ML20087N259

Proposed Tech Spec Changes to Radiological Ets,Offsite Dose Calculation Manual & Process Control Manual

ML20087N259
Person / Time
Site:	Davis Besse
Issue date:	03/15/1984
From:	TOLEDO EDISON CO.
To:
Shared Package
ML20087N246	List: ML20087N245 ML20087N247 ML20087N252 ML20087N259 ML20087N263
References
NUDOCS 8404030274
Download: ML20087N259 (67)

Text

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DEFINITIONS The following DEFINITIONS will be added to this section SOURCE CHECK 1.29 A SOURCE CHECK shall be the observation of channel upscale response when the channel sensor is exposed to a radioactive source.

PROCESS CONTROL PROGRAM 1.30 A PROCESS CONTROL PROGRAM (PCP) shall provide details for the sampling, analysis, and evaluation from which SOLIDIFICATION or DEWATERING radioactive wastes from liquid systems is assured.

SOLIDIFICATION 1.31 SOLIDIFICATION shall be the conversion of wet radioactive wastes into a form that meets destination waste disposal site criteria by removal of freestanding water through chemical processes.

f OFFSITE DOSE CALCULATION MANUAL (00CM) 1.32 The OFFSITE DOSE CALCULATION MANUAL (00CM) shall be a manual containing the methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints. Requirements of the 00CM are provided in Specification 6.14.

GASEOUS RA0 WASTE TREATMENT SYSTEM 1.33 The GASEOUS RA0 WASTE TREATMENT SYSTEM is a system that is designed and installed to reduce radioactive gaseous effluents by collecting primary coolant system offgases and providing for decay for the purpose of reducing the total radioactivity prior to release to the environment.

VENTILATION EXHAUST TREATMENT SYSTEM

1.34 A VENTILATION EXHAUST TREATMENT SYSTEM is a system that is designed l

and installed to reduce radioactive material in particulate form in r- effluents by passing ventilation or vent exhaust gases through HEPA filters for the purpose of removing particulates from the gaseous exhaust stream prior to the release to the environment. Engineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

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v DEFINITIONS PURGE-PURGING 1.35 PURGE OR PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, con-centration or other operating condition, in such a manner that replacement air or gas is' required to purify the confinement.

VENTING 1.36 VENTING is the 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 imply a VENTING process.

MEMBER (S) 0F THE PUBl.IC 1.37 MEMBER (S) 0F THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for-recreational, occupational or other purposes not associated with the plant.

SITE BOUNDARY-1.38 The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise controlled by the licensee.

UNRESTRICTED AREA 1.39 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 expcsure to radiation and radioactive materials, or any area within the SITE BOUh0ARY used for residential quarters or for industrial, <

commercial, institutional, and/or recreational purposes. The definition of UNRESTRICTED AREA used in implementing the Radiological Effluent Technical Specifications has been expanded over that in 10 CFR 20.3(a)(17). The UN-RESTRICTED AREA boundary may coincide with the exclusion _(fenced) area bound-ary, as defined in 10 CFR 100.3(a), but the UNRESTRICTED AREA does not include

' areas over water bodies. The concept of UNRESTRICTED AREAS, established at or beyond the SITE BOUNDARY, is utilized in the LIMITING CONDITIONS FOR OPERATION to keep levels of radioactive materials in liquid and gaseous effluents as low as is reasonably achievable, pursuant to 10 CFR 50.36a.

DEWATERING 1.40 DEWATERING is the conversion of wet radioactive wastes into a form that meets destination waste disposal site criteria by removal of freestanding water through physical processes.

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TABLE 1.2 FREQUENCY NOTATION NOTATION FREQUENCY S At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

D At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

W At least once per 7 days.

M At least once per 31 days.

Q At least once per 92 days.

SA At least once per 6 months.

R At least once per 18 months.

S/U Prior to each reactor startup-P Prior to each release.

N/A Not applicable.

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INSTRUMENTATION RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION i

LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-15 shall be OPERABLE with their alare/ 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 and adjusted in accordance with the methodology and parameters in the OFFSITE DOSE CALCULA-TION MANUAL (00CM).

APPLICABILITY: At all times.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel alarm / trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive

. liquid effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b.. With less than the minimum number of radior;tive liquid effluent .

monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-15. Exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.9 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION AND CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-15.

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TABLE 3.3-15 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION T

w Ul ' MINIMUM El CHANNELS .

INSTRUNENT OPERABLE APPLICABILITY ACTION El 1. Gross Radioactivity Monitors ra Providing Alarms and Automatic Termination of Release, g a. Liquid Radwaste Effluent Line 1 (1) 18 i (either Miscellaneous or Clean, but not both simultaneously)

2. Flow Rate Measurement Devices

a. Liquid Radwaste Effluent Line 1 (1) 19

b. Dilotion Flow to Collection Box 1 (1) 19

3. Gross Beta or Gamma Radioactivity Monitors Providing Alarm But Not

' Providing Automatic Termination of Release

a. Turbine Building / Storm Sewer Drain 1 (1) 19, 20 1

TABLE 3.3-15 (Continued) -

TABLE NOTATION (1) During radioactive releases via this pathway ACTION 18 With the number of channels OPERABLE less than required by -

the Minimum Channels OPERABLE requirement, effluent releases may be resumed, provided that prior to initiating a release:

1. At least two independent samples are analyzed in accordance with Specification 4.11.1.1.3 for analyses performed with each batch;

2. At least two independent verifications of the release rate calculations are performed;

3. At least two independent verifications of the discharge valving are performed; Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 19 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via ,

this pathway may continue provided the flow rate is estimated at.least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. Pump curves may be used to estimate flow.

ACTION 20 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for gross radioactivity (beta or gamma) at a lower limit nf detection of at least 10-7 pCi/ml.

