ML20209D410
| ML20209D410 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/30/1984 |
| From: | Duce S, Mandler J, Serrano W EG&G IDAHO, INC., EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML18031B185 | List: |
| References | |
| CON-FIN-A-6459 EGG-PBS-6691, TAC-63022, TAC-63023, TAC-63024, NUDOCS 8410110593 | |
| Download: ML20209D410 (32) | |
Text
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EGG-PBS-6691 I
I RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) IWLEMENTATION - BROWNS FERRY NUCLEAR PLANT-UNITS 1, 2, AND 3 William Serrano Stephen W. Duce John W. Mandler Ferrol B. Simpson
\\
Thomas E. Young Douglas W. Akers Published September 1984 EG&G IDAHO, INC.
Idaho Falls, Idaho 83415 Prepared for the i
U.S. NUCLEAR REGULATORY COMMISSION Under DOE Contract No. DE-AC07-76ID01570 FIN NO. A6459
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ABSTRACT i.
A review of the Radiological Effluent Technical Specifications '(RETS) for the Browns Ferry Nuclear Plant Units 1, 2, and 3 was performed. The; principal review guidelines used were NUREG-0133i " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants,"
and Draft 7" of NUREG-0473, Revision 3, " Standard Radiological Effluent
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Technical Specifications for Boiling 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 requirements of the NRC review guidelines. The proposed Offsite Dose Calculation Manual was reviewed and generally found to be in compliance with the requirements of the NRC review guidelines.
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.I FOREWORD The Technical Evaluation Report tras 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 Itcensing actions. -The technical evaluation was conducted in accordance with criteria est'ablished by the NRC.
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E CONTENTS PAS.t Abstract............................ 11
~ Foreword............................
111 1
INTRODUCTION,.......................-..
1 1.1 Purpose of the Technical Evaluation............
1 1.2 Generic Issue Background I
1.3 Plant-Specific Background.................
3 2.
REVIEW CRITERIA 5
3.
TECHNICAL EVALUATION......................
7 3.1 General Description of Radiological Effluent System.....
7 3.2 Radiological Effluent Technical Specifications......
8 3.3 Offsite Dose Calculation Manual.............. 22 4
CONCLUSIONS
.......................... 24
- 5., REFERENCES........................... 25 FIGURES 1.
Browns Ferry liquid radwaste treatment system common to all three units 9
2.
Browns Ferry liquid affluent release points for a typical unit with the common diffuser system 10 3.
Browns Ferry off-gas system and SGTS effluent monitoring....
11 4.
Browns Ferry normal building ventilation............ 12
.T.6 ALE Number 1
Correspondence of Provisions of NUREG-0473, The Licensee's Current Technical Specifications and the Licensee's Proposal for Browns Ferry Units 1, 2, and 3.............. 25.
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1.
INTRODUCTION 1.1 Purcose of the Technical Evaluation The purpose of this Technical Evaluation Report (TER) is to review and evaluate the proposed changes in the Technical Specifications' of the
' Browns Ferry Nuclear Plant Units 1, 2, and 3 with regard to Radiological Effluent Technical Specifications (RETS) and the proposed Offsite Dose Calculation Manual (ODCM).
The evaluation used criteria proposed by the Nuclear Regulatory Commission (NRC) staff in the model Technical Specifications for boiling water reactors (BWRs), NUREG-0473,E13 and subsequent revisions. This effort is directed toward the NRC objective of implementing RETS which comply with the regulatory requirements, primarily those of 10 CFR Part 50, Appendix I.[2] Other regulations pertinent to the control of effluent releases are also included within the scope of compliance.
1.2 Generic Issue Backaround Since 1970, 10 CFR Part 50, Section 50.36a,[3] " Technical 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 requirements was issued in 10 CFR Part 50, Appendix I.
The licensees of all operating reectors were requiredC43 to 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 reconenended that proposals to modify Technical Specifications be -
deferred until the NRC completed the model RETS.
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q The model RETS deal with radioactive weste management systems and environn. ental monitoring. Although the model RETS address 10 CFR Part 50, Appendix I requirements, subsequent revisions include provisions for addressing issues net covered in Appendix I.
These provisions are stipulated in the following regulations:.
10 CFR Part 20,[5] " Standards for Protection Against e
Radiation," 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,E73 " General Design Criteria for e
Nuclear Power Plants," which contains Criterion 60--Control of releases of radioactive materials to the environment; Criterion 63--Monitoring fuel and waste storage; and Criterion 64--Monitoring radioactive releases.
