ML20140F307

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Radiological Effluent Tech Specs (RETS) Implementation - Zion Generating Station Units 1 & 2, Informal Rept
ML20140F307
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/30/1985
From: Serrano W
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML20140F312 List:
References
CON-FIN-A-6459 EGG-PBS-6887, NUDOCS 8507110377
Download: ML20140F307 (30)
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Text

s EGG-PBS-6887 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) d

' IWLEMENTATION--ZION GENERATING STATION UNITS 1 AO 2 William Serrano Dougl as W. Aksrs Steven W. Duce Jofo W. Andler Ferrcl B. $1moson Thomas E. Young PuM fshed June 1985 EGLG Idaho, Inc.

Idaho Falls, Idaho 83415 P

Frepared (c," t?3 11.5 Lelear Regulatory Ccatssters We5hItigton. C.C. 2C555 Under DOE Contreet No. DE-AC07 7 TID 0470 rIN 14. A6459 y .rcano371 I

-.--. /

/ XA

. . - - + . .. -

. ABSTRACT A review of the Radiological Effluent Technical Specifications (RETS) of the Zion Generating Station Units 1 and 2 was performed. The principal review guidelines used were NUREG-0133, ' Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," and Draft 7" of NUREG-0472. Revision 3. " Radiological Ef fluent Technical Spectf tcations for Pressurfred Water Reactors." Draft submittels were discussed with the Licensee by both EG&G and the NRC staff untti all items requiring changes to e

the Technical Specifications were resolved. The Licensee then submitted

.- final proposed RETS to the NRC which were evaluated and found to be in coeplianes with the NRC review guidelines. The proposed Offsite Dose Leiculation Manual was reviewed and generally found to be consistent with the NE review guidelines.

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. FOREWORD This Technical Evaluation Report was prepared by EGAG Idaho, Inc. under a contract with the U. S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Systems Integration) for technical assistance in support of NRC operating reactor licensing actions. The -

technical evaluation was conducted in accordance with criteria established by the NRC.

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CONTENTS ABSTRACT .............................................................. t FORDWORD .............................................................. 11 1.

I NTROD UCTI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1. . . . . . . . . . .

1.1 Pu rpose o f t he Techn ic al Eval u at ion . . . . . . . . . . . . . . . . . . . . . . . . 1 1.2 Gen e r i c I s su e Ba ck g rou n d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.3 Pl ant-Sp ec i f ic Back g rou n d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.

RE VI EW C R I TE R I A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 . . . . . . . . . . . .

3.

TECHNI C AL E VAL U ATI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6. . . . . . . . . . . .

3.1 General Description of Radiological Efylvent Systems ....... 6 3.2 Ra d iol ogic al E f fl u ent Techn ic al Spec if ic at ions . . . . . . . . . . . . . 7 3.3 Of fs ite Dose Cel cul at ion Manu al . . . . . . . . . . . . . . . . . . . . . . . . .19 ...

4.

C ONC L U S I ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21. . . . . . . . . . . . .

5.

RE F E RE NC E S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 . . . . . . '. . . . . . .

FIGURES

1. Zion Station liquid radweste treatment and discharge pathways .... 8
2. Zion Station gaseous radweste treatment and discharge pathways ... 9 TABLE
1. Correspondence of provisions of NUREG-0472, the Licensee's current technical spectf1 cations and the Licensee's proposal fo r t he Z i on Generat i ng Stat ion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 l

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1. INTRODUCTION 1.1 Purnese of the Techn teal Evaluat ton The purpose of this Technical Evaluation Report (TER) is to review and evaluate the proposed changes in the Technical Specifications of the Zion

The evaluation used criteria proposed by the Nuclear Regulatory Conctssion (NRC) staff in the model Technical Specifications for pressurized water reactors (PWRs), NUREG-0472.Il3 and subsequent revisions. This effort is directed toward the MtC objective of implementing RETS which comply with the regulatory requirements, primartly those of 10 CFR Part 50.

Appendix I.[2] Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.

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1.2 Generte Innue Raekereund Since 1970, 10 CFR Part 50, Section 50.36.a,[33 ' Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide Technical Specifications which ensure that radfoactive releases will be kept as low as *s reasonably echievable (ALARA). In 1975, numerical guidance for the ALARA requirement was issued in 10 CFR Part 50,

  • Appendix 2

' The licensees of all operating reactors were requiredI43 to submit, no later than June 4,1976, their proposed ALARA Technical i

Specifications and information for evaluation in accordance with 10 CFR Part 50, Appendix I.

However, in February 1976, the NRC staff recessnended that proposals to not:1fy Technical Specifications be deferred unt11 the NRC completed the model RETS.

The model RETS deal with radioactive waste management systems and environmental monitoring. Although the model RETS address the 10 CFR 1

n Part 50, Appendix ! requirements, subsequent revisions include provisions ,

These provisions are for addressing is' sues not covered in Appendix I.

stipulated in the following regulations:

o 10 CFR Part 20,I53 " Standards for Protection Against Radiation " > -

Sections 20.105.c 20.106.g and 20.405.c which require thr.t l

j' nuclear power plants 'and other Licensees comp 15 with 40 CFR Part 190,I63 eEnvironmental Radiation Pmtec. tion Standards for '

Nuclear Power Operations,' and submit- reports to the E when the 40 CFR Part 19011eits have been er may be exceeded.

