ML20106A101

Radiological Effluent Tech Specs (RETS) Implementation - Dresden Station,Units 2 & 3, Informal Rept

ML20106A101
Person / Time
Site:	Dresden
Issue date:	06/30/1984
From:	Serrano W, Simpson F, Thomas Young EG&G, INC.
To:	NRC
Shared Package
ML17195A674	List: ML17195A673 ML20099L700 ML20106A101
References
CON-FIN-A-6459 EGG-PBS-6633, NUDOCS 8407110368
Download: ML20106A101 (37)

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EGCJ ES-5633 RADIOLOGICAL EFFLUENT TECHillCAL SPECIFICATIONS (PETS) I"PLEMEitTATION ORESDEft STATION UNITS 2 A?'D 3 Prepared by T. E. Young F. B. Simpson t*, Serrano

..9 D.11. Akers _

S.11. Duce J. tf. ;tandler a

Published June 1984 E?aG Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared fer the U. S. i!uclear Regulatory Cc xntssion Under 00E Contract t'o. GE-AC07-75 f C01370 f RC FIN flo. A6459 s

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ABSTRACT

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A review of the Radiological Effluent Technical Specifications (RETS) for the Drescen Statien Units 2 and 3 Nuclear Generating Plants was 4

perfcrmed. The principal review guidelines used were NUREG-0133,

" Preparation of Radiological Effluent Technical Specifications for Nuclear i

Power Plants," and Draf t 7 of NUREG-0473, Revision 3, " Standard Radiological Effluent Technical Specifications for Bolling Water Reactors." Draft submittals were discussed with the Licensee by,both EG&G and the NRC staff untII all items requiring changes to the Technical l'

Specifications were resolved. The Licensee than submitted final proposed RETS to the NRC which were evaluated and found to be in compliance with l

the NRC' review guidelines. The proposed Offsite Dose Calculation Manual f

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andProcessControlProgramwerereviewedandigenerallyfoundtobeIn

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compliance with the NRC review guidelines.

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FOREWORD This Technical Evaluation Report was prepared by EG&G Idaho, Inc.

under a contract ylth the U. S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Div'Islon of Systems integration) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC'.

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COPE NT9 1,.

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ADstract............................

I Foreword............'...................

II 1.

INTRODUCTION.......................... 1 1.1 Purpose of the Technical Evaluation............ 1 1.2 Generic issue Eackground I

1.3 Plant-Specific Background.............,... 4

2. -REVIElf CRITERIA.....................'.... 6 3.

TECHN I CA L E VA LUAT I ON...............'....... '8 3.1 General Description of Radiological Ef fluent Systems 8

3.2 Radiological Effluent Technical Specifications 11 3.3 0ffsite Dose Calculation Manual.............. 23 3.4 Process Control Program.................. 25

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CONCLUSIONS

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5. REfEREllCES..............,............., 30 e,

-n FIGURES 1.

Cresden station liquid radweste system and. discharge pathways

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Dresden station gaseous radwaste system and discharge pathways. 10 Id. ELF Me mb a r-TItie EAC2.

1 Correspondence of Provisions of NUREG-0473, The Licensee's Current Technical Specifications and the Licensee's Proposal for Dresden Station Units 2 and 3 29 e

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INTRODUCTION

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t 1.1 Pursese of the Technicar Evaluatten The purpose of this Technical Evaluation Report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Dresden Station Units 2 and 3 Nuclear Generating Plants with regard to Radiological Ef fluent Technical Specifications (RETS), the proposed

'Of fsite Dose Calculation Manual (00CM).and the proposed Process Control Program (PCP).

t The evaluation used criteria proposed by the Nuclear Regulatory Commission (NRC) staff in the model Technical Specifications for bo!!!ng

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water reactors (SWRs), NUREG-0473,[13 and subsequent revisions. This effort is directed toward the NRC objective of implementing RETS which comply with the regulatory requirements, primarily those of 10.CFR Part 50, Appendix 1.[2] Other regulations pertinent"to'the control of effluent releases are also included within the scope of compliance.

1.2 Generic Issue esekereund Since 1970,10 CFR Part 50, Section 50.36a,[3] " Technical Soecif-icatiens on Effluents from Nuclear Power Reactors," has required IIcensees to provide Technical Specifications which ensure that radicactive releases will be kept as low as is reasonably achievable

( ALARA).

In 1975 numerical guidance for the ALARA requirement was issued in 10 CFR Part 50, Appendix 1.

The licensees of all operating reactors were required to submit, no later than June 4,1976,[43 their proposed ALARA Technical Specifications and infccmation fcr evaluation in acccedance with 10 CFR' Part 50, Appendix 1.

Fewever, in February !?75 the NRC staff recommended that proposals to modify Technical Specifications be l

deferred until the NRC completed the model RETS.

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The model RETS deal with radicactive waste management sys'tems and 4

environmental monitoring. Although the model RETS address 10 CFR Part 50, Appendix I requirements, subsequent revisions include provisions for i

addressing issues not covered in Appendix 1.

These provisions are stipulated in the following regulations:

10 CFR Part 20,[5] " Standards for Protection Against e

Radiation," Sections 20.105(c), 20.106(g), and 20.405(c) which require that nuclear power plants and other licensees comply with 40 CFR Part 190,[6] " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to tho' NRC when the 40 CFR Part 190 Ilmits have been or may be exceeded.

10 CFR Part 50, Appendix A,[73 " General Design Criteria for e

Nuclear Power Plants," which contains Criterien 60--Control of releases of radioactive materials to,the environment; Criterion 63--Monitoring fuel and waste storage; and Criterien 64--Monitoring radioactive releases.:.,~

t 10 CFR Part 50, Appendix B,[8] which establishes the quality e

assurance required for nuclear power plants.

The NRC position on the model RETS was established in May 1978 when the NRC's Regulatcry Requirements Review Committee approved the mcdel RETS: NUREG-0472 for PWRs and NUREG-0473 for EWRs. Copies of the model RETS were sent to licensees in July 1978 with a request to submit proposed site-specific RETS on a staggered schedule over a six-month period.

Licensees responded with requests for clarifications and extensicns.

The Atomic Industrial Forum (AlF) formed a task force to comment on the medel RETS. NRC staf f members first met with the AIF task ferce en June 17,1978. The ecdel RETS were subsequently revised (Revisicn 1) to D

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reflect coments from the AIF and others. A principal change was the transfer of much of the material concerning dose calculations from the l

model RETS to a separate document, the 0DCM.-

' Revision 1 of the model RETS was sent to licensees on November 15 and I6,1978 with guidance (NUREG-0133)[93 for preparation of the RETS and

• the CDCM and a new schedule for responses, again staggered over a

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six-month period.

l Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subsequent 1y, a praIiminary copy of s

j Revision 2 of the model RETS and additional guidance on the CDCM and a PCP were issued in February 1979 to each utility at Individual meetings.

