ML20116P039

Forwards Info Re Plans to Transfer Sand Dirt from Inside Protected Area to Fenced Area at Storm Drain Collection Pond,For Use as Dike Stabilization Matl,As follow-up to Insp Repts 50-324/92-25 & 50-325/92-25

ML20116P039
Person / Time
Site:	Brunswick
Issue date:	11/12/1992
From:	Mccarthy D CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-92-245, NUDOCS 9211240269
Download: ML20116P039 (29)

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CP&L Carolins Power & Light Company NOV 121992 SERIAL NLS-92-245 4

w United States Nuclear Regulatory Commission ATTE': TION: Document Control Desk Washington, DC 20555 BRUMSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50 324/ LICENSE NOS DPR-71 & DPR-62 TRANSFER OF DIRT / SAND TO STORM DRAIN CCLLECTION PDND Gentlemen:

a' The purpose of this letter is to provide the NRC with information relative to Carolina Power & Light Campany's (CP&L) plans to transfer sand and dirt from inside the Protected Area of the Brunswick Plant to a fenced area at the Storm Drain Collection Pond, for use as dike stabilization material.

This submittal provides follow-up w information previously provided to the NRC, as discussed in NRC Inspection Report 50-325 6 50-324/92-25. Enclosed are details of the transfer, as well as information necessary for NRC Staff review of this issue.

As discussed with the NRC Staff, CP&L considers this activity a transfer of material to a restricted area on the site, not a disposal; therefcce, CP&L considers it unnecessary to submit a 10 CFR 20.302 applicatior, for alternate disposal. Our current plans are to begin transfer of the dirt / sand materials to the Storm Drain Collection Pono dike area in early 1993, i

Please refer any questions regarding this submittal to Mr. D. 53. Waters at (919) 540-2710.

l Yo rs very truly, 47/c-

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,N/ U Ac D. C. McCarthy Manager i

Nuclear Licensing Section JWD/kab (dct-sand.th)

Enclosure cc:

Mr. S. D. Ebneter Mr. R. H. Lo Mr. R. L. Prevatte i

200075 (0'\\ ;

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l 411 Fayetteville Street

• P Q. Box 1551

• Ra eign, N C 276c2 9211240269 921112 E

"Wh*"NNM PDR ADOCK 05000324 G

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ENCLOSURE 1 i

I BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 4

NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 TRANSFER OF DIRT / SAND TO STORM DRAIN COLLECTION POND DETAILS OF TRANSFER PROCEDURE The dirt and send being transferred to the Storm Drain Collection Pond (SDCP) dike area is being generated as a result of three efforts: 1) lowering of the grade of certain areas inside the Protected Area to ensure proper drainage,2) removal of sand and dirt from the Storm Drain Collection System, and 3) removal of sand and dirt from the Condensate Storage Tank (CST) pump erea to permit installation of a concrete slab and building around these pumps. Figure 1 provides a drawing showing the relatior: ship of the Storm Drain Couection Basin (SDCB) to the Storm Drain Collection Pond. Table 1 provides the results of samples taken on the sand and dirt in the SDCB.

Table 2 provides the results of samples taken at various locations inside the Brunswick Plant Protected Area.

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The SDCP (identified as the stabilization pond in Technical Specification Tables 4.11.1 1 and 4.11.1-2) is located outside the Brunswick Plant Pratected Area but inside the Owner Controlled Area. The area is approximately 64 acres, with approximately 39 acres under water. The entire dike area is fenced and posted as a Radioactive Matenals Area. The sand and dirt to be moved to the SDCP will be shoveted from the Storm Drain Collection Basin and placed into dumpsters. The sand and dirt removed from the CST area is currently being stored :n dumpsters in the Brunswick i

Low Level Warehouse. The dumpsters will be moved by trailer to the Storm Drain Collection Pond j

dike area. The sand / dirt will then be removed from the dumpsters and placed on and inside the bank of the SDCP to aid in building-up and fortifying the Lanks of the SDCP.

4 RADIOLOGICAL CONTROLS TO BE USED DURING TRANSFER i

The sand / dirt collected in the SDCB consists of soil materials that have washed into the basin from various areas inside the Protected Area over the years. As shown in Tables 1 and 2, the sand / dirt has very low levels of radioactiv. contamination; therefore, no special radiological protection devices, such as respirators or additional dosimetry, would be necessary. The dumpsters will be surveyed for loose contamination prior to leaving the Protected Area in accordance with approved plant procedures.

1 DISTRIBUTION OF MATERIAL AROUND THE SDCP The dirt and sand removed from the Protected Area is to be placed on top of, and inside of the existing bank around the SDCP. The top of the bank is maintained wide enough so that a service vehicle can be driven around the SDCP periodically to inspect bank integrity.

ENVIRONMENTAL MONITORING PROGRAM FOR SDCE i

The SDCP is a permitted release point for the Brunswick Plant, as discussed in the brunswick j

Technical Specifications and Updated Final Safety Analysis Report (UFSAR). Releases from the SDCP are sampled for radioactivity in accordance with Technical Specification requirements.

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1' Typical isotopic analysis of the SDCP effluent only shows Tritium, Data for these releases '

4 included in tne Semiannual Rauloactive Effluent Release Report.

As shown in UFSAR Figure 9.3.3-1, multiple areas within the Protected Area d.ain into the Storm Drain Collection Basin. The basin effluent is transferred to the Storm Drain Collection Pond via a transfer line equipped with a radiation monitor with automatic isolation capability. SDCP effluent is released into the Brunswick Plant intake canal (see Figure 1) and are typically made according to

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expected rainfall Releases from the SDCP are typically made over a several-day period, at a release rate of apprnximately 1,000,000 gallons / day.

