided by
..(
the Licensee. Radiation monitors specified in the Licensee-submitted RETS are Spgg) e.., g.. n also properly identified in the flow diagrams.
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.hI The Licensee has provided a description of sampling locculons in the ODCM and has identified them in Table 4.1 and also in Figures 4.0-lb through 4.0-1d id
/ _.w of that document. This description is consistent with the sampling locations l.; $,%i z we specified in the Licensee's RETS Table 3.12.1-1 on environmental monitoring.
..byf; '9, In summary, the Licensee's ODCM uses documented and approved methods that 1-fJ *'*'"l.
f.#,;
are consistent with the methodology and guidance in NUREG-0133, and therefore a 4. -
g :.
?.d
.hb. *g-
. -f is an acceptable reference.
W...j! 'E 4s branklin Research Cente-A DMeson of The Frank 5n insatute
I 1
TER-C550 6-85/8 6 3.4 PROCESS CONTROL PROGRAM (PCP)
NUREG-0472 specifies that the Licensee develop a PCP to ensure that the processing and packaging of solid radioactive wastes will be accomplished in compliance with 10CFR50,10CFR71, and other federal and state regulations or requirements governing the of fsite disposal of the low-level radioactive waste.
The PCP is not intended to contain a set of detailed proceduraa; rather,
,C it is the source of basic criteria for the detailed procedures to be developed by the Licensee. The criteria used for the PCP are to address only today's requirements [24]. 'Ihe uncertainty about PCP requirements results from the recent premulgation of 10CFR61, " Licensing Requirements for Land Disposal of Radioactive Waste."
The NRC staff's technical positions are presently being developed by the Division of Waste Management.
3.4.1 Evaluation The Licensee-submitted PCP contains ccmmitments for the establishment of a management system and control program to monitor effective waste solidifi-cation by the approved contractors / vendors. The commitments include solidification of liquid wet wastes prior to shipment of fsite, using approved procedures for packaging the radioactive waste, and meeting the disposal site specifications and DOT shipping regulations for the solidified liquid wastes.
In addition, the Licensee will follow the current plant procedures to implement ALARA requirements. These commitments satisfy the intent of the NRC guidelines (24].
In summary, it is concluded that the Licensee complies with the NRC criteria for PCP implementation except for oily wastes for which the Licensee has not specifically made any commitment. The Licensee has made a commitment to establish technical specifications for radwaste processing and packaging y
consistent with NBC guidelines.
A EJ ranklin Research Center A Ommon of The Frankan insneute
c, TER-C5506-85/86 4.
COtCLUSIONS Table 1 summarizes the results of the final review and evaluation of the submittal for the Brunswick Steam Electric Plant Units 1 and 2 proposed Radiological Effluent Technical Specifications (RETS). The following conclusions have been reached:
1.
The Licensee's proposed Radiological Ef fluent Technical Specifications (RETS) submitted December 13, 1982 meet the intent of NUREG-0473, " Radiological Ef fluent Technical Sp9cifications."
2.
The Licensee's Offsite Dose Calculation Manual (ODCM) submitted December 13, 1982 uses documented and approved methods and is consistent with the criteria of NUREG-0133. However, a statement should be added to the ODCM the method to account for iodine-133 in the dose rate and dose calculations.
3.
The Licensee's Process Control Program (PCP), submitted December 13, 1982 and evaluated against NRC guidelines [24), complies with the NRC criteria for implementing the PCP, except for oily wastes.
nklin Research Center A % orner, m m.
Table 1.
