Text

Radioactive Effluent Release Report & Offsite Dose Calculation Manual PLA-5618, Bases B 3.11 - B 3.11.4.3
	ML031250280
Person / Time
Site:	Susquehanna
Issue date:	04/30/2003
From:	Shriver B; Susquehanna
To:	; Office of Nuclear Reactor Regulation
References
	PLA-5618
	Download: ML031250280 (86)
	v • d • e

Liquid Effluents Concentration 3.11.1.1 3.11 Radioactive Effluents 3.11.1 Liquid Effluents 3.11.1.1 Liquid Effluents Concentration TRO 3.11.1.1 The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (See FSAR Section 2.1.1.3) shall be limited to 10 times the concentrations specified in Appendix B,Table 2,Column 2 to 10CFR 20.1001-20.2402 for radionuclides other than dissolved or entrained noble gases.

For dissolved or entrained noble gases, the concentration shall be limited to 2E-4 pCi/ml total activity.

APPLICABILITY: At all times.

ACTIONS _

CONDITION REQUIRED ACTION COMPLETION TIME A. Concentration of Al. Restore-the concentration Immediately radioactive material to within the above released in liquid limits effluents to UNRESTRICTED AREAS (See FSAR Section 2.1.1.3) exceeds the limits specified in TRO 3.11.1.1 SUSQUEHANNA - UNIT 2 3.11-1 EFFECTIVE DATE 08/31/1998

Liquid Effluents Concentration 3.11.1.1 TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY I

TRS 3.11.1.1.1 The radioactivity content of each batch of Prior to each radioactive liquid waste shall be release determined by sampling and analysis in accordance with Table 3.11.1.1-1. The results of pre-release analyses shall be used with the calculational methods and parameters in the ODCM to assure that the concentration at the point of release is maintained within the limits of TRO 3.11.1.1 TRS 3.11.1.1.2 Post release analyses of samples composited According to from batch releases shall be performed in the ODCM accordance with Table 3.11.1.1-1. The results of the previous post-release analyses shall be used with the calculational methods and parameters in the ODCM to assure that the concentrations at the point of release were maintained within the limits of TRO 3.11.1.1 SUSQUEHANNA - UNIT 2 3.11-2 EFFECTIVE DATE 08/31/1998

Liquid Effluents Concentration

3. 11. 1.1 TABLE 3.11.1.1-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum of Detection Liquid Release Sampling Analysis Type of Activity (LLD)

Type Frequency Frequency Analysis (LCi/ml Batch Waste Prior to Prior to Principal Gamma 5E-7 Release Tanks Release release Emitters Each Batch Each Batch I-131 1E-6 Prior to 31 days Dissolved and 1E-5 Release Entrained Gases One Batch per (Gamma Emitters) month Prior to 31 days H-3 1E-5 Release Composite"')

Each Batch Gross Alpha 1E-7 Prior to 92 days Sr-89. Sr-90 5E-8 Release Composite")

Each Batch Fe-55 1E-6 le) Minimum frequency for initiation of required analysis.

SUSQUEHANNA - UNIT 2 3.11-3 EFFECTIVE DATE 08/31/1998

Liquid Effluents Dose 3.11.1.2 3.11 Radioactive Effluents 3.11.1 Liquid Effluents 3.11.1.2 Liquid Effluents Dose TRO 3.11.1.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each reactor unit UNRESTRICTED AREAS shall be limited:

a. During any calendar quarter to less than or equal to 1.5 mrems to the total body and to less than or equal to 5 mrems to any organ.

AND

b. During any calendar year to less than or equal to 3.0 mrems to the total body and to less than or equal to 10 mrems to any organ.

APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Calculated dose from Al. Prepare and submit a Within 30 days the release of Special Report to the radioactive materials Commission in liquid effluents exceeding any of the above limits SUSQUEHANNA - UNIT 2 3.11-4 EFFECTIVE DATE 08/31/1998

Liquid Effluents Dose 3.11.1.2 TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.1.2.1 Determine cumulative dose contributions 31 days from liquid effluents for the current calendar quarter and the current calendar year in accordance with methodology and parameters in the ODCM _

SUSQUEHANNA - UNIT 2 3.11-5 EFFECTIVE DATE 08/31/1998

Liquid Waste Treatment System Liquid Waste Treatment System 3.11.1.3 3.11 Radioactive Effluents 3.11.1 Liquid Effluents 3.11.1.3 Liquid Waste Treatment System TRO 3.11.1.3 The appropriate portions of the Liquid Radwaste Treatment System, as described in the ODCM, shall be OPERABLE.

Appropriate portions of the Liquid Waste Treatment System shall be used to reduce the radioactive materials in liquid effluent, prior to their discharge, when projected doses due to liquid effluent releases from each reactor unit to UNRESTRICTED AREAS would exceed 0.06 mrem to the total body or 0.2 mrem to any organ in a 31 day period.

APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Liquid effluent Al. Prepare and submit a 30 days releases being Special Report to the discharged without Commission treatment and in excess of the TRO limit.

SUSQUEHANNA - UNIT 2 3.11-6 EFFECTIVE DATE 08/31/1998

Liquid Waste Treatment System 3.11.1.3 TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.1.3.1 Project doses due to liquid releases from 31 days each reactor unit to the UNRESTRICTED AREAS in accordance with the methodology and parameters inthe ODCM.

TRS 3.11.1.3.2 ------------------ NOTE--------------------

Not required to be performed if.the liquid radwaste system has been utilized to process radioactive liquid during the previous 92 days Demonstrate the Liquid Radwaste (LRW) 92 days Treatment System OPERABLE by operating LRW Treatment System equipment for at least 10 minutes.

SUSQUEHANNA - UNIT 2 3.11-7 EFFECTIVE DATE 08/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation 3.11.1.4 3.11 Radioactive Effluents 3.11.1 Liquid Effluents 3.11.1.4 Liquid Radwaste Effluent Monitoring Instrumentation TRO 3.11.1.4 The Radioactive Liquid Radwaste Effluent Monitoring Instrumentation channels shown in Table 3.11.1.4-1 shall be OPERABLE with their setpoints established in accordance with the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of TRO 3.11.1.1.

APPLICABILITY: At all times.

ACTIONS

NOTE ---------------------------------------

1. Separate condition entry is allowed for each channel

2. The provisions of TRO 3.0.4 are not applicable a

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend the release of Immediately radioactive liquid radioactive liquid effluent monitoring effluents monitored by instrumentation the affected channel alarm/trip channels OR setpoint less A.2 Declare the channel Immediately conservative than the inoperable limits allowed by TRO 3.(11.u1.1__

(conti nued)

SUSQUEHANNA - UNIT 2 3.11-8 EFFECTIVE DATE 08/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation 3.11.1.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Liquid Radwaste B.1 Analyze at least two Prior to, releases are necessary independent samples in initiating each and Effluent Line accordance with TRO release.

Gross Radioactivity 3.11.1.1 Monitoring AND Instrumentation inoperable. B.2 Independently determine Prior to release rates for samples initiating each analyzed per Action B.1 release.

AND B.3 Perform and independently Prior to verify discharge valve initiating each lineup release.

AND B.4 Restore monitoring 14 days instrumentation C. Liquid Radwaste C.1 Maintain at least one Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of releases are not in isolation valve closed securing from progress and the Gross between each source of release or Radioactivity release and the liquid discovery of Monitoring radwaste discharge valve. inoperable instrumentation is . instrument.

inoperable because the inoperable channel is caused by a discharge valve interlock in an off-normal condition or not functioning.

I..LUIIIII~eU kuU LI nuteu)

SUSQUEHANNA - UNIT 2 3. 11-9 EFFECTIVE DATE 08/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation 3.11.1.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Liquid Radwaste D.1 Estimate Flow Rate. Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months releases are necessary during releases.

and Effluent Line or AND Cooling Tower Blowiown 0.2 Restore Monitoring 30 days FliMonitoring Flow montorin Instrumentation.

Instrumentation inoperable.

E. Liquid Radwaste E.1 Maintain at least one Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of releases are not in isolation valve closed securing release progress and cooling between each source of or discovery of tower blowdown flow release and the liquid inoperable monitoring radwaste discharge valve. instrument.

instrumentation is inoperable because the inoperable channel is a discharge valve interlock in an off-normal condition or not functioning.

F. Required Action and F.1 -------- NOTE----------

Associated Completion Only applicable to Time of Conditions B. Condition B C, D, or E not met.

Suspend release of Immediately radioactive effluents via this pathway AND F.2 Explain why the In the next inoperability was not Annual corrected in a timely Radioactive manner Effluent Release Report per TS Section 5.6 SUSQUEHANNA - UNIT 2 3.11-10 EFFECTIVE DATE 08/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation 3.11.1.4 TECHNICAL REQUIREMENT SURVEILLANCE

- ----------------------------- NOTE---------------------------------

Refer to Table 3.11.1.4-1 to determine which TRSs apply for each Monitoring Function.

SURVEILLANCE FREQUENCY TRS 3.11.1.4.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TRS 3.11.1.4.2 Perform CHANNEL CHECK including a source Prior to check. commencing release TRS 3.11.1.4.3 Perform CHANNEL FUNCTIONAL TEST 92 days TRS 3.11.1.4.4 Perform CHANNEL CALIBRATION 24 months SUSQUEHANNA - UNIT 2 3. 11-11 EFFECTIVE DATE 08/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation 3.11.1.4 TABLE 3.11.1.4-1 LIQUID RADWASTE EFFLUENT MONITORING INSTRUMENTATION REQUIRED SURVEILLANCE FUNCTION CHANNELS REQUIREMENTS

1. GROSS RADIOACTIVITY MONITORS PROVIDING AUTOMATIC TERMINATION OF RELEASE

a. Liquid Radwaste Effluent Line 1 TRS 3.11.1.4.2 TRS 3.11.1.4.3 TRS 3.11.1.4.4

2. FLOW RATE MEASUREMENT DEVICES

a. Liquid Radwaste Effluent Line 1 TRS 3.11.1.4.1("

TRS 3.11.1.4.3 TRS 3:11.1.4.4

b. Cooling Tower Blowdown 1 TRS 3.11.1.4.1(8)

TRS 3.11.1.4.3 TRS 3.11.1.4.4 (a) Only required when performing batch releases.

/

SUSQUEHANNA - UNIT 2 3.11-12 EFFECTIVE DATE 08/31/1998

Radioactive Liquid Process Monitoring Instrumentation 3.11.1.5 tS 3.11 Radioactive Effluents K_> 3.11.1 Liquid Effluents 3.11.1.5 Radioactive Liquid Process Monitoring Instrumentation TRO 3.11.1.5 The Radioactive Liquid Process Monitoring Instrumentation channels shown in Table 3.11.1.5-1 shall be OPERABLE with their setpoints established in accordance with the ODCM to ensure the alarm will occur prior to exceeding the limits of TRO 3.11.1.1.

APPLICABILITY: As specified in Table 3.11.1.5-1.

