ML20205B015

From kanterella
Jump to navigation Jump to search
Radiological Effluent Tech Specs (RETS) Implementation - Point Beach Nuclear Plant
ML20205B015
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 05/31/1985
From: Serrano W
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML20205B020 List:
References
CON-FIN-A-6459 EGG-PBS-6863, NUDOCS 8506050540
Download: ML20205B015 (32)
v • d • e


Text

{{#Wiki_filter:. EGG-PBS-6863 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) IMPLEMENTATION-POINT BEACH NUCLEAR PLANT William Serrano John W. Mandler Thomas E. Young Published May 1985 EG&G Idaho, Inc. j Idaho Falls, Idaho 83415 i Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6459 TS$6050546 )U-

ABSTRACT A review of the Radiological Effluent Technical Specifications (RETS) of the Point Beach Nuclear Plant was performed. The principal review guidelines used were NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," and Draft 7" of NUREG-0472, Revision 3, " Radiological Effluent Technical Specifications for Pressurized Water Reactors." Draft submittals were discussed with the Licensee by both EG&G and the NRC staff until all items requiring changes to the Technical Specifications were resolved. The Licensee then submittod final proposed RETS to the NRC which were evaluated and found to be in compliance with the NRC review guidelines. The proposed Offsite Dose Calculation Manual was reviewed and generally found to be consistent with the NRC review guidelines. 1 I i

I l FOREWORD This Technical Evaluation Report was prepared by EG&G Idaho, Inc. under a contract with 'the U. S. Nuclear Regulatory Comission (Office of Nuclear Reactor Regulation, Division of Systems Integration) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC. 1 i D 11 \\

CONTENTS f ABSTRACT.............................................................. 11 FORDWORD.............................................................. 1 1. INTRODUCTION..................................................... 1.1 Pu rpose of the Techn ical Eval u ati on........................ 1 1.2 Gen e ric I s su e Back g rou n d................................... 1 3 1.3 Pl ant-Sp ec i f ic Back g rou nd.................................. 3 2. RE VI EW C R ITER I A.................................................. 5 3. TECHNICAL EVALUATION............................................. 8 3.1 General Description of Radiological Ef fluent Systems....... 8 3.2 Radiol ogical Ef fl uent Technical Specifications............. 10 3.3 Of f s ite Dose Cal cul ation Manu al............................ 20 4. C O NC L U S I O N S...................................................... 23 5. R E F E R E NC E S....................................................... 25 FIGURES 1. Point Beach liquid radwaste treatment and discharge pathways..... 9 2. Point Beach gaseous radwaste treatment and discharge pathways.... 11 TABLE 1. Correspondence of provisions of NUREG-0472. The Licensee's current technical specifications and the Licensee's proposal fo r the Po int Beac h Nucl ear Pl ant................................ 24 I I 111 I l

1. INTRODUCTION 1.1 Purcose of the Technical Eval u ation The purpose of this Technical Evaluation Report (TER) is to review and evaluate the proposed changes in the Technical Specifications of the Point Beach Nuclear Plant (PBNP) with regard to Radiological Effluent Technical Specifications (RETS) and the proposed Offsite Dose Calculation Manual (00CM). The evaluation used criteria proposed by the Nuclear Regulatory Commission (NRC) staff in the model Technical Specifications for pressurized water reactors (PWRs), NUREG-0472,[13 and subsequent revisions. This effort is directed tcward the NRC objective of implementing RETS which comply with the regulatory requirements, primarily those of 10 CFR Part 50, j Appendix I.[23 Other regulations pertinent to the control of effluent releases are also included within the scope of compliance. 4 1.2 Generic Issue Backcround l Since 1970, 10 CFR Part 50, Section 50.36.a,[33 " Technical l Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide Technical Specifications which ensure that radioactive releases will be kept as low as is reasonably achievable ( ALARA). In 1975, numerical guidance for the ALARA requirement was issued in 10 CFR Part 50, Appendix I. The licensees of all operating reactors were requiredE43 to i submit, no later than June 4,1976, their proposed ALARA Technical Specifications and information for evaluation in accordance with 10 CFR Part 50, Appendix I. However, in February 1976, the NRC staff recommended that proposals to modify Technical Specifications be deferred until the NRC completed the model RETS. The model RETS deal with radicactive waste management systems and environmental monitoring. Although the model RETS address the 10 CFR 1 i i I l t.

1 Part 50, Appendix I requirements, subsequent revisions include provisions for addressing issues not covered in Appendix I. These provisions are stipulated in the following regulations: i 10 CFR Part 20,[5] " Standards for Protection Against Radiation," o Sections 20.105.c, 20.106.g and 20.405.c which require that nuclear power plants and other Licensees comply with 40 CFR Part 190,[6] " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40 CFR Part 190 limits have been or may be exceeded. 10 CFR Part 50, Appendix A,[73" General Design Criteria for o Nuclear Power Plants," which contains Criterion 60--Control of releases of radioactive materials to the environment; Criterton 63--Monitoring fuel and waste storage; and Criterion 64--Monitoring radioactive releases, 10 CFR Part 50, Appendix B,[8] which estabi tshes the quality o assurance required for nuclear power plants. The NRC position on the model RETS was established in May 1978 when the NRC's Regulatory Requirements Review Committee approved the model RETS: NUREG-0472 for PWRs and NUREG-0473 for BWRs. Copies of the model RETS were sent to licensees in July 1978 with a request to submit proposed site-specific RETS on a staggered schedule over a six-month period. Licensees responded with requests for clarifications and extensions. The Atomic Industrial Forum ( AIF) formed a task force to comment on the model RETS. NRC staff members first met with the AIF task force on June 17, 1978. The model RETS were subsequently revised (Revision 1) to reflect comments from the AIF and others. A principal change was the transfer of much of the material concerning dose calculations from the model RETS to a separate document, the ODCM, 2 e n,

