ML23117A170

Annual Radioactive Effluent Release Report

ML23117A170
Person / Time
Site:	Millstone
Issue date:	04/27/2023
From:	Armstrong L Dominion Energy Nuclear Connecticut
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
23-117
Download: ML23117A170 (1)

Text

Dominion Energy Nuclear Connecticut, Inc.

Millstone Power Station 31 4 Rope Ferry Road, Waterford, CT 06385 ft Dominion j # Energy Dominion Energy.com APR 2 7 2023 U.S. Nuclear Regulatory Commission Serial No.23-117 Attention: Document Control Desk MPS Lie/LO RO Washington, DC 20555-0001 Docket Nos. 50-245 50-336 50-423 License Nos. DPR-21 DPR-65 NPF-49 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 1, 2, AND 3 2022 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT In accordance with 10 CFR 50.36a, this letter transmits the annual Radioactive Effluent Release Report (RERR) for the period January 1, 2022, through December 31, 2022.

This report meets the provisions of Section 5.7.3 of the Millstone Power Station Unit 1 Permanently Defueled Technical Specifications (POTS), and Sections 6.9.1.6b and 6.9.1.4 of the Millstone Power Station Units 2 and 3 Technical Specifications, respectively. transmits Volume 1 of the 2022 RERR, in accordance with Regulatory Guide 1.21 . The RERR contains information regarding airborne, liquid, and solid radioactivity released from Millstone Power Station, including the off-site dose from airborne and liquid effluents. transmits Volume 2 of the report, which consists of a complete copy of the Radiological Effluent Monitoring and Off-Site Dose Calculation Manual (REMODCM) as of December 31, 2022. This satisfies the requirements of Sections 5.6.1 c of the Millstone Power Station Unit 1 POTS, and Sections 6.15c and 6.13c of the Millstone Power Station Units 2 and 3 Technical Specifications, respectively.

Should you have any questions, please contact Mr. Dean E. Rowe at (860) 444-5292.

Sincerely, L. J. Armstrong Director, Nuclear Station Safety and Licensing

Serial No.23-117 2022 Radioactive Effluent Release Report Page 2 of 4 Attachments: 2 Commitments made in this letter:

1. None.

cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Rd., Suite 102 King of Prussia, PA 19406-1415 P. Longmire NRC Project Manager Millstone Unit 1 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 5-A 10 11555 Rockville Pike Rockville, MD 20852-2738 L. A. Kauffman NRC Inspector U.S. Nuclear Regulatory Commission Region I 475 Allendale Rd., Suite 102 King of Prussia, PA 19406-1415 Nick Eckhoff NRC Inspector U.S. Nuclear Regulatory Commission Region I 475 Allendale Rd., Suite 102 King of Prussia, PA 19406-1415 R. V. Guzman NRC Project Manager Millstone Units 2 and 3 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.23-117 2022 Radioactive Effluent Release Report Page 3 of 4 Director Bureau of Air Management Monitoring & Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127 A. Honnellio Regional Radiation Representative (EPA Region 1, Boston)

U.S. Environmental Protection Agency (Region 1) 5 Post Office Square Suite 100 Boston, MA 02109 G. Allen Jr.

Department of Health and Human Services U. S. Food and Drug Administration 140 Shrewsbury Street, Suite 1 Boylston, MA 01501 M. Bachman Executive Director Connecticut Siting Council 10 Franklin Square New Britain, CT 06051 J.P. Kelley Waterford-East Lyme Shellfish Commission Waterford Town Hall Waterford, CT 06385 J. Folkwein American Nuclear Insurers 95 Glastonbury Blvd.

Glastonbury, CT 06033 D. Carey Connecticut Department of Agriculture Aquaculture Division P. 0. Box 97 Milford, CT 06460 R. Brule First Selectman Town of Waterford Waterford Town Hall Waterford, CT 06385

Serial No.23-117 2022 Radioactive Effluent Release Report Page 4 of 4 K. A. Seery First Selectman Town of East Lyme PO Box 519 Niantic, CT 06357 University Of Connecticut Library Serials Department Storrs, CT 06268

Serial No.23-117 Docket Nos. 50-245 50-336 50-423 License Nos. DPR-21 DPR-65 NPF-49 ATTACHMENT 1 2022 RADIOACTIVE EFFLUENTS RELEASE REPORT VOLUME 1 MILLSTONE POWER STATION UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

Millstone Power Station 2022 Attachment 1 Radioactive Effluents Release Report Volume One Dominion Energy Nuclear Connecticut, Inc.

Unit License Docket 1 DPR-21 50-245 2 DPR-65 50-336 3 NPF-49 50-423

Table of Contents List of Tables .................................................................................................................................................................2 Introduction....................................................................................................................................................................4 1.0 Off-Site Doses..........................................................................................................................................................4 1.1 Dose Calculations ....................................................................................................................................................4 1.1.1 Gaseous Effluents............................................................................................................................................5 1.1.2 Liquid Effluents ..............................................................................................................................................6 1.2 Dose Results ............................................................................................................................................................6 1.2.1 Gaseous Effluents............................................................................................................................................6 1.2.2 Liquid Effluents ..............................................................................................................................................7 1.2.3 Analysis of Results ..........................................................................................................................................7 1.3 Other Sources of Radiation Dose to the Public (from Ref. 13) ..............................................................................12 2.0 Effluent Radioactivity ............................................................................................................................................13 2.1 Gaseous Effluents ..................................................................................................................................................13 2.1.1 Measurement of Radioactivity in Gaseous Effluents ....................................................................................13 2.1.2 Estimate of Errors .........................................................................................................................................15 2.1.3 Gaseous Batch Release Statistics ..................................................................................................................15 2.1.4 Abnormal Gaseous Releases .........................................................................................................................15 2.1.5 Gaseous Release Tables ................................................................................................................................16 2.2 Liquid Effluents .....................................................................................................................................................32 2.2.2 Estimate of Errors .........................................................................................................................................33 2.2.3 Liquid Batch Release Statistics .....................................................................................................................33 2.2.4 Abnormal Liquid Releases ............................................................................................................................33 2.2.5 Liquid Release Tables ...................................................................................................................................34 2.3 Solid Waste ............................................................................................................................................................42 2.4 Groundwater Monitoring .......................................................................................................................................57 3.0 NONFUNCTIONAL Effluent Monitors ................................................................................................................59 4.0 Operating History...................................................................................................................................................59 5.0 ERRATA ...............................................................................................................................................................62 6.0 REMODCM Changes ............................................................................................................................................62 7.0 References..............................................................................................................................................................63 1

List of Tables Table 1-1: 2022 Off-Site Dose Commitments from Gaseous Effluents Millstone Units 1, 2, 3 .................................. 8 Table 1-2: 2022 Off-Site Commitments from Liquid Effluents Millstone Units 1, 2, 3 .............................................. 9 Table 1-3: 2022 Off-Site Dose Comparison to Limits Millstone Units 1, 2, 3 .......................................................... 10 Table 1-4: 2022 Off-Site Dose Comparison Natural Background vs Millstone Station ............................................ 11 Table 2.1-A1: Unit 1 Gaseous Effluents Release Summary ...................................................................................... 16 Table 2.1-A2: Unit 1 Gaseous Effluents - Continuous Ground - BOP Vent & SFPI Vent ....................................... 17 Table 2.1-L1: Unit 1 Liquid Effluents - Release Summary ...................................................................................... 34 Table 2.1-L2: Unit 1 Liquid Effluents - Batch - Liquid Waste Processing .............................................................. 35 Table 2.1-S: Unit 1 Solid Waste & Irradiated Component Shipments ....................................................................... 43 Table 2.2-A1: Unit 2 Gaseous Effluents - Release Summary ................................................................................... 18 Table 2.2-A2: Unit 2 Gaseous Effluents - Ground Batch .......................................................................................... 19 Table 2.2-A3: Unit 2 Gaseous Effluents - Ground Continuous - RWST Vent, Equipment Hatch ........................... 20 Table 2.2-A4: Millstone Unit 2 Gaseous Effluents - Elevated Batch - Millstone Site Stack .................................... 21 Table 2.2-A5: Unit 2 Gaseous Effluents - Elevated Continuous - Millstone Site Stack ........................................... 22 Table 2.2-A6: Unit 2 Gaseous Effluents - Mixed Batch - Unit 2 Main Exhaust Vent .............................................. 23 Table 2.2-A7: Unit 2 Gaseous Effluents - Mixed Continuous - Unit 2 Main Exhaust Vent..................................... 24 Table 2.2-L1: Unit 2 Liquid Effluents - Release Summary ...................................................................................... 36 Table 2.2-L2: Unit 2 Liquid Effluents - Continuous - SGBD, SW, RBCCW, TB Sumps, Tendon Gallery ............ 37 Table 2.2-L3: Unit 2 Liquid Effluents - Batch - Liquid Radwaste System .............................................................. 38 Table 2.2-S: Unit 2 Solid Waste & Irradiated Component Shipments ....................................................................... 47 Table 2.3-A1: Unit 3 Gaseous Effluents - Release Summary ................................................................................... 25 Table 2.3-A2: Unit 3 Gaseous Effluents - Ground Batch - ESF Building Rooftop .................................................. 26 Table 2.3-A3: Gaseous Effluents - Ground Continuous - ESF Building Vent, CTMT Equipment Hatch, RWST Vent, ABD TK-2 VENT ........................................................................................................................................ 27 Table 2.3-A4: Unit 3 Gaseous Effluents - Elevated Batch - Millstone Site Stack .................................................... 28 Table 2.3-A5: Unit 3 Gaseous Effluents - Elevated Continuous - Millstone Site Stack ........................................... 29 Table 2.3-A6: Unit 3 Gaseous Effluents - Mixed Continuous - Unit 3 Ventilation Vent ......................................... 30 Table 2.3-A7:Unit 3 Gaseous Effluents - Mixed Continuous - Unit 3 Ventilation Vent .......................................... 31 Table 2.3-L1: Unit 3 Liquid Effluents - Release Summary ...................................................................................... 39 Table 2.3-L2: Unit 3 Liquid Effluents - Continuous-SGBD, SW, TB Sumps, SRW Sump 3, ABD TK-2 .............. 40 Table 2.3-L3: Unit 3 Liquid Effluents-Batch-Liquid Radwaste System, CPF sumps, Hotwell, SG bulk, WTT Berm

............................................................................................................................................................................... 41 Table 2.3-S :Unit 3 Solid Waste & Irradiated Component Shipments ....................................................................... 52 Table 2.4-GW: Well Sample Results......................................................................................................................... 57 2

List of Acronyms ABD-TK-2 Auxiliary Boiler Drains Tank 2 ADV- Atmospheric Dump Valve BOP - Balance of plant CFR - Code of Federal Regulations CPF - Condensate polishing facility DENC - Dominion Energy Nuclear Connecticut DOT - Department of Transportation DSN - Discharge serial number EBFS - Enclosure building filtration system EDAN- Environmental Data Acquisition Network EDST- Equipment Drain Sump Tank ESF - Engineering safeguards facility GI - Gastrointestinal GWPP - Groundwater protection program HPGe - High purity germanium ISFSI - Independent spent fuel storage installation MPS - Millstone Power Station MPS1 - Millstone Power Station Unit 1 MPS2 - Millstone Power Station Unit 2 MPS3 - Millstone Power Station Unit 3 MDA - Minimum Detectable Activity NCRP- National Council on Radiation Protection and Measurements NEI- Nuclear Energy Institute NPP - Nuclear power plant NRC - Nuclear Regulatory Commission RBCCW - Reactor building closed cooling water REMODCM - Radiological Effluent Monitoring and Offsite Dose Calculation Manual RWST - Reactor water storage tank SFPI - Spent Fuel Pool Island SG - Steam generator SGBD - Steam generator blowdown SLCRS - Secondary Leakage Collection and Recovery System SW - Service water TB - Turbine building WGDT - Waste gas decay tank WRGM - Wide range gas monitor WTT - Waste test tank 3

Introduction This report, for the period of January 1, 2022, through December 31, 2022, is being submitted by DENC, Inc. for MPS1, MPS2, and MPS3, in accordance with 10 CFR 50.36a, the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM), the MPS1 Permanently Defueled Technical Specifications, and the MPS2 and MPS3 Technical Specifications. This report contains radiological and volumetric information on gaseous and liquid effluents, doses to the public from these effluents, shipments of solid waste & irradiated components, onsite well water results, information on effluent instrumentation which was nonfunctional for more than 30 consecutive days and operating history.

Radioactive materials may be disposed of in solid waste shipments sent to licensed disposal sites or released in liquid or gas form in effluents to the local environment. The two basic characteristics used to describe radioactive effluents are radioactivity and radiation dose. The radioactivity of any given radionuclide increases in direct proportion to the amount of the radionuclide present. This report lists the amounts of various radionuclides present in radioactive effluents. For this report, activity can be thought of as the amount of radioactive material present in radioactive effluents. Section 2.0 of this report gives the activity released from MPS in 2022.

Although radioactivity is an important, inherent characteristic that helps to describe radioactive effluents, it is notby itselfa good indicator of the potential health effects from exposure to radiation. Health effects are dependent on many factors, such as the radionuclide, the type of radiation emitted by the radionuclide, the energy of the radiation, the uptake of the radionuclide into the human body, and the metabolism of the radionuclide by the human body. To properly describe the potential health effects from exposure to radioactive materials, a measure that accounts for all of these differences is needed. Dose is a measure of how much radiation energy is absorbed by organs or tissues of the body.

Dose is a good indicator of the potential health effects from exposure to radiation. Section 1.0 of this report gives the dose from activity released from MPS in 2022.

1.0 Off-Site Doses This report provides a summary of the 2022 off-site radiation doses from releases of radioactive materials in gaseous and liquid effluents and from direct radiation from MPS1, 2 and 3. This includes the annual maximum dose in millirem (mrem) to any real member of the public as well the maximum gamma and beta air doses. To provide perspective, these doses are compared to the regulatory limits (in Table 1-3) and to the annual average dose that a member of the public could receive from natural background and other sources (in Table 1-4). The doses from radioactive effluents were less than the doses from other sources of natural radiation that are commonly considered safe. This indicates radioactive effluents from MPS in 2022 had no significant impact on the health and safety of the public or the environment.

1.1 Dose Calculations Dose from radioactive effluents is calculated to ensure compliance with NRC requirements in 10 CFR Part 50, Appendix I (Reference. 7). The dose calculations are based on the measurements and computer models listed below:

measurements of the radioactive materials released to the environment, models of how radionuclides are dispersed and diluted in the environment, models of how radionuclides are incorporated into animals, plants, and soil, and models of the biokinetic of human uptake and metabolism of radioactive materials.

The models are designed to calculate the dose to a real (or hypothetical) individual closest to MPS or to an individual who may be exposed to the highest concentrations of radioactive materials from radioactive effluents. This person is often referred to as the maximum exposed individual. The parameters and assumptions used in these dose calculations include conservative assumptions that tend to overestimate the calculated exposures. Although the location of the maximum individual may vary each quarterly period, the annual dose is the sum of these quarterly doses. This conservatively assumes that the individual is at the location of maximum dose each quarter. As a result, the actual doses received by real individuals are often much less than those calculated.

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The off-site dose to humans from radioactive material in liquid and gaseous effluents have been calculated using measured radioactive effluent data and the dose computation algorithm in OpenEMS, an effluent tracking program (Reference 9). For liquid dose OpenEMS uses equations which yield the same result as the methodology given in NRC Regulatory Guide 1.109 (Reference 3). For airborne dose OpenEMS uses an algorithm equivalent to the NRC code, GASPAR II (Reference 1), which uses a semi-infinite cloud model to implement the NRC Regulatory Guide 1.109 (Reference 3) dose models. The values of average relative effluent concentration (X/Q) and average relative deposition (D/Q) used in OpenEMS were generated using EDAN, a meteorological computer code. The annual summary of hourly meteorological data (in 15-minute increments), which includes wind speed, direction, atmospheric stability, and joint frequency distribution, is not provided in the report but are available. Doses are based upon exposure to radioactivity in gaseous and liquid effluents over a one-year period and an associated dose commitment over a 50-year period from initial exposure. The portion of the doses due to inhalation and ingestion considers radioactive decay and biological elimination of the radioactive materials.

The dose calculations are based upon three types of input: radioactive source term, site-specific data, and generic factors.

The radioactive source terms (Curies) are given in Section 2, Effluent Radioactivity, of this report. The site-specific data includes meteorological data (e.g., wind speed, wind direction, atmospheric stability) to calculate the transport and dispersion of gaseous effluents, average annual milk consumption rates and dilution factors for liquid effluents. The generic factors include the average annual consumption rates (for ingestion of vegetables, produce, meat, fish, and shellfish), shielding factor for air submersion and ground irradiation and occupancy factors for shoreline activity, swimming, and boating.

1.1.1 Gaseous Effluents The following release points are considered ground level:

MPS1 SFPI Vent (73 foot)

MPS1 BOP Vent (80 foot)

MPS2 and 3 Refueling Water Storage Tank (RWST) Vents MPS3 Engineered Safety Features Building (ESF) Ventilation Auxiliary Boiler Drains Tank 2 (ABD TK-2) Vent MPS2 & 3 Containment Equipment Hatch MPS3 Containment Drawdowns Doses for releases from these points were calculated using the 33 foot meteorology. For each unit, doses from their respective release points were summed to determine the total unit gaseous effluent ground level dose.

The following release points are considered mixed mode (partially elevated and partially ground) releases:

MPS2 Auxiliary Building Ventilation (159 foot elevation)

MPS3 Auxiliary Building Ventilation (133 foot elevation)

MPS2 No. 1&2 Atmospheric Dump Valves The doses for mixed mode releases are calculated using 142 foot meteorology for which the Pasquill stability classes are determined based upon the temperature gradient between the 33 foot and 142 foot meteorological tower levels.

The MPS Stack release point at 374 foot elevation is considered an elevated release. Doses for elevated releases are calculated using Pasquill stability classes determined based upon the temperature gradient between the 33 foot and 374 foot meteorological tower levels. Only MPS2 and MPS3 discharge to the MPS Stack. In March 2001, MPS1 was separated from the stack and two new release points were added to MPS1, the Spent Fuel Pool Island (SFPI)

Vent and the Balance of Plant (BOP) Vent. The following are sources of radioactivity for releases from the stack:

MPS2 Waste Gas Decay Tanks batch releases MPS2 Containment Vents batch releases MPS2 Containment Purge batch releases MPS3 Containment Vents batch releases MPS3 Gaseous Waste System continuous releases MPS3 Containment Purge batch releases (only during outage in fourth quarter) 5

1.1.2 Liquid Effluents MPS discharges radioactivity in water through two release pathways - thru the MPS Quarry to the Long Island Sound and thru Discharge Point DSN-006 to Niantic Bay. Discharges to the MPS Quarry are from primary side water, primarily from liquid waste processing systems. Discharges to DSN-006 are from secondary side water, primarily turbine building sumps. MPS1 discharges only to the MPS Quarry from sumps and leakage collection systems. Discharges to both release pathways are considered either continuous or batch discharges. Sources of continuous and batch discharges are listed in Sections 2.2.1.1 and 2.2.1.2. Water containing radioactivity being discharged to the MPS Quarry is diluted mainly by circulating water and, to a minor extent, by service water. Water containing radioactivity being discharged to DSN-006 is diluted by storm drains runoff.

1.2 Dose Results The calculated maximum off-site doses are presented in Table 1-1 for gaseous effluents and Table 1-2 for liquid effluents. The units mrad and mrem used in this report are units of radiation dose. The letter m is for milli, or one-thousandth of a rad or a rem. The word rad is an acronym for radiation absorbed dose. One rad is equal to the absorption of 100 ergs of energy per gram of tissue. The word rem is an acronym for roentgen equivalent man.

One rem is equal to a rad multiplied by factors to account for type of radiation and distribution within the body.

1.2.1 Gaseous Effluents For the dose to the maximum individual, OpenEMS calculates the dose to the whole body, gastrointestinal (GI),

bone, liver, kidney, thyroid, lung, and skin from each of the following pathways: direct exposure from submersion in noble gases in the plume, direct exposure from ground deposition of radioactivity, inhalation, and ingestion of vegetation, produce, cow or goat milk, and meat. A cloud shine dose component for releases of noble gas radioactivity from the elevated MPS Stack is calculated using Reference 14. This cloud shine pathway accounts for dose to the maximum individual from the plume at the site boundary while the plume is still elevated. The values presented are a total from all pathways. Only the whole body, skin, thyroid, and maximum organ (other than thyroid) doses are presented.

For the plume and inhalation pathways, the maximum individual dose is calculated at the off-site location of the highest /Q where a potential for dose exists.

For ground deposition and ingestion pathways (vegetation, meat and milk), the maximum individual dose is calculated at the location of the highest D/Q. For the milk pathways (cow and goat), the calculated dose is included in the maximum individual's dose only at locations and times where these pathways actually exist.

The EDAN computer that records the meteorological parameters used to determine the /Q and D/Q values has experienced a hardware failure. This hardware failure has impacted the preparation 2022 RERR by using the default

/Q and D/Q values documented on page 59 of the REMODCM (Vol.2) instead of the quarterly average values.

Based on functionality of the meteorological instrumentation it is expected that data recover rate will greater than 90%, once the EDAN computer hardware is fixed. The restoration of the EDAN computer is not expected till second half of 2023, so the revised gaseous does values will be updated in the 2023 RERR errata. The values determined in Tables 1-1, 1-3, and 1-4 will be lower once the doses are calculated using the quarterly average /Q and D/Q values.

To determine compliance with 10 CFR 50, Appendix I (Reference 7), the maximum individual whole body and organ doses include all applicable external pathways (i.e., plume and ground exposure) as well as the internal pathways (inhalation and ingestion) are documented below.

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1.2.2 Liquid Effluents Maximum individual doses from the release of radioactive liquid effluents were calculated using OpenEMS which gives dose results equal to dose results calculated using NRC Regulatory Guide 1.109. OpenEMS performs calculations for the following pathways: fish, shellfish, shoreline activity, swimming, and boating. Doses are calculated for the whole body, skin, thyroid, and maximum organ (GI, bone, liver, kidney, and lung).

1.2.3 Analysis of Results Table 1-3 provides a quantitative dose comparison with the limits specified in the REMODCM. Gaseous and liquid effluent doses are compared to limits required by technical specifications and contained in Appendix I of 10 CFR 50.

Total offsite doses are compared to limits in 40 CFR 190 (Reference 8). The data indicates that the total whole body and organ doses to the maximum offsite individual from MPS including all sources of the fuel cycle are well within the limits. On-site radioactive waste and spent fuel storage during this year was within storage criteria and the maximum dose to a member of the public from these sources was approximately 0.08 mrem. The doses from gaseous and liquid effluents were added to the estimated dose from on-site radioactive waste storage to show compliance compared to 40 CFR 190.

The Offsite Dose Comparison, Table 1-4, provides a perspective on the maximum offsite individual dose received from MPS with the natural background radiation dose received by the average Connecticut resident (Reference 4).

The total dose to the maximum individual received from MPS is 0.3% of the dose received from natural background radiation.

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Table 1-1 2022 Off-Site Dose Commitments from Gaseous Effluents MPS1, 2, 3 MPS1 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Annual Total Max Air mrad mrad mrad mrad mrad Beta 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Gamma 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Max Individual mrem mrem mrem mrem mrem Whole Body 7.63E-06 3.90E-05 4.20E-05 1.76E-05 1.06E-04 Skin 7.63E-06 9.12E-06 9.83E-06 9.45E-06 3.60E-05 Thyroid 7.63E-06 3.90E-05 4.20E-05 1.76E-05 1.06E-04 Max organ1 7.63E-06 3.90E-05 4.20E-05 1.76E-05 1.06E-04 MPS2 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Annual Total Max Air mrad mrad mrad mrad mrad Beta 2.94E-06 3.12E-06 3.19E-06 3.53E-06 1.28E-05 Gamma 6.09E-06 6.07E-06 6.16E-06 6.62E-06 2.49E-05 Max Individual mrem mrem mrem mrem mrem Whole Body 2.68E-03 4.94E-02 5.20E-02 1.93E-02 1.23E-01 Skin 4.70E-04 2.06E-03 2.78E-03 2.57E-03 7.89E-03 Thyroid 2.70E-03 5.36E-02 5.73E-02 2.74E-02 1.41E-01 Max organ1 1.03E-02 2.89E-01 2.86E-01 8.37E-02 6.69E-01 MPS3 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Annual Total Max Air mrad mrad mrad mrad mrad Beta 3.10E-05 2.05E-05 2.66E-05 2.68E-05 1.05E-04 Gamma 2.70E-06 9.61E-06 2.18E-06 8.02E-06 2.25E-05 Max Individual mrem mrem mrem mrem mrem Whole Body 4.43E-03 3.64E-02 6.93E-02 2.59E-02 1.36E-01 Skin 1.54E-03 5.29E-03 4.17E-03 3.91E-03 1.49E-02 Thyroid 4.43E-03 4.42E-02 6.93E-02 2.59E-02 1.44E-01 Max organ1 1.65E-02 1.32E-01 3.66E-01 1.07E-01 6.22E-01 NOTES:

1- Maximum of the following organs (not including thyroid): Bone, GI-LLI, Kidney Liver Lung 8

Table 1-2 2022 Off-Site Dose Commitments from Liquid Effluents MPS1, 2, 3 MPS1 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Annual Total Max Individual (mrem) (mrem) (mrem) (mrem) (mrem)

Whole Body 1.25E-05 0.00E+00 0.00E+00 4.67E-06 1.72E-05 Thyroid 3.48E-06 0.00E+00 0.00E+00 1.33E-06 4.81E-06 Max Organ 1.70E-05 0.00E+00 0.00E+00 6.52E-06 2.35E-05 MPS2 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Annual Total Max Individual (mrem) (mrem) (mrem) (mrem) (mrem)

Whole Body 1.88E-05 1.08E-10 8.43E-06 3.53E-05 6.25E-05 Thyroid 1.88E-05 1.08E-10 8.43E-06 3.53E-05 6.25E-05 Max Organ 1.88E-05 1.08E-10 8.43E-06 3.53E-05 6.25E-05 MPS3 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Annual Total Max Individual (mrem) (mrem) (mrem) (mrem) (mrem)

Whole Body 2.65E-04 4.27E-04 1.62E-04 1.06E-04 9.60E-04 Thyroid 1.90E-04 4.22E-04 1.62E-04 1.06E-04 8.80E-04 Max Organ 7.45E-04 4.70E-06 1.62E-04 1.06E-04 1.02E-03 9

Table 1-3 2022 Off-Site Dose Comparison to Limits MPS1, 2, 3 Gaseous Effluents Dose Whole Body Thyroid Max Organ* Skin Beta Air Gamma Air (mrem) (mrem) (mrem) (mrem) (mrad) (mrad)

MPS1 1.06E-04 1.06E-04 1.06E-04 3.60E-05 0.00E+00 0.00E+00 MPS2 1.23E-01 1.41E-01 6.69E-01 7.89E-03 1.28E-05 2.49E-05 MPS3 1.36E-01 1.44E-01 6.22E-01 1.49E-02 1.05E-04 2.25E-05 MPS 2.59E-01 2.85E-01 1.29E+00 2.28E-02 1.18E-04 4.75E-05 Limits 5 15 15 15 20 10 Liquid Effluents Dose Max Whole Body Thyroid Organ*

(mrem) (mrem) (mrem)

MPS1 1.72E-05 4.81E-06 2.35E-05 MPS2 6.25E-05 6.25E-05 6.25E-05 MPS3 9.60E-04 8.80E-04 1.02E-03 MPS 1.04E-03 9.47E-04 1.10E-03 Limits 3 10 10 Total Off-Site Dose from MPS Max Whole Body Thyroid Organ*

(mrem) (mrem) (mrem)

Gaseous 2.59E-01 2.85E-01 1.29E+00 Liquid 1.04E-03 9.47E-04 1.10E-03 Direct Shine** 8.00E-02 8.00E-02 8.00E-02 MPS 3.40E-01 3.66E-01 1.37E+00 Limits 25 75 25

• Maximum of the following organs (not including Thyroid): Bone, GI-LLI, Kidney, Liver, Lung

• • Direct shine is radiation exposure from onsite storage of radwaste and spent fuel.

