NL-05-054, Radioactive Effluent Release Report

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Radioactive Effluent Release Report
ML051180211
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/20/2005
From: Conroy P
Entergy Nuclear Northeast
To:
Document Control Desk, NRC/FSME
References
NL-05-054, RG-1.021
Download: ML051180211 (79)


Text

. II-,~1 El Entergy Nuclear Northeast Indian Point Energy Center

-Eteroy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration April 20, 2005 Indian Point Units 1, 2, and 3 Docket Nos. 50-3, 50-247, and 50-286 NL-05-054 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001

Subject:

2004 Radioactive Effluent Release Report

Dear Sir:

Enclosed is the 2004 Annual Effluent and Waste Disposal Report for Indian Point Unit Nos. 1, 2, and 3. Entergy Nuclear Operation, Inc. (Entergy) is submitting this report in accordance with Technical Specification 5.6.3 and Regulatory Guide 1.21 Entergy is making no new commitments in this letter. Should you have any questions regarding this matter, please contact Mr. Patric W. Conroy, Licensing Manager, at (914) 734-6668.

Sincerely, Patric W. C7 Licensing Manager Indian Point Energy Center cc: next page L I

Docket Nos. 50-3, 50-247 and 50-286 NL-05-054 Page 2 of 2

Enclosure:

2004 Radioactive Effluent Release Report cc: Mr. Samuel J. Collins Attn. Chief, Compliance Section Regional Administrator - Region I New York State DEC U.S. Nuclear Regulatory Commission Division of Water 475 Allendale Road 50 Wolf Road King of Prussia, PA 19406 Albany, NY 12233 Mr. Patrick D. Milano, Senior Project Manager Attn. Regional Water Engineer Division of Reactor Projects I/l1 New York State DEC U.S. Nuclear Regulatory Commission 200 White Plains Road Mail Stop O-8-C2 White Plains, NY 10601 Washington, D.C. 20555-0001 Resident Inspector's Office Mr. Paul Eddy U.S. Nuclear Regulatory Commission NYS Department of Public Service Indian Point 2 3 Empire Plaza P.O. Box 38 Albany, NY 12223 Buchanan, NY 10511-0038 Resident Inspector's Office Mr. Robert Oliveira U.S. Nuclear Regulatory Commission American Nuclear Insurers Indian Point 3 95 Glastonbury Blvd P.O. Box 337 Glastonbury, Conn 06033 Buchanan, NY 10511-0337

ENCLOSURE TO NL-05-054 Indian Point Energy Center 2004 RADIOACTIVE EFFLUENT RELEASE REPORT ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT 1, 2 AND 3 NUCLEAR POWER PLANTS DOCKET NOS. 50-3, 50-247 AND 50-286 DPR-26 AND 64

Docket No. 50-3, 50-247, & 50-286 Page 1 of 76 Radioactive Effluent Release Report: 2004 Facility Indian Point Energy Center (Indian Point Units 1, 2, and 3)

Licensee Entergy Nuclear Operations, Inc (Enter-iy)

This information is provided in accordance with the requirements of Regulatory Guide 1.21. The numbered sections of this report reference corresponding sections of the subject Regulatory Guide, pages 10 to 12. This report includes effluent information from Indian Point units 1, 2, and 3. Since units I and 2 share effluent processing equipment, Technical Specifications, and Offsite Dose Calculation Manuals, all curies and dose attributed to unit 1 in this report are included in the totals identified for unit 2.

A. Supplemental Information

1. Regulatory Limits Indian Point Energy Center is subject to limits on radioactive waste releases that are set forth in the Offsite Dose Calculation Manual, Parts I and 11,per the Technical Specifications. ODCM Part I, also known as the Radiological Effluent Controls (or RECS) is prescribed by Technical Specifications, along with ODCM Part II (calculational methodologies).
2. Maximum Permissible Concentration a) Airborne Releases Maximum concentrations and compliance with 10CFR20 release rate limits are controlled by the application of Radiation Monitor setpoints, preliminary grab sampling, and conservative procedural guidance for batch and continuous releases. These measures, in conjunction with plant design, preclude approaching release rate limits, per the ODCM.

b) Liquid Effluents Unit 1/2:

Proximity to the 10 CFR 20 release rate limits is controlled for each release by the application of minimum acceptable dilution flow of 100,000 gpm for any batch tank release, along with an identical administrative limit employed at unit 3. Together, these controls have been demonstrated in the ODCM to ensure sufficient margin from approaching the 10CFR20 limits. Units 1 and 2 used the OLD IOCFR20 in 2004. An upgrade to the new version is planned, and compliance methodology is being integrated with unit 3 in 2005.

Unit 3:

Proximity to the 10 CFR 20 release rate limits is controlled for each release by the application of a calculated Allowed Diluted Concentration (ADC) and Radiation Monitor setpoints. The ADC is calculated as a function of the "10 times EC" limit, and includes limitations from Beta emitters. These measures, along with an administrative activity limit for effluent waste tanks, preclude approaching release rate limits, per the ODCM.

Docket No. 50-3, 50-247, & 50-286 Page 2 of 76

3. Average Enercqv The average energies (E) of the radionuclide mixtures in releases of fission and activation gases were as follows:

Units 1 and 2:

1st Quarter Ep = 1.36E-01 Mev/dis Ey = 4.64E-02 Mev/dis 2nd Quarter P= 2.40E-01 Mev/dis e I = 6.39E-03 Mev/dis 3rd Quarter Ep = 1.68E-01 Mev/dis y= 3.78E-02 Mev/dis 4th Quarter P= 1.52E-01 Mev/dis Ey = 4.OOE-02 Mev/dis Unit 3:

1st Quarter E= 2.51 E-01 Mev/dis E v= 4.84E-01 Mev/dis 2nd Quarter Ep = 1.72E-01 Mev/dis ry= 1.69E-01 Mev/dis 3rd Quarter Ep= 2.18E-01 Mev/dis Ey = 3.49E-02 Mev/dis 4th Quarter Ep = 2.06E-01 Mev/dis Ey = 3.63E-02 Mev/dis

4. Measurements and Approximations of Total Radioactivity a) Fission and Activation Gases Analyses of effluent gases have been performed in compliance with the requirements of the RECS (ODCM Part I). In the case of isolated tanks (batch releases), the total activity discharged is based on an isotopic analysis of each batch with the volume of gas in the batch corrected to standard temperature and pressure.

Vapor containment purge and pressure relief (vent) discharges routinely total less than 150 hour0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />s/quarter in duration have been treated as batch releases.

However, both types of releases from the Vapor Containment are performed randomly with regard to time of day and duration (release periods were not dependant solely on time of day or atmospheric condition). Therefore, determination of doses due to Vapor Containment releases includes the use of annual average dispersion data, as defined in NUREG 0133, Section 3.3.

At least one complete isotopic concentration analysis of containment air is performed monthly. This analysis is used in conjunction with a process monitor to obtain the isotopic mixture and quantification of each pressure relief. Isotopic analyses for each vapor containment purge are taken prior to and during the purge. This information is combined with the volume of air in each discharge to calculate the quantity of activity released from these discharges.

The continuous building discharges are based on weekly samples of ventilation air analyzed for isotopic content. This information is combined with total air volume discharged and the process radiation monitor readings to determine the quantity of activity from continuous discharges.

Docket No. 50-3, 50-247, & 50-286 Page 3 of 76 b/c) lodines and Particulates lodine-131 and particulate releases are quantified by collecting a continuous sample of ventilation air on a Triethylenediamine (TEDA) impregnated, activated charcoal cartridge and a glass-fiber filter paper. These samples are changed weekly as required in the RECS. The concentration of isotopes found by analysis of these samples is combined with the volume of air discharged during the sampling period to calculate the quantity of activity discharged.

If 1-131 is identified in the routine weekly sample, other iodine isotopic concentrations are then determined on a 24-hour sample at least once per month. The concentration of each isotope is analytically determined by ratioing the activities with weekly media for 1-131. This activity is combined with the volume of air discharged during the sampling period to calculate the quantity of activity discharged.

A compositing method of analyzing for gross alpha is used to improve efficiency. When no Gross Alpha is identified for an entire quarter, a "less than" value is reported (in curies) on Table 1A. This value is derived from established minimum detectable concentrations and the total volume of air released from all continuous release points. This method generates a more accurate minimum detectable total curie level than summing MDCs and occasional false positives at the critical level. The values demonstrate 1) these emissions are statistically indistinguishable from background, and 2) the ODCM required LLDs are not challenged.

d) Liquid Effluents A sample of each batch discharge is taken and an isotopic analysis is performed in compliance with requirements specified in the RECS.

Proportional composite samples of continuous discharges are taken and analyzed in compliance with the applicable RECS table, as well. Isotopic concentration data are combined with the information on volume discharged to determine the amount of each isotope discharged.

Liquid Effluent volumes of waste released on Table 2A are differentiated between processed fluids (contaminated water processed prior to release),

and very slightly contaminated continuous releases like SG Blowdown, which are NOT processed. Because the unprocessed water may contain trace levels of Tritium, etc, it is included in the report, but the volumes are differentiated to prevent confusion regarding the total volume of waste released to the Hudson River. The curies reported, however, are totals of all liquid effluent, continuous and batch.

Docket No. 50-3, 50-247, & 50-286 Page 4 of 76

5. Batch Releases Airborne:

Unit I and 2 Airborne Releases Qtr 1 Qtr 2 Qtr 3 Qtr 4 2004 Number of Batch Releases 28 29 35 51 143 Total Time Period (min) 1770 1560 2630 6830 12800 Maximum Time Period (min) 143 159 255 830 830 Average Time Period (min) 63.1 53.6 75.0 134 89.4 Minimum Time Period (min) 5 3 25 2 2 Unit 3 Airborne Releases Qtr 1 Qtr 2 Qtr 3 Qtr 4 2004 Number of Batch Releases 21 27 19 18 85 Total Time Period (min) 4000 4010 3180 3730 14900 Maximum Time Period (min) 317 265 260 317 317 Average Time Period (min) 191 148 167 207 176 Minimum Time Period (min) 2 5 4 1 1 Liquid:

Unit 1 and 2 Liquid Releases Qtr 1 Qtr 2 Qtr 3 Qtr 4 2004 Number of Batch Releases 32 2 25 25 84 Total Time Period (min) 6820 209 2940 3650 13600 Maximum Time Period (min) 594 105 349 649 649 Average Time Period (min) 213 105 118 146 162 Minimum Time Period (min) 48 104 99 93 48 Unit 3 Liquid Releases Qtr 1 Qtr 2 Qtr 3 Qtr 4 2004 Number of Batch Releases 12 8 10 19 49 Total Time Period (min) 1280 912 1130 2110 5430 Maximum Time Period (min) 140 118 122 126 140 Average Time Period (min) 107 114 113 111 l 111 Minimum Time Period (min) 9 1 05 104 105 9 Average Stream Flow:

Hudson River flow information is obtained from the Department of the Interior, United States Geological Survey (USGS). These data are received after review from the USGS, approximately 18 months after initial data collection. This information is included in the effluents report as the data become available.

Estimated Average Stream Flows of the Hudson River at Indian Point:

Va-I CalW n-, -,4 WUd C11 Ll-,:>

M^I&I W

/rfcW 2002 Fourth 20667 2003 First 27267 2003 Second 29433 2003 Third 14087

Docket No. 50-3, 50-247, & 50-286 Page 5of 76

6. Abnormal Releases a) Liquid None b) Gaseous None
7. ODCM Reporting Requirements The ODCM (RECS) requires reporting of prolonged outages of effluent monitoring equipment. Also required in this report is notification of any changes in the land use census, the Radiological Environmental Monitoring Program (REMP), or exceeding the total curie content limitations in outdoor tanks.

During this reporting period, the following ODCM required effluent monitoring equipment was out of service for periods greater than 30 consecutive days:

Instrument Period Out of Service Justification There are two separate instrument devices which could comprise the required level instrument" on these tanks.

Due to a disparity between their readings, the required level Unit 1, Oct 15, @ 04:30 instrument was conservatively called out of service while Waste awaiting parts to replace one of the devices.

Distillate to Storage However, both devices (the other being the standard Tank, #14 Dec 31, @ 24:00 reference and variable leg d/p cell) passed their calibration Level tests in January, 2005. The slight difference in readings Instrument were investigated with regard to acceptable error tolerance.

It was determined by Ops Management to only use the (placed back in Reference and Variable leg as the ODCM required service on instrument and the pressure gauge as a compensatory 2/14/05 @ 23:23) measurement when the primary means is OOS.

During this interval, tank release volumes were calculated using average pump discharge flow rate (from the ODCM-required flow rate meter) and the duration of the release.

During this reporting period, no tank curie limits in outdoor tanks were exceeded.

The station ODCMs were updated to Revision 8 (Units 1 and 2) and Revision 16 (Unit 3) in the first quarter of 2004. The justification packages are included in Section G of this report.

There were no changes to the Process Control Programs during this reporting period.

