Text

Rev 1.7 to Chapter 12 of Dresden Station Odcm
	ML20217N933
Person / Time
Site:	Dresden
Issue date:	04/30/1998
From:	; COMMONWEALTH EDISON CO.
To:	;
References
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l X244 ALL l Document Control Desk Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Station PI-137 Washington, DC 20555 i

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April 24,1998 l

Attached is a revision to the Offsite Dose Calculation Manual, Dresden Annex, Chapter 12. Please update your manual as follows:

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Remove:

Dresden Chapter 12, Revision 1.6 i

Ingrt:

n Dresden Chapter 12, Revision 1.7 ,

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Please sign below indicating your :=nual has been updated and that your controlled copy number I is correct.

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l Dresden Station Chapter 12 Change Summary ODCM Revision 1.7, April 1998 i Page Channe Descriotion i Updated revision number in header and file designator.

12-ii Updated revision number.

12-39 Added M to the column for Minimum Analysis Frequency for Tritium samples.

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Revision 1.7 April 1998 j

CHAPTER 12.0 l

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SPECIAL NOTE t

l The requirements of the Technical Specifications shall take precedence over this chapter, should any l differences occur.

, The transfer of the Radiological Effluent Technical Specifications (RETS) to the ODCM for Unit 1 )

has been approved by the Nuclear Regulatory Commission in Amendment 39.

! The transfer of the Radiological Effluent Technical Specifications (RETS) to the ODCM for Units 2 and 3 has been approved by the Nuclear Regulatory Commission in Amendments 150 and 145.

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DRESDEN Revision 1.7 April 1998 DRESDEN ANNEX INDEX O

CHAPTER 12 Revision 1.7 O

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DRESDEN Revision 1.7 April 1998 CHAPTER 12 O RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS

(.] (RETS)

TABLE OF CONTENTS PAGE 12.1 DEFINITIONS 12-1 12.2 INSTRUMENTATION 12-5 A. Radioactive Liquid Effluent Monitoring Instrumentation 12-5

1. Radioactive Liquid Effluent Monitoring Instrumentation Operability 12-5

2. Radioactive Liquid Effluent Monitoring Instrumentation Surveillance 12-5 B. Radioactive Gaseous Effluent Monitoring Instrumentation 12-5

1. Radioactive Gaseous Effluent Monitoring Instrumentation Operability 12-5

2. Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance 12-6 C. Liquid and Gaseous Effluents Instrumentation Bases 12-19 12.3 LIQUID EFFLUENTS 12-20 A. Liquid Effluents Limits and Reporting Operability 12-20

1. Concentration in Unrestricted Areas 12-20

2. Dose from Liquid Effluents 12-20

3. Dose Projections 12-21

4. Liquid Radioactive Waste Treatment System 12-22

5. System Operability and Plant Operations 12-22 B. Liquid Effluents Surveillance 12-22

1. Concentration in Unrestricted Areas 12-22

2. Dose from Liquid Effluents )

p) g 3. Dose Projections 12-23 12-23

.,j V C. Liquid Effluents Bases 12-30

1. Concentration ~ 12 30

2. Dose 12-30

3. Liquid Waste Treatment 12-30

4. Mechanical Vacuum Pump 12-31 12.4 GASEOUS EFFLUENTS 12-32 A. Gaseous Effluents Limits and Reporting Operability 12-32

1. Dose Rate . 12-32

2. Noble Gas Dose 12-32

3. lodine-131, lodine-133, Tritium and Particulate Dose 12-33 1

4. Off Gas Treatment 12-34

5. Main Condenser Air Ejector 12-35

6. System Operability and Plant Operations 12-35 B. Gaseous Effluents Surveillance 12-36

1. Dose Rate 12-36

2. Noble Gas Dose 12-36

3. lodine-131, lodine-133 Tritium and Particulate Dose 12-36

4. Off-Gas Treatment 12-36

5. Noble Gases at the Main Condenser Air Ejector 12-37 O

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DRESDEN Revicica 1.1 l April 1998 -

CHAPTER 12 RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS (RETS)

TABLE OF CONTENTS CONTINUED PAGE 12.4 GASEOUS EFFLUENTS (Cont'd)

C. Gaseous Effluents Bases 12-43

1. Gaseous Effluents Dose 12-43

2. Dose, Noble Gases 12-43

3. Dose, Radioiodines, Radioactive Material in Particulate Form and Radionuclides Other than Noble Gases 12-44

4. Gaseous Waste Treatment 12-44 12.5 RADIOLOGICAL ENVIRONMENTAL MON!TORING PROGRAM 12-45

1. Monitoring Program 12-45

2. Land Use Census 12-59

3. Interlaboratory Comparison Program 12-60 12.6 RECORDKEEPING AND REPORTING 12-61 ,;

1. Station Operating Pacords 12-61

2. Reports 12-61

1. Radioactive Effluent Release Report 12-61

2. Annual Radiological Environmental Operating Report 12-61

3. Non-Routine Environmental Report 12-62

3. Offsite Dose Calculation Manual (ODCM) 12-63

4. Major Changes to Radioactive Waste Treatment Systems (Liquid and Gaseous) 12-64 O

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DRESDEN Rsvision 1.7 April 1998 CHAPTER 12 RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS (RETS)

UST OF TABLES NUMBER TLTig PAGE 12.1-1 Surveillance Frequency Notation 12-3 12.1 2 Operational Modes 12-4 12.2-1 Radioactive Liquid Effluent Monitoring instrumentation 12-7 12.2-2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements 12-9 12.2-3 Radioactive Gaseous Effluent Monitoring Instrumentation 12-12 12.2-4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements 12-16 12.3-1 Allowable Concentration of Dissolved or Entrained Noble Gases Released from the Site to Unrestricted Areas in Liquid Waste 12-24 O

V 12.3-2 Radioactive Liquid Waste Sampling and Analysis Program 12-25 12.4-1 Radioactive Gaseous Waste Sampling and Analysis Program 12-38 12.5-1 Radiological Environmental Monitoring Program 12-48 12.5-2 Reporting Levels for Radioactivity Concentrations in Environmental Samples 12-54 Reporting Levels 12.5-3 Detection Capabilities for Environmental Sample Analysis Lower Limit of Detection 12-55 0

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l l DRESDEN Revision 1.7 l April 1998 12.0 RADIOLOGICAL EFFLUENT TECHNICAL STANDARDS l p.,

Q 12.1 DEFINITIONS 1

1. Dose Eauivalent 1-131 - That concentration of I-131 (microcune/ gram) which alone would !

produce the same thyroid dose as the quantity and isotopic mixture of I 131,1-132,1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table ill of TID -14844, " Calculation of Distance '

Factors for Power and Test Reactor Sites".

2. Frecuency Notation- Table 12.1-1 provides the definitions of various frequencies for which surveillances, sampling, etc., are performed unless defined otherwise. Refer to l Technical Specification Table 1-1. l I

3. Immediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operation of the unit and the importance of the required action.

4. Instrument Calibration - An instrument calibration means the adjustment of an instrument signal output so that it ccrresponds, within acceptable range and accuracy, to a known value(s) of the parameter which the instrument monitors. Calibration shall encompass the entire instrument, including actuation, alarm, or trip.

5. Instrument Check - An instrument check is qualitative determination of acceptable operability by observation of instrument behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent l instruments measuring the same variable.

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U 6. Instrument Functional Test - An instrument functional test means the injection of a simulated signal into iiie instrument primary sensor to verify the proper instrument response alarm and/or initiating action.

7. Member of the Public - any individual except when that individual is receiving an occupational dose.

8. Mode - Reactor modes are described in Tabie 12.1-2 (per Technical Specification Taoie 1-2).

9. Occupational Dose-The dose received by an individual in the course of employment in which the individual's assigned duties involve exposure to radiation and/or to radioactive material from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person. Occupational dose does not include dose from background radiation, as a patient from medical practices, from voluntary participation in medical research programs, or as a member of the public.

