ML20136G188

Radiological Effluent Tech Spec Implementation,Millstone Point Nuclear Power Station Unit 1, Technical Evaluation Rept

ML20136G188
Person / Time
Site:	Millstone
Issue date:	07/23/1985
From:	Supotz S CALSPAN CORP.
To:	NRC
Shared Package
ML20136G192	List: ML20136G188 ML20138R188 ML20138R213 ML20138R226
References
CON-NRC-03-81-130, CON-NRC-3-81-130 TAC-8115, TER-C5506-98, NUDOCS 8507250213
Download: ML20136G188 (31)

Text

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• TECHNICAL EVALUATION REPORT -

i NRC DOCKET NO. 50-245 FRC PROJECT C5506 NRC TAC NO. 8115 FRC ASSIGNMENT 4 NRC CONTRACT NO. NRC43-81-130 FRCTASK 98

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! RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATION IMPLEMENTATION (A-2)

NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE POINT NUCLEAR POWER STATION UNIT 1 TER-C5506-98

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Prepared for  ;

FRC Group Leader: S. Pandey Nuclear Regulatory Commission

E Washington,D.C. 20555 NRC Lead Engineer: F. Congel C. Willis July 23, 1985 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 impiled, or assumes any legal liability or )

responsibility for any third party's use, or the results of such use, of any information, appa-

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ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.

Prepared by: Reviewed by: Approved by:

bb.G Llc El Group Leader Y ,fWDepartmDntfirecdr l Principal 1lthor Date: vh 2H C Date: IlA2lb'5 Date: i~I'~ W l FRANKLIN RESEARCH CENTER OlVIsloN OF ARVIN/CALSPAN

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CONTENTS Section Title Page 1 INTRODUCTION . . . . . . . . . . . . . 1 1.1 Purpose of Review . . . . . . . . . . . 1 1.2 Generic Background. . . . . . . . . . . 1 1.3 Plant-Specific Background . . . . . . . . . 3 2 REVIEW CRITERIA. . . . . . . . . . . . . 5 3 TECHNICAL EVALUATION . . . . . . . . . . . 7 3.1 General Description of Radiological Effluent System . . 7 3.2 Radiological Effluent Technical Specifications. . . . 8 c .; Offsite Dose Calculation Manual . . . . . . . 17 4 CONCLUSIONS. . . . . . . . . . . . . . 20 5 REFERENCES . . . . . . . . . . . . . . 22 I .

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• TER-C5506-98 I FIGURES Number Title Page f

1 Liquid Radwaste Treatment Systems, Ef fluent Paths, and Controls for Millstone Point Nuclear Power Station Unit 1. . 8

't 2 Gaseous Radwaste Treatment Systems, Effluent Paths, and controls for Millstone Point Nuclear Power Station Unit 1. 9 ll .

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Cumber Title Page

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, 1 Evaluation of Proposed Radiological Effluent Technical Specifications (RETS), Millstone Point Nuclear Power Station Unit 1 . . . . . . . . . . . . . . 21

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. . TER-C5506-98 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 8 assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by ll the NRC.

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1. INTRODUCTION ,

1.1 PURPOSE OF REVIEW The purpose of this technical evaluation report (TER) is to review and evaluate the proposed changes in the Technical Specifications of Millstone Point Nuclear Power Station Unit I with regard to Radiological Effluent 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 boiling water reactors (BWRs), NUREG-0473 [1] .

This effort is directed toward the NRC objective of implementing RETS which comply principally with the regulatory requirements of the Code of 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 4

i compliance.

1.2 GENERIC BACKGROUND l Since 1970, 10CFR50, Section 50.36a, " Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide j

technical specifications which ensure that radioactive releases will be kept cs low as reasonably achievable (ALARA). In 1975, numerical guidance for the ALARA requirement was issued in 10CFR50, Appendix I [3]. The licensees of all operating reactors were required to submit, no later than June 4,1976, their proposed ALARA Technical Specifications and information for evaluation in cccordance with 10CFR50, Appendix I.

However, in February 1976, the NRC staff recomunended that proposals to modify Technical Specifications be deferred until the NRC completed the model RETS. The model RETS deals with radioactive waste management systems and cnvironmental monitoring. Although the model RETS closely parallels 10CFR50, Apoendix I requirements, it also includes provisions for addressing'other

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issues.