Docket No. 50-3, 50-247, & 50-286 Page 6 of 76 Indian Point Energy Center (Units 1, 2, and 3)

RADIOACTIVE EFFLUENT RELEASE REPORT B. GASEOUS EFFLUENTS 2004

Docket No. 50-3, 50-247, & 50-286 Page 7 of 76 TABLE 1A INDIAN POINT 1 and 2 RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES Year Est. Total A Fission & Activation Gases Units Qtr1 Qtr 2 Qtr 3 Qtr 4 2004  % Error 1.Total Release Ci 2.08E+01 2.26E+00 1.29E+02 2.16E+02 3.68E+02 + 25

2. Average release rate uCisec 2.65E+00 2.87E-01 1.62E+01 2.72E+01 1.16E+01 B. Iodines
1. Total Iodine-131 a NO N/D N/D 1.08E-03 1.08E-03 +25
2. Average release rate uCUsec N/D ND N/D 1.35E-04 3.40E-05 C. Particulates
1. Total Release, with Ci 7.71E-07 1.30E-06 1.79E-05 2.43E-05 4.43E-05 +_25 half-life > 8 days __ _ _ _ _ _ __ _ _ _ _ _ _
2. Average release rate uCVsec 9.81E-08 1.65E-07 2.25E-06 3.06E-06 1.40E-06
3. Gross Alpha Ci <2.05E-06 <1.95E-06 <1.41E-06 <3.55E-06 <8.96E-9 +25 D. Tritium
1. Total release Ci 6.89E-01 3.06E-01 2.11E-01 1.59E+00 2.80E+00l +25
2. Average release rate uCi/sec 8.76E-02 3.89E-02 2.65E-02 2.00E-01 8.84E-02 N/D = None Detected

Docket No. 50-3, 50-247, & 50-286 Page 8 of 76 TABLE 1C INDIAN POINT 1 and 2 CONTINUOUS GASEOUS EFFLUENTS RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

Nuclides Released Year

1) Fission Gases Units Qtr 1 Qtr 2 Qtr 3 Qtr 4 2004 Kr-85m Ci 7.50E-06 1.96E-05 2.71 E-05 Kr-85 Ci Kr-87 Ci Kr-88 Ci Xe-131m Ci Xe-1 33m Ci Xe-1 33 Ci 2.05E+01 1.45E-03 5.38E+00 6.56E+01 9.15E+01 Xe-135m Ci Xe-1 35 Ci 4.50E-04 6.20E-04 5.83E-04 4.03E-05 1.69E-03 Xe-138 Ci Ar-41 Ci 6.24E-05 6.24E-05 Total for Period Ci 2.05E+01 2.09E-03 5.38E+00 6.56E+01 19.15E+01
2) lodines 1-131 Ci N/D N/D N/D 1.07E-03 1.07E-03 1-133 Ci N/D N/D N/D 4.39E-06 4.39E-06 1-135 Ci N/D N/D N/D N/D N/D Total for Period Ci N/D N/D N/D 1.08E-03 I 1.08E-03l
3) Particulates Co-58 Ci N/D N/D 1.22E-05 4.51 E-06 1.67E-05 Cs-1 34 Ci N/D N/D 7.26E-07 8.67E-07 1.59E-06 Cs-137 Ci N/D N/D 3.10E-06 1.79E-05 2.10E-05 Ni-63 Ci 7.71 E-07 1.30E-06 1.80E-06 1.03E-06 4.90E-06 Total for Period Ci 7.71 E-07 1.30E-06 1.79E-05 2.43E-05 4.43E-05

Docket No. 50-3, 50-247, & 50-286 Page 9 of 76 TABLE 1C INDIAN POINT 1 and 2 RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

BATCH GASEOUS EFFLUENTS Nuclides Released Year

1) Fission Gases Qtr I Qtr 2 Qtr 3 Qtr 4 2004 Units Ar-41 Ci 9.94E-03 2.OOE-04 4.31E-02 2.10E-02 7.42E-02 Kr-85 Ci 1.03E-01 2.07E+00 3.36E+01 3.01E+01 6.59E+01 Kr-85m Ci 1.22E-04 1.36E-04 7.22E-02 1.42E-05 7.25E-02 Kr-87 Ci 4.59E-05 5.01E-05 8.13E-06 1.04E-04 Kr-88 Ci 1.47E-04 1.82E-04 4.58E-02 2.05E-05 4.61E-02 Xe-131m Ci 1.68E-04 6.10E-03 1.85E+00 1.45E+00 3.31E+00 Xe-133 Ci 1.32E-01 1.87E-01 8.54E+01 1.18E+02 2.04E+02 Xe-133m Ci 4.13E-04 8.27E-05 1.09E+00 9.09E-01 2.OOE+00 Xe-135 Ci 1.50E-03 1.12E-03 1.58E+00 2.24E-01 1.81E+00 Xe-135m Ci 3.90E-05 4.02E-05 1.18E-05 9.10E-05 Xe-138 Ci 2.79E-05 3.94E-06 3.18E-05 Total for Period Ci 2.48E-01I 2.26E+00 I1.24E+02 11.51 E+02 I2.77E+02
2) lodines 1-131 Ci N/A N/A N/A N/A NIA 1-133 Ci N/A N/A N/A N/A N/A 1-135 Ci N/A N/A N/A N/A N/A

[ Tal for Period Ci N/A N/A N/A N/A N/A

3) Particulates I Total for Period I Ci IN/A I N/A I N/A I N/A I N/A

Docket No. 50-3, 50-247, & 50-286 Page 10 of 76 TABLE 1A INDIAN POINT 3 RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES Year Est. Total A Fission &Activation Gases Units Qtr I Qtr 2 Qtr 3 Qtr 4 2004  % Error

1. Total Release Ci 9.06E-02 2.51E-01 1.04E+00 1.72E+00 3.11E+00- +25
2. Average release rate [_uCi/sec 1.15E-02 3.19E-02 [_1.31E-01 2.17E-01 9.82E-02 B. lodines
1. Totallodine-131 Ci N/D N/D N/D N/D N/D +25
2. Average release rate uCVsec ND N/D N/D N/D N/D C. Particulates
1. Total Release, wth l N/D N/D l N/D NID N/D l 25 half-life > 8 days __ _ _ _ _ _ _ _ _ _ _ _ _ _
2. Average release rate uCi/sec NiD N/D NhD ND N/D)
3. Gross Alpha Ci <3.52E-06 <3.36E-06 <4.55E-06 <5.33E-06 <1.68E-05 +25 D. Tritium
1. Total release J Ci 1.42E+00 1.34E+00 1.14E+00 1.57E+001 5.47E+00 +25
2. Average release rate T uCi/sec 1.81E-01 1.70E-01 1.43E-01 1.97E-01 1.73E-01 N/D = None Detected

Docket No. 50-3, 50-247, & 50-286 Page I1 of 76 TABLE 1C INDIAN POINT 3 - CONTINUOUS GASEOUS EFFLUENTS RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

Nuclides Released Year

1) Fission Gases Units Qtr 1 Qtr 2 Qtr 3 Qtr 4 2004 Ar-41 Ci Kr-85 Ci Kr-85m Ci Kr-87 Ci Kr-88 Ci Xe-131 m Ci Xe-133 Ci 3.21 E-01 3.21 E-01 Xe-133m Ci Xe-1 35 Ci Xe-135m Ci Xe-138 Ci TaI for Period Ci O.OOE+00 IO.OOE+00 I O.OOE+00 J_3.21E-01 3.21E-01
2) lodines 1-131 Ci N/D N/D N/D N/D N/D 1-133 Ci N/D N/D N/D N/D N/D 1-135 Ci N/D N/D NID N/D N/D Total for Period Ci N/D NID N/D N/D N/D
3) Particulates I Total for Period I Ci I N/D I N/D I N/D I N/D I N/D I N/D= None Detected

Docket No. 50-3, 50-247, & 50-286 Page 12 of 76 TABLE IC INDIAN POINT 3 RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

BATCH GASEOUS EFFLUENTS Nuclides Released Year

1) Fission Gases Units Qtr1 Qtr 2 Qtr 3 Qtr 4 2004 Ar-41 Ci 3.20E-02 2.34E-02 1.51E-02 2.16E-02 9.22E-02 Kr-85 Ci 7.OOE-01 1.OOE+00 1.70E+00 Kr-85m Ci Kr-87 Ci Kr-88 Ci Xe-131 m Ci Xe-133 Ci 5.85E-02 2.18E-01 3.21E-01 3.78E-01 9.75E-01 Xe-133m Ci Xe-135 Ci 9.41E-03 2.03E-03 1.68E-03 1.31E-02 Xe-1 35m Ci Total for Period Ci 9.06E-02 2.51 E-01 1.04E+00 1.40E+00 2.78E+00
2) lodines 1-131 Ci N/A N/A NIA N/A N/A 1-133 Ci N/A N/A N/A N/A N/A 1-135 Ci N/A N/A N/A N/A N/A

[Toa 1 for Period Ci N/A N/A N/A N/A N/A

3) Particulates Total for Period Ci l N/A N/A N/A N/A N/A N/A = Not Applicable for Batch Releases

Docket No. 50-3, 50-247, & 50-286 Page 13 of 76 Indian Point Energy Center (Units 1, 2, and 3)

RADIOACTIVE EFFLUENT REPORT C. LIQUID EFFLUENTS 2004

Docket No. 50-3, 50-247, & 50-286 Page 14 of 76 TABLE 2A INDIAN POINT 1 and 2 RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES Year Est. Total A Fission & Activation Products  % Error Units Qtr I Qtr 2 Qtr 3 Qtr 4 2004

1. Total Release (not including Tritium, GrAlpha, &Gases)
2. Average Diluted Conc Ci 2.36E-02 2.38E-03 uCiri 4.84E-11 3.08E-12 1.44E-02 1.66E-11 1

1.98E-02 3.19E-11 6.02E-02 2.19E-11

+ 25 B. Tritium

1. Total Release Ci J 3.92E+01 1.14E+02 8.94E+02 1.29E+02 1.18E+03 +25 ]
2. Average Diluted Conc uCi/rn 8.03E-08 1.48E-07 1.03E-06 l2.07E-07 4.28E-07 C. Dissolved & Entrained Gases
1. Total Release l Ci/ 3.36E4-6 NID 4.69E-1 l2.40E-1 T7.09E-01 +25
2. AverageDilutedtConc uCi/rl 6.88E-15l ND 5.41E-10 l3.87E-1 2.58E-1 2 D. Gross Alpha
1. Total Release I Ci I 1.59E-041 3.00E-051 1.52E-05I 1.26E-04 3.30E-04 +25l

+/-

E Volume of Waste Released l 1.Processed Fluids l liters l2.15E+06 2.16E+06 2.66E+06 3.74E+06l 1.07E+07T +10

2. Unprocessed Fluids liters 4.31 E+07 4.32E+07l 5.33E+07 7.49E+07 2.14E+08 +10 F.VolumeofDilutionWater liters I4.8E+11I7.72E+11l 8.67E+11 6.21E+11 l 2.75E+121 +/-10

Docket No. 50-3, 50-247, & 50-286 Page 15 of 76 TABLE 2B INDIAN POINT 1 and 2 LIQUID RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

CONTINUOUS RADIOACTIVE EFFLUENT Year Nuclides Released Units Qtr I Qtr 2 Qtr 3 Qtr 4 2004 Ni-63 Ci 6.03E-05 [ 6.27E-04 3.72E-04 J_1.72E-03 2.78E-03 Sr-89 Ci 4.68E-05j 3.21 E-04 1.1 3E-04j 2.75E-05 5.09E-04 Sr90Ci 5.36E-05 11.1 OE-04 1.61 E-04 1i.34E-04 4J 9E0 Cs-1 37 Ci 1.1 OE-03 2.69E-04 1.37E-03 Total for Period I Ci I 1.61E-04 I 1.06E-03 I_1.75E-03 I 2.15E-03 I 5.11E-03

Docket No. 50-3, 50-247, & 50-286 Page 16 of 76 TABLE 2C INDIAN POINT 1 and 2 LIQUID RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

BATCH RADIOACTIVE EFFLUENT Year Nuclides Released Units Qtr I Qtr 2 Qtr 3 Qtr 4 2004 Ag-11 Om Ci 1.46E-04 2.62E-05 1.73E-04 Ba-133 Ci 2.03E-05 2.03E-05 Co-57 Ci 1.29E-05 1.29E-05 Co-58 Ci 2.68E-04 1.34E-05 1.90E-04 2.38E-04 7.09E-04 Co-60 Ci 8.71 E-04 1.51 E-04 3.67E-04 1.37E-04 1.53E-03 Cr-51 Ci 1.15E-04 1.15E-04 Cs-134 Ci 8.46E-04 4.01 E-03 4.86E-03 Cs-137 Ci 6.07E-04 3.38E-03 7.1 OE-03 1.11 E-02 1-131 Ci 1.42E-05 1.91 E-04 2.05E-04 1-133 Ci 7.26E-05 7.26E-05 1-135 Ci 1.30E-04 1.30E-04 Mn-54 Ci 4.84E-04 1.54E-05 9.82E-05 5.98E-04 Nb-95 Ci 5.14E-06 5.14E-06 Ni-63 Ci 1.80E-03 4.13E-04 1.98E-03 9.14E-04 5.11 E-03 Sb-124 Ci 1.17E-04 1.17E-04 Sb-125 Ci 1.41 E-03 2.89E-04 5.38E-03 2.1OE-03 9.18E-03 Sr-89 Ci 2.73E-03 5.27E-05 2.34E-05 1.35E-03 4.15E-03 Sr-90 Ci 1.51 E-02 3.53E-04 3.31 E-05 1.47E-03 1.70E-02 Te-123m Ci 1.41 E-05 1.41 E-05 I oal for Period [ Ci 2.35E-02 I1.32E-03 I1.26E-02 I 1.77E-02 5.51 E-02 Dissolved & Entrained Gas Kr-85 Ci 6.15E-02 3.98E-02 1.01E-01 Xe-131m Cl 1._1 OE-02 6.77E-03 1.78E-02 Xe-133 Ci 3.36E-05 3.94E-01 1.93E-01 5.87E-01 Xe-133m Ci 2.OOE-03 4.94E-04 2.49E-03 Xe-1 35 Ci 2.92E-04 2.92E-04 ITal for Period Ci 3.36E-05 O.OOE+0O 4.69E-01 2.40E-01 7.09E-01