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Table 1- 4 2022 Off-Site Dose Comparison Natural Background vs MPS Average Resident Natural Background Radiation Dose Cosmic 30 -100 mrem Terrestrial (Atlantic and Gulf Coastal Plain) 30 - 60 mrem Inhaled 20 - 1,000 mrem In the Body 20 - 80 mrem 100 - 1,240 mrem Courtesy UNSCEAR Report 2000 Maximum Off-Site Individual MPS Whole Body Dose Gaseous Effluents 0.259 mrem Liquid Effluents 0.001 mrem Direct Shine 0.080 mrem 0.340 mrem 11

1.3 Other Sources of Radiation Dose to the Public (from Ref. 13)

This section discusses the doses that the average American typically receives each year from naturally occurring background radiation and all other sources of radiation. The reader can compare the doses received from MPS effluents with the doses received from natural, medical, and other sources of radiation. This comparison provides some context to the concept of radiation dose effects. In March 2009, the National Council on Radiation Protection and Measurements (NCRP) published Report No. 160 as an update to the 1987 NCRP Report No. 93, Ionizing Radiation Exposure of the Population of the United States. Report No. 160 describes the doses to the U.S.

population from all sources of ionizing radiation for 2006, the most recent data available at the time the NCRP report was written. The NCRP report also includes information on the variability of those doses from one individual to another. The NCRP estimated that the average person in the United States receives about 620 mrem of radiation dose each year. NCRP Report No. 160 describes each of the sources of radiation that contribute to this dose, including:

Naturally occurring sources (natural background) such as cosmic radiation from space, terrestrial radiation from radioactive materials in the earth, and naturally occurring radioactive materials in the food people eat and in the air people breathe.

medical sources from diagnosis and treatment of health disorders using radioactive pharmaceuticals and radiation-producing equipment.

consumer products (such as household smoke detectors).

industrial processes, security devices, educational tools, and research activities; and exposures of workers that result from their occupations.

Below is a pie chart showing the relative contributions of these sources of radiation to the dose received by the average American. Larger contributors to dose are represented by proportionally larger slices of the pie. Doses to the public from nuclear power plants are included in the industrial category; doses to workers from nuclear power generation are included in the category of occupational dose. Doses to the public due to effluents from nuclear power plants are less than 0.1% (one-tenth of one percent) of what the average person receives each year from all sources of radiation. Doses to workers from occupational exposures, including those received from work at NPPs, also are less than 0.1% of the average dose to a member of the public from all sources.

Sources of Radiation Exposure to the U.S. Population 12

2.0 Effluent Radioactivity 2.1 Gaseous Effluents 2.1.1 Measurement of Radioactivity in Gaseous Effluents 2.1.1.1 Continuous Releases The following pathways have continuous radiation monitors which monitor gaseous radioactivity and collect radioactive particulates on filters and radioactive halogens (iodines, etc.) on charcoal cartridges except where noted on the list.

MPS1 SFPI Island (no charcoal cartridge)

MPS1 BOP Vent (no charcoal cartridge)

MPS2 Ventilation Vent MPS2 Wide Range Gas Monitor (WRGM) to Site Stack MPS2 Equipment Hatch Opening (no gaseous monitoring)

MPS3 Ventilation Vent MPS3 SLCRS to Site Stack MPS3 ESF Building Vent MPS3 Containment Equipment Hatch Openings (no gaseous monitoring)

MPS2 Atmospheric Dump Valves (ADVS)

Most releases are based on results of sample analyses. Charcoal cartridges and particulate filters are replaced weekly (except every two weeks for MPS1) and analyzed for isotopic content using a gamma spectrometer.

Particulate filters are also analyzed for Strontium-89 (Sr-89) (except for MPS1), Strontium-90 (Sr-90) and gross alpha. At least monthly, gaseous grab samples are taken and analyzed for noble gasses and H-3. The gas washing bottle (bubbler) method is utilized for H-3 collection. This sample is counted on a liquid scintillation detector. Isotopic concentrations at the release point are multiplied by the total flow to obtain the total activity released for each isotope.

Some releases are based on calculation. These include tritium from spent fuel pools, Carbon 14 (C-14), Kr-85 release from SLCRS, Equipment Hatch, and RWST vent releases.

Spent fuel pool tritium release is calculated using concentrations of tritium in the water and evaporation determined by change in pool levels. Grab samples from the MPS1 SFPI Vent and the MPS2 and MPS3 Vents are compared to the measured evaporation and both of these results are included in the amount of tritium released.

C-14 releases are calculated using the methodology in Reference 12. Based on Reference 2, it was conservatively assumed that 30% of the C-14 exists as carbon dioxide (CO2), which may be deposited on surfaces. Thus only 30% of C-14 released yielded dose via ingestion pathways of milk, meat, produce and vegetation. Since the overall quantity of other radioactive releases has steadily decreased due to improvements in power plant operations and improved fuel integrity, C-14 now qualifies as a principal radionuclide. For MPS2 and MPS3, it is assumed that the C-14 will be dispersed equally through the MPS Site Stack and each units main ventilation vent.

Krypton 85 was identified during fuel failure back to 2007 and has caused an elevated response on SLCRS gaseous low range radiation monitor HVR-19B. The detector response elevated above background has been used to determine the amount of Kr-85 released to the environment.

When water is transferred to the RWST there is a potential for a release of radioactivity through the tank vent.

In 2017 MP-CHEM-17-07, Reporting of Radioactivity Released from RWST Vents was written to establish a maximum dose threshold of 0.075 mrem/quarter for creating release permits. The organ dose threshold value of 0.075 mrem/quarter is 1% of the quarterly organ dose limit of 7.5 mrem for H-3 and 13

particulate releases. Nuclides that do not have a partitioning or evaporation factor such as iodines and noble gases are assumed to have been released and are reported in the MPS2 & MPS3 ground release tables. Both the MPS2&3 RWSTs are sampled on a monthly basis during normal operations and prior to transfer when transferring water during outages.

The loading of fuel into canisters was in preparation for transfer of the spent fuel to the Independent Spent Fuel Storage Installation (ISFSI). The loading of fuel bundles of old fuel containing defects have the potential to release Kr-85. Additional monitoring during fuel loading is required by the Radiation Work Permits for loading fuel for an ISFSI campaign, so that any potential release will be monitored by frisker readings and gas grab samples.

2.1.1.2 Batch Releases The following sources of radioactivity releases are considered batch releases:

MPS2 Waste Gas Decay Tanks (WGDT) (via MPS2 WRGM to MPS Stack)

MPS2 Containment Purge (via MPS2 Main Exhaust Vent)

MPS2 Reactor Coolant System Venting MPS2 Equipment Drain Sump Tank.

MPS2 and MPS3 Containment Vents (via EBFS to MPS Stack for MPS2 and via SLCRS to MPS Stack for MPS3)

MPS3 Volume control tank sampling and purging operations MPS3 Process gas system maintenance Waste Gases from the MPS2 Gaseous Waste Processing System are held for decay in waste gas decay tanks prior to discharge through the MPS Site Stack. Each gas decay tank is analyzed prior to discharge for noble gas and H-3. Calculated volume discharged is multiplied by the isotopic concentrations (noble gas and H-3) from the analysis of grab samples to determine the total activity released.

Containment air is sampled prior to each purge for gamma and H-3 to determine the activity released from containment purging. Similar to containment venting, the measured concentrations are multiplied by the containment purge volume to obtain the total activity released. Any iodines and particulates discharged would be detected by the continuous monitoring discussed in section 2.1.1.1. There was only one containment purge conducted in 2022 during MPS3 refueling outage in April. In both cases the discharge pathway alignment to the MP3 Main Exhaust Vent.

Containment air is sampled periodically for gamma and H-3 to determine the activity released from containment venting. The measured concentrations are multiplied by the containment vent volume to obtain the total activity released. MPS2 typically performs this process of discharging air from containment to maintain pressure approximately once per week and MPS3 vents containment about 16 times per month. Any iodines and particulates discharged would be detected by the continuous monitoring discussed in Section 2.1.1.1.

Periodically the MPS3 volume control tank needs to be purged for chemistry control of the reactor coolant system. Normally reactor coolant system gases are maintained and processed by the degasifier, but extensive maintenance required the degasifier to be tagged out of service. While the degasifier was removed from service periodic sampling was required to ensure the reactor chemistry parameters were within specification. These periodic samples would cause deflection on SLCRS gaseous low range radiation monitor HVR-19B and gaseous grab samples of the volume control tank and radiation monitor activity concentration were used to quantify VCT sampling releases.

14

2.1.2 Estimate of Errors Estimates of errors associated with radioactivity measurements were made using the following guidelines:

Radioactivity Measurement Calibration 10% Calibration to NIST* standards Sampling/Data Collection 10% - 20% Variation in sample collection Sample Line Loss 20% - 40% Deposition of some nuclides Sample Counting 10% - 30% Error for counting statistics Flow & Level Measurements 10% - 20% Error for release volumes

• National Institute of Standards and Technology 2.1.3 Gaseous Batch Release Statistics MPS1 - None MPS2 CTMT Vents WGDT Number of Batches 45 7 Total Time (min) 6203 1680 Maximum Time (min) 193 335 Average Time (min) 138 241 Minimum Time (min) 62 195 MPS3 CTMT Vents CTMT Drawdown CTMT Purge Number of Batches 204 0 1 Total Time (min) 49633 0 60 Maximum Time (min) 1166 0 60 Average Time (min) 482 0 60 Minimum Time (min) 53 0 60 2.1.4 Abnormal Gaseous Releases An abnormal gaseous release of radioactivity is defined as radioactive material released in gaseous effluents to the environment that was unplanned or uncontrolled due to an unanticipated event. These do not include normal routine effluent releases from anticipated operational and maintenance occurrences such as power level changes, reactor trip, opening primary system loops, degassing, letdown of reactor coolant or transferring spent resin and do not include non-routine events such as minor leakages from piping, valves, pump seals, tank vents, etc.

2.1.4.1 MPS1 - None 2.1.4.2 MPS2 - None 2.1.4.3 MPS3 - None 15

2.1.5 Gaseous Release Tables The following tables provide the details of the gaseous radioactivity released from each of the MPS units. They are categorized by type of release, source(s), and by release point of discharge to the environment.

Table 2.1-A1 MPS1 Gaseous Effluents - Release Summary 2022 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases

1. Total Activity Ci - - - - -

Released

2. Average Period uCi/sec - - - - -

Release Rate B. Iodines / Halogens

1. Total Activity Ci na na na na na Released

2. Average Period uCi/sec na na na na na Release Rate C. Particulates

1. Total Activity Ci - - - - -

Released

2. Average Period uCi/sec - - - - -

Release Rate D. Gross Alpha

1. Total Activity Ci - - - - -

Released E. Tritium

1. Total Activity Ci 1.01E-02 9.39E-03 1.01E-02 9.74E-03 3.93E-02 Released

2. Average Period uCi/sec 1.30E-03 1.19E-03 1.27E-03 1.22E-03 1.25E-03 Release Rate

"-" denotes less than Minimum Detectable Activity (MDA)

"na" denotes not required to be analyzed

• No activity released 16

Table 2.1-A2 MPS1 Gaseous Effluents - Ground Continuous - BOP Vent & SFPI Vent Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Kr-85 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Iodines / Halogens I-131 Ci na na na na na I-133 Ci na na na na na Other Emitters Ci na na na na na Total Activity Ci na na na na na C. Particulates Be-7 Ci - - - - -

Sr-90 Ci - - - - -

Cs-137 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci - - - - -

E. Tritium H-3 Ci 1.03E-02 9.52E-03 1.14E-02 1.05E-02 4.17E-02

"-" denotes less than Minimum Detectable Activity (MDA)

"na" denotes not required to be analyzed

• No activity released 17

Table 2.2-A1 MPS2 Gaseous Effluents - Release Summary 2022 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases

1. Total Activity Ci 5.22E-02 5.88E-02 6.05E-02 6.86E-02 2.40E-01 Released

2. Average Period uCi/sec 6.72E-03 7.48E-03 7.62E-03 8.63E-03 7.62E-03 Release Rate B. Iodines / Halogens

1. Total Activity Ci 1.24E-05 1.66E-05 3.05E-05 1.94E-05 7.90E-05 Released

2. Average Period uCi/sec 1.60E-06 2.11E-06 3.84E-06 2.44E-06 2.51E-06 Release Rate C. Particulates

1. Total Activity Ci - - 3.43E-07 - 3.43E-07 Released

2. Average Period uCi/sec - - 4.31E-08 - 1.09E-08 Release Rate D. Gross Alpha

1. Total Activity Ci - - - - -

Released E. Tritium

1. Total Activity Ci 3.83E+00 1.42E+00 4.53E+00 3.51E+00 1.33E+01 Released

2. Average Period uCi/sec 4.92E-01 1.81E-01 5.70E-01 4.41E-01 4.21E-01 Release Rate F. C-14

1. Total Activity Ci 2.36E+00 2.52E+00 2.50E+00 2.52E+00 9.90E+00 Released**

2. Average Period uCi/sec 3.03E-01 3.21E-01 3.15E-01 3.17E-01 3.14E-01 Release Rate

"-" denotes less than Minimum Detectable Activity (MDA)

• • Calculated value per "Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents EPRI Final Report, 12/2010.

18

Table 2.2-A2 MPS2 Gaseous Effluents - Ground Level Release - Batch Mode Release Point - No Releases Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Total Activity Ci * * * *

• B. Iodines / Halogens Total Activity Ci * * * *

• C. Particulates Total Activity Ci * * * *

• D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci * * * * *

• No activity released 19

Table 2.2-A3 MPS2 Gaseous Effluents - Ground Level Release - Continuous Mode Release Point - Refuel Water Storage Tank Vent, Equipment Hatch Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Xe-133 Ci - - - - -

Xe-135 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Iodines/Halogens I-131 Ci - - - - -

I-132 Ci - - - - -

I-133 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

C. Particulates Cr-51 Ci - - - - -

Mn-54 Ci - - - - -

Co-58 Ci - - - - -

Co-60 Ci - - - - -

Zr-95 Ci - - - - -

Nb-95 Ci - - - - -

Ag-110m Ci - - - - -

Cs-137 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci - - - - -

"na" denotes Not Required to be Analyzed

"-" denotes less than Minimum Detectable Activity (MDA) 20

Table 2.2-A4 MPS2 Gaseous Effluents - Elevated Release - Batch Mode Release Point - MPS Stack Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Ar-41 Ci 2.20E-02 2.16E-02 2.19E-02 2.34E-02 8.89E-02 Xe-133 Ci 3.00E-02 3.68E-02 3.83E-02 4.47E-02 1.50E-01 Xe-135 Ci 2.35E-04 4.03E-04 3.44E-04 5.37E-04 1.52E-03 Other Emitters Ci - - - - -

Total Activity Ci 5.22E-02 5.88E-02 6.05E-02 6.86E-02 2.40E-01 B. Iodines / Halogens I-131 Ci - - - - -

I-133 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

C. Particulates Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci 2.82E-02 5.28E-02 9.80E-02 8.84E-02 2.67E-01

"-" denotes less than Minimum Detectable Activity (MDA)

"na" denotes not required to be analyzed 21

Table 2.2-A5 MPS2 Gaseous Effluents - Elevated Release - Continuous Mode Release Point - MPS Stack Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Ar-41 Ci - - - - -

Kr-85 Ci - - - - -

Kr-85m Ci - - - - -

Kr-87 Ci - - - - -

Kr-88 Ci - - - - -

Xe-133 Ci - - - - -

Xe-133m Ci - - - - -

Xe-135 Ci - - - - -

Xe-135m Ci - - - - -

Xe-138 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Iodines / Halogens Br-82 Ci - - - - -

I-131 Ci - - - - -

I-133 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

C. Particulates Sr-89 Ci - - - - -

Sr-90 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci 1.82E+00 - - - 1.82E+00 F. C-14 C-14 Ci 1.18E+00 1.26E+00 1.25E+00 1.26E+00 4.95E+00

"-" denotes less than Minimum Detectable Activity (MDA) 22

Table 2.2-A6 MPS2 Gaseous Effluents - Mixed Mode Release - Batch Mode Release Point - MPS2 Main Exhaust Vent, CTMT Purge Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Ar-41 Ci - * * * -

Kr-85 Ci - * * * -

Xe-133 Ci - * * * -

Xe-135 Ci - * * * -

Other Emitters Ci - * * * -

Total Activity Ci - * * * -

B. Iodines / Halogens Br-82 Ci - * * * -

I-131 Ci - * * * -

I-133 Ci - * * * -

Other Emitters Ci - * * * -

Total Activity Ci - * * * -

C. Particulates Co-60 Ci * * * * -

Other Emitters Ci * * * * -

Total Activity Ci * * * * -

D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci - * * * -

• No activity released "na" denotes not required to be analyzed

"-" denotes less than Minimum Detectable Activity (MDA) 23

Table 2.2-A7 MPS2 Gaseous Effluents - Mixed Mode Release - Continuous Mode Release Point - MPS 2 Main Exhaust Vent Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Kr-85 Ci - - - - -

Xe-133 Ci - - - - -

Xe-135 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Iodines / Halogens Br-82 Ci - - - - -

I-131 Ci 2.77E-06 5.62E-06 7.02E-06 5.42E-06 2.08E-05 I-133 Ci 9.67E-06 1.10E-05 2.35E-05 1.40E-05 5.82E-05 Other Emitters Ci - - - - -

Total Activity Ci 1.24E-05 1.66E-05 3.05E-05 1.94E-05 7.90E-05 C. Particulates Co-58 Ci - - - - -

Sr-89 Ci - - - - -

Sr-90 Ci - - - - -

Sb-126 Ci - - 3.43E-07 - 3.43E-07 Cs-137 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - 3.43E-07 - 3.43E-07 D. Gross Alpha Gross Alpha Ci - - - - -

E. Tritium H-3 Ci 1.98E+00 1.37E+00 4.43E+00 3.42E+00 1.12E+01 F. C-14 C-14 Ci 1.18E+00 1.26E+00 1.25E+00 1.26E+00 4.95E+00

"-" denotes less than Minimum Detectable Activity (MDA) 24

Table 2.3-A1 MPS3 Gaseous Effluents - Release Summary 2022 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases

1. Total Activity Ci 5.55E-01 2.87E-01 4.77E-01 4.66E-01 1.78E+00 Released

2. Average Period uCi/sec 7.13E-02 3.65E-02 6.00E-02 5.86E-02 5.66E-02 Release Rate B. Iodines / Halogens

1. Total Activity Ci 5.27E-06 1.09E-05 2.29E-06 1.07E-05 2.91E-05 Released

2. Average Period uCi/sec 6.78E-07 1.38E-06 2.88E-07 1.35E-06 9.24E-07 Release Rate C. Particulates

1. Total Activity Ci - 1.68E-04 - - 1.68E-04 Released

2. Average Period uCi/sec - 2.13E-05 - - 5.32E-06 Release Rate D. Gross Alpha

1. Total Activity Ci - - - - -

Released E. Tritium

1. Total Activity Ci 8.66E+00 1.31E+01 8.66E+00 7.89E+00 3.83E+01 Released

2. Average Period uCi/sec 1.11E+00 1.67E+00 1.09E+00 9.92E-01 1.22E+00 Release Rate F. C-14

1. Total Activity Ci 3.22E+00 1.14E+00 3.20E+00 3.24E+00 1.08E+01 Released**

2. Average Period uCi/sec 4.14E-01 1.45E-01 4.03E-01 4.08E-01 3.42E-01 Release Rate

"-" denotes less than Minimum Detectable Activity MDA)

• • Calculated value per "Estimation of Carbon-14 in Nuclear Power Plant Gaseous Effluents EPRI Final Report, 12/2010.

25

Table 2.3-A2 MPS3 Gaseous Effluents - Ground Level Release - Batch Mode Release Point -ESF Building Rooftop Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Other Emitters Ci * - * *

• Total Activity Ci * - * *

• B. Iodines / Halogens I-131 Ci * - * *

• I-133 Ci * - * *

• Other Emitters Ci * - * *

• Total Activity Ci * - * *

• C. Particulates Other Emitters Ci * - * *

• Total Activity Ci * - * *

• D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci

• 3.70E-03 *

• 3.70E-03

• No activity released

"-" denotes less than Minimum Detectable Activity (MDA)

"na" denotes Not Required to be Analyzed 26

Table 2.3-A3 MPS3 Gaseous Effluents - Ground Level Release - Continuous Mode Release Point - ESF Building Vent, Auxiliary Boiler Vents, Secondary Side Systems Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Xe-133 Ci - 2.79E-03 - - 2.79E-03 Other Emitters Ci - - - - -

Total Activity Ci - 2.79E-03 - - 2.79E-03 B. Iodines / Halogens I-131 Ci - 9.66E-06 - - 9.66E-06 I-133 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - 9.66E-06 - - 9.66E-06 C. Particulates Be-7 Ci - - - - -

Cr-51 Ci - 5.46E-05 - - 5.46E-05 Mn-54 Ci - 3.22E-06 - - 3.22E-06 Fe-59 Ci - 1.44E-06 - - 1.44E-06 Co-58 Ci - 2.84E-05 - - 2.84E-05 Co-60 Ci - 8.24E-06 - - 8.24E-06 Zn-65 Ci - 1.08E-07 - - 1.08E-07 Zr-95 Ci - 5.23E-06 - - 5.23E-06 Nb-95 Ci - 8.22E-06 - - 8.22E-06 Sn-113 Ci - 1.15E-07 - - 1.15E-07 Sb-125 Ci - 1.06E-07 - - 1.06E-07 Cs-137 Ci - 3.10E-07 - - 3.10E-07 Ba-140 Ci - 1.01E-08 - - 1.01E-08 Other Emitters Ci - - - - -

Total Activity Ci - 1.10E-04 - - 1.10E-04 D. Gross Alpha Gross Alpha Ci - - - - -

E. Tritium H-3 Ci 6.57E-02 5.10E-02 6.45E-02 9.27E-02 2.74E-01

"-" denotes less than Minimum Detectable Activity (MDA) 27

Table 2.3-A4 MPS3 Gaseous Effluents - Elevated Release - Batch Mode Release Point - MPS Stack Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Ar-41 Ci 8.13E-03 1.68E-02 7.21E-03 2.55E-02 5.76E-02 Kr-85 Ci - - - - -

Kr-85m Ci 4.91E-05 4.62E-05 3.10E-05 7.83E-04 9.09E-04 Kr-87 Ci 1.58E-04 2.27E-04 8.97E-05 1.46E-03 1.93E-03 Kr-88 Ci 1.66E-04 - 5.82E-05 4.33E-04 6.57E-04 Xe-133 Ci 1.19E-04 - 2.64E-05 1.24E-02 1.25E-02 Xe-135 Ci 2.19E-04 7.37E-02 1.45E-04 5.88E-03 7.99E-02 Xe-135m Ci 1.35E-04 1.65E-04 2.45E-05 1.20E-03 1.52E-03 Xe-138 Ci 6.36E-04 - - 2.75E-04 9.11E-04 Other Emitters Ci - - - - -

Total Activity Ci 9.61E-03 9.09E-02 7.58E-03 4.79E-02 1.56E-01 B. Iodines / Halogens I-131 Ci - - - - -

I-133 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

C. Particulates Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci 1.48E-01 2.61E-02 1.01E-01 2.24E-01 4.99E-01

"-" denotes less than Minimum Detectable Activity (MDA)

"na" denotes Not Required to be Analyzed 28

Table 2.3-A5 MPS3 Gaseous Effluents - Elevated Release - Continuous Mode Release Point - MPS Stack Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Ar-41 Ci - - - - -

Kr-85 Ci 5.45E-01 1.93E-01 4.69E-01 4.18E-01 1.63E+00 Kr-85m Ci - - - - -

Kr-87 Ci - - - - -

Kr-88 Ci - - - - -

Xe-133 Ci - - - - -

Xe-135 Ci - - - - -

Xe-135m Ci - - - - -

Xe-138 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci 5.45E-01 1.93E-01 4.69E-01 4.18E-01 1.63E+00 B. Iodines / Halogens Br-82 Ci 5.27E-06 1.16E-06 2.29E-06 1.07E-05 1.94E-05 I-131 Ci - 6.79E-08 - - 6.79E-08 Other Emitters Ci - - - - -

Total Activity Ci 5.27E-06 1.23E-06 2.29E-06 1.07E-05 1.95E-05 C. Particulates Mn-54 Ci - 1.76E-07 - - 1.76E-07 Co-57 Ci - 3.96E-09 - - 3.96E-09 Co-58 Ci - 3.26E-06 - - 3.26E-06 Other Emitters Ci - - - - -

Total Activity Ci - 3.44E-06 - 3.44E-06 D. Gross Alpha Gross Alpha Ci - - - - -

E. Tritium H-3 Ci 8.22E-01 2.50E-01 4.16E-01 1.18E+00 2.67E+00 F. C-14 C-14 Ci 1.61E+00 5.69E-01 1.60E+00 1.62E+00 5.40E+00

"- denotes less than Minimum Detectable Activity (MDA) 29

Table 2.3-A6 MPS3 Gaseous Effluents - Mixed Mode Release - Batch Mode Release Point - MPS3 Unit 3 Ventilation Vent Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Ar-41 Ci * - * * -

Kr-85 Ci * - * * -

Kr-85m Ci * - * * -

Kr-87 Ci * - * * -

Kr-88 Ci * - * * -

Xe-133 Ci * - * * -

Xe-135 Ci * - * * -

Xe-135m Ci * - * * -

Xe-138 Ci * - * * -

Other Emitters Ci * - * * -

Total Activity Ci * - * * -

B. Iodines / Halogens Br-82 Ci * - * * -

I-131 Ci * - * * -

I-133 Ci * - * * -

Other Emitters Ci * - * * -

Total Activity Ci * - * * -

C. Particulates Br-82 Ci

• 4.50E-07 *

• 4.50E-07 Other Emitters Ci * - * * -

Total Activity Ci

• 4.50E-07 *

• 4.50E-07 D. Gross Alpha Gross Alpha Ci na na na na na E. Tritium H-3 Ci

• 2.12E-01 *

• 2.12E-01

• No activity released

"-" denotes less than Minimum Detectable Activity (MDA)

"na" denotes Not Required to be Analyzed 30

Table 2.3-A7 MPS3 Gaseous Effluents - Mixed Mode Release - Continuous Mode Release Point - MPS3 Ventilation Vent Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Gases Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Iodines / Halogens Br-82 Ci - - - - -

I-131 Ci - - - - -

I-133 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

C. Particulates Cr-51 Ci - 1.88E-05 - - 1.88E-05 Co-58 Ci - 3.13E-05 - 3.13E-05 Nb-95 Ci - 4.17E-06 - - 4.17E-06 Other Emitters Ci - - - - -

Total Activity Ci - 5.43E-05 - - 5.43E-05 D. Gross Alpha Gross Alpha Ci - - - - -

E. Tritium H-3 Ci 7.62E+00 1.26E+01 8.08E+00 6.39E+00 3.47E+01 F. C-14 C-14 Ci 1.61E+00 5.69E-01 1.60E+00 1.62E+00 5.40E+00

"-" denotes less than Minimum Detectable Activity (MDA) 31

2.2 Liquid Effluents 2.2.1 Measurement of Radioactivity in Liquid Effluents 2.2.1.1 Continuous Liquid Releases Water containing radioactivity is continuously released through one of two pathways - the MPS Quarry or DSN006. DSN006 is next to the MPS3 intake structure (DSN is acronym for Discharge Serial Number.) Grab samples are taken for continuous liquid release pathways and analyzed on the gamma spectrometer and liquid scintillation detector (for H-3) if required by the conditional action requirements of the REMODCM. Total estimated volume is multiplied by the isotopic concentrations (if any) to determine the total activity released.

A proportional aliquot of each discharge is retained for composite analysis for Sr-89, Sr-90, Fe-55 and gross alpha if required by the conditional action requirements of the REMODCM. Sources for continuous liquid effluent releases via the MPS Quarry include Steam Generator Blowdown for MPS2 & MPS3, Service Water Effluent for MPS2 & MPS3 and Reactor Building Closed Cooling Water (RBCCW) Sump for MPS2. Sources for continuous liquid effluent releases via DSN006 include Turbine Building Sump discharge from MPS2 &

MPS3, CPF TK2 from MPS3 and SRW Sump 3 from MPS3.

2.2.1.2 Batch Liquid Releases from Tanks and Sumps Batch liquid releases are made via both the MPS Quarry and DSN006. There are numerous sources from which batches of liquids containing radioactivity are discharged to the environs. Except for two sources from MPS3 to DSN006 they are discharged via the MPS Quarry. The sources are:

MPS1 Radwaste Processing System - Includes sources from:

1. Reactor Building Sumps

2. Underground Ventilation Duct

3. Site Stack Sump MPS2 Radwaste Processing System:

1. Clean Waste Monitor Tanks (2)

2. Aerated Waste Monitor Tanks Other Radwaste Sources:

1. CPF Waste Neutralization Sump

2. Steam Generator Bulk

3. Other Systems Bulk Discharges MPS3 Radwaste Processing

1. Waste Test Tanks (2)

2. Low Level Waste Test Tanks (2)

3. Boron Test Tanks (2)

Other Radwaste Sources:

1. CPF Waste Neutralization Sump

2. Steam Generator Bulk

3. Other systems Bulk Discharges (via Quarry or DSN006)

4. Boron and Waste Test Tanks Berm (via DSN006)

Prior to release, a tank is re-circulated for two equivalent tank volumes, a sample is drawn and then analyzed on the HPGe gamma spectrometer and liquid scintillation detector (H-3) for individual radionuclide composition. Isotopic concentrations are multiplied by the volume released to obtain the total activity released.

For bulk releases, several samples are taken during the discharge to verify the amount of radioactivity released.

A proportional aliquot of each discharge is retained for composite analysis for Sr-89, Sr-90, Fe-55, and gross alpha.

