ML20136G029

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Radiological Effluent Tech Spec Implementation (A-2),Maine Yankee Atomic Power Station, Technical Evaluation Rept
ML20136G029
Person / Time
Site: Maine Yankee
Issue date: 05/29/1985
From: Sunny Chen
CALSPAN CORP.
To:
NRC
Shared Package
ML20136G035 List:
References
CON-NRC-03-81-130, CON-NRC-3-81-130 TAC-8775, TER-C5506-97, NUDOCS 8506030242
Download: ML20136G029 (29)


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I TECHNICAL EVALUATION REPORT t

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NRCDOCKET NO. 50- 309 FRC PROJECT C5506 NRC TAC NO. 8775 FRC ASSIGNMENT 4 NRC CONTRACT NO. NRC43-81 130 FRC TASK 97 I'

b RADIOLOGICAL EFFLUENT TECHNICAL yl SPECIFICATION IMPLEMENTATION (A-2)

MAINE YANKEE ATOMIC POWER COMPANY MAINE YANKEE ATOMIC POWER STATION TER-C5506-97 8 Prepared for Nuclear Regulatory Commission FRC Group Leader: S. Pandey Washington, D.C. 20555 Lead NRC Engineer: F. Congel C. Willis May 29, 1985 3

'E 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

'T employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use of any information, appa-I ratus, product or process disclosed in this report, or represents that its use by such third party would not inf ringe privately owned rights.

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Prepared by: Reviewed by: Approved by:

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Date: C -2 O- # f Date: 5-21-# F Date: < 8F N

e FRANKLIN RESEARCH CENTER

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CONTENTS Section Title Page 1 INTRODUCTION . . . . . . . . . . . . . 1 7, 1.1 Purpose of Review . . . . . . . . . . . 1

[3 1.2 Generic Background. . . . . . . . . . . 1

. 1.3 Plant-Specific Backg round . . . . . . . . . 3 d 2 REVIEW CRITERIA. . . . . . . . . . . . . 5 3 TECHNICAL EVA1,UATIOd . . . . . . . . . . . 7 3.1 General Description of Radiological Effluent Systems . . 7 3.2 Radiological Eftluent Technical Specifications. . . . 10 3.3 Offsite Dose Calculation Manual . . . . . . . 17 4 CONCLUSIONS. . . . . . . . . . . . . . 20 5 REFERENCES . . . . . . . . . . . . . . 22 8

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TE R-C5506-97 FIGURES Number Title ,g, L

1 Liquid Radwaste Treatment Systems, Effluent Paths, and t' Controls, Maine Yankee Atomic Power Station. . . . . . . 8 L

2 Gaseous Radwaste Treatment Systems, Ef fluent Paths, and Controls, Maine Yankee Atomic Power Station. . . . . . . 9 J

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Number Title Page 1 Evaluation of Proposed Radiological Effluent Technical

, Specifications (RETS), Maine Yankee Atomic Power Station . . . 23 0

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TER-C5506-97 FOREWORD This Technical Evaluation Report was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of 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

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1. INTRODUCTION l.1 PURPOSE OF REVIEW The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Maine Yankee

( Atomic Power Station with regard to Radiological Ef tluent Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM).

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

This effort is directed toward the NRC objective of implementing RETS which comply principally with the regulatory requirements of the Code or Federal Regulations, Title 10, Part 50 (10CFR50), " Domestic Licensing of Production and Utilization Facilities," Appendix I (2]. Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.

1.2 GENERIC BACKGROUND

  • Since 1970, 10CFR50, Section 50.36a, " Technical Spec 1tications on Effluents from Nuclear Power Reactors," has required licensees to provide technical specitications wnich ensure that radioactive releases will be kept as as low as reasonably achievable (AIARA) . In 1975, numerical guidance tor the ALARA requirement was issued in 10CFR50, Appendix I. The licensees or all U operating reactors were required (3) to submit, no later tnan June 4, 1976,

. their proposed ALARA Technical Specitications and information for evaluation in accordance with 10CFR50, Appendix I.

, However, in February 1976, the NRC staff recommended that proposals to modify Technical Specifications be deferred until the NRC completed'the model i

, RETS. The model RETS deals with radioactive waste management systems and l environmental monitoring. Although the model RETS closely parall is 10CFR50, Appendix I requirements, it also includes provisions for addressingwther i

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These other issues are specifically stipulated by the following s

l regulations:

, o 10CFR20 [4], " Standards for Protection Against Radiation," Paragraphs jl 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.