10 CFR Part 50, Appendix B,[8] which estabitshes the quality e
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 00CM.
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Revision 1 of the mode 1 RETS was sent to licensees on November 15 and 16, 1978 with guidance-(NUREG-0133)[93 for preparation of the RETS and the 00CM 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 i
during Novembe and December 1978. Subsequently, a preliminary copy of Revision 2 of tho' model RETS ~ and additional guidance on the 00CM and a PCP were issued on February 1979 to each utility at individual meetings..
NUREG-0473,. Revision 2,[1] and-NUREG-0472, Revision 2,[10] were pub 11she,d in July 1979 and updated in January 1980 and February 1980. In response to the NRC's request, operating reactor licensees subsequently submitted initial proposals on plant RETS and the ODCM. Reviews leading to ultimate implementation of these documents were initiated by the NRC in September 1981 using subcontracted independent teams as reviewers.,
As the RETS review progressed, feedback from the licensees led the NRC to modify some of the provisions in the February 1,1980 versions of the model RETS to clarify specific concerns of the licensees and thus expedite the reviews. Starting in April 1982, the NRC distributed revised _ versions of the model 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-0473[133 in September 1982 to serve as new guidance for the l
review teams.
1.3 Plant-Sneciffe Backaround In conformance with the 1975 directive,[43 the Tennessee Valley Authority (TVA), the Licensee of the Browns Ferry Nuclear Plant Units 1, 2, and 3 filed with the Commission on February 13, 1976[143 and 3
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.. -.a-December 21, 1976[153 the necessary information to permit an evaluation of the units with respect to the requirements of Sections II. A, II.8, and II.C of 10 CFR Part 50, Appendix I.
The Licensee submitted proposed RETS and an ODCM in letter dated June 29, 1979.[16] EG&G Idaho, Inc., (EG&G) selected as an independent task review team received a copy of the submittal on July 20, 1982 for review and evaluation. The submittal was compared with NUREG-0473 and assessed -
for compliance with the requirements of 10 CFR Part 50, Appendix I, and 10 CFR Part 50, Appendix A.
Review coments and questions dated July 23, 1982[173 were mailed to the NRC prior to arranging a site visit with the Licensee. The site visit (August 18 and 19, 1982) was arranged for the purpose of resolving questions identified in the review of the draft submittal.
Following the site visit in August 1982, the Licensee submitted a preliminary proposal which was received by the NRC on June 3,1983, and by the EG&G review team on June 6, 1983. The preliminary proposal was compared with NUREG-0473. Review coments and questions dated June 13, 1983[183 were prepared by EG&G and transmitted to the NRC. A docketed proposal dated October 27,1983[193 was submitted by the Licensee to the NRC. The docketed proposal was identical in content to the preliminary proposal as reported in EG&G 1etter dated November 29, 1983.[20] The review coments were formally sent to the Licensee on December 20, 1983.[21]
The Licensee responded to the December 20, 1983, review coments via a telephone conference on March 22, 1984, with subsequent revisions to the October 27,1983, docketed submittal. The revisions were reported in a j
supplement to letter dated August 1, 1984.[223 The revisions were reviewed and accepted by the NRC on August 15,1984,C233 and a copy of the agreements transmitted to EG&G. This allowed preparation of a TER by EG&G for transmittal to the NRC.
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,4 The 00CM submitted with the June 29, 1979[163. letter was reviewed by EG&G and review questions were transmitted to' the NRC.[173. An updated ODCM[18] was received by the EG&G review team June 6, 1983 and was reviewed against the NRC review criteria. Review questions and comments were transmitted to the NRC in EG&G 1etter dated June 13, 1983.[19] The 00CM 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.
REVIEW CRITERIA Review criteria for the RETS vere provided by the NRC in three documents:
1.
NUREG-0472, RETS for PWRs 2.
NUREG-0473, RETS for BWRs 3.
NUREG-0133, Preparation of RETS for Nuclear Power Plants.
4 Twelve essential criteria are given for the RETS and 00CM:
1.
All significant releases of radioactivity shall be controlled and monitored.
2.
Offsite concentrations of radioactivity shall not exceed the 10 CFR Part 20, Appendix B, Table II limits.[24]
3.
Offsite radiation doses shall be ALARA.
4 Equipment shall be maintained and used to keep offsite doses ALARA.
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S.
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.
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Wastes shall be processed to shipping and burial' ground criteria under' a documented program, subject to quality assurance
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8.
- An environmental monitoring program, including a land use census, shall be implemented.
9.
The radwaste management program shall be subject to regular audits and reviews.