Revision 1 of the model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133)[93 for preparation of the RETS and o the ODCM and a new schedule for responses, again staggered over a six-month period. Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subskquently, a preliminary copy of Revis' ion 2 of the model RETS and additional guidance on the 00CM and a PCP were issued in February 1979 to each utility at individual meetings. NUREG-0472, Revision 2[13 and NUREG-0473, Revision 2[10] were published in July 1979 and updated in January 1980 and February 1980. In response to the NRC's request, operating reactor i fconsees subsequently submitted initial proposals on plant RETS and the ODCM. Review leading to ultimate implementation of these documents was 'etlated by the NRC in September 1981 using subcontracted independent teams as reviewers. As the RETS reviews progressed, feedback from the i tcensees led the NRC to modify some of the provisions in the February 1,1980 version of Revision 2 to clarify specific concerns of the i tcensees and thus expedite the reviews. Starting in April 1982, the NRC distributed revised versions of RETS in draft form to the licensees during the site visits. The new guidance on these changes was presented in an AIF meeting on May 19, 1982.[113 Some interim changes regarding the Radiological Environmental Monitoring Section were issued in August 1982.[123 With the incorporation of these changes, the NRC issued Draft 7" of Revision 3 of NUREG-0472Cl3] and NUREG-0473[143 in September 1982 to serve as new guidance for the review teams. 1.3 Pl ant-Soecific Backaround In conformance to the 1975 directive,[43 the Wisconsin Electric Power l Company (WE), the Licensee of the Point Beach Nuclear Plant Units 1 and 2, filed with the NRC on June 4,1976C153 a license amendment request. The request included proposed ALARA Technical Specifications for review and approval by the NRC. i -Y 3

In response to the NRC's letters of July 11,1978 (Mr. B. R. Grimes, Assistant Of rector for Engineering and Projects, Division of Operating Reactors, to all power reactor licensees) and November 15, 1978, W isconsin Electric submitted proposed changes to the Point Beach Technical Specifications [163 for NRC review. The NRC reviewed the proposal and L-identified review coments in memorandum dated March 31, 1980.[173 EG&G Idaho, Inc. (EG&G), selected as an independent task review team, initiated a review and evaluation of this submittal. The submittal was compared with the model RETS and assessed for compliance with the requirements of 10 CFR Part 50, Appendix I, and 10 CFR Part 50, Appendix A. ~ 4 Review coments and questions dated May 17, 1982,[18] concerning the RETS proposal were mailed to the NRC and the Licensee prior to arranging a j site visit with the licensee. During the site visit (June 2-3, 1982), 1 technical discussions resolved some of the shortcomings of the proposed RETS (e.g., missing information and other deviations from the requirements) identified in the submitted review. A sumary of the site visit discussions was submitted to the NRC by EG&G in letter dated February 17, 1983.[193 The NRC submitted review coments to the Licensee in letter dated April 25, i 1983.[20] The Licensee responded with a modified RETS submittal dated September 1983 to the NRC with letter dated October 7, 1983.[213 The October 1983 letter contained the modified RETS, the proposed 00CM, the June 1982, Revision 2 Environmental Monitoring Manual, and the Process Control Program. EG&G reviewed the submittals contained with the Licensee's October 1983 letter and transmitted review comments to the 20 with letter dated January 9, 1984.[22] The NRC transmitted review coments to the Licensee with letter dated July 18, 1984.[233 The resultant changes were discussed I between the NRC and the Licensee during a meeting held on October 11, 1984 in Bethesda, Maryland. The Licensee submitted proposed changes to the RETS i with letter dated December 20, 1984.[243 EG&G reviewed the December 1984 RETS proposal and transmitted review comments to the MC with letter dated February 15, 1985.[25] The coments were discussed between.EG&G and NRC in a meeting held on February 27, 1985 in Bethesda, Maryland. The discussions resolved most of the remaining issues and the remainder were 4

resolved between the NRC and the Licensee. The Licensee also submitted ccst-benefit analyses in support of the Radioactive Waste' Treatment Technical Specification with letters dated March 11, 1985 [26] and April 12, 1985.[27] The cost-benefit analyses were reviewed and approved by the NRC. The resolution to all issues allowed EG&G to prepare a TER for submittal to the NRC. 'The Licensee's 00CM proposal submitted with letter dated October 1983[21] was reviewed by EG&G. EG&G review comments were transmitted to the NRC with letter dated January 9, 1964.[22] The comments were discussed between the NRC and the Licensee at the meeting held on October 11, 1984 As a result a complete revision to the ODCM dated January 1985 was prepared by the Licensee and submitted to the NRC. The PBNP Environmental Manual is incorporated into the Offsite Dose Calculational Manual by reference. The 00CM was reviewed by EG8G and review comments transmitted to the NRC with letter dated April 5, 1985.[28] It was determined the ODCM contains documented and approved methods that are generally consistent with the guidelines of NUREG-0133 and is therefore acceptable to NRC as a reference. 2. REVIB# CRITERIA Review criteria for the RETS were provided by the NRC in three documents: 1. NUREG-0472, RETS for PWRs 2. NUREG-0473, RETS for ENRs 3. NUREG-0133, Preparation of RETS for Nuclear Power Plants Twelve essential criteria are given for the RETS and ODCM: 1. All significant releases of radioactivity shall be controlled and monitored. I

f l 2. Offsite concentrations of radioactivity shall not exceed the 10 CFR Part 20, Appendix B, Table 2 limits.[293 3. Of fsite radiation doses shall be ALARA. 4 Eqaiprnent shall be maintained and used to keep offsite doses ALARA. 5. Radwaste tank inventories shall be limited so that failures would not cause offsite doses exceeding 10 CFR Part 20 limits. 6. Hydrogen and/or Oxygen concentrations in the waste gas system shall be controlled to prevent explosive mixtures. I l 7. Wastes shall be processed to shipping and burial ground criteria l under a documented program, subject to quality assurance vertftcation. 8. An environmental monitoring program, including a land use census, shall be implemented. 9. The radwaste management program shall be subject to regular audits and reviews.