DIKE WLURE ANALYSIS An analysis was prformed with respect to the SDCB sand / dirt to consider the worst-case pathway for transfer to man from radionuclides inside and around the SDCP. Four potential pathways to 4

humans were considered, including those resulting from dike overflow, dike failure, or game animal consumption. Since the majority of the radionuclides in the SDCP are adhered to the sand in and rund the pond area, a failure of the dike would result in a localized transfer of radioactive

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material. The concentrations in the pond water would be quickly diluted below detectible amounts in the surrounding estuary system; therefore, the radiological consequences from the loss of the pond water inventory to the surrounding environment, either by overflow of the SDCP or dike failure, are not expected to be any more severe than a controlled, permitted re'Jase. Dike ovetflow has been experienced during one period of heavy rainfall, in April,1991, the plant area received 10.22 inches of rainfall, with the majority falling in a 6 to 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> period. This resulted in water overflowing the dike of the SDCP. Overflow water was sampled and analyzed. Radionuclide-concentrations were less than detectable in the overflow water. Reporting of this event was made to the North Carolina Division of Environmental Management.

8 Since the majority of the gamma-emitting inventory of the SDCP area is in the sediments, two events become the most limiting scenarios: analysis of the food chain pathway resulting from the 3

vegetation and SDCP water being consumed by game animals in the area (i.e., deer), and a i

pathway resulting from the water inventory in the SDCP drying up (as would occur as a result of a dike failure) and the sand becoming airborne. Of these scenarios, the food chain pathway through l

game animals was shown as the most limiting pathway. The analyses were performed using criteria of Regulatory Guide 1.109, and showed a conservative worst-case organ exposure to l

individuals consuming these game animals of 5.68E-2 mrem / year.

i The analysis discussed above considered worst-case pathway for the sand / dirt in the SDCB. When removing sand / dirt from other areas of the plant a check will be made to ensure that the concentration of radionuclides in this material is bounded by the concentration of radionuclides in the SDCB. If the concentration of radionuclides is found to be greater and additional analyses l

indicate that the total worst-case organ exposure is significantly higher than that fre.n the SDCB, l'

then the material will not be transferred to the SDCP.

l PROCEDURES TO MINIMlZE DIKE FAILURE Building-up and stabilizing the SDCP dike, using the sand / dirt material from inside the Protected Area, will help to ensure that the SDCP does not overflow or fail in the future. Vegetation growth along the SDCP over the past several years has been allowed to help stabilize the dike. In f

addition, as discussed earlier, the top of the SDCP bank is maintained wide enough so that a service vehicle can be driven around the SDCP periodically to inspect bank integrity. To help El 2 l

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prevent an overflow event similar to the one that occurred in April,19S1, normal practice is to initiate a permit'ed release when extremely high rainfall is expected.

1 RELATIONSHIP TQ_ OCTOBER 9.1,891 DREDrajNG SUB[,ilTTAL The October 9,1991 10 CFR 20.302 submittal sent to the State of North Carolina was in support of normal dredging activity in the Discharge Canalin the.rea of the Caswell Beach Ocean Discharge Pumps. This area is property of CP&L and is fenced to minimize intruders. The discharge canal bottom sediments ::ontain very low levels of radionuclides as a result of routine radioactive liquid releases from the Brunswick plant. CP&L believed that a 20.302 reauest for afternate disposal was in order since the spoil pcnd used to receive the dredged mate.ials is not posted or controlled as a Radioactive Materials Area. By contrast, the SDCP is a controlled, restricted area and is posted as e Radioactive Materials Area. The SDCP is a permitted liquid release point and is identified as stch in the Brunswick Technical Specifications. The movement of i

sand and dirt from inside the Protected Area to the posted area around the SDCP is actually a transfer of a slightly contaminated soil from one radiologically controlled area to another radiologically controlled area and has a beneficial purpose in helping to build up and stabilize the dike.

ATTACHMENTS f

TABLE 1:

Average isotopic Concentration in Storm Drain Collection Basin Sand TABLE 2:

Results of Soil Samples Taken inside the Brunswick Plant Protected Area FIGURE 1:

Drawing showing the relationship of the Storm Drain Collection Basin (SDCB) and the Storm Drain Collection Pond.

f Applicable portions of the Brunswick Liquid Effluent Technical Specificctions.

Applicable portions of the Brunswick Updated Final Safety Analysis Report.

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TABLE 1 AVERAGE ISOTOPIC CONCENTRATION IN STORM DRAIN COLLECTION BASIN SAND Nuclide 4Ci/g (Wet Weight) 4Ci/g (Dry Weight)

Co-60 S.27E-07 7.15E-07 I-131 5.16E-07 6.24E-07 I-133 8.54E-07

LLD Cs-134 1.66E-08 3.89E-08 i

Cs-137 7.64E-07 1.02E-06 Mn-54

<LLD 3.23E-08 La-140 1.67E-08 4.54E-08 K-40 5.64E-07 7.96E-07 LLD--Lower Limit of Detectability i

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i TABLE 2 RESULTS OF SOIL SAMPLES TAKEN 3

INSIDE THE BRUNSWICK PLANT PROTECTED AREA 4

I LOCATION RESULTS (11CI/4) l AUX SURGE TANK (OUTSIDE FENCE) 4.50E-6 UNIT #2 CONDENSATE STORAGE TANK - (INSIDE FENCE) 6.48E-6 i

UNIT,#2 CONDENSATE STORAGE TANK (OUTSIDE FENCE) 1.62E-6 i

AUXILIARY BOILER 2.07E-5 WAitEHOUSE

'C' FRONT

<LLD WAREHOUSE

'C' SOUTH 5.79F-7 SERVICE WATER BUILDING 2.34E-7 UNIT #1 CONDENSATE STORAGE TANK (INSIDE FENCE) 4.33E-8 DIESEL GENERATOR SHIELD AREA 8._88_E-6 UNIT #1 SHIELD STORAGE 1.38E-5 MAKE-UP WATER TREATMENT-TANK

-6.00E-6 SCAFFOLD WAREHOUSE SOUTH 1.62E-6 SCAFFOLD WAREHOUSE NORTH 5.49E-8 SCAFFOLD WAREHOUSE WEST 7.46E f STORM DRAIN 1.96E-7

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l WEST TURBINE 5.31E-7 i

CST PUMP AREA-(DUMPSTER COMPOSITE SAMPLE) 1.84E-7 CST PUMP AREA (DUMPSTER COMPOSITE SAMPLE) _

9.32E-7 LLD--Lower Limit of Detectability i

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i APPLICABLE SECTIONS OF THE I

BNP UPDATED FINAL SAFETY ANALYSIS REPORT d

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BSEP 1 & 2 UPDATED FSAR i

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The 2C turbine building closed cooling water heat exchanger and pump.

