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| number = ML18127A217
| number = ML18127A217
| issue date = 05/01/2018
| issue date = 05/01/2018
| title = 2017 Annual Radioactive Effluent Release Report
| title = Annual Radioactive Effluent Release Report
| author name =  
| author name =  
| author affiliation = Dominion Energy Nuclear Connecticut, Inc
| author affiliation = Dominion Energy Nuclear Connecticut, Inc
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=Text=
=Text=
{{#Wiki_filter:ATTACHMENT 2 Serial No. 18-176 Docket Nos. 50-245 50-336 50-423 License Nos. DPR-21 DPR-65 NPF-49 201& RADIOACTIVE EFFLUENT RELEASE REPORT VOLUME 2 MILLSTONE POWER STATION UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)
{{#Wiki_filter:}}
I I l MILLSTONE POWER STATION STATION PROCEDURE SroP Acr 8EVIEW Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)
MP-22-REC-BAPOl Rev. 029 Approval Date: 04/03/17 Effective Date: 04/04/17 Millstone All Units Station Procedure Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)
TABLE OF CONTENTS I. Radiological Effluent Monitoring Manual (REMM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 LB. Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 LC. Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1. Liquid Effluent Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . 7 2. Liquid Radioactive Wast e Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 I.D. Gaseous Effluents
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................................ . 23 1. Gaseous Effluent Sampling and Analysis Program .................. . 23 2. Gaseous Radioactive Waste Treatm e nt ........................... . 31 I.E. Radiological Environmental Monitoring
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........ . 36 1. Sampling and Analysis ......................................... . 36 2. Land Use Census ............................................. . 46 3. Interlaboratory Comparison Program ............................ . 4 6 I.F. Report Content .................................................... . 47 1. Annual Radiological Environmental Operating Report .............. . 47 2. Radioactive Effluent Release R e port ............................. . 48 II Off-Site Dos e Calculation Manual (ODCM) ................................ . 51 II.A. Introduction
...................................................... . 51 II.B. Responsibilities
..........................
.......................... . 51 II.C. Liquid Dose Calculations
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......................... . 52 1. Monthly , Quarterly, and Annual Dose Calculation (Applicabl e to All Units) ....................................... . 52 2. Monthly Dose Projections
...................................... . 52 II.D. Gaseous Dose Calculations
.......................................... . 55 1. Site Release Rate Limits ("Instantaneous")
....................... . 55 2. 10 CFR50 Appendix I -Noble Gas Limits ...................
..... . 57 3. 10 CFR50 Appendix I -Iodine, Tritium and Particulate Doses ....... . 59 4. Gaseous Effluent Monthly Dose Projections
....................... . 60 5. Compliance with 40CFR190 ..........................
.......... . 6 3 II.E. Liquid Discharge Flow Rates And Monitor Setpoints
............
........ . 64 1. Unit 1 Liquid Waste Effluent Discharge (RE-MG-110)
............ . 64 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 1 of 137 I 
: 2. Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 3. Unit 2 Clean Liquid Radwaste Effluent Line -RM9049 and Aerated Liquid Radwaste Effluent Line -RM9116 . . . . . . . . . . . . . . . . . . . . . . . . . 65 4. Condensate Polishing Facility Waste Neutralization Sump Effluent Line -CND245 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 5. Unit 2 Steam Generator Blowdown -RM4262 and Unit 2 Steam Generator Blowdown Effluent Conc e ntration Limitation . . . . . . . . . . . . . . . . . . . . . . . 69 6. Unit 2 Condenser Air Ejector -RM5099 ............
..............
69 7. Unit 2 Reactor Building Closed Cooling Water RM6038 and Unit 2 Service Wat e r , and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 8. Unit 3 Liquid Waste Monitor -LWS-RE70 . . . . . . . . . . . . . . . . . . . . . . . 71 9. Unit 3 Regenerant Evaporator Effluent Line -LWC-RE65 . . . . . . . . . 73 10. Unit 3 Wast e Neutralization Sump Effluent Line -CND-RE07 ...... 73 11. Unit 3 Steam Generator Blowdown -SSR-RE08 and Unit 3 Steam G e nerator Blowdown Effluent Conc e ntration Limitation . . . . . . . . . . . . . 73 12. Unit 3 Turbine Building Floor Drains Effluent Lin e -DAS-RE50 and Unit 3 S e rvice Water and Turbine Building Sump Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 II.F. Gaseous Monitor Setpoints . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 1. Unit 1 Spent Fuel Pool Island Monitor -RM-SFPI-02 . . . . . . . . . . . . . 76 2. Unit 2 Wide Range Gas Monitor (WRGM) -RM8169 . . . . . . . . . . . . . . 76 3. Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 4. Unit 3 SLCRS -HVR-RE19B
..............................
.... 77 5. Unit 2 V e nt -Noble Gas Monitor -RM8132B .................... 77 6. Unit 2 Waste Gas Decay Tank Monitor RM9095 ....................
77 7. Unit 3 Vent Noble Gas Monitor -HVR-RElOB
................... 78 8. Unit 3 Engineering Safeguards Building Monitor -HVQ-RE49 ...... 78 III REMODCM Unit One Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 III.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 III.B. Definitions and Surveillance Requirement (SR) Applicability . . . . . . . . . . . . . . 82 III.C. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . . 85 1. Radioactive Liquid Efflu e nt Monitoring Instrumentation . . . . . . . . . . . . . 85 2. Radioactive Gaseous Effluent Monitoring Instrum e ntation . . . . . . . . . . . 88 III.D. Radioactive Effluents Concentrations And Dose Limitations . . . . . . . . . . . . . . . 91 1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 2. Radioactiv e Gaseous Efflu e nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93 III.E. Total Radiological Dose From Station Operations Controls . . . . . . . . . . . . . . . . 97 IV REMODCM Unit Two Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 IVA. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 2 of 137 IVB. Definitions , Applicability and Surveillance Requirements . . . . . . . . . . . . . . . . . 99 IVC. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . 103 1. Radioactiv e Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . 103 2. Radioactive Gaseous Effluent Monitoring Instrum e ntation . . . . . . . . . . 107 IVD. Radioactive Effluents Conc e ntrations And Dose Limitations . . . . . . . . . . . . . . 111 1. Radioactiv e Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 2. Radioactiv e Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113 IVE. Total Radiological Dos e From Station Op e ration . . . . . . . . . . . . . . . . . . . . . . . 117 V REMODCM Unit Thr ee Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119 VA. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119 VB. D efini tions and A pplicability an d Surv e illanc e R e quir eme nts . . . . . . . . . . . . . 119 VC. Radioactive Effluent Monitoring Instrum e ntation . . . . . . . . . . . . . . . . . . . . . . . 122 1. Radioactiv e Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . 122 2. Radioactiv e Gas e ous Effluent Monitoring Instrum e ntation . . . . . . . . . . 126 VD. Radioactive Effluents Conc e ntrations And Dose Limitations . . . . . . . . . . . . . . 131 1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131 2. Radioactive Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133 VE. Total Radiological Dose From Station Op era tions . . . . . . . . . . . . . . . . . . . . . . . 137 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 3 of 137 TABLES AND FIGURES TABLES Table I.C.-1, " Millstone Unit 1 Radioactive Liquid Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Table I.C.-2, "Millstone Unit 2 Radioactiv e Liquid Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Table I.C.-3 , "Millstone Unit 3 Radioactiv e Liquid Wast e Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Table I.D.-1 , " Millstone Unit 1 Radioactive Gaseous Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Table I.D.-2, "Millstone Unit 2 Radioactiv e Gaseous Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Table I.D.-3 , " Millstone Unit 3 Radioactiv e Gaseous Wast e Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Table I.E. -1, " Millstone Radiological Environmental Monitoring Program" . . . 38 Table I.E.-2 , "E nvironmental Monitoring Program Sampling Locations" . . . . . . 39 Table I.E.-3, Reporting Levels For Radioactivity Conc e ntrations In Environmental Samples ..............................................
......... 43 Table I.E.-4 , Maximum Values For Lower Limits Of Det e ction (LLD) ....... 44 Table App. II.A. -1 , " Millstone Effluent R equirements and Methodology Cross Reference" ............
......................................... . Table III.C.-1, " Radioactive Liquid Effluent Monitoring Instrumentation" . . . . 86 Table III.C.-2, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance R e quirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87 Table III.C.-3 , " Radioactive Gas e ous Effluent Monitoring Instrum e ntation" . . 89 Table III.C.-4, " Radioactive Gas e ous Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90 Table IV.C.-1 , " Radioactive Liquid Effl u ent Monitoring Instrumentation" . . . 104 Table IV.C.-2, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 Tabl e IV.C.-3, " Radioactive Gaseous Effluent Instrumentation" . . . . . . . . . . . 108 Table IV.C.-4 , " Radioactive Gaseous Effluent Monitoring Instrumentation Surveillanc e Requirem e nts" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 Table V.C.-1 , " Radioactive Liquid Effl u ent Monitoring Instrumentation" . . . . 123 Table V.C.-2, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125 Table V.C.-3 , "Radioactive Gaseous Effluent Monitoring Instrumentation" . . 127 Table V.C.-4 , " Radioactiv e Gaseous Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 4 of 137 FIGURES Figure I. C.-1, " Reserved" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Figure I.C.-2 , " Simplified Liquid Effluent Flow Diagram Millstone Unit 2 21 Figure I.C.-3, "Simplified Liquid Effluent Flow Diagram Millstone Unit 3 .... 22 Figure I.D. -1, "Simplified Gaseous Effluent Flow Diagram Millstone Unit One" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Figure I.D.-2, " Simplified Gaseous Effluent Flow Diagram Millstone Unit Two" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Figure I.D.-3 , " Simplified Gaseous Effluent Flow Diagram Millston e Unit Three" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Figure I.E.-1 , "Inner TLD, Air , Grass , Soil, and Aquatic Locations" ......... 41 Figure I.E.-2, " Outer TLD and Aquatic Locations
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42 Figure III.D. -1, " Site Boundary for Liquid and Gaseous Effluents" . . . . . . . . . . 96 Figure IV.D. -1, " Sit e Boundary for Liquid and Gaseous Effluents" . . . . . . . . . . 116 Figur e VD. -1, " Sit e Boundary for Liquid and Gaseous Effluents" . . . . . . . . . . 136 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 5 of 137 SECTION I. Radiological Effluent Monitoring Manual (REMM) For the Millstone Nuclear Power Station Nos. 1, 2, & 3 Docket Nos. 50-245, 50-336, 50-423 MP-22-REC-BAPOl STOP THINK ACT REVIEW Rev. 029 6 of 137 SECTION I. RADIOLOGICAL EFFLUENT MONITORING MANUAL (REMM) I.A Introduction The purpose of Section I of this manual is to provide the sampling and analysis programs which provide input to Section II for calculating liquid and gaseous effluent concentrations and offsite dos e s. Guidelines are provided for operating radioactive waste treatment systems in order that offsite doses are kept As-Low-As-Reasonably-Achievabl e (ALARA). The Radiological Environmental Monitoring Program outlined within this manual provides confirmation that the measurable concentrations of radioactive material in the environment as a result of operations at the Millstone Site are not higher than expect e d. In addition , this manual outlines the information required to be submitted to the NRC in both the Annual Radiological Environmental Operating Report and the Radioactive Effluent Release Report. MP-22-REC-REF03, " REMODCM Technical Information Document (TID)," has additional bases and technical information.
It also contains a list of exceptions to Regulatory Guide 1.21 ( see Section 2 of the TID). I.B. Responsibilities All changes to the Radiological Effluent Monitoring Manual (REMM) shall be reviewed and approved by the Facility Safety Review Committee prior to implementation.
All changes and their rationale shall be documented in the Radioactive Effluent Release Report. It shall be the responsibility of the Site Vice President Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications. The delegation of implem e ntation responsibilities is delineated in MP-22-REC-PRG, "Radiological Effluent Program." I.C. Liquid Effluents
: 1. Liquid Effluent Sampling and Analysis Program Radioactive liquid wastes shall be sampled and analyzed in accordance with the program specified in Table I.C.-1 for Millstone Unit No. 1, Table I.C.-2 for Millstone Unit No. 2 , and Table I.C.-3 for Millstone Unit No. 3. The r e sults of the radioactive analyses shall be input to the methodology of Section II to assure that the concentrations at the point of release are maintained within the limits of Radiological Effluent Controls (Section III.D.l.a. for Millstone Unit No. 1, Section IVD.l.a. for Millstone Unit No. 2, and Section VD.La. for Millstone Unit No. 3). STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 7 of 137 Table I.C.-1 Millstone Unit 1 Radioactive Liquid Wa s t e Sampling and Analysis Program Liquid Relea se Source Any Batch R e l ease from a n y so ur ce Sample 'fype and Minimum Analysis Frequency Frequency Gra b samp l e prior to Prior to eac h batch eac h b atc h releaseB re l ease Gra b samp l e prior to Pri or to initi al b a t c h re-in i t ial batch re l ease l ease from each so urce. fro m a n y one so urc e Quarterly for each a nd qu arte rl y compos-source.0 ite th e r eafterC Table I.C. -1 TABLE NOTATIONS
'fype of Lower Limit Radioactivity of Detection Analysis (LLD)A (µCi/ml) Principal Gamma 5 X lQ-7 Emitters Kr-85 1 X 10-S H-3 1 X lQ-S Gross a lph a 1 X lQ-7 Sr-90 5 X 10-S Fe-55 1 X 10-6 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. For a particular measurement system (which may include radiochemical separation):
LLD= 4.66 Sb (E)(V)(2.22x l0 6)(Ye-AL1~
Where:
* LLD is the lower limit of detection as defined above (as µCi per unit mass or volume) I
* 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 transformation)
* V is the sample size (in units of mass or volume)
* 2.22 x 10 6 is the number of transformations per minute per µCi
* Y is the fractional radiochemical yield (when applicable)
* "' is the radioactive decay constant for the particular radionuclide
* Lit is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 8 of 137 Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes , the presence of interfering nuclides , or other uncontrollable circumstances may render these LLDs unachievable.
In such cases , the contributing factors will be identified and recorded on the analysis sheet for the particular sample. B. Prior to the sampling , each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent m i xing provided.
C. A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.
Prior to analysis , all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.
D. For sources with no release during previous quarter , a quarterly sample is not required.
STOP THINK ACT MP-22-REC-BAPO l REVIEW R ev. 0 29 9 o f 137 Table I.C.-2 Millstone U nit 2 Radioactive Liquid Waste Sam plin g and Analysis Program Liquid R e l ease Sample 'fy p e and Minimum Analysis So urce Freq u ency Frequency A.Batch Relea seB. l.Clean Waste Moni-Grab samp le prior to Prior to each batch tor Tank. each batch release release 2.Aerated Waste Monitor Tanlc 3.Steam Generator Bu]kD. 4.Condensate Polishing Facility Quarterly
-Waste Neutralization CompositeF.,G. SumpE* B.Continuou s Release l.Steam Generator BlowdownH*
2.Service Water Effl u ent 1* 3.Turbine SumpsL 4.RBCCW SumpM. D a ily Grab Sample!.&
Weekly prior to aligning to Compos it eF.,G. Long Island Sound for RBCCW sump Monthly Grab Monthly Sample Weekly Grab or Com-Monthly posite CompositeF.
, G. Weekly Composite Quarterly Composi t eF.,G. TABLE I.C.-2 TABLE NOTATIONS Type of Lower L imit Radioactivity of Detection Ana l ys i s (LLD)A (µC i/m l) Principal Gamma 5 X 10-7 EmittersC*
I-131 1 X 10-6 Ce-144 5 X 10-6 Dissolved
& 1 X lQ-S Entrai n ed GasesK. H-3 1 X 10-5 Gross alpha 1 X 10-7 Sr-89 , Sr-90 5 X 10-8 Fe-55 1 X 10-6 Principal Gamma 5 X 10-7 EmittersC.
1-131 1 X 10-6 Ce-144 5 X 10-6 Dis solved & 1 X 10-S Entrained GasesK H-3N* 1 X lQ-S Gross alpha 1 X 10-7 Sr-89 , Sr-90 5 X lQ-8 Fe-55 1 X 10-6 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. For a particular measurement system (which may include radiochemical separation):
LLD = 4.66 Sb (E)(V)(2.22xl06)(Y e-lL1 f) STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 10 of 137 Where:
* LLD is the lower limit of detection as defined above (as µCi 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 transformation)
* V is the sample size (in units of mass or volume)
* 2.22 x 10 6 is the number of transformations per minute per µCi
* Y is the fractional radiochemical y i eld (when applicable)
* A is the r a d i oactive d eca y constant fo r the part i cular radionuclide
* A t is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measur e ment. Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.
Occasionally background fluctuations , unavoidably small sample sizes , the presence of interfering nuclides , or other uncontrollable circumstances may render these LLDs unachievable. In such cases , the contributing factors will be ident i fied and recorded on the analysis sheet for the particular sample. B. A batch release i s the discharge of l i quid wastes of a d i screte volume from the tanks listed in this table. Prior to the sampl i ng , each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided.
If the steam generator bulk can not be recirculated prior to batch discharge , a sample will be obtained by representative compositing during discharge. C. The LLD will be 5 x 1 o-7 µC i/ml. The principal gamma emitters for which this LLD applies are exclusively the following rad i onuclides: Mn-54 , Fe-59 , Co-58 , Co-60 , Zn-65 , Mo-99 , Cs-134, Cs-137 , and Ce-141. Ce-144 shall also be measured , but with an LLD of 5 x 10-6 µC i/ml. This list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and i dentifiable , together with the above nuclides , shall also be i dentified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at t he LLD level. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. D. For the Steam Generator Bulk: lE the applicable batch gamma radioact i vity is not greater than 5 x 1 o-7 µCi/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 are not required.
STOP TH IN K AC T MP-22-REC-B APOl REVIEW R ev. 0 29 11 o f 13 7 E. For the Condensate Polishing Facility (CPF) waste neutralization sump: lE there is no detectable tritium in the steam generators , THEN tr i t i um sampling and analyses is not required.
lE the gross gamma radioactivity in the g r ab sample taken prior to release does not exceed 5 x 1 o-7 µCi/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 and Fe-55 are not required. F. For Batch Releases and Steam Generator Slowdown only , a composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released. G. Pr i or to analysis , all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released. H. For t he Steam Generator Slowdown: lE the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 µC i/ml , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89 , Sr-90 and Fe-55 are not required. For the purposes of this footnote , if steam I generator samples are not available , condensate water gamma radioactivity may be used during times of blowdown. I. Daily grab samples shall be taken at least five days per week. For service water , daily grabs shall include each train that is in-service. For steam generator blowdown , condensate may be I sampled during blowdown if steam generator sample is not available.
J. For the Service Water: IF a weekly gamma analysis does not ind i cate a gamma radioactivity greater than 5 x1 o-7 µCi/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 a r e not required. K. LLD applies exclusively to the following radionuclides:
Kr-87, Kr-88 , Xe-133 , Xe-133m , Xe-135 , and Xe-138. This list does not mean that only these nuclides are to be detected and reported.
Other peaks wh i ch are measurable and identifiable , together with the above nuclides , shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the " Radioactive Effluent Release Report." L. For the Turbine Building Sump: lE there is no detectable tritium in the secondary side before an outage , THEN tritium sampling and analyses is not required during an outage. IF the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 µCi/ml , OR sump is directed to radwaste treatment , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89 , Sr-90 and Fe-55 are not required.
lE the release pathway is directed to yard drains , THEN the LLD for 1-131 shall be 1.5 x 1 o-7 µCi/ml and for gross alpha 1 x 1 o-a µCi/ml. S T OP THI N K AC T MP-22-REC-B APOl R E VI EW R ev. 0 29 12 of 137 M. For the RBCCW Sump: IE the RBCCW Sump is directed to radwaste treatment or is not aligned to Long Island Sound , THEN sampling is not required.
IF the applicable batch gamma radioactivity is not greater than 5 x 1 o-7 µCi/ml, THEN sampling and analysis schedule for gross alpha, Sr-89, Sr-90 , Fe-55 are not required. N. Detectable tritium shall be used to estimate tritium releases to the atmosphere via the blowdown tank vent. STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 13 of 137 Table I.C. -3 Mill s tone U nit 3 Radioacti v e Liquid Wa s te Sa mplin g a nd Anal ys i s Program Liquid R e lea se Sampl e 'fy p e and M inimum An a l ys i s S ourc e Fre qu e nc y Fr e qu e nc y A.B a tch Relea seB-I.Condensate Poli sh-Grab sample prior Prior to each batch ing Faci li ty Wast e t o each b atch re l ease re l ease Neutralization SumpE-2. Waste Tes t Tanks 3.Low Leve l Wast e Tank 4.Boron Test Tanks 5.Steam Generator Bulk D. Quarterly CompositeF.,G. B.Continuou s Rel eas e I.St ea m Ge n erator BlowdownH-2.Service Water Ef-fluent 1* 3.Turbine Bui lding SumpsL Dai l y Grab Sam pl e!. Weekly CompositeF.
, G. Monthly Grab Monthly Samp l e W ee kl y Grab or Com-Mont hl y posite W ee kly Composite CompositeF.,G. Qu arte rly CompositeF.,G.
TABLE I.C.-3 TABLE NOTATIONS
'fy pe of Low e r Limit Radioacti v i ty of Detection An al ys i s (LLD)A (µC i/ml) Principal Gamma 5 X 10-7 EmittersC.
I-131 1 X 10-6 Ce-144 5 X 10-6 Di sso l ved & 1 X 10-S Entrained GasesK. H-3 1 X lQ-S Gross alpha 1 X 10-7 Sr-89, Sr-90 5 X 10-8 Fe-55 1 X 10-6 Princ i pal Gamm a 5 X 10-7 EmittersC.
I-131 1 X lQ-6 Ce-144 5 X 10-6 Di sso lv e d & 1 X 10-S Entrained GasesK-H-3M. 1 X lQ-S Gross alp h a 1 X 10-7 Sr-89 , Sr-90 5 X 10-8 Fe-55 1 X 10-6 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. STOP THINK ACT MP-22-REC-B APOl REVI E W R ev. 0 29 14 o f 137 For a particular measurement system (which may include radiochemical separation)
: LL D = 4.6 6 Sb (E)(V)(2. 22x l Q 6)(Ye -AL1 I) Where:
* LLD is the lower limit of detection as defined above (as µCi 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 transformation)
* V is the sample size (in units of mass or volume)
* 2.22 x 10 6 is the number of transformations per minute per µCi
* Y is the fractional radiochemical yield (when applicable)
* "' is the radioactive decay constant for the particular radionuclide
* At is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is def i ned as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.
Occasionally background fluctuations , unavoidably small sample sizes , the presence of interfering nuclides , or other uncontrollable circumstances may render these LLDs unachievable. In such cases , the contributing factors will be identified and recorded on the analysis sheet for the particular sample. B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed i n this table. Prior to the sampling , each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided. If the steam generator bulk can not be recirculated prior to batch discharge , a sample will be obtained by representative compositing during discharge. C. The LLD will be 5 x 1 o-7 µC i/ml. The principal gamma emitters for which this LLD applies are exclusively the following rad i onuclides: Mn-54 , Fe-59 , Co-58 , Co-60 , Zn-65 , Mo-99 , Cs-134 , Cs-137 , and Ce-141. Ce-144 shall also be measured , but with an LLD of 5 x 10-6 µC i/ml. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable , together with the above nuclides , shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. D. For the Steam Generator Bulk: .!.Ethe applicable batch gamma radioactivity is not greater than 5 x 1 o-7 µCi/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 are not required.
STOP THINK ACT MP-22-REC-BAP Ol REVIEW R ev. 0 29 1 5 of 1 37 E. For the Condensate Polishing Facility (CPF} waste neutralization sump: IF there is no detectable tritium in the steam generators , THEN tritium sampling and analyses is not required.
IF the gross gamma radioactivity in the grab sample taken prior to release does not exceed 5 x 1 o-7 µCi/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89, Sr-90 and Fe-55 are not required.
F. For Batch Releases and Steam Generator Blowdown only , a composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released. G. Prior to analysis , all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released. H. For the Steam Generator Blowdown:
lE the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 µCi/ml , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89 , Sr-90 and Fe-55 are not required.
Steam Generator Blowdown samples are not required when blowdown is being recovered.
I. Daily grab samples shall be taken at least five days per week. For service water , daily grabs shall include each train that is in-service.
J. For the Service Water: lE a weekly gamma analysis does not indicate a gamma radioactivity greater than 5 x1 o-7 µCi/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 are not required. K. LLD applies exclusively to the following radionuclides:
Kr-87 , Kr-88 , Xe-133 , Xe-133m , Xe-135, and Xe-138. This list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and identifiable , together with the above nuclides, shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the " Radioactive Effluent Release Report." L. For the Turbine Building Sump: lE the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 µCi/ml, OR sump is directed to radwaste treatment , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89, Sr-90 and Fe-55 are not required. lE the release pathway is directed to yard drains , THEN the LLD for 1-131 shall be 1.5 x 10-7 µCi/ml and for gross alpha 1 x 1 o-8 µCi/ml. M. Detectable tritium shall be used to estimate tritium releases to the atmosphere via the blowdown tank vent. STOP THINK ACT MP-22-REC-BAPOl REVIEW R e v. 0 2 9 16 of 137 
: 2. Liquid Radioactive Waste Treatment
: a. Dose Criteria for Equipment Functionality Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit. 1) IF the radioactivity concentration criteria for the Unit 3 steam generator blowdown is exceeded with blowdown recovery not available to maintain releases to as low as reasonably achievable; or, IF any of the other radioactive waste processing equipment listed in Section b. are not functional, THEN doses due to liquid effluents from the applicable waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.C.2. 2) IF any of these dose projections exceeds 0.006 mrem to the total body or 0.02 mrem to any organ, THEN best efforts shall be made to return the processing equipment to service , or to limit discharges via the applicable waste stream. 3) IF an actual dose due to liquid effluents exceeds 0.06 mrem to the total body or 0.2 mrem to any organ AND the dose from the waste stream with processing equipment not functional exceeds 10% of one of these limits, THEN prepare and submit to the Commission a Special Report within 30 days as specified in Section 2.c. b. Required Equipment for Each Millstone Unit Best efforts shall be made to return the applicable liquid radioactive waste treatment system equipment specified below for each unit to service or to limit discharge via the applicable waste stream if the projected doses exceed any of the doses specified above. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 17 of 137 
: 1. Millstone Unit No. 1 Was t e Stream Processing Equipment Spent Fuel Pool water One filter and one demineralizer
: 2. Millstone Unit No. 2 Waste Stream Processing Equipment Clean liquid Deborating ion exchanger (Tll) OR Purification ion exchanger (TlOA or TlOB) OR Equivalent ion exchanger Primary demineralizer (T22 A or B) OR Equivalent demin e ralizer ALPS/AIM processing OR Secondary demineralizer (T23 A or B) OR Equivalent demineralizer Aerated liquid ALPS/AIM processing OR Demineralizer (T24) OR Equivalent demineralizer
: 3. Millstone Unit No. 3 Waste S t ream Processing Eq u i p ment or Radioactivity Concentration High level ALPS processing (3LWS-SKD1)
OR Demineralizer (3LWS-DEMN2) and Demineralizer filter (3LWS-FLT3)
OR Demineralizer (LWS-DEMNl) and Demineralizer filter (LWS-FLTl)
Boron recovery Cesium ion exchanger (3BRS-DEMN1A or B) Boron evaporator (3BRS-EV1)
Low level High level processing equipment Steam generator Blowdown recovery when total gamma radioactivity exceeds 5E-7 blowdown µCi/ml or tritium exceeds 0.02 µCi/ml. NOTE: The qualifier OR indicates that any of the equipment listed within the block would satisfy the processing requirement if functional.
STOP THINK ACT MP-22-REC-BAPOl RE VI EW Rev. 029 18 of 137 
: c. Report Requirement For All Three Millstone Units If required by Section 2.a.3), prepare and submit to the Commission a Special Report within 30 days with the following content: * *
* Explanation of why liquid radwaste was being discharged without treatment, identification of any equipment not in service, and the reason for the equipment being out of service , Action(s) taken to restore the equipment to service, and Summary description of action( s) taken to prevent a recurrence . STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 19 of 137 Figure I.C.-1, "Reserved STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 20 of 137 r--Cf) -I 0 I I z ;,;; )> (') -I Containment Leakoff RCP s B leed off Aux Bldg & Enclosure Bldg. Equipment Leako Sampling Drains Piping & E mentDrai.n s Decontamination
** Primary Coolant Letdown Steam Generator Blowdown Primary Drains Tank (Tl 7) Equipment Drain Sump Tank (D5) ,-------* IonExchangeq Coo lantW aste Mixed Bed 4 Receiver (T22A/B) I Tanks (Tl4A/B) .. -----* *------* ----~: ALPS/AI!vl ~----r-* ,-------, 1 IonExchanger 1 1 MixedBed 1 L _(!21~--* C oolant Waste Monitor Tanks (Tl 5AIB) Clean Liqui RadMonito (RM9049) To Coolant Waste Receiv e r T ank (T1 4 A/B) Aerated Waste Drains Tanks (T20N B) io;;E:;~;er-1 t ____ .___ (124) :------L -------Aerated Waste Monitor Tank (T 21) 1---------
1 Deborating I Ion Exc han ger J I --(Ill) --_: ----......,;'**
*--------.
7 1 2 Purifi.cation 1 I Ion E xchangers I (TIOA/B) 1 .. _______ _ Volume Co ntrol Tank (T5) To Primary 1---+ Coolant Loop S/GB lowdown or Quench Tank (T45) Aerate d Liquid Ra d Monit or (R M9116) Condensa te Polishin g Fa cility 8 Waste Neut. Sump .________, R Rad Monitor (CN D245) 8 Turbine Bld g. Floor Drains* I RB= BX I--------S-
/G_Bl_o ... _:v_do_wn __ R_ad_M_oru_
*_to_r_c_RM_4_2 6_2_) -+I Niantic Bay Quarry *T urbine Bldg floor drains normally to st orm drains. Drains may be diverted to the radwaste treatment system. ** HP de con facility s ump i s co lle cte din tote s and s hipped o ffsite. ..**....*
: : = Component included inradwa s te treatment ....... ! equipment requirement (J) -i 0 ""tJ -i I z /\ )> () -i Filter -----**----, I r--Z---, ---------Containment Bldg Sump" Allx B ldg Sump* High Level WasteDran Tank (LWS-TKl A/B) 1 Filter I : Demin : -~(LWS-FLT3)~-~ (LWS-DEMN2)~ 1------~ --------. -----------------, Waste Test Tank LWS-TK3A/B .---------.
~-------.
Demin I I Filter I I (LWS-DEMNl)M (LWS-FLTl)
: Reactor Plant Sample Sinks Lab Wastes* MiscHigh-Level Was t e *Via Reactor Plant Aerated Drain System Letdown Demin (DEMN!A/B)
Demin (DEM1N2 A/B) Degassifier (GWS-GRUl) 1 ALPS processing (LWS,SKDI) 1 I I I I ---------__________________ , Volume Conlrol Tank Cesium Boron Recovery Tank (BRS-TKIA/B) To Primary Gra:le Water Boron Test Tank (BRS-TK2A/B) r----------.
: Boron 1
* Evaporator 1..1 ----' Boron Demineralizer RS-DEMN2 A/B) Filter (BRS-FLT3) Reactor P l ant Gaseous Drains Ion Exchanger (BRS-DEMNl A/B) 1 ,_ -------------* ~---(EV!) ___ : Miscellaneous Low-Level Waste Turbine Plant Leakage to Sump Service Water Discharge CPF Waste Neut Sump (TklO&l l) Steam Generator Blowdown (Open Cycle) Filter (FLT4A/B)
Low-Level Waste Drain Tank (LWS-TK4 A/B) 3P A S-E E5 Q
* 3SSR-RE08 Component included in = radwaste treatment equipment requirement Niantic Bay viaDSN 006 3CND-RE07 3LWS-RE70) ... (1Q C: "'1 ro n I r.i:, ... 9 "C -... :=. ro r ... ,.c C: ... trj 9 C: ro = .... -0 ... (1Q "'1 9 ... --r.,, .... 0 = ro (j = ... .... Quarry I.D. Gaseous Effluents
: 1. Gaseous Effluent Sampling and Analysis Program Radioactive gaseous wastes shall be samp l ed and analyzed in accordance with the program specified in Table I.D.-1 for Millstone Unit No. 1, Table I.D. -2 for Millstone Unit No. 2, and Table I.D. -3 for Millstone Unit No. 3. The results of the radioactive analyses shall be input to th e methodology of Section II to ass ur e that offsite doses are maintained within the limits of Radiological Effluent Controls (Section III.D.2. for Millstone Unit No. 1, Section IV.D.2. for Millstone Unit No. 2, and Section V.D.2. for Millstone Unit No. 3). Table I.D. -1 Millstone Unit 1 Radioactive Gaseo u s Waste Samp lin g and Analysis Program Gaseous Release Point or Source A.Spent Fue l Pool Island Vent B.Balance of Plant Vent Sample 'fype and Min imu m FrequencyB Analys i s Frequency MonthlyD ,F -Gaseous Monthly Grab Sample Contin uou sE* Twice per month Particulate Sample ContinuousE*
Quarterly Particulate Sample Composite Contin uou sE* Continuo u s Nob l e Gas Monitor Twice per month ContinuousE.
Particulate Sample Quarterly Composite Grab sample of Reactor Prior to processing Bldg evaporator staging of each batch tank prior to processing Table I.D. -1 TABLE NOTATIONS
'fype of Radioactivity Lower Limit Analysis of Detection (LLD)A (µCi/ml) Kr-85 1 X lQ-4 H-3G 1 X 10-6 Principal Gamma lxio-11 EmittersC.
-(with half lives greater than 8 days) Sr-90 , Gross alpha lxl0-11 Kr-85 1 X lQ-6 Principal Gamma lxl0-11 EmittersC.
-(with half lives greater than 8 days) Sr-90, Gross alpha 1 X lQ-ll H-3 1 X 1Q-S A. The lower limit of detection (LLD) is defined in Table Notations, Item a, of Tables I.C.-1 , I.C.-2, or I.C.-3. B. Samples not r equir ed when Release Point is not in use. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 23 of 137 I C. Fo r particulate samples , the LLD will be 1 x 10-11 µC i/cc. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides
: Mn-54 , Co-60 , Zn-65 , Cs-134, Cs-137 , and Ce-144. The list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and identifiable , together with the above nuclides , shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. D. IF there is an unexplained increase of the SFPI Vent noble gas monitor of greater than a factor of ten , OR the monitor reads 8.SE-5 µC i/cc or greater , THEN sampling and analysis shall also be performed within 24 hours. E. Continuous when exhaust fans are in operation.
F. When Spent Fuel Pool Island ventilation is shutdown and ventilation of Spent Fuel Pool Island is exhausted to Balance of Plant Vent , the monthly gaseous grab sample shall be obtained from the Balance of Plant Vent. G. Tr i tium analys i s of vent grab sample may be replaced by a calculation of tritium released from the spent fuel pool. STOP THINK ACT M P-22-REC-B APOl REVIEW R ev. 0 29 2 4 o f 1 37 Table I.D.-2 Millstone Un it 2 R a dioacti ve Gaseous Waste Sa mpling and Analysis Program Gase ous Sample 'Iy pe and Minimum Release Point Frequency Analysis or So urc e Frequency
[A.Batch Rel ease I.Waste Gas Stor-Gaseous Grab Prior to each Each Taruc Discharge age Tan1c 8 Waste Gas Tank Discharge B.Containment&Aux Building Releases I.Containment Gaseous Grab of purges l. Prior to Each and vents Purge l. Prior to Each Purge 1 2. Every two weeks 2. Every two weeks for Venting 1 for Venting Monthly Continuous Particulate for Weekly Open Containment Equip-ment Hatch during Outage Continuous Charcoa l for Weekly Open Containment Equip-ment Hatch during Outag e C.Continuous Rel ease l.Vent (RM8132B) 2.Millstone Stack (RM8169-1) Monthly -Gaseous Grab SampleC.,G.
Monthlyl--, 1..1. Continuous Charcoal Sam-Weekly pleD.,F. Continuous P articulate Weekly SampleD.,F.
Continuous Particulate Quarterly Composite Sample 0-Continuous Noble Gasu. Contin uou s Monitor TABLE I.D.-2 TABLE NOTATIONS
'Iype of Lower Limit Radioactivity of D etec tion Analysis (LL D)A (µCi/ml) Princip a l Gamma 1 X lQ-4 Emitters 8 H-3 1 X 1Q-b Princip a l Gamma 1 X lQ-4 Emitters 8 H-3 1 X lQ-b Gamma emitters NA for 1/2 hr count (I-131, others with half-life greater than 8 days) I-131 and I-133 for NA one hour count Principal Gamma 1 X lQ-4 Emitters 8 H-31..1 1 X lQ-O I-131 lxlQ-lL I-133 1 X lQ-lD Principal Gamma l x10-11 EmittersB
-(I-131, others with half lives greater than 8 days) Sr-89, Sr-90 -1 X lQ-ll Gross alpha 1 X lQ-ll Noble Gases -1 X 10-o Gross Radioactivity A. The lower limit of detection (LLD) is defined in Table Notations , Item a , of Tables I.C.-1 , I.C.-2, or I.C.-3. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 25 of 137 B. For gaseous samples , the LLD will be 1 x 1 o-4 µCi/cc and for particulate samples, the LLD will be 1 x 10-11 µCi/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides:
Kr-87, Kr-88 , Xe-133 , Xe-133m , Xe-135 , and Xe-138 for gaseous emission and Mn-54, Fe-59, Co-58, Co-60 , Zn-65 , Mo-99 , 1-131 , Cs-134 , Cs-137, Ce-141, and Ce-144 for particulate emissions.
The list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the " Radioactive Effluent Release Report." C. IE there is an unexplained increase of the Millstone Stack or Unit 2 Vent noble gas monitor of greater than 50%, THEN sampling and analysis for principal gamma emitters shall be performed within 72 hours. Sampling and analysis is not required if the monitor reading has returned to within 20% of the average reading prior to the increase. IF the Millstone Stack or Unit 2 Vent noble gas monitor increased greater than 50% and then has decreased to within 20% of the average reading prior to collecting a sample representative of the elevated reading, THEN an estimate of radioactivity released during the period of elevated reading shall be made. D. The ratio of the sample flow rate to the sampled stream flow rate shall be known. E. RESERVED F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after changing.
For Unit 2 vent only The sampling frequency shall be increased to daily following each reactor shutdown , reactor criticality after shutdown , or thermal power change exceeding 15% of rated thermal power as defined in Technical Specification within a one hour period, if one or both of the following has occurred:
: 1) The Dose Equivalent I-i 31 concentration in the reactor coolant has increased by more than a factor of three above the concentration that existed during steady state , full power operation prior to the power transient.
: 2) The noble gas monitor , RM8i32B , has increased more than a factor of three relative to the radiation monitor reading that existed during steady state, full power operation prior to the power transient.
Analyses shall be completed within 48 hours of changing. For daily samples , the LLDs may be increased by a factor of i 0. Daily sampling shall be maintained for seven days or until such time when both conditions (i) and (2) are not satisfied , whichever is shorter. G. IF the refueling cavity is flooded , THEN grab samples for tritium shall be taken weekly. The grab sample shall be taken from the Millstone Stack or vent where the containment ventilation is being discharged at the time of sampling.
STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 0 29 26 of 137 H. Waste Gas Storage Tanks are normally released on a batch basis via the Millstone Stack. However , for the purpose of tank maintenance , inspection , or reduction of oxygen concentration , a waste gas tank may be vented or purged with nitrogen and released to the environment via the normal or alternate pathway using one of the following methods: Method A: W i thout a permit provided the following conditions are met: (1) The tank has been previously discharged with a permit. (2) The current tank pressure is less than 5 PSIG. (3) No radioactive gases have been added to the tank since the previous discharge from the tank. (4) Valve lineups are verified to ensure that no radioactive waste gases will be added to the tank. (5) Prior to initiation of the vent or purge , a sample of the gas in the tank will be taken and analyzed for any residual gamma emitters and tritium. The tank may be released if: a) Tank radioactivity is less than 1 % of the radioactivity released in the previous batch release from the tank , or less than 1 % of the radioactivity released to date for the calendar year , and b) the radioactivity of Kr-85 and Xe-133 is less than 0.01 Ci and the radioactivity of all other gases is less than 0.001 Ci. Method B: With a permit provided valve lineups are verified to ensure that no radioactive waste gases will be added to the tank. I. IE compared to the radioactivity at the time of the air sample, a Radiation Monitor RM8123 or RM8262 gas channel increases by a factor of two , THEN a new containment air sample shall be taken. IE containment noble gas radioactivity exceeds 1 E-6 µCi/cc as indicated by the last grab sample , THEN sampling frequency shall be increased to weekly until such time that the radioactivity is less than 1 E-6 µCi/cc. J. During an outage a sample is only required prior to the initial purge. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 0 2 9 2 7 of 137 Table I.D.-3 Millstone Unit 3 Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Sample 'Iype and Relea se Point Frequency or So urce A. Containment Release I.Containment Gaseous, parti culate and charcoal grab prior to eac h drawdown (via air ejector) Gaseous grab prior to eac h purgeH. Gaseous Grab every two weeks for vents (i.e., re-leases to maintain sub-atmospheric pressure via containment vacuum pump )1-Contin uou s particulate for open containment eq uipm e nt hatch during outages. Contin uou s charcoal for open containment equipment h atch during outages. B.Continuous Relea se 1.Unit 3 Ventila-Monthly -Gaseous tion Vent Grab Samp l eC., G. (HVR-RElOB) 2.Engineered Continuous charcoal Safeguards samp l eD.,F. Building Contin uou s particulate (HVQ-RE49) sarnp l eD.,F. 3.Millstone Stack via SLCRS Continuous p articulate (HVR-sample 0-R E19B) Continuous noble gasu. Minimum 'Iype of Radioactivi ty Ana l ys i s Analysis Fre qu ency Same as samp l e fre-Princip al gamma quency. emittersB*
Sarne as samp l e fre-On charcoal samp l e: quency. I-131 I-13 3 On particulate sample: Princip al gamma emittersB*
-(I-131, oth-ers with half lives greater than 8 days) Monthly for purge, H-3 vents, a nd d rawdowns Weekly Gamma emitters for V2 hour count (1-131, others wit h half-li fe greater th an 8 days) Weekly I-131 and I-133 for one hour count MonthlyL., u. Principal gamma emittersB H-3u Weekly I-131 I-13 3 Weekly Principal gamma emittersB.