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. o 10CFR50, Appendix A [6), " General Design Criteria tor Nuclear Power Plants," contains Criterion 60 - Control ot releases of radioactive

., materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and Criterion 64 - Monitoring radioactivity releases.

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

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

NUREG-0472 [1] tor pressurized water reactors (PWRs) and NUREG-0473 [8] for boiling water reactors (BWRs) . Copies were sent to licensees in July 1978 7 with a request to submit proposed site-specific RETS on a staggered schedule

' over a 6-month period. Licensees responded with requests for clarifications a and extensions.

The Atomic Industrial Forum (AIF) tormed a task force to comment on the model RETS. NRC staf t members first met with the AIF task torce on June 17, D 1978. The model RETS was subsequently revised to reflect comments from the AIF and others. A principal change was the transter of much or the material 8 concerning dose calculations f rom the model RETS to a separate ODCM.

' The revised model RETS was sent to licensees on Novencer 15 and 16, 1978 k with guidance (NUREG-0133 [9]) tor preparation ot the RETS and the ODCM and a y new schedule for responses, again staggered over a 6-month period.

Four regional seminars on the RETS were conducted by the NRC statt during November and December 1978. Subsequently, Revision 2 of the model'RETS and k additional guidance on the ODCM and the PCP were issued in February *1979 to

_ y-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 teams as reviewers.

As the RETS review process has progressed since September 1981, teedoack

~t trom the licensees has led the NRC to believe that modification to some of the 4 guidelines in the current version of Revision 2 is needed to clarify specitic a concerns of the licensees and thus expedite the entire review process.

Starting 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

, , regarding the Radiological Environmental Monitoring Section were issued in 1982 (11). With the incorporation of these new changes, NRC issued, in September 1982, a draft version of NUREG-0472, Revision 3 (12), to serve as new guidance for the review teams.

1.3 PLANT-SPECIFIC BACKGROUND In response to the NRC's request, the Licensee submitted a RETS proposal 15, 1979. This 8* p[13]

roposal onwasbehalf of at followed Maine a laterYankee date by Power a submittal Station, of the ODCM dated March

[14]. In the RETS'aubmittal, the Licensee generally followed the model RETS format (NUREG-0472) for PWRs. Initial review or the Licensee's submittal was performed in June 1982 by an independent review team at Franklin Research Center (FRC). The Licensee's submittal was compared with the model RETS and assessed for compliance with the requirements as stipulated.

iW Copies or the dratt review, dated June 15, 1982 [15], were delivered to y the NRC and the Licensee prior to a site visit by the independent review team.

i The site visit was conducted on July 7-8, 1982 by the reviewers with the participation of plant personnel and the NRC staff. Discussion tocused on the

'l initial review of thc proposed changes to the RETS and on the techracal approaches for an ODCM. The technical deticiencies in the Licensiee i proposed RETS were considered, and deviations from NRC guidelines were pointed out.

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Upon conclusion of this meeting, many of the differences were clarified and I

resolved; only a few items remained open, pending justitication from the Licensee. These major issues are summarized in Reference 16.

I Under a cover letter dated May 8, 1985 [17), Maine Yankee Atomic Peder

Company delivered its final submittals on REIS and ODCM to the NRC. Copies ot b these submittals were transmitted to FRC for review. The Licensee's RETS

,; submittal was evaluated against NUREG-0472, Draf t Revision 3 [12) . The ODCM

was evaluated according to the existing guidelines specified by NUREG-0133

[9].

[1 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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2. REVIEW CRITERIA l

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

NUREG-0472, RETS for PWRs NUREG-0473, RETS for BWRs s

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

Twelve essential criteria are given for the RETS and ODCM:
1. All significant releases of radioactivity shall be controlled and

,l monitored.

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2. Oftsite concentrations of radioactivity shall not exceed the 10CFR20, Appendix B, Table II limits.
3. Ottsite radiation doses of radioactivity shall be ALARA.
4. Equipment shall be maintained and used to keep of tsite doses ALARA.

m 5. Radwaste tank inventories shall be limited so that tailures will not cause ottsite doses exceeding 10CFR20 limits.