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The lube water system crosstied at Valves 2-SW-V482 and 2-SW-V483.

7 5)

The service water intake structure which houses the service water pumps, screen wash pumps, and lube water pumps for both units.

The circulating water systems share a common intake structure. The intake st ructure houses the circulating water numps for both units (eight pumps total).

3.lA.16 MAKEUP WATER Water drawn from wells at the plant site and potable water from the county system provide all non-saline water needs. Water is piped directly to the fire system storage tank and is also supplied to the makeup watec treatment system which supplies both potable water and demineralized water for the plant. Dual demineralizer trains in this system enhance reliability even though the systems supolied are not significant in terms of interaction crite-ia.

3.lA.17 DEMINERALIZED WATER Water that has been demineralized to a high degree of purity by the makeup water treatment system is stored in the demineralized water storage tank.

This common, non-critical vessel provides separate egress routes for both reactor water makeup systems. Normally closed valves provide a connection with the fire protection system as an emergency backup to the normal fire protection system water supply.

3.lA.18 CONDENSATE STORACE AND TRANSFER Storage tanks for condensate f rom each reactor cooling system are independent, with a valved crosstie permitting interchenge between units.

Single independent trar- ^er pumps serve each tank.

3.lA.19 DRAINACE SYSTEMS 3.lA.19.1 Turbine Building There is no sharing of drainage systems between the Unit I and the Unit 2 areas of the Turbine Building, Clean floor drains and roof drains for the Lait I side of the Turbine Building q

are conveyed separately from those of the U i t 2 side into the yard area, where they are drained independently into tt" yard storm drainage system. The yard storm drainage system also collects numerous other drains, and is ultimately consolidated into a single drain line emptying into the storm drain basin and pumped into the stabilization pond.

The potentially contaminated drains in each of the two sides of the Turbine Building (i.e., the Unit I and 2 areas) are conveyed to separate sumps, from which the drainages are pumped and separately piped to the Radwaste Building 3.lA-6 Amendment No. 7

BSED 1&2 UPDATED FSAR tur processing.

Some clean drains from the lower elevations of the Turbine liut tding are combined with the potentially contaminated drains f rom elevations I

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BSEP 1 & 3 t;PDATED FSAR above then.,,u which cases running primed trcps are provided, with each side of the trap vented to its respective ar w.

3.1A.19.2 Reactor Buildings There is no sharing drainage systems between the Unit 1 and the Unit 2 Reactor Buildings.

Potentially contaminated drains from each of the cwo Reactor Buildings are conveyed separately to the Radwaste Building for processing. Roof 4.ains and drains from the intake air equipment rooms are conveyed separately to the yard storm drainage system.

3.1A.20 FIRE PROTECTION The entire factlity is protected by a fire procection system.

The system has sufficient redundt.ncy to minimize the probability of one failure causing loss of fire protection capability for the entire plant. The fire protection water 4

system can supply either unit individually. Other fire protection features are uniquu to each unit, with the exception of areas which are common to both units.

3.1A.21 INSTRUMENT AIR AND SERVICE AIR Two compressor systems, on'. for each unit, are installed to provide dry, oil free instrument air for instrument operation and valve operation.

Oil-free service air is provided for various uses including breathing atmosphere. These systems distd bute compressed air throughout the plant.

The systems are crosstied through a line connecting the air headers for each unit. Sharing of the two systems is not normal and car. be accomplished only sy manually opening s normally locked closed valve in this crosstie line.

In normal operations, all six compressors run. Air ??ceivers are sized to carry the maximum surge loads of postulated emergencies.

On-line receivers are located in local areas near critical loads. These provide espacity needed for 15 min of operation during a shutdown independent of feed from the distribution piping. Check valves upstream of on-line receivers prevent backflow. Feeds to critical areas are lonped and service will be maintained with a line break in either side of the loop. Service so designed is applied to non-interruptible loads namely, vital instrumentation and valve operation.

Amendment R 4

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3.1A-7

e BSEP 1 & 2 UPDATED FSAR f

9.3.3 EQUIPMENT, FLOOR, AND YARD DRAINAGE SYSTEM i

4 The objective of the drainage systems is to collect and remove all lignid 1

wastes f rom their points on origin in the plant to the circulating water system directly or, if necessary, to the P.adwaste Building f or t reatment prior l

to appropriate -disposal.

i 9.3.3.1 Design Basis i

l Liquid wastes are collected and discharged in such a manner that the operat ion

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or availability of the plani is not limited, and discharges of radioactive material are within the guidelines discussed in Chapter 11.

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9.3.3.2

System Description

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Pl an t equipment and floor drainage systems receive both contaminato; and noncontaminated drains. Contaminated drains are conveyed to the ridwaste s" stem f or determination of radioact ivity and' appropriate treatment prioc to j

disposal. Noncontaminated drains are drained to the storm drain system which discharges into the storm drain collection basin and then into the stabilization pond. A block flow diagram of the drainage system is shown in i

Figure 9.3.3-1.

1 9.3.3.2.1 Contaminated Equipment Drainage System j

Reactor building equipment drains are collected in two separate syste.ns.

One handles drainage f rom all equipment drains located in the drywelli the other handles drainnge from equipment drains located in the Beacotr Building.

