ML20127C328
| ML20127C328 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/30/1984 |
| From: | Akers D, Duce S, Mandler J, Serrano W, Simpson F EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20127C329 | List: |
| References | |
| CON-FIN-A-6459, RTR-NUREG-0133, RTR-NUREG-0473, RTR-NUREG-133, RTR-NUREG-473 EGG-PBS-6742, TAC-08043, TAC-08095, TAC-8043, TAC-8095, NUDOCS 8412100509 | |
| Download: ML20127C328 (38) | |
Text
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Informal Report EGG-PBS-6742 f
RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)
IMPLEMENTATION - EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 William Serrano Douglas W. Akers Stephen W. Duce John W. Handler Ferrol B. Sirnpson Thomas E. Young Idaho National Engineering Laboratory Operated by the U.S. Department of Energy 1
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Prepared for the U.S. NUCLEAR REGULATORY COMMISSION Under DOE Contract No. DE-AC07 761001570 g
NRC Fin No. A6459 Y
b O E b idaho fl2!fY5D A
.C EGG-PBS-6742 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) IMPLEMENTATION - EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 William Serrano Douglas W. Akers Steve W. Duce John W. Mandler Ferrol B. Simpson Thomas E. Young Published November 1984 EG&G Idaho, Inc.
Prepared for the U.S. NUCLEAR REGULATORY COMMISSION Under DOE Contract No. DE-AC07-761001570 4
NRC FIN No. A6459 t
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ABSTRACT A review of the Radiological Effluent Technical Specifications (RETS) for the Edwin I. Hatch Nuclear Plant Units 1 and 2 was performed. The principal review guidelines used were NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants,"
and Draft 7' of NUREG-0473, Revision 3, " Standard Radiological Effluent Technical Specifications for Boiling Water Reactors." Draft submittals were discussed with the Licensee by both EG&G and the NRC staff until all items requiring changes to the Technical Specifications were resolved.
The Licensee then submitted final proposed RETS to the NRC which were evaluated and found to be in compliance with the NRC review guidelines.
The proposed Offsite Dose Calculation Manual was reviewed and generally found to be in compliance with the NRC review guidelines.
4 r
i
4 FORSf0RD This Technical Evaluation Report was prepared by EC&G Idaho, Inc, under a contract with the U. S. Nuclear Regulatory Commission.(Office of Nuclear Reactor Regulation, Division of Systems Integration) for technical assistance in support of NRC operating reac' tor i fconsing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.
e e
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CONTENTS E.A2.1 Abstract.........................,..
i Foreword............................
11 1.
INTRODUCTION.......................... I 1.1 Purpose of the Technical Evaluation............ 1 1.2 Generic Issue Background.................. I 1.3 Pl ant-Sp ecific Backg round................. 3 2.
REVIBf CRITERIA 5
3.
TECHNICAL EVALUATION...................... 7 3.1 General Description of Radiological Effluent System.... 7 3.2 Radiological Effluent Technical Specifications 9
3.3 Offsite Dose Calcul ation Manual.............. 25 4.
CONCLUSIONS 27 5.
REFERENCES........................... 30 FIGURES 1.
Hatch Unit 1 Liquid Radwaste Treatment System.......... 10 2.
Hatch Unit 2 Liquid Radwaste Treatment System.......... 11 3.
Hatch Plant Units 1 and 2 Radioactive Gaseous Effluent Release 12 Points.............................
4.
Hatch Plant Units 1 and 2 Condenser Offgas Treatment System... 13 T.6.BLE Numbor Ti.111 E.iSt 1
Correspondence of Provisions of NUREG-0473, The Licensee's Current Technical Specifications and the Licensee's Proposal for the Edwin I. Hatch Nuclear Plant Unit 1........................
28 2
Correspondence of Provisions of NUREG-0473, The Licensee's Current Technical Specifications and the Licensee's Proposal for the Edwin I. Hatch Nuclear Plant Un i t 2........................
29 iii
1.
INTRODUCTION 1.1 Puroese of the Technical Evaluation The purpose of this Technical Evaluation Report (TER) is to review and evaluate the proposed changes in the Technical Specifications of the Edwin I. Hatch Nuclear Plant Units 1 and 2 with regard to Radiological Effluent Technical Specifications (RETS) and the proposed Offsite Dose Calculation Manual (00CM).
The evaluation usdt! criteria proposed by the Nuclear Regulatory Commission (NRC) staff in the model Technical Specifications for boiling water reactors (EWRs), NUREG-0473,[13 and subsequent revisions. This effort is directed toward the NRC objective of implert.enting RETS which
. comply with the regulatory requirements, primarily those of 10 CFR Part 50, Appendix I.[2] Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.
1.2 Generic Issue Backaround Since 1970, 10 CFR Part 50, Section 50.36a,[3] " Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide Technical Specifications which ensure that f
radioactive releases will be kept as low as is reasonably achievable j
(ALARA).
In 1975 numerical guidance for the ALARA requirement was issued I -
in 10 CFR Part 50, Appendix I.
The 11eensees of all operating reactors i
were required [43 to submit, no later than June 4,1976, their proposed l-ALARA Technical Specifications and information for evaluation in accordance with 10 CFR Part 50, Appendix I.
However, in February 1976 the i
NRC staff recomended that proposals to modify Technical Specifications be r
1 deferred until the NRC completed the model RETS.
i 1
i
C The model RETS deal with radioactive waste management systems and environmental monitoring. Although the model RETS address 10 CFR Part 50, Appendix I requirements, subsequent revisions include provisions for addressing issues not covered in Appendix I.
These provisions are stipulated in the following regulations:
10 CFR Part 20,[5] " Standards for Protection Against e
Radiation," Sections 20.105(c), 20.106(g), and 20.405(c) which require that nuclear power plants and other I tcensees comply with 40 CFR Part 190,[6] " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40 CFR Part 190 limits have been or may be exceeded.