NUREG-0473, Revision 2,[13 and NUREG-0472, Revision 2,[10] were published in July 1979 and updated in January 1980 and February 1980.

In response to the NRC's request, operating reactor licensees subsequently submitted initial preposals on plant RETS'a'nd'the 00CM. Reviews leading to ultimate implementation of these documents were initiated by the NRC in

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September 1981 using subcontracted independent teams as reviewers.

J As the RETS review progressed, feedback from the licensees led the NRC to modify some of the provisions in the February 1,1980 versions of the model RETS to clarify specific concerns of the licensees and thus expedite the reviews. Starting in April 1982, the NRC distributed revt. sed versions "

' cf the model RETS In draft form to the licensees during the site visits.

The new guidance on these changes was presented in an AIF meeting on Ifay 19,1982.[I13 Some Interim changes regarding the Radioicgical Environmental f4onitoring Section were issued in August 1982.[12] With the incorporation of these changes, the'NRC issued Draft 7 of Revision 3 of NUREG-0473[133 in September 1982 to serve as new guidance fcr the review teams.

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in conforeance with the 1975 d!rective[43 Commonwealth Edison Company (CEC), the Licensee of Dresden Station Units 2 and 3 filed with the Commission on June 4, 1975[143 and,'ovember 12, 1976,[15] the 3

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• ecessary Information to permit evaluation of the Cresden Station 'Jnits* 2 and 3 Technical Specifications with respect to the requirerents of 10 CFR

't ij Fart 50, Sections II.A, ll.8, and ll.C of Appendix 1.

These submittals I

.showed that the radioactive waste treatment systems installed at Dresden Station Units 2 and 3 are capable of reducing relesses of radioactive saterials in liquid and gaseous effluents to ALARA levels in confernance with the requirements of 10 CFR Part 50, Section 50.3aa, and of cer.pitance' with Appendix l.[15] CEC did not submit proposed RETS at that time.

EG&G Idaho, Inc. (EC4G), selected as an independent task review team,

' Initiated a review and evaluation of existing RETS for Cresden Station.

These technical specifications were compared with the model RETS and assessed for compliance with the requirements of 10 CFR Part 50, Appendix I, and 10 CFR 50, Appendix A.

Review comments and questions dated January 19, 1982[173 were mailed to the !!F.C price to arranging a site visit with the Licensee. The-site visit was arranged for the purpose of resolving questions identified in the January 1982 review Of CIC's CETS. Durin; the site vist? :n April 5 erd 5 of 1932, technics! discussions resolved nany of the sbcrtcc.Ings of the Licensee's RETS.

l ollowing the site visit, the Licensee submitted draft PETS for 9rnsten Station Units 2 and 3 to the "F0 on January 12,1964,[133 addressing. tost of the discrepancies discussed during the site visit.

~be hnuary 1C? draf * 'I'?. ere revie.od by ths 29M team and rev!ss

0.enTs and questiens identifying unresolved ite.rs era trirsmittid M

" C en Feraary 2, 10.?.U E These issues vire rascIve'.' fe, discussiens

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between the '!RC staf f and representatives of CEC. On f*ay 3, !?i14 CEC submitted proposed RETS that incorporated the resolutions agreed upon. This submission resolved all outstanding RETS issues and these resolutions were forwarded to EC4G on ' fay 10, 1984.[212 This allowed preparation of a7ER for submittal to the NRC. The proposed RETS, submitted itay 10, 1984 are evaluated in Section 3.

1 Review of an existing 00C1 for Dresden Station, dated February 1979[22] was delayed pending completion of the review cf the OCCI for CEC's lead station (Ouad Cities). Subsequently, an updated general GDC1, applicable to all the Licensee's nuclear generating plants, was received by the EC4G review team on April 25,'1983.[23] This general 00Ct was reviewed, and review comtnents and questions pertaining to all CEC nuclear generating plants plus questions specific to Cuad Cities were transmitted i

to the iPC by letters dated itay 17,1983[24] and June 24, 1983.[25]

Comments and questions specific to Dresden Station Units 2 and 3 were transmitted to the TEC on February 14,1984.[26] The CCCi generally

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use's docu. vented and approved cethods that are consistent with the guidelines of NUPEG-0133.

The Licensee submitted a draft Process Control Program (PCP) to the

lRC on January 12, 1984 [18] The EC4G team reviewed this document and trensmitted ccreents and questicns to the ::RO on February 14,190a.5252 On "ay 5, 1984 CEC subnitted a PCP that in general included tre provis!ons of the !GC review guidelines identified in letter dated January 3, 1983.[273 e

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REVIEW CRITERIA Review criterie for the RETS and 00CM were provided by the NRC in r

three documents:

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NUREG-0472, RETS for PWRs,

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NUREG-0473, RETS for EWRs, 3.

NUREG-0133, Preoaration of RETS for Nuclear ' Power Plants.

Twelve essential criteria are given for the RETS and CDCM:

1.

All significant releases of radioactivity shall be controlled and monitored.

2.

Offsite concentrations of radioactivity shall not exceed the 10 CFR Part 20, Appendix B, Table il ' limits.[283 e.t ow 3.

Of fsite radiation doses shall be ALARA.

4 Equipment shall be maintained and used to keep offsite deses ALARA.

5.

Radweste tanks inventeries shall be limited so that failures would not cause offsite doses exceeding 10 CFR Part 20 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 under a dccumented program, subject to quality assurance verificatien.

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An environmental monitoring program, including a land use census, shall be implemented.

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The radweste management program shall be subject to regular audits and reviews.

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10. Procedures for control of !! quid and gaseous effluents shall be j

maintained and followed.

11. Periodic and special reports on environmental menitoring and on releases shall be submitted.

12. Offsite dose calculations shall be performed using documented and approved methods consistent with NRC methodology.

In addition to NUREG-0472 and NUREG-0473, as revised, the NRC staf f issued guidelines,[29,30] clarifications,[31,32] b' ranch positions,[33,34] and NUREG-0543[35] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS requirements. The NRC branch positions issued since the RETS Implementation review began have clarified the model RETS for operating reacters.

Review criteria for the ODCN is based on the following NRC guidelines:

Eranch Technical Position, " General Contents of the Of fsite Dese Calculation Manual;[36] NUREG-0133;[93 and Regulatory Guide i

1.109.[373 The format for the ODCM is left to the Licensee and may be simplified by tables and grid printouts.

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TECHillCAL EVALUATici!