Evaluation of Proposed Radiological Ef fluent Technical Specifications (RETS),
Brunswick Steam Electric Plant Units 1 and 2 2
Y f$
Technical Specifications q'f NRC Staff tbdel Replaces or Updates RETS NUREG-0473 Licensee Proposal Exlet ing Tech. Spec.
p RETS Requirement (Section)
(Section)
(Section)
Evaluation h
Ef fluent instrumentation 3/4.3.3.10, 3/4.3.3.11 3/4.3.5.8, 3/4.3.5.9 3/4.3.5 Meets the intent of NRC criieria n
.S Radioactive Effluent 3/4.11.1.1, 3/4.11.2.1 3/4.11.1.1, 3/1.11.2.1 tbt addressed Meets the intent Concentrations of NRC criteria l
Offsite Doses 3/4.11.1.2, 3/4.11.2.2, 3/4.11.1.2, 3/4.11.2.2, tbt addressed Meets the intent 3/4.11.2.3, 3/4.11.4 3/4.11.2.3, 1/4.11.4 of NBC criteria l
l Effluent Treatment 3/4.11.1.3, 3/4.11.2.4 3/4.11.1.3, 3/4.11.2.4, Ibt addressed Meets the intent j
3/4.11.2.5 of NRC criteria i
U Radioactivity 3/4.11.1.4, 3/4.11.2.6 3/4.11.1.4, 3/4.11.2.7 tbt addressed Meets the intent 8
inventory Limits of NRC criteria Explosive Gas Mixtures 3/4.11 2.5 3/4.11.2.6 tut addressed Meets the intent of NRC criteria Solid Radioactive Waste 3/4.11.3 3/4.11.3 tbt addressed Meets the intent of NRC criteria Fnvironmental ibnitoring 3/4.12.1 3/4.12.1 tbt addressed Meets the intent of NRC criteria Audits and Reviews 6.5.1, 6.5.2 6.5.3, 6.5.5 6.5.2, 6.5.3 Meets the intent of NRC criteria H
Procedures and Records 6.8, 6.10 6.8, 6.10 6.8, 6.10 Meets the intent to of NRC criteria on Reports 6.9.1.11, 6.9.1.12, 6.9.1.7, 6.9.1.9, tbt addressed, Meets the intent g
6.9.2 6.9.2 6.9.2 of NRC criteria cn 5)
Implementation of 6.13, 6.14, 6.15 6.13, 6.14, 6.15 tut addressed Meets the intent Q
Major Programs of NRC criteria cn cn
TER-C550 6-85/8 6 5.
REFERENCES 1.
" Radiological Ef fluent Technical Specifications for Boiling Water Reactor s," Rev. 2 NIC, July 1979 NUREC-0473 2.
Title 10, Code of Federal Regulations, Part 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to i
Meet the Criterion, 'As Low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents" 3.
Title 10, Code of Federal Regulations, Part 50, Appendix I, Svetion V,
" Effective Dates" 4.
Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation" 5.
Title 40, Code of Federal Regulations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations" 6.
Title 10, Code of Federal Regulations, Part 50, Appendix A,
" General Design Criteria for Nuclear Power Plante" 7.
Title 10, Code of Federal Regulations, Part 50, Appendix Bc " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" l
8.
" Radiological Effluent Technical Specifications for Pressurized Water Reactor s," Rev. 2 NBC, July 1979 NUREG-0472 9.
" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications" NRC, October 1978 NUREG-0133 I
10.
C. Willis and F. Congel (NBC)
"Sutuary of Draf t Contractor Guidance of RETS" Presented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19,1982
~
11.
F. Congel (NBC)
Memo to RAB Staf f (NRC)
Subjecu Interim Changes in the Model Radiological Ef fluent Technical Specifications (RETS)
August 9,1982 e
. 24 ranklin Research Center A Dwman of The Franken tresouse
e e
TER-C550 6-85/8 6 12.
" Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draft 7',
intended for contractor guidance in reviewing RETS proposals for operating reactors NIC, September 1982 NUREG-0472 13.
W. Meinke (NEC)
Memo to M. Strum (Yankee Atomic Electric Company)
Subject:
PWR-Specific Changes for NUREG-0472/3, Rev. 3 September 20, 1982 e
14.
Brunswick Radiological Effluent Technical Specifications ib Carolina Power and Light Company, May 31, 1979 NIC Docket Nos. 50-324, 50-325 g
15.
Brunswick Of fsite Dose Calculation Manual Carolina Power and Light Company, June 1979 NRC Docket Nos. 50-324, 50-325 16.
Brunswick Radiological Ef fluent Technical Specifications (Draf t)
Carolina Power and Light Company, August 1982 NRC Docket Nos. 50-324, 50-325 17.