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TABLE 4.3-15 k RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS G

CHANNEL FUNCTIONAL

$ CHANNEL CHECK SOURCE CHECK CHANNEL CALIBRATION TEST INSTRUMENT E

q 1. Gross Beta or Gamma Radioactivity g Monitors Providing Alarm and Automatic Isolation *

a. Liquid Ra'dwaste Effluents Line D II) P R(3) g(2)

, 2. Flow Rate Monitors

a. Liquid Radwaste Effluent Line D I4) N.A. R Q

b. Dilution Flow to Collection Box D I4) N.A. R Q i

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TABLE 4.3-15 (Continued)

TABLE NOTATION (1) During releases via this pathway.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if the instrument indicates measured levels above the alarm / trip setpoint.

(3) The initial CHANNEL CALIBRATION for radioactivity measurement instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards should permit calibrating the system over its intended range of energy and rate capabilities.

For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration should be used, at intervals of at least once per eighteen months. For high range monitoring instrumentation, where calibration with a radioactive source is impractical, an electronic calibration may be substituted for the radiation source calibration.

(4) CHANNEL CHECK shall consist of verifying indication of tiew during periods of release. CHANNEL CHECK shall be made at least once daily on any day on which continuous, periodic, or batch releases are made.

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, INSTRUMENTATION RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.10 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-16 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 and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 3.3-16.

ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel alarm / trip setpoint less conservative than required by the above Specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-16. Exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why j the inoperability was not corrected in a timely manner.

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! c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. ,

SURVEILLANCE REQUIREMENTS 4.3.3.10 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-16.

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TABLE 3.3-16 E

- ;5 RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION T

R;

, 8 MINIMUM i

.m CHANNELS INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTION c

5

-i 1. Waste Gas Decay System H (provides automatic isolation)

a. Noble Gas Activity Monitor 1 (1) Radioactivity Measurement 25

b. Effluent System Flow Rate 1 (1) System Flow Rate Measurement 26 Measuring Device

2. Waste Gas System (provides alarm function)

a. Oxygen Monitor 1 (2)  % 0xygen 28

3. Containment Purge Monitoring System (provides automatic isolation) 4

a. Noble Gas Activity Monitor 1 (1) Radioactivity Measurement 27 4

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TABLE 3.3-16 (Continued)

!! RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION O

a C MINIMUM El CHANNELS

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INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTION i

El 4. Station Vent Stack

r. (provides alarm function)

a. Noble Gas Activity Monitor 1 (1)- Radioactivity Measurement 27

b. Iodine Sampler Cartridge 1 (1) Verify Presence of 29 Cartridge

c. Particulate Sampler Filter 1 (1) Verify Presence of 29 Filter I

d. Effluent System Flow 1 1) System Flow Rate 26 Rate Measuring Device Measurement

e. Sampler Flow Rate Measuring 1 (1) Sampler Flow Rate 26 Device Measurement i

TABLE 3.3-16 (Continued)

TABLE NOTATION (1) During radioactive waste gas releases via this pathway.

(2) During additions to the waste gas surge tank ACTION 25 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank may be released to the environment provided that prior to initiating the release:

1. At least two independent samples are analyzed in accordance with Specification 4.11.2.1.3 for analyses performed with each batch;

2. At least two independent verifications of the release rate calculations are performed;

3. At least two independent verifications of the dis-charge valving are performed.

ACTION 26 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the flow rate is estimated at least onc'e per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

ACTION 27 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 taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and these samples are analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 28 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, additions to the waste t gas surge tank may continue provided another method for ascert-l aining oxygen concentrations, such as grab sample analysis, is l implemented to provide measurements at least once per four I (4) hours during degassing and daily during other operations.

ACTION 29 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases l

via this pathway may continue provided samples are continuously l collected with auxiliary sampling equipment, as required in Tab 1e 4.11-2.

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TABLE 4.3-16 RADI0 ACTIVE GASEQUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS T

m C CHANNEL m CHANNEL SOURCE CHANNEL FUNCTIONAL

~

' CHECK CALIBRATION TEST INSTRUMENT CHECK c

z '

Z l. Waste Gas Decay System

a. Noble Gas Activity Monitor P II)

P R(5) q(3)

II)

b. Effluent System Flow Rate P N/A R Q

2. Waste Gas System

a. Oxygen Monitor Df2) N/A Q(6) N/A

3. Containment Purge Vent System

a. Noble Gas Activity Monitor D II) P(7);M(8) p(5) q(3)

4. Station Vent Stack

a. Noble Gas Activity Monitor D(1) M R(5) q(4)

b. Iodine Sampler W II) N/A N/A N/A

c. Particulate Sampler W(1) N/A N/A N/A

d. System Effluent Flow Rate gy)

Measurement Device D N/A R N/A

e. Sampler Flow Rate Measurement Device W II) N/A R N/A

TABLE 4.3-16 (Continued)

TABLE NOTATION (1) During radioactive waste gas releases via this pathway.

(2) During additions to the waste gas surge tank.

(3) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occurs if the instrument indicates measured levels above the alarm / trip setpoint.

(4) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if the instrument indicates measured levels above the alarm / trip setpoint.

(5) The initial CHANNEL CALIBRATION for radioactivity measurement instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards should permit calibrating the system over its intended range of energy and rate capabilities. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration should be used, at intervals of at least once per eighteen months. For high range' monitoring instrumen-tation, where calibration with a radioactive source is imprac-tical, an electronic calibration may be substituted for the radiation source calibration.

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

1. One volume percent oxygen, balance nitrogen; and I

2. Four volume percent oxygen, balance nitrogen.

• l (7) During containment purges.

(8) When used in a continuous mode.

