ML20127E196

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Revs to Selected Licensee Commitments Manual
ML20127E196
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 01/07/1993
From: Nicholson K
DUKE POWER CO.
To:
References
PROC-930107, NUDOCS 9301190198
Download: ML20127E196 (13)


Text

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' 4 V+ conwrd RJ kit s c :9fn DUKEPOWER January 07, 1993 RE: Catawba Nuclear Station Selected Licenseo Commitments Effective 01/01/93 Attached are revisions to the Catawba Nuclear Station Selected Licensco Commitments. Please reviso your copy as follows:

itemovo Insort LOEP Pago 1 (12/29/92) Page 1 (01/01/93)

Pago 4 (12/21/92) Pago 4 (01/01/93)

Pago 5 (12/21/92) Pago 5 (01/01/93)

( Pago 6 (12/92) Pago 6 (01/01/93)

Chaptor 16.11 Pago 16.11-1 Page 16.11-1 (01/01/93)

Pago 16.11-1.1 (01/01/93)

Page 16.11-2 Page 16.11-2 (01/01/93)

Page 16.11-17 Page 16.11-17 (01/01/93)

Page 16.11-18 Pago 16.11-18 (01/01/93)

Page 16.11-21 Page 16.11-21 (01/01/93)

Pago 16.11-21.1(01/01/93)

Pago 16.11-44 Page 16.11-44 (01/01/93)

Any questions concerning this revision should be directed to the undersigned at 803-831-3237.

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Kay d. Nicholson llogulatory comp 11anco Attachments i ra.c. m 9301190190 930107 PDR ADOCK 05000413 P PDR o*

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DUKE POWER COMPANY SELECTED LICENSEE COMMITMENTS MANUAL List of Effective Pages Page Revision Date LOEP 1 12/29/92 LOEP 2 12/29/92  !

LOEP 3 12/29/92 LOEP 4 01/01/93 LOEP 5 01/01/93 LOEP 6 01/01/93 LOEP 7 12/92 Tab 16.0 16.0-1 12/90 Tab 16.1 16.1-1 Tab 16.2 16.2-1 11/91 {

16.2-2 11/91 16.2-3 11/91 Tab 16.3 16.3-1 11/91 16.3-2 11/91 Table 16.3-1 11/91 Tab 16.4 l

Page 1 01/01/93 J-.~. ._-.._i,,,._..... .,--, e r ..i_.-,,..---,---,e._-, - - - - , _ . . . . ,.r-m . - . _,.._.-e,_e_ -- ,.

DUKE POWER COMPANY ,

SELECTED LICENSEE COMMITHENTS MANUAL List of Effective Pages Page Revision Date Tab 16.11 16.11-1 01/01/93 16.11-1.1 01/01/93 16.11-2 01/01/93 16.11-3 16.11-4 16.11-5 16.11-6 .

16.11-7 16.11-8 12/21/92 16.11-9 i 16.11-10 12/21/92 16.11-11 12/21/92 16.11-12 16.11-13 16.11-14 16.11-15 16.11-16 16.11-17 01/01/93 16.11-18 01/01/93 16.11 16.11-20 16.11-21 01/01/93' Page 4 01/01/93 l

e-u,- 2e s DUKE POWER COMPANY SELECTED LICENSEE COMMITMENTS MANUAL List of Effective Pages Page Revision Date 16.11-21.1 01/01/93 16.11-22 16.11-23 16.11-24 16.11-25 16.11-26 16.11-27 16.11-28 12/21/92 16.11-29 16.11-30 12/21/92 16.11-31 12/21/92 16.11-32 12/21/92 16.11-33 16.11-34 16.11-35 16.11-36 16.11-37

' 16.11-38 16.11-39

. 16.11-40

16.11-41 16.-11 16.11-43 Page 5 01/01/93

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DUKE POWER COMPANY SELECTED LICENSEE COMMITMENTS MANUAL I

List of Effective Pages I

Page Revision Date i

16.11-44 01/01/93  !

16.11-45 16.11-46 16.11-47 16.11-48 16.11-49 16.11-50 16.11-51

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16.11-52 16.11-53 16.11-54 16.11-55 16.11-56 16.11-57 16.11-58 16.11-59 16.11-60 16.11-61 16.11-62 ~

16.11-63 16.11-64--

1 Tab-16,12 Page 6 01/01/93

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16.11 RADIOLOGICAL EFFLUENTS CONTROLS-O RADI0 ACTIVE EFFLUENTS 16.11-1 LIQUID EFFLUENTS CONCENTRATION COMMITMEN' The concentratici, of radioactive material released in liquid effluents to UNRESTRICTED AREA!. (see Figure 16.11-1) shall be limited .to ten times the effluent concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 fe radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to_1 x 10 ' microcurie /ml total activity.

