ML20117N941

Proposed Radiological ETS Re Radiological Effluent & Environ Monitoring

ML20117N941
Person / Time
Site:	Pilgrim
Issue date:	05/14/1985
From:	BOSTON EDISON CO.
To:
Shared Package
ML20117N936	List: ML20117N935 ML20117N941
References
NUDOCS 8505200286
Download: ML20117N941 (58)

Text

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ATTADGENT 'S' PNP 5 ,

RADIOLOGICAL ENVIR0 MENTAL TECelCAL SMCIFICAil0NS SUSNITTAL p

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. Surveillance Page No.

3.7 CONTAINMENT SYSTEMS 4.7 152 A. Primary Containment A ,

152

8. Standby Gas Treatment System 8 158 C.. Secondary Containment C 2 159 D. Primary Containment Isolation Valves D 160

' 3.8 RA010 ACTIVE EFFLUENf5 4.8 177 A. Liquid Effluents Concentration A 177

8. Radioactive Liquid Effluent B 177  !

Instrumentation C. Liquid Radwaste Treatment C 178 D. Gaseous Effluents Dose Rate D 179 E. Radioactive Gaseous Effluent E 180 Instrumentation F. Gaseous Effluent Treatment F 181 G. Main Condenser G 182 H. Mechanical Vacuum Pump H 18,3 3.9 AUXILIARY ELECTRICAL SYSTEMS 4.9 194 A. Auxillary Electrical Equipment A 194

8. Operation with Inoperable Equipment 8 195 >

3.10 CORE ALTERNATIONS 4.10 201 A. Refueling Interlocks A 202 i B. Core Monttoring B 202 C. Spent Fuel Pool Water Level C 203 3.11 REACTOR FUEL ASSEM8LY 4.11 205A A. Average Planar Linear Heat -

Generation Rate (APLHGR) A 205A B. Linear Heat Generation Rate (LHGR) 5 205A-1 '

C. Minimum Critical Power Ratio (MCPR) C 2055 3.12 FIRE PROTECTION 4.12 206 A. Fire Detection Instrumentation A 206

8. Fire Suppression Water System 8 206 C. Spray and/or Sprinkler Systems C 206c D. Halon System D 206d E. Fire Hose Stations E 206e F. Penetration Fire Barrier F 206e G. Dry Chemical Systems G 206e-1 H. Yard Hydrants and Exterior l Hose Houses H ~ 206e-1 i

Amendment No. 11 t

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Page No.

4.0 MISCELLANEOUS RA010 ACTIVE MATERIALS SOURCES 206k 7

4.1 Sealed Source Contamination , 206k 4.2 Surveillance Requirements ', 206k 4.3 Reports '

2061 4.4 Records Retention 2061 5.0 MAJOR DESIGN FEATURES 206m 5.1 Site Features 206m 5.2 Reactor 206m  :

5.3 Reactor Vessel 206m 5.4 Containment 206m 5.5 Fuel Storage 207 '

5.6 Selsmic Design 207 6.0 ADMINISTRATIVE CONTROLS 208 6.1 Responsibility 208 6.2 Organization 208 6.3 Facility Staff Qualifications 208-6.4 Training 2084 6.5 Review and Audit 212 6.6 Reportable Event Action 216 6.7 Safety Limit Violation 216 6.8 Procedures 216 6.9 Reporting Requirements 217 6.10 Record Retention 224 6.11 Radiation Protection Program 226 6.12 (Deleted) 6.13 High Radiation Area 226 6.14 Fire Protection Program 227 6.15 Environmental Qualification 228 Doerational Objectives Surveillance 7.0 RA010 LOGICAL ENVIRONMENTAL MONITORING PROGRAM 8.0 229 7.1 Monitoring Program 8.1 229 7.2 Dose - Liquids 8.2 232 7.3 Dose - Noble Gases 8.3 233 7.4 Dose - Iodine-131, todine-133, 8.4 234 Radioactive Material in Particulate Form, and Tritium 7.5 Total Dose 8.5 234 N

r Amendoent No. 1II

1.0 DEFINITIONS (Continued)

U. Surveillance Frequency - Unless otherwise stated in these -

specificaticos, periodic surveillance tests, checks, calibrations, and examinations shall be performed, within the specified surveillance intervals. These intervals may be adjusted plus 257..

The total maximum combined interval time for.any three consecutive tests shall not exceed 3.25 times the specified interval. The operating cycle interval is considered to be 18 months and the tolerances stated above are applicable.

V. Surveillance Interval - The surveillance interval is the calendar time between surveillance tests, checks, calibrations, and examinations to be performed upon an instrument or component when it is required to be operable. These tests may be walved when the instrument, component, or system is not required to be operable, but the instrument, component, or system shall be tested prior to being declared operable.

H. Fire Suppression Water System - A fire suppression water system shall consist of: a water source (s); gravity tank (s) or pump (s);

and distribution piping with associated sectionalizing control or isolation valves. Such valves shall include hydrant post Indicator valves and the first valve ahead of the water flow alarm device on each sprinkler, hose standpipe or spray system riser.

X. Staggered Test Basis - A staggered test basis shall consist of: (a) a test schedule for n systems, subsystems, trains, or other designated components obtained by dividing the specified test interval into n equal subintervals; (b) the testing of one system, subsystem, train or other designated components at the beginning of each subinterval.

Y. Source Check - A source check shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. ,

Z. Offsite Dose Calculation Manual (ODCM) - An offsite dose calculation manual (00tM) shall be a manual containing the current methodology and parameters to be used for the calculation of offsite doses due to radioactive gaseous and liquid effluents, the calculation of gaseous and liquid effluent monitoring Instrumentation alarm / trip setpoints, and the conduct of the Radiological Environmental Honitoring Program.

Amendment No. Sa

1.0 DEFINITIONS (Continued)

AA. Action - Action shall be that part of a specification which prescribes

• remedial measures required under designated conditions.

88. Member (s) of the Pubile' - Member (s) of the public shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors, or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational or other purposes not associated with the site.

CC. Site Boundary' - The site boundary is shown in Figure 1.6-1 in the FSAR.

l DD. Radwaste Treatment System

1. Gaseous Radwaste Treatment System - The gaseous radwaste treatment system is that system identified in Figure 4.8-2.

2. Liquid Radwaste Treatment System - The 11guld radwaste treatment system is that system identified in Figure 4.8-1, 1

See FSAR Figure 1.6-1 Amendment No. Sb

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x LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT

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C. Control Rod Block Actuation C. Control Rod Block Actuatio'n [ < ,

l. The limiting conditions of 1. Instrudentation shall be '.

operation for the instrumentation functionally teste~d, calibrated that initiates control rod block and checked as indicated in Table -

are given in Table 3.2.C. 4.2.C: ~5'

2. The minimum number of operable System logic shall be instrument channels specified in functionally tested as indicated Table 3.2.C for the Rod Block in Table 4.2.C. '

Monitor may be reduced by one in -

one of the trip systems for maintenance and/or testing, ,

provided that this condition does u.'_ .

not last longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in -

any thirty day period. 4

0. Radiation Monitoring Systems - D. Radiation Monitoring Systems -

Isolation & Initiation Functions Irolation & Initiation Functions a

1. Reactor Building Isolation and 1. Reactor' Building Isolation and Control System and Standby Gas Control System and Standby Gas

~

Treatment System Treatment Sistem . . ,

The limiting conditions for Instrumentation shall be c operation are given in Table functionally tested, calibrated 3.2.0. and checked as indicated in Table 4.2.0. ,

Systeh logic'shall be .

functionally tested as indicated in Table 4.2.0.

P Amendment No. 43 s

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT E. Drywell Leak Detection E. Drywell Leak Detection -

The limiting conditions of Instrumentation shall be operation for the instrumentation functionally tested, calibrated that monitors drywell leak and checked as indicated in Table detection are given in Table 4.2.E.

3.2.E.

F. Surveillance Information Readouts F. Survelliance Information Readouts The limiting conditions for the Instrumentation shall be instrumentation that provides calibrated and checked as surveillance information readouts indicated in Table 4.2.F.

are given in Table 3.2.F.

Amendment No. 44

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';t PNPS-TABLE 3.2.D' RADIATION MONITORING SYSTEMS THAT INITIATE AND/OR ISOLATE Minimum # of'

' Operable Instrument . .