32

2.2.2 Estimate of Errors Estimates of errors associated with radioactivity measurements were made using the following guidelines:

Radioactivity Measurement Calibration 10% Calibration to NIST* standards Sampling/Data Collection 10% - 20% Variation in sample collection Sample Counting 10% - 30% Error for counting statistics Flow & Level Measurements 10% - 20% Error for release volumes

• National Institute of Standards and Technology 2.2.3 Liquid Batch Release Statistics MPS1 MPS2 MPS3 Radwaste Processing System:

Number of Batches 5 6 58 Total Time (min) 215 1282 6560 Maximum Time (min) 53 236 176 Average Time (min) 42 214 111 Minimum Time (min) 35 170 85 MPS1 MPS2 MPS3 Other Radwaste Sources:

Number of Batches NA 5 63 Total Time (min) NA 1136 9749 Maximum Time (min) NA 1698 615 Average Time (min) NA 340 148 Minimum Time (min) NA 5 10 2.2.4 Abnormal Liquid Releases An abnormal release of radioactivity is the discharge of a volume of liquid radioactive material to the environment that was unplanned or uncontrolled. In 2022, the following abnormal liquid releases occurred:

2.2.4.1 MPS1- None 2.2.4.2 MPS2 - None 2.2.4.3 MPS3 On April 16, 2022, totes containing service water were being discharged to DSN006. During the discharge it was determined that one of the totes contained gamma activity and was unsuitable for unrestricted release. The following isotopes included in Table 2.3-L3 are documented below.

H-3 0.00001272Ci (1.272E-05)

Co-60 0.000000023 Ci (2.3E-08)

Sb-125 0.000000031 Ci (3.1E-08)

Cs-137 0.000000051 Ci (5.1E-08)

The whole-body dose offsite from this release was 6.25E-07 mrem and the maximum organ dose was 8.638E-07 mrem. In response to this event peer verification and improved communications have been implemented in the discharge process to prevent reoccurrence.

33

2.2.5 Liquid Release Tables The following tables provide the details of the liquid radioactivity released from each of the MPS units.

Table 2.1-L1 MPS1 Liquid Effluents - Release Summary 2022 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission and Activation Products

1. Total Activity Ci 7.52E-04 - - 3.27E-04 1.08E-03 Released

2. Average Period uCi/ml 3.26E-12 - - 1.22E-12 2.16E-12 Diluted Activity+

B. Tritium

1. Total Activity Ci 8.44E-03 - - 3.36E-04 8.78E-03 Released

2. Average Period uCi/ml 3.65E-11 - - 1.25E-12 1.76E-11 Diluted Activity+

C. Dissolved and Entrained Gases

1. Total Activity Ci - - - - -

Released

2. Average Period uCi/ml - - - - -

Diluted Activity+

D. Gross Alpha

1. Total Activity Ci - - - - -

Released E. Volume

1. Released Waste Liters 9.28E+04 - - 6.81E+04 1.61E+05 Volume

2. Dilution Volume Liters 4.79E+08 - - 4.42E+08 9.21E+08 During Releases

3. Dilution Volume Liters 2.31E+11 - - 2.69E+11 5.00E+11 During Period++

• No activity released

"-" denotes less than Minimum Detectable Activity (MDA)

+ "Total Activity Released" ÷ ("Released Waste Volume" + "Dilution Volume During Period")

++ MPS2 Dilution Volume During Period used because there is no MPS1 dilution They are categorized by type of release, source(s), and by release point of discharge to the environment.

34

Table 2.1-L2 MPS1 Liquid Effluents - Batch Release to Quarry: Liquid Radwaste Processing System Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Products Sr-90 Ci 1.10E-05 - - 1.98E-06 1.30E-05 Cs-137 Ci 7.41E-04 - - 3.25E-04 1.07E-03 Other Emitters Ci - - - - -

Total Activity Ci 7.52E-04 - - 3.27E-04 1.08E-03 B. Tritium H-3 Ci 8.44E-03 - - 3.36E-04 8.78E-03 C. Dissolved & Entrained Gases Kr-85 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci - - - - -

"-" denotes less than Minimum Detectable Activity (MDA) 35

Table 2.2-L1 MPS2 Liquid Effluents - Release Summary 2022 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission and Activation Products

1. Total Activity Ci - - - - -

Released

2. Average Period uCi/ml - - - - -

Diluted Activity

• B. Tritium

1. Total Activity Ci 4.72E+01 1.66E-04 2.61E+01 1.03E+02 1.76E+02 Released

2. Average Period uCi/ml 2.04E-07 7.01E-13 9.24E-08 3.83E-07 1.73E-07 Diluted Activity

• C. Dissolved and Entrained Gases

1. Total Activity Ci - - - - -

Released

2. Average Period uCi/ml - - - - -

Diluted Activity

• D. Gross Alpha

1. Total Activity Ci - - - - -

Released E. Volume

1. Released Waste Volume Primary Liters 2.74E+05 0.00E+00 9.99E+04 1.98E+05 5.72E+05 Secondary Liters 2.28E+06 4.18E+04 1.80E+05 3.97E+05 2.90E+06

2. Dilution Volume During Releases Primary Liters 2.60E+09 0.00E+00 1.22E+09 2.16E+09 5.98E+09 Secondary (DSN006) Liters 4.78E+07 0.00E+00 0.00E+00 3.68E+07 8.46E+07 Secondary (Quarry) Liters 2.40E+10 2.44E+09 4.26E+09 1.74E+09 3.25E+10

3. Dilution Volume During Period Quarry Liters 2.31E+11 2.37E+11 2.83E+11 2.69E+11 1.02E+12 DSN006 Liters 5.23E+07 4.48E+07 4.95E+07 5.76E+07 2.04E+08

• "Total Activity Released" ÷ ("Released Waste Volume" + "Dilution Volume During Period")

"-" denotes less than Minimum Detectable Activity (MDA) 36

Table 2.2-L2 MPS2 Liquid Effluents - Continuous Release to Quarry: Steam Generator Blowdown, Service Water and Reactor Building Closed Cooling Water Release to DSN006: Turbine Building Sumps Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Products Ni-63 Ci - - - - -

Sr-89 Ci - - - - -

Sr-90 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Tritium H-3 Ci 6.52E-03 1.66E-04 8.88E-05 5.12E-03 1.19E-02 C. Dissolved & Entrained Gases Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci - - - - -

"-" denotes less than Minimum Detectable Activity (MDA) 37

Table 2.2-L3 MPS2 Liquid Effluents - Batch Release to Quarry: Liquid Radwaste Processing System, TK-10 Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Products Mn-54 Ci - - - - -

Fe-55 Ci - - - - -

Co-58 Ci - - - - -

Co-60 Ci - - - - -

Ni-63 Ci - - - - -

Sr-89 Ci - - - - -

Sr-90 Ci - - - - -

Nb-97 Ci - - - - -

Ag-110m Ci - - - - -

Sb-125 Ci - - - - -

I-131 Ci - - - - -

Cs-137 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Tritium H-3 Ci 4.72E+01 - 2.61E+01 1.03E+02 1.76E+02 C. Dissolved & Entrained Gases Xe-133 Ci - - - - -

Xe-135 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci - - - - -

"-" denotes less than Minimum Detectable Activity (MDA) 38

Table 2.3-L1 MPS3 Liquid Effluents - Release Summary 2022 Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission and Activation Products

1. Total Activity Ci 1.05E-02 8.01E-04 1.59E-04 - 1.14E-02 Released

2. Average Period uCi/ml 2.66E-11 3.84E-12 3.36E-13 - 7.47E-12 Diluted Activity

• B. Tritium

1. Total Activity Ci 4.51E+02 5.39E+02 2.29E+02 2.95E+02 1.52E+03 Released

2. Average Period uCi/ml 1.15E-06 2.59E-06 4.85E-07 6.48E-07 9.90E-07 Diluted Activity

• C. Dissolved and Entrained Gases

1. Total Activity Ci - - - - -

Released

2. Average Period uCi/ml - - - - -

Diluted Activity

• D. Gross Alpha

1. Total Activity Ci - - - - -

Released E. Volume

1. Released Waste Volume Primary Liters 9.76E+05 1.22E+06 9.21E+05 4.72E+05 3.59E+06 Secondary Liters 1.26E+07 6.17E+06 1.25E+07 1.53E+08 1.85E+08

2. Dilution Volume During Releases Primary Liters 9.76E+05 1.22E+06 9.21E+05 4.72E+05 3.59E+06 Secondary (DSN006) Liters 1.26E+07 6.17E+06 1.25E+07 1.53E+08 1.85E+08 Secondary (Quarry) Liters 6.96E+11 1.30E+11 8.92E+11 8.85E+11 2.60E+12

3. Dilution Volume During Period Quarry Liters 3.93E+11 2.08E+11 4.73E+11 4.56E+11 1.53E+12 DSN006 Liters 5.23E+07 4.48E+07 4.95E+07 5.76E+07 2.04E+08

"-" denotes less than Minimum Detectable Activity (MDA)

• "Total Activity Released" ÷ (Primary "Released Waste Volume" + "Dilution Volume During Period")

39

Table 2.3-L2 MPS3 Liquid Effluents - Continuous Release to Quarry: Steam Generator Blowdown, Service Water, ABD TK-2 Release to DSN006: Turbine Building Sump and SRW Sump 3 Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Products Fe-55 Ci - - - - -

Sr-89 Ci - - - - -

Sr-90 Ci - - - - -

Other Emitters Ci - - - - -

Total Activity Ci - - - - -

B. Tritium H-3 Ci 4.38E+00 3.58E-02 2.98E-01 3.85E-01 5.10E+00 C. Dissolved & Entrained Gases Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci - - - - -

"-" denotes less than Minimum Detectable Activity (MDA) 40

Table 2.3-L3 MPS3 Liquid Effluents - Batch Release to Quarry: Liquid Radwaste Processing System, CPF Waste Neutralization Sumps, Hotwell and Steam Generator Bulk Release to DSN006: Waste Test Tank Berm, CST Surge Tank Leak Nuclides 2022 Released Units 1st Qtr 2nd Qtr 3rd Qtr 4th Qtr Total A. Fission & Activation Products Mn-54 Ci 7.21E-05 1.25E-05 - - 8.46E-05 Fe-55 Ci 5.46E-03 - - - 5.46E-03 Co-58 Ci 1.53E-04 5.78E-04 1.07E-04 - 8.38E-04 Co-60 Ci 1.85E-03 1.10E-04 1.26E-05 - 1.97E-03 Ni-63 Ci 2.34E-03 - - - 2.34E-03 Nb-95 Ci - - - - -

Sb-125 Ci 5.94E-04 8.75E-05 - - 6.82E-04 Cs-137 Ci - 1.33E-05 3.91E-05 - 5.24E-05 Other Emitters Ci - - - - -

Total Activity Ci 1.05E-02 8.01E-04 1.59E-04 - 1.14E-02 B. Tritium H-3 Ci 4.47E+02 5.39E+02 2.29E+02 2.95E+02 1.51E+03 C. Dissolved & Entrained Gases Other Emitters Ci - - - - -

Total Activity Ci - - - - -

D. Gross Alpha Gross Alpha Ci - - - - -

"-" denotes less than Minimum Detectable Activity (MDA) 41

2.3 Solid Waste Solid waste shipment summaries for each unit are given in the following tables:

Table 2.1-S MPS1 Solid Waste and Irradiated Component Shipments Table 2.2-S MPS2 Solid Waste and Irradiated Component Shipments Table 2.3-S MPS3 Solid Waste and Irradiated Component Shipments Number of Shipment from MPS for 2022: 17 Shipments Shipped to Energy Solutions, LLC-Barnwell Processing Facility Barnwell, SC and Bear Creek, Oak Ridge, TN.

The principal radionuclides in these tables were from shipping manifests.

Solidification Agent(s): No solidification on site Containers routinely used for radioactive waste shipment include:

55-gal Steel Drum DOT* 17-H container 7.5 ft3 Steel Boxes 45 ft3 87 ft3 95 ft3 Steel Container 202.1 ft3 Steel "Sea Van" 1280 ft3 Polyethylene High Integrity Containers 120.3 ft3 132.4 ft3 173.4 ft3 202.1 ft3

• United States Department of Transportation 42

Table 2.1-S MPS1 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Resins, Filters, and Evaporator Bottoms Volume Curies Shipped Waste Class ft3 m3 Curies A N/A N/A N/A B N/A N/A N/A C N/A N/A N/A ALL N/A N/A N/A Nuclides for the Above Table:

Radionuclide  % of Total Curies N/A N/A N/A CURIES (TOTAL) N/A 43

Table 2.1-S (continued)

MPS1 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Dry Active Waste Volume Curies Shipped Waste Class ft3 m3 Curies A 8.61E+01 2.44E+00 1.06E-03 B N/A N/A N/A C N/A N/A N/A ALL 8.61E+01 2.44E+00 1.06E-03 Nuclides for the Above Table:

Radionuclide  % of Total Curies H-3 0.43% 4.56E-06 Co-60 0.55% 5.86E-06 Ni-63 0.94% 9.92E-06 Sr-90 0.11% 1.16E-06 Cs-137 97.09% 1.03E-03 Pu-238 < 0.01% 6.39E-08 Pu-239 < 0.01% 4.06E-08 Pu-241 0.07% 7.43E-07 Am-241 0.66% 7.02E-06 Cm-242 0.03% 2.79E-07 Cm-243 0.12% 1.26E-06 CURIES (TOTAL) 1.06E-03 44

Table 2.1-S (continued)

MPS1 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Irradiated Components Volume Curies Shipped Waste Class ft3 m3 Curies A N/A N/A N/A B N/A N/A N/A C N/A N/A N/A ALL N/A N/A N/A Nuclides for the Above Table:

Radionuclide  % of Total Curies N/A N/A N/A CURIES (TOTAL) N/A Other Waste Volume Curies Shipped Waste Class ft3 m3 Curies A N/A N/A N/A B N/A N/A N/A C N/A N/A N/A ALL N/A N/A N/A Nuclides for the Above Table:

Radionuclide  % of Total Curies N/A N/A N/A CURIES (TOTAL) 0.00E+00 45

Table 2.1-S (continued)

MPS1 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Sum of All Low-Level Waste Shipped from Site Volume Curies Shipped Waste Class ft3 m3 Curies A 8.61E+01 2.44E+00 1.06E-03 B N/A N/A N/A C N/A N/A N/A ALL 8.61E+01 2.44E+00 1.06E-03 Nuclides for the Above Table:

Radionuclide  % of Total Curies H-3 0.43% 4.56E-06 Co-60 0.55% 5.86E-06 Ni-63 0.94% 9.92E-06 Sr-90 0.11% 1.16E-06 Cs-137 97.09% 1.03E-03 Pu-238 < 0.01% 6.39E-08 Pu-239 < 0.01% 4.06E-08 Pu-241 0.07% 7.43E-07 Am-241 0.66% 7.02E-06 Cm-242 0.03% 2.79E-07 Cm-243 0.12% 1.26E-06 CURIES (TOTAL) 1.06E-03 46

Table 2.2-S MPS2 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Resins, Filters, and Evaporator Bottoms Volume Curies Shipped Waste Class ft3 m3 Curies A N/A N/A N/A B N/A N/A N/A C N/A N/A N/A ALL N/A N/A N/A Nuclides for the Above Table:

Radionuclide  % of Total Curies N/A N/A N/A CURIES (TOTAL) 0.00E+00 47

Table 2.2-S (continued)

MPS2 Solid Waste and Irradiated Component Shipment January 1, 2022, through December 31, 2022 Dry Active Waste Volume Curies Shipped Waste Class ft3 m3 Curies A 8.31E+03 2.35E+02 8.52E-01 B N/A N/A N/A C N/A N/A N/A ALL 8.31E+03 2.35E+02 8.52E-01 Nuclides for the Above Table:

Radionuclide  % of Total Curies Nb-95 14.71% 1.25E-01 Ag-110m 8.12% 6.92E-02 Zr-95 7.32% 6.24E-02 Ni-63 6.17% 5.26E-02 Fe-55 4.79% 4.08E-02 Co-58 4.69% 4.00E-02 Cs-137 3.78% 3.22E-02 Cr-51 3.20% 2.73E-02 Mn-54 1.58% 1.34E-02 Sb-125 1.38% 1.18E-02 Sn-113 0.24% 2.01E-03 Zn-65 0.17% 1.43E-03 Fe-59 0.13% 1.07E-03 Pu-241 0.08% 7.08E-04 Sb-124 0.03% 2.86E-04 H-3 0.03% 2.43E-04 C-14 0.02% 1.93E-04 Hf-181 0.02% 1.79E-04 Ni-59 0.02% 1.72E-04 CURIES (TOTAL) 8.52E-01 48

Table 2.2-S (continued)

MPS2 Solid Waste and Irradiated Component Shipment January 1, 2022, through December 31, 2022 Irradiated Components Volume Curies Shipped Waste Class ft3 m3 Curies A N/A N/A N/A B N/A N/A N/A C N/A N/A N/A ALL N/A N/A N/A Nuclides for the Above Table:

Radionuclide  % of Total Curies N/A N/A N/A CURIES (TOTAL) 0.00E+00 49

Table 2.2-S (continued)

MPS2 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Other Waste Volume Curies Shipped Waste Class ft3 m3 Curies A 4.64E+02 1.31E+01 1.31E-02 B N/A N/A N/A C N/A N/A N/A ALL 4.64E+02 1.31E+01 1.31E-02 Nuclides for the Above Table:

Radionuclide  % of Total Curies H-3 89.10% 1.17E-02 Nb-95 4.52% 5.94E-04 Zr-95 2.73% 3.58E-04 Co-60 0.93% 1.22E-04 Cr-51 0.82% 1.07E-04 Cs-137 0.40% 5.31E-05 Fe-55 0.33% 4.27E-05 Co-58 0.27% 3.61E-05 Ag-110m 0.20% 2.63E-05 Nb-95m 0.13% 1.73E-05 Ni-63 0.11% 1.51E-05 Mn-54 0.11% 1.49E-05 U (dep) 0.10% 1.37E-05 Sb-125 0.10% 1.32E-05 Tc-99 0.06% 8.4E-06 Fe-59 0.01% 1.78E-06 W-187 0.01% 1.64E-06 Sn-113 0.01% 1.40E-06 CURIES (TOTAL) 1.31E-02 50

Table 2.2-S (continued)

MPS2 Solid Waste and Irradiated Component Shipments January 1, 2022through December 31, 2022 Sum of All Low-Level Waste Shipped from Site Volume Curies Shipped 3 3 Waste Class ft m Curies A 8.77E+03 2.48E+02 8.65E-01 B N/A N/A N/A C N/A N/A N/A ALL 8.77E+03 2.48E+02 8.65E-01 Nuclides for the Above Table:

Radionuclide  % of Total Curies Co-60 42.85% 3.71E-01 Nb-95 14.55% 1.26E-01 Ag-110m 8.00% 6.93E-02 Zr-95 7.25% 6.27E-02 Ni-63 6.08% 5.26E-02 Fe-55 4.72% 4.09E-02 Co-58 4.62% 4.00E-02 Cs-137 3.73% 3.23E-02 Cr-51 3.17% 2.74E-02 Mn-54 1.56% 1.35E-02 H-3 1.38% 1.19E-02 Sb-125 1.36% 1.18E-02 Sn-113 0.23% 2.01E-03 Zn-65 0.17% 1.43E-03 Fe-59 0.12% 1.07E-03 Pu-241 0.08% 7.08E-04 Sb-124 0.03% 2.86E-04 C-14 0.02% 1.93E-04 Hf-181 0.02% 1.79E-04 Ni-59 0.02% 1.72E-04 Co-57 0.01% 6.35E-05 Nb-94 0.01% 5.45E-05 CURIES (TOTAL) 8.65E-01 51

Table 2.3-S MPS3 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Resins, Filters, and Evaporator Volume Curies Shipped Bottoms Waste Class ft3 m3 Curies A 5.56E+02 1.58E+01 5.53E+01 B N/A N/A N/A C 2.68E+01 7.58E-01 6.80E+00 ALL 5.83E+02 1.65E+01 6.21E+01 Nuclides for the Above Table:

Radionuclide  % of Total Curies Ni-63 42.70% 2.65E+01 Fe-55 17.93% 1.11E+01 Co-60 16.31% 1.01E+01 Mn-54 12.05% 7.48E+00 Co-58 5.69% 3.53E+00 H-3 2.32% 1.44E+00 Sb-125 1.28% 7.95E-01 Cs-137 0.66% 4.12E-01 Ni-59 0.33% 2.03E-01 Co-57 0.19% 1.20E-01 C-14 0.18% 1.14E-01 Nb-95 0.14% 8.50E-02 Zr-95 0.06% 3.67E-02 Pu-241 0.04% 2.20E-02 Cs-134 0.03% 1.93E-02 Sn-113 0.03% 1.78E-02 Zn-65 0.02% 1.16E-02 Cr-51 0.01% 7.37E-03 CURIES (TOTAL) 6.21E+01 52

Table 2.3-S (continued)

MPS3 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Dry Active Waste Volume Curies Shipped Waste Class ft3 m3 Curies A 9.83E+03 2.78E+02 7.30E-01 B N/A N/A N/A C N/A N/A N/A ALL 9.83E+03 2.78E+02 7.30E-01 Nuclides for the Above Table:

Radionuclide  % of Total Curies Co-60 32.59% 2.38E-01 Fe-55 25.85% 1.89E-01 Ni-63 12.36% 9.01E-02 Co-58 6.82% 4.98E-02 Nb-95 6.20% 4.52E-02 Cr-51 4.98% 3.64E-02 Zr-95 3.37% 2.45E-02 Mn-54 2.88% 2.10E-02 Cs-137 2.41% 1.76E-02 Sb-125 1.01% 7.35E-03 H-3 0.76% 5.52E-03 Fe-59 0.29% 2.11E-03 Sn-113 0.13% 9.42E-04 Zn-65 0.11% 7.86E-04 Nb-94 0.11% 7.72E-04 Co-57 0.06% 4.50E-04 Nb-95m 0.03% 2.02E-04 Ag-110m 0.02% 1.72E-04 Hf-181 0.01% 7.95E-05 CURIES (TOTAL) 7.30E-01 53

Table 2.3-S (continued)

MPS3 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Irradiated Components Volume Curies Shipped Waste Class ft3 m3 Curies A N/A N/A N/A B N/A N/A N/A C N/A N/A N/A ALL N/A N/A N/A Nuclides for the Above Table:

Radionuclide  % of Total Curies N/A N/A N/A CURIES (TOTAL) 0.00E+00 54

Table 2.3-S (continued)

MPS3 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 21 Other Waste Volume Curies Shipped Waste Class ft3 m3 Curies A 1.68E+02 4.76E+00 4.52E-03 B N/A N/A N/A C N/A N/A N/A ALL 1.68E+02 4.76E+00 4.52E-03 Nuclides for the Above Table:

Radionuclide  % of Total Curies H-3 86.35% 3.91E-03 Nb-95 4.65% 2.10E-04 Zr-95 2.77% 1.25E-04 Co-60 2.28% 1.03E-04 Fe-55 0.81% 3.67E-05 Cr-51 0.80% 3.62E-05 Cs-137 0.56% 2.54E-05 Co-58 0.44% 2.00E-05 Mn-54 0.27% 1.21E-05 Ni-63 0.26% 1.16E-05 Ag-110m 0.24% 1.11E-05 Sb-125 0.16% 7.19E-06 Nb-95m 0.13% 5.78E-06 U (dep) 0.10% 4.58E-06 Tc-99 0.06% 2.80E-06 Zn-65 0.02% 9.96E-07 Co-57 0.02% 9.59E-07 Sn-113 0.02% 8.73E-07 Fe-59 0.02% 7.01E-07 W-187 0.01% 5.45E-07 CURIES (TOTAL) 4.52E-03 55

Table 2.3-S (continued)

MPS3 Solid Waste and Irradiated Component Shipments January 1, 2022, through December 31, 2022 Sum of All Low-Level Waste Shipped from Site Volume Curies Shipped Waste Class ft3 m3 Curies A 1.06E+04 2.99E+02 5.61E+01 B N/A N/A N/A C N/A N/A N/A ALL 1.06E+04 3.00E+02 6.29E+01 Nuclides for the Above Table:

Radionuclide  % of Total Curies Ni-63 42.34% 2.66E+01 Fe-55 18.02% 1.13E+01 Co-60 16.50% 1.04E+01 Mn-54 11.94% 7.50E+00 Co-58 5.70% 3.58E+00 H-3 2.31% 1.45E+00 Sb-125 1.28% 8.03E-01 Cs-137 0.68% 4.30E-01 Ni-59 0.32% 2.03E-01 Nb-95 0.21% 1.30E-01 Co-57 0.19% 1.20E-01 C-14 0.18% 1.14E-01 Zr-95 0.10% 6.14E-02 Cr-51 0.07% 4.38E-02 Pu-241 0.04% 2.20E-02 Cs-134 0.03% 1.93E-02 Sn-113 0.03% 1.88E-02 Zn-65 0.02% 1.24E-02 Fe-59 0.01% 7.08E-03 CURIES (TOTAL) 6.29E+01 56

2.4 Groundwater Monitoring The Groundwater Protection Program (GWPP) at MPS implements the actions cited in the Nuclear Energys Institutes (NEI) Groundwater Protection Initiative, NEI 07-07 (Reference 10). The purpose of the GWPP is to establish a program to assure timely and effective management of situations involving potential releases of radioactive material to ground. A key element in the GWPP is on-site groundwater monitoring. The results of the GWPP are documented in Table 2.4-GW.

Another key element in the GWPP is site hydrological characterization. The general trend of groundwater flow at the station is toward the Long Island Sound. The underdrain system effectively captures groundwater in the area around MPS3 and channels this water via the storm drain system to Long Island Sound On 07/31/2018, during a planned underground pipe inspection of the Unit 3 condensate surge tank, a water leak was identified from one of the return lines to the tank. The leak was near MW-7C and MW-7D wells. The leak was stopped and leaked standing water was captured. Following the event, local and state government stakeholders and the NRC were notified. In fourth quarter of 2022 both MW-7C and MW-7D were less than the minimum detectable activity for tritium and the effectiveness of the leak repair will continue to be monitored.

The level of tritium in the groundwater wells inside the Plant Protected Area does not present an exposure pathway to onsite personnel or members of the public, as there are no drinking water wells onsite. In addition to ground water samples taken within the Protected Area, ground water samples were also taken outside the Protected Area on owner-controlled property. The absence of tritium in wells outside the Protected Area indicates that tritium is confined to the specified locations identified in Table 2.4.

Table 2.4-GW (p. 1 of 2) Well Sample Results H-3 1,2 H-3 1,2 Name Date Name Date (pCi/L) (pCi/L)

MW-7C 3 01/21/2022 2330 MW-7D 01/21/2022 <mda 03/04/2022 2230 03/04/2022 <mda 05/23/2022 2380 05/23/2022 <mda 08/26/2022 3070 08/26/2022 <mda 11/23/2022 <mda 11/23/2022 <mda Notes:

1. There was no gamma radioactivity detected in all samples.

2. MDA is approximately 1,700 pCi/L.

3. Well MW-7D and Well MW-7C are located 2 feet apart near the Unit 3 RWST which is downwind direction from the Unit 3 Ventilation Vent and south of the Unit 3 Condensate Surge Tank. MW-7D is approximately 20 feet deep well, while MW-7C is approximately 60 feet deep. Both wells have been subjected to tritium from atmospheric deposition as well as residual water leakage of the buried condensate piping that was replaced in 2018. The atmospheric deposition is attributed from releases out of the RWST vent and Ventilation Vent.

Gaseous releases from the RWST vent are reported in Table 2.3-A3 and from the Ventilation Vent are reported in Table 2.3-A7. Any releases from RWST Vent or Ventilation Vent that reach the groundwater onsite are captured in sumps and underground vaults, and periodically monitored before release to the environment and reported in Table 2.3-L2. For 2022, low levels of tritium were detected in Well MW-7C. There has been no hydraulic communication with offsite groundwater wells.

