ML20132A855

Radiological Effluent Tech Spec Implementation (A-2), Technical Evaluation Rept

ML20132A855
Person / Time
Site:	Millstone
Issue date:	07/23/1985
From:	Carfagno S, Pandey S Calspan Corp, Franklin Research Ctr
To:	Congel F, Willis C Office of Nuclear Reactor Regulation
Shared Package
ML20132A847	List: ML20132A841 ML20132A849 ML20132A855
References
CON-NRC-03-81-130, TAC 49588, TAC 8116 TER-C5506-99-01, NUDOCS 8509260038
Download: ML20132A855 (28)

Text

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TECHNICAL ENALUATION REPORT a

NRC DOCKET NO. 50-336 FRC PROJECTC5506 NRC TAC NO. 8116 FRC ASSIGNMENT 4 NRC CONTRACT NO. NRC-03-81-130 FRC TASK 99 7

RADIOLOGICAL EFFLUENT TECHNICAL j

SPECIFICATION IMPLEMENTATION (A-2)

NORTHEAST NUCIJ.AR ENERGY COMPANY MILLSTONE POINT NUCLEAR POWER STATION UNIT 2 1

TER-C5506-99 I

1 Prepared for y

Nuclear Regulatory Commission FRC Group Leader:

S. Pandey j

Washington, D.C. 20555 NRC Lead Engineer:

F. Congel C. Willis i

sa July 23,1985 7_-

.i This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or 7

responsibility for any third party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its us9 by such third party would not infringe privately owned rights.

Prepared by:

Reviewed by:

Approved by:

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Principal Attr(or Group Leader' Tepartmer Irepr

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312/ff Date:

7/22/ 5 Date:

Date:

>23M FRANKLIN RESEARCH CENTER DIVISION OF ARVIN/ CALM g

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e-CONTENTS i

f Section Title Page 1

INTRODUCTION 1

1.1 Purpose of Review.

1 1.2 Generic Background.

1 1.3 Plant-Specific Background.

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2 REVIEW CRITERIA.

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3 3

TECHNICAL EVALUATION 1

7 3.1 General Description of Radiological Effluent Systems 7

1 3.2 J

Radiological Effluent Technical Specifications.

10 3.3 Offaite Dose Calculation Manual 17 4

CONCLUSIONS.

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j 1 Liquid Radwaste Treatment Systems, Effluent Paths, and l

l Controls, Millstone Point Nuclear Power Station Unit 2.

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2 Gaseous Radwaste Treatment Systems, Effluent Paths, and

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Controls, Millstone Point Nuclear Power Station Unit 2.

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1 Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Millstone Point Nuclear Power Station Unit 2.

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I This Technical Evaluation Report was prepared by Franklin Research Center g

under a contract with the U.S. Nuclear Regulatory Comunission (Office of i

Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by G

the NRC.

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1.

INTRODUCTION c

w 1.1 PURPOSE OF REVIEW s

The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Millstone Point Nuclear Power Station Unit 2 with regard to Radiological Effluent a

Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM).

The evaluation uses criteria proposed by the NRC staff in the Model Technical Specifications for pressurized water reactors (PWRs), NUREG-0472 [1].

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This effort is directed toward the NRC objective of implementing RETS which comply principally with the regulatory requirements of the Code of Federal j

Regulations, Title 10, Part 50 (10CFR50), " Domestic Licensing of Production I

and Utilization Facilitie*," Appendix I [2]. Other regulations pertinent to

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the control of effluent releases are also included within the scope of compliance.

1.2 GENERIC BACKGROUND Since 1970, 10CFR50, Section 50.36a, " Technical Specifications on Effluents from Nuclear Power Reactors," has requi ed licensees to provide technical specifications which ensure that radioactive releases will be kept as low as reasonably achievable (ALARA).

In 1975, numerical guidance for the p

ALARA requirement was issued in 10CFR50, Appendix I.

The licensees of all operating reactors were required [3] to submIit, no later than June 4, 1976, their proposed ALARA Technical Specifications and information for evaluation in accordance with 10CFR50, Appendix I.

However, in Februar~y 1976, the NRC staff recommended that proposals to modify Technical Specifications be deferre,d until the NRC completed the model PETS. The model RETS deals with radioactive waste management systems and environmental monitoring. Although the model RETS closely parallels 10CFR50,

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Appendix I requirements, it also includes provisions for addressing other

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issues.

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TER-C5506-99 These other issues are specifical1y stipulated by the following regulations:

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o 10CFR20 [4), " Standards for Protection Against Radiation," Paragraphs 20.105(c), 20.106(g), and 20.405(c) require that nuclear power plants and other licensees comply with 40CFR190 [5], " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40CFR190 limits have been or may be exceeded.