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j 3.1 r-erarsi Oescric+f en of c dicientee t Ef

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This section briefly describes the liquid and gaseous radwaste

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effluent treatment systems, release paths, and control systems installed at Dresden Station Units 2 and 3, (S11Rs).

c dteactive Lieutd Effluen+s 3.1 ;1 a

There are two possible sources of radioactive liquid effluents for Dresden Station Units 2 and 3: the radwaste treatment system and the service. water system.

ExceptforthecollectionsumpsandreachoFwatercleanupsystems,the two units share a ccmr.on radwaste system, as shown in Figure 1.

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RadioactivelikuldsarecollectedinthefIoof'drainsampletankandthe decontamination solution tank. The contents of these tanks are isolated, mixed, and sampled prier to discharge to the cf.rculating water discharge canal system at a controlled rate through the monitored radwaste effluent line.

The normally uncontaminated service water effluent is released-to the circulating water discharge snal system via a monitored line.

3.1.2 Radicactive Gesecus Effluents There ere two radioactive gaseous effluent release points fer Dresden Station Units 2 snd 3: the reactor building vent and the main chimney.

7tstets vaste treat.ent systems and discharge pathways are shcun li Ff;ure C.

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GMcNni FOR IINTTS 2 AND 3 COMMON FOR UNTTS 2 AND 1 l' muII v<1uipuent drain sump I

Wasta loactor 1.uilding equipmont drain tank collect.or T 1* Waste filter ruri.ino building oquipmont drain sump l

tank 5

Condensata i

storage e

l1'n 11 storage pool

'p Wasta demineralizer tank 4

lR_oactor cloanup system j

lWasta sample tanks l

Dopontamination solutions y

p I

Waste I

Decontamination l

surge tank Procoat solution tank I

tank I

Discharge Z l

po bryuell floor drain sump,

4 Floor drain J_"

Floor Floor drain canal Z

ltoact.on 1.uilding floor drain sump l

collector n

drain sample a

e h rbino building floor drain stunp tank filter tank I

U Service l

Liquid radwastaJ water effluent line system l

Radwasta building floor drain sumps g

Filter sludge storage tanks U

Spont resin storage tanks l

Raduasto high Uasta

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conductivity neutralizer To floor drain E*

drain sumps tanks collector tank ICondensata domineralizer Irogeneration solutions -

u F To w'aste collector tank Raste Concentrated g

y concentrator waste tank 55-gallon drums Mixer L

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Dresden 5.tation liquid radwaste system and discharge pathways.

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Hain Chimney M

(310 f t.)

Unit 2 SJAE d*

30 Minute lloldup 4 Noble Gas. Monitors Jk Iodine Sampler l

Unit 2 Turbine Building Particulate Sampler Unit 2 Turbine Gland Seal Uni t 2 flechanical Vacuum Pump lRadwasteBuilding l

Unit 3 Turbine Building linit 3 Turbine Gland Seal Uni t 3 Mechanical Vacuum Pump 5

Reactor 30 Minute lloldup

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J Building

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SGTS SGTS JL A S a w u

Noble Gas Monitor l Unit 2 Drywell' l

1 Iodine Sampler l

1 Particulate Sampler I'

O tinit No. 2 Reactor Duilding (Including Fuel llandling Area) t g

Unit flo. 3 Reactor Building l

(Including Fuel llandling Area) 1o l

tini t flo. 3 Drywell i

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Dresden Station gaseous radwaste system and discharge pathways

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-j The reactor building effluents from both units, including releases from the fuel storage areas, are collect.ed in a common header and normally l*

released through the reactor building vent, in the event of high

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radiat. ion levels in the reactor building exhaust plenum, the plenum radiation monitors will isolate the reactor building ventilation system and divert the effluents through the standby gas treatment system for

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eventual release out the main chimney.

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I Drywell air is vented to the main chimney during purging, if I

radioactivity is present in any significant quantity, this purged air is autcmatically routed through the standby gas treatment system, before release cut the main chimney. Gaseous effluents from the main condensers' off-gas treatment systems, turbine buildings, steam packi'ng exhaust systems', mechanical vacuum pump exhausts, and the radweste area are also released via the main chimney.

f 3.2 Padioleofcal Effluent Technical Soecifiestrens The following subsections describe the primary objectives of each section of the model RETS and summarize the commitmentt of the Licensee's FETS. A cross reference between the model RETS and the Licensee's RETS is contained in Table 1.

The chronological sequence of the RETS review was described in the Plant-Specific Eackground, Section 1.3 of this report.

3.2.1 Effluent Instrumen+etten The cbjective of the model RETS with regard te effluent instrumentation Is-to ensure that all significant IIquid and gasecus radicactive effluents are monitored. The model F.ETS specify that all ef fluent genitors be operable with periodic serveillance and that alarm / trip setpoints ce determined in order +o ensure ths? cffsite radicactive effluent concentrations do not exceed maximun permissible ecocentraticn ("?Cs) listed in 10 CFR cart 20, i

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The radioactive liquid effluent lines leading to the common releasa

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pointforDresdenStatlonUnits2and3aremonitoredwithadequate 4

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' nstrumentation surveillance being performed. Action statements in the i

F.ETS require appropriate sampli.ng'and analysis to be performed if releases

,,j are made with less than the minimum number of monitoring channels operable. The locations of the monitors are shown in' Figure 1.

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_-j The radwaste discharge line is continuously monitored during releases 1

although all releases are by batch mode. The monitor provides control room alarm upon high radiation, which initiates operator action, if any sudden increase of the radiation occurs during discharge, the batch release is terminated.

The service water discharge line is continuously monitored and control room alarm annunciation is provided if a high rediation level occurs. The probab,ljity of signiffcant radioactivity release in the service water is s

small, since the closed component cooling water system which it cools is at a lower pressure than the service water system. The RETS contain a ccomitment to perform surveillance of the monitoring instrumentation that ensures they will be OPERAELE.

I Therefore, the Licensee's RETS submittal en radicactive licuid ef fluant instrumentation neets the intent of !!UREC-0473.

i-3.2.1.2 Padleactive Geseous Effluen+ Instro-en+etien l

The radicactive gasecus effluent rel, ease points are,?cnftered Oith adequate instrument surveillance being performed.

Peleases from the main chimney are nonitored by four noble gas -

n:nitcrs which provide control ecem alarm annunciation u;cn hi-h radiaticn. The major scurces of radicactive gases in the cain chi.Tney are l

ir:,The *vo units' eff-ges systems.

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Each unit has dual radiaticn monitors downstream of the-steam Jet air f-,j' e.'ectors but prior to the 30 minute holdup pipe.

If a high radiation

)j condition is detected by these monitors, an Interval timer is initiated that will isolate these systems from the main chimney unless the condit Mn j

is corrected.