- 10. Procedures for control of liquid and gaseous effluents shall be maintained and followed.
- 11. Periodic and special reports on environmental monitoring and on' l
releases shall be submitted.
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- 12. Offsite dese calculations shall be performed using documented and approved methods consistent with NRC methodology..
In addition to NUREG-0472 and NUREG-0473, as revised, the NRC staff issued guidelines,[25,263 clarifications,[27,283 branch positions [29,303 and NUREG-0543,[313 estabitshing a policy that requires the ifconsees of operating reactors to meet the intent, if not the letter, of the model RETS requirements. The NRC branch positions issued since the RETS implementation review began have clarified the model RETS for operating reactors.
Review criteria for the ODCM is based on the following NRC guidelines: Branch Technical Position, " General Content of the Offsite Dose Calculation Manual";[323 NUREG-0133;[9] and Regulatory Guide 1.109.[333 The format for the 00CM is left to the Licensee and may be simplified by tables and grid printouts.
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3.
TECHNICAL EVALUATION l
3.1 General Descriotion of Radioloaical Effluent System This section briefly describes the liquid and gaseous radwaste effluent release paths, radwaste treatment systems, and control systems installed at Browns Ferry Nuclear Plant Units 1, 2, and 3 (BWRs).
l 3.1.1 Radioactive Liouid Effluents There are three radioactive liquid effluent sources for each unit at this three-unit site:
1.
Liquid radwaste treatment system, f
2.
Raw cooling water for the reactor building closed cooling water
- system, 4
j 3.
Residual heat removal (RHR) service water system during shutdown.
The three units share a comon liquid radwaste treatment system as shown in Figure 1.
The radwaste and raw cooling water effluents are discharged to the Tennessee River via the comon diffuser system whereas i
the RHR effluents are discharged directly to the river from each unit.
Therefore, there are four release points to the river at this three unit site. The typical release points are shown in Figure 2.
3.1.2 Radioactive Ganeous Effluents There are eight separate radioactive gaseous effluent release points at this three-unit site.
1.
Comon stack (1) 2.
Reactor Building Yent11ation (3) 3.
Turbine Building Exhaust (3) 4.
Radwaste Building Vent (1) 7 m
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These figures were obtained from the ODCM.
The common main stack is the release' point for effluents from each unit's main condenser off-gas treatment system, each unit's mechanical vacuum pump and gland seal condenser, and effluents from tt.e common standby gas treatment system. Major components of the main condenser off-gas treatment system are Illustrated in Figure 3.
Effluents from the containment purge are released through the reactor building ventilation system except during an emergency in which the reactor building effluents are routed through the SGTS before release via the main stack.
3.2 Radiolooical Effluent Technical Snacifications The following sub-sections describe the primary objectives of each section of the model RETS and a sunmary of the conunitments of the Licensee's RETS. A cross reference between 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 Effluent 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 (NPCs) listed in 10 CFR Part 20.
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l;s BROWS FERRY NUCt. EAR PLANT LIQUID RADWASTE TRE ATMENT SYSTEM From FLOOR FLOOR pp.y7.so Floor DRAIN FLOOR DRAIN L
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Browns Ferry liquid effluent release points for a typical unit with the common diffuser system.
s (TYPICAL UNIT & COMI AION SGTS)
ELEVATED RELEASE (600')
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rRM 00 147 A / 8 FI 90-271 m -)
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Browns Ferry off-gas system and SGTS effluent monitoring.
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' ROOF FANS USED SEASONALLY TO CONTROL TEUPERATURE Figure 4.
Browns Ferry normal building ventilation.
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3.2.1.1 - Radioactive Liouid Effluent Instrumentation The four radioactive liquid effluent release points are monitored with adequate instrument surveillance being performed.
j The common radwaste line and the raw cooling water lines are monitored l
when releases occur via these pathways. The RHR monitors are required to f
be operational during operation of-an RHR loop and associated RHR service water system. ~ Upon high radiation; the liquid radweste monitor will provide alarm and automatic termination of the batch release. High radiation for the raw cooling water system and the RHR system will provide control room alarm to initiate operator action.
3.2.1.2 Radfeactive Gaseous Effluent Instrumentation l
The eight radioactive gaseous affluent. release points are monitored 7
with adequate instrument surveillance being performed.
i The main stack monitor has a backup monitor and each will provide 1
l control room alarm upon a high radiation condition in the main stack. The turbino deck monitor also has a backup monitor and each will provide control room alarm upon a high radiation condition at the turbine deck.