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l 'ihese other issues are specifically stipulated by the following a

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regulations:

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.

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

. Plants," contains Criterion 60 - Control of releases of radioactive 4 materials to the environment; Criterion 63 - Monitoring fuel and waste storage; and Criterion 64 - Monitoring radioactivity releases.

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

J The NRC position on the model RETS was established in May 1978 when the I $

NRC's Regulatory Requirements Review Committee approved the model RETS:

NUREG-0473 [1] for BWRs and NUREG-0472 for pressurized water reactors (PWRs)

[8]. Copies were sent to licensees in July 1978 with a request'to submit proposed

• site-specific RETS on a staggered schedule over a 6-month period.

Licenseep responded with requests for clarifications and extensions. I

! e j The Atomic Industrial Fortun (AIF) formed 'a task force to comunent on the ablRETS. 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 AIF and others. A principal change was the transfer of much of the material concerning dose calculations from the model RETS to a separate ODCM.

l The revised model RETS was sent to licensees on November 15 and 16, 1978 f with guidance (NUREG-0133 [9]) for preparation of the RETS and the ODCM and a ii new schedule for responses, again staggered over a 6-month period.

Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subsequently, Revision 2 of the model RETS and additional guidance on the ODCM were issued in February 1979 to each utility at individual meetings. In response to the NBC's request, operatJny reactor licensees subsequently submitted initial proposals on 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.

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As the RETS review process has progresse'd since September 1981, feedback from the licensees has led the NRC to believe that modification to some of the guidelines in the current version of Revision 2 is needed to clarify specific concerns of the licensees and thus expedite the entire review process.

r starting in April 1982, NIC distributed revised versions of RETS in draft form to the licensees during site visits. The new guidance on these changes was

presented at the AIF meeting on May 19, 1982 [10). Some interim changes regarding the Radiological Environmental Monitoring Section were issued in 1982 [11, 12]. With the incorporation of these new changes, NRC issued, in if , December 1983, a draft version of NUREG-0473, Revision 3 [13), to serve as new guidance for the review teams.

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1.3 PLANT-SPECIFIC BACKGROUND In response to the NRC's request, the Licensee submitted a RETS proposal

[14] on behalf of Millstone Point Nuclear Power Station Unit 1, dated September 19, 1979. This proposal also included a submittal of the ODCM

[15]. In the RETS submittal, the Licensee generally followed the model RETS i format (NUREG-0473) for BWRs. Initial review of the Licensee's submittal was performed in October 1981 by an independent review team at Franklin Research n Center (FRC). The Licensee's submittal was compared with the model RETS and assessed for compliance with the requirements as stipulated.

Copies of the draft review, dated October 30, 1981 [16], were delivered 1 to the NRC and the Licensee prior to a site visit by the independent review team.

!$ The site visit was conducted on November 12-13, 1981 by the reviewers 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 ODCM. The technical deficiencies in the Licensee's proposed RETS were considered, and deviations from NRC guidelines were pointed out. Upon conclusion of this meeting, many of the differences were clarified and resolved; only a few items remained open, pending justification from the Licensee. These major issues are susaarizsd in Reference 17.

TER-C5506-98 Under a cover letter dated May 29, 1985 [18], Northeast Nuclear Energy Company delivered its final submittals on RETS and ODCM* to the NRC. Copies of these submittals were transmitted to FRC for review. The Licensee's RETS submittal was evaluated against NUREG-0473, Draft Revision 3 [13] . The ODCM was evaluated according to the existing guidelines specified by NUREG-0133

[9).

The review also incorporated the additional guidance that FRC received 3

from the NRC staff on plant-specific issues [19]. Details of the RETS review

. were documented in the comparison copy [20).

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• fhe 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 consists of t.wo parts: Section I, the Radiological Effluent Monitoring

, Manual, and Section II, the Offsite Dose Calculation Manual (ODCE).Section I s

, contains the affluent sampling program, radiological environmental monitoring program, and report contents, which are part of the standard RETS. Thus, the

} RETS referred to hereafter in this report would consist of the proposed

" Millstone Point Nuclear Power Station Unit 1 Radiological Effluent Technical

. Specifications" and Section I of the REMODCM, whereas the ODCM refers to Section II of the REMODCM.