10CFR50, Appendix A [6], " General Design Criteria for Nuclear Power o

Plants," contains Criterion 60 - Control of releases of radioactive materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and criterion 64 - Monitoring radioactivity releases.

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o 10CFR50, Appendix B [7), establishes the quality assurance required for nuclear power plants.

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The NRC position on the model RETS was established in May 1978 when the NBC's Regulatory Requirements Review Committee approved the model RETS:

NUREG-0472 [1] for pressurized water reactors (PWRs) and NUREG-0473 [8]'for boiling water reactors (BWRs). Copies were sent to licensees in July 1978

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with a request to submit proposed site-specific RETS on a staggered schedule d

over a 6-month period. Licensees responded with requests for clarifications y

and extensions.

1 The Atomic Industrial Forum (AIF) formed a task force to comment on the t

model RETS. NRC staff members first met with the AIF task force on June 17, 1978. The model RETS was subsequently revised to reflect comments from the

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AIF and others. A principal change was the transfer of much of the material i

concerning dose calculations from the model RETS to a separate ODCM.

The revised model RETS was sent to licensees on November 15 and 16, 1978 I

with guidance (NUREG-0133 [9]) for preparation of the RETS and the ODCM and a new schedule for responses, again staggered over a 6-month period.

e Four regional seminars on the RETS were conducted by the NRC staff during j

November and December 1978. Subsequently,' Revision 2 of the model RETS and i

additional guidance on the ODCM and the PCP were issued in February-1979 to each utility at individual meetings.

In response to the NRC's request, operating reactor licensees have subsequently submitted initial proposals on i

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plant RETS and the ODCM. Review leading to ultimate implementation,of these documents was initiated by the NRC in 1981 using subcontracted independent i

l teams as reviewers.

As the RETS review process has progressed since September 1981, feedback I

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from the licensees has led the NRC to believe that modification to some of the I

guidelines in the current version of Revision 2 is needed to clarify specific concerns of the licensees and thus expedite the entire review process.

St'arting in April 1982, NRC distributed revised versions of RETS in draft form to the licensees during the site visits.

The.new guidance on these changes was presented in the AIF meeting on May 19, 1982 (10]. Some interim changes i

regarding the Radiological Environmental Monitoring Section were issued in i

1982 [11). With the incorporation of these new changes, NRC issued, in l

September 1982, a draft version of NUREG-0472, Revision 3 [12], to serve as I

new guidance for the review teams.

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1.3 PLANT-SPECIFIC BACKGROUND I

In response to the NRC's request, the Licensee submitted a RETS proposal

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. September 19, 1979. This proposal also included a submittal of the ODCM'

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[14]. In the RETS submittal, the Licensee generally followed the model RETS t

format (NUREG-0472) for PWRs.

Initial review of the Licensee's' submittal was

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performed in October 1981 by an independent review team at Franklin Research l

. Center (FRC). The Licensee's submittal was costpared with the model RETS and i

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assessed for compliance with the requirements as stipulated.

f copies of the draft review, dated October 30,1981 [15),.were delivered l

to the NRC and the Licensee prior to a site visit by the independent review T

1 team.

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The site visit was conducted on Novendier 12-13, 1981 by the reviewers

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4 with the participation of plant personnel and the NRC staff. Discussion focused on.the initial review of the proposed changes to the RETS and on the technical approaches for an ODCN. The technical deficiencies in the j

Licensee's proposed RETS were considered, and deviations from NRC guidelines

.were pointed out. Upon conclusion of this. meeting, many of the differences l

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i TER-C5506-99 were clarified and resolved; only a few items remained open, pending justification from the Licensee. Thesemajorissuesaresummarized[in Reference 14 Under a cover letter dated May 29, 1985 [17], Northeast Nuclear Energy Company delivered its final submittals on RETS and ODCM* to the NRC.

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of these submittals were transmitted to FRC for review. The Licensee's RETS submittal was evaluated against NUREG-0472, Draft Revision 3 [12]. The ODCM was evaluated according to the existing guidelines specified by NUREG-0133

[9].

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The review also incorporated the additional guidance that FRC received from the NRC staff on plant-specific issues (18].

Details of the RETS review were documented in the comparison copy (19].

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• The Licensee's submittal contains, in separate attachments, the proposed Radiological Effluent Technical Specifications and the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM). The REMODCM con-sists of two parts: Section I, the Radiological Effluent Monitoring Manual, and Section II, the Offsite Dose calculation Manual (ODCM).Section I con-tains the effluent sampling program, radiological environmental monitoring program, and report contents, which are part of the standard RETS. Thus, the RETS referred to hereafter in this rep 6rt would consist of the proposed

" Millstone Nuclear Power Station Unit 2 Radiological Effluent Technical Specifications" and Section I of the REMODCM, whereas the ODCM refers to Section II of the REMODCM.

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REVIEW CRITERIA g.