10 CFR Part 50, Appendix A,C73' General Design Criteria for o

Nuclear Power Plenty," which contains Critetton 60-Control of L

releases of radioactive materials to the enstronment; Critertem 63--Monitoring fuel and waste storage; and '

Criterion 64--Monitoring radioactive releases.

o 10 CFR Part 50, Appendix 8,C8] which establishes the gus11ty assurance required for nuclear power plants.

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

NUREG-0472 for PWRs and NUREG-0473 for boiling water reactors (StRs).

Copies of the model RETS were sent to licensees in July 1978 with a request to submit proposed site-specific RETS on a staggered schedule over a ,

six-month period. Licensees responded with requests for clarifications and

  • extensions.

The Atomic Industrial Forum ( AIF) formed a task force to comment on l

Mt0 staff mesters first met with the AIF task force on June 17,

' model RETS.

1978, The model RETS were subsequently revised (Revision 1) to reflect comunents from the AIF and others. A principal change was the transfer of much of the material concerning dose calculations from the model R fS to a separate document, the 00CM.

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Revision 1 of the model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133)[93 for preparation of the RETS and the ODCN and a new schedule for responses, again staggered over a six-month per t o'd. -

i Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subsequently, a prelteinary copy of Revision 2 of the model RETS and additional guidance on the ODCM and a Process Control Program (PCP) were issued in February 1979 to each utt11ty '

at individual meetings. NUREG-0472, Revision 2E13 and NUREG-0473,

, Revision 2 Il03 were published in July 1979 and updated in January 1960 and February 1980. In response to the NRC's request, operating reactor licensees subsequently submitted initial proposals on plant RETS and the 00CM.

Review leading to ultimate implementation of these documents was initiated by the NRC in September 1981 using subcontracted independent teams as reviewers.

As the RETS reviews progressed, feedback from the licensees led the NRC to modify some of the provisions in the February 1,1980 version of Revision 2 to clarify specific concerns of the licensees and thus expedite the reviews. Starting in April 1982, the NRC distributed revised versions of RETS in draft fort to the licensees during the site visits. The new guidance on these changes was presented in an AIF meeting on Nay 19,

, 1982.I113 Some interie changes regarding the Radiological Environmental Monitoring Section were issued in August 1982.[123 With the incorporation of these changes, the NRC issued Draft 7" of Revision 3 of NUREG-0472E133 #

and NUREG-0473Cldl in September 1982 to serve as new guidance for the j review teams.

1.3 Plant - Snecif fe Backeround On February 16, 1979, the Commonwealth Edison Company (CECO), the Licensee of the Zion Generating Station Units 1 and 2, submitted proposed RETS and 00CM to NRC.[153 The purpose was to revise the Zion Station Technical Specifications to conform to the requirements of 10 CFR Part 50, 3

l I

Appendix l. FG&G Idaho, Inc., (EG8G). selected as an independent tasr review team, prepared a review and evaluation of the RETS proposal. The proposal was compared to the model RETS and assessed for compliance with the requirements of 10 CFR Part 50. Appencix 1, and 10 CFR Part 50 Appendix A.

Review coments and questions dated January 19,1982[16) were mailed to the NRC prior to arranging a site visit with the Licensee. The site visit (February 8, 1982) was arranged for the purpose of discussing and clarifying ouestions icentified in the review of the draft submittal. .

i

  • The Licensee submitted a revised draft RETS with letter dated October '

2,1984.[173 A review of the October 1984 draft RETS was made by EG&G and l

review comments transmitted to NRC with letter dated October 29, 1984.[183 The NRC transmitted a copy of the review comments to the Licensee with NRC letter dated December 12, 1984 [I93 A telephone conference was held on March 19, 1985 between representatives of the Zion Station and the NRC to discuss and resolve the coments transmitted with the The Licensee responded with another proposal enclosec December 1984 letter.

with letter dated June 25,1985.[20) The NRC reviewed the Specifications included in this proposal and transmitted coments to EG4G.[21)

Resolution of all coments allowed the EG&G review team to complete a TER for transmittal to the NRC.

The ODCM is a generic document for the nuclear power plants within the Ceco system with sections specific to each plant within the system.[22)

  • Generic ODCM review coments were submitted by EG&G to NRC with letter dated January 19. 1982.[16] Review comments specific to the Zion Station were transmitted by EG&G to NRC with letter dated November 15, 1984.[233 The NRC transmitted a copy of the 00CM review comments to the Licensee with letter dated December it. 1984.[24) A telephone conference was held on March 13, 1985 between representatives of CECO. the NRC, and EG&G to discuss the outstanding Zion ODCM issues. The conference call resolved all outstanding issues and it was determined the ODCM contains documented and approved methods that are generally consistent with the guidelines of NUREG-0133 anc is therefore acceptable to NRC as a reference.

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2. REVIEW CRITERI A Review criteria for the RETS were provided by the NRC in three documents:
1. NUREG-0472, RET $ for PWRs
2. NUREG-0473, RET 3 for BWRs

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

Twelve essential criterie are given for the RETS and ODCM:

1.

All significant releases of radioactivity shall be controlled and monitored.

2.

