ML20151S269

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Rev 1.8 to Chapter 12 of Dresden Station Odcm
ML20151S269
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 07/31/1998
From:
COMMONWEALTH EDISON CO.
To:
References
PROC-980731, NUDOCS 9809040097
Download: ML20151S269 (71)


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Document Control Desk Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Station PI-137 Washington DC 20555 August 26,1998 Attach 6d is a revision to the Offsite Dose Calculation Manual, Dresden Annex, Chapter 12.

Please update your manual as follows:

Remove:

Dresden, Chapter 12, Revision 1.7 Insert:

Dresden, Chapter 12, Revision 1.8 S

Please sign below indicating your manual has been updated and that your controlled copy number is correct.

Name Dete Return to:

'~ Comed Procedures Clerk 1400 Opus Place,4th Floor Downers Grove, IL 60515

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-or- A s .

Procedures Clerk 4th Floor ETW 111 7gf a

9909040097 990731 PDR ADOCK 05000010 W PDR

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Change Summary ODCM, Site Annex s- Chapter 12, Revision 1.8 Pagg Chance DescriDtion All Changed header revision number and date to Revision 1.8, July 1998.

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12-2 lnserted the definition of 'Public Dose" (12.1.13) 12-63 New wording was added to section (12.6.3.2.(2)) to reflect the new requirement for independent Technical Review and PORC. '

.. 12-64 (12.6.4.1) was modified to change "On Site Review and investigative Function" to

  • independent Technical Review".

12-64 (12.6.4.1.(7)) was modified to change "On-Site Review and investigative Function" to

  • Independent Technical Review".

12-64 (12.6.4.2) was modified to change "On-Site Review and investigative Function" to

  • Independent Technical Review".

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l Revision 1.8 i July 1996 i

CHAPTER 12.0 i I

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SPECIAL NOTE The requirements of the Technical Opecifications shall take precedence over this chapter, should any differences occur.

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The transfer of the Radiological Effluent Technical Specifications (RETS) to the ODCM for Unit 1 has been approved by the Nuclear Regulatory Commission in Amendment 39.

The transfer of the Radiological Effluent Technical Specifications (RETS) to the ODCM for Units 2 -

and 3 has been approved by the Nuclear Regulatory Commission in Amendments 150 and 145, n;

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DRESDEN R; vision 1.8 .

July 1998 DRESDEN ANNEXINDEX CHAPTER 12 Revision 1.8 I

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DRESDEN Rivision 1.8  !

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^ CHAPTER 12 I RADIOLOGICAL EFFLUENT TECHNICAL STAl4DARDS (RETS)

TABLE OF CONTENTS f.&ftE 12.1 DEFINITIONS 12-1 12.2 INSTRUMENTATION 12-5 A. Radioactrve Liquid Effluent Monitoring Instrumentation 12-5

1. Radioactive Liquid Effluent Monitoring instrumentation Operability 12-5
2. Radcactive Liquid Effluent Monitoring Instrumentation Surveillance 12-5 B. Radioactive Gaseous Effluent Monitoring instrumentation 12-5 l 1. Radioactive Gaseous Effluent Monitoring instrumentation Operability 12 5
2. Radioactive Gaseous Effluent Monitoring instrumentation Surveillance 12-6 C. Liquid and Gaseous Effluents instrumentation Bases 12 19 12.3 LIQUID EFFLUENTS 12-20 A. Liquid Effluents Limits and Reporting Operability 12-20
1. Concentration in Unrestricted Areas 12 20
2. Dose from Liquid Effluents 12-20
3. - Dose Projections 12-21
4. Liquid Radioactive Waste Treatment System 12-22
5. System Operability and Plant Operations 12-22 B. Liquid Effluents Surveillance 12-22
1. Concentration in Unrestricted Areas 12-22
2. Dose from Liquid Effluents 12-23
3. Dose Projectons 12-23 C. Liquid Effluents Bases 12 30
1. Concentration 12-30 1
2. Dose 12-30 l
3. Liquid Waste Treatment 12-30 l l 4. Mechanical Vacuum Pump 12-31 l 12.4 GASEOUS EFFLUENTS 12-32 A. Gaseous Effluents Limits and Reporting Operability 12-32  !
1. Dose Rate 12-32  !
2. Noble Gas Dose 12 32
3. lodine-131, lodine-133, Tritium and Particulate Dose 12-33 l 4. Off-Gas Treatment 12-34

! 5. Main Condenser Air Ejector 12-35

' 6. System Operability and Plant Operations 12-35  ;

B. Gaseous Effluents Surveillance 12-36

1. Dose Rate 12-36

~2. Noble Gas Dose 12-36

3. lodine 131, lodine-133. Tritium and Particulate Dose 12 36
4. Off-Gas Treatment 12 36
5. Noble Gases at the Main Condenser Air Ejector 12-37 9.

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DRESDEN RIvision 1.8 ,

July 1998 . i r

I CHAPTER 12  !

RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS (RETS)  ;

TABLE OF CONTENTS '

, CONTINUED  !

.PAfaE  !

12.4 GASEOUS EFFLUENTS (Cont'd)

.C. Gaseous Effluents Bases 12-43

1. Gaseous Effluents, Dose 12-43
2. Dose, Noble Gases 12-43
3. - Dose, Radioiodines, Radioactive Materialin Particulate Form and Radionuclides Other than Noble Gases 12-44
4. Gaseous Waste Treatment 12-44 [

12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12-45

1. Monitoring Program 12-45 i'
2. Land Use Census 12 59
3. Interlaboratory Comparison Program 12-60 12.6 RECORDKEEPING AND REPORTING 7 12-61

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1. Station Operating Records 12-61
2. Reports 12-61
1. Radioactive Effluent Release Report 12-61 t
2. Annual Radiologcal Environmental Operating Report 12-61
3. Non-Routine Enwnnmental Report 12-62
3. Offsite Dose Calculation Manual (ODCM) 12-63
4. Major Changes to Radioactue Waste Treatment Systems (Liquid and Gaseous) 12-64  !

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DRESDEN R; vision 1.8 July 1998

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' CHAPTER 12 RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS  ;

(RETS)

LIST OF TABLES '

NUMBER IIILE PAGE 12.1 1 Surveillance Frequency Notation 12-3 12.1 2 Operational Modes 12-4 12.2-1 Radioactive Liquid Emuent Monitoring instrumentation 12-7 12.2-2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements 12-9  ;

12.2 3 Radioactive Gaseous Effluent Monitoring instrumentation 12 12 12.2-4 Radioactive Gaseous Effluent Monitoring ,

instrumentation Surveillance Requirements 12-16 '

12.3-1 Allowable Concentration of Dissolved or Entrained Noble Gases Released from the Site to Unrestricted Areas in Liquid Waste 12-24 12.3 2 Radioactive Liquid Waste Sampling and Analysis Program 12-25 12.4-1 Radioactive Gaseous Waste Sampling and Analysis Program 12-38

-12.5-1 Radiological Environmental Monitoring Program 12-48 12.5-2 Reporting Levels for Radioactivity Concentrations in Environmental Samples 12-54 Reporting Levels 12.5-3 Detection Capabilities for Environmental Sample Analysis Lower Limit of Detection 12-55

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. DRESDEN Revision 1.8 July 1998 12.0 RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS

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12.1 DEFINITIONS

1. Dose Eauivalent 1-131 - That concentration of I-131 (microcune/ gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of I 131,1-132,1-133, 1-134, and 1-135 actually present. The thyroid dose conversion f actors used for this calculation shall be those listed in Table til of TID 14844, " Calculation of Distance Factors for Power and Test Reactor Sites".
2. Frecuency Notation- Table 12.1-1 provides the definitions of various frequencies f',r which surveillances, sampling, etc., are performed unless defined otherwise. Refer to Technical Specification Table 1-1.
3. Immediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action.  ;
4. Instrument Calibration - An instrument calibration means the adjustment of an instrument signal output so that it corresponds, within acceptable range and accuracy, to a known value(s) of the parameter which the instrument monitors. Calibration shall encompass the entire instrument, including actuation, alarm, or trip.
5. Instrument Check - An instrument check is qualitative determination of acceptable operability by observation of instrument behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same vanable.
6. Instrument Functional Test - An instrument functional test means the injection of a simulated signal into the instrument primary sensor to venfy the proper instrument response alarm and/or initiating action.
7. Member of the Public - any indiunal except when that individual is receiving an l occupational dose.
8. Mode - Reactor modes are described in Table 12.1-2 (per Technical Specification Table 1-2).
9. Occuoational Dose-The dose received by an individual in the course of employment in which the individual's assigned duties involve exposure to radiation and/or to I radioactive material from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person. Occupational dose does not include

! dose from background radiation, as a patient from medical practices, from voluntary participation in medical research programs, or as a member of the public.

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DRESDEN R: vision 1.8 July 1998 .

12.1 DEFINITIONS (Cordd)

10. The Offsite Dose Calculation Manual (CDCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm / Trip Setpoints, and in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological  !

Environmental Monitoring Programs described in Section 12.5 and (2) descriptions of the

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information that should bo included in the Annual Radiological Environmental Operating 1 and Radioactive Effluent Release Reports required by Sections 12.6.2.1 and 12.6.2.2.

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11. Ooerable - A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, I cooling or seal water, lubrication or other auxiliary equipment that are required for the '

system, subsystem, train, component or device to perform its specified safety function (s) are also capable of performing their related support function (s).

12. The Process Control Procram (PCP) shall contain the current formulas, sampiing, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20,61, and 71, State regulations, burial ground requirements, and other
requirements goveming the disposal of solid radioactive waste.

l 13. Public Dose means the dose received by a member of the public from exposure to l radiation or radioactive material released by

  • V ensee, or to any other source of radiation under the control of a licensee. Public dose oues not include occupational dose or doses

'j' received from background radiation, from any medical adrw .atration the individual has v received, from exposure to individuals administered radioactive material and released in accordance with 10CFR35.75, or from voluntary participation in medical research programs.

14. Rated Thermal Power - Rated thermal power shall be a total reactor core heat transfer rate to the reactor coolant of 2527 thermal megawatts.
15. Reactor Power Ooeration - Reactor power operation is any operation with the mode switch in the "Startup/ Hot Standby" or "Run" position with the reactor critical and above 1% rated thermal power.
16. Source Check The qualitative assessment of Channel response when the Channel sensor is exposed to a radioactive source.

17.

Definitions Related to Estimatino Dose to the Public Usina the ODCM Comouter Prc 1 ram:

1. Actual Refers to using known release data to project the dose to the public for the previous month. These data are stored in the database and used to demonstrate compliance with the reporting requirements of Chapter 12.
2. Projected - Refers to using known release data from the previous month c; estimated release data to forecast a future dose to the public. These draa are NOT incorporated into the database.

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, DRESDEN Revision 1.8 July 1998 TABLE 12.1 1 SURVEILLANCE FREQUENCY NOTATION 1

l. NOTATION FREQUENCY
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l S (Shiftly) At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> l l- D (Daily) At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i

'T At least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />  ;

1 W (Weekly) At least once per 7 days  !

t M (Monthly) At least once per 31 days O (Quarterly) At least once per 92 days l SA (Semiannually) At least once per 184 days  :

1 1 A (Annually) At least once per 366 days l E (Sesquiannually) At least once per 18 months (550 days)

S/U (Startup) Prior to each reactor startup ,

l NA (Not Applicable) Not applicable  ;

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l *Each surveillance requirement shall be performed within the specified time interval with a maximum

! allowable extension not to exceed 25% of the surveillance interval. The bases to Technical Specifications 4.0.8 provides clarification to this statement. These definitions do not apply to the Radiological Environmental Monitoring Program (Section 12.5).