ACTIONS NOTE---------------------------------------

1. Separate condition entry is allowed for each channel

2. The provisions of TRO 3.0.4 are not applicable CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend the release of Immediately Radioactive Liquid liquid effluents Process Monitoring monitored by the affected Instrumentation channel alarm/trip channels OR setpoint less Immediately conservative than the A.2 Declare the channel hantheinoperable consrvaive limits allowed by TRO 3.11. 1.1. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

(continued)

SUSQUEHANNA - UNIT 2 3.11-13 EFFECTIVE DATE 9/01/1998 l

1JL Radioactive Liquid Process Monitoring Instrumentation 3.11L1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Radioactive Liquid B.1.1 Suspend the release of Immediately Process Monitoring liquid effluents Instrumentation monitored by the otherwise inoperable. affected channel.

OR B.1.2 Analyze grab samples Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for isotopic activity when the to the required LLDs associated for liquid effluents pathway is in (Table 3.11.1.1-1). service AND B.2 Restore monitoring 30 days instrumentation C. Required Action and C.1 Explain why the In the next Associated Completion inoperability was not Annual Time of Conditions B corrected in a timely Radioactive not met. manner Effluent Release Report per TS Section 5.6 D. RHR Heat Exchanger to D.1 Analyze grab samples from Prior to be drained to the the RHR Heat Exchanger draining RHR spray pond. for isotopic activity to Heat Exchanger the required LLDs for to the spray liquid effluents (Table pond.

SUSQUEHANNA - UNIT 2 3.11-14 EFFECTIVE DATE 9/01/1998 l

Radioactive Liquid Process Monitoring Instrumentation 3.11.1.5 TECHNICAL REQUIREMENT SURVEILLANCE

NOTE-------------------------------------

Refer to Table 3.11.1.5-1 to determine which TRSs apply for each Monitoring Function.'

SURVEILLANCE FREQUENCY TRS 3.11.1.5.1 Perform CHANNEL CHECK. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TRS 3.11.1.5.2 Perform a Source Check 31 days TRS 3.11.1.5.3 Perform CHANNEL FUNCTIONAL TEST 92 days TRS 3.11.1.5.4 Perform CHANNEL CALIBRATION 24 months SUSQUEHrANNA - UNIT 2 3.11-15 EFFECTIVE DATE 9/01/1998 l

Radioactive Liquid Process Monitoring Instrumentation 3.11.1.5 TABLE 3.11.1.5-1 RADIOACTIVE LIQUID PROCESS MONITORING INSTRUMENTATION C ,

REQUIRED SURVEILLANCE FUNCTION CHANNELS APPLICABILITY REQUIREMENTS GROSS RADIOACTIVITY MONITORS NOT PROVIDING AUTOMATIC TERMINATION OF RELEASE

1. Service Water System Effluent Line 1 Ca) TRS 3.11.1.5.1 TRS 3.11.1.5.2 TRS 3.11.1.5.3 TRS 3.11.1.5.4

2. Supplemental Decay Heat Removal 1 (a) TRS 3.11.1.5.1 Service Water TRS 3.11.1.5.2 TRS 3.11.1.5.3 TRS 3.11.1.5.4

3. RHR Service Water System Effluent 1/Loop (b) TRS 3.11.1.5.1 Line. TRS 3.11.1.5.2 TRS 3.11.1.5.3 TRS 3.11.1.5.4 (a) System aligned through Fuel Pool Cooling Heat Exchanger. Alignment change between Service Water System Effluent Line and Supplemental Decay C.

Heat Removal Service Water is not considered to be a change in the applicable condition.

(b) At all times Ca

'SUSQUEHANNA - UNIT 2 3.11-16 EFFECTIVE DATE 9/01/1998 I

Dose Rate 3.11.2.1 3.11 Radioactive Effluents 3.11.2 Gaseous Effluents 3.11.2.1 Dose Rate TRO 3.11.2.1 The dose rate due to radioactive materials released in gaseous effluents to areas at and beyond the SITE BOUNDARY (See FSAR Section 2.1.1.3) shall be limited to the following:

I. For Noble Gases:

A. Less than or equal to 500 mrems/yr to the total body, and B. Less than or equal to,3000.mrems/yr to the skin AND II. For iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives greater than 8 days A. Less than or equal to 1500 mrem/yr to any organ (Inhalation pathways only.)

APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Dose rate(s) exceed A.1 Restore the release rate Immediately the above limits to within the above limits I _ _

SUSQUEHANNA - UNIT 2 3.11-17 EFFECTIVE DATE 08/31/1998

Dose Rate 3.11.2.1 TECHNICAL REQUIREMENT SURVEILLANCE C, SURVEILLANCE FREQUENCY TRS 3.11.2.1.1 Determine the dose rate due to noble See ODCM gases in gaseous effluents.

TRS 3.11.2.1.2 The dose rate due to iodine-131, iodine- See Table 133, tritium, and all radionuclides in 3.11.2.1-1 particulate form with half-lives greater than 8 days in gaseous effluents shall be determined to be within the limits in accordance with the methodology and parameters of the ODCM by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Table 3.11.2.1-1 _

(-C SUSQUEHANNA - UNIT 2 3.11-18 EFFECTIVE DATE 08/31/1998

Dose Rate 3.11.2.1 TABLE 3.11.2.1-1 RADIOACTIVE GASEOUS EFFLUENT SAMPLING AND ANALYSIS Sampling Minimum Analysis Type of Activity Leter Limit of Gaseous Release Type Method and Frequency Analysis DetectCi/mo(LL)

A. Containment Purge Prior to each purge Prior to each Principal Noble 1E-4 Grab Sample purge Gas Gamma Emitters H-3 1E-6 B. Reactor Building 31 days(') 31 days"( Principal Noble 1E-4 Vents, Turbine Grab Sample Gas Gamma Emitters Building Vents.

and SGTS H-3 1E-6 Continuous(b) Iodine 7 days"c) I-131 1E-12 Cartridge Sample I-133 lE-10 Continuous(b) 7 days" Principal lE-11 Particulate Gamma Particulate sample Emitters 1-131 Continuous(b 2 92 days Gross Alpha lE-11 Particulate Sample Composite(d)

Continuous(b) 92 days Sr-89, Sr-90 lE-11 Particulate sample Composite'd)

Continuous b) Noble Gas Noble Gases. Gross 1E-6 Monitor Beta or Gamma (Xe-133 equivalent)

" If the iodine or particulate monitoring channel(s) is (are) inoperative, noble gas analyses shall also be performed following shutdown. startup, or a THERMAL POWER change exceeding 15X of the RATED THERMAL POWER within a 1-hour period.

(b) 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 TROs 3.11.2.1.

3.11.2.2. and 3.11.2.3.

"c)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. If the iodine or particulate monitoring channel(s) is (are) inoperative. 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 15X of RATED THERMAL POWER in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . and analyses completed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of changing. When samples collected for s 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.

(d Minimum frequency for initiation of required analysis.

SUSQUEHANNA - UNIT 2 3.11l-19 EFFECTIVE DATE 08/31/1998

Dose - Noble Gases 3.11.2.2 3.11 Radioactive Effluents 3.11.2 Gaseous Effluents (2-"

3.11.2.2 Dose - Noble Gases TRO 3.11.2.2 The air dose due to noble gases released in gaseous effluents, from each reactor unit, to areas at and beyond the SITE BOUNDARY (See FSAR Section 2.1.1.3) 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.

C" ACTIONS _

CONDITION REQUIRED ACTION COMPLETION TIME A. The calculated air A.1 Prepare and submit a 30 days dose exceeds the Special Report to the limits. Commission TECHNICAL REQUIREMENT SURVEILLANCE-SURVEILLANCE FREQUENCY TRS 3.11.2.2.1 Determine the cumulative dose contributions 31 days for the current calendar quarter and current calendar year for these sources in accordance with the methodology and parameters in the ODCM SUSQUEHANNA - UNIT 2 3.11-20 EFFECTIVE DATE 08/31/1998

Dose - Iodine, Tritium, and Radionuclides in Particulate Form 3.11.2.3 3.11 Radioactive Effluents 3.11.2 Gaseous Effluents 3.11.2.3 Dose - Iodine, Tritium, and Radionuclides in Particulate Form TRO 3.11.2.3 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 reactor unit, to areas at and beyond the SITE BOUNDARY 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.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. The calculated dose A.1 Prepare and submit a 30 days from the release Special Report to the exceeds the limits. Commission.

TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.2.3.1 Determine the cumulative dose contributions 31 days for the current calendar quarter and current calendar year for these sources in accordance with the methodology and parameters in the ODCM.

SUSQUEHANNA - UNIT 2 3.11-21 EFFECTIVE DATE 08/31/1998

GASEOUS RADWASTE TREATMENT SYSTEM4 3.11.2.4 3.11 Radioactive Effluents 3.11.2 - Gaseous Effluents C 3.11.2.4 GASEOUS RADWASTE TREATMENT SYSTEM TRO 3.11.2.4 The GASEOUS RADWASTE TREATMENT SYSTEM shall be OPERABLE and in operation.

APPLICABILITY: When the main condenser air ejector (evacuation) system is in operation.

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. GASEOUS RADWASTE A.1 Restore GASEOUS 7 days TREATMENT SYSTEM RADWASTE TREATMENT inoperable. SYSTEM to OPERABLE status.

B. Required Action and B.1 Prepare and submit a 30 days associated Completion Time not met.

Special Report to the Commission. (91 TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.2.4.1 Verify GASEOUS RADWASTE TREATMENT 92 days SYSTEM to be in operation.

I SUSQUEHANNA - UNIT 2 - TRM /3.11-22 EFFECTIVE DATE 04/02/2002 C

VENTILATION EXHAUST TREATMENT SYSTEM l 3.11.2.5 3.11 Radioactive Effluents 3.11.2 Gaseous Effluents 3.11.2.5 VENTILATION EXHAUST TREATMENT SYSTEM I TRO 3.11.2.5 The appropriate portions of the VENTILATION EXHAUST TREATMENT SYSTEM, as described in the Offsite Dose Calculation Manual (ODCM),

shall be OPERABLE.

-ag---NOTE-Appropriate portions of the VENTILATION EXHAUST TREATMENT SYSTEM shall be used to reduce radioactive materials in gaseous waste prior to their discharge when projected doses due to gaseous effluent releases from either reactor unit to areas at and beyond the SITE BOUNDARY would exceed 0.3 mrem to any organ in a 31 day period.

APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. VENTILATION EXHAUST A.1 Restore VENTILATION 31 days TREATMENT SYSTEM EXHAUST TREATMENT inoperable. SYSTEM to OPERABLE status. I B. Required Action and B.1 Prepare and submit a 30 days Associated Completion Special Report to the Time of Condition A not Commission.

met. I OR Gaseous waste being discharged without treatment and in excess of TRO limits. I SUSQUEHANNA - UNIT 2 TRM / 3.1 1-23 EFFECTIVE DATE 04/02/2002

VENTILATION EXHAUSTTREATMENTSYSTEM l

3.11.2.5 TECHNICAL REQUIREMENT SURVEILLANCE (9.

SURVEILLANCE FREQUENCY TRS 3.11.2.5.1 Perform dose projection due to gaseous releases from each reactor unit to areas at and beyond the SITE BOUNDARY in accordance with the 31 days I

methodology and parameters in the ODCM.