Channels Per Trip System (1) Trio Function Trip Level Setting Action (2) 2 Refuel Area Exhaust' Upscale, <100 mr/hr A or B Monitors 2 Refuel Area Exhaust Downscale . A or B Honitors NOTES FOR TABLE 3.2.D

1. Whenever the systems are required to be operable, there shall be two operable or tripped trip systems. If this cannot be met, the indicated action shall be taken.

1. Action

, A. Cease operation of the refueling equipment.

B. Isolate secondary containment.and start-the standby gas treatment system.

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Amendment No. 56

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PNPS,

. TABLE 4.2.D' MINIMUM TEST AND CALIBRATION FREQUENCY FOR RADIATION MONITORING SYSTEMS' Instrument Channels Instrument Functional Calibration Instrument Check'(2)

Test-

-1) Refuel Area Exhaust Monitors - Upscale (1) Once/3 months Once/ day

2) Refuel Area Exhaust Monitors - Downscale (1) Once/3 months 'Once/ day Logic System functional Test (4) (6) Frequency

1) Reactor Building Isolation Once/6 months

2) Standby Gas Treatment System Actuation Once/6 months Amendment No. 64

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. 3.2 BASES (Cont'd)

HPCI in the event the HPCI-does not operate. The arrangement of the -

tripping contacts is such as to provide this function when necessary and minimize spurious operation. The trip settings given in the specification are adequate to assure the above criteria are met. The specification preserves the effectiveness of the system during periods of maintenance, testing or calibration, and also minimizes the risk of inadvertent operation; i.e., only one instrument channel out of service.

Four radiation monitors are provided which initiate the Reactor Building Isolation and Control System and operation of the standby gas treatment system. The instrument channels monitor the radiation from the refueling area ventilation exhaust ducts.

Four instrument channels are arranged in a 1 out of 2 twice trip logic.

Trip settings of < 100 mr/hr for the monitors in the refueling area ventilation exhaust ducts are based upon initiating normal ventilation isolation and standby gas treatment system operation so that none of the activity released during the refueling accident leaves the Reactor Building via the normal ventilation path but rather all the activity is processed by the standby gas treatment system.

Flow integrators are used to record the integrated flow of liquid from the drywell sumps. The alarm unit in each integrator is set to annunciate before the values specified in Specification 3.6.C are exceeded. A system whereby the time interval to fill a known volume will be utilized to provide a back-up to the flow integrators. An air sampling system is also provided to detect leakage inside the primary containment.

Amendment No. 72

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-4.2 BASES (Cont'd)

.is shown by Curve No. 2. Note that the unavailability is lower as expected for a redundant system and the minimum occurs at the same test interval. Thus, if the two channels are tested independently, the equation above yields the test interval for minimum unavailability.

A more unusual case is that the testing is not done independently. If both-channels are bypassed and tested at the same time, the result is shown in Curve No. 3. Note that the minimum occurs at about 40,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, much longer than for cases I and 2. Also, the minimum is not

-nearly as low as Case 2 which indicates that this method of testing does not take full advantage of the redundant channel. Bypassing both channels for simultaneous testing should be avoided.

The most likely case would be to stipi:! ate that one channel be bypassed, tested, and restored, and then immediately following, the second channel be bypassed, tested and restored. This is shown by Curve No. 4. Note that there is no true minimum. The curve does have a definite knee and very little reduction in system unavailability is achieved by testing at a shorter' interval than computed by the equation for a single channel.

The best test procedure of all those examined is to perfectly stagger the tests. That is, if the test interval is four months, test one or the other channel every two months. This is shown in Curve No. 5. The difference between Cases 4 and 5 is negligible. There may be other arguments, however, that more strongly support the perfectly staggered tests, including reductions in human _ error.

The conclusions to be drawn are these:

1. A 1 out of n system may be treated the same as a single channel in terms of choosing a test interval; and

2. more than one channel should_ not be bypassed for testing at any one

~ time.

The radiation monitors in the refueling area ventilation duct which initiate building isolation and standby gas treatment operation are arranged in two 1 out of 2 logic systems. The bases given above for the rod blocks apply here also and were used to arrive at the functional testing frequency. Based on experience with instruments of similar design, a testing interval of once every three months has been found adequate.

n Amendment No. 76

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E4. 2 ' BASES'(Cont'd)'

The automatic pressure relief instrumentation can be considered to be a 1 out of 2 logic system and the discussion above applies also.

'The instrumentation which is required for the recirculation pump trip

-and alternate rod insertion systems incorporate analog' transmitters and are'a new,' improved-line of BWR instrumentation. The calibration

-frequency is once per. operating cycle which is consistent with both the equipment capabilities and the requirements for similar equipment used by other reactor vendors. The calibration frequency of the trip units is' proposed to be quarterly, the same.as other similar protective

-instrumentation. Likewise,1the test frequency is specified at monthly like~that of other protective instrumentation. A sensor check is proposed once per day; this is considered to be an appropriate

. frequency, commensurate with the design applications and the fa'ct that the recirculation pump trip and alternate rod insertion systems are backups to existing protective instrumentation.

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~ Amendment No. 77

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8 RADIOACTIVE EFFLUENTS 4.8 RADI0 ACTIVE EFFLUENTS A. Liquid Effluents Concentration A. Liquid Effluents Concentration Applicability: Specification:

At all times. 1. The radioactivity content of each batch of radioactive Specification: liquid waste to be discharged shall be determined prior to

1. The concentration of release by sampling and radioactive material released analysis in accordance with at any time from the site to Table 4.8-1.

areas at and beyond the site boundary shall be limited to 2. The results of pre-release the concentrations specified analyses shall be used with in 10 CFR Part 20, Appendix B, calculational methods in the Table II, Column 2 for Offsite Dose Calculation radionuclides other than Manual (ODCM) to assure that dissolved or entrained noble the concentration at the point gases. For dissolved or of release is limited to the entrained noble gases, the values in Specification concentration of individual 3.8.A.l.

isotopes shall be limited to 2 x 10-* C1/ml.

Action With the concentration of radioactive material released from the site to areas at and beyond the site boundary exceeding the above limits, without delay restore concentration within the above limits.

B. Radioactive Liquid Effluent B. Radioactive Liquid Effluent Instrumentation Instrumentation Applicability: Specification:

As shown in Table 3.8-1. 1. The setpoints for monitoring instrumentation shall be Specification: determined in accordance with the ODCM.

1. The radioactive 11guld effluent monitoring 2. Each radioactive liquid instrumentation channels shown effluent monitoring in Table 3.8-1 shall be instrumentation channel shall operable with their alarm / trip be demonstrated operable at setpoints set to ensure that the frequencies shown in Table the limits of Specification 4.8-2.

3.8.A.1 are not exceeded Amendment No. 177

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k 6' LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.8 Radioactive Llauld Effluent-Instrumentation (Continued) during periods when 11guld

. wastes are being discharged via the radwaste discharge header.

For releases 6ther than the radwaste discharge header, the above specification does not apply, these releases shall be made in accordance with Action 1 of Table 3.8-1.

Action

a. With a radioactive liquid effluent monitoring instrumentation channel alarm / trip setpoint less

. conservative than a value which will ensure that the limits of Specification

-3.8.A.1 are met, without delay suspend the release

, of radioactive liquid effluents monitored by the i affected channel or change the setpoint so that it is acceptably conservative or

.. declare the channel inoperable.

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b. -With one or more radioactive liquid effluent monitoring instrumentation channels inoperable, take the action shown.in Table 3.8-1.

C. Liquid Radwaste Treatment C. Liquid Radwaste Treatment Applicability: Specification:

At all times. 1. Doses due to liquid releases at and beyond the site Specification: boundary shall be calculated at least once per 31-day

1. The 11guld radwaste treatment period in accordance with the system shall be maintained and 00CM, only if releases in that used to reduce the radioactive period have occurred.

materials in liquid wastes Amendment No. 178 1

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.C. Liquid Radwaste Treatment 4.8.C. Liquid Radwaste Treatment (Continued) (Continued) prior to their discharge when 2. The liquid radwaste treatment the dose due to 11guld system schematic is shown in effluent releases to areas at Figure 4.8-1.

and beyond the site boundary averaged over a 31-day period would exceed 0.06 mrem to the total body or 0.20 mrem to any organ.

