Text

NUREG-1302

Offsite Dose Calculation

Manual Guidance: Standard

Radiological Effluent Controls

for Boiling Water Reactors

Generic Letter 89-01, Supplement No. 1

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

W. W. Meinke, T. H. Essig

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Offsite Dose Calculation

Manual Guidance: Standard

Radiological Effluent Controls

for Boiling Water Reactors

Generic Letter 89-01, Supplement No. 1

Date Published: April 1991

W.W. Meinke, T. H. Essig

Division of Radiation Protection and Emergency Preparedness

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555

NUREG-1302

ABSTRACT

This report contains guidance which may be voluntarily used by licensees who

choose to implement the provision of Generic Letter 89-01, which allows Radiological

Effluent Technical Specif 1cations (RETS) to be removed from the main

body of the Technical Specifications and placed in the Offsite Dose Calculation

Manual (ODCM). Guidance is provided for Standard Effluent Controls definitions,

Controls for effluent monitoring instrumentation, Controls for effluent releases,

Controls for radiological environmental monitoring, and th~ basis for Controls.

Guidance on the formulation of RETS has been available in draft form (NUREG-0472

and -0473) for a number of years; the current effort simply recasts those RETS

into Standard Rad1ological Effluent Controls for application to the ODCM. Also

included for completeness are: (1) radiological environmental monitoring program

9uidance previously which had been available as a Branch Technical Position

(Rev. 1, November 1979); (2) existing ODCM guidance; and (3) a reproduction of

Generic Letter 89-01.

ii i

PREFACE

This compilation of Standard Radiological Effluent Controls (SREC) contains all

of the controls addressed in Generic Letter 89-01, to be incorporated into a

licensee's Offsite Dose Calculation Manual (ODCM) at the time the procedural

details of the current Radiological Effluent Technical Specifications (RETS)

are transferred out of the licensee's Technical Specifications (TS). It has

been developed by recasting the RETS of the most current Standard Technical

Specifications from the "LCO" format into the "Controls" format of an ODCM

entry. Note that these GE-SREC have been patterned after the ~-SREC. The

following text guidance incorporates the wording of the most recent SREC,

however, no attempt has been made to translate REC numbering of the W-SREC

into that of the BWR numbering system. -

The following GE-SREC provide the latest version of staff guidance, and document

current practice in the operating procedures required by 10 CFR 20.106,

40 CFR Part 190, 10 CFR 50.36(a), and Appendix I to 10 CFR Part 50. This

document contains no new requirements and its use is completely voluntary.

v

1

3/4

3/4.0

3/4.3

3/4.11

3/4.12

3/4

GE-SREC

TABLE OF CONTENTS

ABSTRACT. • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • iii

PREFACE.. . . • • • • • • • • • • • • • • • • • • . • • • • • • • • • • . • • • • • • • • • . • • • • v

FOREWORD............................................... [l]

DEFINITIONS •••..••••••••••••••••.••••••••••••••••••••••

CONTROLS AND SURVEILLANCE REQUIREMENTS ••••.••••••••••••

App l i cab i 1 i ty ......................................... .

Instrumentation . ...................................... .

Radioactive Effluents •.•.•.••.•••...•••..••.•.••••..•..

Radiological Environmental Monitoring •••••••.••••••.•••

BASES • •••••••••••••••••••••••••••••••••••••••••••••••••

[5]

[15]

[16]

[18]

[39]

[59]

[74]-

APPENDIX A: Radiological Assessment Branch Technical [85]

Position, Revision 1, November 1979

APPENDIX B: General Contents of the Offsite Dose

Calculation Manual

APPENDIX C: Generic Letter 89-01

vii

[94]

[98]

FOREWORD

RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS

Licensee Technical Specification (TS) amendment requests for incorporation of

Radiological Effluent Technical Specifications (RETS) pursuant to 10 CFR 50.36a

and Appendix I to 10 CFR Part 50 were approved in the mid-1980s for most

operating reactors licensed before 1979 (ORs). Plants licensed after 1979

(NTOLs), included the RETS as part of their initial Technical Specifications.

By November 1987, the RETS were implemented by all licensees of operating power

reactors. Detailed Safety Evaluation Reports (SERs) documented the acceptability

of the plant-specific RETS of the ORs, while the acceptance of the RETS

for the NTOLs followed the regular pattern of the Standard Technical Specifications

(STS). Thus, for all operating plants, the compliance of the licensee

with 10 CFR 50.36a and Appendix I to 10 CFR Part 50 is a matter of record.

Early draft revisions of model RETS, distributed to licensees in mid-1978,

·contained equations for dose calculations, setpoint determinations and meteorological

dispersion factors, as well as the procedural details for complying

with Appendix I to 10 CFR Part 50. In later revisions, including Revision 2

used as the bench mark for the NRC staff's acceptance of OR RETS, the equations

were removed and incorporated into an Offsite Dose Calculation Manual (ODCM)

prepared by the licensee and provided to NRC for review along with the proposed

RETS.

Early guidance for preparation of the Radiological Effluent Technical Specifications

(RETS) and Offsite Dose Calculation Manual (ODCM) was published in

NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for

Nuclear Power Plants," October 1978. Copies of model RETS, however, have been

available only in draft form as NUREG-0472, Revision 2, "Radiological Effluent

Technical Specifications for PWRs," February 1, 1980; NUREG-0473, Revision 2,

"Radiological Effluent Technical Specifications for BWRs," February 1, 1980;

and succeeding draft revisions. Staff guidance for the Radiological

Environmental Monitoring Program is contained in the Radiologica1 Assessment

Branch Technical Position (RAB-BTP), originally issued in March 1978 and

upgraded by Revision 1 in November 1979 as a result of the accident at Three

Mile Island. This Revision 1 to the RAB-BTP was forwarded to all operating

reactor licensees in November 1979 and remains in effect at the present time.

Since this BTP was never incorporated into the Regulatory Guide System, a copy

is reproduced in this document as Appendix A. Even though it has been used

extensively in reviewing ODCMs, guidance for the contents of the ODCM is found

only in an appendix to a paper presented at an Atomic Industrial Forum conference

in 1981, and has had only informal distribution since that time.

OFFSITE DOSE CALCULATION MANUAL

The potential for augmentation of a licensee's ODCM through transfer of the

procedural details of the RETS following the guidance of Generic Letter 89-01,

provides an opportunity to assemble in one set of documents the staff guidance

for the ODCM.

GE-SREC [1]

The current overview guidance for development of the ODCM was prepared origina

1 ly in July 1978 and revised in February 1979 after discussions with committees

of the Atomic Industrial Forum. This guidance was made generally

available as "Appendix B - General Contents of the Offsite Dose Calculation

Manual (ODCM) (Revision 1, February 1979)" to the paper authored by . ·

c. A. Willis and F. J. Congel, "Status of NRC Radiological Effluent Technical

Specification Activities" presented at the Atomic Industrial Forum Conference

on NEPA and Nuclear Regulation, October 4-7, 1981, Washington, D.C. -A copy of

this guidance that continues in effect to date, is reproduced in this document

as Appendix B.

During the discussions leading up to the implementation of the RETS by the ORs,

it became important to record in a "living" document certain interpretations

and understandings reached in these discussions. The ODCM thus became a

repository for such interpretations, as well as for other information requested

by the staff in connection with its evaluation of licensee's commitments and

performance under 10 CFR 50.36a and Appendix I to 10 CFR Part 50.

TECHNICAL SPECIFICATION IMPROVEMENT PROGRAM

Recently, the NRC staff has examined the contents of the RETS in relation to

the Commission's Interim Policy Statement on Technical Specification Improvements.

The staff has determined that progranrnatic controls can be implemented

in the Administrative Controls section of the Technical Specifications {TS) to

satisfy existing regulatory requirements for RETS. At the same time, the

procedural details of the current TS on radioactive effluents and radiological

environmental monitoring can be relocated to the Offsite Dose Calculation

Ma nu a 1 ( ODCM).

To initiate the change, new programmatic controls for radioactive effluents and

radiological environmental monitoring are incorporated in the TS to conform to

the regulatory requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a,

and Appendix I to 10 CFR Part 50. The procedural details included in

licensees' present TS on radioactive effluents, environmental monitoring, and

associated reporting requirements will be relocated to the ODCM •. Licensees

will handle future changes to these procedural details in the ODCM ~nder the

administrative controls for changes to the ODCM. Detailed guidance to effect

the transfer of the RETS to the ODCM is given in Generic Letter 89-01, reproduced

in its entirety as Appendix C.

GUIDANCE FOR THE TRANSFER OF RETS TO ODCM

Enclosure 1 of Generic Letter (GL) 89-01 of Appendix B provides detailed

guidance for the preparation of a license amendment request to implement the

transfer of RETS to ODCM. Page 1 of the enclosure states:

"The NRC staff's intent in reco11111ending --- the relocation of procedural

details of the current RETS to the ODCM is to fulfill the goal of the

Commission Policy Statement for Technical Specification Improvements. It

is not the staff's intent to reduce the level of radiological effluent

control. Rather, this amendment will provide programmatic controls for

RETS consistent with regulatory requirements and allow relocation of the

procedura 1 deta i1 s of current RETS to the ODCM."

GE-SREC [2]

Page 2 of Enclosure 1 states:

11 ••• the procedural details covered in the licensee's current RETS,

consisting of the limiting conditions for operation, their applicability,

remedial actions, surveillance requirements, and the Bases

section of the TS for these requirements, are to be relocated to the

ODCM --- in a manner that ensures that these details are incorporated

in plant operating procedures. The NRC staff does not intend to repeat

technical reviews of the relocated procedural details because their

consistency with the applicable regulatory requirements is a matter

of record from past NRC reviews of RETS. 11

DISCUSSION

For the purpose of the transfer described in GL 89-01 of Appendix B, the RETS

will consist of the specifications from the STS listed in Enclosure 2 of Appendix

B of GL 89-01. Licensees with nonstandard TS should consider the analogous

TS in their format.

It is suggested that the most straightforward method of transferring a licensee's

commitments in the RETS to the ODCM in accordance with GL 98-01 is to recast

the RETS in the licensee's present TS from the "Limiting Condition for Operation

(LCO)" format of the TS into the "Controls0 format of the ODCM entry. The

accompanying package provides an example of this recasting into Standard Radiological

Effluent Controls (SREC) from the model RETS for Boiling Water Reactors

(BWRs). This recasting is in format only. The TS pages have been transferred

to the ODCM without change except for the substitution of °Controls0 for "LC0. 11

Plants that have RETS that closely follow the STS format will be able to use

the accompanying examples directly as guidance. For plants with nonstandard

RETS, the transfer of TS commitments to the ODCM should be made similarly page

by page, again with the substitution of °Controls" for 11 LC0. 11

This NUREG report contains no new requirements; licensee implementation of this

guidance is completely voluntary.

SUMMARY

As part of the license amendment request for TS improvement relative to the

RETS, a licensee confirms that the guidance of Generic Letter 89-01 has been

followed. This guidance includes the following:

"The procedural details covered in the licensee's current RETS, consisting

of the limiting conditions for operation, their applicability,

remedial actions, surveillance requirements, and the Bases section of

the TS for these requirements, are to be relocated to the ODCM --- in

a manner that ensures that these details are incorporated in plant

operating procedures."

The Standard Radiological Effluent Controls {SREC) compiled in this report

document current staff practice in the operating procedures required by

10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36(a), and Appendix I to 10 CFR Part 50. Thus they contain all of the controls required by Generic Letter 89-01, to be incorporated into a licensee's ODCM at the time the procedural

details of the current RETS are transferred out of the licensee's TS.

GE-SREC [3]

GE-SREC

NOTE

These GE-SREC have been

patterned after the ~-SREC.

The following text guidance incorporates the

wording of the most recent SREC; however,

no attempt has been made to translate the

REC numbering of the ~-SREC into that

of the BWR numbering system

[4]

GE-SREC

SECTION 1. 0

DEFINITIONS

[5]

1. 0 DEFINITIONS

The defined terms of this section appear in capitalized type and are applicable

throughout these Controls.

ACTION

1.1 ACTION shall be that part of a Control that prescribes remedial measures

required under designated conditions.

CHANNEL CALIBRATION

1.4 An CHANNEL CALIBRATION shall be the adjustment, as necessary, of the

channel such that it responds within the required range and accuracy to known

values of input. The CHANNEL CALIBRATION shall encompass the entire channel

including the sensors and alarm, interlock and/or trip functions and shall

include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed

by any series of sequential, overlapping, or total channel steps such that the

entire channel is calibrated.

CHANNEL CHECK

1.5 A CHANNEL CHECK shall be the qualitative assessment of channel behavior

during operation by observation. This determination shall include, where

possible, comparison of the channel indication and/or status with other

indications and/or status derived from independent instrument channels

measuring the same parameter.

CHANNEL FUNCTIONAL TEST

1.6 A CHANNEL FUNCTIONAL TEST shall be:

a. Analog channels - the injection of a simulated signal into the

channel as close to the sensor as practicable to verify OPERABILITY

including alarm and/or trip functions and channel failure trips.

b. Bistable channels - the injection of a simulated signal into the

sensor to verify OPERABILITY including alarm and/or trip functions.

The CHANNEL FUNCTIONAL TEST may be performed by any series of sequential,

overlapping or total channel steps such that the entire channel is tested.

GE-SREC [6]

DEFINITIONS

DOSE EQUIVALENT I-131

1.10 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microCurie/gram)

which alone would produce the same thyroid dose as the quantity and isotopic

mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid

dose conversion factors used for this calculation shall be those listed in

[Table III of TID-14844, "Calculation of Distance Factors for Power and Test

Reactor Sites" or Table E-7 of NRC Regulatory Guide 1.109, Revision 1,

October 1977].

GE-SREC [7]

DEFINITIONS

FREQUENCY NOTATION

1.13 The FREQUENCY NOTATION specified for the performance of Surveillance

Requirements shall correspond to the intervals defined in Table 1.1.

GASEOUS RADWASTE TREATMENT SYSTEM

1.14 A GASEOUS RADWASTE TREATMENT SYSTEM (e.g., the "augmented offgas

system") is any system designed and installed to reduce radioactive gaseous

effluents by collecting primary coolant system offgases from the main

condenser evacuation system and providing for delay or holdup for the purpose

of reducing the total radioactivity prior to release to the environment.

MEMBER(S) OF THE PUBLIC

1.16 MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally

associated with the plant. This category does not include employees

of the licensee, its contractors, or vendors. Also excluded from this category

are persons who enter the site to service equipment or to make deliveries.

This category does include persons who use portions of the site for recreational,

occupational, or other purposes not associated with the plant.

OFFSITE DOSE CALCULATION MANUAL

1.17 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology

and parameters used in the calculation of offsite doses resulting from

radioactive gaseous and liquid effluents, in the.calculation of gaseous and

liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the

Environmental Radiological Monitoring Program. The ODCM shall also contain

(1) the Radioactive Effluent Controls and Radiological Environmental Monitoring

Programs required by Section 6.8.4 and (2) descriptions of the information that

should be included in the Annual Radiological Environmental Operating and

Semiannual Radioactive Effluent Release Reports required by TS 6.9.l.3 and

6.9.1.4.

GE-SREC [8]

DEFINITIONS

OPERABLE - OPERABILITY

1.18 A system, subsystem, train, component or device shall be OPERABLE or

have OPERABILITY when it is capable of performing its specified function(s),

and when all necessary attendant instrumentation, controls, electric61 power,

cooling or seal water, lubrication or other auxiliary equipment that are

required for the system, subsystem, train, component, or device to perform its

function(s) are also capable of performing their related support function(s).

OPERATIONAL CONDITION - CONDITION

1.19 An OPERATIONAL CONDITION, i.e., CONDITION, shall be any one inclusive

combination of mode switch position and average reactor coolant temperatures

as specified in Table 1.2.

PURGE - PURGING

1.23 PURGE or PURGING shall be any controlled process of discharging air or gas

from a confinement to maintain temperature, pressure, humidity, concentration

or other operating condition, in such a manner that replacement air or gas is

required to purify the confinement.

GE-SREC [9]

DEFINITIONS

RATED THERMAL POWER

1.25 RATED THERMAL POWER shall be a total reactor core heat transfer rate to

the reactor coolant of MWt.

REPORTABLE EVENT

1.27 A REPORTABLE EVENT shall be any of those conditions specified in

Section 50.73 of 10 CFR Part 50.

SITE BOUNDARY

1.30 The SITE BOUNDARY shall be that line beyond which the land is neither

owned, nor leased, nor otherwise controlled by the licensee.

GE-SREC [10]

DEFINITIONS

SOURCE CHECK

1.33 A SOURCE CHECK shall be the qualitative assessment of channel response

when the channel sensor is exposed to a source of increased radioactivity.

THERMAL POWER

1.35 THERMAL POWER shall be the total reactor core heat transfer rate to the

reactor coolant.

GE-SREC [ 11 ]

DEFINITIONS

UNRESTRICTED AREA

1.38 An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY

access to which is not controlled by the licensee for purposes of pr~tection of

individuals from exposure to radiation and radioactive materials, or any area

within the SITE BOUNDARY used for residential quarters or for industrial,

commercial, institutional, and/or recreational purposes.

VENTILATION EXHAUST TREATMENT SYSTEM

1.39 A VENTILATION EXHAUST TREATMENT SYSTEM shall be any system designed and

installed to reduce gaseous radioiodine or radioactive material in particulate

form in effluents by passing ventilation or vent exhaust gases through charcoal

adsorbers and/or HEPA filters for the purpose of removing iodines or particu-

-lates from the gaseous exhaust stream prior to the release to the environment.

Such a system is not considered to have any effect on noble gas effluents.

Engineered Safety Features Atmospheric Cleanup Systems are not considered

to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING

1.40 VENTING shall be the controlled process of discharging air or gas from a

confinement to maintain temperature, pressure, humidity, concentration, or other

operating condition, in such a manner that replacement air or gas is not provided

or required during VENTING. Vent, used in system names, does not imply

a VENTING process.

GE-SREC [12]

NOTATION

s

GE-SREC

D

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SA

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S/U

N.A.

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TABLE 1.1

FREQUENCY NOTATION

FREQUENCY

At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

At least once per 7 days.

At least once per 31 days.

At least once per 92 days.

At least once per 184 days.

At least once per 18 months.

Prior to each reactor startup.

Not applicable.

Completed prior to each release.

[13]

TABLE 1. 2

OPERATIONAL CONDITIONS

MODE SWITCH AVERAGE REACTOR

CONDITION POSITION COOLANT TEMPE&ATURE

1.

2.

3.

4.

5.

POWER OPERATION Run Any temperature

STARTUP Startup/Hot Standby Any temperature

HOT SHUTDOWN Shutdown # ' *** > 200°F

COLD SHUTDOWN Shutdown#,##,*** <= 200°F

REFUELING* Shutdown or Refuel ** •# ~ 140°F

The reactor mode switch may be placed in the Run or Startup/Hot Standby

position to test the switch interlock functions provided that the control

rods are verified to remain fully inserted by a second licensed operator or

other technically qualified member of the unit technical staff.