-(1-131,others with hal f Jj ves greater than 8 days) Qu arterly composite Sr-89, Sr-90 Gross alpha Continuous Noble gases -gross monitor radioactivity TABLE I.D.-3 TABLE NOTATIONS Lower Limit of D etect ion (LL D)A* (µCi/m l) 1 X 10-4 1 X lQ-ll 1 X lQ-lO 1 X lQ-ll 1 X lQ-b NA NA 1 X lQ-4 1 X 10-o 1 X lQ-lL. lxl0-10 1 X 10-u 1 X lQ-ll 1 X lQ-ll 1 X 10-o A. The lower limit of detection (LLD) is defined in Table Notations , Item a , of Tables I.C. -1, I.C. -2, or I.C.-3. ST OP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 28 of 137 B. For gaseous samples , the LLD will be 1 x 1 o-4 µCi/cc and for particulate samples , the LLD will be 1 x 10-11 µCi/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides
: Kr-87 , Kr-88 , Xe-133 , Xe-133m , Xe-135 , and Xe-138 for gaseous emission and Mn-54, Fe-59 , Co-58 , Co-60 , Zn-65 , Mo-99 , 1-131 , Cs-134 , Cs-137 , Ce-141 , and Ce-144 for part i culate emissions. The list does not mean that only these nuclides are to be detected and reported. Other peaks wh i ch are measurable and identifiable , together with the above nuclides , shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances r esult in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. C. lE there is an u nexplained increase of the Unit 3 vent i lation vent or SLCRS noble gas moni t or of greater than 50%, THEN sampling and analysis for principal gamma emitters shall be performed within 72 hours. Sampling and analysis is not required i f the monitor reading has returned to wi t hin 20% of th e average reading prior to th e incre a s e. lE the SLCRS or Unit 3 Vent noble gas monitor increased greater than 50% and then has decreased to within 20% of the reading prior to collecting a sample representat i ve of the elevated reading , THEN an estimate of radioactivity re l eased during the period of elevated reading shall be made. D. The ratio of the sample flow r ate to the sampled stream flow rate shall be known. E. RESERVED F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after chang i ng. For Unit 3 Vent only: The sampling frequency shall be increased to daily following each reactor shutdown , reacto r crit i cality after shutdown , or thermal power change exceeding 15% of rated thermal power as defined in Technical Specification within a one hour period , if one or both of the following has occurred: 1) The Dose Equivalent 1-131 concentration in the reactor coolant has increased by more than a factor of three above the concentration that existed during steady state , full power operation prior to the power transient.
: 2) The noble gas monitor , HVR-RE10B , has increased more than a factor of three relative to the radiation monitor reading that existed during steady state , full power operation prior to the power t ransient.
Analyses shall be completed within 48 hours of changing. For daily samples , the LLDs may be increased by a factor of 10. Daily sampling shall be maintained for seven days or until such time when both conditions (1) and (2) are not satisfied , whichever is shorter. G. IF the refueling cavity is flooded , THEN grab samples for tritium shall be taken weekly from the ventilation vent. H. During an outage a sample is only required prior to the initial purge. STOP THINK ACT MP-22-REC-BAP Ol REVIEW R ev. 0 29 29 of 137 I. lE compared to the radioact i vity at the time of the air sample , Radiation Monitor CMS22 gas channel increases by a factor of two , THEN a new containment air sample shall be taken. lE containment noble gas radioactivity exceeds 1 E-6 µCi/cc as indicated by the last grab sample , THEN sampling frequency shall be increased to weekly until such time that the radioactivity is less than 1 E-6 µCi/cc. S T OP THINK ACT MP-22-RE C-BAP Ol REVIEW R ev. 0 29 3 0 o f 13 7 
: 2. Gaseous Radioactive Waste Treatment
: a. Dose Criteria for Equipment Functionality Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit. 1) IF any of the radioactive waste processing equipment listed in Section 2.b. are not functional or are being bypassed, THEN doses due to gaseous effluents from the untreated waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.D.4. For each waste stream, only those doses specified in Section II.D.4. need to be determined for compliance with this section. 2) IF any of these dose projections exceed 0.02 mrad for gamma radiation, 0.04 mrad for beta radiation or 0.03 mrem to any organ due to gaseous effl u ents, THEN best efforts shall be made to return the processing equipment to service. 3) IF actual doses exceed 0.2 mrad for gamma radiation, 0.4 mrad for beta radiation or 0.3 mrem to any organ AND th e dose from a waste stream with equipment not functional exceed 10% any of these limits , THEN prepare and submit to the Commission a report as specified in Section I.D.2.c. b. Required Eq uipm ent for Each Millstone Unit Best efforts shall be made to return the gaseous radioactive waste treatment system equipment specified below for each unit to service if the projected doses exceed any of doses specified above. For the Unit 2 gas decay tanks, the tanks shall be operated to allow enough decay time of radioactive gases to ensure that the Radiological Effluent Control dose limits are not exceeded.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 31 of 137 
: 1. Millstone Unit No. 1 Waste Stream Processing Equipment None Specified None required 2. Millstone Unit No. 2 Waste Stream Processing Equipment Gaseous Radwaste Five (5) gas decay tanks Treatment System One waste gas compressor Ventilation Exhaust Auxiliary buildin g ventilation HEPA filter (L26 or L27) Treatment System Containment purge HEPA filter (L25) Containment vent HEPNcharcoal filter (L29 A or B) 3. Millstone Unit No. 3 Waste Stream Processing Equ ip ment or Radioactivity Concentration Gaseous Radwaste Charcoal bed adsorbers Treatment System One HEPA filter c. Report Requirement For All Three Millstone Units If required by Section I.D.2.a.3), prepare and submit to the Commission a Special Report within 30 days with the following content:
* Exp lanation of why gaseous radwaste was being discharged without treatment, identification of any equipment out of service, and the reason for being out of service,
* Actions taken to restore the nonfunctional equipment to service , and
* Summary description of actions taken to prevent a recurrence. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 32 of 137 Figure I.D.-1, "Simplified Gaseous Effluent Flow Diagram Millstone Unit One" ~-.. * *** * * ** * * * .... * ** = generalized air flow SFPI Vent Spent Fuel Pool Island (SFPI) Balance of Plant Vent S = particulate sampler STOP RM-SFPl-0 2 Evaporator
-------~ .-------------,
* Vent plenum : '--~-----~----. . . . . . . . . . ~-******************** THINK ACT Reactor Building Turbine Building Radwaste Building MP-22-REC-BAPOl REVIEW Rev. 029 33 of 137 Figure I.D.-2, "Simplified Ga se ou s Effiuent Flow Dia g ram Mill s tone Unit Two" Main Co n de n se r t-----1..i Aif Ejector ------. -------, I I I Wast e Gas * * : Decay Proces.sing
: Waste Gas* 1 Tanks System *Co mpre sso r~ (T1 9 A1B t (F-l AIB) I I C/D/E/F) I I I I I L-----* *-------HE P A (L l 7) Waste G as Containment -----------i Rad Monitor Ven_c ____ ..,* HEP A/Charcoal
..
* ____ _,.. E n c l osure Buildin g/ Co ntainmen t Pur ge lAds or b er Unit (L29AIB): I I I A -A -------.. I I ------1 I* I I 1 ,i I I I I HEPA I Mi ll stone Stack WRGM RM-8 1 69 Unit2 I I ..--------------, I (L25) I St eam Ge n erator Slowdown Quench Tank Vent Fu el Buildin g (A ux Building 38'6) I ** I I I *-----* i-----, I -------~' HEP A (L27) .. _____ , Steam Gene rat or Slowdown Tank Vent ---------------
-----. Enclosure Bldg R oo f Vent r-----, Aux.B l dg I I I I -----------------~*
HEPA 1 __________
.._ _ _....__ ... Ve n t (L26) : R a d Moni tor T ur b ine Bldg I (RM 8 l32A/B) \.. ____ _ Turbin e B l dg Roof Vent
* Th ese fl ow pa t hs u se d durin g a n accident.
STOP . -----. I I I I I I
* _____ J T HINK = C omponen t included in tr ea tment equipment requirem e nt ACT MP-22-REC-BAP Ol REVIEW R ev. 0 29 34 o f 137 Figure I.D.-3, "Simplified Gaseous Effluent Flow Diagram Millstone Unit Three" Atmosphere
* Reactor Plant V e ntil l a ti on Vent .~ Serv i ce Buildin g HEPA/Charcoal
__ !_. (3HVR*FL T2A/B) ----* Fue l Building . A uxi l i ary Build i n g --.;--~ I *-* HEPA/Char co al (3H V R*FL T 1 A/B) ----* ---*---* Wa s te Di s posal Bu i ldin g /~ I I ;;. * ', Containment Structure Secondary
* HEPA & Char co al Containments (3HVR*FL T3A/B) (SLCRS) i---. C ont a i nm e nt Va c uum Sy ste m Drawdown ESF Bui l ding Tu r bine Bui l ding SG Slowdown Tank (3BDG-TK1) CPF Turbine Gland S ea l Ste a m Cond E x haust Atmosphere I** /R\t ent a om or (3HVQ-RE49)
Rd M *1 r----[ Ventilation Vent r R ad M o nit o r (3 HVR*RE10B) R C S Mi l ls ton e L e td ow n S ta c k i G a s eous Was t e S ys t e m .--------------, I I I Charc o al Bed s I I I : (3Gws*AD S 1NB) : ~-------------!
I I GW S Ra d K I HEPA I I I Monitor : (3 GWS*FL T1 A/B): 3 GWS-RE48 S L C RS Rad nitor *RE1 9 B) L-------------l I Mai n Conden s er Air E jecto r I I . " Turbine Bui l ding Roof E x hausters Mo (3HVR : : . ESF Bu1 l d1ng E x haust Atmosphere I I I I Component included in treatment equipmen t requirement
~----1
* These flow pa t hs used during an accident STOP T HINK ** Re l eases from Mechan i cal Rooms A-D not monitored ACT MP-22-REC-BAPOl REV I EW Rev. 029 35 of 137 I.E. Radiological Environmental Monitoring
: 1. Sampling and Analysis The radiological sampling and analyses provide measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from plant operation.
This monitoring program thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways.
Program changes may be made based on operational experience.
The sampling and analyses shall be conducted as specified in Table I.E. -1 for the locations shown Table I.E.-2. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability , malfunction of automatic sampling equipment or other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report pursuant to Section I.F.l. It is recognized that, at times, it may not be possible or practicable to obtain samples of the media of choice at the most desired location or time. In these instances suitable alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program. Any of the above occurrences shall be documented in the Annual Radiological Environmental Operating Report, which is submitted to the U.S. Nuclear Regulatory Commission prior to May 1 of each year. If the level of radioactivity in an environmental sampling medium at one or more of the locations specified in Table I.E. -2 exceeds the report levels of Table I.E. -3 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days from receipt of sample results , a Special Report which includes an evaluation of any release conditions, environmental factors or other aspects which caused the limits of Table I.E.-3 to be exceeded.
When more than one of the radionuclides in Table I.E.-3 are detected in the sampling medium, this report shall be submitted if: concentration (1) concentration (2) ------~ + + ... 1.0 reporting level (1) reporting level (2) STOP TH I NK ACT MP-22-REC-BAPOl REV I EW Rev. 029 36 of 137 When radionuclides other than those in Table I.E.-3 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to an individual is equal to or greater than the appropriate calendar year limit of the Radiological Effluent Controls (Sections III.D.l.b., III.D.2.b., or III.D.2.c.
for Unit 1; Sections IV.D.l.b., IV.D.2.b., or IV.D.2.c. for Unit 2; and Sections V.D.l.b., V.D.2.b., or V.D.2.c. for Unit 3). This report is not required if the measured level of radioactivity was not the result of plant effluents, howev er, in such an event, the condition shall be report e d and described in the Annual Radiological Environmental Operating Report. The detection capabilities required by Table I.E.-4 are state-of-the-art for routine environmental m eas urements in industrial laboratori es. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a mea sure ment system and not as an a posteriori ( after the fact) limit for a particular measurement.
All analyse s 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 pr ese nce of int erfe ring nuclides , or other uncontrollabl e circumstances may render these LLDs unachievable.
In such cases, the contributing factors will b e identified and d esc ribed in the Annual Radiological Environmental Operating Report. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 37 of 137 Table I.E. -1 Mill s tone Radiological Environmental Monitoring Program E x po s ure Pathwa y and/or No. of Sampling an d Coll e ction 'fy p e and Fr e quenc y of Sample Location s Fr e q u enc y A nal ys i s 1. Gamma D ose -39taJ Qu arte rl y Gamma D ose -Qua rt e rl y Environmen t a l TLD 2.Airbome Pa r ticulate 8 Continuous samp l er -filter Gross Beta -Every two weeks change every two weeks Gamma Spectrum -Q uarterly on composite (by l ocation), a n d on indi-victual sample if gross beta is greater t h an lOx t h e mean of t h e co n trol sta-tion's gross b e t a resu lt s 3.Ai rb o rn e Iodin e 8 Co n tin u o u s samp l er -I -131 -Every two weeks canist er change every two weeks 4.Vegetation 5 O ne samp l e near midd l e an d Gamma Isotopic on eac h sample one near end of growing season 5.R eserved 6.Sea Water 2 Co n tin u o u s samp l er with a Gamma I sotopic & Triti u m o n each monthly co ll ection at ind i ca-sample t or l ocation. Qu arterly a t co nt ro l loca t io n -Com p os-i te of 6 weekly grab samp l es 7.Well Water 6 Sem i annua l Gamma I sotopic & Tritium on each sample 8.B ottom Se d i m e n t 5 Semiannua l Gamma I sotop i c on eac h sam pl e 9.So il 3 Annu a ll y Gamma I sotop i c on eac h sam pl e 10.F i n Fish-( ed i ble portion) 2 Sem i -ann u al Gamma I sotop i c on eac h sam pl e 11.Aq u atic flora 4 Qu arterly Gamma I sotopic on eac h sam pl e 13.C l ams (ed ibl e p ortion) 2 S em i-ann u al Gamma I soto pi c on eac h sam pl e 1 4.Lo b sters (e dibl e por t io n) 2 S em i -ann u al Gamma I soto pi c on eac h sam pl e (a) Two or more TLDs or TLD with t w o or more elements per location. (b) Not required during 1 s t quarter. STOP THINK ACT MP-22-REC-BAP O l REVIEW R ev. 0 29 38 o f 13 7 Table I.E.-2 Environmen tal Monitoring Program Sam plin g Locations The following list s the e nvironm e ntal sampling location s a nd the types of samp l es obtained at each location. Sampling lo ca tions are also shown on Figures I.E.-1 and I.E.-2: Location No* Name 1-I Onsite -NAP Parking Lot North 2-I Onsite -Weather Shack 3-I Onsite -Bird Sanctuary 4-I Onsite -Albacore Dri ve 5-I Onsite -Quarry East 6-I Onsite -Quarry Dischar ge 7-I Onsite -Enviro nment a l Lab Dock 8-I Onsite -Environmenta l Lab 9-I Onsite -Bay Point Beach 10-I Waterford-Goshen Fire Dept. 11-I Great Neck Country Club 13-C Mystic, CT 14-C Ledyard, CT 15-C Norwich , CT 16-C Old Lyme, Halls Rd. 17-I Site Bound ary 25-I Fruits & Vegetables 26-C Fruits & Vegetables 27-I Eas t Lyme -Police Station 28-I Two Tree Island 29-I West Jordan Cove 31-I Niantic Shoals 32-I Vicinity of Discharge:.!
33-I Seaside Point 34-I Thames River Yacht Club 35-I Niantic Bay 36-C Black Point 37-C Giant's Neck 41-I Waterford
-Myrock Avenue 42-I Eas t Lyme -Billow Ro ad STOP Direction
& Dis-tance from Re-l ease Point** 0.6 Mi, NNW 0.3 Mi, S 0.3 Mi, NE 1.0 Mi, N 0.1 Mi, SSE 0.3 Mi, SSE 0.3 Mi, SE 0.3 Mi, SE 0.4 Mi, W 1.2 Mi, E 1.6 Mi , ENE 11.5 Mi , ENE 12.0 Mi , NE 14.0 Mi, N 8.8 Mi, W 0.5 Mi, NE Within 10 Miles Beyond 10 Mi l.7Mi, WNW 0.8 Mi, SSE ::; 0.5 Mi , ENE to ESE 1.8 Mi, NW 1.8 Mi, ESE 4.0Mi,ENE
::; 0.5 Mi , SSW to w 2.7Mi, SW 3.5Mi , WSW 3.2 Mi, ENE 2.4Mi, WSW THINK ACT Sampl e Types TLD, Air Particulate , Iodine, Vegetation TLD , Air Particulate, Iodine TLD, Air Particulate , Iodine, Soil TLD, Air Particulate, Iodine, Soil TLD TLD TLD TLD TLD TLD, Air Particulate, Iodine, Vegetation TLD, Air Particulate , Iodine TLD TLD, Soil TLD, Air Particulate, Iodine TLD Vegetation Vegetation Vegetation TLD, Air Particulate , Iodine Fish 1 Clams , Fish 1, Aquatic Flora Bottom Sediment, Clams Bottom Sediment, Fish 1, Seawater, Aquatic Flora Bottom Sediment Bottom Sediment Lobster , Fish, Aquatic Flora Aquatic Flora Bottom Sediment, Seawater TLD TLD MP-22-REC-BAPOl REVIEW Rev. 029 39 of 137 Table I.E.-2, Cont. Location Direction
& Dis-Sample Types tance from Re-No* Name lease Point** 43-I East Lyme -Old Black Point Rd. 2.6 Mi, SW TLD 44-I Onsite -Schoolhouse 0.1 Mi, NNE TLD 45-I Onsite Access Road #1 0.5Mi,NNW TLD 46-I Old Lyme -Hillcrest Rd. 4.6Mi, WSW TLD 47-I East Lyme -W Main St. 4.5Mi, W TLD 48-I East Lyme -Corey & Ro xbury Rd. 3.4Mi, WNW TLD 49-I East Lyme -Society Rd. 3.6 Mi, NW TLD 50-I East Lyme -Manwaring Rd & 2.1 Mi , W TLD Terrace Ave. 51-I East Lyme -Smith Ave. 1.5 Mi, NW TLD 52-1 Waterford
-Riv er Rd. 1.1 Mi, NNW TLD 53-1 Waterford
-Gardiners Wood Rd. 1.4 Mi, NNE TLD 55-1 Waterford
-Magonk Point 1.8 Mi , ESE TLD 56-1 New London -Ocean & Mott Ave. 3.7 Mi , E TLD 57-I New London -Oc ean Ave. 3.6 Mi, ENE TLD 59-I Waterford
-Miner Ave. 3.4 Mi, NNE TLD 60-I Waterford
-Parkway South & 4.0Mi,N TLD Cross Rd. 61-1 Waterford
-Oil Mill & Boston Po st 4.3 Mi , NNW TLD Rd. 62-I East Lyme -Columbus Ave. 1.9 Mi, WNW TLD 63-I Waterford
-Gradiners Wood & 0.8 Mi , NE TLD Jordon Cove Rd. 64-I Waterford
-Shore Rd. 1.1 Mi , ENE TLD 65-1 Waterford
-Bo ston Po st Rd. 3.2Mi, NE TLD 71-1 Onsite well On si te W e ll water 72-1 Onsit e well On site Well water 79-1 Onsite well On si t e Well water 80-I On si t e well Onsite Well water 81-1 Onsite well Onsite Well water 82-1 Onsite well On site Well water 89-C Aquatic B ackground Beyond 4 Mi. Of Lobster discharge 1 Fish to be sampled from one of three locations
-28 , 29 , or 32. 2 Vicinity of discharge includes the Quarry and shoreline area from Fox Island to western point of Red Barn Recreation Area and offshore out to 500 feet.
* I = Indicator; C = Control. ** = The release points are the Millstone Stack for terrestrial locations and the end of the quarry for aquatic location.
NOTE: Environmental TLDs also function as accident TLDs in support of the Millstone Emergency Plan. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 40 of 137 Figure I.E.-1, "Inner TLD , Air, Grass, Soil, and Aquatic Locations" STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 41 of 137 Figure I.E.-2, "Outer TLD and Aquatic Locations" STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 42 of 137 Table I.E.-3 Reportin g Le v el s F or Radio a ctivity C oncentration s In E n vi ronment a l S ample s Anal ys i s Water Ai rborne Fi s h She ll fi s h c. Milk Ve g etable s (p C i/1) Particulate (p C i/g, w e t) (p C i/g , w e t) (p C i/1) (p C i/g , wet) or Ga s e s (p C i/m 3) H-3 20 OOOA ' Mn-54 1 , 000 30 140 F e-59 400 10 60 Co-58 1 , 0 00 3 0 13 0 Co-6 0 300 10 5 0 Zn-65 300 20 8 0 Zr-95 400 Nb-95 400 Ag-llOm 8 30 I-131 20.tl. 0.9 0.2 1 3 0.1 Cs-134 30 10 1 5 60 1 Cs-137 5 0 2 0 2 8 70 2 B a-14 0 200 300 La-140 200 300 A. 20 , 000 pCi/1 for dr i nking water samples. (Th i s is 40 C F R Part 141 v alue.) For non-drinking water pathways , a value of 30 , 000 pCi/1 may be used. B. Reporting level for 1-131 applies to non-drinking wat e r pathways (i.e., seawater). If drinking water pathways are sampled , a value of 2 pCi/1 is used. C. For on-si t e samples , t h ese values can be mu l t i p l ied by 3 to account for the near field dilution factor STOP TH I N K ACT MP-22-REC-B APOl REVIEW R ev. 0 29 43 of 13 7 Analy s is gross b e t a H-3 M n-54 Fe-59 Co-58, 6 0 Z n-65 Zr-95 Nb-95 I-131 Cs-134 Cs-13 7 B a-14 0 L a-14 0 Table I.E.-4 Maximum Value s For Lower Limit s Of Detection (LLD)A* Water (p C i/1) 200 0°* 15 3 0 15 3 0 3 0 15 15c. 15 18 60c. 15c. Airborne Fi s h Milk Particulate S hellfi s h (pCi/1) or Ga s e s (p C i/g, w e t) (p C i/m 3) 1 X lQ-:2. 0.13 0 0.2 60 0.13 0 0.26 0 7 X lQ-2 0.093 1 5 X 10-2 0.13 0 1 5 6 X lQ-2 0.15 0 1 8 70 25 TABLE NOTATIONS Table I.E.-4 Food Product s and Vegeta-tion (p C i/g , w et) 0.06B. 0.0 60 0.0 8 0 Sediment and Soil (pCi/g , d ry) 0.1 50 0.1 80 A. The LLD is the smallest concentration of radioactive material in a sample that w i ll be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. For a particular measurement system (which may include radiochemical separation)
: LLD = 4.66 Sb (E)(V)(2.22)(Ye-M I) Where:
* LLD is the lower limit of detection as defined above (as pCi per unit mass or volume) I
* 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 transformation)
* V is the sample size (i n units of mass or volume)
* 2.22 is the number of transformations per minute per pCi STOP THINK ACT MP-22-REC-B APOl REVI E W R ev. 0 29 44 of 13 7
* Y is the fractional radiochemical yield (when applicable)
* A is the radioactive decay constant for the particular radionuclide
* At is the elapsed time between midpoint of sample collection and midpoint of counting time (or end of the sample collection period) and time of counting.
It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.
Occasionally background fluctuations , unavoidably small sample sizes , the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.
In such cases , the contributing factors will be identified in the Annual Radiological Environmental Operating Report. B. LLD for leafy vegetables.
C. From end of sample period. D. If no drinking water pathway exists (i.e., seawater), a value of 3 , 000 pCi/1 may be used. STOP THINK ACT MP-22-R E C-BAPOl REVIEW R ev. 0 2 9 45 of 137 
: 2. Land Use Census A land use census shall be conducted annually during the growing season to identify; (1) changes in the use of unrestricted areas, (2) receptor locations, and (3) new exposure pathways to permit modifications in monitoring programs for evaluating doses to individuals from principal pathways of exposure.
The land use census shall identify the location of the nearest resident, nearest garden, and any other land-based food sources in each of the meteorological land sectors within a distance of five miles. Sectors SE, SSE, S, and SSW, are not land sectors because they are over water. When a land use census identifies a food source location other than the nearest garden in a sector which yields a calculated dose greater than the dose currently being calculated in the off-site dose models, make the appropriate changes in the sample location used. For each type of food source ( milk, fruits, etc.) other than the nearest garden in a sector, when a land use census identifies a location which has a D/Q 20% or greater than the D/Q for a current indicator location begin sampling from the new location within 30 days. Sample location changes for food sources other than nearest garden shall be noted in the Annual Radiological Environmental Operating Report. 3. Interlaboratory Comparison Program The lnterlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive materia l in environmental sample matrices are performed as part of a quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid. Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program. A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report. With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 46 of 137 I.F. Report Content 1. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report shall include summaries, interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the report period, including a comparison with previous environmental surveillance reports and an assessment of radioactivity from plant operation in the environment.
Any radioactivity from plant operation detected in the environment shall be compared to levels of radioactivity expected based on the effluent monitoring program and modelling of environment exposure pathways for the purpose of verifying the accuracy of the program and modelling.
If levels of radioactivity are detected that result in calculated doses greater than 10CFR50 Appendix I Guidelines, the report shall provide an analysis of the cause and a planned course of action to alleviate the cause. The report shall include a summary table of all radiological environmental samples which shall include the following information for each pathway sampled and each type of analysis:
: 1) Total number of analyses performed at indicator locations.
: 2) Total number of analyses performed at control locations.
: 3) Lower limit of detection (LLD). 4) Mean and range of all indicator locations together.
: 5) Mean and range of all control locations together.
: 6) Name, distance and direction from discharge, mean and range for the location with the highest annual mean (indicator or control).
: 7) Number of non-routine reported measurements as defined in these specifications.
In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual report. The report shall also include a map of sampling locations keyed to a table giving distances and directions from the discharge; the report shall also include a summary of the Interlaboratory Comparison Data required by Section I.E.3. of this manual. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 47 of 137 L The report shall include the results of the land use census required by Section I.E.2. of this manual. 2. Radioactive Effluent Release Report The Radioactive Effluent Release Report (RERR) sha ll include quarterly quantities of and an annual summary of radioactive liquid and gaseous effluents released from the unit in the Regulatory Guide 1.21 (Rev. 1, June 1974) format. Radiation dose assessments for these effluents shall be provided in accordance with 10 CFR 50.36a and the Radiological Effluent Controls.
An annual assessment of the radiation doses from the site to the most likely exposed REAL MEMBER OF THE PUBLIC shall be included to demonstrate conformance with 40 CFR 190. Gaseous pathway doses shall use meteorological conditions concurrent with the quarter of radioactive gaseous effluent releases.
Doses shall be calculated in accordance with the Offsite Dose Calculation Manual. The licensee shall maintain an annual of the hourly meteorological data (i.e., wind speed, wind direction and atmospheric stability) either in the form of a listing or in the form of a joint frequency distribution.
The licensee has the option of submitting this annual meteorological summary with the RERR or retaining it and providing it to the NRC upon request. The RERR shall be submitted prior to May 1 of each year for the period covering the previous calendar year. The RERR shall include a summary of each type of solid radioactive waste shipped offsite for burial or final disposal during the report period and shall include the following information for each type: * * * * *
* type of waste ( e.g., spent resin, compacted dry waste, irradiated components, etc.) solidification agent (e.g., cement) total curies total volume and typical container volumes principal radionuclides (those greater than 10% of total radioactivity) types of containers used (e.g., LSA, Type A, etc.) The RERR shall include a list of all abnormal releases of radioactive gaseous and liquid effluents (i.e., all unplanned or uncontrolled radioactivity releases, including reportable quantities) from the site to unrestricted areas. Refer To MP-22-REC-REF03, "REMO DCM Technical Information Document (TID)," for guidance on classifying releases as normal or STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 48 of 137 abnormal.
The following information shall be included for each abnormal release:
* total number of and curie content of releases (liquid and gas)
* a description of the event and equipment involved
* cause( s) for the abnormal release
* actions taken to prevent recurrence
* consequences of the abnormal release Changes to the MP-22-REC-BAPOl, "Radiological Effluent Monitoring And Offsite Dose Calculation Manual (REMODCM)," shall be submitted to the NRC as appropriate, as a part of or concurrent with the RERR for the period in which the changes were made. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 49 of 137 SECTION II. Offsite Dose Calculation Manual (ODCM) For the Millstone Nuclear Power Station Nos. 1, 2, & 3 Docket Nos. 50-245, 50-336, 50-423 MP-22-REC-BAPOl STOP THINK ACT REVIEW R ev. 029 50 of 137 SECTION IL OFFSITE DOSE CALCULATION MANUAL (ODCM) II.A. Introduction The purpose of the Offsite Dose Calculation Manual (Section II of the REMODCM) is to provide the parameters and methods to be used in calculating offsite doses and effluent monitor setpoints at the Millstone Nuclear Power Station. Included are methods for determining maximum individual whole body and organ doses due to liquid and gaseous effluents to assure compliance with the regulatory dose limitations in 10 CFR 50 , Appendix I. Also included are methods for performing dose projections to assure compliance with the liquid and gaseous treatment system functionality sections of the Radiological Effluent Monitoring Manual (REMM -Section I of the REMODCM).
The manual also includes the methods used for determining quarterly and annual doses for inclusion in the Radioactive Effluent Release Report. The bases for selected site-specific factors used in the dose calculation methodology are provided in MP-22-REC-REF03, "REMODCM Technical Information." Another section of this manual discusses the methods to be used in determining effluent monitor alarm/trip setpoints to be used to ensure compliance with the instantaneous release rate limits in Sections III.D.2.a., IV.D.2.a., and V.D.2.a. This manual includes the methods to be used in performance of the surveillance requirements in the Radiological Effluent Controls of Sections III , IV, and V. Appendix A, Tables App.A-1 provide a cross-reference of effluent requirements and applicable methodologies contained in the REMODCM. II.B. Responsibilities All changes to the Offsite Dose Calculation Manual (ODCM) shall be reviewed and approved by the Facilities Safety Review Committee prior to implementation. All changes and their rationale shall be documented in the Radioactive Effluent Release Report. It shall be the responsibility of the Site Vice President Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications.
The delegation of implementation responsibilities is delineated in the MP-22-REC-PRG , "Radiological Effluent Control." STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 51 of 137 II.C. Liquid Dose Calculations Radiological Effluent Controls (Sections III, IV, and V) limit whole body and maximum organ doses to an individual member of the public to 1.5 mrem whole body and 5 mrem maximum organ per calendar quarter and 3 mrem whole body and 10 mrem maximum organ per year from liquid effluents released from each unit. (See Appendix A, Table App.A-1 for cross-reference effluent control requirements and applicable sections in the REMO DCM which are used to determine compliance).
In addition, installed portions of liquid radwaste treatment system are required to be operated to reduce radioactive materials in liquid effluents when the projected dose over 31 days from applicable waste streams exceeds 0.006 mrem whole body or 0.02 mrem maximum organ. This part of the REMODCM provides the calculation methodology for determining the doses from radioactive materials released into liquid pathways of exposure associated with routine discharges.
: 1. Monthly, Quarterly, and Annual Dose Calculation (Applicable to All Units) For each Unit , whole body and maximum organ doses from liquid effluents shall be calculated at least once per 31 days ( or monthly) using the methodology of Regulatory Guide 1.109, Rev. 1. The calculation shall include contributions from all analyses required by Table I.C-1 for Unit 1, Table I.C-2 for Unit 2, and Table I.C-3 for Unit 3 recorded to date. If any required analyses have not yet been completed for the dose period, an estimate of dose from unanalyzed isotopes shall be included in the dose total. Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit. 2. Monthly Dose Projections Section I.C.2.a. of the REMM requires that certain portions of the liquid radwaste treatment equipment be used to reduce radioactive liquid effluents when the projected doses for each Unit (made at least once per 31 days) exceeds 0.006 mrem whole body or 0.02 mrem to any organ. The following methods are applied in the estimation of monthly dose projections:
: a. Whole Body and Maximum Organ when Steam Generator Total Gamma Radioactivity is less than SE-7 µCi/ml and Steam Generator Tritium is less than 0.02 µCi/ml (Applicable to Units 2 and 3) The projected monthly whole body dose (Units 2 or 3) is determined from: STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 52 of 137 The monthly projected maximum organ dose (Units 2 or 3) is determined from: Where: DMW = the whole body dose from the last typical previously completed month as calc ulat ed per the methods in Section II.C.l. DMo = the maximum organ dose from the last typical previously completed month as calcu l ated per the methods in Section IL C. l. R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month. Ri = the ratio of estimated primary coolant radioactivity for the present month to that for the past month. F2 = the factor to b e applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers).
NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.
The last month should be typical without significant operational differences from the projected month. If there were no releases during last month, do not use that month as the b ase month if it is estimated that there will be releases for the coming month. b. Whole Body and Maximum Organ when Steam Generator Total Gamma radioactivity Exceeds SE-7 µCi/ml or Steam Generator Tritium Exceeds 0.02 µCi/ml (Applicable to Units 2 and 3) The projected monthly whole body dose (Units 2 or 3) is determined from: The monthly projected maximum organ dose (Units 2 or 3) is STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 53 of 137 determined from: Where: DMW=the whole body dose from the last typical previously completed month as calculated per the methods in Section II.C.l. DMo=the maximum organ dose from the last typical previously completed month as calculated per the methods in Section II.C.1. R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month. R 2 = the ratio of estimated volume of steam generator blowdown to be released in present month to the volume released in the past month. F1 = the fraction of curies released last month coming from steam generator blowdown calculated as: curies from blowdown curies from blowdown + curies from batch tanks R3 = the ratio of estimated secondary coolant radioactivity for the present month to that for the past month. R4 = the ratio of estimated primary coolant radioactivity for the present month to that for the past month. F 2 = the factor to be applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers).
NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.
STOP THINK ACT MP-22-REC-BAPOl RE V IEW Rev. 029 54 of 137 L II.D. Gaseous Dose Calculations
: 1. Site Release Rate Limits ("Instantaneous")
Radiological Effluent Controls (Sections III.D.2.a , IVD.2.a, and VD.2.a) for each unit require that the instantaneous off-site dose rates from noble gases released to the atmosphere be limited such that they do not exceed 500 mrem/year at any time to the whole body or 3000 mrem/year to the skin at any time. For iodine-131 , 133, tritium , and particulates (half-lives
> 8 days), the dose rate from all units shall not exceed 1500 mrem/year at any time to any organ. These limits apply to the combination of r e leases from all three Units on the site, and are directly related to the radioactivity release rates measured for each Unit. a. Method 1 for Noble Gas Release Rate Limits Instantaneous noble gas release rate for the site: G1v /90,000 +Q 2 s/560 , 000 + G z v/290,000 + Q 3 s/560 , 000 + Q 3 v/290,000 .:s_ 1 Where: Giv = Noble gas release rate from Spent Fuel Pool Island Vent (µCi/sec) G 2 s = Noble gas release rate from MP2 to Millstone Stack (µCi/sec) G 2 v = Noble gas rel e ase rate from MP2 Vent (µCi/sec) Q3y = Noble gas release rate from MP3 Vent (µCi/s e c) Q3s = Noble gas release rat e from MP3 to Millston e Stack (µCi/sec) As long as the above is less than or equal to 1 , the doses will be less than or equal to 500 mrem to the total body and less than 3000 mrem to th e skin. The limiting factor for the Unit 1 SFPI vent of 90,000 is based on the skin dose limit of 3,000 mrem/year , while all the other factors are based on the whole body dose limit of 500 mrem/year. b. Method 1 Release Rate Limit -I-131, I-133, H-3 and Particulates Half Lives Greater Than 8 Days With releases satisfying the following limit conditions, the dose rate to the maximum organ will be less than 1500 mrem/year from the inhalation pathway: STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 55 of 137 L 1) Site release rate ofl-131, I-133, and tritium (where the thyroid is the critical organ for these radionuclides):
DRthyl + DRtby 2 + DRtby3 1 Where the contribution from each Unit is calculated from: Unit 1: DRthyl = 2.78E-5 0H1v Unit 2: DRtby2 = 8.80E-2131012v
+ 9.67E-3 131012s + 2.08E-2133012v+2.29E-3 133012s + 6.87E-6 OH2v+7.53E-7 OH 2s Unit 3: DRtby 3 = 8.80E-2131Q13y
+ 9.67E-3 131Q13s + 2.08E-2133Q13y
+2.29E-313 3 Q13s + 6.87E-6 QH3V + 7.53E-7 QH3S 2) Site release rate of particulates with half-lives greater than 8 days and tritium (where the critical organ is a composite of target organs for a mix of radionuclides):
DRo rgl + DRor g2 + DRor g3 1 Wh ere the contribution from eac h Unit is calculated from: Unit 1:DRorgl = 3.52E-1 [QPlv + Qprn ]+2.78E-5 0H1V Unit 2:DRorg2 = 9.53E-3 0P2s + 8.67E-2 Qp2v + 7.53E-7 QH 2S + 6.87E-6 QH2V Unit 3:DRorg3 = 9.53E-3 Qp3s + 8.67E-2 Qp 3y + 7.53E-7 QH3S + 6.87E-6 QH3V Each of the release rate quantiti es in th e above equations are defined as: 131012v =Release rate ofl-131 from MP2 V e nt (µCi/sec)* 131012s = Release rate ofl-131 from MP2 to Millstone Stack (µCi/sec) 133Q12v = Release rate of I-133 from MP2 Vent (µCi/sec)* 133Q12s = Release rate of I-133 from MP2 to Millstone Stack (µCi/sec) 131Q13y =Release rate ofl-131 from MP3 Vents (Normal and ESF) (µCi/sec)* STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 56 of 137 131Q13s = Release rate ofl-131 from MP3 to Millstone Stack (µCi/sec) 133Q13y = Release rate of I-133 from MP3 Vents (Normal and ESF) (µCi/sec)* 133Q13s = Release rate of I-133 from MP3 to Millstone Stack (µCi/sec) QHlV = Release rate of tritium from the Spent Fuel Pool Island and Balance of Plant Vents (µCi/sec) QH2v = Release rate of tritium from MP2 Vent (µCi/sec)* QH2s = Release rate of tritium from MP2 to Millstone Stack (µCi/sec) QH3V = Releas e rate of tritium from MP3 Vents (Normal and ESF) (µCi/sec)* QH3S = Release rate of tritium from MP3 to Millstone Stack (µCi/s e c) Qp1v = Release rate of total particulates with half-lives greater than 8 days from the Spent Fuel Pool Island Vent (µCi/sec) Qprn = Release rate of total particulates with half-lives greater than 8 days from the Balance of Plant Vent (µCi/sec) Qpzy = Release rate of total particulates with half-lives greater than 8 days from the MP2 Vent (µCi/sec) QP2s = Release rate of total particulates with half-lives greater than 8 days from MP2 to Millstone Stack (µCi/sec) Qp3y = Release rate of total particulates with half-lives greater than 8 days from MP3 Vents (Normal and ESF) (µCi/sec) Qp3s = Release rate of total particulates with half-lives greater than 8 days from MP3 to Millstone Stack (µCi/sec)
* includes releases via the steam generator blowdown tank vent. c. Method 2 The above Method 1 equations assume a conservative nuclide mix. If necessary, use the methodology given in Regulatory Guide 1.109 to estimate the dose rate from either noble gases or iodines, tritium, and particulates with half-lives greater than 8 days. 2. 10 CFR50 Appendix I -Noble Gas Limits Use the methodology of Regulatory Guide 1.109 Rev.l, to calculate the critical site boundary gamma air and beta air doses at least once per 31 days (monthly).
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 57 of 137 For calculations p erfo rm e d once every 31 days , e nt er th e following meteorology:
Release Point Sit e Stack Mixed-mode or rooftop (e.g., vents) Ground y)Q 8.92E-7 8.lE-6 3.28E-5 D/Q 8.84E-9 l.5E-7 l.68E-7 If th e calculated air dos e excee d s one half th e quarterly Radiological Effl u e nt Control limit , u se met e orology concurrent with quart er of release. Results of these do se calculations sha ll be s umm ed to d etermine comp li ance with quart erly and annual dos e limit s for eac h Unit. For calculations of quart erly do ses for the Radioacti ve Effl u ent R e leas e R epor t , u se average quart e rl y or real-time meteorology.
STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 58 of 137 
: 3. 10 CFR50 Appendix I -Iodine, Tritium , C-14 , and Particulate Doses For each Unit, whole body and maximum organ doses from I-131, I-133, tritium, C-14 and particulates with half-lives greater than 8 days in gaseous effluents shall be calculated at least once per 31 days ( or monthly) using the methodology of Regulatory Guide 1.109, Rev.l. For calculations performed once every 31 days , enter the following meteorology:
Release Point Site Stack Mixed-mode or rooftop (e.g., v e nts) Ground x)Q 8.92E-7 8.lE-6 3.28E-5 D/Q 8.84E-9 l.5E-7 l.68E-7 The calculation shall include contributions from all analyses required by Table I.D-1 for Unit 1, Table I.D-2 for Unit 2, and Table I.D-3 for Unit 3 recorded to date. If any required analyses have not yet been completed for the dose period, an estimate of dose from unanalyzed isotopes shall be included in the dose total. If the calculated dose exceeds one-half the quarterly Radiological Effluent Control limit, use meteorology concurrent with the dose period. Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit. For calculations of quarterly doses for the Radioactive Effluent Release Report, use average quarterly or real-time meteorology. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 59 of 137 
: 4. Gaseous Effluent Monthly Dose Projections Section I.D.2.a. of the REMM requires that certain portions of the gaseous radwaste treatment equipment be returned to service to reduce radioactive gaseous effluents when the projected doses for each Unit (made at l east once per 31 days) exceed 0.02 rnrad gamma air, 0.04 rnrad beta air , or 0.03 rnrem to any organ from gaseous effluents.
The following methods are app li ed in the estimation of monthly dos e proj ec tions. a. Unit 1 Projection Method None required. b. Unit 2 Projection M e thod 1) Due to Gaseous Radwaste Treatment System (Unit 2) Determine the b e ta and gamma monthly air dose projection from noble gases from the following:
D E MG (mrad) = 5E-4 CEN DEMB (rnrad) = 3E-4 cEN D E MO (mrem) = 3E-4 CEN Wh ere: cEN = the numb e r of curies of noble gas estimated to be released from the waste gas storage tanks during the next month. D E MG = the estimated monthly gamma air dose. D E MB= the estimated monthly b eta air dose. D EM o= the estimated monthly organ dose. 2) (Reserved)
: 3) Due to Ventilation Releases (Unit 2) If portions of th e ventilation treatment system are expected to be out of service during the month , determine the monthly maximum organ dose projection (D EM O ) from the following:
: 1. Method 1 Determine D E MO which is the estimated monthly dose to the maximum organ from th e following:
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 60 of 137 DEMO= 1/3 R1 (l.01-R2) (R3+ 0.01) Do For the last quarter of operation , determine Do as determined per Section II.D.3. R1 = the expected reduction factor for the HEPA filter. Typically this should be 100 (see NUREG-0016 or 0017 for additional guidance).
R 2 = the fraction of the time which th e equipment was nonfunctional during the last quarter. R 3 = the fraction of the time which the equipment is expected to be nonfunctional during the next month. Do = maximum organ dose from the previous month. 11. Method 2 If necessary, es timate the curies expected to be released for the next month and applicable method for dose calculation from Section II.D.3. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 61 of 137 
: c. Unit 3 Projection Method 1) Du e to Radioactive Gaseous Waste System (Unit 3) D etermine the beta and gamma monthly air dose projection from noble gases from the following:
DEMG (mrad) = 5E-4 CEN DEMB (rnrad) = 3E-4 CEN DEMO (mrem) = 3E-4 CEN Where: cEN = the number of additional curies of noble gas estimated to be released from Unit 3 during the next month due to the nonfunctional processing equipment.
DEMG = the estimated monthly gamma air dose. DEMB = the estimated monthly beta air dose. DEMO = the estimated monthly organ dose. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 62 of 137 
: 5. Compliance with 40CFR190 The following sources shall be considered in determining the total dose to any real member of the public, at or beyond the site boundary , from uranium fuel cycle sources: a. Gaseous Releases from Units 1 , 2, and 3. b. Liquid Releases from Units 1 , 2, and 3. c. Direct and Scattered Radiation from Radioactive Material on Site. d. Direct and Scattered Radiation from the Independent Sp e nt Fuel Storage Installation (ISSFSI).
Doses shall be obtained per th e requirements of Section 11.C.1 for liquid releases and Section II.D.2 and II.D.3 for gaseous releases.
Direct and scattered radiation doses shall be calculated.
Doses from all sources shall b e added to determine compliance with 40CFR190.
STOP THINK ACT MP-22-REC-BAPOl REV I EW Rev. 029 63 of 137 ILE. Liquid Discharge Flow Rates And Monitor Setpoints
: 1. Unit 1 Liquid Waste Effluent Discharge (RE-MG-110)
The limit on discharge flow rate and setpoint on the Unit 1 liquid waste monitor depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used: STEP 1: From the isotopic analysis and the Effluent Concentration (EC) values for each identified nuclide determine the required reduction factor, i.e.: R = R e quired Reduction Factor = c l '\:""' o f nuclid e i STEP 2: Determine the allowable discharge flow (F) F = O.lxRxD Where: L...., 10 x E C of nuclid e i D = The existing dilution flow which is the any dilution flow from Millstone Unit 2 and/or Unit 3 not being credited for any other radioactivity discharge during discharge of Unit 1 water. 0.1 = safety factor to limit discharge concentration to 10% of the Radiological Effluent Control Limit. STEP 3: Calculate the monitor setpoint as follows: Rset = 2 x AC x RCF + Background Where: Rset = The setpoint of the monitor. AC = The total radwaste effluent concentration
(µCi/ml) in the tank. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 64 of 137 RCF = The response correction factor for the effluent line monitor using the current calibration factor or isotopic-specific responses.
2 = Tolerance limit which brings the setpoint at twice the expected response of the monitor based on sample analysis.
With the safety factor of 0.1 the setpoint would be at 20% of the Radiological Effluent Control Limit. Option setpoint:
A setpoint based upon worst case conditions may be used. Assume the maximum possible discharge flow, a minimum dilution flow not to exceed 100,000 gpm, and a limit of 1 x 10-7 µCi/ml which is lower than any 10CFR20 EC limit except for transuranics.
This will assure that low level releases are not terminated due to small fluctuations in radioactivity.
When using this option setpoint independent verification of discharge lineup shall be performed.
The optional setpoint may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.
: 2. Reserved 3. Unit 2 Clean Liquid Radwaste Effluent Line -RM9049 and Aerated Liquid Radwaste Effluent Line -RM9116 The setpoint on the Unit 2 clean and aerated liquid waste effluent lines depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, an alarm/trip setpoint will be determined prior to the release of each batch. The following method will be used: STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 65 of 137 STEP 1: From the tank isotopic analysis and the Effluent Concentrations (EC) in 10CFR20, App. B, Table 2, Col. 2 for each identified nuclide determine the required reduction factor, i.e.: For Nuclides Other Than Noble Gases: 1 R 1 = Required Reduction Factor=--------
"' 'ff of nuclid e i L..., 10 x EC o f nuclid e i For Noble Gases: If the noble gas concentration is less than 1.1 x 10-2 µCi/ml or the calculated diluted concentration is less than 2 x 10-5 µCi/ml, the reduction factor need not be determined.
The concentration of 1.1 x 10-2 µCi/ml is based on 175 gpm discharge flow, 100,000 gpm dilution flow, and a safety factor of 0.1 (See Note below.) If dilution flow is less than 100,000 gpm, the noble gas concentration limit shall be decreased by the ratio of actual dilution flow to 100,000gpm.
For example, if dilution flow is 50,000 gpm, the limit would be reduced by a factor of 0.5 (50,000/100,000).
R 2 = Required Reduction Factor = c 1 "' l!;;;f of nobl e g a se s 2 X 10-4µC i ml "' C' L..., µm/ noble gases R = the smaller of R 1 or R2 STEP 2: L._, 2 X 10-4uCi ml Determine the allowable discharge flow (F) in gpm: F=O.lxRxD Where: D = the existing dilution flow (D) from circulating and service water pumps. It may include any Unit 3 flow, or portion of Unit 3 flow, not being credited for dilution of a Unit 3 radioactivity discharge during the time of the Unit 2 discharge.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 66 of 137 NOTE Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1. With this condition on discharge flow rate met , the monitor setpoint can be calculated:
Rset 2 x AC x RF (See Note 1 below.) Where: Rset = the setpoint of the monitor ( cpm). AC = the total radwaste effluent concentration
(µCi/ml) in the tank. RF = the response factor for the effluent line monitor using the current calibration factor or isotopic-specific responses.
2 = the multiple of expected count rate on the monitor based on the radioactivity concentration in the tank. This value or that corresponding to 5.6 x 10-5 µCi/ml (Note 2 below), whichever is greater , plus background is the trip setpoint.
For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.
Note 1: If discharging at the allowable discharge rate (F) as determined in abov e , this setpoint would correspond to 20% of the Radiological Effluent Control limit. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 67 of 137 Note 2: This va lu e is bas e d upon assuming maximum discharg e flow (175 gpm), dilution water flow of 100,000 gpm and a limit of 1 x 10-7 which is lower than any Technical Specification limit (ten times 10CFR20 EC values) except for transuranics.
This will assure that low l evel releases are not terminated du e to small fluctuations in radioactivity activity.
However, to verify that the correct tank is being discharged when using this va lu e, independent valve verification shall be performed.
This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however , controls shall b e established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.
Dilution flow may include any Unit 3 flow , or a portion of Unit 3 flow , not being credited for dilution of a Unit 3 radioactive discharge during the time of th e Unit 2 discharg e. 4. Condensate Polishing Facility Waste Neutralization Sump Effluent Line -CND245 The setpoint shall be determined as for the Clean and Aerated Liquid Monitors in Section 11.E.3. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 68 of 137 
: 5. Unit 2 Stearn Generator Blowdown -RM4262 and Unit 2 Stearn Generator Blowdown Effluent Concentration Limitation 5a. Unit 2 Stearn Generator Blowdown -RM4262 Alarm ::; 800 CPM + background This setpoint may be adjusted (increased or decreased) through proper administrative controls.
Adjust e d alarm 6 C'P'M X circulating
& s e rvic e wat e r flow (gpm) :5 + Ba c kground total SG blowdown (gpm) When using the adjusted alarm , ensure that any other simultaneous discharge does not cause an exceedance of regulatory limits. 5b. Unit 2 Stearn Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I. C. -2 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed ten times the concentration limits in 10CFR20 , Appendix B. 6. Unit 2 Condenser Air Ejector -RM5099 N I A since this monitor is no longer a final liquid effluent monitor. 7. Unit 2 Reactor Building Closed Cooling Water RM6038 and Unit 2 Service Water , and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation 7a. Unit 2 Reactor Building Closed Cooling Water RM6038 The purpose of the Reactor Building Closed Cooling Water (RBCCW) radiation monitor is to give warning of abnormal radioactivity in the RBCCW system and to prevent releases to the Service Water system which, upon release to the environment, would exceed ten times the concentration values in 10CFR20. According to Calculation RERM-02665-R2 , radioactivity in RBCCW water which causes a monitor response of greater than the setpoint prescribed below could exceed ten times thelOCFR20 concentrations upon release to the Service Water system. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 69 of 137 SETPOINT DURING POWER OPERATIONS:
To give adequate warning of abnormal radioactivity, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 2,000 cpm. The monitor background reading shall be the normal monitor reading. If the monitor background reading exceeds 2,000 cpm, the setpoint shall be set at the background reading plus 2,000 cpm and provisions shall be made to adjust the setpoint if the background decreases.
SETPOINT DURING SHUTDOWN:
: 1) During outages not exceeding three months the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 415 cpm. If the monitor background reading exceeds 415 cpm, the setpoint shall be set at the background reading plus 415 cpm and provisions shall be made to adjust the setpoint if the background decreases.
: 2) During extended outages exceeding three months, but not exceeding three years, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 80 cpm. If the monitor background reading exceeds 80 cpm , the setpoint shall be set at the background reading plus 80 cpm and provisions shall be made to adjust the setpoint if the background decreases.
PROVISIONS FOR ALTERNATE DILUTION FLOWS: These setpoints are based on a dilution flow of 4,000 gpm from one service water train. If additional dilution flow is credited, the setpoint may be adjusted proportionately.
For example, the addition of a circulating water pump dilution flow of 100,000 gpm would allow the setpoint to be increased by a factor of 25. 7b. Unit 2 Service Water, and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water , RBCCW sump and turbine building sump samples taken in accordance with Table I.C.-2 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water, RBCCW sump and turbine building sump effluents to less than ten times the limits in 10CFR20, Appendix B. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 70 of 137 
: 8. Unit 3 Liquid Waste Monitor -LWS-RE70 The setpoints on the Unit 3 liquid waste monitor depend on dilution water flow, radwaste discharge flow , the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used: Step 1: From the tank isotopic analysis and the Effluent Concentration (EC) values for each identified nuclide determine the required reduction factor, i.e.: For Nuclides Other Than Noble Gases: 1 R 1 = R e quir e d Reduction Factor = ----=----' o f n ucl id e i L 10 x E C o f nuclid e i For Noble Gases: If the noble gas concentration is less than 0.013 µCi/ml or the calculated diluted concentration is less than 2 x 10-5 µCi/ml, the reduction factor need not be determined.
The concentration of 0.013 µCi/ml is based on 100,00 gpm dilution flow and a safety factor of 0.1 (See Note Below.) If dilution flow is less than 100,000 gpm, the noble gas concentration limit shall be decreased by the ratio of actual dilution flow to 100 , 000gpm. For example, if dilution flow is 50 , 000 gpm, the limit would be reduced by a factor of 0.5 (50,000/100,000).
R 2 = Required Reduction Factor= ---=1, o f nobl e g a se s L 2 X 10-4<<Ci ml R = the smaller of Rl or R2 Step 2: Determine the allowable discharge flow (F) F = O.lxRxD Where: 2 X 10-4&#xb5;C i ml ' C" L ~1/ noble gases D = The existing dilution flow (D) from circulating and service water pumps. It may include any Unit 2 flow, or portion of Unit 2 flow , not being credited for dilution of a Unit 2 radioactivity discharge during the time of the Unit 3 discharge.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 71 of 137 NOTE Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1. With this condition on discharge flow rate met, the monitor setpoint can be calculated:
Rset = 2 x AC x RCF (see Note 1) Where: Rset= The setpoint of the monitor. AC= The total radwaste effluent concentration
(&#xb5;Ci/ml ) in the tank. RCF= The response correction factor for the effluent line monitor using the current calibration factor or isotopic-specific responses. 2 The multiple of expected count rate on the monitor based on th e radioactivity concentration in the tank. This value, or that corresponding to 6.6 x 10-5 &#xb5;Ci/ml (Note 2 below), whichever is greater, plus background is the trip setpoint.
For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 72 of 137 NOTE 1. If discharging at the allowable discharge rate (F) as determined above, this Alarm setpoint would yield a discharge concentration corresponding to 20% of the Radiological Effluent Control limit. 2. This value is based upon assuming maximum discharge flow (150 gpm), dilution water flow of 100,000 gpm, and a limit of 1 x 10-7 &#xb5;Ci/ml which is lower than any Technical Specification limit (ten times 10CFR20 EC values) except for transuranics.
This will assure that low level releases are not terminated due to small fluctuations in radioactivity.
However, to verify that the correct tank is being discharged when using this value, independent valve verification shall be performed.
This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.
Dilution flow may include Unit 2 flow, or portion of Unit 2 flow, not being credited for dilution of a Unit 2 discharge during the time of the Unit 3 discharge.
: 9. Unit 3 Regenerant Evaporator Effluent Line -LWC-RE65 The MP3 Regenerant Evaporator has been removed from service with DCR M3-97-041.
Therefore a radiation monitor alarm is not needed. 10. Unit 3 Waste Neutralization Sump Effluent Line -CND-RE07 Same as Section II.E.8. 11. Unit 3 Steam Generator Blowdown -SSR-RE08 and Unit 3 Steam Generator Blowdown Effluent Concentration Limitation lla. Unit 3 Steam Generator Blowdown -SSR-RE08 The alarm setpoint for this monitor assumes: a. Steam generator blowdown rate of 400 gpm (maximum blowdown total including weekly cleaning of generators
-per ERC 25212-ER-99-0133).
: b. The release rate limit is conservatively set at 3 x 10-8 &#xb5;Ci/ml which is well below any 10CFR20 Effluent Concentration except for transuranics
*. c. Circulating and service water dilution flow during periods of blowdown = 100,000 gpm. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 73 of 137 
: d. Background can be added after above calculations are performed.
Therefore , the alarm setpoint corresponds to a concentration of: Alarm (&#xb5;Ci/m[) = lO~O~OO x 3xl0-8 + background
= 7.5xl0-{i
&#xb5;Ci/ml + background This setpoint may be increased through proper administrative controls if the steam generator blowdown rate is maintained less than 400 gpm and/or more than 100,000 gpm dilution flow are available.
The amount of the increase would correspond to the ratio of flows to those assumed above or: ci rculatin g & service water flow (gpm) 400 Alarm (&#xb5;Ci/ ml) = 7.SxlO-<J&#xb5;Ci/ ml x x--------100, 000 S/ G blowdown (gpm) circulating
& se rvic e wat e r flow (gpm) Ba c kground = 3xl0-8&#xb5;Ci/ ml x + Background total S/ G blowdown (gpm) When using the adjusted alarm, ensure that any other simultaneous discharge does not cause an exceedance of regulatory limits. NOTE The Steam Generator Blowdown alarm criteria is in practice based on setpoints required to detect allowable levels of primary to secondary leakage. This alarm criteria is typically more restrictive than that required to meet discharge limits. This fact shall be verified, however, whenever the alarm setpoint is recalculated.
* In lieu of using 3 x 10-8 &#xb5;Ci/ml, ten times the identified 10CFR20 EC values may be used. llb. Unit 3 Steam Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I.C.-3 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed ten times the concentration limits in 10CFR20, Appendix B. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 74 of 137 
: 12. Unit 3 Turbine Building Floor Drains Effluent Line -DAS-RE50 and Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation 12a. Unit 3 Turbine Building Floor Drains Effluent Line -DAS-RE50 The alarm setpoint for this monitor shall be set to four times (4X) the reading of the monitor when there is no gamma radioactivity present in the turbine building sumps. As determined in Calculation RERM-04101R3, the setpoint shall not exceed 1.4 x 10-5 &#xb5;Ci/ml. 12b. Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water and turbine building sump samples taken in accordance with Table I.C.-3 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water and turbine building sump effluents to less than ten times the limits in 10CFR20, Appendix B. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 75 of 137 II.F. Gaseous Monitor Setpoints
: 1. Unit 1 Spent Fuel Pool Island Monitor -RM-SFPI-02 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section 11.D.1.a. in order to satisfy Unit 1 Radiological Effluent Controls III.C.2. and III.D.2.a.
The Unit 1 allocated portion of the site instantaneous release rate limit is 30 , 000 &#xb5;Ci/sec. This assumes that 7% of the site limit for skin dose of 3000 mrem per year is assigned to the Unit 1 Spent Fuel Pool Island vent. If effluent conditions from the Unit 1 Spent Fuel Pool Island vent reach 30,000 &#xb5;Ci/sec, releases from Units 2 and 3 vents and from the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site skin dose limit to be exceeded.
Use Section 11.D.1.a.
and Section 4.2 of MP-22-REC-REF03. "REMODCM Technical Information Document," in making this determination.
The alarm setpoint shall be set at or below the monitor reading in &#xb5;Ci/cc corresponding to the Unit 1 portion of the limit. The setpoint shall be set at or below 1.71E-3 &#xb5;Ci/cc. NOTE: This setpoint is the basis for emergency classification in Unit 1 EAL Table (OA-1 and OU-1). A change to this setpoint would require a concurrent change to the EAL. 2. Unit 2 Wide Range Gas Monitor (WRGM) -RM8169 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section 11.D.1.a.
in order to satisfy Units 2 Radiological Effluent Controls IVC.2. and IVD.2.a. For releases from Unit 2 to the Millstone Stack , the allocated portion of the site instantaneous release rate limit is 72,000 &#xb5;Ci/sec. This assumes that 13% of the site limit is assigned to Unit 2 releases to the Millstone Stack. If effluent conditions from Unit 2 releases to the Millstone Stack reach 72,000 &#xb5;Ci/sec, releases from Units 1, 2 , and 3 vents and from Unit 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section 11.D.1.a. and Section 4.2 of MP-22-REC-REF03, "REMODCM Technical Information Document," in making this determination.
The alarm setpoint shall be set at or below the monitor reading in &#xb5;Ci/cc corresponding to the Unit 2 release to the stack portion of the limit. The setpoint shall be set at or below 1.3E-2 &#xb5;Ci/cc. 3. Reserved STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 76 of 137 
: 4. Unit 3 SLCRS -HVR-RE19B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a.
in order to satisfy Unit 3 Radiological Effluent Controls VC.2. and VD.2.a. For releases from Unit 3 to the Millstone Stack, the allocated portion of the site instantaneous release rate limit is 72,000 &#xb5;Ci/sec. This assumes that 13% of the site limit is assigned to Unit 3 releases to the Millstone Stack. If effluent conditions from Unit 3 releases to the Millstone Stack reach 72,000 &#xb5;Ci/sec , releases from Units 1 and 2 vents, Unit 3 ESF vent and from Unit 2 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site dose limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , " REMODCM Technical Information Document ," in making this determination.
The alarm setpoint shall be set at or below the monitor reading in &#xb5;Ci/cc corresponding to the Unit 3 release to the stack portion of the limit. The setpoint shall be set at or below 1.16 E-2 &#xb5;Ci/cc. 5. Unit 2 Vent -Noble Gas Monitor -RM8132B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a.
in order to satisfy the Unit 2 Radiological Effluent Controls in Sections IVC.2. and IVD.2.a. For releases from Unit 2 vent, the allocated portion of the site instantaneous release rate limit is 95,000 &#xb5;Ci/sec. This assumes that 33% of the site limit is assigned to Unit 2 vent releases. If effluent conditions from Unit 2 vent releases reach 95,000 &#xb5;Ci/sec, releases from Units 1 and 3 vents and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , " REMODCM Technical Information Document," in making this determination. The alarm setpoint shall be set at or below the monitor reading in cpm corresponding to the Unit 2 vent portion of the limit. The setpoint shall be set at or below 42,000 CPM. 6. Unit 2 Waste Gas Decay Tank Monitor RM9095 Administratively all waste gas decay tank releases are via the Millstone Stack. Unit 2 has a release rate limit to the Millstone Stack of 72,000 &#xb5;Ci/sec (see the MP-22-REC-REF03 , " REMODCM Technical Information Document," Section 4.2 for bases). STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 77 of 137 Batch releases of waste gas shall be limited to less than 10% of the Unit 2 releases to the Millstone Stack release rate limits. Therefore , the waste gas decay tank monitor setpoint should be set not to exceed 7 ,2 00 &#xb5;Ci/sec. If the setpoint exceeds 7,200 &#xb5;Ci/se c, the release shall be automatically terminated. The MP2 waste gas decay tank monitor (given &#xb5;Ci/cc per cpm) calibration curve and the tank discharge rate is used to assure that the concentration of gaseous radioactivity being released from a waste gas decay tank does not cause the setpoint of 7,200 &#xb5;Ci/sec to be exceeded.
: 7. Unit 3 Vent Noble Gas Monitor -HVR-RElOB The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a.
in order to satisfy Unit 3 Radiological Effluent Controls in Sections V.C.2. and V.D.2.a. For releases from Unit 3 vent, the allocated portion of the site instantaneous release rate limit is 95,000 &#xb5;Ci/se c. This assumes that 33% of the site limit is assigned to Unit 3 vent releases.
If effluent conditions from Unit 3 vent releases reach 95,000 &#xb5;Ci/se c , releases from Units 1 and 2 vents, Unit 3 ESF vent and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , "REMO DCM Technical Information Document ," in making this determination.
The alarm setpoint shall be set at or below the monitor reading corresponding to the Unit 3 vent portion of the limit. The setpoint shall be set at or below 8.4 x 10-4 &#xb5;Ci/cc. 8. Unit 3 Engineering Safeguards Building Monitor -HVQ-RE49 For releases from Unit 3 ESF vent , the allocated portion of the site instantaneous release rate limit is 2,900 &#xb5;Ci/sec. This applies 1 % of the Unit 3 Vent release rate limit (see Section II.D.l.a.) to Unit 3 ESF vent releases. If effluent conditions from Unit 3 ESF vent releases reach 2,900 &#xb5;Ci/sec, releases from Units 1 and 2 vents, Unit 3 vent and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , " REMODCM Technical Information Document," in making this determination.
The Alarm setpoint shall be set at or below the value of 5.9E-4 &#xb5;Ci/cc. This setpoint assumes a monitor flow rate of 10,500 cfm. However, only 6,000 cfm is monitored.
By assuming 10,500 cfm the setpoint is conservatively low. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 78 of 137 APPENDIX II.A REMODCM METHODOLOGY CROSS-REFERENCES Radiological effluent controls (Sections III, IV, and V) identify the requirements for monitoring and limiting liquid and gaseous effluents releases from the site such the resulting dose impacts to members of the public are kept to '~ Low As Reasonably Achievable" (ALARA). The demonstration of compliance with the dose limits is by calculational models that are implemented by Section II of the REMODCM. Table App. II.A-1 provides a cross-reference guide between liquid and gaseous effluent release limits and those sections of the REMODCM, which are used to determine compliance.
It also shows the administrative Technical Specifications which r e ference the REMO DCM for operation of radioactive waste processing equipment.
This table also provides a quick outline of the applicable limits or dose objectives and the required actions if those limits are exceeded.
Details of the effluent control requirements and the implementing sections of the REMO DCM should be reviewed directly for a full explanation of the requirements.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 79 of 137 Table 11.A.-1 Millstone Effluent Requirement s and Methodology Cross Reference R a diological REMODCM Applicable Limit or E xposur e R eq uired Action Effluent Controls & Methodology Obj ect i ve Period Technical Section Specifications IV N.E.l.a Tables l.C.-2 Ten times 10CFR20App
.B , Instantaneous Restore concentration to within lim-Liquid Effluent and I.C.-3 Table 2, Column 2, & 2x10-4 its within 15 mins. Concentratio n &#xb5;Ci/mL for dissolved noble gases* IVN.E.l.b 11.C.l. :5 1.5 mrem T.B. Calendar Quar-30-day report if exceeded.
Relative Dose-L i quids :5 5 mrem Organ ter** acc u racy or conservat i sm of the ca l-11.C.l. :5 3 mrem T.B. Cale ndar Year cu l ations s h a ll be confirmed by per-:5 10 mrem Org a n fo rm a nc e of the REMP in Secti o n I. T.S. 6.16 & 6.20(Unit
: 2) I.C.2. :5 0.06 mrem T.B. Projected for 31 R et urn to operat i o n L i q u id Waste T.S. 6.14 & 6.15 (Unit 3) 11.C.2. :5 0.2 mrem Organ days (if system ueatment System Liquid Radwaste ueat-n o t in use) ment 111.D.2.a Tables I.D.-1, :5 500 mrem/yr T.B. from Instantaneous R estore release rates to within spec-IVN.D.2.a I.D.-2 , & noble gases* ifications within 15 minutes T.S. 6.20 (Un it 2) I.D-3 T.S. 6.15 (Unit 3) 11.D.l.a. :5 3000 mrem/yr skin fro m Gaseous Effluen t s D ose noble gases* R ate 11.D.l.b. :5 1500 mr em/yr orga n from particu l ates with T 112 > 8 d., 1-131 , 1-133 & tritium* 111.D.2.b 11.D.2. :5 5 mrad gamma air Ca l e ndar Quar-30-day report if exceeded IVN.D.2.bD ose Noble :5 10 mrad beta air ter** Gases :5 10 mrad gamma air Calendar Year :5 20 mrad beta air III.D.2.c 11.D.3. :,; 7 .5 mrem organ Calendar Quar-30-day report if exceeded.
R elative IVN.D.2.c ter** accuracy or conservat ism of the cal-Dose 1-131, 1-133, Par-cu l at i o n s shall be confirmed by per-ticulat es, H-3 :,; 15 mrem organ Calendar Year formance of the REMP in Section I. T.S. 5.6.4 (Un it 1) 11.D.2. > 0.02 mrad gamma a ir Projected for 31 R e turn t o operation Gaseous R ad-T.S. 6.14 (Un it 2) 11.D.4. > 0.04 mr ad bet a air D ays (if system waste Treatment System T.S 6.14 & T.S 6.15 (U3) > 0.03 mrem organ n o t in u se) Gaseous R adwaste ueatment 11.E 11.D.5. :52 5 mrem T.B.* 12 Consecutive 30-day report if Unit 1 Effluent IVIN.F :5 25 mrem organ* M o nths** Contro l 111.D.1.2 , 111.D.2.2, or Total Dose :5 75 mrem thyroid* III.D.2.3 or Units 2/3 Effluent Con-trol IVN.E.1.2, IVN.E.2.2 , or IV/ V.E.2.3 are exceeded by a factor of 2. R estore dose to pub li c t o within the app li cab l e E PA lirnit (s) or ob-tain a variance NOTE: T.B. means tota l or whole b o dy.
* Applies to the entire site (Units 1 , 2 , and 3) discharges combined.
**Cumulative dose contributions calculated once per 31 days. MP-22-REC-BAPOl STOP THINK ACT REVIEW R ev. 029 80 of 137 SECTION III. Millstone Unit 1 Radiological Effluent Controls Docket Nos. 50-245 MP-22-REC-BAP Ol STOP THINK ACT REVIEW R ev. 0 29 81 of 1 37 SECTION III. REMODCM UNIT ONE CONTROLS III.A. Introduction The purpose of this section is to provide the following for Millstone Unit One: a. the effluent radiation monitor contro ls and surveillance requirements, b. the effluent radioactivity concentration and dose controls and surveillance requirements, and c. the ba ses for the controls and surve illanc e requirements.
D efinitions of certain terms are provided as an aid for implementation of the controls and requirements.
Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions III.B. Definitions and Surveillance Requirement (SR) Applicability III.B.1 -Definitions The defined terms of this sub-section appear in capitalized type and are applicable throughout Section III. 1. ACTION -that part of a Control that prescribes remedial measures required under designated conditions.
: 2. INSTRUMENT CALIBRATION
-the adjustment, as necessary, of the instrument output such that it responds within the necessary range and accuracy to know values of the param eter that the instrument monitors.
The INSTRUMENT CALIBRATION shall encompass those components, such as sensors, displays, and trip functions, required to perform the specified safety function(s).
The INSTRUMENT CALIBRATION shall include the INSTRUMENT FUNCTIONAL TEST and may be performed by means of any series of seq u ential , overlapping, or total channel steps so that the entire channe l is calibrated.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 82 of 137 
: 3. INSTRUMENT FUNCTIONAL TEST -the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify that the instrument is FUNCTIONAL , including all components in the channel, such as alarms, interlocks, displays, and trip functions, required to perform the specified safety function(s).
For digital instruments, the computer database may be manipulated, in lieu of a signal injection, to verify operability of alarm and/or trip functions.
The INSTRUMENT FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping , or total channel steps so that the entire channel is tested. 4. CHANNEL CHECK -the qualitative determination of functionality by observation of behavior during operation.
This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.
: 5. FUNCTIONAL
-An instrument shall be FUNCTIONAL when it is capable of performing its specified functions(s).
Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).
: 6. REAL MEMBER OF THE PUBLIC -an individual, not occupationally associated with the Millstone site, who is exposed to existing dose pathways at one particular location.
This does not include employees of the utility or utilities which own a Millstone plant and utility contractors and vendors. Also excluded are persons who enter the Millstone site to service equipment or to make deliveries. This does include persons who use portions of the Millstone site for recreational, occupational, or other purposes not associated with any of the Millstone plants. 7. SITE BOUNDARY -that line beyond which the land is not owned , leased , or otherwise controlled by the licensee.
: 8. SOURCE CHECK -the qualitative assessment of channel response when the channel is exposed to radiation.
: 9. RADIOACTIVE WASTE TREATMENT SYSTEMS -Radioactive Waste Treatment Systems are those liquid, gaseous, and solid waste systems which are required to maintain control over radioactive materials in order to meet the controls set forth in this section. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 83 of 137 111.B.2 -Surveillance Requirement (SR) Applicability
: 1. SRs shall be met during specific conditions in the Applicability for individual LCOs unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in III.B.2 3. Surveillances do not have to be performed on nonfunctional equipment or variables outside specified limits. 2. The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the frequency is met. 3. If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LCO not met may be delayed from the time of discovery up to 24 hours or up to the limit of the specified frequency, whichever is less. This delay period is permitted to allow performance of the surveillance.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met and the applicable Condition(s) must be entered. The Completion Times of the Required Actions begin immediately upon expiration of the delay period. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met and the applicable Condition(s) must be entered. The Completion Times of the Required Actions begin immediately upon failure to meet the Surveillance.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 84 of 137 III.C. Radioactive Effluent Monitoring Instrumentation
: 1. Radioactive Liquid Effluent Monitoring Instrumentation CONTROLS The radioactive liquid effluent monitoring instrumentation channels shown in Table III.C.-1 shall be FUNCTIONAL with applicable alarm/trip setpo ints set to ensure that the limits of Specification III.D.l.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section IL APPLICABILITY:
As shown in Table III.C.-1 ACTION: a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, without delay suspend the release of radioactive liquid effl u ents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptab l y conservative.
: b. With th e number of channels l ess than the minimum channels FUNCTIONAL requirement, take the action shown in Table III.C.-1.
Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, exp lain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table III.C.-2.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 85 of 137 TABLE 111.C.-1 Radioactive Liquid Effluent Monitoring Instrumentation Instrument Action wh e n not functional Notes 1. Liquid Waste Effluent Monitor (RE-MG-110)
A 1 , 2 1. Whenever the pathway is being used except that outages are permitted, for a maximum of 12 hours, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.
: 2. Alarm setpoint required.
Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release: (1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C-1 and; (2) The original release rate calculations and discharge valving are independently verified by a second individual.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 86 of 137 TABLE 111.C.-2 Radioactive Liquid Effiuent Monitoring Instrumentation Surveillance Requirements Instrument Channel Source Channel Channel Check Check Calibration Functional Test 1. Liquid Waste Effl uent Monitor (RE-MG-110)
D* p T(l) Q
* D p T Q Daily Prior to each batch release Once every two years Once every 3 months During releases via this pathway and when the monitor is required FUNCT IONAL per Table 111.C.-1. The CHANNEL CHECK should be done when the discharge is in progress.
(1) Calibration shall include the use of a radioactive liquid or solid source which is traceable to an NIST source. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 87 of 137 
: 2. Radioactive Gaseous Effluent Monitoring Instrumentation CONTROLS The radioactive gaseous effluent monitoring instrumentation channels shown in Table III.C.-3 shall be FUNCTIONAL with applicable alarm setpoints set to ensure that the limits of Control III.D.2.a.
are not exceeded.
The setpoints shall be determined in accordance with methods and parameters described in Section II.F. l. APPLICABILITY:
As shown in Table III.C.-3 ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel alarm setpoint less conservative than required by the above Control, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.
: b. With the number of channels less than the minimum channels functional requirements, take the action shown in Table III.C.-3.
Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radiological Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the INSTRUMENT CHECK, INSTRUMENT CALIBRATION, INSTRUMENT FUNCTIONAL TEST, and SOURCE CHECK operations at the frequencies shown in Table III.C.-4.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 88 of 137 TABLE 111.C.-3 Radioactive Gaseous Effluent Monitoring Instrumentation Ins trum ent Ac tion w h en not functional Not es l.Spent F u e l Po ol Island Vent (a) No bl e Gas Radioactivity Monitor A 1,2 (b) Particulate Sampler B 1 (c) Ven t Flow Rate Monit or C 1 (d) Sampler Flow R ate Monitor D 1,2 2.B a l ance of Pl ant Vent (a) P a rticul a t e Sampler B 1 (b) Sampler F l ow Monitor D 1 1. Channels are FUNCT ION AL and in service on a continuous , uninterrupted basis when exhaust fans are operating , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required tests , checks , calibrations , and samp l ing associated with the instrument or any system or component which affects functioning of the instrument.
: 1. Alarm setpoint required.
ACT I ON ST A TEMENTS Action A With the number of channels FU NCTION AL less than required by the Minimum Channels FUNCTI ON AL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken daily when fuel is being moved , or during any evolution or event which would threaten fuel integrity , and these samples are analyzed for gamma radioactivity within 24 hours. Action B With the number of samplers FUNCT IO NAL le ss than required by the Minimum number FUNCT ION AL requirement , effluent releases via this path w ay may continue provided that the best efforts are made to repair the instrument and that a 24 hour duration samp l e i s collected with auxiliary sampling equipment once every se v en (7) days, or anytime s i gnificant I generation of airborne radioactivit y is expected , and analyzed for principal gamma emitters with half l i ves greater than 8 days within 48 hours after the end of the sampling period. Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. I Act i on C With the number of channels FUNCTI ON AL l ess than required by the Minimum Channels FUNCT ION AL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument.
Action D With the number of channels FU NCTION AL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once during the Chemistry compensatory sampling time period as specified in Action A or Action B. Sample flow rate need not be estimated if the auxiliary sampling equ i pment of Action B is in use. MP-22-REC-BAPOl STOP THINK ACT REVIEW R ev. 029 89 of 137 TABLE 111.C.-4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Instrument Functional Source Check Calibration Test Check l.Spent Fuel Pool Island Vent (a) Noble Gas Radioactivity Monitor D(J) (b) Particulate Sampler (c) Vent Flow Rate Monitor ( d) Sampler Flow Rate Monitor 2.Balance of Plant Vent (a) Particulate Sampler (b) Sampler Flow Monitor D = Daily W = Weekly TM= Twice per month M = Monthly Q = Once every 3 months T = Once every two years NA = Not Applicable (1) RESERVED (2) RESERVED TM D D TM D Table 111.C.-4 TABLE NOTATION T(6) NA T T NA T (3) Instrument check daily only when there exist releases via this pathway. (4) RESERVED (5) RESERVED Q(7) NA NA NA NA NA (6) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to a source which is traceable to the NIST. These sources shall be in a known reproducible geometry.
(7) The INSTRUMENT FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist: 1. Instrument indicates measured levels above the alarm/trip setpoint.
: 2. Instrument indicates a downscale failure. M NA NA NA NA NA STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 90 of 137 III.D. Radioactive Effiuents Concentrations And Dose Limitations
: 1. Radioactive Liquid Effluents
: a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATIONS The concentration of radioactive material released from the site (see Figure III.D.-1) shall not exceed ten times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases , the concentration shall not exceed 2 x 10-4 &#xb5;Ci/ml total radioactivity.
APPLICABILITY:
At all times. ACTION: With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes. SURVEILLANCE REQUIREMENT Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I. The results of the radioactive analysis shall be used in accordance with the methods of Section ILE to assure that the concentrations at the point I of release are maintained within the limits of Specification III.D.1.a. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 91 of 137 
: b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATIONS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 1 released from the site (see Figure III.D.-1) shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and, b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ. APPLICABILITY:
At all times ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 92 of 137 
: 2. Radioactive Gaseous Effluents
: a. Radioactive Gaseous Effluents Dose Rate CONTROLS The dose rate, at any time, offsite (See Figure III.D.-1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values: a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and, b. The dose rate limit for Tritium and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ. APPLICABILITY:
At all times. ACTION: With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Control III.D.2.a.
within 15 minutes. SURVEILLANCE REQUIREMENT
: 1) The release rate , at any time, corresponding to the above dose rates shall be determined in accordance with the methodology of Section II. 2) The release rate, at any time shall be monitored in accordance with the requirements of Section III.C.2. 3) Sampling and analysis shall be performed in accordance with Section I to assure that the limits of Control III.D.2.a.
are met. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 93 of 137 
: b. Radioactive Gaseous Effluents Noble Gas Dose CONTROLS The air dose offsi te ( see Figure III.D. -1) due to noble gases released in gaseous effluents from Unit 1 shall be limited to the following:
: a. During any calendar quarter , to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;
: b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.
APPLICABILITY:
At all times. ACTION: With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 94 of 137 
: c. Gaseous Effluents
-Dose from Radionuclides Other than Noble Gas CONTROLS The dose to any REAL MEMBER OF THE PUBLIC from Tritium and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 1 (see Figure III.D.-1) shall be limited to the following:
: a. During any calendar quarter to less than or equal to 7.5 mrem to any organ; b. During any calendar year to less than or equal to 15 mrem to any organ. APPLICABILITY:
At all times. ACTION: With the calculated dose from the release of Tritium and radioactive materials in particulate form exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases of radioactive materials in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 95 of 137 0 Figure 111.D.-1, "Site Boundary for Liquid and Gaseous Effluents" -IOOO SC4l.(**El0tl NIAIITIC llAt STOP THINK ---ACT ./O~IIAN ~CYt! MP-22-REC-BAPOl REVIEW Rev. 029 96 of 137 III.E. Total Radiological Dose From Station Operations Controls CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to l ess than or equal to 25 mrem to the total body or any organ ( except the thyroid, which is limited to less than or equal to 75 mrem). APPLICABILITY:
At all times. ACTION: With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls III.D.l.b., III.D.2.b.
or III.D.2.c.
prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to l ess than or equal to 25 mrem to the total body or any organ ( except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are les s than the 40 CFR 190 Standard.
If the estimated doses exceed the above limits, the Special Report sha ll include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request , and a variance is granted until staff action on the request is complete.
SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 97 of 137 SECTION IV. Millstone Unit 2 Radiological Effluent Controls Docket Nos. 50-336 MP-22-REC-BAPOl STOP THINK ACT REVIEW Rev. 029 98 of 137 SECTION IV REMO DCM UNIT TWO CONTROLS IVA. Introduction The purpose of this section is to provid e the following for Millstone Unit Two: a. the effluent radiation monitor controls and surveillance requirements, b. the effluent radioactivity concentration and dose controls and surveillance requirements, and c. the bases for the controls and surveillance requirements.
Definitions of certain terms are provided as an aid for implementation of the controls and requirements.
Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions. IVB. Definitions, Applicability and Surveillance Requirements IV.:B.1 -Definitions The defined terms of this sub-section appear in capitalized type and are applicable throughout Section IV 1. ACTION -Those additional requirements specified as corollary statements to each principal control and shall be part of the control. 2. FUNCTIONAL
/ FUNCTIONALITY
-An instrument shall be FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation , controls, normal and emergency electrical power sources , or other auxiliary equipment that are required for the instrument to perform its functions are also capable of performing their related support functions.
: 3. CHANNEL CALIBRATION
-A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to know values of the parameter which the channel monitors.
The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential , overlapping, or total channel steps such that the entire channel is calibrated.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 99 of 137 
: 4. CHANNEL CHECK -A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
: 5. CHANNEL FUNCTIONAL TEST -A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify FUNCTIONALITY including alarm and/or trip functions.
For digital instruments, the computer database may be manipulated, in lieu of a signal injection , to verify functionality of alarm and/or trip functions.
: 6. SOURCE CHECK -A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.
: 7. MEMBER(S)
OF THE PUBLIC -MEMBER(S)
OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries.
This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant. The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.
: 8. MODE -Refers to Mode of Operation as defined in Safety Technical Specifications.
: 9. SITE BOUNDARY -The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.
: 10. UNRESTRICTED AREA -Any area at or beyond the site boundary to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the site boundary used for residential quarters or industrial, commercial, institutional and/or recreational purposes.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 100 of 137 
: 11. DOSE EQUIVALENT I-131 -DOSE EQUIVALENT I-131 shall be that concentration ofl-131 (&#xb5;Ci/gram) which alone would produce the same CDE-thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed under Inhalation in Federal Guidance Report No. 11 (FGR 11), "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion." Iv.B.2 -Applicability IVB.2a -LIMITING CONDITIONS FOR OPERATION
: 1. Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met. 2. Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Condition IVB.2.a(6).
If the Limiting Condition for Operation is restor e d prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.
: 3. NOTUSED. 4. NOTUSED. 5. When a system, subsystem, train, component or device is determined to be nonfunctional solely because its emergency power source is nonfunctional, or solely because its normal power source is nonfunctional, it may be considered FUNCTIONAL for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided:
(1) its corresponding normal or emergency power source is FUNCTIONAL; and (2) all of its redundant system(s), subsystem(s), train(s), component(s) and device(s) are FUNCTIONAL, or likewise satisfy the requirements of this specification.
: 6. Equipment removed from service or declared nonfunctional to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its FUNCTIONALITY or the FUNCTIONALITY of other equipment.
This is an exception to Condition IVB.2.a(2) for the system returned to service under administrative control to perform the testing required to demonstrate FUNCTIONALITY.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 101 of 137 IV.B2.b -SURVEILLANCE REQUIREMENTS
: 1. Surveillance Requirements shall be applicable during any condition specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.
: 2. Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the survei llan ce time interval.
: 3. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Condition IV.B2.b(2), shall constitute a failure to meet the FUNCTIONALITY requirements for a Limiting Condition for Operation.
The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed.
The ACTION requirements may b e delayed for up to 24 hours to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours. Surveillance Requirements do not have to be performed on nonfunctional equipment.
: 4. Entry into any specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 102 of 137 L IVC. Radioactive Effluent Monitoring Instrumentation
: 1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATIONS The radioactive liquid effluent monitoring instrumentation channels shown in Table IVC.-1 shall be FUNCTIONAL with applicable alarm/trip setpoints set to ensure that the limits of Specification IVD.l.a. are not exceeded.
The setpoints sha ll be determined in accordance with methods and parameters described in Section IL APPLICABILITY:
As shown in Table IVC.-1 ACTION: a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, without delay s u spend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.
: b. With the number of channels l ess than the minimum channels FUNCTIONAL requirement, take the action shown in Table IVC.-1. Exert best effo rts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, exp lain in the next Radioactive Effluent R elease Report why the nonfunctionality was not corrected in a timely manner. Releases need not b e terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrum enta tion channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C.-2. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 103 of 137 L TABLE Iv.C.-1 Radioacti ve Liquid E ffluent Monitoring In s trument a tion Instrume nt Action w h e n no t N o t es funct i o n a l l.Gross R a di oactivity M on i to r s P rov idi ng Alarm and Au t oma t ic Termi n ation O f R e l ease (a)C l ea n Li q ui d R a d waste Effl u ent Line A 1 (b)Aera t e d Li qu id R adwaste Effl u en t Line A 2 (c)St ea m G e n era tor Bl owdow n M o ni tor B 2 I ( d)Co nd e n sa t e P o li s hin g Faci li ty W as t e Ne ut Su m p E 2 2.G ross R a di oac t ivity Moni tors Pro v idin g Ala r m and No t P roviding A ut omatic Te r mi n a t i on O f Re l ease (a)R eac tor Bu i ldin g C l osed Coo lin g W a t er M o nit or C 1 3.F l ow R a t e Measure m e n ts -No Al arm Set p o in t R eq ui re m e n ts 1. 2. (a)C l ea n Liqui d R a d was t e Effl u e nt Li ne D 1 (b )Aera t e d Li qu i d R a d waste Effl u e nt Line D 1 ( c) Co nd e n sa t e P o li s hin g Faci l ity D 1 Required to be functional at all times -which means that channels shall be FUNCTIONAL and in service on a continuous , uninterrupted basis , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks , calibrations , or sampling associated with the instrument or any system or component which affects functioning of the instrumen t. Required to be functional whenever the discharge pathway is be i ng used except that outages are permitted , for a maximum of 12 hours , for the purpose of ma i ntenance and performance of required test , checks , calibrations , or sampling associated with the i nstrument or any system or component which affects functioning of the instrument.
ACTION S TATEM E NT S Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements , effluent releases may cont i nue provided that best efforts are made to repair the instrument and that prior to in i tiating a release: (1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C.-2 , and; (2) The original release rate calculations and discharge valving are independently verified by a second individual.
Action B W i th the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , either: STOP TH IN K ACT MP-22-REC-B APOl REVIE W R ev. 029 10 4 of 137 (1) Suspend all effluent releases via this pathway , or (2) Make best efforts to repair the instrument and obtain grab samples and analyze for gamma radioactivity as specified in Table I.C.-2; a) Once per 12 hours when the specific activity of the secondary coolant is greater than 0.01 &#xb5;C i/gm DOSE EQUIVALENT 1-131. b) Once per 24 hours when the specific activity of the secondary coolant i s less than or equal to 0.01 &#xb5;Ci/gm DOSE EQUIVALENT 1-131. Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that once per 12 hours grab samples of the service water effluent are collected and analyzed for gamma radioactivity at LLD as specified in Table I.C.-2; Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours during actual releases.
Pump performance curves may be used to estimate flow. Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements , effluent releases may continue provided that best efforts are made to repair the instrument and that prior to init i ating a release: (1) At least two independent samples are analyzed for gamma rad i oactivity as specified in Table I.C.-2 , and; (2) If one of the samples has gamma radioactivity greater than any of the LLDs in Table I.C.-2 , the original release rate calculations and discharge valving are independently verified by a second individual.
STOP THINK ACT MP-22-RE C-BAP Ol REVIEW R ev. 0 29 10 5 o f 137 TABLE IY.C.-2 Radioacti v e Liquid Effiuent Monitorin g In s trum e ntation S ur v eillance R e quirement s I n s trum e n t C h a nn el S our ce C hann e l C h a n ne l C h eck C h eck Ca lib ration F un c ti ona l Test l.Gross R a d i o act i v i ty Mo n it ors P rovi d ing Ala rm a n d A u to m a ti c Termi n a t ion O f R e l ease a. C l ea n L iqu id R a dw as t e Effl u e nt L i ne D* p R(l) Q(2) b. Aera t e d Li qu i d R a d waste E fflu e n t D* p R(l) Q (2) Line C. Stea m Ge n erato r Bl owdow n M o nit or D* M R (l) Q(2) ct.Conde n sate P o l ishi n g Facility W aste D* p R (l) Q (2) Ne ut Su mp 2.Gross R a di oact i v i ty M onitors P rovid i ng Alarm Bu t Not P rov i ding A u tomatic Termi n ation O f R e l ease a. R eac tor B u ild ing C lo sed C o o lin g D* M R(l) Q (2) Water M onitor 3.Flow R a t e M easure m e n ts a. C l ea n L i qu i d R a d was t e Effl u e nt L i ne D* N I A R Q b. Aera t e d L i q uid R a d was t e E fflu e n t D* N I A R Q Line c. Con d e n sate P o l is h i n g Facil i ty W as t e D* N I A R Q D M p
* N e u t Sum p Daily Monthly Prior to each batch release R = Once every 18 months Q = Once every 3 months N I A= Not Applicable TA BLE IY.C.-2 TABL E NOTATIO N During releases via this pathway and when the mon i tor is required FUNCTIONAL per Table IV.C. -1. The CHANNEL CHECK should be done when the discharge is in progress.
(1) Calibration shall include the use of a radioactive liquid or solid source which i s traceable to an NIST source. (2) The CHANNEL FUNCTIONAL TEST shall also demonstrate tha t control room alarm annunciation occurs if any of the following conditions exist: a) Instrument indicates measured levels above the alarm/trip setpoint.
b) Instrument indicates a downscale or circuit failure. -Automatic isolation of the discharge stream shall also be demonstrated for this case for each monitor except the reactor bui l d i ng closed cooling water monitor. STOP T HI N K AC T M P-22-REC-B APOl R E VI EW R ev. 029 106 of 137 
: 2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATIONS The radioactive gaseous effluent monitoring instrumentation channels shown in Table IV.C.-3 sha ll be FUNCTIONAL with applicable alarm setpoints set to ensure that the limits of Specifications IVD.2.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II. APPLICABILITY:
As shown in Table IVC.-3 ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel a larm setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel , or declare the channel nonfunctional , or change the setpoint so it is acceptably conservative.
: b. With the number of channels less than the minimum channels FUNCTIONAL requirement, take the action shown in Table IV.C.-3. Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL stat us within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive gaseous effl uent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C.-4. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 107 of 137 TABLE IY.C. -3 Radioacti v e Ga s eous Effluent Monitoring In s trumentation Instru m e nt Ac t ion w h e n no t No tes fu n c ti o n a l l.MP 2 V e nt (norm a l ran ge, RM-8132 only; hi g h rang e monitor , R M-816 8, r e q u ir e m e nt s a r e in t h e TS) a. No bl e G as R a di oac ti vity Mo nit or A 1 , 3 b. Io din e S am p ler B 1 C. P ar ti c ul a t e Sam pl er B 1 d. Ve nt F lo w R ate Mon i t or C 1 e. Sa mpl e r F l ow R a t e M on i tor C 1 2.Mill s t o n e St ac k -a ppli ca bl e t o th e WR G M (R M-8 169 , norma l rang e , c h ann e l 1 , on l y; mid rang e c h a nn e l 2 and h i gh ra n g e channe l 3 re q uirements are contai n ed in T R M LC O 3.3.3.8) a. No bl e G as R adioactivity Mo nit or E 1, 3 b. Io din e S am p ler B 1 C. P ar ti c ul ate Sam pl er B 1 d. St ac k Fl o w R a t e Monit or C 1 e. S a mpl e r F lo w Rat e M o nitor C 1 3.W as t e Ga s H o l d up Sys t em a. No bl e G as Mo nit o r P rovi d i n g A ut omatic Te rmi na t io n of D 2,4 R e l ease 1 Required to be functional at all times when air is being released to the environment by the pathway being monitored.
The channel shall be FUNCTIONAL and in service on a continuous , uninterrupted basis. Outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrations , or sampling associated with the instrument or any system or component which affects functioning of the inst r ument. 2 Required to be functional during waste gas holdup system discharge. 3 Alarm setpoint with required. Automat i c i solation feature i s not required. 4 Alarm setpoint r e quired. Automatic isolation feature i s required. ACTION STATEMENTS Act i on A With the number of channels FUNCT I ONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours. If the monitor flow and readout are not adversely affected by the loss of functionality , the daily CHANNEL CHECK may be performed in lieu of the grab sample. STOP THINK ACT MP-22-REC-B AP O l REVIEW R ev. 0 29 10 8 o f 13 7 Action B With the number of samplers FUNCTIONAL less than required by the Minimum number FUNCTIONAL requirement , effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that effluent is continuously sampled with auxiliary sampling equipment and collected at least once per seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours of initiation of this action statement.
Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. Auxiliary sampling outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrations , or sampling.
Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 5 hours. Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use. Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement:
Releases from the Millstone Unit 2 waste gas system may continue provided that best efforts are made to repair the instrument and that prior to initiating the release: a) At least two independent samples of the tank's contents are analyzed; and b) The original release rate calculations and discharge valve lineups are independently verified by a second individual.
Otherwise, suspend releases from the waste gas holdup system. Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , Millstone Unit 2 releases via the Millstone Stack may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours. If the monitor flow and readout are not adversely affected by the loss of functionality , the daily CHANNEL CHECK may be performed in lieu of the grab sample. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 109 of 137 TABLE rv.c. -4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirement s Channel Sourc e Channel Chann e l In s trum en t Check Ch e ck Ca lib ration Function a l T est l.MP 2 V e nt (normal ra n ge, RM-8132 only; high range monitor , RM-8168 , requirement s are in the TS) a. Noble Gas Radioactivity Monitor D M R(l) Q (2) b. Iodine Sampl er w NA NA NA C. P a rticulate Sampler w NA NA NA d. Vent Flow Rate Monitor D NA R Q e. Samp l e r Flow Rat e Monitor D NA R N A 2.Mill stone Stack -app li cable to th e WRGM (RM-8169 , normal rang e, channel 1 , only; mid rang e channe l 2 and hi gh range c h anne l 3 req uir ements are contained in TRM LCO 3.3.3.8) a. Noble Gas Radioactivity Mon itor D M R(l) Q(:l) b. Iodine Sampl er w NA NA NA C. Particulate Sampler w NA NA NA d. Stack Flow Rat e Monitor D NA R Q e. Sampler Flow Rat e Monitor D NA R NA 3.Wast e Gas Holdup Syst e m a. Nobl e Gas Monitor D* p R(l) Q(2) *During releases via this pathway and when the monitor is required FUNCT I ONAL per Table IV.C.-3. The CHANNEL CHECK should be performed when the discharge is in progress.
p D = w = M = Prior to discharge Daily Weekly Monthly R = Once every 18 months Q = Once every 3 months NA= Not Applicable TABLE Iv.C.-4 TABLE NOTATION (,) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to a source which is traceable to the NIST. These sources shall be in a known , reproducible geometry.
(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation*
occu r s if any of the following conditions exist: a) Instrument indicates measured levels above the alarm/trip setpoint.
b) Instrument indicates a downscale failure. * -Also demonstrate automatic isolation for the waste gas system noble gas monitor. STOP THINK ACT MP-2 2-REC-BAPOl REVIEW R ev. 029 110 of 137 IVD. Radioactive Effluents Concentrations And Dose Limitations
: 1. Radioactive Liquid Effluents
: a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATIONS The concentration ofradioactive material released from the site (see Figure IVD. -1) shall not exceed ten times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 10-4 &#xb5;Ci/ml total radioactivity.
APPLICABILITY:
At all times. ACTION: With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I. 2) The results of the radioactive analysis shall be used in accordance with the methods of Section ILE to assure that th e concentrations at I the point of release are maintained within the limits of Specification IVD.l.a. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 111 of 137 
: b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATIONS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 2 released from the site (see Figure IVD.-1) shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and, b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ. APPLICABILITY:
At all times. ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations.
Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in Section II at least once per 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 112 of 137 
: 2. Radioactive Gaseous Effluents
: a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS OF OPERATIONS The dose rate, at any time , offsite (see Figure IV.D.-1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values: a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and , b. The dose rate limit for Iodine-131, Iodine-133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ. APPLICABILITY:
At all times. ACTION: With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Specification IV.D.2.a.
within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) The release rate , at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established above in Specification IV.D.2.a.
The corresponding release rate shall be determined in accordance with the methodology of Section IL 2) The noble gas effluent monitors of Table IV.C.-3 shall be used to control release rates to limit offsite doses within the values established in Specification IV.D.2.a.
: 3) The release rate of Iodine-131 , Iodine-133 , tritium and for all radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Section I. The corresponding dose rate shall be determined using the methodology given in Section II. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 113 of 137 
: b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS OF OPERATIONS The air dose offsite (see Figure IVD.-1) due to noble gases released in gaseous effluents from Unit 2 shall be limited to the following:
: a. During any calendar quarter, to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;
: b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.
APPLICABILITY:
At all times. ACTION: a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 114 of 137 
: c. Gaseous Effluents
-Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS OF OPERATIONS The dose to any REAL MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, Tritium, C-14, and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 2 (see Figure IV.D.-1) shall be limited to the following:
: a. During any calendar quarter to less than or equa l to 7.5 mrem to any organ; b. During any calendar year to less than or equal to 15 mrem to any organ. APPLICABILITY:
At all times. ACTION: a. With the calculated dose from the release of radioiodines , radioactive materials in particulate form, or radionuclides other than noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause( s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dos e Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II onc e every 31 days. 2) Relative accuracy or conservatism of the calcu lation s shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 115 of 137 Figure IY.D. -1, "Site Boundary for Liquid and Gaseous Effluents" 0 500 ,oco ... STOP THINK ACT ./O~OAN COY~ MP-22-REC-BAPOl REVIEW Rev. 029 116 of 137 IV.E. Total Radiological Dose From Station Operation CONTROLS The annual do se or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ ( except the thyroid , which is limited to less than or equal to 75 mrem). APPLICABILITY:
At all tim es. ACTION: With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls IV.D.2.a., IV.D.l.b., or IV.D.2.c.
prepare and submit a Special Report to th e Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Sit e is limited to less than or equal to 25 mrem to the total body or any organ ( except thyroid , which is limited to less than or e qual to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrat es that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effl uent pathways and direct radiation) are less than th e 40 CFR 190. If the estimated doses excee d th e above limits , the Special Report shall includ e a request for a variance in accordance with the provi s ions of 40 CFR 190. Submittal of the report is considered a tim e ly request , and a variance is granted until staff action on the requ es t is complete.
SURVEILLANCE REQUIREMENTS Cumulative dos e contributions from liquid and gaseous effluents and direct radiation from th e Millstone Site shall be det e rmin e d in accordance with Section II onc e per 31 days. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 117 of 137 SECTIONV.
Millstone Unit 3 Radiological Effluent Controls Docket Nos. 50-423 MP-22-REC-BAPOl STOP THINK ACT REVIEW Rev. 029 118 of 137 SECTION V. REMODCM UNIT THREE CONTROLS V.A. Introduction The purpose of this section is to provide th e following for Millstone Unit Three: a. the effluent radiation monitor controls and surveillance requirements, b. the effluent radioactivity concentration and dose controls and surveillance requirements , and c. the bases for the controls and surveillance requirements.
Definitions of certain terms are provided as an aid for implementation of the controls and requirements.
Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions. V.B. Definitions and Applicability and Surveillance Requirements V.B.1 -Definitions Th e defined terms of this sub-section appear in capitalized type and are applicable throughout Section V. 1. ACTION -ACTION shall be that part of the control which prescribes remedial measures required under designated conditions.
: 2. CHANNEL FUNCTIONAL TEST -A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify FUNCTIONALITY of alarm, interlock and/or trip functions.
For digital instruments , the computer database may be manipulated, in lieu of a signal injection , to verify functionality of alarm and/or trip functions. The CHANNEL FUNCTIONAL TEST shall include adjustments, as necessary, of the alarm, interlock and/or trip setpoints such that the setpoints are within th e required range and accuracy.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 119 of 137 
: 3. CHANNEL CALIBRATION
-A CHANNEL CALIBRATION shall be the adjustment, as necessary , of the channel such that it responds within the required range and accuracy to known values of input. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm, interlock and/or trip functions and may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.
: 4. CHANNEL CHECK -A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
: 5. DOSE EQUIVALENT I-131 -DOSE EQUIVALENT I-131 shall be that concentration of I-131 (&#xb5;Ci/gram) which alone would produce the same CDE-thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed under Inhalation in Federal Guidance Report No. 11 (FGR 11), "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion." 6. MEMBER(S)
OF THE PUBLIC -MEMBER(S)
OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the licensee, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries.
This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant. The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.
: 7. MODE -Refers to Mode of Operation as defined in Safety Technical Specifications.
: 8. FUNCTIONAL
-FUNCTIONALITY
-An instrument shall be FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation, controls, electrical power, or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).
: 9. SITE BOUNDARY -The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 120 of 137 
: 10. SOURCE CHECK -A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.
: 11. UNRESTRICTED AREA -Any area at or beyond the SITE BOUNDARY to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the SITE BOUNDARY used for residential quarters or industrial, commercial , institutional and/or recreational purposes.
V.B.2 -Applicability V.B.2.a -LIMITING CONDITIONS FOR OPERATION
: 1. Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met. 2. Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals.
If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals , completion of the ACTION requirements is not required.
V.B.2.b -SURVEILLANCE REQUIREMENTS
: 1. Surveillance Requirements shall be applicable during any condition specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.
: 2. Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance time interval.
: 3. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Condition V.B.2.b(2), shall constitute a failure to meet the FUNCTIONALITY requirements for a Limiting Condition for Operation.
The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed.
The ACTION requirements may be delayed for up to 24 hours to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours. Surveillance Requirements do not have to be performed on nonfunctional equipment.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 121 of 137 
: 4. Entry into any specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.
VC. Radioactive Effluent Monitoring Instrumentation
: 1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATION The radioactive liquid effluent monitoring instrumentation channels shown in Table VC.-1 shall be FUNCTIONAL with their Alarm/Trip setpoints set to ensure that the limits of Specification VD.La are not exceeded.
The alarm/trip setpoints shall be determined in accordance with methodology and parameters as described in Section IL APPLICABILITY:
As shown in Table VC.-1 ACTION: a. With a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.
: b. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels FUNCTIONAL, take the action shown in Table VC.-1. Exert best efforts to restore the nonfunctional instrumentation to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL OPERATIONAL TEST at the frequencies shown in Table VC.-2. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 122 of 137 TABLE V.C.-1 Radioacti v e Liquid Effluent Monitoring In s trumentation Inst rum en t Ac tion wh e n Not es no t fun c ti ona l l.R a di o acti v i ty M o n i to rs Pro v idin g Alarm a nd A u to m a ti c T e rmin a ti o n O f R e l ease a. W as t e N e ut ra li za ti o n Sump Monit or Co nd e n sate P o li s hin g D 2 Fac ility b. T urbin e Bu i ld i n g F l oor D rai n s B 1 C. L iquid W as t e M o nit or A 1 d. RES E R VE D e. Ste am G e n era t o r Bl ow d ow n Monit or B 3 2.F l ow R a t e M eas ur e m en t D evices -N o Alarm S e tp o int R e qui remen t s a. W as t e N e ut ra l iza ti o n Su m p Effl u ents C 1 b. RES E R VE D C. Li quid W as t e E fflu ent L ine C 1 d. RES E RV E D e. St e am G e n era t or Blo w d ow n E fflu ent L in e C 3 1 Req u i re d to be fu n ctional at all times -which means that channels sha l l be FUNCT I ONAL and in service on a continuous , uninterrupted basis , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks, ca l ibrations , or sampling associated w i th the instrument or any system or component which affects functioning of the instrument.
2 Required to be functional in MODEs 1 -5 , and MODE 6 when discharge pathway is being used , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks , calibrations , or sampling associated with the i nstrument or any system or component which affects functioning of the instrument.
The monitor must be on-line with no unexpected alarms. 3 Required to be functional whenever the discharge pathway is being used , except that outages I are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks , calibrations , or sampling assoc i ated with the instrument or any system or component which affects functioning of the instrument.
The monitor must be on-l ine with no unexpected alarms. STOP THINK AC T MP-22-REC-BAP Ol REVIEW R ev. 0 2 9 123 o f 137 TABLE V.C.-1 ACTION STATEMENTS Act i on A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that prior to initiating a release: 1. At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C-3, and; 2. The original release rate calculations and discharge line valving are independently verified by a second individual.
Action B With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided best efforts are made to repair the instrument and that grab samples are analyzed for gamma radioactivity specified in Table I.C. -3: 1. At least once per 12 hours when the specific activity of the secondary coolant is greater than 0.01 &#xb5;Ci/gram DOSE EQUIVALENT 1-131 , or 2. At least once per 24 hours when the specific activity of the secondary coolant is less than or equal to 0.01 &#xb5;Ci/gram DOSE EQUIVALENT 1-131. Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 4 hours during actual releases. Pump performance cuNes may be used to estimate flow. Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements , effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release: 1. At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C-3 , and; 2. If one of the samples has gamma radioactivity greater than any of the lower limits of detection specified in Table I.C.-3 , the original release rate calculations and discharge valving are independently verified by a second individual.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 124 of 137 J L TABLE V.C.-2 Radioacti ve Liquid Effluent Monitoring Instrumentation S urveillance Requirement s Instrument Channel Source Channel Channel Check Check Calibration Functional Test l.Radioactivity Monitors Providing Alarm and Automatic Termination Of Release a. Waste Neutralization Sump Monitor Condensate Polishing Facility b. Turbine Building Floor Drains C. Liquid Waste Monitor d. Deleted e. Steam Generator Blowdown Monitor 2.Flow Rate Measurements
: a. Waste Neutralization Sump Effluents
: b. RESERVED c. Liquid Waste Effl u ent Line d. Deleted e. Steam Generator Bl owdown Effluent Line D M p Daily Monthly Prior to each batch release D D D D D(J) D (3) D(J) R = Q = N/A= TABLE V.C.-2 TABLE NOTATION p R(L) M R(L) p R(L) M R(L) NA R N I A R N I A R Once every 18 months Once every 3 months Not Applicable Q(l) Q(l) Q(l) Q(l) Q Q Q (1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occur if any of the following conditions exists: a) Instrument indicates measured levels above the alarm/trip setpoint, or b) Circuit failure (Alarm only), or Instrument indicates a downscale failure (Alarm only). (2) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION , sources that have been related to the initial calibration shall be used. (3) CHANNEL CHECK shall consist of verify i ng indication of flow during periods of release. CHANNEL CHECK shall be made at least once per 24 hours on days on which continuous , periodic, or batch releases are made. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 125 of 137 J L___ --2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATION The radioactive gaseous effluent monitoring instrumentation channels shown in Table V.C.-3 shall be FUNCTIONAL with their Alarm Setpoints set to ensure that the limits of Specification V.D.2.a. are not exceeded.
The Alarm Setpoints of these channels shall be determined in accordance with the methodology and parameters in Section II. APPLICABILITY:
As shown in Table V.C.-3. ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm Setpoint less conservativ e than required by the above specification , without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional , or change the s e tpoint so it is acceptably conservative. b. With the number of FUNCTIONAL radioactive gaseous effluent monitoring instrumentation channels less than the Minimum Channels FUNCTIONAL, take the ACTION shown in Table V.C.-3. Exert best efforts to restore th e nonfunctional instrumentation to FUNCTIONAL status within 30 days and, if unsuccessful , explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK , CHANNEL CALIBRATION , and CHANNEL FUNCTIONAL TEST at the frequencies shown in Table V.C.-4. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 126 of 137 J TABLE V.C. -3 Radioacti ve Gaseous Effluent Monitoring In st rumentation Instrument Action when Notes not functional l.Millstone Unit 3 Ventilation Vent (Turbine Building -HVR-RElOB, norma l range on ly; high range monitor, HVR-RElOA, requirements are in the TRM) a. Nob l e Gas Radioactivity Monitor P roviding Alarm A 1 ,2 b. Iodine Sampl er B 1 , 2 C. Particulate Sampler B 1 , 2 d. Vent Flow Rate Monitor C 1 , 2 e. Sampler Flow Rate Monitor C 1 2.Mill stone Stack -app l icable to SLCRS (HVR-R E19B, normal range on l y; high range monitor , HVR-RE19A, requirements are in the TRM) a. Noble Gas Radioactivity Monitor Pro vi ding Alarm b. Iodine Sampler C. Particulate Sampler d. Process Flow Rate Monit or e. Sampler Flow Rate Monitor 3.E n gineered Safeguards Building Monitor (HVQ-RE49)
: a. b. C. d. e. Noble Gas Radioactivity Monitor Iodine Sampl er Particulate Sampler Di sc h arge Flow R ate Monitor Sampler Flow Rate Monit or TABLE V.C. -3 Table Notations A 1 ,2 B 1 , 2 B 1 , 2 C 1, 2 C 1 D 1 B 1 B 1 E 1 C 1 1 Instrument required to be functional whenever the release path is in service. Outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrat i ons , or sampling associated with the instrument or any system or component which affects functioning of the instrument.
2 When the Ventilation Vent Flow Rate Monitor or Millstone Stack Process Flow Rate Monitor is nonfunctional because of degraded flow indication, the Noble Gas Monitor and Iodine and Particulate Samplers for the affected pathway (Ventilation Vent or Millstone Stack) rema i n functional as long as there is a minimum indicated process flow. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 127 of 13 7 TABLE V.C.-3 ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that a) best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours , OR b) if the cause of the nonfunctionality is solely due to a loss of annunciation in the control room and the Remote Indicating Controller (RIC) remains FUNCTIONAL , perform a channel check at the RIC at least once per twelve hours and verify the indication has not alarmed. Action B With the number of samplers FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that effluent is continuously sampled with auxiliary sampling equipment at least once per seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours after initiation of this ACTION statement.
Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. Auxiliary sampling outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrations , or sampling. Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 5 hours. Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use. Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours. Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 128 of 137 TABLE V.C.-4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Instrum e nt Channel Sourc e-C hann e l Ch a nnel Wh e n C heck Ch e ck C alibra-Fun c tional Surveil-tion Check lan ce is R e quir e d l.Millstone Unit 3 Ventilation Vent (Turbin e Buildin g -HVR-R E lOB , normal ran ge onl y; high ra n ge monitor , HVR-R E lOA, r e quir e m e nt s ar e in th e TRM) a. Noble Gas Radioactivity Monitor D M R(l) Q(L.)
* Providing Alarm b. Iodine Sampl e r w NA NA NA
* c. Particulate Sampl e r w NA NA NA
* d. Vent Flow Rate Monitor D NA R Q
* e. Sampler Flow Rate Monitor D NA R Q
* 2.Millstone Stack -applicabl e to SLCRS (HVR-R E 19B , normal ran ge only; high r a n ge monitor , HVR-R E 19A , r e quir e m e nt s a re in th e TRM) a. Noble Gas Radioactivity Monitor D M R(3) Q(L.)
* Providing Alarm b. Iodine Sampl e r w NA NA NA
* c. Particulate Sampler w NA NA NA
* d. Process Flow Rate Monitor D NA R Q
* e. Sampler Flow Rate Monitor D NA R Q
* 3.Engineered Safeguards Building Monitor (HVQ-RE49)
* a. Noble Gas Radioactivity Monitor D M R (l) Q(2)
* Providing Alarm b. Iodine Sampler w NA NA NA
* c. Particulate Sampler w NA NA NA
* d. Discharge Flow Rate Monitor D NA R Q
* e. Sampler Flow Rate Monitor D NA R Q
* At all times except wh e n the ven t path is i s o l a t ed. D w M Da ily Wee kl y Mont h ly STOP THINK R = O n ce every 18 months Q = O n ce every 3 months N/A= N o t Applicab l e ACT MP-22-REC-BAPOl REVIEW Rev. 029 129 of 137 T ABLE V.C.-4 Table Notation s (1) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION , sources that have been related to the initial calibration shall be used. (2) The CHANNEL FUNCTIO_NAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist: a) Instrument indicates measured levels above the Alarm Setpoint , or b) Circuit failure , or c) Instrument indicates a downscale failure. (3) The CHANNEL CALIBRATION shall include the use of a known source whose strength is determined by a detector which has been calibrated to an NIST source. These sources shall be in know , reproducible geometry. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 0 29 130 of 137 V.D. Radioactive Effluents Concentrations And Dose Limitations
: 1. Radioactive Liquid Effluents
: a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATION The concentration of radioactive material released from the site (see Figure V.D. -1) shall be limited to ten times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or e ntrained noble gases , the concentration shall not e xceed 2 x 10-4 &#xb5;Ci/ml total radioactivity.
APPLICABILITY:
At all times. ACTION: With the concentration of radioactive material released from the site exceeding the above limits , restore the concentration to within the above limits within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I. 2) The results of the radioactive analysis shall be used in accordance with the methods of Section ILE to assure that the concentrations at I the point of release are maintained within the limits of Specification V.D.l.a. STOP THINK ACT MP-22-REC-BAPOl REV I EW Rev. 029 131 of 137 __J 
: b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 3 released from the site ( see Figure VD. -1) shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and, b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ. APPLICABILITY:
At all times. ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations.
Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in Section II at least once per 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP TH I NK ACT MP-22-REC-BAPOl RE VI EW Rev. 029 132 of 137 ---'
L 2. Radioactive Gaseous Effluents
: a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS OF OPERATION The dose rate, at any time, offsite (see Figure V.D.-1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values: a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and , b. The dose rate limit due to inhalation for Iodine-131 , Iodine-133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ. APPLICABILITY:
At all times. ACTION: With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Specification V.D.2.a. within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established in Specification V.D.2.a. The corresponding release rate shall be determined in accordance with the methodology of Section IL 2) The noble gas effluent monitors of TableV.C.-3 shall be used to control release rates to limit offsite doses within the values established in Specification V.D.2.a. 3) The release rate of Iodine-131 , Iodine-133 , tritium, and for all radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program, specified in Section L The corresponding dose rate shall be determined using the methodology given in Section IL STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 133 of 137 
: b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS OF OPERATION The air dose offsite (see Figure VD.-1) due to noble gases released from Unit 3 in gaseous effluents shall be limited to the following:
: a. During any calendar quarter: Less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation, and b. During any calendar year: Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.
APPLICABILITY:
At all times. ACTION: a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 134 of 137 
: c. Gaseous Effluents
-Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS OF OPERATION The dose to any REAL MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, Tritium, C-14, and radioactive materials in particulate form with half l ives greater than 8 days in gaseous effluents released offsite from Unit 3 released offsite (see Figure VD.-1) shall be limited to the following:
: a. During any calendar quarter: Less than or equal to 7 .5 mrem to any organ and, b. During any calendar year: Less than or equal to 15 mrem to any organ. APPLICABILITY:
At all times. ACTION: c. With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THIN K ACT MP-22-REC-BAPOl REVIEW Rev. 029 135 of 137 L Figure V.D.-1, "Site Boundary for Liquid and Gaseous Effluents" 0 500 tO OO $1;*Ll-FlfET
.,. .... N,A JI TIC ., Ar' STOP THINK ACT Exe lusioh Area. ~'=~ .. Boun~o.ry
-MP-22-REC-BAPOl REVIEW Rev. 029 136 of 137 L VE. Total Radiological Dose From Station Operations CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ ( except the thyroid, which is limited to less than or equal to 75 mrem). APPLICABILITY:
At all times. ACTION: With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls VD.l.b., VD.2.b., or VD.2.c. prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ ( except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR 190 Standard.
If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request , and a variance is granted until staff action on the request is complete.
SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 137 of 137 ATTACHMENT 2 Serial No. 18-176 Docket Nos. 50-245 50-336 50-423 License Nos. DPR-21 DPR-65 NPF-49 201& RADIOACTIVE EFFLUENT RELEASE REPORT VOLUME 2 MILLSTONE POWER STATION UNITS 1, 2, AND 3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC)
I I l MILLSTONE POWER STATION STATION PROCEDURE SroP Acr 8EVIEW Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)
MP-22-REC-BAPOl Rev. 029 Approval Date: 04/03/17 Effective Date: 04/04/17 Millstone All Units Station Procedure Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)
TABLE OF CONTENTS I. Radiological Effluent Monitoring Manual (REMM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 I.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 LB. Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 LC. Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1. Liquid Effluent Sampling and Analysis Program . . . . . . . . . . . . . . . . . . . . . . 7 2. Liquid Radioactive Wast e Treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 I.D. Gaseous Effluents
..................
................................ . 23 1. Gaseous Effluent Sampling and Analysis Program .................. . 23 2. Gaseous Radioactive Waste Treatm e nt ........................... . 31 I.E. Radiological Environmental Monitoring
.......................
........ . 36 1. Sampling and Analysis ......................................... . 36 2. Land Use Census ............................................. . 46 3. Interlaboratory Comparison Program ............................ . 4 6 I.F. Report Content .................................................... . 47 1. Annual Radiological Environmental Operating Report .............. . 47 2. Radioactive Effluent Release R e port ............................. . 48 II Off-Site Dos e Calculation Manual (ODCM) ................................ . 51 II.A. Introduction
...................................................... . 51 II.B. Responsibilities
..........................
.......................... . 51 II.C. Liquid Dose Calculations
..................
......................... . 52 1. Monthly , Quarterly, and Annual Dose Calculation (Applicabl e to All Units) ....................................... . 52 2. Monthly Dose Projections
...................................... . 52 II.D. Gaseous Dose Calculations
.......................................... . 55 1. Site Release Rate Limits ("Instantaneous")
....................... . 55 2. 10 CFR50 Appendix I -Noble Gas Limits ...................
..... . 57 3. 10 CFR50 Appendix I -Iodine, Tritium and Particulate Doses ....... . 59 4. Gaseous Effluent Monthly Dose Projections
....................... . 60 5. Compliance with 40CFR190 ..........................
.......... . 6 3 II.E. Liquid Discharge Flow Rates And Monitor Setpoints
............
........ . 64 1. Unit 1 Liquid Waste Effluent Discharge (RE-MG-110)
............ . 64 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 1 of 137 I 
: 2. Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 3. Unit 2 Clean Liquid Radwaste Effluent Line -RM9049 and Aerated Liquid Radwaste Effluent Line -RM9116 . . . . . . . . . . . . . . . . . . . . . . . . . 65 4. Condensate Polishing Facility Waste Neutralization Sump Effluent Line -CND245 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 5. Unit 2 Steam Generator Blowdown -RM4262 and Unit 2 Steam Generator Blowdown Effluent Conc e ntration Limitation . . . . . . . . . . . . . . . . . . . . . . . 69 6. Unit 2 Condenser Air Ejector -RM5099 ............
..............
69 7. Unit 2 Reactor Building Closed Cooling Water RM6038 and Unit 2 Service Wat e r , and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 8. Unit 3 Liquid Waste Monitor -LWS-RE70 . . . . . . . . . . . . . . . . . . . . . . . 71 9. Unit 3 Regenerant Evaporator Effluent Line -LWC-RE65 . . . . . . . . . 73 10. Unit 3 Wast e Neutralization Sump Effluent Line -CND-RE07 ...... 73 11. Unit 3 Steam Generator Blowdown -SSR-RE08 and Unit 3 Steam G e nerator Blowdown Effluent Conc e ntration Limitation . . . . . . . . . . . . . 73 12. Unit 3 Turbine Building Floor Drains Effluent Lin e -DAS-RE50 and Unit 3 S e rvice Water and Turbine Building Sump Effluent Concentration Limitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 II.F. Gaseous Monitor Setpoints . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 1. Unit 1 Spent Fuel Pool Island Monitor -RM-SFPI-02 . . . . . . . . . . . . . 76 2. Unit 2 Wide Range Gas Monitor (WRGM) -RM8169 . . . . . . . . . . . . . . 76 3. Reserved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 4. Unit 3 SLCRS -HVR-RE19B
..............................
.... 77 5. Unit 2 V e nt -Noble Gas Monitor -RM8132B .................... 77 6. Unit 2 Waste Gas Decay Tank Monitor RM9095 ....................