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3/4.11 RADIOACTIVE 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 3.11-1) shall be limited to the concentrations specified in 10 CFR Part 20.106 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10-4 microcuries/ml.

APPLICABILITY: At all times.

ACTION:

a. With the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, without delay restore the concentration to within the above limits.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 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 analyses shall be used in accordance with the methodology and parameters in the ODCM to assure that

the concentrations at the point of release are maintained within the limits of Specification 3.11.1.1.

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TABLE 4.11-1 RADI0 ACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Minimum Lower Limit Liquid Release Type Sampling Analysis Type of Activity of Detection Frequency Frequency Analysis (LLD) (pCi/ml),

P P Principal Gama 5 x 10 7b A. Batch Waste Each Batch Each Batch d

Release Tanks Emitters I I-131 # 1 x 10' P .3 One Batch /M M Dissolved and 1 x 10 Entrained Gases P M c

H-3 1 x 10

Each Batch Composite Gross Alpha 1 x 10 Com osite c Sr89, Sr90 5 x 10J Each Batch Fe-55 1 x 10' B. Turbine Building Principal Gamma 5 x 10'# D Sump / Storm Continuous S*

Emitters #

Sewer Drain I-131 # 1 x 10' i

P 5 x 10 .7 b

! P C. Condensate Each Batch Each Batch Principal Gamma Demineralizer Emitters #

Backwash ..

I-131 f 1 x 10 l

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TABLE 4.11-1 (Continued).

TABLE NOTATION

a. The LLO is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radio-chemical separation):

LLD =

4.66 s b E V 2.22 Y exp(-Aat) where LLD is the lower limit of detection as defined above (as pCi per unit mass or volume);

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

. E is the counting efficiency (as counts per transformation);

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

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

A is the radioactive decay constant for the particular radionuclide; l At for plant effluents is the elapsed time between the midpoint I

of sample collection and time of counting.

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

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TABLE 4.11-1 (Continued)

TABLE NOTATION

b. The principal gama emitters for which the LLD specification will apply are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, and Ce-141. For Ce-144, the LLD is 2.0x10-s pCi/ml. Other peaks which are measured and identified shall also be reported.

Nuclides which are below the LLD for the analysis should not be reported as being present at the LLD level. When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the semi-annual Radioactive Effluent Release Report.

c. A composite sample is one in which the method of. sampling employed results is a specimen which is representative of the liquids released.

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

e. When the monitor is out of service, a grab sample shall be taken and analyzed once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the condensate pump discharge exceeds 1x10-5 pCi/cc gross beta or gamma.

f. If an isotopic analysis is unavailable, gross beta or gamma measurement of batch release may be substituted provided the concentration released to the unrestricted area does not exceed 1 x 10-7 pCi/ml and a composite sample is analyzed for principal gamma emitters when instrumentation is available.

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RACI0 ACTIVE EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION 3.11.1.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radio-active materials in liquid effluents released to UNRESTRICTED AREAS (see Figure 3.11-1) shall be limited:

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

b. During any calendar year to less than or equal to 3 mrems to the total body and to less than or equal to 10 mrems 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, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Spec 1al Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions that have been taken to reduce the releases and

, the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

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 t

calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

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RADI0 ACTIVE EFFLUENTS LIQUID RADWASTF TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION 3.11.1.3 The liquid radwaste treatment system shall be used to reduce the radioactive materials in liquid wastes prior to their discharge when the projected doses due to the liquid effluent to UNRESTRICTED AREAS (see Figure 3.11-1) would exceed 0.06 mrem to the total body or 0.2 mrem to any organ in a 31 day period.

APPLICABILITY: At all times.

ACTION:

a. With radioactive liquid waste being discharged without treatment and in excess of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days 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 innperable 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 4.11.1.3 In any month in which radioactive liquid effluent is being discharged without treatment, doses due to liquid releases to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM.

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RADI0 ACTIVE 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 10 curies, excluding tritium and dissolved or entrained noble gases,

a. Outside temporary tank.

APPLICABILITY: At all times.

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 <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank contents to within the limit, and describe the event leading to this condition in the next Semiannual Radio-active Effluent Release Report.

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 each of the above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank contents at least once per 7 days when radioactive materials are being added to the tank.

l i a Tanks included in this specification are those outdoor tanks that are not i surrounded by liners, dikes, or walls capable of holding the tank contents l

or that do not have tank overflows and surrounding area drains connected l to the liquid radwaste treatment system.

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RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS DOSE 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 3.11-2) shall be limited to the following:

a. For noble gases: Less than or equal to 500 mrems/ year to the total body and less than or equal to 3000 mrems/ year to the skin, and

b. For iodine-131, 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.

APPLICABILITY: At all times.

ACTION:

a. With the dose exceeding the above limits, without delay restore with release rate to within the above limit (s).

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.1.1 The dose rate due to noble gases in gaseous effluents shall be l

determined to be within the above limits in accordance with the methodology i

and parameters in the 00CM.

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

l l

DAVIS-BESSE, UNIT 1

. - - . - + - - . - - - _

TABLE 4.11-2 RADI0 ACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM-S

< Minimum Lower Limit of T Gaseous Release Type Sampling Analysis Type of Detection (gLO) g_ Frequency Frequency Activity Analysis (pci/ml) 12

'" P P ,,4 Principal Gamma Emittersc e Waste Gas Decay' Each Each 1 x 10 5 Release Release _.

-i Grab Sample H-3 1 x 10 s

P P _4 c

Containment Purge Each Purge Each Purge Principal Gamma Emitters 1 x 10 Grab Sample _.

H-3 1 x 10 C

M H Principal Gamma Emitters 1 x 10

Station Vent Stack Grab Sample _.