1. The reactor mode switch may be placed in the Refuel position while a single

control rod drive is being removed from the reactor pressure vessel per

Specification 3.9.10.1.

Fuel in the reactor vessel with the vessel head closure bolts less than

fully tensioned or with the head removed.

- See Special Tests Exceptions 3.10.1 and 3.10.3.

- - The reactor mode switch may be placed in the Refuel position while a single

control rod is being recoupled provided that the one-rod-out interlock is

OPERABLE.

GE-SREC [14]

GE-SREC

SECTIONS 3.0 AND 4.0

CONTROLS

AND

SURVEILLANCE REQUIREMENTS

[15]

3/4 CONTROLS AND SURVEILLANCE REQUIREMENTS

3/4.0 APPLICABILITY

CONTROLS

3.0.1 Compliance with the Controls contained in the succeeding controls is

required during the OPERATIONAL CONDITIONS or other conditions specified

therein; except that upon failure to meet the Control, the associated ACTION

requirements shall be met.

3.0.2 Noncompliance with a control shall exist when the requirements of the

Control and associated ACTION requirements are not met within the specified

time intervals. Jf the Control is restored prior to expiration of the

specified time intervals, completion of the ACTION requirements is not

required.

3.0.3 When a Control is not met, except as provided in the associated ACTION

requirements, within l hour action shall be initiated to place the unit in an

OPERATIONAL CONDITION in which the control does not apply by placing it, as

applicable, in:

1. At least STARTUP within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION

requirements, the action may be taken in accordance with the specified time

limits as measured from the time of failure to meet the Control. Exceptions

to these requirements are stated in the individual controls.

This control is not applicable in OPERATIONAL CONDITIONS 4 or 5.

3.0.4 Entry into an OPERATIONAL CONDITION or other specified condition shall

not be made unless the conditions for the Control are met without reliance on

provisions contained in the ACTION requirements. _This provision shall not

prevent passage through or to OPERATIONAL CONDITIONS as required to comply

with ACTION requirements. Exceptions to these requirements are stated in the

individual controls.

GE-SREC [16]

APPLICABILITY

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL.

CONDITIONS or other conditions specified for individual Controls unless

otherwise stated in an individual Surveillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified

time interval with:

a. A maximum allowable extension not to exceed 25% of the surveillance

interval, but

b. The combined time interval for any three consecutive surveillance

intervals shall not exceed 3.25 times the specified surveillance

interval.

4.0.3 Failure to perform a Surveillance Requirement within the specified

time interval shall constitute a failure to meet the OPERABILITY requirements

for a Control. Exceptions to these requirements are stated in the individual

controls. Surveillance Requirements do not have to be performed on inoperable

equipment.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified applicable

condition shall not be made unless the Surveillance Requirement(s) associated

with the Control has been performed within the applicable surveillance

interval or as otherwise specified.

GE-SREC [17]

INSTRUMENTATION

RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION

CONTROLS

3.3.3.10 In accordance with [plant name] TS 6.8.4.g.l), the radioactive liquid

effluent monitoring instrumentation channels shown in Table 3.3-12 shall be

OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of

Control 3.11.l.l are not exceeded. The Alarm/Trip Setpoints of these channels

shall be determined and adjusted in accordance with the methodology and

parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

APPLICABILITY: At all times.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel

Alarm/Trip Setpoint less conservative than required by the above

control, immediately suspend the release of radioactive liquid

effluents monitored by the affected channel, or declare the channel

inoperable, or change the setpoint so it is acceptably conservative.

b. With less than the minimum number of radioactive liquid effluent

monitoring instrumentation channels OPERABLE, take the ACTION shown

in Table 3.3-12. Restore the inoperable instrumentation to OPERABLE

status within 30 days and, if unsuccessful, explain in the next

Semiannual Radioactive Effluent Release Report pursuant to Control

6.9.1.4 why this inoperability was not corrected in a timely manner.

c. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

Report all deviations in the Semiannual Radioactive Effluent Release

Report.

SURVEILLANCE REQUIREMENTS 4.3.3.10 Each radioactive liquid effluent monitoring instrumentation channel

shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE

CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST at the frequencies

shown in Table 4.3-8.

GE·SREC [18]

TABLE 3.3-12

,G,",t

' RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION ,"::,:u,'

n

MINIMUM

CHANNELS

INSTRUMENT OPERABLE ACTION

1. Radioactivity Monitors Providing Alarm and

Automatic Termination of Release

a. Liquid Radwaste Effluent Line 1 35

2. Radioactivity Monitors Providing Alarm But Not Providing

Automatic Termination of Release

a. Service Water System Effluent line 1 37

b. Component Cooling Water System Effluent line 1 37

,........, 3. (Not Used) ~ ......

4. Flow Rate Measurement Devices

a. liquid Radwaste Effluent line 1 38

b. Discharge Canal 1 38

5. Radioactivity Recorders*

a. liquid Radwaste Effluent line 1 39

Required only if Alarm/Trip Setpoint is based on recorder-controller.

GE-SREC

(NOT USED}

[20]

ACTION 35 -

ACTION 37 -

ACTION 38 -

ACTION 39 -

GE-SREC

TABLE 3.3-12 (Continued)

ACTION STATEMENTS

With the number of channels OPERABLE less than requir!d by the

Minimum Channels OPERABLE requirement, effluent releases via

this pathway may continue provided that prior to initiating a

release:

a. At least two independent samples are analyzed in accordance

with Control 4.11.1.1.1, and

b. At least two technically qualified members of the facility

staff independently verify the release rate calculations

and discharge line valving.

Otherwise, suspend release of radioactive effluents via this

pathway.

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, effluent releases via

this pathway may continue provided that, at least once per

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , grab samples are collected and analyzed for radioactivity

at a lower limit of detection of no more than

10-7 microCurie/ml.

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, effluent releases via

this pathway may continue provided the flow rate is estimated

at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases. Pump performance

curves generated in place may be used to estimate flow.

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, effluent releases via

this pathway may continue provided the radioactivity level is

determined at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases.

[ 21]

TABLE 4.3-8

C')

m

"~ ~ADI_OACTI_VE_LJJlUID EFFLUENT MONITORING INSTRUMENTATIOt!__~U~Y_EILLANCE REQUIREMENTS m

n

CHANNEL

CHANNEL SOURCE CHANNEL FUNCTIONAL

INSTRUMENT CHECK CHECK CALIBRATION TEST

1. Radioactivity Monitors Providing

Alarm and Automatic Termination

of Release

a. liquid Radwaste Effluent Line 0 p R(l) Q(l)

2. Radioactivity Monitors Providing Alarm But

Not Providing Automatic Termination

of Release

a. Service Water System Effluent line 0 M R(l) Q(2)

,...., b. Component Cooling Water System Effluent N

.N.... ... Line 0 M R(3) Q(2)

3. (Not Used)

4. Flow Rate Measurement Devices

a. liquid Radwaste Effluent Line 0(4) N.A. R Q

b. Discharge Cana 1 0(4) N.A. R Q

5. Radf oactf vf ty Recorders*

a. liquid Radwaste Effluent line 0 N.A. R •Q

Required only if Alarm/Trip Setpoint in based on recorder-controller.

GE·SREC

(NOT USED)

[23]

TABLE 4.3-8 (Continued)

TABLE NOTATIONS

(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation

of this pathway and control room alarm annunciation occur tf any

of the following conditions exists:

a. Instrument indicates measured levels above the Alarm/Trip Setpoint, or

b. Circuit failure, or

c. Instrument indicates a downscale failure, or

d. Instrument controls not set in operate mode.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm

annunciation occurs if any of the following conditions exists:

a. Instrument indicates measured levels above the Alarm Setpoint, or

b. Circuit failure, or

c. Instrument indicates a downscale failure, or

d. Instrument controls not set in operate mode.

(3) The initial CHANNEL CALIBRATION shall be performed using one or more of

the reference standards certified by the National Bureau of Standards (NBS)

or using standards that have been obtained from suppliers that participate

in measurement assurance activities with NBS. These standards shall permit

calibrating the system over its intended range of energy and measurement

range. For subsequent CHANNEL CALIBRATION, sources that have been related

to the initial calibration shall be used.

(4) CHANNEL CHECK shall consist of verifying indication of flow during periods

of release. CHANNEL CHECK shall be made at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months on

days on which continuous, periodic, or batch releases are made.

GE·SREC

[24]

INSTRUMENTATION

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION

CONTROLS

3.3.3.11 In accordance with [plant name] TS 6.8.4.g.1), the radioactive gaseous

effluent monitoring instrumentation channels shown in Table 3.3-13 shall be

OPERABLE with their Alarm/Trip Setpoints set to ensure that the limits of

Control 3.11.2.1 are not exceeded. The Alarm/Trip Setpoints of these channels

shall be determined and adjusted in accordance with the methodology and

parameters in the ODCM.

APPLICABILITY: As shown in Table 3.3-13

ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation

channel Alarm/Trip Setpoint less conservative than required by the

above control, immediately suspend the release of radioactive

gaseous effluents monitored by the affected channel, or declare the

channel inoperable, or change the setpoint so it is acceptably

conservative.

b. With less than the minimum number of radioactive gaseous effluent

monitoring instrumentation channels OPERABLE, take the ACTION shown

in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE

status within 30 days and, if unsuccessful, explain in the next Semiannual

Radioactive Effluent Release Report pursuant to Control

6.9.1.4 why this inoperability was not corrected in a timely

manner.

c. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

Report all deviations in the Semiannual Radioactive Effluent Release

Report.

SURVEILLANCE REQUIREMENTS 4.3.3.11 Each radioactive gaseous effluent monitoring instrumentation channel

shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE

CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST at the frequencies shown

in Table 4.3-9.

GE-SREC (25]

a TABLE 3.3-13

e"'n' RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION ::a

"n '

MINIMUM CHANNELS

INSTRUMENT OPERABLE APPLICABILITY ACTION

1. Main Condenser Offgas Treatment System

Effluent Monitoring System

a. Noble Gas Activity Monitor -

Providing Alarm and Automatic

Termination of Release 1 fr 47

b. Iodine Sampler 1 fr 51

c. Particulate Sampler 1 fr 51

d. Effluent System Flow Rate

,...., Measuring Device 1 fr 46

N

.°...'.. e • Sa1111>ler Flow Rate Measuring Device 1 fr 46

2A. NOT USED

28. NOT USED

a

IABLE_3.3-13 (Continued)

ITI

.,I , RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION

ID

ITI n

MINIMUM CHANNELS

INSTRUMENT OPERABLE APPLICABILITY ACTION

3. Reactor Building Ventilation/Purge System

a. Noble Gas Activity Monitor 1 * 48

b. Iodine Sampler 1 * 51

c. Particulate Sampler 1 * 51

d. Flow Rate Monitor 1 * 46

e. Sampler Flow Rate Monitor 1 * 46

~

N

4. Main Stack System

'"-" a. Noble Gas Activity Monitor 1 * 47

b. Iodine Sampler 1 * 51

c. Particulate Sampler 1 * 51

d. Flow Rate Monitor 1 * 46

e. Sampler Flow Rate Monitor 1 * 46

5. Turbfne Building Ventilation System

•• Noble Gas activity Monitor 1 * 47

b. Iodine Sampler 1 * 51

c • Particulate Sampler 1 * 51

..

TABLE 3.3~13 (Continued)

G')

'"' RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION :"0' n'"

MINIMUM CHANNELS

INSTRUMENT OPERABLE APPLICABILITY ACTION

5. Turbine Building Ventilation

System (Continued)

d. Flow Rate Monitor 1 * 46

e. Sampler Flow Rate Monitor 1 * 46

6. Auxiliary Building Ventilation System

a. Noble Gas Activity Monitor 1 * 47

,....., b. Iodine Sampler 1 * 51

N

00 c. Particulate Sampler 1 * 51 L-1

d. Flow Rate Monitor 1 * 46

e. Sampler Flow Rate Monitor 1 * 46

7. Fuel Storage Area Ventilation System

a. Noble Gas Activity Monitor 1 * 47

b. Iodfne Sampler 1 * 51

c. Particulate Sampler 1 * 51

'

d. Flow Rate Monitor 1 * 46

e. Sampler Flow Rate Monitor 1 * 46

JABLE 3.3-13 (Continued)

~ "e'n' RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION

.0 "n '

MINIMUM CHANNELS

INSTRUMENT ·OPERABLE APPLICABILITY ACTION

8. Radwaste Area Ventilation System

a. Noble Gas Activity Monitor 1 llll 47

b. Iodine Sampler 1 llll 51

c. Particulate Sampler 1 llll 51

d. Flow Rate Monitor 1 llll 46

e. Sampler Flow Rate Monitor 1 llll 46

,_.,

I\) 9. Turbine Gland Seal Condenser Vent and '-0 L...I Mechanical Vacuum Pump Exhaust System

a. Noble Gas Activity Monitor 1 llll 47

b. Iodine Sampler 1 llll 51

c. Particulate Sampler 1 llll 51

d. Flow Rate Monitor 1 llll 46

e. Sampler Flow Rate Monitor 1 llll 46

10. Condenser Air Ejector Radioactivity

Monitor (Prior to Input to Holdup

System)

a. Noble Gas Activity Monitor 1 llllllllllll 45

GE-SREC

CNOT USED)

[30]

TABLE 3.3-13 (Continued)

TABLE NOTATIONS

At all times.

- During main condenser offgas treatment system operation.

- - During operation of the main condenser air ejector.

ACTION 45 -

ACTION 46 -

ACTION 47 -

ACTION 48 -

ACTION 49 -

ACTION 50 -

ACTION 51 -

GE-SREC

ACTION STATEMENTS

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, releases to the

environment may continue for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided:

a. The offgas system is not bypassed, and

b. The offgas delay system noble gas activity effluent

(downstream) monitor is OPERABLE;

Otherwise, be in at least HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, effluent releases via

this pathway may continue provided the flow rate is estimated at

least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, effluent releases via

this pathway may continue provided grab samples are taken at

least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and these samples are analyzed for

radioactivity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, innediately suspend

release of radioactive effluents via this pathway.

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, operation of the main

condenser offgas treatment system may continue provided grab

samples are collected at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and analyzed

within the following 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

With the number of channels OPERABLE one less than required by

the Minimum Channels OPERABLE requirement, operation of this

system may continue for up to 14 days.

With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, effluent releases via

the affected pathway may continue provided samples are continuously

collected with auxiliary sampling equipment as required

in Table 4.11-2.

[31]

GE-SREC

(NOT USED)

(32]

TABLE 4.3-9

~ .'",•, RADIOACTIVE GASEOUS EFFLUENT_MONJ"TORING_ INSTRUMENTATION _SURVEILLANCE REQUIREMENTS

ID "n '

CHANNEL MODES FOR WHICH

CHANNEL SOURCE CHANNEL FUNCTIONAL SURVEILLANCE

INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

1. Main Condenser Offgas Treatment

System Effluent Monitoring System

a. Noble Gas Activity Monitor -

Providing Alarm and Automatic

Termination of Release D D R(3) Q(l) lit

b. Iodine Sampler w N.A. N.A. N.A. lit

c. Particulate Sampler w N.A. N.A. N.A. lit

d. Effluent System Flow Rate D N.A. R Q· 1t

,......, Measuring Devke w

w

'--' e. Sampler Flow Rate Monitor D N. A. R Q 1t

2A. NOT USED

28. NOT USED

~-- -------

TABLE 4.3-9 (Continued)

C')

rT'I I RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION _SURVEILLANCE REQUIREMENTS

";;o'

rT'I n

CHANNEL MODES FOR WHICH

CHANNEL SOURCE CHANNEL FUNCTIONAL SURVEILLANCE

INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED - - --- ----- ------ -

3. Reactor Building Ventilation/Purge

System

a. Noble Gas Activity Monitor 0 M R(3) Q(l) *

b. Iodine Sampler w N.A. N.A. N.A. *

c. Particulate Sampler w N.A. N.A. N.A. *

d. Flow Rate Monitor 0 N.A. R Q *

,......,

w e. Sampler Flow Rate Monitor 0 N.A. R Q * +::>

'-'

4. Main Stack System

a. Noble Gas Activity Monitor 0 M R(3) Q(2) *

b. Iodine Sampler w N.A. N.A. N.A. *

c. Particulate Sampler w N.A. N.A. N.A. *

d. Flow Rate Monitor 0 N.A. R Q *

e. Sampler Flow Rate Monitor 0 N.A. R Q lit

C')

TABLE 4.3-9 {Continued)

"I" "::u' RADIOACTIVE GASEOUS EFFLUENTMONITORING INSTRUMENTATJON_~URVEltLANCEREQUIREMENTS

n""

CHANNEL MODES FOR WHICH

CHANNEL SOURCE CHANNEL FUNCTIONAL SURVEILLANCE

INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

5. Turbine Building Ventilation

System

a. Noble Gas Activity Monitor D M R{3) Q(2) *

b. Iodine Sampler w N.A. N.A. N.A. *

c. Particulate Sampler w N.A. N.A. N.A. *

d. Flow Rate Monitor D N.A. R Q *

,....., e. Sampler Flow Rate Monitor D N.A. R Q * w

<J1

L-1 6. Auxiliary Building Ventilation

System

a. Noble Gas Activity Monitor D M R(3) Q(2) *

b. Iodine Sampler w N.A. N.A. N.A. *

c. Particulate Sampler w N. A. N.A. N.A. *

d. Flow Rate Monitor D N.A. R Q *

e. Sa111Pler Flow Rate Monitor D N.A. R Q *

TABLE 4. 3-_9 (Continued)

C) m

' RADIOACT_l'{_E _ G~~IQUS EFFLUENT MONITORING INSTRUMENTATION SU~VEIJ_L~NCE REQUIREMENTS ;"a' m

n

CHANNEL MODES FOR WHICH

CHANNEL SOURCE CHANNEL FUNCTIONAL SURVEILLANCE

INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

7. Fuel Storage Area Ventilation

System

a. Noble Gas Activity Monitor D M R(3) Q(2) Jilt

b. Iodine Sampler w N. A. N.A. N.A. Jilt

c. Particulate Sampler w N.A. N.A. N.A. Jilt

d. Flow Rate Monitor D N.A. R Q Jilt

,......,

w e. Sampler Flow Rate Monitor D N.A. R Q Jilt

L°-1'

8. Radwaste Area Ventilation System

a. Noble Gas Activity Monitor D M R(J) Q(2) Jilt

b. Iodine Sampler w N.A. N.A. N.A. Jilt

c. Particulate Sampler w N.A. N.A. N.A. Jilt

d. Flow Rate Monitor D N.A. R Q Jilt

e. Sampler Flow Rate Monitor D N.A. R Q lit

G')

JABJ.E_4~3-_~ __ (Continued)

"I ' "' RAOl_OAC'f_l_VE_GASEOUS_~f'FLUENT MONITORING INSTRUMENTJ\IJON_SURVEILLANCE REQUIREMENTS :ID "n '

CHANNEL MODES FOR WHICH

CHANNEL SOURCE CHANNEL FUNCTIONAL SURVEILLANCE

INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

9. Turbine Gland Seal Condenser Vent

and Mechanical Vacuum Pump

Exhaust System

a. Noble Gas Activity Monitor D M R(3) Q(2) *

b. Iodine Sampler w N.A. N.A. N.A. *

c. Particulate Sampler w N.A. N. A. N.A. *

,...., d. Flow Rate Monitor 0 N.A. R Q *

w

...... e. Sampler Flow Rate Monitor D N.A. R Q * ~

10. Condenser Air Ejector Radioactivity

Monitor (Prior to Input to Holdup

System)

a. Noble Gas Activity Monitor D M R(3) Q(2) ***

At all times.