Peleases from the reactor building vent are ronitored and control room

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alarm annunciation occurs upon high radiation. Prior to release at the common reactor building vent, gaseous effluents from each reactor building are monitored in the vent exhaust duct by dual radiation monitors that

' provide automatic Isolation of the reactor building ventilation system and reroute effluents (at a reduced flow rate) to the standby gas treatment system (SGTS). Ef fluents from the SGTS are released via the main chimney.

The Licensee's RETS state that the monitoring requirements for the SJAE monitors are applicable during SJAE operation, and monitoring requirements for other Instruments are appilcable at all times.

Therefore, the Licensee's s'ubmittal on radioactive gaseous effluent instrumentation meets the Intent of fiUREG-0473.

3.2.1.3 Licu rd and Gaseous instruren+atten setroints The setpoints for the radioactivity monitors at each release point are '

established to prevent exceeding concentrations in liquid releases or corresponding dose rates for gaseous releases of 10 CFR Part 20 in unrestricted areas. The setpoints for the liquid and gaseous effluent

. instrumentation will be determined in accordance with the 00CM.

The Licensee's RETS submittal'on liquid and gasecus ef fluent nonitoring Instrurentation satisfies the provisicos and meets the intent cf fERIG-0473.

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if 3.2.2 Concentration and Dese Rates of Effluents Y

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3.2.2.1 Licuid Effluent Concentratten j

.I The Licensee's RETS include a commitment to maintain the concentration I

of radioactive liquid effluents released from the site to the unrestricted areas to within 10 CFR Part 20 limits, and if the concentration of IIquid i

. effluents released to the unrestricted area exceeds these limits, it will be restored without delay to a value equal to or less than the MPC values specified in 10 CFR Part 20. Both batch and continuous releases are i

sampled and analyzed periodically in accordance with an acceptable sampling and' analysis program.

Therefore, the Licensee's RETS submittal on liquid ef fluent concentrations meets the Intent of NUREG-0473.

3.2.2.2 Gaseous Effluent Dese Rate The Licensee's RETS include a commitment to maintain the dose rates in unrestricted areas at or beyond the site boundary due to radioactive materials released in gaseous effluents from the site to within 10 CFR Part 20 limits, and if the concentration of gaseous effluents exceeds these limits or the equivalent dose rate values, it will be restored without delay to a value equal to or less than these limits.

The radicactive gaseous waste sampling and analysis program provides for adequate sampling and analysis of the discharges. Therefore, the Licensee's submittal on gaseous effluent dose rates meets the Intent of NUREG-0473.

3.2.3 Offstte Ooses from Effloants j

The objectives of the model RETS with regard to offsite doses from I

ef fluents are to ensure that ef fsite deses are kept ALARA, are in 14

n compliance with the dose specificaticns of NUREG-0473, and are in l'

accordance with 10 CFR Part 50, Appendix I and 40 CFR Part 190.

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. The Licenses's RETS Include commitments (a) to maintain doses due to IIquids of fluents to within the !1UREG-0473 quarterly and annual dose

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,j criteria, (b) to maintain ncble" gas air doses in unrestricted areas to

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within the IIUREG-0473 quarterly and annual dose criteria, (c) to maintain the dose level due to release of lodine-131, Iodine-133, tritium and materials in particulate form with half lives greater than eight days to within the NUREG-0473 quarterly and annual dose criteria, and (d) to limit the annual dose to any member of the public due to release of radicactivity and radiation from uranium fuel cycle sources to within the requirements of 40 CFR Part 190.

Figu're 4.9.1, the map defining the site boundary fer radioactive gaseous and IIquid e,ffluents, is illegible and should be replaced Th'erefore, the. Licensee's RETS submittal on offsite doses from,,.

radioactive effluents meets the intent of NUREG-0473.

3.2.4 Effluent Treatment The cbjectives of the model RETS with regard to effluent treatment are to ensure that the radicactive waste treatment systems are used to keep

' releases ALARA and to satisfy the provisions for Technical Specif!'ations c

governing the maintenance and use of radwaste treatment equipment.

The Licensee's RETS include a ecmmitrent to use the liquid radweste trecTaent system when the projected mont'hly dose exceeds 25 percent of the annual dose design objective prorated monthly for the two unit site. The projections are to be made at least once per 31 days in accordanco with the CCCM. A ccmmitment is also mace to submit a special reperT within 30 dsys if use of the liquid waste treatment system is recuired and the waste 1

is 'beir.g discharged withcut treatrent.

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l Tha Licensee has committed to operate the offgas treatment system at all times when processing for discharge to the environs.

It was determined that use of the of f-gas charccal adsorber beds are not required below 30

. f l4 percent of rated thermal po or. A commitment is also made to submit a

-d special report within 30 days if gaseous wastes are discharged for more j

?.'an seven days with the charcoal beds bypassed whl.ie the reactor is

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cperated at greater than 30 percent of rated thermal power.

Therefore, the Licensee's RETS submittal en ef fluent treatment meets the intent of NUREG-0473.

3.2.5 Tank inventerv Lini+s I

The objective of the model RETS with regard to a curie limit on liquid-c,ontaining tanks is to ensure that in the event of a tank rupture, the concentrations in the nearest potable water supply and the nearest surface water supply in an unrestricted area.would not exceed the limits of 10 CFR Part 20, Appendix B, Table 11. The objective of the model RETS with regard to a curie limit on gas-containing tanks is to ensur's that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to an Individual'at the nearest exclusion area boundary will not exceed 0.5 rem.

The Licensee's RETS specifies a total limit of 3.0 curies on the traste Sample Tanks, the Floor Crain Sanple Tanks, and ths **aste Surge Tank, and each tank to contain no more than 0.7 curies. The RETS do not address temporary outside tanks, since use of such taiks are not anticipatr e.

Therefcre, the Licensee's RETS submi.ttal en tank inventory limits meets the intent of' NL' REG-0473.

3.2.6 N 'esive Get Miv5 res

. The objective of the ocel 1ETS with reprd to explosive gas mixtures is ?: arevent hyde: gen e.v: !:sicns in 'Fe weste p s syste.

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4 t'. i The Licensee's RETS include a commitment to monitor the hydrogen

j' content of the of fgas holdup stream (downstream of the recombiner), or to verify every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> that the recombiner is operating within the allowable U*

band of the baseline plot of recombiner outlet temperature vs. reactor j

power, if the recombiners are Inoperable for more than 7 days in a i

j calendar quarter whlie the reactor is operating at 'above 30 percent of

• rated thermal power a special report will be submitted to the NRC within j

30 days.

Therefore, the Licensee's RETS submittal en explosive gas mixtures meets the in. tent of NUREG-0473.