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

l

11. Periodic and special reports on environmental monitoring and on releases shall be submitted.
12. Offsite dose calculations shall be performed using documented and approved methods consistent with MtC methodology.

l l G 1

In addition to NUREG-0472 and NUREG-0473 and their subsequent revisions, the NRC staff issued guidelines, [30,31] clarifications, [32,333 and branch positionsC34,35,36] establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS requirements. The NRC branch positions issued since ths RETS implementation review began have clarified the model RETS for operating reactors. ' Review criteria for the ODCM are based on the following NRC guidelines: Branch Technical Position, " General Content of the Offsite Dose Calculation Manual;"[37] NUREG-0133;[93 and Regulatory Guide 1.109.[38] The format for the 00CM is left to the licensee and may be simplified by tables and grid printouts. G 7 i

3. TECHNICAL EVALUATION 3.1 General Descrietion of Radiolocical Effluent Systems This briefly describes the liquid and gaseous radwaste effluent treatment systems, release paths, and control systems installed at Point Beach Nuclear Plant, a RWR, 3.1.1 Radicactive Liouid Effluents A block diagram of the radioactive liquid waste treatment system and i discharge pathways for the Point Beach Nuclear Plants was obtained from the 00CM and is shown in Figure 1. This system can be utilized to process steam generator blowdown and primary side liquid wastes. Processing of liquid wastes is accomplisSed at PENP by the Chemical and Volume Control System and the Liquid Radfoactive Waste System. The Chemical and Volume Control System (CVCS) holdup tanks are shared between Units 1 and Unit 2 and collect reactor coolant letdown for boron control and other miscellaneous reactor coolant drains. These liquids are then processed by the boron recovery portion of the CVCS. Boric acid evaporator condensate is released to the circulating water discharge or recycled to the makeup water storage tank. Activity is released in liquid effluents from the CVCS, the liquid radioactive waste system, and secondary system wastes collected and sent to the retention pond. The CVCS system is operated continuously during normal plant operation. The CVCS will be operated continually except during unlikely periods of system inoperability. Secondary system wastes are collected and discharged without processsing since they are insignificant contributions to total plant liquid releases. The processing of steam generator blowdown and all liquid wastes collected from the controlled side of the plant is not done continually. These wastes may be discharged from the plant without processing. Liquid wastes from the radioactive waste disposal system are diluted by the circulating water system prior to release to Lake Michigan. Liquid waste from the waste disposal system may be discharged to the circulating water system of either unit via the service l

h 4 A f I D -:s .I E a 4-3! l's h 5,,

a..

E e g /% -C a6 'Jk ' A . E.7 t= \\ /% 4: e.3 E- ... 5 7. L 7. -. i.r g =- I -.'3 VN. >e. - A -3 .--t%e L-eJ%.--- i I a J e' k w 5 { 21* t. I s-* 1 1 11 lit

  • ]"

lA 2 st =2* -s a m

  • (

db A 3 I => l*r A c g,f j m 55 l I ki o

  • 1 o

-->',l i

2. :

E u v - a e l "5 -s I,- = IT E = t -+l 2 U M ss u g [E e Ia [ g 6 ,, j d ^ 3., \\ v A & c -4 m -11 i.. ~ M

    • S m

c o 32 % it c; i;* e 4 M 'I f m g g L a* .4 $1 I 21 I ~ 4 o 5 4 a e n m, l a m r I j 'O (D. Qy fe m gp 2- .E 1 54 T l I> !s

  • I '4 11 D2 '

i -{ '! 5 r 2 e j*ii i is . w2: l.. a i a I 6 ~ g j 8 A E 2 } r m = P ---d a i a a 1 l o = ] 2, a 8 f 8 a 3 3 s I 1.r 2 2, e -,8 .35 3 y a a i-jEfr i ! r r r-o I "I :r s r .t t S-A t y d A a I ( g i i j 3 s -I [ y 8 3 l 1 l l e s J I 2 E I 1 1 t f J E i 2 2 2 2 2 2 ]I Q II q 5 I j i ! ! 3 al-Q9 5 1-O 3 E I', 2 SE -j ~

t
)

I:

l A

k

5, s A

( 3 e i 3: !2 5! !i i

water return header. Because of the low radioactivity levels in the circulating water discharge, the concentrations of liquid radioactive effluents at this point are not measured directly. The concentrations in the circulating water discharge are calculated from the measured concentration of the liquid effluent, the discharge flow rate of the effluent and the nominal flow in the circulating water system. 3.1.2 Radioactive Gaseous Effluents A block diagram of the radioactive gaseous waste treatment system and discharge pathways for the Point Beach Nuclear Plants was obtained from the ODCM and is shown in Figure 2. Processing of gaseous wastes is accomplished st PBNP by the gaseous radioactive treatment system and ventilation exhaust filtration systems. Filtration systems are provided for the removal of particulates and/or radiciodines in the Unit I and Unit 2 containment purge and drumming area exhaust stacks, from the auxiliary building ventilation, shield building ventilation, and the chemistry laboratory exhaust, and from gas decay tank and air ejector effluents. Noble gases stripped from primary coolant letdown can be processed by the compressed gas decay tank system. Noble gas releases are on a batch basis following a decay time. The HEPA and carbon adsorber filtration systems are expected to operate continually except the auxiliary building ventilation charcoal filter and air ejector charcoal filter will be operatd to meet the release limits. Prior to release to the atmosphere, gaseous wastes are mixed in the auxiliary building vent with the flow from at least one of two auxiliary building exhaust fans. Further dilution then occurs in the atmosphere. 3.2 Radioloatcal Effluent Technical Soncifications The following subsections describe the primary objectives of each section of the model RETS and a summary of the commitments of the 10 l l \\