77 7. Unit 3 Vent Noble Gas Monitor -HVR-RElOB
................... 78 8. Unit 3 Engineering Safeguards Building Monitor -HVQ-RE49 ...... 78 III REMODCM Unit One Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 III.A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 III.B. Definitions and Surveillance Requirement (SR) Applicability . . . . . . . . . . . . . . 82 III.C. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . . 85 1. Radioactive Liquid Efflu e nt Monitoring Instrumentation . . . . . . . . . . . . . 85 2. Radioactive Gaseous Effluent Monitoring Instrum e ntation . . . . . . . . . . . 88 III.D. Radioactive Effluents Concentrations And Dose Limitations . . . . . . . . . . . . . . . 91 1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 2. Radioactiv e Gaseous Efflu e nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93 III.E. Total Radiological Dose From Station Operations Controls . . . . . . . . . . . . . . . . 97 IV REMODCM Unit Two Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 IVA. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 2 of 137 IVB. Definitions , Applicability and Surveillance Requirements . . . . . . . . . . . . . . . . . 99 IVC. Radioactive Effluent Monitoring Instrumentation . . . . . . . . . . . . . . . . . . . . . . . 103 1. Radioactiv e Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . 103 2. Radioactive Gaseous Effluent Monitoring Instrum e ntation . . . . . . . . . . 107 IVD. Radioactive Effluents Conc e ntrations And Dose Limitations . . . . . . . . . . . . . . 111 1. Radioactiv e Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 2. Radioactiv e Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113 IVE. Total Radiological Dos e From Station Op e ration . . . . . . . . . . . . . . . . . . . . . . . 117 V REMODCM Unit Thr ee Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119 VA. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119 VB. D efini tions and A pplicability an d Surv e illanc e R e quir eme nts . . . . . . . . . . . . . 119 VC. Radioactive Effluent Monitoring Instrum e ntation . . . . . . . . . . . . . . . . . . . . . . . 122 1. Radioactiv e Liquid Effluent Monitoring Instrumentation . . . . . . . . . . . . 122 2. Radioactiv e Gas e ous Effluent Monitoring Instrum e ntation . . . . . . . . . . 126 VD. Radioactive Effluents Conc e ntrations And Dose Limitations . . . . . . . . . . . . . . 131 1. Radioactive Liquid Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131 2. Radioactive Gaseous Effluents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133 VE. Total Radiological Dose From Station Op era tions . . . . . . . . . . . . . . . . . . . . . . . 137 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 3 of 137 TABLES AND FIGURES TABLES Table I.C.-1, " Millstone Unit 1 Radioactive Liquid Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Table I.C.-2, "Millstone Unit 2 Radioactiv e Liquid Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Table I.C.-3 , "Millstone Unit 3 Radioactiv e Liquid Wast e Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Table I.D.-1 , " Millstone Unit 1 Radioactive Gaseous Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Table I.D.-2, "Millstone Unit 2 Radioactiv e Gaseous Waste Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Table I.D.-3 , " Millstone Unit 3 Radioactiv e Gaseous Wast e Sampling and Analysis Program" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Table I.E. -1, " Millstone Radiological Environmental Monitoring Program" . . . 38 Table I.E.-2 , "E nvironmental Monitoring Program Sampling Locations" . . . . . . 39 Table I.E.-3, Reporting Levels For Radioactivity Conc e ntrations In Environmental Samples ..............................................
......... 43 Table I.E.-4 , Maximum Values For Lower Limits Of Det e ction (LLD) ....... 44 Table App. II.A. -1 , " Millstone Effluent R equirements and Methodology Cross Reference" ............
......................................... . Table III.C.-1, " Radioactive Liquid Effluent Monitoring Instrumentation" . . . . 86 Table III.C.-2, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance R e quirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87 Table III.C.-3 , " Radioactive Gas e ous Effluent Monitoring Instrum e ntation" . . 89 Table III.C.-4, " Radioactive Gas e ous Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90 Table IV.C.-1 , " Radioactive Liquid Effl u ent Monitoring Instrumentation" . . . 104 Table IV.C.-2, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 Tabl e IV.C.-3, " Radioactive Gaseous Effluent Instrumentation" . . . . . . . . . . . 108 Table IV.C.-4 , " Radioactive Gaseous Effluent Monitoring Instrumentation Surveillanc e Requirem e nts" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 Table V.C.-1 , " Radioactive Liquid Effl u ent Monitoring Instrumentation" . . . . 123 Table V.C.-2, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125 Table V.C.-3 , "Radioactive Gaseous Effluent Monitoring Instrumentation" . . 127 Table V.C.-4 , " Radioactiv e Gaseous Effluent Monitoring Instrumentation Surveillance Requirements" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 4 of 137 FIGURES Figure I. C.-1, " Reserved" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Figure I.C.-2 , " Simplified Liquid Effluent Flow Diagram Millstone Unit 2 21 Figure I.C.-3, "Simplified Liquid Effluent Flow Diagram Millstone Unit 3 .... 22 Figure I.D. -1, "Simplified Gaseous Effluent Flow Diagram Millstone Unit One" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Figure I.D.-2, " Simplified Gaseous Effluent Flow Diagram Millstone Unit Two" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 Figure I.D.-3 , " Simplified Gaseous Effluent Flow Diagram Millston e Unit Three" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 Figure I.E.-1 , "Inner TLD, Air , Grass , Soil, and Aquatic Locations" ......... 41 Figure I.E.-2, " Outer TLD and Aquatic Locations
........................
42 Figure III.D. -1, " Site Boundary for Liquid and Gaseous Effluents" . . . . . . . . . . 96 Figure IV.D. -1, " Sit e Boundary for Liquid and Gaseous Effluents" . . . . . . . . . . 116 Figur e VD. -1, " Sit e Boundary for Liquid and Gaseous Effluents" . . . . . . . . . . 136 STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 5 of 137 SECTION I. Radiological Effluent Monitoring Manual (REMM) For the Millstone Nuclear Power Station Nos. 1, 2, & 3 Docket Nos. 50-245, 50-336, 50-423 MP-22-REC-BAPOl STOP THINK ACT REVIEW Rev. 029 6 of 137 SECTION I. RADIOLOGICAL EFFLUENT MONITORING MANUAL (REMM) I.A Introduction The purpose of Section I of this manual is to provide the sampling and analysis programs which provide input to Section II for calculating liquid and gaseous effluent concentrations and offsite dos e s. Guidelines are provided for operating radioactive waste treatment systems in order that offsite doses are kept As-Low-As-Reasonably-Achievabl e (ALARA). The Radiological Environmental Monitoring Program outlined within this manual provides confirmation that the measurable concentrations of radioactive material in the environment as a result of operations at the Millstone Site are not higher than expect e d. In addition , this manual outlines the information required to be submitted to the NRC in both the Annual Radiological Environmental Operating Report and the Radioactive Effluent Release Report. MP-22-REC-REF03, " REMODCM Technical Information Document (TID)," has additional bases and technical information.
It also contains a list of exceptions to Regulatory Guide 1.21 ( see Section 2 of the TID). I.B. Responsibilities All changes to the Radiological Effluent Monitoring Manual (REMM) shall be reviewed and approved by the Facility Safety Review Committee prior to implementation.
All changes and their rationale shall be documented in the Radioactive Effluent Release Report. It shall be the responsibility of the Site Vice President Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications. The delegation of implem e ntation responsibilities is delineated in MP-22-REC-PRG, "Radiological Effluent Program." I.C. Liquid Effluents
: 1. Liquid Effluent Sampling and Analysis Program Radioactive liquid wastes shall be sampled and analyzed in accordance with the program specified in Table I.C.-1 for Millstone Unit No. 1, Table I.C.-2 for Millstone Unit No. 2 , and Table I.C.-3 for Millstone Unit No. 3. The r e sults of the radioactive analyses shall be input to the methodology of Section II to assure that the concentrations at the point of release are maintained within the limits of Radiological Effluent Controls (Section III.D.l.a. for Millstone Unit No. 1, Section IVD.l.a. for Millstone Unit No. 2, and Section VD.La. for Millstone Unit No. 3). STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 7 of 137 Table I.C.-1 Millstone Unit 1 Radioactive Liquid Wa s t e Sampling and Analysis Program Liquid Relea se Source Any Batch R e l ease from a n y so ur ce Sample 'fype and Minimum Analysis Frequency Frequency Gra b samp l e prior to Prior to eac h batch eac h b atc h releaseB re l ease Gra b samp l e prior to Pri or to initi al b a t c h re-in i t ial batch re l ease l ease from each so urce. fro m a n y one so urc e Quarterly for each a nd qu arte rl y compos-source.0 ite th e r eafterC Table I.C. -1 TABLE NOTATIONS
'fype of Lower Limit Radioactivity of Detection Analysis (LLD)A (&#xb5;Ci/ml) Principal Gamma 5 X lQ-7 Emitters Kr-85 1 X 10-S H-3 1 X lQ-S Gross a lph a 1 X lQ-7 Sr-90 5 X 10-S Fe-55 1 X 10-6 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. For a particular measurement system (which may include radiochemical separation):
LLD= 4.66 Sb (E)(V)(2.22x l0 6)(Ye-AL1~
Where:
* LLD is the lower limit of detection as defined above (as &#xb5;Ci per unit mass or volume) I
* 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 transformation)
* V is the sample size (in units of mass or volume)
* 2.22 x 10 6 is the number of transformations per minute per &#xb5;Ci
* Y is the fractional radiochemical yield (when applicable)
* "' is the radioactive decay constant for the particular radionuclide
* Lit is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 8 of 137 Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes , the presence of interfering nuclides , or other uncontrollable circumstances may render these LLDs unachievable.
In such cases , the contributing factors will be identified and recorded on the analysis sheet for the particular sample. B. Prior to the sampling , each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent m i xing provided.
C. A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released.
Prior to analysis , all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released.
D. For sources with no release during previous quarter , a quarterly sample is not required.
STOP THINK ACT MP-22-REC-BAPO l REVIEW R ev. 0 29 9 o f 137 Table I.C.-2 Millstone U nit 2 Radioactive Liquid Waste Sam plin g and Analysis Program Liquid R e l ease Sample 'fy p e and Minimum Analysis So urce Freq u ency Frequency A.Batch Relea seB. l.Clean Waste Moni-Grab samp le prior to Prior to each batch tor Tank. each batch release release 2.Aerated Waste Monitor Tanlc 3.Steam Generator Bu]kD. 4.Condensate Polishing Facility Quarterly
-Waste Neutralization CompositeF.,G. SumpE* B.Continuou s Release l.Steam Generator BlowdownH*
2.Service Water Effl u ent 1* 3.Turbine SumpsL 4.RBCCW SumpM. D a ily Grab Sample!.&
Weekly prior to aligning to Compos it eF.,G. Long Island Sound for RBCCW sump Monthly Grab Monthly Sample Weekly Grab or Com-Monthly posite CompositeF.
, G. Weekly Composite Quarterly Composi t eF.,G. TABLE I.C.-2 TABLE NOTATIONS Type of Lower L imit Radioactivity of Detection Ana l ys i s (LLD)A (&#xb5;C i/m l) Principal Gamma 5 X 10-7 EmittersC*
I-131 1 X 10-6 Ce-144 5 X 10-6 Dissolved
& 1 X lQ-S Entrai n ed GasesK. H-3 1 X 10-5 Gross alpha 1 X 10-7 Sr-89 , Sr-90 5 X 10-8 Fe-55 1 X 10-6 Principal Gamma 5 X 10-7 EmittersC.
1-131 1 X 10-6 Ce-144 5 X 10-6 Dis solved & 1 X 10-S Entrained GasesK H-3N* 1 X lQ-S Gross alpha 1 X 10-7 Sr-89 , Sr-90 5 X lQ-8 Fe-55 1 X 10-6 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. For a particular measurement system (which may include radiochemical separation):
LLD = 4.66 Sb (E)(V)(2.22xl06)(Y e-lL1 f) STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 10 of 137 Where:
* LLD is the lower limit of detection as defined above (as &#xb5;Ci 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 transformation)
* V is the sample size (in units of mass or volume)
* 2.22 x 10 6 is the number of transformations per minute per &#xb5;Ci
* Y is the fractional radiochemical y i eld (when applicable)
* A is the r a d i oactive d eca y constant fo r the part i cular radionuclide
* A t is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measur e ment. Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.
Occasionally background fluctuations , unavoidably small sample sizes , the presence of interfering nuclides , or other uncontrollable circumstances may render these LLDs unachievable. In such cases , the contributing factors will be ident i fied and recorded on the analysis sheet for the particular sample. B. A batch release i s the discharge of l i quid wastes of a d i screte volume from the tanks listed in this table. Prior to the sampl i ng , each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided.
If the steam generator bulk can not be recirculated prior to batch discharge , a sample will be obtained by representative compositing during discharge. C. The LLD will be 5 x 1 o-7 &#xb5;C i/ml. The principal gamma emitters for which this LLD applies are exclusively the following rad i onuclides: Mn-54 , Fe-59 , Co-58 , Co-60 , Zn-65 , Mo-99 , Cs-134, Cs-137 , and Ce-141. Ce-144 shall also be measured , but with an LLD of 5 x 10-6 &#xb5;C i/ml. This list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and i dentifiable , together with the above nuclides , shall also be i dentified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at t he LLD level. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. D. For the Steam Generator Bulk: lE the applicable batch gamma radioact i vity is not greater than 5 x 1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 are not required.
STOP TH IN K AC T MP-22-REC-B APOl REVIEW R ev. 0 29 11 o f 13 7 E. For the Condensate Polishing Facility (CPF) waste neutralization sump: lE there is no detectable tritium in the steam generators , THEN tr i t i um sampling and analyses is not required.
lE the gross gamma radioactivity in the g r ab sample taken prior to release does not exceed 5 x 1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 and Fe-55 are not required. F. For Batch Releases and Steam Generator Slowdown only , a composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released. G. Pr i or to analysis , all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released. H. For t he Steam Generator Slowdown: lE the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 &#xb5;C i/ml , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89 , Sr-90 and Fe-55 are not required. For the purposes of this footnote , if steam I generator samples are not available , condensate water gamma radioactivity may be used during times of blowdown. I. Daily grab samples shall be taken at least five days per week. For service water , daily grabs shall include each train that is in-service. For steam generator blowdown , condensate may be I sampled during blowdown if steam generator sample is not available.
J. For the Service Water: IF a weekly gamma analysis does not ind i cate a gamma radioactivity greater than 5 x1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 a r e not required. K. LLD applies exclusively to the following radionuclides:
Kr-87, Kr-88 , Xe-133 , Xe-133m , Xe-135 , and Xe-138. This list does not mean that only these nuclides are to be detected and reported.
Other peaks wh i ch are measurable and identifiable , together with the above nuclides , shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the " Radioactive Effluent Release Report." L. For the Turbine Building Sump: lE there is no detectable tritium in the secondary side before an outage , THEN tritium sampling and analyses is not required during an outage. IF the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 &#xb5;Ci/ml , OR sump is directed to radwaste treatment , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89 , Sr-90 and Fe-55 are not required.
lE the release pathway is directed to yard drains , THEN the LLD for 1-131 shall be 1.5 x 1 o-7 &#xb5;Ci/ml and for gross alpha 1 x 1 o-a &#xb5;Ci/ml. S T OP THI N K AC T MP-22-REC-B APOl R E VI EW R ev. 0 29 12 of 137 M. For the RBCCW Sump: IE the RBCCW Sump is directed to radwaste treatment or is not aligned to Long Island Sound , THEN sampling is not required.
IF the applicable batch gamma radioactivity is not greater than 5 x 1 o-7 &#xb5;Ci/ml, THEN sampling and analysis schedule for gross alpha, Sr-89, Sr-90 , Fe-55 are not required. N. Detectable tritium shall be used to estimate tritium releases to the atmosphere via the blowdown tank vent. STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 13 of 137 Table I.C. -3 Mill s tone U nit 3 Radioacti v e Liquid Wa s te Sa mplin g a nd Anal ys i s Program Liquid R e lea se Sampl e 'fy p e and M inimum An a l ys i s S ourc e Fre qu e nc y Fr e qu e nc y A.B a tch Relea seB-I.Condensate Poli sh-Grab sample prior Prior to each batch ing Faci li ty Wast e t o each b atch re l ease re l ease Neutralization SumpE-2. Waste Tes t Tanks 3.Low Leve l Wast e Tank 4.Boron Test Tanks 5.Steam Generator Bulk D. Quarterly CompositeF.,G. B.Continuou s Rel eas e I.St ea m Ge n erator BlowdownH-2.Service Water Ef-fluent 1* 3.Turbine Bui lding SumpsL Dai l y Grab Sam pl e!. Weekly CompositeF.
, G. Monthly Grab Monthly Samp l e W ee kl y Grab or Com-Mont hl y posite W ee kly Composite CompositeF.,G. Qu arte rly CompositeF.,G.
TABLE I.C.-3 TABLE NOTATIONS
'fy pe of Low e r Limit Radioacti v i ty of Detection An al ys i s (LLD)A (&#xb5;C i/ml) Principal Gamma 5 X 10-7 EmittersC.
I-131 1 X 10-6 Ce-144 5 X 10-6 Di sso l ved & 1 X 10-S Entrained GasesK. H-3 1 X lQ-S Gross alpha 1 X 10-7 Sr-89, Sr-90 5 X 10-8 Fe-55 1 X 10-6 Princ i pal Gamm a 5 X 10-7 EmittersC.
I-131 1 X lQ-6 Ce-144 5 X 10-6 Di sso lv e d & 1 X 10-S Entrained GasesK-H-3M. 1 X lQ-S Gross alp h a 1 X 10-7 Sr-89 , Sr-90 5 X 10-8 Fe-55 1 X 10-6 A. The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. STOP THINK ACT MP-22-REC-B APOl REVI E W R ev. 0 29 14 o f 137 For a particular measurement system (which may include radiochemical separation)
: LL D = 4.6 6 Sb (E)(V)(2. 22x l Q 6)(Ye -AL1 I) Where:
* LLD is the lower limit of detection as defined above (as &#xb5;Ci 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 transformation)
* V is the sample size (in units of mass or volume)
* 2.22 x 10 6 is the number of transformations per minute per &#xb5;Ci
* Y is the fractional radiochemical yield (when applicable)
* "' is the radioactive decay constant for the particular radionuclide
* At is the elapsed time between midpoint of sample collection and midpoint of counting time It should be recognized that the LLD is def i ned as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.
Occasionally background fluctuations , unavoidably small sample sizes , the presence of interfering nuclides , or other uncontrollable circumstances may render these LLDs unachievable. In such cases , the contributing factors will be identified and recorded on the analysis sheet for the particular sample. B. A batch release is the discharge of liquid wastes of a discrete volume from the tanks listed i n this table. Prior to the sampling , each batch shall be isolated and at least two tank/sump volumes shall be recirculated or equivalent mixing provided. If the steam generator bulk can not be recirculated prior to batch discharge , a sample will be obtained by representative compositing during discharge. C. The LLD will be 5 x 1 o-7 &#xb5;C i/ml. The principal gamma emitters for which this LLD applies are exclusively the following rad i onuclides: Mn-54 , Fe-59 , Co-58 , Co-60 , Zn-65 , Mo-99 , Cs-134 , Cs-137 , and Ce-141. Ce-144 shall also be measured , but with an LLD of 5 x 10-6 &#xb5;C i/ml. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable , together with the above nuclides , shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. D. For the Steam Generator Bulk: .!.Ethe applicable batch gamma radioactivity is not greater than 5 x 1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 are not required.
STOP THINK ACT MP-22-REC-BAP Ol REVIEW R ev. 0 29 1 5 of 1 37 E. For the Condensate Polishing Facility (CPF} waste neutralization sump: IF there is no detectable tritium in the steam generators , THEN tritium sampling and analyses is not required.
IF the gross gamma radioactivity in the grab sample taken prior to release does not exceed 5 x 1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89, Sr-90 and Fe-55 are not required.
F. For Batch Releases and Steam Generator Blowdown only , a composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and in which the method of sampling employed results in a specimen which is representative of the liquids released. G. Prior to analysis , all samples taken for the composite shall be thoroughly mixed in order for the composite sample to be representative of the effluents released. H. For the Steam Generator Blowdown:
lE the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89 , Sr-90 and Fe-55 are not required.
Steam Generator Blowdown samples are not required when blowdown is being recovered.
I. Daily grab samples shall be taken at least five days per week. For service water , daily grabs shall include each train that is in-service.
J. For the Service Water: lE a weekly gamma analysis does not indicate a gamma radioactivity greater than 5 x1 o-7 &#xb5;Ci/ml , THEN the sampling and analysis schedule for gross alpha , Sr-89 , Sr-90 , Fe-55 are not required. K. LLD applies exclusively to the following radionuclides:
Kr-87 , Kr-88 , Xe-133 , Xe-133m , Xe-135, and Xe-138. This list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and identifiable , together with the above nuclides, shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level. When unusual circumstances result in a priori LLDs higher than required, the reasons shall be documented in the " Radioactive Effluent Release Report." L. For the Turbine Building Sump: lE the steam generator gross gamma radioactivity does not exceed 5 x 1 o-7 &#xb5;Ci/ml, OR sump is directed to radwaste treatment , THEN the sampling and analysis schedule for all principal gamma , 1-131 , Ce-144 , noble gases , gross alpha , Sr-89, Sr-90 and Fe-55 are not required. lE the release pathway is directed to yard drains , THEN the LLD for 1-131 shall be 1.5 x 10-7 &#xb5;Ci/ml and for gross alpha 1 x 1 o-8 &#xb5;Ci/ml. M. Detectable tritium shall be used to estimate tritium releases to the atmosphere via the blowdown tank vent. STOP THINK ACT MP-22-REC-BAPOl REVIEW R e v. 0 2 9 16 of 137 
: 2. Liquid Radioactive Waste Treatment
: a. Dose Criteria for Equipment Functionality Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit. 1) IF the radioactivity concentration criteria for the Unit 3 steam generator blowdown is exceeded with blowdown recovery not available to maintain releases to as low as reasonably achievable; or, IF any of the other radioactive waste processing equipment listed in Section b. are not functional, THEN doses due to liquid effluents from the applicable waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.C.2. 2) IF any of these dose projections exceeds 0.006 mrem to the total body or 0.02 mrem to any organ, THEN best efforts shall be made to return the processing equipment to service , or to limit discharges via the applicable waste stream. 3) IF an actual dose due to liquid effluents exceeds 0.06 mrem to the total body or 0.2 mrem to any organ AND the dose from the waste stream with processing equipment not functional exceeds 10% of one of these limits, THEN prepare and submit to the Commission a Special Report within 30 days as specified in Section 2.c. b. Required Equipment for Each Millstone Unit Best efforts shall be made to return the applicable liquid radioactive waste treatment system equipment specified below for each unit to service or to limit discharge via the applicable waste stream if the projected doses exceed any of the doses specified above. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 17 of 137 
: 1. Millstone Unit No. 1 Was t e Stream Processing Equipment Spent Fuel Pool water One filter and one demineralizer
: 2. Millstone Unit No. 2 Waste Stream Processing Equipment Clean liquid Deborating ion exchanger (Tll) OR Purification ion exchanger (TlOA or TlOB) OR Equivalent ion exchanger Primary demineralizer (T22 A or B) OR Equivalent demin e ralizer ALPS/AIM processing OR Secondary demineralizer (T23 A or B) OR Equivalent demineralizer Aerated liquid ALPS/AIM processing OR Demineralizer (T24) OR Equivalent demineralizer
: 3. Millstone Unit No. 3 Waste S t ream Processing Eq u i p ment or Radioactivity Concentration High level ALPS processing (3LWS-SKD1)
OR Demineralizer (3LWS-DEMN2) and Demineralizer filter (3LWS-FLT3)
OR Demineralizer (LWS-DEMNl) and Demineralizer filter (LWS-FLTl)
Boron recovery Cesium ion exchanger (3BRS-DEMN1A or B) Boron evaporator (3BRS-EV1)
Low level High level processing equipment Steam generator Blowdown recovery when total gamma radioactivity exceeds 5E-7 blowdown &#xb5;Ci/ml or tritium exceeds 0.02 &#xb5;Ci/ml. NOTE: The qualifier OR indicates that any of the equipment listed within the block would satisfy the processing requirement if functional.
STOP THINK ACT MP-22-REC-BAPOl RE VI EW Rev. 029 18 of 137 
: c. Report Requirement For All Three Millstone Units If required by Section 2.a.3), prepare and submit to the Commission a Special Report within 30 days with the following content: * *
* Explanation of why liquid radwaste was being discharged without treatment, identification of any equipment not in service, and the reason for the equipment being out of service , Action(s) taken to restore the equipment to service, and Summary description of action( s) taken to prevent a recurrence . STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 19 of 137 Figure I.C.-1, "Reserved STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 20 of 137 r--Cf) -I 0 I I z ;,;; )> (') -I Containment Leakoff RCP s B leed off Aux Bldg & Enclosure Bldg. Equipment Leako Sampling Drains Piping & E mentDrai.n s Decontamination
** Primary Coolant Letdown Steam Generator Blowdown Primary Drains Tank (Tl 7) Equipment Drain Sump Tank (D5) ,-------* IonExchangeq Coo lantW aste Mixed Bed 4 Receiver (T22A/B) I Tanks (Tl4A/B) .. -----* *------* ----~: ALPS/AI!vl ~----r-* ,-------, 1 IonExchanger 1 1 MixedBed 1 L _(!21~--* C oolant Waste Monitor Tanks (Tl 5AIB) Clean Liqui RadMonito (RM9049) To Coolant Waste Receiv e r T ank (T1 4 A/B) Aerated Waste Drains Tanks (T20N B) io;;E:;~;er-1 t ____ .___ (124) :------L -------Aerated Waste Monitor Tank (T 21) 1---------
1 Deborating I Ion Exc han ger J I --(Ill) --_: ----......,;'**
*--------.
7 1 2 Purifi.cation 1 I Ion E xchangers I (TIOA/B) 1 .. _______ _ Volume Co ntrol Tank (T5) To Primary 1---+ Coolant Loop S/GB lowdown or Quench Tank (T45) Aerate d Liquid Ra d Monit or (R M9116) Condensa te Polishin g Fa cility 8 Waste Neut. Sump .________, R Rad Monitor (CN D245) 8 Turbine Bld g. Floor Drains* I RB= BX I--------S-
/G_Bl_o ... _:v_do_wn __ R_ad_M_oru_
*_to_r_c_RM_4_2 6_2_) -+I Niantic Bay Quarry *T urbine Bldg floor drains normally to st orm drains. Drains may be diverted to the radwaste treatment system. ** HP de con facility s ump i s co lle cte din tote s and s hipped o ffsite. ..**....*
: : = Component included inradwa s te treatment ....... ! equipment requirement (J) -i 0 ""tJ -i I z /\ )> () -i Filter -----**----, I r--Z---, ---------Containment Bldg Sump" Allx B ldg Sump* High Level WasteDran Tank (LWS-TKl A/B) 1 Filter I : Demin : -~(LWS-FLT3)~-~ (LWS-DEMN2)~ 1------~ --------. -----------------, Waste Test Tank LWS-TK3A/B .---------.
~-------.
Demin I I Filter I I (LWS-DEMNl)M (LWS-FLTl)
: Reactor Plant Sample Sinks Lab Wastes* MiscHigh-Level Was t e *Via Reactor Plant Aerated Drain System Letdown Demin (DEMN!A/B)
Demin (DEM1N2 A/B) Degassifier (GWS-GRUl) 1 ALPS processing (LWS,SKDI) 1 I I I I ---------__________________ , Volume Conlrol Tank Cesium Boron Recovery Tank (BRS-TKIA/B) To Primary Gra:le Water Boron Test Tank (BRS-TK2A/B) r----------.
: Boron 1
* Evaporator 1..1 ----' Boron Demineralizer RS-DEMN2 A/B) Filter (BRS-FLT3) Reactor P l ant Gaseous Drains Ion Exchanger (BRS-DEMNl A/B) 1 ,_ -------------* ~---(EV!) ___ : Miscellaneous Low-Level Waste Turbine Plant Leakage to Sump Service Water Discharge CPF Waste Neut Sump (TklO&l l) Steam Generator Blowdown (Open Cycle) Filter (FLT4A/B)
Low-Level Waste Drain Tank (LWS-TK4 A/B) 3P A S-E E5 Q
* 3SSR-RE08 Component included in = radwaste treatment equipment requirement Niantic Bay viaDSN 006 3CND-RE07 3LWS-RE70) ... (1Q C: "'1 ro n I r.i:, ... 9 "C -... :=. ro r ... ,.c C: ... trj 9 C: ro = .... -0 ... (1Q "'1 9 ... --r.,, .... 0 = ro (j = ... .... Quarry I.D. Gaseous Effluents
: 1. Gaseous Effluent Sampling and Analysis Program Radioactive gaseous wastes shall be samp l ed and analyzed in accordance with the program specified in Table I.D.-1 for Millstone Unit No. 1, Table I.D. -2 for Millstone Unit No. 2, and Table I.D. -3 for Millstone Unit No. 3. The results of the radioactive analyses shall be input to th e methodology of Section II to ass ur e that offsite doses are maintained within the limits of Radiological Effluent Controls (Section III.D.2. for Millstone Unit No. 1, Section IV.D.2. for Millstone Unit No. 2, and Section V.D.2. for Millstone Unit No. 3). Table I.D. -1 Millstone Unit 1 Radioactive Gaseo u s Waste Samp lin g and Analysis Program Gaseous Release Point or Source A.Spent Fue l Pool Island Vent B.Balance of Plant Vent Sample 'fype and Min imu m FrequencyB Analys i s Frequency MonthlyD ,F -Gaseous Monthly Grab Sample Contin uou sE* Twice per month Particulate Sample ContinuousE*
Quarterly Particulate Sample Composite Contin uou sE* Continuo u s Nob l e Gas Monitor Twice per month ContinuousE.
Particulate Sample Quarterly Composite Grab sample of Reactor Prior to processing Bldg evaporator staging of each batch tank prior to processing Table I.D. -1 TABLE NOTATIONS
'fype of Radioactivity Lower Limit Analysis of Detection (LLD)A (&#xb5;Ci/ml) Kr-85 1 X lQ-4 H-3G 1 X 10-6 Principal Gamma lxio-11 EmittersC.
-(with half lives greater than 8 days) Sr-90 , Gross alpha lxl0-11 Kr-85 1 X lQ-6 Principal Gamma lxl0-11 EmittersC.
-(with half lives greater than 8 days) Sr-90, Gross alpha 1 X lQ-ll H-3 1 X 1Q-S A. The lower limit of detection (LLD) is defined in Table Notations, Item a, of Tables I.C.-1 , I.C.-2, or I.C.-3. B. Samples not r equir ed when Release Point is not in use. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 23 of 137 I C. Fo r particulate samples , the LLD will be 1 x 10-11 &#xb5;C i/cc. The principal gamma emitters for which this LLD applies are exclusively the following radionuclides
: Mn-54 , Co-60 , Zn-65 , Cs-134, Cs-137 , and Ce-144. The list does not mean that only these nuclides are to be detected and reported.
Other peaks which are measurable and identifiable , together with the above nuclides , shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. D. IF there is an unexplained increase of the SFPI Vent noble gas monitor of greater than a factor of ten , OR the monitor reads 8.SE-5 &#xb5;C i/cc or greater , THEN sampling and analysis shall also be performed within 24 hours. E. Continuous when exhaust fans are in operation.
F. When Spent Fuel Pool Island ventilation is shutdown and ventilation of Spent Fuel Pool Island is exhausted to Balance of Plant Vent , the monthly gaseous grab sample shall be obtained from the Balance of Plant Vent. G. Tr i tium analys i s of vent grab sample may be replaced by a calculation of tritium released from the spent fuel pool. STOP THINK ACT M P-22-REC-B APOl REVIEW R ev. 0 29 2 4 o f 1 37 Table I.D.-2 Millstone Un it 2 R a dioacti ve Gaseous Waste Sa mpling and Analysis Program Gase ous Sample 'Iy pe and Minimum Release Point Frequency Analysis or So urc e Frequency
[A.Batch Rel ease I.Waste Gas Stor-Gaseous Grab Prior to each Each Taruc Discharge age Tan1c 8 Waste Gas Tank Discharge B.Containment&Aux Building Releases I.Containment Gaseous Grab of purges l. Prior to Each and vents Purge l. Prior to Each Purge 1 2. Every two weeks 2. Every two weeks for Venting 1 for Venting Monthly Continuous Particulate for Weekly Open Containment Equip-ment Hatch during Outage Continuous Charcoa l for Weekly Open Containment Equip-ment Hatch during Outag e C.Continuous Rel ease l.Vent (RM8132B) 2.Millstone Stack (RM8169-1) Monthly -Gaseous Grab SampleC.,G.
Monthlyl--, 1..1. Continuous Charcoal Sam-Weekly pleD.,F. Continuous P articulate Weekly SampleD.,F.
Continuous Particulate Quarterly Composite Sample 0-Continuous Noble Gasu. Contin uou s Monitor TABLE I.D.-2 TABLE NOTATIONS
'Iype of Lower Limit Radioactivity of D etec tion Analysis (LL D)A (&#xb5;Ci/ml) Princip a l Gamma 1 X lQ-4 Emitters 8 H-3 1 X 1Q-b Princip a l Gamma 1 X lQ-4 Emitters 8 H-3 1 X lQ-b Gamma emitters NA for 1/2 hr count (I-131, others with half-life greater than 8 days) I-131 and I-133 for NA one hour count Principal Gamma 1 X lQ-4 Emitters 8 H-31..1 1 X lQ-O I-131 lxlQ-lL I-133 1 X lQ-lD Principal Gamma l x10-11 EmittersB
-(I-131, others with half lives greater than 8 days) Sr-89, Sr-90 -1 X lQ-ll Gross alpha 1 X lQ-ll Noble Gases -1 X 10-o Gross Radioactivity A. The lower limit of detection (LLD) is defined in Table Notations , Item a , of Tables I.C.-1 , I.C.-2, or I.C.-3. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 25 of 137 B. For gaseous samples , the LLD will be 1 x 1 o-4 &#xb5;Ci/cc and for particulate samples, the LLD will be 1 x 10-11 &#xb5;Ci/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides:
Kr-87, Kr-88 , Xe-133 , Xe-133m , Xe-135 , and Xe-138 for gaseous emission and Mn-54, Fe-59, Co-58, Co-60 , Zn-65 , Mo-99 , 1-131 , Cs-134 , Cs-137, Ce-141, and Ce-144 for particulate emissions.
The list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.
Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances result in a priori LLDs higher than required , the reasons shall be documented in the " Radioactive Effluent Release Report." C. IE there is an unexplained increase of the Millstone Stack or Unit 2 Vent noble gas monitor of greater than 50%, THEN sampling and analysis for principal gamma emitters shall be performed within 72 hours. Sampling and analysis is not required if the monitor reading has returned to within 20% of the average reading prior to the increase. IF the Millstone Stack or Unit 2 Vent noble gas monitor increased greater than 50% and then has decreased to within 20% of the average reading prior to collecting a sample representative of the elevated reading, THEN an estimate of radioactivity released during the period of elevated reading shall be made. D. The ratio of the sample flow rate to the sampled stream flow rate shall be known. E. RESERVED F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after changing.
For Unit 2 vent only The sampling frequency shall be increased to daily following each reactor shutdown , reactor criticality after shutdown , or thermal power change exceeding 15% of rated thermal power as defined in Technical Specification within a one hour period, if one or both of the following has occurred:
: 1) The Dose Equivalent I-i 31 concentration in the reactor coolant has increased by more than a factor of three above the concentration that existed during steady state , full power operation prior to the power transient.
: 2) The noble gas monitor , RM8i32B , has increased more than a factor of three relative to the radiation monitor reading that existed during steady state, full power operation prior to the power transient.
Analyses shall be completed within 48 hours of changing. For daily samples , the LLDs may be increased by a factor of i 0. Daily sampling shall be maintained for seven days or until such time when both conditions (i) and (2) are not satisfied , whichever is shorter. G. IF the refueling cavity is flooded , THEN grab samples for tritium shall be taken weekly. The grab sample shall be taken from the Millstone Stack or vent where the containment ventilation is being discharged at the time of sampling.
STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 0 29 26 of 137 H. Waste Gas Storage Tanks are normally released on a batch basis via the Millstone Stack. However , for the purpose of tank maintenance , inspection , or reduction of oxygen concentration , a waste gas tank may be vented or purged with nitrogen and released to the environment via the normal or alternate pathway using one of the following methods: Method A: W i thout a permit provided the following conditions are met: (1) The tank has been previously discharged with a permit. (2) The current tank pressure is less than 5 PSIG. (3) No radioactive gases have been added to the tank since the previous discharge from the tank. (4) Valve lineups are verified to ensure that no radioactive waste gases will be added to the tank. (5) Prior to initiation of the vent or purge , a sample of the gas in the tank will be taken and analyzed for any residual gamma emitters and tritium. The tank may be released if: a) Tank radioactivity is less than 1 % of the radioactivity released in the previous batch release from the tank , or less than 1 % of the radioactivity released to date for the calendar year , and b) the radioactivity of Kr-85 and Xe-133 is less than 0.01 Ci and the radioactivity of all other gases is less than 0.001 Ci. Method B: With a permit provided valve lineups are verified to ensure that no radioactive waste gases will be added to the tank. I. IE compared to the radioactivity at the time of the air sample, a Radiation Monitor RM8123 or RM8262 gas channel increases by a factor of two , THEN a new containment air sample shall be taken. IE containment noble gas radioactivity exceeds 1 E-6 &#xb5;Ci/cc as indicated by the last grab sample , THEN sampling frequency shall be increased to weekly until such time that the radioactivity is less than 1 E-6 &#xb5;Ci/cc. J. During an outage a sample is only required prior to the initial purge. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 0 2 9 2 7 of 137 Table I.D.-3 Millstone Unit 3 Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Sample 'Iype and Relea se Point Frequency or So urce A. Containment Release I.Containment Gaseous, parti culate and charcoal grab prior to eac h drawdown (via air ejector) Gaseous grab prior to eac h purgeH. Gaseous Grab every two weeks for vents (i.e., re-leases to maintain sub-atmospheric pressure via containment vacuum pump )1-Contin uou s particulate for open containment eq uipm e nt hatch during outages. Contin uou s charcoal for open containment equipment h atch during outages. B.Continuous Relea se 1.Unit 3 Ventila-Monthly -Gaseous tion Vent Grab Samp l eC., G. (HVR-RElOB) 2.Engineered Continuous charcoal Safeguards samp l eD.,F. Building Contin uou s particulate (HVQ-RE49) sarnp l eD.,F. 3.Millstone Stack via SLCRS Continuous p articulate (HVR-sample 0-R E19B) Continuous noble gasu. Minimum 'Iype of Radioactivi ty Ana l ys i s Analysis Fre qu ency Same as samp l e fre-Princip al gamma quency. emittersB*
Sarne as samp l e fre-On charcoal samp l e: quency. I-131 I-13 3 On particulate sample: Princip al gamma emittersB*
-(I-131, oth-ers with half lives greater than 8 days) Monthly for purge, H-3 vents, a nd d rawdowns Weekly Gamma emitters for V2 hour count (1-131, others wit h half-li fe greater th an 8 days) Weekly I-131 and I-133 for one hour count MonthlyL., u. Principal gamma emittersB H-3u Weekly I-131 I-13 3 Weekly Principal gamma emittersB.
-(1-131,others with hal f Jj ves greater than 8 days) Qu arterly composite Sr-89, Sr-90 Gross alpha Continuous Noble gases -gross monitor radioactivity TABLE I.D.-3 TABLE NOTATIONS Lower Limit of D etect ion (LL D)A* (&#xb5;Ci/m l) 1 X 10-4 1 X lQ-ll 1 X lQ-lO 1 X lQ-ll 1 X lQ-b NA NA 1 X lQ-4 1 X 10-o 1 X lQ-lL. lxl0-10 1 X 10-u 1 X lQ-ll 1 X lQ-ll 1 X 10-o A. The lower limit of detection (LLD) is defined in Table Notations , Item a , of Tables I.C. -1, I.C. -2, or I.C.-3. ST OP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 28 of 137 B. For gaseous samples , the LLD will be 1 x 1 o-4 &#xb5;Ci/cc and for particulate samples , the LLD will be 1 x 10-11 &#xb5;Ci/cc. The principal gamma emitters for which these LLDs apply are exclusively the following radionuclides
: Kr-87 , Kr-88 , Xe-133 , Xe-133m , Xe-135 , and Xe-138 for gaseous emission and Mn-54, Fe-59 , Co-58 , Co-60 , Zn-65 , Mo-99 , 1-131 , Cs-134 , Cs-137 , Ce-141 , and Ce-144 for part i culate emissions. The list does not mean that only these nuclides are to be detected and reported. Other peaks wh i ch are measurable and identifiable , together with the above nuclides , shall also be identified and reported. Nuclides which are below the LLD for the analyses should not be reported as being present at the LLD level for that nuclide. When unusual circumstances r esult in a priori LLDs higher than required , the reasons shall be documented in the Radioactive Effluent Release Report. C. lE there is an u nexplained increase of the Unit 3 vent i lation vent or SLCRS noble gas moni t or of greater than 50%, THEN sampling and analysis for principal gamma emitters shall be performed within 72 hours. Sampling and analysis is not required i f the monitor reading has returned to wi t hin 20% of th e average reading prior to th e incre a s e. lE the SLCRS or Unit 3 Vent noble gas monitor increased greater than 50% and then has decreased to within 20% of the reading prior to collecting a sample representat i ve of the elevated reading , THEN an estimate of radioactivity re l eased during the period of elevated reading shall be made. D. The ratio of the sample flow r ate to the sampled stream flow rate shall be known. E. RESERVED F. Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after chang i ng. For Unit 3 Vent only: The sampling frequency shall be increased to daily following each reactor shutdown , reacto r crit i cality after shutdown , or thermal power change exceeding 15% of rated thermal power as defined in Technical Specification within a one hour period , if one or both of the following has occurred: 1) The Dose Equivalent 1-131 concentration in the reactor coolant has increased by more than a factor of three above the concentration that existed during steady state , full power operation prior to the power transient.
: 2) The noble gas monitor , HVR-RE10B , has increased more than a factor of three relative to the radiation monitor reading that existed during steady state , full power operation prior to the power t ransient.