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1 DRESDEN Revision 1.7 April 1998 12.1 DEFINITIONS (Cont'd)

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

Radiological Environmental Monitoring Programs described in Section 12.5 and (2) descriptions of the information that should be included in the Annual Radiological j Environmental Operating and Radioactive Effluent Release Reports required by Sections 12.6.2.1 and 12.6.2.2.

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

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

13. Rated Thermal Power - Rated thermal power shall be a total reactor core neat transfer rate to the reactor coolant of 2527 thermal megawatts.

14. Reactor Power Operation - Reactor power operation is any operation with the mode switch in the "Startup/ Hot Standby" or "Run" position with the reactor critical and above 1% rated thermal power.

15. Source Check - The qualitative assessment of Channel response when the Channel sensor is exposed to a radioactive source.

16. Definitions Related to Estimatina Dose to the Public Usina the ODCM Computer Proaram:

1. Actual- Refers to using known release data to project the dose to the public for the previous month. These data are stored in the database and used to demonstrate compliance with the reporting requirements of Chapter 12.

2. Projected - Refers to using known release data from the previous month or estimated release data to forecast a future dose to the public. These data are NOT incorporated into the database.

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h3worddataedemWn12ri 7. doc 12-2

DRESDEN Revision 1.7 April 1998 TABLE 12.1 1 SURVEILLANCE FREQUENCY NOTATION NOTATION FREQUENCY

S (Shiftly) At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D (Daily) At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months T At least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months W (Weekly) At least once per 7 days M (Monthly) At least once per 31 days O (Quarterly) At least once per 92 days SA (Semiannually) At least once per 184 days A (Annually) At least once per 366 days E (Sesquiannually) At least once per 18 months (550 days)

S/U (Startup) Prior to each reactor startup NA (Not Applicable) Not applicable O -

Each surveillance requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval. The bases to Technical Specifications 4.0.8 provides clarification to this statement. These definitions do not apply to the Radiological Environmental Monitoring Program (Section 12.5).

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DRESDEN Revision 1.7 April 1998 TABLE 12.1-2 i OPERATIONAL MODES ei I

MODE SWITCH AVERAGE REACTOR MODE POSITION

COOLANT TEMPERATURE

1. POWER OPERATION Run Any temperature

2. STARTUP Startup/ Hot Standby Any temperature

3. HOT SHUTDOWN Shutdown () > 212 F

4. COLD SHUTDOWN Shutdown ('**) $ 212 F l I

5. REFUELING (* Shutdown or Refuel (* 5140 F j t

TABLE NOTATIONS

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

) The reactor mode switch may be placed in the Refuel position while a single control rod drive is being removed from the reactor pressure vessel per Technical Specification 3.10.l.

(* Fuel in the teactor vessel with one or more vessel head closure bolts less than fully tensioned or ,

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(* See Technical Specification Special Test Exceptions 3.12.A and 3.12.B.

(* The reactor mode switch may be placed in the Refu61 position while a single control rod is being moved provided the one-rod-out interlock is OPERABLE.

When there is no fuel in the reactor vessel, the reactor is considered not to be in any OPERATIONAL MODE. The reactor mode switch may then be in any position or may be inoperable.

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DRESDEN Revision 1.7 April 1998 12.2 INSTRUMENTATION A. Radioactive Liauid Effluent Monitorina Instrumentation p 1. Radioactive Liauid Effluent Monitorina Instrumentation Operability

\"/ 1. The effluent monitoring instrumentation shown in Table 12.2-1 shall be operable with alarm trip setpoints set to insure that the limits of Section 12.3.A are not exceeded. The alarm setpoints shall be determined in accordance with the

(' 2CM.

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

3. With one or more radioactive liquid effluent monitoring instruments inoperable, talte the action shown in Table 12.2-1. Retum the instrument to operable status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner. This ,

is in lieu of an LER. !

4. In the event operability requirements and associ ted action requirements cannot be satisfied because of circumstances in excen of those addressed in the i specifications, provide a 30-day written repor' to the NRC and no changes are i required in the operational condition of the plant, and this does not prevent the plant from entry into any operational mode.

2. Radioactive Liauid Effluent Monitorina Instrumentation Surveillance

1. Each radioactive liquH effluent monitoring instrument shown in Table 12.2-2 O

V shall be demonstrated operable by performance of the given source check, instrument check, calibration, and functional test operations at the frequencies

'M shown in T6bi612.2-2. l B. Radioactive Gaseous Effluent Monitorina instrumentation

1. Eadioactive Gaseous Effluent Monitorina Instrumentation Operability l

1. The effluent monitoring instrumentation shown in Table 12.2-3 shall be operable with alarm / trip setpoints set to ensure that the limits of Section 12.4.A are not exceeded. The alarm / trip setpoints shall be determined in accordance with the ODCM.

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

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DRESDEN Revision 1.7 April 1993 12.2.B.1 Radioactive Gaseous Effluent Monitorina Instrumentation Ooerability (Cont'd)

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

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

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

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

3. Both offgas monitors on Unit 2 and Unit 3 must be operational and the monitor reading correlated to the chimney release rate based on the conservative assumption of both units' charcoal absorbers being bypassed.

4. If the provisions of 12.4.A.1.1,12.4.A.1.2, or 12.4.A.1.3 cannot be met, an orderly load reduction of the unit (s) shall be initiated immediately.

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

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

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DRESDEN Rsvision 1.7 April 1998 TAB' E 12.2-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION UNIT 1 Minimum Total Channels No. of Instrument Operable Channels Action Discharge Canal 1 1 12 Sampler

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

When Instrument is unavailable and assotited actions cannot be performed, then discharges may not be made.

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DRESDEN Revision 1.7 April 1998 l TABLE 12.2-1 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION UNITS 2 & 3 Minimum Total Channels No. of Instrument Operable Channels Action

1. Service Water Effluen; 1 1 10 Gross Activity Monitor

2. Liquid Radwaste Effluent 1 1 11 Gross Activity Monitor ACTIONS ACTION 10 - With less than the minimum number of operable channels, releases via this pathway may continue, provided that at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months grab samples are collected and analyzed for beta or gamma activity at an LLD of less than or equal to 10'7 uCi/ml.

(The grab sample should normally be taken at the Service Water Monitor or at a location which would be representative of the Service Water which is monitored.)

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

pathway may continue, provided that prior to initiating a release, at least 2 independent samples are analyzed, and at least 2 members of the facility staff independently verify the release calculation and discharge valving. Otherwise, suspend release of radioactive effluent via this pathway.

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DRESDEN Revision 1.7 April 1998 TABLE 12.2-2 i RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS UNIT 1 l Functional Calibration" Instrument Source Instrument Test Check

Check l

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l Discharge Canal

l. Sampler *

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l *When Instrument is unavailable and associated actions cannot be performed, then discharges may not l be made.

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DRESDEN Revision 1.7 April 1998 TABLE 12.2-2 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS UNITS 2 & 3 Functional Calibration *)* Instrument Source instrument Test (*)* Check

Check

1. Liquid Radwaste Effluent Gross Q(* E 44 D E(*

Activity Monitor

2. Service Water Effluent Gross Q(* E(4 D E Activity Monitor i

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DRESDEN Revision 1.7 April 1998 TABLE 12.2-2 (Cont'd) s

( ,) RADIOACTIVE LIQUID EFFLUENT MONITORING

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INSTRUMENTATION SURVEILLANCE REQUIREMENTS l TABLE NOTATIONS

(*)

The instrument Functional Test shall also demonstrate that control room alarm annunciation occurs, if any of the following conditions exist, where applicable. j

1. Instrument indicated levels above the alarm setpoint.

2. Circuit failure.

3. Instrument indicates a downscale failure.

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4. Instrument controls not set in OPERATE mode. l

) Calibration shallinclude performance of a functional test.

") Calibration shallinclude performance of a source check.

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

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

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Functional tests anorations, and instrument checks are not required when these instruments are not

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required to be operable or are tripped. Calibration is not required to be performed more than once every 18 months.

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(8)

Operability is verified prior erforming discharge and once a day during planned discharge.