l nemftleef StillOING Efwlt ta aten.,d.cee entte 1 e 3 helmine sultatee weetiletten d E tttAst%It t% -.t.,l .t .we. l... y . f mersettney u service setteing wentitetlen s u - c.. wt wt 'h g _.I I 7 Y-I f g ~ to g ud-I ammelliery mostletag vestitetlese I x i I T huelltery Bhat)dlag geget t letleut $3mW hadletlem Arees) k f toesy 3 I W i En.a a i--or tm.r vtwr 9.it i. it..t e m. W , t w.t c e se,. s.s g 1 8 unite I e 2 See gecer gese Effloomt e < r g ui is Peteensstwt sinence g omat aar ejer.aen Refseemt g mest a votmut Cnerfoot Tasest T' g tatt 2 Att tjeeter Effluseit COCE"8C toelt 7 3 O p trueratenest f 1 e-- 1 l._ m.ite i.. w e l 4g ree. 8,ta=== ces seete,es. ymmes F I'm (1bertant, vnnst n ~ 8pE entt I ensitelsement cesittemmes voet RT 282 1 J m Onit 1 contalmeent Pineena d DetmeegeC 4 l * * - " * " 4 er.,r telt 7 emmtetsuneet e==** emot .8 malt 3 timmtetsument Perge a r 4 5 .:. 21 o Delte I e 3 See SteIpper totidlag venttIetten 9 r ain. 24 's 3 unite I s 3 gyeset reet Peel Serface t h 3,et l

  1. f 4F28M Mf th cumprnst F it.Tr a '

F 3 g.TT A aristgieer s i s' htte 9 4 2 segmentag a 9,,gg w,,,, g,,, I.1 1 M, ge.eptat puertr f DAntpAf fIVf f.A%If4f518A%31 .-) to tl'issat pruttr gggggg,g pgienggeseg Figure 2. Point Beach gaseous radwaste treatment and discharge pathways, 4 e

1 i i Licensee's RETS. A cross-reference between the numbering in the model RETS and the Licensee's RETS is contained in Table 1. The chronological sequence of the RETS review was described in the Plant-Specific Background, Section 1.3 of this report. 3.2.1 Ef fluent Instrumentation ' 'The objective of the model RETS with regard to effluent instrumentation is to ensure that all significant liquid and gaseous radioactive effluents are monitored. The model RETS specify that all effluent monitors be operable with periodic surveillance and that alarm / trip setpoints be determined in order to ensure that offsite radioactive effluent concentrations do not exceed maximum permissible concentrations (MPCs) listed in 10 CFR Part 20. The Licensee has provided radiation monitors for all effluent lines with potential for release of significant amounts of radioactivity in liquid or gaseous effluents. 3.2.1.1 Radioactive Licuid Effluent Instrumentation. There are three release points for radioactive liquids to the circulating water discharge and each release point is provided with a radiation monitor. Additionally monitors are provided at significant locations upstream from these release points as shown in Figure 1. Stream flows are determined from instrumentation or pump curves. Thus, instrumentation is provided for all significant radioactive liquid release points with acceptable surveillance performed on the monitoring system. 3.2.1.2 Radioactive Gaseous Effluent Instrumentation. Radioactive gases are released to the atmosphere at four release points. Each release point is provided with radiation monitors w:th additional monitors at significant locations upstream from the release points as shown in Figure 2. Noble gas and SPING monitors are located at each release point. Eacn monitoring system contains flow rate measuring devices and acceptable surveillance checks are performed on each system. 12 i

l 3. 2.1. 3 Licuid and Gaseous Instrumentation Seteoints. The Licensee's Technical Specifications require that the concentration of radioactive material will be monitored "during releases via this pathway" for all monitored effluent paths. The setpoints at each release point are established to prevent exceeding the release concentrations for liquid releases or corresponding dose rates for gaseous releases of 10 CFR Part 20 in unrestricted areas. The setpoints for the liquid and gaseous effluent instrumentation will be determined in accordance with the Offsite Dose Calcul ation Manual (ODCM). The Licensee's RETS submittal on liquid and gaseous effluent monitoring instrumentation has satisfied the provisions and meets the intent of NUREG-0472. 3.2.2 Concentration and Dese Rates of Effluents 3.2.2.1 Licuid Effluent Concentration. The Licensee's RETS include a commitment to maintain the concentration of radioactive liquid effluents released from the site to the unrestricted areas to within 10 CFR Part 20 limits. Both batch and continuous radioactive liquid releases are sampled and analyzed periodically in accordance with an acceptable sampling and analysis program. Therefore, the Licensee's RETS submittal on liquid effluent concentrations meets the intent of NUREG-0472. 3.2.2.2 Gaseous Effluent Dose Rate. The Licensec's RETS include a commitment to maintain the gaseous dose rate from the site in the unrestricted area to within NUREG-0472 limits. Both batch and continuous radioactive gaseous releases are sampled and analyzed periodically in accordance with an ecceptable sampling and analysis program. Thersfore, the Licensee's RETS submittal on gaseous effluent dose rates meets the intent of NUREG-0472. 13 l

3.2.3 Offsite Doses fron Effluents The objectives of the model RETS with regard to offsite doses from ef fluents are to ensure that offsite doses are kept ALARA, are in compliance with dose specifications of NUREG-0472 and are in accordance with 10 CFR Part 50, Appendix I and 40 CFR Part 190. The Licensee's RETS include a commitment to: 1. Limit the quarterly and annual dose due to liquid effluents to within the NUREG-0472 critaria 2. Limit the quarterly and annual air dose due to noble gas releases converted to total body and skin doses to within the NUREG-0472 criteria 3. Limit the quarterly and annual dose to any organ due to release of iodine-131, tritium, and radionuclides in particulate form to within the NUREG-0472 criteria. The Licensee's RETS state that compliance to 40 CFR 190 is assured oy demonstrating compliance to the Appendix I doses. However, the direct radiation component will be included if necessary to demonstrate compliance in the event the radioactive effluents exceed twice the annual limits. Therefore, the Licensee's RETS submittal of offsite doses from radioactive effluents meets the intent of NUREG-0472. 3.2.4 Ef fluent Treatment The objectives of the model RETS with regard to effluent treatment are to ensure thst the radioactive waste treatment systems are used to keep l releases ALARA and to satisfy the provisions for Technical Specifications 9everning the maintenance and use of radwaste treatment equipment. 14 l l