TABLE 4.3-9 (Continued)

TABLE NOTATIONS

- During main condenser offgas treatment system operation.

- - During operation of the main condenser air ejector.

(1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic

isolation of this pathway and control room alarm annunciation occurs if

any of the following conditions exists:

a. Instrument indicates measured levels above the Alarm/Trip Setpoint, or

b. Circuit failure, or

c. Instrument indicates a downscale failure, or

d. Instrument controls not set in operate mode.

(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room

alarm annunciation occurs if any of the following conditions exists:

a. Instrument indicates measured levels above the Alarm Setpoint, or

b. Circuit failure, or

c. Instrument indicates a downscale failure, or

d. Instrument controls not set in operate mode.

(3) The initial CHANNEL CALIBRATION shall be performed using one or more of

the reference standards certified by the National Bureau of Standards (NBS)

or using standards that have been obtained from suppliers that participate

in measurement assurance activities with NBS. These standards shall permit

calibrating the system over its intended range of energy and measurement

range. For subsequent CHANNEL CALIBRATION, sources that have been related

to the initial calibration shall be used.

(4) The CHANNEL CALIBRATION shall include the use of standard gas samples

containing a nominal:

a. One volume percent hydrogen, balance nitrogen, and

b. Four volume percent hydrogen, balance nitrogen.

(5} The CHANNEL CALIBRATION shall include the use of standard gas samples

containing a nominal:

a. One volume percent oxygen, balance nitrogen, and

b. Four volume percent oxygen, balance nitrogen.

GE-SREC [38]

3/4.11 RADIOACTIVE EFFLUENTS

3/4.11.1 LIQUID EFFLUENTS

CONCENTRATION

CONTROLS

3.11.1.1 In accordance with [plant name] TS 6.8.4.g.2) and 3), the concentration

of radioactive material released in liquid effluents to UNRESTRICTED AREAS

(see Figure 5.1-3) shall be limited to the concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2 for radionuclides other than dissolved

or entrained noble gases. For dissolved or entrained noble gases, the concentration

shall be limited to 2 x 10-4 microCurie/ml total activity.

APPLICABILITY: At all times.

ACTION:

a. With the concentration of radioactive material released in liquid

effluents to UNRESTRICTED AREAS exceeding the above limits,

immediately restore the concentration to within the above limits.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.1.l Radioactive liquid wastes shall be sampled and analyzed according

to the sampling and analysis program of Table 4.11-1.

4.11.1.1.2 The results of the radioactivity analyses shall be used in accordance

with the methodology and parameters in the ODCM to assure that the concentrations

at the point of release are maintained within the limits of Control 3.11.1.1.

GE-SREC [39]

TABLE 4.11-1

RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM

- LOWER LIMIT

MINIMUM OF DETECTION

LIQUID RELEASE SAMPLING ANALYSIS TYPE OF ACTIVITY (LLD)(l)

TYPE FREQUENCY FREQUENCY ANALYSIS (μCi/ml)

l. Batch Waste p p

Release Each Batch Each Batch Principal Gamma 5xl0- 7

Tanks(2) Emitters(3)

I-131 lxlO-ti

a.

p M Dissolved and lxl0-5

One Batch/M Entrained Gases

(Gamma Emitters)

b.

p M H-3 lxl0-5

Each Batch Composite<4>

Gross Alpha lxl0-7

c.

p Q Sr-89, Sr-90 5x10- 8

Each Batch Composite<4>

Fe-55 lxl0-6

2. Continuous w Principal Gamma 5x10- 7

Releases< 5> Continuous<6> Composite< 6> Emitters<3>

I-131 lxl0-6

a.

M M Dissolved and lxl0-5

Grab Sample Entrained Gases

(Gamma Emitters)

b.

Continuous<6>

M

Composite<6>

H-3 lxl0-5

Gross Alpha lxl0-7

c.

Continuous<6>

Q

Composite<6>

Sr-89, Sr-90 Sxl0-8

Fe-SS lxl0-6

GE-SREC [40]

TABLE NOTATIONS

(l)The LLD is defined, for purposes of these controls, as the smallest

concentration of radioactive material in a sample that will yield a net

count, above system background, that will be detected with 95% probability

with only 5% probability of falsely concluding that a blank bbservation

represents a "real" signal.

For a particular measurement system, which may include radiochemical

separation:

LLD = 07:54, 10 May 2016 (EDT)07:54, 10 May 2016 (EDT)Mark Hawes 07:54, 10 May 2016 (EDT)

E • V • 2.22 x 106 • Y· exp (-AAt)

Where:

LLD = the 11a priori" lower limit of detection (microCurie per unit

mass or volume),

sb = the standard deviation of the background counting rate or of

the counting rate of a blank sample as appropriate (counts per

minute),

E = the counting efficiency (counts per disintegration),

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

2.22 x 106 =the number of disintegrations per minute per microCurie,

Y = the fractional radiochemical yield, when applicable,

A= the radioactive decay constant for the particular radionuclide

(sec- 1), and ·

At = the elapsed time between the midpoint of sample collection and

the time of counting (sec).

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

It should be recognized that the LLD is defined as an ! priori (before

the fact) limit representing the capability of a measurement system and

not as an! posteriori (after the fact) limit for a particular measurement.

<2>A batch release is the discharge of liquid wastes of a discrete volume.

Prior to sampling for analyses, each batch shall be isolated, and then

thoroughly mixed by a method described in the ODCM to assure

representative sampling.

GE-SREC [41]

TABLE 4.11-1 (Continued)

TABLE NOTATIONS (Continued)

C3>The principal gamma emmiters for which the LLD control applies include

the following radionucli~es: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99,

Cs-134, Cs-137, and Ce-141. Ce-144 shall also be measured, but with an

LLD of S x 10-6 • This list does not mean that only these nuclides are to

be considered. Other gamma peaks that are identifiable, together with

those of the above nuclides, shall also be analyzed and reported in the

Semiannual Radioactive Effluent Release Report pursuant to Control 6.9.1.4

in the format outlined in Regulatory Guide 1.21, Appendix B, Revision 1,

June 1974.

<4>A composite sample is one in which the quantity of liquid sampled is

proportional to the quantity of liquid waste discharged and in which the

method of sampling employed results in a specimen that is representative

of the liquids released.

C5>A continuous release is the discharge of liquid wastes of a nondiscrete

volume, e.g., from a volume of a system that has an input flow during the

continuous release.

<6>To be representative of the quantities and concentrations of radioactive

materials in liquid effluents, samples shall be collected continuously in

proportion to the rate of flow of the effluent stream. Prior to analyses,

all samples taken for the composite shall be thoroughly mixed in order

for the composite sample to be representative of the effluent release.

GE-SREC

[42]

RADIOACTIVE EFFLUENTS

DOSE

CONTROLS

3.11.1.2 In accordance with [plant name] TS 6.8.4.g.4) and 6.8.4.9.5), the

dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials

in liquid effluents released, from each unit, to UNRESTRICTED AREAS (see

Figure 5.1-3) shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrems to

the whole body and to less th~n or equal to 5 mrems to any organ,

and

b. During any calendar year to less than or equal to 3 mrems to the

whole body and to less than or equal to 10 mrems to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials

in liquid effluents exceeding any of the above limits, prepare

and submit to the Commission within 30 days, pursuant to Control

6.9.2, a Special Report that identifies the cause(s) for exceeding

the limit(s) and defines the corrective actions that have been taken

to reduce the releases and the proposed corrective actions to be

taken to assure that subsequent releases will be in compliance with

the above limits. This Special Report shall also include: (1) the

results of radiological analyses of the drinking water source, and

(2) the radiological impact on finished drinking water supplies with

regard to the requirements of 40 CFR Part 141, Safe Drinking Water

Act.*

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.2 Cumulative dose contributions from liquid effluents for the current

calendar quarter and the current calendar year shall be determined in accordance

with the methodology and parameters in the ODCM at least once per 31 days.

aThe requirements of ACTION a.(l) and (2) are applicable only if drinking water

supply is taken from the receiving water body within 3 miles of the plant

discharge. In the case of river-sited plants this is 3 miles downstream only.

GE-SREC [43]

RADIOACTIVE EFFLUENTS

LIQUID RADWASTE TREATMENT SYSTEM

CONTROLS

3.11.1.3 In accordance with [plant name] TS 6.8.4.g.6), the Liquid Radwaste

Treatment System shall be OPERABLE and appropriate portions of the system shall

be used to reduce releases of radioactivity when the projected doses due to the

liquid effluent, frOll each unit, to UNRESTRICTED AREAS (see Figure S.1-3) would

exceed 0.06 mrem to the whole body or 0.2 mrem to any organ in a 31-day period.

APPLICABILITY: At all times.

ACTION:

a. With radioactive liquid waste being discharged without treatment and

in excess of the above limits and any portion of the Liquid Radwaste

Treatment System not in operation, prepare and submit to the Commission

within 30 days, pursuant to Control 6.9.2, a Special Report that

includes the following information:

1. Explanation of why liquid radwaste was being discharged without

treatment, identification of any inoperable equipment or

subsystems, and the reason for the inoperability,

2. Action(s) taken to restore the inoperable equipment to OPERABLE

status, and

3. Summary description of action(s) taken to prevent a recurrence.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.3.1 Doses due to liquid releases from each unit to UNRESTRICTED AREAS

shall be projected at least once per 31 days in accordance with the methodology

and parameters in the ODCM when Liquid Radwaste Treatment Systems are not being

fully utilized.

4.11.1.3.2 The installed Liquid Radwaste Treatment System shall be

considered OPERABLE by meeting Controls 3.11.1.1 and 3.11.1.2.

GE-SREC

[44]

RADIOACTIVE EFFLUENTS

3/4.11.1.4 (NOT USED)

GE-SREC [45]

RADIOACTIVE EFFLUENTS

3/4.11.2 GASEOUS EFFLUENTS

DOSE RATE

CONTROLS

3.11.2.1 In accordance with [plant name] TS 6.8.4.g.3) and 7), the dose rate

due to radioactive materials released in gaseous effluents from the site to

areas at and beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to

the following:

a. For noble gases: Less than or equal to 500 mrems/yr to the whole

body and less than or equal to 3000 mrems/yr to the skin, and

b. For Iodine-131, for Iodine-133, for tritium, and for all radionuclides

in particulate form with half-lives greater than 8 days:

Less than or equal to 1500 mrems/yr to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the dose rate(s) exceeding the above limits, immediately restore

the release rate to within the above limit(s).

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.1.l The dose rate due to noble gases in gaseous effluents shall be

determined to be within the above limits·in accordance with the methodology

and parameters in the ODCM.

4.11.2.1.2 The dose rate due to Iodine-131, Iodine-133, tritium, and all

radionuclides in particulate form with half-lives greater than 8 days in

gaseous effluents shall be determined to be within the above limits in

accordance with the methodology and parameters in the ODCM by obtaining

representative samples and performing analyses in accordance with the sampling

and analysis program specified in Table 4.11-2.

GE-SREC [46]

,C.',>,

I

,":I.D,',

n

,....,

~ ....... .......

TABLE 4.11-2

RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM

SAMPLING

GASEOUS RELEASE TYPE FREQUENCY

1. -Off gas Treatment M

System

MINIMUM

ANALYSIS

FREQUENCY

M

Grab Sample ________ _

TYPE OF

ACTIVITY ANALYSIS

Principal Gamma Emitters(Z)

2. - Containment PURGE ___ - P 3 P

OR VENT Each PURGE( ) Each PURGE(J) Principal GaMa Emitters(Z)

-Grab Samp 1 e

LOWER LIMIT OF

DETECTION (LLD)(l)

(μCi/ml)

lxl0-4

M H-3 (oxide) lx10~ 6

3. a. (list other M(lT,TS)

M(3)

Principal Gamma Emitters(Z) lxl0-4

release points

where gaseous Grab Sample

effluents are

released from

the facility)

4. All Release Types

as listed in 1.,

2., and 3. above

,~~ ,,~ H-3 (oxide) lxl0-6

c-ontinuous\UJ W I-131 ___ - --------- - lx10- 1z

Continuous< 6>

Charcoal

Sample

w<7)

Particulate

Sample

Principal Gamma Emitters<2>

Continuous< 6> M Gross Alpha

Composite Particulate

Sample

Continuous(G) Q Sr-89, Sr-90

Composite Particulate

Sample

Continuous<6> Noble Gas

Monitor

Noble Gases

Gross Beta or Gamma

lxlQ-11

lxlo-11

lxl0-6

TABLE 4.11-2 (Continued)

TABLE NOTATIONS

(l)The LLD is defined, for purposes of these controls, as the smallest

concentration of radioactive material in a sample that will yield a net

count, above system background, that will be detected with 95% probability

with only 5% probability of falsely concluding that a blank observation

represents a 11 real 11 signal.

For a particular measurement system, which may include radiochemical

separation:

4.66 Sb

LLD = ----------------

E • V • 2.22 x 106 • Y • exp (-~t)

Where:

LLD = the "a priori" lower limit of detection (microCurie per unit

mass or volume),

sb = the standard deviation of the background counting rate or of

the counting rate of a blank sample as appropriate (counts per

minute),

E = the counting efficiency (counts per disintegration),

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

2.22 x 106 = the number of disintegrations per minute per microCurie,

Y = the fractional radiochemical yield, when applicable,

A= the radioactive decay constant for the particular radionuclide

(sec- 1), and

~t = the elapsed time between the midpoint of sample collection and

the time of counting (sec).

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

It should be recognized that the LLD is defined as an ! priori (before

the fact) limit representing the capability of a measurement system and

not as an! posteriori (after the fact) limit for a particular measurement.

GE-SREC [48]

TABLE 4.11-2 (Continued)

TABLE NOTATIONS (Continued)

(l)The principal gamma emitters for which the LLD control applies include

the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and

Xe-138 in noble gas releases and Mn-54, Fe-59, Co-58, Co-60, Zn;65, Mo-99,

I-131, Cs-134, Cs-137, Ce-141 and Ce-144 in Iodine and particulate

releases. This list does not mean that only these nuclides are to be

considered. Other gamma peaks that are identifiable, together with those

of the above nuclides, shall also be analyzed and reported in the

Semiannual Radioactive Effluent Release Report pursuant to Control 6.9.1.4

in the format outlined in Regulatory Guide 1.21, Appendix B, Revision 1,

June 1974.

<3>sampling and analysis shall also be performed following shutdown, startup,

or a THERMAL POWER change exceeding 15% of RATED THERMAL POWER within a

1-hour period.

<4>Not applicable.

<5>Tritium grab samples shall be taken at least once per 7 days from the

ventilation exhaust from the spent fuel pool area, whenever spent fuel is

in the spent fuel pool.

(G)The ratio of the sample flow rate to the sampled stream flow rate shall be

known for the time period covered by each dose or dose rate calculation

made in accordance with Controls 3.11.2.1, 3.11.2.2, and 3.11.2.3.

C7>samples shall be changed at least once per 7 days and analyses shall be

completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after changing, or after removal from sampler.

Sampling shall also be performed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for at least

7 days following each shutdown, startup, or THERMAL POWER change exceeding

15% of RATED THERMAL POWER within a 1-hour period and analyses shall be

completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. When samples collected for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

are analyzed, the corresponding LLDs may be increased by a factor of 10.

This requirement does not apply if: (1) analysis shows that the DOSE

EQUIVALENT 1-131 concentration in the reactor coolant has not increased

more than a factor of 3; and (2) the noble gas monitor shows that

effluent activity has not increased more than a factor of 3.

GE-SREC [49]

RADIOACTIVE EFFLUENTS

DOSE - NOBLE GASES

CONTROLS

3.11.2.2 In accordance with [plant name] TS 6.8.4.g.5) and 8), the air dose

due to noble gases released in gaseous effluents, from each unit, to areas at

and beyond the SITE BOUNDARY (see Figure 5.1-3) shall be limited to the

following:

a. During any calendar quarter: Less than or equal to 5 mrads for

gamma radiation and less than or equal to 10 mrads for beta radiation,

and

b. During any calendar year: Less than or equal to 10 mrads for gamma

radiation and less than or equal to 20 mrads for beta radiation.

APPLICABILITY: At all times.

ACTION

a. With the calculated air dose from radioactive noble gases in gaseous

effluents exceeding any of the above limits, prepare and submit to

the Commission within 30 days, pursuant to Control 6.9.2, a Special

Report that identifies the cause(s) for exceeding the limit(s) and

defines the corrective actions that have been taken to reduce the

releases and the proposed corrective actions to be taken to assure

that subsequent releases will be in compliance with the above limits.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.2 Cumulative dose contributions for the current calendar quarter and

current calendar year for noble gases shall be determined in accordance with

the methodology and parameters in the ODCM at least once per 31 days.

GE-SREC [50]

RADIOACTIVE EFFLUENTS

DOSE - IODINE-131, IODINE-133, TRITIUM, AND RADIOACTIVE MATERIAL IN

PARTICULATE FORM

CONTROLS

3.11.2.3 In accordance with [plant name] TS 6.8.4.g.5) and 9), the dose to a

MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radionuclides

in particulate form with half-lives greater than 8 days in gaseous

effluents released, from each unit, to areas at and beyond the SITE BOUNDARY

{see Figure 5.1-3) shall be limited to the following:

a. During any calendar quarter: Less than or equal to 7.5 mrems to any

organ and,

b. During any calendar year: Less than or equal to 15 mrems to any

organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of lodine-131, Iodine-133,

tritium, and radionuclides in particulate form with half-lives

greater than 8 days, in gaseous effluents exceeding any of the above

limits, prepare and submit to the Commission within 30 days, pursuant

to Control 6.9.2, a Special Report that identifies the cause{s) for

exceeding the limit{s) and defines the corrective actions that have

been taken to reduce the releases and the proposed corrective actions

to be taken to assure that subsequent releases will be in compliance

with the above limits.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.3 Cumulative dose contributions for the current calendar quarter and

current calendar year for Iodine-131, Iodine-133, tritium and radionuclides

in particulate form with half-lives greater than 8 days shall be determined

in accordance with the methodology and parameters in the ODCM at least once

per 31 days.

GE-SREC [ 51]

RADIOACTIVE EFFLUENTS

GASEOUS RADWASTE TREATMENT SYSTEM

CONTROLS

3.11.2.4 The GASEOUS RADWASTE TREATMENT SYSTEM shall be in operation.

APPLICABILITY: Whenever the main condenser air ejector (evacuation) system is

in operation.