Docket No. 50-3, 50-247, & 50-286 Page 17 of 76 TABLE 2A INDIAN POINT 3 RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES Year Est. Total A. Fission & Activation Products 2004  % Error Units Qtr I Qtr 2 Qtr 3 Qtr 4

1. Total Release (not including Ci 3.06E-03 3.03E-03 4.68E-03 4.80E-03 1.56E-02 + 25 Tritium, Gr Alpha, & Gases) T
2. Average Diluted Conc uCi/ml 6.28E-12 3.92E-12 5.40E-12 7.72E-12 5.67E-12 B. Tritium
1. Total Release l Ci 2.88E+01 7.18E+01 4.49E+01 5.30E+02 6.75E+02 +25
2. Average Diluted Conc J l uCiml 5.89E-08 l 9.30E-08 5.18E-08 8.53E-07 l 2.46E-07 C. Dissolved & Entrained Gases
1. Total Release l Ci JO.OOE+00 1.81E-04 7.03E-05 7.15E-03 7.40E-03 + 25
2. AverageDiluted Conc uCi/ml l O.OOE+00l 2.35E-13 8.11E-14 1.15E-11 T 2.69E-12 D. Gross Alpha
1. Total Release l Ci 2.O0E-05l 1.78E-05l 2.40E-05 I 1.02E-04 I 1.64E-04 l+ 25 E. Volume of Waste Released
1. Processed Fluids liters 3.50E+05 3.24E+05 2.53E+05 3.19E+05 1.25E+06 + 10
2. Unprocessed Fluids liters 3.31E+06 2.10E+06 1.64E+06 1.64E+06 8.68E+06 + 10 F. Volume of Dilution Water liters 4.88E+11 I7.72E+11 l8.67E+11 6.21E+11 l 2.75E+12 + 10

Docket No. 50-3, 50-247, & 50-286 Page 18 of 76 TABLE 2B INDIAN POINT 3 LIQUID RADIOACTIVE EFFLUENT REPORT (Jan - Dec 2004)

BATCH RADIOACTIVE EFFLUENT Nuclides Released Year Units Qtr I Qtr 2 Qtr 3 Qtr 4 2004 Ag-1I Om Ci 2.88E-04 3.93E-04 1.88E-03 6.53E-04 3.22E-03 Co-58 Ci 1.10E-04 8.92E-05 2.45E-05 2.24E-04 Co-60 Ci 4.15E-04 7.86E-04 1.1OE-03 1.64E-03 3.94E-03 Cs-1 34 Ci 2.82E-04 2.02E-05 1.52E-04 4.53E-04 Cs-137 Ci 2.96E-04 3.75E-05 4.71 E-05 3.41 E-04 7.22E-04 Fe-55 Ci 8.28E-04 4.35E-04 1.26E-03 Mn-54 Ci 4.57E-06 1.75E-05 1.54E-05 4.80E-05 8.54E-05 Nb-95 Ci 2.36E-05 2.36E-05 Ni-63 Ci 2.98E-04 7.59E-04 1.16E-03 7.87E-04 3.01 E-03 Sb-125 Ci 1.35E-03 9.90E-05 1.95E-05 1.17E-03 2.64E-03 Total for Period Ci 3.06E-03 I 3.03E-03 I 4.68E-03 I 4.80E-03 J 1.56E-02 Dissolved and Entrained Gas Kr-85 Ci 6.73E-03 6.73E-03 Xe-133 Ci 1.81 E-04 7.03E-05 4.24E-04 6.76E-04 Total for Period Ci O.OOE+OI 1.81E-04 I 7.03E-05 7.15E-03 7.40E-03 I (No Liquid Continuous Releases in 2004)

Docket No. 50-3, 50-247, & 50-286 Page 19 of 76 Indian Point Energy Center (Units 1, 2, and 3)

RADIOACTIVE EFFLUENT REPORT D. SOLID WASTE 2004

Docket No. 50-3, 50-247, & 50-286 Page 20 of 76 Units 1 and 2 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/01/2004 to 12/31/2004 Percent Cutoff: 0 (all identified isotopes are included)

Waste Stream : Resins, Filters, and Evap Bottoms LW S Re sin Waste Volume Curies  % Error (Ci)

Class ft3 m3 Shipped A 2.06E+02 5.83E+00 1.19E+01 +/-25%

B 0.OOE+00 O.OOE+00 0.OOE+00 +/- 25%

C 0.OOE+00 0.OOE+00 0.OOE+00 +/- 25%

All 2.06E+02 5.83E+00 1.19E+01 +/-25%

Waste Stream : Dry Active Waste DAW/Dirt;B-25 BOX DAW 20' Sea Land DAW 55 Gal Drum Scrap Metal20'Sea Land Waste Volume Curies  % Error (Ci)

Class ft3 m3 Shipped A 1.51 E+04 4.27E+02 5.45E+00 +/-25%

B 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

C 6.75E+01 1.91 E+00 1.69E+01 +/-25%

All 1.51 E+04 4.29E+02 2.24E+01 +/-25%

Waste Stream  : Irradiated Components Waste Volume Curies  % Error (Ci)

Class ft3 m3 Shipped A 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

B 0.OOE+00 0.OOE+00 0.OOE+00 +1-25%

C 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

All 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

Waste Stream Other Waste Waste Volume Curies  % Error (Ci) 3 3 Class ft m Shipped A 9.14E+03 2.59E+02 1.77E+00 +/-25%

B 0.OOE+00 O.OOE+00 0.OOE+00 +/-25%

C 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

All 9.14E+03 2.59E+02 1.77E+00 +/-25%

Waste Stream Sum of All4 Categories C o m b in e d Pa c ka g e s:

DAW/Dirt; B-25 Box DAW 20'Sea Land LWS Resin Waste Oil Scrap Metal20'Sea Land DAW 55 Gal Drum Waste Volume Curles  % Error (Cl)

Class ft 3 m3 Shipped A 2.44E+04 6.90E+02 1.92E+01 +1-25%

B 0.OOE+00 0.00E+00 0.OOE+00 +/-25%

C 6.75E+01 1.91 E+00 1.69E+01 +/-25%

All 2.44E+04 6.92E+02 3.61 E+01 +/-25%

Docket No. 50-3, 50-247, & 50-286 Page 21 of 76 Units I and 2 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/01/2004 to 12/31/2004 Percent Cutoff: 0 Number of Mode of Transportation Destination Shipments 15 Hittman Transport GTS Duratek 3 RACE Logistics RACE LLC 1 Hittman Transport Studsvik Processing Facility Resins, Filters, and Evap Bottoms Waste Class A Nuclide Name Percent Abundance Curies H-3 8.985% 1.07E+00 Mn-54 0.516% 6.14E-02 Fe-55 6.035% 7.18E-01 Co-57 1.165% 1.39E-01 Co-58 4.364% 5.19E-01 Co-60 5.406% 6.43E-01 Ni-63 15.621% 1.86E+00 Sr-90 0.073% 8.71 E-03 Sb-125 3.046% 3.63E-01 Cs-1 34 14.584% 1.74E+00 Cs-137 29.864% 3.55E+00 Ce-144 10.322% 1.23E+00 Pu-238 0.004% 5.14E-04 Pu-239 0.002% 2.85E-04 Am-241 0.006% 6.73E-04 Cm-242 0.001% 1.52E-04 Cm-243 0.006% 7.44E-04 Resins, Filters, and Evap Bottoms Waste Class All Nuclide Name Percent Abundance Curies H-3 8.985% 1.07E+00 Mn-54 0.516% 6.14E-02 Fe-55 6.035% 7.18E-01 Co-57 1.165% 1.39E-01 Co-58 4.364% 5.19E-01 Co-60 5.406% 6.43E-01 Ni-63 15.621% 1.86E+00 Sr-90 0.073% 8.71 E-03 Sb-1 25 3.046% 3.63E-01 Cs-134 14.584% 1.74E+00 Cs-137 29.864% 3.55E+00 Ce-144 10.322% 1.23E+00 Pu-238 0.004% 5.14E-04 Pu-239 0.002% 2.85E-04 Am-241 0.006% 6.73E-04 Cm-242 0.001% 1.52E-04 Cm-243 0.006% 7.44E-04

Docket No. 50-3, 50-247, & 50-286 Page 22 of 76 Units I and 2 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01101/2004 to 12/31/2004 Percent Cutoff: 0 Dry Active Waste Waste Class A Nuclide Name Percent Abundance Curies H-3 0.381% 2.08E-02 C-14 0.488% 2.66E-02 Mn-54 0.776% 4.23E-02 Fe-55 34.686% 1.89E+00 Co-58 0.001% 7.08E-05 Co-60 42.613% 2.32E+00 Ni-63 12.467% 6.80E-01 Sr-90 0.076% 4.14E-03 Zr-95 0.001% 7.71 E-05 Nb-95 0.002% 1.23E-04 Ag-I1 Om 0.000% 1.75E-06 Sb-125 2.376% 1.30E-01 Cs-1 34 0.717% 3.91 E-02 Cs-I 37 2.034% 1.11 E-01 Ce-144 2.751% 1.50E-01 Pu-238 0.013% 7.34E-04 Pu-239 0.007% 3.79E-04 Pu-241 0.563% 3.07E-02 Am-241 0.025% 1.39E-03 Cm-242 0.003% 1.38E-04 Cm-243 0.018% 9.96E-04 Dry Active Waste Waste Class C Nuclide Name Percent Abundance Curies H-3 0.382% 6.47E-02 C-14 0.489% 8.28E-02 Mn-54 0.775% 1.31E-01 Fe-55 34.650% 5.87E+00 Co-60 42.656% 7.22E+00 Ni-63 12.471% 2.11E+00 Sr-90 0.076% 1.29E-02 Sb-125 2.376% 4.02E-01 Cs-134 0.718% 1.22E-01 Cs-137 2.045% 3.46E-01 Ce-144 2.730% 4.62E-01 Pu-238 0.013% 2.28E-03 Pu-239 0.007% 1.18E-03 Pu-241 0.564% 9.55E-02 Am-241 0.025% 4.31 E-03 Cm-242 0.002% 4.22E-04 Cm-243 0.018% 3.1OE-03

Docket No. 50-3, 50-247, & 50-286 Page 23 of 76 Units 1 and 2 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01101/2004 to 12/31/2004 Percent Cutoff: 0 Dry Active Waste Waste Class All Nuclide Name Percent Abundance Curies H-3 0.382% 8.55E-02 C-14 0.487% 1.09E-01 Mn-54 0.776% 1.74E-01 Fe-55 34.673% 7.76E+00 Co-58 0.000% 7.08E-05 Co-60 42.635% 9.54E+00 Ni-63 12.468% 2.79E+00 Sr-90 0.076% 1.70E-02 Zr-95 0.000% 7.71 E-05 Nb-95 0.001% 1.23E-04 Ag-iI Om 0.000% 1.75E-06 Sb-125 2.375% 5.32E-01 Cs-I 34 0.718% 1.61 E-01 Cs-1 37 2.046% 4.58E-01 Ce-144 2.734% 6.12E-01 Pu-238 0.013% 3.01 E-03 Pu-239 0.007% 1.56E-03 Pu-241 0.563% 1.26E-01 Am-241 0.025% 5.70E-03 Cm-242 0.003% 5.60E-04 Cm-243 0.018% 4.09E-03 Other Waste Waste Class A Nuclide Name Percent Abundance Curies H-3 0.382% 6.74E-03 C-14 0.488% 8.62E-03 Mn-54 0.780% 1.38E-02 Fe-55 34.675% 6.12E-01 Co-60 42.633% 7.53E-01 Ni-63 12.448% 2.20E-01 Sr-90 0.076% 1.34E-03 Sb-1 25 2.378% 4.20E-02 Cs-1 34 0.719% 1.27E-02 Cs-1 37 2.041% 3.60E-02 Ce-144 2.750% 4.85E-02 Pu-238 0.013% 2.37E-04 Pu-239 0.007% 1.23E-04 Pu-241 0.563% 9.94E-03 Am-241 0.025% 4.49E-04 Cm-242 0.003% 4.47E-05 Cm-243 0.018% 3.22E-04

Docket No. 50-3, 50-247, & 50-286 Page 24 of 76 Units 1 and 2 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01101/2004 to 12/31/2004 Percent Cutoff: 0 Other Waste Waste Class All Nuclide Name Percent Abundance Curies H-3 0.382% 6.74E-03 C-14 0.488% 8.62E-03 Mn-54 0.780% 1.38E-02 Fe-55 34.675% 6.12E-01 Co-60 42.633% 7.53E-01 Ni-63 12.448% 2.20E-01 Sr-90 0.076% 1.34E-03 Sb-125 2.378% 4.20E-02 Cs-1 34 0.719% 1.27E-02 Cs-1 37 2.041% 3.60E-02 Ce-144 2.750% 4.85E-02 Pu-238 0.013% 2.37E-04 Pu-239 0.007% 1.23E-04 Pu-241 0.563% 9.94 E-03 Am-241 0.025% 4.49E-04 Cm-242 0.003% 4.47E-05 Cm-243 0.018% 3.22E-04 Sum of All 4 Categories Waste Class A Nuclide Name Percent Abundance Curies H-3 5.749% 1.10E+00 C-14 0.184% 3.52E-02 Mn-54 0.615% 1.18E-01 Fe-55 16.837% 3.22E+00 Co-57 0.727% 1.39E-01 Co-58 2.716% 5.20E-01 Co-60 19.462% 3.72E+00 Ni-63 14.430% 2.76E+00 Sr-90 0.074% 1.42E-02 Zr-95 0.000% 7.71 E-05 Nb-95 0.001% 1.23E-04 Ag-110m 0.000% 1.75E-06 Sb-125 2.794% 5.35E-01 Cs-134 9.354% 1.79E+00 Cs-1 37 19.333% 3.70E+00 Ce-144 7.474% 1.43E+00 Pu-238 0.008% 1.49E-03 Pu-239 0.004% 7.86E-04 Pu-241 0.213% 4.07E-02 Am-241 0.013% 2.51 E-03 Cm-242 0.002% 3.35E-04 Cm-243 0.011% 2.06E-03