TRS 3.11.2.5.2 --- NOTE-Not required if the appropriate system has been utilized to process radioactive gaseous effluents during the previous 92 days.

Verify VENTILATION EXHAUST TREATMENT 92 days SYSTEM is OPERABLE by operating the system 2 10 minutes.

C-SUSQUEHANNA - UNIT 2 TRM /3.11-24 EFFECTIVE DATE 04/02/2002 C

Radioactive Gaseous Effluent Monitoring Instrumentation 3.11.2.6 3.11 Radioactive Effluents 3.11.2 Gaseous Effluents 3.11.2.6 Radioactive Gaseous Effluent Monitoring Instrumentation TRO 3.11.2.6 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.11.2.6-1 shall be OPERABLE with their setpoints established in accordance with the ODCM to ensure that the limits of Requirement 3.11.2.1 are not exceeded.

APPLICABILITY: According to Table 3.11.2.6-1 ACTIONS

- ---------------------------- NOTE---------------------------------------

1. Separate condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. Radioactive gaseous A.1 Suspend the release of Immediately effluent monitoring radioactive gaseous instrumentation effluents monitored by channel alarm/trip the affected channel setpoint less OR conservative than O required to ensure A.2 Declare the channel Immediately that the limits of inoperable Requirement 3.11.2.1 are not exceeded (continued)

SUSQUEHANNA - UNIT 2 3.11-25 EFFECTIVE DATE 9/01/1998 l

Radioactive Gaseous Effluent Monitoring Instrumentation 3.11.2.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C B. Reactor Building B.1 Take grab samples Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Ventilation System while release is Noble Gas Activity in progress.

Monitor low range AND channel inoperable B.2 Analyze grab samples for Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isotopic activity to the of grab sample required LLDs for principal noble gas gamma emitters (Table 3.11.2.1-1)

AND B.3 Restore monitoring 30 days instrumentation.

C. Reactor Building C.1 Ensure samples are Continuously Ventilation System collected with auxiliary while release is Iodine Monitor or sampling equipment as in progress.

Particulate Monitor required by Table inoperable 3.11.2.1-1 AND C.2 Restore monitoring 30 days instrumentation D. Reactor Building D.1 Estimate flow rate. Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Ventilation Monitoring while release is System Effluent System AND in progress Flow Rate Monitor or Sampler Flow Rate Monitor inoperable D.2 Restore monitoring 30 days instrumentation.

(continued)

SUSQUEHANNA - UNIT 2 3.11-26 EFFECTIVE DATE 9/01/1998 I

Radioactive Gaseous Effluent Monitoring Instrumentation 3.11.2.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Turbine Building E.1 Verify mechanical vacuum Immediately Ventilation System pump is not in operation.

Noble Gas Activity AND Monitor low range channel inoperable E.2 Take grab samples. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AND while release is in progress E.3 Analyze grab samples for Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isotopic activity to the after sample required LLDs for principal noble gas gamma emitters (Table 3.11.2.1-1).

AND E.4 Restore monitoring 30 days instrumentation

.F. Turbine Building F.I Ensure samples are Continuously Ventilation System collected with auxiliary while release is Iodine Monitor or sampling equipment as in progress Particulate Monitor required by Table inoperable 3.11.2.1-1 AND F.2 Restore-monitoring 30 days instrumentation G. Turbine Building G.1 Estimate flow rate. Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Ventilation Monitoring AND while release is System Effluent System in progress.

Flow Rate Monitor or G.2 Restore monitoring 30 days Sampler Flow Rate instrumentation Monitor inoperable instrumentation I~cont nueu kconLinuea)

SUSQUEHANNA - UNIT 2 3.11-27 EFFECTIVE DATE 9/01/1998 1

Radioactive Gaseous Effluent Monitoring Instrumentation 3.11.2.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME Ci H. Standby Gas Treatment H.1 Take grab samples. Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months System Noble Gas AND while release is Activity Monitor low in progress.

range channel inoperable H.*2 Analyze grab samples for Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months isotopic activity to the of grab sample required LLDs for being taken.

principal noble gas gamma emitters (Table AND H.3 Restore monitoring 30 days instrumentation.

I. Standby Gas Treatment I.1 Ensure samples are Continuously System Iodine Monitor or Particulate Monitor collected with auxiliary sampling equipment as while releases are in progress L,)

inoperable required by Table 3.11.2.1-1.

AND I.2 Restore monitoring 30 days instrumentation.

J. SGTS Ventilation J.1 Estimate flow rate. Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Monitoring System AND while release is Effluent flow rate in progress.

monitor or sample flow rate monitor Inoperable. J.2 Restore monitoring 30 days Instrumentation. _____ ____

kcontl nuedi 3.11-28 EFFECTIVE DATE 9/01/1998 [

SUSQUEHANNA - UNIT.2

Radioactive Gaseous Effluent Monitoring Instrumentation 3.11.2.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. Required Actions and K.1 Explain why this In the next Completion Times not inoperability was not Annual met for Conditions B corrected in atimely Radioactive through J. manner. Effluents Release Report

.per TS Section 5.6.

TECHNICAL REQUIREMENT SURVEILLANCE Refer to Table 3.11.2.6-1 to determine which TRSs apply for each Monitoring Function.

SURVEILLANCE FREQUENCY TRS 3.11.2.6.1 Perform CHANNEL CHECK 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TRS 3.11.2.6.2 Perform CHANNEL CHECK 7 days TRS 3.11.2.6.3 Perform Source Check 31 days TRS 3.11.2.6.4 Perform CHANNEL FUNCTIONAL TEST 92 days TRS 3.11.2.6.5 Perform CHANNEL CALIBRATION 24 months SUSQUEHANNA - UNIT 2 3.11-29 EFFECTIVE DATE 9/01/1998 I

Radioactive Gaseous Effluent Monitoring Instrumentation

3. 11.2.6 TABLE 3.11.2.6-1 (Page 1 of 3)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION C(-I REQUIRED SURVEILLANCE FUNCTION APPLICABILITY CHANNELS REQUIREMENTS

1. REACTOR BUILDING VENTILATION MONITORING SYSTEM

a. Noble Gas Activity Monitor At all Times 1 TRS 3.11.2.6.1 (Low Range) TRS 3.11.2.6.3 TRS 3.11.2.6.4 TRS 3.11.2.6.5

b. Iodine Monitor At all Times 1 TRS 3.11.2.6.2 TRS 3.11.2.6.3 TRS 3.11.2.6.4 TRS 3.11.2.6.5

c. Particulate Monitor - At all Times 1 TRS 3.11.2.6.2 TRS 3.11.2.6.3 TRS 3.11.2.6.4 TRS 3.11.2.6.5

d. Effluent System Flow Rate Monitor At all Times 1 TRS 3.11.2.6.1 TRS 3.11.2.6.4 TRS 3.11.2.6.5

e. Sampler Flow Rate Monitor At all Times 1 TRS 3.11.2.6.1 TRS 3.11.2.6.4 TRS 3.11.2.6.5 (continued)

SUSQUEHANNA - UNIT 2 3.11-30 EFFECTIVE DATE 9/01/1998 .1

Radioactive Gaseous Effluent Monitoring Instrumentation 3.11.2.6 TABLE 3.11.2.6-1 (Page 2 of 3)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION REQUIRED SURVEILLANCE FUNCTION APPLICABILITY CHANNELS REQUIREMENTS

2. TURBINE BUILDING VENTILATION MONITORING SYSTEM

a. Noble Gas Activity. Monitor At all Times 1 TRS 3.11.2.6.1 (Low Range) TRS 3.11.2.6.3 TRS 3.11.2.6.4 TRS 3.11.2.6.5

b. Iodine Monitor At all Times 1 TRS 3.11.2.6.2 TRS 3.11.2.6.3 TRS 3.11.2.6.4 TRS 3.11.2.6.5 c: Particulate Monitor At all Times 1 TRS 3.11.2.6.2 TRS 3.11.2.6.3 TRS 3.11.2.6.4 TRS 3.11.2.6.5

d. Effluent System Flow Rate Monitor At all Times 1 TRS 3.11.2.6.1 TRS 3.11.2.6.4 TRS 3.11.2.6.5

e. Sampler Flow Rate Monitor At all Times 1 TRS 3.11.2.6.1 TRS 3.11.2.6.4 TRS 3.11.2.6.5 (continued)

SUSQUEHANNA - UNIT 2 3.11-31 EFFECTIVE DATE 9/01/1998 l

Radioactive Gaseous Effluent Monitoring I nstrumentati on 3.11.2.6 TABLE 3.11.2.6-1 (Page 3 of 3)

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION

(.

REQUIRED SURVEILLANCE FUNCTION APPLICABILITY CHANNELS REQUIREMENTS

3. STANDBY GAS TREATMENT SYSTEM (SGTS)

MONITOR

a. Noble Gas Activity Monitor During 1 TRS 3.11.2.6.1 (Low Range) operation of TRS 3.11.2.6.3 SGTS(' ) TRS 3.11.2.6.4 TRS 3.11.2.6.5

b. Iodine Monitor During 1 TRS 3.11.2.6.2 operation of TRS 3.11.2.6.3 SGTS18) TRS 3.11.2.6.4 TRS 3.11.2.6.5

c. Particulate Monitor During 1 TRS 3.11.2.6.2 operation of TRS 3.11.2.6.3 SGTS(a) TRS 3.11.2.6.4 TRS 3.11.2.6.5

d. Effluent System Flow Rate Monitor During 1 TRS 3.11.2.6.1 operation of TRS 3.11.2.6.4 SGTS"' TRS 3.11.2.6.5

e. Sampler Flow Rate Monitor During 1 TRS 3.11.2.6.1 operation of TRS 3.11.2.6.4 SGTS"' TRS 3.11.2.6.5 (a) The provisions of TRO 3.0.4 are not applicable.

C SUSQUEHANNA - UNIT 2 3. 11-32 EFFECTIVE DATE 9/01/1998

Total Dose 3.11.3 3.11 Radioactive Effluents 3.11.3 Total Dose TRO 3.11.3 The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC, due to releases of radioactivity and radiation, from uranium fuel cycle sources shall be limited to less than or equal to 25 mrem to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrem.

APPLICABILITY: At all times ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Calculated doses from A.1 Initiate actions to Immediately the release of calculate whether the radioactive materials TRO limits have been in liquid or gaseous exceeded effluents exceed twice the limits of Requirements 3.11.1.2.a, 3.11.1.2.b, 3.11.2.2.a, 3.11.2.2.b.

3.11.2.3.a, or 3.11.2.3.b B. TRO limits exceeded B.1 Prepare and submit a 30 days Special Report to the Commission SUSQUEHANNA - UNIT 2 3. 11- 33 EFFECTIVE DATE 08/31/1998

Total Dose 3.11.3 TECHNICAL REQUIREMENT SURVEILLANCE C

SURVEILLANCE FREQUENCY TRS 3.11.3.1 Determine the cumulative dose from liquid 31 days and gaseous effluents in accordance with the methodology and parameters in the ODCM TRS 3.11.3.2 Determine cumulative dose contributions 12 months from direct radiation from unit operation in accordance with the methodology and parameters in the ODCM C

(,

SUSQUEHANNA - UNIT 2 3.11-34 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 3.11 Radioactive Effluents 3.11.4 Radiological Environmental Monitoring 3.11.4.1 Monitoring Program TRO 3.11.4.1 The radiological environmental monitoring program shall be conducted as specified in Table 3.11.4.1-1.