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DRESDEN Revision 1.7 l April 1998 -

l l TABLE 12.2-3 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION l

l-l UNIT 1 l

l Minimum Total Applicable Channels No. of Operational Instrument Operable Channels Modes Action

1. Main Chimney SPING Noble Gas 1 3

28 Monitors

2. Main Chimney Particulate 1 1 27 Samplers l

3. Main Chimney lodine Samplers 1 1 27

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At all times. .

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i DRESDEN Revision 1.7 April 1996 TABLE 12.2-3 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION UNITS 2 & 3 Minimum Total Applicable Channels No. of Operational Instrument Operable Channels Modes Action

1. Main Chimney Noble Gas /SPING/ 1 3 20 GE Low Range Activity Monitor

2. Main Chimney SPING Noble Gas 1 1 26 Monitors Mid, Hi Range

3. Main Chimney lodine Sampler 1 1 22

4. Main Chimney Particulate Sampler 1 1 22

5. Main Chimney Flow Rate Monitor 1 1 21

6. Main Chimney Sampler Flow Rate 1 1 21 Monitor

7. Reactor Building Vent Exhau:r, See Technical Specifications Section 3/4.2 Duct Radiation Monitor

8. Reactor Building Vent SPING 1 1 25 Noble Gas Monitor Low, Mid,

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High Rrnge

9. Reactor Building Vent Flow 1 1 21 Rate Monitor

10. Reactor Building Vent Sampler 1 1 21 Flow Rate Monitor

11. Reactor Building Vent lodine 1 1 22 Sampler

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12. Reactor Building Vent 1 1 22 Particulate Sampler

13. Offgas Radiation Activity 1 2 "

29 Monitor

At all times.

- During Steam Jet Air Ejector operation.

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DRESDEN Rsvision 1.7 April 1998 TABLE 12.2-3 (Cont'd)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION ACTIONS AND TABLE NOTATIONS ACTION 20 - With less than the minimum channels operable, effluent releases via this pathway may continue for up to 30 days provided grab samples are taken at least once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and analyzed for noble gas within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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

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

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

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

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

ACTION 22 - With less than the minimum channels operable, effluent releases via this pathway

[ may continue provided samples are continuously collected with auxiliary sampling

equipment, as required in Table 12.4-1, (The normal sampler for 2/3 Main Chimney is the 2/3 Main Chimney SPING while for the 2/3 Reactor Building Vent it is the 2/3 Reactor Building Vent SPING. j If the 2/3 Chimney SPING is not operational, the normat backup is the GE Low Range Activity Skid. This skid collects an lodine and Particulate sample.

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

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

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

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

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

. h%vorddatabdcmWn12r17. doc 12-14

DRESDEN Revision 1.7 April 1998 report to the Commission pursuant to Technical Specification 6.9.B within the next 30 days outlining the plans, actions taken and procedures to be used to provide for the loss of sampling capability of the system.

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

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

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

(The normal lodine and Particulate sampler for D1 Main Chimney is the D1 Main Chimney SPING. If the D1 Chimney SPING is not operational, the normal backup is a sample pump attached to the sample stream from the Main Chimney. The sample pump collects an lodine and Particulate sample.)

ACTION 28 - With less than the minimum channels operable, effluent releases via this pathway may continue provided daily noble gas samples are taken and analyzed daily.

Restore the inoperable equipment to operable status within 30 days. If service can not be retumed, document equipment availability difficulties within the Radioactive Effluent Release Report for the period including actions taken in response to the equipment and procedures used to provide for the loss of sampling capability of the system.

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

ACTION 29 - *'

With less than the minimum channels operable, gases from the main condenser off gas system may be released to the environment for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided the off gas system is not Dypassed and at least one chimney monitor is operable; otherwise, be in HOT STANDBY in 12 houm.

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DRESDEN Revision 1.7 April 1998 i I

TABLE 12.2-4 l (O

,j RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS UNIT 1 Applicable Functional Calibration *) Instrument Source Operational Instrument Test ('" Check Check Modes

1. Main Chimney SPING Q E D M

l Noble Gas Monitor Low Range

'At all times.

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DRESDEN Rsvision 1.7 j April 1998 l TABLE 12.2-4 )

l RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS O UNITS 2 & 3 i i

Applicable l Functional Calibration *" Instrument Source Operational Instrument Test ('"') Check (') Check Modes

1. Main Chimney Noble Q E D M Gas Activity Monitor

2. Main Chimney SPING Q E D M Noble Gas Monitor Lo, Mid, High Range

3. Main Chimney NA NA D(0 NA Particulate and lodine Sampier

4. Main Chimney Flow Q E D NA Rate Monitor -

5. Main Chimney Sampler Q(* E D NA Flow Rate Monitor

6. Reactor Bldg Vent Sea Technical Specifications Section 3/4.2

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Exhaust Duct Radiation Monitor

7. Reactor Bldg Vent Q E D M SPING Noble Gas Monitor Lo, Mid, High Range C. Reactor Bldg Vent O E D NA Flow Rate Monitor

9. Reactor Bldg Sampler Q(* E D NA Flow Rate Monitor

10. Reactor Bldg Vent NA NA D(O NA

Particulate and

! lodine Sampler l

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11. Off Gas Radiation Q E D E Activity Monitor l

At all times.

- During Steam Jet Air Ejector operation.

O hWddatabdcmen12r17. doc 12-17

DRESDEN R3 vision 1.7 April 1998 TABLE 12.2 4 (Cont'd)

O) 5 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRtiYC **. TION SURVEILLANCE REQUIREMENTS TABLE NOTATIONS

(*)

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

1. Instrument indicates levels above the alarm setpoint.

2. Circuit failure.

3. Instrument Indicates a downscale failure.

4. Instrument controls not set in OPERATE mode.

) Calibration shall include performance of a functional test.

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

(*

Functional test shall be performed on local switches providing low flow alarm.

(*)

Functional tests, calibrations, and instrument checks are not required when these instruments

. are not required to be operable or are tripped. Calibration is not required to be performed more

than once every 18 months. "*

(

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h;\worddatabdCmWn12ri-7. doc i

12 18

]

DRESDEN Revision 1.7 12.2.C Liauid And Gaseous Effluents Instrumentation Bases

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

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h:WyorddatabdomWn12ri-7. doc 12-19

)

DRESDEN Revision 1.7 April 1998 12.3 LIQUID EFFLUENTS 12.3.A J,.iauid Effluents Limits and Reportina Operability

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

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

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

1. During any Calendar Quarter:

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

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

2. During any Calendar Year:

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

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

3. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) and defines the corrective actions taken and the proposed actions to be taken to ensure that future releases are in compliance with Sections 12.3.A.2.1 and 12.3.A.2.2. This is in lieu of a Licensee Event Report.

I Upe: technical specification approval, ten (10) times the Appendix B value may be used to determine the maximum instantaneous liquid release.

h.iworddatabdcmWn12ri.7 doc 12-20

DRESDEN Revision 1.7 April 1998 12.3.A Liould Effluents Limits and Reportino Operability (Cont'o)

/~'N 4. With the calculated dose from the release of radioactive materials in h liquid effluents exceeding the limits of Sections 12.3.A.2.1 or 12.3.A.2.2., prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose or dose commitment to a member of the public from all uranium fuel cycle sources is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is hmited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures to all real individuals from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are less than the 40 CFR Part 190 Standard. Otherwise obtain a variance from the Commission to permit releases which exceed the 40 CFR Part 190 Standard. The radiation exposure analysis contained in the Special Fiepe t shall use methods prescribed in the ODCM. This report is in lieu of a Licensee Event Report.

5. When the projected annual whole body or any intemal organ dose computed at the nearest downstream community water system is equal to or exceeds 2 mrem from all radioactive materials released in liquid effluents from the Station, prepare and submit a Special Report within 30 days to the operator of the community water system. The report is prepared to assist the operator in meeting the requirements of 40 CFR Part 141, EPA Primary Drinking Water Standards. A copy of this report will be sent to the NRC. This is in lieu of a Licensee Event Report.

