ML20105C035
| ML20105C035 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/28/1983 |
| From: | Fernandez C FRANKLIN INSTITUTE |
| To: | Congel F, Willis C NRC |
| Shared Package | |
| ML18092A428 | List: |
| References | |
| CON-NRC-03-81-130, CON-NRC-3-81-130 TAC-08154, TAC-08155, TAC-8154, TAC-8155, TER-C5506-111-1, TER-C5506-111-112-R1, NUDOCS 8308030399 | |
| Download: ML20105C035 (32) | |
Text
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4 TEChiNICAL EVALUATION REPORT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATION IMPLEMENTATION (A-2) f PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM NUCLEAR GENERATING STATION UNITS 1 AND 2 I
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l NRC DOCKET NO. 50-272, 50-311 FRC PROJECTC5506 I
I FRC ASSIGNMENT 4 I
NRCTAC NO. 8154, 8155 FRC TASKS 111, 112 NRC CONTRACT NO. NRC-03 81130 Prepared by Author:
C. Fe,rnandez Franklin Research Center 20th and Race Streets FRC Group Leader:
S. Pandey Philadetphia,PA 19103 Pr paredfor Nuclear Regulatory Commissia1 Lead NRC Engineer:
F. Congel Wr.shington, D.C. 20555 C. Willis June 29, 1983 Revised July 28, 1983 This report was prepared as an account of work sponsored by an agen i
Employees, makes any war'anty, expressed or implied, or assumes any legal liabil ty or rIsponsibility for any third 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 use by such third party would not infringe privately owned rights.
Approved by:
Reviewed by:
Prepared by:
- c. %A J g J,g b oa N
departm ntDirector Princloal Author [
Group Leader 6/29/D Date: b }'I!
b,N N Date:
Date:
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I TER-C5506-111/112 CONTENTS Section Title Page 1
INTRODUCTION 1
1 1.1 Purpose of Review.
1.2 Generic Background.
1 1.3 Plant-Specific Background.
3 2
REVIEW CRITERIA.
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TECHNICAL EVALIDLTION 7
3.1 General Description of Radiological Effluent System 7
3.2 Radiological Effluent Technical Specifications.
9 3.3 Offsite Dose Calculation Manual 18 4
CONCLUSIONS.
22 5
REFERENCES.
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iii nklin Research Center A Dhuson of The Fransen buense
I TER-C5506-111/112 i
FIGURES Number Title Page 1
Liquid Radwaste Treatment Systems, Effluent Paths, and Controls for Salen Nuclear Generating Station Units 1 and 2.
8 2
Gaseous Radwaste Treatment Systems, Effluent Paths, and Controls for Salen Nuclear Generating Station Units 1 and 2.
10 TABLE Number Title Page 1
Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Salen Nuclear Generating Station Units 1 and 2 23 5
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TER-C5506-lll/112 FOREWORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract i#ith the U.S. Nuclear Regulatory Cosumission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NBC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NBC.
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INTRODUCTION 1.1 PURPOSE OF REVIEW
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The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Salem Nuclear Generating Station Units 1 and 2 with regard to Radiological Effluent Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM).
The evaluation uses criteria proposed by the NRC staff in the model technical specifications for pressurized water reactors (PWRs), NUREG-0472 [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 [21 Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.
1.2 GENERIC BACEGROUND 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 (ALABA). In 1975, numerical guidance for the ALARA requirement was issued in 10CFR50, Appendix I.
The licensees of all cperating reactors were required [3] to submit, no later than June 4,1976, their proposed ALARA Technical Specifications and information for evaluation l
in accordance with 10CFR50, Appendix I.
l However, in February 1976, the NRC staff recommended that proposals to modify Technical Specifications be deferred until the NRC completed the model RETS. The model RETS deals with radioactive waste management systems and j.
environmental monitoring. Although the model RETS closely parallels 10CFR50, Appendix I requirements, it also includes provisions for addressing other i= sues.
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TER-C5506-111/112 These other issues are specifically stipulated by the following 4
regulations:
10CFR20 [4], " Standards for Protection Against Radiation," Paragraphs o
20.105 (c), 20.106 (g), and 20.405 (c) require that nuclear power plants and other licensees comply with 40CFR190 [51, " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40CFR190 limits have been or may be exceeded.
10CFR50, Appendix A ['6], " General Design Criteria for Nuclear Power-o Plants," contains Criterion 60 - Control of releases of radioactive materials to the environment Criterion 63 - Monitoring fuel and waste I
storage; and Criterion 64 - Monitoring radioactivity releases.
10CFR50, Appendix B [7], establishes the quality assurance required o
for nuclear power plants.
l The NRC position on the model RETS was established in May 1978 when the NRC's Regulatory Requirements Review Committee approved the model RETSt-NUREG-0472 for PNRs [1] and NUREG-0473 [8] for boiling water reactors (BWRs).
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. Licensees responded with requests for clarifications and extensions.
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I The Atomic Industrial Forum (AIF) formed a task force to comment on the model RETS. NRC staff members first met with the AIF task force on June 17, t
1978. The model RETS was subsequently revised to reflect comments from the
'1 AIF and others. A principal change was the transfer of much of the material concerning dose calculations from the model RETS to a separate CDCM.
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The revised model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133 [9]) for preparation of the RETS and the ODCM and a new schedule for responses, again staggered over a 6-month period.