Analyses shall be completed within 48 hours of changing. For daily samples , the LLDs may be increased by a factor of 10. Daily sampling shall be maintained for seven days or until such time when both conditions (1) and (2) are not satisfied , whichever is shorter. G. IF the refueling cavity is flooded , THEN grab samples for tritium shall be taken weekly from the ventilation vent. H. During an outage a sample is only required prior to the initial purge. STOP THINK ACT MP-22-REC-BAP Ol REVIEW R ev. 0 29 29 of 137 I. lE compared to the radioact i vity at the time of the air sample , Radiation Monitor CMS22 gas channel increases by a factor of two , THEN a new containment air sample shall be taken. lE containment noble gas radioactivity exceeds 1 E-6 &#xb5;Ci/cc as indicated by the last grab sample , THEN sampling frequency shall be increased to weekly until such time that the radioactivity is less than 1 E-6 &#xb5;Ci/cc. S T OP THINK ACT MP-22-RE C-BAP Ol REVIEW R ev. 0 29 3 0 o f 13 7 
: 2. Gaseous Radioactive Waste Treatment
: a. Dose Criteria for Equipment Functionality Applicable to All Millstone Units The following dose criteria shall be applied separately to each Millstone unit. 1) IF any of the radioactive waste processing equipment listed in Section 2.b. are not functional or are being bypassed, THEN doses due to gaseous effluents from the untreated waste stream to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in Section II.D.4. For each waste stream, only those doses specified in Section II.D.4. need to be determined for compliance with this section. 2) IF any of these dose projections exceed 0.02 mrad for gamma radiation, 0.04 mrad for beta radiation or 0.03 mrem to any organ due to gaseous effl u ents, THEN best efforts shall be made to return the processing equipment to service. 3) IF actual doses exceed 0.2 mrad for gamma radiation, 0.4 mrad for beta radiation or 0.3 mrem to any organ AND th e dose from a waste stream with equipment not functional exceed 10% any of these limits , THEN prepare and submit to the Commission a report as specified in Section I.D.2.c. b. Required Eq uipm ent for Each Millstone Unit Best efforts shall be made to return the gaseous radioactive waste treatment system equipment specified below for each unit to service if the projected doses exceed any of doses specified above. For the Unit 2 gas decay tanks, the tanks shall be operated to allow enough decay time of radioactive gases to ensure that the Radiological Effluent Control dose limits are not exceeded.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 31 of 137 
: 1. Millstone Unit No. 1 Waste Stream Processing Equipment None Specified None required 2. Millstone Unit No. 2 Waste Stream Processing Equipment Gaseous Radwaste Five (5) gas decay tanks Treatment System One waste gas compressor Ventilation Exhaust Auxiliary buildin g ventilation HEPA filter (L26 or L27) Treatment System Containment purge HEPA filter (L25) Containment vent HEPNcharcoal filter (L29 A or B) 3. Millstone Unit No. 3 Waste Stream Processing Equ ip ment or Radioactivity Concentration Gaseous Radwaste Charcoal bed adsorbers Treatment System One HEPA filter c. Report Requirement For All Three Millstone Units If required by Section I.D.2.a.3), prepare and submit to the Commission a Special Report within 30 days with the following content:
* Exp lanation of why gaseous radwaste was being discharged without treatment, identification of any equipment out of service, and the reason for being out of service,
* Actions taken to restore the nonfunctional equipment to service , and
* Summary description of actions taken to prevent a recurrence. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 32 of 137 Figure I.D.-1, "Simplified Gaseous Effluent Flow Diagram Millstone Unit One" ~-.. * *** * * ** * * * .... * ** = generalized air flow SFPI Vent Spent Fuel Pool Island (SFPI) Balance of Plant Vent S = particulate sampler STOP RM-SFPl-0 2 Evaporator
-------~ .-------------,
* Vent plenum : '--~-----~----. . . . . . . . . . ~-******************** THINK ACT Reactor Building Turbine Building Radwaste Building MP-22-REC-BAPOl REVIEW Rev. 029 33 of 137 Figure I.D.-2, "Simplified Ga se ou s Effiuent Flow Dia g ram Mill s tone Unit Two" Main Co n de n se r t-----1..i Aif Ejector ------. -------, I I I Wast e Gas * * : Decay Proces.sing
: Waste Gas* 1 Tanks System *Co mpre sso r~ (T1 9 A1B t (F-l AIB) I I C/D/E/F) I I I I I L-----* *-------HE P A (L l 7) Waste G as Containment -----------i Rad Monitor Ven_c ____ ..,* HEP A/Charcoal
..
* ____ _,.. E n c l osure Buildin g/ Co ntainmen t Pur ge lAds or b er Unit (L29AIB): I I I A -A -------.. I I ------1 I* I I 1 ,i I I I I HEPA I Mi ll stone Stack WRGM RM-8 1 69 Unit2 I I ..--------------, I (L25) I St eam Ge n erator Slowdown Quench Tank Vent Fu el Buildin g (A ux Building 38'6) I ** I I I *-----* i-----, I -------~' HEP A (L27) .. _____ , Steam Gene rat or Slowdown Tank Vent ---------------
-----. Enclosure Bldg R oo f Vent r-----, Aux.B l dg I I I I -----------------~*
HEPA 1 __________
.._ _ _....__ ... Ve n t (L26) : R a d Moni tor T ur b ine Bldg I (RM 8 l32A/B) \.. ____ _ Turbin e B l dg Roof Vent
* Th ese fl ow pa t hs u se d durin g a n accident.
STOP . -----. I I I I I I
* _____ J T HINK = C omponen t included in tr ea tment equipment requirem e nt ACT MP-22-REC-BAP Ol REVIEW R ev. 0 29 34 o f 137 Figure I.D.-3, "Simplified Gaseous Effluent Flow Diagram Millstone Unit Three" Atmosphere
* Reactor Plant V e ntil l a ti on Vent .~ Serv i ce Buildin g HEPA/Charcoal
__ !_. (3HVR*FL T2A/B) ----* Fue l Building . A uxi l i ary Build i n g --.;--~ I *-* HEPA/Char co al (3H V R*FL T 1 A/B) ----* ---*---* Wa s te Di s posal Bu i ldin g /~ I I ;;. * ', Containment Structure Secondary
* HEPA & Char co al Containments (3HVR*FL T3A/B) (SLCRS) i---. C ont a i nm e nt Va c uum Sy ste m Drawdown ESF Bui l ding Tu r bine Bui l ding SG Slowdown Tank (3BDG-TK1) CPF Turbine Gland S ea l Ste a m Cond E x haust Atmosphere I** /R\t ent a om or (3HVQ-RE49)
Rd M *1 r----[ Ventilation Vent r R ad M o nit o r (3 HVR*RE10B) R C S Mi l ls ton e L e td ow n S ta c k i G a s eous Was t e S ys t e m .--------------, I I I Charc o al Bed s I I I : (3Gws*AD S 1NB) : ~-------------!
I I GW S Ra d K I HEPA I I I Monitor : (3 GWS*FL T1 A/B): 3 GWS-RE48 S L C RS Rad nitor *RE1 9 B) L-------------l I Mai n Conden s er Air E jecto r I I . " Turbine Bui l ding Roof E x hausters Mo (3HVR : : . ESF Bu1 l d1ng E x haust Atmosphere I I I I Component included in treatment equipmen t requirement
~----1
* These flow pa t hs used during an accident STOP T HINK ** Re l eases from Mechan i cal Rooms A-D not monitored ACT MP-22-REC-BAPOl REV I EW Rev. 029 35 of 137 I.E. Radiological Environmental Monitoring
: 1. Sampling and Analysis The radiological sampling and analyses provide measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from plant operation.
This monitoring program thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and modeling of the environmental exposure pathways.
Program changes may be made based on operational experience.
The sampling and analyses shall be conducted as specified in Table I.E. -1 for the locations shown Table I.E.-2. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability , malfunction of automatic sampling equipment or other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report pursuant to Section I.F.l. It is recognized that, at times, it may not be possible or practicable to obtain samples of the media of choice at the most desired location or time. In these instances suitable alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program. Any of the above occurrences shall be documented in the Annual Radiological Environmental Operating Report, which is submitted to the U.S. Nuclear Regulatory Commission prior to May 1 of each year. If the level of radioactivity in an environmental sampling medium at one or more of the locations specified in Table I.E. -2 exceeds the report levels of Table I.E. -3 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days from receipt of sample results , a Special Report which includes an evaluation of any release conditions, environmental factors or other aspects which caused the limits of Table I.E.-3 to be exceeded.
When more than one of the radionuclides in Table I.E.-3 are detected in the sampling medium, this report shall be submitted if: concentration (1) concentration (2) ------~ + + ... 1.0 reporting level (1) reporting level (2) STOP TH I NK ACT MP-22-REC-BAPOl REV I EW Rev. 029 36 of 137 When radionuclides other than those in Table I.E.-3 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose to an individual is equal to or greater than the appropriate calendar year limit of the Radiological Effluent Controls (Sections III.D.l.b., III.D.2.b., or III.D.2.c.
for Unit 1; Sections IV.D.l.b., IV.D.2.b., or IV.D.2.c. for Unit 2; and Sections V.D.l.b., V.D.2.b., or V.D.2.c. for Unit 3). This report is not required if the measured level of radioactivity was not the result of plant effluents, howev er, in such an event, the condition shall be report e d and described in the Annual Radiological Environmental Operating Report. The detection capabilities required by Table I.E.-4 are state-of-the-art for routine environmental m eas urements in industrial laboratori es. It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a mea sure ment system and not as an a posteriori ( after the fact) limit for a particular measurement.
All analyse s 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 pr ese nce of int erfe ring nuclides , or other uncontrollabl e circumstances may render these LLDs unachievable.
In such cases, the contributing factors will b e identified and d esc ribed in the Annual Radiological Environmental Operating Report. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 37 of 137 Table I.E. -1 Mill s tone Radiological Environmental Monitoring Program E x po s ure Pathwa y and/or No. of Sampling an d Coll e ction 'fy p e and Fr e quenc y of Sample Location s Fr e q u enc y A nal ys i s 1. Gamma D ose -39taJ Qu arte rl y Gamma D ose -Qua rt e rl y Environmen t a l TLD 2.Airbome Pa r ticulate 8 Continuous samp l er -filter Gross Beta -Every two weeks change every two weeks Gamma Spectrum -Q uarterly on composite (by l ocation), a n d on indi-victual sample if gross beta is greater t h an lOx t h e mean of t h e co n trol sta-tion's gross b e t a resu lt s 3.Ai rb o rn e Iodin e 8 Co n tin u o u s samp l er -I -131 -Every two weeks canist er change every two weeks 4.Vegetation 5 O ne samp l e near midd l e an d Gamma Isotopic on eac h sample one near end of growing season 5.R eserved 6.Sea Water 2 Co n tin u o u s samp l er with a Gamma I sotopic & Triti u m o n each monthly co ll ection at ind i ca-sample t or l ocation. Qu arterly a t co nt ro l loca t io n -Com p os-i te of 6 weekly grab samp l es 7.Well Water 6 Sem i annua l Gamma I sotopic & Tritium on each sample 8.B ottom Se d i m e n t 5 Semiannua l Gamma I sotop i c on eac h sam pl e 9.So il 3 Annu a ll y Gamma I sotop i c on eac h sam pl e 10.F i n Fish-( ed i ble portion) 2 Sem i -ann u al Gamma I sotop i c on eac h sam pl e 11.Aq u atic flora 4 Qu arterly Gamma I sotopic on eac h sam pl e 13.C l ams (ed ibl e p ortion) 2 S em i-ann u al Gamma I soto pi c on eac h sam pl e 1 4.Lo b sters (e dibl e por t io n) 2 S em i -ann u al Gamma I soto pi c on eac h sam pl e (a) Two or more TLDs or TLD with t w o or more elements per location. (b) Not required during 1 s t quarter. STOP THINK ACT MP-22-REC-BAP O l REVIEW R ev. 0 29 38 o f 13 7 Table I.E.-2 Environmen tal Monitoring Program Sam plin g Locations The following list s the e nvironm e ntal sampling location s a nd the types of samp l es obtained at each location. Sampling lo ca tions are also shown on Figures I.E.-1 and I.E.-2: Location No* Name 1-I Onsite -NAP Parking Lot North 2-I Onsite -Weather Shack 3-I Onsite -Bird Sanctuary 4-I Onsite -Albacore Dri ve 5-I Onsite -Quarry East 6-I Onsite -Quarry Dischar ge 7-I Onsite -Enviro nment a l Lab Dock 8-I Onsite -Environmenta l Lab 9-I Onsite -Bay Point Beach 10-I Waterford-Goshen Fire Dept. 11-I Great Neck Country Club 13-C Mystic, CT 14-C Ledyard, CT 15-C Norwich , CT 16-C Old Lyme, Halls Rd. 17-I Site Bound ary 25-I Fruits & Vegetables 26-C Fruits & Vegetables 27-I Eas t Lyme -Police Station 28-I Two Tree Island 29-I West Jordan Cove 31-I Niantic Shoals 32-I Vicinity of Discharge:.!
33-I Seaside Point 34-I Thames River Yacht Club 35-I Niantic Bay 36-C Black Point 37-C Giant's Neck 41-I Waterford
-Myrock Avenue 42-I Eas t Lyme -Billow Ro ad STOP Direction
& Dis-tance from Re-l ease Point** 0.6 Mi, NNW 0.3 Mi, S 0.3 Mi, NE 1.0 Mi, N 0.1 Mi, SSE 0.3 Mi, SSE 0.3 Mi, SE 0.3 Mi, SE 0.4 Mi, W 1.2 Mi, E 1.6 Mi , ENE 11.5 Mi , ENE 12.0 Mi , NE 14.0 Mi, N 8.8 Mi, W 0.5 Mi, NE Within 10 Miles Beyond 10 Mi l.7Mi, WNW 0.8 Mi, SSE ::; 0.5 Mi , ENE to ESE 1.8 Mi, NW 1.8 Mi, ESE 4.0Mi,ENE
::; 0.5 Mi , SSW to w 2.7Mi, SW 3.5Mi , WSW 3.2 Mi, ENE 2.4Mi, WSW THINK ACT Sampl e Types TLD, Air Particulate , Iodine, Vegetation TLD , Air Particulate, Iodine TLD, Air Particulate , Iodine, Soil TLD, Air Particulate, Iodine, Soil TLD TLD TLD TLD TLD TLD, Air Particulate, Iodine, Vegetation TLD, Air Particulate , Iodine TLD TLD, Soil TLD, Air Particulate, Iodine TLD Vegetation Vegetation Vegetation TLD, Air Particulate , Iodine Fish 1 Clams , Fish 1, Aquatic Flora Bottom Sediment, Clams Bottom Sediment, Fish 1, Seawater, Aquatic Flora Bottom Sediment Bottom Sediment Lobster , Fish, Aquatic Flora Aquatic Flora Bottom Sediment, Seawater TLD TLD MP-22-REC-BAPOl REVIEW Rev. 029 39 of 137 Table I.E.-2, Cont. Location Direction
& Dis-Sample Types tance from Re-No* Name lease Point** 43-I East Lyme -Old Black Point Rd. 2.6 Mi, SW TLD 44-I Onsite -Schoolhouse 0.1 Mi, NNE TLD 45-I Onsite Access Road #1 0.5Mi,NNW TLD 46-I Old Lyme -Hillcrest Rd. 4.6Mi, WSW TLD 47-I East Lyme -W Main St. 4.5Mi, W TLD 48-I East Lyme -Corey & Ro xbury Rd. 3.4Mi, WNW TLD 49-I East Lyme -Society Rd. 3.6 Mi, NW TLD 50-I East Lyme -Manwaring Rd & 2.1 Mi , W TLD Terrace Ave. 51-I East Lyme -Smith Ave. 1.5 Mi, NW TLD 52-1 Waterford
-Riv er Rd. 1.1 Mi, NNW TLD 53-1 Waterford
-Gardiners Wood Rd. 1.4 Mi, NNE TLD 55-1 Waterford
-Magonk Point 1.8 Mi , ESE TLD 56-1 New London -Ocean & Mott Ave. 3.7 Mi , E TLD 57-I New London -Oc ean Ave. 3.6 Mi, ENE TLD 59-I Waterford
-Miner Ave. 3.4 Mi, NNE TLD 60-I Waterford
-Parkway South & 4.0Mi,N TLD Cross Rd. 61-1 Waterford
-Oil Mill & Boston Po st 4.3 Mi , NNW TLD Rd. 62-I East Lyme -Columbus Ave. 1.9 Mi, WNW TLD 63-I Waterford
-Gradiners Wood & 0.8 Mi , NE TLD Jordon Cove Rd. 64-I Waterford
-Shore Rd. 1.1 Mi , ENE TLD 65-1 Waterford
-Bo ston Po st Rd. 3.2Mi, NE TLD 71-1 Onsite well On si te W e ll water 72-1 Onsit e well On site Well water 79-1 Onsite well On si t e Well water 80-I On si t e well Onsite Well water 81-1 Onsite well Onsite Well water 82-1 Onsite well On site Well water 89-C Aquatic B ackground Beyond 4 Mi. Of Lobster discharge 1 Fish to be sampled from one of three locations
-28 , 29 , or 32. 2 Vicinity of discharge includes the Quarry and shoreline area from Fox Island to western point of Red Barn Recreation Area and offshore out to 500 feet.
* I = Indicator; C = Control. ** = The release points are the Millstone Stack for terrestrial locations and the end of the quarry for aquatic location.
NOTE: Environmental TLDs also function as accident TLDs in support of the Millstone Emergency Plan. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 40 of 137 Figure I.E.-1, "Inner TLD , Air, Grass, Soil, and Aquatic Locations" STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 41 of 137 Figure I.E.-2, "Outer TLD and Aquatic Locations" STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 42 of 137 Table I.E.-3 Reportin g Le v el s F or Radio a ctivity C oncentration s In E n vi ronment a l S ample s Anal ys i s Water Ai rborne Fi s h She ll fi s h c. Milk Ve g etable s (p C i/1) Particulate (p C i/g, w e t) (p C i/g , w e t) (p C i/1) (p C i/g , wet) or Ga s e s (p C i/m 3) H-3 20 OOOA ' Mn-54 1 , 000 30 140 F e-59 400 10 60 Co-58 1 , 0 00 3 0 13 0 Co-6 0 300 10 5 0 Zn-65 300 20 8 0 Zr-95 400 Nb-95 400 Ag-llOm 8 30 I-131 20.tl. 0.9 0.2 1 3 0.1 Cs-134 30 10 1 5 60 1 Cs-137 5 0 2 0 2 8 70 2 B a-14 0 200 300 La-140 200 300 A. 20 , 000 pCi/1 for dr i nking water samples. (Th i s is 40 C F R Part 141 v alue.) For non-drinking water pathways , a value of 30 , 000 pCi/1 may be used. B. Reporting level for 1-131 applies to non-drinking wat e r pathways (i.e., seawater). If drinking water pathways are sampled , a value of 2 pCi/1 is used. C. For on-si t e samples , t h ese values can be mu l t i p l ied by 3 to account for the near field dilution factor STOP TH I N K ACT MP-22-REC-B APOl REVIEW R ev. 0 29 43 of 13 7 Analy s is gross b e t a H-3 M n-54 Fe-59 Co-58, 6 0 Z n-65 Zr-95 Nb-95 I-131 Cs-134 Cs-13 7 B a-14 0 L a-14 0 Table I.E.-4 Maximum Value s For Lower Limit s Of Detection (LLD)A* Water (p C i/1) 200 0&deg;* 15 3 0 15 3 0 3 0 15 15c. 15 18 60c. 15c. Airborne Fi s h Milk Particulate S hellfi s h (pCi/1) or Ga s e s (p C i/g, w e t) (p C i/m 3) 1 X lQ-:2. 0.13 0 0.2 60 0.13 0 0.26 0 7 X lQ-2 0.093 1 5 X 10-2 0.13 0 1 5 6 X lQ-2 0.15 0 1 8 70 25 TABLE NOTATIONS Table I.E.-4 Food Product s and Vegeta-tion (p C i/g , w et) 0.06B. 0.0 60 0.0 8 0 Sediment and Soil (pCi/g , d ry) 0.1 50 0.1 80 A. The LLD is the smallest concentration of radioactive material in a sample that w i ll be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a " real" signal. For a particular measurement system (which may include radiochemical separation)
: LLD = 4.66 Sb (E)(V)(2.22)(Ye-M I) Where:
* LLD is the lower limit of detection as defined above (as pCi per unit mass or volume) I
* 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 transformation)
* V is the sample size (i n units of mass or volume)
* 2.22 is the number of transformations per minute per pCi STOP THINK ACT MP-22-REC-B APOl REVI E W R ev. 0 29 44 of 13 7
* Y is the fractional radiochemical yield (when applicable)
* A is the radioactive decay constant for the particular radionuclide
* At is the elapsed time between midpoint of sample collection and midpoint of counting time (or end of the sample collection period) and time of counting.
It should be recognized that the LLD is defined as an a priori (before the fact) limit representing the capability of a measurement system and not as an a posteriori (after the fact) limit for a particular measurement.
Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.
Occasionally background fluctuations , unavoidably small sample sizes , the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.
In such cases , the contributing factors will be identified in the Annual Radiological Environmental Operating Report. B. LLD for leafy vegetables.
C. From end of sample period. D. If no drinking water pathway exists (i.e., seawater), a value of 3 , 000 pCi/1 may be used. STOP THINK ACT MP-22-R E C-BAPOl REVIEW R ev. 0 2 9 45 of 137 
: 2. Land Use Census A land use census shall be conducted annually during the growing season to identify; (1) changes in the use of unrestricted areas, (2) receptor locations, and (3) new exposure pathways to permit modifications in monitoring programs for evaluating doses to individuals from principal pathways of exposure.
The land use census shall identify the location of the nearest resident, nearest garden, and any other land-based food sources in each of the meteorological land sectors within a distance of five miles. Sectors SE, SSE, S, and SSW, are not land sectors because they are over water. When a land use census identifies a food source location other than the nearest garden in a sector which yields a calculated dose greater than the dose currently being calculated in the off-site dose models, make the appropriate changes in the sample location used. For each type of food source ( milk, fruits, etc.) other than the nearest garden in a sector, when a land use census identifies a location which has a D/Q 20% or greater than the D/Q for a current indicator location begin sampling from the new location within 30 days. Sample location changes for food sources other than nearest garden shall be noted in the Annual Radiological Environmental Operating Report. 3. Interlaboratory Comparison Program The lnterlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive materia l in environmental sample matrices are performed as part of a quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid. Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program. A summary of the results obtained as part of the above required Interlaboratory Comparison Program shall be included in the Annual Radiological Environmental Operating Report. With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 46 of 137 I.F. Report Content 1. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report shall include summaries, interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the report period, including a comparison with previous environmental surveillance reports and an assessment of radioactivity from plant operation in the environment.
Any radioactivity from plant operation detected in the environment shall be compared to levels of radioactivity expected based on the effluent monitoring program and modelling of environment exposure pathways for the purpose of verifying the accuracy of the program and modelling.
If levels of radioactivity are detected that result in calculated doses greater than 10CFR50 Appendix I Guidelines, the report shall provide an analysis of the cause and a planned course of action to alleviate the cause. The report shall include a summary table of all radiological environmental samples which shall include the following information for each pathway sampled and each type of analysis:
: 1) Total number of analyses performed at indicator locations.
: 2) Total number of analyses performed at control locations.
: 3) Lower limit of detection (LLD). 4) Mean and range of all indicator locations together.
: 5) Mean and range of all control locations together.
: 6) Name, distance and direction from discharge, mean and range for the location with the highest annual mean (indicator or control).
: 7) Number of non-routine reported measurements as defined in these specifications.
In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in the next annual report. The report shall also include a map of sampling locations keyed to a table giving distances and directions from the discharge; the report shall also include a summary of the Interlaboratory Comparison Data required by Section I.E.3. of this manual. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 47 of 137 L The report shall include the results of the land use census required by Section I.E.2. of this manual. 2. Radioactive Effluent Release Report The Radioactive Effluent Release Report (RERR) sha ll include quarterly quantities of and an annual summary of radioactive liquid and gaseous effluents released from the unit in the Regulatory Guide 1.21 (Rev. 1, June 1974) format. Radiation dose assessments for these effluents shall be provided in accordance with 10 CFR 50.36a and the Radiological Effluent Controls.
An annual assessment of the radiation doses from the site to the most likely exposed REAL MEMBER OF THE PUBLIC shall be included to demonstrate conformance with 40 CFR 190. Gaseous pathway doses shall use meteorological conditions concurrent with the quarter of radioactive gaseous effluent releases.
Doses shall be calculated in accordance with the Offsite Dose Calculation Manual. The licensee shall maintain an annual of the hourly meteorological data (i.e., wind speed, wind direction and atmospheric stability) either in the form of a listing or in the form of a joint frequency distribution.
The licensee has the option of submitting this annual meteorological summary with the RERR or retaining it and providing it to the NRC upon request. The RERR shall be submitted prior to May 1 of each year for the period covering the previous calendar year. The RERR shall include a summary of each type of solid radioactive waste shipped offsite for burial or final disposal during the report period and shall include the following information for each type: * * * * *
* type of waste ( e.g., spent resin, compacted dry waste, irradiated components, etc.) solidification agent (e.g., cement) total curies total volume and typical container volumes principal radionuclides (those greater than 10% of total radioactivity) types of containers used (e.g., LSA, Type A, etc.) The RERR shall include a list of all abnormal releases of radioactive gaseous and liquid effluents (i.e., all unplanned or uncontrolled radioactivity releases, including reportable quantities) from the site to unrestricted areas. Refer To MP-22-REC-REF03, "REMO DCM Technical Information Document (TID)," for guidance on classifying releases as normal or STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 48 of 137 abnormal.
The following information shall be included for each abnormal release:
* total number of and curie content of releases (liquid and gas)
* a description of the event and equipment involved
* cause( s) for the abnormal release
* actions taken to prevent recurrence
* consequences of the abnormal release Changes to the MP-22-REC-BAPOl, "Radiological Effluent Monitoring And Offsite Dose Calculation Manual (REMODCM)," shall be submitted to the NRC as appropriate, as a part of or concurrent with the RERR for the period in which the changes were made. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 49 of 137 SECTION II. Offsite Dose Calculation Manual (ODCM) For the Millstone Nuclear Power Station Nos. 1, 2, & 3 Docket Nos. 50-245, 50-336, 50-423 MP-22-REC-BAPOl STOP THINK ACT REVIEW R ev. 029 50 of 137 SECTION IL OFFSITE DOSE CALCULATION MANUAL (ODCM) II.A. Introduction The purpose of the Offsite Dose Calculation Manual (Section II of the REMODCM) is to provide the parameters and methods to be used in calculating offsite doses and effluent monitor setpoints at the Millstone Nuclear Power Station. Included are methods for determining maximum individual whole body and organ doses due to liquid and gaseous effluents to assure compliance with the regulatory dose limitations in 10 CFR 50 , Appendix I. Also included are methods for performing dose projections to assure compliance with the liquid and gaseous treatment system functionality sections of the Radiological Effluent Monitoring Manual (REMM -Section I of the REMODCM).
The manual also includes the methods used for determining quarterly and annual doses for inclusion in the Radioactive Effluent Release Report. The bases for selected site-specific factors used in the dose calculation methodology are provided in MP-22-REC-REF03, "REMODCM Technical Information." Another section of this manual discusses the methods to be used in determining effluent monitor alarm/trip setpoints to be used to ensure compliance with the instantaneous release rate limits in Sections III.D.2.a., IV.D.2.a., and V.D.2.a. This manual includes the methods to be used in performance of the surveillance requirements in the Radiological Effluent Controls of Sections III , IV, and V. Appendix A, Tables App.A-1 provide a cross-reference of effluent requirements and applicable methodologies contained in the REMODCM. II.B. Responsibilities All changes to the Offsite Dose Calculation Manual (ODCM) shall be reviewed and approved by the Facilities Safety Review Committee prior to implementation. All changes and their rationale shall be documented in the Radioactive Effluent Release Report. It shall be the responsibility of the Site Vice President Millstone to ensure that this manual is used as required by the administrative controls of the Technical Specifications.
The delegation of implementation responsibilities is delineated in the MP-22-REC-PRG , "Radiological Effluent Control." STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 51 of 137 II.C. Liquid Dose Calculations Radiological Effluent Controls (Sections III, IV, and V) limit whole body and maximum organ doses to an individual member of the public to 1.5 mrem whole body and 5 mrem maximum organ per calendar quarter and 3 mrem whole body and 10 mrem maximum organ per year from liquid effluents released from each unit. (See Appendix A, Table App.A-1 for cross-reference effluent control requirements and applicable sections in the REMO DCM which are used to determine compliance).
In addition, installed portions of liquid radwaste treatment system are required to be operated to reduce radioactive materials in liquid effluents when the projected dose over 31 days from applicable waste streams exceeds 0.006 mrem whole body or 0.02 mrem maximum organ. This part of the REMODCM provides the calculation methodology for determining the doses from radioactive materials released into liquid pathways of exposure associated with routine discharges.
: 1. Monthly, Quarterly, and Annual Dose Calculation (Applicable to All Units) For each Unit , whole body and maximum organ doses from liquid effluents shall be calculated at least once per 31 days ( or monthly) using the methodology of Regulatory Guide 1.109, Rev. 1. The calculation shall include contributions from all analyses required by Table I.C-1 for Unit 1, Table I.C-2 for Unit 2, and Table I.C-3 for Unit 3 recorded to date. If any required analyses have not yet been completed for the dose period, an estimate of dose from unanalyzed isotopes shall be included in the dose total. Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit. 2. Monthly Dose Projections Section I.C.2.a. of the REMM requires that certain portions of the liquid radwaste treatment equipment be used to reduce radioactive liquid effluents when the projected doses for each Unit (made at least once per 31 days) exceeds 0.006 mrem whole body or 0.02 mrem to any organ. The following methods are applied in the estimation of monthly dose projections:
: a. Whole Body and Maximum Organ when Steam Generator Total Gamma Radioactivity is less than SE-7 &#xb5;Ci/ml and Steam Generator Tritium is less than 0.02 &#xb5;Ci/ml (Applicable to Units 2 and 3) The projected monthly whole body dose (Units 2 or 3) is determined from: STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 52 of 137 The monthly projected maximum organ dose (Units 2 or 3) is determined from: Where: DMW = the whole body dose from the last typical previously completed month as calc ulat ed per the methods in Section II.C.l. DMo = the maximum organ dose from the last typical previously completed month as calcu l ated per the methods in Section IL C. l. R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month. Ri = the ratio of estimated primary coolant radioactivity for the present month to that for the past month. F2 = the factor to b e applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers).
NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.
The last month should be typical without significant operational differences from the projected month. If there were no releases during last month, do not use that month as the b ase month if it is estimated that there will be releases for the coming month. b. Whole Body and Maximum Organ when Steam Generator Total Gamma radioactivity Exceeds SE-7 &#xb5;Ci/ml or Steam Generator Tritium Exceeds 0.02 &#xb5;Ci/ml (Applicable to Units 2 and 3) The projected monthly whole body dose (Units 2 or 3) is determined from: The monthly projected maximum organ dose (Units 2 or 3) is STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 53 of 137 determined from: Where: DMW=the whole body dose from the last typical previously completed month as calculated per the methods in Section II.C.l. DMo=the maximum organ dose from the last typical previously completed month as calculated per the methods in Section II.C.1. R1 = the ratio of the total estimated volume of liquid batches to be released in the present month to the volume released in the past month. R 2 = the ratio of estimated volume of steam generator blowdown to be released in present month to the volume released in the past month. F1 = the fraction of curies released last month coming from steam generator blowdown calculated as: curies from blowdown curies from blowdown + curies from batch tanks R3 = the ratio of estimated secondary coolant radioactivity for the present month to that for the past month. R4 = the ratio of estimated primary coolant radioactivity for the present month to that for the past month. F 2 = the factor to be applied to the estimated ratio of final curies released if there are expected differences in treatment of liquid waste for the present month as opposed to the past month (e.g., bypass of filters or demineralizers).
NUREG-0017 or past experience shall be used to determine the effect of each form of treatment which will vary. F2 = 1 if there are no expected differences.
STOP THINK ACT MP-22-REC-BAPOl RE V IEW Rev. 029 54 of 137 L II.D. Gaseous Dose Calculations
: 1. Site Release Rate Limits ("Instantaneous")
Radiological Effluent Controls (Sections III.D.2.a , IVD.2.a, and VD.2.a) for each unit require that the instantaneous off-site dose rates from noble gases released to the atmosphere be limited such that they do not exceed 500 mrem/year at any time to the whole body or 3000 mrem/year to the skin at any time. For iodine-131 , 133, tritium , and particulates (half-lives
> 8 days), the dose rate from all units shall not exceed 1500 mrem/year at any time to any organ. These limits apply to the combination of r e leases from all three Units on the site, and are directly related to the radioactivity release rates measured for each Unit. a. Method 1 for Noble Gas Release Rate Limits Instantaneous noble gas release rate for the site: G1v /90,000 +Q 2 s/560 , 000 + G z v/290,000 + Q 3 s/560 , 000 + Q 3 v/290,000 .:s_ 1 Where: Giv = Noble gas release rate from Spent Fuel Pool Island Vent (&#xb5;Ci/sec) G 2 s = Noble gas release rate from MP2 to Millstone Stack (&#xb5;Ci/sec) G 2 v = Noble gas rel e ase rate from MP2 Vent (&#xb5;Ci/sec) Q3y = Noble gas release rate from MP3 Vent (&#xb5;Ci/s e c) Q3s = Noble gas release rat e from MP3 to Millston e Stack (&#xb5;Ci/sec) As long as the above is less than or equal to 1 , the doses will be less than or equal to 500 mrem to the total body and less than 3000 mrem to th e skin. The limiting factor for the Unit 1 SFPI vent of 90,000 is based on the skin dose limit of 3,000 mrem/year , while all the other factors are based on the whole body dose limit of 500 mrem/year. b. Method 1 Release Rate Limit -I-131, I-133, H-3 and Particulates Half Lives Greater Than 8 Days With releases satisfying the following limit conditions, the dose rate to the maximum organ will be less than 1500 mrem/year from the inhalation pathway: STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 55 of 137 L 1) Site release rate ofl-131, I-133, and tritium (where the thyroid is the critical organ for these radionuclides):
DRthyl + DRtby 2 + DRtby3 1 Where the contribution from each Unit is calculated from: Unit 1: DRthyl = 2.78E-5 0H1v Unit 2: DRtby2 = 8.80E-2131012v
+ 9.67E-3 131012s + 2.08E-2133012v+2.29E-3 133012s + 6.87E-6 OH2v+7.53E-7 OH 2s Unit 3: DRtby 3 = 8.80E-2131Q13y
+ 9.67E-3 131Q13s + 2.08E-2133Q13y
+2.29E-313 3 Q13s + 6.87E-6 QH3V + 7.53E-7 QH3S 2) Site release rate of particulates with half-lives greater than 8 days and tritium (where the critical organ is a composite of target organs for a mix of radionuclides):
DRo rgl + DRor g2 + DRor g3 1 Wh ere the contribution from eac h Unit is calculated from: Unit 1:DRorgl = 3.52E-1 [QPlv + Qprn ]+2.78E-5 0H1V Unit 2:DRorg2 = 9.53E-3 0P2s + 8.67E-2 Qp2v + 7.53E-7 QH 2S + 6.87E-6 QH2V Unit 3:DRorg3 = 9.53E-3 Qp3s + 8.67E-2 Qp 3y + 7.53E-7 QH3S + 6.87E-6 QH3V Each of the release rate quantiti es in th e above equations are defined as: 131012v =Release rate ofl-131 from MP2 V e nt (&#xb5;Ci/sec)* 131012s = Release rate ofl-131 from MP2 to Millstone Stack (&#xb5;Ci/sec) 133Q12v = Release rate of I-133 from MP2 Vent (&#xb5;Ci/sec)* 133Q12s = Release rate of I-133 from MP2 to Millstone Stack (&#xb5;Ci/sec) 131Q13y =Release rate ofl-131 from MP3 Vents (Normal and ESF) (&#xb5;Ci/sec)* STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 56 of 137 131Q13s = Release rate ofl-131 from MP3 to Millstone Stack (&#xb5;Ci/sec) 133Q13y = Release rate of I-133 from MP3 Vents (Normal and ESF) (&#xb5;Ci/sec)* 133Q13s = Release rate of I-133 from MP3 to Millstone Stack (&#xb5;Ci/sec) QHlV = Release rate of tritium from the Spent Fuel Pool Island and Balance of Plant Vents (&#xb5;Ci/sec) QH2v = Release rate of tritium from MP2 Vent (&#xb5;Ci/sec)* QH2s = Release rate of tritium from MP2 to Millstone Stack (&#xb5;Ci/sec) QH3V = Releas e rate of tritium from MP3 Vents (Normal and ESF) (&#xb5;Ci/sec)* QH3S = Release rate of tritium from MP3 to Millstone Stack (&#xb5;Ci/s e c) Qp1v = Release rate of total particulates with half-lives greater than 8 days from the Spent Fuel Pool Island Vent (&#xb5;Ci/sec) Qprn = Release rate of total particulates with half-lives greater than 8 days from the Balance of Plant Vent (&#xb5;Ci/sec) Qpzy = Release rate of total particulates with half-lives greater than 8 days from the MP2 Vent (&#xb5;Ci/sec) QP2s = Release rate of total particulates with half-lives greater than 8 days from MP2 to Millstone Stack (&#xb5;Ci/sec) Qp3y = Release rate of total particulates with half-lives greater than 8 days from MP3 Vents (Normal and ESF) (&#xb5;Ci/sec) Qp3s = Release rate of total particulates with half-lives greater than 8 days from MP3 to Millstone Stack (&#xb5;Ci/sec)
* includes releases via the steam generator blowdown tank vent. c. Method 2 The above Method 1 equations assume a conservative nuclide mix. If necessary, use the methodology given in Regulatory Guide 1.109 to estimate the dose rate from either noble gases or iodines, tritium, and particulates with half-lives greater than 8 days. 2. 10 CFR50 Appendix I -Noble Gas Limits Use the methodology of Regulatory Guide 1.109 Rev.l, to calculate the critical site boundary gamma air and beta air doses at least once per 31 days (monthly).
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 57 of 137 For calculations p erfo rm e d once every 31 days , e nt er th e following meteorology:
Release Point Sit e Stack Mixed-mode or rooftop (e.g., vents) Ground y)Q 8.92E-7 8.lE-6 3.28E-5 D/Q 8.84E-9 l.5E-7 l.68E-7 If th e calculated air dos e excee d s one half th e quarterly Radiological Effl u e nt Control limit , u se met e orology concurrent with quart er of release. Results of these do se calculations sha ll be s umm ed to d etermine comp li ance with quart erly and annual dos e limit s for eac h Unit. For calculations of quart erly do ses for the Radioacti ve Effl u ent R e leas e R epor t , u se average quart e rl y or real-time meteorology.
STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 58 of 137 
: 3. 10 CFR50 Appendix I -Iodine, Tritium , C-14 , and Particulate Doses For each Unit, whole body and maximum organ doses from I-131, I-133, tritium, C-14 and particulates with half-lives greater than 8 days in gaseous effluents shall be calculated at least once per 31 days ( or monthly) using the methodology of Regulatory Guide 1.109, Rev.l. For calculations performed once every 31 days , enter the following meteorology:
Release Point Site Stack Mixed-mode or rooftop (e.g., v e nts) Ground x)Q 8.92E-7 8.lE-6 3.28E-5 D/Q 8.84E-9 l.5E-7 l.68E-7 The calculation shall include contributions from all analyses required by Table I.D-1 for Unit 1, Table I.D-2 for Unit 2, and Table I.D-3 for Unit 3 recorded to date. If any required analyses have not yet been completed for the dose period, an estimate of dose from unanalyzed isotopes shall be included in the dose total. If the calculated dose exceeds one-half the quarterly Radiological Effluent Control limit, use meteorology concurrent with the dose period. Results of these dose calculations shall be summed to determine compliance with quarterly and annual dose limits for each Unit. For calculations of quarterly doses for the Radioactive Effluent Release Report, use average quarterly or real-time meteorology. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 59 of 137 
: 4. Gaseous Effluent Monthly Dose Projections Section I.D.2.a. of the REMM requires that certain portions of the gaseous radwaste treatment equipment be returned to service to reduce radioactive gaseous effluents when the projected doses for each Unit (made at l east once per 31 days) exceed 0.02 rnrad gamma air, 0.04 rnrad beta air , or 0.03 rnrem to any organ from gaseous effluents.
The following methods are app li ed in the estimation of monthly dos e proj ec tions. a. Unit 1 Projection Method None required. b. Unit 2 Projection M e thod 1) Due to Gaseous Radwaste Treatment System (Unit 2) Determine the b e ta and gamma monthly air dose projection from noble gases from the following:
D E MG (mrad) = 5E-4 CEN DEMB (rnrad) = 3E-4 cEN D E MO (mrem) = 3E-4 CEN Wh ere: cEN = the numb e r of curies of noble gas estimated to be released from the waste gas storage tanks during the next month. D E MG = the estimated monthly gamma air dose. D E MB= the estimated monthly b eta air dose. D EM o= the estimated monthly organ dose. 2) (Reserved)
: 3) Due to Ventilation Releases (Unit 2) If portions of th e ventilation treatment system are expected to be out of service during the month , determine the monthly maximum organ dose projection (D EM O ) from the following:
: 1. Method 1 Determine D E MO which is the estimated monthly dose to the maximum organ from th e following:
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 60 of 137 DEMO= 1/3 R1 (l.01-R2) (R3+ 0.01) Do For the last quarter of operation , determine Do as determined per Section II.D.3. R1 = the expected reduction factor for the HEPA filter. Typically this should be 100 (see NUREG-0016 or 0017 for additional guidance).