H-3 1 x 10 W 12 b

Continuous Charcoal I-131 1 x 10 Sample b ~"

Continuous Parti ulate Principal Gamma Emitters C 1 x 19 Sample M

b ~"

Continuous Composite Gross Alpha 1 x 10 Particulate Sample b Q Continuous Composite ~

Sr-89, Sr-90 1 x 10 Particulate Sample b

Continuous Noble Gas Noble Gases _a Monitor Gross Beta or Gamma 1 x 10

TABLE 4.11-2 (Continued)

TABLE NOTATION

a. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radio-chemical separation):

LLD =

4.66 s b E V 2.22 Y exp(-AAt) where LLD is the lower limit of detection as defined above (as pCi per unit mass or volume);

s3is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute);

E is the counting efficiency (as counts per transformation);

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

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

A is the radioactive decay constant for the particular j radionuclide; l At for plant effluents is the elapsed time between the midpoint of sample collection and time of counting.

! 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 a posteriori (after the fact) limit for a particular measureiiient.

b. 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 and 3.11.2.3.

l DAVIS-BESSE, UNIT 1

f f

TABLE 4.11-2 (Continued)

TABLE NOTATION

c. The principal gamma emitters for which the LLD specification will (pply are exclusively the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissions and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measured and identified, together with the above nuclides, shall also be identified and reported.

Nuclides which are below the LLO for the analyses should be reported as "less than" the nuclide's LLD and should not be reported as being present at the LLD level for that nuclide. The "less than" values shall not be used in the required dose calculations. When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the Semiannual Radioactive Effluent Release Report.

i i

DAVIS-BESSE, UNIT 1.

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RADI0ACTIVS EFFLUENT'S DOSE - NOBLE GASES LIMITING CONDITION FOR OPERATION 3.11.2.2 The air dose due to noble gases released in gaseous effluents to areas at and beyond the SITE BOUNDARY (see Figure 3.11-2) 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,

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. i APPLICABILITY: At all times.

ACTION:

a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, in lieu of a Licensee Event Report, 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 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.

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

(

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i DAVIS-BESSE, UNIT 1

(_

a RADI0 ACTIVE EFFLUENTS DOSE - 10 DINE-131, TRITIUM, AND RADIONUCLIDES IN PARTICULATE FORM LIMITING CONDITION FOR OPERATION 3.11.2.3 The dose to a MEMBER OF THE PUBLIC from iodine-131, tritium, and all radionuclides in particulate form with half-11ves greater than 8 days in gaseous effluents released to areas at and beyond the SITE BOUNDARY (see Figure 3.11-2) 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: f

a. With the calculated dose from the release of iodine-131, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseota effluents, exceeding any of the above limits, in lieu of a Licensee Event Report, 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 sub-sequent releases will be in compliance with the above limits.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

I SURVEILLANCE REQUIREMENTS 4.11.2.3 Cumulative dose contributions for the current calendar quarter l

and current calendar year for iodine-131, tritium, and radionuclides in particulate form with half lives greater than 8 days shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

l^

DAVIS-BESSE, UNIT 1 l

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,,- , 1.0 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 is equal to or

greater than the calendar year limits of Specifications 3.11.1.2, 3.11.2.2 and 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.

c. With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 3.12-1, identify l

locations for obtaining replacement samples and if practical add them to the radiological environmental monitoring program within 30 days. The locations from which samples were unavailable may then be deleted from the monitoring program. In lieu of a Licensee Event Report and pursuant to Specification 6.9.1.11, identify the cause of the unavailabil.ty of samples and identify the new location (s) for obtaining replacement samples in the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

DAVIS-BESSE, UNIT 1 c

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RADIOLOGICAL ENVIRONMENTAL MONITORING

d. With specimens unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons, every effort will be made to complete corrective action prior to the end of the next sampling period.

All deviations from the sampling schedule will be documented in the Annual Radiological Environmental Operating Report pursuant to Specification 6.1.1.10.

e. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.1.1 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 00CM and shall be analyzed pursuant to the requirements of Table 3.12-1, and the detection capabilities required by Table 4.12-1.

4.12.1.2 Cumulative potential dose contributions for the current calendar year from radionuclides detected in environmental samples shall be determined in accordance with the methodology and parameters in the ODCM.

l l

1 l

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l l DAVIS-BESSE, UNIT 1 l

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TABLE 3.12-1 h RADIOLOGICAL ENVIRONMENTAL HONITORING PROGRAM 0;

o, -

01 Exposure Pathway Number of Representative Type and Frequency XI and/or Sample Samples and Sample Locations a Collection Frequency of Analysis U Gamma dose quarterly E 1. DIRECT RADIATION 27 routine monitoring stations either Quarterly 1 with two or more dosimeters or with e one instrument for measuring and recording dose rate continuously, placed as follows:

an inner ring of stations, generally one in each meteorological sector in the general area of the SITE BOUNDARY; an outer ring of stations, one in each meteorological sector in the 6- to 8-km range from the site, except the sectors over Lake Erie; the balance of the stations to be placed in special interest areas such as population centers, nearby residences, schools, and in 1 or 2 areas to serve as control stations.

4 e

TABLE 3.12-1 (Continued)

E

5 RADIOLOGICAL ENVIROM4 ENTAL MONITORING PROGRAM T

• Number of Representative Type and Frequency

$ Exposure Pathway and/or Sample Samples and Sanaple Locations, of Analysis

.m.

Collection Frequency b

-4

2. AIRBORNE H Radioiodine and Samples from 5 locations Continuous sampler Radiciodine Cannister:

Particulates operation with sample I-131 analysis weekly.

3 samples from close to the 3 SITE collection weekly, or BOUNDARY locations, in different more frequently if sectors, generally from areas of required by dust Particulate Sampler:

I higher calculated annual average loading Gross beta radioactivity groundlevel D/Q. analysig following filter ch'ange; O "* I'***PIC

1 sample from the vicinity of a analysis do*"f composite nearby community, generally in the (by location) quarterly.

area of higher calculated annual average groundlevel D/Q.