Four regional seminars on the RETS were conducted by the NIC staff during November and December 1978. Subsequently, Revision 2 of the model RETS and l
cdditional guidance on the CDCM and a Process Control Program (PCP) were
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issued in February 1979 to each utility at individual meetings. In response to the NRC's request, operating reactor licensees have subsequently submitted initial proposals on plant RETS and the CDCM. Review leading to ultimate nklin Research C nter n ~ -
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TER-C5506-111/112 implementation of these documen,ts was initiated by the NBC in 1981 using subcontracted independent teams as reviewers.
As the RETS review process has progressed since September 1981, feedback from the licensees has led the NBC to believe that modification to some provisions in the current version of Revision 2 is needed to better clarify specific concerne of the licensees and thus expedite the entire review Starting in April 1982, NBC distributed revised versions of RETS in process.
draft form to the licensees during the site visite. The new guidance on these changes was presented in the AIF meeting on May 19, 1982 [10]. Some interim changes regarding the Radiological Environmental Monitoring Section were issued in August 1982 [11]. With the incorporation of these new changes, NRC l
issued, in September 1982, a draft version of NUREG-0472, Revision 3 [12], to serve as new guidance for the review teams.
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1.3 PLANT-SPECIFIC BACEGROUND In conformance with the 1975 directive (3], Public Service Electric and Gas Company (PSE&G), the Licensee for Salen Nuclear Generating Station Units 1 and 2, submitted information for 10CFR50, Appendix I Evaluation, dated June 4, 1976 [13] and additional information on October 26, 1976 [14] and December 1, 1976 [15].
The RETS and ODCM were addressed in the next submittal by the Licensee, dated November 26, 1979 [16]. The submittal was a response to the November 15-16, 1978 NRC request and followed the format of NUREG-0472 for PWRs. On March 19, 1982, Franklin Research Center (FRC), selected as an independent i
reviewer, initiated a review and evaluation of the RETS and ODCM submittals.
These submittals were compared to the model RETS [1] and to the generci provisions for the ODCM [17] which were given to each operating reactor (OR) as guidelines for preparing the RETS and the ODCM. The Licensee s RETS and 8
1 ODCM submittals were assessed for compliance with the requirements of 10CFRSO, l,
Appendix I, and the "Ger.eral Design Criteria," 10CFR50, Appendix A.
Copies of the draf t review reports dated April 16, 1982 (18, 19] were j
delivered to the NRC and to the Licensee prior to a site visit to the Salem b-I
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c TER-C5506-111/112 Nuclear Generating Station in Hancocks Bridge, NJ.
The purpose of the site visit was to resolve questions raised in the draft review reports.
The site visit was conducted on June 14-15, 1982. Discussions were held with PSE&G and Salem Station personnel to review the RETS and ODCM reports.
Agreement was reached on most items dicussed at the meetings, at which time the Licensee made a commitment to resubmit drafra of the RETS and ODCM by August 15, 1982. A trip report was prepared and delivered to the NBC on August 13, 1982 [20]. The report included the resolutions reached, as well as "open' items" to be resolved by the NBC with the Licensee.
On May 10,1983, revised draft copies [21] of the Licensee's RETS for Salem Unit 2 were received by the FRC review team and the final review was initiated. The formal RETS submittal for Salem Units 1 and 2, dated June 17, 1983 [22], was received by the FBC RETS review team on June 24, 1983 [23];
J this review addresses this final submittal. Beca'use Salem Units 1 and 2 are identical plants with similar technical specifications, this technical evaluation report (TER) addresses the evaluation of RETS for both units. The proposed RETS was reviewed and evaluated based on the draft model RETS, NUREG-0472, Revision 3 [12], and comments on the proposed RETS were supplied to the NBC on May 27, 1983 [24]. A revised ODCM was submitted on June 24, 1983 [25]. A process control program has not been submitted with the RETS.
Details of the RETS review are documented in the comparison copy (26].
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TER-C5506-lll/ll2 2.
REVIEW CRIT 2RIA Review criteria for the RETS and CDCM were provided by the NRC in three documents:
NUREG-0472, RETS for PWRs NUREG-0473, RETS for BWRs NUREG-0133, Preparation of RETS for Nuclear Power Plants. -
Twelve essential criteria are given for the RETS and ODCM:
1.
All significant releases of radioactivity shall be controlled and monitored.
2.
Offsite concentrations of radioactivity shall not exceed the 10CFR20, Appendix B, Table II limits.
3.
Offsite radiation doses shall be ALARA.
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4.
Equipment shall be maintained and used to keep offsite doses ALARA.
P 5.
Radwaste tank inventories shall be limited so that failures will not cause offsite doses exceeding 10CFR20 limits.
6.
Hydrogen and/or oxygen concentrations in the waste gas system shall be controlled to prevent explosive mixtures.
7.
Wastes shall be processed to shipping and burial ground criteria l
under a documented program, subject to quality assurance l
verification.
8.
An environmental monitoring program, including a land-use census, 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 l
releases shall be submitted.
12.
offsite dose calculations shall be performed using documented and approved methods consistent with NBC methodology. nklin Res h Center
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TER-C5506-lll/112 4
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] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS provisions. The NBC branch positions issued s'ince the RETS implementation review began have clarified the model RETS implementation for operating reactors.
d Review of the ODCM will be based on the following NBC guidelines: Br&r.ch Technical Position, " General Content of the Offsite Dose Calculation Manual *
[17]; NUREG-0133 [9]; and Regulatory Guide 1.109 [34]. The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.