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Revision 1.8 i DRESDEN July 1998 ,

TABLE 12.12 4s OPERATIONAL MODES MODE SWITCH AVERAGE REACTOR MQQF. POSITION S COOLANT TEMPERATURE

1. POWER OPERATION Run Any temperature 2.STARTUP Startup/ Hot Standby Any temperature
3. HOT SHUTDOWN Shutdown (* *' > 212 F
4. COLD SHUTDOWN Shutdown (***) 5212'F
5. REFUELING'" Shutdown or Refuel (*# $ 140*F TABLE NOTATIONS

(*) The reactor mode switch may be placed in the Run, Startup/ Hot Standby, or Refuel position to test the switch interlock functions provided the control rods are verified to remain fully inserted by a second licensed operator or other technically qualified individual.

  • The reactor mode switch may be placed in the Refuel position while a single control rod driva is '

being removed from the reactor pressure vessel per Technical Specification 3.10.l. ,

i* Fuel in the reactor vessel with one or more vessel head closure bolts less than fully tensioned or

' with the head removed.

'S See Technical Specification Special Test Exceptions 3.12.A and 3.12.B. i

'*' The reactor mode switch may be placed in the Refuel position while a single control rod is being moved rsrovided the one-rod-out interlock is OPERABLE.

  • Wnen i ' no fuel in the reactor vessel, the reactor is considered not to be in any OPERA, JAL MODE. The reactor mode switch may then t's in any position or may be inoperable.

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- DRESDEN Revision 1.8 j July 1998 1 12.2 INSTRUMENTATION A. Radioactive Liauid Effluent Monitorina instrumentation 1

1. Radioactive Lioutd Effluent Monttonna Instrumentation Ooerability i
1. The effluent monitoring instrumentation shown in Table 12.2-1 shall be operable with alarm trip setpoints set to insure that the limits of Section 12.3.A are not exceeded. The alarm setpoints shall be determined in accordance with the ,

ODCM. )

2. With a radioactive liquid effluent monitonng instrument alarm / trip setpoint less i conservative than required, without delay suspend the release of radioactive I liquid effluents monitored by the affected instrument, or declare the instrument inoperable, or change the setpoint so it is acceptably conservative.
3. With one or more radioactive liquid effluent monitoring instruments inoperable, take the action shown in Table 12.2-1. Retum the instrument to operable status within 30 days and, if unsuccessful, exp!ain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. This is in lieu of an LER.
4. In the event operability requirements and associated action requirements cannot be satisfied because of circumstances in excess of those addressed in the specifications, provide a 30-day wntten report to the NRC and no changes are required in the operational condition of the plant, and this does not prevent the plant f rom entry into any operational mode.
2. Radioactive Liauid Effluent Monitorina Instrumentation Surveillance

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1. Each radioactive liquid effluent monitoring instrument shown in Table 12.2-2 shall be demonstrated operable by performance of the given source check, instrument check, calibration, and functional test operations at the frequencies shown in Table 12.2-2.

B. Radioactive Gaseous Effluent Monitorino Instrumentation

1. Radioactive Gaseous Effluent Monitorina Instrumentatio'n Ooerability
1. The effluent monitoring instrumentation shown in Table 12.2-3 shall be operable  !

with alarm / trip setpoints set to ensure that the limits of Section 12.4.A are not )

exceeded. The aiarm/ trip setpoints shall be determined in accordance with the i ODCM.

2. With a radioactive gaseous effluent monitoring instruments alarm / trip set point less conservative than required, without delay suspend the release of radioactive gaseous effluents monitored by the affected instrument, or declare the instrument inoperable, or change the setpoint so it is acceptably conservative.

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i DRESDEN R; vision 1.8 f July 1998 .

12.2.B.1 Radioactive Gaseous Effluent Monitorino Instrumentation Ooerability (Cont'd) t

3. With one or more radioactive gaseous affluent monitoring instruments inoperable, take the action shown in Table 12.2 3. Retum the instrument to operable status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. This is in lieu of an LER.

4 The Unit 2/3 plant chimney gas sampling system may be out of service for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for the purpose of servicing the high range noble gas monitor as long as the following conditions are satisfied:

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1. Both units are at steady state conditions with the recombiners and charcoal absorbers in service for the operating unit (s).

l- 2. The dose rate in unrestricted areas must be shown by calculation to be less than l the limits of 12.4.A assuming the charcoal absorbers are bypassed on both units.

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, 3. Both offgas monitors on Unit 2 and Unit 3 must be operational and the monitor reading correlated to the chimney release rate based on the conservative

  • assumption of both units' charcoal absorbers being bypassed.
4. If the provisions of 12.4.A.1.1,12.4.A.1.2, or 12.4.A.1.3 cannot be met, an orderly load reduction of the unit (s) shall be initiated immediately.

l S. In the event operability requirements and associated action requirements cannot be satisfied because of circumstances in excess of those addressed in this Section, provide a 30-day written report to the NRC and no changes are required in the operational condition of the plant, and this does not prevent the plant from entry into any operation mode.

2. Radioactive Gaseous Effluent Monitorino Instrumentation Surveillance Each radioactive gaseous radiation monitoring instrument in Table 12.2-4 shall be demonstrated operable by performance of the given source check, instrument check, calibration, and functional test operations at the frequency shown in Table l

12.2-4.

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, DRESDEN Revision 1.8  !

July 1998 TABLE 12.21

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RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION UNIT 1 1

Minimum Total Channels No. of instrument Operable Channels Action l Discharge Canal 1 1 12

(. Sampler

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ACTION 12 - Operability is venfied prior to performing and once a day during planned discharge.

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  • When instrument is unavailable and associated actions cannot be performed, then discharges may not  ;

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Revision 1.8 DRESDEN July 1998 .

TABLE 12.21 RADIOACTIVE LIOUlD EFFLUENT MONITORING INSTRUMENTATION  !

UNITS 2 & 3 ,

Minimum Total Cnannels ' ' No. of Instrument - Operable Channels Action j i

' 1.- Service Water Effluent 1 1 10'  :

Gross ActivityMonitor  !

2. Liquid Radwaste Effluent 1 1 11  ;

Gross Activity Monitor ACTIONS i ACTION 10.- With less than the minimum number of operable channels, releases via this pathway [

- may continue, provided that at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples are collected and r analyzed for beta or gamma activity at an LLD of less than or equal to 10# uCl/ml.

l (The grab sample should normally be taken at the Service Water Monitor or at a  ;

location which would be representative of the Service Water which is monitored.)  !

ACTION 11 - With less than a minimum number of operable channels, effluent releases via this . ., _;

pathway may continue, provided that prior to initiating a release, at least 2 independent i samples are analyzed, and at least 2 members of the facility staff independently verify ,

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the release calculation and discharge valving. Otherwise, suspend release of  ;

radioactive effluent via this pathway.  !

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TABLE 12.2 2 ,

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RADIOACTIVE LIQUID EFFLUENT MONITOFilNG  !

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, INSTRUMENTATION SURVEILLANCE REQUIREMENTS UNIT 1 I l

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' Functional Calibration'** Instrument Source instrument Test Check

  • Check Discharge Canal Sampler *
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*When instrument is unavailable and associated actions cannot be performed, then discharges may not be made.

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DRESDEN- R vision 1.8.

July 1998 ,

TABLE 12.2-2 .

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RADIOACTIVE LIQUID EFFLUENT MONITORING  !

INSTRUMENTATION SURVEILLANCE REQUIREMENTS j UNITS 2 & 3, '

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I Functional Calibration *H' instrument Source Instrument Test t *"* Check" Check  !

1. Liquid Radwaste  !

i Emuent Gross O . E(* D E* l Activity Monitor [

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2. Service Water Emuent Gross O E9) D E j Activity Monitor j t

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TABLE 12.2 2 (Cont'd)

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS TABLE NOTATIONS

! * . The Instrument Functional Test shall also demonstrate that control room alarm annunciation occurs, if any of the following conditions exist, where appicable.

l 1. Instrument indicated levels above the alarm setpoint.

! 2. Circuit failure.

3. Instrument indicates a downscale f ailure.

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4. Instrument controls not set in OPERATE mode.
  • Calibration shallinclude performance of a functional test.

"' Calibration shallinclude performance of a source check.

" Source check shall consist of observing instrument response during a discharge.

  • Functional tests may be performed by using trip check and test circuitry associated with the monitor chassis.

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  • Functional tests, calibrations, and instrument checks are not required when these instruments are not required to be operable or are tripped. Calibration is not required to be performed more than once every 18 months.
  • Operability is verified prior to performing discharge and once a day during planned discharge.

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DRESDEN RIvision 1.8 July 1998 ,

i TABLE 12.2-3 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION UNIT 1 Minimum Total Applicable

' Channels No. of Operational Instrument Operable Channels Modes Action L

1. Main Chimney SPING Noble Gas 1 3 28 Monitors
2. Main Chimney Particulate 1 1 27 Samplers
3. Main Chimney lodine Samplers ' 1 1 27  ;

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  • At all times. -

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' July 1998 TABLE 12.2 3 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION UNITS 2 & 3 l Minimum Total Applicable

, Channels No. of Operational l Instrument Operable Channels Modes Action E Main Chimney Noble Gas /SPING/ 1 3 20 ]

GE Low Range Activity Monitor '

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l Main Chimney SPING Noble Gas Monitors Mid, Hi Range 1 1 26 )

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3. Main Chimney lodine Sampler 1 1 22

' 4. Main Chimney Particulate Sampler 1- 1 22

5. Main Chimney Flow Rate Monitor 1 1 21
6. Main Chimney Sampier Flow Rate 1 1 21 Monitor

- 7. Reactor Building Vent Exhaust See Technical Specifications Section 3/4.2 Duct Radiation Monitor Ti .y 8. Reactor Building Vent SPING *

~ 1 1 25 Noble Gas Monitor Low, Mid, High Range

9. Reactor Building Vent Flow 1 1 21-Rate Monitor
10. Reactor Building Vent Sampler 1 1 21 Flow Rate Monitor 11,~ Reactor Building Vent lodine 1 1 22 Sampler
12. . Reactor Building Vent 1 1 22 Particulate Sampler
13. Offgas Radiation Activity 1 2 29

. Monitor

  • At all times.

! " During Steam Jet Air Ejector operation.

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DRESDEN R: vision 1.8 July 1998 TABLE 12.2-3 (Cont'd)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION ACTIONS AND TABLE NOTATIONS b~

ACTION 20 - With less than the minimum channels operable, effluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and analyzed for ole gas within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(The SPING has one low range noble gas channel, Channel 5, while the GE Low Range Activity Monitor has two low-range noble gas channels.

The grab samples are usually taken at either the SPING, if it is aligned in the flow path, or at the GE Low Range Activity Monitor Skid.)

ACTION 21 - With the number of operable channels less than the minimum required, effluent releases via this pathway may continue provided that the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

(The Main Chimney Flow Rate Monitor and the Reactor Building Vent Flow Rate Monitor are used for flow through the Chimney / Vent. Channel 10 of the SPING gives the Chimney / Vent flow rate. This value can also be obtained from Point History.

The Main Chimney Sampler Flow Rate Monttor and the Reactor Building Vent Sampler Flow Rate Monitor are used for the flow through the SPING or backup sampler. Channel 15 of the SPING gives the sampler flow rate for the SPING. The U2, U3 and GE Backup systems each have a flow rate monitor.)

ACTION 22 - With less than the minimum charineis operable, effluent releases via this pathway may continue provided samples are continuously collected with auxiliary sampling equipment, as recuired in Table 12.4-1.

(The normal sampler for 2/3 Main Chimney is the 2/3 Main Chimney SPING while for

, the 2/3 Reactor Builcing Vent it is the 2/3 Reactor Building Vent SPING.