3. Dose Projections

/~

V At all times during processing prior to discharge to the environs, process and control equipment provided to reduce the amount or concentration of radioactive materials shali be operated when the projected dose due to liquid effluent releases to unrestricted areas (Dres .en Station ODCM Annex, Appendix F, Figure F-1), when averaged over 31 days, exceeds 0.12 mrem to the total body or 0.40 mrem to any organ'.

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

10 h W,ordotabdcmvin12ri.7. doc 12-21

T 1 l l 1 !

DRESDEN Revision 1.7 April 1998 12.3. A Uauid Effluents Limits and Reportina Operability (Cont'd)

4. Liauid Radioactive Waste Treatment System '

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

1. Identification of the defective equipment.

2. Cause of the defect in the equipment.

3. Action (s) taken to restore the equipment to an operating status.

4. Length of time the above requirements were not satisfied.

5. Volume and curie content of the waste discharged which was not processed by the appropriate equipment but which required processing.

6. Action (s) taken to prevent a recurrence of equipment failures.

This is in lieu of a Licensee Event Report.

5. System Operability and Plant Operations in the event a limit and/or associated action requirements identified in Sections 12.3.A and 12.3.B cannot be satisfied because of circumstances in excess of those addressed in this Section, no changes are required in the operational condition of the plant, and this does not prevent the plant from entry into any operational mode.

i 12.3.B Liauid Effluents Surveillance

1. Concentration in Unrestricted Areas The concentration of radioactive material in unrestricted areas shall be determined to be within the prescribed limits by obtaining representative samples in accordance with the sampling and analysis program specified in Table 12.3-2. The sample analysis results will be used with the calculational methods in the ODCM to determine that the concentrations are within the limits of Section 12.3.A.1.

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i h wvorddatabdcmen12rt 7. doc 12-22

DRESDEN Revision 1.7 April 1998 12.3.B Licuid Effluents Surveillance (Cont'd)

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

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

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

Q v

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1 h WrorddatabdcmWn12ri.7 doc 12-23

DRESDEN Revision 1.7 April 1998 TABLE 12.3-1 ALLOWABLE CONCENTRATION OF DISSOLVED OR ENTRAINED NOBLE GASES RELEASED FROM THE SITE TO UNRESTRICTED AREAS IN LIQUID WASTE NUCLIDE AC(uCi/mIP Kr-85m 2 x 10" Kr-85 5 x 10" Kr-87 4 x 10~5 Kr-88 9 x 10'5 Ar-41 7 x 10 4 Xe-131m 7 x 10" Xe-133m 5 x 10" Xe-133 6 x 10" Xe-135m 2 x 10" ,:

Xe-135 _

2 x 10" Computed from Equation 20 of ICRP Publication 2 (1959), adjusted for infinite cloud submersion in water, and R = 0.01 rem / week, density = 1.0 g/cc and Pw/Pt = 1.0.

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h:'. vrddatabdcmMn12r1-7. doc 12-24 1

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DRESDEN Revision 1.7 April 1998 TABLE 12.3-2 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM UNIT 1 i

j LOWER LIMIT OF TYPE OF ACTIVITY DETECTION

LIQUID RELEASE SAMPLING MINIMUM ANALYSIS ANALYSIS (LLD)") (pCi/ml) !

i TYPE FREQUENCY <e) FREQUENCY (*)

(

Above See TS 3/4.8.J See TS 3/4.8.J Principal Gamma 5x10-7 Ground Emitters")

Liquid Storage Dissolved & Entrained 1x10-5 Tanks Gases") (Gamma Emitters)

[ ',

l hMddataalcmwn12r1-7. doc 12-25

{

DRESDEN Revision 1.7 April 1998 TABLE 12.3-2 l RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM l UNITS 2 & 3 l I

LOWER LIMIT OF i TYPE OF ACTIVITY DETECTION I

LIQUID RELEASE SAMPLING MINIMUM ANALYSIS ANALYSIS (LLD)(" (pCi/ml)

TYPE FREQUENCY

FREQUENCY

A. Batch Prior to Prior to Principal Gamma 5x10-7 Release Each Batch Each Batch Emitters

4 Tanks 1-131 1x10 Prior to M Gross Alpha 1x10~7 Each Batch Composite

H-3 1x10~5 Prior to O Fe-55 1x10*

a Each Batch Composite

Sr-89, Sr-90 5x10 Prior to M Dissolved & Entrained 1x10'5 One Batch /M Gases *(Gamma Emitters)

M* 4 B. Plant MW I131 1x10 Continuous (Grab Sample)

Releases") p

{

MW MS

~

Principal Gamma 5x10-7 (Grab Sample) Emitters

MW M* Dissolved & Entrained 1x10'S (Grab Sample) Gases * (Gamma Emitters)

M* M* H-3 1x10~5 l (Grab Sample)

Gross Alpha 1x10~7 l

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

(Grab Sample) ?

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

Liquid Storage Emitters

Tanks Dissolved & Entrained 1x10'5 Gases * (Gamma Emitters) hhddataedemwn12r17 doc 12-26 i

L____ _-__

DRESDEN Revision 1.7 April 1998 TABLE 12.3-2 (Cont'd)

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION W The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

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

LLD = 4.66S.,

E V 2.22 x 10CY exp (-AAt)

Where:

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

so= the standard deviation of the backpround counting rate or of the counting rate of a blank sample as appropriate (cou,1ts per minute),

E = the counting efficiency (counts per disintegration),

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

8 2.22 x 10 = the number of disintegrations per minute per microcurie, Y = the fractional radiochemical yield, when applicable, O' A= the radioactive decay constant for the particular radionuclide (sec "), and At = the elapsed time between the midpoint of sample collection and the time of counting -

(sec).

Typical value.s of E V, Y, and At should be used in the calculation.

Altemate LLD Methodolooy An altemate methodology for LLD determination follows and is similar to the above LLD equation:

(2,71 + 4.65VB) Decay LLD =

E q b Y t (2.22E06) ,

O hAvorddatabdcm4n12ri-7. doc 12 27

DRESDEN Revision 1.7 April 1998 TABLE 12 3-2 (Continued)

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION Where:

j B = background sum (counts)

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

Y = fractional radiochemical yield or collection efficiency (if applicable) t = count time (minutes) 2.22E06 = number of disintegrations per minute per microcurie (2.71 + 4.65VB) = k2 + (2k V 2 V B), and k = 1.645.

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

Decay = e'^' [ ART /(1-e. ART)] [ To /(1-e'*")), (if applicable)

A = radioactive deidy' constant, (units consistent with At, RT and Ta)

At =

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

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

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

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

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

O hWddatabdcmWn12rl 7 doc 12-28

i DRESDEN Rzvision 1.7 April 1998 TABLE 12.3-2 (Cont'd)

RADIOACTIVE LlOUID WASTE SAMPLING AND ANALYSIS Pt40 GRAM

)

TABLE NOTATION A composite sample is one in which the quantity of liquid samples is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.

If the alarm setpoint of the service water effluent monitor as determined in the ODCM is excoeded, the frequency of analysis shall be increased to daily until the condition no longer exists.

A batch release is the discharge of liquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated and then thoroughly mixed to assure representative sampling. A continuous release is the discharge of liquid wastes of a nondiscrete volume; e.g.,

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

The principal gamma emitters for which the LLD specification applies exclusively are Se following radionuclides: Mn-54, Fe-59, Co-60, Zn-65, Co-58, Mo-99, Cs-134 Cs-137, Ce-141, and Ce-144. Other peaks which are measurable and identifiable by gamma ray spectrometry together with the above nuclides, shall be also identified and reported when the actual analysis is performed on a sample. Nuclides which are below the LLD for the analyses shall not be reported as being present at the LLD level for that nuclide.

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

Other dissolved and entrained gases (gamma emitters) which are measurable and identifiable

[' by gamma ray spectrometry, together with the above nuclides, shall also be identified and ~*

reported when an actual analysis is performed on a sample. Nuclides which are below the LLD for the analyses shall not bc rcported as being present at the LLD level for that nuclide.