I sample from a control location, 2 15-30 km distant.

3. WATERBORNE

a. Surface 2 samples Weekly composite Compositefortritfue sample (Indicator and gamma isotopic location is a analysis monthly.

continuous,

- composite trickle-feed)

b. Ground Sample from one source Quarterly Gamma isotopicd and onlyifjikelytobe tritium analysis quarterly.

affected I

i TABLE 3.12-1 (Continued)

!! RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 0;

d>

01 Exposure Pathway Number of Representative Type and Frequency N and/or Sample Samples and Sample Locations a Collection Frequency of Analysis

.? ,

E c. Drinking 1 sample from the nearest Weekly composite Gross beta on monthly Q source. sample. composite. Tritiug es and gamma isotopic 1 sample from a control location analysis on quarterly composite. 1-131 analysis on each composite when the dose calculated for

, the consumption of the water is greater than 1 mrem per year.

d. Sediment from 1 sample from area with existing Semiannually Gamma isotopic analysis d Shoreline or potential recreational value semiannually.

4. INGESTION

a. Hilk If available, samples from milking Semimonthly when Gamma isotopicd and animals up to 2 locations within animals are on I-131 analysis semi-8 km distance having the highest pasture, monthly monthly when animals

. dose potential. at other times are on pasture; monthly at other times.

1 sample from milking animals at a control location 15-30 km distant and generally in a less prevalent wind direction. _

2 l

l

TABLE 3.12-1 (Continued)

E

$ RADIOLOGICAL ENVIRONMENIAL MONITORING PROGRAM T

I" g Exposure Pathway Number.of Representative Type and Frequency

.m and/or Sample Samples and Sample Locations a Collection Frequency of Analysis E

Ub Fish 1 sample each of 2 commercially 1 sample in season. Gamma isotopic analysis d H and/or recreationally important on edible portions.

species in vicinity of site.

1 sample of same species in  !

. areas not influenced by plant-discharge.

d

c. Food Products Samples of up to 3 different kinds Monthly when avail- Gamma. isotopic and of broad leaf vegetation growth in able. I-131 analysis.

two different offsite locations of higher predicted annual average ground-level D/Q if milk sampling is not performed.

I sample of each of the similar Monthly when avail- Gamma isotopicd and broad leaf vegetation grown able. I-131 analysis.

15-30 km distant in a less i

prevalent wind direction if milk sampling is not performed.

TABLE 3.12-1 (Continued)

TABLE NOTATION a

Specific parameters of distance and direction sector from the centerline of one reactor, 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 00CM. Refer to NUREG-0133, " Preparation of Radio-

. logical Effluent Technical Specifications for Nuclear Power Plants".

October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979. 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 alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program. In lieu of a Licensee t Event Report and pursuant to Specification 6.9.1.11, identify the cause of the unavailability of samples for that pathway and identify the new location (s) for obtaining replacement samples in the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

b 0ne or more instruments, such as a pressurized ion chamber, for measuring -

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

Film badges shall not be used as dosimeters for measuring direct radiation.

The number of direct radiation monitoring stations may be reduced according

.to geographical linitations; e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the char-acteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading.

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

d Gamma isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attributable to the effluents

. from the facility.

i l ' Groundwater samples shall be taken when this source is tapped for drinking r or irrigation purposes in ' areas where the hydraulic grodient or recharge properties are suitable for contamination.

l i

DAVIS-BESSE, UNIT 1 i

r TABLE 3.12-2

!! REPORTING LEVELS FOR RADI0 ACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES U

a Reporting Levels C

K; Water Airborne Particulate Fish Milk Vegetables ji Analysis (pCi/1) or Gases (pCi/m3 ) (pCi/kg, wet) (pCi/1) (pCi/kg, wet)

M r, 11 - 3 2 x 104^

Mn-54 1 x 103 3 x 104 Fe-59 4 x 102 1 x 104 Co-58 1 x 103 3 x 104 Cc-60 3 x 102 1 x 104 Zn-65 3 x 102 2 x 104 Zr-Nb-95 4 x 102 I-131 2 0.9 3 1 x 102 Cs-134 30 10 1 x 10s 60 1 x 103 Cs-137 50 20 2 x 103 70 2 x 103 Ba-La-140 2 x 102 3 x 102

• For drinking water samples, this is the 40 CFR 141 value. If no drinking water pathway exists, a value of 30,000 pCi/ liter may be used.

TABLE 4.12-1 LOWER LIMITS OF DETECTION (LLD)*

v co E Airborne Particulate

$ Water Or Gas Fish Milk Food Products Sediment

~

Analysis (pCi/1) (pCi/m3 ) (pCi/kg, wet) (pci/1) (pC1/kg, wet) (pCi/kg, dry) c.

z b

U Gross Beta 4 1 x 10-2 e

C 3g 2000

• 54 15 130 Mn 59 30 260 Fe 58, 60 Co 15 130 65 30 260 2n 95 15 Zr d

131; I 7 x 10-2 1 60 134, 137 15(10b ),18 6 x 10-2 130 15 60 150 Cs 140 15 15 8a NOTE: This list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measureable and identifiable, together with the above nuclides, shall be identified and reported.

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

4

c.

TABLE 4.12-1 (Continued)

TABLE NOTATION

a. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

4.66 s b LLD =

E V 2.22 Y exp(-Aat) where LLD 'is tb 3 lower limit of detection as defined above (as pCi per unit mass or volume).

s is the standard deviation of the background counting rate 3

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

E is the counting efficiency (as counts Der transformation).

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

2.22 is the number of transformations per minute per picocurie.