If the 2/3 Chimney SPING is not operational, the normal backup is the GE Low l Range Activity Skid. This skid collects an lodine and Particulate sample.

If the 2/3 Reactor Building Vent SPING is not operational, the normal backups are the U2 and U3 Reactor Building Vent Samplers. The sampler for each vent collects an lodine and Particulate sample.

If the normal backup sampler is not available, use of an afternate sampler should be used as long as it pulls from the same process stream.)

l ACTION 25 - With less than the minimum channels operable, effluent releases via this pathway may continue provided that the minimum number of operable channels for the Reactor Building Vent Exhaust Duct Radiation Monitor are operable.

(These are Channels 5 (low-range),7 (mid-range) and 9 (high-range) on the 2/3 Reactor Building Vent SPING.)

ACTION 26- With less than the minimum channels operable, effluent releases via this pathway may continue provided the low range monitor is operable and on scale. Restore the inoperable equipment to operable status within 21 days, or prepare and submit a '

V) l report to the Commission pursuant to Technical Specification 6.9.B within the next 30 ,

g:Vnurphybdctn\annextresdendn12ri 8 doc 12-14 l

l  !

1 l DRESDEN R; vision 1.8 l

July 1998 l

days outlining the plans, actions taken and procedures to be used to provide for the loss of sampling capability of the system.

(These are Channels 7 (mid-range) and 9 (high-range) on the 2/3 Main Chimney l SPING.)

ACTION 27- The main chimney SPING monitor may be out-of service for calibration and maintenance provided that particulate and iodine samples are taken and analyzed.

The samples shall he collected using attemate filter holders and pumps connected to the main chimney sample stream.

(The normal lodinc and Particulate sampler for D1 Main Chimney is the D1 Main Chimney SPING. If the D1 Chimney SPING is not operational, the normal backup is

! a sample pump attached to the sample stream from the Main Chimney. The sample

! pump collects an lodine and Particulate sample.)

ACTION 28 - With less than the minimum channels operable, effluent releases via this pathway may continue provided daily nobie gas samples are taken and analyzed daily. Restore the inoperable equipment to operable status within 30 days. If service can not be i retumed, document equipment availability difficulties wrthin the Radioactive Effluent l Release Report for the period including actions taken in response to the equipment and procedures used to provide for the loss of sampling capability of the system.

(The normal noble gas monitors are Channels 5 (low-range),7 (mid-range) and 9 (high-range) on the D1 Chimney SPING. Grab samples can either be taken off of l

the SPING or taps on the piping for the sample stream.)

ACTION 29 - With less than the minimum channels operable, gases from the main condenser off

]

gas system may be released to the environment for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided the off j gas system is not bypassed and at least one chimney monitor is operable; 1 otherwise, be in HOT STANDBY in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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l g%urphyW1Cm\arnexwresdenun12r1 8. doc 12-15

l L . i l

DRESDsN R: vision 1.8 - .

July 1998 TABLE 12.2 4 RADIOACTIVE GASEOUS EFFLUENT MONITORING Ol ks i

INSTRUMENTATION SURVEILLANCE REQUIREMENTS UNIT 1 l

l \

!. Applicable  ;

' Functional Calibration

  • Instrument Source Operational Instrument Test'" Check Check Modes-I
1. Main Chimney SPING Q E D M *

. Noble Gas Monitor ,

Low Range .i.

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l l- ' 'At all times.

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! 4 I

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t

l.  ;

I  ;

F i

ghurphrodctmannexWresdenWn12r18 doc O i i

12 16 '

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DRESDEN Raision 1.8 l

uly 1998 TABLE 12.2-4

~ RADIOACTIVE GASEOUS EFFLUENT MONITORING

! INSTRUMENTATION SURVEILLANCE REQUIREMENTS i~ UNITS 2 & 3 l

Applicable

! Functional Calibration"') Instrument Source Operational Instrument Test'***' Check

  • Check Modes
1. Main Chimney Noble Q E D M Gas Activity Monitor
2. Main Chimney SPING Q E D M
  • Noble Gas Monitor Lo, Mid. High Range - '
3. Main Chimney NA NA D(4 NA
  • Particulate and lodine Sampler
4. Main Chimney Flow Q E D NA
  • Rate Monitor
5. Main Chimney Sampler 05 E D NA
  • Flow Rate Monitor
6. Reactor Bldg Vent ' See Technical Specifications Section 3/4.2

, ,. Exhaust Duct Radiation Monitor

7. Reactor Bldg Vent O E D M SPING Noble Gas Monitor Lo, Mid, High Range
8. Reactor Bldg Vent O E D NA
  • Flow Rate Monitor
9. Reactor Bldg Sampler Q* E D NA
  • Flow Rate Monitor
10. Reactor Bldg Vent .NA NA D'" NA
  • I Particulate and lodine Sampler -
11. Off Gas Radiation O E D E Activity Monitor i
  • At all times.

" During Steam Jet Air Ejector operation.

l

.s l gtnurphybdctn'annexWresdenwn12ri-8 doc l 12-17 l l

DRESDEN Revision 1.8 July 1998 ,

TABLE 12.2 4 (Cont'd) Q RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS TABLE NOTATIONS The instrument Functional Test shall also demonstrate that control room alarm annunciation occurs, if any of the following conditions exist, where applicable.

1. Instrument indicates levels above the alarm setpoint.
2. Circuit failure.
3. Instrument indicates a downscale failure.
4. ' Instrument controls not set in OPERATE mode.

'M Calibration shall include performance of a functional test.

'" Instrument check to verify operability of sampler; that the sampler is in place and functioning properly.

(* - Functk al test shall be performed on local switches providing low flow alarm.

( '* Functional tests, calibrations, and instrument checks are not required when these instruments are not required to be operable or are tripped. Calibration is not required to be performed more than O

once every 18 months. ..-

[..

_ :5

. gwurphfoocmunnexWresdorfon12r18. doc 12 18

~

DRESDEN Revision 1.8 July 1998 12.2.0 Liouid And Gaseous Effluents Instrurre6f i;e6 Bases

,^.

1. The radioactive liquid and gaseous effluent instrumentation is provided to monitor the release of radioactive materials in liquid and gaseous effluents during releases. The alarm setpoints for the instruments are provided to ensure that the alarms will occur prior to exceeding the limits of RETS.

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gwsp:T/Amannenwresdenen12ri-8. doc 12-19

DRESDEN R: vision 1.8 July 1998 .

12.3 LIQUID EFFLUENTS 12.3.A Liouid Effluents Limits and Reoortino Ooerability

1. Concentration in Unrestricted Areas The concentration of radioactive material released from the site to unrestricted areas (at or beyond the site boundary, Dresden Station ODCM Annex, Appendix F, Figure F 1) shall be limited to the concentrations specified in Appendix B, Table 2. Column 2 to 10CFR20.1001-20.2402', for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to the values listed in Table 12.3 1.

With the concentration of radioactive material released from the srte to unrestricted areas exceeding the above limits, without delay decrease the release rate of radioactive materials and/or increase the dilution flow rate to restore the concentration to within the above limits.

2. Dose from Liouid Effluents The dose or dose commitment above background to a member of the public from radioactive materials in liquid effluents released to unrestricted areas (at or beyond the site boundary) from the site shall be limited to the following:
1. During any Calendar Quarter:

(1) Less than or equal to 3 mrem to the whole body.

(2) Less than or equal to 10 mrem to any organ.

."y*

2. During any Calendar Year:

i (1) Less than or equal to 6 mrem to the whole body.

(2) Less than or equal to 20 mrem to any organ.

3. With the calculated dosc from the release of radioactive materials in liquid effluents exceeding any of ine above limits, prepare and submit to

! the Commission within 30 days a Special Report which identifies the i

cause(s) and defines the corrective actions taken and the proposed l

actions to be taken to ensure that future releases are in compliance with l

Sections 12.3.A.2.1 and 12.3.A.2.2. This is in lieu of a Licensee Event Report.

l upon technical specification approval. ten (10) times the Appendix B value may be used to determine the maximum instantaneous liquid release.

Q g \murphybdcm\annerwresdentn12rl-8 doc 12 20

. _ _ _ . . _ _ . _ _ ~ _ . _ . . . . _ _ . _ _ . _ . _ _ . . . . _ ..

, DRESDEN Revision 1.8 July 1998 12.3.A Liouid Effluents Limits and Reoortino Ooerability (Cont'd)  ;

n

."" 4. With the calculated dose from the release of radioactive materials in liquid effluents exceeding the limits of Sections 12.3.A.2.1 or 12.3.A.2.2.,

l prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose or dose j

- commitment to a member of the public from all uranium fuel cycle

]

sources is limited to less than or equal to 25 mrem to the total body or 1 any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutrve months. This Special Report shallinclude an analysis which demonstrated that radiation exposures to all real individua:s from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are less than the 40 CFR Part 190 Standard. Otherwise obtain a variance from the Commission to permit releases which exceed the 40 UFR Part 190 Standard. The radiation exposure analysis contained in the Special Report shall use methods prescribed in the ODCM. This report is in lieu of a Licensee Event i Report.

5. When the projected annual whole body or any intemat organ dose computed at the nearest downstream community water system is equal to or exceeds 2 mrem from all radioactive materials released in liquid  !

effluents from the Station, prepare and submit a Special Report within 30  ;

days to the operator of the community water system. The report is i prepared to assist the operator in meeting the requirements of 40 CFR Part 141, EPA Primary Drinking Water Standards. A copy of this report will be sent to the NRC. This is in lieu of a Licensee Event Report. i

3. Dose Proiections

^'

At all times during processing prior to discharge to the environs, process and

. control equipment provided to reduce the amount or concentration of radioactive

  1. ~

materials shall be operated when the projected dose due to liquid effluent releases to unrestricted areas (Dresden Station ODCM Annex, Appendix F.

Figure F 1), when averaged over 31 days, exceeds 0.12 mrem to the total body or 0.40 mrem to any organ'.

l r

"These values represent 2% of the annual dose limits of Appendix i to 10CFR50.

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gNnurphy\odemiannerdresdenidn12rt 8 doc

(

l l 12-21

DRESDEN R; vision 1.8 July 1998 12.3.A Liouid Effluents Limits and Rooortina Ooerabiktv (Cont'd)

4. Liouid Radioactive Waste Treatment System l

If liquid waste has to be or is being discharged without treatment as required above, prepare and submit to the Commission with 30 days, a report which includes the following information.

1. Identification of the defective equipment.
2. Cause of the defect in the equipment.
3. Action (s) taken to restore the equipment to an operating status.
4. Length of time the above requirements were not satisfied.
5. Volume and curie content of the waste discharged which was not processed by the appropriate equipment but which required processing.
6. Action (s) taken to prevent a recurrence of equipment failures.

This is in lieu of a Licensee Event Report.

5. System Ooerability and Plant Ooerations in the event a limit and/or associated action requirements identified in Sections 12.3.A and 12.3.B cannot be satisfied because of circumstances in excess of those addressed in this Section, no changes are required in the operational

~~'

condition of the plant, and this does not prevent the plant from entry into any -

operational mode. .

12.3.B Liauid Effluents Surveillance

1. Concentration in Unrestricted Areas The concentration of radioactive material in unrestncted areas shall be determined to be within the prescribed limits by obtaining representative samples in accordance with the sampling and analysis orogram specified in Table 12.3-2.

The sample analysis results will be used with the ca!culational methods in the ODCM to determine that the concentrations are within the limits of Section 12.3. A.1.