Review criteria for the RETS and ODCM were provided by the NRC in three documents:

L NUREG-0472, RETS for PWRs I

NUREG-0473, RETS for BWRs NUREG-0133, Preparation of RETS for Nuclear Power Plants.

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Twelve essential criteria are given for the RETS and ODCM l

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All significant releases of radioactivity shall be controlled and j

j monitored."

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Offsite concentrations of radioactivity shall not exceed the L;

10CFR20, Appendix B, Table II limits.

3.

Offsite radiation doses of radioactivity shall be ALARA.

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Equipment shall be maintained and used to keep offsite doses ALARA.

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Radwaste tank inventories shall be limited so that failures will not

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Hydrogen and/or oxygen concentration in the waste gas system shall

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be controlled to prevent explosive mixtures.

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Wastes shall be processed to shipping and burial ground criteria 1

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under a documented program, subject to quality assurance W

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An environmental monitoring program, including a land-use census and an interlaboratory costperison prog' ram,.shall be implemented.

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The radwaste management program shall be subject to regular audits

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and reviews.

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Procedures for, control of liquid and gaseous effluents shall be l

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Periodic and special reports on innvironmental monitoring and on releases shall be submitted.

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offsite dose calculations shall be performed using documented and l

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. approved methods consistent.with NBC methodology.

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TER-C5506-99 Subsequent to the publication of NUREG-0472 and NUREG-0473, the NRC staff issued guidelines [20, 21], clarifications [22, 23], and branch po(itions [24, 25, 26, 27] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter of the model RETS provisions.

The NBC branch positions issued since the RETS implementation review began

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have clarified the model RETS implementation for operating reactors.

Review of the ODCM was based on the following NRC guidelines:

Branch Technical Position, " General Content of the Offolte Dose Calculation Manual"

[28]; NUREG-0133 [9); and Regulatory Guide 1.109 (29]. The ODCM format is left to the licensee and may be simplified by tables and grid printouts.

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TECHNICAL EVALUATION c-3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSTEMS This section briefly describes the liquid and gaseous radwaste effluent systems, release paths, and control systems installed at Millstone Point Nuclear Power Station Unit 2, a PWR.

The station site is located at Millstone Point in the town of'Waterford, Connecticut, on the north shore of the Long Island Sound and on-the east side of Niantic Bay.

The Unit 2 reactor is also located immediately to the north of Unit 1, a BWR.

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3.1.1 Radioactive Liquid Effluent 7

j The liquid radwaste system of Millstone Point Nuclear Power Station Unit 2 consists mainly of the clean liquid waste system and the aerated liquid I

waste system, as shown in Figure 1.

The clean liquid wastes are held up in A

the primary drain tank until processing.

Processing of these wastes consists

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of either one or a combination of holdup for natural decay, filtration, and E

ion exchange. Aerated liquid wastes are collected in drain tanks prior to processing.

Processing of aerated liquid wastes consists of holdup of natural 3

decay and evaporation. These waste effluents are merged into the circulation water for release through the discharge canal.

Also discharged into the circulation water are effluents from the

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3 condensate polishing waste neutralization, steam generator blowdown, turbine building floor drain, and service water.

3.1.2 Radioactive Gaseous Effluent The waste gases from'the Millstone Point Nuclear Power Station Unit 2 are collected and processed by holdup by natural decay and filtration. Following processing, the effluents are discharged to the environment through the Unit 1 stack (375 feet high). Also routed to the Unit I stack for release dre the; main condenser air ejector and containment purge affluents (see Figure 2).

Other gaseous effluents, such as from the auxiliary building, turbine building, and steam generator blowdown, are routed to the Unit 2 roof vent for l

' release.

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Liquid Radwaste Treatment Systems, Effluent Paths, and Controls, Millstone Point Nuclear Power Station Unit 2 e

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Gaseous Radwaste Treatment Systems, Effluents Paths, and Controls, Millstone Point Nuclear Power Station Unit 2,

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TER-C5506-99 3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS The present evaluation of the Licensee's proposed RETS against the provisions of NUREG-0472 included the following:

(1) a review of information provided in the Licensee's 1979 draft submittals [13, 14], (2) a discussion of problem areas in those submittals by means of a site visit (16), and (3) a I.

review of the Licensee's May 29, 1985 final submittal (17].

i 3.2.1 Effluent Instrumentation y

The objective of the RETS with regard to effluent instrumentation is to d

ensure that all significant releases of radioactivity are monitored.

The RETS specify that all effluent monitors be operable and alarm / trip setpoints be determined to ensure that radioactivity levels do not exceed the maximum permissible concentration (MPC) set by 10CFR20. To further ensure that the instrumentation functions properly, surveillance requirements are needed in i J the specifications.