R 2 = the fraction of the time which th e equipment was nonfunctional during the last quarter. R 3 = the fraction of the time which the equipment is expected to be nonfunctional during the next month. Do = maximum organ dose from the previous month. 11. Method 2 If necessary, es timate the curies expected to be released for the next month and applicable method for dose calculation from Section II.D.3. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 61 of 137 
: c. Unit 3 Projection Method 1) Du e to Radioactive Gaseous Waste System (Unit 3) D etermine the beta and gamma monthly air dose projection from noble gases from the following:
DEMG (mrad) = 5E-4 CEN DEMB (rnrad) = 3E-4 CEN DEMO (mrem) = 3E-4 CEN Where: cEN = the number of additional curies of noble gas estimated to be released from Unit 3 during the next month due to the nonfunctional processing equipment.
DEMG = the estimated monthly gamma air dose. DEMB = the estimated monthly beta air dose. DEMO = the estimated monthly organ dose. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 62 of 137 
: 5. Compliance with 40CFR190 The following sources shall be considered in determining the total dose to any real member of the public, at or beyond the site boundary , from uranium fuel cycle sources: a. Gaseous Releases from Units 1 , 2, and 3. b. Liquid Releases from Units 1 , 2, and 3. c. Direct and Scattered Radiation from Radioactive Material on Site. d. Direct and Scattered Radiation from the Independent Sp e nt Fuel Storage Installation (ISSFSI).
Doses shall be obtained per th e requirements of Section 11.C.1 for liquid releases and Section II.D.2 and II.D.3 for gaseous releases.
Direct and scattered radiation doses shall be calculated.
Doses from all sources shall b e added to determine compliance with 40CFR190.
STOP THINK ACT MP-22-REC-BAPOl REV I EW Rev. 029 63 of 137 ILE. Liquid Discharge Flow Rates And Monitor Setpoints
: 1. Unit 1 Liquid Waste Effluent Discharge (RE-MG-110)
The limit on discharge flow rate and setpoint on the Unit 1 liquid waste monitor depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used: STEP 1: From the isotopic analysis and the Effluent Concentration (EC) values for each identified nuclide determine the required reduction factor, i.e.: R = R e quired Reduction Factor = c l '\:""' o f nuclid e i STEP 2: Determine the allowable discharge flow (F) F = O.lxRxD Where: L...., 10 x E C of nuclid e i D = The existing dilution flow which is the any dilution flow from Millstone Unit 2 and/or Unit 3 not being credited for any other radioactivity discharge during discharge of Unit 1 water. 0.1 = safety factor to limit discharge concentration to 10% of the Radiological Effluent Control Limit. STEP 3: Calculate the monitor setpoint as follows: Rset = 2 x AC x RCF + Background Where: Rset = The setpoint of the monitor. AC = The total radwaste effluent concentration
(&#xb5;Ci/ml) in the tank. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 64 of 137 RCF = The response correction factor for the effluent line monitor using the current calibration factor or isotopic-specific responses.
2 = Tolerance limit which brings the setpoint at twice the expected response of the monitor based on sample analysis.
With the safety factor of 0.1 the setpoint would be at 20% of the Radiological Effluent Control Limit. Option setpoint:
A setpoint based upon worst case conditions may be used. Assume the maximum possible discharge flow, a minimum dilution flow not to exceed 100,000 gpm, and a limit of 1 x 10-7 &#xb5;Ci/ml which is lower than any 10CFR20 EC limit except for transuranics.
This will assure that low level releases are not terminated due to small fluctuations in radioactivity.
When using this option setpoint independent verification of discharge lineup shall be performed.
The optional setpoint may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.
: 2. Reserved 3. Unit 2 Clean Liquid Radwaste Effluent Line -RM9049 and Aerated Liquid Radwaste Effluent Line -RM9116 The setpoint on the Unit 2 clean and aerated liquid waste effluent lines depend on dilution water flow, radwaste discharge flow, the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, an alarm/trip setpoint will be determined prior to the release of each batch. The following method will be used: STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 65 of 137 STEP 1: From the tank isotopic analysis and the Effluent Concentrations (EC) in 10CFR20, App. B, Table 2, Col. 2 for each identified nuclide determine the required reduction factor, i.e.: For Nuclides Other Than Noble Gases: 1 R 1 = Required Reduction Factor=--------
"' 'ff of nuclid e i L..., 10 x EC o f nuclid e i For Noble Gases: If the noble gas concentration is less than 1.1 x 10-2 &#xb5;Ci/ml or the calculated diluted concentration is less than 2 x 10-5 &#xb5;Ci/ml, the reduction factor need not be determined.
The concentration of 1.1 x 10-2 &#xb5;Ci/ml is based on 175 gpm discharge flow, 100,000 gpm dilution flow, and a safety factor of 0.1 (See Note below.) If dilution flow is less than 100,000 gpm, the noble gas concentration limit shall be decreased by the ratio of actual dilution flow to 100,000gpm.
For example, if dilution flow is 50,000 gpm, the limit would be reduced by a factor of 0.5 (50,000/100,000).
R 2 = Required Reduction Factor = c 1 "' l!;;;f of nobl e g a se s 2 X 10-4&#xb5;C i ml "' C' L..., &#xb5;m/ noble gases R = the smaller of R 1 or R2 STEP 2: L._, 2 X 10-4uCi ml Determine the allowable discharge flow (F) in gpm: F=O.lxRxD Where: D = the existing dilution flow (D) from circulating and service water pumps. It may include any Unit 3 flow, or portion of Unit 3 flow, not being credited for dilution of a Unit 3 radioactivity discharge during the time of the Unit 2 discharge.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 66 of 137 NOTE Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1. With this condition on discharge flow rate met , the monitor setpoint can be calculated:
Rset 2 x AC x RF (See Note 1 below.) Where: Rset = the setpoint of the monitor ( cpm). AC = the total radwaste effluent concentration
(&#xb5;Ci/ml) in the tank. RF = the response factor for the effluent line monitor using the current calibration factor or isotopic-specific responses.
2 = the multiple of expected count rate on the monitor based on the radioactivity concentration in the tank. This value or that corresponding to 5.6 x 10-5 &#xb5;Ci/ml (Note 2 below), whichever is greater , plus background is the trip setpoint.
For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.
Note 1: If discharging at the allowable discharge rate (F) as determined in abov e , this setpoint would correspond to 20% of the Radiological Effluent Control limit. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 67 of 137 Note 2: This va lu e is bas e d upon assuming maximum discharg e flow (175 gpm), dilution water flow of 100,000 gpm and a limit of 1 x 10-7 which is lower than any Technical Specification limit (ten times 10CFR20 EC values) except for transuranics.
This will assure that low l evel releases are not terminated du e to small fluctuations in radioactivity activity.
However, to verify that the correct tank is being discharged when using this va lu e, independent valve verification shall be performed.
This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however , controls shall b e established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.
Dilution flow may include any Unit 3 flow , or a portion of Unit 3 flow , not being credited for dilution of a Unit 3 radioactive discharge during the time of th e Unit 2 discharg e. 4. Condensate Polishing Facility Waste Neutralization Sump Effluent Line -CND245 The setpoint shall be determined as for the Clean and Aerated Liquid Monitors in Section 11.E.3. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 68 of 137 
: 5. Unit 2 Stearn Generator Blowdown -RM4262 and Unit 2 Stearn Generator Blowdown Effluent Concentration Limitation 5a. Unit 2 Stearn Generator Blowdown -RM4262 Alarm ::; 800 CPM + background This setpoint may be adjusted (increased or decreased) through proper administrative controls.
Adjust e d alarm 6 C'P'M X circulating
& s e rvic e wat e r flow (gpm) :5 + Ba c kground total SG blowdown (gpm) When using the adjusted alarm , ensure that any other simultaneous discharge does not cause an exceedance of regulatory limits. 5b. Unit 2 Stearn Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I. C. -2 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed ten times the concentration limits in 10CFR20 , Appendix B. 6. Unit 2 Condenser Air Ejector -RM5099 N I A since this monitor is no longer a final liquid effluent monitor. 7. Unit 2 Reactor Building Closed Cooling Water RM6038 and Unit 2 Service Water , and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation 7a. Unit 2 Reactor Building Closed Cooling Water RM6038 The purpose of the Reactor Building Closed Cooling Water (RBCCW) radiation monitor is to give warning of abnormal radioactivity in the RBCCW system and to prevent releases to the Service Water system which, upon release to the environment, would exceed ten times the concentration values in 10CFR20. According to Calculation RERM-02665-R2 , radioactivity in RBCCW water which causes a monitor response of greater than the setpoint prescribed below could exceed ten times thelOCFR20 concentrations upon release to the Service Water system. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 69 of 137 SETPOINT DURING POWER OPERATIONS:
To give adequate warning of abnormal radioactivity, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 2,000 cpm. The monitor background reading shall be the normal monitor reading. If the monitor background reading exceeds 2,000 cpm, the setpoint shall be set at the background reading plus 2,000 cpm and provisions shall be made to adjust the setpoint if the background decreases.
SETPOINT DURING SHUTDOWN:
: 1) During outages not exceeding three months the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 415 cpm. If the monitor background reading exceeds 415 cpm, the setpoint shall be set at the background reading plus 415 cpm and provisions shall be made to adjust the setpoint if the background decreases.
: 2) During extended outages exceeding three months, but not exceeding three years, the setpoint shall be two times the radiation monitor background reading, provided that the background reading does not exceed 80 cpm. If the monitor background reading exceeds 80 cpm , the setpoint shall be set at the background reading plus 80 cpm and provisions shall be made to adjust the setpoint if the background decreases.
PROVISIONS FOR ALTERNATE DILUTION FLOWS: These setpoints are based on a dilution flow of 4,000 gpm from one service water train. If additional dilution flow is credited, the setpoint may be adjusted proportionately.
For example, the addition of a circulating water pump dilution flow of 100,000 gpm would allow the setpoint to be increased by a factor of 25. 7b. Unit 2 Service Water, and RBCCW Sump and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water , RBCCW sump and turbine building sump samples taken in accordance with Table I.C.-2 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water, RBCCW sump and turbine building sump effluents to less than ten times the limits in 10CFR20, Appendix B. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 70 of 137 
: 8. Unit 3 Liquid Waste Monitor -LWS-RE70 The setpoints on the Unit 3 liquid waste monitor depend on dilution water flow, radwaste discharge flow , the isotopic composition of the liquid, the background count rate of the monitor and the efficiency of the monitor. Due to the variability of these parameters, the alert and alarm setpoints will be determined prior to the release of each batch. The following method will be used: Step 1: From the tank isotopic analysis and the Effluent Concentration (EC) values for each identified nuclide determine the required reduction factor, i.e.: For Nuclides Other Than Noble Gases: 1 R 1 = R e quir e d Reduction Factor = ----=----' o f n ucl id e i L 10 x E C o f nuclid e i For Noble Gases: If the noble gas concentration is less than 0.013 &#xb5;Ci/ml or the calculated diluted concentration is less than 2 x 10-5 &#xb5;Ci/ml, the reduction factor need not be determined.
The concentration of 0.013 &#xb5;Ci/ml is based on 100,00 gpm dilution flow and a safety factor of 0.1 (See Note Below.) If dilution flow is less than 100,000 gpm, the noble gas concentration limit shall be decreased by the ratio of actual dilution flow to 100 , 000gpm. For example, if dilution flow is 50 , 000 gpm, the limit would be reduced by a factor of 0.5 (50,000/100,000).
R 2 = Required Reduction Factor= ---=1, o f nobl e g a se s L 2 X 10-4<<Ci ml R = the smaller of Rl or R2 Step 2: Determine the allowable discharge flow (F) F = O.lxRxD Where: 2 X 10-4&#xb5;C i ml ' C" L ~1/ noble gases D = The existing dilution flow (D) from circulating and service water pumps. It may include any Unit 2 flow, or portion of Unit 2 flow , not being credited for dilution of a Unit 2 radioactivity discharge during the time of the Unit 3 discharge.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 71 of 137 NOTE Note that discharging at this flow rate would yield a discharge concentration corresponding to 10% of the Radiological Effluent Control Limit due to the safety factor of 0.1. With this condition on discharge flow rate met, the monitor setpoint can be calculated:
Rset = 2 x AC x RCF (see Note 1) Where: Rset= The setpoint of the monitor. AC= The total radwaste effluent concentration
(&#xb5;Ci/ml ) in the tank. RCF= The response correction factor for the effluent line monitor using the current calibration factor or isotopic-specific responses. 2 The multiple of expected count rate on the monitor based on th e radioactivity concentration in the tank. This value, or that corresponding to 6.6 x 10-5 &#xb5;Ci/ml (Note 2 below), whichever is greater, plus background is the trip setpoint.
For the latter setpoint, independent valve verification shall be performed and minimum dilution flow in Note 2 shall be verified and if necessary, appropriately adjusted.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 72 of 137 NOTE 1. If discharging at the allowable discharge rate (F) as determined above, this Alarm setpoint would yield a discharge concentration corresponding to 20% of the Radiological Effluent Control limit. 2. This value is based upon assuming maximum discharge flow (150 gpm), dilution water flow of 100,000 gpm, and a limit of 1 x 10-7 &#xb5;Ci/ml which is lower than any Technical Specification limit (ten times 10CFR20 EC values) except for transuranics.
This will assure that low level releases are not terminated due to small fluctuations in radioactivity.
However, to verify that the correct tank is being discharged when using this value, independent valve verification shall be performed.
This value may be adjusted (increased or decreased) by factors to account for the actual discharge flow and actual dilution flow; however, controls shall be established to ensure that the allowable discharge flow is not exceeded and the dilution flow is maintained.
Dilution flow may include Unit 2 flow, or portion of Unit 2 flow, not being credited for dilution of a Unit 2 discharge during the time of the Unit 3 discharge.
: 9. Unit 3 Regenerant Evaporator Effluent Line -LWC-RE65 The MP3 Regenerant Evaporator has been removed from service with DCR M3-97-041.
Therefore a radiation monitor alarm is not needed. 10. Unit 3 Waste Neutralization Sump Effluent Line -CND-RE07 Same as Section II.E.8. 11. Unit 3 Steam Generator Blowdown -SSR-RE08 and Unit 3 Steam Generator Blowdown Effluent Concentration Limitation lla. Unit 3 Steam Generator Blowdown -SSR-RE08 The alarm setpoint for this monitor assumes: a. Steam generator blowdown rate of 400 gpm (maximum blowdown total including weekly cleaning of generators
-per ERC 25212-ER-99-0133).
: b. The release rate limit is conservatively set at 3 x 10-8 &#xb5;Ci/ml which is well below any 10CFR20 Effluent Concentration except for transuranics
*. c. Circulating and service water dilution flow during periods of blowdown = 100,000 gpm. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 73 of 137 
: d. Background can be added after above calculations are performed.
Therefore , the alarm setpoint corresponds to a concentration of: Alarm (&#xb5;Ci/m[) = lO~O~OO x 3xl0-8 + background
= 7.5xl0-{i
&#xb5;Ci/ml + background This setpoint may be increased through proper administrative controls if the steam generator blowdown rate is maintained less than 400 gpm and/or more than 100,000 gpm dilution flow are available.
The amount of the increase would correspond to the ratio of flows to those assumed above or: ci rculatin g & service water flow (gpm) 400 Alarm (&#xb5;Ci/ ml) = 7.SxlO-<J&#xb5;Ci/ ml x x--------100, 000 S/ G blowdown (gpm) circulating
& se rvic e wat e r flow (gpm) Ba c kground = 3xl0-8&#xb5;Ci/ ml x + Background total S/ G blowdown (gpm) When using the adjusted alarm, ensure that any other simultaneous discharge does not cause an exceedance of regulatory limits. NOTE The Steam Generator Blowdown alarm criteria is in practice based on setpoints required to detect allowable levels of primary to secondary leakage. This alarm criteria is typically more restrictive than that required to meet discharge limits. This fact shall be verified, however, whenever the alarm setpoint is recalculated.
* In lieu of using 3 x 10-8 &#xb5;Ci/ml, ten times the identified 10CFR20 EC values may be used. llb. Unit 3 Steam Generator Blowdown Effluent Concentration Limitation The results of analysis of blowdown samples required by Table I.C.-3 of Section I of the REMODCM shall be used to ensure that blowdown effluent releases do not exceed ten times the concentration limits in 10CFR20, Appendix B. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 74 of 137 
: 12. Unit 3 Turbine Building Floor Drains Effluent Line -DAS-RE50 and Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation 12a. Unit 3 Turbine Building Floor Drains Effluent Line -DAS-RE50 The alarm setpoint for this monitor shall be set to four times (4X) the reading of the monitor when there is no gamma radioactivity present in the turbine building sumps. As determined in Calculation RERM-04101R3, the setpoint shall not exceed 1.4 x 10-5 &#xb5;Ci/ml. 12b. Unit 3 Service Water and Turbine Building Sump Effluent Concentration Limitation Results of analyses of service water and turbine building sump samples taken in accordance with Table I.C.-3 of Section I of the REMODCM shall be used to limit radioactivity concentrations in the service water and turbine building sump effluents to less than ten times the limits in 10CFR20, Appendix B. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 75 of 137 II.F. Gaseous Monitor Setpoints
: 1. Unit 1 Spent Fuel Pool Island Monitor -RM-SFPI-02 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section 11.D.1.a. in order to satisfy Unit 1 Radiological Effluent Controls III.C.2. and III.D.2.a.
The Unit 1 allocated portion of the site instantaneous release rate limit is 30 , 000 &#xb5;Ci/sec. This assumes that 7% of the site limit for skin dose of 3000 mrem per year is assigned to the Unit 1 Spent Fuel Pool Island vent. If effluent conditions from the Unit 1 Spent Fuel Pool Island vent reach 30,000 &#xb5;Ci/sec, releases from Units 2 and 3 vents and from the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site skin dose limit to be exceeded.
Use Section 11.D.1.a.
and Section 4.2 of MP-22-REC-REF03. "REMODCM Technical Information Document," in making this determination.
The alarm setpoint shall be set at or below the monitor reading in &#xb5;Ci/cc corresponding to the Unit 1 portion of the limit. The setpoint shall be set at or below 1.71E-3 &#xb5;Ci/cc. NOTE: This setpoint is the basis for emergency classification in Unit 1 EAL Table (OA-1 and OU-1). A change to this setpoint would require a concurrent change to the EAL. 2. Unit 2 Wide Range Gas Monitor (WRGM) -RM8169 The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section 11.D.1.a.
in order to satisfy Units 2 Radiological Effluent Controls IVC.2. and IVD.2.a. For releases from Unit 2 to the Millstone Stack , the allocated portion of the site instantaneous release rate limit is 72,000 &#xb5;Ci/sec. This assumes that 13% of the site limit is assigned to Unit 2 releases to the Millstone Stack. If effluent conditions from Unit 2 releases to the Millstone Stack reach 72,000 &#xb5;Ci/sec, releases from Units 1, 2 , and 3 vents and from Unit 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section 11.D.1.a. and Section 4.2 of MP-22-REC-REF03, "REMODCM Technical Information Document," in making this determination.
The alarm setpoint shall be set at or below the monitor reading in &#xb5;Ci/cc corresponding to the Unit 2 release to the stack portion of the limit. The setpoint shall be set at or below 1.3E-2 &#xb5;Ci/cc. 3. Reserved STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 76 of 137 
: 4. Unit 3 SLCRS -HVR-RE19B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a.
in order to satisfy Unit 3 Radiological Effluent Controls VC.2. and VD.2.a. For releases from Unit 3 to the Millstone Stack, the allocated portion of the site instantaneous release rate limit is 72,000 &#xb5;Ci/sec. This assumes that 13% of the site limit is assigned to Unit 3 releases to the Millstone Stack. If effluent conditions from Unit 3 releases to the Millstone Stack reach 72,000 &#xb5;Ci/sec , releases from Units 1 and 2 vents, Unit 3 ESF vent and from Unit 2 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site dose limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , " REMODCM Technical Information Document ," in making this determination.
The alarm setpoint shall be set at or below the monitor reading in &#xb5;Ci/cc corresponding to the Unit 3 release to the stack portion of the limit. The setpoint shall be set at or below 1.16 E-2 &#xb5;Ci/cc. 5. Unit 2 Vent -Noble Gas Monitor -RM8132B The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a.
in order to satisfy the Unit 2 Radiological Effluent Controls in Sections IVC.2. and IVD.2.a. For releases from Unit 2 vent, the allocated portion of the site instantaneous release rate limit is 95,000 &#xb5;Ci/sec. This assumes that 33% of the site limit is assigned to Unit 2 vent releases. If effluent conditions from Unit 2 vent releases reach 95,000 &#xb5;Ci/sec, releases from Units 1 and 3 vents and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , " REMODCM Technical Information Document," in making this determination. The alarm setpoint shall be set at or below the monitor reading in cpm corresponding to the Unit 2 vent portion of the limit. The setpoint shall be set at or below 42,000 CPM. 6. Unit 2 Waste Gas Decay Tank Monitor RM9095 Administratively all waste gas decay tank releases are via the Millstone Stack. Unit 2 has a release rate limit to the Millstone Stack of 72,000 &#xb5;Ci/sec (see the MP-22-REC-REF03 , " REMODCM Technical Information Document," Section 4.2 for bases). STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 77 of 137 Batch releases of waste gas shall be limited to less than 10% of the Unit 2 releases to the Millstone Stack release rate limits. Therefore , the waste gas decay tank monitor setpoint should be set not to exceed 7 ,2 00 &#xb5;Ci/sec. If the setpoint exceeds 7,200 &#xb5;Ci/se c, the release shall be automatically terminated. The MP2 waste gas decay tank monitor (given &#xb5;Ci/cc per cpm) calibration curve and the tank discharge rate is used to assure that the concentration of gaseous radioactivity being released from a waste gas decay tank does not cause the setpoint of 7,200 &#xb5;Ci/sec to be exceeded.
: 7. Unit 3 Vent Noble Gas Monitor -HVR-RElOB The instantaneous release rate limit from the site shall be set in accordance with the conditions given in Section II.D.l.a.
in order to satisfy Unit 3 Radiological Effluent Controls in Sections V.C.2. and V.D.2.a. For releases from Unit 3 vent, the allocated portion of the site instantaneous release rate limit is 95,000 &#xb5;Ci/se c. This assumes that 33% of the site limit is assigned to Unit 3 vent releases.
If effluent conditions from Unit 3 vent releases reach 95,000 &#xb5;Ci/se c , releases from Units 1 and 2 vents, Unit 3 ESF vent and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , "REMO DCM Technical Information Document ," in making this determination.
The alarm setpoint shall be set at or below the monitor reading corresponding to the Unit 3 vent portion of the limit. The setpoint shall be set at or below 8.4 x 10-4 &#xb5;Ci/cc. 8. Unit 3 Engineering Safeguards Building Monitor -HVQ-RE49 For releases from Unit 3 ESF vent , the allocated portion of the site instantaneous release rate limit is 2,900 &#xb5;Ci/sec. This applies 1 % of the Unit 3 Vent release rate limit (see Section II.D.l.a.) to Unit 3 ESF vent releases. If effluent conditions from Unit 3 ESF vent releases reach 2,900 &#xb5;Ci/sec, releases from Units 1 and 2 vents, Unit 3 vent and from Units 2 and 3 releases to the Millstone Stack shall be determined to ensure that the sum of the individual noble gas release rates do not cause the site limit to be exceeded.
Use Section II.D.l.a.
and Section 4.2 of MP-22-REC-REF03 , " REMODCM Technical Information Document," in making this determination.
The Alarm setpoint shall be set at or below the value of 5.9E-4 &#xb5;Ci/cc. This setpoint assumes a monitor flow rate of 10,500 cfm. However, only 6,000 cfm is monitored.
By assuming 10,500 cfm the setpoint is conservatively low. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 78 of 137 APPENDIX II.A REMODCM METHODOLOGY CROSS-REFERENCES Radiological effluent controls (Sections III, IV, and V) identify the requirements for monitoring and limiting liquid and gaseous effluents releases from the site such the resulting dose impacts to members of the public are kept to '~ Low As Reasonably Achievable" (ALARA). The demonstration of compliance with the dose limits is by calculational models that are implemented by Section II of the REMODCM. Table App. II.A-1 provides a cross-reference guide between liquid and gaseous effluent release limits and those sections of the REMODCM, which are used to determine compliance.
It also shows the administrative Technical Specifications which r e ference the REMO DCM for operation of radioactive waste processing equipment.
This table also provides a quick outline of the applicable limits or dose objectives and the required actions if those limits are exceeded.
Details of the effluent control requirements and the implementing sections of the REMO DCM should be reviewed directly for a full explanation of the requirements.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 79 of 137 Table 11.A.-1 Millstone Effluent Requirement s and Methodology Cross Reference R a diological REMODCM Applicable Limit or E xposur e R eq uired Action Effluent Controls & Methodology Obj ect i ve Period Technical Section Specifications IV N.E.l.a Tables l.C.-2 Ten times 10CFR20App
.B , Instantaneous Restore concentration to within lim-Liquid Effluent and I.C.-3 Table 2, Column 2, & 2x10-4 its within 15 mins. Concentratio n &#xb5;Ci/mL for dissolved noble gases* IVN.E.l.b 11.C.l. :5 1.5 mrem T.B. Calendar Quar-30-day report if exceeded.
Relative Dose-L i quids :5 5 mrem Organ ter** acc u racy or conservat i sm of the ca l-11.C.l. :5 3 mrem T.B. Cale ndar Year cu l ations s h a ll be confirmed by per-:5 10 mrem Org a n fo rm a nc e of the REMP in Secti o n I. T.S. 6.16 & 6.20(Unit
: 2) I.C.2. :5 0.06 mrem T.B. Projected for 31 R et urn to operat i o n L i q u id Waste T.S. 6.14 & 6.15 (Unit 3) 11.C.2. :5 0.2 mrem Organ days (if system ueatment System Liquid Radwaste ueat-n o t in use) ment 111.D.2.a Tables I.D.-1, :5 500 mrem/yr T.B. from Instantaneous R estore release rates to within spec-IVN.D.2.a I.D.-2 , & noble gases* ifications within 15 minutes T.S. 6.20 (Un it 2) I.D-3 T.S. 6.15 (Unit 3) 11.D.l.a. :5 3000 mrem/yr skin fro m Gaseous Effluen t s D ose noble gases* R ate 11.D.l.b. :5 1500 mr em/yr orga n from particu l ates with T 112 > 8 d., 1-131 , 1-133 & tritium* 111.D.2.b 11.D.2. :5 5 mrad gamma air Ca l e ndar Quar-30-day report if exceeded IVN.D.2.bD ose Noble :5 10 mrad beta air ter** Gases :5 10 mrad gamma air Calendar Year :5 20 mrad beta air III.D.2.c 11.D.3. :,; 7 .5 mrem organ Calendar Quar-30-day report if exceeded.
R elative IVN.D.2.c ter** accuracy or conservat ism of the cal-Dose 1-131, 1-133, Par-cu l at i o n s shall be confirmed by per-ticulat es, H-3 :,; 15 mrem organ Calendar Year formance of the REMP in Section I. T.S. 5.6.4 (Un it 1) 11.D.2. > 0.02 mrad gamma a ir Projected for 31 R e turn t o operation Gaseous R ad-T.S. 6.14 (Un it 2) 11.D.4. > 0.04 mr ad bet a air D ays (if system waste Treatment System T.S 6.14 & T.S 6.15 (U3) > 0.03 mrem organ n o t in u se) Gaseous R adwaste ueatment 11.E 11.D.5. :52 5 mrem T.B.* 12 Consecutive 30-day report if Unit 1 Effluent IVIN.F :5 25 mrem organ* M o nths** Contro l 111.D.1.2 , 111.D.2.2, or Total Dose :5 75 mrem thyroid* III.D.2.3 or Units 2/3 Effluent Con-trol IVN.E.1.2, IVN.E.2.2 , or IV/ V.E.2.3 are exceeded by a factor of 2. R estore dose to pub li c t o within the app li cab l e E PA lirnit (s) or ob-tain a variance NOTE: T.B. means tota l or whole b o dy.
* Applies to the entire site (Units 1 , 2 , and 3) discharges combined.
**Cumulative dose contributions calculated once per 31 days. MP-22-REC-BAPOl STOP THINK ACT REVIEW R ev. 029 80 of 137 SECTION III. Millstone Unit 1 Radiological Effluent Controls Docket Nos. 50-245 MP-22-REC-BAP Ol STOP THINK ACT REVIEW R ev. 0 29 81 of 1 37 SECTION III. REMODCM UNIT ONE CONTROLS III.A. Introduction The purpose of this section is to provide the following for Millstone Unit One: a. the effluent radiation monitor contro ls and surveillance requirements, b. the effluent radioactivity concentration and dose controls and surveillance requirements, and c. the ba ses for the controls and surve illanc e requirements.
D efinitions of certain terms are provided as an aid for implementation of the controls and requirements.
Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions III.B. Definitions and Surveillance Requirement (SR) Applicability III.B.1 -Definitions The defined terms of this sub-section appear in capitalized type and are applicable throughout Section III. 1. ACTION -that part of a Control that prescribes remedial measures required under designated conditions.
: 2. INSTRUMENT CALIBRATION
-the adjustment, as necessary, of the instrument output such that it responds within the necessary range and accuracy to know values of the param eter that the instrument monitors.
The INSTRUMENT CALIBRATION shall encompass those components, such as sensors, displays, and trip functions, required to perform the specified safety function(s).
The INSTRUMENT CALIBRATION shall include the INSTRUMENT FUNCTIONAL TEST and may be performed by means of any series of seq u ential , overlapping, or total channel steps so that the entire channe l is calibrated.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 82 of 137 
: 3. INSTRUMENT FUNCTIONAL TEST -the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify that the instrument is FUNCTIONAL , including all components in the channel, such as alarms, interlocks, displays, and trip functions, required to perform the specified safety function(s).
For digital instruments, the computer database may be manipulated, in lieu of a signal injection, to verify operability of alarm and/or trip functions.
The INSTRUMENT FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping , or total channel steps so that the entire channel is tested. 4. CHANNEL CHECK -the qualitative determination of functionality by observation of behavior during operation.
This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.
: 5. FUNCTIONAL
-An instrument shall be FUNCTIONAL when it is capable of performing its specified functions(s).
Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).
: 6. REAL MEMBER OF THE PUBLIC -an individual, not occupationally associated with the Millstone site, who is exposed to existing dose pathways at one particular location.
This does not include employees of the utility or utilities which own a Millstone plant and utility contractors and vendors. Also excluded are persons who enter the Millstone site to service equipment or to make deliveries. This does include persons who use portions of the Millstone site for recreational, occupational, or other purposes not associated with any of the Millstone plants. 7. SITE BOUNDARY -that line beyond which the land is not owned , leased , or otherwise controlled by the licensee.
: 8. SOURCE CHECK -the qualitative assessment of channel response when the channel is exposed to radiation.
: 9. RADIOACTIVE WASTE TREATMENT SYSTEMS -Radioactive Waste Treatment Systems are those liquid, gaseous, and solid waste systems which are required to maintain control over radioactive materials in order to meet the controls set forth in this section. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 83 of 137 111.B.2 -Surveillance Requirement (SR) Applicability
: 1. SRs shall be met during specific conditions in the Applicability for individual LCOs unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in III.B.2 3. Surveillances do not have to be performed on nonfunctional equipment or variables outside specified limits. 2. The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the frequency is met. 3. If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LCO not met may be delayed from the time of discovery up to 24 hours or up to the limit of the specified frequency, whichever is less. This delay period is permitted to allow performance of the surveillance.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met and the applicable Condition(s) must be entered. The Completion Times of the Required Actions begin immediately upon expiration of the delay period. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met and the applicable Condition(s) must be entered. The Completion Times of the Required Actions begin immediately upon failure to meet the Surveillance.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 84 of 137 III.C. Radioactive Effluent Monitoring Instrumentation
: 1. Radioactive Liquid Effluent Monitoring Instrumentation CONTROLS The radioactive liquid effluent monitoring instrumentation channels shown in Table III.C.-1 shall be FUNCTIONAL with applicable alarm/trip setpo ints set to ensure that the limits of Specification III.D.l.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section IL APPLICABILITY:
As shown in Table III.C.-1 ACTION: a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, without delay suspend the release of radioactive liquid effl u ents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptab l y conservative.
: b. With th e number of channels l ess than the minimum channels FUNCTIONAL requirement, take the action shown in Table III.C.-1.
Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, exp lain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table III.C.-2.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 85 of 137 TABLE 111.C.-1 Radioactive Liquid Effluent Monitoring Instrumentation Instrument Action wh e n not functional Notes 1. Liquid Waste Effluent Monitor (RE-MG-110)
A 1 , 2 1. Whenever the pathway is being used except that outages are permitted, for a maximum of 12 hours, for the purpose of maintenance and performance of required test, checks, calibrations, or sampling.
: 2. Alarm setpoint required.
Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release: (1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C-1 and; (2) The original release rate calculations and discharge valving are independently verified by a second individual.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 86 of 137 TABLE 111.C.-2 Radioactive Liquid Effiuent Monitoring Instrumentation Surveillance Requirements Instrument Channel Source Channel Channel Check Check Calibration Functional Test 1. Liquid Waste Effl uent Monitor (RE-MG-110)
D* p T(l) Q
* D p T Q Daily Prior to each batch release Once every two years Once every 3 months During releases via this pathway and when the monitor is required FUNCT IONAL per Table 111.C.-1. The CHANNEL CHECK should be done when the discharge is in progress.
(1) Calibration shall include the use of a radioactive liquid or solid source which is traceable to an NIST source. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 87 of 137 
: 2. Radioactive Gaseous Effluent Monitoring Instrumentation CONTROLS The radioactive gaseous effluent monitoring instrumentation channels shown in Table III.C.-3 shall be FUNCTIONAL with applicable alarm setpoints set to ensure that the limits of Control III.D.2.a.
are not exceeded.
The setpoints shall be determined in accordance with methods and parameters described in Section II.F. l. APPLICABILITY:
As shown in Table III.C.-3 ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel alarm setpoint less conservative than required by the above Control, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.
: b. With the number of channels less than the minimum channels functional requirements, take the action shown in Table III.C.-3.
Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radiological Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the INSTRUMENT CHECK, INSTRUMENT CALIBRATION, INSTRUMENT FUNCTIONAL TEST, and SOURCE CHECK operations at the frequencies shown in Table III.C.-4.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 88 of 137 TABLE 111.C.-3 Radioactive Gaseous Effluent Monitoring Instrumentation Ins trum ent Ac tion w h en not functional Not es l.Spent F u e l Po ol Island Vent (a) No bl e Gas Radioactivity Monitor A 1,2 (b) Particulate Sampler B 1 (c) Ven t Flow Rate Monit or C 1 (d) Sampler Flow R ate Monitor D 1,2 2.B a l ance of Pl ant Vent (a) P a rticul a t e Sampler B 1 (b) Sampler F l ow Monitor D 1 1. Channels are FUNCT ION AL and in service on a continuous , uninterrupted basis when exhaust fans are operating , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required tests , checks , calibrations , and samp l ing associated with the instrument or any system or component which affects functioning of the instrument.
: 1. Alarm setpoint required.
ACT I ON ST A TEMENTS Action A With the number of channels FU NCTION AL less than required by the Minimum Channels FUNCTI ON AL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken daily when fuel is being moved , or during any evolution or event which would threaten fuel integrity , and these samples are analyzed for gamma radioactivity within 24 hours. Action B With the number of samplers FUNCT IO NAL le ss than required by the Minimum number FUNCT ION AL requirement , effluent releases via this path w ay may continue provided that the best efforts are made to repair the instrument and that a 24 hour duration samp l e i s collected with auxiliary sampling equipment once every se v en (7) days, or anytime s i gnificant I generation of airborne radioactivit y is expected , and analyzed for principal gamma emitters with half l i ves greater than 8 days within 48 hours after the end of the sampling period. Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. I Act i on C With the number of channels FUNCTI ON AL l ess than required by the Minimum Channels FUNCT ION AL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument.
Action D With the number of channels FU NCTION AL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once during the Chemistry compensatory sampling time period as specified in Action A or Action B. Sample flow rate need not be estimated if the auxiliary sampling equ i pment of Action B is in use. MP-22-REC-BAPOl STOP THINK ACT REVIEW R ev. 029 89 of 137 TABLE 111.C.-4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Instrument Channel Instrument Functional Source Check Calibration Test Check l.Spent Fuel Pool Island Vent (a) Noble Gas Radioactivity Monitor D(J) (b) Particulate Sampler (c) Vent Flow Rate Monitor ( d) Sampler Flow Rate Monitor 2.Balance of Plant Vent (a) Particulate Sampler (b) Sampler Flow Monitor D = Daily W = Weekly TM= Twice per month M = Monthly Q = Once every 3 months T = Once every two years NA = Not Applicable (1) RESERVED (2) RESERVED TM D D TM D Table 111.C.-4 TABLE NOTATION T(6) NA T T NA T (3) Instrument check daily only when there exist releases via this pathway. (4) RESERVED (5) RESERVED Q(7) NA NA NA NA NA (6) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to a source which is traceable to the NIST. These sources shall be in a known reproducible geometry.
(7) The INSTRUMENT FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist: 1. Instrument indicates measured levels above the alarm/trip setpoint.
: 2. Instrument indicates a downscale failure. M NA NA NA NA NA STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 90 of 137 III.D. Radioactive Effiuents Concentrations And Dose Limitations
: 1. Radioactive Liquid Effluents
: a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATIONS The concentration of radioactive material released from the site (see Figure III.D.-1) shall not exceed ten times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases , the concentration shall not exceed 2 x 10-4 &#xb5;Ci/ml total radioactivity.
APPLICABILITY:
At all times. ACTION: With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes. SURVEILLANCE REQUIREMENT Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I. The results of the radioactive analysis shall be used in accordance with the methods of Section ILE to assure that the concentrations at the point I of release are maintained within the limits of Specification III.D.1.a. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 91 of 137 
: b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATIONS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 1 released from the site (see Figure III.D.-1) shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and, b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ. APPLICABILITY:
At all times ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 92 of 137 
: 2. Radioactive Gaseous Effluents
: a. Radioactive Gaseous Effluents Dose Rate CONTROLS The dose rate, at any time, offsite (See Figure III.D.-1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values: a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and, b. The dose rate limit for Tritium and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ. APPLICABILITY:
At all times. ACTION: With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Control III.D.2.a.
within 15 minutes. SURVEILLANCE REQUIREMENT
: 1) The release rate , at any time, corresponding to the above dose rates shall be determined in accordance with the methodology of Section II. 2) The release rate, at any time shall be monitored in accordance with the requirements of Section III.C.2. 3) Sampling and analysis shall be performed in accordance with Section I to assure that the limits of Control III.D.2.a.
are met. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 93 of 137 
: b. Radioactive Gaseous Effluents Noble Gas Dose CONTROLS The air dose offsi te ( see Figure III.D. -1) due to noble gases released in gaseous effluents from Unit 1 shall be limited to the following:
: a. During any calendar quarter , to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;
: b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.
APPLICABILITY:
At all times. ACTION: With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 94 of 137 
: c. Gaseous Effluents
-Dose from Radionuclides Other than Noble Gas CONTROLS The dose to any REAL MEMBER OF THE PUBLIC from Tritium and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 1 (see Figure III.D.-1) shall be limited to the following:
: a. During any calendar quarter to less than or equal to 7.5 mrem to any organ; b. During any calendar year to less than or equal to 15 mrem to any organ. APPLICABILITY:
At all times. ACTION: With the calculated dose from the release of Tritium and radioactive materials in particulate form exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases of radioactive materials in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 95 of 137 0 Figure 111.D.-1, "Site Boundary for Liquid and Gaseous Effluents" -IOOO SC4l.(**El0tl NIAIITIC llAt STOP THINK ---ACT ./O~IIAN ~CYt! MP-22-REC-BAPOl REVIEW Rev. 029 96 of 137 III.E. Total Radiological Dose From Station Operations Controls CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to l ess than or equal to 25 mrem to the total body or any organ ( except the thyroid, which is limited to less than or equal to 75 mrem). APPLICABILITY:
At all times. ACTION: With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls III.D.l.b., III.D.2.b.
or III.D.2.c.
prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to l ess than or equal to 25 mrem to the total body or any organ ( except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are les s than the 40 CFR 190 Standard.
If the estimated doses exceed the above limits, the Special Report sha ll include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request , and a variance is granted until staff action on the request is complete.
SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 97 of 137 SECTION IV. Millstone Unit 2 Radiological Effluent Controls Docket Nos. 50-336 MP-22-REC-BAPOl STOP THINK ACT REVIEW Rev. 029 98 of 137 SECTION IV REMO DCM UNIT TWO CONTROLS IVA. Introduction The purpose of this section is to provid e the following for Millstone Unit Two: a. the effluent radiation monitor controls and surveillance requirements, b. the effluent radioactivity concentration and dose controls and surveillance requirements, and c. the bases for the controls and surveillance requirements.
Definitions of certain terms are provided as an aid for implementation of the controls and requirements.
Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions. IVB. Definitions, Applicability and Surveillance Requirements IV.:B.1 -Definitions The defined terms of this sub-section appear in capitalized type and are applicable throughout Section IV 1. ACTION -Those additional requirements specified as corollary statements to each principal control and shall be part of the control. 2. FUNCTIONAL
/ FUNCTIONALITY
-An instrument shall be FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation , controls, normal and emergency electrical power sources , or other auxiliary equipment that are required for the instrument to perform its functions are also capable of performing their related support functions.