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O h.\worddatabdcmWn12ri.7. doc 12-29

DRESDEN Revision 1.7 April 1998 12.3.C LIQUID EFFLUENTS BASES

1. Concentration This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified in Appendix B, Table 2, Column 2 to 10CFR20.1001 20.2402.

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

Routine Reactor Releases for the Purpose of implementing Appendix I", April 1977.

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

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

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hTworddatabdcmWn12r17 doc 12-30

DRESDEN Revision 1.7 April 1998 12.3.C LlOUID EFFLUENTS BASES -(Continued)

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

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1 h:\worddatabdcmbn12ri-7. doc 12-31

DRESDEN Revision 1.7 April 1993 12.4 GASEOUS EFFLUENTS 1 A. Gaseous Effluents Limits and Reportina Ooerability

1. Dose Rate The dose rate in unrestricted areas at or beyond the site boundary (Dresden Station ODCM Annex, Appendix F, Figure F-1) due to radioactive materials released in gaseous effluents from the site shall be limited to the following.

1. For Noble Gases:

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

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

2. For iodine-131, for iodine-133, tritium and for all radionuclides in particulate form with half-lives greater than 8 days, less than a dose rate of 1500 mrem / year.

3. If the dose rates exceed the above limits, without delay decrease the release rates to bring the dose rates tvithin the limits, and provide notification to the Commission (per 10 CFR Part 20.2203).

2. Noble Gas Dose The air dose in unrestricted areas at or beyond the site boundary due to noble gases l released in gaseous effluents from the unit shall be limited to the following: '

1. For Gamma Radiation O (1) Less than or equal to 5 mrad during any calendar quarter.

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

2. For Beta Radiation (1) Less than or equal to 10 mrad during any calendar quarter, (2) Less than or equal to 20 mrad during any calendar year.

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

O V

h \worddata'occmbn12r17. doc 12-32

l DRESDEN Revision 1.7 April 1998 12.4.A Gaseous Effluents Limits and Reoortina Operability (Cont'd)

4. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding the limits of Sections 12.4.A.2.1 or 12.4.A.2.2, prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the doses or dote commitment to a member of the public from all uranium fuel cycle sources is limited to less than or equal to 25 mrem to the total body or any organ (except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures to all members of the public from all uranium fuel cycle sources (including all effluent pathways and direct radiation) are less tr,an 40 CFR Part 190 Standard. Otherwise, obtain a variance from the Commission to permit releases which exceed the 40CFR Part 190 Standard. The radiation exposure analysis contained in the Special Report shall use the methods prescribed in the ODCM. This report is in lieu of a Licensee Event Report.

5. Process and control equipment provided to reduce the amount or concentration of radioactive materials shall be operated when the projected dose due to gaseous effluents released to the unrestricted areas, when averaged over 31 days, exceeds 2% of the annual dose limits of Appendix 1 to 10CFR50.

3. lodine-131. todine-133. Tritium. and Particulate Dose The dose to a member of the public in unrestricted areas at or beyond the site boundary from iodine-131, lodine-133, tritium, and all radionuclide: in particulate form with half-lives greater than 8 days in gaseous effluents releasea from the unit shall be limited to the following.

1. Less than or equal to 7.5 mrem to any organ during any calendar quarter.

2. L.ess than or equal to 15 mrem to any organ during any calendar year.

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

4. With the calculated dose from the release of iodine-131, lodine 133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents exceeding the limits of Sections 12.4.A.3.1. or 12.4.A.3.2.,

prepare and submit a Special Report to the Commission within 30 days and limit subsequent releases such that the dose or dose commitment to a member of the public from all uranium fuel sources l

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i h:%vorddatabdcm'dn12r17. doc l 12-33 1

1

DRESDEN Revision 1.7 April 1990 12.4.A Gaseous Effluents Limits and Reportino Operability (Cont'd) is limited to less than or equal to 25 mrem to the total body or organ (except j the thyroid, whict. is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures to all members of the public from all uranium fuel cycle sources (including all effluent p9thways and direct radiation) are less than the 40 CFR Part 190 Standard. Otherwise, obtain a variance from the Commission to permit releases which exceed the 40 CFR Part 190 Standard. The radiation exposure analysis contained in the Special Report shall use the methods prescribed in the ODCM. This report is in lieu of a Licensee Event Report.

5. Process and control equipment provided to reduce the amount or concentration of radioactive materials shall be operated when the projected dose due to gaseous effluents released to the unrestricted areas, when averaged over 31 days, exceeds 2% of the annual dose limits of Appendix 1 to 10CFR50.

4. Off-Gas Treatment

1. At all times during processing for discharge to the environs, process and control equipment provided to reduce the amount of concentration of radioactive materials shall be operated. j i

2. The above specification shall not apply for the Off-Gas Charcoal Adsorber Beds below 30 percent of rated thermal power. ;

f 3. The recombiner shall be operable whenever the reactor is operating at a

pressure greater than 900 psig.

4. The recombiner may be inoperable for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

5. With either the recombiners inoperable, or all charcoal beds by passed for more than 7 days in a calendar quarter while operating above 30 percent of the rated thermal power, prepare and submit to the Commission within 30 days a Special Report which includes the following information.

a. Identification of the defective equipment.

b. Cause of the defect in the equipment.

c. Action (s) taken to restore the equipment to an operating status.

d. Length of time the above requirements were not satisfied.

e. Volume and curie content of the waste discharged which was not processed by the inoperab!e equipment but which required processing.

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hWrddataedemdn12r17. doc 12 34

r DRESDEN Revision 1.7 l April 1998 l 12.4.A Gaseous Effluents Limits and Reportino Operability (Cont'd)

I

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

l This is in lieu of a Licensee Event Report.

5. Main Condenser Air Elector The release rate of the sum of the activities from the noble gases measured at the main condenser air ejector d :ll be limited to < 100 microcuries/sec per MWt (after 30 minutes decay) when in i; ades 1,2*, and 3*_ With the release rate of the sum of the activities from noble gases at the main condenser air ejector effluent (as measured prior to the offgas holdup line) > 100 microcuries/sec per MWt, after 30 minutes decay, restore the release rate to within its limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , or be in at least STARTUP with the main steam isolation valves closed within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

(Refer to Technical Specification 3.8.l.)

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

v

When the main condenser air ejector is in operation.

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9 h:\worddatabdomun12ri 7. doc ;

12-35 ,

DRESDEN Revision 1.7 April 1998 12.4.B Gaseous Effluents Surveillance l

1. Dose Ratg

{ l I

The dose rates due to radioactive materials released in gaseous effluents from the l site shall be determined to be within the prescribed limits by obtaining representative I samples in accordance with the sampling and analysis program specified in Table 12.4-1. The dose rates are calculated using methods prescribed in the ODCM.

2. Noble Gas Dose I The air dose due to releases of radioactive noble gases in gaseous effluents shall be determined to be within the prescribed limits by obtaining representative samples in accordance with the sampling and analysis program specified in Sections A and B of Table 12.4-1. The allocation of effluents between units having shared effluent control system and the determination of cumulative and projected dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once every 31 days.

3. lodine-131. lodine-133. Tritium and Particulate Dose The dose to a member of the public due to releases of iodine-131, lodine-133, ,

tritium, and all radionuclides in particulate form with half-lives greater than 8 days j Aall be determined to be within the prescribed limits by obtaining representative samples in accordance with the sampling and analysis program specified in Table 12.4-1.

For radionuclides not determined in each batch or weekly composite, the dose

[\ ^ contribution to the current calendar quarter cumulative summation may be estimated '

by assuming an average monthly concentration based on the previous monthly or quarterly composite analyses. However, for reporting purposes, the calculated dose contributions shall be based on the actual composite analyses when possible.