The radwaste building vent monitor and the reactor / turbine building vent monitor provides control room alarm annunciation upon a high radiation condition. Automatic isolation of the main condenser off-gas treatment l
l system from the main stack is provided by the sample flow abnormal j
instrument in the off-gas post-treatment system. The hydrogen explosive
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gas monitor will automatically terminate discharges from the recombiners i
if hydrogen concentrations exceed the limits. Upon high radiation, the.
j reactor building / turbine building monitor provides alarm and automatic routing through the SGTS before release at the main stack.
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i The Licensee has provided radiation monitors with alarm annunciation for potential radioactive liquid or gaseous release points. In addition, automatic isolation for discharges from the recombiners is provided by the '
explosive gas monitors and automatic isolation of the off-gas treatment system is provided by the sample flow abnormal. The Licensee's RETS stat'e the concentration of radioactive liquid or gases will be monitored at all times during release.
- 3. 2.1.3 Liouid and Gaseous Instrumentation Setooints i
The setpoints at each release point are established to prevent exceeding concentrations in liquid releases or corresponding dose rates for gaseous releases of 10 CFR Part 20 in unrestricted areas. A map showing the unrestricted area boundaries was included as Figure 4.8-lb of the preposal. The setpoints for the liquid and gaseous effluent instrumentation will be determined in accordance with the Offsite Dose Calculation Manual (ODCM).
i The Licensee's RETS submittal on liquid and gaseous cffluent monitoring instrumentation has satisfied the provisions and meats the L
intent of NURECr 0473.
i 3.2.2 Concentration and Dose Rates of Effluents i
3.2.2.1.Licuid Effluent Concentration i
The Licensee's RETS include a connitment to maintain the concentration of radioactive liquid effluents released from the site to the unrestricted areas to ~within'10 CFR'Part 20 limits, and if the concentration of liquid l
effluents to the unrestricted area exceeds these limits, appropriate i
action will be initiated without delay to bring the release within l
limits. The batch releases are sampled and analyzed periodically in i
accordance with a sampling and analysis program.
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Therefore, the Licensee's RETS submittal on liquid effluent concentraticns meets the intent of NUREG-0473.
3.2.2.2 Gaseous Effluent Dose Rate The Licensee's RETS include a comitment to maintain the;offsite gaseous dose rate from the site to areas at and beyond the site boundary to within 10 CFR Part 20 limits, and if the concentration of. gaseous effluents exceeds these limits or the equivalent dose rate values, appropriate corrective action will be initiated without delay to bring the values within limits.
The radioactive gaseous waste sampling and analysis program provides adequate sampling and analysis of the discharges.
Therefore, the Licensee's RETS submittal on gaseous effluent dose rates meets the intent of NUREG-0473.
3.2.3 Offsite Doses from Effluents The objectives of the model RETS with regard to offsite doses from effluents are to ensure that offsite doses are kept ALARA, are in compliance with the dose specifications of NUREG-0473, and are in accordance with 10 CFR Part 50, Appendix I and 40 CFR Part 190.
The Licensee's RETS include commitments (a) to maintain doses due to liquids effluents to within the NUREG-0473 quarterly and annual dose criteria, (b) to maintain noble gas air doses to areas at and beyond the site boundary to within the NUREG-0473 quarterly and annual dose criteria, (c) to maintain the dose level to areas at and beyond the site boundary due to release of iodine-131, todine-133, tritium and materials in particulate form with half lives greater than eight days to within the NUREG-0473 quarterly and annual dose criteria, and (d) to limit the annual dose to any member of the public due to release of radioactivity and radiation from uranium fuel cycle sources to within the requirements of 40 CFR Part 190.
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.x Therefore, the Licensee's RETS submittal on offsite doses from radioactive of fluents meets the intent of NOREG-0473.
3.2.4 Effluent Treatment The objectives of the model RETS with regard to effluent treatment are to ensure that the radioactive waste treatment systems are used to keep releases ALARA and to satisfy the provisions for Technical Specifications governing the maintenance and use of radweste treatment equipment.
The Licensee's RETS include a comitment to use the liquid radwaste treatment system when the projected monthly doses exceed 25 percent of the annual dose design objectives. The projections are to be' made at least once per 31 days. The Licensee's RETS include a commitment to prepare a special report if liquid radwaste is being discharged for more than 31 days without treatment and the projected doses are in excess of the limits.
The Licensee's RETS include a comitment to use the gaseous radwaste treatment system during operation above 25 percent power. With gaseous wastes being discharged for more than seven days without treatment through the charcoal adsorbers a special report will be submitted to the NRC. The Licensee's submittal does not address the gaseous ventilation exhaust treatment systems as these systems do not exist at these plants. However, the radwaste building has built-in HEPA filters which cannot be bypassed.