3.2.7 Solid Radwaste System The objective of the model RETS with regard to the solid radweste system is to ensure that radwaste will be proporly processed and packaged before it is shipped from the plant to the budlal site to satisfy the requirements of 10 CFR Part 20, Section 20.301 and 10 CFR Part. 71.[38]

W The Licensee's RETS Include a commitment to process wet radioactive wastes in accordance with a PCP to ensure the solid waste shall meet shipping and burial ground re,quirements prior to shipment from ine site.

Therefore, the Licensee's RETS submittal on solid radioective waste meets the Intent of NUREG-0473.

l =

e l

l 17 l

. 4

-i't 4

l 4

3.2.8 Dedfotecica! Envfren-entel Menf+crino Procram 1

l

'l The objectives of the model RETS with reg'ard to radiological jj environmental monitoring are to ensure that (a) an adequate full-area j

coverage environmental monitoring program exists, (b) there is an d

appropriate land 'use census, and (c) an acceptable Interlaboratory Comparison Program exists. The monitoring program implements Section U

IV.B.2 of Appendix ! to CFR Part 50, and the land use census satisfies the requirements of Section IV.B.3 of Appendix lato 10 CFR Part 50. The requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks are performed as part of the quality assurance program for environmental monitoring to demonstrate that valid results are obtained for Section IV.B.2 of Appendix l to 10 CFR Part 50.

The Licensee's RETS for a radiological environmental monitoring program have followed in general the Intent of the ocdel RETS and the Branch Technical Position on the subject issued November 1979,[343 as appI! cable to the site, and have generally %provided an adequate number of locations for pathways identified. The Licensee's method of sample analysis and maintenance of the menttering program satisfies the requirements of Appendix 1, 10 CFR Part 50. The Licensee's RETS contain a land use census specificaticn which requires obtaining the appropriate annual information for a SWR. The RETS also state that the Licensee will participate in an NRC-eporoved Interlaboratcry Ccmperison Program.

Thus, the Licensee's RETS submittal for a radiological environmental monitoring program meets the Intent of NUREG-0473.

3.2.9 Audits and Reviews I

The objective of t'he redel RETS' with regard to audits and reviews is to ensure that audits and reviews of the radweste and environmental l

trenitoring programs are properly conducted.

18

i n!

i t--

4 The Licensee's administrative structure identifies the Onsite Review

'j' and Investigative Function and the Audit Function (Hanager of Quality 1

Assurance) as the two entitles comparable to-the Unit Review Group (URG) 7.

and the Company Nuclear Review and Audit Group (CNRAG), respectively.

The Onsite Review and investigative Function is responsible for reviewing any unplanned on-site release of radioactive material, changes to the ODCM and PCP, and major changes to the radweste treatment systems.

The Manager of Quality Assurance is responsible for auditing the radiological, environmental program and results thereof, the 00CM and implementing procedures,.the PCP and implementing procedures, and the perfccmance of activities required by the quality assurance (QA) program.

These audits are performed at the frequency required by the model RETS except for the QA audit which is performed at least once per two years.

The Onsite Review and investigative Function and the fianager of Quality. Assurance encompass the total responsibility for reviews and

,ww.,

audits specified in NUREG-0473.

~ '"

3.2.10 Procedures and cecords The objective of the model RETS with regard to precedures is to ensure that written procedures be established, implemented, and maintained for the CP, the CCC.*d, and the QA prcgram for effluent and envircnnental monitoring. The objective of the model RETS with regard to records is to ensure that documented records pertaining to the radiological environmental monitoring program are retained.

The Licensee's RETS include a commitment to establish, laplement, and naintain written procedures for the PCP, CCCM, and QA programs. The L*:e.see's existing technical specificatiens require the rec:rds of off-site environmental monitoring surveys to be retained for the life of tFs pl ant, which meets the intent cf the model RETS.

19 y.---,

,,y

___.----m

i q

I Therefere, the Licensee's RETS submittal.on procedures and records q

meets the. intent of NtJREG-0473.

3.2.11 Reoorts

~

The objective of the model RETS with regard to reporting re' uirements q

is to ensure that appropriate annual and samlannual periodic reports and special reports are submitted to the NRC.

The Licensee's RETS include commitments to submit the following reports:

1.

Environmental Procram Data (Annual Recor+)

The Licensee's RETS Includes a conrnitment that this report will be submitted by March 31 of the next year.

It will include:

e Summaries, Interpretations, and analysis of trends of the

.-_L' results of environmental sampling, e

Results of the census to determine the locations of animals producing milk for human consumption.

Results of environmental sc.epling summarized on a quarterly e

basis foFicwing the format of Regulatory Guide 4.8 Yable 1 (December 1975).[393 The report shall explain any missing

results, An assessment of radiation dose via the principal pathways e

of exposure resulting from plant em!'ssions of radioactivity including the maximum noble gas gamma and beta air doses in the unrestricted area.

~

4 e

The reason fer emissicn if the nearest dairy to the station f.s not in the monitoring program.

e An annual summary of meteorological conditions concurrent with the releases of gaseous effluents.

e The results of the Interlaboratory Comparison Program.

e.

The results of the 40 CFR 190 uranium fuel cycle dose analysis for the calendar year.

a -

e A summary description of the monitoring program.

e Maps showing simpiing locations and tables giving distance and direction of sampling locations from the station.

2.

Padicactive Effluent Release Recert (Semisnnual)

Thisreportshallbesubmitted'totheCo'mmIssion'within60daysafter January 1 and July 1 of each year specifying the quantity of each of the principal radionuclides released to unrestricted areas in IIquid and gaseous ef fluents during the previous 6 months. The format and content of the report shall be in accordance with Regulatory Guide 1.21 (Revision 1) dated June 1974, which contains the requirements for reporting the solid wastes shipped offsite. Any changes to the FC? shall be included in this report. Changes to the OCCM shall be included in the monthly operating report.

3.

Soeciai Pecer+s The Licensee's RETS incluce a commitment to file a special report, within 30 days of'the tire specified in the Technical Specifications under the follcwing conditions:

l l

l 21 l

i Exceeding the li' quid effluent dose limits of'3pecification e

3.8.S.2.s or 3.8.3.2.b.

Exceeding the gaseous ef fluent dose limits of Specifications e

3.8.A.2.a, 3.8.A.2.b, 3.8.A.3.a, or 3.8.A.3.b.

Exceeding the total dose limits of Specifications 3.8.A.2.a, e

-j 3.8.A.2.b, 3.8.A.3.a, 3.8.A.3.3.b, 3.8.3.2.a, or 3.8.3.2.b.

Exceeding the reporting levels given in Table 4.0.5 for the e

radioactivity ceasured in the environmental sanpling program.

o b' hen radioactive liquid or gaseous ef fluents require treatment before discharge according to Specification 3.8.S.3 and the waste treatment equipment is in operable.