: 3. CHANNEL CALIBRATION
-A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to know values of the parameter which the channel monitors.
The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential , overlapping, or total channel steps such that the entire channel is calibrated.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 99 of 137 
: 4. CHANNEL CHECK -A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
: 5. CHANNEL FUNCTIONAL TEST -A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify FUNCTIONALITY including alarm and/or trip functions.
For digital instruments, the computer database may be manipulated, in lieu of a signal injection , to verify functionality of alarm and/or trip functions.
: 6. SOURCE CHECK -A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.
: 7. MEMBER(S)
OF THE PUBLIC -MEMBER(S)
OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries.
This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant. The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.
: 8. MODE -Refers to Mode of Operation as defined in Safety Technical Specifications.
: 9. SITE BOUNDARY -The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.
: 10. UNRESTRICTED AREA -Any area at or beyond the site boundary to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the site boundary used for residential quarters or industrial, commercial, institutional and/or recreational purposes.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 100 of 137 
: 11. DOSE EQUIVALENT I-131 -DOSE EQUIVALENT I-131 shall be that concentration ofl-131 (&#xb5;Ci/gram) which alone would produce the same CDE-thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed under Inhalation in Federal Guidance Report No. 11 (FGR 11), "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion." Iv.B.2 -Applicability IVB.2a -LIMITING CONDITIONS FOR OPERATION
: 1. Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met. 2. Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Condition IVB.2.a(6).
If the Limiting Condition for Operation is restor e d prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.
: 3. NOTUSED. 4. NOTUSED. 5. When a system, subsystem, train, component or device is determined to be nonfunctional solely because its emergency power source is nonfunctional, or solely because its normal power source is nonfunctional, it may be considered FUNCTIONAL for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided:
(1) its corresponding normal or emergency power source is FUNCTIONAL; and (2) all of its redundant system(s), subsystem(s), train(s), component(s) and device(s) are FUNCTIONAL, or likewise satisfy the requirements of this specification.
: 6. Equipment removed from service or declared nonfunctional to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its FUNCTIONALITY or the FUNCTIONALITY of other equipment.
This is an exception to Condition IVB.2.a(2) for the system returned to service under administrative control to perform the testing required to demonstrate FUNCTIONALITY.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 101 of 137 IV.B2.b -SURVEILLANCE REQUIREMENTS
: 1. Surveillance Requirements shall be applicable during any condition specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.
: 2. Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the survei llan ce time interval.
: 3. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Condition IV.B2.b(2), shall constitute a failure to meet the FUNCTIONALITY requirements for a Limiting Condition for Operation.
The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed.
The ACTION requirements may b e delayed for up to 24 hours to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours. Surveillance Requirements do not have to be performed on nonfunctional equipment.
: 4. Entry into any specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 102 of 137 L IVC. Radioactive Effluent Monitoring Instrumentation
: 1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATIONS The radioactive liquid effluent monitoring instrumentation channels shown in Table IVC.-1 shall be FUNCTIONAL with applicable alarm/trip setpoints set to ensure that the limits of Specification IVD.l.a. are not exceeded.
The setpoints sha ll be determined in accordance with methods and parameters described in Section IL APPLICABILITY:
As shown in Table IVC.-1 ACTION: a. With a radioactive liquid effluent monitoring instrumentation channel alarm/trip setpoint less conservative than required by the above Specification, without delay s u spend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.
: b. With the number of channels l ess than the minimum channels FUNCTIONAL requirement, take the action shown in Table IVC.-1. Exert best effo rts to restore the nonfunctional monitor to FUNCTIONAL status within 30 days and, if unsuccessful, exp lain in the next Radioactive Effluent R elease Report why the nonfunctionality was not corrected in a timely manner. Releases need not b e terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrum enta tion channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C.-2. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 103 of 137 L TABLE Iv.C.-1 Radioacti ve Liquid E ffluent Monitoring In s trument a tion Instrume nt Action w h e n no t N o t es funct i o n a l l.Gross R a di oactivity M on i to r s P rov idi ng Alarm and Au t oma t ic Termi n ation O f R e l ease (a)C l ea n Li q ui d R a d waste Effl u ent Line A 1 (b)Aera t e d Li qu id R adwaste Effl u en t Line A 2 (c)St ea m G e n era tor Bl owdow n M o ni tor B 2 I ( d)Co nd e n sa t e P o li s hin g Faci li ty W as t e Ne ut Su m p E 2 2.G ross R a di oac t ivity Moni tors Pro v idin g Ala r m and No t P roviding A ut omatic Te r mi n a t i on O f Re l ease (a)R eac tor Bu i ldin g C l osed Coo lin g W a t er M o nit or C 1 3.F l ow R a t e Measure m e n ts -No Al arm Set p o in t R eq ui re m e n ts 1. 2. (a)C l ea n Liqui d R a d was t e Effl u e nt Li ne D 1 (b )Aera t e d Li qu i d R a d waste Effl u e nt Line D 1 ( c) Co nd e n sa t e P o li s hin g Faci l ity D 1 Required to be functional at all times -which means that channels shall be FUNCTIONAL and in service on a continuous , uninterrupted basis , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks , calibrations , or sampling associated with the instrument or any system or component which affects functioning of the instrumen t. Required to be functional whenever the discharge pathway is be i ng used except that outages are permitted , for a maximum of 12 hours , for the purpose of ma i ntenance and performance of required test , checks , calibrations , or sampling associated with the i nstrument or any system or component which affects functioning of the instrument.
ACTION S TATEM E NT S Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements , effluent releases may cont i nue provided that best efforts are made to repair the instrument and that prior to in i tiating a release: (1) At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C.-2 , and; (2) The original release rate calculations and discharge valving are independently verified by a second individual.
Action B W i th the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , either: STOP TH IN K ACT MP-22-REC-B APOl REVIE W R ev. 029 10 4 of 137 (1) Suspend all effluent releases via this pathway , or (2) Make best efforts to repair the instrument and obtain grab samples and analyze for gamma radioactivity as specified in Table I.C.-2; a) Once per 12 hours when the specific activity of the secondary coolant is greater than 0.01 &#xb5;C i/gm DOSE EQUIVALENT 1-131. b) Once per 24 hours when the specific activity of the secondary coolant i s less than or equal to 0.01 &#xb5;Ci/gm DOSE EQUIVALENT 1-131. Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that once per 12 hours grab samples of the service water effluent are collected and analyzed for gamma radioactivity at LLD as specified in Table I.C.-2; Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 4 hours during actual releases.
Pump performance curves may be used to estimate flow. Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements , effluent releases may continue provided that best efforts are made to repair the instrument and that prior to init i ating a release: (1) At least two independent samples are analyzed for gamma rad i oactivity as specified in Table I.C.-2 , and; (2) If one of the samples has gamma radioactivity greater than any of the LLDs in Table I.C.-2 , the original release rate calculations and discharge valving are independently verified by a second individual.
STOP THINK ACT MP-22-RE C-BAP Ol REVIEW R ev. 0 29 10 5 o f 137 TABLE IY.C.-2 Radioacti v e Liquid Effiuent Monitorin g In s trum e ntation S ur v eillance R e quirement s I n s trum e n t C h a nn el S our ce C hann e l C h a n ne l C h eck C h eck Ca lib ration F un c ti ona l Test l.Gross R a d i o act i v i ty Mo n it ors P rovi d ing Ala rm a n d A u to m a ti c Termi n a t ion O f R e l ease a. C l ea n L iqu id R a dw as t e Effl u e nt L i ne D* p R(l) Q(2) b. Aera t e d Li qu i d R a d waste E fflu e n t D* p R(l) Q (2) Line C. Stea m Ge n erato r Bl owdow n M o nit or D* M R (l) Q(2) ct.Conde n sate P o l ishi n g Facility W aste D* p R (l) Q (2) Ne ut Su mp 2.Gross R a di oact i v i ty M onitors P rovid i ng Alarm Bu t Not P rov i ding A u tomatic Termi n ation O f R e l ease a. R eac tor B u ild ing C lo sed C o o lin g D* M R(l) Q (2) Water M onitor 3.Flow R a t e M easure m e n ts a. C l ea n L i qu i d R a d was t e Effl u e nt L i ne D* N I A R Q b. Aera t e d L i q uid R a d was t e E fflu e n t D* N I A R Q Line c. Con d e n sate P o l is h i n g Facil i ty W as t e D* N I A R Q D M p
* N e u t Sum p Daily Monthly Prior to each batch release R = Once every 18 months Q = Once every 3 months N I A= Not Applicable TA BLE IY.C.-2 TABL E NOTATIO N During releases via this pathway and when the mon i tor is required FUNCTIONAL per Table IV.C. -1. The CHANNEL CHECK should be done when the discharge is in progress.
(1) Calibration shall include the use of a radioactive liquid or solid source which i s traceable to an NIST source. (2) The CHANNEL FUNCTIONAL TEST shall also demonstrate tha t control room alarm annunciation occurs if any of the following conditions exist: a) Instrument indicates measured levels above the alarm/trip setpoint.
b) Instrument indicates a downscale or circuit failure. -Automatic isolation of the discharge stream shall also be demonstrated for this case for each monitor except the reactor bui l d i ng closed cooling water monitor. STOP T HI N K AC T M P-22-REC-B APOl R E VI EW R ev. 029 106 of 137 
: 2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATIONS The radioactive gaseous effluent monitoring instrumentation channels shown in Table IV.C.-3 sha ll be FUNCTIONAL with applicable alarm setpoints set to ensure that the limits of Specifications IVD.2.a. are not exceeded. The setpoints shall be determined in accordance with methods and parameters described in Section II. APPLICABILITY:
As shown in Table IVC.-3 ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel a larm setpoint less conservative than required by the above specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel , or declare the channel nonfunctional , or change the setpoint so it is acceptably conservative.
: b. With the number of channels less than the minimum channels FUNCTIONAL requirement, take the action shown in Table IV.C.-3. Exert best efforts to restore the nonfunctional monitor to FUNCTIONAL stat us within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive gaseous effl uent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table IV.C.-4. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 107 of 137 TABLE IY.C. -3 Radioacti v e Ga s eous Effluent Monitoring In s trumentation Instru m e nt Ac t ion w h e n no t No tes fu n c ti o n a l l.MP 2 V e nt (norm a l ran ge, RM-8132 only; hi g h rang e monitor , R M-816 8, r e q u ir e m e nt s a r e in t h e TS) a. No bl e G as R a di oac ti vity Mo nit or A 1 , 3 b. Io din e S am p ler B 1 C. P ar ti c ul a t e Sam pl er B 1 d. Ve nt F lo w R ate Mon i t or C 1 e. Sa mpl e r F l ow R a t e M on i tor C 1 2.Mill s t o n e St ac k -a ppli ca bl e t o th e WR G M (R M-8 169 , norma l rang e , c h ann e l 1 , on l y; mid rang e c h a nn e l 2 and h i gh ra n g e channe l 3 re q uirements are contai n ed in T R M LC O 3.3.3.8) a. No bl e G as R adioactivity Mo nit or E 1, 3 b. Io din e S am p ler B 1 C. P ar ti c ul ate Sam pl er B 1 d. St ac k Fl o w R a t e Monit or C 1 e. S a mpl e r F lo w Rat e M o nitor C 1 3.W as t e Ga s H o l d up Sys t em a. No bl e G as Mo nit o r P rovi d i n g A ut omatic Te rmi na t io n of D 2,4 R e l ease 1 Required to be functional at all times when air is being released to the environment by the pathway being monitored.
The channel shall be FUNCTIONAL and in service on a continuous , uninterrupted basis. Outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrations , or sampling associated with the instrument or any system or component which affects functioning of the inst r ument. 2 Required to be functional during waste gas holdup system discharge. 3 Alarm setpoint with required. Automat i c i solation feature i s not required. 4 Alarm setpoint r e quired. Automatic isolation feature i s required. ACTION STATEMENTS Act i on A With the number of channels FUNCT I ONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours. If the monitor flow and readout are not adversely affected by the loss of functionality , the daily CHANNEL CHECK may be performed in lieu of the grab sample. STOP THINK ACT MP-22-REC-B AP O l REVIEW R ev. 0 29 10 8 o f 13 7 Action B With the number of samplers FUNCTIONAL less than required by the Minimum number FUNCTIONAL requirement , effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that effluent is continuously sampled with auxiliary sampling equipment and collected at least once per seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours of initiation of this action statement.
Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. Auxiliary sampling outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrations , or sampling.
Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated once per 5 hours. Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use. Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement:
Releases from the Millstone Unit 2 waste gas system may continue provided that best efforts are made to repair the instrument and that prior to initiating the release: a) At least two independent samples of the tank's contents are analyzed; and b) The original release rate calculations and discharge valve lineups are independently verified by a second individual.
Otherwise, suspend releases from the waste gas holdup system. Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , Millstone Unit 2 releases via the Millstone Stack may continue provided that best efforts are made to repair the instrument and that grab samples are taken once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours. If the monitor flow and readout are not adversely affected by the loss of functionality , the daily CHANNEL CHECK may be performed in lieu of the grab sample. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 029 109 of 137 TABLE rv.c. -4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirement s Channel Sourc e Channel Chann e l In s trum en t Check Ch e ck Ca lib ration Function a l T est l.MP 2 V e nt (normal ra n ge, RM-8132 only; high range monitor , RM-8168 , requirement s are in the TS) a. Noble Gas Radioactivity Monitor D M R(l) Q (2) b. Iodine Sampl er w NA NA NA C. P a rticulate Sampler w NA NA NA d. Vent Flow Rate Monitor D NA R Q e. Samp l e r Flow Rat e Monitor D NA R N A 2.Mill stone Stack -app li cable to th e WRGM (RM-8169 , normal rang e, channel 1 , only; mid rang e channe l 2 and hi gh range c h anne l 3 req uir ements are contained in TRM LCO 3.3.3.8) a. Noble Gas Radioactivity Mon itor D M R(l) Q(:l) b. Iodine Sampl er w NA NA NA C. Particulate Sampler w NA NA NA d. Stack Flow Rat e Monitor D NA R Q e. Sampler Flow Rat e Monitor D NA R NA 3.Wast e Gas Holdup Syst e m a. Nobl e Gas Monitor D* p R(l) Q(2) *During releases via this pathway and when the monitor is required FUNCT I ONAL per Table IV.C.-3. The CHANNEL CHECK should be performed when the discharge is in progress.
p D = w = M = Prior to discharge Daily Weekly Monthly R = Once every 18 months Q = Once every 3 months NA= Not Applicable TABLE Iv.C.-4 TABLE NOTATION (,) Calibration shall include the use of a known source whose strength is determined by a detector which has been calibrated to a source which is traceable to the NIST. These sources shall be in a known , reproducible geometry.
(2) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation*
occu r s if any of the following conditions exist: a) Instrument indicates measured levels above the alarm/trip setpoint.
b) Instrument indicates a downscale failure. * -Also demonstrate automatic isolation for the waste gas system noble gas monitor. STOP THINK ACT MP-2 2-REC-BAPOl REVIEW R ev. 029 110 of 137 IVD. Radioactive Effluents Concentrations And Dose Limitations
: 1. Radioactive Liquid Effluents
: a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATIONS The concentration ofradioactive material released from the site (see Figure IVD. -1) shall not exceed ten times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall not exceed 2 x 10-4 &#xb5;Ci/ml total radioactivity.
APPLICABILITY:
At all times. ACTION: With the concentration of radioactive material released from the site exceeding the above limits, restore the concentration to within the above limits within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I. 2) The results of the radioactive analysis shall be used in accordance with the methods of Section ILE to assure that th e concentrations at I the point of release are maintained within the limits of Specification IVD.l.a. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 111 of 137 
: b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATIONS The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 2 released from the site (see Figure IVD.-1) shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and, b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ. APPLICABILITY:
At all times. ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations.
Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in Section II at least once per 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 112 of 137 
: 2. Radioactive Gaseous Effluents
: a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS OF OPERATIONS The dose rate, at any time , offsite (see Figure IV.D.-1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values: a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and , b. The dose rate limit for Iodine-131, Iodine-133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ. APPLICABILITY:
At all times. ACTION: With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Specification IV.D.2.a.
within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) The release rate , at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established above in Specification IV.D.2.a.
The corresponding release rate shall be determined in accordance with the methodology of Section IL 2) The noble gas effluent monitors of Table IV.C.-3 shall be used to control release rates to limit offsite doses within the values established in Specification IV.D.2.a.
: 3) The release rate of Iodine-131 , Iodine-133 , tritium and for all radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program specified in Section I. The corresponding dose rate shall be determined using the methodology given in Section II. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 113 of 137 
: b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS OF OPERATIONS The air dose offsite (see Figure IVD.-1) due to noble gases released in gaseous effluents from Unit 2 shall be limited to the following:
: a. During any calendar quarter, to less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation;
: b. During any calendar year to less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.
APPLICABILITY:
At all times. ACTION: a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 114 of 137 
: c. Gaseous Effluents
-Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS OF OPERATIONS The dose to any REAL MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, Tritium, C-14, and radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents released offsite from Unit 2 (see Figure IV.D.-1) shall be limited to the following:
: a. During any calendar quarter to less than or equa l to 7.5 mrem to any organ; b. During any calendar year to less than or equal to 15 mrem to any organ. APPLICABILITY:
At all times. ACTION: a. With the calculated dose from the release of radioiodines , radioactive materials in particulate form, or radionuclides other than noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause( s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dos e Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II onc e every 31 days. 2) Relative accuracy or conservatism of the calcu lation s shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 115 of 137 Figure IY.D. -1, "Site Boundary for Liquid and Gaseous Effluents" 0 500 ,oco ... STOP THINK ACT ./O~OAN COY~ MP-22-REC-BAPOl REVIEW Rev. 029 116 of 137 IV.E. Total Radiological Dose From Station Operation CONTROLS The annual do se or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ ( except the thyroid , which is limited to less than or equal to 75 mrem). APPLICABILITY:
At all tim es. ACTION: With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls IV.D.2.a., IV.D.l.b., or IV.D.2.c.
prepare and submit a Special Report to th e Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Sit e is limited to less than or equal to 25 mrem to the total body or any organ ( except thyroid , which is limited to less than or e qual to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrat es that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effl uent pathways and direct radiation) are less than th e 40 CFR 190. If the estimated doses excee d th e above limits , the Special Report shall includ e a request for a variance in accordance with the provi s ions of 40 CFR 190. Submittal of the report is considered a tim e ly request , and a variance is granted until staff action on the requ es t is complete.
SURVEILLANCE REQUIREMENTS Cumulative dos e contributions from liquid and gaseous effluents and direct radiation from th e Millstone Site shall be det e rmin e d in accordance with Section II onc e per 31 days. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 117 of 137 SECTIONV.
Millstone Unit 3 Radiological Effluent Controls Docket Nos. 50-423 MP-22-REC-BAPOl STOP THINK ACT REVIEW Rev. 029 118 of 137 SECTION V. REMODCM UNIT THREE CONTROLS V.A. Introduction The purpose of this section is to provide th e following for Millstone Unit Three: a. the effluent radiation monitor controls and surveillance requirements, b. the effluent radioactivity concentration and dose controls and surveillance requirements , and c. the bases for the controls and surveillance requirements.
Definitions of certain terms are provided as an aid for implementation of the controls and requirements.
Some surveillance requirements refer to specific sub-sections in Sections I and II as part of their required actions. V.B. Definitions and Applicability and Surveillance Requirements V.B.1 -Definitions Th e defined terms of this sub-section appear in capitalized type and are applicable throughout Section V. 1. ACTION -ACTION shall be that part of the control which prescribes remedial measures required under designated conditions.
: 2. CHANNEL FUNCTIONAL TEST -A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify FUNCTIONALITY of alarm, interlock and/or trip functions.
For digital instruments , the computer database may be manipulated, in lieu of a signal injection , to verify functionality of alarm and/or trip functions. The CHANNEL FUNCTIONAL TEST shall include adjustments, as necessary, of the alarm, interlock and/or trip setpoints such that the setpoints are within th e required range and accuracy.
STOP THINK ACT MP-22-REC-BAPOl REVIEWRev.
029 119 of 137 
: 3. CHANNEL CALIBRATION
-A CHANNEL CALIBRATION shall be the adjustment, as necessary , of the channel such that it responds within the required range and accuracy to known values of input. The CHANNEL CALIBRATION shall encompass the entire channel including the sensors and alarm, interlock and/or trip functions and may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.
: 4. CHANNEL CHECK -A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation.
This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
: 5. DOSE EQUIVALENT I-131 -DOSE EQUIVALENT I-131 shall be that concentration of I-131 (&#xb5;Ci/gram) which alone would produce the same CDE-thyroid dose as the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed under Inhalation in Federal Guidance Report No. 11 (FGR 11), "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and Ingestion." 6. MEMBER(S)
OF THE PUBLIC -MEMBER(S)
OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the licensee, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries.
This category does include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant. The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.
: 7. MODE -Refers to Mode of Operation as defined in Safety Technical Specifications.
: 8. FUNCTIONAL
-FUNCTIONALITY
-An instrument shall be FUNCTIONAL or have FUNCTIONALITY when it is capable of performing its specified functions(s) and when all necessary attendant instrumentation, controls, electrical power, or other auxiliary equipment that are required for the instrument to perform its functions(s) are also capable of performing their related support function(s).
: 9. SITE BOUNDARY -The SITE BOUNDARY shall be that line beyond which the land is not owned, leased, or otherwise controlled by the licensee.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 120 of 137 
: 10. SOURCE CHECK -A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to radiation.
: 11. UNRESTRICTED AREA -Any area at or beyond the SITE BOUNDARY to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the SITE BOUNDARY used for residential quarters or industrial, commercial , institutional and/or recreational purposes.
V.B.2 -Applicability V.B.2.a -LIMITING CONDITIONS FOR OPERATION
: 1. Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met. 2. Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals.
If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals , completion of the ACTION requirements is not required.
V.B.2.b -SURVEILLANCE REQUIREMENTS
: 1. Surveillance Requirements shall be applicable during any condition specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.
: 2. Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance time interval.
: 3. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Condition V.B.2.b(2), shall constitute a failure to meet the FUNCTIONALITY requirements for a Limiting Condition for Operation.
The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed.
The ACTION requirements may be delayed for up to 24 hours to permit the completion of the surveillance when the allowable outage time limits of the ACTION requirements are less than 24 hours. Surveillance Requirements do not have to be performed on nonfunctional equipment.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 121 of 137 
: 4. Entry into any specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.
VC. Radioactive Effluent Monitoring Instrumentation
: 1. Radioactive Liquid Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATION The radioactive liquid effluent monitoring instrumentation channels shown in Table VC.-1 shall be FUNCTIONAL with their Alarm/Trip setpoints set to ensure that the limits of Specification VD.La are not exceeded.
The alarm/trip setpoints shall be determined in accordance with methodology and parameters as described in Section IL APPLICABILITY:
As shown in Table VC.-1 ACTION: a. With a radioactive liquid effluent monitoring instrumentation channel Alarm/Trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel nonfunctional, or change the setpoint so it is acceptably conservative.
: b. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels FUNCTIONAL, take the action shown in Table VC.-1. Exert best efforts to restore the nonfunctional instrumentation to FUNCTIONAL status within 30 days and, if unsuccessful, explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Releases need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENTS Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL OPERATIONAL TEST at the frequencies shown in Table VC.-2. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 122 of 137 TABLE V.C.-1 Radioacti v e Liquid Effluent Monitoring In s trumentation Inst rum en t Ac tion wh e n Not es no t fun c ti ona l l.R a di o acti v i ty M o n i to rs Pro v idin g Alarm a nd A u to m a ti c T e rmin a ti o n O f R e l ease a. W as t e N e ut ra li za ti o n Sump Monit or Co nd e n sate P o li s hin g D 2 Fac ility b. T urbin e Bu i ld i n g F l oor D rai n s B 1 C. L iquid W as t e M o nit or A 1 d. RES E R VE D e. Ste am G e n era t o r Bl ow d ow n Monit or B 3 2.F l ow R a t e M eas ur e m en t D evices -N o Alarm S e tp o int R e qui remen t s a. W as t e N e ut ra l iza ti o n Su m p Effl u ents C 1 b. RES E R VE D C. Li quid W as t e E fflu ent L ine C 1 d. RES E RV E D e. St e am G e n era t or Blo w d ow n E fflu ent L in e C 3 1 Req u i re d to be fu n ctional at all times -which means that channels sha l l be FUNCT I ONAL and in service on a continuous , uninterrupted basis , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks, ca l ibrations , or sampling associated w i th the instrument or any system or component which affects functioning of the instrument.
2 Required to be functional in MODEs 1 -5 , and MODE 6 when discharge pathway is being used , except that outages are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks , calibrations , or sampling associated with the i nstrument or any system or component which affects functioning of the instrument.
The monitor must be on-line with no unexpected alarms. 3 Required to be functional whenever the discharge pathway is being used , except that outages I are permitted , for a maximum of 12 hours , for the purpose of maintenance and performance of required test , checks , calibrations , or sampling assoc i ated with the instrument or any system or component which affects functioning of the instrument.
The monitor must be on-l ine with no unexpected alarms. STOP THINK AC T MP-22-REC-BAP Ol REVIEW R ev. 0 2 9 123 o f 137 TABLE V.C.-1 ACTION STATEMENTS Act i on A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements, effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that prior to initiating a release: 1. At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C-3, and; 2. The original release rate calculations and discharge line valving are independently verified by a second individual.
Action B With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided best efforts are made to repair the instrument and that grab samples are analyzed for gamma radioactivity specified in Table I.C. -3: 1. At least once per 12 hours when the specific activity of the secondary coolant is greater than 0.01 &#xb5;Ci/gram DOSE EQUIVALENT 1-131 , or 2. At least once per 24 hours when the specific activity of the secondary coolant is less than or equal to 0.01 &#xb5;Ci/gram DOSE EQUIVALENT 1-131. Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 4 hours during actual releases. Pump performance cuNes may be used to estimate flow. Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirements , effluent releases may continue provided that best efforts are made to repair the instrument and that prior to initiating a release: 1. At least two independent samples are analyzed for gamma radioactivity as specified in Table I.C-3 , and; 2. If one of the samples has gamma radioactivity greater than any of the lower limits of detection specified in Table I.C.-3 , the original release rate calculations and discharge valving are independently verified by a second individual.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 124 of 137 J L TABLE V.C.-2 Radioacti ve Liquid Effluent Monitoring Instrumentation S urveillance Requirement s Instrument Channel Source Channel Channel Check Check Calibration Functional Test l.Radioactivity Monitors Providing Alarm and Automatic Termination Of Release a. Waste Neutralization Sump Monitor Condensate Polishing Facility b. Turbine Building Floor Drains C. Liquid Waste Monitor d. Deleted e. Steam Generator Blowdown Monitor 2.Flow Rate Measurements
: a. Waste Neutralization Sump Effluents
: b. RESERVED c. Liquid Waste Effl u ent Line d. Deleted e. Steam Generator Bl owdown Effluent Line D M p Daily Monthly Prior to each batch release D D D D D(J) D (3) D(J) R = Q = N/A= TABLE V.C.-2 TABLE NOTATION p R(L) M R(L) p R(L) M R(L) NA R N I A R N I A R Once every 18 months Once every 3 months Not Applicable Q(l) Q(l) Q(l) Q(l) Q Q Q (1) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation occur if any of the following conditions exists: a) Instrument indicates measured levels above the alarm/trip setpoint, or b) Circuit failure (Alarm only), or Instrument indicates a downscale failure (Alarm only). (2) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION , sources that have been related to the initial calibration shall be used. (3) CHANNEL CHECK shall consist of verify i ng indication of flow during periods of release. CHANNEL CHECK shall be made at least once per 24 hours on days on which continuous , periodic, or batch releases are made. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 125 of 137 J L___ --2. Radioactive Gaseous Effluent Monitoring Instrumentation LIMITING CONDITIONS OF OPERATION The radioactive gaseous effluent monitoring instrumentation channels shown in Table V.C.-3 shall be FUNCTIONAL with their Alarm Setpoints set to ensure that the limits of Specification V.D.2.a. are not exceeded.
The Alarm Setpoints of these channels shall be determined in accordance with the methodology and parameters in Section II. APPLICABILITY:
As shown in Table V.C.-3. ACTION: a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm Setpoint less conservativ e than required by the above specification , without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel nonfunctional , or change the s e tpoint so it is acceptably conservative. b. With the number of FUNCTIONAL radioactive gaseous effluent monitoring instrumentation channels less than the Minimum Channels FUNCTIONAL, take the ACTION shown in Table V.C.-3. Exert best efforts to restore th e nonfunctional instrumentation to FUNCTIONAL status within 30 days and, if unsuccessful , explain in the next Radioactive Effluent Release Report why the nonfunctionality was not corrected in a timely manner. Release need not be terminated after 30 days provided the specified actions are continued.
SURVEILLANCE REQUIREMENT Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated FUNCTIONAL by performance of the CHANNEL CHECK, SOURCE CHECK , CHANNEL CALIBRATION , and CHANNEL FUNCTIONAL TEST at the frequencies shown in Table V.C.-4. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 126 of 137 J TABLE V.C. -3 Radioacti ve Gaseous Effluent Monitoring In st rumentation Instrument Action when Notes not functional l.Millstone Unit 3 Ventilation Vent (Turbine Building -HVR-RElOB, norma l range on ly; high range monitor, HVR-RElOA, requirements are in the TRM) a. Nob l e Gas Radioactivity Monitor P roviding Alarm A 1 ,2 b. Iodine Sampl er B 1 , 2 C. Particulate Sampler B 1 , 2 d. Vent Flow Rate Monitor C 1 , 2 e. Sampler Flow Rate Monitor C 1 2.Mill stone Stack -app l icable to SLCRS (HVR-R E19B, normal range on l y; high range monitor , HVR-RE19A, requirements are in the TRM) a. Noble Gas Radioactivity Monitor Pro vi ding Alarm b. Iodine Sampler C. Particulate Sampler d. Process Flow Rate Monit or e. Sampler Flow Rate Monitor 3.E n gineered Safeguards Building Monitor (HVQ-RE49)
: a. b. C. d. e. Noble Gas Radioactivity Monitor Iodine Sampl er Particulate Sampler Di sc h arge Flow R ate Monitor Sampler Flow Rate Monit or TABLE V.C. -3 Table Notations A 1 ,2 B 1 , 2 B 1 , 2 C 1, 2 C 1 D 1 B 1 B 1 E 1 C 1 1 Instrument required to be functional whenever the release path is in service. Outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrat i ons , or sampling associated with the instrument or any system or component which affects functioning of the instrument.
2 When the Ventilation Vent Flow Rate Monitor or Millstone Stack Process Flow Rate Monitor is nonfunctional because of degraded flow indication, the Noble Gas Monitor and Iodine and Particulate Samplers for the affected pathway (Ventilation Vent or Millstone Stack) rema i n functional as long as there is a minimum indicated process flow. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 127 of 13 7 TABLE V.C.-3 ACTION STATEMENTS Action A With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that a) best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours , OR b) if the cause of the nonfunctionality is solely due to a loss of annunciation in the control room and the Remote Indicating Controller (RIC) remains FUNCTIONAL , perform a channel check at the RIC at least once per twelve hours and verify the indication has not alarmed. Action B With the number of samplers FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that the best efforts are made to repair the instrument and that effluent is continuously sampled with auxiliary sampling equipment at least once per seven (7) days and analyzed for principal gamma emitters with half lives greater than 8 days within 48 hours after the end of the sampling period. Auxiliary sampling must be initiated within 12 hours after initiation of this ACTION statement.
Operation of the auxiliary sampling equipment shall be verified every twelve (12) hours. Auxiliary sampling outages are permitted for a maximum of 12 hours for the purpose of maintenance and performance of required tests , checks , calibrations , or sampling. Action C With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that the flow rate is estimated at least once per 5 hours. Sample flow rate need not be estimated if the auxiliary sampling equipment of Action B is in use. Action D With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument and that grab samples are taken at least once per 12 hours and these samples are analyzed for gamma radioactivity within 24 hours. Action E With the number of channels FUNCTIONAL less than required by the Minimum Channels FUNCTIONAL requirement , effluent releases via this pathway may continue provided that best efforts are made to repair the instrument.
STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 128 of 137 TABLE V.C.-4 Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements Instrum e nt Channel Sourc e-C hann e l Ch a nnel Wh e n C heck Ch e ck C alibra-Fun c tional Surveil-tion Check lan ce is R e quir e d l.Millstone Unit 3 Ventilation Vent (Turbin e Buildin g -HVR-R E lOB , normal ran ge onl y; high ra n ge monitor , HVR-R E lOA, r e quir e m e nt s ar e in th e TRM) a. Noble Gas Radioactivity Monitor D M R(l) Q(L.)
* Providing Alarm b. Iodine Sampl e r w NA NA NA
* c. Particulate Sampl e r w NA NA NA
* d. Vent Flow Rate Monitor D NA R Q
* e. Sampler Flow Rate Monitor D NA R Q
* 2.Millstone Stack -applicabl e to SLCRS (HVR-R E 19B , normal ran ge only; high r a n ge monitor , HVR-R E 19A , r e quir e m e nt s a re in th e TRM) a. Noble Gas Radioactivity Monitor D M R(3) Q(L.)
* Providing Alarm b. Iodine Sampl e r w NA NA NA
* c. Particulate Sampler w NA NA NA
* d. Process Flow Rate Monitor D NA R Q
* e. Sampler Flow Rate Monitor D NA R Q
* 3.Engineered Safeguards Building Monitor (HVQ-RE49)
* a. Noble Gas Radioactivity Monitor D M R (l) Q(2)
* Providing Alarm b. Iodine Sampler w NA NA NA
* c. Particulate Sampler w NA NA NA
* d. Discharge Flow Rate Monitor D NA R Q
* e. Sampler Flow Rate Monitor D NA R Q
* At all times except wh e n the ven t path is i s o l a t ed. D w M Da ily Wee kl y Mont h ly STOP THINK R = O n ce every 18 months Q = O n ce every 3 months N/A= N o t Applicab l e ACT MP-22-REC-BAPOl REVIEW Rev. 029 129 of 137 T ABLE V.C.-4 Table Notation s (1) The initial CHANNEL CALIBRATION shall be performed using one or more of the reference standards certified by the National Institute of Standards and Technology (NIST) or using standards that have been obtained from suppliers that participate in measurement assurance activities of NIST. These standards shall permit calibrating the system over its intended range of energy and measurement range. For subsequent CHANNEL CALIBRATION , sources that have been related to the initial calibration shall be used. (2) The CHANNEL FUNCTIO_NAL TEST shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist: a) Instrument indicates measured levels above the Alarm Setpoint , or b) Circuit failure , or c) Instrument indicates a downscale failure. (3) The CHANNEL CALIBRATION shall include the use of a known source whose strength is determined by a detector which has been calibrated to an NIST source. These sources shall be in know , reproducible geometry. STOP THINK ACT MP-22-REC-BAPOl REVIEW R ev. 0 29 130 of 137 V.D. Radioactive Effluents Concentrations And Dose Limitations
: 1. Radioactive Liquid Effluents
: a. Radioactive Liquid Effluents Concentrations LIMITING CONDITIONS OF OPERATION The concentration of radioactive material released from the site (see Figure V.D. -1) shall be limited to ten times the concentrations specified in 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than dissolved or entrained noble gases. For dissolved or e ntrained noble gases , the concentration shall not e xceed 2 x 10-4 &#xb5;Ci/ml total radioactivity.
APPLICABILITY:
At all times. ACTION: With the concentration of radioactive material released from the site exceeding the above limits , restore the concentration to within the above limits within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program specified in Section I. 2) The results of the radioactive analysis shall be used in accordance with the methods of Section ILE to assure that the concentrations at I the point of release are maintained within the limits of Specification V.D.l.a. STOP THINK ACT MP-22-REC-BAPOl REV I EW Rev. 029 131 of 137 __J 
: b. Radioactive Liquid Effluents Doses LIMITING CONDITIONS OF OPERATION The dose or dose commitment to any REAL MEMBER OF THE PUBLIC from radioactive materials in liquid effluents from Unit 3 released from the site ( see Figure VD. -1) shall be limited: a. During any calendar quarter to less than or equal to 1.5 mrem to the total body and to less than or equal to 5 mrem to any organ; and, b. During any calendar year to less than or equal to 3 mrem to the total body and to less than or equal to 10 mrem to any organ. APPLICABILITY:
At all times. ACTION: a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive materials in liquid effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations.
Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in Section II at least once per 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP TH I NK ACT MP-22-REC-BAPOl RE VI EW Rev. 029 132 of 137 ---'
L 2. Radioactive Gaseous Effluents
: a. Radioactive Gaseous Effluents Dose Rate LIMITING CONDITIONS OF OPERATION The dose rate, at any time, offsite (see Figure V.D.-1) due to radioactivity released in gaseous effluents from the site shall be limited to the following values: a. The dose rate limit for noble gases shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin; and , b. The dose rate limit due to inhalation for Iodine-131 , Iodine-133, Tritium, and for all radioactive materials in particulate form with half lives greater than 8 days shall be less than or equal to 1500 mrem/yr to any organ. APPLICABILITY:
At all times. ACTION: With the dose rate(s) exceeding the above limits, decrease the release rate to comply with the limit(s) given in Specification V.D.2.a. within 15 minutes. SURVEILLANCE REQUIREMENTS
: 1) The release rate, at any time, of noble gases in gaseous effluents shall be controlled by the offsite dose rate as established in Specification V.D.2.a. The corresponding release rate shall be determined in accordance with the methodology of Section IL 2) The noble gas effluent monitors of TableV.C.-3 shall be used to control release rates to limit offsite doses within the values established in Specification V.D.2.a. 3) The release rate of Iodine-131 , Iodine-133 , tritium, and for all radioactive materials in particulate form with half lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples and performing analyses in accordance with the sampling and analysis program, specified in Section L The corresponding dose rate shall be determined using the methodology given in Section IL STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 133 of 137 
: b. Radioactive Gaseous Effluents Noble Gas Dose LIMITING CONDITIONS OF OPERATION The air dose offsite (see Figure VD.-1) due to noble gases released from Unit 3 in gaseous effluents shall be limited to the following:
: a. During any calendar quarter: Less than or equal to 5 mrad for gamma radiation and less than or equal to 10 mrad for beta radiation, and b. During any calendar year: Less than or equal to 10 mrad for gamma radiation and less than or equal to 20 mrad for beta radiation.
APPLICABILITY:
At all times. ACTION: a. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit(s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 134 of 137 
: c. Gaseous Effluents
-Doses from Radionuclides Other than Noble Gas LIMITING CONDITIONS OF OPERATION The dose to any REAL MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, Tritium, C-14, and radioactive materials in particulate form with half l ives greater than 8 days in gaseous effluents released offsite from Unit 3 released offsite (see Figure VD.-1) shall be limited to the following:
: a. During any calendar quarter: Less than or equal to 7 .5 mrem to any organ and, b. During any calendar year: Less than or equal to 15 mrem to any organ. APPLICABILITY:
At all times. ACTION: c. With the calculated dose from the release of radioiodines, radioactive materials in particulate form, or radionuclides other than noble gases in gaseous effluents exceeding any of the above limits prepare and submit to the Commission within 30 days a Special Report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limit. SURVEILLANCE REQUIREMENTS
: 1) Dose Calculations
-Cumulative dose contributions for the current calendar quarter and current calendar year shall be determined in accordance with Section II once every 31 days. 2) Relative accuracy or conservatism of the calculations shall be confirmed by performance of the Radiological Environmental Monitoring Program as detailed in Section I. STOP THIN K ACT MP-22-REC-BAPOl REVIEW Rev. 029 135 of 137 L Figure V.D.-1, "Site Boundary for Liquid and Gaseous Effluents" 0 500 tO OO $1;*Ll-FlfET
.,. .... N,A JI TIC ., Ar' STOP THINK ACT Exe lusioh Area. ~'=~ .. Boun~o.ry
-MP-22-REC-BAPOl REVIEW Rev. 029 136 of 137 L VE. Total Radiological Dose From Station Operations CONTROLS The annual dose or dose commitment to any REAL MEMBER OF THE PUBLIC, beyond the site boundary, from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ ( except the thyroid, which is limited to less than or equal to 75 mrem). APPLICABILITY:
At all times. ACTION: With the calculated dose from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Controls VD.l.b., VD.2.b., or VD.2.c. prepare and submit a Special Report to the Commission within 30 days and limit the subsequent releases such that the dose commitment from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site is limited to less than or equal to 25 mrem to the total body or any organ ( except thyroid, which is limited to less than or equal to 75 mrem) over 12 consecutive months. This Special Report shall include an analysis which demonstrates that radiation exposures from the site to any REAL MEMBER OF THE PUBLIC from the Millstone Site (including all effluent pathways and direct radiation) are less than the 40 CFR 190 Standard.
If the estimated doses exceed the above limits, the Special Report shall include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request , and a variance is granted until staff action on the request is complete.
SURVEILLANCE REQUIREMENTS Cumulative dose contributions from liquid and gaseous effluents and direct radiation from the Millstone Site shall be determined in accordance with Section II once per 31 days. STOP THINK ACT MP-22-REC-BAPOl REVIEW Rev. 029 137 of 137}}

Latest revision as of 22:49, 5 January 2025

Annual Radioactive Effluent Release Report
ML18127A217
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 05/01/2018
From:
Dominion Energy Nuclear Connecticut
To:
Office of Nuclear Reactor Regulation
References
Download: ML18127A217 (139)
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