Offsite concentrations of radioactivity shall not exceed the 10 CFR Part 20, Appendix B, Table 211mits.[253 3.

Offsite radiation doses shall be ALARA.

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

5.

l Radwaste tank inventories shall be limited so that failures would not cause offsite doses exceeding 10 CFR Part 20 limits. I 6.

Hydrogen and/or Oxygen concentrations in the waste gas system shall be controlled to prevent explosive mixtures.

7.

Wastes shall be processed to shipping and burial ground criteria under a documented program, subject to quality assurance verification.

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8. An environmental monitoring program, including a land use census, shall be implemented. -
9. The radwaste management program shall be subject to regular audits .

and reviews.

10.

Procedures for control of liquid and gaseous effluents shall be maintained and followed. .

11. Periodic and special reports on environmental monitoring and on .

releases shall be submitted.

12.

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

In addition to NUREG-0472 and NUREG-0473 and their subsequent revisions, the l and branch NRC staff issued guidelines, [26,273 clarifications, [288293 positionsC30,31,323 establishing a policy that requires the licensees of I operating reactors to meet the intent, if not the letter, of the model RETS

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The NRC branch positions issued since the RETS implementation requirements.

review began have clarified the model RETS for operating reactors.

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l Review criteria for the ODCM are based on the following NRC Branch Technical Position,

  • General Content of the Offsite Dose, guidelines: .

Calculation Mar.ual;*[333 NUREG-0133;I93 and Regulatory Guide 1.109.C343 The format for the ODCM is left to the licensee and may be simplified by tables and grid printouts.

3.0 TECHNICAL EVALUATION

General Descrietion of Radioloeical Ef fluent Systees 3.1 .

This section contains a brief description of the liquid and gaseous radwaste effluent treatment systems, release paths, and control systems installed at the Zion Generating Station PWRs, Units 1 and 2.

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. 1 3.1.1 Radteactive Lieutd Effluents There are two radioactive effluent release points from the two-unit Zion Station as shown in Figure 1.

The first release point is from batch releases from the Lake Discharge Tanks. Liquid radwaste from either unit is pumped to one of two Lake Discharge Tanks before batch release to Lake Michigan.

The second release point is from the Waste water Treatment Facility.

Low-level radioactive liquid wastes from the fire sump is pumped to the Waste Water Treatment Facility before continuous release to Lake Michigan.

3.1.2 Raeteartive Gameous Effluents A block diagram of the radioactive gaseous release system is shown in Figure 2.

As can be seen from Figure 2, effluentt, are collected in a common header before release from either the Unit 1 or Unit 2 exhaust duct.

Consequently it is difficult to apportion the radioactivity between the two units and allocation will normally be made evenly between units.

3.2 Raefelsefcal Effluent Technteal sneefftentions The following subsections describe the primary objectives of each section of the model RETS and a susunary of the comunitments of the Licensee's RETS.

A cross-reference between the numbering in the model RETS and the Licensee's RETS is contained in Table 1. The chronological sequence of the

  • RETS review was described in the Plant-Specific Background, Section 1.3 of
  • this tsport.

3.2.1 Effluent Instrumentation The objective of the model RETS with regard to effluent instrumentation is to ensure that all significant liquid and gaseous radioactive ef fluents are monitored. The model RETS specify that all effluent monitors be operable with periodic surveillance and that alars/ trip setpoints be 7

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~~~~l Lake Discharge Tanks I OR-PR04 OA Lake Michigan Liquid e l  ; ;

Radwaste 03 OR-PROS i

L _ _. _ J 6 Turbine Building OR-PR25 Waste O- ,

1 I

Lake Michigan Turbine Butiding Floor Fire Sump I

jl Waste Water Treatment Factitty r

and Equipment Drain Fire Sump Pumps Tanks Fimsre 1 Zion Station liquid radwaste effluent pathway.

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Unit 1 Exhaust Duct Unit 2 Exhaust Duct IRT-PR25 2RT-PR25 -

O O

{ ~ K R-PR09 O OR-0014 Q \/ R- M40 R-PR09 ~l Unit 1 P-PR40 d

Unit 2 SO Containment Containment II OR-PR22 OR-PR36 -

OR-PRIO f~l R-0015 O -

"~" -

- ~

R-0015

"-""'5 Gas

  • n#

L

?2 **

p--------- ,

Building i Unit 1 Unit 2  !

Auxiliary Condenser Condenser Building l Air l

! Air and I Ejector Ejector Miscellanesou Vents l l

! OR-PR18 l l L _ _ __ __ --- __ - - - - ]

U' ' R-PR49 Turbine Buf1 ding e.

Figure 2 Zion Station gaseous radwaste effluent pathways.

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I determined in orJer to ensure that offsite radioactive effluent concentrations do not exceed maximum pomissible concentrations (WCs) listed in 10 CFR Part 20.

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' The Licensee has provided radiation monitors for all effluent lines '

with potential for release of significant amounts of radioactivity in liquid )

l or gaseous effluents.

l 3.2.1.1 Radioactive Liouid Effluent Instra==ntation l Instmment channels ORTPR04 and ORTPROS are used to monitor all -

j releases from the lake discharge tanks. On high alare the monitor automatically initiates closure of a valve to prevent further release. The discharge value is kept closed and tagged out of service at all times except l 1

during the discharge. The lake discharge tanks are sampled and quantified before release. The flow rate is determined from flow rate monitoring l l devices.