Individaal drywell equipment drain lines collect in branch lines and discharge to the drywell equipment drain tank. Sump pumps are provided to t ransf er these wastes from the tank to the radwaste system. The reactor building equipment drain system begins with c.ef.n connect ions at equipment..The effluents from these drains are cullected in branch lines and discharged to the Reactor Building equipment drain tank for transfer to the radwaste i

system. Containment i s maintained in transf erring wastes f rom the sumre to l

the radwaste system by maintaining a minimum water level in the sump which seals the pump suction lines so that there is no continuous air path between

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the pump suction inlet and lines passing the containment boundary. Two l

autonatic isolation valves out side the drywell are provided to ensure i

containment integrity.

The Turbine Building contaminated equipment drainage system begins with funnel drains at the equipment. Liquid waste ir(m these funnel drains flows by gravity into branch drain lines and discharges into an equipment drain sump location below the basement level. A sump pump is provided to trpnsfer these wastes f rom the Turbine Building to the radwaste system.

The Radwaste Building contaminated equipment drainage system begins with funnel drains at the equipment, where liquid waste flows by gravity into drain lines and discherges to a collecting sump.

A sump pump is provided to a

transfer these wastes from t he sump to the radwaste srrtem.

9.3.3-1 Amendment No. 8-I

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BSEP 1 & 2 UPDATED FSAR 9.3.3.2.2 Contaminated Floor Drainage System I

The contaminated s toor drainage system includes all floor drains f rom the Reactor Building, Turbine Building, Nitrogen and Off gas Services Building, the Radwaste Building and all other floor drains having a potential for I

radioact ive spillage. Precautions have also been taken within the building to I

preclude overflow of any radicactive 1tquids into areas served by the non-j radioactive drainage systec, Drains in the contaminated floor drainige system are routed to sumps in various parts of the plant as required, f rom which the liquids are s ransferred i

by sump pumps to a col.ector tank in the radwaste system.

9.3.3.2.3 Noncentaminated Water Prainage System The drainage collection system consist s of an underground network of storm sewer piping, noncontaminated builoing floor drains, and building roof drainage piping.

(See Section 2.4.10.2 for further information concerning building roof drainage.) Cravity supplies the motive force for' drainage.

Surf ace drainage, runof f af ter rains, and neut ral non-radioactive wastes are

-l collected by this system. These sources, as well as t he cooling t ower blowdown discharge and the makeup water treatment system discharge, feed into the storm drainage basin.

The st orm drainage basin, located nort'hwest of the Turbine Buildir.0, i s a j

concrete structure with a total capacity of 102,000 gallnns. The bcsin originally was constructed with a removable gate at the south end which l

allowed free flow through a culvert to the head of the discharge canal and provided relief from overfilling of the basin. The basin is equipped with ltwo,lockedclosedbutterflyvalvesinseriestoprevent free flow and to ensure there is not an inadvertent release during periods ol heavy rain, the contents of the basin may be released to the discharge canal in accordance with regulatory requirements. An oil skimmer removes surf ace oils that ma y be present in the drainage water. The water is directed through a weir into the storm drainage basin pump bay where it is pumped into a stabilization pond.

The stabili.tation, pond is an area.f or final retention of storm drainage water. The pond is enlarged to provide an increased surface area to aid in i

evaporation of the water to the atmosphere. The stabilization pond covers approximately 64 acrest however, a standpipe located at 30 feet above mean sea level only allows water to cellect in 39 acres. The stabilization pond is constructdfromaspoilsponduseddupingthedredgingoftheintakecanal and has a storage capacity of 4.7 x 10 gallons. When f ull, the mean depth of the pond is 3.5 feet. The underflow-overflow discharge stiucture that leads to-the intake canal prevents discharge of oil, grease, and floating debris to j

the environment.

The storm drainage basin and the stabilization pond as a possible radioactive j

effluent release pathway is discussed in Section 11.2.2.7.

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BSEP 1 & 2 UPDATED FSAR 11.2.2.6 Surge System The surge system is a multiple purpose system which af fords both redundant f

design and increased production capability since:

a)

It servas as a bulk storage f acility for quantities of radioactive waste in excess of normal operational quantities, b)

It offers a parallel treatment path to the waste collector system.

]

The major components of the surge system are the waste sur6e tank, the waste collector filter, the waste demineralizer, the auxiliary surge tank, the auxiliary surge filter, and the auxiliary surge demineralizer.

Water may be transferred f rom the waste surge tank to the auxiliary surge tank. The "cff standard" line from the two waste sample tanks goea directly to the auxiliary surge tank.

The auxiliary surge cystem receives water directly f rom the Residual deat Retnoval (RilR) Systems and the overflow f rom either condensate storage tank.

There is only one path provided for water from the auxiliary surge tank; a pipe line with double block valves leads f rom the auxiliary surge tank directly into the top of the waste surge tank.

Any water that enters the surge system can exit that system only throur,h the waste collector filter and demineralizer or through the surge filter and demineralizer.

This system will facilitate the rapid treatment of large quantities of high purity, low activity water following reactor refueling.

11.2.?.?

Storm Drainage Collection System The storm drain collection basin has been recognized as a potential effluant pathway due to contaminated liquids entering the storm drains. A discussion of the storm drain collection system is presented in Section 9.3.3.2.3.

The storm drain basin is equipped with a monitoring system comprised of a radiation monitor, a pil meter, a flow uonitor, and a composite sampler. The storm drain basin can be operated in the manual or automatic mode. The monitoring system will lock-out normal operation of the basin pumps on high radiation or low or high pil conditions, preventing releases that excced specifications. The lock-out feature can be overridden manually via a key-locked switch, or automatically via a basin high-high wel. ~ gnal. The high-high level override signal prevents contaminated water i rom backing up into the plant.

In manual position, the basin is sampled daily for liquid pumped f rom the basin to the stabilization pond. The stabilization pond is released to the intake caral af ter sampling requirements have been met.