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2. REVIEW CRITERIA .

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

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

3 Twelve essential criteria are given for the RETS and ODCM i

l. All significant releases of radioactivity shall be controlled and monitored.

? 2. Offsite concentrations of radioactivity shall not exceed the l 10CFR20, Appendix B, Table II limits.

3. Offsite radiation doses of radioactivity shall be ALARA.

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

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e Radweste tank inventories shall be limited so that failures will not cause offsite doses exceeding 10CFR20 limits.

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

% 7. Wastes shall be processed to shipping and 2N rial ground criteria

under a documented program, subject to quality assurance verification.

8. An environmental monitoring program, including.a land-use census and an interlaboratory comparison program, shall be implemented.

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$ 9. 'Ihe radweste management program shall be subject to regular audits

/ and reviews.

10. Procedures for control of liquid and gaseous effluents shall be maf r.tained and followed.

11. Periodic and special reports on environmental monitoring and on releases shall be submitted.

12. Offsite dose calculations shall be performed using docMnted and approved methods consistent with NRC methodology.

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• TER-C5506-98 Subsequent to the publication of NUREG-0472 and NUREG-0473, the NRC staff issued guidelines [21, 22), clarifications [23, 24], and branch positions [25, 26, 27, 28] establishing a policy that requires the licensees of operating 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 l have clarified the model RETS implementation for operating reactors.

Review of the ODCM wds based on the following NRC guidelines Branch

'[ Technical Position, " General Content of the Offsite Dose Calculation Manual"

[29]; NUREG-0133 [9); and Regulatory Guide 1.109 [30]. The ODCM format is k

g left to the licensee and may be simplified by tables and grid printouts. l I

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3. TECHNICAL EVALUATION 3.1 GENERAL DESCRIPTION OF RADICLOGICAL EFFLUENT SYSTEMS This section briefly describes the liquid and gaseous radwaste affluent systems, release paths, and control systems installed at Millstone Point Nuclear Power Station Unit 1, a BWR. 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 I reactor is also located immediately to the south of Unit 2, a PWR.

3.1.1 Radioactive Liquid Effluent The liquid radioactive wastes at Millstone Point Nuclear Power Station Unit 1 consist of four types: equipment drain wastes, floor drain wastes,

, chemical wastes, and detergent wastes. The bulk of high purity wastes comes from the reactor coolant, condensate, and feedwater systems. Following

• processing and batch sampling, the liquid is pumped to the condensate storage tank for reuse in the plant or discharge offsite. All these wastes are discharged in batches into the discharge canal for release. Also joined into I

the circulating water and released to the environment is the continuous disharge of service water. The above effluent treatment systems and flow I

paths are shown in Figure 1.

J 3.1.2 Radioactive Gaseous Effluent -

The main condenser offgases from Millstone Point Nuclear Power Station Unit 1 are processed and routed to the main stack (375 feet high) for dilution and discharged to the atmosphere (see Figure 2). The substreams also routed to the plant stack are the gland seal / mechanical vacuum pumps' discharges, and

, discharges from the turbine building, the radwaste building, and the reactor building. The gaseous radwaste system consists of a delay line for condenser offgas, which provides approximately 5 minutes of decay time prior o release via the stack, and a series of the charcoal delay beds.

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Figure 1. Liquid Radwaste Treatment Systems, Effluent Paths, and Controls, Millstone Point Nuclear Power Station Unit 1 l

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Figure 2. Gaseous Radwaste Treatment Systems, Effluents Paths, and Controls, Millstone Point Nuclear Power Station Unit 1  ;

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3.2 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICNTIONS ~h The present evaluation of the Licensee's proposed RETS against t e (1) a review of litformation provisions of NUREG-0473 included the following (2) a discussion of provided in the Licensee's 1979 draft submittals [14,15), [17), and (3) a problem areas in those submittals by means of a site visit 29, 1985 final submittal [18).