, j 6. Hydrogen and/or oxygen concentration in the waste gas system snall be controlled to prevent explosive mixtures.

7. Wastes shall be processed to shipping and curial ground criteria under a documented program, subject to quality assurance D. veritication.

,a 8. An environmental monitoring program, including a land-use census and I an interlaboratory comparison program, 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.
11. Periodic and special reports on environmental monitoring and on releases shall be submitted.
12. Of tsite dose calculations shall be performed using documed}ed arid approved methods consistent with NRC methodology. I;2

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

The NRC branch positions issued since the RETS implementation review began g have clarified the model RETS implementation for operating reactors.

g Review of the ODCM was based on the following NRC guidelines: Branch k; Technical Position, " General Content of the Offsite Dose Calculation Manual"

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

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3. TECHNICAL EVALUATION 3.1 GENERAL DESCRIPTION OF RADIOLOGICAL EFFLUENT SYSI' EMS This section briefly describes the liquid and gaseous radwaste effluent
j. systems, release paths, and control systems installed at Maine Yankee Atomic
L Power Station. The station site is located on a peninsula known as Bailey

, Point, which extends towards the south of Montsweag Bay in Maine.

! i 3.1.1 Radioactive Liquid Effluent The liquid radwaste system of Maine Yankee Atomic Power Station consists mainly of the hydrogenated liquid waste system and the aerated liquid waste system, as shown in Figure 1. Hydrogenated liquid wastes are held up in the primary drain tank until processing. Processing of these wastes consists of either one or a como1 nation of holdup for natural decay, filtration, and ion exchange. Aerated liquid wastes are collected in two drain tanks prior to processing. Processing of aerated liquid wastes consists of holdup of natural decay and evaporation. These two waste streams constitute the liquid radwaste

/ effluent.

Blowdown tros the steam generator is also discharged to the seal pit via the circulating water discharge canal. Another effluent line coming from the turbine building sump is also discharged to the seal pit before being released to the bay.

3.1.2 Radioactive Gaseous Effluent

' The gaseous radwastes of the Maine Yankee Atomic Power Station also g- consist of ettlu'ents contained in the hydrogenated gases and aerated gases.

The hydrogenated wastes are collected by the hydrogenated gas header and are processed by holdup by natural decay and filtration. The aerated gases are at

,, low activity; they are collected through the aerated gas header and,are discharged after tiltration to the primary vent stack. Thesewast'ehasesare merged to the vent stacks for dilution and released to the atmosphere (see Figure 2). Also routed to the vent sta::k 'are the etfluents trcm the primary auxiliary building, the reactor containment, the steam generator clowdown tank

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Peteery System Hydrogenated Drains

  • Vent to Weste Car Surae Tank Pete ry E*f**

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Radiator Stonitor - Alare Function d ' 2601, 2602, 2603 Filter

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Badiation leonttor Alers & loolation r-Flow Indication RM-3801 l 6 9P l Service Water Radiation dk Turbine Blda. Sump

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RM-1601

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w Figure 1. Liquid Radwaste Treatment Systems, Et tluent Paths, and Controls, Maine Yankee Atomic Power Station

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Containment Att Psitation Monttar Alare function of on line purge isolation

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Containment Purge ,

Stack Radiation leonttor Alare & on line purge isolation RM-39021. RM-3902Y Stack Continuous Sampler c Primary Aestilar? Sullding (Shielded Areast li -

RCA Storage Area - Radiation Monitor - Alare Function RM-1801 y Condenser Air Ejectors

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- Radiation Monitor - Alera & leolation RM-3901 runc: ton 4 ,

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and Controls, Maine hnkt:e AtcJdic Power Station 1

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vent, the condenser offgas, and the radwaste storage area.

I 3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS Tne present evaluation of the Licensee's proposed RETS against the provisions of NUREG-0472 included the tollowing: (1) a review of information

( provided in the Licensee's 1979 draf t submittals [13,14], (2) a discussion or problem areas in those submittals by means of a site visit (16], and (3) a review of the Licensee's May 8, 1985 final submittal (17].