Only releases f rom the stabilization pond are considered of f-site releases since the pond is located in a restricted (fenced) area. An analysis

• performed using cc.:servative values of radioactive concentrations and leak rates indicated that environmental doses attributable to this pathway are in s i e,ni f ic an t.

11.2.2-6 Amendment No. 9

... -... - _. _ _ _ - ~

BSEP 1 & 2 4

UPDATED FSAR I

The collection basin is provided with an overflow line to the head of the di scha rge canal.

This line is equipped with two locked closed butterfly valves in series to prevent an inadvertent release. During periods of heavy rains, the contents of the basin may be released to the discharge canal in i

accordance with regulatory requirement s.

l 11.2.2.8 Heans for Keeping Activity Discharges as 1.ow as Practicable j

Radwastes are received and processed in the subsystems described below. To ensure operability of each of these systems so that wastes are processed by the treatment methods provided, the following system features are included t i

i J

J 4

i J

I l

ll.2.2-6a Amendment No. 9

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APPLICABLE SECTIONS OF THE BNP TECHNICAL SPECIFICATIONS (UNIT 1 ONLY)

I 4

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3/4.!! RADIDAcTIVE_ CFFLUENTS 3/4.11.1 LIQUID EFFLUENTS CONCENTRATION LIMITING CONDITION FOR OPERATION 1

3.11.1.1 The concentration of radioactive material released in liquid efflu-1 ents to UNRESTRICTED AREAS (see Figure 5.1.3-1) af ter dilution in-the discharge canal shall be limited to the concentrations specified in 10 CFR I

Part 20, Appendix B Table II, Column 2 for radionuclides other than dissolved concentration shall be limited to 2 x 10~gr entrained nobic gases, the or entrained noble gases.

For dissolved microcuries/ml.

1 1

APPLICABILITY: At all times.

ACTIOM:

1 With the concentrt', ion of radioact ive material released in liquid ef fluents to j

UNRESTRICTED AREAS exceeding the above limits, without delay restore the concentration to within the above limits.

j i

SURVEILLAllCE REQUIREMENTS 4.11.1.1.1 Radioactive liquid wastes shall be sampled and analyzed according I

to the sampling and analysis program of Table 4.11.1-1.

If the stabilization pond or service water samples analyzed according to Table 4.11.1-1 in concentrations of any gamma-emitting radionuclides greater than 5x10~gicate L

tci/ml (trigger level), then the liquid wastes exceeding-the trigger level shall be I

sampled and analyzed according to the sampling and analysis program of Table nuclide is less than Lx10~g the sample concentration of each gamma-emitting 4.11.1-2 until such time a i

pCi/ml.

l l

i 4.11.1.1.2 The results of radioactivity analyses shall be used in accordance j

with the methods in the ODCM to assure that the concentrations at the point of release are maintained within the limits of Specification 3.11.1.1.

NOTE: See Bases 3/4.11.1.1 4

i t

l BRUNSWICK - UNIT 1 3/4 11-1 Amendment No. 62 w

1 1

TABLE 4. I 1.1-1 RADIOACTIVE LIQUID WASTE S AMPLING AND ANALYSIS PROGRAM i

l Minimum Type of Lower Limit of I

Liquid Release Type Sv:pling An alyf is Ac tivity Detection (LLD)

Frequency Frequency Analysis (101/ml) (a)(e) 5 x 10'7(b) j Ael. Sample Tanks, P

P Principal i

Detergent Drain Each Each Batch Gamma Ta nk, and Sa l t Ba t ch Emitters (8) i Water Release Ta nks I-131 1 x 10-6

)

l (Batch Release)(h)

P Dissolved ai.d I x 10-5 One M

Entrained Ba tch/M Gases (gamas emitters) i

2. Circulating P

M Gross Alpha 1 x 10~7 Water Pit Each i

Batch Composit e(c)

H-3 1 x 10-5 P

Q St-89, Sr-90 5 x 10-8 Each Batch Composite (c)

Fe -55 1 x 10-6 5 x 10-7(b)

P P

Principal St abg zation B.

Pond Each Each Gamma l

Re lease Re lease Emitters (8) f D

D During During i

Release (p{

Release (p{

Periods Periods 5x10 7(b) i C.

Service Water (d)

W W

Principa)

(Potential During During Gam:4a j

Continuous Sy stem Sy s tem Emitters (8)

Release)

Operation Operation 1

.I, i

i J

k 4

i BRUNSWICK - UNIT 1 3/4 11-2 Amendment No. 62

._,__,.-,,..,._.._.,.,___,,,,,.._.,_.....-,_,.,,._,_4._,,._

.. - ~ - -. - -

TABLE 4.11.1,1 (Cont inued)

RADIOACTIVE LIQUID WASTE S AMPLIN7 AND ANALYSIS PROGRAM i

TABLE NOTATION (a)

The detectability limits f or activity analysis are based on techni-

)

cal feasibility limits and on the potential sidnificance in the environment of the quantities released.

For aomo nuclides, lower detection limits may be readily achievable; and when nuclides are J

measured below the stated limits, they should also be reported.

(b) When operational limitations preclude specific gamma radionue)ide analysis of each batch, gross radioactivity measurerents shall be made to estimate the quantity and concentrations of radioactive material released in the batch; and a weekly sample composited f rom proportional aliquots from each batch released during the week shall i

be analyzed for principal gamma-emitting radionuclides.

(c) A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid watte discharged and in which the method of sampling employed results in a specimen that is repre-sentative of the liquids released.

(d) The stabilization pond and service water liquid release types represent potential release pathways and not actual release pathways.

Surveillance of these pathways is intended to alert the plant to a potential problem; analysis for principal gamma emitters should be suf ficient to reet this intent.

If analysis for principal gamma emgtters indicates a problem (i.e., exceeds the trigger level of 5x10-LCi/ml), then complete sampling and analyses shall be performed as per Table 4.11.1-2.