APPLICABILITY: At all times A f-TT nMC ALI IUI4 1__________

REQUIRED ACTION COMPLETION TIME CONDITION A.1 Report and describe the Annually A. Radiological environmental events and any actions monitoring program not taken to prevent their being conducted as recurrence in the Annual specified in Table Radiological 3.11.4.1-1 Environmental Operating Report OU cays B. The average level of B.1 Prepare and submit a radioactivity over any Special Report to the calendar quarter as Commission the result of an individual radionuclide in plant effluents in a particular environmental exposure pathway in a particular environmental sampling medium, at a specified location exceeds the applicable reporting level of Table 3.11.4.1-2 I curt - ;.iiu4 f -- ~ .: - .- N U;onlLnFutUa SUSQUEHANNA - UNIT 2 3.11-35 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

( "

C. More than one of the C.1 Prepare and submit a 30 days radionucli des in Table Special Report to the 3.11.4.1-2 are Commission detected in a particular environmental exposure pathway at a specified monitoring location and are the result of plant effluents AND The sum of the ratios of the quarterly average activity levels to their corresponding reporting levels of each detected C radionuclide, from Table 3.11.4.1-2, is

Ž 1.0 (continued)

(9.

SUSQUEHANNA - UNIT 2 3.11-36 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more D.1 Prepare and submit a 30 days Radionuclide(s) other Special Report to the than those in Table Commission 3.11.4.1-2 are detected in a particular environmental exposure pathway at a specified location and are the result of plant effluents AND The potential annual dose to a MEMBER OF THE PUBLIC from all detected radionuclides that are the result of plant effluents is greater than or equal to the calendar year limits of TROs 3.11.1.2, 3.11.2.2 and 3.11.2.3 E. The requirements for a E.1 Report and discuss the Annually Special Report per reasons for not Conditions B. C. or D attributing identified are met, but the radionuclides to plant radionuclides that are effluents in the Annual detected are not the Radiological result of plant Environmental Operating effluents Report _______n______

kLcUlnt, II UCUI SUSQUEHANNA - UNIT 2 3.11-37 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C(

F. Milk or fresh leafy ------------- NOTE-----------

vegetable samples are The specific locations from unavailable from one which samples were or more of the sample unavailable may then be locations- required by deleted from the monitoring Table 3.11.4.1-1 program.

F.1 Identify locations for 30 days obtaining replacement samples and add them to the radiological environmental monitoring program AND F.2 Identify the cause of the unavailability of Annually U

samples and identify the new location(s) for obtaining replacement samples in the next Annual Radioactive Effluent Release Report G

SUSQUEHANNA - UNIT 2 3.11-38 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.4.1.1 Collect the radiological environmental As required by monitoring samples pursuant to Table Table 3.11.4.1-1 3.11.4.1-1 TRS 3.11.4.1.2 Analyze samples pursuant to the As required by requirements of Table 3.11.4.1-1 with Table 3.11.4.1-1 equipment meeting the detection capabilities required by Table 3.11.4.1-3 TRS 3.11.4.1.3 Determine annual cumulative potential Annually dose contributions from radionuclides detected in environmental samples in accordance with the methodology and parameters in the ODCM.

SUSQUEHANNA - UNIT 2 3.11-39 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 TABLE 3.11.4.1-1 (Page 1 of 3).

_ RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE . SAMPLING AND EXPOSURE PATHWAY SAMPLES AND COLLECTION TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS FREQUENCY OF ANALYSIS

1. DIRECT RADIATION 40 routine monitoring stations with two or Quarterly Gamma dose quarterly more dosimeters or with one instrument for measuring and recording dose rate continuously placed as follows:

1. An inner ring of stations, one in each meteorological sector, in the general area of the SITE BOUNDARY

2. An outer ring of stations, one in each meteorological sector. in the 3 to 9 mile range from the site

3. The balance of the stations placed in special interest areas such as population centers, nearby residences, schools, and in 1 or 2 areas to serve as control stations AIRBORNE L-,1 Radioiodine Samples from 5 locations Continual Radioiodine and a. 1 sample from close to each of the 3 SITE sampler Canister:

Particul ates BOUNDARY locations (indifferent sectors) operation 1-131 Analysis with the highest calculated annual average with sample weekly groundlevel X/Q collection weekly, or Particulate Sampler:

b. 1 sample from the vicinity of the more Gross Beta radio community having one of the highest frequently if activity analysis calculated annual ground level xIQ required by following filter

c. 1 sample from a control location, between dust loading change"': Gamma 15 and 30 km distant and in the least isotopic analysis of prevalent wind direction of wind blowing composite (by from the plant location) quarterly (continued)

'a) 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 thorn daughter decay. If gross beta activity in air particulate samples is greater than ten times the yearly mean of control samples. gamma isotopic analysis shall be performed on the individual samples.

C SUSQUEHANNA - UNIT 2 3. 11-40 EFFECTIVE DATE 08/31/1998

Monitoring Program 3.11.4.1 X^ TABLE 3.11.4.1-1 (Page 2 of 3)

J RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLING AND EXPOSURE PATHWAY SAMPLES AND COLLECTION TYPE AND FREQUENCY SAMPLE LOCATIONS FREQUENCY OF ANALYSIS AND/OR SAMPLE

3. WATERBORNE

a. Surface 1 sample upstream Composite Gamma isotopic 1 sample downstream sample over analysis monthly.

one-month Composite for period tritium analyses quarterly

b. Ground Samples from 1 or 2 sources only if likely to Quarterly Gamma isotopic and be affected tritium analyses quarterly Drinking 1 sample from each of 1 to 3 of the nearest Composite 1-131 analysis on c.

water supplies that could be affected by its sample over each composite when discharge 2-week period the dose calculated when I-131 for the consumption 1 sample from a control location analysis is of the water is performed, greater than 1 mrem monthly per year. Composite composite for gross beta and otherwise gamma isotopic analyses monthly.

Composite for tritium analyses quarterly 1 sample from downstream area with existing or Semiannually Garmma isotopic

d. Sediment from potential recreational value analyses shoreline semiannually (continued)

SUSQUEHANNA - UNIT 2 3. 11-41 EFFECTIVE DATE 08/31/1998

M2 Monitoring Program 3.11.4.1 TABLE 3.11.4.1-1 (Page 3 of 3)

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM L \

NUMBER OF REPRESENTATIVE SAMPLING AND EXPOSURE PATHWAY SAMPLES AND COLLECTION TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS FREQUENCY OF ANALYSIS

4. INGESTION

a. Milk a. Samples from milking animals in 3 Semimonthly Gamma isotopic and locations within 5km from the plant when animals 1-131 analysis having the highest dose potential. If are on semimonthly when there are none, then. 1 sample from pasture. animals are on milking animals in each of 3 areas monthly at pasture: monthly at between 5 and 8km distant where doses other times. other times.

are calculated to be greater than 1 mrem per year.

1 sample from milking animals at a control location (between 15 and 30km from the plant preferably in the least prevalent direction for wind blowing from the plant).

b. Fish and/or b. 1 sample of each of two recreationally Sample in Gamma isotopic Invertebrates important species in vicinity of plant season, or analysis on edible discharge area. semiannually portions.

1 sample of same species in areas not if they are influenced by plant discharge.

not C.,

seasonal.

c. Food c. 1 sample of each principal class of food At time of Gamma isotopic Products products from any area which is irrigated harvest analysis on edible by water inwhich liquid plant wastes portions.

have been discharged.

Samples of 3 different kinds of broad leaf vegetation grown nearest each of two Monthly when Gamma isotopic and different offsite locations of highest available I-131 analysis.

predicted annual average ground level D/Q if milk sampling is not performed.

1 sample of each of.the similar broad Monthly when Gamma isotopic and leaf vegetation grown between 15 to 30km available I-131 analysis.

from the plant, preferably, in the least prevalent direction for wind blowing from the plant if milk sampling is not performed.

SUSQUEHANNA - UNIT 2 3. 11-42 EFFECTIVE DATE 08/31/1998

Monitoring Program

.3.11.4.1 TABLE 3.11.4.1-2 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES Reporting Levels Water Airborne Particulate Fish Milk Food Products (pCi/l) or Gases (pCi/m') (pCi/kg. wet) (pCi/i) (pCi/kg. wet)

Analysis H-3 20,000"')

Mn-54 1.000 30.000 Fe-59 400 10,000 Co-58 1,000 30.000 Co-60 300 10.000 Zn-65 300 20.000 Zr-Nb-95 400(b')

2 0.9 3 100 I-131 30 10 1,000 60 1,000 Cs-134 50 20 2,000 70 2.000 Cs-137 Ba-La-140 b) 300 2 00 S For drinking water samples. This is 40 CFR Part 141 value.

value of 30,000 pCi/l may be used.

If no drinking water pathway exists, a Total for parent and daughter.

SUSQUEHANNA - UNIT 2 3. 11-43 EFFECTIVE DATE 08/31/1998

Pu Monitoring Program 3.11.4.1 TABLE 3.11.4.1-3 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS .

LOWER LIMIT OF DETECTION (LLD)

Water Airborne Fish Milk Food Sediments Analysis (pCi/D) Particulate Or (pCi/kg. wet) (Ci/1) Products (pCi/kg.

Gas (pCi/n 3) p (pCi/kg. dry) wet)

Gross Beta 4 0.01 H-3 2000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 1-131 1i') 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15 15

(" LLD for drinking water samples.

SUSQUEHANNA - UNIT 2 3. 11-44 EFFECTIVE DATE 08/31/1998

Land Use Census 3.11 .4.2 3.11 Radioactive Effluents 3.11.4 Radiological Environmental Monitoring 3.11.4.2 Land Use Census TRO 3.11.4.2 A land use census shall be conducted.

APPLICABILITY: At all times.

RfPrT ACPI I, IkC, LIOTM I I CONDITION REQUIRED ACTION COMPLETION TIME t

A. Land use census A.1 Identify the new As defined by identifies a location(s) in the next the Annual location(s) which Annual Radioactive Radioactive Effluent and Waste Effluent and yields a calculated dose or dose Disposal Report Waste Disposal commitment greater Report than the values currently being calculated in Requirement 3.11.2.3 -I t B.1 Add the new location(s) 30 days B. Land use census identifies a to the radiological location(s) that environmental monitoring yields a calculated program dose or dose AND commitment (via the B.2 As defined in same exposure pathway) Identify the new location(s) in the next Annual 20 percent greater Radioactive than at a location Annual Radioactive Effluent Release Report Effluent Release from which samples are Report currently being per TS Section 5.6 obtained in accordance with Requirement 3.11.4.1 I=-

SUSQUEHANNA - UNIT 2 3.11-45 EFFECTIVE DATE 08/31/1998

Land Use Census 3.11.4.2 TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.4.2.1 Conduct the land use census 12 months SUSQUEHANNA - UNIT 2 3.11-46 EFFECTIVE DATE 08/31/1998

/ I

/I

Interlaboratory Comparison Program 3.11.4.3 3.11 Radioactive Effluents 3.11.4 Radiological Environmental Monitoring 3.11.4.3 Interlaboratory Comparison Program TRO 3.11.4.3 Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program.

APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Analyses not being A.1 Report the corrective As required performed actions taken to prevent a recurrence to the Commission TECHNICAL REQUIREMENT SURVEILLANCE SURVEILLANCE FREQUENCY TRS 3.11.4.3.1 Include a summary of the results obtained Annually as part of the above required Interlaboratory Comparison Program in the Annual Radiological Environmental Operating Report SUSQUEHANNA - UNIT 2 3.11-47 EFFECTIVE DATE 08/31/1998

Liquid Effluents Concentration B 3.11.1.1 B 3.11.1.1 Liquid Effluents Concentration BASES TRO This requirement isprovided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will be less than 10 times the concentration levels specified in 10 CFR Part 20.1001 to 20.2402, Appendix B.

Table 2, Column 2. The requirement provides operational flexibility for releasing liquid effluents in concentrations to follow the Section II.A and II.C design objectives of Appendix I to 10 CFR part 50. This limitation provides reasonable 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 50. to a Member of the Public and (2)restrictions authorized by 10 CFR 20.1301(e). The concentration limit for dissolved or entrained noble gases is based upon the assumptions that Xe-135 is the controlling radionuclide and its effluent concentration in air (submersion) was converted to an equivalent concentration in water. This requirement does not affect the requirement to comply with the annual limitations of 10 CFR 20.1301(a). This requirement 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 the other~detection limits can be found in Curie, L.A., "Lower Limit of Detection:

Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements."

(References 2, 3, and 4)

This section of the TRM is also part of the ODCM (Reference 2).

Actions The Actions are defined to ensure proper corrective measures are taken in response to exceeding the TRO limits.

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the parameters are maintained within the TRO limits. Table 3.11.1.1-1 defines Radioactive Liquid Waste Sampling and Analysis Program. The lower limit of detection (LLD) is defined, for purposes of these Requirements, as the smallest concentration of radioactive material in a sample that (continued)

SUSQUEHANNA - UNIT 2 B 3.11-1 EFFECTIVE DATE 8/31/1998

Liquid Effluents Concentration B 3.11.1.1 B 3.11.1.1 Liquid Effluents Concentration BASES (continued)

TRS will yield a net count, above system background, that will be (continued) detected with 95% probability with only 5%probability of falsely concluding that a blank observation represents a "real' signal. For a particular measurement system, which may include radiochemical separation:

LLD = 4.66s E.V.2.22E6 Y. exp(-At)

Where:

LLD is the a priori lower limit of detection as defined above (as microcuries per unit mass or volume).

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

E is the counting efficiency, as counts per disintegration, V isthe sample size, in units of mass or volume, 2.22 E6 is the number of disintegrations per minute per microcurie, Y isthe fractional radiochemical yield, when applicable.

A is the radioactive decay constant for the particular radionuclide, and At for plant effluents isthe elapsed time between the midpoint of sample collection and time of counting.

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

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

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

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-2 EFFECTIVE DATE 8/31/1998

Liquid Effluents Concentration B 3.11.1.1 B 3.11.1.1 Liquid Effluents Concentration BASES (continued)

TRS The principal gamma emitters for which the LLD specification (continued) applies include the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144.

The dissolved and entrained gases (gamma emitters) for which the LLD specification applies include the following radionuclides:

Kr-85, Kr-85m. Kr-87, Kr-88, Ar-41, Xe-133, Xe-133m, Xe-135, and Xe-135m. 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 accordance with the ODCM.

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 over a period no longer than the Minimum Analysis Frequency.

The Minimum Analysis Frequency as listed for the Composite Samples shall mean the minimum frequency for initiation of the required analyses, not completion of the analyses and evaluation of the results. Since the analysis involves sending the samples to an offsite laboratory and performance of involved sample preparation and wet chemical analyses, there will be a delay between initiation of the analysis and receipt of the results.

The analysis initiation shall'normally be done on a calendar month for the 31 day frequency or calendar quarter for a 92 day frequency.

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program.-,

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual.

3. NUREG/CR-4007, September, 1984.

4. 10 CFR Part 20.

SUSQUEHANNA - UNIT 2 B 3.11-3 EFFECTIVE DATE 8/31/1998

Liquid Effluents Dose B 3.11.1.2 B 3.11.1.2 Liquid Effluents Dose BASES TRO This requirement is provided to implement the requirements of Sections II.A, III.A and IV.A of Appendix I, 10 CFR Part 50. The Technical Requirement for Operation implements the guides set forth in Section II.A of Appendix I. Also, for fresh water sites with drinking water supplies which 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 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 Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. (References 2, 3. 4, and 5)

This section of the TRM is also part of the ODCM (Reference 2).

Actions 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 will be kept "as low as is reasonably achievable."

The Special Report to the Commission under Action A.1 shall (continued)

SUSQUEHANNA - UNIT 2 B 3.11-4 EFFECTIVE DATE 8/31/1998

Liquid Effluents Dose B 3.11.1.2 B 3.11.1.2 Liquid Effluents Dose BASES (continued)

ACTIONS . identify the cause(s) for exceeding the limit(s) and define the (continued) 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 specified limits. This Special Report shall also include the radiological impact on finished drinking water supplies at the nearest downstream drinking water source. -

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the TRO limits are maintained.

REFERENCES 1. Tech Spec 5.5.4 - Radioactive Effluent Controls program

2. Tech Spec 5.5.1 - Offsite Dose Calculation Manual

3. 10 CFR Part 20

4. 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.

5. Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for

-the Purpose of Implementing Appendix I."April 1977.

SUSQUEHANNA - UNIT 2 B 3.11-5 EFFECTIVE DATE 8/31/1998

Liquid Waste Treatment System B 3.11.1.3 B 3.11.1.3 Liquid Waste Treatment System BASES TRO 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 Requirement implements the requirements of 10 CFR Part 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. (Reference 3)

This section of the TRM is also part of the ODCM (Reference 2).

Actions The Actions are defined to ensure proper corrective measures are taken in response to the inoperable components.

The Special Report to the Commission under Action A.1 shall include the following:

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.

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the system is maintained OPERABLE. OPERABILITY is demonstrated by operating the liquid radwaste treatment system equipment for at least 10 minutes.

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program.

2. Technical Specification 5.5.1 - ODCM.

3. 10 CFR Part 50.

SUSQUEHANNA - UNIT 2 B 3.11-6 EFFECTIVE DATE 8/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation B 3.11.1.4 B 3.11.1.4 Liquid Radwaste Effluent Monitoring Instrumentation-BASES TRO The radioactive liquid-effluent instrumentation are 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 in accordance with the procedures in the ODCM (Reference 2) to ensure that the alarm/trip will occur prior to exceeding the 10 times the concentration values specified in Appendix B, Table 2. Column 2 of 10CFR20.1001 - 10CFR20.2401 (Ref. 2). 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. (Reference 4)

OPERABILITY of the radiation monitoring instrumentation requires their alarm/trip setpoints set to ensure that the limits of Requirement 3.11.1.1 are not exceeded. The alarm/trip setpoints of these channels shall be determined in accordance with the methodology and parameters described in the ODCM.

OPERABILITY of the Liquid Radwaste Effluent Line gross radioactivity monitor includes the proper functioning of the discharge valve interlocks (sample pump low flow, high radiation alarm, and radiation monitor failure).

OPERABILITY of the Cooling Tower Blowdown flow rate measurement device includes the proper functioning of the Liquid Radwaste Effluent Line discharge valve interlock (i.e. cooling' tower blowdown low flow).

The Required Channels for each function in Table 3.11.1.4-1 are as follows:

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-7 EFFECTIVE DATE 8/31/1998

Liquid Radwaste Effluent Monitoring Instrumentation B 3.11.1.4 B 3.11.1.4 Liquid Radwaste Effluent Monitoring Instrumentation BASES (continued)

TRO a. Liquid Radwaste Effluent rad monitor (Function 1.a) one (continued) instrument per station.

b. Liquid Radwaste Effluent flow rate (Function 2.a) one instrument per station.

c. Cooling Tower Blowdown flow rate (Function 2.b) one instrument per station.

It should be noted that the radioactive liquid waste stream is diluted in the Cooling Tower blowdown line prior to entering the Susquehanna River. The setpoint for this dilution water flow is 5000 gpm from the combination of the Unit 1 blowdown, Unit 2 blowdown flow, and Spray Pond Discharge.

Options exist to ensure the requirement of one OPERABLE Cooling Tower Blowdown flow Instrument per station is met as required by Table 3.11.1.4-1, Function 2.b. As long as any one of three instruments (Unit 1 Tower, Unit 2 Tower, Total Site Blowdown) are OPERABLE and alignment of HS-06443A and HSS-01503 on panel OC301 is such that the OPERABLE instrument(s) are in the circuit, then the TRM Requirement is met. ,-

This section of the TRM is also part of the ODCM (Reference 2).

Actions The Actions are defined to ensure proper corrective measures are taken in response to the inoperable components.

Pump curves generated in situ may be used to estimate flow for Action D.1.

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the monitoring instrumentation is maintained OPERABLE.

The TRSs shall be performed in accordance with the Technical Specification definition for the test with the following additional requirements:

The Liquid Radwaste Effluent Line radiation monitor CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and' control room alarm annunciation occur if any (continued)

SUSQUEHANNA - UNIT 2 B 3.11-8 EFFECTIVE DATE 8/31/1998

Liquid Radwaste.Effluent Monitoring Instrumentation B 3.11.1.4 B 3.11.1.4 Liquid Radwaste Effluent Monitoring Instrumentation BASES (continued)

TRS of the following conditions exist:

(continued) 1. Instrument indicates measured levels above the alarm/trip setpoint.

2. Circuit failure.

3. Instrument indicates' a downscale failure.

The liquid Radwaste Effluent Line radiation monitor initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NIST. These standards shall permit calibrating the system over its intended range of energy and

-measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration may be used in lieu of the reference standards associated with the initial calibration.

The Liquid Radwaste Effluent Line flow rate monitor and Cooling Tower Blowdown flow rate monitor 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.

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. 10 CFR Part 20 -

4. 10 CFR Part 50 SUSQUEHANNA - UNIT 2 B 3.11-9 SEFFECTIVE DATE 8/31/1998

Radioactive Liquid Process Monitoring Instrumentation I ' % B 3.11.1.5 B 3.11.1.5 Radioactive Liquid Process Monitoring Instrumentation BASES TRO The radioactive liquid process 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 in accordance with the procedures in the ODCM (Reference 2) to'ensure that the alarm/trip will occur prior to exceeding 10 times the concentration values specified in Appendix B. Table 2. Column 2 of.10CFR20.1001 - 20.2401 (Reference 3). 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. (Reference 4)

This section of the TRM is also part of the ODCM (Reference 2).

Actions The Actions are defined to ensure proper corrective measures are taken in response to the inoperable components.

If an RHR heat exchanger and its applicable RHRSW loop are in service there is a pathway from the heat exchanger to the spray pond. If the heat exchanger and RHRSW loop are not in service (i.e., valved-out, RHRSW pump not running, or piping drained) then a pathway does not exist.