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U 3.2.1.1 Radioactive Liquid Effluent Monitoring Instrumentation A radiation monitor has been installed for the liquid effluent line (Figure 1) which receives effluent releases from the clean liquid waste and the aerated liquid waste systems.

The monitor also has automatic isolation capabilities. The Licensee also has radiation monitors for the steam generator blowdown, the aerated liquid radwaste system, the condenser air ejector, and the condensate polishing facility. These radiation monitors also have alarm and automatic termination functions.

These existing monitoring capabilities have provided adequate assurance that the provisions of NUREG-0472 for the radioactive liquid effluent monitoring instrumentation are met.

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3.2.1.2 Radioactive Gaseous Effluent Monitoring Instrumentation

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l The waste gas holdup system is equipped with a noble gas monitor capable ij of providing alarm and automatic isolation functions.

TER-C5506-99 The Licensee also has provided radiation monitors for the Unit I stack and Unit 2 roof vent from which the plant gaseous effluents are relEa' sed.

The existing monitoring capabilities provided by the Licensee have met the intent of NUREG-0472 for radioactive gaseous effluent monitoring o

o instrumentation.

3.2.2 Concentration and Dose Rates of Effluents

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3.2.2.1 Liquid Effluent Concentration In Section 3.11.1.1 of the Licensee's submittal, a commitment is made to maintain the concentration of radioactive liquid effluents released from the site to within 10CFR20 limits, and if the concentration of liquid effluents exceeds these limits, the concentration will be restored to within the MPC T

limits specified in 10CFR20.

Both batch and continuous radioactive liquid 6

effluent releases are sampled and analyzed periodically in accordance with a sampling and analysis program (Table C-2,Section I of the Licensee's REMODCM i

submittal), which meets the intent of NUREG-0472.

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It is determined that the Licensee-proposed specification meets the intent of NUREG-0472 with respect to liquid effluent concentration.

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3.2.2.2 Gaseous Effluent Dose Rate

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q In Section 3.11.2.1 of the Licensee's submittal, a commitment is made to maintain the offsite gaseous dose rate due td radioactive' materials released in gaseous effluents from the site to areas at and beyond the site boundary to o

within 10CFR20 limits, or the equivalent dose rate values prescribed by Section 3.11.2.1 of NUREG-0472. If the dose rate of gaseous effluents exceeds these limits, it will be restored to a value equal to or within these limits.

This commitment satisfies the provisions of NUREG-0472.

The radioactive gaseous waste sampling and analysis program (Table D-2,Section I of the Licensee's REMODCM submittal) provides adequate sampling and l

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TER-CS506-99 analysis of the vent discharges, including' the substreams, and therel' ore meets the intent of NUREG-0472.

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j 3.2.3 Offsite Doses from Effluents J

i The objective of the RETS with regard to offsite doses from effluents is j

to ensure that offsite doses are kept ALARA and are in accordance with I

10CFR50, Appendix I, and 40CFR190. The Licensee has made a ccamitment to (1) w

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meet the quarterly and yearly dose limitations for liquid effluents, per Section II.A of Appendix I, 10CFR50; (2) restrict the air doses for beta and h

gasma radiation from the site to areas at and beyond the site boundary as i

specified in 10CFR50, Appendix I, Section II.B; (3) maintain.the dose level at 1

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and beyond the site boundary from releases of iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days k

within the design objectives of 10CFR50, Appendix I, Section II.C; and (4) 1 g

limit the annual dose including direct radiation from significant plant 7

sources to any member of the public to within the requirements of 40CFR190.

b In each pertinent section, the Licensee has made a ccannitment to perform dose j

calculations in accordance with methods given in the ODCM. These commitments he satisfy the intent of NUREG-0472.

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j 3.2.4 Effluent Treatment l

The objectives of the RETS with regard to effluent treatment are to ensure that wastes are treated to keep releases ALARA and to satisfy the 4

provisions of technical specifications governing the maintenance and use of radwaste treatment equipment.

1 In the proposed Radiological Effluent M nitoring Manual, Sections C-2 and 9

j D-2, the Licensee has made a commitment to use the liquid and gaseous radweste treatment systems to reduce the radioactive' materials in liquid and gaseous F

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wastes prior to their discharge when the estimated doses exceed the preceribed dose limits. These proposed dose limits ares i

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Liquid radwaste treatment system.

Proposed estimated dose

• limits are 0.06 mrem to the total body or 0.2 mram to any organ when sveraged over 31 days, as specified by the model RETS.

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Gaseous radwaste treatment systems. Proposed estimated air dose limits are 0.2 mrad for gamma radiation and 0.4 mrad for beta l

radiation when averaged over 31 days, as specified by the model RETS.

g The Licensee has made an additional commitment to set a limit of 0.3 arem to any organ due to gaseous particulate effluents.

j The Licensee's commitments meet the intent of NUREG-0472 with respect to J

j effluent treatment.