57

Table 2.4-GW (p. 2 of 2)

Well Sample Results H-3 1,2 H-3 1,2 Name Date Name Date (pCi/L) (pCi/L) 3 DP-102 03/04/2022 1990 MW-GPI-10 03/11/2022 <mda 06/24/2022 Dry 05/31/2022 <mda 09/20/2022 <mda 08/26/2022 <mda 12/14/2022 6510 11/28/2022 <mda ME-2 09/26/2022 <mda MW-GPI-11 03/04/2022 <mda ME-5 09/26/2022 <mda 05/27/2022 <mda MW-6A 01/21/2022 Dry 08/26/2022 <mda 05/23/2022 <mda 11/23/2022 <mda 07/28/2022 <mda 10/20/2022 <mda MW-6B 01/21/2022 <mda 05/23/2022 <mda 07/28/2022 <mda 10/20/2022 <mda MW-GPI-02 03/11//2022 <mda 05/23/2022 <mda S11-MW-1 06/24/2022 <mda 08/31/2022 <mda S12-MW-1 03/11/2022 <mda 11/28/2022 <mda 06/24/2022 <mda MW-GPI-03 8/31/2022 <mda 09/20/2022 <mda MW-GPI-04 07/22/2022 <mda 12/14/2022 <mda MW-GPI-06 03/04/2022 <mda S12-MW-3 03/11/2022 <mda 06/23/2022 <mda 06/24/2022 <mda 09/20/2022 <mda 09/20/2022 <mda 12/27/2022 <mda 12/14/2022 <mda MW-GPI-08 03/11/2022 <mda T1-MW-3 08/31/2022 <mda 05/31/2022 <mda S13-MW-1 06/23/2022 <mda 08/31/2022 <mda S1-MW-1 08/31/2022 <mda 11/28/2022 <mda S3-MW-2 05/24/2022 <mda MW-GPI-09 03/11/2022 <mda T10-MW-5E 07/28/2022 <mda 05/31/2022 <mda T10-MW-6A 07/22/2022 <mda 08/31/2022 <mda T10-MW-6B 07/22/2022 <mda 11/28/2022 <mda Notes:

1. There was no gamma radioactivity detected in these samples.

2. MDA is approximately 1,760 pCi/L.

3. DP-102 is a shallow groundwater monitoring well located inside the Unit 3 RCA yard, 3 fts. from the base of the Unit 3 RWST, which is also in the downwind direction of the Unit 3 Ventilation Vent. Tritium in this well is related to atmospheric deposition of tritiated water vapor from the MP3 RWST vent and is not indicative of a leak. Gaseous releases from the RWST vent and the Ventilation Vent are reported in Table 2.3-A3 and Table 2.3-A7. Any releases from RWST Vent or Unit 3 Ventilation Vent which reach the groundwater in this area are eventually captured, by design, in the sumps and underground vaults, and periodically monitored before release to the environment, reported in Table 2.3-L2. There has been no hydraulic communication with offsite groundwater.

58

3.0 NONFUNCTIONAL Effluent Monitors During the period January 1, 2022, through December 31, 2022, the following effluent instrumentation were NONFUNCTIONAL for more than 30 consecutive days:

3.1. MPS1 - None 3.2. MPS2-RM-245 The Condensate Polishing Facility Waste Neutralization Sump Effluent Line RM-245 was out of service for greater than 30 days from April 17, 2022, to October 27, 2022. An instrument failure alarm occurred, and it was subsequently determined that the instrument circuit board had failed. The troubleshooting for determining the cause and repairs required for the instrument card delayed restoration to functionality. During the time that the monitor was not available (NON-FUNCTIONAL) there were no Condensate Polishing Facility discharges that contained gamma activity, as determined by two independent sample analyses using a gamma spectrometer.

RM-9116 On September 7, 2022, the Aerated Liquid Radwaste Effluent Line RM-9116 indication failed low, and the radiation monitor was declared NON-FUNCTIONAL. This radiation monitor was retired as part of an engineering design change to replace the Programmable Input Output System (PIOPs).

The design change eliminated RM-9116 and the aerated waste pathway will be shared with Clean and Aerated Liquid Waste Discharge RM-9049. There were no aerated waste discharges in 2022.

RM-9049 and RM-6038 On October 17, 2022, an engineering design change to replace the Programmable Input Output System (PIOPs) removed the Clean Liquid Effluent Line RM-9049 and MPS2 Reactor Building Closed Colling Water RM -6038 from service. The design change retired RM-9116, combined the Clean Liquid Effluent Line and the Aerated Liquid Radwaste Effluent Line pathways through RM-9049, and connected RM 9049 to a General Atomics microprocessor. RM-6038 was impacted by the design change because RM-9049 wired to a shared microprocessor.

Compensatory actions were implemented for RM-6038 required one grab sample every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

During the PIOPs replacement three grab samples a day were analyzed for gamma activity and tritium activity with all results < MDA. The only discharges performed while RM-9049 was out of service were to support the re-test of the system and they were <MDA for gamma activity.

RM-9049 and RM6038 were returned to service and declared FUNCTIONAL on January 10, 2023.

3.3. MPS3 - None 4.0 Operating History The operating history of the MPS Units during this reporting period was as follows:

MPS1 was shut down November 11, 1995, with a cessation of operation declared in July 1998.

MPS2 operated with a capacity factor of 98.2%

MPS3 operated with a capacity factor of 84.6%

The power histograms for 2022 are on the following pages.

59

M P2 - Power History Year of 2022 110

1. 2. 3.

100 90 80 70

<X 60 w

~

0 0..

'i!. 50 40 30 20

1. 01/22/22 - Forced outage for RBCCW leak.

10 2. 05/20/22 - Down power to 93% for turbine valve testing.

3. 09/21/22 - Down power to 93% for turbine valve testing.

0 01/01/22 02/01/22 03/01/22 04/01/22 05/01/22 06/01/22 07/01/22 08/01/22 09/01/22 10/01/22 11/01/22 12/01/22 01/01/~

60

61 5.0 ERRATA No sections from previous years reports were revised.

6.0 REMODCM Changes The description and the bases of the change(s) for REMODCM Revision 31 (effective November 15, 2019 ) are included here in Volume 1 of the Radioactive Effluent Release Report. In addition, a complete copy of the REMODCM revision 32 (approved August 29, 2022) is provided to the Nuclear Regulatory Commission as Volume 2 of the Radioactive Effluent Release Report.

6.1 Summary of Changes Programmatic and technical changes include:

Table l.E.-1 "Millstone Radiological Environmental Monitoring Program" Added milk sampling requirements and its sampling alternative for when milk sampling becomes available as specified in NUREG 1301-Table 3.12-1. (p.38)

"Unit 1 Spent Fuel Pool Island Monitor - RM-SFPI-02" A "Note" in this section was removed as it is not applicable in the new revision, Rev.02, of MPS 1 EAL Table. The note used to indicate the interdependency between the MPS l EAL table and the REMODCM related to the RM-SFPI-02 alarm setpoint. (p.76)

EC# MP2-19-01091 will change the clean waste water effluent line and aerated waste effluent line will be plumbed to discharge through radiation monitor Unit 2 Clean and Aerated Waste Discharge - RM9049, thus eliminating existing RM-9116. (p.2)

The word "valve" was a spelling error as the word should be "value". (p.67)

EC# MP2-19-01091 will change the clean waste water effluent line and aerated waste effluent line will be plumbed to discharge through radiation monitor Unit 2 Clean and Aerated Waste Discharge - RM9049, thus eliminating existing RM-9116. (p.65,68)

Updated Table IV.C.-1 with the new noun name for RM-9049 "Clean and Aerated Liquid Discharge RM is support of design change EC# MP2-19-01091. (p.104)

Added "Effluent Line" to Table IV.C.-1 3. (C) Condensate Polishing Facility. (p.104)

Eliminated the surveillance requirements for RM-9116 to support design change EC# MP2-19-01091. (p.106)

Removed RM-9116 from the diagram and aligned the Aerated Waste effluent line through RM-9049. (p. 21) 62

7.0 References

1. NUREG-0597, User Guide to GASPAR Code, KF Eckerman, FJ Congel, AK Roecklien, WJ Pasciak, Division of Site Safety and Environmental Analysis, Office of Nuclear Reactor Regulation, US Nuclear Regulatory Commission, Washington, DC 20555, manuscript completed January 1980, published June 1980.

2. EPRI Report 1021106, Estimation of Carbon-14 in Nuclear Power Plants Gaseous Effluents, December 2010.

3. NRC 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.

4. UNSCEAR 2000 Report Vol. I, Sources and Effects of Ionizing Radiation, United Nations Scientific Committee on the Effects of Atomic Radiation

5. NRC 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.

6. NUREG/CR-1276, ORNL/NUREG/TDMC-1, User's Manual for LADTAP II - A Computer Program for Calculating Radiation Exposure to Man from Routine Release of Nuclear Reactor Liquid Effluents, DB Simpson, BL McGill, prepared by Oak Ridge National Laboratory, Oak Ridge, TN 37830, for Office of Administration, US Nuclear Regulatory Commission, manuscript completed 17 March 1980.

7. 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Reasonably Achievable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents.

8. 40 CFR Part 190, Environmental Radiation Protection Standard for Nuclear Power Operation.

9. OpenEMS Software Version 1.1.0.SP5 Build DOM/MLS Upd 68.

10. NEI 07-07, Nuclear Energy Institute, Industry Ground Water Protection Initiative - Final Guidance Document, Revision 1 March 2019.

11. NRC Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste, Revision 2, October 2008.

12. EPRI Report 1024827, Carbon-14 Dose Calculation Methods at Nuclear Power Plants, April 2012.

13. NUREG/CR-2907, Vol. 15, Radioactive Effluents from Nuclear Power Plants Annual Report 2009, R. Conatser, US Nuclear Regulatory Commission and N. Daugherty, Oak Ridge Associated Universities, Aug. 2013.

14. Radiation Protection Calculation #16-18, Isotopic Cloud Shine Doses for MPS Releases, Jan. 24, 2017.

15. MP-CHEM-17-07, Reporting of Radioactivity Released from RWST Vents, May 26, 2016.

16. RER-20-01, Unit 3 Outage Discharges with Minimal Dilution Flow, October 17, 2020.

63

Serial No.23-117 Docket Nos. 50-245 50-336 50-423 License Nos. DPR-21 DPR-65 NPF-49 ATTACHMENT 2 2022 RADIOACTIVE EFFLUENT RELEASE REPORT VOLUME 2 MILLSTONE POWER STATION UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)

MILLSTONE POWER STATION STATION PROCEDURE STOP THINK ACT REVIEW Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)

MP---22---REC---BAP01 Rev. 032 Approval Date: 08/29/2022 Effective Date: 01/10/2023

Millstone All Units Station Procedure Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)

TABLE OF CONTENTS I. Radiological Effluent Monitoring Manual (REMM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I.B. Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I.C. Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1. Liquid Effluent Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . 7

2. Liquid Radioactive Waste Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 I.D. Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

1. Gaseous Effluent Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . 23

2. Gaseous Radioactive Waste Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 I.E. Radiological Environmental Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

1. Sampling and Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

2. Land Use Census . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3. Interlaboratory Comparison Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 I.F. Report Content . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

1. Annual Radiological Environmental Operating Report . . . . . . . . . . . . . . . 48

2. Radioactive Effluent Release Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 II Off---Site Dose Calculation Manual (ODCM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 II.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 II.B. Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 II.C. Liquid Dose Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

1. Monthly, Quarterly, and Annual Dose Calculation (Applicable to All Units) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

2. Monthly Dose Projections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 II.D. Gaseous Dose Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

1. Site Release Rate Limits (Instantaneous) . . . . . . . . . . . . . . . . . . . . . . . . 56

2. 10 CFR50 Appendix I --- Noble Gas Limits . . . . . . . . . . . . . . . . . . . . . . . . . 58

3. 10 CFR50 Appendix I --- Iodine, Tritium and Particulate Doses . . . . . . . . 59

4. Gaseous Effluent Monthly Dose Projections . . . . . . . . . . . . . . . . . . . . . . . . 60

5. Compliance with 40CFR190 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 II.E. Liquid Discharge Flow Rates And Monitor Setpoints . . . . . . . . . . . . . . . . . . . . . 63

1. Unit 1 Liquid Waste Effluent Discharge (RE---M6---110) . . . . . . . . . . . . . 63 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 1 of 135

2. Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

3. Unit 2 --- Clean and Aerated Liquid Waste Discharge --- RM9049 . . . . . 64

4. Condensate Polishing Facility Waste Neutralization Sump Effluent Line --- CND245 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

5. Unit 2 Steam Generator Blowdown --- RM4262 and Unit 2 Steam Generator Blowdown Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . 67

6. Unit 2 Condenser Air Ejector --- RM5099 . . . . . . . . . . . . . . . . . . . . . . . . . . 67

7. Unit 2 Reactor Building Closed Cooling Water RM6038 and Unit 2 Service Water, and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

8. Unit 3 Liquid Waste Monitor --- LWS---RE70 . . . . . . . . . . . . . . . . . . . . . . . 69

9. Unit 3 Regenerant Evaporator Effluent Line --- LWC---RE65 . . . . . . . . . 71

10. Unit 3 Waste Neutralization Sump Effluent Line --- CND---RE07 . . . . . . 71

11. Unit 3 Steam Generator Blowdown --- SSR---RE08 and Unit 3 Steam Generator Blowdown Effluent Concentration Limitation . . . . . . . . . . . . . 71

12. Unit 3 Turbine Building Floor Drains Effluent Line --- DAS---RE50 and Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73 II.F. Gaseous Monitor Setpoints . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

1. Unit 1 Spent Fuel Pool Island Monitor --- RM---SFPI---02 . . . . . . . . . . . . . 74

2. Unit 2 Wide Range Gas Monitor (WRGM) --- RM8169 . . . . . . . . . . . . . . 74

3. Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74

4. Unit 3 SLCRS --- HVR---RE19B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

5. Unit 2 Vent --- Noble Gas Monitor --- RM8132B . . . . . . . . . . . . . . . . . . . . 75

6. Unit 2 Waste Gas Decay Tank Monitor RM9095 . . . . . . . . . . . . . . . . . . . . 75

7. Unit 3 Vent Noble Gas Monitor --- HVR---RE10B . . . . . . . . . . . . . . . . . . . 76

8. Unit 3 Engineering Safeguards Building Monitor --- HVQ---RE49 . . . . . . 76 III REMODCM Unit One Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 III.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 III.B. Definitions and Surveillance Requirement (SR) Applicability . . . . . . . . . . . . . . 80 III.C. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . . 83

1. Radioactive Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . . 83

2. Radioactive Gaseous Effluent Monitoring Instrumentation . . . . . . . . . . . 86 III.D. Radioactive Effluents Concentrations And Dose Limitations . . . . . . . . . . . . . . . 89

1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89

2. Radioactive Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 III.E. Total Radiological Dose From Station Operations Controls . . . . . . . . . . . . . . . . 95 IV REMODCM Unit Two Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 IV.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 IV.B. Definitions, Applicability and Surveillance Requirements . . . . . . . . . . . . . . . . . 97 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 2 of 135

IV.C. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . 101

1. Radioactive Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . 101

2. Radioactive Gaseous Effluent Monitoring Instrumentation . . . . . . . . . . 105 IV.D. Radioactive Effluents Concentrations And Dose Limitations . . . . . . . . . . . . . . 109

1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

2. Radioactive Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 IV.E. Total Radiological Dose From Station Operation . . . . . . . . . . . . . . . . . . . . . . . 115 V REMODCM Unit Three Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117 V.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117 V.B. Definitions and Applicability and Surveillance Requirements . . . . . . . . . . . . . 117 V.C. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . 120

1. Radioactive Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . 120

2. Radioactive Gaseous Effluent Monitoring Instrumentation . . . . . . . . . . 124 V.D. Radioactive Effluents Concentrations And Dose Limitations . . . . . . . . . . . . . . 129

1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129

2. Radioactive Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131 V.E. Total Radiological Dose From Station Operations . . . . . . . . . . . . . . . . . . . . . . . 135 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 3 of 135

TABLES AND FIGURES TABLES Table I.C.---1, Millstone Unit 1 Radioactive Liquid Waste Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Table I.C.---2, Millstone Unit 2 Radioactive Liquid Waste Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Table I.C.---3, Millstone Unit 3 Radioactive Liquid Waste Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Table I.D.---1, Millstone Unit 1 Radioactive Gaseous Waste Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Table I.D.---2, Millstone Unit 2 Radioactive Gaseous Waste Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Table I.D.---3, Millstone Unit 3 Radioactive Gaseous Waste Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Table I.E.---1, Millstone Radiological Environmental Monitoring Program . . . 38 Table I.E.---2, Environmental Monitoring Program Sampling Locations . . . . . . 40 Table I.E.---3, Reporting Levels For Radioactivity Concentrations In Environmental Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Table I.E.---4, Maximum Values For Lower Limits Of Detection (LLD) . . . . . . . 45 Table App. II.A.---1, Millstone Effluent Requirements and Methodology Cross Reference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Table III.C.---1, Radioactive Liquid Effluent Monitoring Instrumentation . . . . 84 Table III.C.---2, Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 Table III.C.---3, Radioactive Gaseous Effluent Monitoring Instrumentation . . 87 Table III.C.---4, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 Table IV.C.---1, Radioactive Liquid Effluent Monitoring Instrumentation . . . 102 Table IV.C.---2, Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104 Table IV.C.---3, Radioactive Gaseous Effluent Instrumentation . . . . . . . . . . . 106 Table IV.C.---4, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 Table V.C.---1, Radioactive Liquid Effluent Monitoring Instrumentation . . . . 121 Table V.C.---2, Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123 Table V.C.---3, Radioactive Gaseous Effluent Monitoring Instrumentation . . 125 Table V.C.---4, Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 4 of 135

FIGURES Figure I.C.---1, Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Figure I.C.---2, Simplified Liquid Effluent Flow Diagram Millstone Unit 2 . . . . 21 Figure I.C.---3, Simplified Liquid Effluent Flow Diagram Millstone Unit 3 . . . . 22 Figure I.D.---1, Simplified Gaseous Effluent Flow Diagram Millstone Unit One . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Figure I.D.---2, Simplified Gaseous Effluent Flow Diagram Millstone Unit Two . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Figure I.D.---3, Simplified Gaseous Effluent Flow Diagram Millstone Unit Three . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Figure I.E.---1, Inner TLD, Air, Grass, Soil, and Aquatic Locations . . . . . . . . . 42 Figure I.E.---2, Outer TLD and Aquatic Locations . . . . . . . . . . . . . . . . . . . . . . . . 43 Figure III.D.---1, Site Boundary for Liquid and Gaseous Effluents . . . . . . . . . . 94 Figure IV.D.---1, Site Boundary for Liquid and Gaseous Effluents . . . . . . . . . . 114 Figure V.D.---1, Site Boundary for Liquid and Gaseous Effluents . . . . . . . . . . 134 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 5 of 135

SECTION I.

Radiological Effluent Monitoring Manual (REMM)

For the Millstone Nuclear Power Station Nos. 1, 2, & 3 Docket Nos. 50---245, 50---336, 50---423 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 6 of 135

SECTION I. RADIOLOGICAL EFFLUENT MONITORING MANUAL (REMM)

I.A. Introduction The purpose of Section I of this manual is to provide the sampling and analysis programs which provide input to Section II for calculating liquid and gaseous effluent concentrations and offsite doses. Guidelines are provided for operating radioactive waste treatment systems in order that offsite doses are kept As---Low---As---Reasonably---Achievable (ALARA).

The Radiological Environmental Monitoring Program outlined within this manual provides confirmation that the measurable concentrations of radioactive material in the environment as a result of operations at the Millstone Site are not higher than expected.

In addition, this manual outlines the information required to be submitted to the NRC in both the Annual Radiological Environmental Operating Report and the Radioactive Effluent Release Report.

MP---22---REC---REF03, REMODCM Technical Information Document (TID), has additional bases and technical information. It also contains a list of exceptions to Regulatory Guide 1.21 (see Section 2 of the TID).

I.B. Responsibilities All changes to the Radiological Effluent Monitoring Manual (REMM) shall be reviewed and approved by the Facility Safety Review Committee prior to implementation.

All changes and their rationale shall be documented in the Radioactive Effluent Release Report.

It shall be the responsibility of the Site Vice President Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications. The delegation of implementation responsibilities is delineated in MP---22---REC---PRG, Radiological Effluent Program.

I.C. Liquid Effluents

1. Liquid Effluent Sampling and Analysis Program Radioactive liquid wastes shall be sampled and analyzed in accordance with the program specified in Table I.C.---1 for Millstone Unit No. 1, Table I.C.---2 for Millstone Unit No. 2, and Table I.C.---3 for Millstone Unit No. 3. The results of the radioactive analyses shall be input to the methodology of Section II to assure that the concentrations at the point of release are maintained within the limits of Radiological Effluent Controls (Section III.D.1.a. for Millstone Unit No. 1,Section IV.D.1.a. for Millstone Unit No.

2, and Section V.D.1.a. for Millstone Unit No. 3).

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 7 of 135

Table I.C.---1 Millstone Unit 1 Radioactive Liquid Waste Sampling and Analysis Program Liquid Release Sample Type and Minimum Analysis Type of Lower Limit Source Frequency Frequency Radioactivity of Detection Analysis (LLD)A (mCi/ml)

Any Batch Grab sample prior to Prior to each batch Principal Gamma 5 x 10 ---7 Release from any each batch releaseB release Emitters source Kr---85 1 x 10 ---5 H---3 1 x 10 ---5 Grab sample prior to Prior to initial batch re- Gross alpha 1 x 10 ---7 initial batch release lease from each source.

from any one source Quarterly for each Sr---90 5 x 10 ---8 and quarterly compos- source.D ite thereafterC Fe---55 1 x 10 ---6 Table I.C.---1 TABLE NOTATIONS A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a real signal.

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

4.66 S b LLD =

(E)(V)(2.22x10 6)(Ye t)

Where:

S LLD is the lower limit of detection as defined above (as mCi per unit mass or volume)

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

S E is the counting efficiency (as counts per transformation)

S V is the sample size (in units of mass or volume)

S 2.22 x 106 is the number of transformations per minute per mCi S Y is the fractional radiochemical yield (when applicable)

S is the radioactive decay constant for the particular radionuclide S t is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 8 of 135

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and recorded on the analysis sheet for the particular sample.

B. Prior to the sampling, each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided.

C. A composite sample is one in which the quantity of liquid sampled 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. Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.

D. For sources with no release during previous quarter, a quarterly sample is not required.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 9 of 135

Table I.C.---2 Millstone Unit 2 Radioactive Liquid Waste Sampling and Analysis Program Liquid Release Sample Type and Minimum Analysis Type of Lower Limit Source Frequency Frequency Radioactivity of Detection Analysis (LLD)A (mCi/ml)

A.Batch ReleaseB.

1.Clean Waste Moni- Grab sample prior to Prior to each batch Principal Gamma 5 x 10 ---7 tor Tank. each batch release release EmittersC.

2.Aerated Waste I---131 1 x 10 ---6 Monitor Tank.

3.Steam Generator Ce---144 5 x 10 ---6 BulkD. Dissolved & 1 x 10 ---5 Entrained GasesK.

4.Condensate H---3 1 x 10 ---5 Polishing Facility

--- Waste Quarterly Gross alpha 1 x 10 ---7 Neutralization CompositeF.,G.

Sr---89, Sr---90 5 x 10 ---8 SumpE.

Fe---55 1 x 10 ---6 B.Continuous Release 1.Steam Generator Daily Grab SampleI.& Weekly Principal Gamma 5 x 10 ---7 BlowdownH. prior to aligning to CompositeF.,G. EmittersC.

Long Island Sound for 2.Service Water RBCCW sump I---131 1 x 10 ---6 EffluentJ.

Ce---144 5 x 10 ---6 3.Turbine SumpsL. Monthly Grab Monthly Dissolved & 1 x 10 ---5 Sample Entrained GasesK.

4.RBCCW SumpM. Weekly Grab or Com- Monthly H---3N. 1 x 10 ---5 posite CompositeF.,G.

Weekly Composite Quarterly Gross alpha 1 x 10 ---7 CompositeF.,G.

Sr---89, Sr---90 5 x 10 ---8 Fe---55 1 x 10 ---6 TABLE I.C.---2 TABLE NOTATIONS A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a real signal.

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

4.66 S b LLD =

(E)(V)(2.22x10 6)(Ye t)

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 10 of 135

Where:

S LLD is the lower limit of detection as defined above (as mCi per unit mass or volume)

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

S E is the counting efficiency (as counts per transformation)

S V is the sample size (in units of mass or volume)

S 2.22 x 106 is the number of transformations per minute per mCi S Y is the fractional radiochemical yield (when applicable)

S is the radioactive decay constant for the particular radionuclide S t is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and recorded on the analysis sheet for the particular sample.

B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed in this table. Prior to the sampling, each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided. If the steam generator bulk can not be recirculated prior to batch discharge, a sample will be obtained by representative compositing during discharge.

C. The LLD will be 5 x 10 --- 7 mCi/ml. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn---54, Fe---59, Co---58, Co---60, Zn---65, Mo---99, Cs---134, Cs---137, and Ce---141. Ce---144 shall also be measured, but with an LLD of 5 x 10 --- 6 mCi/ml. This list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

D. For the Steam Generator Bulk:

IF the applicable batch gamma radioactivity is not greater than 5 x 10 --- 7 mCi/ml, THEN the sampling and analysis schedule for gross alpha, Sr---89, Sr---90, Fe---55 are not required.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 11 of 135

E. For the Condensate Polishing Facility (CPF) waste neutralization sump:

IF there is no detectable tritium in the steam generators, THEN tritium sampling and analyses is not required.

IF the gross gamma radioactivity in the grab sample taken prior to release does not exceed 5 x 10 --- 7 mCi/ml, THEN the sampling and analysis schedule for gross alpha, Sr---89, Sr---90 and Fe---55 are not required.

F. For Batch Releases and Steam Generator Blowdown only, a composite sample is one in which the quantity of liquid sampled 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.

G. Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.

H. For the Steam Generator Blowdown:

IF the steam generator gross gamma radioactivity does not exceed 5 x 10 --- 7 mCi/ml, THEN the sampling and analysis schedule for all principal gamma, I---131, Ce---144, noble gases, gross alpha, Sr---89, Sr---90 and Fe---55 are not required. For the purposes of this footnote, if steam generator samples are not available, condensate water gamma radioactivity may be used during times of blowdown.

I. Daily grab samples shall be taken at least five days per week. For service water, daily grabs shall include each train that is in---service. For steam generator blowdown, condensate may be sampled during blowdown if steam generator sample is not available.

J. For the Service Water:

IF a weekly gamma analysis does not indicate a gamma radioactivity greater than 5 x10 --- 7 mCi/ml, THEN the sampling and analysis schedule for gross alpha, Sr---89, Sr---90, Fe---55 are not required.

K. LLD applies exclusively to the following radionuclides: Kr---87, Kr---88, Xe---133, Xe---133m, Xe---135, and Xe---138. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

L. For the Turbine Building Sump:

IF there is no detectable tritium in the secondary side before an outage, THEN tritium sampling and analyses is not required during an outage.

IF the steam generator gross gamma radioactivity does not exceed 5 x 10 --- 7 mCi/ml, OR sump is directed to radwaste treatment, THEN the sampling and analysis schedule for all principal gamma, I---131, Ce---144, noble gases, gross alpha, Sr---89, Sr---90 and Fe---55 are not required.

IF the release pathway is directed to yard drains, THEN the LLD for I---131 shall be 1.5 x 10 --- 7 mCi/ml and for gross alpha 1 x 10 --- 8 mCi/ml.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 12 of 135

M. For the RBCCW Sump:

IF the RBCCW Sump is directed to radwaste treatment or is not aligned to Long Island Sound, THEN sampling is not required.

IF the applicable batch gamma radioactivity is not greater than 5 x 10 --- 7 mCi/ml, THEN sampling and analysis schedule for gross alpha, Sr---89, Sr---90, Fe---55 are not required.

N. Detectable tritium shall be used to estimate tritium releases to the atmosphere via the blowdown tank vent.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 13 of 135

Table I.C.---3 Millstone Unit 3 Radioactive Liquid Waste Sampling and Analysis Program Liquid Release Sample Type and Minimum Analysis Type of Lower Limit Source Frequency Frequency Radioactivity of Detection Analysis (LLD)A (mCi/ml)

A.Batch ReleaseB.

1.Condensate Polish- Grab sample prior Prior to each batch Principal Gamma 5 x 10 ---7 ing Facility Waste to each batch release release EmittersC.

Neutralization SumpE. I---131 1 x 10 ---6 2.Waste Test Tanks Ce---144 5 x 10 ---6 3.Low Level Waste Dissolved & 1 x 10 ---5 Tank Entrained GasesK.

4.Boron Test Tanks H---3 1 x 10 ---5 5.Steam Generator Bulk D. Quarterly Gross alpha 1 x 10 ---7 CompositeF.,G.

Sr---89, Sr---90 5 x 10 ---8 Fe---55 1 x 10 ---6 B.Continuous Release 1.Steam Generator Daily Grab SampleI. Weekly Principal Gamma 5 x 10 ---7 BlowdownH. CompositeF.,G. EmittersC.

2.Service Water Ef- I---131 1 x 10 ---6 fluentJ.

Ce---144 5 x 10 ---6 3.Turbine Building Monthly Grab Monthly Dissolved & 1 x 10 ---5 SumpsL. Sample Entrained GasesK.

Weekly Grab or Com- Monthly H---3M. 1 x 10 ---5 posite CompositeF.,G.

Weekly Composite Quarterly Gross alpha 1 x 10 ---7 CompositeF.,G.

Sr---89, Sr---90 5 x 10 ---8 Fe---55 1 x 10 ---6 TABLE I.C.---3 TABLE NOTATIONS A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a real signal.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 14 of 135

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

4.66 S b LLD =

(E)(V)(2.22x10 6)(Ye t)

Where:

S LLD is the lower limit of detection as defined above (as mCi per unit mass or volume)

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

S E is the counting efficiency (as counts per transformation)

S V is the sample size (in units of mass or volume)

S 2.22 x 106 is the number of transformations per minute per mCi S Y is the fractional radiochemical yield (when applicable)

S is the radioactive decay constant for the particular radionuclide S t is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and recorded on the analysis sheet for the particular sample.