3 review of the Licensee's May l3

.) 3.2.1 Effluent Instrumentation i is to The objective of the RETS with regard to effluent instrumentat d. Hone RETS i

ensure that all significant releases of radioactivity are mon tore it be p

specify that all effluent monitors be operable and alarm / trip setpo n s determined to ensure that radioactivity levels do not exceed the maximum To further ensure that the i permissible concentration (MPC) set by 10CFR20. d d in

'G instrumentation functions properly, surveillance requirements are nee e g

the specifications.

, @A Radioactive Liquid Effluent Monitoring Instrumentation 3.2.1.1 l t line A radiation monitor has been installed for the liquid eff uen i floor (Figure 1) which receives effluent releases fromhequipment e monitor has dra ns, drains, chemical waste, and detergent waste systems.W e Licensee als

- automati'c isolation capabilities.

for the service water line. nce These existing monitoring capabilities have provided adequate assura

${ i id affluent that the provisions of NUREG-0473 for the radioactive l qu I

monitoring instrumentation are met.

Radioactive Gaseous Effluent Monitoring Instrumentation 3.2.1.2 i The condenser air ejector is equipped with a noble gas monitor.

l i a stack, which The Licensee also has provided radiation monitors for lthe Un t include a noble gas monitor and iodine and particulate samp ers.

have met The existing monitoring capabilities provided fluent by themonitoring Licensee the intent of NUREG-0473 for radioactive gaseous ef instrumentation.

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, . TER-C5506-98 3.2.2 Concentration and Dose Kates of Effluents ,

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3.2.2.1 Liquid Effluent Concentration In Section 3.8.C.1 of the Licensee's submittal, a commitment is made to maintain the concentration of radioactive liquid effluents released from the cite to within 10CFR20 limits, and if the concentration of liquid effluents exceeds these limits, the concentration will be restored to within the MPC limits specified in 10CFR20. Both batch and continuous radioactive liquid cffluent releases are sampled and analyzed periodically in accordance with a campling and analysis program (Table C-2,Section I of the Licensee's REMODCM submittal), which meets the intent of NUREG-0473.

It is determined that the Licensee-proposed specification meets the intent of NUREG-0473 with respect to liquid effluent concentration.

l Gaseous Effluent Dose Rate 3.2.2.2

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In Section 3.8.D.1 of the Licensee's submittal, a ccennitment is made to I

maintain the offsite gaseous dose rate due to radioactive materials released

'i in gaseous effluents from the site to areas at and beyond the site boundary to within 10CFR20 limits, or the equivalent dose rate values prescribed by ,

Section 3.11.2.1 of NUREG-0473. If the dose rate of gaseous effluents exceeds ,

these limits, it will be restored to a value equal to or within these limits.

This comunitment satisfies the provisions of NUREG-0473.

The radioactive gaseous waste sampling dnd analysis program (Table D-2,

.. Section I of the Licensee's REMODCM submittal) provides adequate sampling and

cnalysis of the vent discharges, including the substreams, and therefore meets the intent of NUREG-0473.

3.2.3 offsite Doses from Effluents The objective of the RETS with regard to offsite doses from effluents is to ensure that offsite doses are kept ALARA and are in accordance-with

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10CFR50, Appendix I, and 40CFR190. %e Licensee has made a commitme,nt to (1) r meet the quarterly and yearly dose limitations for liquid effluents, per 4

Section II.A of Appendix I, 10CFR50; (2) restrict the air doses for beta and j gasuna radiation from the site to areas at and beyond the site boundary as cpecified in 10CFR50, Appendix I, Section II.B; (3) maintain the dose level at and beyond the site boundary from releases of iodine-131, iodine-133, tritium, l

cnd all radionuclides in particulate form with half-lives greater than 8 days l

within the design objectives of 10CFR50, Appendix I, Section II.Cr and (4) limit the annual dose including direct radiation from significant plant

sources to any member of the public to within the requirements of 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

'l catisfy the intent of NUREG-0473.