10 CFR Part 50, Appendix A,[73 " General Design Criteria e
for Nuclear Power Plants," which contains Criterion 60--Control of releases of radioactive materials to the environment; Criterion 63--Monitoring fuel and waste storage; and Criterion 64-Monitoring radioactive releases, 10 CFR Part 50, Appendix B,[8] which establishes the e
quality assurance required for nuclear power plants.
l The NPC position on the model RETS was established in May 1978 when l
the NRC's Regulatory Requirements Review Comittee approved the model l
RETS: NUREG-0472 for PWRs and NUREG-0473 for ENRs. Copies of the model RETS were sent to licensees in July 1978 with a request to submit proposed l
site-specific RETS on a staggered schedule over a six-month period.
i Licensees responded with requests for clarifications and extensions.
I The Atomic Industrial Forum ( AIF) formed a task force to coment on the model RETS. NRC staff members first met with the AIF task force on j
June 17, 1978. The model RETS were subsequently revised (Revision 1) to l
reflect coments from the AIF and others. A principal change was the l
l 2
transfer of much of the material concerning dose calculations from the model RETS to a separate document, the OOCH.
Revision 1 of the model RETS was sent to the licensees on November 15 and 16, 1978 with guidance (NUREG-0133)[93 for preparation of.th,e RETS and the 00CM and a new schedule for responses, again staggered over a six-month period.
Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subsequently, a preliminary copy of Revision 2 of the model RETS and additional guidance on the ODCM and a Process Contrc1 Program (PCP) were issued in February 1979 to each utility at individual meetings. NUREG-0473, Revision 2,[1] was published in July 1979 and updated in January 1980 and February 1980. In response to the NRC's request, operating reactor licensees subsequently submitted initial proposals on plant RETS and the 00CM. Reviews leading to ultimate implementation of these documents were initiated by the NRC in September 1981 using subcontracted independent teams as reviewers.
As the RETS review progressed, feedback from the licensees led the NRC to modify some of the provisions in the February 1,1980 versions of the model RETS to clarify specific concerns of the licensees and thus expedite the reviews.
Starting in April 1982, the NRC distributed revised versions of the model RETS in draft form to the licensees during the site visits.
The new guidance on these changes was presented in an AIF meeting on May 19, 1982.[103 Some interim changes regarding the Radiological Environmental Monitoring Section were issued in August 1982.[113 With the incorporation of these changes, the NRC issued Draft 7 of Revision 3 of NUREG-0473[123 in September 1982 to serve as new guidance for the review teams.
1.3 Pl ant - Soecific Backaround Georgia Power Company (GPC), the Licensee of Hatch plant submitted 3
proposed RETS December 21, 1978 to NRC. EG4G Idaho, Inc. (EG4G), selected as an independent task review team, initiated a review and evaluation of the December,1978 submittal. This submittal was compared with the model RETS and assessed for compliance with the requirements of 10 CFR 50, Appendix I, and 10 CFR S0, Appendix A.
Review comments and questions dated February 11,1982[13] were mailed to the NRC and the Licensee. The Licensee informed the NRC of their intentions to update their RETS submittal and would consider the February 1982 comments in preparation of the new submittal. The updated draft proposal, dated August 13, 1982, was transmitted to NRC in October 1982 and a copy was received by EGSG on October 11, 1982. This proposal was reviewed by EG&G and coments transmitted to the NRC in letter dated November 23, 1982.[143 A site visit was arranged for the purpose of discussing and resolving issues identified in the November 1982 letter.
During the site visit on February 23 and 24,1983, technical discussions resolved many of the issues identified in the November 1982 letter. An EG&G 1etter dated April 4, 1983[15] was transmitted to NRC summarizing issues unresolved at the plant visit.
Georgia Power Company submitted a revised draft proposal September 1, 1983[16] which transferred their Radiological Effluent Technical Specifications from Appendix B to Appendix A.
EG&G reviewed this draft proposal and transmitted the review comments to NRC in letter dated October 19, 1983.[173 Following the September 1,1983 submittal, GPC j
l submitted a complete revision to the December 21, 1978 submittal with letter dated October 6,1983. The Licensee then transmitted with [[letter::05000366/LER-1983-061-03, /03L-0:on 830921,during RCIC Turbine Exhaust Diaphragm Pressure Instrument Procedure HNP-2-3414, Connection Line Inadvertently Broke Off RCIC Turbine D Exhaust Diaphragm Pressure Switch|letter dated October 17, 1983]][183 a final typed version of the October 6 submittal. Since the October 6 submittal was the official submittal it j
was reviewed by EG4G and review comments transmitted to NRC in letter dated December 14, 1983.[193 NRC discussed and resolved with Georgia j
Power personnel the December 1983 comments.
As a result of the discussions, a complete revision to the October 6, 1983 RETS subittal dated August 1, 1984 was transmitted to NRC.[20]
4 l
1
C NRC determined the August 1984 submittal officit.11y resolved all e
outstanding issues. A summary of the resolutions was transmitted to EG&G dated September 6, 1984.[213 The Licensee identified technical inaccuracies and typographical errors in the August 1984 submittal and replaced it with another submittal dated October 1, 1984.[22].This i
submittal allowed preparation of a TER by EG&G for transmittal to NRC.
The December 21, 1978 ODCM was reviewed by EG&G and review comments submitted to the NRC and the Licensee in letter dated December 10, 1962.[233 The 00CM was not discussed at the plant visit at the request of the Licensee since the 00CM was obsolete and a new version was being prepared. A revised draft 00CM proposal dated July 1983 was transmitted by the Licensee to the NRC with letter dated September'1,1983.[16]
This 00CM was reviewed by EG&G and review coments transmitted to the NRC with letter dated November 17, 1983.[24]
The Licensee submitted a corrected 00CM dated October 1, 1984.[253 The October 1984 submittal was reviewed by EG&G and it was determined the 00CM contains documented and approved methods that are generally consistent with the guidelines of NUREG-0133 and is therefore acceptable to NRC as a reference.
2.
REVIEW CRITERIA Review criteria for the RETS and ODCM were provided by the NRC in two documents:
1.
NUREG-0473, PETS for EWRs, 2.