Action

a. With radioactive liquid waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission within 30 days a special report which includes the following information:

1. Explanation of why 11guld radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability.

2. Action (s) taken to restore the inoperable equipment to operable status.

3. Summary description of action (s) taken to prevent a recurrence.

D. Gaseous Effluents Dose Rate D. Gaseous Effluents Dose Rate Applicability: Specification:

At all times. 1. The instantaneous dose rate due to noble gases in gaseous Specification: effluents shall be determined to be within the limits of

1. The instantaneous dose rate Specification 3.8.D.1.a on a due to radioactive materials continuous basis using the released in gaseous effluents noble gas activity monitors Amendment No. 179

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LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.D. Gaseous Effluents Dose Rate 4.8.D. Gaseous Effluents Dose Rate (Continued) (Continued) from the site to areas at and with appropriate setpoints and beyond the site boundary (see in accordance with the ODCM.

FSAR Figure 1.6-1) shall be limited to the following: 2. The instantaneous dose rate due to iodine-131, lodine-133,

a. For noble gases: Less than tritium, and all radionuclides or equal to 500 mrem /yr to in particulate form with the total body and less half-lives greater than 8 days than or equal to 3000 in gaseous effluents shall be mrem /yr to the skin, and determined to be within the limits of Specification

b. For iodine-131, iodine-133, 3.8.D.I.b in accordance with tritium, and all the ODCM by obtaining radionuclides in representative samples and particulate form with performing analyses in half-lives greater than 8 accordance with the sampling days: Less than or equal and analysis program specified to 1500 mrem /yr to any in Table 4.8-3.

organ.

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

E. Radioactive Gaseous Effluent E. Radioactive Gaseous Effluent Instrumentation Instrumentation Applicability: Specification:

As shown in Table 3.8-2. 1. The setpoints shall be determined in accordance with Specification: ODCM.

.l. The radioactive gaseous 2. Each radioactive gaseous effluent monitoring effluent monitoring instrumentation channels shown instrumentation channel shall in Table 3.8-2 shall be be demonstrated operable at operable with their alarm / trip the frequencies shown in Table setpoints set to ensure that 4.8-4.

the limits of Specification 3.8.0.1 are not exceeded.

Amendment No. 180

a LIMITING CONDITIONS FOR OPERATION- SURVEILLANCE REQUIREMENTS 3.8.E. Radioactive Gaseous Effluent Instrumentation (Continued)

Action

-a. With a radioactive gaseous effluent monitoring instrumentation channel alarm / trip setpoint less conservative than a value

-which will ensure that the limits of Specification 3.8.D.1 are met, change the setpoint so that it is acceptably conservative or declare the channel inoperable.

b. With one or more radioactive gaseous effluent monitoring instrumentation channels inoperable, take the action shown in Table 3.8-2.

F. Gaseous Effluent Treatment F. Gaseous Effluent Treatment Applicability: Specification:

The augmented offgas system shall 1. Augmented offgas annunciator be put into service prior to operability shall be verified reaching 50 percent reactor power once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

during startup.

2. The concentration'of hydrogen Action in the augmented offgas treatment system shall be -

a. With gaseous effluents being determined to be within the discharged for more'than 14 limits of Specification days without treatment, 3.8.F.1 by continuously _

prepare and submit to the monitoring the waste gases in Commission within 30 days, a the augmented offgas treatment special report which includes system with the hydrogen the following information: monitor which is required to be operable by Table 3.8-2.

1. Identification of any inoperable equipment or subsystems, and the reason for the inoperability.

2. Action (s) taken to restore the inoperable equipment -

to operable status.

Amendment No. 181

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.F. Gaseous Effluent Treatment (Continued) l

3. Summary description of action (s) taken to prevent a recurrence.

Specification:

1. The concentration of hydrogen in the augmented offgas treatment system shall be limited to less than or equal to 2 percent by volume at the outlet of the augmented offgas recombiner. See also Action 5 for Item 4.a on Table 3.8-2.

Action

a. With the concentration of hydrogen in the augmented offgas-treatment system greater than 2 percent by volume but less than or equal to 4 percent by volume, restore the concentration of hydrogen to within the limit within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

G. Main Condenser G. Main Condenser Applicability: Specification:

At all times when steam is 1. The gross radioactivity (beta available to the air ejectors. and/or gamma) release rate of noble gases from the steam jet Specification: air ejector shall be determined to be within the

1. The gross radioactivity (beta limit of Specification 3.8.G.1 and/or gamma) release rate of at the following frequencies noble gases measured at the by-performing an isotopic steam jet air ejector shall be analysis of a representative limited to 500,000 pC1/ set sample of gases taken at the (referenced to a 30-minute discharge of the steam jet air holdup). ejector (prior to dilution and/or discharge):

Action

a. At least once per 31 days.

With the gross radioactivity (beta and/or gamma) release

. Amendment No. 182

LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.8.G. Main Condenser (Continued) 4.8.G. Main Condenser (Continued) rate of noble gases at the b. When the average daily steam jet air ejector gross radioactivity exceeding 500,000 C1/sec release rate increases by (referenced to a 30-minute 50 percent over the holdup), restore the gross previous day, after radioactivity release rate to factoring out increases within the limit within 72 due to changes in reactor hours or be in at least hot thermal power level.

standby within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. See also Action 1 for Item 3.a on Table 3.8-2.

H. Mechanical Vacuum Pump H. Mechanical Vacuum Pump Specification: Specification:

1. The mechanical vacuum pump 1. At least once during each shall be capable of being operating cycle verify isolated and secured on a automatic securing and signal of high radioactivity isolation of the mechanical in the steam lines whenever vacuum pump.

the main steam isolation valves are open.

2. If the limits of Specification 3.8.H.1 are not met, the vacuum pump shall be isolated.

Amendment No. 183

TABLE 3.8-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION Minimum Channels.

Instrument Operable- Applicability Action *

1. Gross Radioactivity Monitors Providing Automatic Termination of Release

a. Liquid Radwaste Effluent Line l' During actual discharge. I of liquid wastes

2. Flow Rate Measurement Devices

a. Liquid Radwaste Effluent 1 During actual' discharge 2 Line of liquid wastes

b. Discharge Canal'. NA 'During actual discharge 3 of 11guld wastes

' Flow will be estimated based on the design flow rate of the operating circulating water pumps and/or the operating salt service water p' umps.

2 ACTION 1 With the number of operable channels less than required by the minimum channels operable requirement, effluent releases may be resumed.provided that prior to. initiating a release:

a. At least two independent samples are analyzed in accordance with Specification 4.8.A.1, and.

b. An. independent verification of the release rate calculations.ls performed, and i c. An independent verification of the discharge valving is performed.

ACTION 2 With the number of operable channels less than required by the minimum channels operable requirement, effluent releases via this pathway may continue provided that the flow rate is verified at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases.

ACTION 3 Suspend all radioactive liquid effluent discharges if no dilution water is available.

Amendment No. ~ 184

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TABLE 3.8-2~

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument. Operable Appilcability Parameter Action * .

1. . Main Stack Effluent Monitoring System ,

Noble Gas Activity Monitor - '

Radioactivity Rate

a. 1 Providing Alarm Measurement- 3

b. Iodine _ Sampler Cartridge 1 Collect Halogen Sample 4

c. Particulate Sampler Filter 1 ' Collect Particulate Sample 4

d. Effluent System flow Rate 1 System Flow Rate Measuring Device Measurement 2

e. Sampler Flow Rate Measuring 1 Sampler Flow Rate Device Measurement 2

2. Reactor Building Ventilation Effluent Monitocing System

a. Noble Gas Activity Monitor - 1 Radioactivity Rate Providing Alarm Measurement 3

b. Iodine, Sampler Cartridge 1 Collect Halogen Sample 4

c. Particulate Sampler ~ Filter' 1 Collect Particulate Sample 4 Amendment No. 185

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TABLE'3.8-2 (Continued)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION Minimum Channels Instrument Operable Applicability Parameter Action *

2. Reactor Building Ventilation Effluent Monitoring System (Continued)

d. Effluent System Flow Rate 1 System Flow Rate 2 Measurement Device Measurement-

e. Sampler Flow Rate Measurement 1 Sampler Flow Rate 2 Device Measurement

3. Steam Jet Air Ejector Radioactivity Monitor

a. Noble Gas Activity Monitor 1 Noble Gas Radio- 1 (Providing alarm and auto- activity Rate isolation of stack) Measurement

4. Augmented Offgas Treatment System Explosive Gas Monitoring

a. Hydrogen Monitor 1 Hydrogen Concentra- 5 tion Measurement S

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Amendment No. '186

1 TABLE 3.8-2 (Continued)

TABLE NOTATION

' During releases via this pathway.