ACTION:

a. With gaseous radwaste from the main condenser air ejector system

being discharged without treatment for more than 7 days, prepare and

submit to the Commission within 30 days, pursuant to Control 6.9.2, a

Special Report that includes the following information:

1. Identification of the inoperable equipment or subsystems and

the reason for inoperability,

2. Action(s) taken to restore the inoperable equipment to OPERABLE

status, and

3. Summary description of action(s) taken to prevent a

recurrence.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.4 The readings of the relevant instruments shall be checked every 12

hours when the main condenser air ejector is in use to ensure that the gaseous

radwaste treatment system is functioning.

GE-SREC [52]

RADIOACTIVE EFFLUENTS

VENTILATION EXHAUST TREATMENT SYSTEM

CONTROLS

3.11.2.5 The VENTILATION EXHAUST TREATMENT SYSTEM shall be OPERABLE and

appropriate portions of this system shall be used to reduce releases of

radioactivity when the projected doses in 31 days due to gaseous effluent

releases, from each unit, to areas at and beyond the SITE BOUNDARY

(see Figure 5.1-3) would exceed:

a. 0.2 mrad to air from gamma radiation, or

b. 0.4 mrad to air from beta radiation, or

c. 0.3 mrem to any organ of a MEMBER OF THE PUBLIC.

APPLICABILITY: At all times.

ACTION:

a. With radioactive gaseous waste being discharged without treatment

and in excess of the above limits, prepare and submit to the

Commission within 30 days, pursuant to Control 6.9.2, a Special

Report that includes the following information:

1. Identification of any inoperable equipment or subsystems, and

the reason for the inoperability,

2. Action(s) taken to restore the inoperable equipment to OPERABLE

status, and

3. Summary description of action(s) taken to prevent a recurrence.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.5.1 Doses due to gaseous releases from each unit to areas at and

beyond the SITE BOUNDARY shall be projected at least once per 31 days in

accordance with the methodology and parameters in the ODCM when the Ventilation

Exhaust Treatment System is not being fully utilized.

4.11.2.5.2 The installed VENTILATION EXHAUST TREATMENT SYSTEM shall be

considered OPERABLE by meeting Controls 3.11.2.1, and either 3.11.2.2 or

3.11.2.3.

GE-SREC [53]

RADIOACTIVE EFFLUENTS

3/4.11.2.6 (NOT USED)

GE-SREC [54]

RADIOACTIVE EFFLUENTS

3/4.11.2.7 (NOT USED)

GE-SREC [55]

RADIOACTIVE EFFLUENTS

MARK I or II CONTAINMENT

CONTROLS

3.11.2.8 VENTING or PURGING of the Mark I or II containment drywell shall be

through the Standby Gas Treatment System.

APPLICABILITY: Whenever the drywell is vented or purged.

ACTION:

a. With the requirements -0f the above control not satisfied, suspend all

VENTING and PURGING of the drywell.

b. The provisions of fontrols 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.8 The containment drywell shall be determined to be aligned for VENTING

or PURGING through the Standby Gas Treatment System within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to

start of and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during VENTING or PURGING of the

drywell.

GE-SREC (56]

RADIOACTIVE EFFLUENTS

3/4.11.3 (NOT USED)

GE-SREC [57]

RADIOACTIVE EFFLUENTS

3/4.11.4 TOTAL DOSE

CONTROLS

3.11.4 in accordance with [plant name] TS 6.8.4.g.ll), the annual (calendar

year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of

radioactivity and to radiation from uranium fuel cycle sources shall be limited

to less than or equal to 25 mrems to the whole body or any organ, except the

thyroid, which shall be limited to less than or equal to 75 mrems.

APPLICABILITY: At all times.

ACTION:

a. With the calculated doses from the release of radioactive materials

in liquid or gaseous effluents exceeding twice the limits of Control

3.ll.l.2a., 3.ll.l.2b., 3.ll.2.2a., 3.11.2.2b., 3.11.2.3a., or

3.ll.2.3b., calculations shall be made including direct radiation

contributions from the units (including outside storage tanks etc.) to

determine whether the above limits of Control 3.11.4 have been

exceeded. If such is the case, prepare and submit to the Commission

within 30 days, pursuant to Control 6.9.2, a Special Report that

defines the corrective action to be taken to reduce subsequent

releases to prevent recurrence of exceeding the above limits and

includes the schedule for achieving conformance with the above limits.

This Special Report, as defined in 10 CFR 20.405(c), shall include an

analysis that estimates the radiation exposure (dose) to a MEMBER OF

THE PUBLIC from uranium fuel cycle sources, including all effluent

pathways and direct radiation, for the calendar year that includes

the release(s) covered by this report. It shall also describe levels

of radiation and concentrations of radioactive material involved, and

the cause of the exposure levels or concentrations. If the estimated

dose(s) exceeds the above limits, and if the release condition resulting

in violation of 40 CFR Part 190 has not already been corrected,

the Special Report shall include a request for a variance in accordance

with the provisions of 40 CFR Part 190. Submittal of the report

is considered a timely request, and a variance is granted until staff

action on the request is complete.

b. The provisions of Controls 3.0.3 and 3.-0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.4.1 Cumulative dose contributions from liquid and gaseous effluents

shall be determined in accordance with Controls 4.11.1.2, 4.11.2.2, and

4.11.2.3, and in accordance with the methodology and parameters in the ODCM.

4.11.4.2 Cumulative dose contributions from direct radiation from the units

(including outside storage tanks etc.) shall be determined in accordance with

the methodology and parameters in the ODCM. This requirement is applicable

only under conditions set forth in ACTION a. of Control 3.11.4.

GE-SREC [58]

3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING

3/4.12.1 MONITORING PROGRAM

CONTROLS

3.12.1 In accordance with [plant name] TS 6.8.4.h.1), the Radiological

Environmental Monitoring Program shall be conducted as specified in -

Table 3.12-1.

APPLICABILITY: At all times.

ACTION:

a. With the Radiological Environmental Monitoring Program not being

conducted as specified- in Table 3.12-1, prepare and submit to

the Commission, in the Annual Radiological Environmental Operating

Report required by Control 6.9.l.3, a description of the reasons

for not conducting the program as required and the plans for preventing

a recurrence.

b. With the level of radioactivity as the result of plant effluents in

an environmental sampling medium at a specified location exceeding

the reporting levels of Table 3.12-2 when averaged over any calendar

quarter, prepare and submit to the Commission within 30 days, pursuant

to Control 6.9.2, a Special Report that identifies the cause(s)

for exceeding the limit(s) and defines the corrective actions to be

taken to reduce radioactive effluents so that the potential annual

dose* to a MEMBER OF THE PUBLIC is less than the calendar year limits

of Controls 3.11.1.2, 3.11.2.2, or 3.11.2.3. When more than

one of the radionuclides in Table 3.12-2 are detected in the sampling

medium, this report shall be submitted if:

concentration 1 + concentration 2

repor t"1 ng 1e ve 1 l repor t 1ng eve 2 + ••• > 1.0

When radionuclides other than those in Table 3.12-2 are detected and

are the result of plant effluents, this report shall be submitted if

the potential annual dose* to a MEMBER OF THE PUBLIC from all radionuclides

is equal to or greater than the calendar year limits of

Control 3.11.1.2, 3.11.2.2, or 3.11.2.3. This report is not

required if the measured level of radioactivity was not the result

of plant effluents; however, in such an event, the condition shall

be reported and described in the Annual Radiological Environmental

Operating Report required by Control 6.9.1.3.

The methodology and parameters used to estimate the potential annual dose to

a MEMBER OF THE PUBLIC shall be indicated in this report.

GE-SREC

[59]

RADIOLOGICAL ENVIRONMENTAL MONITORING

CONTROLS

ACTION (Continued)

c. With milk or fresh leafy vegetation samples unavailable from one or

more of the sample locations required by Table 3.12-1, identify

specific locations for obtaining replacement samples and add them

within 30 days to the Radiological Environmental Monitoring Program

given in the ODCM. The specific locations from which samples were

unavailable may then be deleted from the monitoring program. Pursuant

to Control 6.14, submit in the next Semiannual Radioactive Effluent

Release Report documentation for a change in the ODCM including a

revised figure(s) and table for the ODCM reflecting the new

location(s) with supporting information identifying the cause of

the unavailability of samples and justifying the selection of the

new location(s) for obtaining samples.

d. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.1 The radiological environmental monitoring samples shall be collected

pursuant to Table 3.12-1 from the specific locations given in the table and

figure(s) in the ODCM, and shall be analyzed pursuant to the requirements of

Table 3.12-1 and the detection capabilities required by Table 4.12-1.

GE·SREC [60]

a

.m,•,

ID m

n

,.....,

.°....._.'..

EXPOSURE PATHWAY

AND/OR SAMPLE

TABLE 3.12-1

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM*

NUMBER OF

REPRESENTATIVE

SAMPLES AND

SAMPLE LOCATIONS(l)

SAMPLING AND

COLLECTION FREQUENCY

1. Direct Radiation<2> Forty routine monitoring stations Quarterly.

(DR1-DR40) either with two or more

dosimeters or with one instrument

for measuring and recording dose

rate continuously, placed as

follows:

An inner ring of stations, one in

each meteorological sector in the

general area of the SITE BOUNDARY

(DR1-DR16);

An outer ring of stations, one in

each meteorological sector in

the 6- to 8-km range from the

site (DR17-DR32); and

The balance of the stations

(DR33-DR40) to be placed in

special interest areas such

as population centers, nearby

residences, schools, and in one

or two areas to serve as control

stations.

TYPE ANO FREQUENCY

OF ANALYSIS

Gamma dose quarterly.

•The number, media, frequency, and location of samples may vary from site to site. This table pre's ents an

acceptable minimum program for a site at which each entry is applicable. Local site characteristics must be

examined to determine if pathways not covered by this table may significantly contribute to an individual's

dose and should be included in the sample program. The code letters in parentheses, e.g., ORI, Al, provide

one way of defining sample locations in this control that can be used to identify the specific locations

in the map(s) and table in the OOCM.

........

°' N

........

I:')

""I '

":a'

"n" '

EXPOSURE PATHWAY

AND/OR SAMPLE

2. Airborne

Radioiodine and

Particulates

3. Waterborne

a. Surface(S)

b. Ground

TABLE 3.12-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

NUMBER OF

REPRESENTATIVE

SAMPLES AND

SAMPLE LOCATIONS(l)

Samples from five locations

(Al-AS):

Three samples (Al-A3) from

close to the three SITE

BOUNDARY locations, in

different sectors, of the

highest calculated annual

average ground-level D/Q;

One sample (A4) from the

vicinity of a community

having the highest calculated

annual average groundlevel

D/Q; and

One sample (AS) from a control

location, as for example 15 to

30 km distant and in the least

prevalent wind direction.

SAMPLING AND

COLLECTION FREQUENCY

Continuous sampler operation

with sample collection

weekly, or more

frequently if required by

dust loading.

One sample upstream (Wal). Composite sample over

One sample downstream (Wa2). 1-month period. (G)

Samples from one or two sources Quarterly.

(Wbl, Wb2), only if likely to be

affected<7>.

TYPE AND FREQUENCY

OF ANALYSIS

Radioiodine Cannister:

I-131 analysis weekly.

Particulate Sampler:

Gross beta radioactivity

analysis following

filter change;(J) and 4

gamma isotopic analysis< )

of composite (by

location) quarterly.

Gamma isotopic analysis<4>

monthly. Composite for

tritium analysis quarterly.

Gamma isotopic<4> and

tritium analysis quarterly

G)

m

I

"::0' m

n

r-1

O'I

w

L....J

EXPOSURE PATHWAY

AND/OR SAMPlE

TABLE 3.12-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

NUMBER OF

REPRESENTATIVE

SAMPLES AND

SAMPLE LOCATIONS(l)

SAMPLING ANO

COLLECTION FREQUENCY

3. Waterborne (Continued)

c. Drinking

d. Sediment

from

Shoreline

4. Ingestion

a. Milk

One sample of each of one to

three (Wcl - Wc3) of the nearest

water supplies that could be

affected by its discharge.

One sample from a control

location (Wc4).

One sample from downstream area

with existing or potential

recreational value (Wdl).

Samples from milking animals

in three locations (lal - Ia3)

within 5 km distance having the

highest dose potential. If

there are none, then one

sample from milking animals

in each of three areas

(lal - la3) between 5 to

8 km distant where doses

are calculated to bf8~reater

than 1 mrem per yr. One

sample from milking animals

at a control location (la4),

15 to 30 km distant and in the

least prevalent wind direction.

Composite sample over

2-week period(6) when

1-131 analysis is performed;

monthly composite

otherwise.

Semiannually.

Semimonthly when

animals are on pasture;

monthly at other times.

TYPE AND FREQUENCY

OF ANALYSIS

I-131 analysis on each

composite when the dose

calculated for the consumption

of the water

is greater than 1 mrem

per year<8>. Composite

for gross beta and gannna

isotopic analyses<4>

monthly. Composite for

tritium analysis quarterly.

Gamma isotopic analysis<4>

semiannually.

Gamma isotopic<4> and

1-131 analysis semimonthly

when animals

are on pasture; monthly

at other times.

~

I

Cit

,~,,

"

,....,

0\

.i::.

1--1

EXPOSURE PATHWAY

AND/OR SAMPLE

4. Ingestion (Continued)

b. Fish and

Invertebrates

c. Food

Products

TABLE 3.12-1 (Continued)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

NUMBER OF

REPRESENTATIVE

SAMPLES AND

SAMPLE LOCATIONS(l)

One sample of each commercially

and recreationally important

species in vicinity of plant

discharge area. (lbl - lb~>·

One sample of same species in

areas not influenced by plant

discharge (lblO - lb ).

One sample of each principal

class of food products from

any area that is irrigated

by water in which liquid

plant wastes have been

discharged (Icl - le~>·

Samples of three different

kinds of broad leaf vegetation

grown nearest each of

two different offsite locations

of highest predicted

annual average ground level

D/Q if milk sampling is not

performed (lclO - Icl3).

One sample of each of the

similar broad leaf vegetation

grown 15 to 30 km distant

in the least prevalent

wind direction if milk sampling

is not performed (lc20 -

lc23).

SAMPLING AND

COLLECTION FREQUENCY

Sample in season, or

semiannually if they

are not seasonal.

At time of harvest<9>.

Monthly during

growing season.

Monthly during

growing season.

TYPE AND FREQUENCY

OF ANALYSIS

Gamma isotopic analysis(4)

on edible portions.

Gamma isotopic analyses<4>

on edible portion.

Gamma isotopic<4> and 1-131

analysis.

Gamma isotopic<4> and 1-131

analysis.

TABLE 3.12-1 (Continued)

TABLE NOTATIONS

(1) Specific parameters of distance and direction sector from the centerline

of one reactor, and additional description where pertinent, shall be provided

for each and every sample location in Table 3.12-1 in a table and

figure(s) in the ODCM. Refer to NUREG-0133, "Preparation of Radiological

Effluent Technical Specifications for Nuclear Power Plants," October 1978,

and to Radiological Assessment Branch Technical Position, Revision 1,

November 1979. Deviations are permitted from the required sampling

schedule if specimens are unobtainable due to circumstances such as

hazardous conditions, seasonal unavailability, and malfunction of automatic

sampling equipment. If specimens are unobtainable due to sampling

equipment malfunction, eff~rt shall be made to complete corrective action

prior to the end of the next sampling period. All deviations from the

sampling schedule shall be documented in the Annual Radiological Environmental

Operating Report pursuant to Control 6.9.1.3. It is recognized

that, at times, it may not be possible or practicable to continue to

obtain samples of the media of choice at the most desired location or

time. In these instances suitable alternative media and locations may be

chosen for the particular pathway in question and appropriate substitutions

made within 30 days in the Radiological Environmental Monitoring Program

given in the ODCM. Pursuant to Control 6.14, submit in the next

Semiannual Radioactive Effluent Release Report documentation for a change

in the ODCM including a revised figure(s) and table for the ODCM reflecting

the new location(s) with supporting information identifying the cause

of the unavailability of samples for the pathway and justifying the selection

of the new location(s) for obtaining samples.

(2) One or more instruments, such as a pressurized ion chamber, for measuring

and recording dose rate continuously may be used in place of, or in addition

to, integrating dosimeters. For the purposes of this table, a

thermoluminescent dosimeter (TLD) is considered to be one phosphor; two

or more phosphors in a packet are considered as two or more dosimeters.

Film badges shall not be used as dosimeters for measuring direct radiation.

(The 40 stations is.not an absolute number. The number of direct radiation

monitoring stations may be reduced according to geographical limitations;

e.g., at an ocean site, some sectors will be over water so that the number

of dosimeters may be reduced accordingly. The frequency of analysis or

readout for TLD systems will depend upon the characteristics of the specific

system used and should be selected to obtain optimum dose information

with minimal fading.)

(3) Airborne particulate sample filters shall be analyzed for gross beta

radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more after sampling to allow for radon and

thoron daughter decay. If gross beta activity in air particulate samples

is greater than 10 times the yearly mean of control samples, gamma

isotopic.analysis shall be performed on the individual samples.

GE-SREC [65]

TABLE 3.12-1 (Continued)

TABLE NOTATIONS (Continued)

(4) Gamma isotopic analysis means the identification and quantification of

gamma-emitting radionuclides that may be attributable to the effluents

from the facility.

(5) The "upstream sample" shall be taken at a distance beyond significant

influence of the discharge. The 11 downstream11 sample shall be taken in an

area beyond but near the mixing zone. "Upstream" samples in an estuary

must be taken far enough upstream to be beyond the plant influence. Salt

water shall be sampled only when the receiving water is utilized for

recreational activities.

(6) A composite sample is one in which the quantity (aliquot) of liquid sampled

is proportional to the quantity of flowing liquid and in which the method

of sampling employed results in a specimen that is representative of the

liquid flow. In this program composite sample aliquots shall be collected

at time intervals that are very short (e.g., hourly) relative to the

compositing period (e.g., monthly) in order to assure obtaining a

representative sample.

(7) Groundwater samples shall be taken when this source is tapped for drinking

or irrigation purposes in areas where the hydraulic gradient or recharge

properties are suitable for contamination.

(8) The dose shall be calculated for the maximum organ and age group, using

the methodology and parameters in the ODCM.

(9) If harvest occurs more than once a year, sampling shall be performed

during each discrete harvest. If harvest occurs continuously, sampling

shall be monthly. Attention shall be paid to including samples of

tuberous and root food products.

GE-SREC [66]

G'>

'"I

"::0' n""

......,

O"I

.......

L.....I

ANALYSIS

H-3

Mn-54

Fe-59

Co-58

Co-60

Zn-65

Zr-Nb-95

1-131

Cs-134

Cs-137

Ba-La-140

TABLE 3.12-2

REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES

REPORTING LEVELS

WATER AIRBORNE PARTICULATE FISH MILK

(pCi/1) OR GASES (pCi/m3) (pCi/kg, wet) (pCi/1)

20,000*

1,000 30,000

400 10,000

1,000 30,000

300 10,000

300 20,000

400

2** 0.9 3

30 10 1,000 60

50 20 2,000 70

200 300

FOOD PRODUCTS

(pCi/kg, wet)

100

1,000

2,000

For drf nkf ng water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value

of 30,000 pCf/1 may be used.

- If no drfnkfng water pathway exists, a value of 20 pCi/1 may be used.

