ML20198A305

Proposed ETS Changes for Consistency W/Rev 3 to NUREG-0472 & Rev 1 to Radiological Assessment Branch Technical Position on Environ Monitoring

ML20198A305
Person / Time
Site:	Three Mile Island
Issue date:	05/16/1986
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20198A290	List: ML20198A286 ML20198A300 ML20198A305
References
RTR-NUREG-0472, RTR-NUREG-472 NUDOCS 8605200417
Download: ML20198A305 (16)

Text

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LIMITING CONDITIONS FOR OPERATION 3.2 RADIOLOGICAL ENVIRONMENTAL MONITORING 3.2.1 MONITORING PROGRAM REQUIREMENTS The radiological environmental monitoring program shall be conducted and samples shall be collected as specified in Table 3.2-1. Samples shall be analyzed pursuant to the requirements of Table 3.2-1 and the detection capabilities required by Table 3.2-2.

APPLICABILITY: At all times.

ACTION:

With the radiological environmental monitoring program not being a.

conducted as specified in Table 3.2-1, prepare and submit to the Commission in the Annual Radiological Environmental Operating Report, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

b. With the level of radioactivity as the result of plant effluents in an l environmental sampling medium exceeding the reporting levels of Table 3.2-3 when averaged over any calendar quarter, prepare and submit to the Commission within 60 days from the end of the affected calendar quarter, 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 Specifications 2.1.1 and 2.1.2 of Appendix B. When more than one of the radionuclides in Table 3.2-3 are detected as the result of plant effluents in the sampling medium, this report shall be submitted if:

concentration (1) + concentration (2) +... >1.0 reporting level (1) reporting level (2)

When radionuclides other than those in Table 3.2-3 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 is equal to or greater than the calendar year limits of Specification 2.1.1 or 2.1.2 of Appendix B. This report is not required if the measured level of radioactivity 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.

c. With milk or fresh leafy vegetables unavailable from one or more of the sample locations required by Table 3.2-1, identify locations for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days.

• The methodology and parameters used to estimate the potential annual dose to a member of the public shall be indicated in this report.

THREE MILE ISLAND - UNIT 2 3.2-1

F LIMITING CONDITIONS FOR OPERATION f

i -

The locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause of the unavailability of samples and identify the new location (s) for obtaining replacement samples in the next semi-annual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new locations.

BASES:

The radiological monitoring program required by this specification provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of members of the public resulting from the station operation. This monitoring program thereby implementsSection IV B.2 of Appendix I to 10 CFR 50 and supplements the radiological effluent  ;

monitoring program by verifying that the measurable concentrations of I radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways. Guidance for this monitoring is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring (Revision 1, November, 1979). Program changes may be initiated based on operational experience.

I \

THREE MILE ISLAND - UNIT 2 3.2-2

TABLE 3.2-1 Y RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM A

m x - ,

Number of Samples

- Exposure Pathway and Sampling and TypeandFrequegcy g, and/or Sample Sample Locationsa Collection Frequency b of Analy:11 s 8

[ 1. AIRBORNE Z

H Particulates Samples from 5 locations Continuous sampler operation Analyze.for gross beta m from Table 1 of the ODCM. with sample collection radioactivity following weekly, or more frequently filter changed.

if required by dust loading. Perform gamma isotopic analysis e on composite (by location) sample quarterly.

2. DIRECT RADIATIONC Samples from 40 locations Quarterly Gamma dose-quarterly from Table 2 of the ODCM (using either 2 dosimeters w or at least 1 instrument for y continuously measuring and recording dose rate at each w

location).

TABLE 3.2-1 (Cont'd)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

.a Number of Samples h

Exposure Pathway and Sampling and Type and Frequency 3

and/or Sample Sample Locations a Collection Frequency b of Analysisb p

m cw

(

2

3. WATER BORNE Gamma isotopic analysis e

a. Surfacef Samples from 2 locations Composite 9 sample over 7 from Table 3 of the 00CM. .1-monthly period. monthly. Composite for c

z - 1 sample from downstream tritium-analysis quarterly.