Docket No. 50-3, 50-247, & 50-286 Page 25 of 76 Units 1 and 2 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/0112004 to 12/3112004 Percent Cutoff: 0 Sum of All 4 Categories Waste Class C Nuclide Name Percent Abundance Curies H-3 0.382% 6.47E-02 C-14 0.489% 8.28E-02 Mn-54 0.775% 1.31E-01 Fe-55 34.650% 5.87E+00 Co-60 42.656% 7.22E+00 Ni-63 12.471% 2.11E+00 Sr-90 0.076% 1.29E-02 Sb-125 2.376% 4.02E-01 Cs-134 0.718% 1.22E-01 Cs-1 37 2.045% 3.46E-01 Ce-144 2.730% 4.62E-01 Pu-238 0.013% 2.28E-03 Pu-239 0.007% 1.18E-03 Pu-241 0.564% 9.55E-02 Am-241 0.025% 4.31 E-03 Cm-242 0.002% 4.22E-04 Cm-243 0.018% 3.1 OE-03 Sum of All 4 Categories Waste Class All Nuclide Name Percent Abundance Curies H-3 3.222% 1.16E+00 C-14 0.328% 1.18E-01 Mn-54 0.690% 2.49E-01 Fe-55 25.248% 9.09E+00 Co-57 0.386% 1.39E-01 Co-58 1.443% 5.20E-01 Co-60 30.253% 1.09E+01 Ni-63 13.527% 4.87E+00 Sr-90 0.075% 2.70E-02 Zr-95 0.000% 7.71 E-05 Nb-95 0.000% 1.23E-04 Ag-110m 0.000% 1.75E-06 Sb-125 2.601% 9.37E-01 Cs-134 5.304% 1.91 E+00 Cs-1 37 11.245% 4.05E+00 Ce-144 5.249% 1.89E+00 Pu-238 0.010% 3.77E-03 Pu-239 0.005% 1.96E-03 Pu-241 0.378% 1.36E-01 Am-241 0.019% 6.82E-03 Cm-242 0.002% 7.57E-04 Cm-243 0.014% 5.16E-03

Docket No. 50-3, 50-247, & 50-286 Page 26 of 76 Unit 3 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/01/2004 to 12/31/2004 Percent Cutoff: 0 (all identified isotopes are included)

Waste Stream : Resins, Filters, and Evap Bottoms LWS Resin 14-170 Primary Resin 8-120 Waste Volume Curies  % Error (Ci) 3 3 Class ft m Shipped A 3.42E+02 9.67E+00 2.37E+01 +/- 25%

B 1.20E+02 3.41 E+00 6.07E+01 +/- 25%

C 0.00E+00 0.00E+00 0.OOE+00 +/- 25%

All 4.62E+02 1.31 E+01 8.44E+01 +1-25%

Waste Stream  : Dry Active Waste DAW/GIC - B-25 (Unit 3)Dirt;B-25 BOX Waste Volume Curles  % Error (Ci)

Class ft3 m3 Shipped A 2.02E+03 5.71 E+01 4.92E-02 +/-25%

B 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

C 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

All 2.02E+03 5.71 E+01 4.92E-02 +/-25%

Waste Stream  : Irradiated Components Waste Volume Curles  % Error (Ci)

Class ft3 m3 Shipped A 0.OOE+00 0.00E+00 0.O0E+00 +/-25%

B 0.OOE+00 0.00E+00 0.00E+00 +/-25%

C 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

All 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

Waste Stream  : Other Waste Waste Volume Curies  % Error (Ci)

Class ft3 m3 Shipped A 0.00E+00 0.00E+00 0.OOE+00 +/-25%

B 0.OOE+00 0.00E+00 0.OOE+00 +/-25%

C 0.OOE+00 0.00E+00 0.OOE+00 +/-25%

All 0.00E+00 0.OOE+00 0.OOE+00 +/-25%

Waste Stream  : Sum of All4 Categories C o m b ined Pa c ka g es:

LWS Resin 14-170 Primary Resin 8-120 DAW/GIC-B-25 (Unit 3)

Waste Volume Curies  % Error (Cl)

Class ft3 m3 Shipped A 2.36E+03 6.68E+01 2.37E+01 +/-25%

B 1.20E+02 3.41 E+00 6.07E+01 +/-25%

C 0.OOE+00 0.OOE+00 0.OOE+00 +/-25%

All 2.48E+03 7.02E+01 8.44E+01 +/-25%

Docket No. 50-3, 50-247, & 50-286 Page 27 of 76 Unit 3 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/01/2004 to 12/31/2004 Percent Cutoff: 0 Number of Mode of Transportation Destination Shipments 3 Hittman Transport Studsvik Processing Facility 4 Hittman Transport GTS Duratek Resins, Filters, and Evap Bottoms Waste Class A Nuclide Name Percent Abundance Curies H-3 46.783% 1.11E+01 C-14 0.098% 2.33E-02 Cr-51 0.017% 4.07E-03 Mn-54 0.214% 5.07E-02 Fe-55 4.469% 1.06E+00 Co-57 0.029% 6.82E-03 Co-58 0.565% 1.34E-01 Co-60 4.279% 1.01E+00 Ni-63 4.457% 1.05E+00 Sr-90 0.031% 7.23E-03 Nb-95 0.000% 7.17E-05 Ag-1 Om 0.307% 7.27E-02 Sb-125 2.483% 5.87E-01 Cs-1 34 6.544% 1.55E+00 Cs-1 37 7.857% 1.86E+00 Ce-144 21.287% 5.03E+00 Pu-238 0.005% 1.30E-03 Pu-239 0.002% 4.33E-04 Pu-241 0.559% 1.32E-01 Am-241 0.004% 8.73E-04 Cm-242 0.001% 2.28E-04 Cm-243 0.009% 2.07E-03

Docket No. 50-3, 50-247, & 50-286 Page 28 of 76 Unit 3 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/0112004 to 12/3112004 Percent Cutoff: 0 Resins, Filters, and Evap Bottoms Waste Class B Nuclide Name Percent Abundance Curies H-3 0.003% 1.88E-03 C-14 0.059% 3.55E-02 Mn-54 2.056% 1.25E+00 Fe-55 1.060% 6.43E-01 Co-57 0.300% 1.82E-01 Co-58 4.516% 2.74E+00 Co-60 18.647% 1.13E+01 Ni-59 0.020% 1.22E-02 Ni-63 28.800% 1.75E+01 Sr-90 0.157% 9.56E-02 Tc-99 0.032% 1.95E-02 Sb-125 1.404% 8.52E-01 Cs-1 34 17.837% 1.08E+01 Cs-1 37 24.671 % 1.50E+01 Ce-144 0.045% 2.73E-02 Pu-238 0.001% 3.96E-04 Pu-241 0.393% 2.38E-01 Cm-242 0.001% 3.94E-04 Cm-243 0.001% 4.47E-04 Resins, Filters, and Evap Bottoms Waste Class All Nuclide Name Percent Abundance Curies H-3 13.117% 1.11E+01 C-14 0.070% 5.88E-02 Cr-51 0.005% 4.07E-03 Mn-54 1.540% 1.30E+00 Fe-55 2.015% 1.70E+00 Co-57 0.224% 1.89E-01 Co-58 3.408% 2.88E+00 Co-60 14.619% 1.23E+01 Ni-59 0.014% 1.22E-02 Ni-63 21.976% 1.85E+01 Sr-90 0.122% 1.03E-01 Nb-95 0.000% 7.17E-05 Tc-99 0.023% 1.95E-02 Ag-11iOm 0.086% 7.27E-02 Sb-125 1.706% 1.44E+00 Cs-134 14.671% 1.24E+01 Cs-i 37 19.958% 1.68E+01 Ce-144 6.000% 5.06E+00 Pu-238 0.002% 1.69E-03 Pu-239 0.001% 4.33E-04 Pu-241 0.439% 3.71 E-01 Am-241 0.001% 8.73E-04 Cm-242 0.001% 6.22E-04 Cm-243 0.003% 2.52E-03

Docket No. 50-3, 50-247, & 50-286 Page 29 of 76 Unit 3 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/01/2004 to 12/31/2004 Percent Cutoff: 0 Dry Active Waste Waste Class A Nuclide Name Percent Abundance Curies Mn-54 0.781% 3.85E-04 Fe-55 17.624% 8.68E-03 Co-58 10.821% 5.33E-03 Co-60 13.090% 6.45E-03 Ni-63 18.712% 9.22E-03 Zr-95 10.484% 5.16E-03 Nb-95 24.523% 1.21 E-02 Ag-11Om 0.202% 9.93E-05 Sb-1 25 0.954% 4.70E-04 Cs-I34 0.643% 3.17E-04 Cs-1 37 2.167% 1.07E-03 Dry Active Waste Waste Class All Nuclide Name Percent Abundance Curies Mn-54 0.781% 3.85E-04 Fe-55 17.624% 8.68E-03 Co-58 10.821% 5.33E-03 Co-60 13.090% 6.45E-03 Ni-63 18.712% 9.22E-03 Zr-95 10.484% 5.16E-03 Nb-95 24.523% 1.21 E-02 Ag-I1 Om 0.202% 9.93E-05 Sb-1 25 0.954% 4.70E-04 Cs-1 34 0.643% 3.17E-04 Cs-I 37 2.167% 1.07E-03

Docket No. 50-3, 50-247, & 50-286 Page 30 of 76 Unit 3 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01101/2004 to 12/31/2004 Percent Cutoff: 0 Sum of All 4 Categories Waste Class A Nuclide Name Percent Abundance Curies H-3 46.772% 1.11E+01 C-14 0.098% 2.33E-02 Cr-51 0.017% 4.07E-03 Mn-54 0.215% 5.11E-02 Fe-55 4.503% 1.07E+00 Co-57 0.029% 6.82E-03 Co-58 0.587% 1.39E-01 Co-60 4.283% 1.02E+00 Ni-63 4.463% 1.06E+00 Sr-90 0.030% 7.23E-03 Zr-95 0.022% 5.16E-03 Nb-95 0.051% 1.21 E-02 Ag-1I Om 0.307% 7.28E-02 Sb-125 2.475% 5.87E-01 Cs-1 34 6.533% 1.55E+00 Cs-1 37 7.842% 1.86E+00 Ce-144 21.195% 5.03E+00 Pu-238 0.005% 1.30E-03 Pu-239 0.002% 4.33E-04 Pu-241 0.556% 1.32E-01 Am-241 0.004% 8.73E-04 Cm-242 0.001% 2.28E-04 Cm-243 0.009% 2.07E-03 Sum of All 4 Categories Waste Class B Nuclide Name Percent Abundance Curies H-3 0.003% 1.88E-03 C-14 0.059% 3.55E-02 Mn-54 2.056% 1.25E+00 Fe-55 1.060% 6.43E-01 Co-57 0.300% 1.82E-01 Co-58 4.516% 2.74E+00 Co-60 18.647% 1.13E+01 Ni-59 0.020% 1.22E-02 Ni-63 28.800% 1.75E+01 Sr-90 0.157% 9.56E-02 Tc-99 0.032% 1.95E-02 Sb-125 1.404% 8.52E-01 Cs-1 34 17.837% 1.08E+01 Cs-137 24.671% 1.50E+01 Ce-144 0.045% 2.73E-02 Pu-238 0.001% 3.96E-04 Pu-241 0.393% 2.38E-01 Cm-242 0.001% 3.94E-04 Cm-243 0.001% 4.47E-04

Docket No. 50-3, 50-247, & 50-286 Page 31 of 76 Unit 3 Solid Waste Shipped Offsite for Disposal and Estimates of Major Nuclides by Waste Class and Stream 01/0112004 to 12131/2004 Percent Cutoff: 0 Sum of All 4 Categories Waste Class All Nuclide Name Percent Abundance Curies H-3 13.157% 1.11E+01 C-1 4 0.070% 5.88E-02 Cr-51 0.005% 4.07E-03 Mn-54 1.541% 1.30E+00 Fe-55 2.025% 1.71 E+00 Co-57 0.224% 1.89E-01 Co-58 3.420% 2.89E+00 Co-60 14.587% 1.23E+01 Ni-59 0.014% 1.22E-02 Ni-63 21.939% 1.85E+01 Sr-90 0.122% 1.03E-01 Zr-95 0.006% 5.16E-03 Nb-95 0.014% 1.21 E-02 Tc-99 0.023% 1.95E-02 Ag-11 Om 0.086% 7.28E-02 Sb-1 25 1.707% 1.44E+00 Cs-134 14.698% 1.24E+01 Cs-1 37 19.915% 1.68E+01 Ce-144 5.998% 5.06E+00 Pu-238 0.002% 1.69E-03 Pu-239 0.001% 4.33E-04 Pu-241 0.440% 3.71E-01 Am-241 0.001% 8.73E-04 Cm-242 0.001% 6.22E-04 Cm-243 0.003% 2.52E-03

Docket No. 50-3, 50-247, & 50-286 Page 32 of 76 Indian Point Energy Center (Units 1, 2, and 3)

RADIOACTIVE EFFLUENT REPORT E. RADIOLOGICAL IMPACT ON MAN Jan 1, 2004 - Dec 31, 2004

Docket No. 50-3, 50-247, & 50-286 Page 33 of 76 RADIOLOGICAL IMPACT ON MAN The radiological impact on man is determined by conservatively calculating doses to a hypothetical maximally exposed individual offsite based on plant effluents. These calculations are divided into 3 categories: Noble Gases, Particulates and Iodine, and Liquid Releases (fish and invertebrate consumption).