I:) TABLE 4.12-1

"' DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS(!) (l) I

";:a'

"n ' LOWER LIMIT OF DETECTION ~LLD}( 3 )

WATER AIRBORNE PARTICULATE FISH MILK FOOD PRODUCTS SEDIMENT

ANALYSIS (pCi/1) OR GASES (pCi/m3) (pCi/kg, wet) (pCi/l) (pCi/kg, wet) (pCi/kg, dry)

Gross Beta 4 0.01

H-3 2000*

Mn-54 15 130

Fe-59 30 260

Co-58,60 15 130

....,

CJ'I Zn-65 30 260

CX>

~

Zr-Nb-95 15

1-131 1** 0.07 1 60

Cs-134 15 0.05 130 15 60 150

Cs-137 18 0.06 150 18 80 180

Ba-La-140 15 15

If no drinking water pathway exists, a value of 3000 pCi/1 may be used.

- If no drinking water pathway exists, a value of 15 pCi/1 may be used.

TABLE 4.12-1 (Continued)

TABLE NOTATIONS

(l)This list does not mean that only these nuclides are to be considered.

Other peaks that are identifiable, together with those of the above

nuclides, shall also be analyzed and reported in the Annual Radiological

Environmental Operating Report pursuant to Control 6.9.1.3.

(2)Required detection capabilities for thermoluminescent dosimeters used

for environmental measurements shall be in accordance with the recommendations

of Regulatory Guide 4.13.

(3)The LLD is defined, for purposes of these controls, as the smallest

concentration of radioactive material in a sample that will yield a net

count, above system background, that will be detected with 95% probability

with only 5% probability of falsely concluding that a blank observation

represents a "real" signal.

For a particular measurement system, which may include radiochemical

separation:

4.66 Sb

LLD = ---------------

E • V • 2.22 • Y • exp(-~t)

Where:

LLD = the "a priori" lower limit of detection (picoCuries per unit

mass or volume),

E

v

= the standard deviation of the background counting rate or of the

counting rate of a blank sample as appropriate (counts per minute),

= the counting efficiency (counts per disintegration),

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

2.22 = the number of disintegrations per minute per picoCurie,

Y = the fractional radiochemical yield, when applicable,

A = the radioactive decay constant for the· particular radionuclide

(sec- 1), and

At = the elapsed time between environmental collection, or end of

the sample collection period, and time of counting (sec).

Typical values of E, V, Y, and At should be used in the calc·ulation.

GE-SREC [69)

TABLE 4.12-1 (Continued)

TABLE NOTATIONS (Continued)

It should be recognized that the LLD is defined as an ! priori (before the

fact) limit representing the capability of a measurement system and not as

an! posteriori (after the fact) limit for a particular measuremeQt.

Analyses shall be performed in such a manner that the stated LLDs will be

achieved under routine conditions. Occasionally background fluctuations,

unavoidable small sample sizes, the presence of interfering nuclides, or

other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors shall be identified and described

in the Annual Radiological Environmental Operating Report pursuant to

Control 6.9.1.3.

GE-SREC [70]

RADIOLOGICAL ENVIRONMENTAL MONITORING

3/4.12.2 LAND USE CENSUS

CONTROLS

3.12.2 In accordance with [plant name] TS 6.8.4.h.2), a Land Use Census shall

be conducted and shall identify within a distance of 8 km (5 miles) the

location in each of the 16 meteorological sectors of the nearest milk animal,

the nearest residence, and the nearest garden* of greater than 50 m2 (500 ft2 )

producing broad leaf vegetation. [For elevated releases as defined in Regulatory

Guide 1.111, Revision 1, July 1977, the Land Use Census shall also

identify within a distance of 5 km (3 miles) the locations in each of the

16 meteorological sectors of all milk animals and all gardens of greater than

50 m2 producing broad leaf vegetation.]

· APPLICABILITY: At all times.

ACTION:

a. With a Land Use Census identifying a location(s) that yields a·

calculate1 dose or dose commitment greater than the values currently

being calculated in Control 4.11.2.3, pursuant to Control 6.9.1.4,

identify the new location(s) in the next Semiannual Radioactive

Effluent Release Report.

b. With a Land Use Census identifying a location(s) that yields a·

calculated dose or dose commitment (via the same exposure pathway)

20% greater than at a location from which samples are currently

being obtained in accordance with Control 3.12.1, add the new

location(s) within 30 days to the Radiological Environmental Monitoring

Program given in the ODCM. The sampling location(s), excluding

the control station location, having the lowest calculated dose

or dose commitment(s), via the same exposure pathway, may be deleted

from this monitoring program after [October 31] of the year in which

this Land Use Census was conducted. Pursuant to Control 6.14,

submit in the next Semiannual Radioactive Effluent Release Report

documentation for a change in the ODCM including a revised figure(s)

and table(s) for the ODCM reflecting the new location(s) with information

supporting the change in sampling locations.

c. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

Broad leaf vegetation sampling of at least three different kinds of vegetation

may be performed at the SITE BOUNDARY in each of two different direction

sectors with the highest predicted D/Qs in lieu of the garden census.

Controls for broad leaf vegetation sampling in Table 3.12-1, Part 4.c., shall

be followed, including analysis of control samples.

GE-SREC [71]

RADIOLOGICAL ENVIRONMENTAL MONITORING

SURVEILLANCE REQUIREMENTS 4.12.2 The Land Use Census shall be conducted during the growing season at

least once per 12 months using that information that will provide the best

results, such as by a door-to-door survey, aerial survey, or by conS'Ulting

local agriculture authorities. The results of the Land Use Census shall be

included in the Annual Radiological Environmental Operating Report pursuant to

Control 6.9.1.3.

GE-SREC [72]

RADIOLOGICAL ENVIRONMENTAL MONITORING

3/4.12.3 INTERLABORATORY COMPARISON PROGRAM

CONTROLS

3.12.3 In accordance with [plant name] TS 6.8.4.h.3), analyses shall be

performed on all radioactive materials, supplied as part of an Interlaboratory

Comparison Program that has been approved by the Commission, that correspond to

samples required by Table 3.12-1.

APPLICABILITY: At all times.

ACTION:

a. With analyses not being performed as required above, report the

corrective actions taken to prevent a recurrence to the Commission

in the Annual Radiological Environmental Operating Report pursuant

to Control 6.9.1.3.

b. The provisions of Controls 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.3 The Interlaboratory Comparison Program shall be described in the ODCM.

A summary of the results obtained as part of the above required Interlaboratory

Comparison Program shall be included in the Annual Radiological Environmental

Operating Report pursuant to Control 6.9.1.3.

GE-SREC

[73]

GE-SREC

BASES FOR

SECTIONS 3.0 AND 4.0

CONTROLS

AND

SURVEILLANCE REQUIREMENTS

-NOTE

The BASES contained in succeeding paqes summarize

the reasons for the Controls in Sect1ons 3.0

and 4.0, but are not part of these Controls.

[74]

INSTRUMENTATION

BASES

3/4.3.3.10 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION

The radioactive liquid effluent instrumentation is provided to monitor

and control, as applicable, the releases of radioactive materials in liquid

effluents during actual or potential releases of liquid effluents. The

Alarm/Trip Setpoints for these instruments shall be calculated and adjusted in

accordance with the methodology and parameters in the ODCM to ensure that the

alarm/trip will occur prior to exceeding the limits of 10 CFR Part 20. The

OPERABILITY and use of this instrumentation is consistent with the requirements

of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

3/4.3.3.11 RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION

The radioactive gaseous effluent instrumentation is provided to monitor and

control, as applicable, the releases of radioactive materials in gaseous effluents

during actual or potential releases of gaseous effluents. The Alarm/Trip

Setpoints for these instruments shall be calculated and adjusted in accordance

with the methodology and parameters in the ODCM to ensure that the alarm/trip

will occur prior to exceeding the limits of 10 CFR Part 20. The OPERABILITY

and use of this instrumentation is consistent with the requirements of General

Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

GE-SREC [75]

3/4.11 RADIOACTIVE EFFLUENTS

BASES

3/4.11.1 LIQUID EFFLUENTS

3/4.11.1.1 CONCENTRATION

This control is provided to ensure that the concentration of radioactive

materials released in liquid waste effluents to UNRESTRICTED AREAS will be less

than the concentration levels specified in 10 CFR Part 20, Appendix B, Table

II, Column 2. This limitation provides additional assurance that the levels of

radioactive materials in bodies of water in UNRESTRICTED AREAS will result in

exposures within: (1) the Section II.A design objectives of Appendix I, 10 CFR

Part SO, to a MEMBER OF THE PUBLIC, and (2) the limits of 10 CFR Part 20.106(e)

· to the population. The concentration limit for dissolved or entrained noble

gases is based upon the assumption that Xe-13S is the controlling radioisotope

and its MPC in air (submersion) was converted to an equivalent concentration in

water using the methods described in International Commission on Radiological

Protection (ICRP) Publication 2.

This control applies to the release of radioactive materials in liquid

effluents from all units at the site.

The required detection capabilities for radioactive materials in liquid

waste samples are tabulated in terms of the lower limits of detection (LLDs).

Detailed discussion of the LLD, and other detection limits can be found in

Currie, L. A., "Lower Limit of Detection: Definition and Elaboration of a

Proposed Position for Radiological Effluent and Environmental Measurements,"

NUREG/CR-4007 (September 1984), and in the HASL Procedures Manual, HASL-300.

3/4.11.1.2 DOSE

This control is provided to implement the requirements of Sections II.A,

III.A, and IV.A of Appendix I, 10 CFR Part SO. The Control implements the

guides set forth in Section II.A of Appendix I. The ACTION statements provide

the required operating flexibility and at the same time implement the guides

set forth in Section IV.A of Appendix I to assure that the releases of radioactive

material in liquid effluents to UNRESTRICTED AREAS will be kept "as low

as is reasonably achievable." Also, for fresh water sites with drinking water

supplies that can be potentially affected by plant operations, there is

reasonable assurance that the operation of the facility will not result in

radionuclide concentrations in the finished drinking water that are in excess

of the requirements of 40 CFR Part 141. The dose calculation methodology and

parameters in the ODCM implement the requirements in Section III.A of

Appendix I that conformance with the guides of Appendix I be shown by calculational

procedures based on models and data, such that the actual exposure of

a MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially

underestimated. The equations specified in the ODCM for calculating the

doses due to the actual release rates of radioactive materials in liquid

effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of

GE-SREC [76]

RADIOACTIVE EFFLUENTS

BASES

DOSE (Continued)

Reactor Effluents for the Purpose of Evaluating Compliance with 10 CF~ Part SO,

Appendix I, 11 Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating

Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases

for the Purpose of Implementing Appendix I," April 1977.

This control applies to the release of radioactive materials in liquid

effluents from each unit at the site. For units with shared Radwaste Systems,

the liquid effluents from the shared system are to be proportioned among the

units sharing that system .

. 3/4.11.1.3 LIQUID RADWASTE TREATMENT SYSTEM

The OPERABILITY of the Liquid Radwaste Treatment System ensures that this

system will be available for use whenever liquid effluents require treatment

prior to release to the environment. The requirement that the appropriate portions

of this system be used when specified provides assurance that the releases of

radioactive materials in liquid effluents will be kept "as low as is reasonably

achievable." This control implements the requirements of 10 CFR 50.36a,

General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design

objective given in Section II.D of Appendix I to 10 CFR Part 50. The specified

limits governing the use of appropriate portions of the Liquid Radwaste Treatment

System were specified as a suitable fraction of the dose design objectives set

forth in Section II.A of Appendix I, 10 CFR Part 50 for liquid effluents.

This control applies to the release of radioactive materials in liquid

effluents fr~m·each unit at the site. For units with shared Radwaste Systems,

the liquid effluents from the shared system are to be proportioned among the

units sharing that system.

GE-SREC [77]

RADIOACTIVE EFFLUENTS

BASES

3/4.11.2 GASEOUS EFFLUENTS

3/4.11.2.1 DOSE RATE

This control is provided to ensure that the dose at any time at and

beyond the SITE BOUNDARY from gaseous effluents from all units on the site

will be within the annual dose limits of 10 CFR Part 20 to UNRESTRICTED AREAS.

The annual dose limits are the doses associated with the concentrations of

10 CFR Part 20, Appendix B, Table II, Column I. These limits provide reasonable

assurance that radioactive material discharged in gaseous effluents will not

result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA,

either within or outside the SITE BOUNDARY, to annual average concentrations

exceeding the limits specified in Appendix B, Table II of 10 CFR Part 20

-(10 CFR Part 20.106(b)). For MEMBERS OF THE PUBLIC who may at times be within

the SITE BOUNDARY, the occupancy of that MEMBER OF THE PUBLIC will usually be

sufficiently low to compensate for any increase in the atmospheric diffusion

factor above that for the SITE BOUNDARY. Examples of calculations for such

MEMBERS OF THE PUBLIC, with the appropriate occupancy factors, shall be given

in the ODCM. The specified release rate limits restrict, at all times, the

corresponding gamma and beta dose rates above background to a MEMBER OF THE

PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrems/year

to the whole body or to less than or equal to 3000 mrems/year to the skin.

These release rate limits also restrict, at all times, the corresponding

thyroid dose rate above background to a child via the inhalation pathway to

less than or equal to 1500 mrems/year.

This control applies to the release of radioactive materials in gaseous

effluents from all units at the site.

The required detection capabilities for radioactive material in gaseous

waste samples are tabulated in terms of the lower limits of detection (LLDs).

Detailed discussion of the LLD, and other detection limits can be found in

Currie, L. A., "Lower Limit of Detection: Definition and Elaboration of a

Proposed Position for Radiological Effluent and Environmental Measurements,"

NUREG/CR-4007 (September 1984), and in the HASL Procedures Manual, HASL-300.

3/4.11.2.2 DOSE - NOBLE GASES

This control is provided to implement the requirements of Sections II.B,

III.A and IV.A of Appendix I, 10 CFR Part 50. The control implements the

guides set forth in Section I.B of Appendix I. The ACTION statements provide

the required operating flexibility and at the same time implement the guides

set forth in Section IV.A of Appendix I to assure that the releases of radioactive

material in gaseous effluents to UNRESTRICTED AREAS will be kept "as low

as is reasonably achievable." The Surveillance Requirements implement the

requirements in Section III.A of Appendix I that conformance with the guides of

Appendix I be shown by calculational procedures based on models and data such

that the actual exposure of a MEMBER OF THE PUBLIC through appropriate pathways -

is unlikely to be substantially underestimated. The dose calculation

GE-SREC [78]

RADIOACTIVE EFFLUENTS

BASES

DOSE-NOBLE GASES (Continued)

methodology and parameters established in the ODCM for calculating the doses

due to the actual release rates of radioactive noble gases in gaseous effluents

are consistent with the methodology provided in Regulatory Guide 1.109,

"Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents

for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,11

Revision I, October 1977 and Regulatory Guide 1.111, "Methods for Estimating

Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases

from Light-Water Cooled Reactors, 11 Revision l, July 1977. The ODCM equations

provided for determining the air doses at and beyond the SITE BOUNDARY are

based upon the historical average atmospheric conditions.

This control applies to the release of radioactive materials in gaseous

effluents from each unit at the site. For units with shared Radwaste Treatment

Systems, the gaseous effluents from the shared system are proportioned among

the units sharing that system.

3/4.11.2.3 DOSE - IODINE-131, IODINE-133, TRITIUM, AND RADIOACTIVE MATERIAL

IN PARTICULATE FORM

This control is provided to implement the requirements of Sections II.C,

III.A and IV.A of Appendix I, 10 CFR Part 50. The Controls are the guides set

forth in Section II.C of Appendix I. The ACTION statements provide the

required operating flexibility and at the same time implement the guides set

forth in Section IV.A of Appendix I to assure that the releases of radioactive

materials in gaseous effluents to UNRESTRICTED AREAS will be kept "as low as is

reasonably achievable." The ODCM calculational methods specified in the

Surveillance Requirements implement the requirements in Section III.A of

Appendix I that conformance with the guides of Appendix I be shown by calculational

procedures based on models and data such that the actual exposure of a

MEMBER OF THE PUBLIC through appropriate pathways is unlikely to be substantially

underestimated. The ODCM calculational methodology and parameters for

calculating the doses due to the actual release rates of the subject materials

are consistent with the methodology provided in Regulatory Guide 1.109,

"Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents

for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

Revision 1, October 1977 and, Regulatory Guide 1.111, "Methods for Estimating

Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases

from Light-Water-Cooled Reactors," Revision 11 July 1977. These equations also

provide for determining the actual doses based upon the historical average

atmospheric conditions. The release rate controls for Iodine-131 Iodine-133,

tritium, and radionuclides in particulate form with half-lives greater than

8 days are dependent upon the existing radionuclide pathways to man in the

GE-SREC [79]

RADIOACTIVE EFFLUENTS

BASES

DOSE - IODINE-131, IODINE-133, TRITIUM, AND RADIOACTIVE MATERIAL IN PARTICULATE

FORM (Continued)

areas at and beyond the SITE BOUNDARY. The pathways that were examined in the

development of the calculations were: (1) individual inhalation of airborne

radionuclides, (2) deposition of radionuclides onto green leafy vegetation

with subsequent consumption by man, (3) deposition onto grassy areas where milk

animals and meat producing animals graze with consumption of the milk and meat

by man, and (4) deposition on the ground with subsequent exposure of man.

This control applies to the release of radioactive materials in gaseous

effluents from each unit at the site. For units with shared Radwaste Treatment

Systems, the gaseous effluents from the shared system are proportioned among

the units sharing that system.

3/4.11.2.4 ANO 3/4.11.2.5 GASEOUS RAOWASTE TREATMENT SYSTEM AND VENTILATION

EXHAUST TREATMENT SYSTEM

The OPERABILITY of the WASTE GAS HOLDUP SYSTEM and the VENTILATION EXHAUST

TREATMENT SYSTEM ensures that the systems will be available for use whenever

gaseous effluents require treatment prior to release to the environment. The

requirement that the appropriate portions of these systems be used, when specified,

provides reasonable assurance that the releases of radioactive materials in

gaseous effluents will be kept "as low as is reasonably achievable. 11 This

control implements the requirements of 10 CFR 50.36a, General Design

Criterion 60 of Appendix A to 10 CFR Part 50 and the design objectives given

in Section 11.D of Appendix I to 10 CFR Part 50. The specified limits governing

the use of appropriate portions of the systems were specified as a suitable

fraction of the dose design objectives set forth in Sections 11.B and II.C of

Appendix I, 10 CFR Part 50, for gaseous effluents.

This control applies to the release of radioactive materials in gaseous

effluents from each unit at the site. For units with shared Radwaste Treatment

Systems, the gaseous effluents from the shared system are proportioned among

the units sharing that system.

GE-SREC [80]

RADIOACTIVE EFFLUENTS

BASES

3/4 11.2.6 NOT USED

3/4 11.2.7 NOT USED

3/4.11.2.8 MARK I CONTAINMENT

This specification provides reasonable assurance that releases from drywell

purging operations will not exceed the annual dose limits of 10.CFR part 20

for unrestricted areas.