H (indicator) location

- 1 sample from upstream (control) location (or location not influenced by plant discharges)

Samples from 2 locations Composite 9 sample over Gross beta and gamma

b. Drinking 1sotopic analysis e from Table 3 of the ODCM. 1-monthly period.

- 1 sample at the location monthly. Composite for of the nearest water supply tritium analysis

<a quarterly.

y that could be affected by station discharge.

a

- 1 sample from a control location.

Sample twice per year Gamma isotopic analysis e

c. Sediment from Samples from 2 locations of each sample, Shoreline (1 Control and 1 Indicator) (Spring and Fall) from Table 4 of the ODCM.

4. INGESTION Semi-monthly when animals Gamma isotopic analysis e

a. Milk Samples from 4 locations of each sample. Composite from Table 5 of the ODCM. are on pasture, monthly at other times. for Sr-90 analysis quarterly.

TABLE 3.2-1 (Cont'd)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM I

E Number of Samples ,

" Sampling and Type and Frequency Exposure Pathway and 3

and/or Sample Sample Locations a Collection Frequencyb of AnalysisD p

m 4 INGESTION (Cont'd)

b. Fish and Samples from 2 locations Sample twice per year Gamma isotopic analysis e 7 Invertebrates from Table 6 of the ODCM. (Spring and Fall) on edible portions.

c 2 - 1 sample of recreationally a important bottom feeders m and 1 sample of recrea-tionally important preda-tors in the vicinity of the plant discharge.

- I sample of recreationally important bottom feeders and 1 sample of recreationally important predators from an area not influenced by the

-[. plant discharge.

c. Food Products Samples from 2 locations At time of harvest. Gamma isotopic analysise from Table 7 of the ODCM on edible portion.

(when available).

- 1 sample of green leafy vegetables or leafy vege-tation at a location in the immediate plant vicinity (indicator).

- I sample of same species or group from a location not influenced by plant discharge.

TABLE 3.2-1 (ConU d)

TABLE NOTATION

a. Sampling locations are provided in the ODCM. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons. All deviations from the sampling schedule shall be explained in the Annual Radiological Environmental Operating Report.

b. Frequency notation: Weekly (7 days 125%), semi-monthly (15 days 125%),

monthly (31 days 125%), and quarterly (92 days 125%)

c. One or more instruments, such as a pressurized ion chamber fcr measuring and recording dose rate continuously, may be used in place of, or in addition to, integrating dosimeters. For the purpose of this table, a thermoluminescent dosimeter (TLD) is considered to be one phosphor; two or more phosphors in a packet are considered as two or more cosimeters.

Film badges shall not be used as dosimeters for measuring direct radiation.

d. Airborne 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 particulate samples is greater than ten times the mean of control samples, gamma isotopic analysis shall be performed on the individual samples,

e. Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

f. The " upstream sample" shall be taken at a distance beyond significant influence of the discharge. The " downstream sample" shall be taken in an area beyond but near the mixing zone,

g. Composite sample aliquots shall be collected at time intervals that are short (e.g., hourly) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sample.

THREE MILE ISLAND - UNIT 2 3.2-6

TABLE 3.2-2 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSESa LOWER LIMIT OF DETECTION (LLD)b c .

N N Airborne Water Particulate Fish Milk Food Products Sediment

- -Analysis (pC1/1) (pC1/m3) (pCi/kg, wet) (pC1/1) (pC1/kg, wet) (pC1/kg, dry)

[ f m

gross beta 4 1 x 10-2 . . . . .

2 -

7 3H 2000 y 54Mn 15 130

-4 m 59Fe 30 260 58,60Co 15 130 652n 30 260

, 95Z r' 30 90S r 2

~

95Nb 15 15 5 x 10-2 130 15 60 150 134Cs 18 6 x 10-2 150 18 80 180 137Cs 140Ba 60 60 15 140La 15 i

t

TABLE 3.2-2 (Cont'd)

TABLE NOTAT10N

a. This list dces not mean that only these nuclides are to be considered.