APPLICABILITY: At all-times.

REMEDIAL ACTION: ,

With the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, immediately restore the con-centration to within the above limits.

TESTING REQUIREMENTS:

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Radioactive liquid wastes shall be sampled and analyzed acccrding to.the sampling and analysis program of Table 16.11-1.

The results of the radioactivity analyses'shall b9 used in accordance with the -

methodology.and parameters in the_00CM to~ assure that the concentrations at the point of releap aro maintained within the limite of SLC-15.11-1.

REFERENCES:

1. Catawba Offsite Dose Calculation Manual
2. 10 CFR Part 20, Appendix B-BASES:

The basic requirements for Selected Licensee Commitments concerning effluents-

. from nuclear pocer reactors are stated in.10 CFR 50.36a. These requirements

-indicate _that compliance with effluent Selected Licensee Commitments will-keep average annual releases of radioactive material in ef fluents to small percentageslof'the limits specified-in the old-10 CFR 20.106_(new 10 CFR 20.1302). These. requirements further-indicate that operational' flexibility is allowed, compatible with cor iderations of-health and safety, which'may t

temporarily result in releases 1 higher than such.small percentages, but still within the limits ~specified'in the old 10 CFR 20.106 which references Appendix B, Table Il concentrations (MPCs). These referenced. concentrations are ,

specific values' 16.11-1 01/01/P.i

p which relate to an annual dose of 500 mrem. It is further indicated in 10 CFR Q 50.36a that when using operational flexibility, best ef forts shall be exerted to' keep levels of radioactive materials in effluents as low as is reasonably ,,

achievable (ALARA) as set forth in 10 CFR 50, Appendix 1.

As stated in the Introduction to Appendix B of the new 10 CFR 20, the liquid effluent concentration (EC) limits given in Appendix B, Table 2, Column 2, are based on an annual dose of 50 mrem. Since a release concentration corresponding to a limiting dose rate of 500 mrem / year has been acceptable as a SLC limit for liquid effluents, which applies at all times as an assurance that the limit; of 10 CFR 50, Appendix 1 are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of 10.

Operational history at Catawba has demonstrated that the use of the concentration values associateJ with the old 10 CFR 20.106 as SLC limits has -

resulted in calculated maximum individual doses to a MEMBER OF THE PUBLIC that are small percentages of the limits of 10 CFR 50, Appendix 1. Therefore, the use of concentration values which correspond to an annual dose of 500 mrem (ten times the concentration values stated in the new 10 CFR 20, Appendix B, Table 2, Column 2) should not have a negative impact on the ability to antinue to operate within the limits of 10 CFR 50, Appendix I and 40 CFR 190.

Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations. As discussed above, the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 2, relate to a dose of 50 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem / year. This h

V low value is impractical upon which to base effluent monitor setpoint calculations for many liquid effluent release situations when monitor

- background, monitor sensitivity, and monitor performance must be taken into account.

Therefore, to accommodate operational flexibility needed for ef fluent releases, the limits associated with SLC 16.11-1 are based on ten times the ,

concentrations stated in the new 10 CFR20, Appendix B Table 2, Column 2, to apply at all times. The multiplier of ten is proposed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix B, Table II, Column 2, are based, is a factor of 10 higher than the annual dose of 50 mrem, upon which the concentrations in the new 10 CFR 20, Appendix B, Table 2, Column 2, are based. Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controllina radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described in 'nternational Commission '

on Radiological Protection (ICRP) publication 2.

This commitment applies to the release of radioactive materials in liquid effluent from all units at the site.

The reautred detection capabilities for radioactive materials in liquid waste samples are tabulated in terms of the lower limits of detection (LLDs),

Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-3_00 (revised annually), Currie, L. A. , " Limits 16.11-1.1 01/01/93

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h' for Qualitative Detection and Quantitat.ive Determination _- Application to -

Radiochemistry," Annal, Chem.~ 40, 586-93 (1968), and Hartwell, J, K. ,

" Detection 1.lmits for Radioanalytical Counting Techniques,!' Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). l 1

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l 16.11 RADIOLOGICAL EFFLUENT CONTROLS--

_O RADI0 ACTIVE EFFLUENTS 16.11-5 CHEMICAL TREATMENT PONOS

_ COMMITMENT The quantity of radioactive material contained in each chemical treatment pond shall be limited by the following expression:

A 26J .