An annual average dispersion factor is used in the calculations, the details of which are presented in the Offsite Dose Calculation Manuals (ODCM).

The computer code used to perform gaseous dose calculations incorporates the models and parameters presented in the Indian Point ODCMs, which utilize the assumptions in Regulatory Guide 1.109 and NUREG 0133.

These doses were calculated using radioactive releases from the Indian Point Units 1, 2, and 3 Nuclear Power Plants. Indian Point Energy Center is a multi-unit site owned and operated by Entergy Nuclear Operations, Incorporated.

Doses to individuals from liquid pathways for the fish and invertebrate consumption pathways are computed using the methodology and parameters in the ODCMs, which incorporates the calculational models that are present in Regulatory Guide 1.109 and NUREG 0133.

Carbon 14 release concentration and resulting dose have been estimated using data generated at IP3 from August 1980 to June 1982 after a study conducted by the NY State Department of Health. These estimates are consistent with NUREG 0017, Rev. 1. The maximum expected annual dose from Carbon 14 releases at IP2 and IP3 have been calculated using the maximum dependable gross electrical capacity, which is approximately 1000 MW(e) maintained for the entire year. The resultant worst case doses are based upon site specific assumptions of source term released for an entire year at 1000 MW(e) output, as outlined in the ODCM.

The annual dose to the maximally exposed individual (child) from gaseous releases of Carbon-14 is 0.254 mRem to the critical organ (bone) and 0.0508 mRem to the total body. The annual dose to the maximally exposed individual (child) from liquid releases of Carbon-14 is 0.00583 mRem to the critical organ (bone) and 0.00117 mRem to the total body. These curies and doses are reported separately from other isotopes to preclude confusion.

Docket No. 50-3, 50-247, & 50-286 Page 34 of 76 Doses to members of the public from airborne and liquid releases are minimal due to the relatively insignificant total duration of these individuals on site. Their doses can be calculated from standard ODCM methodology, with typical occupancy factors employed.

These factors are determined by comparing the expected hours on site to 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> (the number of hours in a year, used in calculations in the ODCM).

example 1: Several students visit the site for an 8-hour guided tour.

Their occupancy factor is: 8 / 8760 or .0009.

example 2: A man drives his wife to work and drops her off at the security gate each morning, with a total stay-time on site for 2 minutes per day. His occupancy factor is calculated as follows:

2 min/60 min per hour =.0333 hr; 0.0333 / 8760 = 3.8E-6 These factors, when multiplied by doses calculated per the ODCM, demonstrate that dose to MEMBERS OF THE PUBLIC within the site boundary is negligible, despite a potential reduction in the atmospheric dispersion.

In compliance with 40CFR190, the following table indicates the measured direct shine dose component for Indian Point Energy Center property in 2004:

Whole Body Max Organ (mrem) (mrem) 40 CFR190limit 25 -75 Airborne Effluents (IP1 & 2) 1.23E-2 1.23E-2 Liquid Effluents (IP1 & 2) 3.20E-3 1.05E-2 Airborne Effluents (IP 3) 7.97E-4 7.97E-4 Liquid Effluents (IP 3) 2.04E-4 5.54E-4 Radwaste Storage on Site *

  • Indian Point Energy <4.0 < 4.0 Center Total Dose
  • Indistinguishable from background. Four mrem is conservatively used from a one mrem siting criteria established for each area.

Docket No. 50-3, 50-247, & 50-286 Page 35 of 76 INDIAN POINT UNITS 1 and 2 NUCLEAR POWER PLANTS RADIOLOGICAL IMPACT ON MAN JANUARY - DECEMBER 2004 Maximum exposed individual doses in mrem or mrad A. LIQUID DOSES Qtr 1 Qtr 2 Qtr 3 Qtr 4 ANNUAL Organ Dose (mrem) 8.79E-03 2.OOE-04 3.42E-04 1.24E-03 1.05E-02 Applicable Limit (mrem) 5 5 5 5 10 Percent of Limit ( 1.76E-01 4.OOE-03 6.84E-03 2.48E-02 1.05E-01 Age Group Adult Adult Adult Adult Adult Critical Organ Bone Bone Liver Bone Bone Adult Total Body (mrem) 2.16E-03 l 6.04E-05 2.90E-04 6.87E-04 3.20E-03 l Applicable Limit (mrem) l 1.5 1.5 1.5 1.5 3 Percent of Limit (%) 7 1.44E-01 4.03E-03 1.93E-02 4.58E-02 1.07E-01 B. AIRBORNE NOBLE GAS DOSES Qtr 1 Qtr 2 Qtr 3 Qtr 4 ANNUAL Gamma Air (mrad) 5.81 E-04 8.06E-06 2.89E-03 5.23E-03 8.71 E-03 Applicable Limit (mrad) 5 5 5 5 10 j

IBeta Percent of Limit l (%) 1.16E-02 1.61E-04 5.78E-02 1.05E-01 8.71 E-02 Air (mrad) 1.69E-03 3.27E-04 1.30E-02 1.96E-02 3.46E-02 Applicable Limit (mrad) 1 10 10 10 10 20 j Percent of Limit (%) 7 1.69E-02 3.27E-03 1.30E-01 1.96E-01 1 .73E-01 C. AIRBORNE IODINE and PARTICULATE DOSES l Qtr 1I Qtr 2 I Qtr 3 I Qtr 4 I ANNUAL Iodine/Part (mrem) 9.90E-05 4.43E-05 6.06E-05 1.21 E-02 1.23E-02 Applicable Limit _(mrem) 7.5 7.5 7.5 7.5 15 Percent of Limit (%) 1.32E-03 5.91E-04 8.08E-04 1.61 E-01 8.20E-02 jAge Group I I Child I Child l Child I Child l Child lCritical Organ I I Liver I Liver I Liver I Thyroid I Thyroid I

Docket No. 50-3, 50-247, & 50-286 Page 36 of 76 INDIAN POINT 3 NUCLEAR POWER PLANT RADIOLOGICAL IMPACT ON MAN JANUARY - DECEMBER 2004 Maximum exposed individual doses in mrem or mrad A. LIQUID DOSES Qtr4 ANNUAL Qtrl Qtr 1 Qtr 2 Qtr 3 Qtr 3 Qtr 4 ANNUAL Organ Dose (mrem) 6.90E-05 l 6.95E-05 1.92E-04 2.24E-04 5.54E-04 Applicable Limit (mrem) 5 l 5 5 5 10 Percent of Limit (%) 1.38E-03 1.39E-03 3.83E-03 4.48E-03 5.54E-03 Age Group Adult Adult Adult Adult Adult Critical Organ GILLI GILLI GILLI GILLI GILLI Adult Total Body (mrem) 4.22E-05 1.81 E-05 1.18E-05 1.32E-04 2.04E-04 Applicable Limit (mrem) 1.5 1.5 1.5 1.5 3 Percent of Limit (%) 2.81 E-03 1.21 E-03 7.88E-04 8.77E-03 6.79E-03 B. AIRBORNE NOBLE GAS DOSES l Qtr 1 Qtr 2 Qtr 3 Qtr 4 ANNUAL Gamma Air (mrad) J 2.24E-05 2.54E-05 2.41E-05 l 4.41 E-05 [ 1.16E-04 Applicable Limit (mrad) 5 5 10 J Percent of Limit (%) 4.48E-04 5.08E-04 4.82E-04 8.82E-04 1.16E-03 Beta Air (mrad) 2.56E-05 5.06E-05 2.70E-04 4.25E-04 7.71 E-04 l Applicable Limit (mrad) 10 10 10 10 20 J Percent of Limit (%) 2.56E-04 5.06E-04 2.70E-03 4.25E-03 3.86E-03 l C. AIRBORNE IODINE and PARTICULATE DOSES IQtr 1l Qtr 2 l Qtr 3 Qtr 4 l ANNUAL Iodine/Part (mrem) 2.08E-04 1.95E-04 1.66E-04 2.28E-04 7.97E-04 lApplicable Limit I (mrem) l 7.5 l 7.5 l 7.5 l 7.5 l 15 l Percent of Limit (%) 2.77E-03 2.60E-03 2.21 E-03 3.04E-03 5.31 E-03 lAge Group l l Child I Child l Child I Child I Child Critical Organ Liver Liver Liver Liver Liver

Docket No. 50-3, 50-247, & 50-286 Page 37 of 76 Indian Point Energy Center (Units 1, 2, and 3)

RADIOLOGICAL EFFLUENT REPORT F. METEOROLOGICAL DATA Jan 1, 2004 - Dec 31, 2004 This data is stored onsite and is available in printed or electronic form.

Docket No. 50-3, 50-247, & 50-286 Page 38 of 76 Indian Point Energy Center (Units 1, 2, and 3)

RADIOACTIVE EFFLUENT REPORT G. OFFSITE DOSE CALCULATION MANUAL, PROCESS CONTROL PROGRAM, OR LAND USE CENSUS LOCATION CHANGES 2004 There were no changes in the REMP locations for dose calculations and/or environmental monitoring in year 2004.

There were no changes to the Land Use Census in year 2004.

The PCPs were not upgraded in this period.

They remain Rev 7 for unit 3 and Rev 9 for units 1 and 2.

Unit 1 and 2's ODCM was upgraded in February, 2004 to Revision 8.

Unit 3's ODCM was upgraded in January, 2004 to Revision 16.

(See the following pages)

Docket No. 50-3, 50-247, & 50-286 Page 39 of 76 Brief Summary of Changes for Units I and 2 ODCM Rev 8, Feb 2004 1 Incorporated errata previously noted from ITS submittal in section 3.0.

2 Modified Table 3.2.1-1 to split VCPRIPurge requirements, updated PV/SV H-3 requirements, added a precaution to grab sampling for airborne H-3, and restructured requirements for collection of 24-hr charcoals.

3 Corrected typo in 3.2.2 to change air dose to 'mrad'and added 'air"to the dose listed in condition "A.

4 Corrected same typo in 3.2.4 and 3.2.5, and adjusted DSR 3.2.5.1 to ensure it applied to all gaseous releases.

5 Modified Table 3.3.1-1 to include R-62 and the NCD &SFDS outlet flow totalizers as effluent instrumentation.

6 Modified Table 3.3.2-1 to include R-45's lack of a physical low flow alarm. Also modified R-60's requirement for source checks from 'pnorto release" to every 31-days like R-44 (this was an errorleft in unit I Tech Specs).

7 Modified D 4.1 to clarify -UNRESTRICTED AREA' and the use of the site map (Figure D 4.1-1).

8 Modified D 5.2d to clarify the discussion regarding MET data usage for effluents.

9 Modified ODCM Part II, section 1.1 to include updated liquid effluent methodology, including sampling descriptions for SG Blowdown, sharing dilution flow without the use of the outdated 'MOUs, and other general program description and format.

10 Modified section 1.2 to identify 10CFR20 for source of instantaneous release rate regulation and modified the description of how Tritium release rate is controlled.

11 Added RECS limits, a description of applicable pathways, and a discussion regarding C-14 to section 1.3.

12 Improved definition of DF in equation (L-1) in section 1.4.

13 Improved definition before and after equation (L-2).

14 Added verbiage to dose projection requirements in Tables 1-1 and 2-1.

15 Added Tables 1-2 to 1-5 (Dose and Bioaccumulation factors for each isotope and age group).

16 Modified release rate limit sharing (without the use of the old MOUs), added C-14 discussion, and modified description of Table 2-1 in section 2.1.

17 Modified representation of equations G-1, G-2, and G-3, including equation for K-eff in section 2.3.

18 Modified representation of equations G-4 through G-7 in section 2.4.

19 Modified representation of equations G-8 through G-10 in sections 2.5 and 2.6.

20 Modified representation of equations G-1 I through G-18 in sections 2.7.

21 Added Tables 2-2 through 2-12.

22 Added examples of the use of occupancy factors in ODCM Part I, section 3.0, per RECS 3.4.1.1 23 Added explanation of terms in ODCM Part II, section 4.2.1 24 Added explanation to the SGBD flash tank vent partition factor in Appendix D..

25 Added Appendix I to show the derivation and equations for determining the uCi/sec split between units for sharing the 10CFR20 airborne effluent limits.

Docket No. 50-3, 50-247, & 50-286 Page 40 of 76 item 1 OBJECTIVE:

Incorporate the errata noted in RECS 3.0 from the ITS project.

DESCRIPTION OF CHANGES:

Updated minor word changes in the direction for DLCOs and DSRs.

IMPACT:

None JUSTIFICATION:

These improvements are in keeping with NUREG 1431 and industry standard refinement of actions and surveillances. They do not present a challenge to licensing basis documents. Some changes were typographical from the previous revision, while others are for clarification and consistency with NUREG 1431. These statements ensure proper application of DLCOs and DSRs in the ODCM.

Docket No. 50-3, 50-247, & 50-286 Page 41 of 76 Item 2 OBJECTIVE:

Update RECS Table 3.2.1-1 to enhance consolidation and more closely follow NUREG 1301.