If there is no pathway, the requirement to perform grab sampling is not applicable when the RHR Service Water System Effluent Line Radiation Monitor has been declared inoperable.

The function of pumping down the RHR heat exchanger and RHRSW system piping to the Spray Pond provides a pathway for a release of potentially radioactively contaminated water. The RHRSW system is considered an 80-10 system because a pathway to the environment from this system exists through the Spray Pond and because the system, although normally not radioactively contaminated, has the potential for becoming radioactively contaminated in the event that a leak develops across an RHR heat exchanger. Therefore, grab samples must be collected periodically when the RHRSW system radiation monitor for a particular loop is inoperable (malfunctioning) and water from that loop of the system is being returned to the Spray Pond.

Also, grab samples must be collected prior to operations in which water from the RHRSW system will be drained to the Spray Pond. (continued)

SUSQUEHANNA - UNIT 2 TRM / B 3.11-10 EFFECTIVE DATE 2/01/1999

Radioactive Liquid Process Monitoring Instrumentation B 3.11.1.5 BASES (continhued)

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the monitoring instrumentation is maintained OPERABLE.

Performance of the CHANNEL CHECK ensures that a gross failure of the instrument has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel against a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between instrument channels could be an indication of excessive instrument drift in one of the. channels or something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrument continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria, which are developed by the plant staff based on an investigation of a combination of the channel instrument uncertainties, may be used to support-this parameter comparison and include indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit and does not necessarily indicate the channel is inoperable.

The TRSs shall be performed in accordance with the Technical Specification definition for the test with the following additional requirements:

The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exists:

1. Instrument indicates measured levels above the alarm setpoint.

2. Circuit failure.

3. Instrument indicates a downscale failure. and

4. Instrument controls not set in operate mode.

(continued)

SUSQUEHANNA - UNIT 2 TRM/B 3.11-11 EFFECTIVE DATE 04/07/2000

1.

Radioactive Liquid Process Monitoring Instrumentation B 3.11.1.5 BASES (conti nued)

TRS The initial CHANNEL CALIBRATION shall be performed using one or (continued) more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration may be used in lieu of the reference standards associated with the initial calibration.

REFERENCES . 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. 10 CFR Part 20

4. 10 CFR Part 50 SUSQUEHANNA - UNIT 2 TRM/B 3.11-11a EFFECTIVE DATE 04/07/2000

Dose Rate B 3.11.2.1 B 3.11.2.1 Dose Rate BASES TRO This requirement provides reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a Member of the Public either within or outside the Site Boundary, in excess of the design objectives of Appendix I to 10CFR50. It provides operational flexibility for releasing gaseous effluents while satisfying section II.B and II.C design objectives of Appendix I. For individuals who may at 'times be within the Site Boundary. the occupancy of the individual will

-usually be sufficiently low to compensate for any increase in atmospheric diffusion factor above that for the Site Boundary.

The specified release rate limits restrict, at all times, the corresponding dose rates above background to a Member-of the Public at or beyond the Site Boundary to less than or equal to 500 mrem/yr to the total body or to less than or equal to 3000 mrem/yr to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above -

background to an individual via the inhalation pathway to less I than or equal to 1500 mrem/yr. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC 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. (Reference 3)

I This Requirement applies to the release of gaseous effluents from all reactors at the site.

This section of the TRM is also part of the ODCM (Reference 2).

(continued)

SUSQUEHANNA - UNIT 2 TRM / B 3.11-12 EFFECTIVE DATE 2/01/1999

- Dose Rate

- B 3.11.2.1 B 3.11.2.1 Dose Rate BASES (continued)

Actions The Actions are defined to ensure proper corrective measures are taken in response to the limits being exceeded.

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the dose rates are maintained within limits.

Dose rates are determined in accordance with the methodology and parameters of the ODCM.

Table 3.11.2.1-1 defines Radioactive Gaseous Waste Sampling and Analysis Program. The lower limit of detection (LLD) is defined, for purposes of these requirement, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a 'real" signal. For a particular measurement system, which may include radiochemical separation:

LLD = 4 . 66 Sb E

V

2.22E6

Y

exp(-XAt)

Where:

LLD is the a priori lower limit of detection as defined above.

(as microcuries per unit mass or volume),

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

E is the counting efficiency, as counts per disintegration.

V is the sample size, in units of mass or volume, 2.22 E6 is the number of disintegrations per minute per microcurie, Y is the fractional radiochemical yield, when applicable, A is the radioactive decay constant for the particular radionuclide, and At for plant effluents is the elapsed time between the midpoint of sample collection and time of counting (for plant effluents, not environmental samples).

(continued)

SUSQUEHANNA - UNIT 2 TRM / B 3.11-13 EFFECTIVE DATE 2/01/1999

Dose Rate B 3.11.2.1 B 3.11.2.1 Dose Rate BASES (continued)

TRS The value of sb used in the calculation of the LLD for a (continued) detection system shall be based.on the actual observed variance of the background counting rate or of the counting rate of the blank samples (as appropriate) rather than on an unverified theoretically predicted variance.. Typical values of E. V. Y.

and At shall be used in the calculation.

The principal gamma emitters for which the LLD specification applies include the following radionuclides: Kr-87. Kr-88. Xe-133. Xe-133m.. Xe-135. Xe-135m and Xe-138 for gaseous emissions and Mn-54. Fe-59, Co-58, Co-60. Zn-65. Mo-99. Cs-134. Cs-137.

Ce-141 and Ce-144 for particulate emissions. This list does not mean that only these nuclides are to be considered. Other gamma peaks which are identifiable, together with those of the above nuclides. shall also be analyzed and reported in the Annual Radioactive Effluent Release Report.

The design of the systems for the sampling of particulates and iodines provide for sample nozzle entry velocities which are approximately isokinetic with instack air velocities. Gaseous particulate and iodine samples are gathered continuously, with the sample size proportional to the stack emissions: a composite gaseous sample is a combination of all the particulate filters gathered in a sampling period.

Particulate or iodine sampling required to be in continuous service will be considered to remain and have been in continuous service when its service is interrupted for a time period not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per sampling period. For particulate and iodine sampling, this is a small fraction of the normal minimum analysis frequency.

The minimum Analysis Frequency as listed for the Composite Samples shall mean the minimum frequency for initiation of the required analyses, not completion of the analysis and evaluation of the results. Since the analysis involves sending the samples to an offsite laboratory and performance of involved sample preparation and wet chemical analyses, there will be a delay between initiation of the analysis and receipt of the results.

The analysis initiation shall normally be done on a calendar quarter for a 92 day frequency.

(continued)

SUSQUEHANNA - UNIT 2 TRM/B 3.11-14 EFFECTIVE DATE 11/01/1999

Dose Rate I4' B 3.11.2.1 B 3.11.2.1 Dose Rate BASES (continued)

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls Program

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. 10CFR Part 20 SUSQUEHANNA - UNIT 2 TRM / B 3.11-15 EFFECTIVE DATE 2/01/1999

Dose - Noble Gases B 3.11.2.2 B 3.11.2.2 Dose - Noble Gases BASES TRO This requirement is provided to implement the requirements of Sections II.B, III.A and IV.A of Appendix I, 10 CFR Part 50.

(Reference 5) The Technical Requirement for Operation implements the guides set forth in Section II.B of Appendix I.

This section-of the TRM is also part of the ODCM (Reference 2).

Actions 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 will be kept "as low as is reasonably achievable". -

The Special Report required under Action A.1 shall identify the cause(s) for exceeding the limit(s) and define 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.

TRS The TRSs 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 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, " Revision 1, October 1977 and Regulatory Guide 1.111.

"Methods for estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977. The ODCM equations provided for determining the air doses at and beyond the SITE BOUNDARY are based upon the historical average atmospheric conditions.

(References 2, 3 and 4)

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-16 EFFECTIVE DATE 8/31/1998

Dose - Noble Gases B 3.11.2.2 B 3.11.2.2 Dose - Noble Gases BASES (continued)

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program

2. Technical Specification Spec 5.5.1 - Offsite Dose Calculation Manual

3. Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I",

Revision 1, October 1977.

4. Regulatory Guide 1.111, "Methods for estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977.

5. 10 CFR Part 50.

I---\

SUSQUEHANNA - UNIT 2 B 3.11-17 EFFECTIVE DATE 8/31/1998

Dose - Iodine, Tritium, and Radionuclides in Particulates Form B 3.11.2.3 B 3.11.2.3 Dose - Iodine, Tritium, and Radionuclides in Particulates Form BASES TRO This requirement is provided to implement the requirements of Sections II.C, III.A and IV.A of Appendix I, 10 CFR Part 50. The Limiting Conditions for Operation are the guides set forth in Section II.C of Appendix I. (Reference 5)

This section of the TRM is also part of the ODCM (Reference 2).

Actions 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 will be kept" as low as is reasonably achievable."

The Special Report required under Action A.1 shall identify the cause(s) for exceeding the limit(s) and define 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.

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the TRO limits are maintained.

The ODCM calculational methods specified in the TRSs implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based onimodels 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 methods 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 1, July 1977. These equations also provide for determining the actual (continued)

SUSQUEHANNA - UNIT 2 B 3.11-18 EFFECTIVE DATE 8/31/1998

in Particulates Form Dose - Iodine, Tritium, and Radionuclides Dose - Iodine, Tritium, and Radionuclides in Particulates Form B 3.11.2.3 B 3.11.2.3 Dose - Iodine, Tritium, and Radionuclides in Particulates Form BASES (continued)

TRS doses based upon the historical average atmospheric conditions.

(continued) The release rate Requirements for iodine-131, iodine-133, tritium, and radionuclides in particulate form with half lives greater than 8 days are dependent on the existing radionuclide pathways to man inareas at and beyond the SITE BOUNDARY. The pathways which were examined in the development of these calculations were: 1) individual inhalation of airborne radio-nuclides, 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.

(References 2,3 and 4)

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program.

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual.

3. Regulatory Guide 1.109. "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

Revision 1,. October 1977.

4. Regulatory Guide 1.111, 'Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977.

5. 10 CFR Part 50 SUSQUEHANNA - UNIT 2 B 3.11-19 EFFECTIVE DATE 8/31/1998

GASEOUS RADWASTE TREATMENT SYSTEM B 3.11.2.4 B 3.11 2.4 GASEOUS RADWASTE TREATMENT SYSTEM BASES-TRO This TRO ensures that the GASEOUS RADWASTE TREATMENT SYSTEM is OPERABLE and in operation to reduce radioactive materials in gaseous waste prior to discharge when the main condenser air ejector (evacuation) system is in operation. This requirement provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable". This TRO implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and the design objectives given in Section Il.D of Appendix I to 10 CFR Part 50. The limits governing the use of the system were specified as a suitable fraction of the dose design objectives'set forth in Sections ll.B and

-I.C of Appendix 1,10 CFR Part 50, for gaseous effluents (Ref. 1).

This section of the TRM is part of the Offsite Dose Calculation Manual (Ref.

2) and implements the requirements of the Radiological Effluent Controls Program (Ref. 3).

ACTIONS The ACTIONS are defined to ensure proper corrective measures are taken in response to the inoperable components.