(e)

The lower limit of detectability (LLD) is the smallest concentration of a radioactive material in an unknown sample that will be detected with a 95% probability with a 5% probability of f alsely concluding that a blank observation repr?sents a "real" signal.

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

4.66 g LLD =

E*V'2.22 x 10

'Y*exp(-

t,)

where:

4 LLD is the "a priori" lower limit of detection as defined above (as microcuries per unit mass or volume).

(N/tb) 2 a

=

b standard deviation of background (cpm)

=

BRUNSWICK - UNIT 1 3/4 11-3 Amendment No. 62

.r, e-a

\\

I TABLE..11.1-1 (Continued) i RADIOACTIVE LIQUID WASTE S AMPLINC AND ANALYSIS PROGRAM

~

TABLE NOTATION i

background count rate (cpm) l N

=

i time background counted f or (min) 1 t

=

b councing efficiency, as counts per disintegration E

=

volume or mass of sample V

=

6 conversion factor (dpm/ microcurie) 2.22 x 10

=

f ractional radiochemical yield j

Y

=

radioactive decay constant of ith nuclide (see-I) l

=

g t,

elapsed time between sample collection and counting (sec)

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

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

(f) 1he stabilization pond is typically released over a several-day period. The pond is to be sampled and analyzed prior to commencing release.

When composite sampling instrumentation becomes availabic and is OPERABLE, daily grab sampling of the stabilization pond i

ef fluent will not be required during release and -he composite l

sample will be analyzed on a weekly basia.

l (g) The principal gamma emitters f or which the LLD upecifications apply exclusively are the following radionuclides:

Mn-54, Fe-59, co-58, I

Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144.

Ihis liat does not mean that only these nuclides are to be considerud. Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be ansly:cd and reported in the Semiannual Radioactive Ef fluent Release Report pursuant to Specification l

6.9.1.8.

(h) A batch release is the discharge of liquid wastes of a discrete volume.

Prior to sampling for analyses, each batch shall be iso-1 lated and then thoroughly mixed to assure representative sampling.

Once fully operational, the salt water tanks will be included as indicated in Table 4.11.1-1.

j I

BRUNSWICK - UNIT 1 3/4 11-4 Amendment No. 62 l

1 t

i 4

TABLE 4.I1.1-2 RADIOACTIVE &. QUID WASTE S AMPLING AND ANALYSIS PROGRAM FOR POTENTI AL RELEASE PATHWAYS WHICH HAVE EXCEEDED TRIGGER i EVELS i

Minimum Type of Lower Limit of Sampling Analysis Ac tivity Detection (LLD)

Liquid Release Type Frequency frequency

_ Analysis

.(tCi/ml)(a)(e)

A.

Stabilizatiot P

P

'rincipal 5 x 10-7(b) 4 Pond Ea ch Ea eb Gamau.

Release Release Emitters (8)

D D

I-131 1 ::.10-6 During Daring Pe riods Periods I

Release Release P

Dissolved 1 x 10-5 One M

and Release /M Entrained Gases (Gamma l

Emitters)

P 4

Ea ch M

Gross Alpha 1 x 10"7 Composite (c)

H-3 1 x 10-5 i

Re: 3 ; e_

P Ea ch Q

Sr-89. Sr-90 5 x 10-8 Release Composite (c)

F~ i$

1 x 10-6 B.

Service Water D(d)

W Principal l-(Continu9up Composite (c)

Gamma 5 x 10-7(bl Release)(h)

Emitters (8) s

-I-131 1 x 10-6 M

M Dissolved Grab and 1 x 10-5 Sample Entrained Cases (Gamma Emitters)

• 0(d )

M Gross Alpha 1 x 10-7 Composite (C) 11 - 3 1 x 10-5 5 x 10-8

[

D(d Q

Sr-89, Sr-90 Composite (0)

Fe -55

-1 x 10-6 BRUNSWIQt - UNIT 1 3/4 11-5 Amendment No. 62 w

.- - +

..w.

,.y

a TABLE 4.11.1-2 (Continued)

RADIOACTIVE LIQUID WASTE S AMpLING AND ANALYSIS PROGRAM FOR POTENTI AL RELEASE PATHWAYS WHICH H AVE EXCEEDED TRIGGER LEVELS i

TABLE NOTATION (a) The detectcbility limits f or activity analysis are based on technical feasibility limits and on the potential significance in the environment of the quantities released.

For some nuclidos, lower detection limits may be re..dily achievablei and when nuclides are measured below the stated limito, they should also be reported.

(b) When operational limitations preclude specific gamma radionuclide analysis of each batch, gross radioactivity measurements shall be made to estimate the quantity and concentrations of radionctive material released in the batch; and a weekly sample composited f rcm proportional aliquots from each batch released during the werk shall be analytod f or principal gamma-emitting tadionuclides.

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

(d) Until such time as continuouu proportional composite samplers are installed on the service water discharge line, daily grab sampling of the service water ef fluent will be required for use in making up the comp o sit e.

(e) ihe lower limit of detectability (LLD) is the smallest concentration of a radioactive material in an unknown sample that will be detecced with a 95% probability uith a 5% probability of f alsely concluding that a blank observa' ion represents a "real" signal.

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

4.66cb LLD

=

-6 E *V'2. 22 x 10 Y exp(-

t,)

l I

LLD is the "a priori" lower limit of detection as defined above (as microcuries por unit mass or volume)

(N/tb) 2 o

=

g standard deviation cf background (cpm)

=

background count rate (cpm)

N j

=

,-l0 time background counted f or (min) t

=

b BRUNSWICK - UNIT 1 3/4 11-6 Amendment No. 62 l

l*

1 TABLE 4.11.1 2 (Continued)

RADIOACTIVE LIQUID WASTE S AMPLING AND ANALYSIS PROGRAM

}

FOR POTENTIAL RELEASE PATHWAYS WHI

• 9 AVE EXCEEDED TRIGGER LEVELS i

TABLE NOTATION 1

1 counting ef ficiency, as counts per disintegration l

E

=

4 V

voluma or mass of sample

=

0 conversion f actor (dpm/mictocurie)

2. 2 2 x 10

=

1 fractional radiochemical yield i

Y

=

j radioactive decay constant of ith nuclide (sec-I) j l

=

g i

clapsad time betweets sample collection and counting (sec) t a

o should be used in the Typical values of E, V, Y, and t,ized that the LLD is defined as an calculation.