Therefere, the Licensee's RETS submittal on reports meets the intent of NUREG-0473.

..; F e

3.2.12 0+Ser Adriats+r3+Ive Centrots An objective of the model RETS in the administrative controls section is to ensure that any chan.qes to the PCP and CCC.1 and major changes to the radicactive waste treatment systems are reported to the NF.C.

Such changes shall be reviewed and accepted by the URG before loplementation.

The Licensee's RETS state that changes to the CCC?l and FCP shall becoce effective as reviewed by the Onsite Review Function. Changes in the CCC:t sFall be repceted to the Conmission by inclusion in the Ucnthly Operating Report. Changes to the'FCP shall be reported to the Ocnmission in the Radioactive Effluent Release (Semiannual) Report for the parted in

.thich the chenge was made. \\Mjor changes to the radicactive waste treatment systens shsil be reported in the enthly Re;cet for the perled in wh!ch the evaluaticn was raviewed by the Onsite Revies Furction.

22

.1 Therefore,theLicensee'skETSsubmittalfortheseadministrative is '

controls meets the Intent of NUREG-0473.

j, 3.3 offsite cose Calbulation Manual

+

As'specifled In NUREG-0473, the ODCM is to be developed' by the

+

' Licensee to document the methodology and approaches used to calculate of fsite doses and maintain the operability of the effluent system. As a minimum, the ODCM should provide equations and methodology for the following topics:

Alarm and trip setpoints for effluent Instrumentation.

e Liquid effluent concentration in unrestricted areas.

e e

Gaseous effluent dose rate or cencontrations at or beyond the site boundary.

~ 27$5

~

Liquid and' gaseous effluent dose contributions.

e Total dose compliance, incl'uding direct shine.

}

e e

Liquid and gaseous effluent dose projections.

In addition, the OCCM 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. A description and the locations of samples In support of the i

environmental monitoring program are also needed in the CCCM.

r.

~ 3 '.3.1 Eveluatien The Licensee's CDC4 satisfies the equation in the addendum of NUREG-0133 to determine the alarm and trip setpoints for the IIquid t

l l

23

.. ~....

>0 3

a effluent ecalt'rs. This assur'es that the alarm and trip actions will o

f cccur prior to exceeding the 10 CFR Part 20, Appendix B, Table 11 values 1

at the discharge point to the unrestricted area.

j 5

i

~

i

- t The alarm and trip setpoints for the gaseous ef fluent monitors are

siculated to assure that alarm and trip actions will occur pricr to

l exceeding the limits set in 10 CFR Part 20 for annual dose rates to unrestricted areas. The Licensee uses equations similar to those contained in NUREG-0133 with the dose rate values identified in NUREG-0473. The OCCM describes the noble gas monitoring system for the main chimney releases as two channels of sodium Iodide detectors, which is inconsistent' with Table 3.2.5 of the Technical Specifications.

The Licensee's 00CM contains the methods and calculational relationships that are used to compare the radioactivity concentrations in

' liquid effluents at the point of release to the 10 CFR Part 20 limits prior to the release and after the release.

1 TheLicensee'sODC*1statesthatnoblegas;dischargesareassuredtobe within the NUREG-0473 dose rate limits by correctly determining the setpoints for the noble gas monitors. The dose rate due to the release of I-131, 1-133, and racionuclides in particulate' form with half-lives

~

greater than eight day Is' assured to be within the NUFEG-0473 limit of 1500 neem per year by calculating the dose rate to an adult via the Inhalation pathway. (The bases statement in MU9EG-Ca73 states' the thyroid dose rate to a child via the inhalation pathway is the limiting dese rate pathway.) The dose rates are calculated using the maxima X/Q or D/Q at or beyond the unrestricted area boundary.

o e

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24

-. ~. - - -

j.

l i!'

The _ Licensee's CDCM demonstrates compliance with 10 CFR Part 50,

'f' Appendix I by calculating the monthly dose commitments for IIquid and gaseous ef fluents at least once per 31 days.

• The calculated cumulative

[4 values are compared to the quarterly and annual limits to demonstrate compliance.

The Licensee's RETS commits to projecting doses to determine if the liquid radwaste treatment system must be operated. The ODCM does not include the dose projection methodology.

' Specific, parameters of distance and the direction sector from the centerline of a reactor and additional information have been provided for most of the sample locations in RETS Environmental Monitoring Table 4.8-4, in ODCM Tables 8.4-1 and 8.4-3, and in ODCM Figures 8.4-1 end 8.4-2.

The CDCM does not contain simplified diagrams of the !! quid and gaseous release points, the liquid radwaste treatment system, or the solid a

radwaste system. Forty-two TLD locations are^ stated in the Technical-Specifications, which are not all identified in the GCCM figures. Two public. water samples are required whereas only one surface water location is identified in the CDCM.

In addition, the fish consumption rate of 2.4 x 10-4 kg/hr on page 7.2-1 of the ODCM should be 2.4 x 10-3 kg/hr.

The Licensee's ODC:! for Dresden Station Units 2 and 3 is generally in compliance with the !;RC requirements and uses c:ethods consistent with the nethodology and guidance prescribed in f:UREG-0133.

3.4 Process Control proccam NUREG-0473 specifies that the Licensee develep. a FCP to ensure that the processing and packaging of sclid radioactive wastes will be 2ccenplished in ccrpliance witt to CFR cart 20, 10 CFR Part 7*,[392 ned other Federal and State regulattens or requirecen's governing tre offsite dispcsal cf the icw-level radicactive waste.

25 w

g e

--a-y -

y

_m.

.m_,

u The PCP is not intended to contain a set of detailed procedures; rather, it is the source of basic criteria for the detailed procedures to be develcped by the Licensee. The criteria u~ sed for the PCP are to address only today's requirements. The uncertainty about PCP requirements results from the recent promulgation of 10 CFR Part 61, " Licensing Requirements for land Disposal.of Radioective Waste." The NRC staff's

• technical positions are presently being developed by the Division of Waste Management.

3. 4.1 Evaluation The Lice'nsee's PCP describes the types of IIquid wastes to be solidified and the processes used to accomplish solidification. Waste is normally solidified using a commercially built cement solidification system. The manufacturer's tested procedures and waste-cement mixture formulations ar e followed. Periodically, the Quality Assurance Department destructively examines fillet containers. Drums are inspected for. free standing water, quality of solidification and mixture.

1^

Periodically, Dresden w!!! use vendor supplied equipment and services to solidify various waste ferms. A vendor must meet applicable CEC qt2llty standards as well as current NRC requirements (approved Topical Report).

A commitment is made that all wastes shtrped of f site are packaged and shipped in compliance with DOT, NRC, and burial ground criteria.