A.1 With the GASEOUS RADWASTE TREATMENT SYSTEM inoperable, action must be taken to restore it to OPERABLE status in order to maintain radioactive releases from the main condenser as low as reasonably achievable, and in compliance with regulatory requirements. The 7 day Completion Time is reasonable to perform repairs and to maintain radioactive release objectives.

B.1 If the Required Action and Completion Time of Condition A are not met, a Special Report must be prepared and submitted to the Commission. The 30 day Completion Time is reasonable for preparation of the report. The Special Report should include 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.

(continued)

SUSQUEHANNA - UNIT 2 TRM / B 3.11 -20 EFFECTIVE DATE 04/02/2002

GASEOUS RAD WASTE TREATMENT SYSTEM

- GASEOUS RADWASTE TREATMENT SYSTEM I B 3.11.2.4 B 3.11.2.4 GASEOUS RADWASTE TREATMENT SYSTEM I1/-"

BASES -

TRS The TRSs are performed at the specified Frequency to ensure that the GASEOUS RADWASTE TREATMENT SYSTEM is maintained OPERABLE. l TRS 3.11.2.4.1 l This surveillance requires verification that the GASEOUS RADWASTE TREATMENT SYSTEM is in operation when the main condenser air ejector (evacuation) system is in operation. The Frequency of 92 days is appropriate considering the performance of monthly dose projections.

REFERENCES 1. 10 CFR Part 50 l

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. Technical Specification 5.5.4 - Radioactive Effluent Controls program.

J SUSQUEHANNA - UNIT 2 TRM / B 3.11-20a EFFECTIVE DATE 04/02/2002

VENTILATION EXHAUST TREATMENT SYSTEM B 3.11.2.5 B 3.11.2.5 VENTILATION EXHAUST TREATMENT SYSTEM BASES TRO This TRO ensures that the appropriate portions of the VENTILATION EXHAUST TREATMENT SYSTEM, as described in the Offsite Dose Calculation Manual (ODCM) are OPERABLE at all times. The TRO is modified by a Note which requires that the appropriate portions of the VENTILATION EXHAUST TREATMENT SYSTEM be used to reduce radioactive materials in gaseous waste prior to their discharge when projected doses due to gaseous effluent releases from either reactor unit to areas at and beyond the SITE BOUNDARY would exceed 0.3 mrem to any organ in a 31 day period. This requirement provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as reasonably achievable." This TRO implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50, and the design objectives given in Section II.D of Appendix I to 10 CFR Part 50. The 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 ll.B and IL.C of Appendix I, 10 CFR Part 50, for gaseous effluents (Ref. 1) .

The VENTILATION EXHAUST TREATMENT SYSTEM is comprising of the following systems, as described in the ODCM:

The Unit 1 Reactor Building filtered exhaust system, including the following filters:

1F216A, IF216B,1 F217A,1 F217B,1 F218A,1 F218B, IF255A,1 F255B, 1F257A,1 F257B,1 F258A AND 1F258B.

The Unit 2 Reactor Building filtered exhaust system, including the following filters:

2F216A, 2F2166B, 2F217A, 2F2177B, 2F218A, 2F218B, 2F255A, 2F255B, 2F257A, 2F257B, 2F258A AND 2F258B.

The Unit 1 Turbine Building filtered exhaust system, including the following filters:

1F1 57A, 1F1 57B, 1F1 58A, and 1F1 58B.

The Unit 2 Turbine Building filtered exhaust system, including the following filters:

2F1 57A, 2F1 57B, 2F1 58A, and 2F1 58B.

(continued)

SUSQUEHANNA - UNIT 2 TRM/B, 3.1 1-21 EFFECTIVE DATE 04/02/2002

VENTILATION EXHAUST TREATMENT SYSTEM I B 3411.2.5 B 3.11.2.5 VENTILATION EXHAUST TREATMENT SYSTEM I' -

BASES -

TRO The Radwaste Building filtered exhaust system, including the following I (continued) filters:

OF355A and OF3556.

The Radwaste Degasifier exhaust system, including the following filters: I 0F372, OF373 and 0F374.

The Radwaste Tank Vent exhaust system, including the following filters: I OF358 and OF359.

The S&A Hot Shop exhaust system, including the following filters: I 0F716.

The Control Structure Filter Unit exhaust system, including the following I filters:

OF134, OF135, 0F137, OF1 38, 0F140, OF141, 0F143, and OF1 44.

This section of the TRM is part of the ODCM (Ref. 2) and implements the requirements of the Radiological Effluent Controls Program (Ref. 3).

I' ACTIONS The ACTIONS are defined to ensure proper corrective measures are taken in response to the inoperable components. Dose evaluations are performed when evolutions occur which result in an effluent path to the environment with some level of degraded treatment. In effect, degraded treatment renders the monthly dose projection per TRS 3.11.2.5.1 questionable. The dose evaluation is an estimated projection under the degraded conditions.

Dose evaluations should be performed under the following conditions:

1. When bypassing a treatment system (a preliminary evaluation prior to I bypassing the filter and a follow-up evaluation after the bypass);

(continued)

SUSQUEHANNA - UNIT 2 TRM/13 3.11 -22 EFFECTIVE DATE 04/02/2002 - N

VENTILATION EXHAUST TREATMENT SYSTEM l B 3.11.2.5 B 3.11.2.5 VENTILATION EXHAUST TREATMENT SYSTEM l e> BASES-ACTIONS 2. When placing an inoperable filter train in service (a preliminary l (continued) evaluation prior to starting the system and a follow-up evaluation after the system is in service); l

3. If a surveillance on a treatment system fails while the filter is in service; and

4. Any other event which results in degraded treatment. l The appropriate portion of the VENTILATION EXHAUST TREATMENT l SYSTEM will be declared inoperable if any of the following conditions exist: l

1. Failure of a surveillance test; l

2. Broken or non-functional component which prevents the system from being run (e.g. both 100% fans or one 50% fan in the system); or

3. Bypass or degradation of system filtration in which effluent flow continues without full treatment. l A.1 I With any portion of the VENTILATION EXHAUST TREATMENT SYSTEM inoperable, action must be taken to restore it to OPERABLE status. The 31 day Completion Time is a reasonable time frame to repair the inoperable components.

B.1 I If the Required Action and Completion Time of Condition A are not met, or gaseous waste is being discharged without treatment and in excess of the TRO limits, a Special Report must be prepared and submitted to the Commission. The 30 day Completion Time is reasonable for preparation of the report. The Special Report should include the following information:

1. Identification of the inoperable equipment or subsystems and the reason for inoperability l

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

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

SUSQUEHANNA - UNIT 2 TRM/I3 3.1 1-23 EFFECTIVE DATE 04/02/2002

I VENTILATION EXHAUST TREATMENT SYSTEM B 3.11.2.5 B 3.11.2.5 VENTILATION EXHAUST TREATMENT SYSTEM BASES -

TRS The TRSs are performed at the specified Frequency to ensure that the VENTILATION EXHAUST TREATMENT SYSTEM is maintained OPERABLE.

TRS 3.11.2.5.1 This surveillance requires that a dose projection be performed in accordance with the methodology and parameters in the ODCM. The dose projection is performed based on the most recently available effluent data.

If it is known prior to performing the dose projection that a treatment system will be out of service, and if data exists which indicates how the lack of treatment will impact effluents, these factors will be considered when performing the dose projection. The 31 day Frequency is consistent with Reference 3.

TRS 3.11.2.5.2 l This surveillance verifies that the VENTILATION EXHAUST TREATMENT SYSTEM is OPERABLE by operating the system > 10 minutes. Operation of the system for at least 10 minutes'provides sufficient time to verify the appropriate parameters are within their normal operating range. The Frequency of 92 days is appropriate considering the performance of monthly dose projections.

This TRS is modified by a Note which states that the TRS is not required to be performed if the appropriate system has been utilized to process radioactive gaseous effluents during the previous 92 days. This allowance is appropriate because actual processing of radioactive gaseous effluents demonstrates system OPERABILITY.

REFERENCES 1. 10CFR Part 50. I

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual. I

3. Technical Specification 5.5.4 - Radioactive Effluent Controls program. I SUSQUEHANNA - UNIT 2 TRM/I3 3.1 1-23a EFFECTIVE DATE 4/2/2002 ' i

Radioactive Gaseous Effluent Monitoring Instrumentation B 3.11.2.6 B 3.11.2.6 Radioactive Gaseous Effluent Monitoring Instrumentation BASES TRO 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 alarmltrip setpoints for these instruments shall be calculated in accordance with the procedures in the ODCM (Reference 2) to ensure that the alarm/trip will occur prior to exceeding the release rate limits corresponding to dose rates above background to a member of the public at or beyond the site boundary to

500 mremlyr to the total body or to < 3000 mrem/yr to the skin. These release rate limits also restrict the corresponding thyroid dose rate above background to a child via the inhalation pathway to

1500 mremlyr. 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. (References 3 and 4)

OPERABILITY requires their alarm/trip setpoints set to ensure that the limits of Requirement 3.11.2.1 are not exceeded. The alarm/trip setpoints of these channels shall be determined in accordance with the methodology and parameters in the ODCM.

This section of the TRM is also part of the ODCM (Reference 2).

ACTIONS The Actions are defined to ensure proper corrective measures are taken in response to the inoperable components.

Low range Noble Gas channel readings from the local vent monitor may be used to meet the requirement for a Noble Gas grab sample and grab sample analysis.

Noble Gas release grab samples are not required to be taken when there are no releases via that pathway. Effluent flow is to be determined by vent flow instrumentation or by a vent flow estimate every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Continuous sample collection shall be on the same basis as described in the Bases for TRO 3.11.2.1 Monitoring may be interrupted for up to 30 minutes to perform particulate filter/iodine cartridge changeout required by TRM Table 3.11.2-1 without entering the TRO ACTIONS.

(continued)

SUSQUEHANNA - UNIT 2 TRM/B 3.11 -24 EFFECTIVE DATE 03/21/2003

Radioactive Gaseous Effluent Monitoring Instrumentation B 3.11.2.6 B 3.11.2.6 Radioactive Gaseous Effluent Monitoring Instrumentation BASES (continued)

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the monitoring instrumentation is maintained OPERABLE.

The TRSs shall be performed in accordance with the Technical Specification definition for the test with the following additional requirements:

The CHANNEL FUNCTIONAL TEST for all noble gas activity.monitors.

Iodine Monitors, and Particulate Monitors shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exists:

1. Instrument indicates measured levels above the alarm/trip setpoint.

2. Circuit failure,

3. Instrument indicates a downscale failure, and

4. Instrument controls not set in operate mode.

The initial CHANNEL CALIBRATION for all noble gas activity monitors, Iodine Monitors, and Particula~te Monitors shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities with NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION. sources that have been related t6 the initial calibration may be used in lieu of reference standards associated with the initial calibration.

Particulate or iodine sampling required to be in continuous service will be considered to remain and have been in continuous service when its service is interrupted for a period of time not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per sampling period. For particulate and iodine sampling, this is a small fraction of the normal minimum analysis frequency.