The Licensee's submitted cost-benefit analyses demonstrated it was cost-beneficial to operate certain components of the radioactive liquid and gaseous treatment systems only when required to meet the release limits. This analysis was reviewed and approved by the NRC. A special report shall be submitted to the NRC with'i, thirty days if the treatment system is inoperable and the waste is being discharged for 31 days without treatment. 'Therefore, the Licensee's RETS submittal on effluent treatment meets the intent of NUREG-0472. 3.2.5 Tank Inventerv Limits The objective of the model RETS with regard to a curie limit on liquid-containing tanks is to ensure that in the event of a tank rupture, the concentrations in the nearest potable water supply and the nearest surface water supply in an unrestricted area would not exceed the limits of 10 CFR Part 20, Appendix B Table II. The objective of the model RETS with regard to a curie limit on gas-containing tanks is to ensure that in the event of an uncontrolled release of the tank's contents the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem. There are no tanks containing radioactive liquids outside of buildings. In addition, a dike surrounds the buildings. The only temporary tanks are those used for sludge lancing which are provided with a catch tray capable of containing the entire 4000-ga11on volume. It is impossible to inject gaseous activity into one stcrage tank to result in an offsite dose of 0.5 rem based on the corresponding total inventory of noble gases in. the reactor coolant system. Therefore, a Technical Specification stating the curie limit for a waste gas decay tank is not required. 15 G

Therefore, the Licensee's RETS submittal on tank inventory limits meets the intent of NUREG-0472. 3.2.6 Exelosive Gas Mixtures The objective of the model RETS with regard to explosive gas mixtures is to prevent hydrogen explosions in the waste gas system. The waste gas system is operated hydrogen rich. Therefore, the concentrations are controlled by limiting the oxygen concentrations to $,4% by volume. The proposed specifications and instrumentation for explosive gas mixtures have been approved by the NRC on an interim basis until the NRC establishes a final position on the explosive gas monitoring. Therefore, the Licensee's submittal on explosive gas mixtures meets the intent of NUREG-0472 for the interim. 9.2.7 Solid Radwaste System The objective of the model RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged before it is shipped from the plant to the burial site to satisfy the requirements of 10 CFR Part 20, Section 20.301 and 10 CFR Part 71.C39] l The Licensee's RETS include a comitment to use the solid radwaste l system in accordance with a Process Control Program to process wet radioactive wastes to meet shipping and burial ground requirements. l Therefore, the Licensee's RETS submittal on solid radioactive waste meets the intent of NUREG-0472. I l 3.2.8 Radiolecteal Environmental Monitorine Procram The objectives of the model RETS with regard to a radiological environmental monitoring program are to ensure that (a) an adequate 16 a

full-area coverage environmental monitoring program exists, (b) there is an appropriate land use census, and (c) an acceptable Interlaboratory Comparison Program exists. The monitoring program implements Section IV.B.2 of Appendix I to 10 CFR Part 50, the land use census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50, and the requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks are performed as part of the quality assurance program for environmental monitoring to demonstrate that valid results are obtained for Section IV.B.2 of Appendix I to 10 CFR Part 50. The Licensee's RETS on a radiological environmental monitoring program have followed the model RETS and the Branch Technical Position on the subject issued November 1979,[343 as applicable to the site, and have provided an adequate number of sample locations for pathways identified. The Licensee's method of sample analysis and maintenance of the monitoring program satisfies the requirements of Appendix I,10 CFR Part 50. The Licensee's RETS contain a land use census specification which requires j sufficient annual information for a PWR. The RETS also state that the Licensee will participate in an NRC approved Interlaboratory Comparison Program. Thus, the Licensee's RETS submittal for a radiological environmental program meets the intent of NUREG-0472. 3.2.9 Audits and Reviews The objective of the model RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring programs are properly conducted. The Licensee's administrative structure identifies the Unit Review Group (URG) and the Offsite Review Committee (OSRC) as the two groups l comparable to the Unit Review Group (URG) and the Company Nuclear Review and Audit Group (CNRAG), respectivel y. 17

The URG is responsible for reviewing all changes to the ODCM and the l PCP. The URG is also responsible for reviewing every release of radioactive material to the environment in excess of the release limits. 4 An audit of the activities encompassed by the Offsite Dose Calculation Manual and the Process Control Program and its implementing procedures shall be performed at least once every 24 months utilizing either offsite licensee personnel or a consulting firm. An audit of the radiological environmental monitoring program and the results thereof shall be performed at least once every 12 months utilizing either offsite licensee personnel or a qualified consulting firm. The results of these audits shall be transmitted to the Vice-President--Nuclear Power and the Chairman of the Offsite Review Committee. The URC and OSRC encompass the total responsibility for reviews and audits specified in NUREG-0472. Therefore, the Licensee's requirement for audits and reviews meets the intent of NUREG-0472. 3.2.10 Procedures and Records The objective of the model RETS with regard to procedures is to ensure that written procedures be established, implemented, and maintained for the PCP, the ODCM, and the GA program for effluent and environmental monitoring. The objective of the model RETS with regard to records is to ensure that documented records pertaining to the radiological environmental monitoring program are retained for the duration of the operating license. The Licensee's RETS include a requirement to establish, implement, and maintain written procedures for the radwaste solidification program (PCP) and the dose evaluation program (00CM). Quality assurance program procedures for effluent and environmental monitoring shall be addressed in the Quality Assurance Program. The Licensee's RETS state that records of analyses required by the Radiological Environmental Monitoring Program shall be permanently retained. 18