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TECHNICAL EVALUATION i
3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEMS This section briefly describes the liquid and gaseous radwaste effluent systems, release paths, and control systems installed at Salen Nuclear i
Generating Station Units 1 and 2, which are both pressurized water reactors.
3.1.1, Radioactive Liquid Effluent The liquid radwaste treatment system, which is similar for both Units 1 and 2, has the capability to collect, treat, store, and dispose of most j
radioactive liquid wastes. The wastes are collected in sumps and drain tanks in the various buildings and are then transferred to the appropriate tanks in i
the radwaste building for further treatment, temporary storage, and disposal.
The processed liquid wastes are either returned to the chemical and volume control system or released to the environment through the discharge canal.
Batches of radioactive liquid waste are discharged to the Delaware River if the concentration of radioactive materials is within the allowable limits.
A diagram of the liquid effluent release paths indicating the location of the liquid effluent monitors is shown in Figure 1.
The radioactive liquid wastes originating from the primary drains, equipment drains, primary coolant l
letdown, and chemical wastes are processed through filters and evaporators prior to release. The laundry drains are stored in the waste monitor tanks prior to discharge. These wastes are monitored and controlled by liquid radwaste effluent radiation monitor (R18). The steam generator blowdown waste effluents are monitored by the chemical waste basin line radiation monitor (R37). Potential leakage of radioactive material into the service water effluents is monitored by the containment fan coolers / service water line discharge monitors (R13A, B, C, D, and E).
The turbine building floor drain effluents are an insignificant source of radioactive material and therefore are not monitored. As a safety measure, the liquid radwaste effluent radiation monitor (R18) and steam generator blowdown line radiation monitors (R19A, B, C, and D) are provided with automatic termination of release upon a high concentration alarm signal., -
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Liquid Radwaste Treatment Systems, Effluent Paths, and Controls for Salen Nuclear Generating Station Unita 1 and 2
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3.1.2 Radioactive Gaseous Effluent Airborne particulates and gases vented from process equipment and building
.. ventilation exhaust air are the normal sources of radioactive gaseous effluents from the Sales site. The major source from eaca unit is the waste gas holdup 4
system, which contains four waste decay tanks to ensure that releases are ALARA.
A diagram showing the location of radioactive gaseous effluent monitors is shown in Figure 2.
Wastes originating from the following sources are dis-4 charged through the plant vent stacks main condenser / air ejector, containment i-purge, process gas, and the ventilation exhaust from the fuel handling build-ing, radwaste area, and the auxiliary building. The plant vent stack releases are monitored by a noble gas monitor (R41C or R16), a particulkte sampler (M1A), and an iodine sampler (MlB). Noble gas monitor R41C provides alarm and automatic termination of release for effluents from the waste gas., holdup system. The waste gas holdup system is equipped with an oxygen monitor ter-~
prevent the possibility of explosive gas mixture concentrations in the waste gas decay tanks. Ventilation releases from the auxiliary building, containment purge, and the fuel handling building are processed by HEPA filters and _,
charcoal filters as shown in Figure 2.
The turbine building ventilation is i
normally released without monitoring.
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3.2 RADIOLOGICAL EFFLUEN'l-T1!EHNICAL SPECIFICATIONS
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The evaluation of the Licensee's proposed RETS against the provisions of NUREG-0472 included the followings i'
o a review of information provided by the Licensee in the 1979 proposed RETS submittal (16) l resolution of problem areas in that submittal by means of a site visit f.
o (20]
f o review of the Licensee's June 17, 1983 final RETS submittal [22].
l 3.2.1 Effluent Instrumentaticn L!
~ l The objective of the RETS with regard to effluent instrumentation is to j.;
ensure that all significant liquid and gaseous effluent releases are monitored.
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TER-C5506-lll/ll2 Plant Vent Oxygen Monitor
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41C(gas O RA18'(lodine) l Evaporator Gas,
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Tanks R15-Tank Vents '
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I Turbine Building *
(unmonitored)
Figure 2.
Gaseous Radwaste Treatment Systems, Effluents Paths, and Controls for Salem Nuclear Generating Station Units 1 and 2 M UW Franklin Research Center
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TER-C5506-111/112 r
The RETS specify that all effluent monitors be operable and that alarm / trip f
setpoints be determined in order to ensure that radioactive levels do not exceed the maximum permissible concentration (MPC) set by 10CFR20. To further ensure that the instrumentation functions properly, surveillance requirements are also needed in the specifications.
In Section 3/4.3.3.8 of the Licensee's submittal, a commitment is made to monitor and control all significant liquid effluent release paths. The following monitors are provided:
liquid radwaste effluent line monitor;- steam generator blowdown line monitors, containment fan coolers-service water line monitors, and chemical waste basin line/ monitor. These monitors have i
appropriate alars/ trip setpoints and are demonstrated to be operable by performance of surveillance operations consister.t with the model RETS [121 Flow rate measurement devices are provided for the liquid radweste effluent line and steam generator blowdown lines in order to determine the total
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radioactivity released through each liquid release point. The steam gern~erator -
blowdown line is adequately sampled; however, a continuous composite sampler is not provided. Temporary outside storage tanks, if present, will be ~"~
provided with. tank level indicating devices. The radioactive liquid effluent monitoring instrumentation meets the intent of NUREG-0472.
l In Section 3/4.3.3.9 of the Licensee's su' mittal, a couaitment is made to a
l monitor and control all significant gaseous effluent release paths. The plant, vent monitor and the waste gas holdup system noble gas monitor are provided for this purpose. The waste gas holdup system is equipped with an oxygen monitor to detect an explosive gas mixture concentration. These monitors are'----
demonstrated to be operable by performance of surveillance operations consistent with the model RETS (12]. Because there are no steam generator blowdown effluent releases directly to the atmosphere, the alternative provisions discussed in NUREG-0133 for the steam generator blowdown vent are o
j applicable. The radioactive gaseous effluent monitoring instrumentation meets,
the intent of NUREG-0472.