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V j(C)x<10)'0 excluding tritium and dissolved or entrained noble gases, Where:

A) = pond inventory limit for single radionuclide "j", in Curies; C

3 = radionuclide "j", microCuries/ml;10 CFR 20, Apnendix B, Table 2, Columnl' 2, co V = design volume of liquid and slurry in the pond, in gallons; and 264 = ccnversion unit, microCuries/ Curie per milliliter / gallon.

-APPLICABILITY: At all times.

R_E}LEDIAL ACTION:

With the quantity of radioactive material in any of the above listed ponds exceeding the above limit, immediately suspend all additions of radioactive material to the pond and initiate corrective action.to-reduce the_ pond contents to within the limit.

1 TESTING REQUIREMENJS:

The quantity of radioactive material contained in each batch of_ resin / water slurry to be_ transferred to the chemical treatment ponds shall-be determined

-to_be within-the ab_ove-limit by analyzing a representative sample of the' batch

'to be' transferred to the chemical treatment' ponds'and_shall be limited by-the expression:

l I b < 0.006 J.(C J x 10)-

Where:

c) = radioactive restn'/ water slurry concen m for radionuclide '".i" 16.'11-17 01/01/93

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E entering the UNRESTRICTED AREA chemical treatment ponds, in microcuries/ milliliter; and, C

3 = radionuclide "j", in microCuries/ milliliter.10 CFR 20, Appendix 8, Table 2, Column l. 2, conce

REFERENCES:

1. Catawba Offsite Dose Calculation Manual.
2. 10 CFR Part 20, Appendix B 3, 10 CFR Part 50, Appendix I BASES:

The inventory limits of the chemical treatment ponds (CTP) are based on -

limiting the consequences of an uncontrolled release of the pond inventory.

The expression in this commitment assumes the pond inventory is uniformly mixed, that the pond is located in an uncontrolled area as defined in 10 CFR Part 20, and that the_ concentration limit in Note 1 to Appendix B of 10 CFR Part 20 applies.

The batch limits of resin / water slurry transferred to the CTP assure that _

radioactive material transferred to the CTP are "as low is reasonably achievable" in accordance with-10 CFR 50.36a. The expression in SLC.16.11-6 assures no batch will be transferred to the CTP unless.the sum of the ratios of the activity of the radionuclides to their respective concentration

,* limitation is less than the ratto of the 10 CFR Part 50 Appendix I, Section II.A total body dose level to the instantaneous whole body dose rate-limitation, or that: '[

3 mrem /yr t _1 g ) x 10)< 500 mrem /yr = 0.006 C

(

Where:

c) = radioactive resin / water slurry concentration for radionuclide "j" -

entering the UNRESTRICTED AREA CTP, in microcuries/ milliliter; -and, C) =.10 CFR Part 20, Appendix B, Table 2, Column 2, concentration -l for single radionuclide "j", 'in- microCuries/ milliliter.

The filter /demineralizers using powdered resin ar.d the blowdown demineralizeri are backwashed-or sluiced to a holding tank. The tank will be agitated to obtain a-representative sample of the resin inventory in the tank. A_'_ known weight of the wet,_ drained resin (moisture content approximately 55 to 60L

- bulk density of about 58 pounds.per cubic foot) will then be. counted. The.

concentration'of the resin slurry to be pumped-to the chemical treatment ponds-will then be determined by the formula:

O 16.11 01/01/93

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BASES:

I I The basic requirements for Selected Licensee Commitments concerning offluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent Selected Licensee Commitments will keep average annual releases of radioactive material in effluents to small percentages of the limits specified in the old 10 CFR 20.106 (new 10 CFR 20.1301). These requirements further indicate that operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10 CFR 20.106 which references Appendix B, Table II concentrations (MPCs). These referenced concentrations are specific values which relate to an annual dose of 500 mrems. It is further indicated in 10 CFR 50.36a that when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix I.