3.2.1 Effluent Instrumentation The oojective of the RETS with regard to effluent instrumentation is to ensure that all significant releases ot radioactivity are monitored. The RETS specify that all ef fluent 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

' the specifications.

e W 3.2.1.1 Radioactive Liquid Eftluent Monitoring Instrumentation A radiation monitor (RM-3801) has been installed for the 11guld ettluent D line (Figure 1) which receives efiluent releases f rom the hydrogenated liquid waste and the aerated liquid waste systems. The monitor also has automatic U isolation capabilities. The Licensee also has radiation monitors (RM-2601,

-2602, and -2603) for the steam generator blowdown effluent line. These radiation monitors also have alarms. The Licensee has also provided a monitor (RM-1601) for the service water line.

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' The waste gas holdup system is equipped with a noble gas monitor

( RM-3091) capable of providing alarm and automatic isolation functions.

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l TER-C5506-97 The vent stack is equipped with a redundant noble gas monitoring system (RM-3902X, RM-3902Y) with alarm and isolation capabilities. A noble gas

, monitor (RM-1801) is also installed at the condenser air ejector system.

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

% instrumentation.

3.2.2 Concentration and Dose Rates of Effluents 3.2.2.1 Liquid Effluent concentration In Section 3.16.A of the Licensee's submittal, a commitment is made to maintain the concentration of radioactive liquid effluents released to the 0 unrestricted areas to within 10CFR20 limits, and if the concentration of liquid effluents exceeds these limits, the concentration will be restored without delay to within the MPC limits specified in 10CFR20. Both batch and continuous radioactive liquid effluent releases are sampled and analyzed periodically in accordance with a sampling and analysis program (Table 4.12-1 of the Licensee's submittal), which meets the intent of NUREG-0472.

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

3.2.2.2 Gaseous Effluent Dose Rate In Section 3.17.A of the Licensee's submittal, a commitment is made to maintain the offsite gaseous dose rate due to radioactive materials released

'in gaseous eftluents from the site to areas at and beyond the site boundary to within 10CFR20 limits, or the equivalent dose rate values prescrioed by Section 3.11.2.1 of NUREG-0472. If the dose rate of gaseous effluents exceeds these limits, it will be restored without delay 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 (Sable 4.12-2 of the Licensee's submittaA) providesadequatesamplingandanaly'sikofthe vent discharges, including the substreams, and therefore meets the intent of NUREG-0472.

, TER-C5506 -97 i 3.2.3 Offsite Doses from Effluents The objective of the RETS with regard to otfsite doses from effluents is

!l' to ensure that offsite doses are kept ALARA and are in accordance with 10CFR50, Appendix I, and 40CFR190. The Licensee has made a commitment to (1) meet the quarterly and yearly dose limitations for liquid eftluents, per Section II.A of Appendix I,10CFR50; (2) restrict the air doses for beta and r gamma radiation from the site to areas at and beyond the site boundary as j specified in 10CFR50, Appendix I, Section II.B; (3) maintain the dose level at and beyond the site boundary f rom releases of iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days within the design objectives of 10CFR50, Appendix I, Section II.C; and (4) j limit the annual dose including direct radiation from signiticant plant i sources to any member of the public to within the requirements ot 40CFR190.

In each pertinent section, the Licensee has made a commitment to perform dose calculations in accordance with methods given in the ODCM. These commitments satisfy the intent of NUREG-0472.

d s 3.2.4 Effluent Treatment The objectives of the RETS with regard to effluent treatment are to l ensure that wastes are treated to keep releases ALARA and to satisfy the

)U provisions ot technical specific'tions a governing the maintenance and use of l radweste treatment equipment.

53 In the proposed Specifications 3.16.C.1 and 3.17.D.1, the Licensee has

,ande a commitment to use the liquid and gaseous radwaste treatment systems and W the ventilation exhaust treatment system to reduce the radioactive materials in liquid and gaseous wastes prior to their discharge when the estimated doses exceed the prescribed dose limits. These proposed dose limits ares

a. Liquid radwaste treatment system. Proposed estimated dose limits are

, 0.06 stem to the total body or 0.2 prem to any organ when gveraged over 31 days, as specified by the model REIS. *]. *gg

b. Gaseous radwaste treatment systems. Proposed estimated air dose
limits are 0.2 stad for gamma radiation and 0.4 mrad for' beta j radiation when averaged over 31 days, as specified by the model RETS.

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c. Ventilation exhaust treatment system. Proposed estimated dose limit

, is 0.3 mrom to any organ when averaged over 31 days, as specitied oy the model RETS.

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The Licensee's comunitments meet the intent of NUREG-0472 with respect to effluent treatment.