During augmented offgas treatment system operation.

• During operation of the steam jet air ejector.

ACTION 1 . With the number of operable channels less than required by the

-minimum channels operable requirement, gases from the steam jet air ejector may be released to the offgas system for up to 72

-hours provided:

a. The augmented offgas treatment system is not bypassed, and

b. .The offgas holdup system noble gas activity effluent monitor (downstream) is operable.

Otherwise, be in at least hot standby within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

ACTION 2* With the number of operable channels less than required by the minimum channels operable requirement, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

ACTION'3* ' With the number of operable channels less than required by the minimum channels operable requirement, effluent releases via this pathway may continue provided grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 4* With the number of operable channels less than required by the minimum channels operable requirement, effluent releases via this pathway may continue provided samples are continuously collected with auxiliary sampling equipment as required in Table 4.8-3.

ACTION 5 With the number of operable channels less than required by the

-minimum. channels operable requirement, operation of the augmented offgas holdup system may continue provided grab samples are collected at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, analyzed within the following 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and the proper function of the recombiner is assured by monitoring recombiner temperature.

• Note: (For Actions 2, 3, and 4) If the instruments are not returned to operable status within 30 days, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

Amendment No. 187 m

TABLE 4.8-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum Type of of Detection Sampling Analysis Activity (LLD)

. Liquid Release Type Frequency Frequency Analysis ( C1/ml)(

-A. Batch Haste Release Each Batch Prior to Principal 5 x 10-'

Tanks (*' Release Gamma Each Batch Emitters (*)

1. Non-treatable I-131 1 x 10-'

Releases (e.g.,

Neutralizer

-Sumps) and Dissolved 1 x 10-5

2. Treatable and Entrain-Releases ed Gases (e.g., Radwaste Tanks)

Composite H-3 1 x 10-5 from Each Monthly Batch Composite (*) Gross alpha 1 x 10-'

Composite Quarterly Sr-89, Sr-90 5 x 10-*

from Each Composite (*'

Batch Fe-55 1 x 10-*

B. Continuous Releases

1. Salt Service Weekly Weekly Principal 5 x 10-'

Water grab sample Gamma Emitters l

Amendment No. 188 l i

TABLE 4.8-1 (Continued)

TABLE NOTATION

' . Refer to ODCM for LLD definition.

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 which is representative of the liquids released.

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

The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. This list does not mean that only these nuclides are to b3 considered. Other gamma peaks that are identifiable, together with those of.the above nuclides, shall.be analyzed and reported in the Semiannual Radioactive Effluent

' Release Report.

l l

l Amendment No. 189

o TABLE 4.8-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Channel Instrument Source Channel Functional Instrument- Check Check Calibration- . Test

1. Gross Beta or Gamma Radioactivity Monitors Providing Alarm and Auto-matic Isolation

a. Liquid Radwaste Effluents Line NA Once per Quarterly.

operating cycle *

2. Flow Rate Measurement Devices

a. Liquid Radwaste Effluent Line NA Once per Quarterly operating cycle I

'During.or prior to release via this pathway.

• Previously established calibration procedures will be used for these-requirements.

Amendment No. 190-

s TABLE 4.8-3 RADI0 ACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Minimum Type of Sampling Analysis Activity (LLD)

-Gaseous Release. Type Frequency Frequency Analysis ( C1/ml)

Main Stack Monthly Principal

.and Grab Monthly Gamma Rx Bldg. Vent Sample Emitters'** 1 x 10-'

H-3 1 x 10-'

Weekly Continuous Charcoal I-131 1 x 10-iz Sample Weekly Principal Continuous Particulate Gamma 1 x 10-

Sample Emitters'**

(I-131, others)

Monthly Composite Continuous' Particulate gross alpha 1 x 10-

Sample Quarterly Composite Continuous ( Particulate Sr-89, Sr-90 1 x 10-

Sample Continuous Continuous Noble Gas Noble Gases Monitor Gross Gamma 1 x 10-'

Amendment No. 191

TABLE 4.8-3 (Continued)

TABLE NOTATION

• • • Refer to ODCM for LLD definition.

(*'

The principal gamma emitters for which the LLD specification, applies

exclusively are the_following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissions; and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144 for particulate emissions. This list does not mean that only these nuclides are to be considered. Other gamma peaks that are identifiable, together

~ with those of the.above nuclides, shall be analyzed and reported in the Semiannual Radioactive Effluent Release Report.

~(*)

When the average daily gross radioactivity release rate increases by 50 percent over the previous day (after factoring out power level changes),

the iodine and particulate filters shall be analyzed to determine the release rate for lodines and particulates.

)

The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specification 3.8.D.

Amendment No. 192

. TABLE 4.8 -

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS Instrument Instrumer+ Source Instrument Functional Instrument Check Check Calibration Test l 1. Main Stack Effluent Monitoring System l

l a. Noble Gas Activity Monitor Daily' Monthly Once'per Quarterly i (Two channels) operating cycle *

b. Iodine Sampler Cartridge NA NA NA NA

c. Particulate Sampler Filter NA NA NA NA

a. Effluent System Flow Rate Daily' NA Once per Quarterly Measuring Device operating cycle _,

e. Sampler Flow Rate Measuring Daily' NA Once per Quarterly Device operating cycle

2. Reactor Building Ventilation Effluent Monitoring System

a. Noble Gas Activity Monitor Daily' Monthly Once per Quarterly operating cycle

• l I

! b. Iodine Sampler Cartridge NA NA NA NA

c. Particulate Sampler Filter NA NA NA NA l

l d. Effluent System Flow Rate Daily' NA Once per Quarterly-1 Measuring Device operating.

cycle l

l Amendment No. 193

. ).

i

[ ~

l TABLE 4.8-4 (Continued)'

l RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS l

Instrument Instrument Source Instrument ' Functional Instrument Check Check Calibration Test

e. Sampler Flow Rate Measuring' Daily' NA Once per Quarterly Device operating cycle l 3. Steam Jet Air Ejector Radioactivity Monitor l

a. Noble Gas Activity Monitor Daily

• NA Once per Quarterly l operating cycle *

4. Augmented Offgas Treatment System Explosive Gas Monitoring System l a. Hydrogen Monitor Daily

• NA Quarterly 5 Monthly l

'During releases via this pathway.

'During augmented offgas treatment system operation.

'During operation of the steam jet air ejector.

'Previously established calibration procedures will be used for these requirements.

' Calibrate at 2 points with standard gas samples differing by at least 11 but not exceeding 41.

Amendment No. 193a '

HIGH PURITY WASTE SYSTEM Clean Haste s Hlxed Bed s Treated Water s Discharge Tanks Ionex Tanks or Recycle LOW PURITY WASTE SYSTEM Chemical Waste s Discharge e

Tanks DETERGENT WASTE SYSTEM (Decon Areas)

Misc Waste Tanks or Non-treatable Releases > Discharge (e.g., neutralizer sumps)

Figure 4.8-1 Liquid Radwaste Treatment System Schematic Amendment No. 193b

SJAE Recombiner Condenser Drier 4 Charcoal to Stack Condenser GLAND SEALS from. s s Turbine ).7-minute Holdup' to Stack Gland Seals .,

MECHANICAL VACUUM PUMP from s Main ' to Stack Condenser DRYWELL from s Drywell to Stack REACTOR BUILDING from Reactor > to R.B.

Bldg Vent RADWASTE BUILDING from -

Radwaste > to R.B.

Bldg Vent TURBINE BUILDING from Turbine s to R.B.

Bldg Vent

{ No significant effect in reducing offsite doses when compared to transit time required for releases to reach site boundary. ,

Figure 4.8-2 Gaseous Effluent Treatment Schematic Amendment No. 193c

BASES

'3/4.8 RADIOACTIVE EFFLUENTS A. Liquid Effluents Concentration This specification is provided to ensure that the concentration of radioactive materials released in 11guld waste effluents at and beyond the site boundary will be less than the concentration levels specified in~10 CFR Part 20, Appendix B, Table II. This limitation provides additional assurance that the levels of radioactive materials in bodies of water at and beyond the site boundary will not result in exposures within (1) the Section II.A design objectives of Appendix I,10 CFR Part 50, to a member of the public and (2) the limits of 10 CFR Part 20.106(e) to the population.