3/4.11.3 NOT USED

3/4.11.4 TOTAL DOSE

This control is provided to meet the dose limitations of 10 CFR Part 190

that have been incorporated into 10 CFR Part 20 by 46 FR 18525. The control

requires the preparation and submittal of a Special Report whenever the

calculated doses due to releases of radioactivity and to radiation from

uranium fuel cycle sources exceed 25 mrems to the whole body or any organ,

except the thyroid, which shall be limited to less than or equal to 75 mrems.

For sites containing up to four reactors, it is highly unlikely that the

resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR

Part 190 if the individual reactors remain within twice the dose design

objectives of Appendix I, and if direct radiation doses from the units

GE-SREC [81]

RADIOACTIVE EFFLUENTS

BASES

TOTAL DOSE (Continued)

(including outside storage tanks, etc.) are kept small. The Special Report

will describe a course of action that should result in the limitation of the

annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits.

For the purposes of the Special Report, it may be assumed that the dose

commitment to the MEMBER of the PUBLIC from other uranium fuel cycle sources is

negligible, with the exception that dose contributions from other nuclear fuel

cycle facilities at the same site or within a radius of 8 km must be

considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the

requirements of 40 CFR Part 190, the Special Report with a request for a

variance (provided the release conditions resulting in violation of 40 CFR Part

190 have not already been corrected), in accordance with the provisions of 40

CFR 190.11 and 10 CFR 20.405c, is considered to be a timely request and

fulfills the requirements of 40 CFR Part 190 until NRC staff action is completed.

The variance only relates to the limits of 40 CFR Part 190, and does

not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in Controls 3.11.1.l and 3.11.2.1. An individual is not

considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged

in carrying out any operation that is part of the nuclear fuel cycle.

GE-SREC [82]

3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING

BASES

3/4.12.1 MONITORING PROGRAM

The Radiological Environmental Monitoring Program required by tRis

control provides representative measurements of radiation and of radioactive

materials in those exposure pathways and for those radionuclides that lead to

the highest potential radiation exposure of MEMBERS OF THE PUBLIC resulting

from the plant operation. This monitoring program implements Section IV.B.2

of Appendix I to 10 CFR Part 50 and thereby supplements the Radiological

Effluent Monitoring Program by verifying that the measurable concentrations of

radioactive materials and levels of radiation are not higher than expected on

the basis of the effluent measurements and the modeling of the environmental

exposure pathways. Guidance for this monitoring program is provided by the

Radiological Assessment Branch Technical Position on Environmental Monitoring,

Revision 1, November 1979. The initially specified monitoring program will be

effective for at least the first 3 years of commercial operation. Following

this period. program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are

tabulated in terms of the lower limits of detection (LLDs). The LLDs required

by Table 4.12-1 are considered optimum for routine environmental measurements

in industrial laboratories. It should be recognized that the LLD is defined

as an! priori (before the fact) limit representing the capability of a measurement

system and not as an! posteriori (after the fact) limit for a particular

measurement.

Detailed discussion of the LLD, and other detection limits, can be found

in Currie, L. A., "Lower Limit of Detection: Definition and Elaboration of a

Proposed Position for Radiological Effluent and Environmental Measurements,"

NUREG/CR-4007 (September 1984), and in the HASL Procedures Manual, HASL-300.

3/4.12.2 LAND USE CENSUS

This control is provided to ensure that changes in the use of areas at and

beyond the SITE BOUNDARY are identified and that modifications to the

Radiological Environmental Monitoring Program given in the ODCM are made if

required by the results of this census. The best information from the

door-to-door survey, from aerial survey or from consulting with local agricultural

authorities shall be used. This census satisfies the requirements

of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to

gardens of greater than 50 m2 provides assurance that significant exposure

pathways via leafy vegetables will be identified and monitored since a garden

of this size is the minimum required to produce the quantity (26 kg/year) of

leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child.

To determine this minimum garden size, the following assumptions were made:

(1) 20% of the garden was used for growing broad leaf vegetation (i.e., similar

to lettuce and cabbage), and (2) a vegetation yield of 2 kg/m2 •

GE-SREC [83]

RADIOLOGICAL ENVIRONMENTAL MONITORING

BASES

3/4.12.3 INTERLABORATORY COMPARISON PROGRAM

The requirement for participation in an approved Interlaboratory Comparison

Program is provided to ensure that independent checks on the precision and

accuracy of the measurements of radioactive materials in environmental sample

matrices are performed as part of the quality assurance program for environmental

monitoring in order to demonstrate that the results are valid for the purposes

of Section IV.B.2 of Appendix I to 10 CFR Part 50.

GE-SREC [84]

APPENDIX A

Rad;olog;cal Assessment Branch Technical Position,

Revision 1, November 1979

[85]

Branch Technical Position

Background

Revision l

November 1979

Regulatory Guide 4.8 1 Environmental Technical Specifications for Nuclear Power

Plants, issued for comment fn December 1975, is being revised based on CDftlllents

received. The Radiological Assessment Branch issued a Branch Position on the

radiological portion of the environmental monitoring program in March, 1978.

The position was formulated by an NRC working group which considered comments

received after the issuance of the Regulatory Guide 4.8. This is Revision 1

of that Branch Position paper. The changes ar1 marked by a vertical line in

the right margin. The most significant change is the increase in direct

radiation measurement stations.

10 CFR Parts 20 and 50 requir1 that radiological environmental monitoring

programs be established to provide data on measurabl1 levels of radiation and

radioactive materials in the site environs. In addition, Appendix I to 10 CFR Part 50 requires that the relationship between quantities of radioactive

material released in effluents during normal operation, including anticipated

operational occurrences, and resultant radiation doses to individuals from

principals pathways of exposure be evaluated. These programs should be conducted

to verify the effectiveness of in-plant measures used for controlling

the release of radioactive materials. Surveillance should be established to

identify changes in the use of unrestricted areas (1.g., for agricultrual

purposes) to provide a basis for modifications in th• monitoring programs for

evaluating doses to individuals from principal pathways of exposure. NRC

Regulatory Guide 4.1, Rev. l, uPrograms for Monitoring Radioactivity in the

·environs of Nuclear Power Plants," provides an acceptable basis for the design

of programs to monitor levels of radiation and radioactivity in the station

environs.

This position sets forth an example of an acceptable minimum radiological

monitoring program. Local site characteristics •ust be examined to determine

if pathways not covered by this guide may significantly contribute to an

individual's dose and should be included in the sampling program.

[86]

Program Reouirements

2

AN ACCEPTABLE RADIOLOGICAL

ENVIRONMENTAL MONITORING PROGRAM

Environmental samples shall be collected and analyzed according to Table 1 at

locations shown in Figure l. 1 Analytical techniques used shall be such that

the detection capabilities in Table 2 are achieved.

The results of the radiological environmental monitoring are intended to

supr·~ment the results of the radiological effluent •onitoring by verifying

that-:he measurable concentrations of radioactive materials and levels of

radiation are not higher than expected on the basis of the effluent measurements

and modeling of the environmental exposure pathways. Thus, the specified

environmental monitoring program provides measurements of radiation and of radioactive

materials in those exposure pathways and for those radionuclides which

lead to the highest potential radiation exposures of individuals resulting from

the station operation. The initial radiological environmental monitoring program

should be conducted for the first three years of con111ercial operation (or other

period corresponding to a maximum burnup in the initial core cycle). Following

this period, program changes may be proposed based on operational experience.

The specified detection capabilities are state-of-the-art for routine environmental

measurements in industrial laboratories.

Deviations are permitted from the required sampling schedule if specimens are

unobtainable due to hazardous conditions, seasonal unavailability, malfunction

of automatic sampling equipment and other legitimate reasons. If specimens

are unobtainable due to sampling equipment malfunction, every effort shall be

made to complete corrective action prior to the end of the next sampling

period. All deviations from the sampling schedule shall be documented in the

annual report.

The laboratories of the licensee and licensee's contractors which perform

analyses shall participate in the Environmental Protection Agency's (EPA's)

Environmental Radioactivity Laboratory Intercomparisons Studies (Crosscheck)

Program or equivalent program. This participation shall include 111 of the

determinations (sample medium-radionuclide combination) that are offered by

EPA and that also are included in the monitoring program. The results of

analysis of these crosscheck samples shall be included in the annual report.

The participants in the EPA crosscheck program may provide their EPA program

code so that the NRC can review the EPA's participant data directly in lieu of

submission in the annual report.

It may be necessary to require special studies on a case-by-case and

site specific basis to establish the·relationship between quantities of

radioactive material released in effluents, the concentrations in

environmental media, and the resultant doses for important pathways.

[87]

3

If the results of a determination in the EPA crosscheck progr .. (or equivalent

program) art outside the specified control limits, the laboratory shall inv~stigate

the cause of the problem and take steps to correct it. The results cf

this investigation and corrective action shall be included fn the annual

report.

The requirement for the participation in the EPA crosscheck program, or simila~

program, is based on the need for independent checks on the precision and

accuracy of the measurements of radioactive material f n environmental sample

matrices as part of the quality assurance program for environmental monitoring

in or-der to demonstrate that the results are l"easoQably valid. A census shall be conducted annually during the growing season to determine

the location of the nearest milk animal and nearest garden greater than

SO square meters (SOO sq. ft.) prodwcfng broad leaf vegetation in each of the

16 meteorological sectors within a dist.Ince of 8 km (S •iles).I For elevated

releases as defined in Regulatory Guide 1.111, Rev. 1., the census shall also

~dentify the locations of all mflk animals, and gardens greater than 50 square

meters producing broad 11a'T"V1g1tation out to a distance of 5 km. (3 milts)

for each radial sector.

If ft is learned fl'"Oll thf s census that the milk animals or gardens are present

at a location which yields a calculated thyroid dose greater than those previously

sampled, or if the census results f n changes f n the location used f n the

radioactive effluent technical specfffcatfons for dose calculations, a written

report shall be submitted to the Director of Operating Reactors, NRR (with a

copy to the Director of the NRC Regional Office) within 30 days identifying

the new location (distance and direction). Milk animal or garden locations

·resulting in higher calculated doses shall be added to the surveillance program

as soon as practicable.

The sampling location (excluding the control sample location) having the

lowest calculated dose 111y then be dropped from the surveillance program at

the end of the grazing or growing season during which the census was conducted.

Any location frOll whicn mf lk can no longer be obtained may be dropped

from the surveillance program after notifying the NRC in writing that they are

no longer obtainable at that lotition. The results of the land-use census

shall be reported in the annual :-eport.

ihe census of milk animals and ~ardens producing broad leaf vegetation is

based on the requirement fn Appendix I of 10 CFR Part 50 to "Identify changes

fn the use of unrestricted area' (e.g., for agricultural purposes) to permit

aodificatfons in monitoring prog•·ams for evaluating doses to individuals from

principal pathways of 1xposure.h The consumption of •ilk from ani .. ls grazing

on contaminated pasture and of l~~fy vegetation contaminated by airborne

Broad leaf vegetation sampling ~•Y be performed at the site boundary in a

sector with the highest D/Q in ~itU of the garden census.

[88]

4

radioiodine is a major potential source of exposure. Samples from milk_animals

are considered a better indicator of radioiodine in the environment than

vegetation. If the census reveals milk animals are not present or are

unavailable for sampling, then vegetation must be sampled.

The SO square meter garden, considering 20% used for growing broad leaf vegetation

(i.e., similar to lettuce and cabbage), and a vegetation yield of 2 kg/m2 ,

will produce the 26 kg/yr assumed in Regulatory Guide 1.109, Rev 1., for child

consumption of leafy vegetation. The option to consider the garden to be

broad leaf vegetation at the site boundary in 1 sector with the highest D/Q

should be conservative and that location may be used to calculate doses due to

radioactive effluent releases in place of the actual locations which would be

determined by the census. This option does not apply to plants with elevated

releases as defined in Regulatory Guide 1.111, Rev. l.

The increase in the number of direct radiation stations is to better characterize

the individual exposure (mrem) and population exposure (man-rem) in accordance

with Criterion 64 - Monitoring radioactivity releases, of 10 CFR Part 50,

Appendix A. The NRC will place a similar amount of stations in the area

between the two rings designated in Table 1.

NOTE ~

Guidance on the subjects contained on pages 4 through 16 of the Radiological

Assessment Branch Technical Position (RAB-BTP) has been modified and upgraded

based on operating £xperience since Revision 1 was published in 1979. The

current staff guidance for the following items has been incorporated in the

Section 3/4-12 and Secti~n 6 Controls of NUREG-1301 and 1302.

0

•

0

Reporting Requirement

Table 1: Operational Radiological Environmental Monitoring Report

lable 2: Detection Capabilities for Environmental Sample Analysis

Table 4: Reporting Levels for Radioactivity Concentrations in Environmental

Samples

7he following items remain unchanged:

•

0

Footnote to lable 1 on page 10

Table 3 of page 14

Figure l of page 16

[89]

Pages s. 6, 7, s. 9, 11. 12, 13, 15

The above pages have been superceded by text and tables

in NUREG-1301 and 1302.

[90]

lAOLE 1 (Conltnued)

Note: In addition to the above guidance for operational 110niloring. the following ..atertal ts supplied for guidance

on preoperattonal pt·ogra•s.

Preoperalional Envlro11111enlal Surveillance Progra•

A Preoper·attonal Envlron11enlal Surveillance Progra• should be instituted two years prior to the institution of station

plant operation.

The purposes of thf s progra• are:

1. To .. asure background levels and their variations along the anticipated critical pathways in the area

surrounding the station.

2. To train personnel

3. To evaluate procedures, equi.,.ent and techniques

The elements (sa11Pllng .. dla and type of analysts) of both preoperational and operational progra•s should be essentially

the sa.e. The duration of the preoperatlonal progra•. for specific .. dia, presented in the following table

~ should be followed:

_.,

'--' Dur.lion of Preoperaltonal Sa1111>1tng Progra• for Specific Media

6 110nths

• airborne Iodine

• Iodine In •Ilk (while

anl•als are In pasture)

1 year

. airborne particulates

. •ilk (re•alning analyses)

• surf ace waler

• groundwater

• drinking water

2 years

• direct radiation

• fish and invertebrates

• food products

. sediment fro• shoreline

.... 0

.T..,A. _B_L_E _ l_

ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM ANNUAL SUtttARY

Na11e of Faclltty Docket No.

Location of Facf1fty Reporting P-er_,i_o. d... -' -

- (County, Slate) -----

Medlu• or

Pathway Sa111pled

{Unit of

Measure11enl)

Air Parttculates

(pCf /•3)

,......,

U)

"' L...J

Fish pCf/kg

(wet weight)

.

Type- and-- ---lowe_r_ Lt11ft Alflndtcalor--Tocallon with-Highest - --Control locat~ons

Total NUllber of a LocatlonB Annual Mean b Mean (f)

of Analyses Detectton Mean (f) Name Mean (f) Range

Perforwed (LLD) Range Dtstance & Range

Dtrectton

Gross p 416 0.01 0.08(200/312) Middletown 0.10 (5/52) 0.08 (8/104)

(0.05-2.0) 5 11i les 340° (0.08-2.0) (0. 05-1. 40)

y·Spec. 32

137cs 0.01 0.05 (4/24) S11fthvtlle 0.08 (2/4) <LLD

(0.03-0. 13) 2.5 •fles 160° (0.03-2.0)

1311 0.07 0. 12 (2/24) Podunk 0.20 (2/4) 0.02 (2/4)

(0.09-0. 18) 4.0 11tles 270° (0.10-0.31)

y-Spec. 8

137Cs 130 <LLD - <LLD 90 (1/4)

134cs 130 <LLD - <LLD <LLD

60co 130 180 (3/4) River Mt le 35 See Col111111 4 <LLD

(150-225)

•see Table 2, note b.

NU.her of ·

Nonrouttne

Reported

Measurements

1

4

1

0

b Mean and range based upon detectable 11easure11ents only. Fraction of detectable 11easure11ents at specified locations

ts indicated In parentheses. ( f)

Hole: The example data are provided for f llustratfve purposes only.

......

Figure l

{This figure shall be of a suitable scale to show the distance and direction

of each monitoring station. A key shall be provided to indicate what is

sampled at each location.)

[93]

..

APPENDIX B

"Appendix B - General Contents of the Offsite Dose Calculat;on

Manual (ODCM) (Revision 1, February 1979)" to the paper authored by

C. A. Willis and F. J. Congel, "Status of NRC Radiological Effluent Technical

Specification Activities" presented at the Atomic Industrial Forum Conference

on NEPA and Nuclear Reg.ulation, October 4-7, 1981, Washington, D.C.

[94]

APPENDIX 8

GENERAL CONTENTS OF THE OFFSITE DOSE CALCULATION MANUAL (ODCM*)

(Rev. 1, February 1979)

Section 1 - Set Points

Provide the equations and methodology to be used at the station or unit for

each alarm and trip set point on each effluent release point according to the

Specifications 3.3.3.8 and 3.3.3.9. The instrumentation for each alarm and

trip set point, including radiation.monitoring and sampling systems and

effluent control features, should be identified by reference to the FSAR

(or Final Hazard Summary). This information should be consistent with the

recommendations of Section I of Standard Review Plan 11.5, NUREG-75/087,

(Revision 1). If the alarm and/or trip set point value is variable~ provide

the equation to determine the set point value to be used, based on actual

release conditions, that will assure that the Specification is met at each

release point; and provide the value to be used when releases are not in

progress. If dilution or dispersion is used, state the onsite equipment

and measurement method used during release, the site related parameters and

the set points used to assure that the Specification is met at each release

point. The fixed and variable set points should consider the radioactive

effluent to have a radionuclide distribution represented by normal and

anticipated operational occurrences.

Section 2 - Liquid Effluent Concentration

Provide the equations and methodology to be used at the station or unit

for each liquid release point according to the Specification 3.11.1.1. For

systems ~1th continuous or batch releases, and for systems designed to

monitor and control both continuous and batch releases, provide the assump-

. tions and parameters to be used to compare the output of the monitor with

the 1 i'qui d concentration sped fi ed. State the 1 imitations for comb1 ned

discharges to the same release point. In addition, describe the method and

assumptions for obtaining representative samples fran ~ach batch and use of

previous post-release analyses or canposite sample analyses to meet the

Specification. ·

S~ction 3 - Gaseous Effluent Dose Rate

Provide the equations and methodology to be used at the station or unit for

each gaseous release point according to Specification 3.11.2.1. Consider

the various pathways, release point elevations, site related parameters and

radionuclide contribution to.the dose impact limitation. Provide the

the fonnat for the ODCM fs left up to the licensee and may be simplified by

tables and grid printout. Each page should be numbered and indicate the

facility approval and effective date. ·

[95]

- 2 -

dose factors to be used for the identified radionuclides released. Provide

the annual average dispersion values (X/Q and D/Q), the site specific parameters

and release point elevations.

Section 4 - Liquid Effluent Dose

Provide the equations and methodology to be used at the station or unit for

each liquid release point according to the dose objectives given in Specification

3.11.1.2. The section should describe how the dose contributions

are to be calculated for the various pathways and release points, the equations

and assumptions to be used, the site specific parameters to be measured

and used, the receptor location by direction and distance, and the method of

estimating and updating cumulative doses due to liquid releases. The dose

factors, pathway transfer factors, pathway usage factors, and dilution factors

for the points of pathway origin, etc., should be given, as well as

receptor age group, water and food consumption rate and other factors

assumed or measured. Provide the met~od of determining the dilution factor

at the discharge during any liquid effluent release and any site specific

parameters used in these determinations.