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3.2.5 Radioactivity Inventory Limits e

a The objective of the RETS with regard to tank inventory limits is to ensure that the rupture of a radwaste tank would not cause ottsite doses

'j greater than the limits set in 10CFR20 tor non-occupational exposure. The Licensee's outside liquid storage tanks are all diked and thus a specification is not needed for tank inventory. This meets the intent of NUREG-0472. For gas storage tanks, the Licensee has set a limit of 90,000 curies noble gas (considered as xenon-133). The Licensee's submittal regarding the radioactivity inventory limits thus meets the intent of NUREG-0472.

r L 3.2.6 Explosive Gas Mixtures

. The objective of the RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in the waste gas systems. The Licensee has stated

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that the waste gas holdup system is hydrogen-rich and is not designed to U withstand a hydrogen / oxygen explosion.

In Specification 3.17.F.1 of the Licensee's submittal, a commitment is made to limit the concentration of oxygen in the waste gas holdup system to less than 44 by volume whenever the hydrogen concentration exceeds 24 by L volume. The Licensee has provided a sampling of oxygen concentrations (according to Section 4.2 of the proposed submittal) to monitor the 7

possibility of an explosive gas mixture concentration in the waste gas holdup system. The Licensee action specification states that if both the oxygen and

hydrogen concentration levels are exceeded, actions will be taken to suspend j alladditionsofwastegasestothesystemandtoreducetheconcnkationof i oxygen to less than the limit. ~k As in the previoe- 'Is c' othet plants, it is determined tnat the f Licensee meets the intent of NUREG-0472 in the interim until the NRC completes its study of the explosive gas proolem.

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, 3.2.7 Solid Radwaste System

<l The objective of the RETS with regard to the solid radwaste system 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 J

establishment of a Process Control Program (PCP) to show compliance with this

!k objective. The Licensee has made a commitment (Specification 5.5.B of the j, submittal) 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 Program The objectives of the RETS with regard to environmental monitoring are to ensure that an adequate and full-area-coverage monitoring program exists and j that the 10CFR50, Appendix I requirements for technical specitications on j environmental monitoring are satisfied. In all cases, the Licensee has f generally followed NUREG-0472 guidelines, including the Branch Technical Position dated November 1979 (25], and has provided an adequate number (38) ot thermoluminescent dostmeter (TLD) sample locations omitting water sectors not applicable to land pathways. The Licensee's methods of analysis and main'tenance of yearly records satisfy the NRC guidelines and meet the intent

!U of 10CFR50, Appendix I. The Licensee has also made a commitment to document j the new environmental monitoring sample locations in the Annual Radiological Environmental Operating Report, which meets the intent of NUREG-0472. The specification for the land use census satisties the provisions or Section 4.8.B of NUREG-0472 by providing for an annual census in the specified areas.

W The Licensee participates in an interlaboratory comparison program approved by the NRC and reports the results in the Annual Radiological Environmental

, li Operating Report, which also meets the intent of NUREG-0472.

I 3.2.9 Audits and Reviews }* *h -

I The objective ot the RETS with regard to audits and reviews ls to ensure j' tnat aud".s and revien at th' --

  • st? nd environmental monitoring programs i*

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I TER-C5506-97 are properly conducted. The Licensee's administrative structure designates the Nuclear Safety Audit and Review (NSAR) Committee as the group responsible j for review of the proposed changes to the PCP and the ODCM. Audits are performed under the cognizance of the NSAR; these audits encompass the ODCM, the PCP, and any other area of facility program. Audits of the environmental 4 monitoring program are covered by the Licensee's existing Techn' cal Specifications, and the Licensee stated that audits of the qualit assurance

] program are currently covered by the requirements of Regulatory Gu de 1.33 and i the plant's Quality Assurance Program. It is determined that the Licensee-proposed administrative structure satistactorily meets the intent of NUREG-0472.

G 3.2.10 Procedures and Records Tne objective of the RETS with regard to procedures is to satisty the provisions for written procedures specified in NUREG-0472 tor implementing the ODCM and the PCP. It is also an objective of RETS to properly retain the W documented records related to the environmental monitoring program and certain QA procedures. The Licensee has made a commitment to establish, implement, I and maintain written procedures for PCP and ODCM. The Licensee stated thdt the RETS monitoring program and their implemented procedures will ne auditable and covered by the Licensee's existing technical specifications and quality assurance program. It was determined (18) that the Licensee meets the intent of NUREG-0472. The Licensee intends to retain the records of analyses required by the radiological environmental monitoring program that would permit evaluation of the accuracy of the analysis at a later date. It is thus determined that the Licensee has 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 addi13U'strative 7 controls is to ensure that appropriate periodic and special report:0ere submitted to the FRC.