Therefore, the Licensee's RETS submittal on effluent treatment meets the intent of NUREG-0473.
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 16
surface water supply in an unrestricte'd area would not exceed the limits of 10 CFR Part 20, Appendix B, Table II.
The Licensee's RETS limits the maximum activity to 10 curies in a liquid radwaste tank or temporary radwaste storage tank than can be discharged directly to the environs. The submittal comits to adequate surveillance of the tank's contents in accordance with NUREG-0473.
Therefore, the Licensee's RETS submittal on tank inventory limits meets the intent of NUREG-0473.
3.2.6 Exolosive 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 Licensee's RETS limits the concentration of hydrogen in the off-gas downstream of the recombiners to i 45 by volume whenever the SJAE is in service. The hydrogen concentration shall be determined to be within the limits by use of continuous hydrogen monitors which have adequate surveillance requirements. Therefore, the Licensee's RETS submittal on explosive gas mixtures meets the intent of NUREG-0473.
3.2.7 Solid Radwasta Svstem 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.E343 The Licensee has comitted to use the methods prescribed in a Process Control Program (PCP) to ensure that the requirements of shipping and burial ground requirements are met prior to shipment of radwaste from the site.
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O Therefore, the Licensee's RETS submittal on solid radioactive waste.
meets the intent of NUREG-0473.
3.2.8 Radiolooical Environmental Monitorina Proaram The objectives of the model RETS with regard to radiological environmental monitoring are to ensure that (a) an adequate full-area coverage environmental monitoring program exists, (b) thern is an appropriate land use census, and (c) an acceptable Interlaboratory Comparison Program exists. The monitoring program implementsSection 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 for a radiological environmental monitoring program have followed in general the intent of the model RETS and the Branch Technical Position on the subject issued November 1979,[293 as applicable to the site, and have generally 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 the appropriate annual information for a BWR. 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 monitoring program meets the intent of NUREG-0473.
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a.
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 radweste and environmental monitoring programs are properly conducted..
The Licensee's administrative structure identifies the Plant Operations Review Committee (PORC) and the Nuclear Safety Review Board (NSR8) as the two entities comparable to the Unit Review Group (URG) and the Company Nuclear Review and Audit Group (CMtAG), roepectively.
The PORC is responsible for reviewing every unplanned release of radioactive material and the adequacy of the PCP and 00CM at least'once every 24 months.
The NSRB'is responsible for auditing the radiological environmental' monitoring program and results thereof, the 00CM and implementing procedures, the PCP and implementing procedures, and the performance of activities required by the quality assurance (QA) program. These audits are performed at the frequency required by the model RETS.
The PORC and NSRB encompass the total responsibility for-reviews and audits spectfied in NUREG-0473.
3.2.10 Procedures and Racards The objective of the model RETS with regard to procedures is to ensure that written procedures be estabitshed, implemented and maintained for the PCP, the 00CM, and the QA 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.
The Licensee's RETS include a connitment to establish, implement, and maintain written procedures for the PCP, 00CM, and QA programs. The 19
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..a Licensee's existing technical specifications state that the records of the off-site environmental monitoring program will be retained for the life of the plant which meets the intent of NUREG-0473.
Therefore, the Licensee's RETS submittal on procedures and records meets the intent of NUREG-0473.
3.2.11 Renorts The objective of the model RETS with regard to reporting requirements is to ensure that appropriate annual and semiannual periodic reports and special reports are submitted to the NRC.
The Licensee's RETS include commitments to submit the following reports:
1.
Radioloatcal Environmental Monitorina (Annual Renort)
This report includes sumaries, interpretations and analysis of trends of the results of the radiological environmental surveillance program. The report also includes the results of the land use census and results of participation in the Interlaboratory Comparison Program. The report shall include a summary description of the environmental monitoring program and a map of all sampling locations keyed to a table giving directions and distances from one reactor. The report will be submitted prior to May 1 of each year.
2.
Radioactive Effluent Relaana Recort (Remiannual)
This report contains a sumary of the quantities of radioactive liquid and gaseous effluents and solid waste shipped from the plant and is submitted within 60 days after January 1 and July 1 of each year. The report shall include a sumary of the 20
- .,. 4 s..