Therefore, the Licensee's PCP is in compliance with the intent of the NRC guideltnes as presently developed.[273 4.0 Cerefusfens The Licensee's preposed RETS, CCCT1, and PCP were reviewed, evaluated 2nd *t was cencluded that:

25 t

u.

_,.m.m._

e

'The Licensee's proposed RETS for Dresden Station Units 2 and 3 submitted Stay 3,1984 meets the intent of the fGC staf f's

)

" Standard Radiological Effluent Tecttnical Specifications for Eolling Water Reactors," flUREG-0473.

The Licensee's ODCM received by the NRC April 19, 1983[23]

generally uses documented and approved methods that are consistent with the methodology and guidelines in NUREG-0133, with the fqilowing exceptions:

~

~ The outstanding issues noted in~ references 24 and 25 that 1.,

apply to the generic Sections of the CEC ODCM. The most significant of these issues are:

a.

The dose rate to an adult (Instead of a child) via the Inhalation pathway is used,to assure that the. limit of 1500meem/yearinSpect'~ida.... tion 3.8.A.1.b is not f

exceeded, 4.nn b.

The dose projections to determine when to use the IIqu'd waste treatment system, required by Speci fication 4.8.B.3, are not included.

2.

The CCC'J description for the main chinney's noble gas monitoring system appears to be inconsistent with T6 ole 3.2.5 of the Technical Specifications.

3.

The listing of sampling Iccations in Table 8.4-1 does not include serples of public' water from two locations as f

required by Table 4.8.4 of the proposed RETS.

~

4 The 42 TLD locations are not identified in Figures S.4-1 cr 8.4-2.

5.

The s;s cf F*gures 3.4-1 =nd 9.J-2 do not include the enviren.vental sariple locations 17 thrcugh 38 in Table 6.4-3.

i 27 L

6.

Block diagrees are not included sh.owing: the liquid and l'

gaseous radwaste treatment systems, the IIquid and gaseous p

radwaste release pathways, or the solid radweste system.

a 7.

The value for the fish consumption rate on page 7.2-1 should be reevaluated.

n 1

The Licensee's proposed PCP submitted f'ay 3,1984 meets the e

Intent of the flRC's present guidelines.

. A correspondence between (a) NUREG-0473, (b) the Licensee's current RETS, and (c') the Licensee's proposed RETS is shown in Table 1.

6 9

6

• 4 eh h6

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1 28 l-

i TABLE 1.

CORRESP0t:DENCE CF PROVISIONS CF NUREG-0473, THE LICENSEE'S 1'

CURREtrT TECHNICAL SPECIFICATIONS AND THE LICENSEE'S PROPOSAL FOR DRESDEN STATION UNITS 2 AFD 3.,

NUREG-Current Technical Licensee's RCTS Recuirement'

-0473 Soectftesttens Proeosai a

Effluont (Liquid) 3.3.3.10 3.8.C.1 3.2.F instruerentation (Gaseous) 3.3.3.11 3.2.0, 3.8.A.1 3.2.G Concentrations in Liquids 3.11.1.1 3.8.C.2, 3.8.E

3. 8.B.1 Dose Rate for Gases 3.11.2.1 3.8.A.2, 3.8.E 3. 8.A.1 3.8.8.2 Offsite Doses from Liquids 3.11.1.2

3. 8.A.2 Offsite Doses from Gases 3.11.2.2 Offstte Doses from 3. 8.A.3 lodine-131, etc.

3.11.2.3

3. 8.A.2.d,

Total Offsite Dose 3.11.4 3. 8.A.3.d,

3.8.B.2.d

'y.

Liquid Radwaste Treatment 3.11.1.3 4.8.E.1 3.8.B.3-4 Gaseous Radweste Treatment 3.11.2.4 4.8.E.1 3. 8.A.4,b Tank l'nventory Limits 3.11.1.4

.8,0 3.0.8 Explosive Gas Mixtures 3.11.2.6 3. 8.A.5-6 Main Condenset Effluent 3.11.2.7 3.8.A.7 Mark I or Mark 11 3.11.2.8 Containment Solid Radwaste (PC?)

3.11.3 3. 8.?

Radiological Environmental 3.12.1 4.8.E.1 3.8.E ibnitoring Land Use Censas 3.12.2 4.8.E.2 3. 8.E.'5-6 4

interlaboratory Ccmparisons 3.12'.3 3.8.E.7-8 Audits and Reviews 6.5.1 6.1. G.2. a 6.1.G.2.d 6.5.2~

6.1.G.I.b 6.1.G.I.b Procedures and Fecords 6.8, 6.10

--, 6.5.8

--, 6.5.B

=cports 6.9 6.6.C.1 6.6.C.1 6.6,0.2 6.6.0.2 Other Adm.inistrative 6.13 6.9 0:-+ro l s (:C?, "CC", Chan;es 6.14 6.5 to Racwaste Systems) 6.15 5.10 2

t 1

i

.I1 "I

5.0 REFEREHCES 1.

United States Huclear Regulatory Commission, Radfotocical Effluent 6

Technics f Soecif f estions for Bollina Water Reactors, ilVREG-0473, Revision 2, July 1979.

2.

United States Office of tho' Federal Register, Title 10, Code of Feders! Deculations, Part 50, Appendix 1, " Numerical Guide for Design Objectives and Limiting Conditions for Operation to iteet the Criterion

'As Low as in Reasonably Achievable' for Radioactive ifaterial in Light-t!ater-Cooled Nuclear Power Reactor Effluents."

3.

United States Of fice of the Federal Register, Title 10, Code of Federal Peculattens, Part 50, Section 50.36a, " Technical Specifications on Effluents from Huclear Power Reactors."

4.

United States Of fice of the Federal Register, Title 10, Code of Federal Requisttens, Part 50,Section V.9., " Effective Dates."

5.

United States Office of the Federal Register, Title 10, Code of Federal Deculations, Part 20, " Standards for Protection Against Radiation."

6.

United States Office of the Federal Register, Title 40, Cede of Fadarst Reculations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations."

7.

United States Office of the Federal Register, Title 10, Code of Federst Reculatter.s, Part 50, Appendix A, " General Design Celteria fer fluclear Power Plants."

8.

United States Office of the Federal Register, Title 10, Code cf raderal Ceculettens, Part 50, Appendix 8, "Cuality Assurance Criteria for Nuclear Power Plants and Fuel.:eprocessing Plants.

9.

United States Nuclear Regulatory Commission, Precere+fon of Pedfolectest Effluent Technfeel Scecif ica+fons for Muet eer Power Plan +s, NUREG-0133, October 1978.