DESCRIPTION OF CHANGES:

1) Split VC Press Relief and Purge requirements
2) Updated PV/SV H-3 requirements (from weekly to monthly with caveats for SFP condition, per NUREGs 0472 and 1301)
3) Added precautionary phrases to the use of grab sampling for H-3 on the main plant vent (again from these NUREGS)
4) Restructured requirements for the collection of 24-hour charcoals from the outdated format to more clear direction such that a 24-hour charcoal is collected for 1-133 & 1-135 only upon positive identification of any Iodine on the weekly charcoal, not to exceed one 24-hour charcoal test in a 31-day period.

IMPACT:

None. The updates are more in keeping with NUEG 1301. The redefined 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> charcoal collection requirements will allow simplification of lower tier documents as time allows.

JUSTIFICATION:

The inclusion of separate rows for VC Press Relief and Purge is a clarification beyond the licensing bases documents (NUREG 0472, 1301, 1431), but will assist in consolidating IPEC ODCMs. Since an understanding of the methods of VC Pressure Reliefs are required by Reg Guide 1.21, it is beneficial to include the basis for VC Press Relief quantification (not just Purges).

The PV/SV H-3 periodicity is established in bases documents (NUREGS 0472 and 1301) as a MONTHLY sample, allowing for either a "grab" or "continuous" sample arrangement in virtually every ODCM in the US. However, these documents do, in fact, require WEEKLY sampling when the CONTINUOUS sampling is not in effect while there is spent fuel in the spent fuel pool. Indian Point 2 adopted this overly conservative methodology upon initial licensing, selecting WEEKLY for the periodicity on the PV and SV Tritium analyses since initial startup. No other plant in the country could be found where this test was performed weekly, while Indian Point 2 was actually performing this test tvice a week, to meet the perceived requirement. In reality, plants with continuous monitoring (silica gel columns), like Indian Point 2 and 3, need not be subject to this extra sampling (perNUREG 0472 and 1301, Tables 4.11-2, Notes 4 and 5). Therefore, H-3 sampling of the PV and SV is STILL listed as "continuous", but the analysis frequency was changed to every 31 days. The appropriate notes were referenced to ensure grab sampling periodicity is increased, should the continuous sampling be interrupted (identical to unit 3's caveat). In reality, the analysis frequency for both units is actually established by the approved continuous sampling method, itself, as the Silica column is changed-out and analyzed when it indicates it is full of moisture (approx 21 days).

The impractical practice of performing a 24-hour charcoal test monthly was an attempt at both units to comply with the requirement of looking for 1-133 and 1-135 following power changes, startups, or shutdowns. This sampling was required if RCS DEI and PV Noble Gas increased by a factor of 3 as a result of the power change. Since this condition is RARELY observed, and random selection of a 24-hour charcoal test does NOT offer a tangible benefit for quantification, direction was added to obtain these samples, not only when these conditions are met, but anytime a positive lodine-131 is identified in the weekly routine analysis, on a frequency not to exceed once per 31 days. In other words, if each weekly charcoal is free of iodine, no test is required for 1-133/135. This direction, coupled with the existing direction, will ensure that 24-hour charcoal samples are collected when they need to be, while simultaneously enhancing the efficiency and credibility of the effluents program.

Docket No. 50-3, 50-247, & 50-286 Page 42 of 76 Item 3 OBJECTIVE:

Correct typo in RECS 3.2.2 to change air dose to from umrem" to umrad".

DESCRIPTION OF CHANGES:

Corrected typo to change air dose to 'mrad" and added "air" to the dose listed in condition "A" IMPACT:

None JUSTIFICATION:

Typographical carry-over from initial licensing error. NUREG 0472 and 1301 use "mrad" in this location.

Docket No. 50-3, 50-247, & 50-286 Page 43 of 76 Item 4 OBJECTIVE:

Correct typo in RECS 3.2.4 and 3.2.5 to change air dose to from 'mrem" to "mrad".

DESCRIPTION OF CHANGES:

Corrected 3.2.4 and 3.2.5 typo to change air dose to "mrad" and DSR 3.2.5.1 to identify 'gaseous releases", not just Iodine and Particulate.

IMPACT:

None JUSTIFICATION:

The changes from "mrem" to "mrad" are typographical and were carried forward from initial licensing. NUREG 0472 and 1301 use "mrad" in this location.

This DSR is similar to that of noble gas (3.2.4.1) but applies only when the cleanup systems are NOT in service. Since the 31-day projection air-dose limits for noble gas are provided in the DLCO, it is more appropriate to ensure the DSR applies to them as well, hence the more general words "gaseous releases", per NUREG 1301.

Docket No. 50-3, 50-247, &50-286 Page 44 of 76 Item 5 OBJECTIVE:

Include R-62 and effluent totalizers on the North Curtain Drain (NCD) and Sphere Foundation Drain Sump (SFDS) as instrumentation requiring ODCM surveillance.

DESCRIPTION OF CHANGES:

Added requirements for the daily channel check and a 2-year calibration for the effluent flow totalizers.

Added requirements for the channel check, source check, channel operational check, and refueling calibration for R-62.

IMPACT:

The effluent flow totalizers will be checked daily and a calibration test will be performed every 2 years after installation. The calibration test may constitute swapping out the instrument with a spare and arranging with the vendor to calibrate the device between cycles. The testing for R-62 is already in place.

JUSTIFICATION:

The North Curtain Drain pathway had been treated as a batch release pathway, including the use of Frac Trucks and associated flow rate and level instruments. With the modification complete, once the pathway is operated as intended, it will be an intermittent continuous release. This kind of pathway in bases documents typically includes a flow meter or totalizer to allow proper quantification of effluents. Since this mechanical flow totalizer has no automatic functions, the only requirements consistent with NUREG 1301 are the daily channel check and the refueling calibration. These requirements were added to Table D 3.3.1-1, part 3c to comply with a typical continuous release pathway description in NUREG 1301 and Reg Guide 1.21.

Effluent instrumentation for the Sphere Foundation Drain Sump (R-62 and the totalizer) are required by unit 1 Technical Specifications (Section 4.4). They were inadvertently omitted from the ODCM update when these specifications were updated for ITS because they were not specifically identified in the old sections of unit 2 technical specifications (3.9 and 4.10), but merely mentioned in a paragraph summarizing unit 1 operating limits.

They are now listed among other required effluent instrumentation in the ODCM for clarity and consistency with NUREG 1301.

Docket No. 50-3, 50-247, & 50-286 Page 45 of 76 Item 6 OBJECTIVE:

Modify Table 3.3.2-1 to stipulate R-45's inability to bring up or test a low flow alarm. Modify R-60's source check requirement from 'prior to release" to "every 31 days" like R-44.

DESCRIPTION OF CHANGES:

The Condenser Air Ejector monitor (R-45) does NOT have a low flow alarm and cannot be tested like other monitors in this specification. An added note (e)was added to specifically exclude the need to test the low flow alarm during the Channel Operational Test of R-45.

Modified the source check requirements for R-60 (unit 1 stack vent) from "prior to release" to every 31 days.

IMPACT:

None JUSTIFICATION:

This update is necessary to differentiate monitors that can be tested for this automatic function from those that do not include it. Since there is no automatic function to test, the requirement for R-45 is separated from other monitors.

R-60's source check requirements were erroneously carried forward from old unit I Technical Specifications. This requirement was previously set to "prior to release" when applicable to unit 1 gas decay tanks or other unit 1 equipment. The only releases directed to unit 1 stack are continuous and a source check "prior to release" is not applicable. Changing this to the standard requirement of every 31 days was deferred so it could be updated here in the ODCM via the 10CFR50.59 process. Setting the periodicity of this monitor's source check to every 31 days is consistent with other continuous release monitors like R-44 and guidance in NUREG 0472, 1301, and 1431.

Docket No. 50-3, 50-247, & 50-286 Page 46 of 76 Item 7 OBJECTIVE:

Resolve the confusion with the map defining 'UNRESTRITED AREA" in RECS

4.1 DESCRIPTION

OF CHANGES:

Added the phrase from unit 3 ODCM, describing the expanded definition of "UNRESTRICTED AREA" (over that of 10CFR20) to refer to areas "at or beyond the site boundary" and that the definition did not apply over water bodies. This differs from inferred earlier definitions and notes on the map suggesting that the UNRESTRICTED AREA boundary in the compass direction of the river, was on the far shore. This inference is incorrect. The map, as well as the verbiage in RECS 4.1 were updated to remove this confusion.

IMPACT:

No impact for effluents. Effluent dose calculations were always considered in the most restrictive area, and this point was not over water. This clarification prevents a negative impact due to a potential mis-interpretation in evaluating the dry-cask storage issues at Indian Point.

JUSTIFICATION:

Although unit 2 has not yet adopted the new 10CFR20, the over-riding definitions of SITE BOUNDARY and UNRESTRICTED AREA (for effluent concerns) are still drawn from NUREG 0472. The wording in the paragraph before the map clarifies any potential confusion as to the applicability of this rule over water, and is identical to that of unit 3's ODCM for integration concerns.

Docket No. 50-3, 50-247, & 50-286 Page 47 of 76 Item 8 OBJECTIVE:

Clarify the ambiguous MET data discussion in D5.2d of the RECS.

DESCRIPTION OF CHANGES:

The previous words in the section were derived from NUREG 0472, but used erroneous phraseology. The original words were an attempt to justify the use of live or averaged MET data for calculating doses to workers inside the site boundary. In the old passage, the preferred method was stated (from industry standards in the 70's), only to be immediately followed in the next sentence with a caveat which appeared to allow any type of MET data usage. The two effected sentences were re-worded to simply state the typical use of annual average MET data as the normal method.

IMPACT:

None. Actual usage of annual average MET data occurred, which is consistent with industry practice.

JUSTIFICATION:

There are no challenges to basis documents in improving the words of this paragraph. Live MET data remains available for use in special circumstances, but for this application, the industry standard and most defendable method is to use annual average data, determined from a period of averaging actual MET data. The rewording of these two sentences removes the vague caveat, and states the normal method of determining the MET data for this purpose, in keeping with NUREG 0133 and Reg Guide 1.23.

Docket No. 50-3, 50-247, & 50-286 Page 48 of 76 Item 9 OBJECTIVE:

Update the narrative in ODCM Part II, Section 1.1 regarding liquid effluents.

DESCRIPTION OF CHANGES:

Added or modified several phrases to assist in integration of units ODCMs, as follows:

1) Added specifics regarding assurances of representative samples of Distillate Tanks, Steam Generators, and water from the North Curtain Drain.
2) Renamed monitor calibration factor as conversion factor (uCiml per net cpm).
3) Updated liquid setpoint options to allow increasing if unit 3 dilution can be "borrowed", without using the term "MOU" (borrowing is controlled by unit Shift Managers).
4) Added statement regarding the "documentation" of continuous releases, but no permit required.

IMPACT:

None JUSTIFICATION:

These additional or modified statements do not alter the effluents program or the intent of the liquid portion of the ODCM. They provide greater specifics on the unit 2 pathways and ensure terms for rad monitor setpoints are identical between units. Communication protocol for "borrowing circulators" is defined without using the old term Memorandum of Understanding (MOU) as this communication is now simply performed between Shift Managers (same utility). This method will continue to ensure compliance with IOCFR20 and guidance from NUREG 1301.

Docket No. 50-3, 50-247, & 50-286 Page 49 of 76 Item 10 OBJECTIVE:

Clarify ODCM Part II, Section 1.2 with regard to the use of the old Part 20 and Tritium release rate controls.

DESCRIPTION OF CHANGES:

Specifically identified 10CFR20 as the source for instantaneous release rate regulation. Modified the sentence regarding tritium to show specific methods by which compliance is guaranteed for this isotope (apportioning dilution specifically for this purpose).

IMPACT:

None.

JUSTIFICATION:

These improvements clarify existing controls and practice and do not involve a change. The added words for tritium improve traceability to actual 10CFRO20 compliancy and address questions from previous audits regarding the specific methods of control of tritium release rates, which were adequately covered in lower tier documents. This added sentence in the ODCM allows for better traceability to 10CFR20 and NUREG 0472, and 1301, with regard to specific requirements for diluted concentration of tritium in the discharge canal.

Docket No. 50-3, 50-247, & 50-286 Page 50 of 76 Item 11 OBJECTIVE:

Add RECS limits, a discussion of applicable pathways, and methodology for quantifying C-14 to ODCM Part II, section 1.3.

DESCRIPTION OF CHANGES:

Added a summary of the RECS limits at the start of this section. The applicable pathways for liquid effluent were updated per references in the ODCM from NY University Medical Center, to fresh water fish and salt water invertebrates, and a summary of the methodology for C-14 quantification was added to the ODCM from the work performed and summarized in the unit 3 and JAF ODCMs.

IMPACT:

New software for tracking liquid effluent dose has been implemented with the new, slightly updated dose and bio-accumulation factors. No significant change in reported dose will result from these changes alone.

JUSTIFICATION:

The adoption of one set of rules and factors for IPEC liquid effluents was part of the site integration plan. Specific identified pathways for liquid effluents do not force any particular change in calculational methodology. Dose factors and bio-accumulation factors in use at the site were prescribed from studies listed in the ODCM references, and the use of site-specific factors where applicable. Although unit 2 and 3 initially chose different pathway names, the bulk of the site-specific parameter changes drove the dose factors toward common values.

Due to the more documented pedigree from NY University Medical Center (Ref 18), works by M.E. Wren and J.W. Lentsch (Ref 20), and multiple references from the unit 3 ODCM, the liquid pathways selected for IPEC were updated to fresh water fish and salt water invertebrates. The use of sound, defendable, site-specific factors over those suggested in Reg Guide 1.109 are highly recommended in NUREG 0133, 0472, and 1301. This practice has also been identified by several independent auditors as a significant improvement from the base level of compliance with these documents.