I I 3.2.4 Effluent Treatment

i The objectives of the RETS with regard to effluent treatment are to

4) Casure that wastes are treated to keep releases ALARA and to satisfy the

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

In the proposed Radiological Effluent Monitoring Manual, Sections C-2 and Ii D-2, the Licensee has made a casunitment to use the liquid and gaseous radweste treatment systems to reduce the radioactive materials in liquid and gaseous wastes prior to their discharge when the estimated doses exceed the prescribed

, ' Cose limits. These proposed dose limits ares  ;

!I a. Liquid radwaste treatment system. Proposed estimated dose limits are 0.06 mrem to the total body or 0.2 arem to any organ when averaged over 31 days, as specified by the model RETS.

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

The Licensee has r.ade an additional commitment to set a limit of 0.3 ~

area to any organ due to gaseous particulate effluents.

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'he Licensee's commitments meet the int'ent of NUREG-0473 with respect to ,

effluent treatment. .

3.2.5 Radioactivity Inventory Limits The objective of the RETS with regard to tank inventory limits is to ensure that the rupture of a radweste tank would not cause offsite doses greater than the limits set in 10CFR20 for 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-0473. For the main condenser offgas system, the Licensee proposed to limit the noble gas in process radioactivity release rate to within 1.46 x 106 uci/sec.

The Licensee's submittal regarding the radioactivity inventory limits thus meets the intent of NUREG-0473.

j 3.2.6 Explosive Gas Mixtures '

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

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

In Specification 3.8.D.5 of the Licensee's submittal, a commitment is made to limit the concentration of hydrogen in the main condenser offgas treatment to less than 4% by volume. The Licensee has also provided a j

hydrogen monitor to continuously monitor for the possibility of an explosive j gas mixture concentration in the waste gas holdup system.

As in the previous reviews of other plants, it is determined that the Licensee meets the intent of NUREG-0473 in the interim until the NRC completes its study of the explosive gas problem.

3.2.7 Solid Radweste system '

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The objective of the RETS with regard to the solid radweste system is to ensure that radweste will be properly processed and packaged before it is shipped to a burial site. Specification 3.11.3 of NUREG-0473 provides for the

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establishment of a Process Control Program (PCP) to show compliance,with this objective. Although the Licensee has not provided a technical specification regarding the solid radwaste treatment, the Licensee has made a commitment (Section 6.17 under the Administrative Controls) to establish and implement a l I

! PCP and thus to ensure that radwaste is properly processed and packaged before '

1 it is shipped to the burial site. This was determined [18] to meet the intent of NUREG-0473.

' 3D.2 . 8 Radiological Environmental Monitoring Program I The objectives of the RETS with regard to environmental monitoring are to ensure that an adequate and full-area-coverage monitoring program exists and that the 10CFR50, Appendix I requirements for technical specifications on environmental monitoring are satisfied. In all cases, the Licensee has s generally followed NUREG-0473 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 i applicable to land pathways. The Licensee's methods of analysis and

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maintenance of yearly records satisfy the NRC guidelines and meet the intent

l 'of 10CFR50, Appendix I.

'% The Licensee has also' made a comunitment to document l

i l the~ new environmental monitoring sample locations in the Annual Radiological l Environmental operating Report, which meets the intent of NUREG-0473. He l specification for the land use census satisfies the provisions of Section

] 3.12.2 of WUREG-0473 by providing for an annual census in the specified areas. Se Licensee participates in an interlaboratory comparison program i

approved by the NRC and reports the results in the Annual Radiological

Environmental Operating Report, which also meets the intent of NUREG-0473.

j 3.2.9 Audits and Reviews

The objective of the RETS with regard to audits and reviews is to ensure i

! that audits and reviews of the radwaste and environmental monitorin'g programs -

t l are properly conducted. The Licensee's administrative structure designates j the Plant Operation Review hitee (PORC) as the group responsible for review 1

of the proposed changes to the Technical Specifications, the PCP, and the 3

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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 interit of NUREG-0473.

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-0473 for implementing the ODCM and the PCP. It is also an objective of RETS to properly retain the documented records related to the environmental monitoring program and certain QA procedures. The Licensee has made a comunitment to establish, implement, '

and maintain written procedures for the PCP, the REMODCM, and the QA program for effluent and environmental monitoring. S e 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-0473. '

l 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 WUREG-0473:

1. Annual radiological environmental operating report. In Section 6.9.1.10 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. His commitment was considered [18] to meet the poporting provisions of NUREG-0473.