Section 5 - Gaseous Effluent Dose

Provide the equations and methodology to be used at the station or unit for

each gaseous release point according to the dose objectives given fn

Specifications 3.11.2.2 and 3.11.2.3. The section should describe how the

dose contributions are to be calculated for the various pathways and release

points, the equations and assumptions to be used, the site specific parameters

to be measured and used, the receptor location by direction and distance, and

the method to be used for estimating and updating cumulative doses due to

gaseous releases. The location, direction and distance to the neare~t residence,

cow, goat, meat animal, garden, etc., should be given, as well as

receptor age group, crop yield, grazing time and other factors.assumed or

measured. Provide the method of determining dispersion values (X/Q and D/Q)

for releases and any site specific parameters and release point elevations

used in these determinations.

Section 6 - Projected Doses

For liquid and gaseous radwaste treatment systems, prCHide the method of

p~ojecting doses due to effluent releases for the normal and alternate

pathways of treatment according to the specifications, describing the components

and subsystems to be used.

[96]

- 3 -

Section 7 - Operability of Equipment

Provide a flow diagram{s) defining the treatment paths and the components of

the radioactive liquid, gaseous and solid waste management systems that are

to be maintained and used, pursuant to 10 CFR 50.36a, to meet Technical Specifications 3.11.1.3, 3.11.2.4 and 3.11.3.1. Subcomponents of packaged

equipment can be identified by a list. For operating reactors whose construction

permit applications were filed prior to January 2, 1971, the flow

diagram{s) shall be consistent with the infonnation prOYided in confonnance

with Section V.B.l of Appendix I to 10 CFR Part 50. For OL applications

whose construction permits were filed after January 2, 1971, the flow

diagram{s) shall be consistent with the infonnation provided in Chapter 11

of the Final Safety Analysis Report (FSAR) or amendments thereto.

Section 8 - Sample locations

Provide a map of the Radiological Environmental Monitoring Sample Locations

indicating the numbered sampling locations given in Table 3.12-1. Further

clarification on these numbered sampling locations can be provided by a list,

indicating the direction and distance from the center of the buil.ding complex

of the unit or station, and may include a discriptive name for identification

purposes.

[97].

APPENDIX C

GENERIC LETlER 89-01

IMPLEMENTATION OF PROGRAMMATIC CONTROLS FOR RADIOLOGICAL EFFLUENT

TECHNICAL SPECIFICATIONS IN THE ADMINISTRATIVE CONTROLS SECTION OF

THE TECHNICAL SPECIFICATIONS AND THE RELOCATION OF PROCEDURAL DETAILS

OF RETS TO THE OFFSITE DOSE CALCULATION MANUAL OR TO THE PROCESS

CONTROL PROGRAM

(98]

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

January 31, 1989

lO ALL PO\IER REACTOR LICENSEES AHD l.PPLICANTS

SUBJECT: JMPLEME~T1'TION OF PROGRAMMATIC CONTROLS FOR RADIOLOGICAL EFFLUENT

TECHNICAL SPECIFICATIOriS JN TH£ ADMINISTRATIVE CONTROLS SECTION OF

THE TECHNICAL SPECIFICATIONS AND THE RELOCATION OF PROCEDURAL DETAILS

OF ~ETS TO THE OFFSITE DOSE CALCULATION MANUAL OR TO THE PROCESS

CO~TROL PROGRAH (GENERIC LETTER 89-01)

The HRC staff has examined the contents of the Radiological Effluent Technical

Specif1cot;ons (RETS) in relation to the Conniss1on's Interim Polfcy Statement

on Technical Specification lmprovernents. The staff has detennfned that progran1:

1atic controls can be implemented in the Administrative Controls section of

the Technical Specifications (TS) to satisfy existing regulatory reauirements

for RETS. At the same time, the procedural details of the current TS on radioactive

effluents and radiological environmental monitoring can be relocated to

the Offs1te Dose Calculation Manual (ODCM). like~ise, the procedural details

of the current TS on solid radioactive wastes can be relocated to the Process

Control Program (PCP). lhese actions sin1plif.Y the RETS, meet the regulator.Y

reauirements for radioactive effluents and radiological environmental monitoring,

and are provided as a line-item improven1ent of the TS, consistent with the

soals of the Policv Statement. ·

Wew progrannatic controls for radioactive effluents and radiological environmenta

1 11onitoring are incorporated 1n the TS to conform to the regulator.v

reauirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.361, and Appendil I

to 10 CFR Part 50. £listing progrannatic reauirements for the PCP are being

retained in the TS. The procedural details included 1n licensees' present TS

on radioactive effluents. solid radioactive wastes, env1ronmenta1 110nitoring,

and associated reporting reau1ranents will be relocated to the ODCM or PCP as

appropriate. licensees will handle future changes to these procedural details

in the ODCM and the PCP under the administrative controls for changes to the

ODCM or PCP. Finally, the definitions of the ODC~ and PCP are updated to

reflect these changes.

Enclosure 1 provides guidance for the preparation of a license amendment reauest

to implement these alternatives for RETS. Enclosure 2 provides a listing

of existing RETS and a description of how each ts addressed. Enclosure 3

provides model TS for progr111111atic controls for RElS and its associated reporting

reauirements. Finally, Enclosure 4 provides 110del specifications for

retaining existir.g reauirements for eiplosive gas monitoring tnstrumentation

reauirements that apply on a plant-specific basis. Licensees are encouraged to

propose changes to TS that are consistent with the guidance provtded tn the

enclosures. Conforming ar.endment reauests wf 11 be expeditiously revtewed by

[99]

Generic Letter 89-01 2 January 31, 1989

the NRC Project Manager for the fac;11ty. Proposed amendments that deviate

from th;s guidance will require a longer, more deta;led review. Please contact

the appropriate Project Manager if you have questions on this matter.

Enclosures:

l through 4 as stated

Sincerely,

Mark Hawes. fA..

Acting Associate D ctor for Projects

Office of Nuclear Reactor Regulat;on

[100]

Generic Letter 89-ol ENCLOSURE 1

GUIDANCE FOR THE IMPLEMENTATION OF PROGRAMMATIC CONTROLS FOR RETS

IN THE ADMINISTRATIVE CONTROLS SECTION OF TECHNICAL SPECIFICATIONS

AND THE RELOCATION OF PROCEDURAL DETAILS OF CURRENT RETS TO THE

OFFSITE DOSE CALCULATION MANUAL OR PROCESS CONTROL PROGRAM

INTRODUCTION

This enclosure provides guidance for the preparation of a license amendment

request to implement programmatic controls in Technical Specifications (TS)

for radioactive effluents and for radiological environmental monitoring conforming

to the applicable regulatory requirements. This will allow the relocation

of existing procedural details of the current Radiological Effluent

Technical Specifications (RETS) to the Offsite Dose Calculation Manual (ODCM).

Procedural details for solid radioactive wastes will be relocated to the

Process Control Program (PCP). A proposed amendment will (1) incorporate programmatic

controls in the Administrative Controls section of the TS that satisfy

the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR S0.36a. and

Appendix I to 10 CFR Part 50, (2) relocate the existing procedural details in

current specifications involving radioactive effluent monitoring instrumentation,

the control of liquid and gaseous effluents, equipment requirements for

liquid and gaseous effluents, radiological environmental monitoring, and radiological

reporting details from the TS to the ODCM, (3) relocate the definition

of solidification and existing procedural details in the current specification

on solid radioactive wastes to the PCP, (4) simplify the associated reporting

requirements, (5) simplify the administrative controls for changes to the ODCM

and PCP, (6) add record retention requirements for changes to the ODCM and PCP,

and (7) update the definitions of the ODCM and PCP consistent with these

changes.

The NRC staff's intent in recommending these changes to the TS and the relocation

of procedural details of the current RETS to the ODCM and PCP is to fulfill

the goal of the Commission Policy Statement for Technical Specification

Improvements. It is not the staff's intent to reduce the level of radiological

effluent control. Rather, this amendment will provide programmatic controls

for RETS consistent with regulatory requirements and allow relocation of the

procedural details of current RETS to the ODCM or PCP. Therefore, future

changes to these procedural details will be controlled by the controls for

changes to the ODCM or PCP included in the Administrative Controls section of

the TS. These procedural details are not required to be included in TS by

10 CFR 50.36a.

DISCUSSION

Enclosure 2 to Generic Letter 89- provides a summary listing of specifications

that are included under the heading of RETS in the Standard Technical

Specifications (STS) and their disposition. Most of these specifications will

be addressed by programmatic controls in the Administrative Controls section of

the TS. Some specifications under the heading of RETS are not covered by the

new programmatic controls and will be retained as requirements in the existing

plant TS. Examples include requirements for explosive gas monitoring instrumentation,

limitations on the quantity of radioactivity in liquid or gaseous

holdup or storage tanks or in the condenser exhaust for BWRs, or limitations on

explosive gas mixtures in offgas treatment systems and storage tanks.

[ 1 01]

Generic Letter 89- 01 - 2 - Enclosure 1

Licensees with nonstandard TS should follow the guidance provided in Enclo

·sure 2 for the disposition of similar requirements in the format of their TS.

Because solid radioactive wastes are addressed under existing programmatic

controls for the Process Control Program, which is a separate program from the

new programmatic controls for liquid and gaseous radioactive effluentsJ the

requirements for solid radioactive wastes and associated solid waste reporting

requirements in current TS are included as procedural details that will be

relocated to the PCP as part of this line-item improvement of TS. Also, the

staff has concluded that records of licensee reviews performed for changes made

to the ODCM and PCP should be documented and retained for the duration of the

unit operating license. This approach is in lieu of the current requirements

that the reasons for changes to the ODCM and PCP be addressed in the Semiannual

Effluent Release Report.

The following items are to be included in a license amendment request to imple- .

ment these changes. First, the model specifications in Enclosure 3 to Generic

Letter 89- should be incorporated into the TS to satisfy the requirements of

10 CFR 20.106, 40 CFR Part 190, 10 CFR S0.36a, and Appendix I to 10 CFR Part 50.

The definitions of the ODCM and PCP should be updated to reflect these changes.

The programmatic and reporting requirements are general in nature and do not

contain plant-specific details. Therefore, these changes to the Administrative

Controls section of the TS are to replace corresponding requirements in plant

TS that address these items. They should be proposed for incorporation into

the plant's TS without change in substance to replace existing requirements.

If necessary, only changes in format should be proposed. If the current TS

include requirements for explosive gas monitoring instrumentation as part of

the gaseous effluent monitoring instrumentation requirements, these requirements

should be retained. Enclosure 4 to Generic Letter 89- provides model

specifications for retaining such requirements.

Second, the procedural details covered in the licensee's current RETS, consisting

of the limiting conditions for operation, their applicability, remedial

actions, surveillance requirements, and the Bases section of the TS for these

requirements, are to be relocated to the ODCM or PCP as appropriate and in a

manner that ensures that these details are incorporated in plant operating procedures.

The NRC staff does not intend to repeat technical reviews of the relocated

procedural details because their consistency with the applicable regulatory

requirements is a matter of record from past NRC reviews of RETS. If

licensees make other than editorial changes in the procedural details being

transferred to the ODCM, each change should be identified by markings in the

margin and the requirements of new Specification 6.14a.(1) and (2) followed.

Finally, licensees should confirm in the amendment request that changes for

relocating the procedural details of current RETS to either the ODCM or PCP

have been prepared in accordance with the proposed changes to the Administrative

Controls section of the TS so that they may be implemented i1111ediately

upon issuance of the proposed amendment. A complete and legible copy of the

revised ODCM should be forwarded with the amendment request for NRC use as a

reference. The NRC staff will not concur in or approve the revised ODCM.

[102]

Generic Letter 89-01 - 3 - Enclosure l

licensees should refer to •Generic Letter 89· • fn the Subject line of license

amendment reauests implementing the guidance of this Generic Letter. This w;11

fac;litate the staff's tracking of licensees' responses to this Generic Letter.

SUMMARY

lhe license amendment reauest for the line-item improvements of the TS relative

to the RETS will entail (l) the incorporation of prograzrmatic controls for

radioactive effluents and radiological environmental monitoring in the Administrative

Controls section of the TS, (2) incorporatation of the procedural

details of the current RETS in the ODCM or PCP as appropriate, and (3) confirmation

that the guidance of this Generic Letter has been followed.

[103]

blSPOSITION OF SPECIFICATIONS AND ADMINISTRATIVE CONTROLS

INCLUDED UNDER THE HEADING OF RETS IN TRE STANDARb TECHNICAL SPEtlFIC~TJONS G"t

nt

I

SPECIFICATION TITLE nlSPOSITION OF EXISTING SPECIFlCATlON .n.,t - ....

n

1.17 OFFSITE DOSE CALCULATION HANUAL Definition is updated to reflect the change 1n scope ,...

nt of the ODCM. r+

r+

nt

1.22 PROCESS CONTROL PROGRAM Definitfon ts updated to reflect the change in scope

.,

(IO of the PCP. '° 0 '

1.32 SOLIDIFICATION Def initfon ts relocated to the PCP. -

3/4.3.3.10 RADIOACTIVE LIQUID EFFLUENT Programnatic controls are included fn 6.8.4 g. Item t).

MONITORING INSTRUMENTATJON Existing specification procedural details are relocated

to the ODCM.

3/4.3.3.11 RADIOACTIVE GASEOUS EFFLUENT Progrannatic controls are included in 6.8.4 g. Item t).

MONITORING 1NSTRUJ.1ENTATION Existing specification procedural details are relocated

to the ODCH. Existing reouf rements for explosive gas

,....., monitoring 1nstrumentat1on should be retained. Model __. specff icatfons for these reau1rements are provided in

0 Enclosure 4.

'"-"-"

3/4.11.1.1 LIQUID EFFLUENTS: CONCENTRATION Progrannatfc controls are included in 6.8.4 g. Items 2)

and 3). Exfstfng specification procedural details are

relocated to the ODCM.

3/4.11.1.2 LIQUID EFFLUENTS: DOSE Programnatfc controls are included fn 6.8.4 g. Items 4)

and 5). Existing spec1ffcat1on procedural details are

relocated to the OOCM.

3/4.11.1.3 LIQUID EFFLUEHTS: LIQUID Progrannatfc controls are included in 6.8.4 g. Item 6).

RADWASTE TREATMENT SYSTEM Existfnq speciffcatfon procedural details are relocated

to the ODCM.

"'

3/4.11.t.4 LIQUID HOLDUP TANKS Existing specification reaufrements to be retained. ::I

-n 0

.c", '

nt

"'

DISPOSITION OF SPECIFICATIONS ANO ADMINISTRATIVE CONTROLS

INCLUDED UNDER THEHEADJffG_OF RETS IN THE STANDARD TECHNICAL SPECIFICATIONS_{Cont.) G')

19

,::.:9,

SPECIFICATION TITLE DISPOSITION OF EXISTING SPECIFICATION - -.., n

3/4.11.2.1 GASEOUS EFFLUENTS: DOSE RATE Progrannatfc controls are fncluded fn 6.8.4 g. Items 3) ,...

ft)

and 7). Exfst1ng specification procedural details are ..........

relocated to the ODCM. .Cl,»

3/4.11.2.2 GASEOUS EFFLUENTS: DOSE-tlOBLE Progrannatfc controls are included in 6.8.4 g. Items 51 °'°' GASES and 8). Existing specification procedural details are -0' relocated to the ODCM.

3/4.11.2.3 GASEOUS EFFLUENTS: DOSE-- IODINE- Progrannatic controls are included 1n 6.8.4 g. Items 5)

131, IODINE-133, TRITIUM, AND and 9). Existing specification procedural details are

RADIOACTIVE MATERIAL IN PARTICU- relocated to the ODCM.

LATE FORM

3/4.11.2.4 GASEOUS EFFLUENTS: GASEOUS Progrannattc controls are tncluded tn 6.8.4 g. Item 6).

RADWASTE TREATMENT or Existing spectftcation procedural details are relocated

...-..-... VENTILATION EXHAUST TREATMENT to the ODCM • N 0 SYSTEM • U1

L..J 3/4.11.2.5 EXPLOSIVE GAS MIXTURE Existing specfffcatfon reauirements should be retained.

3/4.11.2.6 GAS STORAGE TANKS Exf stfng specf ficatton reauirements should be retained.

3/4.11.2.7 MAIN CONDENSER (DWP) Existing specfffcatfon reauirements should be retained.

..

3/4.U.2.8 PURGING AND.VENTING (BWR Mark II Progrannattc controls are included fn 6.8.4 g. lte• 10).

contain1nents) Existing specification procedural details are relocated

to the ODCM.

3/4.11.3 SOLID RADIOACTIVE WASTES Extsttng specification procedural details are relocated

to the PCP.

"~' 3/4.11.4 RADIOACTIVE EFFLUENTS: TOTAL Progrannatic controls are included in 6.8.4 g~ ltan 11). n- DOSE Existing specification procedural details are relocated . 0

to the ODCM. c."., '

m

"'

~ -------- -----~·----- -------- --------

blSPOSITION OF SPECIFICATIONS AND ADMINISTRATIVE CONTROLS

INCLUDED UNDER THE H[ADlNG_OF_RETS_JN_THE ~TANDARD TEtHNltAL seEtlflCATIONS_{Cont.) °t'D'

s

f1> SPECIFICATION TITLE DISPOSITION OF E~ISTING_SPECIFICATION ...,. n

3/4.12.1 RADIOLOGICAL ENVIRONMENTAL Progrannattc controls are tncluded tn 6.8.4 h. Item t). r- MONITORING: MONITORING PROGRAM Extsttng spectftcatton procedural details are relocated "r+'

r+ to the OOCM. .",'

m

3/4.12.2 RADIOLOGICAL ENVIRONMENTAL Progrannattc controls are tncluded tn 6.8.4 h. Item 2). . '° I MONITORING: LAND USE CENSUS Existtng specification procedural details are relocated 0_ ,,

to the ODCM.

3/4.12.3 RADIOLOGICAL ENVIRONMENTAL Progrannattc controls are included fn 6.8.4 h. Item 3).

MONITORING: INTERLABORATORY Ex1st1ng specification procedural details are relocated

COMPARISON PROGRAM to the ODCM.

5.1.3 DESIGN FEATURES: SITE - MAP Existing spectftcatfon reauf rements should be retained.

DEFINING UNRESTRICTED AREAS ANO

SITE BOUNDARY FOR RADIOACTIVE • ....-..-.. GASEOUS AND LIQUID EFFLUENTS w

0

O' 6.9.1.3 REPORTING REQUIREMENTS: ANNUAL Specification sfl!plffied and existing reportfng details L......J RADIOLOGICAL ENVIRONMENTAL are relocated to the ODCM.

OPERATUIG REPORT

6.9.1.4 REPORTING REQUIREMENTS: SEMI- Specffication Si11Plffted and exfsting reporting details

ANNUAL RADIOACTIVE EFFLUENT are relocated to the ODCM or PCP as appropriate.