B. Radioactive Liquid Effluent Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in 11guld effluents during actual or potential releases of 11guld effluents. The alarm / trip setpoints for these instruments shall be calculated in accordance with NRC approved methods in the Offsite Dose Calculation Manual (0DCM) to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. The operability and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

C. Liquid Effluent Treatment The requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in 11guld effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of 10 CFR Part 50.36a, General Design Criteria 60 of Appendix A to 10 CFR Part 50 and design objective Section II.0 of Appendix I to 10 CFR Part 50. The specified limits -

governing the use of appropriate portions of the 11guid radwaste treatment system were specified as a suitable fraction of the guide set forth in Section II.A of Appendix I, 10 CFR Part 50, for 11guld effluents.

D. Gaseous Effluents Dose Rate This specification is provided to ensure that the dose rate at anytime at and beyond the site boundary from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20. The annual dose limits are the doses associated with the concentration of 10 CFR Part 20, Appendix B, Table II. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a member of the public either within or outside the site boundary to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20.106(b). For members of the pubile who may at times be within the site boundary, the occupancy of the individual will usually be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the site boundary. The specified release rate limits restrict, at all times, the corresponding Amendment No. 193d

s

• I 1

BASES 3/4.8.D Gaseous Effluents Dose Rate (Continued) gamma and beta dose rates above background to a member of the public.at or beyond the site boundary to 1 500 mrem / year to the total body or:to s 3000' mrem / year'to the skin. These release rate limits also restrict, at all times the corresponding thyroid dose rate above background to an infant M via the cow-ml.lk-infant pathway to 1 1500 mrem / year for the. nearest cow to the plant.

E. RadioactiveGaseousProcessandEffluentMonitoringInstrumeNtati$n The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. .The alarm / trip setpoints for these instruments shall be. -

calculated in accordance with NRC approved methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. The process monitoring instrumentation includes provisions fo'r monitoring (and controlling) the concentrations of potentially explosive gas mixtures in the main condenser offgas treatment system. .The operability and use of this instrumentation is cor.sistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. -

F. Gaseous Effluent Treatment The requirement that the appropriate portions of these systems be used when specified provides reasonable assurance that the releases of radioactive-materials in gaseous effluents will be kept "as low as is reasonably achievable." This specification implements the requirements of

~

10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to l_0 CFR Part 50, and design objective Section II.D of Appendix I'to 10 CFR Part

50. The_specified limits governing the use of appropriate portions c,f the systems were specified as a suitable fraction of the guide set forth in Sections II.B and II.C of Appendix I, 10 CFR Part 50, for gaseous effluents. ,

Maintaining the concentration of_ hydrogen below it's flammability limits provides assurance that releases of radioactive materials willibe controlled in conformance with the requirements of General Design Criteria 60 of Appendix A to 10 CFR Part 50.

-G. Main Condenser-Restricting the gross radioactivity rate of noble gases from the main condenser provides reasonable assurance that the total body exposure to a member of the public'at and beyond the site boundary will not exceed a small fraction of the limits of 10 CFR Part 100 in the event this effluent-is inadvertently discharged directly to the environment without-treatment. This specification implements the requirements of General

Design Criteria 60 and 64 of Appendix A to 10 CFR Part 50.

Amendment No. 193e

BASES 3/4.8.G Main Condenser (Continued)

Two air ejector off-gas monitors are provided and when their trip point is reached, cause anilsolation of the air ejector off-gas line. Isolation is initiated.when both' instruments reach their high. trip point orLone has an upscale trip and the other a downscale trip. There is a fifteen minute delay before the air. ejector off-gas isolation valve is closed. This

. delay-is accounted for by the 30-minute holdup time of the off-gas before it is released to the stack.

Both instruments are required for' trip but the instruments are so designed-that any instrument failure gives a downscale trip. The trip settings of the instruments are set so that the instantaneous stack releare rate limit given in Specification 3.8 is not exceeded.

H. Mechanical Vacuum Pump The purpose of isolating the mechanical vacuum pump line is to limit the release of activity from the main condenser. During an accident, fission products would be transported from the reactor through the main steam lines to the condenser. The fission product radioactivity would be sensed

.by the main steam line radioactivity monitors, which initiate isolation.

l Amendment.No. 193f

e

' ~

6.9.C.  ; Unique Reporting Requirements

~

-1. Radioactive-Effluent Release Report

~~

A report shal1 be submitted to the Commission within 60 days after

< January 1 and July I'of each year specifying the-quantity of each of the principal radionuclides released at.and.beyond the site boundary l in.11guld and gaseous effluents'during the previous 6 months. The format and content of the report shall be in accordance with Appendix B'of_ Regulatory Guide 1.21 (Revision 1) dated June, 197.4.

- 2 .- Annual Radiological Environmental Monitoring Report t 'A' report on the radiological environmental surveillance program for .

the previous calendar year of operation shall be submitted'to the Director of the NRC Regional Office with a copy to-the Director, Office of Nuclear Reactor Regulation as a separate document prior to

.May'1 of the-year. The reports shall include.. summaries,.

Interpretations, and statistical evaluation of the results of the ,

radiological environmental surveillance activities for the report period, operational-controls and_. previous! environmental surveillance ,

-reports, and'an assessment of-the observed' impacts of the plant operation on the environment. The reports shall also include-the

results of any land use surveys which affect the choice of sample locations. If harmful effects or evidence of irreversible' damage are detected by the monitoring, the licensee shall provide an analysis of.

'the problem and a proposed course of action.to alleviate the problem.

The Annual Radiological Environmental Monitoring Report shall include a summary of the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the. locations specified'in the table and figures-in'the Offslte Dose Calculation _ Manual (ODCM) as-well as summarized.and. tabulated:results.of these analyses and measurements-in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

In the event that some results are.not available prior to May-1 of the year, the report shall be submitted,-noting.and explaining the' reasons for.the missing results. The missing data shall be submitted as soon as possible in a supplementary report.

.The report shall also include the following: a summary description of the radiological environmental monitoring program; at least two legible maps' covering all sampling locations keyed to a table

.giving distances and directions-from the centerline of the reactor; One map shall cover stations near the site boundary; a second shall

. include the more distant stations.

Amendment No. 223

t l

6.9.C.2 Annual Radiological Environmental Monitoring Report (Continued) discussion of all deviations from the sampling schedule of Table '

-8.1-1; and discussion of all analyses in which the lower limits of detection _(LLD) required by Table 8.1-4 were not achievable.

3. Offsite Dose Calculation Manual (ODCM)

Any changes to the ODCH shall be submitted to the Commission in the semiannual radioactive effluent release report.

t Amendment No. 223a

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.0 RADIOLOGICAL ENVIRONMENTAL 8.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM MONITORING PROGRAM 7.1 Monitoring Program 8.1 Monitoring Program Applicability: Specification:

At all times. A. ENVIRONMENTAL MONITORING Specification: The radiological environmental monitoring samples shall be A. ENVIRONMENTAL MONITORING collected pursuant to Table 8.1-1 from the specific locations given An environmental monitoring program in the table and figure (s) in the shall be conducted to evaluate the Offsite Dose Calculation Manual effects of station operation on the (00CM) and shall be analyzed environs and to verify the pursuant to the requirements of effectiveness of the source Table 8.1-1 and the detection controls on radioactive materials. capabilities required by Table 8.1-4.

The radidlogical environmental monitoring program shall be 1. Cumulative dose contributions conducted as specified in Table for the current calendar year 8.1-1. from radionuclides detected in environmental samples Action: shall be determined in accordance with the

1. With the radiological methodology and parameters in environmental monitoring program the ODCM. These results will not being conducted as specified be reported in the Annual in Table 8.1-1, prepare and Radiological Environmental submit to the Commission, in the Monitoring Report.

Annual Radiological Environmental Monitoring Report required by Specification 6.9.C.2, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

2. With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels l of Table 7.1-1 when averaged over any calendar quarter, _

prepare and submit to the Commission within 30 days, a special report that identifies the cause(s) for exceeding the limit (s) and defines the l corrective actions to be taken Amendment No. 229

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.1.A ENVIRONMENTAL MONITORING (Continued) to reduce radioactive effluents so that the potential annual dose to a member of the public is less than the calendar year limits of Specifications 7.2, 7.3, and 7.4. When more than one of the radionuclides in Table 7.1-1 are detected in the sampling medium, this report shall be submitted if:

concentration (1) + concentration (2) + .. > 1.0 reporting level (1) reporting level (1)

When radionuclides other than those in Table 7.1-1 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits of Specifications 7.2, 7.3, and 7.4. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Monitoring Report.