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' The discharge line from the fire sump pumps to the Waste Water -

Treatment Facility is continuously monitored by instrument channel ORTPR25. f On high alam the monitor automatically trips all of the ff re sump pumps.

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l The fire sus, is sampled and quantified daily and the flow rate is determined based on pump capacity and run time.

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The Licensee's RETS identifies acceptable surveillance checks to be perfomed on the liquid effluent instrumentation.

3.2.1.2 Radioactive caseous Ef fluent instrumentation The block diagram of Figure 2 shows the position of the gaseous l effluent monitors. The vaste gas decay tacks are monitored with noble gas monitors OR-PRio and iodine and particulate monitors OR-PR100. On high alarm the noble gas monitor automatically initiates termination of release.

The flow rates are determined using flow rate measuring devices.

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1 The auxiliary building ventilation and miscellaneous areas ventilation are released through the auxiliary building exhaust duct. On high alarm from the noble gas monitor the operator is alerted to take action that will reduce the release rate.

The effluents are also monitored for todine and particulate releases with OR-PRIS and RfR49.

The air ejector effluents are monitored for noble gases with R-0015 and for iodine and particulate releases with R-PR26.

  • On high alars, the containment purge noble gas monitors R-PR09A  !

j automatically initiate termination of release. The effluents are also

  • monitored for iodine and particulate releases with instrument channels R-PR09 and R-PR40.

Service building effluents are monitored for noble gases with OR-PR22 and for iodine and particulates with ORfR36.

Flow rate monitoring devices are included for the stack, air ejector, j and waste gas releases.

( The sampler flow rate monitors are not specifically identified as they are a component of the radiation monitors.

i Each monitoring system has acceptable surveillance checks that meet the intent of NUREG-0472.

3. 2.1. 3 tieutd and anneous Instrumentation sateoints t

The Licensee's Technical Specifications require that the instrument setpoints for the radioactive liquid effluents be set to ensure that concentrations of radioactive material released from the site be limited to within the 10 CFR Part 20 concentrations. The setpoints for the radioactive gaseous affluent instrumentation are set to ensure the dose rates of NUREG-0472 are not exceeded. The setpoints stil be set in accordance with the methodology in the 0004 The Licensee's RETS submittal on liquid and gaseous effluent monitoring f instrumentation has satisfied the provisions and meets the intent of NUREG-0472.

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3.2.2 concentration and Done Rates of Effluents 3.2.2.1 _Linuid Ef fluent cancentration_

The Licensee's RETS include a coseitsent to maintain the concentration of radioactive liquid effluents released from the site to within 10 CFR *

. Part 20 limits. Both batch and continuous radioactive liquid releases are sampled and analyzed periodically in accordance with an acceptable sampling and analysis program.

Therefore, the Licensee's RETS submittal on liquid effluent concentrations meets the intent of NUREG-0472. .

3. 2. 2. 2 Gaseous Effluent Dose Rate The Licensee's RETS include a couaitment to maintain the gaseous dose Both batch and continuous rate from the site to within NUREG-0472 limits.

radioactive gaseous releases are sampled and analyzed periodically in accordance with an acceptable sampling and analysis program.

Therefore, the Licensee's RETS submittal on gaseous effluent dose rates meets the intent of NUREG-0472.

3 2.3 Offsite Doses free Effluents The objectives of the model RETS with regard to offsite doses from effluents are to ensure that offsite doses are kept ALARA, are in compliance._

with dose specifications of NUREG-0472 and are in accordance with 10 CFR l

Part 50, Appendix I and 40 CFR Part 190.

f The Licensee's RETS include a cosnitment tot

1. Limit the quarterly and annual dose due to liquid effluents to within the NUREG-0472 criteria allowed for the two units at the site.

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2.

Limit the quarterly and annual air dose from the site due to noble gas releases to within the NUREG-0472 criteria.

3.

Limit the quarterly and annual dose to any organ due to Folease of todine-131, tritium, and radionuclides in particulate form with half-lives greater than eight days from the site to within the NUREG-0472 criteria. .

4.

Limit releases such that the dose or dose casunitment to a member of the public from all uranium fuel cycle sources is within the 40 CFR Part 190 limits.

Therefore, the Licensee's RETS submittal on offsite doses from radioactive effluents meets the intent of NUREG-0472.

3.2.4 Effluent Treatment i

The objectives of the model RETS with regard to effluent treatment are to ensure that the radioactive waste treatment systems are used to keep releases ALARA and to satisfy the provisions for Technical Specifications governing the maintenance and use of radwaste treatment equipment.

The Licensee's RETS include a comenttment to use the liquid radwaste

' treatment system when the projected monthly doses exceed 25 percent of the 1 annual dose design objectives for the two-unit site. The projections are to

' be made at least once per 31 days in accordance with the methodology in the .*

00CM.

A specification requiring use of the gaseous radwaste treatment equipment is not included since the Zion gaseous radwaste treatment equipment is in continual use.

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Therefore, the Licensee's RETS submittal on effluent treatment meets tt.e intent of NUREG-0472.