NUREG-0133, Preparation of RETS for Nuclear Power Plants.
5
Twelve essential criteria are given for the RETS and 00CM:
1.
All significant releases of radioactivity shall be controlled and monitored.
2.
Offsite concentrations of radioactivity shall not exceed the 10 CFR Part 20, Appendix B, Table II limits.[26]
3.
Offsite radiation doses shall be ALARA.
4 Equipment shall be maintained and used to keep offsite doses ALARA.
s 5.
Radwaste tank inventories shall be limited so that failures would not cause offsite doses exceeding 10 CFR Part 20 limits, m
6.
~
Hydrogen and/or oxygen concentrations in the waste gas system shall be controlled to prevent explosive mixtures.
7.
Wastes shall be processed to shipping and burial ground criteria under a documented program, subject to quality assurance verification.
8.
An environmental monitoring program, including a land use census, shall be implemented.
9.
The radwaste management program shall be subject to regular audits and reviews.
- 10. Procedures for control of liquid and gaseous effluents shall be maintained and followed.
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- 11. Periodic and special reports on environmental monitoring and on releases shall be submitted.
- 12. Offsite dose calculations shall be performed using documented and approved methods consistent with NRC methodology.
In addition to NUREG-0473, as revised, the NRC staff issued guidelines,[27,28] clarifications,[29,30] branch positions,[31,323 and NUREG-0543,[333 establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS requirements. The NRC branch positions issued since the RETS implementation review began have clarified the model RETS for operating reactors.
Review criteria for the ODCM is based on the following NRC guidel ines: Branch Technical Position, " General Contents of the Offsite Dose Calculation Manual;[343 NUREG-0133;[93 and the Regulatory Guide 1.109.[35] The format for the 00CM is left to the Licensee and may be simplified by tables and grid printouts.
3.
TECHNICAL EVALUATION 3.1 General Descriotion of Radioloofcal Effluent System This section briefly describes the liquid and gaseous radwaste effluent treatment systems, release paths, and control systems installed at the Edwin I. Hatch Nuclear plants, BvRs.
7 i
_ _ _ _ _.,, _ = _ _ _ _ _,.
3.1.1 Padioactive Liouid Effluents The E. I. Hatch Nuclear Plant Units 1 and 2 are located on the Altamaha River which supplies make-up water to the Circulating Water System and receives decant from the Cooling Tower. There are.two Boiling Water Reactors on the site; each unit is served by its own Liquid Radwaste System. The two units release liquid radwaste to separate discharge lines from the Circulating Water Systems. Additional dilution flow is furnished by the Cooling Tower blowdown, Turbine Building service water, and the Plant Service Water System, if necessary. Since each unit is served by a separate dilution stream, liquid releases may be made independently from each of the two units. Releases from the Plant Service Water Systems are to the Main Condenser Circulating Flume or to the Cooling Tower Blowdown Discharge Line when needed for additional dilution. Although no significant releases of radioactivity are expected from the Plant Service Water Systems, these ef fluent pathways are monitored as a precautionary measure.
The sources of liquid radioactive effluents from Unit 1 are Waste Sample Tank A, Waste Sample Tank B, Chemical Waste Sample Tank A Chemical Waste Tank B, Floor Drain Sample Tank, Laundry Drain Tank A, Laundry Drain Tank B, and Domineralizer Feed Tank. All of these sources discharge to a common line which is served by Radiation Monitor 1011-N007. These Unit 1 sources release to a dilution stream served by flow element FE N-501, which is capable of isolating liquid radwaste dischargos from Unit 1 if pre-defined minimum dilution flow is not available in the dilution stream.
The sources of liquid radioactive effluents from Unit 2 are Waste Sample Tank A, Waste Sample Tank B, Chemical Waste Sample Tank A, Chemical Waste Sample Tank B, and Floor Drain Sample Tank. All of these sources discharge to a common line which is served by Radiation Pfonitor 2011-N007.
These Unit 2 sources release to a dilution stream served by a flow element FE N-502, which is capable of isolating liquid radwaste discharges from Unit 2 f f pre-defined minimum dilution flow is not available in the dilution stream.
I 8
Although liquid radwaste releases from the two units may proceed independently and concurrently, liquid releases are administratively controlled so that only one source per unit is released at a time. Block diagram descriptions of the systems are shown in Figures 1 and 2.
3.1.2 Radioactive Gaseous Ef fluents At Hatch plant there are four points where radioactivity is released to the atmosphere in gaseous discharges. These four release points ares (1) The main stack which serves both units; (2) Unit I reactor building vent stack; (3) Unit 2 reactor building vont stack; and (4) Unit I recombiner building vent.
The main stack serves as the discharge point for the following release sources from each units mechanical vacuum pumps, off-gas system, gland seal exhaust, and standby gas treatment system, throu0h which drywell purges are discharged. The waste gas treatment building ventilation also discharges through the main stack.
Each reactor building vent stack serves as the discharge point for the reactor building, refueling floor ventilation, turbine building, and radwaste building of each respective unit.
The Unit I recombiner building vent discharges directly to the atmosphere. A block diagram description of the radioactive gaseous release points is shown in Figure 3 and a description of the condenser offgas treatment system is shown in Figure 4 3.2 Radioloateal Ef fluent Technical Scecif feations 1
The following subsections describe the primary objectives of each section of the model RETS and summarize the commitments of the Licensee's RETS. A cross reference between the model RETS and the Licensee's RETS is contained in Tables 1 and 2.
The chronological sequence of the RETS 9
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Hatch Unit 2 Liquid Radwaste Treatment System 11
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, l Reactor Building Vent Buth Units Reactor Building Vent Refueling Floor Vent Turbine Building Vent Radwaste Building Vent a b Unit 1 Rectabiner Building i
N Mechanical Vacuum Pimp Both Units Off-Gas System Both Units a
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1 Main Stack Figure 3.
Hatch Plant Units 1 and 2 Radioactive Gaseous Effluent Release Points l
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HATCH Plant Units 1 and 2 Condenser Offgas Treatment System l
l 13 t
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c review was described in the Plant-Specific Background, Section 1.3 of this repo rt.