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3.2.5 Radioactivity Inventory Limits The objective of the RETS with regard to tank inventory limits is to l

ensure that the rupture of a radweste tank would not cause offsite doses

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c greater than the limits set in 10CFR20 for non-occupational exposure. The J

Licensee's outside liquid storage tanks are all diked and thus a specification t

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is not needed for tank inventory. This meets the intent of NUREG-0472. For J

gas storage tanks, the Licensee's stringent specifications on coolant activity.

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level make a specification for tank curie limit unnecessary. The Licensee's justifications were considered [8] as meeting the intent of NUREG-0472.

The Licensee's substittal regarding the radioactivity inventory limits

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3.2.6 Explosive Gas Mixtures i

j The objective of the RETS with regard to explosive gas mixtures is to i

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prevent hydrogen explosions in the waste gaar systems. The Licensee has stated that the waste gas holdup system is hydrogen-rich and is not designed to withstand a hydrogen / oxygen explosion.

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The Licensee does not have a technical specification and has not provided r

I monitors for the explosive gas. The Licensee cited 9 years of operation ii, experience of the existing waste gas system and the use of routine grab

,f samples for gas analysis to ensure an explosion-proof. mixture.

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As in the previous reviews of other plants, it is determined that the i

L Licensee meets the intent of NUREG-0472 in the interim until the NBC completes its study of the explosive gas problem.

3.2.7 Solid Radwaste System i

The objective of the RETS with regard to the solid radwaste sys' tem is to ensure that radwaste will be properly processed and packaged before it is shipped to a burial site. Specification 3.11.3 of NUREG-0472 provides for the establishment of a Process Control Program (PCP) to show compliance with this i

objective. Although the Licensee has not provided a technical specification j

regarding the solid radwaste treatment, the Licensee has made a commitment (Section 6.17 under the Adininistrative Controls) to establish and implement a PCP and thus to ensure that radwaste is properly processed and packaged before it is shipped to the burial site. This was determined [18] to meet the intent of NUREG-0472.

3.2.8 Radiological Environmental Monitoring Procram The objectives of the RETS with regard to environmental monitoring are to B

ensure that an adequate and full-area-coverage monitoring program exists and that the 10CFR50, Appendix I requirements for technical specificaticna on environmental monitoring are satisfied.

In all cases, the Licensee has

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generally followed NUREG-0472 guidelines, including the Branch Technical Position dated November 1979 [25), and has provided an adequate number (39) of thermoluminescent dosimeter (TLD) sample locations omitting water sectors not applicable to land pathways. The Licensee's methods of analysis and maintenance of yearly records satisfy the NRC guidelines and meet the intent of 10CFR50, Appendix I.

The Licensee has also made a coenaitment to document the new environmental monitoring sample locations in the Annual Radiological 3

Environmental. Operating Reporti which meets the intent of NUREG-0472.._. 'Ihe specification for the land use census satisfies the provisions of Section 3.12.2 of NUREG-0472 by providing for an annual census in the specified I

The Licensee participates in an interlaboratory comparison program areas.

,, approved by the NRC and reports the results in the Annual Radiological Environmental Operating Report, which also meets the intent of NUREG-0472.,

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TER-C5506-99 3.2.9 Audits and Reviews t

The objective of the 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 designates the Plant Operation Review rnemitee (PORC) as the group responsible for review k

of the proposed changes to the Technical Specifications, the PCP, and the REMODCM. Audits are performed under the cognizance of the Nuclear Review Board (NRB); these audits encompass the Technical Specifications, REMODCM, PCP, and the quality assurance (QA) program. It is determined that the Licensee-proposed administrative structure satisfactorily meets the intent of NUREG-0472.

3.2.10 Procedures and Records The objective of the RETS with regard to procedures is to satisfy the provisions for written procedures specified in NUREG-0472 for~ implementing the P

ODCM and the PCP.

Y It is also an objective of RETS to properly retain the documented records related to the environmental monitoring program and certain 7

QA procedures. The Licensee has made a commitment to establish, implement,

.I and maintain written procedures for the PCP, the REMODCM, and the QA program for effluent and environmental monitoring. The Licensee intends to retain the records of gaseous and liquid radioactive material released to the environs that would permit evaluation of the accuracy of the analysis at a later date.

It is thus determined that the Licensee met the intent of NUREG-0472.

3.2.11 Reports In addition to the reporting requirements of Title 10, Code of Federal

~

Regulations (10CFR), the objective of the RETS with regard to administrative controls is to ensure that appropriate periodic and special reports are submitted to the NBC.

The Licensee has made a commitment to follow applicable reporting requirements stipulated by 10CFR regulations and also the following reports specified by NUREG-0472:

TER-C5506-99 1.

Annual radiological environmental operating report.