^
. a 2 '
.-~
v
. +
s ne meteorological conditions concurrent with the release of gaseous effluents during each quarter. Calculated offsite doses to members of the public resulting-from the release of liquid and gaseous effluents shall be reported. Changes to the PCP and 00CM shall be contained in the report. The Licensee's RETS include a commitment to the format and content of the reporting requirements of Regulatory Guide 1.21 (Revision 1) dated June 1974. This contains the requirements of reporting the solid wastes shipped offsite.
3.
Soecial Renorts The Licensee's RETS include a consnitment to file a special report within 30 ' days under the following conditions:
e Exceeding the liquid effluent dose limits according to' Specification 3.8. A.4.
e Exceeding the gaseous effluent dose limits according to Specifications 3.8.B.4 and 3.8.B.6.
e Exceeding the total dose limits according to Specification 3.8.C.2.
e Exceeding the reporting levels for the radioactivity measured in the environmental sampling program according to Specification 3.13.A.3.
e When radioactive liquid or gaseous effluents are released 4
without treatment before discharge according to Specifications 3.8.A.6 and 3.8.8.8.
Therefore, the Licensee's RETS submittal on reports meets the intent of NUREG-0473.
21
r 3.2.12 Other Administrative contro1m-i An obj'ctive of the model RETS in the administrative controls section is to ensure that any changes to the PCP and 00CM and major changes to' the
- radioactive waste treatment systems are reported to the NRC.
Such changes
- r shall be reviewed and accepted by the URG before implementation.
The Licensee's RETS state that the aforementioned changes to the PCP.
and ODCM will be reported to the NRC after review and acceptance by the:
~
PORC. The Licensee states major changes to the radweste treatment systems are addressed in accordance with 10 CFR 50.59.
Therefore, the Licensee's RETS submittal for these administrative I
controls meets the intent of NUREG-0473.
r t
3.3 offsite Done calculation Manual As specified in NUREG-0473, the 00CN is to be dev310 ped by the Licensee to document the methodology and approaches used to calculate t
offsite doser and maintain the operability of the effluent system. 'As a minimum, the ODCM should provide equations and methodology for the following topics:
2 e
alarm and trip setpoints for effluent instrumentation e
liquid effluent concentrations in unrestricted areas gaseous effluent dose rates or concentrations at or beyond the e
site boundary e
liquid and gaseous effluent dose contributions total dose compliance, including direct shine e
e liquid and gaseous effluent dose projections.
I In addition, the 00CM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and l
the components of the radioactive liquid, gaseous, and solid waste 3
management systems. A description and the location of samples in support of the environmental monitoring program are also needed in the 00CM.
22
.u a u.
v 3.3.1 Evaluation.
The Licensee's 00CN satisfies the equation in the addendum of NUREG-0133 to determine.the alarm and trfp setpoints for the liquid This assures that the alarm and trip actions will effluent monitors.
occur prior to exceeding the 10 CFR Part 20, Appendix 8. Table II values at the discharge point to the unrestricted area.
The alarm and trip setpoints for the gaseous effluent monitors are calculated to assure that alarm and trip actions will occur _ prior to exceeding the limits set in 10 CFR Part 20 for annual dose rates to unres'tricted areas. The Licensee uses equations similiar to those contained in NUREG-0133 with the dose rate values identiffed in NUREG-0473.
The Licensee's 00CM contains the methods and calculational relationships that are used to compare the radioactivity concentrations in liquid releases at the point of release to the 10 CFR Part 20 Ifmits prior to the release and after the release.
The Licensee's 00CM assures that noble gas discharges are within the NUREG-0473 dose rate Ifmits by correctly determining the setpoints for the
~
The dose rate due to the release of I-131, trf tfum, noble gas monitors.
and particulates with half-lives greater than eight days is assured to be within the NUREG-0473 limit of 1500 mrom per year by calculating the dose to the thyroid for the infant via the milk ingestion, ground contamination and inhalation pathway due to the expected release using a calculated afr concentration.
The Licensee's 00CM demonstrates coup 11ance with 10 CFR Part 50.
Appendix I by calculating the monthly dose commitments for liquid and The calculated cumulative gaseous effluents at least once per 31 days.
values are compared to the quarterly and annual limits to demonstrate compliance, n
23
a m
u..
.x.
The Licensee's RETS commits to projecting doses to determine if the liquid radwaste treatment system must be operated. The ODCM includes the-dose projection methodology.
Specific parameters of distance and the direction sector from the centerline of a reactor and additional information have been provided for each and every sample location identified in RETS Environmental Monitoring Table 3.13.A in Tables 3.1-2 and 3.1-3, and in Figures 3.1-1, 3.1-2, 3.1-3, and 3.1-4 of the ODCM. The ODCM contains simplified diagrams of the liquid and gaseous release points and the liquid and gaseous radwaste treatment system.