3.2.1 Effluent Instrumoatation The objective of the model RETS with regard to effluent instrumentation is to ensure that all significant liquid and gaseous radioactive effluents are monitored. The model RETS specify that all effluent monitors be operable with periodic surveillance and that alarm / trip setpoints be determined in order to ensure that offsite radioactive effluent concentrations do not exceed maximum permissible concentrations (MPCs) listed in 10 CFR Part 20.
- 3. 2.1.1 Radioctive Liouid Effluent Instrumentation Although each unit has unique liquid release sources, independent radwaste systems, independent liquid effluent radiation monitors, and separate dilution streams, the radiation monitor setpoint methodology is appropriate for both units.
The calculated liquid monitor setpoint values will be regarded as upper bounds for the actual setpoint adjustments. Setpoint adjustments are not required to be performed if the existing setpoint level corresponds to a lower count rate than the calculated value. The actual monitor setpoint, which corresponds to the calculated concentration plus background for the specific monitor, is determined from calibration data or from operational data associated with liquid sample analysis data. If no release is planned for a particular pathway, or if there is no detectable activity in the planned release, the monitor setpoint will be established as close to background as practical to prevent spurious alarms and yet alarm should an inadvertent release occur.
The liquid radwaste effluent line monitors provide alarm and automatic termination of release functions prior to exceeding the concentration 14
i limits specified in 10 CFR 20, Appendix B, Table II, Column 2 at the release point to the unrestricted area.
Concentration of radioactivity in the plant service water lines normally is expected to be insignificant. Therefore, the monitor setpoints will be established as close to background as practical to prevent spurious alarms and yet alarm should an inadvertent release occur.
If either of these effluent streams should become contaminated with radioactivity, radionuclide concentrations must be determined and a radiation monitor setpoint determined.
The Licensees RETS contain a commitment to perform surveillance of the monitoring instrumentation to ensure they will be operable. Therefore, the Licensee's RETS submittal on radioactive liquid effluent instrumentation meets the intent of NUREG-0473.
~3.2.1.2 Radioactive Gaseous Effluent Instrumentation Releases from the main stack, Unit I reactor building vent stack, Unit 2 reactor building vent stack, and Unit I recombiner building vent are monitored and control room alarm occurs upon a high radiation condition at the noble ' gas monitors. Each monitoring system has a gas monitor, an iodine sampler, a particulate sampler, and a sampler flow rate measuring device. Therefore, the radioactive gaseous effluent release points are monitored with adequate instrument surveillance performed.
For each unit a condenser offgas pretreatment noble gas monitor provides control room alarm upon a high radiation condition.
The Licensee's RETS submittal on radioactive gasecus effluent instrumentation meets the intent of NUREG-0473.
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3.2.1.3 Liouid and Gaseous Effluent Instrumentation Setooints The setpoints for the radioactivity monitors at each release point are estabitshed to prevent exceeding concentrations in liquid releases or corresponding dose rates for gaseous releases of 10 CFR Part 2.0,,in unrestricted areas. The setpoints for the liquid and gaseous effluent instrumentation will be determined in accordance with the 00CM.
The Licensee's RETS submittal on liquid and gaseous effluent monitoring instrumentation and their corresponding setpoints have satisfied the provisions and meets the intent of NUREG-0473.
3.2.2 Loncentration and Dose Rates of Effluents 3.2.2.1 Liouid Effluent Concentration The Licensee's RETS include a commitment to limit the concentration of radioactive liquid effluents released from the site to unrestricted areas to the concentrations specified in 10 CFR Part 20 Appendix B, Table II (Column 2) i tmits. If the concentration of liquid effluents released to unrestricted areas exceeds these limits, the concentration will be restored without delay to within limits. Batch releases are sampled and analyzed periodically in accordance with an acceptable sampling and analysis program.
Therefore, the Licensee's RETS submittal on liquid effluent concentrations meets the intent of NUREG-0473.
3.2.2.2 Gaseous Effluent Dose Rate The Licensee's RETS include a commitment to limit the gaseous dose rates from the site to within 10 CFR Part 20 limits, and if the dose rates due to gaseous effluents exceed these limits the release rate will be decreased without delay to comply with the limits.
16
C The radioactive gaseous waste sampling and analysis program provides for adequate sampling and analysis of the discharges. Therefore, the Licensee's submittal on gaseous effluent dose rates meets the intent of NUREG-0473.
3.2.3 Offsite Doses from Effluents The objectives of the model RETS with regard to offsite doses from effluents are to ensure that offsite doses are kept ALARA, are in compliance with the dose specifications of NUREG-0473, and are in accordance with 10 CFR Part 50, Appendix I and 40 CFR Part 190.
The Licensee's RETS include commitments:
(a) to limit doses to a member of the public due to liquids effluents to within the NUREG-0473 quarterly and annual dose criteria; (b) to limit noble gas air doses in unrestricted areas to within the NUREG-0473 quarterly and annual dose criteria; (c) to limit doses to any organ of a member of the public due to release of iodine-131, fodine-133, tritium, and materials in particulate form with half-lives greater than eight days to within the NUREG-0473 quarterly and annual dose criteria; and (d) to limit the annual dose or dose commitment to any member of the pubi te due to release of radioactivity and radiation from uranium fuel cycle sources to within the requirements of 40 CFR Part 190.
Therefore, the Licensee's RETS submittal on offsite doses from radioactive effluents meets the intent of NUREG-0473.
3.2.4 Effluent Treatment The objectives of the model RETS with regard to effluent treatment are to ensure that the radioactive waste treatment systems are used to keep releases ALARA and to satisfy the provisions for Technical Specifications governing the maintenance and use of radwaste treatment equipment.
17 l
-n.
The Licensee's RETS include a commitment to use the liquid radwaste treatment system when the projected quarterly doses exceed 25 percent of the annual dose design objectives for the two unit site. The projections are to be made monthly in accordance with the ODCM. The Licensee's RETS include a commitment to prepare a special report if radwaste treatment is required before release and the radwaste treatment system is inoperable.