B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed in this table. Prior to the sampling, each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided. If the steam generator bulk can not be recirculated prior to batch discharge, a sample will be obtained by representative compositing during discharge.

C. The LLD will be 5 x 10 --- 7 mCi/ml. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn---54, Fe---59, Co---58, Co---60, Zn---65, Mo---99, Cs---134, Cs---137, and Ce---141. Ce---144 shall also be measured, but with an LLD of 5 x 10 --- 6 mCi/ml. This list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

D. For the Steam Generator Bulk:

IF the applicable batch gamma radioactivity is not greater than 5 x 10 --- 7 mCi/ml, THEN the sampling and analysis schedule for gross alpha, Sr---89, Sr---90, Fe---55 are not required.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 15 of 135

E. For the Condensate Polishing Facility (CPF) waste neutralization sump:

IF there is no detectable tritium in the steam generators, THEN tritium sampling and analyses is not required.

IF the gross gamma radioactivity in the grab sample taken prior to release does not exceed 5 x 10 --- 7 mCi/ml, THEN the sampling and analysis schedule for gross alpha, Sr---89, Sr---90 and Fe---55 are not required.

F. For Batch Releases and Steam Generator Blowdown only, a composite sample is one in which the quantity of liquid sampled 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.

G. Prior to analysis, all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.

H. For the Steam Generator Blowdown:

IF the steam generator gross gamma radioactivity does not exceed 5 x 10 --- 7 mCi/ml, THEN the sampling and analysis schedule for all principal gamma, I---131, Ce---144, noble gases, gross alpha, Sr---89, Sr---90 and Fe---55 are not required.

Steam Generator Blowdown samples are not required when blowdown is being recovered.

I. Daily grab samples shall be taken at least five days per week. For service water, daily grabs shall include each train that is in---service.

J. For the Service Water:

IF a weekly gamma analysis does not indicate a gamma radioactivity greater than 5 x10 --- 7 mCi/ml, THEN the sampling and analysis schedule for gross alpha, Sr---89, Sr---90, Fe---55 are not required.

K. LLD applies exclusively to the following radionuclides: Kr---87, Kr---88, Xe---133, Xe---133m, Xe---135, and Xe---138. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

L. For the Turbine Building Sump:

IF the steam generator gross gamma radioactivity does not exceed 5 x 10 --- 7 mCi/ml, OR sump is directed to radwaste treatment, THEN the sampling and analysis schedule for all principal gamma, I---131, Ce---144, noble gases, gross alpha, Sr---89, Sr---90 and Fe---55 are not required.

IF the release pathway is directed to yard drains, THEN the LLD for I---131 shall be 1.5 x 10 --- 7 mCi/ml and for gross alpha 1 x 10 --- 8 mCi/ml.

M. Detectable tritium shall be used to estimate tritium releases to the atmosphere via the blowdown tank vent.

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2. Liquid Radioactive Waste Treatment

a. Dose Criteria for Equipment Functionality Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit.

1) IF the radioactivity concentration criteria for the Unit 3 steam generator blowdown is exceeded with blowdown recovery not available to maintain releases to as low as reasonably achievable; or, IF any of the other radioactive waste processing equipment listed in Section b. are not functional, THEN doses due to liquid effluents from the applicable waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.C.2.

2) IF any of these dose projections exceeds 0.006 mrem to the total body or 0.02 mrem to any organ, THEN best efforts shall be made to return the processing equipment to service, or to limit discharges via the applicable waste stream.

3) IF an actual dose due to liquid effluents exceeds 0.06 mrem to the total body or 0.2 mrem to any organ AND the dose from the waste stream with processing equipment not functional exceeds 10% of one of these limits, THEN prepare and submit to the Commission a Special Report within 30 days as specified in Section 2.c.

b. Required Equipment for Each Millstone Unit Best efforts shall be made to return the applicable liquid radioactive waste treatment system equipment specified below for each unit to service or to limit discharge via the applicable waste stream if the projected doses exceed any of the doses specified above.

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1. Millstone Unit No. 1 Waste Stream Processing Equipment Spent Fuel Pool water One filter and one demineralizer

2. Millstone Unit No. 2 Waste Stream Processing Equipment Clean liquid Deborating ion exchanger (T11) OR Purification ion exchanger (T10A or T10B) OR Equivalent ion exchanger Primary demineralizer (T22 A or B) OR Equivalent demineralizer ALPS/AIM processing OR Secondary demineralizer (T23 A or B) OR Equivalent demineralizer Aerated liquid ALPS/AIM processing OR Demineralizer (T24) OR Equivalent demineralizer

3. Millstone Unit No. 3 Waste Stream Processing Equipment or Radioactivity Concentration High level ALPS processing (3LWS---SKD1) OR Demineralizer (3LWS---DEMN2) and Demineralizer filter (3LWS---FLT3) OR Demineralizer (LWS---DEMN1) and Demineralizer filter (LWS---FLT1)

Boron recovery Cesium ion exchanger (3BRS---DEMN1A or B)

Boron evaporator (3BRS---EV1)

Low level High level processing equipment Steam generator Blowdown recovery when total gamma radioactivity exceeds 5E---7 blowdown mCi/ml or tritium exceeds 0.02 mCi/ml.

NOTE: The qualifier OR indicates that any of the equipment listed within the block would satisfy the processing requirement if functional.

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c. Report Requirement For All Three Millstone Units If required by Section 2.a.3), prepare and submit to the Commission a Special Report within 30 days with the following content:

S Explanation of why liquid radwaste was being discharged without treatment, identification of any equipment not in service, and the reason for the equipment being out of service, S Action(s) taken to restore the equipment to service, and S Summary description of action(s) taken to prevent a recurrence.

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Figure I.C.---1, Reserved MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 20 of 135

Figure I.C.---2, Simplified Liquid Effluent Flow Diagram Millstone Unit 2 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 21 of 135

Figure I.C.---3, Simplified Liquid Effluent Flow Diagram Millstone Unit 3 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 22 of 135

I.D. Gaseous Effluents

1. Gaseous Effluent Sampling and Analysis Program Radioactive gaseous wastes shall be sampled and analyzed in accordance with the program specified in Table I.D.---1 for Millstone Unit No. 1, Table I.D.---2 for Millstone Unit No. 2, and Table I.D.---3 for Millstone Unit No. 3.

The results of the radioactive analyses shall be input to the methodology of Section II to assure that offsite doses are maintained within the limits of Radiological Effluent Controls (Section III.D.2. for Millstone Unit No. 1,Section IV.D.2. for Millstone Unit No. 2, and Section V.D.2. for Millstone Unit No. 3).

Table I.D.---1 Millstone Unit 1 Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sample Type and Minimum Type of Radioactivity Lower Limit Point or Source FrequencyB Analysis Analysis of Detection Frequency (LLD)A (mCi/ml)

A.Spent Fuel Pool MonthlyD,F --- Gaseous Monthly Kr---85 1 x 10 ---4 Island Vent Grab Sample H---3G 1 x 10 --- 6 Twice per month Principal Gamma 1 x 10 ---11 ContinuousE. EmittersC. --- (with half Particulate Sample lives greater than 8 days)

ContinuousE. Quarterly Sr---90, Gross alpha 1 x 10 ---11 Particulate Sample Composite ContinuousE. Continuous Kr---85 1 x 10 ---6 Noble Gas Monitor B.Balance of Twice per month Principal Gamma 1 x 10 --- 11 Plant Vent EmittersC. --- (with half ContinuousE. lives greater than 8 days)

Particulate Sample Quarterly Sr---90, Gross alpha 1 x 10 --- 11 Composite Grab sample of Reactor Prior to processing H---3 1 x 10 --- 5 Bldg evaporator staging of each batch tank prior to processing Table I.D.---1 TABLE NOTATIONS A. The lower limit of detection (LLD) is defined in Table Notations, Item a, of Tables I.C.---1, I.C.---2, or I.C.---3.

B. Samples not required when Release Point is not in use.

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C. For particulate samples, the LLD will be 1 x 10 --- 11 mCi/cc. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides: Mn---54, Co---60, Zn---65, Cs---134, Cs---137, and Ce---144. The list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

D. IF there is an unexplained increase of the SFPI Vent noble gas monitor of greater than a factor of ten, OR the monitor reads 8.8E---5 mCi/cc or greater, THEN sampling and analysis shall also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

E. Continuous when exhaust fans are in operation.

F. When Spent Fuel Pool Island ventilation is shutdown and ventilation of Spent Fuel Pool Island is exhausted to Balance of Plant Vent, the monthly gaseous grab sample shall be obtained from the Balance of Plant Vent.

G. Tritium analysis of vent grab sample may be replaced by a calculation of tritium released from the spent fuel pool.

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Table I.D.---2 Millstone Unit 2 Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Sample Type and Minimum Type of Lower Limit Release Point Frequency Analysis Radioactivity of Detection or Source Frequency Analysis (LLD)A (mCi/ml)

A.Batch Release Principal Gamma 1 x 10 ---4 1.Waste Gas Stor- Gaseous Grab Prior to each Each Tank Discharge EmittersB Waste Gas Tank Discharge age TankH H---3 1 x 10 --- 6 B.Containment&Aux Building Releases 1.Containment Gaseous Grab of purges 1. Prior to Each Principal Gamma 1 x 10 ---4 and vents Purge EmittersB

1. Prior to Each PurgeJ 2. Every two weeks

2. Every two weeks for for Venting VentingI Monthly H---3 1 x 10 ---6 Continuous Particulate for Weekly Gamma emitters NA Open Containment Equip- for 1/2 hr count ment Hatch during Outage (I---131, others with half---life greater than 8 days)

Continuous Charcoal for Weekly I---131 and I---133 for NA Open Containment Equip- one hour count ment Hatch during Outage C.Continuous Release 1.Vent Monthly --- Gaseous Grab MonthlyC, G. Principal Gamma 1 x 10 ---4 (RM8132B) SampleC.,G. EmittersB H---3G 1 x 10 ---6 2.Millstone Continuous Charcoal Sam- Weekly I---131 1 x 10 ---12 Stack pleD.,F. I---133 1 x 10 ---10 (RM8169---1) Continuous Particulate Weekly Principal Gamma 1 x 10 ---11 SampleD.,F. EmittersB ---

(I---131, others with half lives greater than 8 days)

Continuous Particulate Quarterly Composite Sr---89, Sr---90 --- 1 x 10 ---11 SampleD. Gross alpha 1 x 10 ---11 Continuous Noble GasD. Continuous Monitor Noble Gases --- 1 x 10 ---6 Gross Radioactivity TABLE I.D.---2 TABLE NOTATIONS A. The lower limit of detection (LLD) is defined in Table Notations, Item a, of Tables I.C.---1, I.C.---2, or I.C.---3.

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B. For gaseous samples, the LLD will be 1 x 10 --- 4 mCi/cc and for particulate samples, the LLD will be 1 x 10 --- 11 mCi/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides: Kr---87, Kr---88, Xe---133, Xe---133m, Xe---135, and Xe---138 for gaseous emission and Mn---54, Fe---59, Co---58, Co---60, Zn---65, Mo---99, I---131, Cs---134, Cs---137, Ce---141, and Ce---144 for particulate emissions. The list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

C. IF there is an unexplained increase of the Millstone Stack or Unit 2 Vent noble gas monitor of greater than 50%, THEN sampling and analysis for principal gamma emitters shall be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Sampling and analysis is not required if the monitor reading has returned to within 20% of the average reading prior to the increase.

IF the Millstone Stack or Unit 2 Vent noble gas monitor increased greater than 50% and then has decreased to within 20% of the average reading prior to collecting a sample representative of the elevated reading, THEN an estimate of radioactivity released during the period of elevated reading shall be made.

D. The ratio of the sample flow rate to the sampled stream flow rate shall be known.

E. RESERVED F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing.

For Unit 2 vent only The sampling frequency shall be increased to daily following each reactor shutdown, reactor criticality after shutdown, or thermal power change exceeding 15% of rated thermal power as defined in Technical Specification within a one hour period, if one or both of the following has occurred:

1) The Dose Equivalent I---131 concentration in the reactor coolant has increased by more than a factor of three above the concentration that existed during steady state, full power operation prior to the power transient.

2) The noble gas monitor, RM8132B, has increased more than a factor of three relative to the radiation monitor reading that existed during steady state, full power operation prior to the power transient.

Analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. For daily samples, the LLDs may be increased by a factor of 10.

Daily sampling shall be maintained for seven days or until such time when both conditions (1) and (2) are not satisfied, whichever is shorter.

G. IF the refueling cavity is flooded, THEN grab samples for tritium shall be taken weekly. The grab sample shall be taken from the Millstone Stack or vent where the containment ventilation is being discharged at the time of sampling.

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H. Waste Gas Storage Tanks are normally released on a batch basis via the Millstone Stack.

However, for the purpose of tank maintenance, inspection, or reduction of oxygen concentration, a waste gas tank may be vented or purged with nitrogen and released to the environment via the normal or alternate pathway using one of the following methods:

Method A: Without a permit provided the following conditions are met:

(1) The tank has been previously discharged with a permit.

(2) The current tank pressure is less than 5 PSIG.

(3) No radioactive gases have been added to the tank since the previous discharge from the tank.

(4) Valve lineups are verified to ensure that no radioactive waste gases will be added to the tank.

(5) Prior to initiation of the vent or purge, a sample of the gas in the tank will be taken and analyzed for any residual gamma emitters and tritium. The tank may be released if:

a) Tank radioactivity is less than 1% of the radioactivity released in the previous batch release from the tank, or less than 1% of the radioactivity released to date for the calendar year, and b) the radioactivity of Kr---85 and Xe---133 is less than 0.01 Ci and the radioactivity of all other gases is less than 0.001 Ci.

Method B: With a permit provided valve lineups are verified to ensure that no radioactive waste gases will be added to the tank.

I. IF, compared to the radioactivity at the time of the air sample, a Radiation Monitor RM8123 or RM8262 gas channel increases by a factor of two, THEN a new containment air sample shall be taken.

IF, containment noble gas radioactivity exceeds 1E---6 mCi/cc as indicated by the last grab sample, THEN sampling frequency shall be increased to weekly until such time that the radioactivity is less than 1E---6 mCi/cc.

J. During an outage a sample is only required prior to the initial purge.

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Table I.D.---3 Millstone Unit 3 Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Sample Type and Minimum Type of Radioactivity Lower Limit Release Point Frequency Analysis Analysis of Detection or Source Frequency (LLD)A. (mCi/ml)

A. Containment Release 1.Containment Gaseous, particulate and Same as sample fre- Principal gamma 1 x 10 ---4 charcoal grab prior to quency. emittersB.

each drawdown (via air ejector)

Gaseous grab prior to Same as sample fre- On charcoal sample: 1 x 10 ---12 each purgeH. quency. I---131 1 x 10 ---10 I---133 Gaseous Grab every two On particulate sample: 1 x 10 ---11 weeks for vents (i.e., re- Principal gamma leases to maintain emittersB. --- (I--- 131, oth-sub---atmospheric ers with half lives greater pressure via containment than 8 days) vacuum pump)I.

Monthly for purge, H---3 1 x 10 ---6 vents, and drawdowns Continuous particulate Weekly Gamma emitters for 1/2 NA for open containment hour count (I--- 131, others equipment hatch during with half--- life greater than 8 outages. days)

Continuous charcoal for Weekly I---131 and I---133 for one NA open containment hour count equipment hatch during outages.

B.Continuous Release 1.Unit 3 Ventila- Monthly --- Gaseous MonthlyC., G. Principal gamma 1 x 10 --- 4 tion Vent Grab SampleC., G. emittersB (HVR---

RE10B) H---3G 1 x 10 --- 6 2.Engineered Continuous charcoal Weekly I---131 1 x 10 ---12 Safeguards sampleD.,F. I---133 1 x 10 ---10 Building Continuous particulate Weekly Principal gamma 1 x 10 --- 11 (HVQ---RE49) sampleD.,F. emittersB. --- (I ---131, others 3.Millstone with half lives greater than 8 Stack via days)

SLCRS Continuous particulate Quarterly composite Sr---89, Sr---90 1 x 10 --- 11 (HVR--- sampleD. Gross alpha 1 x 10 --- 11 RE19B)

Continuous noble gasD. Continuous Noble gases --- gross 1 x 10 --- 6 monitor radioactivity TABLE I.D.---3 TABLE NOTATIONS A. The lower limit of detection (LLD) is defined in Table Notations, Item a, of Tables I.C.---1, I.C.---2, or I.C.---3.

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B. For gaseous samples, the LLD will be 1 x 10 --- 4 mCi/cc and for particulate samples, the LLD will be 1 x 10 --- 11 mCi/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides: Kr---87, Kr---88, Xe---133, Xe---133m, Xe---135, and Xe---138 for gaseous emission and Mn---54, Fe---59, Co---58, Co---60, Zn---65, Mo---99, I---131, Cs---134, Cs---137, Ce---141, and Ce---144 for particulate emissions. The list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the Radioactive Effluent Release Report.

C. IF there is an unexplained increase of the Unit 3 ventilation vent or SLCRS noble gas monitor of greater than 50%, THEN sampling and analysis for principal gamma emitters shall be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Sampling and analysis is not required if the monitor reading has returned to within 20% of the average reading prior to the increase.

IF the SLCRS or Unit 3 Vent noble gas monitor increased greater than 50% and then has decreased to within 20% of the reading prior to collecting a sample representative of the elevated reading, THEN an estimate of radioactivity released during the period of elevated reading shall be made.

D. The ratio of the sample flow rate to the sampled stream flow rate shall be known.

E. RESERVED F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing.

For Unit 3 Vent only:

The sampling frequency shall be increased to daily following each reactor shutdown, reactor criticality after shutdown, or thermal power change exceeding 15% of rated thermal power as defined in Technical Specification within a one hour period, if one or both of the following has occurred:

1) The Dose Equivalent I---131 concentration in the reactor coolant has increased by more than a factor of three above the concentration that existed during steady state, full power operation prior to the power transient.

2) The noble gas monitor, HVR---RE10B, has increased more than a factor of three relative to the radiation monitor reading that existed during steady state, full power operation prior to the power transient.

Analyses shall be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. For daily samples, the LLDs may be increased by a factor of 10.

Daily sampling shall be maintained for seven days or until such time when both conditions (1) and (2) are not satisfied, whichever is shorter.

G. IF the refueling cavity is flooded, THEN grab samples for tritium shall be taken weekly from the ventilation vent.

H. During an outage a sample is only required prior to the initial purge.

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I. IF, compared to the radioactivity at the time of the air sample, Radiation Monitor CMS22 gas channel increases by a factor of two, THEN a new containment air sample shall be taken.

IF, containment noble gas radioactivity exceeds 1E---6 mCi/cc as indicated by the last grab sample, THEN sampling frequency shall be increased to weekly until such time that the radioactivity is less than 1E---6 mCi/cc.

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2. Gaseous Radioactive Waste Treatment

a. Dose Criteria for Equipment Functionality Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit.

1) IF any of the radioactive waste processing equipment listed in Section 2.b. are not functional or are being bypassed, THEN doses due to gaseous effluents from the untreated waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.D.4.

For each waste stream, only those doses specified in Section II.D.4.

need to be determined for compliance with this section.

2) IF any of these dose projections exceed 0.02 mrad for gamma radiation, 0.04 mrad for beta radiation or 0.03 mrem to any organ due to gaseous effluents, THEN best efforts shall be made to return the processing equipment to service.

3) IF actual doses exceed 0.2 mrad for gamma radiation, 0.4 mrad for beta radiation or 0.3 mrem to any organ AND the dose from a waste stream with equipment not functional exceed 10% any of these limits, THEN prepare and submit to the Commission a report as specified in Section I.D.2.c.

b. Required Equipment for Each Millstone Unit Best efforts shall be made to return the gaseous radioactive waste treatment system equipment specified below for each unit to service if the projected doses exceed any of doses specified above. For the Unit 2 gas decay tanks, the tanks shall be operated to allow enough decay time of radioactive gases to ensure that the Radiological Effluent Control dose limits are not exceeded.

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1. Millstone Unit No. 1 Waste Stream Processing Equipment None Specified None required

2. Millstone Unit No. 2 Waste Stream Processing Equipment Gaseous Radwaste Five (5) gas decay tanks Treatment System One waste gas compressor Ventilation Exhaust Auxiliary building ventilation HEPA filter (L26 or L27)

Treatment System Containment purge HEPA filter (L25)

Containment vent HEPA/charcoal filter (L29 A or B)

3. Millstone Unit No. 3 Waste Stream Processing Equipment or Radioactivity Concentration Gaseous Radwaste Charcoal bed adsorbers Treatment System One HEPA filter

c. Report Requirement For All Three Millstone Units If required by Section I.D.2.a.3), prepare and submit to the Commission a Special Report within 30 days with the following content:

S Explanation of why gaseous radwaste was being discharged without treatment, identification of any equipment out of service, and the reason for being out of service, S Actions taken to restore the nonfunctional equipment to service, and S Summary description of actions taken to prevent a recurrence.

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Figure I.D.---1, Simplified Gaseous Effluent Flow Diagram Millstone Unit One MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 33 of 135

Figure I.D.---2, Simplified Gaseous Effluent Flow Diagram Millstone Unit Two MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 34 of 135

Figure I.D.---3, Simplified Gaseous Effluent Flow Diagram Millstone Unit Three MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 35 of 135

I.E. Radiological Environmental Monitoring

1. Sampling and Analysis The radiological sampling and analyses provide measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from plant operation. This monitoring program 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 modeling of the environmental exposure pathways.

Program changes may be made based on operational experience.

The sampling and analyses shall be conducted as specified in Table I.E.---1 for the locations shown Table I.E.---2. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment or other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period.

All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report pursuant to Section I.F.1. It is recognized that, at times, it may not be possible or practicable to obtain samples of the media of choice at the most desired location or time. In these instances suitable alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program. Any of the above occurrences shall be documented in the Annual Radiological Environmental Operating Report, which is submitted to the U. S. Nuclear Regulatory Commission prior to May 1 of each year.

If the level of radioactivity in an environmental sampling medium at one or more of the locations specified in Table I.E.---2 exceeds the report levels of Table I.E.---3 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days from receipt of sample results, a Special Report which includes an evaluation of any release conditions, environmental factors or other aspects which caused the limits of Table I.E.---3 to be exceeded. When more than one of the radionuclides in Table I.E.---3 are detected in the sampling medium, this report shall be submitted if:

concentration (1) concentration (2)

+ + 1.0 reporting level (1) reporting level (2)

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When radionuclides other than those in Table I.E.---3 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to an individual is equal to or greater than the appropriate calendar year limit of the Radiological Effluent Controls (Sections III.D.1.b.,

III.D.2.b., or III.D.2.c. for Unit 1; Sections IV.D.1.b., IV.D.2.b., or IV.D.2.c.

for Unit 2; and Sections V.D.1.b., V.D.2.b., or V.D.2.c. for Unit 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.

The detection capabilities required by Table I.E.---4 are state-of-the-art for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement. All analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified and described in the Annual Radiological Environmental Operating Report.

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Table I.E.---1 Millstone Radiological Environmental Monitoring Program Exposure Pathway and/ No. of Sampling and Collection Type and Frequency of or Sample Locations Frequency Analysis 1.Gamma Dose --- 39(a) Quarterly Gamma Dose --- Quarterly Environmental TLD 2.Airborne Particulate 8 Continuous sampler --- filter Gross Beta --- Every two weeks change every two weeks Gamma Spectrum --- Quarterly on composite (by location), and on indi-vidual sample if gross beta is greater than 10x the mean of the control sta-tions gross beta results 3.Airborne Iodine 8 Continuous sampler --- I---131 --- Every two weeks canister change every two weeks 4.Vegetation 5 One sample near middle and Gamma Isotopic on each sample one near end of growing season 5.Milk --- Refer To Table I.E---1.1 6.Sea Water 2 Continuous sampler with a Gamma Isotopic & Tritium on each monthly collection at indica- sample tor location. Quarterly at control location --- Compos-ite of 6 weekly grab samples 7.Well Water 6 Semiannual Gamma Isotopic & Tritium on each sample 8.Bottom Sediment 5 Semiannual Gamma Isotopic on each sample 9.Soil 3 Annually Gamma Isotopic on each sample 10.Fin Fish (edible portion) 2 Semi---annual Gamma Isotopic on each sample 11.Aquatic flora 4 Quarterly Gamma Isotopic on each sample 13.Clams (edible portion) 2 Semi---annual Gamma Isotopic on each sample 14.Lobsters (edible portion) 2 Semi---annual Gamma Isotopic on each sample (a) Two or more TLDs or TLD with two or more elements per location.

(b) Not required during 1st quarter.

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Table I.E.---1.1 Milk Sampling Requirements Number of Locations and Sampling and Type and Frequency Sampling Criteria Collection Frequency of Analysis If milk location(s) are available, obtain samples from Semimonthly when an- Gamma Isotopic and milking animals from up to three locations within 3 miles imals are on pasture; I---131 analysis on each (5 km) distance having the highest dose potential. If there Monthly, for non---pas- sample are none, then one sample from milking animals in each ture producers.

of three areas between 3 to 5 miles (5 to 8 km) distant where doses are calculated to greater than 1 mrem per year. One sample from milking animals at a control loca-tion 9 to 18 miles (15 to 30 km) distant and in the least prevalent wind direction.

If milk location(s) are not available, obtain samples of Monthly, if available, or Gamma Isotopic and three different kinds of broad leaf vegetation grown at harvest.(a) I---131 analysis on each nearest each of two different offsite locations of highest sample predicted annual average ground level D/Q (a) Harvest consists of one sample near the middle and one sample near the end of the growing season.

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Table I.E.---2 Environmental Monitoring Program Sampling Locations The following lists the environmental sampling locations and the types of samples obtained at each location. Sampling locations are also shown on Figures I.E.---1 and I.E.---2:

Location Direction & Dis- Sample Types tance from Re-No* Name lease Point**

1---I Onsite --- NAP Parking Lot North 0.6 Mi, NNW TLD, Air Particulate, Iodine, Vegetation 2---I Onsite --- Weather Shack 0.3 Mi, S TLD, Air Particulate, Iodine 3---I Onsite --- Bird Sanctuary 0.3 Mi, NE TLD, Air Particulate, Iodine, Soil 4---I Onsite --- Albacore Drive 1.0 Mi, N TLD, Air Particulate, Iodine, Soil 5---I Onsite --- Quarry East 0.1 Mi, SSE TLD 6---I Onsite --- Quarry Discharge 0.3 Mi, SSE TLD 7---I Onsite --- Environmental Lab Dock 0.3 Mi, SE TLD 8---I Onsite --- Environmental Lab 0.3 Mi, SE TLD 9---I Onsite --- Bay Point Beach 0.4 Mi, W TLD 10---I Waterford---Goshen Fire Dept. 1.2 Mi, E TLD, Air Particulate, Iodine, Vegetation 11---I Great Neck Country Club 1.6 Mi, ENE TLD, Air Particulate, Iodine 13---C Mystic, CT 11.5 Mi, ENE TLD 14---C Ledyard, CT 12.0 Mi, NE TLD, Soil 15---C Norwich, CT 14.0 Mi, N TLD, Air Particulate, Iodine 16---C Old Lyme, Halls Rd. 8.8 Mi, W TLD 17---I Site Boundary 0.5 Mi, NE Vegetation 25---I Fruits & Vegetables Within 10 Miles Vegetation 26---C Fruits & Vegetables Beyond 10 Mi Vegetation 27---I East Lyme --- Police Station 1.7 Mi, WNW TLD, Air Particulate, Iodine 28---I Two Tree Island 0.8 Mi, SSE Fish1 29---I West Jordan Cove 0.5 Mi, ENE to Clams, Fish1, Aquatic Flora ESE 31---I Niantic Shoals 1.8 Mi, NW Bottom Sediment, Clams 32---I Vicinity of Discharge2 Bottom Sediment, Fish1, Seawater, Aquatic Flora 33---I Seaside Point 1.8 Mi, ESE Bottom Sediment 34---I Thames River Yacht Club 4.0 Mi, ENE Bottom Sediment 35---I Niantic Bay 0.5 Mi, SSW to Lobster, Fish, Aquatic Flora W

36---C Black Point 2.7 Mi, SW Aquatic Flora 37---C Giants Neck 3.5 Mi, WSW Bottom Sediment, Seawater 41---I Waterford --- Myrock Avenue 3.2 Mi, ENE TLD 42---I East Lyme --- Billow Road 2.4 Mi, WSW TLD MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 40 of 135

Table I.E.---2, Cont.

Location Direction & Dis- Sample Types tance from Re-No* Name lease Point**

43---I East Lyme --- Old Black Point Rd. 2.6 Mi, SW TLD 44---I Onsite --- Schoolhouse 0.1 Mi, NNE TLD 45---I Onsite Access Road #1 0.5 Mi, NNW TLD 46---I Old Lyme --- Hillcrest Rd. 4.6 Mi, WSW TLD 47---I East Lyme --- W. Main St. 4.5 Mi, W TLD 48---I East Lyme --- Corey & Roxbury Rd. 3.4 Mi, WNW TLD 49---I East Lyme --- Society Rd. 3.6 Mi, NW TLD 50---I East Lyme --- Manwaring Rd & 2.1 Mi, W TLD Terrace Ave.