3. With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 8.1-1, identify locations for obtaining replacement samples and add them to the Radiological Environmental Monitoring Program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitoring program.

Amendment No. 230

-OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.1.A ENVIRONMENTAL MONITORING

.(Continued)

Pursuant to Specification 6.9.C.2, identify the cause of the unavailability.of samples and identify the new location (s) obtaining replacement samples in the next Annual. Environmental Radiation Monitoring Report and also  ;

include in the. report the table for the ODCM reflecting the new location (s).

B. LAND USE CENSUS' B. LAND USE CENSUS A land use census shall be The land use census shall be conducted and shall identify, conducted during the growing within a distance of 8 km (5 season, at least once per 12 miles), the location in each of months using that information that the 16 meteorological sectors of will provide the best results, the nearest milk animal, the such as by a door-to-door survey, nearest residence and the nearest aerial survey, or.by consulting-

-garden of greater than 50 m 2 local agriculture authorities.

(500 ft*) producing broad leaf The results of the land use census vegetation. (For elevated. shall be included in the Annual releases as defined in Regulatory Radiological Environmental Guide 1.111, Revision 1, July Monitoring Report.

1977, the land use census shall L also identify, within a distance Broad leaf vegetation sampling of of 5 km (3 miles), the locations at least three different kinds of in each of the 16 meteorological vegetation may be performed at the sectors of all milk animals and site boundary in each of the two all gardens of greater than 50 different direction sectors with m7 producing broad leaf the highest predicted D/Qs, in vegetation. lieu of the garden. census.

Specifications for broad leaf Action vegetation sampling in Table 8.1-1 shall be followed, including

1. With a land use census analysis of control samples, identifying a location (s) that yields a calculated dose or dose commitment greater than the values currently being calculated in Specification 8.4.A ' identify the new location (s) in the next Annual Environmental Radiological

~

Monitoring Report.

Amendment No. 231

0 OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.1.8 LAND USE CENSUS (Continued)

-2. With a land use census identifying a location (s) that yields a calculated dose or dose commitment (via the same exposure pathway) 20 percent greater than at a location from which samples are currently being obtained in accordance with Specification 7.1, add the new location (s) to the Radiological Environmental Monitoring Program within 30 days. The sampling location (s), excluding'the control station location, having the lowest calculated dose or dose commitment (s), via the.same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this land use census was conducted. Identify the new location (s) in the next Annual Environmental Radiological Monitoring Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

7.2- Dose - Liquids 8.2 Dose - Llaulds Applicability: Specification:

At all times. A. Dose Calculations - Cumulative dose contributions from liquid Specification: effluents shall be determined in accordance with the ODCM for each A. The dose or dose commitment to a calendar month during which member of the public from releases occurred.

radioactive materials in liquid effluents released at and beyond the site boundary shall be limited:

1. During any calendar quarter to 1 1.5 mrem to the total body and to i 5 mrem to any organ, -

and

2. During any calendar year to 1 3 mrem to the total body and to i 10 mrem to any organ.

Amendment No. 232

r:-

9 s.

OPERATIONAL OBJECTIVES SdRVEILLANCE REQUIREMENTS 7.2 Dose - Liquids-(Continued)

. Action With the calculated dose from the l release of radioactive materials in liquid' effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, a special report that identifies the cause(s), corrective actions taken, and cor,ective actions to be taken.

7.3 Dose - Noble Gases 8.3 Dese -' Noble-Gases

. Applicability: Specification:

At all times. A. Dose Calculations - Cumulative dose contributions for the total Specification: time period shall be determined in accordance with the ODCM for A. The air dose in areas at and beyond each calendar month during which the. site boundary due to noble gases releases occurred.

released in gaseous effluents shall be-limited to the following:

1. During any calendar quarter, to 1 5 mrad for gamma radiation and i 10 mrad for beta radiation; and

2. During any calendar year, to 1 10 mrad for gamma radiation and 1 20 mrad for beta radiation.

4 Action With the calculated air dose from

-radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, a special report which identifies the cause(s), the corrective actions-taken, and corrective actions to be taken.

f Amendment No. 233

9 OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.4 Dose - Iodine-131, Iodine-133, 8.4 Dose - Iodine-131, Iodine-133, Radioactive Material in Radioactive Material in Particulate Form, and Tritium Particulate Form, and Tritium Applicability: Specification:

At all times A. Dose Calculations - Cumulative dose contributions for the total Specification: time period shall be determined for lodine-131, iodine-133, A. The dose to a member of the public radioactive material in from iodine-131, lodine-133, particulate form with half-lives radioactive materials in greater than 8 days, and tritium particulate form with half-lives in accordance with the ODCM for greater than 8 days, and tritium each calendar month during which in gaseous effluents released to releases occurred.

areas at and beyond the. site boundary shall be limited to the following:

1. During any calendar quarter to 1 7.5 mrem'to any organ, and

2. During any calendar year to 1 15 mrem to any organ.

Action With the calculated dose from the release of iodine-131, iodine-133, radioactive materials in particulate form, and tritium in gaseous effluents exceeding any of the above limits; prepare and submit to the Commission within 30 days, a special report which

> identifies the cause(s),

corrective actions taken, and the corrective actions to be taken, t

7.5 Total Dose 8.5 Total Dose

l. Applicability: Specification:

[ At all times. A. Dose Calculations - Cumulative dose contributions from liquid Specification: and gaseous effluents shall-be determined in accordance with A. The dose or dose commitment to any Specifications 7.2~.A, 7.3.A, and member of the public from Pilgrim 7.4.A; and in accordance with the Station sources is limited to 1 25 ODCM.

mrem to the total body or any organ (except the thyroid, which Amendment No. 234

i I ,

OPERATIONAL OBJECTIVES SURVEILLANCE REQUIREMENTS 7.5 Total Dose (Continued) is limited to < 75 mrem) over a period of any calendar year.

Action With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specifications 7.2.A, 7.3.A, or 7.4.A; prepare and submit a special report to the Commission and limit the subsequent releases such that the dose or dose commitment to any member of the public from all uranium fuel cycle sources is limited to 1 25 mrem to the total body or any organ (except thyroid, which is limited to 1 75 mrem) over any calendar year. This special report shall include an analysis which demonstrates that radiation exposures to all members of the public from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are less than the 40 CFR, Part 190 standard. Otherwise, obtain a variance from the Commission to permit releases which exceed the 40 CFR, Part 190 standard.

I

)

Amendment No. 235

TABLE 7.1-1 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Reporting Levels Water Airborne Particulate Fish Milk- Vegetables Analysis (pC1/L) or Gases (pC1/M') (pC1/kg, wet) (pC1/1) (pC1/kg, wet)

H-3 2 x 10*

Mn-54 1 x 10' 3 x 10*

Fe-59 4 x 10 1 x 10*

Co-58 1 x 10' 3 x 10*

Co-60 3 x 10 2 1 x 10*

Zn-65 3 x 10 2 x 10*

Zr-95 4 x 10*

I-131 2 0.9 3 1 x 10:

Cs-134 30 10 1 x 10' 60 1 x 10' Cs-137 50 20 2 x 10' 70 2 x 10' Ba-140 2 x 10* 3 x 10 2 5

4 Amendment No. 236

_ 7 TABLE 8.1-1 OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Locations Exposure Pathway (Direction-Distance) Sampling and Type and Frequency i or Sample Type from Reactor Collection Frequency ~ of Analysis

. AIRBORNE Particulates 11 Locations (See Continuous sampling over . Gross beta radioactivity Table 8.1-2) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after

~

i one week

{- filter change

Quarterly 11 Locations (See Composite (by location) for Table 8.1-2) gamma isotopic" Radioiodine 11 Locations (See Continuous sampling with Analyze weekly for I-131 i Table 8.1-2) canister collection weekly

) DIRECT

• 40 Locations (See Quarterly Gamma exposure quarterly '

l Table 8.1-3)

Plymouth Beach and Annually Gamma exposure survey' Priscilla/ White Horse Beach I

WATERBORNE Discharge Canal Continuous composite Gamma isotopic monthly, (Surface Water) sample. and composite for H-3