The Licensee's RETS include a commitment to use the gaseous radwaste treatment system whenever the main condenser air ejector system is in operation.
A specification for the ventilation exhaust treatment system is not included in the submittel. Reactor building effluents from one unit are
, continuously filtered prior to discharge. Effluents from the other unit are released directly to the environment but are routed through a filter
~
upon a high radiation condition.
~5 Therefore, the Licensee's RETS submittal on effluent treatment meets the intent of NUREG-0473.
3.2.5 Tank Inventorv Limits The objectives of the model RETS with regard to a curie limit on liquid-containing tanks is to ensure that in the event of a tank rupture, the concentrations in the nearest potable water supply and the nearest surface water supply in an unrestricted area would not exceed the limits of 10 CFR Part 20, Appendix B, Table II. The objective of the model RETS with regard to a curie limit on gas-containing tanks is to ensure that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem.
18
The Licensee's RETS include a commitment to limit the quantity of radioactivity in temporary liquid radwaste storage tanks to less than or equal to 10 curies, excluding tritium and dissolved or entrained noble gases. There are no gas decay tanks at this B(R.
Therefore, the Licensee's RETS submittal on tank inventory limits meets the intent of NUREG-0473.
1 3.2.6 Exolosive Gas Mixtures The objective of the model RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in the waste gas system.
The Licensee's waste gas system is designed to withstand the effects of an explosion. The Licensee's RETS has committed to limit the 4
concentration of hydrogen in the offgas system downstream of the recombiners to i 45 by volume. The hydrogen concentration will be determined by use of one hydrogen monitor. With the hydrogen monitor inoperable gas samples are collected once per four hours and analyzed within the ensuing four hours or a temporary hydrogen analyzer will be installed downstream of the recombiner and concentration readings taken and logged every four hours.
Therefore, the Licensee's RETS submittal on explosive gas mixtures meets the intent of NUREG-0473.
3.2.7 Solid Radwaste System The objective of the model RETS with regard to the solid radwaste system is to ensure that radwar.te will be properly processed and packaged before it is shipped from the plant to the burial site to implement the requirements of 10 CFR Part 20, Section 20.301, and 10 CFR Part 71.[36]
The Licensee's RETS include a commitment to use the solid radwaste system in accordance with a Process Control Program to process wet 19
radioactive wastes to meet requirements of 10 CFR Part 20 and of 10 CFR Part 71 prior to shipment of radioactive wastes from the site.
Therefore, the Licensee's RETS submittal on solid radioactive waste meets the intent of NUREG-0473.
3.2.8 ' Radioloofcal Environmental Monitorino Prooram The objectives of the model RETS with regard to radiological environmental monitoring are to ensure that:
(a) an adequate full-area coverage environmental monitoring program exists; (b) there is an appropriate land use census; and (c) an acceptable Interlaboratory Comparison Program exists. The monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50, the land use census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50, and the requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks are performed as part of the quality assurance program for environmental monitoring to demonstrate that valid results are obtained for Section IV.B.2 of Appendix I to 10 CFR Part 50.
The Licensee's RETS for a radiological environmental monitoring program have followed in general the intent of the model RETS and the Branch Technical Position on the subject issued November 1979,[323 as l
applicable to the site, and have generally provided an adequate number of sample locations for pathways identified. The Licensee's method of sample analysis and maintenance of the monitoring program satisfies the requirements of Appendix I,10 CFR Part 50. The Licensee's RETS contain a land use census specification which requires obtaining the appropriate annual information for a BVR. The RETS also state that the Licensee will participate in an NRC-approved Interlaboratory Comparison Program.
Thus, the Licensee's RETS submittal for a radiological environmental monitoring program meets the intent of NUREG-0473.
20 t
3.2.9 Audits and Reviews The objective of the model RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring programs are properly conducted.
The Licensee's administrative structure identifies the Plant Review Board (PRB) and the Safety Review Board (SRB) as the two entities comparable to the Unit Review Group (URG) and the Company Nuclear Review and Audit Group (CNRAG), respectively.
The PRB is responsible for reviewing changes to the PCP and the ODCM and for reviewing unplanned onsite releases of radioactive material.
The SRB is responsible for auditing the radiological environmental monitoring program, the ODCM, the PCP and the performance of activities
. required by the QA program. The audits are performed at the frequency of the model RETS except for the QA audit which is performed biennially.
The Plant Review Board and the Safety Review Board encompass the total responsibility for reviews and audits specified in NUREG-0473. Therefore, the Licensee's requirements for audits and reviews meet the intent of NUREG-0473.
3.2.10 Procedures and Records The objective of the model RETS with regard to procedures is to ensure that written procedures be established, implemented, and maintained for the PCP, the ODCM and the QA program for effluent and environmental monitoring. The objective of the model RETS with regard to records is to ensure that documented records pertaining to the radiological environmental monitoring program are retained for the life of the plant.
21
The Licensco's RETS include a commitment to estabi tsh, implement, and a
maintain written procedures for the PCP, ODCM and QA programs. The Licensee's technical specifications state that records of analyses of the Radiological Environmental Monitoring Program will be retained for the duration of the unit operating license.
3 Therefore, the Licensee's RETS submittal on procedures and records meets the intent of NUREG-0473.
E I
i 3.2.11 Reoorts r
The objective of the model RETS with regard to reporting requirements is to ensure that appropriate annual and semiannual periodic reports and special reports are submitted to the NRC.
The Licensee's RETS include commitments to submit the following reports:
1.
Annual Radiolecical Environmental Surveill ance Recort The Licensee's RETS includes a commitment : hat this report will be submitted to NRC prior to May 1 of each year. The report shall include:
o Summaries, interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the reporting period, E
e Results of the land use census e
Results of the Interlaboratory Comparison Program e
1 Summary description of the radiological environmental e
monitoring program E
I 22
e Maps of all sampling locations as keyed to a table indicating distances and directions from main stack 2.