3.2.5 Tank Inventerv tirits The objective of the model RETS with regard to a curie limit on liquid-containing tanks is to ensure that in the event of a tank rupture, the concentrations in the nearest potable water supply and the nearest surface water supply in an unrestricted area would not exceed the limits of 10 CFR Part 20, Appendix B Table II. The objective of the model RETS with ,

regard to a curie limit on gas-containing tanks is to ensure that in the event of an uncontrolled release of the tank's contents the resulting total ,

body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rom.

The Licensee's Specifications limits the quantity to 10 curies of radioactive liquid in outdoor liquid tanks. The Licensee's Specifications limit the quantity of radioactivity in each gas decay tank to 22,000 curfes (considered as Xe-133). This is less than the quantity required that would result in a 0.5 rem dose at the nearest unrestricted area boundary.

Therefore, the Licensee's RETS submittal on tank inventory limits meets the intent of NUREG-0472 3.2.6 rwelesive nas wirtures  :

The objective of the model RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in the waste gas system.

The Licensee's Specification limits the concentration of hydrogen and oxygen in the waste gas system to less than or equal to 35 by volume.

Appropriate actions are required in the event the concentrations exceed 35

' by volume.

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As in the case of other plants, the Licensee's submittal on explosive gas mixtures is accepted on an interi1 basis until NRC develops final guidance on monitoring and control of explosive gas mixtures.

3.2.7 Solid Radweste System The objective of the model RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged oefore it is shippec from the plant to the burial site to satisfy the recuirements of 10 CFR Part 20, Section 20.301 and 10 CFR Part 71.[35)

The Licensee's RETS include a comitment to use the solid radwaste system in accordance with a Process Control Program to process wet radioactive wastes to meet shipping and burial ground requirements.

Therefore, the Licensee's RETS submittal on solid radioactive waste meets the intent of NUREG-0472.

3.2.8 Radiolocical Environmental Monitorino Procram The objectives of the model RETS with regard to a radiological environmental monitoring program are to ensure that (a) an adequate full-area coverage environmental monitoring program exists (b) there is an appropriate land use census, and (c) an acceptable Interlaboratory Comparison Program exists.

The monitoring program implementsSection IV.B.2 .

l .

of Appendix ! to 10 CFR Part 50, the land use census satisfies the reouirements of Section IV.B.3 of Appendix I to 10 CFR Part 50, and the reautrement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks are performed as part l

of the cuality assurance program for environmental monitoring to demonstrate that valid results are optained for Section IV.B.2 of Appendix ! to 10 CFR Dart 50.

l The Licensee's RETS on a radiological environmental monitoring program nave fc11 owed the model RETS and the Branch Technical Position on the subject issued November 1979,E313 as applicable to the site, and have l 15 l

provided an adequate number of sample locations for pathways identified.

The Licensee's method of sample analysis and maintenance of the monitoring The program satisfies the requirements of Appendix I,10 CFR Part 50.

Licensee's RETS contain a land use census specification which requires The RETS also state that the sufficient annual information for a PWR. .

Licensee will participate in an NRC approved Interlaboratory Comparison P rogram.

Thus, the Licensee's RETS submittal for a radiological environmental prograrr. meets the intent of NUREG-0472.

3.2.9 Audits and Reviews l

The objective of the model RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring

! programs are properly conducted.

The Licensee's administrative t'.;ructure identifies the Onsite Review and Investigative Function and the Offsite Review and Investigative Function as the two groups comparable to the Unit Review Group (URG) and the Company Nuclear Review and Audit Group (CNRAG), respectively.

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The Onsite Review and Investigative Function has responsibility for reviewing changes to the 00CM and the PCP.

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  • l The Offsite Review and Investigative Function has responsibility for auditing the Radiological Environmental Monitoring Program at least once overy 12 months, the ODCM at least once overy 24 months, the Process Con Program and implementing procedures at least once per 24 months, and the performance of activities required by the Quality Assurance Program to meet the criteria of 10 CFR 50, Appendix B.

Therefore, the Licensee's requirements for audits and reviews meet the intent of HUREG-0472.

16 I . _ - _ - _ _ . _ . . _ - - __ _

3.2.10 procedures and Records The objective of the mocel RETS with regard to procedares is to ensure that written procedures be established, implemented, and ruintained for the pCp, the ODCM, and the QA program for effluent and envircnmental monitoring. ,

The objective of the model RETS with regard to records is to ensure that documented records pertaining to the radioltgical environmental monitoring program are retained for the duration of the Operating License.

The Licensee's RETS include a requirement to establish. implement, anc maintain written procedures for the radwaste solidification program (PCp) and the dose evaluation program (ODCM). Quality assurance program procedures for effluent and environmental monitoring shall be aodressed in the Quality Assurance program.

The Licensee's RETS state that records of Offsitt Environmental Monitoring surveys snail be retained for the duration of the Operating License.

Therefore, the Licensee's RETS submittal on crocedures and records meets the intent of NUREG-0472.

3.2.11 Reports The objective of tne mocel RETS with regard to reporting requirements .'

is to ensure that appropriate annual and semiannual periodic reports and special reports are suDmitted to the NRC.

The Licensee's RETS include commitments to submit the following reports:

1.

Annual Radiological Environmental Operatino Report This report will be submitted by April 30 of the next year. The report shall include:

o Results of the radiological environmental saroling program, o

An assessment of the monitoring results and radiation doses via the principal pathways of exposure.