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

4. Off-Gas Treatment l l

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

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hTworddatabdcmWn12ri 7 doc 12-36

DRESDEN Revision 1.7 April 1998 12.4.B Gaseous Effluents Surveillance - Continued I

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

1. At least once per 31 days.

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

(Refer to Technical Specification 4.8.1.)

)

O h:\worddatabdcmV$n12ri 7. doc 12-37

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DRESDEN Revision 1.7 April 1998 1

TABLE 12.41 i O RADIOACTIVE GASEOUS WASTE SAMPLING l AND ANALYSIS PROGRAM I UNIT 1 GASEOUS SAMPLING MINIMUM TYPE OF RELEASE FREQUENCY ANALYSIS LOWER LIMIT OF ACTIVITY TYPE FREQUENCY ANALYSIS DETECTION (LLD)U)

(pCi/ml)

A. Main M M Principal Gamma 1x10" Chimney (Grab Sample) Emitters *)

Tritium 4 1x10 4

Noble Gases 1x10 M(") M (3) 1-131 1x1012 ;

(Continuous) lodine Sample 1-133 1x10 i MS M() Principal Gamma 1x10-"

(Continuous) Particulate Sample Emitters *)

Q Q Sr-89, Sr 90 1x10'"

O (Continuous) Composite Particulate Sample Gross Alpha

1 G

hTworddatabdcmWn12ri-7. doc 12-38

DRESDEN Rsvision 1.7 April 1998 Table 12.4-1 RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM UNITS 2 & 3 l l

LOWER LIMIT I GASEOUS SAMPLING MINIMUM TYPE OF ACTIVITY OF l RELEASE FREQUENCY ANALYSIS ANALYSIS DETECTION l TYPE FREQUENCY (LLD)") (pCi/ml)

A. Main M Mc2) Principal Chimney (Grab Sample) Gamma Emitters") 1x10" Reactor Bldg. M Tritium 1x10 4

Vent Stack B. All Continuous (*) W3) 1-131 1x10 a2 Release lodine Sample I-133 1x10" Types as Listed i in A l above l

Continuous (*) W) Principal Gamma 1x10 " I Particulate Sample Emitters *)

~~

Continuous (') Q Sr-89 1 x10'"

Composite Particulate Sample Sr-90 1 x10'"

Continuous (*) Q Gross Alpha 1 x10'" i Composite I Particulate Sample

}

(

C. Main Continuous (') 4 Noble Gas Monitor Noble Gases 1x10 '

Chimney d

D. Reactor Continuous (') Noble Gas Monitor Noble Gases 1x10 Bldg.

Vent Stack l

hAvorddatabdcmMn12ri 7. doc 12-39 i l

DRESDEN Ravision 1.7 April 1998 TABLE 12.4-1 (Cont'd)

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION f

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

For a particular measurement system, which may include radiochemical separation: l LLD = 4.66Ss ,

E V 2.22 x 10 6~

Y exp ( LAt)

Where:

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

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

E = the counting efficiency (counts per disintegration),

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

8 2.22 x 10 = the number of disintegrations per minute per microcurie, ,

V Y = the fractional radi0 chemical yield, when applicable, A= the radioactive decay constant for the particular radionuclide (sec "), and at = the elapsed time between the midpoint of sample collection and the time of counting q (sec).

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

Altemate LLD Methodoloav An attemate methodology for LLD determination tollows and is similar to the above LLD equation:

(2.71 + 4.65VB)+ Decay LLD =

E q b Y t (2.22E06)

O hTworddatabdcmVin12ri.7. doc 12-40

DRESDEN Revision 1.7 April 1998 TABLE 12.4-1 (Continued)

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATIONS Where:

8 = background sum (counts)

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

Y = fractional radiochemical yield or collection efficiency, (if applicable) t = count time (minutes) 2.22E06 = number of disintegrations per minute per microcurie (2.71 + 4.65VB) = k2 + (2k V 2 V B), and F = 1.645.

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

Decay = e"' [ ART /(1 e#7)] [ATo /(1-e*)), (if applicable)

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

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

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

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

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

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

O h.\worddatabdcmbn12rt-7. doc 12-41

DRESDEN Revision 1.7 April 1998 TABLE 12.4-1 (Cont'd)

'~~T RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION Sampling and analyses shall also be performed following shutdown, startup, or a thermal power change exceeding 20 percent of rated thennal power in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months unless (1) analysis shows that the dose equivalent 1-131 concentration in the primary coolant has not increased more than a factor of 5, and (2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3.

Samples shall be changed at least once per 7 days and the analyses completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after removal from the sampler. Sampling shall also be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following each shutdown, startup, or thermal power level change exceeding 20% of rated thermal power in one hour. This requirement does not apply if 1) analysis shows that the dose equivalent 1-131 concentration in the primary coolant has not increased more than a factor of 5, and 2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3.

When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are analyzed, the corresponding LLDs may be increased by a factor of 10.

The ratio of sample flow rate to the s&mpled stream flow rate shall be known.

The principal gamn a imitters for which the LLD specification applies exclusively are the following radionuclis'= Mr-87, Kr 88, Xe-133, Xe 133m, Xe 135, and Xe-138 for gaseous emissions, and Mn 54, Fe 59, Co-60, Zn-65, Co-58, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144 for particulatt emissions. Other peaks which are measurable and identifiable by gamma ray spectromt:try, together with the above nuclides, shall be also identified and reported when an actual analys,s is performed on a sample. Nuclides which are below the LLD for the O

V analyses shall not be reported as being present at the LLD level for the nuclide. '

Analysis frequency shall be increased to 1/ week if release rates exceed 1% of any applicable limit referenced in the ODCM, when added to Units 2 and 3 airbome effluents.

i h \worddataiodemVfn12r17 doc 12-42

DRESDEN Revision 1.7 April 1998 12.4.C Gaseous Effluents Bases

~OG 1. Gaseous Effluents - Dose This Section is provided to ensure that the dose at the unrestricted area boundary from gaseous effluents from the units on site will be within the annual dose limits of 10CFR20 for unrestricted areas. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual in an unrestricted area to annual average concentrations exceeding the limits specified in Appendix B Table 2 of 10CFR20.1001-2402. The release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual at or oeyond the unrestricted area boundary to less than or equal to 500 mrem / year to the total body or to less than or equal to 3000 mrem / year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background via the inhalation pathway to less than or equal to 1500 mrem / year. For purposes of calculation doses resulting from airbome releases, the main chim_ney is considered to be ,

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

2. Dose. Noble Gases This Section is provided to implement the requirements of Sections 11.B, Ill.A and IV.A of Appendix 1,10 CFR Part 50. The Operability Requirements implement the guides set forth it Section 11.3 of Appendix 1. The statements provide the required operating flexibbity and at the same time implement the guides set forth in Section IV.A of Appendix i to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The surveillance requirements implement the requirernents in Section Ill.A of Appendix i that conformance with the guides of Appendix i

.O I is to be shown by calculational procedures based on models and data such that the 'l Vg actual exposure of an individual through the appropriate pathways is unlikely to be {

substantially underesiimated. The dose calculations established in the ODCM for '

calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents will be consistent with the methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evalusting Compliance with 10 CFR Part 50, Appendix 1," Revisior.1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water Cooled Reactors," Revision 1, July 1977. NUREG-0133 provides methods for dose calculations consistent with Regulatory Guides 1.109 and 1.111.

%/

hTworddataedermdn12r17 doc 12-43

DRESDEN Revision 1.7 April 1998 12.4.C Gaseous Effluents Bases (Cont'd)

3. Dose. Radiolodines. Radioactive Material in Particulate Form and Radionuclides Other than Noble Gases This Section is provided to implement the requirements of Sections ll.C, Ill.A and IV.A of Appendix 1,10 CFR Part 50. The Operability Requirements are the guides set forth in Section ll.C of Appendix l. The statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as reasonably achievable " The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section Ill.A of Appendix 1 that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated. The ODCM calculational methods approved by NRC for calculating the doses due to the actual release rates of the subject materials are required to be consistent with the methodology provided in Regulatory Guide 1.109. " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I", Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate limits for radiciodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area. The pathways which were examined in the development of these limits were: 1)individualinhalation of airbome '

radionuclides,2) deposition of radionuclides onto green leafy vegetation with subsequent l consumption by man and 3) deposition onto grassy areas where milk animals graze with consumption of the milk by man. 'I

4. Gaseous Waste Treatment The operability of the gaseous waste treatment which reduces amounts or concentrations of radioactive materials ensures that the system will be available for use l whenever gaseous effluents require treatment prior to release to the environment. The 1 requirement that the appropriate portions of this system be operable when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as reasonably achievable". This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to j 10 CFR Part 50, and design objective Section ll.D of Appendix ! to 10 CFR Part 50.