10. United States Nuclear Regulatory Ccmmission, S'endard Pedr tocient o

?oee ficattens for cassurtree tr tar :aec+ers, r

a E

• f luen-Techn ica l MUREG-0472, Revision 2, July 1979,

11. C. A. Willis and F. J. Congel, "Suirmary of Craft Contractor Guidance of 'ITS," afr ~~vtrea-an'st Sutee--it+=d "e?+t-c,'resst

+cn 7, c,

"ay ! ?,1952.

9

12. F. J. Congel, !'emo to RAS Staf f (':RC), tata-t-C', aces

!* -'a "cdat 0,III, August 9, 1982.

.~

1 T

, t

.j

13. United States Nuclear Regu'latory Commission, Standard 2ndrofeofcal Effluent Technical Soecifications for Boilina Water Reactors, fiUREG-0473, Revision 3, Draf t 7, September 1982.

14. "Information Relevant to Keeping Levels o'f Radioactivity in Effluents

4 a

to Unrestricted Areas As Low As is Reasonably Achievable," Dresden Station, Unit Nos. 2 and 3, June 4,1976, Commonwealth, Edison Company.

15. "Ammendment I to Dresden Station, Unit No. 2 and 3, Appendix I Feport," November 12, 1976, Commonwealth Edison Company.

16. NRC Memorandum, DSE Evaluation of Dresden Nuclear Pewer Ststion. Unit Nos. 1. 2. and 3 With Reseect to Aeoendix I to 10 CFR Pa t 50, September 7, 1977.

17. F. B. Simpson, Letter of Transmittal, Transmittel of Ouestions for the

. Commonwealth RETS Review - Sim-2-82, January 19, 1982.

18. B. Rybak, Letter of Transmittal, Dresden Station Units 2 and 3 Oraft Radiolecical Effluent Technical Soecifications (PETS) NRC Docket Egt._

50-237 and 50-249, January 12, 1984

' ~ ~

I

19. W. Serrano, Letter of Transmittal, Pavlew of Ores' en Draft' oETS d

Submittat - Serr-3-84, February 8, 1984.

..e: utt :. 0,;

20. B. Rybak, letter of transmittal, Dresden Station Units 2 and 3'.

~

Procesed Arrerdment to OPR-19 4 25 Dadiolocical Ef fluent Techn tesi Sceciffections (CETS). 4:C Oceket >bs. So-?t7 and 90 739. May 3,.1984 1

i

21. C. L. Tillier, Transmittal of resolution to Dresden RETS review comments, May 10, 1984.

22. Commonwealth Edison Company, "Dresden Station'0ffsita Dose Calculation lianual," February 1979.

3. L. Literski, letter of transmittal, Revised pages to Cuad Cities, Dresden, and Zlon CDCM, April 4,1983.

24. W. Serrano, Letter of Transmittal, Cuad Cities SETS and CDCf4 Final Feviews - Serr-13-83, May 17,1983,

25. M. Serrano, Letter of Transmittal, Outstandino items of +he o;ad Cf +ies DETS and OOC?t :eviews - Sere-19-83, June 24,1983.

25.11. Serrano, Letter of Transmittal, Dresden PC and 00Cf8 Aeviews.

Sere-4-1984, February 14, 1984.

27. C. A. Illllis, Lotter of Trsnsmitts!, Guidance en 'he eview of +5e

ccess Cen+rel -ecrans (PC'), January 3, 1983.

22. United States Office of Federal Register, Title 10, Code e' rad 9"?'

Se+;'a+ teas, :srt 20, Accendix E, Concentrations in Air and 't/ ster

,e "stura! Isek;rtund.

l

27. C. A. *,!Illis, Letter to F. ?. Simpsen (su-nart:Ing chen;es to OETS e:uire. ents 'Olle. tr; eeting with Atemic Industrial Forum),

• ove-cer

, l}61.

31

-.-,n

l i

30. W. E. Kreger (NRC), memo to R. J. Mattson (NRC), Plans for Dest ino J

With the Exolosive Gas issue in imolerentino the Radfotoofcal Effluent j

?-

Technical Soecifications (RETS), December 14, 1981.

,j 1

1

31. C. A. Willis and F. J. Congel, " Status of NRC Radiological Effluent Technical Specification Activities,"* Atomic Industrial Forum 3

Conference on HEDA and Nuclear Reculatloas. October 4-7, 1981.

?C. C.* A. Willis, memo to P. C.. We'gner, Plans for ino f erent'f na Radfotocical Ef f teen + Technical Soeeffications for Coeratine Reac*ers, ibvember 4,1981.

33. W. P. Gammill (NRC), memo to P. C. Wagner (NRC), Current Ros f + fen on Padfefoofcal Efffuent Technical Soecifications (RETS) Includina

~

Exo f os ive Gas Controls, October 7,1981.

~

34.' United States Nuclear Regulatory Commission, Radiological Assessment

~

Branch Technical Position, An Acceotable Radioteofcal Environmental fbn f terino Deceram, November 1979.

35. United States Nuclear Regulatory Commission. Methods for Demonstratino -

LWR Cero f f ance with the EPA Uranium Fuel Cvele Standard (40 CFR Part 10.01, NUREG-0543, February 1980.

36. United States Nuclear Regulatory Commission, Branch Technical Position, General Con +ents of the Of f site Dose Calculation uanual, Revision 1, February 8,1979.

.:4

__.w

37. Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Corpliance with 10 CFR Part 50, Appendix I," Revision 1, U. S. fluelear Regulatory Ccmmission, Washington, D. C.

20555, October 1977.

38. United States Office of the Federal Register, Title 10, Code of r deral ceculattens, Part 71, " Packaging of Radicactive Material for e

Transport and Transportation of Radioactive fiaterial Under Certain Conditions."

4

39. Regulatory Guide 4.8, " Environmental Technical Specifications for Nuclear Power Plants," U. S. Nuclear Regulatory Commission, Washington, D. C., December 1975.

22

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RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)

IMPLEMENTATION - DRESDEN STATION UNITS 2 AND 3 NUCLEAR

.o.r...

,co ure.

GENERATING PLANTS

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June 1984 T. E. Yctng, F. E. Simpson, W. Serrano, D. W. Akers, S. W. Duce, J. W. Mandler June 1984

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A review of the Radiological Effluent Technical Specificatiens (RETS) for the Dresden Station Units 2 and 3 Nuclear Generating Plants was performed. The principal review guidelines used were NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," and Draft 7

of NUREG-0473, Revision 3. " Standard Radiological Effluent Technical Specifications for Boiling Water Reactors." Draft submittals were discussed with the Licensee by both EG&G and the NRC staff until all items requiring changes to the Technical Specifications were resolved. The Licensee then submitted final proposed RETS to the NRC which were evaluated and found to be in compliance with the NRC review guidelines. The proposed Offsite Dose Calculation Manual and Process Control Program were reviewed and generally found to be in compliance with the NRC review guidelines.

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