RELEASE REPORT

6.13 PROCESS CONTROL PROGRAM Specffication reaufrements are si1111>11f1ed.

6.14 OFFSITE OOSE CALCULATION MANUAL Specfftcatton reaufrewnents are sf1111>lifted.

6.15 MAJOR CHANGES TO LIQUID, GASEOUS, Existing procedural details are relocated to the ODCM or

AND SOLID RADWASTE TREATMENT PCP as appropriate. ":3' SYSTEMS n_, ,

0

..c"., '

N

Generic Letter 89~1 Enclosure 3

TECHNICAL SPECIFICATIONS TO BE REVISED

1.17 DEFINITIONS: OFFSITE DOSE CALCULATION MANUAL

1.22 DEFINITIONS: PROCESS CONTROL PROGRAM

6.8.4 g. PROCEDURES AND PROGRAMS: RADIOACTIVE EFFLUENT CONTROLS

6.8.4 h. PROCEDURES AND PROGRAMS: RADIOLOGICAL ENVIRONMENTAL MONITORING

6.9.1.3 REPORTING REQUIREMENTS: ANNUAL RADIOLOGICAL ENVIRONMENTAL

OPERATING REPORT

6.9.1.4 REPORTING REQUIREMENTS: SEMIANNUAL RADIOACTIVE EFFLUENT

RELEASE REPORT

6.10 RECORD RETENTION

6.13 PROCESS CONTROL PROGRAM {PCP)

6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)

MODEL TECHNICAL SPECIFICATION REVISIONS

(To supplement or replace existing specifications)

1.0 DEFINITIONS

OFFSITE DOSE CALCULATION MANUAL

1.17 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology

and parameters used in the calculation of offsite doses resulting from radioactive

gaseous and liquid effluents, in the calculation of gaseous and liquid

effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Environmental

Radiological Monitoring Program. The ODCM shall also contain (1) the

Radioactive Effluent Controls and Radiological Environmental Monitoring Programs

required by Section 6.8.4 and (2) descriptions of the information that

should be included in the Annual Radiological Environmental Operating and Semiannual

Radioactive Effluent Release Reports required by Specifications 6.9.1.3

and 6.9.1.4.

1.22 The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas,

sampling, analyses, test, and determinations to be made to ensure that processing

and packaging of solid radioactive wastes based on demonstrated processing

of actual or simulated wet solid wastes will be accomplished in such a way as

to assure compliance with 10 CFR Parts 20, 61, and 71, State regulations,

burial ground requirements, and other requirements governing the disposal of

solid radioactive waste.

[107]

Generic Letter 89- 01 - 2 - Enclosure 3

6.0 ADMINISTRATIVE CONTROLS

6.8 PROCEDURES AND PROGRAMS

6.8.4 The following programs shall be established, implemented, and maintained:

g. Radioactive Effluent Controls Program

A program shall be provided conforming with 10 CFR 50.36a for the

control of radioactive effluents and for maintaining the doses to

MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably

achievable. The program (1) shall be contained in the OOCM,

(2) shall be implemented by operating procedures, and (3) shall include

remedial actions to be taken whenever the program limits are

exceeded. The program shall include the following elements:

1) Limitations on the operability of radioactive liquid and gaseous

monitoring instrumentation including surveillance tests and setpoint

determination in accordance with the methodology in the

OOCM 1 .

2) Limitations on the concentrations of radioactive material

released in liquid effluents to UNRESTRICTED AREAS conforming to

10 CFR Part 20 1 Appendix B, Table II, Column 21

3) Monitoring, sampling, and analysis of radioactive liquid and

gaseous effluents in accordance with 10 CFR 20.106 and with the

methodology and parameters in the ODCM 1

4) Limitations on the annual and quarterly doses or dose commitment

to a MEMBER OF THE PUBLIC from radioactive materials in liquid

effluents released from each unit to UNRESTRICTED AREAS conforming

to Appendix I to 10 CFR Part 50,

5) Determination of cumulative and projected dose contributions

from radioactive effluents for the current calendar quarter and

current calendar year in accordance with the methodology and

parameters in the ODCM at least every 31 days.

6) Limitations on the operability and use of the liquid and gaseous

effluent treatment systems to ensure that the appropriate

portions of these systems are.used to reduce releases of radioactivity

when the projected doses in a 31-day period would

exceed 2 percent of the guidelines for the annual dose or dose

connitllent conforming to Appendix I to 10 CFR Part 50 1

7) Limitations on the dose rate resulting from radioactive material

released in gaseous effluents to areas beyond the SITE BOUNDARY

conforming to the doses associated with 10 CFR Part 20,

Appendix 81 Table II 1 Column 1,

[108]

Generic Letter 89~1 - 3 - Enclosure 3

ADMINISTRATIVE CONTROLS

6.8.4 g. Radioactive Effluent Controls Program (Cont.)

8)

9)

10)

Limitations on the annual and quarterly air doses resulting from

noble gases released in gaseous effluents from each unft to

areas beyond the SITE BOUNDARY conforming to Appendix I to

10 CFR Part SO,

Limitations on the annual and quarterly doses to a MEMBER OF

THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radionuclides

in particulate form with half-lives greater than 8 days

in gaseous effluents released from each unit to areas beyond the

SITE BOUNDARY conforming to Appendix I to 10 CFR Part SO,

Limitations on venting and purging of the Mark II containment

through the Standby Gas Treatment System to maintain releases

as low as reasonably achievable (BWRs w/Mark II containments),

and

11) Limitations on the annual dose or dose commitment to any MEMBER

OF THE PUBLIC due to releases of radioactivity and to radiation

from uranium fuel cycle sources conforming to 40 CFR Part 190.

h. Radiological Environmental Monitoring Program

A program shall be provided to monitor the radiation and radionuclides

in the environs of the plant. The program shall provide

(1) representative measurements of radioactivity in the highest

potential exposure pathways, and (2) verification of the accuracy of

the effluent monitoring program and modeling of environmental exposure

pathways. The program shall (1) be contained in the ODCM,

(2) conform to the guidance of Appendix I to 10 CFR Part 50, and

(3) include the following:

l) Monitoring, sampling, analysis, and reporting of radiation and

radionuclides in the environment in accordance with the methodology

and parameters in the ODCM,

2) A Land Use Census to ensure that changes in the use of areas at

and beyond the SITE BOUNDARY are identified and that modifications

to the monitoring program are made if required by the

results of this census, and

3) Participation in 1 Interlaboratory Comparison Program to ensure

that independent checks on the precision and accuracy of the

measurements of radioactive materials in environmental sample

•atrices are performed as part of the quality assurance program

for environmental monitoring.

[109]

Generic Letter 89"1)1 - 4 - Enclosure 3

ADMINISTRATIVE CONTROLS

6.9 REPORTING REQUIREMENTS

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT*

6.9.1.3 The Annual Radiological Environmental Operating Report covering the

operation of the unit during the previous calendar year shall be submitted

before May 1 of each year. The report shall include summaries, interpretations,

and analysis of trends of the results of the Radiological Environmental

Monitoring Program for the reporting period. The material provided shall be

consistent with the objectives outlined in (1) the ODCM and (2) Sections

IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part SO.

SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT**

6.9.1.4 The Semiannual Radioactive Effluent Release Report covering the operation

of the unit during the previous 6 months of operation shall be submitted

within 60 days after January 1 and July l of each year. The report shall include

a summary of the quantities of radioactive liquid and gaseous effluents

and solid waste released from the unit. The material provided shall be

(1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance

with 10 CFR S0.36a and Section IV.B.1 of Appendix I to 10 CFR Part SO.

6.10 RECORD RETENTION

6.10.3 The following records shall be retained for the duration of the unit

Operating License:

o. Records of reviews performed for changes made to the OFFSITE DOSE

CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

6.13 PROCESS CONTROL PROGRAM (PCP)

Changes to the PCP:

a. Shall be documented and records of reviews performed shall be retained

as required by Specification 6.10.30. This documentation shall

contain:

1) Sufficient information to support the change together with the

appropriate analyses or evaluations justifying the change(s) and

A single submittal may be made for a multi-unit station.

- A single submittal may be made for a multi-unit station. The submittal

should combine those sections that are common to all units at the station;

however, for units with separate radwaste systems, the submittal shall specify

the releases of radioactive material from each unit.

[ 11 0]

Generic Letter 89-01 - 5 - Enclosure 3

ADMINISTRATIVE CONTROLS

6.13 PROCESS CONTROL PROGRAM (PCP) (Cont.)

2) A determination that the change will maintain the overall conformance

of the solidified waste product to existing requirements

of Federal, State, or other applicable regulations.

b. Shall become effective after review and acceptance by the [URG] and

the approval of the Plant Manager.

6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)

Changes to the COCH:

a. Shall be documented and records of reviews performed shall be retained

as required by Specification 6.10.30. This documentation shall

contain:

1) Sufficient information to support the change together with the

appropriate analyses or evaluations justifying the change(s) and

2) A determination that the change will maintain the level of

radioactive effluent control required by 10 CFR 20.106, 40 CFR

Part 190, 10 CFR S0.36a, and Appendix I to 10 CFR Part SO and

not adversely impact the accuracy or reliability of effluent,

dose, or setpoint calculations.

b. Shall become effective after review and acceptance by the [URG] and

the approval of the Plant Manager. ·

c. Shall be submitted to the Commission in the form of a complete,

legible copy of the entire ODCM as a part of or concurrent with the

Semiannual Radioactive Effluent Release Report for the period of the

report in which any change to the ODCH was made. Each change shall

be identified by markings in the margin of the affected pages,

clearly indicating the area of the page that was changed, and shall

indicate the date (e.g .• month/year) the change was implemented.

r 1 1 1 i

G•meric Letter 89- 01

MODIFICATION OF THE SPECIFICATION FOR RADIOACTIVE GASEOUS

EFFLUENT MONITORING INSTRUMENTATION TO RETAIN REQUIREMENTS

FOR EXPLOSIVE GAS MONITORING INSTRUMENTATION

INSTRUMENTATION

EXPLOSIVE

RABi8A£;iYE GASESHS-EFFtHEN; MONITORING INSTRUMENTATION

LIMITING CONDITION FOR OPERATION

Enclosure 4

explosive

3.3.3.11 The radioactiYe gasecas-effiaent monitoring instrumentation channels

shown in Table 3.3-13 shall be OPERABLE with their Alarm/Trip Setpoints set to

ensure that the limits of Specifications-3~!!:!:!-and 3.11.2.5 are not

exceeded. ihe-Aiarmf;r;p-Setpo;nts·of-these·channeis-meet;ng·Spec;f;caticn

S:!i:2:i-shaii·be-determ;ned·and·adlasted-in-accordance-with-the·methodoica.y

and-parameters-in-the-BBEM:

APPLICABILITY: As shown in Table 3.3-13

ACTION:

explosive

a. With an radioacti•e gaseoas-effiaent monitoring instrumentation

channel Alarm/Trip Setpoint less conservative than required by the

above specification;-immediateiy-saspend-the-reiease-cf-radioacti•e

aseoas·effiaents-monitored-by-the-affected-channei;-cr declare the

channel inoperable and take the ACTION shown in Table 3.3-13.

explosive

b. With less than the minimum number of radioactiYe gaseoas-effiaent

monitoring instrumentation channels OPERABLE, take the ACTION shown

in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE

status within 30 days and, if unsuccessful expiain-in-the-next-Sem;annaai

·Rad;oaeti•e-Effiaent-Reiease-Report prepare and submit a

Special Report to the Commission pursuant to Specification 6:9:!:4

6.9.2 to explain why this 4.noperability was not corrected in a timely

manner.

c. The provisions of Specification 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS

explosive

4.3.3.11 Each radioaeti•e gaseoas-effiaent monitoring instrumentation channel

shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SBYREE

£HEEK; CHANNEL CALIBRATION and ANALOG CHANNEL OPERATIONAL TEST at the

frequencies shown in Table 4.3-9.

Sample STS 3/4 3-(n)

[ 112]

TABLE 3.3-13

i-." .' ~E~X§PJLgO~S~IViEl v5 6AS59US Mark HawesbU~Nl MONITORING INSTRUMENTATION

"-4' MINIMUM CllANNCL~

Cit INSTRUMENT OPERABLE APPLICABILITY

1. (Not used)

2A. WASTE GAS HOLDUP SYSTEM Explosive Gas

Monitoring System (for systems designed

to withstand the effects of a hydrogen

explosion)

•• Hydrogen Monttor (Automatic Control) 1 ••

b. Hydrogen or Oxygen Monitor (Process) 1 ••

w ......... 28. WASTE GAS HOLDUP SYSTEM Explostve Gas w Monitoring System (for systetns not designed

-• to withstand the effects of a hvdrogen ,......, :s explosion) _.. .+.. _.. - w a. Hydrogen Monttors (Auto111ttc Control, 2 •• L-1 redundant)

b. Hydrogen or Oxygen Monttors (Process. 2 •• dual)

-ACTI-ON

49

50, 52

50

.,,

ID = .ID,

-'• n -"r+'

.r..+..

m

'°I

0.. ..

I

N

I

,.,

J

.n.. . .0, .

.c..... .

Generic. ,le~~et, 8_9-i)l - 3.-

(Not used)

- During WASTE GAS HOLDUP SYSTEM operation.

ACTION 45 - (Not used)

ACTION 46 - (Not used)

ACTION 47 - (Not used)

ACTION 48 - (Not used)

ACTION STATEMENTS

Enclosure.4

ACTION 49 - With the number of channels OPERABLE less than required by the

Minimum Channels OPERABLE requirement, operation of this WASTE

GAS HOLDUP SYSTEM may continue provided grab samples are .

collected at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and analyzed within the

following 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ACTION 50 - With the number of channels OPERABLE one less than required by

the Minimum Channels OPERABLE requirement, operation of this

system may continue provided grab samples are taken and analyzed

at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . With both channels inoperable,

operation may continue provided grab samples are taken and

analyzed at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during degassing operations

and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during other operations.

ACTION 51 - (Not used)

ACTION 52 - With the number of channels OPERABLE one less than required by

the Minimum Channels OPERABLE requirement, suspend oxygen

supply to the recombiner.

Sample STS 3/4 3-(n+2)

r 114 i

TAME 4.3-9

~ en • ,.

--El EXPLOSIVE ,:,:.I ~AQlQAGJIV~ GAS~OUC Mark Hawes 07:54, 10 May 2016 (EDT)U~Nl MONITORING INSTRUMENTATION SURVEl~LANCE REgUIREMENTS ..,

ftt -.,. n

-4 ,..

Cit fD CHANNEL MODES FOR WHICH r+

r+ CHAtlNEL SOURG~ CHANNEL OPERAT lOtlAL SURVEILLANCE ,...,

INSTRUMENT CHECK GN~GK CALIBRATION TEST IS REQUIRED - °' '°

(Not used) I 1. 0__ ,

2A. WASTE GAS HOLDUP SYSTEM Explostve

Gas Monitoring System (for systems

designed to withstand the effects

of a hydrogen explosion)

a. Hydrogen Monttor D II.A. Q(4) M ••

w (Automatic Control)

........ w b. Hydrogen or Oxygen Monitor 0 N.A. Q(4) or Q(5) " •• • .. ,...., -I (Process) ...... ~ ...... + <.Tl 28. WASTE GAS HOLDUP SYSTEM E1plostve -w '-' Gas Monitoring Svstem (for systems

not designed to withstand the effects

of a hydrogen explosion)

a. Hydrogen Monitors

(Automatic Control, redundant)

0 N.A. Q(4) M ••

b. Hydrogen or Oxygen Monttors

(Process, dual)

0 N.A. Q(4) or Q(S) M ••

,.,

I

-n 0

c.". ,'

.fD.

G~neric Letter 89- 01

(Not used)

- 5 -

TABLE 4.3-9 (Continued)

TABLE NOTATIONS

During WASTE GAS HOLDUP SYSTEM operation.

(1) (Not used)

(2) (Not used)

(3) (Not used)

Enclosure 4

(4) The CHANNEL CALIBRATION shall include the use of standard gas samples

containing a nominal:

a. One volume percent hydogen, balance nitrogen, and

c. Four volume percent hydrogen, balance nitrogen.

(5) The CHANNEL CALIBRATION shall include the use of standard gas samples

containing a nominal:

a. One volume percent oxygen, balance nitrogen, and

b. Four volume percent oxygen, balance nitrogen.

Sample STS 3/4 3-(n+4)

[ 11 6]

NRC FORM 335

12-891

NRCM 1102,

3201. 3202

2. TITLE AND SUBTITLE

U.S. NUCLEAR REGULATORY COMMISSION

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse}

Offsite Dose Calculation Manual Guidance: Standard

Radiological Effluent Controls for Boiling Water Reactors

Generic Letter 89-01, Supplement No. 1

5. AUTHOR(S)

W. Wayne Meinke and Thomas H. Essig

1. REPORT NUMBER

3.

(Al1lgned by NRC. Add Vol., Supp .. Rov.,

1nd Addendum Numbers, If eny.J

NUREG-1302

DATE REPORT PUBLISHED

MONTH 1 April YEAR 1991

4. FIN OR GRANT NUMBER

N/A

6. TYPE OF REPORT

Industry Guidance

7. PERIOD COVERED llnclusive Dares!

N/A

B. PERFORMING ORGANIZATION - NAME AND ADDRESS !If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor, provide

name and mailing address.)

Division of Radiation Protection and Emergency Preparedness

Off ice of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Conunission

Washington, D.C. 20555

9. SPONSOR ING ORGANIZATION - NAME AND ADDRESS !If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Comminion,

and mailing address.}

Same as above

10. SUPPLEMENTARY NOTES

11. ABSTRACT 1200 words or less!

This report contains guidance which may be voluntarily used by licensees who choose

to implement the provision of Generic Letter 89-01, which allows Radiological Effluent

Technical Specifications (RETS) to be removed from the main body of the Technical

Specifications and placed in the Offsite Dose Calculation Manual (ODCM). Guidance is

provided for Standard Effluent Controls definitions, Controls for effluent monitoring

instrumentation, Controls for effluent releases, Controls for radiological environmental

monitoring, and the basis for Controls.

Guidance on the formulation of RETS has been available in draft form (NUREG-0472 and

-0473) for a number of years: the current effort simply recasts those RETS into

Standard Radiological Effluent Controls for application to the ODCM. Also included

for completeness are: (1) radiological environmental monitoring program guidance

previously which had been available as a Branch Technical Position (Rev. 1, November

1979): (2) existing ODCM guidance: and (3) a reproduction of Generic Letter 89-01.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.I

Generic Letter 89-01

Licensee Guidance

Effluent Controls

Effluent Monitoring

Radiological Environmental Monitoring

Boiling Water Reactors

NRC FORM 335 (2-891

13. AVAILABILITY STATEMENT

Unlimited

14. SECURITY CLASSIFICATION

(This Page)

Unclassified

(This Report)

Unclassified

15. NUMBER OF PAGES

16. PRICE

THIS DOCUMENT WAS PRINTED USING RECYCLED PAPER

NUREG-1302, Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors

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