51---I East Lyme --- Smith Ave. 1.5 Mi, NW TLD 52---I Waterford --- River Rd. 1.1 Mi, NNW TLD 53---I Waterford --- Gardiners Wood Rd. 1.4 Mi, NNE TLD 55---I Waterford --- Magonk Point 1.8 Mi, ESE TLD 56---I New London --- Ocean & Mott Ave. 3.7 Mi, E TLD 57---I New London --- Ocean Ave. 3.6 Mi, ENE TLD 59---I Waterford ---Miner Ave. 3.4 Mi, NNE TLD 60---I Waterford --- Parkway South & 4.0 Mi, N TLD Cross Rd.

61---I Waterford --- Oil Mill & Boston Post 4.3 Mi, NNW TLD Rd.

62---I East Lyme --- Columbus Ave. 1.9 Mi, WNW TLD 63---I Waterford --- Gradiners Wood & 0.8 Mi, NE TLD Jordon Cove Rd.

64---I Waterford --- Shore Rd. 1.1 Mi, ENE TLD 65---I Waterford --- Boston Post Rd. 3.2 Mi, NE TLD 71---I Onsite well Onsite Well water 72---I Onsite well Onsite Well water 79---I Onsite well Onsite Well water 81---I Onsite well Onsite Well water 82---I Onsite well Onsite Well water 83---I Onsite well Onsite Well water 89---C Aquatic Background Beyond 4 Mi. Of Lobster discharge 1Fish to be sampled from one of three locations ---28, 29, or 32.

2Vicinity of discharge includes the Quarry and shoreline area from Fox Island to western point of Red Barn Recreation Area and offshore out to 500 feet.

• I = Indicator; C = Control.

• • = The release points are the Millstone Stack for terrestrial locations and the end of the quarry for aquatic location.

NOTE: Environmental TLDs also function as accident TLDs in support of the Millstone Emergency Plan.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 41 of 135

Figure I.E.---1, Inner TLD, Air, Grass, Soil, and Aquatic Locations MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 42 of 135

Figure I.E.---2, Outer TLD and Aquatic Locations MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 43 of 135

Table I.E.---3 Reporting Levels For Radioactivity Concentrations In Environmental Samples Analysis Water Airborne Fish ShellfishC. Milk Vegetables (pCi/l) Particulate (pCi/g, wet) (pCi/g, wet) (pCi/l) (pCi/g, wet) or Gases (pCi/m3)

H---3 20,000A.

Mn---54 1,000 30 140 Fe---59 400 10 60 Co---58 1,000 30 130 Co---60 300 10 50 Zn---65 300 20 80 Zr---95 400 Nb---95 400 Ag---110m 8 30 I---131 20B. 0.9 0.2 1 3 0.1 Cs---134 30 10 1 5 60 1 Cs---137 50 20 2 8 70 2 Ba---140 200 300 La---140 200 300 A. 20,000 pCi/l for drinking water samples. (This is 40 CFR Part 141 value.) For non---drinking water pathways, a value of 30,000 pCi/l may be used.

B. Reporting level for I---131 applies to non---drinking water pathways (i.e., seawater). If drinking water pathways are sampled, a value of 2 pCi/l is used.

C. For on---site samples, these values can be multiplied by 3 to account for the near field dilution factor MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 44 of 135

Table I.E.---4 Maximum Values For Lower Limits Of Detection (LLD)A.

Analysis Water Airborne Fish Milk Food Sediment (pCi/l) Particulate Shellfish (pCi/l) Products and Soil or Gases (pCi/g, wet) and Vegeta- (pCi/g, dry)

(pCi/m3) tion (pCi/g, wet) gross beta 1 x 10 ---2 H---3 2000D.

Mn---54 15 0.130 Fe---59 30 0.260 Co---58, 60 15 0.130 Zn---65 30 0.260 Zr---95 30 Nb---95 15 I---131 15C. 7 x 10 ---2 0.093 1 0.06B.

Cs---134 15 5 x 10 ---2 0.130 15 0.060 0.150 Cs---137 18 6 x 10 ---2 0.150 18 0.080 0.180 Ba---140 60C. 70 La---140 15C. 25 TABLE NOTATIONS Table I.E.---4 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a real signal.

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

4.66 S b LLD =

(E)(V)(2.22)(Ye -t)

Where:

S LLD is the lower limit of detection as defined above (as pCi per unit mass or volume)

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

S E is the counting efficiency (as counts per transformation)

S V is the sample size (in units of mass or volume)

S 2.22 is the number of transformations per minute per pCi MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 45 of 135

S Y is the fractional radiochemical yield (when applicable)

S is the radioactive decay constant for the particular radionuclide S t is the elapsed time between midpoint of sample collection and midpoint of counting time (or end of the sample collection period) and time of counting.

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

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors will be identified in the Annual Radiological Environmental Operating Report.

B. LLD for leafy vegetables.

C. From end of sample period.

D. If no drinking water pathway exists (i.e., seawater), a value of 3,000 pCi/l may be used.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 46 of 135

2. Land Use Census A land use census shall be conducted annually during the growing season to identify; (1) changes in the use of unrestricted areas, (2) receptor locations, and (3) new exposure pathways to permit modifications in monitoring programs for evaluating doses to individuals from principal pathways of exposure. The land use census shall identify the location of the nearest resident, nearest garden, and any other land---based food sources in each of the meteorological land sectors within a distance of five miles. Sectors SE, SSE, S, and SSW, are not land sectors because they are over water.

When a land use census identifies a food source location other than the nearest garden in a sector which yields a calculated dose greater than the dose currently being calculated in the off---site dose models, make the appropriate changes in the sample location used.

For each type of food source (milk, fruits, etc.) other than the nearest garden in a sector, when a land use census identifies a location which has a D/Q 20%

or greater than the D/Q for a current indicator location begin sampling from the new location within 30 days.

Sample location changes for food sources other than nearest garden shall be noted in the Annual Radiological Environmental Operating Report.

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

Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program. A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report.

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.

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I.F. Report Content

1. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report shall include summaries, interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the report period, including a comparison with previous environmental surveillance reports and an assessment of radioactivity from plant operation in the environment. Any radioactivity from plant operation detected in the environment shall be compared to levels of radioactivity expected based on the effluent monitoring program and modelling of environment exposure pathways for the purpose of verifying the accuracy of the program and modelling. If levels of radioactivity are detected that result in calculated doses greater than 10CFR50 Appendix I Guidelines, the report shall provide an analysis of the cause and a planned course of action to alleviate the cause.

The report shall include a summary table of all radiological environmental samples which shall include the following information for each pathway sampled and each type of analysis:

1) Total number of analyses performed at indicator locations.

2) Total number of analyses performed at control locations.

3) Lower limit of detection (LLD).

4) Mean and range of all indicator locations together.

5) Mean and range of all control locations together.

6) Name, distance and direction from discharge, mean and range for the location with the highest annual mean (indicator or control).

7) Number of non---routine reported measurements as defined in these specifications.

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. The missing data shall be submitted in the next annual report.

The report shall also include a map of sampling locations keyed to a table giving distances and directions from the discharge; the report shall also include a summary of the Interlaboratory Comparison Data required by Section I.E.3. of this manual.

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The report shall include the results of the land use census required by Section I.E.2. of this manual.

2. Radioactive Effluent Release Report The Radioactive Effluent Release Report (RERR) shall include quarterly quantities of and an annual summary of radioactive liquid and gaseous effluents released from the unit in the Regulatory Guide 1.21 (Rev. 1, June 1974) format. Radiation dose assessments for these effluents shall be provided in accordance with 10 CFR 50.36a and the Radiological Effluent Controls. An annual assessment of the radiation doses from the site to the most likely exposed REAL MEMBER OF THE PUBLIC shall be included to demonstrate conformance with 40 CFR 190. Gaseous pathway doses shall use meteorological conditions concurrent with the quarter of radioactive gaseous effluent releases. Doses shall be calculated in accordance with the Offsite Dose Calculation Manual. The licensee shall maintain an annual of the hourly meteorological data (i.e., wind speed, wind direction and atmospheric stability) either in the form of a listing or in the form of a joint frequency distribution. The licensee has the option of submitting this annual meteorological summary with the RERR or retaining it and providing it to the NRC upon request. The RERR shall be submitted prior to May 1 of each year for the period covering the previous calendar year.

The RERR shall include a summary of each type of solid radioactive waste shipped offsite for burial or final disposal during the report period and shall include the following information for each type:

S type of waste (e.g., spent resin, compacted dry waste, irradiated components, etc.)

S solidification agent (e.g., cement)

S total curies S total volume and typical container volumes S principal radionuclides (those greater than 10% of total radioactivity)

S types of containers used (e.g., LSA, Type A, etc.)

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The RERR shall include a list of all abnormal releases of radioactive gaseous and liquid effluents (i.e., all unplanned or uncontrolled radioactivity releases, including reportable quantities) from the site to unrestricted areas.

Refer To MP---22---REC---REF03, REMODCM Technical Information Document (TID), for guidance on classifying releases as normal or abnormal. The following information shall be included for each abnormal release:

S total number of and curie content of releases (liquid and gas)

S a description of the event and equipment involved S cause(s) for the abnormal release S actions taken to prevent recurrence S consequences of the abnormal release Changes to the MP---22---REC---BAP01, Radiological Effluent Monitoring And Offsite Dose Calculation Manual (REMODCM), shall be submitted to the NRC as appropriate, as a part of or concurrent with the RERR for the period in which the changes were made.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 50 of 135

SECTION II.

Offsite Dose Calculation Manual (ODCM)

For the Millstone Nuclear Power Station Nos. 1, 2, & 3 Docket Nos. 50---245, 50---336, 50---423 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 51 of 135

SECTION II. OFFSITE DOSE CALCULATION MANUAL (ODCM)

II.A. Introduction The purpose of the Offsite Dose Calculation Manual (Section II of the REMODCM) is to provide the parameters and methods to be used in calculating offsite doses and effluent monitor setpoints at the Millstone Nuclear Power Station. Included are methods for determining maximum individual whole body and organ doses due to liquid and gaseous effluents to assure compliance with the regulatory dose limitations in 10 CFR 50, Appendix I. Also included are methods for performing dose projections to assure compliance with the liquid and gaseous treatment system functionality sections of the Radiological Effluent Monitoring Manual (REMM --- Section I of the REMODCM). The manual also includes the methods used for determining quarterly and annual doses for inclusion in the Radioactive Effluent Release Report.

The bases for selected site-specific factors used in the dose calculation methodology are provided in MP---22---REC---REF03, REMODCM Technical Information.

Another section of this manual discusses the methods to be used in determining effluent monitor alarm/trip setpoints to be used to ensure compliance with the instantaneous release rate limits in Sections III.D.2.a., IV.D.2.a., and V.D.2.a.

This manual includes the methods to be used in performance of the surveillance requirements in the Radiological Effluent Controls of Sections III, IV, and V.

Appendix A, Tables App.A-1 provide a cross-reference of effluent requirements and applicable methodologies contained in the REMODCM.

II.B. Responsibilities All changes to the Offsite Dose Calculation Manual (ODCM) shall be reviewed and approved by the Facilities Safety Review Committee prior to implementation.

All changes and their rationale shall be documented in the Radioactive Effluent Release Report.

It shall be the responsibility of the Site Vice President Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications. The delegation of implementation responsibilities is delineated in the MP---22---REC---PRG, Radiological Effluent Control.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 52 of 135

II.C. Liquid Dose Calculations Radiological Effluent Controls (Sections III, IV, and V) limit whole body and maximum organ doses to an individual member of the public to 1.5 mrem whole body and 5 mrem maximum organ per calendar quarter and 3 mrem whole body and 10 mrem maximum organ per year from liquid effluents released from each unit. (See Appendix A, Table App.A---1 for cross---reference effluent control requirements and applicable sections in the REMODCM which are used to determine compliance). In addition, installed portions of liquid radwaste treatment system are required to be operated to reduce radioactive materials in liquid effluents when the projected dose over 31 days from applicable waste streams exceeds 0.006 mrem whole body or 0.02 mrem maximum organ. This part of the REMODCM provides the calculation methodology for determining the doses from radioactive materials released into liquid pathways of exposure associated with routine discharges.

1. Monthly, Quarterly, and Annual Dose Calculation (Applicable to All Units)

For each Unit, whole body and maximum organ doses from liquid effluents shall be calculated at least once per 31 days (or monthly) using the methodology of Regulatory Guide 1.109, Rev. 1. The calculation shall include contributions from all analyses required by Table I.C---1 for Unit 1, Table I.C---2 for Unit 2, and Table I.C---3 for Unit 3 recorded to date. If any required analyses have not yet been completed for the dose period, an estimate of dose from unanalyzed isotopes shall be included in the dose total.

Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit.

2. Monthly Dose ProjectionsSection I.C.2.a. of the REMM requires that certain portions of the liquid radwaste treatment equipment be used to reduce radioactive liquid effluents when the projected doses for each Unit (made at least once per 31 days) exceeds 0.006 mrem whole body or 0.02 mrem to any organ. The following methods are applied in the estimation of monthly dose projections:

a. Whole Body and Maximum Organ when Steam Generator Total Gamma Radioactivity is less than 5E---7 mCi/ml and Steam Generator Tritium is less than 0.02 mCi/ml (Applicable to Units 2 and 3)

The projected monthly whole body dose (Units 2 or 3) is determined from:

D E MW = DMW [R 1 R 4 F 2]

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 53 of 135

The monthly projected maximum organ dose (Units 2 or 3) is determined from:

D E MO = DMO [R 1 R 4 F 2]

Where:

DMW = the whole body dose from the last typical previously completed month as calculated per the methods in Section II.C.1.

DMO = the maximum organ dose from the last typical previously completed month as calculated per the methods in Section II.C.1.

R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month.

R4 = the ratio of estimated primary coolant radioactivity for the present month to that for the past month.

F2 = the factor to be applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers).

NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.

The last month should be typical without significant operational differences from the projected month. If there were no releases during last month, do not use that month as the base month if it is estimated that there will be releases for the coming month.

b. Whole Body and Maximum Organ when Steam Generator Total Gamma radioactivity Exceeds 5E---7 mCi/ml or Steam Generator Tritium Exceeds 0.02 mCi/ml (Applicable to Units 2 and 3)

The projected monthly whole body dose (Units 2 or 3) is determined from:

D E MW = DMW [(1 F 1) R 1 R 4 F 2 + F 1 R 2 R 3]

The monthly projected maximum organ dose (Units 2 or 3) is determined from:

D E MO = DMO [(1 F 1) R 1 R 4 F 2 + F 1 R 2 R 3]

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 54 of 135

Where:

DMW= the whole body dose from the last typical previously completed month as calculated per the methods in Section II.C.1.

DMO= the maximum organ dose from the last typical previously completed month as calculated per the methods in Section II.C.1.

R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month.

R2 = the ratio of estimated volume of steam generator blowdown to be released in present month to the volume released in the past month.

F1 = the fraction of curies released last month coming from steam generator blowdown calculated as:

curies from blowdown curies from blowdown + curies from batch tanks R3 = the ratio of estimated secondary coolant radioactivity for the present month to that for the past month.

R4 = the ratio of estimated primary coolant radioactivity for the present month to that for the past month.

F2 = the factor to be applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers).

NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 55 of 135

II.D. Gaseous Dose Calculations

1. Site Release Rate Limits (Instantaneous)

Radiological Effluent Controls (Sections III.D.2.a, IV.D.2.a, and V.D.2.a) for each unit require that the instantaneous off---site dose rates from noble gases released to the atmosphere be limited such that they do not exceed 500 mrem/year at any time to the whole body or 3000 mrem/year to the skin at any time. For iodine---131, 133, tritium, and particulates (half---lives >8 days), the dose rate from all units shall not exceed 1500 mrem/year at any time to any organ. These limits apply to the combination of releases from all three Units on the site, and are directly related to the radioactivity release rates measured for each Unit.

a. Method 1 for Noble Gas Release Rate Limits Instantaneous noble gas release rate for the site:

Q1V /90,000 +Q2S/560,000 + Q2V/290,000 + Q3S/560,000 + Q3V/290,000 < 1 Where:

Q1V = Noble gas release rate from Spent Fuel Pool Island Vent (mCi/sec)

Q2S = Noble gas release rate from MP2 to Millstone Stack (mCi/sec)

Q2V = Noble gas release rate from MP2 Vent (mCi/sec)

Q3V = Noble gas release rate from MP3 Vent (mCi/sec)

Q3S = Noble gas release rate from MP3 to Millstone Stack (mCi/sec)

As long as the above is less than or equal to 1, the doses will be less than or equal to 500 mrem to the total body and less than 3000 mrem to the skin. The limiting factor for the Unit 1 SFPI vent of 90,000 is based on the skin dose limit of 3,000 mrem/year, while all the other factors are based on the whole body dose limit of 500 mrem/year.

b. Method 1 Release Rate Limit --- I---131, I---133, H---3 and Particulates Half Lives Greater Than 8 Days With releases satisfying the following limit conditions, the dose rate to the maximum organ will be less than 1500 mrem/year from the inhalation pathway:

1) Site release rate of I---131, I---133, and tritium (where the thyroid is the critical organ for these radionuclides):

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 56 of 135

DRthy1 + DRthy2 + DRthy3 1 Where the contribution from each Unit is calculated from:

Unit 1: DRthy1 = 2.78E---5 QH1V Unit 2: DRthy2 = 8.80E---2 131QI2V + 9.67E---3 131QI2S +

2.08E---2 133QI2V+2.29E---3 133QI2S +

6.87E---6 QH2V+7.53E---7 QH2S Unit 3: DRthy3 = 8.80E---2 131QI3V + 9.67E---3 131QI3S +

2.08E---2 133QI3V +2.29E---3 133QI3S +

6.87E---6 QH3V + 7.53E---7 QH3S

2) Site release rate of particulates with half---lives greater than 8 days and tritium (where the critical organ is a composite of target organs for a mix of radionuclides):

DRorg1 + DRorg2 + DRorg3 1 Where the contribution from each Unit is calculated from:

Unit 1:DRorg1 = 3.52E---1 [QP1V + QP1B ]+2.78E---5 QH1V Unit 2:DRorg2 = 9.53E---3 QP2S + 8.67E---2 QP2V +

7.53E---7 QH2S + 6.87E---6 QH2V Unit 3:DRorg3 = 9.53E---3 QP3S + 8.67E---2 QP3V +

7.53E---7 QH3S + 6.87E---6 QH3V Each of the release rate quantities in the above equations are defined as:

131QI2V =Release rate of I---131 from MP2 Vent (mCi/sec)*

131QI2S = Release rate of I---131 from MP2 to Millstone Stack (mCi/sec) 133QI2V =Release rate of I---133 from MP2 Vent (mCi/sec)*

133QI2S = Release rate of I---133 from MP2 to Millstone Stack (mCi/sec) 131QI3V =Release rate of I---131 from MP3 Vents (Normal and ESF)

(mCi/sec)*

131QI3S = Release rate of I---131 from MP3 to Millstone Stack (mCi/sec)

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133QI3V =Release rate of I---133 from MP3 Vents (Normal and ESF)

(mCi/sec)*

133QI3S = Release rate of I---133 from MP3 to Millstone Stack (mCi/sec)

QH1V = Release rate of tritium from the Spent Fuel Pool Island and Balance of Plant Vents (mCi/sec)

QH2V = Release rate of tritium from MP2 Vent (mCi/sec)*

QH2S = Release rate of tritium from MP2 to Millstone Stack (mCi/sec)

QH3V = Release rate of tritium from MP3 Vents (Normal and ESF)

(mCi/sec)*

QH3S = Release rate of tritium from MP3 to Millstone Stack (mCi/sec)

QP1V = Release rate of total particulates with half---lives greater than 8 days from the Spent Fuel Pool Island Vent (mCi/sec)

QP1B = Release rate of total particulates with half---lives greater than 8 days from the Balance of Plant Vent (mCi/sec)

QP2V = Release rate of total particulates with half---lives greater than 8 days from the MP2 Vent (mCi/sec)

QP2S = Release rate of total particulates with half---lives greater than 8 days from MP2 to Millstone Stack (mCi/sec)

QP3V = Release rate of total particulates with half---lives greater than 8 days from MP3 Vents (Normal and ESF) (mCi/sec)

QP3S = Release rate of total particulates with half---lives greater than 8 days from MP3 to Millstone Stack (mCi/sec)

• includes releases via the steam generator blowdown tank vent.

c. Method 2 The above Method 1 equations assume a conservative nuclide mix. If necessary, use the methodology given in Regulatory Guide 1.109 to estimate the dose rate from either noble gases or iodines, tritium, and particulates with half-lives greater than 8 days.

2. 10 CFR50 Appendix I --- Noble Gas Limits Use the methodology of Regulatory Guide 1.109 Rev.1, to calculate the critical site boundary gamma air and beta air doses at least once per 31 days (monthly).

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For calculations performed once every 31 days, enter the following meteorology:

Release Point /Q D/Q Site Stack 8.92E---7 8.84E---9 Mixed---mode or rooftop (e.g., vents) 8.1E---6 1.5E---7 Ground 3.28E---5 1.68E---7 If the calculated air dose exceeds one half the quarterly Radiological Effluent Control limit, use meteorology concurrent with quarter of release.

Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit.

For calculations of quarterly doses for the Radioactive Effluent Release Report, use average quarterly or real---time meteorology.

3. 10 CFR50 Appendix I --- Iodine, Tritium, C---14, and Particulate Doses For each Unit, whole body and maximum organ doses from I---131, I---133, tritium, C---14 and particulates with half---lives greater than 8 days in gaseous effluents shall be calculated at least once per 31 days (or monthly) using the methodology of Regulatory Guide 1.109, Rev.1.

For calculations performed once every 31 days, enter the following meteorology:

Release Point /Q D/Q Site Stack 8.92E---7 8.84E---9 Mixed---mode or rooftop (e.g., vents) 8.1E---6 1.5E---7 Ground 3.28E---5 1.68E---7 The calculation shall include contributions from all analyses required by Table I.D---1 for Unit 1, Table I.D---2 for Unit 2, and Table I.D---3 for Unit 3 recorded to date. If any required analyses have not yet been completed for the dose period, an estimate of dose from unanalyzed isotopes shall be included in the dose total. If the calculated dose exceeds one---half the quarterly Radiological Effluent Control limit, use meteorology concurrent with the dose period.

Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit.

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For calculations of quarterly doses for the Radioactive Effluent Release Report, use average quarterly or real---time meteorology.

4. Gaseous Effluent Monthly Dose ProjectionsSection I.D.2.a. of the REMM requires that certain portions of the gaseous radwaste treatment equipment be returned to service to reduce radioactive gaseous effluents when the projected doses for each Unit (made at least once per 31 days) exceed 0.02 mrad gamma air, 0.04 mrad beta air, or 0.03 mrem to any organ from gaseous effluents. The following methods are applied in the estimation of monthly dose projections.

a. Unit 1 Projection Method None required.

b. Unit 2 Projection Method

1) Due to Gaseous Radwaste Treatment System (Unit 2)

Determine the beta and gamma monthly air dose projection from noble gases from the following:

DEMG (mrad) = 5E---4 CEN DEMB (mrad) = 3E---4 CEN DEMO (mrem) = 3E---4 CEN Where:

CEN = the number of curies of noble gas estimated to be released from the waste gas storage tanks during the next month.

DEMG = the estimated monthly gamma air dose.

DEMB= the estimated monthly beta air dose.

DEMO= the estimated monthly organ dose.

2) (Reserved)

3) Due to Ventilation Releases (Unit 2)

If portions of the ventilation treatment system are expected to be out of service during the month, determine the monthly maximum organ dose projection (DEMO ) from the following:

i. Method 1 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 60 of 135

Determine DEMO which is the estimated monthly dose to the maximum organ from the following:

DEMO = 1/3 R1 (1.01--- R2) (R3+ 0.01) DO For the last quarter of operation, determine DO as determined per Section II.D.3.

R1 = the expected reduction factor for the HEPA filter.

Typically this should be 100 (see NUREG---0016 or 0017 for additional guidance).

R2 = the fraction of the time which the equipment was nonfunctional during the last quarter.

R3 = the fraction of the time which the equipment is expected to be nonfunctional during the next month.

DO = maximum organ dose from the previous month.

ii. Method 2 If necessary, estimate the curies expected to be released for the next month and applicable method for dose calculation from Section II.D.3.

c. Unit 3 Projection Method

1) Due to Radioactive Gaseous Waste System (Unit 3)

Determine the beta and gamma monthly air dose projection from noble gases from the following:

DEMG (mrad) = 5E---4 CEN DEMB (mrad) = 3E---4 CEN DEMO (mrem) = 3E---4 CEN Where:

CEN = the number of additional curies of noble gas estimated to be released from Unit 3 during the next month due to the nonfunctional processing equipment.

DEMG =the estimated monthly gamma air dose.

DEMB =the estimated monthly beta air dose.

DEMO =the estimated monthly organ dose.

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5. Compliance with 40CFR190 The following sources shall be considered in determining the total dose to any real member of the public, at or beyond the site boundary, from uranium fuel cycle sources:

a. Gaseous Releases from Units 1, 2, and 3.

b. Liquid Releases from Units 1, 2, and 3.

c. Direct and Scattered Radiation from Radioactive Material on Site.

d. Direct and Scattered Radiation from the Independent Spent Fuel Storage Installation (ISFSI).

Doses shall be obtained per the requirements of Section II.C.1 for liquid releases and Section II.D.2 and II.D.3 for gaseous releases.

Direct and scattered radiation doses shall be calculated. Doses from all sources shall be added to determine compliance with 40CFR190.

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II.E. Liquid Discharge Flow Rates And Monitor Setpoints

1. Unit 1 Liquid Waste Effluent Discharge (RE---M6---110)

The limit on discharge flow rate and setpoint on the Unit 1 liquid waste monitor depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used:

STEP 1:

From the isotopic analysis and the Effluent Concentration (EC) values for each identified nuclide determine the required reduction factor, i.e.:

R = Required Reduction Factor = 1 mCi ml of nuclide i 10 x EC of nuclide i STEP 2:

Determine the allowable discharge flow (F)

F = 0.1 x R x D Where:

D= The existing dilution flow which is the any dilution flow from Millstone Unit 2 and/or Unit 3 not being credited for any other radioactivity discharge during discharge of Unit 1 water.

0.1 = safety factor to limit discharge concentration to 10% of the Radiological Effluent Control Limit.

STEP 3:

Calculate the monitor setpoint as follows:

Rset = 2 x AC x RCF + Background Where:

Rset = The setpoint of the monitor.

AC = The total radwaste effluent concentration (mCi/ml ) in the tank.

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RCF = The response correction factor for the effluent line monitor using the current calibration factor or isotopic---specific responses.

2= Tolerance limit which brings the setpoint at twice the expected response of the monitor based on sample analysis. With the safety factor of 0.1 the setpoint would be at 20% of the Radiological Effluent Control Limit.

Option setpoint:

A setpoint based upon worst case conditions may be used. Assume the maximum possible discharge flow, a minimum dilution flow not to exceed 100,000 gpm, and a limit of 1 x 10-7 mCi/ml which is lower than any 10CFR20 EC limit except for transuranics. This will assure that low level releases are not terminated due to small fluctuations in radioactivity. When using this option setpoint independent verification of discharge lineup shall be performed. The optional setpoint may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.

2. Reserved

3. Unit 2 --- Clean and Aerated Liquid Waste Discharge --- RM9049 The setpoint on the Unit 2 clean and aerated liquid waste effluent lines depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, an alarm/trip setpoint will be determined prior to the release of each batch.

The following method will be used:

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STEP 1:

From the tank isotopic analysis and the Effluent Concentrations (EC) in 10CFR20, App. B, Table 2, Col. 2 for each identified nuclide determine the required reduction factor, i.e.:

For Nuclides Other Than Noble Gases:

R 1 = Required Reduction Factor = 1 mCi ml of nuclide i 10 x EC of nuclide i For Noble Gases: If the noble gas concentration is less than 1.1 x 10 ---2 mCi/ml or the calculated diluted concentration is less than 2 x 10 ---5 mCi/ml, the reduction factor need not be determined. The concentration of 1.1 x 10 ---2 mCi/ml is based on 175 gpm discharge flow, 100,000 gpm dilution flow, and a safety factor of 0.1 (See Note below.) If dilution flow is less than 100,000 gpm, the noble gas concentration limit shall be decreased by the ratio of actual dilution flow to 100,000gpm. For example, if dilution flow is 50,000 gpm, the limit would be reduced by a factor of 0.5 (50,000/100,000).

2 x 10 4 mCi R 2 = Required Reduction Factor = 1 = ml mCi ml of noble gases 4mCi mCi ml noble gases 2 x 10 ml R = the smaller of R1 or R2 STEP 2:

Determine the allowable discharge flow (F) in gpm:

F = 0.1 x R x D Where:

D = the existing dilution flow (D) from circulating and service water pumps. It may include any Unit 3 flow, or portion of Unit 3 flow, not being credited for dilution of a Unit 3 radioactivity discharge during the time of the Unit 2 discharge.