Therefore, the Licensee's RETS submittal on procedures and records 8 meets the intent of NUREG-0472. 3.2.11 Reoorts The objective of the model RETS with regard to reporting requirements is to ensure that appropriate annual and semf annual periodic reports and special reports are submitted to the NRC. The licensee's RETS include commitments to submit the following reports: 1. Environmental Monitorino This report is submitted on a semi-annual basis. The report will contain reasons for not conducting the environmental monitoring program as required, and reasons "or unavailability of samples. The report shall include results of the land use census and a description of corrective actions to be taken if the contracted laboratory is not participating in the Interlaboratory Comparison Program. 2. Semiannual Monitorino Recort Semiannual Monitoring Reports are submitted containing information relative to the amount of liquid, gaseous, and solid waste effluents released from the facility. It was determined that the reporting comitments met the intent of the requirements of NUREG-0472. 3. Snecial Recorts The Licensee's RETS include a commitment to file a special report under i the following conditions: Exceeding the liquid effluent dose limits according to o Specifications 15.7.5.F.3 and 15.7.8.4.E. l l 19

Exceeding the gaseous effluent dose limits according to o Specifications 15.7.5.F.3 and 15.7.8.4.E within 30 days of determination. Exceeding the total dose limits according to Specification o 15.7.5.H.3 within 30 days. Exceeding the reporting levels for the radioactivity measured in .o environmental sampling program Specification 15.7.7.C.1 within 30 days. Therefore, the Licensee's RETS submittal on reports meets the intent of NUREG-0472. 3.2.12 Other Administrative Controls An objective of the model RETS in the administrative controls section is to ensure that any changes to the PCP and ODCM and major changes to the radioactive waste treatment systems are reported to the NRC. The Licensee's RETS require that changes to the ODCM, PCP and major changes to the radioactive waste treatment systems be reported to the NRC. Notification of changes to the 00CM (including changes to the PBNP Environmental Manual) and the PCP will be included in the Semiannual Monitoring Report for the period in which the changes are made. Major changes to the radioactive waste treatment systems will be reported with the annual update to the FSAR. Therefore, the Licensee's RETS submittal for these administrative controls meets the intent of NUREG-0472. 3.3 Offsite Dose Calculation Manual As specified in NUREG-0472, the 00CM is to be developed by the Licensee 20

to document the methodology and approaches used to calculate offsite doses and maintain the operability of the ef fluent system. As a minimum, the ODCM should provide equations and methodology for the following topics: alarm and trip setpoints for effluent instrumentation o liquid effluent concentration in unrestricted areas o gaseous effluent dose rate or concentrations at or beyond the site o boundary liquid and gaseous effluent dose contributions o total dose compliance, including direct shine o liquid and gaseous effluent dose projections. o In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management A description and the location of samples in support of the systems. environmental monitoring program are also needed in the 00CM. 3.3.1 Evalu ation The alarm setpoint for the liquid effluent monitors are based on the MPC of a reference isotope. The setpoint calculation satisfies the equation in the addendum of NUREG-0133 to determine the alarm and trip setpoints for the liquid effluent monitors. This assures that the alarm and trip actions will occur prior to exceeding the 10 CFR Part 20, Appendix B, Table II values at the discharge point to the unrestricted area. The alarm setpoints for the noble gas monitors are based on the MPC of a reference isotope. The calculation, based on equations similar to those in NUREG-0133, ensure that alarm will occur prior to exceeding the concentration limits in 10 CFR Part 20, Appendix B, Table II to the l unrestricted areas. Compliance to 10 CFR Part 50 Appendix I is assured by 1imiting the l curies released to below quantities which would result in the dose limits 21

of Appendix I. A summation of all releases in equivalent curies may be performed on a quarterly basis. Additionally dose calculations may be performed in lieu of determining the curies released. The curies released or the doses calculated are compared to the quarterly allowed limits to demonstrate compliance. For liquid effluents the limiting dose is the adult total body dose due to radiotodines a:id the adult total body dose due to tritium and particul ates. For gascous effluents, the total body noble gas gamma dose is limiting, the infant thyroid dose due to radiofodines is limiting, and for remaining isocopes the liver dos, to a child is limiting. Demonstration to 40 CFR Fart 190 compliance shall be performad if the dose calculations exceed twice the annual limits. The calculations shall include direct radiation contributions from the reactor units and from any outside storage tanks. Dose projections to determine use of the liquid or gaseous cleanup systems are not included in the 00CM. This is acceptable since the Technical Specifications based on a cost-benefit analyses require use of the equipment to meet the release limits. The ODCM contains block diagrams of the radioactive liquid and gaseous treatment systems and effluent flow paths. A complete description of the PBNP radiological environmental monitoring program is contained in the PBNP Environmental Monitoring Manual which is incorporated in the ODCM by reference. Specific parameters of distance and the direction sector from the plant, have been provided for each and every sample location. The Licensee's 00CM for the Point Beach Nuclear Plant is generally in compliance with the NRC requirements and uses methods consistent with the methodology and guidance prescribed in NUREG-0133. 22 l l

4.0 CONCLUSION

S The Licensee's proposed RETS and ODCM were reviewed and evaluated and the following conclusions were reached: o The Licensee's proposed RETS for the Point Beach Nuclear Plant submitted December 20, 1984 and modified by submittals dated March 11, 1985 and April 12, 1985 meets the intent of the NRC staff's " Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors", NUREG-0472. The specifications for explosive gas mixtures meet the intent for the interim. o The Licensee's 00CM dated January 1985 and submitted on January 21, 1985 uses documented and approved methods that are applicable to the Point Beach Nuclear Plant and are generally consistent with the guidelines of NUREG-0133. The PBNP Environmental Manual is included in the ODCM by reference. Therefore, the 00CM is an acceptable reference. A correspondence between (a) NUREG-0472, (b) the Licensee's current RETS, and (c) the Licensee's proposed RETS is shown in Table 1. l l l l l b 1 l