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

1. Annual radiological environmental operating report. In Section 5.9.1.8 of the Licensee's submittal, a commitment is made to provide an annual radiological environmental surveillance report that

( includes summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities.

i The report also includes the results of land use censuses.

2. Semiannual radioactive effluent release reports. In Section 5.9.1.9 of the Licensee's submittal, a commitment is made to provide semiannual radioactive effluent and solid waste release reports which include a summary or radioactive liquid and gaseous effluents and solid waste released and an assessment of offsite doses. Listings of new locations for dose calculations identitied by the land use 0 censuses as well as any changes to ODCM are also included in the report. The Licensee has also made a commitment to report deviations trom the liquid and gaseous radwaste treatment specitications during the reporting period.

p 3. Special report. The Licensee has made a commitment as prescribed oy

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

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o exceeding liquid ef fluent dose limits according to Specification 3.16.B o exceeding gaseous effluent dose limits according to Specitications D 3.17.B. and 3.17.C n o exceeding total dose limits according to Specifications 3.16 and 3.17 o exceeding the reporting levels ot' Table 4.8-3 for the radioactivity measured in the environmental sampling medium.

r These reporting commitments have satistied [18] the provisions ol NUREG-0472.

3.2.12 Implementation of Major Programs One objective of the administrative controls is to ensure that(implemen-tation of major programs such as the ODCM, the PCP, and major chen.es to the radioactive waste treatman* a) 'em felloe ppr-'.-f at- .&c 'strative proce-dures. The Licensee has made a commitment to review, report, and implement i

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major programs such as the ODCM. The Licensee has also made a commitment to review and implement a PCP. Copies of the PCP procedures are available on site for inspection, as is the case with any procedure of the Licensee. The Licensee considers that reporting of major changes to the radwaste treatment system is covered by the existing Technical Specifications. It is 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 maintain the operability of the effluent system. As a minimum, the ODCM should provide equations and methodology for the following topics:

o alarm and trip setpoint on eftluent instrumentation o liquid effluent concentration in unrestricted areas o gaseous effluent dose rate at or beyond the site boundary o liquid and gaseous effluent dose contributions o liquid and gaseous offluent dose projections.

In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, detining 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

~

environmental monitoring program are also needed in the ODCM.

3 3.3.1 Evaluation The Licensee has tollowed the methodology of Regulatory Guide 1.109 (29) to determine the t.larm and trip setpoints for the liquid and gaseous etfluent

monitors. The Licensee has made a commitment to ensure that simultaneous liquid releases from the plant do not exceed the MPC values specified by

.r 10CFR20. '..

e

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TER-C5506-97 j The Licensee has demonstrated the method ot calculating the radioactive liquid concentration by describing in the ODCM the means of collecting and analysing representative samples prior to and after releasing liquid eftluents

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into the circulating water discharge. The method provides added assurance of compliance with 10CFR20 for liquid releases.

L 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 turm with half-lives greater than 8 days are in compliance with 10CFR20. In all cases, the Licensee has used the highest annual average values of relative J

concentration to determine the controlling locations. The Licensee's approach

! or using the MPC values meets the dose rate design objectives and the intent of Regulatory Guide 1.109 on the requirement of 10CFR20.

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

For liquid releases, the Licensee has identified fish and shellfish cona amption and direct radiation from the shoreline deposits as the viable pathways. In the calculation, the Licensee has generally used key parameters

'B that follow the suggested values given in Regulatory Cuide 1.109. The Licensee has used the maximally exposed individual as the reference receptor.

Evaluation of the cumulative dose f rom noble gas releases includes both 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 f' radiatio'n. The Licensee has used the maximum annual average relative concentration (X/Q) and has followed the methodology and parameters of f Regulatory Guide 1.109.