As stated in the Introduction to Appendix B of the new 10 CFR 20, the gaseous effluent concentration (EC) limits given in Appendix B, Table 2, Column 1, are based on an annual dose of 50 mrems for isotopes for which inhalation or ingestion is limiting or 100 mrems for isotopes for which submersion (noble gases) is limiting. Since release concentrations corresponding to limiting

,_ dose rates less than or equal to 500 mrems/ year to the whole

(

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) body, 3000 mroms/ year to the skin from noble gases, and 1500 mrems/ year to any organ from Iodine-131, Iodine-133, tritium and all radionuclides in particulate form with half-lives greater than eight days at the site boundary has been acceptable as a SLC limit for gaseous effluents to assure that the limits of 10 CFR 50, Appendix I and 40 CFR 190 are not likely to be exceeded, it should not be necessary to restrict the operational flexibility by incorporating the dose rate associated with the EC value for isotopes based on inhalation / ingestion (50 mrems/ year) or the dose rate associated with the EC value for isotopes based on submersion (100 mrems/ year).

Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations. As discussed above, the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 1, relate to a dose of 50 or 100 mrems in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100 mrems/ year. These low values are impractical upon which to base effluent monitor setpoint calculations for many gaseous effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account.

Therefore, to accommodate operational flexibility needed for effluent releases, the limits associated with gaseous release rate SLCs will be maintained at the current instantaneous dose 16.11-21

, 01/01/93

rate limit for noble gases of 500 mrems/ year to the whole body

_- /' and 3000 mrems/ year to the skin; and for Iodine-131, for Iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days, an instantaneous dose rate limit-of 1500 mrems/ year to any organ.

Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Operational history at Catawba has demonstrated that the use of the dose rate values listed above (i.e., 500 mrems/ year, 3000 mrems/ year, and 1500 mrems/ year) as SLC limits has resulted in calculated maximum individual doses to MEMBERS OF THE PUBLIC that are small percentages of the limits of 10 CFR 50, Appendix I and 40 CFR 190. For MEMBERS OF THE PUBLIC who may at times be within the SITE BOUNDARY, the occupancy of. _

that MEMBER OF THE PUBLIC will usually be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the SITE BOUNDARY. Examples of calculations for such MEMBERS OF THE PUBLIC, with the appropriate occupancy factors, shall be given in the ODCM. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem / year to the whole body or to less than or equal to 3000 mrem / year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background to a child via the inhalation pathway to less-than or equal to 1500 mrem / year.

This commitment applies to the release of radioactive materials in gaseous effluents from all units at the site.

The required detection capabilities for radioactive material in gaseous waste samples are tabulated in terms of the lower-limits of detection (LLDs). Detailed discussion of the LLD, and other detection limits can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, 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).

O 16.I1-21.1 01/01/93

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REFERENCES:

1. Catawba Offsite Dose Calculation Manual.
2. 10 CFR Part 20
3. 40 CFR Part 190 BASES: -

This commitment is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Part 20 by 46 FR 18525. The commitment requires the preparation and submittal of a Special Report'whenever the calculated doses due to releases of radioactivity and to radiation.from uranium fuel cycle sources exceed 25 mrem to the whole body or any-organ, except the thyroid,'which shall be limited to less than or equal to 75 mrem.

For sites containing up to four reactors, it is highly unlikely that the resultant dose to a MEMBER OF .THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the individual reactors remain within twice the dose design objectives of Appendix I, and_if direct radiation doses from the units and from outside storage tanks are kept small. 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 40 CFR Part 190 limits. For the purposes of the Special Report, it may be assumed that the dose. commitment to the ..

MEMBER OF THE PUBLIC from other uranium fuel cycle sources isl negligible, with the exception-that dose contributions from other nuclear fuel cycle facilities

-L(_m) at the same site or within a radius of 8-km must be considered. If the= dose si to any MEMBER OF THE PUBLIC is. estimated to exceed the requirements of 40 CFR Part 190, the Special Report with a request for a variance (provided the release conditions resulting-in violation of 40 CFR Part=190 have not already been corrected), in accordance with the' provisions of 40 CFR 190.11-and-10 CFR 20.2203(a)(4), is considered to be a timely request and fulfills the requirements of_40 CFR _Part 190 untti NRC_ staf f action is completed. The variance only relates to the' limits of 40 CFR Part 190, and does not_ apply in any way to the other requirements for dose limitation _ of _10-CFR Part 20, as addressed'in SLC 16.31-1-and 16.11-6. An individual _is not considered a-MEMBER _0F THE PUBLIC during any_ period in which he/she is engaged in carrying.

out any operation that is part of the nuclear fuel cycle, i

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