Y is the fractional radiochemical yield (when applicable).

A is the radioactive decay constant for the particular radionuclide.

At is the elapsed time between end of the sample collection period and time of counting.

l Typical values of E, V, Y and at should be used in the calculations.  ;

l l

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DAVIS-BESSE, UNIT 1

TABLE 4.12-1 (Continued)

TABLE NOTATION The LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as 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 inter-fering nuclides, or uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and described in the Annual Radiological Environmental Operating Report.

For more complete discussion of the LLD and other detection limits, see the following:

(1) HASL Procedures Manual, HASL-300 (revised annually)'.

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

(3) Hartwell, J. K. , " Detection Limits for Radioisotopic Counting Techniques", Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).

b. LLD for drinking water.

c. If no drinking water pathway exists, a value of 3000 pCf/ liter may be used.

d. LLD only when specific analysis for I-131 required.

1 l

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l DAVIS-BESSE, UNIT 1 l

. - - - ,e - -

3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.2 LAND USE CENSUS LIMITING CONDITIONS FOR OPERATIONS 3.12.2 A land use census shall be conducted and shall identify within a distance of 8 km (5 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence and the nearest garden of greater than 50 m 2 (500 ftz) prcducing broad leaf vegetation.

APPLICABILITY: At all times.

ACTION:

a. With a land use census identifying a location (s) that yields a calculated dose or dose commitment greater than the values currently being calculated in Specification 4.11.2.3, in lieu of a Licensee Event Report, identify the new location (s) in the next Semiannual Radioactive Effluent Release Report, pursuant to Specification 6.9.1.11.

b. With a land use census identifying a location (s) that yields a calculated dose or dose commitment (via the same exposure pathway) 20 percent greater than at a location from which samples are currently being obtained in accordance with Specification 3.12.1, add the new location (s) if practical to the radiological environmental monitoring program within 30 days. The sampling location (s), excluding the control station location, having a lower calculated dose or dose commitment (s), via the same exposure pathway, may be deleted from this monitoring program. In lieu of a Licensee Event Report and pursuant to Specification 6.9.1.11, identify the new location (s) in the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

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 during the growing season at least once per 12 months using that information that will provide the best results, such as by a door-to-door survey, aerial survey, or by consulting local agriculture authorities. The results of the land use census shall be included in the Annual Radiological Environnental Operating Report pursuant to Specification 6.9.1.10.

DAVIS-BESSE, UNIT 1 l

i

~

l

RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM LIMITING CONDITION FOR OPERATION 3.12.3 Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program that has been approved by the Commission.

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 6.9.1.10.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS

4. 12.3 A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radio-logical Environmental Operating Report pursuant to Specification 6.9.1.10.

l l

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DAVJS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS BASES 3/4.11.1 LIQUID EFFLUENTS 3/4.11.1.1 CONCENTRATION This specification is provided to ensure that the concentration of L radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified

i. in 10 CFR Part 20.106. This limitation as implemented by the ODCM pro-l vides additional assurance that the levels of radioactive materials in bodies i- of water outside the site should not result in exposures exceeding (1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, to an

. individual and (2) the limits of 10 CFR Part 20.106(e) to the population.

l The concentration limit for noble gases is based upon the assumption that Xe-135 is the controlling' radioisotope and its MPC in air (submersion) was i converted to an equivalent concentration in water using the methods described l in International Commission on Radiological Protection (ICRP) Publication 2.

3/4.11.1.2 00SE l

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

! Limiting 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 will be kept "as low as is reasonably achievable". Also, for fresh water sites with drinking water supplies which can be potentially affected by plant oparations, there is reasonable assurance that the operation of the facility will not result l in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR 141. The dose calculations in the ODCM implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I is to be shown by cal-culational procedures based on modes and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underesticated. The equations v ecified 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.

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DAVIS-BESSE, UNIT 1 l

l

INSTRUMENTATION BASES 3/4.3.3.9 RADI0 ACTIVE LIQUID EFFLUENT INSTRUMENTATION The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases. The alarm / trip setpoints for these instruments shall be calculated in accordance with methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20.

3/4.3.3.10 RADI0 ACTIVE GASEOUS EFFLUENT INSTRUMENTATION The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases. The alarm / trip setpoints for these instruments shall be calculated in accordance with methods 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 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 Critaria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

DAVIS-BESSE, UNIT 1 v-,r- , ,sy-- awe- - * - *- -

RADIOACTIVE EFFLUENTS BASES 3/4.11.1.3 LIQUID WASTE TREATMENT The requirements that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable". This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and design objective Section II.D of Appendix A to 10 CFR Part 50. Based on a cost analysis of treating liquid radwaste, the specified limits governing the use of appropriate portions of the liquid radwaste treatment system were specified as the dosc design objectives as set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

3/4.11.1.4 LIQUID HOLDUP TANKS 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.

J s

DAVIS-BESSE~, UNIT 1

RADIOACTIVE EFFLUENTS BASES 3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 DOSE RATE This specification is provided to ensure that the dose at the SITE BOUNDARY from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for unrestricted areas. The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table II.

These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a member of the public outside the site boundary to annual average con .

centrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part 20.106(a)). For members of the public who t may at times be within the site boundary, the occupancy of that member of the public will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the site boundary.

The specified release limits restrict the corresponding gamma and beta doses above background to an individual at or beyond the unrestricted area boundary to i 500 mrem / year to the total body or to 1 3000 mrem / year to the skin. These release limits also restrict, at all times, the corresponding thyroid does above background to a child via the inhalation -

pathway to 5 1500 mrem / year.

!- DAVIS-BESSE, UNIT 1 t

r RADIOACTIVE EFFLUENTS BASES 3/4.11.2.2 DOSE, NOBLE GASES 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 the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section III. A of Appendix I that conform with the guides of Appendix I ta be shown by calculation procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109,

" Calculation of Annual Doses to Man from Rountine 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.