J gwurpnywacmwnnerwrescenunt2r1-8 coc 12-22

. DRESDEN RIvision 1.8 July 1998 12.3.B Liauid Effluents Surveillance (Cont'd)

2. Dose from Liauid Effluents The dose contnbution from measured quantities of radioactive material shall be determined by calculaaion at least once per 31 days and cumulative summation of these total body and organ dosed shall be maintained for each calendar quarter.

Doses computed at the nearest community water system will consider only the drinking water pathway and shall be projected using the methods prescribed in ODCM, at least once per 92 days.

3. Dose Projections Doses due to liquid releases to unrestncted areas (at or beyond the site boundary) shall be projected at least once per 31 days in accordance with the ODCM.

h.

'A gNnurphpunneMfendeMOn12ri B. doc 12-23

I

. i DRESDEN Revision 1.8 -  !

July 1998 ,

TABLE 12.3-1 ALLOWABLE CONCENTRATION OF DISSOLVED - l OR ENTRAINED NOBLE GASES RELEASED FROM  !

THE SITE TO UNRESTRICTED AREAS i IN LIQUID WASTE l

NUCLlDE AC(uCi/mt)* 6 i

Kr-85m 2 x 10" Kr 85 5 x 10" -f Kr-87 4 x 10~5 Kr-88 9 x 10

Ar-41 7 x 10'8 l t

d Xe-131m 7 x 10 Xe-133m 5 x 10" Xe 133 6 x 10*

i Xe-135m 2 y 10" '~'

Xe-135 2 x 10" l

( ..

Computed from Equation 20 of ICRP Publication 2 (1959), adjusted for infinite cloud submersion in '

water, and R = 0.01 rem / week, density = 1.0 g/cc and Pw/Pt = 1.0.

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9:VnurphyNodern\anneddresdenWi12ri-8. doc .

12-24  !

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.- DRESDEN Revision 1.8 July 1998 TABLE 12.3-2

~-

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM UNIT 1 LOWER LIMIT OF TYPE OF ACTIVITY DETECTION LIQUID RELEASE SAMPLING ' MINIMUM ANALYSIS ANALYSIS (LLD)"8 (pCi/ml) i

. TYPE FREQUENCY FREQUENCY (

Above See TS 3/4.8.J See TS 3/4.8.J Principal Gamma 5x10

Ground Emitters (*)

Liquid Storage Dissolved & Entrained 1x10 ,

. Tanks ~ Gases (*3 (Gamma i Emitters) l i.

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vr j g:VNv.f4nWnnoundreadenWn12r1-8 doc l

12-25 e

.... e---e ~ , , - ---,,n., ,, ,~e-- r g -4

DRESDEN RIvision 1.8 July 1998 .

TABLE 12.3-2 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM UNITS 2 & 3 a LOWER LIMIT OF TYPE OF ACTIVITY DETECTION LIQUID RELEASE SAMPLING MINIMUM ANALYSIS ANALYSIS (LLD)"' (pCi/ml)

TYPE FREQUENCY

  • FREQUENCY
  • A. Batch Prior to Prior to Principal Gamma 5x10

Release Each Datch Each Batch Emitters'*

4 Tanks 1131 1x10 Prior to M Groso Alpha 1x10

Each Batch Comnasite(*) H-3 1x10

4 Prior to o Fe-55 1x10 Each Batch Composite '*) Sr-89, Sr-90 5x10*

Prior to M Dissolved & Entrained 1 x10

One Batch /M Gases *(Gamma  ;

Emrtters)  ;

4 B. Plant M'* M* l131 1x10 Continuous (Grab Sample) .

Releases

  • f M* M* Principal Gamma 5x10'7 >

(Grab Sample) Emitters

  • MS M* Dissolved & Entrained 1x10 f (Grab Sample) Gases * (Gamma Emitters)

M* M* H-3 1x10

(Grab Sample)  ;

Gross Alpha 1x10

l O* Q* Sr-89, Sr-90 5x10 4

(Grab Sample) j 4

Fe 55 1x10 C. Above Ground See TS 3/4.8.J See TS 3/4.8.J Principal Gamma 5x10

Liquid Storage Emitters

  • Tanks Lissolved & Entrained 1 x10

Gases * (Gamma i i

Emitters) s.

'Y g-VnurphfodctmannexWresdenWn12r1-8. doc 12-26

- - - - - - . . . . . - ..- . . . . = - -- ,

  • DRESDEN Revision 1.8 i-July 1998 ,

t TABLE 12.3-2 (Cont'd)

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM

^

TABLE NOTATION s

m The LLD is defined, for purposes of these specifications, as the smallest concentration of j radioactive matenal in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank  ;

observation represents a "real' signal.

For a particular measurement system, which may include radiochemical separation:

LLD = 4.66Ss E

  • V
  • 2.22 x 10". Y
  • exp (-A.at) l Where:

LLD = the lower limit of detection (microCuries per unit mass or volume),

so= the standard deviation of the background counting rate or of the counting rate of a ,

blank sample as appropriate (counts per minute),  ;

E = the counting efficiency (counts per disintegration),

V = the sample size (units of mass or volume),

I 2.22 x 10' = the number of disintegrations per minute per microcurie,

'N Y = the f ractional radiochemical yield, when applicable, j

~

b the radioactive decay constant for the particular radionuclide (sec "), and At = the elapsed time between the midpoint of sample collection and the time of counting (sec).  !

Typical values of E V, Y, and At should be used in the calculation. l l

Alternate LLD Methodoloav An alternate methodology for LLD determination follows and is similar to the above LLD equation:

(2.71 + 4.65VB) Decay LLD =

E q b Y t (2.22E06) l i

i' g:VnurphfodemunneAdresderMn12r1 8, doc 12-27 l

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I l DRESDEN Revision 1.8 i July 1998 .  ;

r TABLE 12,3-2 (Continued)

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM g

M i TABLE NOTATION  !

i

! Where: 1 l

B = background sum (counts) [
E = counting efficiency, (counts detected / disintegrations) 1 i q = sample quantity, (mass or volume)

'l b = abundance,(if applicable)

Y = fractional radiochemical yield or collection efficiency (if applicable) I t = count time (minutes) l _ '2.22E06 = number of disintegrations per minute per microcurie  !

l (2.71 + 4.65VB) = k' + (2k V 2 V B), and k = 1.645.

l (k=value of the t statistic from the single-tailed t distribution at a significance level l of 0.95% and infinite degrees of freedom. This means that the LLD result

  • l represents a 95% detection probability with a 5% probability of falsely concluding that the nuclide present when it is not or that the nuclide is not present when it is.)

Decay = e* [ ART /(1 e#)) [ATa/(1-e*)), (if applicable) -

l l A = radioactive decay constant, (units consistent with At, RT and To)

At = " delta t", or the elapsed time between sample collection or the midpoint of sample l collection and the time the count is started, depending on the type of sample, (units consistent with A) ,

l RT = elapsed real time, or the duration of the sample count, (units consistent with A) (

)

l To = sample deposition time, or the duration of analyte collection onto the sample l< media, (unit consistent with A) .;

The LLD may be determined using installed radioanalytical software, if available. In  !

addition to determining the correct number of channels over which to total the

[

background sum, utilizing the software's ability to perform decay corrections (i.e. during

j. sample collection, from sample collection to start of analysis and during counting), this l- attemate method will result in a more accurate determination of the LLD. >

I L

it should be recognized that the LLD is defined as a before the fact limit and not as an after the

l. fact limit for a particular measurement, j

i m  :

df I g:vsv.%iaannerdresdenWn12r1-8.coe ,

12-28

_._.--z_.-_____---____-__._--___--_------_____-________--___-_____-__-_________._----__--_____.___

DRESDEN Revision 1.8 July 1998 TABLE 12.3-2 (Cont'd)

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM l TABLE NOTATION

  • A composite sample is one in which the quantity of liquid samples is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.
  • If the alarm setpoint of the service water effluent monitor as determined in the ODCM is exceeded, the frequency of analysis shall be increased to daily until the condition no longer exists.
  • A batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated and then thoroughly mixed to assure representative sampling. A continuous release is the discharge of liquid wastes of a nondiscrete volume; e.g.,

from a volume or system that has an input flow during the release.

  • The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn-54, Fe-59, Co-60, Zn-65, Co-58, Mo-99, Cs-134, Cs-137 Ce-141, and Ce-144.

Other peaks which are measurable and identifiable by gamma ray spectrometry together with the above nuclides, shall be also identified ar ! reported when the actual analysis is performed on a sample. Nuclides which are below the LL 9 for the analyses shall not be reported as being present at the LLD level for that nuclide.

  • The dissolved and entrained gases (gamma emitters) for which the LLD specification applies exclusively are the following radionuclides: Kr-87. Kr 88, Xe-133, Xe-133m, Xe-135, and Xe-138.

Other dissolved and er,irained gases (gamma emitters) which are measurable and identifiable by gamma ray spectrometry, together with the above nuclides, shall also be identified and reported when an actual analysis is performed on a sample. Nuclides which are below the LLD for the analyses shall not be reported as being present at the LLD level for that nuclide.

1

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l g vnurpnywocmenererescenen12r18 coc 12-29

DRESDEN R; vision 1.8 July 1998 12.3.C LIQUID EFFLUENTS BASES

1. Concentration This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified in Appendix B, Table 2 Column 2 to 10CFR20.1001-20.2402.
2. Dose This specification is provided to implement the requirements of Sections ll.A. Ill.A and IV.A of Appendix I,10 CFR Part 50. The operational requirements implements the guides set forth in Section ll.A of Appendix 1. The statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix i to assure that the releases of radioactive materialin liquid effluents will be kept "as low as reasonably achievable". The dose calculations in the ODCM implement the requirements in Section Ill.A of Appendix 1 that conformance with the guides of Appendix 1 be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents will be consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I", Revision 1. October 1977 and Regulatory Guide 1.113 " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of implementing Appendix I", April 1977.

NUREG-0113 provides methods for dose calculations consistent with Reg Guide 1.109 and 1.113. -

3. Liouid Waste Treatment The operability of the liquid radwaste treatment system ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement that tne appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as reasonably achievable". This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFF Part 50 and design objective Section 11.D of Appendix 1 to 10 CFR Part 50.

%Y g hurphrodem\annerWresdenWn12r1 8. doc 12-30

.. DRESDEN Revision 1.8 July 1998 12.3.C - LIQUID EFFLUENTS BASES - (Continued)

4. MechancalVacuum Pumo The purpose of isolating the mechanical vacuum line is to limit release of activity from the main condenser. During an accident, fission products would be transported from the reactor through the main steam line to the main condenser. The fission product radioactivity would be sensed by the main steamline radioactivity monitors which initiate isolation. ,

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i v q g:vnm/ev.wwwnwrnoenwn12rt a.coe 12-31 i

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DRESDEN Rsvision 1.8 July 1998 ,

12.4 G ASEOUS EFFLUENTS A. Gaseous Effluents Limrts and Reoortino Ooerability ,

1. Dose Rate The dose rt 5 in unrestricted areas at or beyond the site boundary (Dresden Station ODCM Annet Appendix F, Figure F 1) due to radioactive materials released in gaseous effit' nts from the site shall be limited to the following.
1. For Nob.a Gases:

(1) Less than a dose rato of 500 mrem / year to the whole body.

(2) Less than a dose rate of 3000 mrem / year to the skin.

2. For iodine-131, for iodine-133, tritium and for all radionuclides in particulate form with half-!ives greater than 8 days, less than a dose rate of 1500 mrem / year.
3. If the dose rates exceed the above limits, without delay decrease the release rates to bring the dose rates within the limits, and provide notification to the Commission (per 10 CFR Part 20.2203).
2. Noble Gas Dose The air dose in unrestricted areas at or beyond the site boundary due to noble gases released in gaseous effluents from the unit shall be limited to the following:
1. For Gamma Radiation

/

(1) Less than or equal to 5 mrad during any cal 6adar quarter.