Semi-Annual Radioactive Effluent Release Reoort This report contains a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the units as outlined in Regulatory Guide 1.21, Revision 1, June 1974.
The report submitted 60 days after January 1 of each year shall include an annual summary of meteorological data collected over the previous year. This same report shall include: an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the station during the previous calendar year; an assessment of the radiation doses from liquid and gaseous effluents to members of the pubi te due to their activities inside the site boundary; a summary of solid waste shipped offsite; a summary of unplanned releases; and changes to the 00CM and PCP during the reporting period.
3.
Soecial Reoorts The Licensee's RETS include a commitment to file a special report, within 30 days of the time specified in the Technical Specifications under the following conditions:
e Exceeding the liquid effluent dose limits of Unit 1 Specification 3.15.1.2 or Unit 2 Specification 3.11.1.2 e
Exceeding the gaseous effluent dose limits of Unit 1 Specifications 3.15.2.2 or 3.15.2.3 and Unit 2 Specifications 3.11.2.2 or 3.11.2.3.
23
.~. _. -.
Exceeding the total dose.11mits of Unit 1 Specification e
i 3.15.2.5 or Unit 2 Specification 3.11.2.5.
Exceeding the reporting levels given in Table 3.16.1-2 of e
Unit 1 Specification 3.16.1 for the radioactivity measured in the environmental sampling program, i
When radioactive liquid or gaseous effluents require e
treatment before discharge according to Unit 1 Speciftettons f
3.15.1.3 or 3.15.2.4 and Unit 2 Specifications 3.11.1.3 or i
3.11.2.4. and the waste treatment equipment is in operable.
Therefore, the Licensee's RETS submittal on reports meets the intent of NUREG-0473.
3.2.12 Other Administrative Centrols
~
An objective of the model RETS in the administrative controls section is to ensure that any changes to the PCP and ODCM and major changes to the radioactive waste treatment systems are reported to the NRC.
Such changes shall be reviewed and accepted by the URG before implementation.
The Licensee's RETS state that changes to the 00CM shall become effective upon review and acceptance by the PRB. Changes to the 00CM shall be reported to the Comission in the Semi-Annual Radioactive Effluent Release Report.
Changes to the PCP shall be reported in the Semi-Annual Radioactive l
Effluent Release Report.
s The Licensee will report major changes to the radwaste treatment systems in accordance with the requirements of 10 CFR 50.59.
E 24
Therefore, the Licensee's RETS submittal for these administrative controls meets the intent of NUREG-0473.
3.3 Offsite Dose Calculation Manual As specified in NUREG-0473, the ODCM is to be developed by the Licensee to document the' methodology and approaches used to calculate offsite doses and maintain the operability of the effluent system. As a i
minimum, the 00CM should provide equations and methodology for the following topics:
e Alarm and trip setpoints for effluent instrumentation, s
e Liquid effluent concentration in unrestricted areas.
9 e
Gaseous affluent dose rate or concentrations at or beyond the
'i site boundary.
4 e
Liquid and gaseous effluent dose contributions, o
Total dose compliance, including direct shine, e
Liquid and gaseous effluent dose projections.
In addition, the ODCM should contain flow diagrams consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems. A description and the locations of samples in support of the environmental monitoring program are also needed in the 00CM.
3.3.1 Evaluation The Licensee's 00CM satisfies the equation in the addendum of NUREG-0133 to determine the alarm and trip setpoints for the liquid i
~
25
C effluent monitors. This assures that the alarm and trip actions will e
occur prior to exceeding the 10 CFR Part 20, Appendix B, Table II values at the discharge point to the unrestricted area.
The alarm and trip setpoints for the gaseous effluent monitors are calculated to assure that alarm actions will occur prior to exceeding the limits set in 10 CFR Part 20 for annual dose rates to unrestricted areas.
The Licensee uses equations similar to those contained in NUREG-0133 with the dose rate values identified in NUREG-0473.
The noble gas discharges are assured to be within the NUREG-0473 dose rate limits by correctly determining the setpoints for the noble gas monitors. The dose rate due to the release of I-131, I-133, tritium, and radionuclides in particulate form with half-lives greater than eight days is assured to be within the NUREG-0473 limit of 1500 mrem per year by calculating the dose rate to the child age group via the inhalation f
pathway. The dose rates are calculated using the highest annual average relative concentration at the site boundary for ground-level releases and the highest annual average relative concentration in the unrestricted area p
with releases from the main stack, an elevated release point.
i The Licensee's ODCM demonstrates compliance with 10 CFR Part 50, Appendix I by calculating the monthly dose commitments for liquid and gaseous effluents at least once per 31 days. The calculated cumulative values are compared to the quarterly and annual limits to demonstrate I
compl iance.
i i
Dose projections to determine use of the liquid radwaste treatment
(
system are described in the ODCM. Dose projections are not required for the ventilation exhaust treatment systems. At one unit the reactor um building effluents cannot by-pass the filter system and at the other unit the reactor building effluents are automatically routed through a filter system upon a high radiation condition.
E 26
Specific parameters of distance and the direction sector from the main stack of Unit I and additional information have been provided for the samples of Unit 1 Environmental Monitoring Table 3.16.1-1 in the Unit 1 technical specifications. The data are contained in Table 3.0-1 and in Figures 3.0-1 and 3.0-2 of the ODCM.
The Technical Specifications and the ODCM contain a simplified drawing of the liquid and gaseous release points. The 00CM contains a simp 1 tfied drawing of the liquid radwaste treatment system and the condenser offgas treatment system.
The Licensee's 00CM is generally in compliance with the NRC requirements and uses methods consistent with the methodology and guidance prescribed in NUREG-0133.
4.0 Conclusions The Licensee's proposed RETS and ODCM were reviewed, evaluated and it was concluded that:
e The Licensee's proposed RETS for Edwin I Hatch Nuclear Plant Units 1 and 2 submitted October 1,1984 meets the intent of the NRC staff's " Standard Radiological Effluent Technical Specifications for Boiling Water Reactors," NUREG-0473.
e The Licensee's ODCM submitted October 1,1984 generally uses documented and approved methods that are consistent with the methodology and guidelines in NUREG-0133.