It should be recogn i

)

"a priori" (before the fact) limit representing the capability of a measurement system and not as an "a posteriori" (ef ter the f act) limit for a particular meanarement.

I (f) The stabilization pond is typically released over a several~ day j-period. The pond is to be sampled _cnd analyzed prior to commencing re case. Whet composite sampling instrumentation becomes available and is OPERABLE, daily grab sampling of the stabilizatirn pond of fluent will not be required during telease and the composite sample will be analyzed on a weekly basis.

[

(g) 1he principal gamme emitters f or which the LLD specifications apply exclusively are the following radionuclides Mn-54, Fe-59, co-50, Co-60, Zn-65, Mo-99, Cs-134 Cs-137, Cn-141, and Ce-144.

This ' list does not mean that only these nuclides are to be considered.

Other gamma peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Semiannual f

Radioactive Ef fluent Release Report pursuant to Specification r

j 6.9.1.8.

r L

(h) A continuous release is the discharge of liquid waste of a l

nondiscrete volume, e.g., from a volume of a system ; hat has an input flow during the continuous release.

i

- BRUNSWICL - UNIT 1-3/4 11 Amendment No. 62-E..

__.__ -_.,_._..._.i,._._.._._,_,_._

_.. _. _. = _

1 l

]

kAD10 ACTIVE EFFLUENTS DOSE LIQUID EFFLUENTS a

f LIMITINC CONDITION FOR OPERATION l

3.11.1.2 The dose or dose comnitment to e MEMBER OF THE PUBLIC f rom radio-active materials in liquid effluents released to UNRESTRICTED AREAS (see i

j Figure 5.1.3-1) shall be limited:

n i

During any calendar quarter to less than or equal to 3 mrem to the a.

total body and to ler3 than or equal to 10 mrem to any organ, and j

b.

During any calendar year to less than or eqaal to 6 mrem to the total l

body and to less than ot equal to 20 mrem to any organ.

j APPLICABILITY: At all times.

e l

ACTION:

a.

With the calculated dosen f rom th.: release of radioactive materials in liquid effluents exceeding any of the above limits, in lieu of a i

1.icensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the j

corrective actions that have been taken to reduce che releases and i

the proposed correccive action to he taken to assure that subsequent I

releases will be in compliance with the above limits.

i b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

i SURVEILLANCE REQUIREMENTS i

4.11.1.2 Dose Calculations - Cumulative dose contributions f rom liquid ef f'u-ents for the current calendar quarter and the current calendar year shall be determined in accordance with the ODCM at least once per 31 days.

l l

t t

NOTE 4 See Bases 3/4.11.1.2 1.

I l

b I

BRUNSWICK' ! UNIT 1 3/4' 11-8

- Amendment No. 62

m. ~ _ -

_,.__,_,,2;.,,_

.._i.____,_._,_.,._...i_,,_,.l...,...-...._...__,,..,

3/6.I1 RAD 10ACTI /E EFFLUENTS BASES 3/4.11.!

LIQUID EFFLUENTS 3/4.I1.1.1 CCNCENTRATION a

l This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS after dilution in the discharge canal will be less than the concentration levels specified in 10 CFR Part 20, Appendix B. Table II, Column 2.

This limitation provides additional assurance that the levels of radioactive materials in bodies of water in UNRESTRICTED AREAS will not result in exposures within (1) the Section II. A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF Tile PUBLIC and (2) the limits of 10 CFR Part 20.106(e) to the population.

The concentration limit f or dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its MPC in c.ir l

(submersion) was converted to an equivalent concentration 1.n wef.er using the methods described in International Comminion on Radiological 'otection (ICRP), Publication 2.

T1.e required detection capabilities f or radioactive materials in liquid waste sen,>1cs are tabulated in terms of the Lower Limits of Detection (LLDs).

Dorailed discussion of the LLD and other detection limits can be found in liASL Procedures Manuals, llASL-300 (revised annually), Currie. L. A. " Limits for Qualitative Detection and Quantitative Determination - Application to Radio-chemistry" Anal. Chem. 40, 586-93 (1968), and llartwell, J.

K.,

" Detection Li airs f or 5tsdioanalytical Counting Techniques," Atlantic Richfield Hanford Compai.y Rey 7t ARH-SA-215 (June 1975).

"Without delay" laplies tha;. the operator, upon determining the limiting l

condition for operation is being exceeded, takes the next appropriate action o comply with the specification.

Note that f or batch releases, recirculation of at least two tank volumes shall be considered adequate for thorough mixing.

i The stabilization pond and service water liquid release types reprecent potential release pathways and not actual release pathways.

Surveillance of these pathways is intended to alert the plant to a potential problem; analysis l

for principal gamma emitters should be sufficient to meet this intent.

If analysis f or principa1 8amma emitters indicates a problem (i.e., exceeds the trigger level of 5x10~6 pCi/ml), then complete sampling and gnalyses shall be performed as per Table 4.11.1-2.

The trigger level of 5x10- tCi/mi was chosen i

as being suf ficient to provide reasonable assurance of a ccountability of all nuclides released based upon lower limits of detection and expec >J 1

concentrations.

3/4.I1.1.2 DOSE - LIQUID EFFLUENTS This specification is provided to implement the requirements of Sections II. A.

III.A. and IV.A of Appendix I, 10 CPR Part 50.

The limiting condition for 3RUNSWICK - UNIT I B 3/4 11-1 Amendment No. 62 l

_.. _ _.. _ _.. _ ~

c RADIOACTIVE EFFLUENTS l

BASES DOSES (Continued) j operttion implements the guides set f orth in Section 11. A of Appendix 1.