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3.2.2 Concentration and Dose Rates of Effluents 3.2.2.1 Liquid Effluent Concentration In Section 3/4.11.1.1 of the Licensee's submittal, a commitment is made to maintain the concentration of radioactive liquid effluents released from the site to the unrestricted areas to within 10CFR20 limits, and if the concentration of liquid effluents to the unrestricted area exceeds these limits, it will be restored without delay to a value equal to or l'ess than the MPC values specified in 10CFR20. All batches of radioactive liquid waste effluents and continuous releases from the steam generator blowdown effluents are sampled and analysed periodically in accordance with a sampling and
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analysis program (Table 4.11-1 of the Licensee's submittal), which meets the intent of NUREG-0472.
3.2.2.2 Gaseous Effluent Dose Rate In Section 3/4'11.2.1 of the Licensee's submittal, a commitment is made to maintain the offsite gaseous dose rate from the site to areas at and beyond the site boundary to within 10CFR20 limits, and if the concentration of gaseous effluents exceeds these limits or the equivalent dose values, it will be restored without delay to a value equal to or less than these limits.
The radioactive gaseous waste sampling and analysis program (Table 4.11-2 of the Licensee's submittal) provides adequate grab and continuous sampling and analysis of the waste gas storage tanks, containment purge, and plant vent and therefore meets the intent of NUREG-0472.
i 3.2.3 offsite Doses from Effluents i
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The objective of the RETS with regard to offsite doses from effluents is i
to ensure that offsite doses are kept ALARA, are in compliance with the dose specifications of NUREG-0472, and are in accordance with 10CFR50, Appendix I, and 40CFR190. The Licensee has made a commitment to meet the quarterly and yearly dose limits for (1) liquid effluents, per Section 3.11.2 (12]; (2) air doses for beta and gamma radiation in unrestricted areas due to noble gases as specified in 10CFR50, Appendix I,Section II.B; and (3) dose to any member of 4 nklin Res m,e_ arch Center. _ _ _
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TER-C5506-111/112 the public from releases of iodine-131, tritium, and particulates with half-lives greater than 8 days within the design objectives of 10CFR50, Appendix I,Section II.C.
The Licensee has made a commitment to limit the annual dose or dose cosmitment to any member of the public due to releases of radioactivity and radiation from uranium fuel cycle sources to within the requirements of 4'0CFR190. The Licensee has ccanitted to perform the dose calculations according to methods and parameters given in the ODCM. This satistles the intent of NUREG-0472.
t 1 i 3.2.4 Effluent Treatment The objective of the RETS with regard to effluent treatment is to ensure that wastes are treated to keep releases ALARA and to satisfy the provisions for techn' cal specifications governing the maintenance and use of radwaste i
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treatment equipment. In Sections 3/4.11.1.3 and 3/4.11.2.4, the Licensee has made a constitment to use the liquid and gaseous radwaste treatment systems and the ventilation exhaust treatment system to reduce the radioactive materials in liquid and gaseous wastes prior to their discharge when the projected dose due to effluents from each reactor unit exceeds prescribed dose limits. The projected doses shall be determined at least once per 31 days in accordance with the ODCM. The Licensee, however, proposes projected dose limits different from those given in the model RETS. The. proposed projected dose limits are:
l a.
Liquid radwaste treatment system. Proposed projected dose limits of 0.375 area to the total body.or 1.25 area to any organ during any calendar quarter, instead of model RETS projected dose limits of 0.06 meen to the total body or 0.2 area to any organ when averaged over 31 days.
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Gaseous radwaste treatment systems. Proposed projected air dose limits of 0.625 mead for gamma radiation and 1.25 stad for beta radation in any calendar quarter, instead of model RETS projected air dose limits of 0.2 mrad for gamma radiation and 0.4 mead for beta radation when averaged over 31 days.
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Ventilation exhaust' treatment system. Proposed projected dose limit of 1.875 mrem to any organ in any calendar quarter, instead of model 1
RETS projected dose limit of 0.3 mrem to any organ when averaged over 31 days. nidin Research Center
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!l The Licensee's proposed projected dose limits do not meet the guidance of NUREG-0472. However, the NBC staff regards the proposed approach to be a o
reasonable alternative, and it therefore meets the intent of NUREG-0472.
3.2.5 Tank Inventory Limits
.;,j The objective of the RETS with regard to tank inventory limits is to i
ensure that the rupture of a radwaste tank would not cause offsite doses greater than the limits set in 10CFR20 for nonoccupational exposure. In Sections 3/4.11.1.4 and 3/4.11.2.6 of the Licensee's submittal, a commitment is made to limit the radioactive inventory of each outside temporary tank to less than 10 curies (excluding tritium and dissolved or entrained noble gases), and each gas storage tank to less than 36,000 curies of noble gases
- i (considered as xenon-133). The Licensee has commit ~ted to a sampling program of the outside temporary tanks and the gas storage tanks to ensure that-the l
radioactive content of the tanks does not exceed the specified limits. The Licensee's commitment to comply with tank inventory limits satisfies the intent of NUREG-0472.