Brunswick Offsite Dose Calculation Mancal (Draf t)
Carolina Power and Light Company, Auguct 1982 NRC Docket Nos. 50-324, 50-325 18.
" Comparison of Specification NUREG-0473, Radiological Ef fluent Technical Specifications for BWRs, vs. Licensee Submittal of Radiological Effluent Technical Specifications for Brunswick Steam Electric Plant Units 1 and 2" (Draf t)
Franklin Research Center, September 15, 1982 19.
Technical Review of Offsite Dose Calculation Manual for Brunswick Steam 5
Electric Plant Units 1 and 2 (Dr af t)
Franklin Research Center, September 15,'1982 20.
Franklin Research Center Letter of Transmittal to NRC
Subject:
Trip report on site visit to Brunswick Steam Electric Plant Units 1 and 2 October 5,1982 21.
Brunswick Radiological Effluent Technical Specifications (RETS)
Carolina Power and Light Company December 13, 1982 NRC Docket Nos. 50-324, 50-325 nklin Research Center A Omsaan of The Frank 5n kuntute 4
r TER-C550 6-85/8 6 22.
Brunswick Offsite Dose Calculation Manual Carolina Power and Light Company, December 13, 1982 NRC Docket Nos. 50-324, 50325 23.
Brunswick Process Control Program Carolina Power and Light Company, December 13, 1982 NBC Docket Nos. 50-324, 50-325 24.
C. Willis (NRC)
Letter to S. Pandey (FDC) 7 j
,Q, y."/,$1".% t ff.;j:tff.y
Subject:
Guidance on the Review of Process Control Program (PCP) j?N January 7, 1983
..>g y 3-25.
"Cor:parison of Specification NUREG-0473, Padiological Ef fluent Technical
[ py)fhj t }
j Specifications for BWRs, vs. Licensee Final Submittal, dated December 13,
. __ f ~
1982, of Radiological Ef fluent Technical Specifications for Brunswick Steam Electric Plant" Franklin Research Center, February 15, 1983 26.
W. Meinke (NRC)
Memo to S. Pandey (FRC)
Subject:
Additional Comments to FRC RETS Review on Brunswick Steam Electric Plant February 4,1983 27.
C. Willis (NRC)
Letter to Dr. S. Pandey (FRC)
Subject:
Changes to RETS requirements following meeting with Atomic Industrial Forum (AIF)
November 20, 1981 28.
C. Willis (NRC)
Letter to Dr. S. Pandey (FRC)
Subject:
Control of explosive gas mixture in PWRs December 18, 1981 29.
C. Willis and F. Congel (NRC)
" Status of NBC Radiological Ef fluent Technical Specification Activities" Presented at the AIF conference on NEPA and Nuclear Regulations, Washing toq, D.C.
October 4-7c 1981 30.
C. Willis (NBC)
Memo to P. C. Wagner (NIC)
" Plan for Implementation of RETS for Operating Reactotts" 4
November 4,1981
_ b Franklin Research Center A Chemon of The frankhn insature
l l
TER-C5506-85/86 31.
W. P. Gammill (NRC)
Memo to P. C. Wagner (NBC) j
" Current Position on Radiological Ef fluent Technical Specifications (RETS) Including Explosive Gas Controls" October 7,19 81 32.
"An Acceptt.ble Radiological Environmental Monitoring Program" Rsdiological Assessment Branch 'Itchnical Position, Revision 1 November 1979 33.
W. P. Gammill/F. J. Congel (NPC)
Memo to ETSB/RAB (NRC)
" Radiological Ef fluent Technical Specifications (RETS) Provisions for I - 133" November 29, 1982 34.
Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40CFR190)
NBC, February 1980 NUPEG-0543 35.
" General Contents of tr.e Offsite Dose calculation Manual," Revision 1 Branch Technical Position, Radiological Assessment Branch February 8,1979 36.
Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR50, Appendix I NRC, October 1977 Regulatory Guide 1.109, Revision 1
, A 000hranklin Research Center
^ >=en ce w rre %,
__