Other peaks that are icentifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Orzerating Report.

b. Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

c. The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net i

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 = 4.66 sb E V 2.22 Y exp(- A at)

Where:

LLD is the "a priori" lower limit of detection as defined above, as picocuries per unit mass or volume, sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate, as counts per minute, E is the counting efficiency, as counts per disintegration, V is the sample size in units of mass or volume, 2.22 is the number of disintegrations per minute per picocurie, Y is the fractional radiochemical yield, when applicable, A is the radioactive decay constant for the particular radionuclide and at for environmental samples is the elapsed time between sample collection, or end of the sample collection period, and time of counting.

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

THREE MILE ISLAND - UNIT 2 3.2-8

p _ __ . - .. . - . _. _.

E' y ,

. TABLE 3.2-2 -(Cont'd) _-

. . t,

1. .; TABLE NOTATION

- , s It should be recognized that the LLD is defined-as an "a priori" (before tu,e 'f act) limit representing'the capability of a measurement system and not'as an "a posteriori" (after the' fact) limit for a particular measurement. Analyses shall be' performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable c,trcumstances may render these LLDs unachievable. In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental

- Operating Report.

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i THREE MILE ISLAND - UNIT 1 3.2-9

TABLE 3.2-3 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES A

Airborne ,

Water Particulate Fish Milk Food Products Analysis .(pC1/l)' (pCi/m3) (pCilk), wet) (pC1/l) (pCi/kg, wet) m e-e

(

z H-3 2 x 10 4(a) 7 Mn-54 1 x 103 3 x 104 E Fe-59 4 x 102 1 x 104 N Co-58 1 x 103 3 x 104 Co-60 3 x 102 1 x 104 Zn-65 3 x 102 ,

2 x 104 Sr-90 8 Zr-Nb-95 4 x 102 E Cs-134 30 10 1 x 103 60 1 x 103 Cs-137 50 20 2 x 103 70 2 x 103 Ba-La-140 2 x 102 3 x 102 (a)For drinking water samples. This is 40 CFR 141 value.

LIMITING CONDITIONS FOR OPERATION 3.2.2 LAND USE CENSUS A land use census shall be conducted annually and shall identify within a distance of 8 km (5 miles) the location in each of the 16 meteorological sectors the nearest milk animal, the nearest garden

• of greater than 50 m2 (500 ft 2) producing broad leaf vegetation, and the nearest residence.

APPLICABILITY: At all times.

ACTION:

a. With a land use census identifying a location (s) which yields a calculated dose or dose commitment greater than the values currently being calculated in Specification 2.1.1 or 2.1.2 of Appendix B, identify the new location (s) in the next Semiannual Radioactive Effluent Release Report,

b. With a land use census identifying a location which yields a calculated dose or dose commitment (via the same exposure pathway) 20% greater than g at a location from which samples are currently being obtained in accordance with Specification 3.2.1, add the new location (s) to the radiological environmental monitoring program within 30 days. The sampling location, excluding the control station location, having the lowest calculated dose or dose commitments (via the same exposure pathway) may be deleted from this monitoring program after October 31 of the year in which this land use census was conducted. Identify the new location (s) in the next Seminannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

BASES:

This specification is provided to ensure that changes in the use of unrestricted areas are identified and that modificattorc, to the monitoring program are made if required by the results of this census. The best survey information from the door-to-door or aerial surveys or consulting with local agricultural authorities shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 500 square feet (50 m2) provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 Kg/yr) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were used: 1) that 20% of the garden was used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and

2) a vegetation yield of 2 Kg/ square meter.

• Broad leaf vegetation sampling of at least three differeit kinds of vegetation  ;

may be performed at the site boundary in each of two different sectors with

' the highest predicted D/Qs in lieu of the garden census. Specifications for broad leaf sampling in Table 3.2-1 shall be followed, including analysis of control samples.

THREE MILE ISLAND - UNIT 2 3.2-11

LIMITING CONDITIONS FOR OPERATION 13.2.3 INTERLABORATORY COMPARIS0N PROGRAM Analysis shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program which has been approved by the Commission (NRC).

APPLICABILITY: At all times ACTION:

With analyses not being performed as required above, report the corrective action taken to prevent a recurrence to the Commission in the Annual

~ Radiological Environmental Operating Report.

BASES:

The requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks on precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of a quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid.

l THREE MILE ISLAND - UNIT 2 3.2-12 l l

I l

more detailed analysis of the data and a proposed course of action to alleviate the problem.