3.2.6 Exelosive Gas Mixtures l
The objective of the RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in the waste gas system. The waste gas holdup system is a hydrogen-rich system not designed to withstand a hydrogen explosion and therefore Section 3/4.11.2.5B of the model RETS - [12] applies to this submittal. In Section 3/4.11.2.5 of the Licensee's submittal, a commitment is made to limit the concentration of oxygen in the waste gas holdup system to less than 24 by volume whenever the hydrogen concentration
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exceeds 4% by volume. An oxygen monitor is provided to continuously monitor i
for the possibility of an explosive gas mixture concentration in the waste gas holdup system. The Licensee action specification states that the oxygen concentration will ce reduced to appropriate concentration levels when trigger l
. levels are exceeded as specified in the model RETS (12]. In Table 3.3-13, 1
l Radioactive Gaseous Effluent Monitoring Instrumentation, redundant channels are not provided as specified in the model RETS [12]; however, the present ;
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system meets the intent of the model RETS on an interim basis according to the current NBC staff position on explosive gas monitoring for PWRs (31].
3.2.7 Solid Radwaste System The objective of the RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged before it is shipped to a burial site, in accordance with 10CFR71 and Specification 3.11.3 l
of NUREG-0472. In Section 3/4.11.3 of the Licensee's submittal, a commitment is made to use the solid radwaste system to process wet radioactive waste in
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accordance with a process control program to ensure meeting the shipping and burial ground requirements. The process control program is used to verify the solidification of at least one representative test specimen from every 10
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batches of each type of wet radioactive waste. Tae Frocess control program i
a ensures that radwaste is properly processed and p5ckaged before it is: shipped to the burial site, and therefore satisfies the intent of NUREG-0472.
3.2.8 Radiological Environmental Monitoring Program The objectives of the RETS with regard to environmental monitoring are to ensure that (1) an adequate full-area-coverage (land and water inclusive) monitoring program exists; (2) the requirements of 10CFR50, Appendix I for technical specifications on environmental monitoring are satisfied; and (3) the Licensee maintains both a land-use census and interlaboratory comparison program.
The Licensee has followed NUREG-0472 guidelines, including the Branch Technical Position dated November 1979 [32), ard has provided an adequate number of sample locations for pathways identified.
The 40 thermoluminescent dosimeter (TLD) monitoring stations proposed by the Licensee satisfy the specification of NUREG-0472. The Licensee's method of analysis and maintenance of tne monitoring program satisfies the require-ments of Appendix I,10CFR50. The Licensee' has also made a corcmitment to describe the specific sample locations in the ODCM. This meets the intent of NUREG-0472. 4 dhd Franklin Research Center A Ommon of The Freseen bisenste
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.w TER-C5506-lll/112 The commitments to a yearly land-use census within NUREG-0472 specifica-tions and to an ongoing interlaboratory comparison program'aquivalent to the model RETS guidelines on environmental monitoring meet the intent of NUREG-0472.
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 station operations review committee (SORC) and the nuclear review board (NRB) as the two groups responsible for reviews and audits, respectively. In Section 6.5.1.6 of the Licensee's submittal, a commitment is made for review of changes to the process control program and the offsite dose calculation
~
manual and for review of unplanned releases to the environment by the station operations review committee. In Section 6.5.2.8 of the Licensee's submittal, a commitment is made to perform periodic audits of the radiological environmental monitoring pr^ ram by the nuclear review board. NBC staff considers that audits of 8.te dose calculation manual, process control pretram, and the quali program for effluent and environmental conitoring are providt 4.5.2.8.a of the Licensee's present technical specifica. it.
, audits and review sectior.a of the submittal meet the int
N 3.2.10 Procedures an Q
The objective of the h. 'S w
,,ard to procedures is to satisfy the provisions for written peccedures ror implementing the ODCM, PCP, and QA program. It is also an objective of RETS to properly retain the documented records related to the environmental monitoring program and certain QA procedures. The Licensee has made a commitment to establish, implement, and maintain written procedures for the PCP, ODCM, and QA programs which satisfy the provisions of NUREG-0472. The Licensee, also, has made a commitment to retain the records of the radiological environmental monitoring program, and this meets the intent of NUREG-0472. A NU Frank!!n Research Center A Osme.ose of The Feuen buenne
"'ER-C5506-lll/112 3.2.11 Reports In addition to the reporting requirements of Title 10, Code of Federal Regulations (10CFR), the objective of the RETS with regard to administrative controls is also to e'nsure that appropriate periodic and special reports are submitted to the NBC.
The Licensee has made a commitment to follow applicable reporting requirements stipulated by 10CFR regulations and also the following reports specified by NUREG-0472:
1.
Annual radiological environmental operating report. In Section 6.9.1.10 of the Licensee's submittal, a commitment is made to provide 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 the results of land use censuses, and participation in an inter-laboratory comparison program specified by Specification 3.12.3 of NUREG-0472.
2.
Semiannual radioactive and solid waste release reports. In Section 6.9.1.11 of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent and solid waste release reports which include a summary of radioactive liquid and gaseous effluents and solid waste released, an assessment of offsite doses, and a list of unplanned releases. Listing of new location for dose calculations identified by the land use census as well as any changes to ODCM are also included in the report.