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NOTE Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1.

With this condition on discharge flow rate met, the monitor setpoint can be calculated:

Rset = 2 x AC x RF (See Note 1 below.)

Where:

Rset = the setpoint of the monitor (cpm).

AC = the total radwaste effluent concentration (mCi/ml) in the tank.

RF = the response factor for the effluent line monitor using the current calibration factor or isotopic---specific responses.

2= the multiple of expected count rate on the monitor based on the radioactivity concentration in the tank.

This value or that corresponding to 5.6 x 10-5 mCi/ml (Note 2 below),

whichever is greater, plus background is the trip setpoint. For the latter setpoint, independent value verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.

Note 1: If discharging at the allowable discharge rate (F) as determined in above, this setpoint would correspond to 20% of the Radiological Effluent Control limit.

Note 2: This value is based upon assuming maximum discharge flow (175 gpm), dilution water flow of 100,000 gpm and a limit of 1 x 10-7 which is lower than any Technical Specification limit (ten times 10CFR20 EC values) except for transuranics. This will assure that low level releases are not terminated due to small fluctuations in radioactivity activity. However, to verify that the correct tank is being discharged when using this value, independent valve verification shall be performed. This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained. Dilution flow may include any Unit 3 flow, or a portion MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 66 of 135

of Unit 3 flow, not being credited for dilution of a Unit 3 radioactive discharge during the time of the Unit 2 discharge.

4. Condensate Polishing Facility Waste Neutralization Sump Effluent Line ---

CND245 The setpoint shall be determined as for the Clean and Aerated Liquid Waste Discharge Monitor in Section II.E.3.

5. Unit 2 Steam Generator Blowdown --- RM4262 and Unit 2 Steam Generator Blowdown Effluent Concentration Limitation 5a. Unit 2 Steam Generator Blowdown --- RM4262 Alarm 800 CPM + background This setpoint may be adjusted (increased or decreased) through proper administrative controls.

circulating & service water flow (gpm)

Adjusted alarm 6 CPM x + Background total SG blowdown (gpm)

When using the adjusted alarm, ensure that any other simultaneous discharge does not cause an exceedance of regulatory limits.

5b. Unit 2 Steam Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I.C.---2 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed ten times the concentration limits in 10CFR20, Appendix B.

6. Unit 2 Condenser Air Ejector --- RM5099 N/A since this monitor is no longer a final liquid effluent monitor.

7. Unit 2 Reactor Building Closed Cooling Water RM6038 and Unit 2 Service Water, and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation 7a. Unit 2 Reactor Building Closed Cooling Water RM6038 The purpose of the Reactor Building Closed Cooling Water (RBCCW) radiation monitor is to give warning of abnormal radioactivity in the RBCCW system and to prevent releases to the Service Water system MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 67 of 135

which, upon release to the environment, would exceed ten times the concentration values in 10CFR20. According to Calculation RERM---02665---R2, radioactivity in RBCCW water which causes a monitor response of greater than the setpoint prescribed below could exceed ten times the10CFR20 concentrations upon release to the Service Water system.

SETPOINT DURING POWER OPERATIONS:

To give adequate warning of abnormal radioactivity, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 2,000 cpm. The monitor background reading shall be the normal monitor reading. If the monitor background reading exceeds 2,000 cpm, the setpoint shall be set at the background reading plus 2,000 cpm and provisions shall be made to adjust the setpoint if the background decreases.

SETPOINT DURING SHUTDOWN:

1) During outages not exceeding three months the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 415 cpm. If the monitor background reading exceeds 415 cpm, the setpoint shall be set at the background reading plus 415 cpm and provisions shall be made to adjust the setpoint if the background decreases.

2) During extended outages exceeding three months, but not exceeding three years, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 80 cpm. If the monitor background reading exceeds 80 cpm, the setpoint shall be set at the background reading plus 80 cpm and provisions shall be made to adjust the setpoint if the background decreases.

PROVISIONS FOR ALTERNATE DILUTION FLOWS:

These setpoints are based on a dilution flow of 4,000 gpm from one service water train. If additional dilution flow is credited, the setpoint may be adjusted proportionately. For example, the addition of a circulating water pump dilution flow of 100,000 gpm would allow the setpoint to be increased by a factor of 25.

7b. Unit 2 Service Water, and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water, RBCCW sump and turbine building sump samples taken in accordance with Table I.C.---2 of Section I of the MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 68 of 135

REMODCM shall be used to limit radioactivity concentrations in the service water, RBCCW sump and turbine building sump effluents to less than ten times the limits in 10CFR20, Appendix B.

8. Unit 3 Liquid Waste Monitor --- LWS---RE70 The setpoints on the Unit 3 liquid waste monitor depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used:

Step 1:

From the tank isotopic analysis and the Effluent Concentration (EC) values for each identified nuclide determine the required reduction factor, i.e.:

For Nuclides Other Than Noble Gases:

R 1 = Required Reduction Factor = 1 mCi ml of nuclide i 10 x EC of nuclide i For Noble Gases: If the noble gas concentration is less than 0.013 mCi/ml or the calculated diluted concentration is less than 2 x 10 ---5 mCi/ml, the reduction factor need not be determined. The concentration of 0.013 mCi/ml is based on 100,00 gpm dilution flow and a safety factor of 0.1 (See Note Below.) If dilution flow is less than 100,000 gpm, the noble gas concentration limit shall be decreased by the ratio of actual dilution flow to 100,000gpm.

For example, if dilution flow is 50,000 gpm, the limit would be reduced by a factor of 0.5 (50,000/100,000).

2 x 10 4 mCi R 2 = Required Reduction Factor = 1 = ml mCi ml of noble gases 4mCi mCi ml noble gases 2 x 10 ml R = the smaller of R1 or R2 Step 2:

Determine the allowable discharge flow (F)

F = 0.1 x R x D MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 69 of 135

Where:

D = The existing dilution flow (D) from circulating and service water pumps.

It may include any Unit 2 flow, or portion of Unit 2 flow, not being credited for dilution of a Unit 2 radioactivity discharge during the time of the Unit 3 discharge.

NOTE Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1.

With this condition on discharge flow rate met, the monitor setpoint can be calculated:

Rset = 2 x AC x RCF (see Note 1)

Where:

Rset= The setpoint of the monitor.

AC= The total radwaste effluent concentration (mCi/ml ) in the tank.

RCF= The response correction factor for the effluent line monitor using the current calibration factor or isotopic---specific responses.

2 = The multiple of expected count rate on the monitor based on the radioactivity concentration in the tank.

This value, or that corresponding to 6.6 x 10-5 mCi/ml (Note 2 below),

whichever is greater, plus background is the trip setpoint. For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.

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NOTE

1. If discharging at the allowable discharge rate (F) as determined above, this Alarm setpoint would yield a discharge concentration corresponding to 20% of the Radiological Effluent Control limit.

2. This value is based upon assuming maximum discharge flow (150 gpm), dilution water flow of 100,000 gpm, and a limit of 1 x 10-7 mCi/ml which is lower than any Technical Specification limit (ten times 10CFR20 EC values) except for transuranics. This will assure that low level releases are not terminated due to small fluctuations in radioactivity. However, to verify that the correct tank is being discharged when using this value, independent valve verification shall be performed. This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained. Dilution flow may include Unit 2 flow, or portion of Unit 2 flow, not being credited for dilution of a Unit 2 discharge during the time of the Unit 3 discharge.

9. Unit 3 Regenerant Evaporator Effluent Line --- LWC---RE65 The MP3 Regenerant Evaporator has been removed from service with DCR M3---97---041. Therefore a radiation monitor alarm is not needed.

10. Unit 3 Waste Neutralization Sump Effluent Line --- CND---RE07 Same asSection II.E.8.

11. Unit 3 Steam Generator Blowdown --- SSR---RE08 and Unit 3 Steam Generator Blowdown Effluent Concentration Limitation 11a. Unit 3 Steam Generator Blowdown --- SSR---RE08 The alarm setpoint for this monitor assumes:

a. Steam generator blowdown rate of 400 gpm (maximum blowdown total including weekly cleaning of generators --- per ERC 25212---ER---99---0133).

b. The release rate limit is conservatively set at 3 x 10 ---8 mCi/ml which is well below any 10CFR20 Effluent Concentration except for transuranics*.

c. Circulating and service water dilution flow during periods of blowdown = 100,000 gpm.

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d. Background can be added after above calculations are performed.

Therefore, the alarm setpoint corresponds to a concentration of:

100, 000 Alarm (mCiml) = x 3x10 -8 + background = 7.5x10 -6 mCiml + background 400 This setpoint may be increased through proper administrative controls if the steam generator blowdown rate is maintained less than 400 gpm and/or more than 100,000 gpm dilution flow are available. The amount of the increase would correspond to the ratio of flows to those assumed above or:

circulating & service water flow (gpm) 400 Alarm (mCi ml) = 7.5x10 -6mCi ml x x +

100, 000 S G blowdown (gpm) circulating & service water flow (gpm)

Background = 3x10 8mCi ml x + Background total S G blowdown (gpm)

When using the adjusted alarm, ensure that any other simultaneous discharge does not cause an exceedance of regulatory limits.

NOTE The Steam Generator Blowdown alarm criteria is in practice based on setpoints required to detect allowable levels of primary to secondary leakage. This alarm criteria is typically more restrictive than that required to meet discharge limits. This fact shall be verified, however, whenever the alarm setpoint is recalculated.

• In lieu of using 3 x 10 ---8 mCi/ml, ten times the identified 10CFR20 EC values may be used.

11b. Unit 3 Steam Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I.C.---3 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed ten times the concentration limits in 10CFR20, Appendix B.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 72 of 135

12. Unit 3 Turbine Building Floor Drains Effluent Line --- DAS---RE50 and Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation 12a. Unit 3 Turbine Building Floor Drains Effluent Line --- DAS---RE50 The alarm setpoint for this monitor shall be set to four times (4X) the reading of the monitor when there is no gamma radioactivity present in the turbine building sumps. As determined in Calculation RERM---04101R3, the setpoint shall not exceed 1.4 x 10 ---5 mCi/ml.

12b. Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water and turbine building sump samples taken in accordance with Table I.C.---3 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water and turbine building sump effluents to less than ten times the limits in 10CFR20, Appendix B.

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II.F. Gaseous Monitor Setpoints

1. Unit 1 Spent Fuel Pool Island Monitor --- RM---SFPI---02 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.1.a. in order to satisfy Unit 1 Radiological Effluent Controls III.C.2. and III.D.2.a.

The Unit 1 allocated portion of the site instantaneous release rate limit is 30,000 mCi/sec. This assumes that 7% of the site limit for skin dose of 3000 mrem per year is assigned to the Unit 1 Spent Fuel Pool Island vent. If effluent conditions from the Unit 1 Spent Fuel Pool Island vent reach 30,000 mCi/sec, releases from Units 2 and 3 vents and from the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site skin dose limit to be exceeded. Use Section II.D.1.a. and Section 4.2 of MP---22---REC---REF03. REMODCM Technical Information Document, in making this determination.

The alarm setpoint shall be set at or below the monitor reading in mCi/cc corresponding to the Unit 1 portion of the limit. The setpoint shall be set at or below 1.71E---3 mCi/cc.

2. Unit 2 Wide Range Gas Monitor (WRGM) --- RM8169 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.1.a. in order to satisfy Units 2 Radiological Effluent Controls IV.C.2. and IV.D.2.a.

For releases from Unit 2 to the Millstone Stack, the allocated portion of the site instantaneous release rate limit is 72,000 mCi/sec. This assumes that 13%

of the site limit is assigned to Unit 2 releases to the Millstone Stack. If effluent conditions from Unit 2 releases to the Millstone Stack reach 72,000 mCi/sec, releases from Units 1, 2, and 3 vents and from Unit 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.

Use Section II.D.1.a. and Section 4.2 of MP---22---REC---REF03, REMODCM Technical Information Document, in making this determination.

The alarm setpoint shall be set at or below the monitor reading in mCi/cc corresponding to the Unit 2 release to the stack portion of the limit. The setpoint shall be set at or below 1.3E---2 mCi/cc.

3. Reserved MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 74 of 135

4. Unit 3 SLCRS --- HVR---RE19B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.1.a. in order to satisfy Unit 3 Radiological Effluent Controls V.C.2. and V.D.2.a.

For releases from Unit 3 to the Millstone Stack, the allocated portion of the site instantaneous release rate limit is 72,000 mCi/sec. This assumes that 13%

of the site limit is assigned to Unit 3 releases to the Millstone Stack. If effluent conditions from Unit 3 releases to the Millstone Stack reach 72,000 mCi/sec, releases from Units 1 and 2 vents, Unit 3 ESF vent and from Unit 2 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site dose limit to be exceeded. Use Section II.D.1.a. and Section 4.2 of MP---22---REC---REF03, REMODCM Technical Information Document, in making this determination.

The alarm setpoint shall be set at or below the monitor reading in mCi/cc corresponding to the Unit 3 release to the stack portion of the limit. The setpoint shall be set at or below 1.16 E---2 mCi/cc.

5. Unit 2 Vent --- Noble Gas Monitor --- RM8132B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.1.a. in order to satisfy the Unit 2 Radiological Effluent Controls in Sections IV.C.2. and IV.D.2.a.

For releases from Unit 2 vent, the allocated portion of the site instantaneous release rate limit is 95,000 mCi/sec. This assumes that 33% of the site limit is assigned to Unit 2 vent releases. If effluent conditions from Unit 2 vent releases reach 95,000 mCi/sec, releases from Units 1 and 3 vents and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded. Use Section II.D.1.a. and Section 4.2 of MP---22---REC---REF03, REMODCM Technical Information Document, in making this determination.

The alarm setpoint shall be set at or below the monitor reading in cpm corresponding to the Unit 2 vent portion of the limit. The setpoint shall be set at or below 42,000 CPM.

6. Unit 2 Waste Gas Decay Tank Monitor RM9095 Administratively all waste gas decay tank releases are via the Millstone Stack. Unit 2 has a release rate limit to the Millstone Stack of 72,000 mCi/sec (see the MP---22---REC---REF03, REMODCM Technical Information Document, Section 4.2 for bases).

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Batch releases of waste gas shall be limited to less than 10% of the Unit 2 releases to the Millstone Stack release rate limits. Therefore, the waste gas decay tank monitor setpoint should be set not to exceed 7,200 mCi/sec. If the setpoint exceeds 7,200 mCi/sec, the release shall be automatically terminated.

The MP2 waste gas decay tank monitor (given mCi/cc per cpm) calibration curve and the tank discharge rate is used to assure that the concentration of gaseous radioactivity being released from a waste gas decay tank does not cause the setpoint of 7,200 mCi/sec to be exceeded.

7. Unit 3 Vent Noble Gas Monitor --- HVR---RE10B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.1.a. in order to satisfy Unit 3 Radiological Effluent Controls in Sections V.C.2. and V.D.2.a.

For releases from Unit 3 vent, the allocated portion of the site instantaneous release rate limit is 95,000 mCi/sec. This assumes that 33% of the site limit is assigned to Unit 3 vent releases. If effluent conditions from Unit 3 vent releases reach 95,000 mCi/sec, releases from Units 1 and 2 vents, Unit 3 ESF vent and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded. Use Section II.D.1.a. and Section 4.2 of MP---22---REC---REF03, REMODCM Technical Information Document, in making this determination.

The alarm setpoint shall be set at or below the monitor reading corresponding to the Unit 3 vent portion of the limit. The setpoint shall be set at or below 8.4 x 10 ---4 mCi/cc.

8. Unit 3 Engineering Safeguards Building Monitor --- HVQ---RE49 For releases from Unit 3 ESF vent, the allocated portion of the site instantaneous release rate limit is 2,900 mCi/sec. This applies 1% of the Unit 3 Vent release rate limit (see Section II.D.1.a.) to Unit 3 ESF vent releases.

If effluent conditions from Unit 3 ESF vent releases reach 2,900 mCi/sec, releases from Units 1 and 2 vents, Unit 3 vent and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded. Use Section II.D.1.a. and Section 4.2 of MP---22---REC---REF03, REMODCM Technical Information Document, in making this determination.

The Alarm setpoint shall be set at or below the value of 5.9E---4 mCi/cc. This setpoint assumes a monitor flow rate of 10,500 cfm. However, only 6,000 cfm is monitored. By assuming 10,500 cfm the setpoint is conservatively low.

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APPENDIX II.A REMODCM METHODOLOGY CROSS---REFERENCES Radiological effluent controls (Sections III, IV, and V) identify the requirements for monitoring and limiting liquid and gaseous effluents releases from the site such the resulting dose impacts to members of the public are kept to As Low As Reasonably Achievable (ALARA). The demonstration of compliance with the dose limits is by calculational models that are implemented by Section II of the REMODCM.

Table App. II.A---1 provides a cross---reference guide between liquid and gaseous effluent release limits and those sections of the REMODCM, which are used to determine compliance. It also shows the administrative Technical Specifications which reference the REMODCM for operation of radioactive waste processing equipment. This table also provides a quick outline of the applicable limits or dose objectives and the required actions if those limits are exceeded. Details of the effluent control requirements and the implementing sections of the REMODCM should be reviewed directly for a full explanation of the requirements.

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Table II.A.---1 Millstone Effluent Requirements and Methodology Cross Reference Radiological REMODCM Applicable Limit or Exposure Required Action Effluent Controls & Methodology Objective Period Technical Section Specifications IV/V.E.1.a Tables I.C.---2 Ten times 10CFR20App.B, Instantaneous Restore concentration to within lim-Liquid Effluent and I.C.--- 3 Table 2, Column 2, & 2x10 ---4 its within 15 mins.

Concentration mCi/mL for dissolved noble gases*

IV/V.E.1.b II.C.1. 1.5 mrem T.B. Calendar Quar- 30--- day report if exceeded. Relative Dose--- Liquids 5 mrem Organ ter** accuracy or conservatism of the cal-culations shall be confirmed by per-II.C.1. 3 mrem T.B. Calendar Year formance of the REMP in Section I.

10 mrem Organ T.S. 6.16 & 6.20(Unit 2) I.C.2. 0.06 mrem T.B. Projected for 31 Return to operation Liquid Waste T.S. 6.14 & 6.15 (Unit 3) II.C.2. 0.2 mrem Organ days (if system Treatment System Liquid Radwaste Treat- not in use) ment III.D.2.a Tables I.D.--- 1, 500 mrem/yr T.B. from Instantaneous Restore release rates to within spec-IV/V.D.2.a I.D.--- 2, & noble gases* ifications within 15 minutes T.S. 6.20 (Unit 2) I.D--- 3 T.S. 6.15 (Unit 3) II.D.1.a. 3000 mrem/yr skin from Gaseous Effluents Dose noble gases*

Rate II.D.1.b. 1500 mrem/yr organ from particulates with T1/2 > 8d.,

I-131, I-133 & tritium*

III.D.2.b II.D.2. 5 mrad gamma air Calendar Quar- 30--- day report if exceeded IV/V.D.2.bDose Noble 10 mrad beta air ter**

Gases 10 mrad gamma air Calendar Year 20 mrad beta air III.D.2.c II.D.3. 7.5 mrem organ Calendar Quar- 30--- day report if exceeded. Relative IV/V.D.2.c ter** accuracy or conservatism of the cal-Dose I-131, I-133, Par- culations shall be confirmed by per-ticulates, H-3 15 mrem organ Calendar Year formance of the REMP in Section I.

T.S. 5.6.4 (Unit 1) II.D.2. >0.02 mrad gamma air Projected for 31 Return to operation Gaseous Rad-T.S. 6.14 (Unit 2) II.D.4. >0.04 mrad beta air Days (if system waste Treatment System T.S 6.14 & T.S 6.15 (U3) >0.03 mrem organ not in use)

Gaseous Radwaste Treatment II.E II.D.5. 25 mrem T.B.* 12 Consecutive 30--- day report if Unit 1 Effluent IVI /V.F 25 mrem organ* Months** Control III.D.1.2, III.D.2.2, or Total Dose 75 mrem thyroid* III.D.2.3 or Units 2/3 Effluent Con-trol IV/V.E.1.2, IV/V.E.2.2, or IV/

V.E.2.3 are exceeded by a factor of

2. Restore dose to public to within the applicable EPA limit(s) or ob-tain a variance NOTE: T.B. means total or whole body.

• Applies to the entire site (Units 1, 2, and 3) discharges combined.

• • Cumulative dose contributions calculated once per 31 days.

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SECTION III.

Millstone Unit 1 Radiological Effluent Controls Docket Nos. 50---245 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 79 of 135

SECTION III. REMODCM UNIT ONE CONTROLS III.A. Introduction The purpose of this section is to provide the following for Millstone Unit One:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub---sections in Sections I and II as part of their required actions III.B. Definitions and Surveillance Requirement (SR) Applicability III.B.1 --- Definitions The defined terms of this sub---section appear in capitalized type and are applicable throughout Section III.

1. ACTION --- that part of a Control that prescribes remedial measures required under designated conditions.

2. INSTRUMENT CALIBRATION --- the adjustment, as necessary, of the instrument output such that it responds within the necessary range and accuracy to know values of the parameter that the instrument monitors. The INSTRUMENT CALIBRATION shall encompass those components, such as sensors, displays, and trip functions, required to perform the specified safety function(s). The INSTRUMENT CALIBRATION shall include the INSTRUMENT FUNCTIONAL TEST and may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is calibrated.

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3. INSTRUMENT FUNCTIONAL TEST --- the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify that the instrument is FUNCTIONAL, including all components in the channel, such as alarms, interlocks, displays, and trip functions, required to perform the specified safety function(s). For digital instruments, the computer database may be manipulated, in lieu of a signal injection, to verify operability of alarm and/or trip functions. The INSTRUMENT FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested.

4. CHANNEL CHECK --- the qualitative determination of functionality by observation of behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.

5. FUNCTIONAL --- An instrument shall be FUNCTIONAL when it is capable of performing its specified functions(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).

6. REAL MEMBER OF THE PUBLIC --- an individual, not occupationally associated with the Millstone site, who is exposed to existing dose pathways at one particular location. This does not include employees of the utility or utilities which own a Millstone plant and utility contractors and vendors.

Also excluded are persons who enter the Millstone site to service equipment or to make deliveries. This does include persons who use portions of the Millstone site for recreational, occupational, or other purposes not associated with any of the Millstone plants.

7. SITE BOUNDARY --- that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

8. SOURCE CHECK --- the qualitative assessment of channel response when the channel is exposed to radiation.

9. RADIOACTIVE WASTE TREATMENT SYSTEMS --- Radioactive Waste Treatment Systems are those liquid, gaseous, and solid waste systems which are required to maintain control over radioactive materials in order to meet the controls set forth in this section.

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III.B.2 --- Surveillance Requirement (SR) Applicability

1. SRs shall be met during specific conditions in the Applicability for individual LCOs unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in III.B.2 3.

Surveillances do not have to be performed on nonfunctional equipment or variables outside specified limits.

2. The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the frequency is met.

3. If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LCO not met may be delayed from the time of discovery up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is less. This delay period is permitted to allow performance of the surveillance. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met and the applicable Condition(s) must be entered. The Completion Times of the Required Actions begin immediately upon expiration of the delay period. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met and the applicable Condition(s) must be entered. The Completion Times of the Required Actions begin immediately upon failure to meet the Surveillance.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 82 of 135

III.C. Radioactive Effluent Monitoring Instrumentation

1. Radioactive Liquid Effluent Monitoring Instrumentation CONTROLS The radioactive liquid effluent monitoring instrumentation channels shown in Table III.C.---1 shall be FUNCTIONAL with applicable alarm/trip setpoints set to ensure that the limits of Specification III.D.1.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II.

APPLICABILITY: As shown in Table III.C.---1 ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels FUNCTIONAL requirement, take the action shown in Table III.C.---1.

Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table III.C.---2.

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TABLE III.C.---1 Radioactive Liquid Effluent Monitoring Instrumentation Instrument Action when not functional Notes

1. Liquid Waste Effluent Monitor (RE---M6---110) A 1, 2

1. Whenever the pathway is being used except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.

2. Alarm setpoint required.

Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

(1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C---1 and; (2) The original release rate calculations and discharge valving are independently verified by a second individual.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 84 of 135

TABLE III.C.---2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Source Channel Channel Check Check Calibration Functional Test

1. Liquid Waste Effluent Monitor (RE---M6---110) D* P T(1) Q D = Daily P = Prior to each batch release T = Once every two years Q = Once every 3 months

• During releases via this pathway and when the monitor is required FUNCTIONAL per Table III.C.---1. The CHANNEL CHECK should be done when the discharge is in progress.

(1) Calibration shall include the use of a radioactive liquid or solid source which is traceable to an NIST source.

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2. Radioactive Gaseous Effluent Monitoring Instrumentation CONTROLS The radioactive gaseous effluent monitoring instrumentation channels shown in Table III.C.---3 shall be FUNCTIONAL with applicable alarm setpoints set to ensure that the limits of Control III.D.2.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II.F.1.

APPLICABILITY: As shown in Table III.C.---3 ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel alarm setpoint less conservative than required by the above Control, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels functional requirements, take the action shown in Table III.C.---3. Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radiological Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the INSTRUMENT CHECK, INSTRUMENT CALIBRATION, INSTRUMENT FUNCTIONAL TEST, and SOURCE CHECK operations at the frequencies shown in Table III.C.---4.

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TABLE III.C.---3 Radioactive Gaseous Effluent Monitoring Instrumentation Instrument Action when not functional Notes 1.Spent Fuel Pool Island Vent (a) Noble Gas Radioactivity Monitor A 1, 2 (b) Particulate Sampler B 1 (c) Vent Flow Rate Monitor C 1 (d) Sampler Flow Rate Monitor D 1, 2 2.Balance of Plant Vent (a) Particulate Sampler B 1 (b) Sampler Flow Monitor D 1

1. Channels are FUNCTIONAL and in service on a continuous, uninterrupted basis when exhaust fans are operating, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required tests, checks, calibrations, and sampling associated with the instrument or any system or component which affects functioning of the instrument.

2. Alarm setpoint required.

ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken daily when fuel is being moved, or during any evolution or event which would threaten fuel integrity, and these samples are analyzed for gamma radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Action B With the number of samplers FUNCTIONAL less than required by the Minimum number FUNCTIONAL requirement, effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration sample is collected with auxiliary sampling equipment once every seven (7) days, or anytime significant generation of airborne radioactivity is expected, and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the end of the sampling period.

Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours.

Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument.

Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once during the Chemistry compensatory sampling time period as specified in Action A or Action B. Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use.

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TABLE III.C.---4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Instrument Functional Source Check Calibration Test Check 1.Spent Fuel Pool Island Vent (a) Noble Gas Radioactivity Monitor D(3) T(6) Q(7) M (b) Particulate Sampler TM NA NA NA (c) Vent Flow Rate Monitor D T NA NA (d) Sampler Flow Rate Monitor D T NA NA 2.Balance of Plant Vent (a) Particulate Sampler TM NA NA NA (b) Sampler Flow Monitor D T NA NA D = Daily W = Weekly TM = Twice per month M = Monthly Q = Once every 3 months T = Once every two years NA = Not Applicable Table III.C.---4 TABLE NOTATION (1) RESERVED (2) RESERVED (3) Instrument check daily only when there exist releases via this pathway.

(4) RESERVED (5) RESERVED (6) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to a source which is traceable to the NIST. These sources shall be in a known reproducible geometry.

(7) The INSTRUMENT FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

1. Instrument indicates measured levels above the alarm/trip setpoint.

2. Instrument indicates a downscale failure.

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III.D. Radioactive Effluents Concentrations And Dose Limitations

1. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATIONS The concentration of radioactive material released from the site (see Figure III.D.---1) shall not exceed ten times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 10-4 mCi/ml total radioactivity.

APPLICABILITY: At all times.

ACTION:

With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes.

SURVEILLANCE REQUIREMENT Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I.

The results of the radioactive analysis shall be used in accordance with the methods of Section II.E to assure that the concentrations at the point of release are maintained within the limits of Specification III.D.1.a.

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b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATIONS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 1 released from the site (see Figure III.D.---1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and,

b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times ACTION:

a. 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) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 90 of 135

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate CONTROLS The dose rate, at any time, offsite (See Figure III.D.---1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and,

b. The dose rate limit for Tritium and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

APPLICABILITY: At all times.

ACTION:

With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Control III.D.2.a. within 15 minutes.

SURVEILLANCE REQUIREMENT

1) The release rate, at any time, corresponding to the above dose rates shall be determined in accordance with the methodology of Section II.

2) The release rate, at any time shall be monitored in accordance with the requirements of Section III.C.2.

3) Sampling and analysis shall be performed in accordance with Section I to assure that the limits of Control III.D.2.a. are met.

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b. Radioactive Gaseous Effluents Noble Gas Dose CONTROLS The air dose offsite (see Figure III.D.---1) due to noble gases released in gaseous effluents from Unit 1 shall be limited to the following:

a. During any calendar quarter, to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;

b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY: At all times.