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o Results of land use census.

o Sureary of meteorological conditions concurrent with the release of gaseous effluents.

o A map of all sampling locations.

o Results of participation in the Interlaboratory Comparison Program.

]

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2. Famiannual Radiametive Ef fluent Relamme Ranort The report submitted within 60 days after January 1 and July 1 of each year shall cover the radioactive content of effluents released to The data ,

vnrestricted areas during the previous six months of operation.

shall be in the format of Regulatory Guide 1.21. Revision 1, June 1974.

1 The report shall include a summary of solid easte shipped offsite r

daring the reporting period; a svanary of unplanned releases from the site 1.o unrestricted areas; any changes to the Process Control Program made an annual summary of hourly meteorological data during the reporting period collected over the previous year; an assessment of radiation doses from liquid and gaseous effluents; and an assessment to demonstrate compliance to 40 CFR 190.

It was determined that the Licensee's RETS submittal on reports meets the intent of NUREG-0472.U13 3.2.12 Other Adrinistrative controls An objective of the model RETS in the administrative controls section is to ensure that any changes to the PCP and CDCM and major changes to the radioactive vaste treatment systems are reported to the NfC.

The Licensee's Specification requires that changes to the CDCM and PCP be reported to the NRC by inclusion in the Monthly Operating Report within 90 days of the ef fective date of the ch'ange.[213 18 i

i

- , , - . , , . ---..,...-..n, . . , . _ . . . , . , . , - , - . _ _ . . _ , , - - - - - - - , - - - , . , . - . . . , , , - - - - - - . , , . .

Therefore, the Licensee's RETS submittal for these administrative controls meets the intent of NUREG-0472.

3.3 Offsite Deze calculation Manual As specified in NUREG-0472, the CDCM f a to be developed by the Licensee to document the methodology and approaches used to calculate offstte doses and maintain the operability of the effluent system. As a minimum, the 00CM should provide equations and methodology for the following topics:

o alarm and trip setpoints for effluent instrumentation o

liquid effluent concentration in unrestricted areas o

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

liquid and gaseous effluent dose contributions o

total dose compliance, including direct shine o

liquid and gaseous effluent dose projections.

In addition, the 00CN should contain flow diagrams, consistent with the systems being used at the station, deffntng the treatment paths and the components of the radfoactive 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 00CM.

i 3.3.1 Evaluatten The Licensee's 00CM satisfies the equation in the addendum of NUREG-0133 to determine the alarm and trip setpoints for the liquid effluent monitors.

This assures that the alarm and trip actions will occur prior to l exceeding the 10 CFR Part 20, Appendix B Table II values at the discharge point to the unrestricted area.

! 19 r

e

! The alarm and trip setpoints for the gaseous effluent monitors are calculated to assure that alars and trip actions will occur prior to exceeding the limits set in 10 CFR Part 20 for annual dose rates to unrestricted areas. The Licensee uses equations similar to those contained in NUREG-0133 with the dose rate values indentified in NUREG-0472. .

The Licensee's 00CM contains the methods and calculational relationships that are used to compare the radioactivity concentrations at the point of release to the 10 CFR Part 20 limits prior to the release anc .

after the release.

The Licensee's 00CM states that noble gas discharges are assured to be within the NUREG-0472 dose rate limits by correctly deterstains the setpoints for the noble gas monitors. The dose rate due to the release of I-131, tritium, and particulates with half-lives greater than eight days is assured to be within the NUREG-0472 limit of 1500 mrom per year by calculating the dose rate to a child via the inhalation pathway due to the l

actual release using the highest calculated annual average relative concentration X/Q used for estimating dose to an individual.

f The Licensee's 00CM demonstrates compliance with 10 CFR Part 50, i

Appendix I by calculating the monthly dose comettaents for liquid and

gaseous effluents at least once per 31 days. The calculated cumulative -

values are compared to the quarterly and annual limits to demonstrate cocpliance.

The Licensee's ODCM will contain the dose projection methodology to determine when to use the liquid radwaste trsatment eqsipment.

Specific parameters of distance and the direction sector from the conter11ne of a reactor and additional information have been provided for each and every sample location in the Zion RETS Environmental Monitoring Table 3.16-1, in Tables 8.4-1 and 8.4-3, and in Figures 8.4-1 and 8.4-2 of the Zion 00CM.

20 f -. .- _ - - _ - - _

The Licensee's ODCM for Zion Station Units 1 and 2 is generally in compliance with the NRC requirements and uses methods consistent with the methodology and guidance prescribed in NUREG-0133.

4.0 CONCLUSION

S The Licensee's proposed RETS and ODCM were reviewed and evaluated and the following conclusions were reached:

o The Licensee's proposed RETS for the Zion Station Units 1 and 2 submitted June 25 , 1985 meets the intent of the NRC staff's

" Standard Radioo 1'gical Effluent Technical Specifications for Pressurized Water Reactors", NUREG-0472.

o The Licensee's ODCM. Revision 8 dated March 1983, uses documented anc approved methods that are applicable to the Zion Generating Station Units 1 and 2 and are generally consistent with the guidelines of NUREG-0133. Therefore, the CDCM is an acceptacle continuing reference.