A correspondence between (a) NUREG-0473, (b) the Licensee's current RETS, and (c) the Licensee's proposed RETS are shown in Tables 1 and 2.
27
TABLE 1.
CORRESPONDENCE OF PROVISIONS OF NUREG-0473, THE LICENSEE'S CURRENT TECHNICAL SPECIFICATIONS AND THE LICENSEE'S PROPOSAL FOR THE E. I. HATCH NUCLEAR PLANT UNIT 1.
RETS Current Technical Licensee's Recuirement NUREG-0473 Srecifications Procesal Ef fl uent 3.3.3.10 2.1.1, 2.1.2 3.14.1 Instrumentation 3.3.3.11 2.1.3, 2.1.4 3.14.2 Concentrations 3.11.1.1 2.1.1.a
,_3.15.1.1 3.11.2.1 2.1.3.a 3.15.2.1 Offsite Doses 3.11.1.2 2.1.a 3.15.1.2 3.11.2.2 2.1.c 3.15.2.2 3.11.2.3 2.1.d 3.15.2.3 3.11.4 3.15.2.5 Radwaste Treatment 3.11.1.3 2.1.1.f 3.15.1.3 3.11.2.4 2.1.3.d, 2.1.3.e 3.15.2.4 3.11.2.5 Tank Inventory 3.11.1.4 3.15.1.4 Limits Explosive Gas 3.11.2.6 2.1.3.h 3.15.2.6 Mixtures Main Condenser 3.11.2.7 2.1.3. f 3.15.2.7 Effluent Mark I or II 3.11.2.8 Containment Solid Radwaste 3.11.3 2.1.5 3.15.3.1 Environmental
-3.12.1 3.2 3.16.1 Monitoring Land Use Census 3.12.2 3.2 3.16.2 Interl aboratory 3.12.3 3.16.3 Comparisons Reviews 6.5.1 6.5.1.6 l
Audits 6.5.2 6.5.2.8 i
Procedures 6.8 6.8.1 Records 6.10 5.8.1 6.10.2 Annual Report 6.9.1.11 5.7.1.a 6.9.1.6 Semiannual Report 6.9.1.12 5.7.1.b 6.9.1.8,
' l 6.9.1.9 PCP 6.13 00CM 6.14 6.16 Radwaste Treatment 6.15 28
d TABLE 2.
CORRESPOPOENCE OF PROVISIONS OF NUREG-0473, THE LICENSEE'S CURRENT TECHNICAL SPECIFICATIONS AND THE LICENSEE'S PROPOSAL FOR THE E. I. HATCH NUCLEAR PLANT UNIT 2.
C RETS Current Technical Licensee's Reauirement NUREG-0473 Soecifications Prooosal Ef fluent 3.3.3.10 2.1.1, 2.1.2 3.3.6.9 Instrumentation.
'3.3.3.11 2.1.3, 2.1.4 3.3.6.10 Concentrations 3.11.1.1 2.1.1.a 3.11.1.1 3.11.2.1 2.1.3. a
- 3.11.2.1 Offsite Ooses 3.11.1.2 2.1.a 3.11.1.2 3.11.2.2 2.1.c 3.11.2.2 3.11.2.3 2.1.d 3.11.2.3 3.11.4 3.11.2.5 Radwaste Treatment 3.11.1.3 2.1.1.f 3.11.1.3 3.11.2.4 2.1.3.d, 2.1.3.e 3.11.2.4 3.11.2.5 Tank Inventory 3.11.1.4 3.11.1.4 Limits Explosive Gas 3.11.2.6 2.1.3. h 3.11.2.6 Mixtures 4
Main Condenser 3.11.2.7 2.1.3. f 3.11.2.7 Ef fluent Mark I or II 3.11.2.8 Containment Solid Radwaste 3.11.3 2.1.5 3.11.3.1
- Environmental 3.12.1 3.2 Monitoring Land Use Census 3.12.2 3.2 Interl aboratory 3.12.3 Comparisons Reviews 6.5.1 6.5.1.6 Audits 6.5.2 6.5.2.8 6.8.1 Procedures 6.8 Records 6.10 5.8.1 6.10.2 Annual Report 6.9.1.11 5.7.1.a 6.9.1.7 Semiannual Report 6.9.1.12 5.7.1.b 6.9.1.8 PCP 6.13 6.16
-0DCM 6.14 Radwaste Treatment 6.15 29
5.0 REFERENCES
1.
United States Nuclear Regulatory Comission, Radiolooical Effluent Technical Soecifications for Boilina Water Reactors, NUREG-0473, l
Revision 2, July 1979.
2.
United States Office of the Federal Register, Title 10, fode of i
Federal Reaulations, Part 50, Appendix I, " Numerical Guide for Design Objectives and Limiting Conditions for Operation to Meet the l
Criterion 'As Low as is Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents."
3.
United States Office of the Federal Register, Title 10, Code of Federal Reculations, Part 50, Section 50.36a, " Technical Specification on Effluents from Nuclear Power Reactors."
4.
United States Office of the Federal Register, Title 10, Code of Federal Raoulations, Part 50,Section V.B., " Effective Dates."
5.
United States Office of the Federal Register, Title 10, Code of Federal Reaulations, Part 20, " Standards for Protection Against Radiation."
6.
United States Office of the Federal Register, Title 40, Code of Federal Reaulations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations."
7.
United States Office of the Federal Register, Title 10, Code of Federal Reaulations, Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants."
8.
United States Office of the Federal Register, Title 10, Code of Federal Reaulations, Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
9.
United States Nuclear Regulatory Comission, Preparation of Radioloofcal Effluent Technical Soecifications for Nuclear Power ElAD.t.1, NUREG-0133, October 1978.
10.
C. A. Willis and F. J. Congel, "Sumary of Draft Contractor Guidance of RETS," AIF Environmental Subcomittee Meetina. Washinoton D.C.,
May 19, 1982.