In Section 6.9.1.7 of the Licensee's submittal, a commitment is made,to provide an annual radiological environmental surveillance report that includes the information delineated in the Licensee's proposed REMODCM. This commitment was considered [18] to meet the reporting provisions of NUREG-0472.

2.

Semiannual radioactive effluent release reports.

In Section 6.9.1.8

[

of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent release reports which include information delineated in the proposed REMODCM.

His commitment was considered to meet the reporting provisions of NUREG-0472.

3.

Special report. The Licensee has made a commitment as prescribed by 7

the proposed specification to file with the NRC a special report in 30 cays from the end of the quarter under the following conditions:

}

exceeding liquid effluent dose limits according to Specification o

A 3.11.1.2

}

exceeding gaseous effluent dose limits according to Specifications o

j 3.11.2.2 and 3.11.2.3 exceeding total dose limits according to Specification 3.11.3 o

exceeding the reporting levels of Table E-1 of the Licensee's o

proposed REMODCM for the radioactivity measured in the environmental sampling medium.

The Licensee has also made a commitment to file with the NRC a special

~

report under the following conditions exceeding liquid radioactive waste treatment limits according to o

Section I (C.2) of the proposed REMODCM.

exceeding gaseous radioactive waste treatment limits according to o

Section I (D.2) of the proposed REMODCM.

?

f These reporting commitments have satisfied [18] the provisions of NUREG-0472.

3.2.12 Inglementation of Major Programs One objective of the administrative controls is to ensure that implemen-tation of major programs such as the REMODCM, the PCP,.and major changes to the radioactive waste treatment system follow appropriate administrative 6

~ procedures. The Licensee has made a commitment to review, report, and,

i

TER-C5506-99 implement major programs such as the REMODCM. The License::, has also made a commitment to review and implement a PCP.

The Licensee cons!.Jors that reporting of major changes to the radwaste treatment system is covered by the existing Technical Specifications.

It was determined (18] that the Licensee's commitments meet the intent of NUREG-0472.

3.3 OFFSITE DOSE CAICULATION MANUAL (ODCM)

As specified in NUREG-0472, the ODCM is to be developed by the Licensee to ' document the methodology and approaches used to calculate offsite doses and i

maintain the operability of the effluent system. As a minimum, the ODCM i

should provide equations and methodology for the following topics:

o alarm and trip setpoint on effluent instrumentation o liquid effluent concentration in unrestricted areas i

l gaseous effluent dose rate at or beyond the site boundary o

i o liquid and gaseous effluent dose contributions J

liquid and gaseous effluent dose projections.

o 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 location of samples in support of the f ~~

environmental monitoring program are also needed in the ODCM.

i 3.3.1 Evaluation The Licensee's ODCM is contained in Section II of the proposed REMODCM.

The Licensee has fo'llowed the methodology of NUREG-0133 [9] to determine the alarm and trip setpoints for the liquist and gaseous effluent monitors, which ensures that the maximum permissible concentrations (MPCs), as specified in 10CFR20, will not be exceeded by discharges from various liquid or gaseous 5

release points.

f l

. t i

TER-C5506-99 l

The Licensee has demonstrated the method of calculating the radioactive liquid concentration by describing in the ODCM the means of colleesing and analyzing representative samples prior to and after releasing liquid effluents into the circulating water discharge. The method provides added assurance of compliance with 10CPR20 for liquid releases.

i Methods are also included for showing that the air maximum permissible concentration (MPC) at or beyond the site boundary due to noble gases, iodine-131, iodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days is in compliance with 10CFR20.

In all cases, P

the Licensee has used the highest annual average values of relative a

concentration (X/Q) to determine the controlling locations.

The Licensee's I

approach of using the MPC values meets the dose rate design objectives and the intent of NUREG-0133 on the requirement of 10CFR20.

3 Evaluation of the cumulativo dose is performed to ensure that the quarterly and annual dose design objectives specified in RETS are not exceeded.

For liquid releases, the Licensee has identified saltwater fish and shellfish consumption, and direct radiation from shoreline sediment as the viable pathways.

In the calculation, the Licensee has generally used key parameters that follow the suggested values given in Regulatory Guide 1.109.

The Licensee has used the maximally exposed individual as the reference 8

receptor.

I ~~ ~

Evaluation of the cumulative dose from noble gas releases includes both I

beta and gamma and air doses at and beyond the site boundary. The critical organs under consideration are the total body for gamma and skin for beta i

radiation.

The Licensee has used the maximum annual average relative concentration -(X/Q) and,has followed the methodology and parameters of Regulatory Guide 1.109.