(2) Less than or equal to 10 mrad during any calendar year.

l

2. For Beta Radiation (1) Less than or equal to 10 nirad during any calendar quarter.

(2) Less than or equal to 20 mrad dunng any calendar year.

3. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, a Special Report which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to ensure that future re, eases are in compliance with Sections 12.4.A.2.1 and 12.4.A.2.2. This is in lieu of a Licensee Event Report.

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I g-vnurphyedemannexwresdenwn12rt-8. oc 12-32 j l

l DRESDEN Rivision 1.8 July 1998

{

12.4.A Gaseous Effluents Limits and Reoortina Ooerability(Cont'd)

4. With the calculated air dose from radioactive noble gases in gaseous I

~

effluents exceeding the limits of Sections 12.4.A.2.1 or 12.4.A.2.2, prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the doses or dose commitment to a member of the public from all uranium fuel cycle sources is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures to all members of the public frcm all uranium fuel cycle sources ,

(including all effluent pathways and direct radiation) are less than 40 CFR  !

Part 190 Standard. Otherwise, obtain a vanance from the Commission to I permit releases which exceed the 40CFR Part 190 Standard. The radiation exposure analysis contained in the Special Report shall use the methods prescribed in the ODCM. This report is in lieu of a Licensee Event Report. I

5. Process and control equipment provided to reduce the amount or concentration of radioactive materials shall be operated when the projected dose due to gaseous effluents released to the unrestricted areas, when averaged over 31 days, exceeds 2% of the annual dose limits of Appendix i to 10CFR50. l
3. lodine-131. lodine-133. Tritium. and Particulate Dose The dose to a member of the public in unrestricted areas at or beyond the site boundary from iodine-131, iodine-133, tntium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from the unit shall be

'. limited to the following.

1. Less tnan or equal to 7.5 mrem to any organ during any calendar quarter.
2. Less than or equal to 15 mrem to any organ during any calendar year.
3. With the calculated dose from the release of iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions taken to ensure that future releases are in compliance with Section 12.4.A.3.1 and 12.4.A.3.2. This is in lieu of a Licensee Event Report.
4. With the calculated dose from the release of iodine-131, iodine-133, tntium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents exceeding the limits of Sections 12.4.A.3.1. or 12.4.A.3.2.,

prepare and submit a Special Report to the Commission within 30 days and limit subsequent releases such that the dose or dose commitment to a member of the public from all uranium fuel sources girnurphybdom'anneteesdenwn12r1-8. doc 12-33

DRESDEN Revision 1.8 July 1998 .

12.4.A Gaseous Effluents Limits and Reoortino Ooerability(Cont'd) is limited to less than or equal to 25 mrem to the total body or organ (except the thvroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures to all members of the public from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are less than the 40 CFR Part 190 Standard. Otherwise, obtain a variance from the Commission to permit releases which exceed the 40 CFR Part 190 Standard. The radistion exposure analysis contained in the Special Report shall use the methods prescribed in the ODCM. This report is in lieu of a Licensee Event Report.

5. Process and control equipment provided to reduce the amount or concentration of radioactive materials shall be operated when the projected dose due to gaseous effluents released to the unrestncted areas, when averaged over 31 days, exceeds 2% of the annual dose limrts of Appendix I to 10CFR50.
4. Off-Gas Treatment
1. At all times during processing for discharge to the environs, process and control equipment provided to reduce the amount of concentration of radioactive materials shall be operated.
2. The above specification shall not apply for the Off-Gas Charcoal Adsorber Beds below 30 percent of rated thermal power.
3. The recombiner shall be operable whenever the reactor is operating at a v pressure greater than 900 psig.
4. The recombiner may be inoperable for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
5. With either the recombiners inoperable, or all charcoal beds by-passed for more than 7 days in a calendar quarter while operating above 30 percent of the rated thermal power, prepare and submit to the Commission within 30 days a Special Report which includes the following information.
a. Identification of the defective equipment.
b. Cause of the defect in the equipment,
c. Action (s) taken to restore the equipment to an operating status. '
d. Length of time the above requirements were not satisfied.
e. Volume and cune content of the waste discharged which was not processed by the inoperable equipment but which required processing.

O gWurphpodomanneAdresdenen12r1 8 doc 12-34

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DRESDEN Revision 1.8 i* July 1998

.12.4.A Gaseous Effluents Limits and Reoortina Ooerability(Cont'd) l

]

l , f. Action (s) taken to prevent a recurrence of equipment failures.

l This is in lieu of a Licensee Event Report.

6. Main Condenser Air Eiector l The release rate of the sum of the activities from the noble gases measured at the main condenser air ejector shall be limited to s 100 microcuries/sec per MWt (after 30 minutes decay) when in modes 1,2*, and 3' . With the release rate of the sum of the activities from noble gases at the main condenser air ejector effluent (as measured prior to the offgas holdup line) > 100 microcunes/sec per MWt, Efter 30 minutes decay, restore the release rate to within its limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or t;9 in et least STARTUP with the main steam isolation valves closed within the next 8 hr.;uG.

l (Refer to Technical Specification 3.8.l.)

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6. Svstem Ooerability and Plant Operations l

l In the event a limit and/or associated action requirements identified 6 Sections 12.4.A and 12.4.B cannot be satisfied because of circumstances in excess of those addressed in this Section, no changes are required in the operational condition of the plant, and this does not prevent the plant from entry into any operational mode.

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l "When the main condenser air ejector is in operation.

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12-35

9 DRESDEN R1 vision 1.8 July 1998 .

12.4.B Gaseous Effluents Survenllance

1. Dose Rate The dose rates due to radioactive materials released in gaseous effluents from the site shall be determined to be within the presenbed limits by obtaining representative samples in accordance with the sampling and analysis program specified in Table 12.41.' The dose rates are calculated using methods prescribed in the ODCM. -
2. Noble Gas Dose The air dose due to releases of radioactive noble gases in gaseous effluents shall be determined to be within the prescribed limits by obtaining representative samples in accordance with the sampling and analysis program specifed in Sections A and B of Table 12.4-1.' The allocation of effluents between units having shared effluent control system and the determination of cumulative and projected dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once every 31 days.
3. lodine 131. lodine-133. Tritium and Pailblata Dose The dose to a member of the public due to releases of iodine-131, iodine-133, intium, and all radionuclides in particulate form with half-lives greater than 8 days shall be determined to be within the prescribed limits by obtaining representative samples in accordance with the sampling and analysis program specified in Table 12.4-1.

For radionuclides not determined in each batch or weekly composite, the dose contribution to the current calendar quarter cumulative summation may be estimated by assuming an average monthly concentration based on the previous monthly or  !$

V quarterty composite analyses. However, for reporting purposes, the calculated dose contributions shall be based on the actual composite analyses when possible.

The allocation of effluents between units having shared effluent control system and the determination of cumulative and projected dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once every 31 days.

4. Off-Gas Treatment .

Doses due to treated gases released to unrestricted areas at or beyond the site boundary shall be projected at least once per 31 days in accordance with the ODCM.

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DRESDEN R; vision 1.8 q

July 1998 '

)

12.4.B Gaseous Effluents Surveillance Continued l

S. Noble Gases at the Main Condenser Air Eiector The release rate of noble gases from the main condenser air ejector shall be continuously monitored. The release rate of the sum of the activities from noble gases from the main condenser air ejector shall be determined to be within the limits l of 12.4.A.5 at the following frequencies by performing an isotopic analysis of a I representative sample of gases taken at the recombiner outlet, or at the air ejector outlet if the recombiner is by-passed.

i 1.- At least once per 31 days.

2. Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following determination of an increase of greater than 50%.

(Refer to Technical Specification 4.8.1.)

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DRESDEN Revtion 1.8 July 1998 ,

TABLE 12.4-1 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM UNIT 1 GASEOUS SAMPLING MINIMUM TYPE OF ACTIVITY LOWER LIMIT OF RELEASE- FREQUENCY ANALYSIS ANALYSIS TYPE DETECTION (LLD)m FREQUENCY (pCi/ml)

A. Main M M Principal Gamma 1 x10

Chimney (Grab Sample) Emitters *)

4 Tritium 1x10 4

Noble Gases 1x10 M'* *) M *) 1-131 1 x10

(Continuous) lodine Sample 1-133 1 x10"

M"' M)88 Principal Gamma 1 x10'"

(Continuous) Particulate Sample . Emitters *)

O O . > 89, Sr 90

. 1 x10'" g (Continuous) Composite >ss Alpha ,

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Particulate Sample I

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l gwurpnywocrmannexwrescenen12ri-e.coc 12-38

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DRESDEN R;; vision 1.8 July 1998 Table 12.4-1

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM l UNITS 2 & 3 l LOWER LIMIT GASEOUS SAMPLING MINIMUM TYPE OF ACTIVITY OF RELEASE FREQUENCY ANALYSIS ANALYSIS DETECTION TYPE FREQUENCY (LLD)") (pCi/ml)

A. Main M M(*) Principal Chimney (Grab Sample) Gamma Emitters") 1x10" Reactor Bldg. M 4 Tritium 1x10 Vent Stack B. All Continuous) Wi ') 1-131 1 x10*

- Release lodine Sample 1-133 1 x10

Types ,

as l Listed in A )

above S

Continuous (') W) Principal Gamma 1 x10'"

Particulate Sample Emitters *) 1 Continuous (*) O Sr 89 1x10'" .

Composite l Particulate Sample St-90 1 x10'"

Continuous (*) G Gross Alpha 1 x10'"

Composite Particulate Sample C. Main 4 Continuous (*) Noble Gas Monitor Noble Gases 1x10 Chimney D. Reactor Continuous (*) Noble Gas Monitor Noble Gases 1x10" Bldg.

Vent Stack l

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g VnurphybdemWineMresdendn12ri 8 doc j 12-39 l

DRESDEN Revision 1.8 July 1998 TABLE 12.4-1 (Cont'd)

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION

  • The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive matenal in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system, which may include radiochemical separation:

LLD = 4 66S, E

  • V
  • 2.22 x 10'
  • Y
  • exp (-lat)

Where:

LLD = the lower limit of detection (micr0 Curies per unit mass or volume),

so= the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (counts per minute),

E = the counting efficiency (counts per disintegration),

V = the sample size (units of mass or volume), ,

2.22 x 10' = the number of disintegrations per minute per microcurie, D a

Y = the fractional radiochemical yield, when applicable, A= the radioactive decay constant for the particular radionuclide (sec "), and At = the elapsed time between the midpoint of sample collection and the time of counting (sec).

^

Typical values of E, V, Y, and at should be used in the calculation.

Alternate LLD Methodoloov An attemate methodology for LLD determination follows and is similar to the above LLD equation:

(2.71 + 4.65*!B)* Decay  :

l LLD = l E q b Y t (2.22E06)  ;

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, DRESDEN Revision 1.8 July 1998 l i

j TABLE 12 41 (Continued)  ;

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' . RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM l TABLE NOTATIONS

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Where:

B = background sum (counts) -

, E = counting efficiency, (counts detected / disintegrations) q = sample quantity,(mass or volume)

, }

b = abundance,(if apphcable)  !

l i j Y = fractional raciochemical yield or collection efficiency, (if applicable)

{

i t = count time (minutes)  ;

. . I 2.22E06 = number of disintegrations per minute per microcurie l

(2.71 + 4.65VB) = kr + (2k V 2 V B), and k = 1.645.