TABLE 1. CORRESPONDENCE OF PROVISIONS OF NUREG-0472, THE LICENSEE'S CURRENT TECHNICAL SPECIFICATIONS AND THE LICENSEE'S PROPOSAL FOR THE POINT BEC H NUCLEAR PLANT. Licensee Current Technical Proposal RETS Recu trements NUREG-0472 Soecification ( Section) Effluent 3.3.3.10 15.3.9. A 15.7.3.A.1 Instrumentation 3.3.3.11 15.3.9.B 15.7.3.B.1 Conenetration 3.11.1.1 15.3.9.C 15.7.5.A.2 3.11.2.1 15.3. 9.D 15.7.5.C.2 Offsite Doses 3.11.1.2 15.3.9.E 15.7.5.B.I.2 3.11.2.2 15.3.9.F.3 15.7.5.D.1.a,; 3.11.2.3 15.3.9.F.2,4,5 15.7.5.D.1.b,2 3.11.4 15.7.5.H Radwaste Treatment 3.11.1.3 15.3.9.I 15.7.5.G.1 3.11.2.4 15.3.9.I.2 15.7.5.G.2 Tank Inventory 3.11.1.4 Limits 3.11.2.6 Explosive Gas 3.11.2.5 15.7.5.I Mixtures Solid Radwaste 3.11.3 15.7.5.J Environmental Monitoring 3.12.1 15.7.7.A.1 Land Use Census 3.12.2 15. 7. 7. D Interlaboratory Comparison 3.12.3 15.7.7.E Audits and Reviews 6.5.1 15.6.5.2.6 15.6.5.2.6,7 6.5.2 15.6.5.3.8 15.7.8.2.A,B Procedures and. 'r<ecords 6.8 15.7.8.3 6.10 15.6.10.v Reports 6.9 15.6.9.2.0 15.7.8.4 Other Administrative 6.13 15.7.8.4.A.6 Control s 6.14 15.7.8.4.A.6 6.15 15.7.8.5 24 1 1

) 4 5. REFERENCES 1. United States Nuclear Regulatory Commission, Standard Radioloatcal Ef fluent Technical Soecifications for Pressurized Water Reactors, NUREG-0472, Revision 2, July 1979. 2. United States Office of The Federal Register, Title 10, Code of Federal Reculations, Part 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion ' As Low as is Reasonably Achievable' for Radioactive Material in . Light-Water-Cooled Nuclear Power Reactor Effluents." 3. United States Office of the Federal Register, Title 10, Code of Federal Reculations, Part 50, Section 50.36a, " Technical Specifications on Effluents from Nuclear Power Reactors." 4 United States Office of the Federal Register, Title 10, Code of Federal Recul ations, Part 50, Appendix I, Section V.B., " Effective Dates." 5. United States Office of the Federal Register, Title 10, Code of Federal Recul ations, Part 20, " Standards for Protection Against Radiation." 6. United States Office of the Federal Register, Title 40, Code of Federal Reculations, Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations." 7. United States Office of the Federal Register, Title 40, Code of Federal Reculations, Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants." 8. United States Office of the Federal Register, Title 10, Code of Federal l Reaulations, Part 50, Appendix B. " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." 9. United States Nuclear Regulatory Cormission, Preparation of Radiolacical Effluent Technical Soecifications for Nuclear Power Pl ants, NUREG-0133, October 1978. i

10. United States Nuclear Regulatory Commission, Standard Radioloofcal Effluent Technical Soecifications for Boiline Water Reactors, l

NUREG-0473, Revision 2, July 1979. l l 11. C. A. Willis and F. J. Congel, " Summary of Draft Contractor Guidance of RETS, "AIF Environmental Subcommittee Meetina. Washincton. D. C.", l May 19, 1982. l l i 12. F. J. Congel, memo to RAB Staff (NRC), Interim Channes in the Model BEII, August 9, 1982. i 25 t

A h l 13. United States Nuclear Regulatory Comission, Standard Radiolecical Effluent Technical Snecifications for Pressurized Water Reactors, NUREG-0472, Revision 3, Draft 7", September 1982. 14 United States Nuclear Regulatory Comission, Standard Radiolecical Effluent Technical Soecifications for Boilina Water Reactors, NUREG-0473, Revision 3, Graft 7", September 1982. 15. Letter from Sol Burstein, WE, to B.C. Rusche, NRC,

Subject:

TECHNICAL SPECIFICATION CHANGE REQUEST FOR MAINTAINING RELEASES AS LOf AS REASONABLY ACHIEVABLE, June 4,1976. 16. Letter from Sol Burstein, WE, to H. R. Denton, NRC,

Subject:

NODIFICATION TO CHANGE REQUEST NO. 33 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS POINT BEACH NUCLEAR PLANT UNITS 1 Am 2, January 28, 1980.

17. Memorandum R. L. Bangert, NRC, to A. Schwencer, NRC,

Subject:

REVIEW OF PROPOSED RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS FOR POINT BEACH NUCLEAR PLANT UNIT NO.1 AND 2, March 31,1930.

18. Letter from T. E. Young, EG&G, to C. A. Willis, NRC,

Subject:

TRANSMITTAL OF QUESTIONS FOR POINT BEACH RETS REVIEW-TEY-2-82, May 17, 1982.

19. Letter from W. Serrano, EG&G, to C. A. Willis, NRC,

Subject:

STATUS OF POINT BEACH RETS SUBMITTAL-Serr-7-83, February 17, 1983.

20. Letter from R. A. Cl ark, NRR, to C. W. Fay, WE,

Subject:

F0AW ARD EG&G

SUMMARY

OF DISCUSSIONS WITH RESPECT TO RETS DURING THE 6-2-82 PLANT .Y.L111, April 25,1983.