For iodine-131, iodine-133, tritium, and particulates with half-lives greater than 8 days, the Licensee has provided a method to demonstrate that cumulative doses calculated from the release meet both quarterly and annual P

design objectives. The Licensee has demonstrated a method of calculating the

. -dose using maximum annual average relative concentration (X/Q) for the.

i i

4 TER-C5506-99 inhalation pathway and has included annual average deposition parameter (D/Q) 3 fortheleafyvegetablepathwayandthegrass-cow-milkpathwayforIngestion.

i' This approach is consistent with the methodology of NUREG-0133.

Adequate flow diagrama defining the effluent paths and components of the 1

radioactive liquid and gaseous waste treatment systems have been provided by t

the Licensee. Radiation monitors specified in the Licensee-submitted RETS are also properly identified in the flow diagrams.

i J.

The Licensee has provided a description of sampling locations in the ODCM and has identified them in Appendix G of the submittal. his description is consistent with the sampling locations specified in the Licensee's Table E-1 1

on environmental monitoring.

I A

The Licensee has assessed the total dose (40CFR190 requirement) including the direct radiation, which satisfies the total dose provision of NUREG-0473.

j i

In summary, the Licensee'.s ODCM uses documented and approved methods that are consistent with the methodology and guidance in NUREG-0133 and is f

therefore an acceptable reference.

i 1

e e -

g a

l 1

l T

TER-C5506-99 4.

. CONCLUSIONS Table 1summarizestheresultsofthefinalreviewandevaluatbnofthe RETS submittal for the Millstone Point Nuclear Power Station Unit 2 proposed Radiological Effluent Technical Specifications (RETS). The evaluation was a

based on the Licensee's final submittal of the RETS and ODCM.

'Ihe following h

conclusions were reached:

1.

The Licensee's proposed Radiological Effluent Technical Specifications (RETS), submitted May 29, 1985 [17], meet the intent of NUREG-0472, for " Radiological Effluent Technical Specifications."

a 2.

The Licensee's Offsite Dose Calculation Manual (ODCM), submitted May 29, 1985 [17), uses documented and approved methods that are

)

generally consistent with the criteria of NUREG-0133 and applicable j

to Millstone Point Nuclear Power Station Unit 2.

It is thus an acceptable reference.

T b

1 1

3 I

i ib T7 I

8 e

C7 l

i I I

TER-C5506-99 Table 1.

Evaluation of Proposed. Radiological Effluent Technical Specifications (RETS), Millstone Point Nuclear Power Station Unit 2 w

Technical Specifications Replaces NRC Staff or Updates Std. RETS Licensee Existing g

NUREG-0472 Proposal Tech. Specs.

(Section)*

(Section)

(Section)

Evaluation Effluent 3/4.3.3.3.10 3.3.3.9 3.3.3.1 Meets the intent Instrumentation 3/4.3.3.3.11 3.3.3.10 of NPC criteria Radioactive 3/4.11.1.1 3.11.1.1 2.4.1 Meets the intent I

Effluent 3/4.11.2.1 3.11.2.1 2.4.2 of NRC criteria I

Concentrations Appendix B j

offsite Doses 3/4.11.1.2, 3.11.1.2 To be added Meets the intent j

3/4.11.2.2, 3.11.2.2 to Appendix A of NRC criteria 3/4.11.2.3, 3.11.2.3 7

3/4.11.4 A

Effluent 3/4.11.1.3 C.2 (REM)**

2.4.1 Meets the intent Treatment 3/4.11.2.4 D.2 (REM)**

2.4.2 of NRC criteria Appendix B Radioactivity 3/4.11.1.4 NA NA Meets the intent 9

Inventory Limits 3/4.11.2.6 NA NA of NRC criteria Explosive Gas 3/4.11.2.5B NA NA 9

Mixtures Meets the intent of NRC criteria j

on an interim basis Solid Radioactive 3/4.11.3 6.17 NA Meets the intent.

y Waste of NRC criteria Environmental 3/4.12.1 E (REM)**

3.2 Meets the intent

' Monitoring App'ndix B of NRC criteria e

~

Audits and

6. 5.1, 4. 5.2 6.5.1, 6.5.2 6.5.1, 6.5.2 Meets the intent Reviews of NRC criteria Procedures and 6.8, 6.10 6.8, 6.10 6.8, 6.10 Meets the intent Records of NRC criteria Reports 6.9 6.9 6.9 Meets the intent of NRC criteria Implementation of 6.13, 6.14, 6.16, 6.17 To be added Meets the intent

_ Major Programs 6.15 to Appendix A of NRC criteria i

• Section number sequence is according to NUREG-0472, Rev. 3, Draft 7" (12]..

r i

TER-C5506-99 i

5.

REFERENCES

~

i u-

{

l.

" Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 2 i

NRC, July 1979 NUREG-0472 i

b 2.

Title 10, Code of Federal Regulations, Part 50, Appendix I, "Ntsnerical Guides for Design Objectives and Limiting Conditions for Operation to l

Meet the Criterion, 'As Low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents" 3.