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RADI0 ACTIVE EFFLUENTS BASES 3/4.11.2.3 DOSE, RADI0 IODINES, RADI0 ACTIVE MATERIAL IN PARTICULATE FORM AND RADIONUCLIDES OTHER THAN NOBLE GASES 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 flexi-bility 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 will be kept "as low as is reasonably achievable." The 00CM 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 an individual through appropriate pathways is unlikely to be substantially underestimated. The ODCM methods 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, " Calculating 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 I, 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 release rate specifications for radioiodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area.

The pathways which are examined in the development of these calculations are: 1) individual inhalation of airborne radionuclides, 2) deposition of l-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) deprai-tion on the ground with subsequent exposure of man.

l 3/4.11.2.4 GASEOUS RADWASTE TREATMENT SYSTEM l

The requirements that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as reasonably achieveable". This specification implements the requirements of'10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to l

10 CFR Part 50. The specified limits governing the use of appropriate i

portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

DAVIS-BESSE, UNIT 1

RADIOACTIVE EFFLUENTS BASES 3/4.11.2.5- EXPLOSIVE GAS MIXTURE This specification is provided to ensure that the concentration of potentially explosive gas mixtures contained in the waste gas treatment system is maintained below the flammability limits of hydrogen with oxygen. Maintaining the concentration of hydrogen or oxygen below their flammability limits provides assurance that the releases of radio-active materials will be controlled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50.

3/4.11.3.1 SOLID RADIOACTIVE WASTE ,

The requirements for solid radioactive waste handling and disposal given under this specification provide assurance that solid radioactive materials shipped offsite, meet destination disposal site requirements and are packaged in conformance with 10 CFR Part 20,10 CFR Part 71, and 49 CFR Parts 170-178.

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RADIOACTIVE EFFLUENTS, BASES 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 Part 20 by 46 FR 18525.

The specification requires the preparation and submittal of a Special Report whenever the calculated doses from plant generated radioactive effluents and direct radiation exceed 25 mress to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mress.

For sites containing up to 4 reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits 1

'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 outside storage tanks are kept small.

The Special Report will describe a course of action that should result in the limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits. For the purposes of the

! Special Report, it may be assumed that the dose commitment to the MEMBER OF THE PUBLIC from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 8 km must be considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part 190, the l Special Report with a request for a variance (provided the release l conditions resulting in violation of 40 CFR Part 190 have not already l been corrected), in accordance with the provisions of 40 CFR Part

!- 190.11 and 10 CFR Part 20.405c, is considered to be a timely request

! and fulfills the requirements of 40 CFR Part 190 until NRC staff action is completed. The variance only relates to the limits of 40 CFR Part 190, and does not apply in any way to the other 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 a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle.

DAVIS-BESSE, UNIT 1

3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING BASES 3/4.12.1 MONITORING PROGRAM The radiological monitoring program required by this specification pro-vides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from the station operation. This monitoring program thereby supplements the radiological effluent monitoring program by measuring concentrations of radioactive materials and levels of radiation which may be compared with those expected on the basis of the effluent measurements and modeling of the i environmental exposure pathways.

3/4.12.2 LAND USE CENSUS This specification is provided to ensure that changes in the use of unrestricted areas are identified and that modifications to the monitoring program are made if required by the results of this census. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part

50. Restricting the census to gardens of greater than 50 m2 provides assurance that significant exposura pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/ year) of leafy vegetables assumed in Regualtory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were made: 1) 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and' cabbage), and 2) a vegetation yield of 2 kg/m2 ,

3/4.12.3 INTERLABORATORY COMPARISON PROGRAM The requirement for participation in an approved Interlaboratory Compari-son Program is provided to ensure that Independent checks on the precision and accuracy of the measurements of radioactive material in environmental l sample matrices are performed as part of the quality assurance program for I environmental monitoring in order to demonstrate that the results are reasonably valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50.

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ADMINISTRATIVE CONTROLS 6.5 REVIEW AND AUDIT 6.5.1 STATION REVIEW BOARD (SRB)

RESPONSIBILITIES

6. 5.1. 6 The Station Review Board shall be responsible for:

The following SRB responsibilities will be added.

k. Review of any unplanned, accidental or uncontrolled radioactive releases, evaluation of the event, ensurance that remedial action is identified to prevent recurrence, review of a report covering the evaluation and forwarding of the report to the Station Superintendent and to the CNRB.

1. Review of the OFFSITE DOSE CALCULATION MANUAL and implementation of procedures at least once per 24 months.

m. Review of the PROCESS CONTROL PROGRAM and implementation of procedures for processing and packaging of radioactive wastes at least once per 24 months.

n. Review of the Annual Radiological Environmental Operating Report.

o. Review of the Semiannual Radioactive Effluent Release Report.

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ADMINISTRATIVE CONTROLS 6.5 REVIEW AND AUDIT 6.5.2 COMPANY NUCLEAR REVIEW BOARD (CNRB)

AUDITS 6.5.2.8 Audits of facility acitivities shall be performed under the cognizance of the CNRB. These audits shall encompass:

The following CNRB audit responsibility will be added.

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k. The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

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ADMINISTRATIVE CONTROLS 6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

The following paragraphs will be added to this section.

g. The radiological environmental monitoring program.

i h. The Process Control Program.

i. Offsite Case Calculation Manual implementation.

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ADMINISTRATIVE CONTROLS 6.9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted.

The following paragraphs will be added to this section.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.10 Routine Radiological Environmental Operating Reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year. The initial report shall be submitted prior to May 1 of the year following initial criticality.