21. Letter from C. W. Fay, WE, to H. R. Denton, NRC,

Subject:

MODIFICATION TO CHANGE REQUEST NO. 33 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS POINT BEACH NUCLEAR PLANT UNITS 1 A m 2, October 7, 1983. 1

22. Letter from W. Serrano, EG4G, to C. L. Miller, NRC,

Subject:

POINT BEACH RETS Am 00CM REVIEW-Serr-1-84, January 9,1984.

23. Letter from J. R. Miller, NRC, to C. W. Fay, WE,

Subject:

NRC COMMENTS ON INITIAL REVIEW OF 10-7-83 RETS SUENITTAL, July 18, 1984. l 24 Letter from C. W. Fay, WE, to H. R. Denton, MtC,

Subject:

RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS CHANGE REollFST 33 POINT BEACH NUCLEAR PLANT. UNITS 1 AlO 2, December 20, 1984.

25. Letter from W. Serrano, EG&G, to C. R. Nichols, MIC,

Subject:

REVIEW OF POINT BEACH RETS-Sarr-2-85, February 15, 1985.

26. Letter from C. W. Fay, WE, to H. R. Denton, MtC,

Subject:

RADWASTE COST-BENEFIT ANALYSIS POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, March 11,1985. 26

27. Letter from C. W. Fay, WE, to H.R. Denton, NRC,

Subject:

DOCKETS 256 AND 301. MODIFICATIONS TO TECHNICAL SPECIFICATIONS (RETS) POINT BEACH NUCLEAR PL ANT UNITS 1 AND 2, April 12,1985.

28. Letter from W. Serrano, EG&G, to C. R. Nichols, NRC,

Subject:

REVIEW OF POINT BEACH ODCM-Serr-09-85, April 5,1985.

29. United States Office of The Federal Register, Title 10, Code of Federal Reculations, Part 20, Appendix B, " Concentrations in Air and Water Above Natural Background."

30. 'C. A. Willis, Letter to F. B. Simpson (summarizing changes to RETS requirements following meeting with Atomic Industrial Forum), November 20, 1981. 31. W. E. Kreger, NRC, memo to R. J. Mattson, NRC, Pl ans for Dealine with the Exolosive Gas Issue in Imolementina the Radiolocical Effluent Technical Soecifications (RETS), December 14, 1981. 1 32. C. A. Willis and F. J. Congel, " Status of NRC Radiological Effluent Technical Specification Activities," Atomic Industrial Forum Conference on HEPA and Nuclear Reculations, October 4-7, 1981. 33. C. A. Willis, Memo to P. C. Wagner, Pl ans for Imol ementino Radiolocical Effluent Technical Soecifications for Ooeratine Reactors, November 4,1981. 34 W. P. Garmil, NRC, Memo to P. C. Wagner, NRC, Current Position on Radiolocical Effluent Technical Soecifications (RETS) Incl udina Exelosive Gas Controls, October 7,1981.

35. United States Nuclear Regulatory Commission, Radiological Assessment Branch Technical Position, An Accootable Radioloaical Environmental Monitorine Procram, November 1979.

l

36. United States Nuclear Regulatory Commission, Methods for Demonstrctina UWR Comoliance with the EPA Uranium Fuel Cvele Standard (40 CFR Part 190), NUREG-0543, February 1980.
37. United States Nuclear Regulatory Commission, Branch Technical Position, General Contents of the Offsite Dose Calculation-Manual, Revision 1, l

February 8, 1979.

38. 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, U.S. Nuclear Regulatory Commission, Washington, D. C. 20555, October 1977.
39. United States Office of the Federal Register, Title 10, Code of Federal Reculations, Part 71, " Packaging of Radioactive Material for Transport i

l and Transportation of Radioactive Material Under Certain Conditions." 27 l

a m.C #was 338 W s. hwcktAM Et tukAf gev Caesasission i kt' Oaf mvveta semp e, reps ees we'

  • e. dea e r

U*i 2E**' BIBUOGRAPHIC DATA SHEET EGG-PBS-6863 ut ~tt.vereoss o ,.t.t.t.s, , a.vt.6... , r.v a.~o ss.iit a RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) IMPLEMENTATION - POINT BEACH NUCLEAR PLANT .,t.t.o., co..a r t o May 1985 ...o.,,, W. Serrano, J. W. Mandler, T. E. Young May 1985 4 PeostCTsY.6amo.a umaf mwwet. 7 6 6*80.wi=G o.s.ne2.T$0m h.wt.ho m.*6:4G.CQ.8ss #,,,a,de ca.e, Radiation M'easurements Section EG&G Idaho, Inc. Idaho Falls, ID 83415 ii.rveto.poar

i. yo..o...

o..... .r.o ...t..... 6..c.oo.tu u ,,,ca Division of Systems Integration Office of Nuclear Regulatory Research ' " ' ' ' "'"' " ~ ~*"' U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i2 Sv #Leut47.e. NOTES e .a..sv..cv,m A review of the Radiological Effluent Technical Specifications (RETS) of the Point Beach Nuclear Plant was performed. The principal review guidelines used were NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," and Draft 7" of l NUREG-0472, Revision 3, " Radiological Effluent Technical Specifications for Pressurized Water Reactors." Draft submittals were discussed with the Licensee by both EG&G and the NRC staff until all items requiring changes to the Technical Specifications were resolved. The Licensee then submitted final proposed RETS to the NRC which were evaluated and found to be in compliance with the NRC review guidelines. The proposed Offsite Dose Calculation Manual was reviewed and generally found to be consistent with the NRC review guidelines. is..,. g t, .. coco.t.1 m.6.... ..t. o o. anc...ro.. i is steu.itv c5.ss> sic.Tio% j or.. m., [ ei0847 8:t8$1081% ENDED 70 485 f T.. sus.,.i P 17 4W#et. 088. Gen b l is paict l l i ? . _ _ _ _}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20205B015&oldid=4065132"