Docket No. 50-3, 50-247, &50-286 Page 51 of 76 Item 12 OBJECTIVE:

Improve the definition of DF in equation L-1 in section

1.4 DESCRIPTION

OF CHANGES:

1 DF' was described per RG 1.109 as "Environmental Transit Time" to show its origin, rather than simply identify it as the decay factor between sample time and start of release. This term was also identified as being conservatively set to 1.0, as releases of short half-lived isotopes are avoided.

IMPACT:

None JUSTIFICATION:

This improvement clarifies compliance with RG 1.109 for liquid effluent dose calculations. The current wording allows for simplification of the calculation (short lived isotopes are not routinely released), while still showing traceability to the basis document's equation.

Docket No. 50-3, 50-247, & 50-286 Page 52 of 76 Item 13 OBJECTIVE:

Improve the definition of equation L-2 in section

1.4 DESCRIPTION

OF CHANGES:

The paragraphs before and after the equations were amended to clarify isotopes most likely to be major contributors to dose, and to include greater detail in the descriptions of terms in the equation.

IMPACT:

None JUSTIFICATION:

All isotopes are included in dose calculations. These paragraphs simply provide the reader with the isotopes that are typically most predominant. Including greater detail from RG 1.109 for the equation parameters improves traceability. There are no changes to this methodology.

Docket No. 50-3, 50-247, & 50-286 Page 53 of 76 Item 14 OBJECTIVE:

Add instruction for determining the 31-day dose projection requirements listed on Tables 1-1 and 2-1.

DESCRIPTION OF CHANGES:

Added specific direction as to how the 31-day dose projections are performed, rather than simply stating the requirement. A simple equation was added, showing monthly doses averaged over a specified period as the starting point, plus or minus major planned evolutions.

IMPACT:

None.

JUSTIFICATION:

This format allows for adjusting the projection just before or after a refueling outage, while still providing guidance as to its formulation. The requirement for a stipulated method of performing dose projections originates in Reg Guide 1.109 as well as NUREG 0133, and is regularly a subject of effluent inspections by the NRC. This improvement was individually identifies as being needed in the liquid waste self assessment in Aug 2003. The added specifics in these sections of the ODCM do not change the regulation or surveillance, but ensure there is an auditable set of criteria for this projection. It also provides consistent direction for both units 2 and 3 for future integration of ODCMs, while maintaining the requirements of the RECS (which are driven from NUREGs 0133 and 1301) for 31-day dose projections.

Docket No. 50-3, 50-247, & 50-286 Page 54 of 76 Item 15 OBJECTIVE:

Add tables to ODCM Part II, Section 1, for dose factors and bio-accumulation factors for each isotope which could be identified in liquid waste.

DESCRIPTION OF CHANGES:

While previous revisions only listed the key isotopes for liquid waste dose assessment, inclusion of ALL isotopes in the liquid waste nuclide library has become industry standard, since calculations are now all generally performed by computer. Previous computer codes did, in fact, include all isotopes, as will future computer codes. Each isotope's factors were added to the ODCM listings for completeness. This listing is comprised of Tables 1-2,1-3,1-4, and 1-5.

IMPACT:

None.

JUSTIFICATION:

It is industry standard practice that offsite doses can be correctly calculated with no other reference but the ODCM, should it be necessary. While the dose factors for the infrequently seen missing nuclides were, in fact, included in station software, they were added to this rev of the ODCM for completeness and to assist in the move toward integration, as defined in NUREG 0133 and Reg Guide 1.109.

Docket No. 50-3, 50-247, & 50-286 Page 55 of 76 Item 16 OBJECTIVE:

Update ODCM Part II, Section 2.1 to clarify the 10CFR20 dose rate split between units, define "long term releases" per NUREG 0133, add a discussion of C-14 emissions, and re-define Table 2-1.

DESCRIPTION OF CHANGES:

Updated the verbiage of the split for noble gas air dose and its basis (discussed later in the setpoint sections).

Added phrases from the unit 3 ODCM defining long term" releases per NUREG 0133, and the C-14 conclusions (determined from the work at IP3 and Fitzpatrick in the early 1980's). Defined Table 2-1 to be a summary of RECS requirements, similar to Table 1-1 for liquids (the previous information on old Table 2-1 was moved to Appendix I, discussed later).

IMPACT:

None JUSTIFICATION:

While the 10CFR20 setpoint bases and sharing are discussed later (in the setpoint section), this section first mentions the basis for a split other than simply 50-50. This discussion was clarified without the use of the outdated term UMOU7. A straightforward description of the term long term releases" was added directly from NUREG 0133 to ensure there is an audit trail for the use of annual average MET data, and complete understanding of the SITE release rate applicability for 10CFR20.

Additionally, information from unit 3's work with C-14 in the early 1980's was added to this section to include coverage of how C-14 is quantified. This work was accepted as bases material for quantification of C-14 at Fitzpatrick and Indian Point 3 on a basis of production (GW(e)) per year. It is now bases material owned by Entergy and can be applied to unit 2, as well. Therefore, the curies and dose from C-14 is now based on effective full power hours for the effected plant.

The previous information from the old Table 2-1 was moved to Appendix I, so the new Table 2-1 could match the purpose of Table 1-1, defining the RECS requirements for airborne effluents. There are no changes to the controls or surveillances from these changes. The data was simply relocated.

These updates were performed for clarity and to ensure better traceability to NUREGs 0133 and 1301 for defining the ODCM and the effluents program.

Docket No. 50-3, 50-247, & 50-286 Page 56 of 76 Item 17 OBJECTIVE:

Update ODCM Part II, section 2.3 to include definition of all equation parameters.

DESCRIPTION OF CHANGES:

Some parameters in these equations were not fully described. There source (Reg Guide 1.109 or NUREG 0133) was added, and in a few cases, a new term was added for clarity. Equations were represented with Microsoft Word's Equation Generator for greater accuracy and readability. A term for total gaseous release rate qt was added in equation G-2 for completeness. Kff and it's components were more clearly defined, per RG 1.109 IMPACT:

None JUSTIFICATION:

There were no changes to these calculations. The equations were clarified with modern word processing tools to ensure they demonstrate complete compliance with the equations found if NUREG 0133 and Reg Guide 1.109. There were no changes to software codes are hand calculation methodologies. These updates also ensured each term in the equation was defined as to its origin: either user input, or a constant from the source documents.

Docket No. 50-3, 50-247, & 50-286 Page 57 of 76 Item 18 OBJECTIVE:

Update the representation of Iodine and Particulate dose rate equations in ODCM Part II, Section 2.4.

DESCRIPTION OF CHANGES:

Modified the Iodine and Particulate dose rate equation to exclude the milk and ground plane pathways.

Discussed potential addition of these pathways per the land use census if required. Added definition and values for breathing rates in equation G-6.

IMPACT:

None. There was no actual cow-milch pathway within the 5 mile radius. Overestimation of doses did not represent actual release impact.

JUSTIFICATION:

Effluent inspectors, independent auditors, and NUREG 0133 itself, has repeatedly urged utilities to carefully tie the land use census and site specific parameters into the ODCM in such a way as to be as accurate as possible with modeled releases. Specifically, in later years, ANI has been clear on the negative litigation potential of reporting phantom dose in the guise of uconservativism". Since there remains a close tie between the land use census, the REMP, and the Effluents programs, modeling of only those pathways actually significant to the licensee has become the industry standard approach.

At IPEC, the Franklin Institute was contracted to prepare the ODCMs and original Technical Specifications for each unit. Based on the later studies at unit 3, the ground plane pathway was determined to be an insignificant contributor to the dose rate at the site boundary for Iodine and Particulate, and reflected in the final documents from the Franklin Institute for unit 3. Since the distance to the site boundary is indeed larger for unit 2, this updated methodology has been applicable for unit 2, as well. Since the ground plane pathway for dose rate at the site boundary is still insignificant with respect to the dose from inhalation, it is excluded from the unit 2 ODCM on the same bases after integration. Hand and computer calculations continue to demonstrate that the ground plane pathways contributes less than 0.1% of the dose rate from lodine-131 at the site boundary, confirming the conclusions from the Franklin Institute and NUREG 0133.

There is no cow-milk pathway identified in the REMP or the IPEC land use census. Therefore, this pathway was excluded from later revisions of the unit 3 ODCM, and should be excluded from unit 2's.

The inclusion of actual breathing rates for each age group was performed for completeness, to assist in the integration of the station ODCMs, and to better show compliance with Reg Guide 1.109.

Docket No. 50-3, 50-247, & 50-286 Page 58 of 76 Item 19 OBJECTIVE:

Update the representation of Noble Gas air dose calculations in ODCM Part II, Sections 2.5 and 2.6.

DESCRIPTION OF CHANGES:

Gamma and Beta air dose calculations were more clearly represented with standard equations from NUREG 0133, and included a potential ground level component, normally zero. Terms in these equations were defined per Reg Guide 1.109.

IMPACT:

None JUSTIFICATION:

Equations did not change, but were clarified and defined completely, per Reg Guide 1.109 and NUREG 0133.

An added term was included in case of ground level releases, again per these source documents.

Docket No. 50-3, 50-247, & 50-286 Page 59 of 76 Item 20 OBJECTIVE:

Improve the representation of the equations in ODCM Part II, Section 2.7, and include descriptions of each identified parameter in the equations.

DESCRIPTION OF CHANGES:

Many pages of detail were added to this section to fully describe the airborne dose factors (Ri, Rv, and Rg). The cow-milk pathway is excluded per the land use census. Special equations were added for the computation of Tritium doses. Microsoft Word's equation generator was used for these complex equations.

IMPACT:

None JUSTIFICATION:

Other than the elimination of the milk pathway, no changes were made to these equations. They were represented with more clarity, and each term is defined, from verbiage found in the tables of Reg Guide 1.109 and NUREG 0133. These expressions and their explanation are identical to those used in the source documents, as well as unit 3's ODCM for enhanced integration of the effluents program. The inclusion or exclusion of the cow-milk pathway is dependant on the results of the land use census. Current industry best practices are NOT to include false pathways in a less-than-accurate attempt to show conservativism. Generally, these decisions led to the accumulation of false data from which negative criticism arose from the NRC as well as outsiders with regard to the historical record and general litigation protection. INPO, the NRC, and particularly ANI are now adamantly opposed to this 'conservative" approach and strongly recommend a more accurate compilation of modeled offsite dose calculations.

While this policy places demands on keeping the land use census current and reacting to any changes, the guidelines and policies of the REMP are strong enough to ensure we can rely on these programs for timely updates. The inclusion of only active pathways is now industry standard and the REMP organization understands their responsibility in keeping the census current, as defined in the RECS and NUREGs 0472 and 1301.

  • Docket No. 50-3, 50-247, & 50-286 Page 60 of 76 Item 21 OBJECTIVE:

Add Table 2-2 through 2-12 in ODCM Part II, Section 2.

DESCRIPTION OF CHANGES:

Forty pages of tables were added to the ODCM to ensure each isotope, age group, and organ has a dose factor listed. This improvement is due to the industry standard practice ensuring the ODCM can be used as a stand-alone document to calculate effluent doses, should it become necessary, and for completeness. The tables were in fact inherent in the software used to calculate doses, but are now added to the ODCM as well.

IMPACT:

None.

JUSTIFICATION:

It is industry standard practice that offsite doses can be correctly calculated with no other reference but the ODCM, should it be necessary. While the dose factors for the infrequently seen missing nuclides were, in fact, included in station software, they were added to this rev of the ODCM to assist in the move toward integration, and to demonstrate complete compliance with Reg Guide 1.109.

Docket No. 50-3, 50-247, & 50-286 Page 61 of 76 Item 22 OBJECTIVE:

Add an example of the 'occupancy factor' application for 40CFR1 90 dose calculations in Section 3.0.

DESCRIPTION OF CHANGES:

Added a paragraph showing the application of the occupancy factor for ODCM calculations of total dose for MEMBERS OF THE PUBLIC within the site boundary IMPACT:

None JUSTIFICATION:

RECS 3.4.1 includes DSR 3.4.1.1 which requires these dose calculations in accordance with the methodology and parameters in the ODCM (as defined in NUREGs 0133, 0472, and 1301). The example was added to demonstrate compliance of this methodology in showing the insignificance of the "total dose" component of this calculation, while complying with 40CFR1 90 requirements of this section.

Docket No. 50-3, 50-247, & 50-286 Page 62 of 76 Item 23 OBJECTIVE:

Add an explanation of terms used in ODCM Part II,section 4.2.1.

DESCRIPTION OF CHANGES:

The original work performed to back-calculate a conservative uCi/sec release rate associated with 10CFR20's noble gas release rate limit was represented in this section as a single equation. Two terms were undefined and an explanation of their origin was added.

IMPACT:

None JUSTIFICATION:

No changes were made to this equation. Terms were better defined and a reference was added to identify greater detail to be found in Appendix I.

Docket No. 50-3, 50-247, & 50-286 Page 63 of 76 Item 24 OBJECTIVE:

Add explanation of terms used in Appendix D of ODCM Part II.

DESCRIPTION OF CHANGES:

Added the explanations of terms in the f factor equation of Appendix D (enthalpy of steam at pressure and in the tank).

IMPACT:

None JUSTIFICATION:

This additional information was included to provide a basis for the conversion of steam to a mixture of both steam and water in the tank(s), primarily for Tritium quantification. The equations were derived from the Steam Tables and Westinghouse descriptions of the Flash Tanks for partitioning the potential Tritium in SG blowdown and the flash tank vent, if either of these pathways are used. Listing the enthalpy of the steam and showing the units (BTU/lbm) aids in establishing the bases for future references and for a more successful audit trail.