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2. Semiannual radioactive effluent release reports. In Section 6.9.1.11 l

of the Licensee's submittal, a commitment is made to provi4e 4 semiannual radioactive effluent release reports which include l information delineated in the proposed REMODCM. This casunitment was considered to meet the reporting provisions of NUREG-0473.

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3. special report. The Licensee has made a casunitment as prescribed by the proposed specification to file with the NRC a special report in 30 days from the end of the quarter under the following conditions: i t

5 o exceeding liquid effluent dose limits according to specification

3.8.C.2 o exceeding gaseous effluent dose limits according to Specifications l 3.8.D.2 and 3.8.D.3 1

f o exceeding total dose limits according to specification 3.8.D.4

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

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l o proposed REMDOCM for the radioactivity measured in the '

environmental sampling medium.

The Licensee has also made a constituent to file with the NIC a special i report under the following conditions:

i o exceeding liquid radioactive waste treatment limits according to Section I (C.2) of the proposed REMODCM.

s

o exceeding gaseous radioactive waste treatment limits according_to i

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

I

, These, reporting commitments have satisfied [18] the provisions of i

l MUREG-0473. .

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3.2.12 Isolementation of Major Programs I

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

J j implement major programs such as the RENDDCM. S e Licensee has also made a j commitment to review and implement a PCP. S e Licensee considers that reporting of sujer changes to the radweste treatment system is covered by the I existing Technical Specifications. It was determined (18] that the Licensee's i

l commitments meet the intent of NUREG-0473. l d

i l

, , TER-C5506-98 3.3 OFFSITE DOSE CAIEULATION MANUAL (ODCM) ,

As specified in NUREG-0473, the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the effluent system. As a minimum, the ODCM should provide equations and methodology for the following topics:

o alarm and trip setpoint on effluent 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 effluent dose projections.

In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems. A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

! 3.3.1 Evaluation The Licensee's ODCM is contained in Section II of the proposed P?.MODCM.

The Licensee has followed the methodology of NUREG-0133 [9] to determine

- the alarm and trip setpoints for the liquid 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

, release points.

The Licensee has demonstrated the method of calculating the radioactive liquid concentration by describing in the ODCM the means of collecting and cnalyzing representative samples prior to and after releasing liquid effluents into the circulating water discharge. The method provides added assurance of

~

compliance with 10CFR20 for liquid releases. t Methods are also included for showing that the air maximum psrmissible concentration (MPC) at or beyond the site boundary due to noble gases, iodine-131, iodine-133, tritium, and radionuclides in particulate form with i

1 I

l L i ,

TER-C5506-98

. i half-lives greater than 8 days is in compliance with 10CFR20. In all cases, the Licensee has used the highest annual average values of relative-concentration (X/Q) to determine the controlling locations. %e Licensee's i

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

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

j For liquid releases, the Licensee has ident'ified saltwater fish and a' chellfish consumption, and direct radiation frota shoreline sediments as the viable p'athways. In the calculation, the Licensee has generally used key parameters that follow the r<uggested values given in Regulatory Guide 1.109.

p The Licensee has used the maximally exposed individual as the reference r ceptor.

Evaluation of the cumulative dose from noble gas releases includes both beta and gamma and air doses at and beyond the site boundary. The critical organs under cons!deration are the total body for gamma and skin for beta rndiation. The Licensee has used the maximum annual average relative concentration (X/Q) and has followed the methodology and parameters of Regulatory Guide 1.109.

3 1

Foriodine-131, iodine-133, tritium [andparticulateswithhalf-lives

greater than 8 ' days, the Licensee has provided a method to demonstrate that j cumulative doses calculated from the release meet both quarterly and annual

) design objectives. The Licensee has demonstrated a method of calculating the dose using maximum annual average relative concentratilon (X/Q) for the inhala-tion pathway and has included annual average deposition parameter (D/Q) for the leafy vegetable pathway and the grass-cow-milk pathway for ingestion.

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

Adequate flow diagrams defining the affluent paths and components of the r:dioactive liquid and gaseous waste treatment' systems have been prov'ided by the Licensee. Radiation monitors specified in the Licensee-submitted RETS are alto properly identified in the flow diagrams.

i l

g=- - y.c--y,---,wg .ey--- . _ . , . . -, -

- , - , - , - ,_,--,v.