The Annual Radiological Environmental Operating Reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with the preoperational studies, with operational controls, as appropriate, and with previous environmental surveillance reports and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of land use censuses required by Specification 3.12.2.

L 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 00CM, as well as summar-ized'and tabulated results of these analyses and measurements. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the

missing results. The missing data shall be submitted as soon as possible in l a supplementary report.

The reports shall also include the following: a summary description of the i

radiological environmental monitoring program; at least two legible maps covering all sampling locations keyed to a table giving distances and directions from the centerline of one reactor; the results of licensee l

participation in the Interlaboratory Comparison Program, required by l Specification 3.12.3; and discussion of all analyses in which the LLD required by Table 4.12-1 was not achievable.

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SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6.9.1.11 Routine Radioactive Effluent Release Reports covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each year. The period of the first report shall begin with the date of initial criticality.

The Radioactive Effluent Release Reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, " Measuring,

! Evaluating, and Reporting Radioactivity in Solid Wastes and Release 3 of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The Radioactive Effluent Release Report to be submitted within 60 days after January 1 of each year shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability. This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. This same report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY (Figures 3.11-1 and 3.11-2 during the report period. All assumptions used in making these assessments, i.e., specific activity, exposure time and location, shall be included in these reports. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFF5ITE DOSE CALCULATION MANUAL (00CM).

l l- The Radioactive Effluent Release Report to be submitted 60 days after l January 1 of each year shall also include an assessment of radiation l doses to the likely most exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to i show conformance with 40 CFR Part 190, Environmental Radiation Protection l Standards for Nuclear Power. Operation.

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ADMINISTRATIVE CONTROLS SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (Continued)

The Radioactive Effluent Release Reports shall include the following information for each class of solid waste (as defined by 10 CFR Part 61) shipped offsite during the report period:

a. Container volume,

b. Total curie quantity (specify whether determined by measurement or estimate),

c. Principal radionuclides (specify whether determined by measurement or estimate.

d. Source of waste and processing employed (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms).

t e. Type of container (e.g., Type A, Type B, Large Quantity), and

. f. Solidification agent or absorbent (e.g., cement, urea formaldehyde).

The Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive

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materials in gaseous and liquid effluents made during the reporting period.

The Radioactive Effluent Release Reports shall include any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the OFFSITE DOSE CALCULATION MANUAL (00CM), as well as a listing of new locations for dose calculations and/or. environmental monitoring identified by the land

. use census pursuant to Specification 3.12.2.

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A ADMINISTRATIVE CONTROLS 6.9 REPORTING REQUIREMENTS 6.9.2

h. Dose or dose commitment exceedences to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released to UNRESTRICTED AREAS (Specification 3.11.1.2).

i. The discharge of radioactive liquid waste without treatment and in excess of the limits in Specification 3.11.1.3.

j. The calculated air dose from radioactive gases exceeding the limits in Specification 3.11.2.2.

k. The calculated dose from the release of iodine-131, tritium, and radionuclides in particulate form with half-lives greater than 8 days, in gaseous effluents exceeding the limits in Specification 3.11.2.3.

1. The discharge of radioactive gaseous waste without treatment and in excess of the limits in Specification 3.11.2.4.

m. The calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding the limits in Specification 3.11.4.

n. The level of radioactivity as the result of plant effluents in an environmental sampling medium exceeding the reporting levels of Table 3.12-2 (Specification 3.12.1).

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ADMINISTRATIVE CONTROLS 6.10 RECORD RETENTION 6.10.2 The following records shall be retained for the duration of the Facility Operating License.

The following paragraph will be added to this Section.

m. Records of analyses required by the radiological environmental monitoring program that would permit evaluation of the accuracy of the analyses at a later date. This should include procedures effective at specified times and QA recorcs showing that these procedures were followed.

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ADMINISTRATIVE CONTROLS The following paragraphs will be added to the Administrative Controls Section.

6.14 PROCESS CONTROL PROGRAM (PCP) 6.14.1 Licensee initiated changes to the PCP:

1. Shall be submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made. This submittal shall contain:

a. Information to support the rationale for the change.

b. A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and

c. Documentation of the fact that the change has been reviewed and found acceptable by the SRB.

2. Shall become effective as reviewed and accepted by the SRB. 6.15 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.15.1 Licensee initiated changes to the ODCM:

1. Shall be submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made effective. This submittal shall contain:

a. Information to support the rationale for the change,

b. A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and

c. Documentation of the fact that the change has been reviewed and found acceptable by the SRB.

2. Shall become effective as reviewed and accepted by the SRB.

DAVIS-BESSE, UNIT 1

ADMINISTRATIVE CONTROLS 6.16 MAJOR CHANGES TO RADI0 ACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS 6.15.1 Licensee initiated major changes to the radioactive waste systems (liquid, gaseous and solid):

1. Shall be reported to the Commission in the update to the Safety Analysis Report. The discussion of each change shall contain:

a. A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR Part 50.59.

b. Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;

c. A detailed description of the equipment, components and processes involved and the interfaces with other plant systems;

d. An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto;

e. An evaluation of the change, which shows the expected maximum exposures to i individual in the UNRESTRICTED AREA and to the general population that differ l from those previously estimated in the l license application and amendments l thereto;

f. A comparison of the predicted releases of radioactive materials, in liquid

! and gaseous effluents and in solid i waste, to the actual releases for the

! period prior to when the changes are to l be made;

g. An estimate of the exposure to plant operating personnel as a result of the change; and DAVIS-BESSE, UNIT 1

ADMINISTRATIVE CONTROLS 6.14 - PROCESS CONTROL PROGRAM (PCP)

h. Documentation of the fact that the change was reviewed and found acceptable by the Station Review Board.

2. Shall become effective upon review and acceptance by the Station Review Board.

PD 4306JJ t

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