The Annual Report shall also include a summary of:

1) All ETS noncompliances and the corrective actions taken to remedy them.

2) Changes made to state and federal permits and certification.

3) Changes made to the Environmental Program Description Document.

4) Changes in station design which could involve an environmental impact or change the findings of the FSFES.

5) All nonroutine submitted per ETS Section 4.6.

6) Changes in ETS.

A.(2) Annual Environmental Operating Report Part B Radiological

• Routine Radiological Environmental Operating Reports covering the operation of the Unit during the previous calendar year shall be submitted to the Commission prior to May 1 of each year.

The Annual Radiological Environmental Operating Reports shall include summaries, intu pretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with

. preoperational studies, with operational controls as appropriate, and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of land use censuses required by Specification 3.2.2.

The Annual Radiological Environmental Operating Reports shall include the results of analysis of all radiological environmental samples and environmental radiation measurements required by Table 3.2-1 taken during the period pursuant to the locations specified in the Table and Figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in a format similar to the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following: a sunmary description of the radiological environmental monitoring program; a map (s) of all sampling locations keyed to a table giving distances and directions from a point that is midway between the Reactor Buildings of TMI-l and TMI-2; the results of licensee participation in the Interlaboratory Comparison Program, required by Specification 3.2.3; discussion of all deviations from the sampling schedule of Table 3.2-1; discussion of all the required analyses in which the LLD required by Table 3.2-2 was not achievable.

• A single submittal may be made for a multiple unit station.

5-7

B. Data Reporting Formats Results of analysis of all nonradiological environmental data collected in accordance with Section 3.1 shall be summarized and tabulated on an annual basis. In the event that some results are not available by May 1, the report shall be submitted noting and explaining the missing results.

The missing data shall be submitted as soon as possible in a supplementary report.

C. Quarterly Radiological Releases and Estimated Dose Report The following information shall be submitted to the Director of the Regional Office. This information shall be submitted on a calendar quarter basis (January-March, April-June, July-September, and October-December) and shall be submitted no later than 60 days following the end of each calendar quarter.

(1) Estimates of the amounts and types of radioactivity that were released to the environment during the quarter and during the calendar year. This shall include estimates of the total activity of each nuclide and time rate of release of each nuclide.

(2) Estimates of population and maximum individual doses which occurred during the calendar quarter and during the calendar year shall be provided. The estimates shall be based on actual hydrological and meteorological conditions which occurred during the releases.

Calculational methods shall be those of U.S. NRC Regulatory Guides 1.109 (Revision 1, October 1977), 1.111 (Revision 1, July 1977),

1.112 (Revision 0-R, April 1976) and 1.113 (Revision 1, April 1977). These calculations shall be based on estimates of actual population distributions during the releases and shall take into consideration factors such as boating or fishing recreation.

' 6.2

. NONROUTINE REPORTS A report shall be submitted in the event that a " Limiting Condition for Operation" (Section 2), if applicable, is exceeded or if an " Exceptional Occurrence" as specified in Section 4.6 occurs. Report shall be submitted under one of the report schedules described below.

5.6.2.a Prompt Report Those events specified as prompt report occurrences shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, telegraph, or facsimile transmission to the NRC followed by a wr". ten report to the NRC within 30 days.

5-8

5.6.2.b -Thirty Day Event N6nroutine events not requiring a prompt report as described in Subsection 5.6.2.a shall be reported to the NRC either within 30 days of their occurrence or within the time limit specified by the reporting requirement of the corresponding certification or permit issued pursuant to Sections 401 or 4-2 of PL 92-500, which ever time during following the nonroutine event shall result in the earlier submittal.

5.6.2.c Content of Nonroutine Reports Written 30-day reports and, to the extent possible, the preliminary telephone, telegraph, or facsimile reports shall (a) describe, analyze, and evaluate the occurrence, including extent and magnitude of the impact, (b) describe the cause of the occurrence, and (c) indicate the corrective action (including any significant changes made in procedures) taken to preclude repetition of the occurrence and to prevent similar occurrences involving similar components or systems.

5-9