Title 10, code of Federal Regulations, Part 50, Appendix I,Section V,

" Effective Dates"'

a 4.

Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation" 5.

Title 40, code of Federal Regulations, Part 190, " Environmental Radiation l

Protection Standards for Nuclear Power Operations" 6.

Title 10, Code of Federal Regulations, Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants" f

7.

Title 10, Code of Federal Regulations, Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power' Plants and Fuel Reprocessing Plants" r

8.

" Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 2 l

NRC, July 1979

+

3 NUREG-0473

~~

9.

" Preparation of Radiological Effluent Technical Specifications for

]

j Nuclear Power Plants, A Guidance Manual-for Users of Standard Technical Specifications" NBC, October 1978 4

i

{

NUREG-0133 10.

C. Willis and F. Congel (NRC)

"Susumary of Draft dontractor Guidance of RETS" Presented at the AIF Environmental Subccaunittee Meeting, Washington, DC May 19, 1982-11.

F. Congel (NRC) i Memo to RAB Staff (NRC) i y

Subject:

Interim Changes in the Model Radiological Effluent Technical Specifications (RETS) i August 9,1982 1

z. ~

TER-C5506-99 12.

" Radiological Effluent Technical Specifications for Pressurized Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors

[

NRC, September 1982 NUREG-0472 13.

Radiological Effluent Technical Specification, Millstone Point Nuclear Power Station Unit 2 g

Northeast Nuclear Energy Company September 19, 1979 NRC Docket No. 50-336 14.

Offsite Dose calculation Manual Millstone Point Nuclear Power Station Unit 2 j

Northeast Nuclear Energy Company i

September 19, 1979 NRC Docket No. 50-336 k

15.

g

" Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs vs. Millstone Point Nuclear Power Station Unit 2 Radiological Effluent Technical Specifications" (Draft)

{

Franklin Research Center, October 30, 1981 16.

Letter of Transmittal

}

Subject:

Trip Report on Site Visit to Millstone Point Nuclear Power d

Station Unit 2 (November 12-13, 1981)

Franklin Research Center 17.

J. F. Opeka (Northeast Nuclear Energy Company)

Letter of Transmittal to NRC

Subject:

Millstone Point Nuclear Power Station Unit 2 - Proposed Revisions to-Radiological Effluent Technical Specifications May 29, 1985 NRC Docket No. 50-336 l

n 18.

W. Meinke (NRC)

Memo to S.'Pandey (FRC)

Subject:

Resolution of Discrepancies in RETS Submittal of May 29, 1985',

l for Millstone Point Nuclear Power Station Unit 2 June 2, 1985 19.

" Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs, vs. Licensee Final Submittal, dated May 29, 1985, of Radiological Effluent Techni' cal Specifications for Millstone Point Nuclear Power Station Unit 2" Franklin Research center, July 1985

~ ~ ~

6 20.

C. Willis (NRC)

Letter to S. Pandey (FRC)

Subject:

Changes to RETS requirements following meeting with Atomic Industrial Forum (AIF)

November 20, 1981 TER-C5506-99 21.

C. Willis (NRC)

Lettet to S. Pandey (FRC)

[

Subject:

Control of explosive gas mixture in PWRs g-December 18, 1981 22.

C. Willis and F. Congel (NRC)

" Status of NRC Radiological Effluent Technical Specification Activities" Presented at the AIF Conference on NEPA and Nuclear Regulations,

[

Washington, D.C.

October 4-7, 1981 e

23.

C. Willis (NRC)

~

Memo to P. C. Wagner (NBC)

" Plan for Implementation of RETS for Operating Reactors" l

November 4, 1981 e

24.

W. P. Gammill (NRC)

]

Memo to P. C. Wagner (NRC)

" Current Position on Radiological Effluent Technical Specifications (RETS) Including Explosive Gas Controls" October 7, 1981 v

i*

25.

"An Acceptable Radiological Environmental Monitoring Program" I

Radiological Assessment Branch Technical Position, Revision 1 NRC, November 1979 d

26.

W. P. Cammill and F. J. Congel (NRC) i Memo to ETSB/RAB (NRC) j

" Radiological Effluent Technica1 Specifications (RETS) Provisions for

~

I-133"

~

November 29, 1982 27.

Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40CFR190)

NRC, February 1980 NUREG-0543 28.

(

" General Contents of the Offsite Dose Calculation Manual," Revision 1 Branch Technical Position, Radiological, Assessment Branch NRC, February 8, 1979 29.

" Calculation of Annual Doses to Man fran Routine Releases of Reactor Effluents for the Purpose of Evaluatipg Compliance with 10CFR50, Appendix I" NRC, October 1977 Regulatory Guide 1.109, Rev.1 9 9,.

.