Docket No. 50-3, 50-247, & 50-286 Page 64 of 76 Item 25 OBJECTIVE:

Add Appendix I (from old Table 2-1 and unit 3's Appendix) to describe the joint sharing of 10CFR20 and 10CFR50 limits for units 2 and 3.

DESCRIPTION OF CHANGES:

Appendix 3-A from unit 3's ODCM was inserted into unit 2's ODCM as Appendix I to show the apportionment and distribution of dose rate limits, as well as the generation of time averaged limits from specified release mixtures.

IMPACT:

None JUSTIFICATION:

This appendix adds the historical documentation of the formulation of the shared limits for both units. It serves only as a basis for application of setpoints in lower tier documentation. These back-calculated setpoints are performed in accordance with 10CFR20 and 10CFR50 for both plants, with the appropriate split identified for I OCFR20, due to the different distances to the site boundary. This information was summarized in single page in previous revisions, and expanded to match the description iri unit 3's ODCM and to assist in site effluents integration, as well as clearly show the methods of site-wide compliance with 10CFR20 limits.

Docket No. 50-3, 50-247, & 50-286 Page 65 of 76 Prepared by: Steven Sandike Unit 3 ODCM Rev 16 Justification Package Jan 12, 2004

1. Removed duplicated referenced terms in RECS 1.0 which were already defined in Tech Specs, leaving those not yet defined.
2. Replaced the old verbiage for 'Channel Functional Test' with the new phrase from Tech Specs: 'Channel Operational Test" to be consistent with NUREG 1431 and ITS.
3. Removed references to PORC and replaced with OSRC.
4. Reworded ODCM Part II, Steps 2.1.7, 2.1.8, 2.2.2, and 3.1.6 to remove references to 'Memorandums of Understanding. Identified the routine methods of 10CFR20 and 10CFR50 assurances from site integration.
5. Clarified the term E in equation from ODCM Part II, Step 2.2.6.d Added the word 0existing" to clarify that this term is used for the required dilution flow for pre-existing releases, prior to calculation of required dilution for further releases.
6. Clarified the equation following ODCM Part II, Step 2.2.6.e. The improved definition of the term E was incorporated here as well. Following the equation, a statement was parenthetically added noting that with no concurrent releases, the term B becomes the available release rate without having to perform this subtraction.
7. Corrected the typographical error in the equation following ODCM Part II, Step 2.4.2. The outside summation is inferred to include all terms following the sign, which is better expressed with brackets around all terms following the first summation. These outside brackets were added to the equation.
8. Added the Condenser Air Ejector as a ground level release point, ODCM Part II, Sec 3.1.20.
9. In ODCM Part II, step 3.3.2, included the basis for only using inhalation pathway for instantaneous Iodine, Particulate, and H-3 dose rate measurements at the site boundary, rather than also including the ground plane and milk pathways mentioned in NUREG 0133. Added a sentence identifying the equation's use of only the inhalation pathway, as the other two pathways are insignificant or non-existent.
10. Updated Appendix 3-A, Page 1, to match Indian Point 2 ODCM and better explain the meteorological terms.

Slightly modified the distances in the unit 2 column to match the unit 2 ODCM. Added extra explanation of each meteorological term.

11. Updated ODCM Part II, Section 4.0 (sample locations for the REMP), to identify new figures and information on the following maps and tables. The new maps are more clear and include county markings for reference points.

An additional map, Figure 4-3 shows all non-RECS locations. Eliminated confusion with sample location DR28 and DR31. Also eliminated confusion with regard to specific desired fish species to sample. Some specific examples of acceptable fish were added to the applicable listing, as well as a caveat to include similar species if needed. Added detail was provided to each sample location to preclude confusion with similar ones and to enhance standardization between units 2 and 3. These issues were identified in the June 2003 REMP self-assessment.

Each change is discussed in detail on the following pages.

Docket No. 50-3, 50-247, & 50-286 Page 66 of 76 Item 1 OBJECTIVE:

Remove duplicated referenced terms in RECS 1.0 which were already defined in Tech Specs.

DESCRIPTION OF CHANGES:

Removed those already defined in Tech Specs, leaving those not yet defined.

IMPACT:

None JUSTIFICATION:

This improvement was consistent with NUREG 1431 and modem bases documents designed to reduce superfluous repetition. To ensure no confusion, a note was added to RECS 1.0 at the beginning of the section regarding the common definitions found in the Technical Specifications.

Docket No. 50-3, 50-247, & 50-286 Page 67 of 76 Item 2 OBJECTIVE:

Replace the old verbiage for "Channel Functional Test" with the new phrase from Tech Specs: "Channel Operational Test" to be consistent with NUREG 1431 and ITS.

DESCRIPTION OF CHANGES:

Replaced all instances of the old phrase with the new one.

IMPACT:

None JUSTIFICATION:

This update in the syntax has no bearing on the actions inherent in this quarterly test.

The old words were updated to the new phraseology to be consistent with NUREG 1431 and ITS, which defined the new phrase, but did NOT define the old phrase.

Docket No. 50-3, 50-247, & 50-286 Page 68 of 76 Item 3 OBJECTIVE:

Remove references to PORC and replace with OSRC.

DESCRIPTION OF CHANGES:

Removed 'PORC" and replaced with UOSRC".

IMPACT:

None JUSTIFICATION:

Consistent with improved Technical Specifications and other governing documents.

&50-286 No. 50-3, 50-247, Docket Docket No. 50-3, 50-247, & 50-286 Page 69 of 76 Item 4 OBJECTIVE:

Reword ODCM Part II, Steps 2.1.7, 2.1.8, 2.2.2, and 3.1.6 to remove references to "Memorandums of Understanding" and describe how each unit controls assurances of compliance with 10CFR20 and 10CFR50 DESCRIPTION OF CHANGES:

Reworded 2.1.7, 2.1.8, and 2.2.2 identifying the routine method of 10CFR20 assurance as the use of unit-specific dilution flow (with Shift Manager intervention if circulators are to be 'borrowed"). Added description of routine method of 10CFR50 compliance as the use of total site dilution with each unit's resulting dose additive. Reworded Step 3.1.6 to describe integrated site compliance methods for 10CFR20 and referenced Appendix 3-A for description of generation of setpoints.

IMPACT:

Lower tier procedures removed references to "MOUs", while keeping existing practices and policies.

JUSTIFICATION:

It is common practice to record the Shift Manager's use of 'borrowed' circulators in the control rooms, to ensure common understanding of the duration of shared circulators for liquid releases. Airborne releases have routinely been controlled by already apportioned fractions of the 10CFR20 limit in each unit's noble gas radiation monitor setpoints.

"Memorandums of Understanding" are no longer required as a result of site integration.

These changes clarify the ongoing permitting and processing of liquid effluents, and the radiation monitor setpoint bases for airborne effluents, by clearly separating the requirements of 10CFR20 from those of 10CFR50.

These changes are in keeping with Improved Technical Specifications, 10CFR20, and other governing documents and will not present a challenge to effluent control.

Docket No. 50-3, 50-247, &50-286 Page 70 of 76 Item 5 OBJECTIVE:

Clarify the term E in equation from ODCM Part 11,Step 2.2.6.d DESCRIPTION OF CHANGES:

Added the word 'existing' to clarify that this term is used for the required dilution flow for pre-existing releases, prior to calculation of required dilution for further releases.

IMPACT:

None JUSTIFICATION:

This improvement clarifies methodology outlined in existing governing documents.

Although station procedures, practices, and software have correctly handled the possibility of multiple liquid effluent releases, this basis document description was not as clear as lower tier documents and software codes. This update should prevent confusion in the future and ensure traceability to bases documents. There are no changes in effluent processing or permitting and effluent control is not challenged.

Docket No. 50-3, 50-247, & 50-286 Page 71 of 76 Item 6 OBJECTIVE:

Reduce confusion in the equation following ODCM Part II, Step 2.2.6.e DESCRIPTION OF CHANGES:

The definition of B (available dilution flow) did not change. However, the improved definition of the term E was incorporated here as well. Following the equation, a statement was parenthetically added, noting that, with no other concurrent releases, the term B becomes the available release rate.

IMPACT:

None JUSTIFICATION:

This update again prevents potential loss of traceability for future updates. Station procedures, policies, and software correctly handle multiple liquid releases and apportionment of dilution. However, this and the previous equation required clarification in the bases document to preserve traceability.

Docket No. 50-3, 50-247, & 50-286 Page 72 of 76 Item 7 OBJECTIVE:

Correct the typographical error in the equation following ODCM Part II, Step 2.4.2.

DESCRIPTION OF CHANGES:

The outside summation is inferred to include all terms following the sign, which is better expressed with brackets around all terms following the first summation. These outside brackets were added to the equation.

IMPACT:

None JUSTIFICATION:

Typographical. The brackets are represented in NUREG 0133, but are now more clear in the ODCM, using Microsoft WORD's equation generator. (Station procedures, policies, and software have correctly implemented this expression in dose calculations.) The inclusion of the brackets allows closer comparison of the equation format with the governing document (NUREG 0133).

Docket No. 50-3, 50-247, & 50-286 Page 73 of 76 Item 8 OBJECTIVE:

Identify the Condenser Air Ejector as a ground level release point (for both units).

DESCRIPTION OF CHANGES:

Added the Condenser Air Ejector to those release points listed as ground level in ODCM Part 11, Section 3.1.20.

IMPACT:

Parameter updated in Effluents Management Software (RETDAS). No releases have been identified from this pathway since 1989 and the previous generation of Steam Generators at Indian Point 3. However, in an effort to more accurately identify ground level releases at both units, this pathway has been setup for the use of ground level MET data, should it ever become active.

JUSTIFICATION:

Although other gaseous release points are listed as "mixed mode", the condenser air ejector for both units is only a foot above the turbine deck roof. It is more appropriately listed as ground level. Therefore, the ground level dispersion coefficient from IP3-CALC-RAD-00001 was inserted as the applicable parameter in the software for this release point. Additionally, this pathway was, and continues to be treated as a ground-level release at unit 2. This update demonstrates compliance with the description and use of MET data in NUREG-0133.

Docket No. 50-3, 50-247, & 50-286 Page 74 of 76 Item 9 OBJECTIVE:

In ODCM Part II, step 3.3.2, include basis for only using inhalation pathway for instantaneous Iodine, Particulate, and H-3 dose rate measurements at the site boundary, rather than also including the ground plane and milk pathways mentioned in NUREG 0133.

DESCRIPTION OF CHANGES:

Added a sentence identifying the equation's use of only the inhalation pathway, as the other two pathways are insignificant or non-existent.

IMPACT:

None JUSTIFICATION:

The original Tech Specs and ODCM were drafted by the Franklin Institute in 1983-1984. Studies performed at that time demonstrated dose rates calculated from the ground plane pathway at the site boundary were 3 to 4 orders of magnitude lower than those of the inhalation pathway. The ground plane pathway was therefore eliminated in this equation at that time (ODCM Rev 0) for simplification, per the recommendation of the Franklin Institute. Additionally, since there is no milk pathway at IPEC, this pathway was similarly excluded form the 10CFR20 calculation at the site boundary.

There had not been an explanation readily available as to this deviation from NUREG 0133, and it was discovered by an in-house QA inspector in 2003. Adding this sentence to the ODCM will provide an explanation for the deviation from NUREG 0133 and serve as a reminder to others, should the significance or pathways change in the future. The reference back to the specific section of the NUREG is included.

Docket No. 50-3, 50-247, &50-286 Page 75 of 76 Item 10 OBJECTIVE:

Update Appendix 3-A, Page 1, to match the Indian Point 2 ODCM and better explain the meteorological terms.

DESCRIPTION OF CHANGES:

Slightly modified the distances in the unit 2 column to match the unit 2 ODCM.

Added extra explanation of each meteorological term.

IMPACT:

None JUSTIFICATION:

This update better explains the use of each term for both units, and ensures correct references to specific locations where the calculational models identify the ODCM calculations to be performed.

Docket No. 50-3, 50-247, & 50-286 Page 76 of 76 Item 11 OBJECTIVE:

Update ODCM Part II, Section 4.0 (sample locations for the REMP), to identify new figures and information on the pages following. Update Figures 4-1, 4-2, and add Figure 4-3. Update Table 4-1 with minor corrections enhancing consistency in location descriptions and to eliminate confusion with regard to specific fish species.

DESCRIPTION OF CHANGES:

The opening two paragraphs under section 4.0 were modified to identify the updated maps and wording in the table. Maps are larger, more clear, and include county markings. An additional map, 4-3, was added to show non-RECS locations. Some specific examples of acceptable fish were added to the listing, as well as a caveat to include similar species if needed. Resolved confusion with points DR28 and DR31.

IMPACT:

None JUSTIFICATION:

Unit 2 ODCM had listed RECS and non-RECS sample points, where unit 3's ODCM only listed those required by the old Tech Specs, subsequently identified as RECS-required locations. To be complete and assist in the move toward integration, all locations were added to the unit 3 ODCM, and an extra figure was added to show the non-RECS locations. Additionally, some fine adjustments were made to the exact name and location of each point to precisely match in both ODCMs and in lower tier procedures. These changes are compliant with guidance from NUREG 1301 and other bases documents describing the REMP.

This update also clarifies sampling issues with fish and some confusion with description and location identifiers for similar sampling locations. It also ensures each unit's ODCM lists precisely the same data, location, and guidance with regard to sampling biota. These changes do not constitute a change to the REMP, but are for clarity and consistency in each unit's ODCM.