A correspondence between (a) NUREG-0472, (b) the Licensee's current RETS, and (c) the Licensee's proposed RETS is shown in Table 1.

O G

e i

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21 i

TABLE 1.

CORRESPOCENCE OF PROVISIONS OF NUREG-0472, THE LICENSEE'S CURRENT TEC$1 CAL SPECIFICATIONS AND THE LICENSE FOR THE ZION STATION UNITS 1 APO 2. __

Licensee Proposal Current Technical (section) pluREG-Dd72 tomeificatten RETS Renuiracerts 3.11.3 3.11.3. A 3.3.3.10 3.12.3.A Effluent 3.3.3.11 3.12.1.C Instrumentation 3.11.1 3.11.1.A -

3.11.1.1 3.12.1.A Concentration 3.11.2 1 3.12.1

- 3.11.2.A 3.11.1.2 3.12.2.A Offsite Doses 3.11.2.2

- 3.12.2.B 3.11.2.3 3.11.2 3 11.4 3.12.2 3 11.4.A 3.11.1.3 ----

Radweste Treatment 3.11.2.4 3.11 4.6 3.11.5 Tank Inventory 3 11.1.4 3 12.4.A 3.11.2.6 3.12.4 Limits -

3.12.5 3.11.2.5.A Explostve Gas Mixtures 3 20.1.A 3.11.3 Solid Radwaste 3.16 3 16.1 .

Environwental Monitoring 3.12.1 3 16 3.16.2 3.12.2 Land Use Census 3 16.3 Interlaboratory Comparison 3.12.3 6.2 6.1 7.B 6.5.1 6.1 7.A Audits and Reviews 6.5 2 6.1

~~- 6.1.7.A.5 6.6 6.5.2.F Procedures and Records 6.10 6.5.B 6.6 6.6.3 6.9 Reports

- 6.6.2.D.5 6.13 6.7 Other Adrintstrative 6.14 Controls 6.15 22

5. REFERENCES
1. United States Nuclear Regulatory Consission, Standard RadicloeicgL Ef fluent Technical innef f tentions for Frannart2nd Watar Raaetoes, NUREG-0472, Revision 2, July 1979,
2. United States Office of The Federal Register, Title 10, Na of radmeal _ '

Regulations, Part 50, Appendix I, *Nunortcal Guides for Design Objectives and Lietting Conditions for Operation to Meet the Criterton .

'As Low as is Reasonably Achievable' for Radioactiva Material in Light-Water-Cooled Nuclear Power Reactor Effluents.'

r

3. United States Office of the Federal Register, Title 10, cada of radaral Regulations, Part 50, Section 50.36a, ' Technical specifications on Ef fluents from Nuclear Power Reactors.'
4. United States Office of the Federal Register. Title 10, cod
  • ef Faderal  ?

. Bagulatinas, Part 50, Appendix I, Section Y.B., ' Effective Datas."

5. United States Office of the Federal Registo:, Title 10, cede of Fgd Regulations, Part 20, " Standards for Protection Against Radiation."
6. United States Office of the Federal Register, Title .40, hof Faderal i

Regulations, Part 190, ' Environmental Radiation Protection Standards for Nuclear Power Operations.'

7. United States Office of the Federal Register Title 40, code of radaral l Regulations, Part 50, Appendix A, " General Design Criterta for kuclear Power Plants."
8. United States Office of the Federal Register, Title 10, code of Fader 1 Reculations, Part 50, Appendix B, "bality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.a
9. United States Nuclear Regulatory Commission, Pranaratton of_

l

  • Radielocical Effluent Technical Scacif fea+ f ona fer huelaar_ Power

, Flacia, NUREG-0133, October 1978.

  • 10. United States Nuclear Regulatory Constssion,11&Dhrd Radielegical l Ef fluent Technical Seselfications for Reiling Water Raartsrz, NUREG-0473, Revision 2, July 1979.

I 11. C. A. Willis and F. J. Congel, *$usuary of Draft Contractor Guidance cf RETS, 'MF Environmental sube-ittee usettne. wanhtncton. D c.r, May 19, 1982.

12. F. J. Congel, memo to RAB Staff (NRC), Intarte changen in the Model_

i E IA, August 9, 1982.

13. United States Nuclear Regulatory Commission, standard Raefelegied.

Ef fluart Technical feecificat f oes for Pressur12a1 Water Raaetors, ,

NUREG-0472, Revision 3, Draf t 7", September 1987.

l l 23 1

L. I J

c

14. United States Nuclear Regulatory Come.issich, st.ndard Radl_deeteel ,

Ef fluent Technical teacifications_ for Ibillne Watar Rameters. I NUREG-0473, Revision 3. Draf t 7". Septester 1962.

ParoosFD

15. Letter f rw C. Reed, CECO, to H. R. Dentoa, NE, subject)

CHMGES TO F Acf LITY OPERATf MG LTPfW'I NDS. OPR tu AND '#M, February 16, 1979.

16. Letter f ree T. B. Stepson EG4G, to C. A. Willis, MC, subject: ,

TRANSPITTE OF fM5TIONS FOR T)*E P0teOWE ALTM *lET1 REitIEW__K1152,42, J anuary 19, 1967.

17.

Letter f rom R. N. Cascarano, CECO, to H. R. Denton, AC, Subject, M .