Bartlett Pond Weekly grab sample analysis quarterly

• i (SE-1.7 mi)

Powder Point Weekly grab sample (NNH-7.8 ml)*

A00ATIC l

1 Shellfish Discharge outfall Quarterly (at approximate Gamma isotopic * '

(clams, mussels Duxbury Bay- 3-month intervals) or quahogs as Manomet Point.

available) Plymouth or Kingston

~

Harbor Marshfield*

Amendment No. 237 1

TABLE 8.1-1 (Continued)

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Locations Exposure Pathway (Direction-Distance) Sampling and Type and Frequency or Sample Type from Reactor Collection Frequency of Analysis Lobster Vicinity of discharge Four times per season Gamma Isotopic *'on point edible portions Offshore

• Once per season Fish Vicinity of discharge Quarterly (when particular Gamma isotopic" on point species available) for Groups edible portions 5 Offshore

• I and II5 , in season for Groups III and IV 5, annually for each group Sediments Rocky Point Sem1 annually Gamma isotopic 2 Plymouth Harbor Duxbury Bay Plymouth Beach Manomet Point Marshfield INGESTION (Terrestrial)

Milk Plymouth County Farm, Sem1 monthly during Gamma isotopic 2

, radio-when available periods when animals are lodine analysis all samples (H-3.5 mi)* on pasture,-otherwise Whitman Farm monthly (NH-21 mi)*

Cranberries Manomet Point Bog At time of harvest Gamma isotopic' on edible (SE-2.6 mi) portions Bartlett Rd. Bog (SSE/S-2.8 mi)

Pine St. Bog (HNH-17 mi)*

Amendment No. 238 ,

.i TABLE 8.1-1 (Continued)

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Locations Exposure Pathway -(Direction-Distance) Sampling and . Type and Frequency or Sample Type from Reactor Collection Frequency of Analysis Tuberous and green Plymouth County Farm At time of harvest Gamma isotopicon edible leafy' vegetables (H-3.5 mi)* portions

. Bridgewater Farm (W-20 mi)*

Beef Forage Plymouth County Farm Annually Gamma Isotopic *

(W-3.5 mi)*

Wh1tman Farm (NH-21 mi)*

t Amendment No. 239

~

TABLE 8.1-1 (Continued)

NOTES

' If gross beta radioactivity is greater than 10 times the control value, gamma isotopic will be performed on the sample.

• Gamma isotopic means the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

• If integrated gamma activity (less K-40) is greater than 10 times the control value (less K-40), strontium-90 analysis will be performed on the sample.

Indicates control location.

5 Fish analyses will be performed on a minimum of 2 sub-samples, consisting of approximately 400 grams each from each of the following groups:

I. Bottom Oriented II. Near Bottom III. Anadromous IV. Coastal Distribution Migratory Hinter flounder Tautog Alewife Bluefish Yellowtail founder Cunner Rainbow smelt Atlantic herring Atlantic cod Striped bass Atlantic menhaden Pollock Atlantic mackerel Hakes

• Mussel samples from four locations (immediate vicinity of discharge outfall, Manomet Point, Plymouth or Kingston Harbor, and Green Harbor in Marshfield) will be analyzed quarterly as follows:

One kilogram wet weight of mussel bodies, including fluid within shells will be collected. Bodies will be reduced in volume by drying at about 100*C. Sample will be compacted and analyzed by Ge(L1) gamma spectrometry or alternate technique, if necessary, to achieve a sensitivity of 5 pC1/kg for Cs-134, Cs-137. Co-60, Zn-65, and Zr-95; and 15 pC1/kg for Ce-14a. Sensitivity values are to be determined in accordance with a 95% confidence level on k, and a 50% confidence level on k. (See HASL-300 for definitions).

The mussel shell sample from one location will be analyzed each quarter.

One additional mussel shell sample will be analyzed semlannually.

Unscrubbed shells to be analyzed will be dried, processed, and analyzed similarly to the mussel bodies.

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Amendment No. 240

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i TABLE 8.1-1 (Continued)

NOTES Because of the small volume reduction in pre-processing of shells, sensitivities attained will be less than that for mussel bodies. The equipment and counting times to be employed for analyses of shells will be the same or comparable to that employed for mussel bodies so that the reduction in sensitivities (rclative to those for mussel bodies) will be strictly limited to the effects of poorer geometry related to lower sample volume reduction. ~ Shell samples not scheduled for analysis will be reserved (unscrubbed) for possible later analysis.

If radiocestem (Cs-134 and Cs-137) activity exceeds 200 pC1/kg (wet) in

. mussel bodib , these samples will be analyzed by radlochemical separation, electrodeposition, and alpha spectrometry for radioisotopes of plutonium, with a sensitivity of 0.4 pC1/kg.

Sediment samples from four locations (Manomet Point, Rocky Point,'

Plymouth Harbor, and head of Duxbury Bay) will be analyzed once per year (preferably early summer) as follows:

Cores will be taken to depths of 30-cm, minimum depth, wherever sediment conditions permit, by a hand-coring sampling device. If sediment conditions do not permit 30-cm deep cores, the deepest cores achievable with a hand-coring device will be taken. In any case, core depths will not be less than 14-cm. Core samples will be sectioned into 2-cm increments; surface and alternate increments will be analyzed, all others will be reserved. Sediment sample volumes (determined by core diameter and/or number of individual cores taken from any single location) and the counting technique will be sufficlect to achieve sensitivities of 50 pC1/kg dry sediment for Cs-134, Cs-137, Co-60, Zn-65, and Zr-95 and 150 pCl/kg for Ce-144. In any case, individual core diameters will not be less than 2 inches.

The top 2-cm section from each core will be analyzed for Pu isotopes (Pu-238, Pu-239,'and Pu-240) using radiochemical separations, electrodeposition, and alpha spectrometry with target sensitivity of 25 pC1/kg dry sediment. Two additional core slices per year (mid-depth slice from two core samples) will be similarly analyzed.

• These locations may be altered in accordance with results of surveys discussed in Specification 8.1.B.

• Minimum sensitivities for gamma exposure measurements are as follows:

Gamma exposure - 1 R/hr average exposure rate.

Gamma exposure survey - 1 R/hr exposure rate.

Amendment No. 241 i

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TABLE 8.1-2 AIR PARTICULATES. GASEOUS RADI0IO0lNE. AND SOIL SURVEILLANCE STATIONS Sampling Location Distance and (Sample Designation) Direction from Reactor Offsite Stations East Weymouth (EW) (Control Station) 21 miles NN Plymouth Center (PC) 4.0 miles W-WNW Manomet Substation (MS) 2.S miles SE Cleft Rock Area (CR) 0.9 miles S Onsite Stations

-Rocky Hill Road (ER) 0.8 miles SE Rocky Hill Road (WR) 0.3 miles W-WNW Overlook Area (OA) 0.03 miles N Property Line (PL) 0.34 miles NW Pedestrian Bridge-(PB) 0.14 miles N East Breakwater (EB) 0.3S miles ESE Warehouse (WS) 0.03 miles SSE W

Amendment No. 242 L

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TABLE 8.1-3 EXTERNAL GAMMA EXPOSURE SURVEILLANCE STATIONS' Distance and Dostmeter Location (Designation) Direction from Station ONSITE STATIONS-Property LineL(D) 0.17 miles NNW Property Line (F) 0.12 miles NW ,,,

Property Line (I) 0.14 miles W Property Line (G) 0.20 miles WSW Rocky Hill Road (A) -0.12 miles SW Property Line (H) 0.21 miles SSW Pubile Parking Area (PA) 0.07 miles N-NNE Pedestrian Bridge (PB) 0.1 miles NE Overlook Area (OA) 0.03 miles W East Breakwater (EB) 0.26 miles ESE Property Line (C) 3.3 miles ESE-SE Property Line (HB) 0.34 miles SE Rocky Hill Road (B) 0.26 miles SSE Microwave Tower (MT) 0.38 miles S Emerson Road (EM) 0.68 miles SE-SSE White Horse Road (WH) 0.89 miles SE-SSE j Property Line (E) 0.75 miles SSE-S Rocky Hill Road (WR) 0.3 miles W-WNW Property Line (J) 1.36 miles SSE-S Property Line (K) 1.42 miles SSE-S Rocky Hill Road (ER) 0.8 miles SE Property Line (L) 0.40 miles E -

Amendment No. 243

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TABLE 8.1-3 (Continued)

EXTERNAL GAMMA EXPOSURE SURVEILLANCE STATIONS' ,

Distance and Dosimeter Location (Designation) -Direction from Station ONSITE-STATIONS (Continued)

Warehouse (WS) 0.1 miles SE

' Property Line (PL) '

O.3 miles W OFFSITE STATIONS Duxbury (SS) 6.25 miles SSN-SW -

Kingston (KS) 10 miles HNW

• North Plymouth (NP) 5.5 miles WNW Plymouth Center (PC). 4.0 miles W-WNW South Plymouth (SP) 3 miles WSW Bayshore Drive (BD) 0.7 miles W-WNW Cleft Rock Area (CR) 0.9 miles S .