(kwalue of the t statistic from the single-tailed t distribution at a significance level  !

l cf 0.95% and infinite degrees of freedom. This means that the LLD result j represents a 95% detection probability with a 5% probability of falsely concluding i

(: that the nuclide present when it is not or that the nuclide is not present when it is.) l l ".N.-

m;,Y' Decay = e* [ ART /(1 e#)][AT /(1 e")), (if applicable)

A = radcactive decay constant, (units consistent with At, RT and Ta)

L At = "della t", or the elapsed time between sample collection or the midpoint of sample f

! collection and the time the count is started, depending on the type of sample, ,

(

(units consistent with A) -  !

D RT = elapsed real time, or the duration of the sample count, (units consistent with A) i

! To = sample deposition time, or the duration of analyte collection onto the semple E modsa, (unit consistent with A)

The LLD may be determined using installed radioanalytical software, if available. In '

j; addition to determining the correct number of channels over which to total the background sum, utilizing the software's ability to perform decay corrections (i.e. during i-sample collection, from sample collection to start of analysis and during counting), this attemate method will result in a more accurate determination of the LLD.

It should be recognized that the LLD is defined as a before the fact limit and not as an after the

fact limit for a particular measurement.

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DRESDEN R:: vision 1.8 July 1998 -

TABLE 12.41 (Cont'd)

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION

  • h Sampling and analyses shall also be performed following shutdown, startup, or a thermal power change exceeding 20 percent of rated thermal power in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> unless (1) analysis shows that the  !

dose equivalent 1-131 concentration in the primary coolant has not increased more than a factor of 5, and (2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3.

Samples shall be changed at least once per 7 days and the analyses completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after removal from the sampler, Sampling shall also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following each shutdown, startup, or thermal power level change exceeding 20% of rated thermal power in one hour. This requirement does not apply if 1) analysis shows that the dose equivalent 1-131  ;

concentration in the pnmary coolant has not increased more than a factor of 5, and 2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3. p When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are analyzed, the corresponding LLDs may be increased by -

a factor of 10.

The ratio of sample flow rate to the sampled stream flow rate shall be known, i The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr-87, Kr-88, Xe-133, Xe 133m, Xe-135, and Xe-138 for gaseous emissions, and Mn-54, Fe-59, Co-60, Zn-65, Co-58, Mo-99, Cs-134, Cs-137, Ce-141, and l

Ce-144 for particulate emissions. Other peaks which are measurable and identifiable by 3

gamma ray spectrometry, together with the above nuclides, shall be also identified and reported .

when an actual analysis is performed on a sample. Nuclides which are below the LLD for the _' '

analyses shall not be reported as being present at the LLD level for the nuclide. t Analysis frequency shall be increased to 1/ week if release rates exceed 1% of any applicable  ;

limit referenced in the ODCM, when added to Units 2 and 3 airbome effluents.

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12-42 i

DRESDEN Ravision 1.8 July 1998 12.4.C Gaseous Effluents Bases j

1. ' Gaseous Effluents. Dose '

This Section is provided to ensure that the dose at the unrestricted area boundary from

. gaseous effluents from the units on site will be within'the annual dose limits of 10CFR20 for unrestricted areas. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual in  ;

an unrestricted area to annual average concentrations exceeding the limits specified in Appendix B, Table 2 of 10CFR20.1001-2402. The release rate limits restrict, at all  ;

times, the corresponding gamma and beta dose rates above background to an individual

. at or beyond the unrestricted area boundary to less than or equal to 500 mrem / year to ,

the total body or to less than or equal to 3000 mrem / year to the skin. These release rate 'l limits also restrict, at all times, the corresponding thyroid dose rate above background  :

via the inhalation pathway to less than or equal to 1500 mrem / year. For purposes of  !

calculation doses resulting from airbome releases, the main chimney is considered to be  !

an elevated release point and the reactor building vent stack is considered to be a mixed l mode release point.

2. Dose. Noble Gases  !

This Section is provided to implement the requirements of Sections ll.B. lil.A and IV.A of i

- Appendix 1,10 CFR Part 50. The Operability Requirements implement the guides set forth in Section 11.3 of Appendix 1. The statements provide the required operating '  !

flexibility and at the same time implement the guides set forth in Section IV.A of Appendix l to assure that the releases of radioactive material in gaseous effluents will be  ;

_ kept "as low as is reasonably achievable." The surveillance requirements implement the '

T requirements in Section Ill.A of Appendix l that conformance with the guides of Appendix s

j I is to be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109," Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1," Revision 1, October 1977 and Regulatory Guide 1.111,

  • Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water Cooled Reactors," Revision 1, July 1977. NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.111.

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DRESDEN R; vision 1.8 July 1998 ,

f 12.4.C Gaseous Effluents Bases (Cont'd)

3. Dose. Radioiodines. Radioactive Materialin Particulate Form and Radionuclides Other than Noble Gases This Section is provided to implement the requirements of Sections ll.C, Ill.A and IV.A of Appendix 1,10 CFR Part 50. The Operability Requirements are the guides set forth in Section ll.C of Appendix i. The statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix 1 to assure that the releases of radioactiva materials in gaseous effluents will be kept "as low as reasonably achievable." The ODOM calculational methods specified in the surveillance requirements implement the requirements in Section ill.A of Appendix 1 that conformance with the guides of Appen:iix 1 be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methods approved by NRC for calculating the doses due to the actual release rates of the subject materials are required to be consistent with the methodology provided in Regulatory Guide 1.109.

" Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I", Revision 1, October 1977 and Regu atory Guide 1.111, " Methods for Estimating Atmospheric Transport end Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors,"

Revision 1. July 1977. These equations also provide for determining the actual doses based upon the historical average atmosphenc conditions. The release rate limits for

radiciodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted l

area. The pathways which were examined in the development of these limits were: 1) l individualinhalation of airborne radionuclides,2) deposition of radionuclides onto green i leafy vegetation with subsequent consumption by man and 3) deposition onto grassy '

areas where milk animals graze with consumption of the milk by man.

l 4. Gaseous Waste Treatment l

l The operability of the gaseous waste treatment which reduces amounts or concentrations l of radioactive materials ensures that the system will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of this system be operable when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as reasonably achievable". This specification implements the

} requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 l CFR Part 50, and design objective Section 11.D of Appendix I to 10 CFR Part 50.

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.V g1rnurphybacmmnnendrescenwn12r1 8.coc 12-44

i DRESDEN Revision 1.8 July 1998 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.1 Monitorino Procram Ooerability Reouirements 12.5.1.A The Radiological Environmental Monitonng Program shall be conducted as specified in Table 12.5-1.

Acoficabilitv At all times.

Action

1. With the Radiological Environmental Monitoring Program not being conducted as specified in Table 12.5-1, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Section 12.6.1, a description of the re' sons for not conducting the program as required and the plans for preventing a recu~ence.

Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal availability, malfunction of sampling equipment, if a person / business who participates in the program goes out of business or no longer can provide sample, or contractor omission which is corrected as soon as discovered. If the equipment malfunctions, corrective actions shall be completed as soon as practical. If a person / business supplying samples goes out of business, a replacement supplier shall be found as soon as possible. All deviations from the sampling schedule will be described in the Annual Radiological Environmental Operating Report.

2. With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table ,

12.5-2 when averaged over any calendar quarter, prepare and submit to the l Commission within 30 days, pursuant to Technical Specification 6.9.B. a Special '

Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose

  • to a MEMBER OF THE PUBLIC is less than the calendar year limits of Section 12.3.A.2,12.4.A.2, or 12.4.A.3. When more than one of the l radionuclides in Table 12.5-2 are detected in the sampliag medium, this report l shall be submitted if:

concentration (1) . concentration (2) + .21.0 l reporting level (1) reporting level (2)

When radionuclides other than those in Table 12.5-2 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose

  • to A MEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of Section 12.3.A.2,12.4.A.2, or 12.4,A.3. This report is not required if the measured level of radioactinty was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Section 12.6.1.
  • The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report, g

gTnurphpodctn\annetdresden\dn12r1 8. doc 12-45

DRESDEN RGvision 1.8 July 1998 ,

12.5- RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (Continued)

3. If the sample type or sampling location (s) as required by Table 12.5-1 become(s) permanently unavailable , identify suitable attemative sampling media for the pathway of interest and/or specific locations for obtaining replacement samples and add them to the Radiological Environmental Monitoring Program as soon as practicable. The specific locations from which samples were unavailable may then be deleted from the monitoring program.

Prepare and submit controlled version of the ODCM within 180 days including a revised figure (s) and table reflecting the new location (s) with supporting information identifying the cause of the unavailability of samples and justifying the selection of new location (s) for obtaining samples.

Surveillance Recuirements 12.5.1.B The radioiogical environmental monitoring program samples shall be collected pursuant to Table 12.51 f rom the specific locations given in the table and figure (s) in the ODCM, and shall be analyzed pursuant to the requirements of Table 12.5-1 and the detection capabilities required by Table 12.5-3.

Baams 12.5.1.C The Radiological Environmental Monitoring Program required by this section provides representative measurements of radiation and of radioactive matenals in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation. This monitoring program implementsSection IV.B.2 of Appendix 1 to 10 CFR Part 50 anc S thereby supplements the radiological effluent monitoring program by venfying that the s measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring.

The initially specified monitoring program will be effective for at lerist the first 3 years of commercial operation. Following this period, program changes may be initiated based on operational experience.

l The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs), The LLDs required by Table 12.5 3 are considered optimum for routine environmental measurements in industrial laboratones. It should be recognized that the LLD is defined as a before the fact limit representing the capability of a measurement system and not as. an after the fact limit for a particular measurement.

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual. HASL 300 (revised annually), Currie, LA., " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry," Anal. Chem.

40,586-93 (1968), and Hartwell, J.K., Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

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-'. - DRESDEN Revision 1.8 July 1998 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (Continued) interoretations 12.5.1.D Table 12.5-1 requires 'one sample of each community drinking water supply downstream l of the plant within 10 kilometers." Drinking water supply is defined as water taken from j rivers, lakes, or reservDirs (not well water) which is used for drinking.

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DRESDEN Revision 1.8 July 1998 TABLE 12.5-1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM EXPOSURE PATHWAY NUMBER OF REPRESENTATIVE SAMPLES SAMPLING AN6 COLLECTION TYPE AND AND/ OR SAMPLE AND SAMPLE LOCATIONSm FREQUENCY FREQUENCY OF ANALYSIS

1. Airbome Samples from a total of eight locations: Continuous particulate sampler Radioiodine Canister:

Radioiodine and operation with sample collection 1-131 analysis beweekly Particulates a. Indicator- Near Field weekly, or more frequently if on near field samples and required due to dust loading, and control."

Four samples from locations within 4 km (2.5 mi) radioiodine canister collection in different sectors. biweekly. Particulate Samoler:

Gross beta analysis

b. Indicator- Far Field following weekly filter change 'and gamma Four additionallocations within 4 to 10 km (2.5 to isotopic analysis"'

6.2 mi) in different sectors. quarterly on composite filters bylocation on near

c. Control field sa control.gpies and One sample from a control location within 10 to 30 km (6.2 to 18.6 mi).

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DRESDEN Revision' t.8 July 1998 ,

TABLE 12.5-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM EXPOSURE PATHWAY NUMBER OF REPRESENTATIVE SAMPLES SAMPLING AND COLLECTION TYPE AND ANDIOR SAMPLE AND SAMPLE LOCATIONSm FREQUENCY FREQUENCY OF ANALYSIS

2. Direct Forty routine monitoring stations either with a Quarterly Gamma dose on each Radiation
  • thermoluminescent dosimeter (TLD) or with one TLD quarterfy.

instrument for measuring dose rate continuously, placed as follows:

a. Indicator-Inner Ring (100 Series TLD)

One in each meteorological sector, in the general area of the SITE BOUNDARY  ;

(0.1 to 2 miles);

b. Indicator- Outer Ring (200 Series TLD)

One in each meteorological sector, within 3.2  ;

to 10 km (2 to 6.2 mi); and

c. Other One at each Airborne location given in part .