The l

ACTION statements provide the required operating flexibility and at t.he same i

time impletuent the guides set f orth in Section IV. A of Appendix 1 of 10 CFit l

Part 50 to assure that releases of radioactive material in liquid effluents to UNRF,STRICTED AREAS will be kept "as low as is reasonably schievable." Ihe t

dose calculations in the ODCM implement the requiren.ents in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calcuintional procedures based on modelo and data, such that the actual exposure of a MEMBER OF THE PtIBLIC through appropriate pathways is unlikely to be substantially underestimated.

The equations specified in the ODCH for j

calculating the dons due to the actual release rates of radioactive materials in liquid effluents will be consistent with the methodology provided in i

Regulatory Guide 1.109, " Calculation of Annual Doses to Man f rom Routine j

Releases of Reactor Ef fluents for the Purpose of Evaluating Compliance with 10 i

CFR Part 50, Appendix 1," Pevision 1, October 1977 and Regulatory Guide 1.113, j

" Estimating Aquatic Dispersion of Ef fluents f rom Accidental and Routine Reactor Releases f or the Purpuse of Impicmenting Appendix 1," April 1977.

a i

The dose or dose conanitment to a MEMBER OF THE PUBLIC is based on the 10 CFR q

Part 50, Appendix 1, guideline nf t a.

1. 5 mre:: to the total body and 5.0 mrem to any organ during any calendar quarter, and b.

3 mrem to the total body and 10 mrem to any organ during any calen-dar yeae, l

f rom radioactive material in liquid ef fluents f rom each reactor unit to UNRE-STRICTED AREAS. This specification is written for a two unit site.

I j

3/4.11.1.3 LT4UID RADWASTE TREATMENT SYGTEM j

The requirenent that. appropriate portions of this system be used, when speci-l fied, provides assurance that the releases of radioactive naitrials in liquid i

ef fluents wili be kept "as low se reasonably achievable." ht specification implements the requirenents of 10 CFR Part 50.36a, General Desigr. Criteria 60 I

of Appendix A to 10 CFR Part 50 and the design objectives given in Section II.D of Appendix 1 to 10 CFR Part 50.

The specified-limits governing the use a

of appropriate portions of the liquid rahte treatment system were specified as L suitable fraction of the dose design objectives set forth in Section II. A l

of Appendix I, 10 CFR Part 50, for liquid e f fluents.

l Mechanical filtration as per system design is considered to be an appropriate couponent of the liquid radwaste treatment system.

4 The. requirements of 0.12 mrem total body or 0.4 mrem to any organ in a 31-day period is based on two reactor units having a shared liquid radwaste treatment cyctem.-

BRUNSWICK - UNIT 1 B 3/4 11-2 Amendment No. - 62 e

~-

._,.._,m_.___.._.

_. _...,. _.., _ ~. _, _., _. _,

,,,,-_-_r

4 OUTGOING NRC CORRESPONDENCE COMMITP4ENT ID FORM (Alternate Fo m NGGM 304 01)

FACTS #: 92G0299 LETTER DATE:

NLS/ PLANT #: NLS 92 245 DEPART MENT:

The following commitments are being made in this response:

FACTS COMMITMENT RESPONSIBLE COMPLETION ITEM GROUP DATE ASSIGNED Perform additional analyses for-E&RC Prior to moving exposure pathways prior to moving material to land / dirt from CST area and other SDCP.

plant areas to the SDCP.

PREPARER:

DATE:

RESPONSE MANAGER:

DATE:

c s

i f

OUTGOING NRC CORRESPONDENCE INPUT VERIFICATION

]

i FACTS #:

92G0299 NLS #:

NLS 92 245 DOCUMENT IDENTIFICATION: Brunswick Nuclear Probst Transfer of Sand / Dirt to SDCP INPUT VERIFICATION: For items 15 below, attachments to, or notes on the reverse of this page, are acceptable to ensure completeniss.

THE ACCURACY OF THE ATTACHED INPUT WAS VERIFIED BY ONE OR MORE OF THE FOLLOWING METHOD (S) (SEE NOTE 1]:

PACKAGE PREPARER PERSONAL KNOWLEDGE OF SUBJECT / PROJECT Tony Harris y

INPUT OBTAINED FROM OTHERS (LIST SOURCES)

Name Organization Jim Davis, Sue Fitzpatrick E&RC Tony Harris Gary Worley E&RC Tony Harris REVIEW OF PLANT TECHNICAL DOCUMENTS (LIST DOCUMENTS)

UFSAR, Technical Specifications Tony Harris VERIFIED BY FIELD OBSERVATIONS (DISCUSS EXTENT)

OTHER (DESCRIBE) 6/5/02 MEMO from 43ncer to Essig/ Carrion Tony Harris COMMITMENT ID FORM (NG 5021)

Attached X

No Commitments FSAR CHANGE FORM (NG 5024)

Attached No FSAR Changes X

(NOTE 2)

RESPONSE MANAGER (See NOTE 1)

DATE n

y v

-wm...

.,,-e r,

_,. _y

,-r.,-

A 4

a-_.m.a4- _ -A-

-_Aa&4

_J.A_,mA-.c

.u.4 so

_4._

w"S e _-

h

.X e

..a-i.r.m

,_s,.,i=

2,,,, ___,.:,.,

w NOTE 1:

Each individu:1, P Sis signature, att2sts that to ths b:st of his knowlIdge end bastd on personal knowieuwe, reports from cognizant individuals, or reference to appropriate i

' 1cumentation that the input provided is accurate and free from material falso statement, j

NOTE 2:

10 CFR 50.71(e) requires that the FSAR(s) be revised "to contain all the changes necessary to reflect information and analyses submitted to the Commission.*

4 e

4 i

1 n

4 1

I f

j

^

l

...,, - - _ _..,_ _. __._,_ ~_.,

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