O hAvorddatabdcmWn12r1-7. doc 12-44

DRESDEN Revision 1.7 April 1998 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.1 Monitorina Proaram Operability Reauirements 12.5.1. A The Radiological Environmental Monitoring Program shall be conducted as specified in Table 12.5-1.

ADolicability: At all times.

Action: j

1. With the Radiological Environmental Monitoring Program not being conducted as specified in Table 12.51, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Section 12.6.1, a description of the reasons for not conducting the program as required and the e plans for preventing a recurrence.

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

possible. All deviations from the sampling scheduls will be described in the i Annual Radiological Environmental Operating Report.

2. With the level of radioactivity as the result of plant effluents in an environmental '

( sampling medium at a specified location exceeding the reporting levels of Table 12.5-2 whesi overaged over any calendar quarter, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.B, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce radioactive effluents so that the potential ,

annual dose

to a MEMBER OF THE PUBLIC is less than the calendar year I limits of Section 12.3.A.2,12.4.A.2, or 12.4.A.3. When more than one of the l radionuclides in Table 12.5-2 are detected in the sampling medium, this report I shall be submitted if: j concentration (1) . concentration (2) + ...> 1.0 reporting level (1) reporting level (2)

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

to A MEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of Section 12.3.A.2,12.4.A.2, or 12.4.A.3.

This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Section 12.6.1.

The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report.

d h3worddatabdcmbn12ri 7. doc 12-45

f l

l DRESDEN Revision 1.7 l

April 1998 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (Continued)

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

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

Surveillance Reauirements 12.5.1.8 The radiological environmental monitoring program samples shall be collected pursuant to Table 12.5-1 from the specific locations given in the table and figure (s) in the ODCM, and shall be analyzed pursuant to the requirements of Table 12.5-1 and the detection capabilities required by Table 12.5-3.

Bases 12.5.1.C The Radiological Environmental Monitoring Program required by this section provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation. This monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50 and ,

thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways. Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring.

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

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table 12.5-3 are considered optimum for routine environmental measurements in industrial laboratories.

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

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, LA., " Limits for Qualitative (

Detection and Quantitative Determination - Application to Radiochemistry," Anal. Chem.

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

hworddataiodemVin12rt 7. doc 12-46

DRESDEN Revision 1.7 April 1998 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (Continued)

Interpretations 12.5.1.0 Table 12.5-1 requires "one sample of each community drinking water supply downstream of the plant within 10 kilometers." Drinking water supply is defined as water taken from l rivers, takes, or reservoirs (not well water) which is used for drinking, l

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s mid lpi m nt o wr t nn e io t

n nosu R E t t 1 t s e u) l o a oa st i

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r B c im t n sic ea r

prea

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M i

d lei h di o 3ad i

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c nj o k m

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(

r o

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le i 1 m n B R I I TT r m b A

I V AA f

sc hm a s t a isi h T N TC ea2 e g

si t le lew NO E lp e6 b e pn L EL n( a v mw

_ A S EE mim a nk s w t

e f

a ao C L g e srg

_ I R P eo0 e l e

G P ivr1 v d vs O EM t gn t o

a o iale) .

t L RA S t a si n yh o r t pi O r b" nm e m t

F e ai I

D OD sw w e n e nn") sa6 A N r ehs o oo e s R r r 8 E A rt t R o pan i po1 t

a epa t s t t sa lo r et o B ic r dd r a at t r at M

U d

n owou oa l e le e t e g n o oi3 wd c

I Tf q t

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a b Y

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t 2

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w h

o

DRESDEN Revision 1.7 j April 1998 l l

TABLE 12.5-1 (Continued)

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

Power Plants," October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979.

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

(3) Airbome particulate sample filters shall b9 analyzed for gross beta radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulato samples is greater than 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples.

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

(5) One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation.

l The 40 locations is not an absolute number. The number of direct radiation monitoring l stations may be reduced according to geographical limitations; e.g., if a station is 3 adjacent to a lake, some sectors may be over water thereby reducing the number of dosimeters which could be placed at the indicated distances. The frequency of analysis or readout fo TLD systems will depend upon the characteristics of the specific system used and shouid be selected to obtain optimum dose information with minimal fading.

(6) Groundwater samples shall be taken when this source is tapped for drinking or irrigation

purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

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

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

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

l (9) Biweekly refers to every two weeks.

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

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

O h1worddatabdctnwnt2ri 7. doc 12-53 i

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=

lI!!

DRESDEN Revision 1.7 i April 1998 I l

TABLE 12.5-3 (Continued)

DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS TABLE NOTATIONS (1) The nuclides on this list are not the only nuclides intended to be considered. Other peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Operating Report.

(2) Required detection capabilities for thermoluminescent dosimeters used for environmental measurements shall be in accordance with the recommendations of Regulatory Guide 4.13.

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

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

4.66 So + 3/to LLD =

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

4.66 So LLD ~

(E) (V) (2.22) (Y) (exp (-Aat)) .,

~

, Wh.:re: 4.66 So >> 3/te l

l l

LLD = the "a priori" Minimum Detectable Concentration (picoCuries per unit masa or volume),

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

4TotalCounts

= 16 E = the counting efficiency (counts per disintegration),

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

2.22 = the number of disintegrations per minute per picocurie, Y = the fractional radiochemical yield, when applicable, A = the radioactive decay constant for the particular radionuclide (sec"),

O' h:%rnrddata.3dem'dn12ri-7. doc ,

i 12-56 i

e I

DRESDEN Revision 1.7 April 1998 !

TABLE 12.5-3 (Continued) f G DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS

'd TABLE NOTATIONS

)

to = counting time of the background or blank (minutes), and at = the elapsed time between sample collection, or end of the sample collection period, and the time of counting (sec).

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

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

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

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

Altemate LLD Methodolooy An altemate methodology for LLD determination follows and is similar to the above LLD equation:

(2.71 + 4.65VB)* Decay LLD =

E q b Y t (2.22E06) .

Where:

eer B = background sum (counts)

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

b = abundance, (if applicable)

Y = fractional radiochemical yield or collection efficiency, (if applicable) t = count time (minutes) 2.22E06 = number of disintegrations per minute per microcurie 1

(2.71 + 4.65VB) = k2 + (2k V 2 V B), and k = 1.645. !

(k=value of the t statistic from the single-tailed t distribution at a significance level E of 0.95% and infinite degrees of freedom. This means that the LLD result represents a 95% detection probability with a 5% probability of falsely concluding ;

that the nuclide present when it is not or that the nuclide is not present when it is.) i Decay = e*^' p.RT/(1-e#')] [).To /(1-e8)], (if applicable)

O h:'worddatabdcmWn12ri.7. doc 12-57

DRESDEN Revision 1.7 April 1998 TABLE 12.5-3 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS TABLE NOTATIONS A = radioactive decay constant, (units consistent with At, RT and To)

At = " delta t*, or the elapsed time between sample collection or the midpoint of sample collection and the time the count is started, depending on the type of sample, (units consistent with 1)

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

To = sample deposition time, or the duration of analyte collection onto the sample media, (unit con # Mnt with 1)

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

It should be recognized that the LLD is defined as a before the fact limit and not as an after the fact limit for a particular measurerr.ent (4) If no drinking water rathway exists, the value of 15 pCl/l may be used. ,

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

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

(7) This LLD is the minimum allowaole, however, vendors performing environmental sample analyses off-site will be required to meet an LLD of 200 pCl/1.