11.
F. J. Congel, Memo to RAB Staff (NRC), Interim Chances in the Model E, August 9,1982.
- 12. United States Nuclear Regulatory Comission, Standard Radiolooical Effluent Technical Soecifications for Boilina Water Reactors, NUREG-0473, Revision 3, Draft 7, September 1982.
30
- 13. Letter from W. Serrano, EG&G, to C. A. Willis, NRC,
Subject:
TRANSMITTAL OF QUESTIONS FOR HATCH RETS REVIEW - Serr-1-82, February 11, 1982.
14 Letter fron D. W. Akers, EG&G, to C. A. Willis, NRC,
Subject:
TRANSMITTAL OF QUESTIONS FOR THE HATCH 1 AND 2 RETS REVIEW -
DWA-11-82,' November 23, 1982.
- 15. Letter from W. Serrano, EG&G, to C. A. Willis, NRC,
Subject:
UNRESOLVED ITEMS FROM HATCH RETS REVIEW - Serr-9-83, April 4,1983.
16.
Letter from R. D. Baker, Georgia Power Company, to C. A. Willis, NRC,
Subject:
DRAFT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS SUBMITTAL, NED-83-426, September 1,1983.
- 17. Letter from W. Serrano, EG&G, to C. L. Miller, NRC,
Subject:
REVIEW OF HATCH 1 A!O 2 DRAFT RETS - Serr-26-83, October 19, 1983.
18 Letter from L. T. Gucwa, Georgia Power Company, to J. F. Stolz, NRC,
Subject:
RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS SUBMITTAL, NED-83-509, October 17, 1983.
'19.
Letter from W. Serrano, EGSG, to C. L. Miller, NRC,
Subject:
REVIEW 0F 10-6-83 HATCH RETS - Serr-33-83, December 14, 1983.
20.
Letter from J. T. Beckham, Jr., Georgia Power Company, to J. F.
Stolz, NRC,
Subject:
RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS SUBMITTAL, NED-84-307, August 1, 1984
- 21. Correspondence from C. L. Miller, NRC, to W. Serrano, EG&G Idaho, Resolution of RETS Issues for HATCH Plant Units 1 and 2, September 6, 1984 22.
Letter from L. T. Gucwa, Georgia Power Company, to J. F. Stolz, NRC,
Subject:
RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS SUBMIlTAL, NED-84-489, October 1, 1984
- 23. Letter from D. W. Akers, EG&G, to C. L. Miller, NRC, Subjects TRANSMITTAL OF QUESTIONS FOR THE HATCH 1 Af0 2 00CM REVIEW -
DWA-12-82, December 10, 1982.
24.
Letter from W. Serrano, EG&G, to C. L. Miller, NRC,
Subject:
REVIEW OF JULY 1983 HATCH DRAFT ODCM - Serr-30-83, November 17, 1983.
- 25. Letter from L. T. Gucwa, Georgia Power Company, to J. F. Stolz, NRC,
Subject:
OFFSITE DOSE CALCULATION MANUAL AND PROCESS CONTROL PROGRAM i
SUBMITTAL, NED-84-488, October 1, 1984
- 26. United States Office of Federal Register, Title 10, Code of Federal Reaulations, Part 20, Appendix B, Concentrations in Air and Water Above Natural Background.
E 31 i
l l
l
- 27. Letter from C. A. Willis, NRC, to F. B. Simpson, EG&G,
Subject:
SUMMARY
OF CHANGES TO RETS REQUIREMENTS FOLLOWING MEETING WITH ATOMIC INDUSTRIAL FORUM, November 20, 1981.
- 28. Memorandum from W. E. Kreger, NRC, to R. J. Mattson, NRC,
Subject:
PLANS FOR DEALING WITH THE EXPLOSIVE GAS ISSUE IN IMPLEMENTING THE RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS), December 14, 1981.
29.
C. A. Willis and F. J. Congel, " Status of NRC Radiological Effluent Technical Specification Activities," Atomic Industrial Forum Conference on HEPA and Nuclear Reaulations, October 4-7, 1981.
- 30. Memorandum from C. A. Willis, NRC, to P. C. Wagner, NRC,
Subject:
PLANS FORDWLEMENTING RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS FOR OPERATING REACTORS, November 4,1981.
- 31. Memorandum from W. P. Garmill, NRC, to P. C. Wagner, NRC,
Subject:
CURRENT POSITION ON RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) INCLUDING EXPLOSIVE GAS CONTROLS, October 7,1981.
32.
United States Nuclear Regulatory Commission, Radiological Assessment Branch Technical Position, An Accootable Radioloafcal Environmental Monitorina Proaram, November 1979.
- 33. United States Nuclear Regulatory Commission, Methods for Demonstratina LWR Comoliance with the EPA Uranium Fuel Cvele Standard (40 CFR Part 190), NUREG-0543, February 1980.
34 United States Nuclear Regulatory Commission, Branch Technical Position, General Contents of the Offsite Dose Calculation Manual, Revision 1, February 8,1979.
3S. Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part S0, Appendix I," Revision 1, U.S. Nuclear Regulatory Commission, Washington, D. C.
20S55, October 1977.
36.
United States Office of the Federal Register, Title 10, Code of Federal Reaulations, Part 71, " Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions."
32
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IMPLEMENTATION - EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 l
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November 1984
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A review of the Radiological Effluent Technical Specifications (RETS) for the Edwin I. Hatch Nuclear Plant Units 1 and 2 was performed.
The principal review guidelines used were NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," and Draft 7 of NUREG-0473, Revision 3,
" Standard Radiological Effluent Technical Specifications for Boiling Water Reactors."
Draft submittals were discussed with the Licensee by both EG&G and the NRC staff until all items requiring changes to the Technical Specifications were resolved. The Licensee then submitted final proposed RETS to the NRC which were evaluated and found to be in compliance with the NRC review guidelines. The proposed Offsite Dose Calculation Manual was reviewed and generally found to be in compliance with the NRC review guidelines.
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