For iodine-131, iodine-133, tritium, and particulates with half-lives l greater than 8 days, the Licensee has provided a method to demonstrate that cumulative doses calculated f rom the release meet both quarterly InIL. annual avsign objectives. The Licensee has demonstrated a method of calcu bting the

'o dose using maximum annual average relative concentration (X/Q) for the inhalation pathway and has included annual average deposition parameter (D/Q) tor the leafy vegetable pathway and the grass-cow-milk pathway tor ingestion.

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

. . . - - .--__ ___- .. - _ __ _- 18--__ = _ - _ _ _ . _ - _ - _ - - _ _ - _ - - _ _ _ - - . - _ - _

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TER-C 5506 -97

, Adequate flow diagrams defining the ef fluent paths and components of the il radioactive liquid and gaseous waste treatment systems have been provided by

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

The Licensee has provided a description of sampling locations in the ODCM k

i and has identified them in Table 4.1 of the submittal. This description is consistent with the sampling locations specified in the Licensee's Table 4.8-1 on environmental monitoring.

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

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4. CONCLUSIONS i
Table 1 summarises the results of the final review and evaluation of ti.e RETS submittal for the Maine Yankee Atomic Power Station proposed Radiological Effluent Technical Specitications (RETS) . The evaluation was based on tne 4

g Licensee's final submittal of the RETS and ODCM. The following conclusions were reached:

1. The Licensee's proposed Radiological Ef tluent Technical Specifications (RETS), submitted May 8, 1985 [17], meet the intent of
NUREG-0472, for " Radiological Effluent Technical Specifications."
2. The Licensee's Of fsite Dose Calculation Manual (ODCM), suomitted May 8, 1985 [17), uses documented and approved methods that are generally

. consistent with the criteria of NUREG-0133 and applicable to Maine Yankee Atomic Power Station. It is thus an acceptable reterence.

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TER-C5506-97 Table 1. Evaltation of Proposed Radiological Effluent Technical Specifications (RETS), Maine Yankee Atomic Power Station Technical Specifications Replaces NRC Staff or Updates Std. RETS Licensee Existing NUREG-0472 Proposal Tech. Specs.

L (Section) * (Section) (Section) Evaluation Etfluent 3/4.3.3.3.10 3.28.A To be added Meets the intent

Instrumentation 3/4.3.3.3.11 3.28.B to Appendix A ot NRC criteria

. Radioactive 3/4.11.1.1 3.16.A 3.16.A Meets the intent Ettauent 3/4.11.2.1 3.17. A 3.17.A of NRC criteria Concentrations

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!u Offsite Doses 3/4.11.1.2, 3/4.11.2.2, 3.16.B 3.17.B 3.16.A 3.17.A Meets the intent of NRC criteria 3/4.11.2.3, 3.17. C 3/4.11.4 Effluent 3/4.11.1.3 3.16.C 3.16.B Meets the intent r Treatment 3/4.11.2.4 3.17.D 3.17.B of Nhc criteria Radioactivity 3/4.11.1.4 NA To be added Meets the intent Inventory Limits 3/4.11.2.6 3.17.E to Appendix A of NRC criteria

. g ,,

W Explosive Gas 3/4.ll.2.5B 3.17.F To be added Meets the intent Mixtures to Appendix A of NRC criteria on an interim basis Solid Radioactive 3/4.11.3 5.5.B 5.5.B Meets the intent p Waste of NRC criteria Environmental 3/4.12.1 4.8 4.8 Meets the intent

. Monitoring of NRC criteria

  • Audits and 6.5.1, 6.5.2 5.5.B 5.5.B Meets the intent Reviews of NRC criteria r

Procedures and 6.8, 6.10 5.5.B.9 5.5.B.9 Meets the intent Records of NRC criteria

f Reports 6.9 5.9 5.9 Meet.s the intent of NaC criteria
f *k Implementation of 6.13, 6.14, 5.5.B.9 5.5.B.9 Meets the intent l'

Major Programs 6.15 of NRC criteria

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

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5. REFERENCES l
1. " Radiological Effluent Technical Specifications for Pressurized Water

! Reactors," Rev. 2 NRC, July 1979 NUREG-0472

2. Title 10, Code of Federal Regulations, Part 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, 'As Low As Is Reasonably Achievable,' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Ef fluents"

] 3. Title 10, Code of Federal Regulations, Part 50, Appendix I,Section V, g " Effective Dates"

4. Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation" lD
5. Title 40, Code of Federal Regulations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations"
6. Title 10, Code of Federal Regulations, Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants"
7. Title 10, Code of Federal Regulations, Part 50, Appendix B, " Quality

, Assurance Criteria for Nuclear Power Plants ano Fuel Reprocessing Plants"

8. " Radiological Effluent Technical Specitications for Boiling Water keactors," Rev. 2 NRC, July 1979 0 NUREG-0473

'Q 9. " Preparation of Radiological Effluent Technical Specitications for

' []

Nuclear Power Plants, A Guidance Manual tor Users of Standard Technical Specifications" NRC, October 1978 NUREG-0133

, 10. C. Willis and F. Congel (NRC)

" Summary of Draf t Contractor Guidance of RETS" Presented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19, 1982

. 11. F. Congel (NRC) "-

Memo to RAB Staff (NBC) ~?

i Subjects Interim Changes in the Model Radiological Effluent' Technical Specifications (RETS)

August 9, 1982 l

- - - - - , , - - , , . - , - , - , - - - - - - , , , - - , - - - - - - - - - - - - - - - - .- , - - - - - - - - - - - - - - - - - - a-.,- - n,

I l TER-C5506-97 I 12. " Radiological Ef fluent 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 Ef fluent Technical Specification, Maine Yankee Atomic Power Station k Maine Yankee Atomic Power Company March 15, 1979 NRC Docket No. 50-309
14. Oftsite Dose Calculation Manual m

Maine Yankee Atomic Power Station Maine Yankee Atomic Power Company May 14, 1979 NRC Docket No. 50-309

'0 15. " Comparison of Specification NUREG-0472, Radiological Effluent Technical Specifications for PWRs vs. Maine Yankee Radiological Ef fluent Technical Specifications" (Dratt)

'0 Franklin Research Center, June 15, 1982

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16. Letter of Transmittal

{

Subject:

Trip Report on Site Visit to Maine Yankee Atomic Power Station (July 7-8, 1982)

., Franklin Research Center

17. J. B. Randazza (Maine Yankee Atomic Power Company)

Letter of Trar.smittal to NRC h

U

Subject:

Maine Yankee Atomic Power Station - Request for Amendment May 8, 1985 NRC Docket No. 50-309

18. W. Meinke (NRC) '

Memo to S. Pandey (FRC)

Subject:

Resolution of Discrepancies in RETS Submittal of May 8,1985, tor Maine Yankee Atomic Power Station May 17, 1985

19. " Comparison of Specification NUREG-0472, Radiological Ef fluent Tecnnical Specifications for PWRs, vs. Licensee Final Submittal, dated May 8,1985, of Radiological Etfluent Technical Specifications tor Maine Yankee Atomic Power Station" Franklin Research Center, June 1985 . . . .

..r-t 20. C. Willis (NRC)

  • ii Letter to S. Pandey (FRC) -

g, s

Subject:

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

November 20, 1981

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21. C. Willis (NRC)

Letter to S. Pandey (FRC)

Subject:

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

22. C. Willis and F. Congel (NRC)

I " Status of NRC Radiological Effluent Technical Specification Activities" b

Presented at the AIF Conference on NEPA and Nuclear Regulations, Washington, D.C.

Octooer 4-7, 1981 j 23. C. Willis (NRC)

Memo to P. C. Wagner (NRC)

" Plan for Implementation of RETS for Operating Reactors

  • Novemoer 4,1981
24. W. P. Gammill (NRC)

Memo to P. C. Wagner (NRC)

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

25. "An Acceptable Radiological Environmental Monitoring Program" Radiological Assessment Branch Technical Position, Revision 1 a NRC, November 1979
26. W. P. Gammill and F. J. Congel (NBC)

I* Memo to ETSb/RAB (NRC)

" Radiological Effluent Technical Specifications (RETS) Provisions for I-133" Novemoer 29, 1982

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

NRC, February 1980 NUREG-0543 p 28. " General Contents of the Offsite Dose Calculation Manual," Revision 1 Branch Tech,nical Position, Radiological Assessment Branch NRC, February 8, 1979

~i 29. " Calculation of Annual Doses to Man from Routine Releases of Reactor Ef fluents for the Purpose of Evaluating Compliance with 10CFR50, g

Appendix I" a NRC, Octooer 1977 _ . , ,

Regulatory Guide 1.109, Rev. 1 . 7-l{