The Licensee's ODCM for Browns Ferry Units 1, 2, and 3 is generally in compliance with the NRC requirements and uses methods consistent with the methodology and guidance prescribed in NUREG-0133.
4 CONCLUSIONS The Licensee's proposed RETS and ODCM were reviewed and evaluated and the following conclusions were reached:
e The Licensee's proposed RETS for the Browns Ferry Nuclear Plant Units 1, 2, and 3 submitted October 27, 1983, and supplemented with revisions on August 1,1984, meets the intent of the NRC staff's " Standard Radiological Effluent Technical Specifications for Boiling Water Reactors", NUREG-0473.
e The Licensee's ODCM, dated January 4, 1983, uses documented and approved methods that are applicable to Browns Ferry Units 1, 2, and 3 and are consistent with the methodology and guidelines of NUREG-0133.
It is thus an acceptable reference.
A correspondence between (a) NUREG-0473, (b) the Licensee's current RETS, and (c) the Licensee's proposed RETS is shown in Table 1.
]
24 i
t TABLE 1.
CORRESPONDENCE OF PROVISIONS OF NUREG-0473, THE LICENSEE'S CURRENT TECHNICAL SPECIFICATIONS AND THE' LICENSEE'S PROPOSAL FOR BROWNS FERRY UNITS 1, 2, AND 3 1
Licensee NUREG-Current Technical Proposal I
RETS Raaseirament 0473 Snecification (section) l i
i Effluent 3.3.3.10 3. 2. D.1 -
{
Instrumentation 3.3.3.11 3.2.K.1 Concentrations 3.11.1.1 3.8.A.1' 3.8.A.1 3.11.2.1 3.8.8.1
- 3. 8. B.1 Offsite Doses
'3.11.1.2' 3.8.A.3
}
3.11.2.2 3.8.B.3 3.11.2.3 3.8.B.5-j 3.11.4 3.8.C.1 i
j Effluent Treatment 3.11.1.3 3.8.A.4 3.8.A.5 j
3.11.2.4 3.8.B.7 3.11.2.5 Tank Inventory 3.11.1.4 3.8.A.5 3.8.A.7 i
Limits 1
)[
. Explosive Gas 3.11.2.6 3.8.B.9 j
Mixtures Main Condenser 3.11.2.7 i
effluent I
Mark I or Mark II 3.11.2.7 3.2.A i
Containment i,
Solid Radweste (PCP) 3.11.3 3.8.F.1 4
4 Environmental 3.12.1 3.13.A j
MonitoFing Land Use Census 3.12.2 3.13.8.1 i
Interlaboratory 3.12.3 3.13.C.1-
{-
Comparisons f
Audits and Reviews 6.5.1 6.2.B.4 i'
6.5.2 6.2.8 6.2.A.8 Procedures and Records 6.8, 6.10
--, 6.6.A.10 6.3.A. 6.6.A.10 Reports: Annual 6.9.1.11 6.7.1.d j
Som1 annual 6.9.1.12 6.7.3.A 6.7.3.A l
Other Administrative 6.13 6.3.E Controls 6.14 6.3.0 6.15 f
4, 25
7, i
5.
REFERENCES. -
1.
United States Nuclear Regulatory Commis'sion, Standard Radiological Ef fluent Technical Sneef fications for Boilina water P-torn,,
NUREG-0473, Revision 2, July 1979.
2.
United States Office of the Federal Register, Title 10, Code of Federal Regulations. Part 50, Appendix I, " Numerical Guides for Design.
Objectives and Limiting Conditions for Operation to Meet the Criterion.
'As Low as is Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents."
3.
United States Office of the Federal Register, Title 10, Code of Federal Regulations. 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 Reaulations. Part 50, Appendix I,Section V.B., " Effective Dates."
5.
United States Office of the Federal Register, Title 10, Code of Federal Regulations. Part 20, " Standards for Protection Against Radiation."
6.
United States Office of the Federal Register, Title 40, Code of Federal Reaulations. Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operations."
7.
United States Office of the Federal Register, Title 10, Code of Federal Regulations. Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants."
8.
United States Office of the Federal Register, Title 10, Casit.gt.,
Federal Regulations. Part 50, Appendix 8 " Quality Assurance Criteria i
for Nuclear Power Plants and Fuel Reprocessing Plants."
9.
United States Nuclear Regulatory Cossnission, Pranaration of Radiolaatcal Effluent Technical Snacifications for Nuclear Pamar P_lants, NAEG-0133, October 1978.