O h%orddatabdcmen12r1-7. doc 12-58

l DRESDEN Revision 1.7 i April 1998 12.5.2 Land Use Census

' ('}')erability

\ Reouirements

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

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

Arnlicability: At all times.

Action:

1. With a Land Use Census ide ,tifying a location (s) that yields a calculated dose or dose commitment, via the same exposure pathway 20% greater than at a location from which samples are currently being obtained in accordance with Section 12.5.1, add the new location (s) within 30 days to the Radiological Environmental Monitoring Program given in Chapter 11. The sampling location (s), exc uding the control location, having the lowest calculated dose or dose commitment (s), via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year in which this Land Use Census was conducted. Submit in the next Annual Radiological Environmental Operating Report documentation for a change in the ODCM including a revised figure (s) and table (s) for the ODCM reflecting the new location (s) with information supporting the change in sampling locations.

This requ;rement may be reduced according to geographical limitations; e.g. at a lake site where some sector's will be over water.

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

Surveillance Reauirements _

f).5.2.B The Land Use Census shall be conducted during the growing season, between June 1 and October 1, at least '

V once per 12 moriths using that information that will provide the best results, such as by a door-to door survey, aerial survey, or by consulting loccl agricuiture authorities. The results of the Land Use Census snall be included in the Annual Radiological Environmental Operating Report.

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

This census satisfics the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. An annual garden census will not be required since the licensee will assume that there is a garden at the nearest residence la each sector for dose calculations.

I l

l

[

V}

hAvorddatabdctmdn12rl-7 doc 12-59

DRESDEN R: vision 1.7 April 1998 12.5.3 Interf aboratory Comparison Proaram Operability Reouirements 12.5.3.A Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program that correspond to samples required by Table 12.5-1.

Acolicability: At all times.

Action:

1. With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report.

Surveillance Reauirements 12.5.3.B A summary of the results obtained as part of the above required int 9rlaboratory Comparison Program shall be included in the Annual Radiological Environmentai Operating Report.

Bases 12.5.3.C The requirement for participation in an Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive materialin environmental samples matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix 1 to 10 CFR Part 50.

O h.%vorddataWcind12ri.7. doc 12-60

f I

DRESDEN Revision 1.7 April 1998 12.6 RECORDKEEPING_A_ND REPORTING

>O 12.6.1. Station Operatino Records 1

1. Records and/or logs relative to the following items shall be kept in a manner l convenient for review and shall be retained for at least five years.

! (

l

1. Records and periodic checks, inspection and/or calibrations perfcrmed l to verify the surveillance requirements (See the applicabic surveillance in the Instrumentation, Liquid Effluents, Gaseous Effluents, and Radiological Environmental Monitoring Sections) are being met. All equipment failing to meet surveillance requirements and the corrective action taken shall be recorded.

2. Records of radioactive shipments.

2. Records and/or logs relative to the following items shall be recorded in a manner convenient for review and shall be retained for the life of the plant.

I 1. Records of off-site environmental monitoring surveys.

l 2. Records of radioactivity in liquid and gaseous wastes released to the I i environment.

3. Records of reviews performed for changes made to the ODCM.

l 12.6.2. Reports

1. Radioactive Effluent Release Report

, The Radioactive Effluent Release Report covering the operation of the unit I during the previous 12 months of operation shall be submitted to the Commission prior to April 1 of each year. The report shallinclude a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance with 10 CFR l Part 50.36a and Section IV.B.1 of Appendix l to 10 CFR Part 50.

2. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the l

objectives in (1) the ODCM and (2) Sections IV.B.2., IV.B.3, and IV.C of Appendix i to 10 CFR Part 50. A detailed listing of the requirement of the report is given below:

I U

hhrddatabdcm'dn12ri 7. doc 12-61

DRESDEM Revision 1.7 April 1998 12.0.2 Reports - (Cont'd)

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

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

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

(b) An assessment of the monitoring results and radiation dose via the principal pathways of exposure resulting from plant emissions of radioactivity including the maximum noble gas gamma and beta air doses in the unrestricted area. The assessment of radiation doses shall be performed in accordance with the ODCM.

(c) Results of the census to determine the locations of animals producing milk for human consumption, and the pasture season feeding practices at dairies in the monitoring program.

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

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

(f) The results of the interlaboratory comparison program described in Secuon 12.5.3.

(g) The results of the 40 CFR Part 190 uranium fuel cycle dose analysis fo-each calendar year.

(h) A summary of the monitoring program, including maps showing sampling locations and tables giving distance and direction of sampling locations from the station.

i 1

3. Non-Routine Environmental Report (a) If a confirmed measured radionuclide concentration in an environmental sampling medium averaged over any calendar quarter sampling period exceeds the reporting level given in Table 12.5-2 and if the radioactivity is attributable to plant operation, a written report shall be submitted to the Regional Administru.ar of NRC Regional Office, with a copy to the Director, Office of Nuclear Reactor Regulation, wi'hin 30 days from the end of the quarter. When more than one of the radionuclides in Table 12.5-2 are detected in the medium, the reporting level shall have been exceeded if IC/(RL), is equal to or greater than 1 where C is the concentration of the l'" radionuclide in the medium and RL is the reporting level of radionuclide i.

I O'l hhddata odomen12r1-7. doc 12-62 I

r DRESDEN Revision 1.7 April 1998 m 12.6.2 Reports - (Cont'd)

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

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

12.6.3. Offsite Dose Calculation Manual (ODCM)

1. The ODCM shall contain the methodology and parameters used in the caiculation of offsite doses due to radioactive gaseous and liquid effluents and in I

the calculation of gaseous and liquid effluent monitoring Alarm / Trip setpoints I and in the conduct of the Radiological Environmental Monitoring Program. The J ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological '

, Environmental Monitoring Programs described in Section 12.2 - 12.5 and (2) l descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports j required by Sections 12.6.2.1 and 12.6.2.2.

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

2. Changes to the ODCM:

O l *l l

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

! as required by Technical Specification 6.14.A. This documentation shall l l

contain: '

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

(2) Shall be effective after review and acceptance by the Onsite Review &

Investigative Function and the approval of the Station Manager, on the date specified by the Onsite Review and Investigative Function.

O

\

h:horddatabdcmen12r17. doc 12-63

DRESDEN Revision 1.7 April 1998 12.6.3 Offsite Dose Calculation Manual (ODCM)-(Cont'd)

(3) Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM or updated pages, if the Commission retains a controlled copy. If an entire copy of the ODCM is submitted, it shall be submitted as a part of or concurrent with the Radioactive Effluent Release Report for the period of tlia report in which any change to the ODCM wre made effective. Each change shall be identified by

. markings ni the margin of the affected pages, clearly indicating the area of the page that was changed, and shallindicate the date (e.g.,

month / year) the change was implemented.

12.6.4. Maior Chanaes to Radioactive Waste Treatment Systems (Liould and Gaseous)

NOTE: This information may be submitted as part of the annual FSAR update.

1. Licensee initiated major changes to the radioactive waste systems may be made provided:

The change is reported in the Monthly Operating Report for the period in which the evaluation was reviewed by the On-Site Review and investigative Function.

The discussion of each change shall contain:

(1) A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR Part 50.59; (2) Sufficient detailed information to support the reason for the change; (3) A detailed descriptior of the equipment, components, and process involved and the interfaces with other plant systems; (4) An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents that differ from those previously predicted in the license application and amendments; (5) A comparison of the predicted releases of radioactive materials in liquid and gaseous effluents to the actual releases for the period in which the changes were made; (6) An estimate of the exposure to plant operating personnel as a result of the change; and (7) Documentation of the fact that the change was reviewed and found acceptable by the On-Site Review and Investigative Function.

2. The change shall become effective upon review and acceptance by the On-Site Review and Investigative Function.

O h.WyorddataWcr. Mn* .it 7 dou 12-64

ML20217N933

Text

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