3.
Prompt notification with written followup. In Section 6.9.1.8 of the Licensee's submittal, a commitment is made to provide prompt notification with written followup for the followings o offsite releases of radioactive materials in liquid and gaseous effluents which exceed the liquid concentration limits of Section 3.11.1.1 and the gaseous dose rate limits of Section 3.11.2.1.
Exceeding the limits of Sed: tion 3.11.1.4 for the storage of o
radioactive liquids in outside tanks and of Section 3.11.2.6 for the storage of noble gases in the gas storage tanks.
4.
Thirty-day written report. In Section 6.9.1.9 cf the Licensee's submittal, a commitment is made to provide a 30-day written repcet for an unplanned offsite release of more than 1 curie of radioactive material in liquid effluents or of more than 150 curies of noble gas in gaseous effluents.
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i TER-C5506-111/112 i
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- 5. -Special report. In Section 6.9.2 cf the Licensee's submittal, a commitment is made to provide a special report for exceeding Section 3.11.1.2 liquid effluent dose limits, Sections 3.11.2.2 and 3.11.2.3 gaseous effluent dose limits, and Section 3.11.4 total dose limits.
l A special report is required for the extended inoperability of liquid and gaseous radwaste treatment systems and for measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting levels of Table 3.12-2.
These reporting commitments have satisfied the provisions of NUREG-0472.
3.2.12 Implementation of Maior Programs One objective of the administrative controls is to ensure that implemen-tation of major programs, such as the PCP, ODCM,.and major changes to the J
radioactive waste treatment system, fcilows appropriate administrative proce-dures. The Licensee has made a commitment to review, report, and implement major programs such as the PCP, ODCM, and major changes to the radioactive waste treatment system. This meets the intent of NUREG-0472.
3.2.13' Design Features i
The objective of the RETS with regard to design features is to provide a map of the site area defining the site boundary and unrestricted areas within the site boundary, as well as defining points of release.for liquid and gaseous effluents and points where liquid effluents leave the site. The Licensee has provided an acceptable site map which meets the intent of NUREG-0472.
3.3 OFFSITE DOSE CAICULATION MANUAL (ODCM)
As specified in NUREG-0472, the CDCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and -
maintain the operability of the effluent systems. As a minimum, the ODCM should provide equations and methodology for the following topics:
alarn and trip setpoint on effluent instrumentation o
liquid effluent concentration in unrestricted areas o
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TER-C5506-111/112 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 thealarmandtripsetpointsfortheliquidandgaseouseffluentmoniIors, which ensures that the maximum permissible concentrations (MPC), as specified in 10CFR20', will not be exceeded by discharges from various liquid or gastous release points. To augment conservatism and to address the case ef simultaneous releases, the Licensee has calculated monitor setpoints using a realistic worst-case combination of MPC values, flow rates, dispersion coefficients, isotopic composition, and a 25% meter error factor. Detailed l
parameters are given for calculating individual monitor setpoints.
The Licensee demonstrated the method of calculating the radioactive liquid concentration by identifying the liquid effluent sources, by providing parameters and equations needed to de'termine effluent concentrations, and by providing a method for analyzing representative sr.mples prior to and after releasing liquid effluents into the circulating water discharge. The method provides added assurance of compliance with 10CFR20 for liquid offluent releases.
Methods are also included for showing that dose rates at or beyond the site boundary due to noble gases, iodine-131, tritium, and particulates with half-lives greater than 8 days are in compliance with 10CFR20. In this '
calculation, the Licensee has considered effluent releases from the waste gas decay tanks, containment purge, and releases from ventilation systems, all nklin Research Center A OMmen af The Fransen insamme
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i TER-C5506-111/112 of which are discharged through the plant vent, and are treated as mixed mode releases. The Licensee has used the highest annual average values of relative concentration (X/Q) and relative deposition (D/Q) to determine the controlling locations. For dose rate calculations from noble gases, the Licensee has considered a semi-infinite cloud model. The Licensee intends to use the maximally exposed individual and the critical organ as the reference f
receptor. The Licensee has considered exposure pathways from inhalation and the milk and ground pathway, although milk ingestion exposure frois ground-plane deposition is not strictly required for gaseous dose rate calculations. However, the equation used by-the Licensee on page 6.2 of the submittal does not agree with the corresponding equation given in Section 5.3.1 of NUREG-0133.
Evaluation of the cumulative dose is to ensure that the quarterly and annual dose design objectives specified in the luifTS are not exceeded.' -
For liquid releases, the Licensee has identified fish and invertebrate consumption as the two viable pathways. In the calculation, the Licensee uses a near-field dilutiors factor specific to the plant; all other key parameters follow the suggested values given in Regulatory Guide 1.109. As in the case of dose rate calculations, the Licensee has 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 days.
Evaluation of the cumulative dose from noble gas releases includes both l
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) l values as discussed earlier and has foJ. lowed the methodology and parameters of NUREG-0133 and Regulctory Guide 1.109.
i For iodine-131, tritium, and particulates with half-lives greater than 8 days, the Licensee has provided a method to demonstrate that camulative doses calculated from the release meet both quarterly and annual design objectives.