1.a. and 1.b.

The balance of the TLDs to be placed at special interest locations beyond the Restricted Area where either a MEMBER OF THE PUBLIC or Commonwealth Edison employees have routine access.

(300 Series TLD) g-VnurphfodemWmerdresdenW112rt-8 doc O _ -

u -- _ _ - -

O

DREST *N- Revision'1 *

{, July 1996( )

TABLE 12.5-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM EXPOSURE PATHWAY NUMBER OF REPRESENTATIVE SAMPLES SAMPLING AND COLLECTION TYPE AND -

ANDI OR SAMPLE AND SAMPLE LOCATIONS"3 FREQUENCY FREQUENCY OF ANALYSIS

2. Direct d. Control . Quarterly Gamma dose on each Radiation"(Contd) TLD quarterly.

One at each Airbome controllocation given in part 1.c

3. Waterbome a. Indicator Quarterly W and
a. Ground / Well Gamma isotopic tritium analysis quarterly.

Samples from three sources only if likely to be affected."

b. Drinking

isotopicanalysesd 'on One Sample from each community drinking monthly cc,TMie; water supply that could be affected by the tritium analysis on station discharge within 10 km (6.2 mi) quartetty composite.

downstream of discharge.

c. Surface if no community water supply (Drinking Water) Weekly grab samples. Gross beta and gamma Waterm exists within 10 kn; downstream of dischargs isotopic analyses" on then surface water sampling shall be performed. monthly composite; tritium analysis on
a. Indicator quarterly composite.

One sample downstream

d. Control a. Control Weekly grab samples.

Sample

  • Gross beta and gamma isotopic analyses" on One surface sample upstream of discharge. monthly composite; tritium analysis on quarterly composite.

g haphrodemwnenweedenw12rt.8 doc 12-50

DRED. 4 ' Revision 1..

July 1998 i

TABLE 12.5-1 (Continued)  ;

~ RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM  ;

EXPOSURE PATHWAY NUMBER OF REPRESENTATIVE SAMPt.ES SAMPLING AND COLLECTION TYPE AND  !

ANDIOR SAMPLE AND SAMPLE LOCATIONS"3 FREQUENCY FREQUENCY OF '

ANALYSIS -

e. Sediment a. Indicator Semiannually. Gamma isotopic - t analysis (*' semiannually.. .;

At least one sample from downstwam marea i within 10 km (6.2 mi).

4. Ingestion a. Indicator Beweekly8 when animals are Gamma isotopic"3 and on pasture (May through I-131""8 analysis on each '
a. Milk
  • Samples from milking animals from a October), monthly at other times sample.

maximum of three locations within 10 km (Novemberthrough April).

(6.2 mi) distance.  ;

b. Control  ;

One sample from milkin0 animals at a control location within 10 to 30 km (6.2 to 18.6 mi).  ;

b. Fish a. Indicator Two times annually, Gamma isotopic analysis"3on edible
  • Representative samples of commercially and portions  !

recreationally important species in discharge #

area. t

b. Control
  • G P

Representative samples of commercially and i

recreationally important species _in contml  ;

locations upstream of discharge.

i 3

?

h g Wu p.,Wi.wwieuweedene12rt-8 doc l

4 12-51

_ .._ _ _________._,__.m. ,_.__m..__ _ . ___.____._.m__ ._.m._ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ ._ _ _ _ _ ._.__ _., ... m_~.......-._.,__,....,.-..............m... . ,

DRESDEN Revision 1.8 July 1998 TABLE 12.5-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM EXPOSURE PATiEVAY NUMBER OF REPRESENTATIVE SAMPLES SAMPLING AND COLLECTION ' TYPE AND ANDI OR SAMPLE AND SAMPLE LOCATIONS W FREQUENCY FREQUENCY 09-ANALYSIS

c. Food Products a. Indicator Annually Gamma isotopicW analysis on each sample.

Two representative samples from the principal food pathways grown in each of four major quadrants within 10 km (6.2 mi):

At least one root vegetable sample ("I At least one broad leaf vegetable (or '

vegetation)'")

b. Control Two representative samples similar to indicator samples grown within 15 to 30 km (9.3 to 18.6 mi).

i i

g wbg.ie JannexWresdendn12rt-8 doc O 'U O. .

DRESDEN R: vision 1.8 July 1998 4

TABLE 12.5-1 (Continued)

- RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM TABLE NOTATIONS (1) Specific parameters of distance and direction from the centerline of the midpoint of the two units and additional description where pertinent, shall be provided for each and every sample location in Table 1.1 1 of the ODCM Station Annexes. Refer to NUREG-0133,

  • Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants,"

October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979. i l

(2) Far field samples are analyzed when the respective near field sample results are I inconsistent with previous measurements and radioactivity is confirmed as having its j origin in airbome effluents from the station, or at the discretion of the Radiation Protection '

Director.

(3) Airbome particulate sample filters shall be analyzed for gross beta radioactivity 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air pammilate samples is greater than 10 times the yearly mean of control samples, game  : topic analysis shall be performed on the individual samples.

(4) Gamma isotopic analysis mea < s the identification and quantification of gamma emitting radionuclides that may be attributable to the effluents from the station.

(5) One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating

)

dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation. l The 40 locations is not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations; e.g., if a station is adjacent to a lake, some sectors may be over water thereby reducing the number of dosimeters which could be placed at the indicated distances. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading.

l (6) Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

(7) The " downstream" sample shall be taken in an area beyond but near the mixing zone.

The " upstream sample" shall be taken at a distance beyond significant influence of the discharge. Upstream samples in an estuary must be taken far enough upstream to be beyond the station influence.

(8) If milking animals are not found in the designated indicator locations, or if the owners decline to participate in the REMP, all milk sampling may be discontinued.

(9) Biweekly refers to every two weeks.  !

(10) 1-131 analysis means the analytical separation and counting procedure are specific for this radionuclide.

(11) One sample shall consist of a volume / weight of sample large enough to fill contractor specified container.

'w*

gwurphy\odem\anneMrescendn12r1-8.coc 1

12-53 j

DRESDEN Revision 1.8 July 1998 TABLE 12.5-2 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES REPORTING LEVELS WATER AIRBORNE PARTICULATE FISH MILK FOOD PRODUCTS ANALYSIS (pCi/I) OR GASES (pCi/mi (pCi/kg, wet) (pCi/I) (pCi/kg, wet)

H-3 20,000"3 Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zi-Nb 95 400 1-131 2* 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137 50 20 2,000 70 2,000 Ba-La-140 200 300.

(1) For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCill may be used.

(2) If no drinking water pathway exists, a value of 20 pCill may be used.

g Wiurphykxicm\annexkiresdenkin12rt -8 doc 0 __ - -

'f v O. .

. s

't -

DR lN Revision ..c July 1998 ,

TABLE 12.5-3 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS"8 LOWER LIMIT OF DETECTION (LLD)"'I ,

WATER AIRBORNE PARTICULATE FISH MILK FOOD PRODUCTS SEDIMENT ANALYSIS (pCi/I) OR GASES (pCi/m') (pCi/kg, wet) (pCill) (pCi/kg. wet) - (pCi/kg, dry)

Gross Beta 4 0.01 1000 H-3 2,000"3 hAn-54 15 130 Fe-59 30 260 Co-58,60 15 130 Zn-65 30 260

! Zr-Nb-95 15- ,

1-131

  • 1/15"3 0.07 100 0.5/503 60 Cs-134 15 0.01 100 15 60 150 Cs-137 18 0.01 100 18 80 180 Ba-La-140 15 15 g V%g.,Ay,winexWesdenw112rt-8 doc 12-55

DRESDEN Revtion 1.8 July 1998 .

f TABLE 12.5 3 (Continued)

DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS  %

I TABLE NOTATIONS j (1) The nuclides on this list are not the only nuclides intended to be considered. Other peaks that are identifiable, j together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological

Environmental Operating Report.

1 (2) Required detection capabilities for thermoluminescent dosimeters used for environmental measurements shall be f

in accordance with the recommendations of Regulatory Guide 4.13.

l- '(3) The Lower Limit of Detection (LLD) is defined, for purposes of these specifications, as the smallest concentration i of radioactive material in a sample that will yield a net count, above system background, that will be detected wrth l 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

' For a particular measurement system, which may include radiochemical separation, the LLD is defined as follows:

4.66 So + 3/t.

LLD =

(E) (V) (2.22) (Y) (exp ( ht))

4.66 S.

LLD -

(E) (V) (2.22) (Y) (exp (-ht))

l

,o Where: 4.66 Son 3/to g.

LLD =

the "a priori" Minimum Detectable Concentration (picoCuries per unit mass or volume),

so =

the standard deviation of the background counting rate or of the counting rate of a blank sample, as appropriate (counts per minute),

4 Total Counts

, ta E = the counting efficiency (counts per disintegration),

V = the sample size (units of mass or volume),

2.22 = the number of disintegrations per minute per picocurie, Y = the fractional radiochemical yield, when applicable.

A = the radioactive decay constant for the particular radionuclide (sec"),

g:Vnurphy'odemunnerwesden on12r1-8 doc 12-56

l I DRESDEN R vision 1.8

. July 1998 TABLE 12.5 3 (Continued) i DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS

! d TABLE NOTATIONS l

to = counting time of the backgrourd or blank (minutes), and j at = the elapsed time between sam;;?e collection, or end of the sample collection period, and the time i of counting (sec).

1 Typical values of E V, Y, and at should be used in the calculation.

It should be recognized that the LLD is defined as a before the fact limit representing the capability of a measurement system and not as an after the fact limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routirs conditions. ,

Occasionally, background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or j other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors I shall be identified and dexribed in the Annual Radiological Environmental Operating Report.

Attemate LLD Methodoloov An attemate methodology for LLD determination fol!ows and is similar to the above LLD equation:

f2.71 + 4.65VB) Decay l LLD =

E q b Y t (2.22E06)

Where:

B = background sum (counts)

E = counting efficiency, (counts detected / disintegrations) q = sample quantity, (mass or volume) b = abundance,(if applicable)

Y = fractional radiochemical yield or collection efficiency, (if applicable) t = count time (minutes) 2.22E06 = number of disintegrations per minute per microcurie (2.71 + 4.65VB) = k + (2k V 2 V B), and k = 1.645.

(k=value of the t statistic from the single-tailed t distribution at a significance level l of 0.95% and infinite degrees of freedom. This means that the LLD result represents a 95% detection probability wrth a 5% probabihty of falsely concluding that the nuclide present when it is not or that the nuclide is not present when it is.)

l Decay = e*# [ ART /(1-e'*"')) [ATo /(1-e')], (if applicable) l 0 vnuronyeoemannexwesoenen12r1-8. ooc 12-57

DRESDEN R; vision 1.8 July 1998 ,

TABLE 12.5 3 '~

DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS TABLE NOTATIONS A = radioactive decay constant, (units consistent with At, RT and Ta)

At = delta t", or the elapsed time between sample collection or the midpoint of sample coflection and the time the count is started, depending on the type of sample, (units consistent with A)

RT = elapsed real time, or the duration of the sample count, (units consistent with A)

To = sample deposition time, or the duration of analyte collection onto the sample media, (unit consistent with A)

The LLD may be determined using installed radioanalytical software, if available. In addition to determining the correct number of channels over which to total the background sum, utilizing the software's ability to perform decay corrections (i.e. during sample collection, from sample collection to start of analysis and during counting), this aitemate method will result in a more accurate determination of the LLD.