GENERAT1hG STA90N LW1151_AWD 7 Pn0P34m TECHNTaAt 9ETIFIC g gg;3,g g DockrT NOS. W-79t. A2 EG 4fg, October 2,1984, 3[11f1fi

18. Letter frce W. Ser rana, EGtG, to C. L. M111af NAC,

Subject:

210N DW7_MTS - Larr-2bM, October 29,19M.

19. Letter f rom 3.f.. Vergh, NN, to D. L. f &f rar, CCCo,

Subject:

MDS FATIow sa TS CDEEEII. Occescer 12, 1964.

Lsttar from CECO to MC, ifoh GENER1TTNa STATT2 ' win i Aw3 2,E:1go,QegL 20.

Ig(ygAl SPE9IFICATIONE NRC CCCWf NDF, ED-79.WjrAC4, June 75, 1765

21. Correspondenco f ree C. R. Nichcis. NT , to W. Serrano, 'fG&6, 3ubjecf.i II0fi37sn rfTs. 'sumalT1 AL, June 18,1985.
22. Letter from Ceco te NRC, futiset Jien CLG Rav!sion B, March 1983,
23. Letter free W. Seerano, EG4G, to C. L. Miller, HPC, 6ubject: QLSC2 .

Eg12ry - sere.*>9.fA, f hovescer 15, 1984 Letter f rom S. A. Varga, '#E, to D. L. Farrst, Ceco, subject: EQS 24 STATION of#U REVIf1cMEMTS, Decceter 12,1(84. 2 23, United States Office of The Federal Registere Title 10, Cadr cLEt.att.A1.-

4 Est,y_1_atiers, Part 20. Appendix 3, Concetitrat19er in Air atid ' aster Above Natural Backg/ our.d."

2e. C. A. yt:115, tetter to F. B. Sieg,sor. (susenartzing chuges tc PETS regairements following meeting eith Atceic Industrial Torun),

Noveceer 20, 1981.

27. W. I. rreger, M90, memo to R. J. Mattson, NE, E}Aps for i Dealine w11 the__ Eclesivs c.as 1acue in Inispen*jftg.1ht.RafisJg,jst Ef firent Tact nhat scacificatdor s _ FRET!', December 14, 1981, .

-- ~ --

23. C A. > tills and F l. Cor. gal "$tatus et NRC Radtological Ef fluent

'fschric41 Spect f tcation Act141 ties," Atr.wie Industrial recur En-feren e gn hirA med huelaar Racelationa, October 4-7, 1981. _

25.  !

C. A. Willis, Memo to P, C. Wagner, Pinna far imelementintBggjalogtra?

Ef fluart Tach.micai Noveanber J,1931. Seeef fications for Dee atine Reartgtg.

30.

W. P Gair.11, MtC, hemo *,o P. C, Wagner, NRC, Curreht Pnaitten ca_

R&f

  • e l oc ir A1.111]y3n$ Tat ha i ca ! ,$g3cJ f i c a t i us ' iEFT S )

fxrlesive cas co-trals, Octcber 7,1981. Inciuffg 31.

United States kwelear Regulatory Cons!ssion, Radiclogical Assessment branct Teschn(cal Fosition, Ac Areaetagla Radinimigal Environnertal Ponitorine Prcat m_ai, hovember 1979

30. United States Nuclear hogulatorf Comission, Mathada LtWR Coe;11ance with _the EPA lfraniufr real Cvela itandaM fio CF Rfer_ Dammatrat'ng Pat-t__ lenb NWEG-0533, 7ebruary 1983.

33.

United States Nuclear Negu14 tory Cour.1ssion, Branch Tochatcal Pcsition, genera?

Fetruary Conterts 8,1979. of the. Offaite Den

  • Ct Jgulation kaneal, Revision le 34.

Regel.itory Gytde 1.109, " Calculation of Annual Doses to Man from Routints Releases of Aeactor Effluents for the Purpose of Evaluating Corpitance with 10 CFR Part 50, Appendix I "Reviator.1, 0.5. Nuclear Regulatory Comission. Washington, C. C. 20555, October 1377. '

35.

Unites States Office of 'the Federal Register, Title 10, Cada of raden1,,,

Recclatloas, Part 71, ' Packaging of Ractoettive Material f or Transport 316 Transportation tif Radioactive Material Under Certain Cmd1tions."

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Jun, icoe T. E. Young, D. W. AkersW. Serrano. . W. J. W. Mandler. F......

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B. Simpson. .. ,u S --

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Rectation Measurements Section EG8G Idaho. Inc. ' '" "'*"m :

Idaho Falls.' 10 83415

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Division of Systems Integration ... n .. ,

Of f tce of Nuclear Regalatory Research U.S. haclear Regulatory Comission , _-

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of the Zion Generating Station thits The .

1 ons and (RETS) principal 2 was performe Effluent Technical Specifications for Nuclear Power P NUREG-0472. Revtston 3, ' Radiological Ef fluent Technical ,

raft 7" ofS Pressurized Water Reactors.'

e the Technical Specifications werequiring resolved. changes to Licensee by compliance with the NRC review guidelines. u o be in final proposed RE Calculation the MC review golde? Manual fnes,was reviewed and generally found to be coThe proposed nsistent with

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