The Licensee has demonstrated a method of calculating the dose using maximum nk!!n Research Center l
A Dheeson of 7he Franaen an.stume l
o
.a TER-C5506-lll/112 annual average (X/Q) values for the inhalation pathway and has included (D/Q) values for the milk and ground-plane pathway. However, the Licensee has yet to provide the methodology and key parameters for deriving the dose factors R and P shown in Table 6.1 of the submittal.
g g
Using the existing methodology for gaseous and liquid dose calculations, the Licensee has' demonstrated a procedure to determine the quarterly dose and to ensure that the design' objectives for the liquid'radwaste system and the gaseous radwaste treatment 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 i,
the Licensee. Radiation monitors specified in the Licensee-submitted RETS are also properly identified in the flow diagrams.
The Licensee has provided a description of sampling locations in the ODCM and has identified them in Table 7-1 and also in Figures 7-1 and 7-2 of that document. This description is consistent with the sampling locations specified in the Licensee's RETS Table 3.12-1 on environmental monitoring.
In summary, the Licensee's ODCM uses documented and approved methods that are consistent with the methodology and guidance in NUREG-0133, and therefore is an acceptable reference, except the following deficiencies were found in the submittal:
l 1.
Figure 2-2, " Gaseous Releases to the Environment," does not indicate containment purge releases.
2.
The equation given on page 6.2 does not agree with the corresponding equation given in Section 5.3.1 of NUREG-0133. Also, methodology and
~
key parameters are not provided by the Licensee in deriving the equation.
3.
Table 6.1 on page 6.6 should be labeled "R, Dose Factors for 1
Radioiodines and Radioactive Particulates in Gaseous Effluents" instead of "P, Dose Parameters for Radiciodines and Radioactive i
Particulates in Gaseous Effluents." Alsc, methodology and key parameters for the derivations of R s and P s are not given.
i t
4.
The table of contents for the ODCM calls for a Section 7.2, "Esti:: ate of Direct Radiation Dose," which has not been included in the ODCM submittal. fJd Franklin Research Center A Chosen of The Franneninsaame
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TER-C5506-111/ll2 4.
CONCLUSIONS Table 1 summarizes the results of the final review and evaluation of the submittal for Salen Nuclear Generating Station Units 1 and 2.
The following conclusicas have been reached:
~
l.
The Licensee's proposed RETS submitted June 17,1983 [22] meets the intent of the NBC staff's " Standard Radiological Effluent Technical Specifications," NUBEG-0472, for sales Nuclear Generating Station Units 1 and 2.
2.
The Licensee's proposed ODCM, submitted June 24,1983 [25], uses documented and approved methods consistent with the criteria of NUREG-0133, except for the deficiencies listed in the summary of the.
evaluation.
3.
The Licensee has not yet submitted a PCP..for review. Review.o,f the formal submittal of PCP will be recorded in a supplement to this TER.
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TER-C5506-111/112 4
Table 1.
Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Salen Nuclear Generating Station Units 1 and 2 Technical Specifications Replaces NE Staff or Updates Std. RETS Licensee Existing NUREG-0472 Proposal Tech. Specs.
(Section)*
(Section)
(Section)
Evaluation Effluent 3/4.3.3.3.10 3/4.3.3.3.8 2.3.1, 2.3.2 Meets the intent Instrumentation 3/4.3.3.3.11 3/4.3.3.3.9 2.3.3, 2.3.4 of NBC criteria (Appendix B)
Radioactive 3/4.11.1.1 3/4.11.1.1
~ 2.3.1, 2.3.2 Meets the intent Effluents 3/4.11.2.1 3/4.11.2.1 2.3.3, 2.3.4 of NBC criteria (A m ndix B) offsite Doses 3/4.11.1.2, 3/4.11.1.2 2.3.1, 2.3.3 Meets the intent i
3/4.11.2.2, 3/4.11.2.2 (Appendix B) of NRC criteria 3/4.11.2.3, 3/4.11.2.3 i
l 3/4.11.4 3/4.11.4 Effluent 3/4.11.1.3 3/4.11.1.3 2.3.2, 2.3.4 Meets the intent Treatment 3/4.11.2.4 3/4.11.2.4 (Appendix B) of NRC criteria l
Tank Inventory 3/4.11.1.4 3/4.11.1.4 2.3.1, 2.3.5 Meets the intent" -
l Limits 3/4.11.2.6 3/4.11.2.6 (Appendix B) of NRC criteria Explosive Gas 3/4.ll.2.5B 3/4.11.2.5 Not addressed Meets the intent of NBC criteria in Mixtures I
the interim i
Solid Radioactive 3/4.11.3 3/4.11.3 2.3.5 Meets the intent t
l Waste (Appendix B) of NBC criteria Environmental 3/4.12.1 3/4.12.1 3.2 Meets the intent l
Monitoring (Appendix B) of NBC criteria Audits and 6.5.1, 6.5.2 6.5.1, 6.5.2 6.5.1, Meets the, intent Reviews 6.5.2.7 of NBC criteria (Appendix A)
Procedures and 6.8, 6.10 6.8, 6.10 6.8, 6.10 Meets the intent Records (Appendix A) of NRC criteria
- Section nu:r.ber sequence is according to NUREG-0472, Rev. 3 (12}.
l,
4 branidin, Research Center
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TER-C5506-lll/112 Table 1 (Cont)
Technical specifications Replaces NIC Staff or Updates Std. RETS Licensee Existing
^
NUREG-0472 Proposal Tech. Spetcp.