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. 10 CFR Part 20

4. 10 CFR Part 50 SUSQUEHANNA - UNIT 2 TRM/B 3.11-25 EFFECTIVE DATE 11/01/1999

Total Dose B 3.11.3 B 3.11.3 Total Dose BASES TRO This Requirement is provided to meet the dose limitations of 40 CFR 190 that have been incorporated into 10 CFR 20 by 46 CFR 18525. The Requirement requires the preparation and submittal of a Special Report whenever the calculated doses from plant radioactive effluents exceed twice the design objective doses of Appendix I. For sites containing up to 4 reactors, it is highly unlikely that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR 190 if the individual reactors remain within the reporting requirement level. 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 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 5 miles must be considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR 190, the Special Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 is considered to be a timely request and fulfills the requirements of 40 CFR 190 until NRC staff action is completed. 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.

Reference 3 Actions The Actions are defined to ensure proper corrective measures are taken when requirements are not met.

Calculations required by Action B.1 shall include direct radiation contributions from both reactor units and from outside storage tanks to determine whether the limits of this TRO have been exceeded.

(continued)

SUSQUEHANNA - UNIT 2 - B 3.11-26 EFFECTIVE DATE 8/31/1998

Total Dose B 3.11.3 B 3.11.3 Total Dose BASES (continued)

ACTIONS The Special Report to be issued per Action B.1 shall define the (continued) corrective action to be taken to reduce subsequent releases, to prevent recurrence of exceeding the above limits, and include the schedule for achieving conformance with the above limits.

This Special Report 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.

r-'

TRS The TRSs are defined to be performed at the specified Frequency to ensure that requirements are implemented.

TRS 3.11.3.1 cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with TROs 3.11.1.2, 3.11.2.2, and 3.11.2.3, The direct radiation dose is determined from the results of radiation monitoring with TLDs that is conducted by the SSES REMP. The REMP TLDs are processed quarterly. There is no requirement to show compliance with the 40CFR190 dose limits more frequently than an annual basis.

Demonstration of compliance with this dose limit considers the combined dose contributions from liquid and gaseous effluents and direct radiation.

REFERENCES 1. Technical Specification 5.5.4 - Radioactive Effluent Controls program

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. 40 CFR 190 SUSQUEHANNA - UNIT 2' B 3.11-27 EFFECTIVE DATE 8/31/1998

Monitoring Program B 3.11.4.1 B 3.11.4.1 Monitoring Program BASES TRO The radiological environmental monitoring program required by this Requirement provides representative measurements of radiation and-of radioactive materials in those environmental exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation. This monitoring program thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements' and modeling of the environmental exposure pathways. Changes to-the radiological environmental monitoring program specified in Table 3.11.4.1-1 may be made based on expected SSES operation and the results of radiological environmental monitoring during SSES operation.

The required detection capabilities for environmental'sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table 3.11.4.1-3 are considered optimum for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the-capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually);

Currie, L. A., "Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry" Anal. Chem. 40, 586-93 (1968); and Hartwell, J. K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

(Reference 1)

This section of the TRM is also part of the ODCM (Reference 2).

Actions The Actions are defined to ensure proper corrective measures are taken when requirements are not met.

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-28 EFFECTIVE DATE 8/31/1998

Monitoring Program B 3.11.4.1 B 3.11.4.1 Monitoring Program BASES (continued) , N ACTIONS Per Action A.1, the Annual Radiological Environmental Operating (continued) Report shall provide a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

The Special Report submitted per Action B.1 shall identify the cause(s) for exceeding the limit(s) and define 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 Requirements 3.11.1.2, 3.11.2.2 and 3.11.2.3.

Include revised figure(s) and table for the ODCM reflecting the new locations for obtaining samples per Action F.1 in the next Annual Radioactive Effluent Release Report.

TRS The TRSs are defined to be performed at the specified frequency to ensure that the requirements are implemented. Monitoring samples collected per TRS 3.11.4.1.1 shall be from the specific locations given in the table and figure in the ODCM. (Reference 2)

Table 3.11.4.1-1 Sample Locations 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 this Table and 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. (Reference 3) 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 (continued)

SUSQUEHANNA - UNIT 2 B 3.11-29 EFFECTIVE DATE 8/31/1998

Monitoring Program B 3.11.4.1 B 3.11.4.1 Monitoring Program BASES (continued)

TRS period. All deviations from the sampling schedule shall be (continued) documented in the Annual Radiological Environmental Operating Report. 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. Identify the cause of the unavailability of samples for that pathway and identify the new location(s) for obtaining replacement-samples in the next Annual Radioactive

-Effluent Release Report and also include in the report a revised figure(s) and table for the ODCM reflecting the new location(s).

Direct Radiation 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 phosphr,;' 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.

Radioiodine and Particulates - Sampling and Collection Frequency The charcoal cartridges used in the airborne radioiodine sampling conducted as part of the radiological environmental monitoring program are designed and tested by the manufacturer to assure a high efficiency in the capture of radioiodine.- Certificates from the

-manufacturer'of the cartridges are provided with each batch of cartridges certifying the percent retention of the radiodine for stated air flows.

Radioiodine and'Particulates - Particulate Sample; Waterborne -

Surface, Ground, Sediment; Food Products Gamma isotopic analysis means the identification-and quantification of gamma-' emitting radionuclides that may be attributable to the effluents from the facility.

Waterborne - Surface The "upstream sample" shall be taken at a distance beyond significant influence of the discharge. The "downstream" sample shall be taken in the discharge line.

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-30 EFFECTIVE DATE 8/31/1998

Monitoring Program B 3.11.4.1 B 3.11.4.1 Monitoring Program BASES (continued),

TRS Waterborne - Drinking - Sampling and Collection Frequency A (continued) composite sample is one inwhich the quantity (aliquot) of liquid sampled is proportional to the quantity of flowing liquid and inwhich the method of sampling employed results in a specimen that is representative of the liquid flow. In this program composite samples shall be collected at time intervals that are veryshort (e.g., hourly) relative to the compositing period (e.g., monthly) inorder to assure obtaining a representative sample.

Waterborne - Ground - Samples and Sample Locations 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.

Drinking Water 131 Analyses Calculation of the dose projected from I-131 in drinking water to determine if I-131 analyses of the water are required shall be performed for the maximum organ and age group using the methodology and parameters of the ODCM.

Food Products - Sampling and Collection Frequency If harvest occurs more than once a year, sampling shall be performed during each discrete harvest. Ifharvest occurs continuously, sampling shall be monthly. Attention shall be paid to including samples of tuborous and root food products.

Table 3.11.4.1-3 This list does not mean that only these nuclides are to be considered. Other peaks that are identifiable at 95X confidence level together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Operating report.

Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. (Reference 4)

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-31 EFFECTIVE DATE 8/31/1998

Monitoring Program B 3.11.4.1 B 3.11.4.1 Monitoring Program BASES (continued)

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

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

LLD= 4.66s EeV 2.22.Y-exp(-AAt)

Where:

LLD is the a priori lower limit of detection as defined above (as picrocuries per unit mass or volume),

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

E is the counting efficiency, as counts per disintegration, V is the sample size, in units of mass or volume, 2.22 is the number of disintegrations per minute per picrocurie, Y is the fractional radiochemical yield, when applicable, X is the radioactive decay constant for the particular radionuclide, and At for environmental samples is the elapsed time between sample collection (or end of the sample collection period) and time of counting.

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

(continued)

SUSQUEHANNA - UNIT 2 B 3.11-32 EFFECTIVE DATE 8/31/1998

Monitoring Program B 3.11.4.1 B 3.11.4.1 Monitoring Program BASES (continued)

\-

TRS It should be recognized that the LLD is defined as a priori (continued (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement. Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDS unachievable. In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report.

REFERENCES 1. HASL Procedures Manual, HASL-300 (revised annually); Curie, L.A., "Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry" Anal .Chem.

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

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual

3. 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.

4. Regulatory Guide 4.13 SUSQUEHANNA - UNIT 2 B 3.11-33 EFFECTIVE DATE 8/31/1998

Land Use Census B 3.11.4.2 B 3.11.4.2 Land Use Census BASES (5

TRO The Land Use Census shall identify within a distance of 8 km of miles) the location in each of the 16 meteorological sectors the nearest milk animal, the nearest residence and the nearest garden of greater than 50m` (500ft ) producing broad leaf 2

vegetation.

This Requirement is provided to ensure that changes in the use that of areas at and beyond the SITE BOUNDARY are identified and by modifications to the monitoring program are made if required the results of this census. The best information from the door-to-door survey, aerial survey or consulting with local agricultural authorities or any combination of these methods shall be used. This census satisfies the requirements of Section to IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census that gardens of greater than 500 square feet provides assurance 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 a

vegetables assumed inRegulatory Guide 1.109-for consumption by child. To determine this minimum garden size, the following assumptions were used: 1) that 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/square meter.

(Reference 1 and 2)

Broad leaf vegetation sampling of at least three different kinds of of vegetation may be performed at the site boundary in each two different direction sectors with the highest predicted D/Qs in lieu of the garden census. Specifications for broad leaf vegetation sampling inTable 3.11.4.1-1 item 4c shall be followed, including analysis of control samples.

3).

This section of the TRM is also part of the ODCM (Reference are Actions The Actions are defined to ensure proper corrective measures taken inwhen requirements are not met.

(continued)

B 3.11-34 EFFECTIVE DATE 8/31/1998 SUSQUEHANNA - UNIT 2

Land Use Census B 3.11.4.2 B 3.11.4.2 Land Use Census BASES (continued)

ACTIONS The sampling location(s), excluding the control station (continued) location, having the lowest calculated dose, or dose commitment(s) (via the same exposure pathway) may be deleted from the monitoring program after October 31 of the year in which the land use census was conducted.

TRS The TRSs are defined to be performed-at the specified Frequency to ensure that the requirements are implemented.

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 consulting local agriculture authorities.

The results of the land use census shall be included in the Annual Radiological Environmental Operating Report.

REFERENCES 1 10 CFR Part 50 2 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 3 Technical Specification 5.5.1 - Offsite Dose Calculation Manual SUSQUEHANNA - UNIT 2 B 3.11-35 EFFECTIVE DATE 8/31/1998

Interlaboratory Comparison Program B 3.11.4.3 B 3.11.4.3 Interlaboratory Comparison Program BASES TRO *The Interlaboratory Comparison Program shall be accepted by the I Commission. The requirement for participation in an Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid for the purpose of Section IV.B.2 of Appendix I to 10 CFR Part 50. (Reference 1)

This part of the TRM is also part of the ODCM (Reference 2)

Actions The Actions are defined to ensure proper corrective measures are taken in response to the detection of unacceptably large deviations (systematic biases) from known values for the quantities being measured.

The corrective actions taken to prevent a recurrence shall be reported to the Commission in the Annual Radiological Environmental Operating Report.

TRS The TRSs are defined to be performed at the specified Frequency to ensure that the requirements are implemented.

REFERENCES 1. 10 CFR Part 50

2. Technical Specification 5.5.1 - Offsite Dose Calculation Manual SUSQUEHANNA - UNIT 2 TRM / B 3.11-36 EFFECTIVE DATE 2/12/1999

PLA-5618, Radioactive Effluent Release Report & Offsite Dose Calculation Manual PLA-5618, Bases B 3.11 - B 3.11.4.3

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