ACTION:

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 reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

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c. Gaseous Effluents --- Dose from Radionuclides Other than Noble Gas CONTROLS The dose to any REAL MEMBER OF THE PUBLIC from Tritium and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 1 (see Figure III.D.---1) shall be limited to the following:

a. During any calendar quarter to less than or equal to 7.5 mrem to any organ;

b. During any calendar year to less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of Tritium and radioactive materials in particulate form 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 to be taken to reduce the releases of radioactive materials in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

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Figure III.D.---1, Site Boundary for Liquid and Gaseous Effluents MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 94 of 135

III.E. Total Radiological Dose From Station Operations Controls CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which is limited to less than or equal to 75 mrem).

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls III.D.1.b., III.D.2.b. or III.D.2.c. prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site 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 from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR 190 Standard.

If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR 190.

Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days.

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SECTION IV.

Millstone Unit 2 Radiological Effluent Controls Docket Nos. 50---336 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 96 of 135

SECTION IV. REMODCM UNIT TWO CONTROLS IV.A. Introduction The purpose of this section is to provide the following for Millstone Unit Two:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub---sections in Sections I and II as part of their required actions.

IV.B. Definitions, Applicability and Surveillance Requirements IV.B.1 --- Definitions The defined terms of this sub---section appear in capitalized type and are applicable throughout Section IV.

1. ACTION --- Those additional requirements specified as corollary statements to each principal control and shall be part of the control.

2. FUNCTIONAL / FUNCTIONALITY --- An instrument shall be FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation, controls, normal and emergency electrical power sources, or other auxiliary equipment that are required for the instrument to perform its functions are also capable of performing their related support functions.

3. CHANNEL CALIBRATION --- A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to know values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

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4. CHANNEL CHECK --- A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

5. CHANNEL FUNCTIONAL TEST --- A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify FUNCTIONALITY including alarm and/or trip functions. For digital instruments, the computer database may be manipulated, in lieu of a signal injection, to verify functionality of alarm and/or trip functions.

6. SOURCE CHECK --- A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.

7. MEMBER(S) OF THE PUBLIC --- MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant.

This category does not include employees of the utility, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

The term REAL MEMBER OF THE PUBLIC means an individual who is exposed to existing dose pathways at one particular location.

8. MODE --- Refers to Mode of Operation as defined in Safety Technical Specifications.

9. SITE BOUNDARY --- The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

10. UNRESTRICTED AREA --- Any area at or beyond the site boundary to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the site boundary used for residential quarters or industrial, commercial, institutional and/or recreational purposes.

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11. DOSE EQUIVALENT I---131 --- DOSE EQUIVALENT I---131 shall be that concentration of I---131 (mCi/gram) which alone would produce the same CDE---thyroid dose as the quantity and isotopic mixture of I---131, I---132, I---133, I---134, and I---135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed under Inhalation in Federal Guidance Report No. 11 (FGR 11), Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion.

IV.B.2 --- Applicability IV.B.2a --- LIMITING CONDITIONS FOR OPERATION

1. Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

2. Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Condition IV.B.2.a(6). If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3. NOT USED.

4. NOT USED.

5. When a system, subsystem, train, component or device is determined to be nonfunctional solely because its emergency power source is nonfunctional, or solely because its normal power source is nonfunctional, it may be considered FUNCTIONAL for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is FUNCTIONAL; and (2) all of its redundant system(s), subsystem(s), train(s), component(s) and device(s) are FUNCTIONAL, or likewise satisfy the requirements of this specification.

6. Equipment removed from service or declared nonfunctional to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its FUNCTIONALITY or the FUNCTIONALITY of other equipment. This is an exception to Condition IV.B.2.a(2) for the system returned to service under administrative control to perform the testing required to demonstrate FUNCTIONALITY.

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IV.B2.b --- SURVEILLANCE REQUIREMENTS

1. Surveillance Requirements shall be applicable during any condition specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

2. Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance time interval.

3. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Condition IV.B2.b(2), shall constitute a failure to meet the FUNCTIONALITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillance Requirements do not have to be performed on nonfunctional equipment.

4. Entry into any specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.

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IV.C. Radioactive Effluent Monitoring Instrumentation

1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATIONS The radioactive liquid effluent monitoring instrumentation channels shown in Table IV.C.---1 shall be FUNCTIONAL with applicable alarm/trip setpoints set to ensure that the limits of Specification IV.D.1.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II.

APPLICABILITY: As shown in Table IV.C.---1 ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels FUNCTIONAL requirement, take the action shown in Table IV.C.---1.

Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C.---2.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 101 of 135

TABLE IV.C.---1 Radioactive Liquid Effluent Monitoring Instrumentation Action when not Instrument Notes functional 1.Gross Radioactivity Monitors Providing Alarm and Automatic Termination Of Release (a)Clean and Aerated Liquid Waste Discharge A 1 (b)Steam Generator Blowdown Monitor B 2 (c)Condensate Polishing Facility Waste Neut Sump E 2 2.Gross Radioactivity Monitors Providing Alarm and Not Providing Automatic Termination Of Release (a)Reactor Building Closed Cooling Water Monitor C 1 3.Flow Rate Measurements --- No Alarm Setpoint Requirements (a)Clean Liquid Radwaste Effluent Line D 1 (b)Aerated Liquid Radwaste Effluent Line D 1 (c) Condensate Polishing Facility Effluent Line D 1

1. Required to be functional at all times --- which means that channels shall be FUNCTIONAL and in service on a continuous, uninterrupted basis, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument.

2. Required to be functional whenever the discharge pathway is being used except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument.

ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

(1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C.---2, and; (2) The original release rate calculations and discharge valving are independently verified by a second individual.

Action B With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, either:

(1) Suspend all effluent releases via this pathway, or MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 102 of 135

(2) Make best efforts to repair the instrument and obtain grab samples and analyze for gamma radioactivity as specified in Table I.C.---2; a) Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the secondary coolant is greater than 0.01 mCi/gm DOSE EQUIVALENT I---131.

b) Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the specific activity of the secondary coolant is less than or equal to 0.01 mCi/gm DOSE EQUIVALENT I---131.

Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples of the service water effluent are collected and analyzed for gamma radioactivity at LLD as specified in Table I.C.---2; Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. Pump performance curves may be used to estimate flow.

Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

(1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C.---2, and; (2) If one of the samples has gamma radioactivity greater than any of the LLDs in Table I.C.---2, the original release rate calculations and discharge valving are independently verified by a second individual.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 103 of 135

TABLE IV.C.---2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Source Channel Channel Check Check Calibration Functional Test 1.Gross Radioactivity Monitors Providing Alarm and Automatic Termination Of Release

a. Clean and Aerated Liquid Waste D* P R(1) Q(2)

Discharge

b. Steam Generator Blowdown Monitor D* M R(1) Q(2) c.Condensate Polishing Facility Waste D* P R(1) Q(2)

Neut Sump 2.Gross Radioactivity Monitors Providing Alarm But Not Providing Automatic Termination Of Release

a. Reactor Building Closed Cooling D* M R(1) Q(2)

Water Monitor 3.Flow Rate Measurements

a. Clean Liquid Radwaste Effluent Line D* N/A R Q

b. Aerated Liquid Radwaste Effluent D* N/A R Q Line

c. Condensate Polishing Facility Waste D* N/A R Q Neut Sump D = Daily R = Once every 18 months M = Monthly Q = Once every 3 months P = Prior to each batch release N/A= Not Applicable TABLE IV.C.---2 TABLE NOTATION

• During releases via this pathway and when the monitor is required FUNCTIONAL per Table IV.C.---1. The CHANNEL CHECK should be done when the discharge is in progress.

(1) Calibration shall include the use of a radioactive liquid or solid source which is traceable to an NIST source.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

a) Instrument indicates measured levels above the alarm/trip setpoint.

b) Instrument indicates a downscale or circuit failure.

--- Automatic isolation of the discharge stream shall also be demonstrated for this case for each monitor except the reactor building closed cooling water monitor.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 104 of 135

2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATIONS The radioactive gaseous effluent monitoring instrumentation channels shown in Table IV.C.---3 shall be FUNCTIONAL with applicable alarm setpoints set to ensure that the limits of Specifications IV.D.2.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II.

APPLICABILITY: As shown in Table IV.C.---3 ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel alarm setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.

b. With the number of channels less than the minimum channels FUNCTIONAL requirement, take the action shown in Table IV.C.---3.

Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C.---4.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 105 of 135

TABLE IV.C.---3 Radioactive Gaseous Effluent Monitoring Instrumentation Action when not Instrument Notes functional 1.MP2 Vent (normal range, RM---8132 only; high range monitor, RM---8168, requirements are in the TS)

a. Noble Gas Radioactivity Monitor A 1, 3

b. Iodine Sampler B 1

c. Particulate Sampler B 1

d. Vent Flow Rate Monitor C 1

e. Sampler Flow Rate Monitor C 1 2.Millstone Stack --- applicable to the WRGM (RM---8169, normal range, channel 1, only; mid range channel 2 and high range channel 3 requirements are contained in TRM LCO 3.3.3.8)

a. Noble Gas Radioactivity Monitor E 1, 3

b. Iodine Sampler B 1

c. Particulate Sampler B 1

d. Stack Flow Rate Monitor C 1

e. Sampler Flow Rate Monitor C 1 3.Waste Gas Holdup System

a. Noble Gas Monitor Providing Automatic Termination of D 2, 4 Release 1 Required to be functional at all times when air is being released to the environment by the pathway being monitored. The channel shall be FUNCTIONAL and in service on a continuous, uninterrupted basis. Outages are permitted for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument.

2 Required to be functional during waste gas holdup system discharge.

3 Alarm setpoint with required. Automatic isolation feature is not required.

4 Alarm setpoint required. Automatic isolation feature is required.

ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gamma radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the monitor flow and readout are not adversely affected by the loss of functionality, the daily CHANNEL CHECK may be performed in lieu of the grab sample.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 106 of 135

Action B With the number of samplers FUNCTIONAL less than required by the Minimum number FUNCTIONAL requirement, effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that effluent is continuously sampled with auxiliary sampling equipment and collected at least once per seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of initiation of this action statement. Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. Auxiliary sampling outages are permitted for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling.

Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use.

Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement:

Releases from the Millstone Unit 2 waste gas system may continue provided that best efforts are made to repair the instrument and that prior to initiating the release:

a) At least two independent samples of the tanks contents are analyzed; and b) The original release rate calculations and discharge valve lineups are independently verified by a second individual. Otherwise, suspend releases from the waste gas holdup system.

Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, Millstone Unit 2 releases via the Millstone Stack may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gamma radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the monitor flow and readout are not adversely affected by the loss of functionality, the daily CHANNEL CHECK may be performed in lieu of the grab sample.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 107 of 135

TABLE IV.C.---4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Channel Channel Source Channel Instrument Functional Check Check Calibration Test 1.MP2 Vent (normal range, RM---8132 only; high range monitor, RM---8168, requirements are in the TS)

a. Noble Gas Radioactivity Monitor D M R(1) Q(2)

b. Iodine Sampler W NA NA NA

c. Particulate Sampler W NA NA NA

d. Vent Flow Rate Monitor D NA R Q

e. Sampler Flow Rate Monitor D NA R NA 2.Millstone Stack --- applicable to the WRGM (RM---8169, normal range, channel 1, only; mid range channel 2 and high range channel 3 requirements are contained in TRM LCO 3.3.3.8)

a. Noble Gas Radioactivity Monitor D M R(1) Q(2)

b. Iodine Sampler W NA NA NA

c. Particulate Sampler W NA NA NA

d. Stack Flow Rate Monitor D NA R Q

e. Sampler Flow Rate Monitor D NA R NA 3.Waste Gas Holdup System

a. Noble Gas Monitor D* P R(1) Q(2)

• During releases via this pathway and when the monitor is required FUNCTIONAL per Table IV.C.---3. The CHANNEL CHECK should be performed when the discharge is in progress.

P = Prior to discharge R = Once every 18 months D = Daily Q = Once every 3 months W = Weekly NA= Not Applicable M = Monthly TABLE IV.C.---4 TABLE NOTATION (1) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to a source which is traceable to the NIST. These sources shall be in a known, reproducible geometry.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation* occurs if any of the following conditions exist:

a) Instrument indicates measured levels above the alarm/trip setpoint.

b) Instrument indicates a downscale failure.

• --- Also demonstrate automatic isolation for the waste gas system noble gas monitor.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 108 of 135

IV.D. Radioactive Effluents Concentrations And Dose Limitations

1. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATIONS The concentration of radioactive material released from the site (see Figure IV.D.---1) shall not exceed ten times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 10-4 mCi/ml total radioactivity.

APPLICABILITY: At all times.

ACTION:

With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes.

SURVEILLANCE REQUIREMENTS

1) Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I.

2) The results of the radioactive analysis shall be used in accordance with the methods of Section II.E to assure that the concentrations at the point of release are maintained within the limits of Specification IV.D.1.a.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 109 of 135

b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATIONS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 2 released from the site (see Figure IV.D.---1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and,

b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. 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) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations. Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in Section II at least once per 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 110 of 135

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS OF OPERATIONS The dose rate, at any time, offsite (see Figure IV.D.---1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and,

b. The dose rate limit for Iodine---131, Iodine---133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

APPLICABILITY: At all times.

ACTION:

With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Specification IV.D.2.a. within 15 minutes.

SURVEILLANCE REQUIREMENTS

1) The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established above in Specification IV.D.2.a. The corresponding release rate shall be determined in accordance with the methodology of Section II.

2) The noble gas effluent monitors of Table IV.C.---3 shall be used to control release rates to limit offsite doses within the values established in Specification IV.D.2.a.

3) The release rate of Iodine---131, Iodine---133, tritium and for all radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Section I. The corresponding dose rate shall be determined using the methodology given in Section II.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 111 of 135

b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS OF OPERATIONS The air dose offsite (see Figure IV.D.---1) due to noble gases released in gaseous effluents from Unit 2 shall be limited to the following:

a. During any calendar quarter, to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;

b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY: At all times.

ACTION:

a. 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 reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 112 of 135

c. Gaseous Effluents --- Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS OF OPERATIONS The dose to any REAL MEMBER OF THE PUBLIC from Iodine---131, Iodine---133, Tritium, C---14, and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 2 (see Figure IV.D.---1) shall be limited to the following:

a. During any calendar quarter to less than or equal to 7.5 mrem to any organ;

b. During any calendar year to less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than 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 and defines the corrective actions to be taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 113 of 135

Figure IV.D.---1, Site Boundary for Liquid and Gaseous Effluents MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 114 of 135

IV.E. Total Radiological Dose From Station Operation CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which is limited to less than or equal to 75 mrem).

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls IV.D.2.a., IV.D.1.b., or IV.D.2.c. prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site 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 from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR 190.

If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR 190.

Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 115 of 135

SECTION V.

Millstone Unit 3 Radiological Effluent Controls Docket Nos. 50---423 MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 116 of 135

SECTION V. REMODCM UNIT THREE CONTROLS V.A. Introduction The purpose of this section is to provide the following for Millstone Unit Three:

a. the effluent radiation monitor controls and surveillance requirements,

b. the effluent radioactivity concentration and dose controls and surveillance requirements, and

c. the bases for the controls and surveillance requirements.

Definitions of certain terms are provided as an aid for implementation of the controls and requirements.

Some surveillance requirements refer to specific sub---sections in Sections I and II as part of their required actions.

V.B. Definitions and Applicability and Surveillance Requirements V.B.1 --- Definitions The defined terms of this sub---section appear in capitalized type and are applicable throughout Section V.

1. ACTION --- ACTION shall be that part of the control which prescribes remedial measures required under designated conditions.

2. CHANNEL FUNCTIONAL TEST --- A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify FUNCTIONALITY of alarm, interlock and/or trip functions. For digital instruments, the computer database may be manipulated, in lieu of a signal injection, to verify functionality of alarm and/or trip functions.

The CHANNEL FUNCTIONAL TEST shall include adjustments, as necessary, of the alarm, interlock and/or trip setpoints such that the setpoints are within the required range and accuracy.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 117 of 135

3. CHANNEL CALIBRATION --- A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel such that it responds within the required range and accuracy to known values of input. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm, interlock and/or trip functions and may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

4. CHANNEL CHECK --- A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.

5. DOSE EQUIVALENT I---131 --- DOSE EQUIVALENT I---131 shall be that concentration of I---131 (mCi/gram) which alone would produce the same CDE---thyroid dose as the quantity and isotopic mixture of I---131, I---132, I---133, I---134, and I---135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed under Inhalation in Federal Guidance Report No. 11 (FGR 11), Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion.

6. MEMBER(S) OF THE PUBLIC --- MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant.

This category does not include employees of the licensee, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

The term REAL MEMBER OF THE PUBLIC means an individual who is exposed to existing dose pathways at one particular location.

7. MODE --- Refers to Mode of Operation as defined in Safety Technical Specifications.

8. FUNCTIONAL --- FUNCTIONALITY --- An instrument shall be FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation, controls, electrical power, or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).

9. SITE BOUNDARY --- The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.

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10. SOURCE CHECK --- A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.

11. UNRESTRICTED AREA --- Any area at or beyond the SITE BOUNDARY to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the SITE BOUNDARY used for residential quarters or industrial, commercial, institutional and/or recreational purposes.

V.B.2 --- Applicability V.B.2.a --- LIMITING CONDITIONS FOR OPERATION

1. Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

2. Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

V.B.2.b --- SURVEILLANCE REQUIREMENTS

1. Surveillance Requirements shall be applicable during any condition specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

2. Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance time interval.

3. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Condition V.B.2.b(2), shall constitute a failure to meet the FUNCTIONALITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillance Requirements do not have to be performed on nonfunctional equipment.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 119 of 135

4. Entry into any specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.

V.C. Radioactive Effluent Monitoring Instrumentation

1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATION The radioactive liquid effluent monitoring instrumentation channels shown in Table V.C.---1 shall be FUNCTIONAL with their Alarm/Trip setpoints set to ensure that the limits of Specification V.D.1.a are not exceeded. The alarm/trip setpoints shall be determined in accordance with methodology and parameters as described in Section II.

APPLICABILITY: As shown in Table V.C.---1 ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.

b. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels FUNCTIONAL, take the action shown in Table V.C.---1. Exert best efforts to restore the nonfunctional instrumentation to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL OPERATIONAL TEST at the frequencies shown in Table V.C.---2.

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TABLE V.C.---1 Radioactive Liquid Effluent Monitoring Instrumentation Action when Instrument Notes not functional 1.Radioactivity Monitors Providing Alarm and Automatic Termination Of Release

a. Waste Neutralization Sump Monitor Condensate Polishing D 2 Facility

b. Turbine Building Floor Drains B 1

c. Liquid Waste Monitor A 1

d. RESERVED

e. Steam Generator Blowdown Monitor B 3 2.Flow Rate Measurement Devices --- No Alarm Setpoint Requirements

a. Waste Neutralization Sump Effluents C 1

b. RESERVED

c. Liquid Waste Effluent Line C 1

d. RESERVED

e. Steam Generator Blowdown Effluent Line C 3 1 Required to be functional at all times --- which means that channels shall be FUNCTIONAL and in service on a continuous, uninterrupted basis, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument.

2 Required to be functional in MODEs 1---5, and MODE 6 when discharge pathway is being used, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument.

The monitor must be on-line with no unexpected alarms.

3 Required to be functional whenever the discharge pathway is being used, except that outages are permitted, for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument. The monitor must be on-line with no unexpected alarms.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 121 of 135

TABLE V.C.---1 ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

1. At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C---3, and;

2. The original release rate calculations and discharge line valving are independently verified by a second individual.

Action B With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided best efforts are made to repair the instrument and that grab samples are analyzed for gamma radioactivity specified in Table I.C.---3:

1. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the secondary coolant is greater than 0.01 mCi/gram DOSE EQUIVALENT I---131, or

2. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the specific activity of the secondary coolant is less than or equal to 0.01 mCi/gram DOSE EQUIVALENT I---131.

Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. Pump performance curves may be used to estimate flow.

Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release:

1. At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C---3, and;

2. If one of the samples has gamma radioactivity greater than any of the lower limits of detection specified in Table I.C.---3, the original release rate calculations and discharge valving are independently verified by a second individual.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 122 of 135

TABLE V.C.---2 Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Source Channel Channel Check Check Calibration Functional Test 1.Radioactivity Monitors Providing Alarm and Automatic Termination Of Release

a. Waste Neutralization Sump Monitor D P R(2) Q(1)

Condensate Polishing Facility

b. Turbine Building Floor Drains D M R(2) Q(1)

c. Liquid Waste Monitor D P R(2) Q(1)

d. Deleted

e. Steam Generator Blowdown Monitor D M R(2) Q(1) 2.Flow Rate Measurements

a. Waste Neutralization Sump Effluents D(3) NA R Q

b. RESERVED

c. Liquid Waste Effluent Line D(3) N/A R Q

d. Deleted

e. Steam Generator Blowdown Effluent D(3) N/A R Q Line D = Daily R = Once every 18 months M = Monthly Q = Once every 3 months P = Prior to each batch release N/A= Not Applicable TABLE V.C.---2 TABLE NOTATION (1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occur if any of the following conditions exists:

a) Instrument indicates measured levels above the alarm/trip setpoint, or b) Circuit failure (Alarm only), or Instrument indicates a downscale failure (Alarm only).

(2) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used.

(3) CHANNEL CHECK shall consist of verifying indication of flow during periods of release.

CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on days on which continuous, periodic, or batch releases are made.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 123 of 135

2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATION The radioactive gaseous effluent monitoring instrumentation channels shown in Table V.C.---3 shall be FUNCTIONAL with their Alarm Setpoints set to ensure that the limits of Specification V.D.2.a. are not exceeded. The Alarm Setpoints of these channels shall be determined in accordance with the methodology and parameters in Section II.

APPLICABILITY: As shown in Table V.C.---3.

ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm Setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.

b. With the number of FUNCTIONAL radioactive gaseous effluent monitoring instrumentation channels less than the Minimum Channels FUNCTIONAL, take the ACTION shown in Table V.C.---3. Exert best efforts to restore the nonfunctional instrumentation to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.

SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST at the frequencies shown in Table V.C.---4.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 124 of 135

TABLE V.C.---3 Radioactive Gaseous Effluent Monitoring Instrumentation Action when Instrument Notes not functional 1.Millstone Unit 3 Ventilation Vent (Turbine Building --- HVR---RE10B, normal range only; high range monitor, HVR---RE10A, requirements are in the TRM)

a. Noble Gas Radioactivity Monitor Providing Alarm A 1, 2

b. Iodine Sampler B 1, 2

c. Particulate Sampler B 1, 2

d. Vent Flow Rate Monitor C 1, 2

e. Sampler Flow Rate Monitor C 1 2.Millstone Stack --- applicable to SLCRS (HVR---RE19B, normal range only; high range monitor, HVR---RE19A, requirements are in the TRM)

a. Noble Gas Radioactivity Monitor Providing Alarm A 1, 2

b. Iodine Sampler B 1, 2

c. Particulate Sampler B 1, 2

d. Process Flow Rate Monitor C 1, 2

e. Sampler Flow Rate Monitor C 1 3.Engineered Safeguards Building Monitor (HVQ---RE49)

a. Noble Gas Radioactivity Monitor D 1

b. Iodine Sampler B 1

c. Particulate Sampler B 1

d. Discharge Flow Rate Monitor E 1

e. Sampler Flow Rate Monitor C 1 TABLE V.C.---3 Table Notations 1 Instrument required to be functional whenever the release path is in service. Outages are permitted for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling associated with the instrument or any system or component which affects functioning of the instrument.

2 When the Ventilation Vent Flow Rate Monitor or Millstone Stack Process Flow Rate Monitor is nonfunctional because of degraded flow indication, the Noble Gas Monitor and Iodine and Particulate Samplers for the affected pathway (Ventilation Vent or Millstone Stack) remain functional as long as there is a minimum indicated process flow.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 125 of 135

TABLE V.C.---3 ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that a) best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gamma radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, OR b) if the cause of the nonfunctionality is solely due to a loss of annunciation in the control room and the Remote Indicating Controller (RIC) remains FUNCTIONAL, perform a channel check at the RIC at least once per twelve hours and verify the indication has not alarmed.

Action B With the number of samplers FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that effluent is continuously sampled with auxiliary sampling equipment at least once per seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after initiation of this ACTION statement. Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. Auxiliary sampling outages are permitted for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose of maintenance and performance of required tests, checks, calibrations, or sampling.

Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use.

Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and these samples are analyzed for gamma radioactivity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 126 of 135

TABLE V.C.---4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Source- Channel Channel When Check Check Calibra- Functional Surveil-tion Check lance is Required 1.Millstone Unit 3 Ventilation Vent (Turbine Building --- HVR---RE10B, normal range only; high range monitor, HVR---RE10A, requirements are in the TRM)

a. Noble Gas Radioactivity Monitor D M R(1) Q(2)

• Providing Alarm

b. Iodine Sampler W NA NA NA *

c. Particulate Sampler W NA NA NA *

d. Vent Flow Rate Monitor D NA R Q *

e. Sampler Flow Rate Monitor D NA R Q

• 2.Millstone Stack --- applicable to SLCRS (HVR---RE19B, normal range only; high range monitor, HVR---RE19A, requirements are in the TRM)

a. Noble Gas Radioactivity Monitor D M R(3) Q(2)

• Providing Alarm

b. Iodine Sampler W NA NA NA *

c. Particulate Sampler W NA NA NA *

d. Process Flow Rate Monitor D NA R Q *

e. Sampler Flow Rate Monitor D NA R Q

• 3.Engineered Safeguards Building Monitor (HVQ---RE49)

a. Noble Gas Radioactivity Monitor D M R(1) Q(2)

• Providing Alarm

b. Iodine Sampler W NA NA NA *

c. Particulate Sampler W NA NA NA *

d. Discharge Flow Rate Monitor D NA R Q *

e. Sampler Flow Rate Monitor D NA R Q *

• At all times except when the vent path is isolated.

D = Daily R = Once every 18 months W = Weekly Q = Once every 3 months M = Monthly N/A= Not Applicable MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 127 of 135

TABLE V.C.---4 Table Notations (1) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration shall be used.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

a) Instrument indicates measured levels above the Alarm Setpoint, or b) Circuit failure, or c) Instrument indicates a downscale failure.

(3) The CHANNEL CALIBRATION shall include the use of a known source whose strength is determined by a detector which has been calibrated to an NIST source. These sources shall be in know, reproducible geometry.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 128 of 135

V.D. Radioactive Effluents Concentrations And Dose Limitations

1. Radioactive Liquid Effluents

a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATION The concentration of radioactive material released from the site (see Figure V.D.---1) shall be limited to ten times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 10-4 mCi/ml total radioactivity.

APPLICABILITY: At all times.

ACTION:

With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes.

SURVEILLANCE REQUIREMENTS

1) Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I.

2) The results of the radioactive analysis shall be used in accordance with the methods of Section II.E to assure that the concentrations at the point of release are maintained within the limits of Specification V.D.1.a.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 129 of 135

b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 3 released from the site (see Figure V.D.---1) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and,

b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. 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) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations. Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in Section II at least once per 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 130 of 135

2. Radioactive Gaseous Effluents

a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS OF OPERATION The dose rate, at any time, offsite (see Figure V.D.---1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values:

a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and,

b. The dose rate limit due to inhalation for Iodine---131, Iodine---133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ.

APPLICABILITY: At all times.

ACTION:

With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Specification V.D.2.a. within 15 minutes.

SURVEILLANCE REQUIREMENTS

1) The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established in Specification V.D.2.a. The corresponding release rate shall be determined in accordance with the methodology of Section II.

2) The noble gas effluent monitors of TableV.C.---3 shall be used to control release rates to limit offsite doses within the values established in Specification V.D.2.a.

3) The release rate of Iodine---131, Iodine---133, tritium, and for all radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program, specified in Section I. The corresponding dose rate shall be determined using the methodology given in Section II.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 131 of 135

b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS OF OPERATION The air dose offsite (see Figure V.D.---1) due to noble gases released from Unit 3 in gaseous effluents shall be limited to the following:

a. During any calendar quarter: Less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation, and

b. During any calendar year: Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.

APPLICABILITY: At all times.

ACTION:

a. 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 reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 132 of 135

c. Gaseous Effluents --- Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS OF OPERATION The dose to any REAL MEMBER OF THE PUBLIC from Iodine---131, Iodine---133, Tritium, C---14, and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 3 released offsite (see Figure V.D.---1) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrem to any organ and,

b. During any calendar year: Less than or equal to 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

c. With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than 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 and defines the corrective actions to be taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit.

SURVEILLANCE REQUIREMENTS

1) Dose Calculations --- Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days.

2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 133 of 135

Figure V.D.---1, Site Boundary for Liquid and Gaseous Effluents MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 134 of 135

V.E. Total Radiological Dose From Station Operations CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ (except the thyroid, which is limited to less than or equal to 75 mrem).

APPLICABILITY: At all times.

ACTION:

With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls V.D.1.b., V.D.2.b., or V.D.2.c. prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site 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 from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR 190 Standard.

If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR 190.

Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days.

MP---22---REC---BAP01 STOP THINK ACT REVIEW Rev. 032 135 of 135