Manomet (MP) 2.25 miles ESE-S Manomet (ME) 2.5 miles SE Manomet.(MS) 2.5 miles SSE Manomet (MB) 3.5 miles SE-SSE College Pond (CP) 6.5 miles SSW-SW Sagamore (CS) 10 miles SSE-S Plymouth Airport (SA) 8 miles WSW East Weymouth (EW)* 21 miles NW Saquish Neck (SN)' 4.6 miles NNW Thermal Luminescent Dosimeters (TLDs)

Control Station TLDs for this location will be provided to a third party and will be analyzed for gamma exposure whenever returned to Boston Edison Company.

Amendment No. 244

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ei TABLE 8.1-4 #

MAXIMUM VALUES FOR THE LONER LIMITS OF DETECTION (LLD)*

Nater Airborne Particulate Het Solids Milk Food Products- Dry Solids Analysis (pC1/kg) or Gas (pCl/M')_ (pC1/kg, wet) (pCl/c) (DC)/ka, wet)- (DC1/ka, dry) gross beta 4* 1 x 10-2

'N 2000*

• • Mn 15 130 4

5'Fe 30 260 i

5'

Co 15 130 50

'5

! 2n 30 260 50 j Zr 15 50 I 'I i 7 x 10-2 1 60*

* 'Cs 15 18 1 x 10-* 130 15 60 50 4

'**Ba- 15 15

(

'**Ce '150 l

• Refer to ODCM for LLD definition.

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• LLD for surface water.

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• LLD for leafy vegetables.

!

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

Amendment No. 245

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BASES 7/8.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 7/8.1 Monitoring Program 7/8.1.A ENVIRONMENTAL MONITORING An environmental radiological monitoring program is conducted to verify the adequacy of in-plant controls on the release of radioactive materials. The program is designed to detect radioactivity concentrations to ensure that radiation doses to individuals do not exceed the levels set forth in 10 CFR 50, Appendix I.

A supplemental monitoring program for sediments and mussels has been incorporated into the basic program (see Notes 6 and 7 to Table 8.1-1) as a result of an agreement with the Massachusetts Hildlife Federation. This supplemental program is designed to provide information on radioactivity levels at substantially higher sensitivity levels in selected samples to verify the adequacy (or, alternatively, to provide a basis for later modifications) of the long-term marine sampling schedules. As part of the supplemental program, analysis of mussels for isotopes of plutonium will be performed if radiocesium activity should exceed 200 pC1/kg in the edible portions.

The 200 pC1/kg radiocesium " action level" is based on calculations which show that if radiocesium from plant releases reached this level, plutonium could possibly appear at levels of potential interest. The calculations also show that the dose delivered from these levels of plutonium would not be a significant portion of the total dose attributable to liquid effluents.

The program was also designed to be consistent, wherever applicable, with NUREG 0473.

Grotadwater flow at the plant site is into Cape Cod Bay; therefore, .

terrestrial monitoring of groundwater is not included in this program.

Detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLD). The LLD in Table 8.1.4 is considered optimum for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually), curie, L.A.; " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry", Anal. Chem. 40, 586-93 (1968); and Hartwell, J. K.,

" Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

In measurable quantities having a potential dose (human food chain) significance comparable to other nuclides if present at their detection limits.

Amendment No. 246 '

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-cr BASES 7/8.1.8 LAND USE CENSUS This section is provided to ensure that changes in the use of areas at and beyond the site boundary are identified and that modifications to the radiological environmental monitoring program are made if required by the results of this census. -The best information from the door-to-door

' survey,'from aerial survey, or from consulting with local agricultural authorities shall be used. This census satisfies the requirements of 10CFR50, Appendix I, Section IV.B.3. Restricting the census to gardens of greater than 50 m' provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored, since a

-garden of this size is the minimum required to produce the quantity (26 kg/ year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the

-following assumptions were made: 1) 20% of the garden was used for growing broad leaf vegetation 2(i.e., similar to lettuce and cabbage), and

2) a vegetation yleid of 2 kg/m .

7/8.2 DOSE - LIQUID This section-is provided to implement the requirements of Sections II.A,

'III.A, and IV.A of 10CFR50, Appendix I, to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable." Because Pilgrim is not a site where plant operations can conceivably affect drinking water, none of these requirements are intended to assure compliance with 40 CFR'141. The dose j calculations in the ODCM implement the requirements of 10CFR50, Appendix I, Section III.A to ensure that the actual exposure of a member of the public through appropriate pathways is unlikely to be substantially unde'. estimated. The equations specified in the 00CM for calculating the doses due to the actual release rates of radioactive materials in 11guld effluents will be consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating CompItance with 10CFR .

Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113. " Estimating Aquatic Olspersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I,"

April 1977. NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.113.

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Amendment No. 247 l

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0 BASES 7/8.3 DOSE - NOBLE GASES -

This section is provided to implement the requirements of 10CFR50, Appendix I, Secti6ns II.B. III.A, and IV.A to ensure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The surveillance requirements implement the requirements of 10CFR50, Appendix I, Section III.A to ensure that the actual exposure of a member of the public through the appropriate pathways is unlikely to be substantially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109 and Regulatory Guide 1.111. " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. The ODCM equations provided for determining the air doses at and beyond the site boundary will be based upon the historical average atmospheric conditions.

NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.111.

7/8.4 DOSE - 10 DINE-131, 10 DINE-133, RADIOACTIVE MATERIAL IN PARTICULATE FORM, AND TRITIUM This section is provided to implement the requirements of Sections II.C, III.A and IV.A of 10 CFR50, Appendix I, to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the surveillance requirements implement the requirements of 10CFR50, Appendix I, Section III.A to ensure that the actual exposure of a member of the pubilc through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methods approved by the NRC for calculating the doses due to the actual release rates of the subject materials are required to be consistent with the methodology provided in Regulatory Guides 1.109 and 1.111. These equations also provide for .

determining the actual doses based upon the historical average atmospheric conditions. The release rate specifications for lodine-131, radioactive material in particulate form with half-lives greater than 8 days, and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in areas at and beyond the site boundary. The pathways which are examined in the development of these calculations are: 1) Individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, 3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man.

Amendment No. 248

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7/8.5 TOTAL DOSE

• This section is provided to meet the dose limitations of 40CFR190 that [

have now been incorporated into 10CFR20 by 46 FR 18525. The specification requirer the preparation and submittal of a special report whenever the  ;

calculated doses from plant radioactive effluents exceed twice the design  ;

objective doses of 10CFR50, Appendix,I. For sites containing up to 4 reactors, it is highly unlikely that the resultant dose to a member of the I public will' exceed the dose limits of 40CFR190 if the Individual reactors }

remain within the reporting requirement level. The special report will '

describe a course of action that should result in the limitation of the  ;

annual dose to a member of the public to within the 40CFR190 Ilmits. For i the purposes of the special report, it may be assumed that the dose  ;

commttaent to the member of the public from other uranium fuel cycle  !

' sources is negligible, except dose contributions from other nuclear fuel  !

cycle facilities at the same site or within a radius of 8 km must be considered. If the dose to any member of the pub 11c is estimated to ,

exceed the Ilmits of 40CFR190, a request for a variance in a special ,

• - . report in accordance with 40CFR190.11 and 10CFR20.405C is considered to be a timely request and fulfills the requirements of 40CFR190 until NRC staff ,

. action is completed. This is provided that the release condittoos r resulting in violation of 40CFR190 have not already been corrected. The variance only relates to the limits of 40CFR190, and does not apply in any way to the other requirements for dose limitation of 10CFR20. An  !

Individual is not considered a member of the public during any period in  :

which he/she'Is engaged in any operation that is part of the nuclear fuel  ;

cycle.  :

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l Amendment No. 249 f w_