O

,' ,, s TER-C5506-98 The Licensee has provided a description of sampling locations ,in the ODCM and has identified them in Appendix G of the submittal. This description is consistent with the sampling locations specified in the Licensee's Table E-1 on environmental monitoring.

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

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

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4. CONCLUSIONS Table 1 sununarizes the results of the final review and evaluation of the RETS submittal for the Millstone Point Nuclear Power Station Unit 1 proposed Radiological Effluent Technical Specifications (RETS). The evaluation was -

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

1.

The Licensee's proposed Radiological Effluent Technical

,g Specifications (RETS), submitted May 29, 1985 (18), meet the intent of NUREG-0473, for " Radiological Effluent Technical Specifications."

. 2.

The Licensee's Offsite Dose Calculation Manual (ODCM), submitted May 29, 1985 [18), uses documented and approved methods that are generally consistent with the criteria of NUREG-0133 and applicable to Millstone Point Nuclear Power Station Unit 1. It is thus an acceptable reference.

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G G

O I

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e s *

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• TER-C5506-98 ,

Table 1. Evaluation of Proposed Itadiological Effluent Technical Specifications (RETS), Millstone Point Nuclear Power Station " Unit 1 Technical Specifications Replaces NRC Staff or Updates Std. RETS Licensee Existing NUREG-0473 Proposal Tech. Specs.

(Section)* (Section) (Section) Evaluation Effluent 3/4.3.3.3.10 3.8.A 3.8 Instrumentation 3/4.3.3.3.11 3.8.B Meets the intent of NRC criteria Radioactive 3/4.11.1.1 3.8.C.1 3.8 Effluent 3/4.11.2.1 3.8.D.1 Meets the intent concentrations of NRC criteria Offsite Doses 3/4.11.1.2, 3.8.C.2 To be added 3/4.11.2.2, 3.8.D.2 Meets the intent .

to Appendix A of NRC criteria 3/4.11.2.3, 3.8.D.3 3/4.11.4 3.8.D.4

, Effluent 3/4.11.1.3 C.2 (REM)** Appendix B Treatment 3/4.11.2.4 Meets the intent D.2 (REM)** -

of NRC criteria Radioactivity 3/4.11.1.4 NA NA Inventory Limits 3/4.11.2.6 NA Meets the intent-NA of NRC criteria Explosive Gas 3/4.11.2.5B 3.8.D.5 NA Mixtures Meets the intent of NBC criteria

~

on an interim basis solid Radioactive 3/4.11.3 6.17 NA Meets the intent Waste of NRC criteria Environmental 3/4.12.1 E (REM)** Appendix B Monitoring Meets the intent of NRC criteria Audits and 6.5.1, 6.5.2 6.5.3, 6.5.4 6.5.1, 6.5.2 Reviews Meets the intent of NRC criteria Procedures and 6.8, 6.10 6.8, 6.10 6.8, 6.10 4

Records Meets the intent of NRC criteria Reports 6.9 6.9 6.9 Meets the intent of.NSC criteria Implementation of 6.13, 6.14, 6.16, 6.17

. Major Programs To be added Meets the intent 6.15 1 i

to Appendix A ofINRC criteria  !

"Section number sequence is according to NUREG-0473, Rev. 3, Draft 7" [13).

e a TER-C5506-98 l

\

, 5. REFERENCES. , j

1. " Radiological Effluent Technical Specifications for Pressurized Water l Reactors," Rev. 2 l NRC, July 1979 )

NUREG-0473 1

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 Effluents"

3. Title 10, Code of Federal Regulations, Part 50, Appendix I,Section V,

" Effective Dates"

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 Protection Standards for Nuclear Power Operations" i

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 and Fuel Reprocessing Plants"

8. " Radiological Effluent Technical Specifications for B' oiling Water Reactors," Rev. 2 NRC, July 1979 NUREG-0473

9. " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual- for Users of Standard Technical Specifications" NBC, October 1978 NUREG-0133

10. C. Willis and F. Congol (NRC)

"Susanary of Draft Contractor Guidance of RETS" Presented at the AIF Environmental Subcommittee Meeting, Washington, DC May 19,1982

11. F. Congol (NRC) .

I Memo to RAB Staff (NRC) . .