(section)*
(section)
(section)
Evaluation Reports 6.9.1.9, 6.9.1.8, 6.9.1.4, Meets the intent 6.9.1.11, 6.9.1.9,
6.9.1.6, of.NBC criteria 6.9.1.12, 6.9.1.10, 6.9.1.9, 6.9.2 6.9.1.11, 6.9.2 6.9.2 (Appendix A) 5.6 (Appendix B)
Implementation of 6.13, 6.14, 6.13, 6.14, Not addressed Meets the intent Major Programs 6.15 6.15 of NIC criteria l
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TER-C5506-111/ll2 5.
REFERENCES
\\
-l 1.
" Radiological Effluent Technical Specifications for Pressurized Water j
Reactors," Rev. 2 NBC, July-1979 NUREG-0472 2.
Title 10, Code of Federal Regulations, Part 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to 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,Section 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 3tatliation Protection Standards for Nuclear Power Operations" 6.
Title 10, Code of Federal Regulations, Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants"
~*
7.
Title 10, Code of Federal Regulations, Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" 8.
" Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 2 NBC, July 1979 NUR" 4473 9.
" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications" NBC, October 1978
' NUREG-0133 10.
C. Willis and F. Congel (NBC)
" Summary of Draft Contractor Guidance of RETS" Presented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19,1982 11.
F. Congel (NBC)
Memo to RAB Staff (NBC)
Subject:
Interim Changes in the Model' Radiological Effluent Technical Specifications (RETS)
August 9,1982 nidin Research Center A Onaean af The Premen buenne
TER-C5506-111/112 12.
" Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draf t 7', intended for contractor guidance in f
reviewing RETS proposals for operating reactors j
NBC, September 1982 NUREG-0472
~
13. Additional Information Required for Appendix I Implementation, Salen Nuclear Generating Station, Unit Nos. 1 and 2, Docket Nos. 50-272 and 50-311 Letter-of Tranreittal, Jc.no 4,1976 Revision 1, June 21, 1976 14.
Responses to Additional Information Request for Salen Nuclear Generating Station, Units Nos.1 and 2 Letter of Transmittal October 26, 1976 15.
Responses to Adi11tional Information Request for Salem Nuclear Generating
, Station, Unit Nos. 1 and 2 Letter of Transmittal,- December 1,1976 16.
F. P. Librizzi (PSE&G)
Letter to A. Schwencer (NBC)
November 26, 1979 17.
General Contents of the Offsite Dose Calculation Manual," Rev.1 i
NBC, 1979 18.
" Radiological Effluent Technical Specification Implementation, Comparison of Plant and Model,RETS" Franklin Research Center, Draft dated April 16, 1982 19.
" Radiological Effluent Technical Specification Implementation, Technical Review of Plant Offsite Dose Calculation Manual" Franklin Research Center, Draf t dated April 16, 1982 20.
Trip Report to Salem Nuclear Power Station
(
Trip Date: June 14-15, 1982 l
C. Fernandez/S. Pandey (FBC) to F. Congel/C. Willis/W. Meinke (NBC) l August 13, 1982 21.
Draft Final Salem Unit 2 RETS Submittal Tranmitted to S. Pandey (FBC) from W. Meinke (NBC)
May 10,1983 if-22.
E. A. Liden (PSEEG) l Letter to S. Varga (NBC) l June 17,1983 I
l
- -.,m,e_ arch Center ranidin Res
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u.. a. a _.]
TER-C5506-lll/112 23.
W. Meinke (NBC)
" Memo to S. Pandey (FBC)
June 24, 1983 24.
Informal Technical Communication from C,, Fernandez/S. Pandey (FBC) to W. Meinke (NBC) l "RETS Review Questions" May 27, 1983 25.
E. A. Liden (PSE&G)
Letter to S. A. Varga (NBC) 4 Subjects ODCM June 24, 1983 26.
" Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs, vs. Licensee Final Submittal of Radiological Effluent Technical Specifications, dated May 10, 1983, for Salen Nuclear Generating Station" Franklin Research Center May 27, 1983 27.
C. Willis (NIC)
Letter to S. Pandey (FBC)
Subject:
Changes to RETS requirements following meeting with Atomic Industrial Forum. (AIF)
November 20, 1981 l
28.
C. Willis (NBC)
Letter to S. Pandey (FBC)
Subject:
Control of explosive gas mixture in PWRs December 18, 1981 t
29.
C. Willis and F. Congel (NBC)
" Status of NBC Radiological Effluent Technical Specification Activities" Presented at the AIF Conference on NEPA and Nuclear Regulations,
~
l Washington, D.C.
October 4-7, 1981 30.
C. Willis (NBC)
Memo to P. C. Wagner (NBC)
" Plan for Implementation of RETS f'or Operating Reactors" i
November 4,1981 1
31.
W. P. Gammill (NBC)
Memo to P. C. W2gner (NBC)
" Current Position on Radiological Effluent Technical Specifications (RETS) Including Explosive Gas Controls" October 7,1981
' UUdhranklin Research Center A Onimen of The Fresuen buseuse L-
w TER-C5506-lll/ll2 32.
"An Acceptable Radiological Environmental Monitoring Program" Radiological Assessment Branch Technical Position, Revision 1 November 1979 33.
Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40CFR190)
NBC, February 1980 NUREG-0543
- 34. Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10CFR50, Appendix I NBC, October 1977 Regulatory Guide 1.109, Revision 1 i
nPJin Research Center a m e m r,.a m.