- 10. United States Nuclear Regulatory Commission, Standard Radiological
)
Effluent Technical Specifications for Prenmurized Water Reactors.
NUREG-0472, Revision 2, July 1979.
- 11. C. A. Willis and F. J. Congel, " Summary of Draft Contractor Guidance of RETS," AIF Envirc.r--.tal Suhe=-it+== Maatina. Washinatan. D.C..
May 19, 1982.
- 12. F. J. Congel, memo to RAB Staff (NRC), Interia chana== in the Madal fEL1, August 9,1982.
26 m
m
m t.
- 13. United States Nuclear Regulatory Commission, Standard Radiolootcal Effluent Technical Senef fications for Praamurized Water Reactors,.
NUREG-0472, Revision 3, Oraft 7', September 1982.
- 14. Response to Request for Appendix I Information for Browns Ferry.
Nuclear Plant, Unit Nos.1, 2, and 3, Tennessee. Valley Authority, letter of transmittal dated February 13, 1976, with Enclosures 1 and 2.
- 15. Response to Request for Additional Appendix I Information for Browns Ferry Nuclear Plant, Units Nos.1, 2, and 3.
Tennessee Valley Authority, letter of transmittal dated December 21, 1976, with enclosure.
- 16. J. E. G111 eland letter of transmittal, In the Matter of the Tenna ma Vallev Authoritv Dacinet Nos. E0-250.50-28n. 10-20s. June 29, 1979.
~
- 17. W. Serrano letter of transmittal, Transmittal of oumations for Browns Farrv RETS Review. Serr-10-82, July 23,1982.
g..
e
- 18. W. Serrano letter of transmittal, Browns Ferry RETS and 00cM Reviews.
serr-16-a1, June 13,1983.
- 19. L. M. Mills letter of transmittal, In the Matter of the Tennemana Vallev Authority Docket Non. E0-210.10-2an.10-20s, October 27, 1983.
- 20. W. Serrano letter of transmittal, Pa=aarison of Browns Ferry RETS Submittals. sarr-12-R1, November 29, 1983.
- 21. D. B. Vasallo (NRC) letter to H. G. Parris (TVA), Browns Farrv 1. 2.1 EEII, December 20, 1983.
- 22. L. M. Mills, letter of transmittal, In the Matter of the Tannaamaa Vallav Authority Docket Non. 50-210.10-280. - E0-20s, August 1, 1984.
- 23. C. L. Millt Personal Communication, Final Resolution of Browns Farrv RETS submittal. August 15, 1984.
- 24. United States Office of the Federal Register, Title 10, code of Fadarillagulations. Part 20, Appendix 8, " Concentrations in Air and Water Above Natural Background."
- 25. C. A. Willis, letter to F. B. Simpson (summarizing changes to RETS requirements following meeting with Atomic Industrial Forum), November 20, 1981.
- 26. W. E. Krger (NRC), memo to R. J. Mattson (NRC), Plans for Dealino with The Fwnlosive can inaua in fan 1 - ntino The Radioloofcal Effluent Technical faaeffications (RETS), DeCamber 14, 1981.
27
~
J s
i
- 27. C. A. Willis and F. J. Congel, " Status of NRC Radiological Effluent Technical Specification Activities," Atomic Industrial Forum conference on HEPA and Huelaar Raoulations, October 4-7, 1981.
- 28. C. A. Willis, memo to P. C. Wagner, Plans for fanlementino Radioloeical Effluent Technical Snacifications for Onaratino Reactors.
5 November de 1981.
- 29. W. P. Gamill (NRC), memo to P. C. Wagner (NRC), Current Position on Radiolooical Effluent Technical Snacifications (RETS) includino Exolosive Gas Controls, October 7,1981.
- 30. United States Nuclear Regulatory Commission, Radiological Assessment Branch Technical Position, hotahla Radiolooical Environmental Monitorino Prooram, November 1979,
- 31. United States Nuclear Regulatory Comission, Methods for Damanstratino LWR Comoliance with the EPA Uranium Fuel Cvela Standard (40 CFR Part 120.)., NUREG-0543, February 1980.
- 32. United States Nuclear Regulatory Comission, Branch Technical Position, General Contents of the offsite Dona Calculation Manual, Revision 1, February 8, 1979.
- 33. 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," Revi ion 1, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555, October 1977.
- 34. United States Office of the Federal Register, Title 10, Code of Federal Reaulations, Part 71, " Packaging of Radioactive MatRrial For Transport and Transportation of Radioactive Material Under Certain Conditions."
28
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