Subject:

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

August 9, 1982

, ~22-

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• TER-C5506-98 l

12. W. Meinke (FRC) '

Memo to M. Strum (Yankee Atomic Electric Company) .

l

Subject:

BWR-Specific Changes for NUREG-0472/3, Rev. 3 .

l September 20, 1982

13. " Radiological Effluent Technical Specifications for Boiling Water Reactors," Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors NBC, September 1982 NUREG-0473

14. Radiological Effluent Technical Specification, Millstone Point Nuclear Power Station Unit 1 Northeast Nuclear Energy Company September 19, 1979 NRC Docket No. 50-245

15. Offsite Dose Calculation Manual Millstone Point Nuclear Power Station Unit 1 Northeast Nuclear Energy Company September 19, 1979 NRC Docket No. 50-245

16. " Comparison of Specification NUREG-0473, Radiological Effluent Technical Specifications for PWRs vs. Millstone Point Nuclear Power Station Unit 1 Radiologiual Effluent Technical Specifications" (Draft)

Franklin desearch Center, October 30, 1981

17. Letter of Transmittal

Subject:

Trip Report on Site Visit to Millstone Point Nuclear Power Station Unit 1 (November 12-13, 1981)

Franklin Research Center

)

18. , J. F. Opeka (Northeast Nuclear Energy Company)

Letter of Transmittal to NRC .

Subject Millstone Point Nuclear Power Station Unit 1 - Proposed Revisions to Radiological Effluent Technical Specifications May 29, 1985 NRC Docket No. 50-245

19. W. Meinke (NRC)

Memo to S. Pandey (FEC)

Subject:

Resolution of Discrepancies in RETS Submittal of May 29, 1985, for Millstone Point Nuclear Power Station Unit 1 June 2, 1985

20. " Comparison of Specification NUREG-0473, Radiological Effluent Technical Specifications for BWRs, vs. Licensee Final Submittal, dated May 29, 1985, of Radiological Effluent Technical Specifications for Millstone Point Nuclear Power Station Unit 1" Franklin Research Center, July 1985

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21. C. Willis (NRC)

Letter to S. Pandey (FRC) *

Subject:

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

November 20, 1981

22. C. Willis (NIC)

Letter to S. Pandey (FRC)

Subject:

Control of explosive gas mixture in PWRs December 18, 1981

23. C. Willis and F. Congel (NBC)

" 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

24. C. Willis (NRC)

} Memo to P. C. Wagner (NRC) i

" Plan for Implementation of RETS for Operating Reactors" j November 4, 1981 245 W. P. r-anumill (NBC) -

Memo to P. C. Wagner (NRC)

" Current Position on Radiological Effluent Technical Spe::ifications 4

(RETS) Including Explosive Gas Controls" October 7, 1981

26. "An Acceptable Radiological Environmental Monitoring Program" -

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

27. W. P. Gammill and F. J. Congel (NBC)

Memo to ETSB/RAB (NBC)

" Radiological Effluent Technical Specifications (RETS) Provisions for I-133"

, November 29, 1982 3

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

NRC, February 1980 NUREG-0543

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

NRC, February 8, 1979 -

t

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

_,__,m.m_._m.____ . _ . _ _ _ _ , _ , , . . , , , _ _ . . , _ _ . , . _ _ _ _ . , . _ _ _ ., . . _ _ _ _ _

m

1. < ggi 011185 Mr. John F. Opeka A copy of our related Safety Evaluation along with the Technical Evaluation Report prepared 'itt Franklin Research Center is enclosed. This action will appear in the Commission's biweekly notice publication in the Federal Register. The license amendment is effective on January 1, 1986.

Sincerely, psi;;iaal s, .J by John A. Zwolinski, Chief Operating Reactors Branc,5 #5 Division of Licensing

Enclosures:

1. Amendment flo. Ibb to License No. DPR-21

2. Safety Evaluatinn cc w/ enclosures:

See next page DISTRIBUTION EDocket: File $ HThcrpson ELJordan TBarnhart (4)

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