It should be recognized that the LLD is defined as a before the fact limit and not as an after the fact limit for a particular measurement.

If no drinking water pathway exists, the value of 15 pCi/l may be used.

(5) A value of 0.5 pCi/l shall be used when the animals are on pasture (May through October) and a value of 5 pCi/l shall be used at all other times (November through April).

(6) This LLD applies only when the analytical separation and countint procedure are specific for this radionuclide.

(7) This LLD is the minimum allowable, however, vendors performing environmental samp!e analyses off-site will be required to meet an LLD of 200 pCi/1.

l

%,./

g:Vnurphybdcmunnexwrescendn12r1 8. doc l

l 12-58 l

, DRESDEN Revision 1.8 July 1998 12.5.2 Land Use Census

,. Operability Recuirements 12.5.2.A. A Land Use Census shall be conducted and shall identify within a distance of 10 km (6.2 miles) the location in each of the 16 meteorological sectors

  • of the nearest milk animal, the nearest residence", and an enumeration of livestock. For dose calculation, a garden will be assumed at the nearest residence.

ADolicability: At all times.

Action:

1. With a Land Use Census identifying a location (s) that yields a calculated dose or dose commitment, via the same exposure pathway 20% greater than at a location from which samples l are currently being obtained in accordance with Section 12.5.1, add the new location (:-) within 30 days to the Radiological Environmental Monitoring Program given in Chapter 11. The sampling location (s), excluding the control location, having the lowest calculated dose or dose commitment (s), via the same exposure pathway, may be deleted from this monitonng program after October 31 of the year in which this Land Use Census was conducted. Submit in the next Annual Radiological Environmental Operating Report documentation for a change in the ODCM including a revised figure (s) and table (s) for the ODCM reflecting the new location (s) with information supporting the change in sampling locations.
  • This requirement may be reduced according to geographical limitations; e.g. at a lake site where some sector's will be over water.

"The nearest industrial facility shall also be documented if closer than the nearest residence.

  1. Surveillance Reouirements '

l 12.5.2.B The Land Use Census shall be conducted during the growing season, between June 1 and October I 1, at least once per 12 months using that information that will provide the best results, such as by a door-to-door survey, aerial survey, or by consulting local agriculture authorities. The results of the Land Use Census shall be included in the Annual Radiological Environmental Operating Report. l Bases i

12.5.2.C This specification is provided to ensure that changes in the use of areas at and beyond the SITE I BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring l Program given in the ODCM are made if required by the results of this census.

This census satisfies the requirements of Section IV.B.3 of Appendix i to 10 CFR Part 50. An annual garden census will not be required since the licensee will assume that there is a garden at the '

nearest residence in each sector for dose calculations.

g VnurphybdCm'ennexdresdendn12r1-a DOC 12-59

. i DRESDEN Rrvision 1.8 '

July 1998 .

T 12.5.3 Intertaboratorv Comoarison Procram 'W Ooerability Raouirements [

12.5.3.A - Analyses shall be performed on radioactive materiais supplied as part of an intertaboratory  !

Comparison Program that correspond to samples required by Table 12.5-1. j Acohcability At all times.

i AGli20 r

With analyses not being performed as required above, report the corrective actions '

1.

~ taken to prevent a recurrence to the Commission in the Annual Radiological  ;

Environmental Operating Report.

i Surveillance Reauirements

.12.5.3.B A summary of the results obtained as part of the above required interlaboratory Comparison Program shall be ;ncluded in the Annual Radiological Environmental Operating Report.

Bases r

12.5.3.C '

The requirement for participation in an interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive materialin environmental samples matrices are performed as part of the quahty  ;

assurance program for environmental monitoring in order to demonstrate that the results are -s.

valid for the purposes of Section IV.B.2 of Appendix 1 to 10 CFR Part 50. .  ;

/

f f

i i

i I

L i i

i

! [

f L

i .

% I g:VnurphybdcmWmexWresdenWn12rl-8 doc r 12-60 I t

. -. -. . - - .. . - _. .. =_ . _

4

. DRESDEN R: vision 1.8 July 1998 12.6 RECORDKEEPING AND REPORTING 12.6.1. Station Ooeratino Records

1. Records and/or logs relative to the following items shall be kept in a manner convenient for review and shall be retained for at least five years. ,
1. Records and periodic checks, inspection and/or calibrations performed to

! verify the surveillance requirements (See the applicable surveillanco in '

the Instrumentation, Liquid Effluents, Gaseous Effluents, and l

Radiological Environmental Monitoring Sections) are being met. All equipment failing to meet surveillance requirements and the corrective l action taken shall be recorded.

2. Records of radioactive shipments.

+

2. Records and/or logs relative to the following items shall be recorded in a manner convenient for review and shall be retained for the life of the plant.  ;
1. Records of off site environmental monitoring surveys.
2. Records of radioactivity in liquid and gaseous wastes released to the environment.
3. Records of reviews performed for changes made to the ODCM.

l .

12.6.2. Reports l '/

s . 1. Radioactive Effluent Release Report l l The Radioactive Effluent Release Report covering the operation of the unit during the previous 12 months of operation shall be submitted to the Commission prior to April 1 of each year. The report shallinclude a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.

The material provided shall be (1) consistent with the objectives ordlined in the i ODCM and PCP and (2) in conformance with 10 CFR Part 50.36a and Section IV.B.1 of Appendix i to 10 CFR Part 50.

2. Annual Radiological Environmental Operating Report i The Annual Radiological Environmental Operating Report covenng the operation  !

of the unit during the previous calendar year shall be submitted pnor to May 1 of each year. The report shallinclude summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the l reporting period. The material provided shall be consistent with the objectives in (1) the ODCM and (2) Sections IV.B.2., IV.B.3, and IV.C of Appendix l to 10 CFR

. Part 50. A detailed listing of the requirement of the report is given below:

l 2

v g:Vnurptr/& AannexwresdenWn12r1 8. doc

- 12-61

DRESDEN R2 vision 1.8 July 1998 .

12.6.2 Reports - (Cont'd)

(a) Results of environmental sampling summarized on a quarterly basis following the format of Regulatory Guide 4.8 Table 1 (December 1975);

(individual sample results will be retained at the station);

in the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for i the missing results. Summaries, interpretations, and analysis of trends of I the results are to be provided.

i (b) An assessment of the monitoring results and radiation dose via the principal pathways of exposure resulting frc.n plant emissions of  ;

radioactivity including the maximum noble gas gamma and beta air doses ,

in the unrestricted area. The assessment of radiation doses shall be  ;

performed in accordance with the ODCM.- )

(c) Results of the census to determine the locations of animals producing  !

milk for human consumption, and the pasture season feeding practices at dairies in the monitoring program.

?

(d) The reason for the omission if the nearest dairy to the station is not in the monitoring program.  ;

i (e) An annual summary of meteorological conditions concurrent with the l releases of gaseous effluents in the form of joint frequency distributions i of wind speed, wind direction, and atmospheric stability.

l (f) The results of the interlaboratory comparison program described in "

Section 12.5.3.

(g) The results of the 40 CFR Part 190 uranium fuel cycle dose analysis for  ;

each calendar year. ,

t (h) A summary of the monitoring program, including maps showing sampling  !

locations and tables giving distance and direction of sampling locations  !

from the station.

3. Non-Routine Environmental Report (a) If a confirmed measured radonuclide concentration in an environmental  !

sampling medium averaged over any calendar quarter sampling period I exceeds the reporting level given in Table 12.5-2 and if the radioactivity is l attnbutable to plant operation, a wntten report shall be submitted to the  :

Regional Administrator of NRC Regional Office, with a copy to the i Director, Office of Nuclear Reactor Regulation, within 30 days from the  !

end of the quarter. When more than one of the radionuclides in Table 12.5-2 are detected in the medium, the reporting level shall have been i exceeded if IC/(RL), is equal to or greater than 1 where C is the

{

concentration of the i* radionuclide in the medium and RL is the reporting level of radionuclide i.

Q  ;

I g:vnurphrodem\anneedresdorndn12r1-8 doc 12-62 i

1 - - t' er-*ie er . - ' - e-- -a. _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . . . - - _ . _ _ _ _ _ _

...-. - - . _. _ - - - .- .~_ -

l'e DRESDEN Revision 1.8

, . July 1998 l

I 12.6.2 Rooorts - (Cont'd)

(b) If radionuclides other than those in Table 12.5-2 are detected and are due to plant effluents, a reporting levelis exceeded if the potential annual dose to an individual is equal to or greater than the design objective doses of 10 CFR Part 50, Appendix 1.

(c) This report shallinclude an evaluation of any release conditions, environmental factors, or other aspects necessary to explain the j anomalous affect.

12.6.3. Offsite Dose Calculation Manual (ODCM)

, 1. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring Alarm / Trip setpoints and in the conduct of the Radiological Environmental Monitoring Program. The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs described in Section 12.2 - 12.5 and (2) desenptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports required by Sections 12.6.2.1 and 12.6.2.2.

The ODCM shall be subject to review and approval by the Commission prior to initialimplementation.

1

2. Changes to the ODCM:  !

?. (1) Shall be documented and records of reviews performed shall be retained

./ as required by Technical Specification 6.14.A. This documentation shall contain:

(a) Sufficient information te support the change together with appropriate analyses e,r evaluations justifying the change (s); and (b) A determination that the ' change will maintain the level of radioactive effluent control required by 10 CFR Part 20.1302,40 CFR Part 190,10 CFR Part 50.36a, and Appendix 1 to 10 CFR Part 50 and not adversely impact the accuracy or reliability of  !

effluent, dose or set point calculations. '

(2) Shall be effective after review snd acceptance by independent Technical Review and PORC/ Station Manager, on the date specified by the revision package.

l .-

l:  !

[ g:Vnu@rybe.n MnnextiresdenVin12r1-8. doc l- 12-63

i DRESDEN RIvision 1.8 July 1998 ,

12.6.3 'Offsite Dose Calculation Manual (ODCM)-(Cont'd)

(3) Shall be submitted to the Commission in the form of a complete, legible  :

. copy of the entire ODCM or updated pages, if the Commission retains a controlled copy, if an entire copy of the ODCM is submitted, it shall be ,

submitted as a part of or concurrent with the Radioactive Effluent ,

Release Report for the period of the report in which any change to the ODCM was made effective. Each change shall be identified by markings  ;

in the margin of the affected pages, clearly indicating the area of the page  ;

that was changed, and shall indicate the date (e.g., month / year) the >

change was implemented.

12.6.4 Maior Chanoes to Radioactive Waste Treatment Svstems fLiouid and GaseQMEl NOTE: This information may be submitted as part of the annual FSAR update. .

1. Licensee initiated major changes to the radioactive waste systems may be made provded. j i

The change is reported in the Monthly Operating Report for the period in which j the evaluation was reviewed by independent Technical Review. The discussion j of each change shall contain:  ;

i (1) A summary of the evaluation that led to the determination that the change i could be made in accordance with 10 CFR Part 50.59; i i

(2) Sufficient detailed information to support the reason for the change; m l (3) A detailed description of the equipment, components, and process "

i involved and the interfaces with other plant systems; l

(4) An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents that differ from those previously predicted in the license application and amendments; (5) A comparison of the predicted releases of radioactive materials in liquid l and gaseous effluents to the actual releases for the period in which the t changes were made; j (6) An estimate of the exposure to plant operating personnel as a result of the change; and (7) Documentation of the fact that the change was reviewed and found  ;

acceptable by independent Technical Review, j i

2. The change shall become effective upon review and acceptance by independent  !

Technical Review.

I y

g:VnurphrodctmannexWresdenen12r1 8.00c 12-64

~l