ML16120A352

LaSalle County, Units 1 and 2 - 2015 Annual Radioactive Effluent Release Report, Including Offsite Dose Calculation Manual, CY-LA-170-301, Revision 6. Part 3 of 9

ML16120A352
Person / Time
Site:	LaSalle
Issue date:	04/29/2016
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16120A531	List: ML16120A259 ML16120A351 ML16120A352 ML16120A357 ML16120A358 ML16120A364 ML16120A365 ML16120A385 RA16-017, 2015 Annual Radioactive Effluent Release Report, Including Offsite Dose Calculation Manual, CY-LA-170-301, Revision 6. Part 9 of 9
References
RA16-017 CY-LA-170-301, Rev. 6
Download: ML16120A352 (71)

Text

GASEOUS RELEASE TYPE A. Containment Vent and Purge System ti B. Main Vent Stack c. Standby Gas Treatment System D. Main Vent Stack And Standby Gas Treatment Systemc CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1 (Page 1of5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM TYPE OF LOWER LIMIT OF SAMPLING ANALYSIS ACTIVITY DETECTION (LLD) FREQUENCv<'>

FREQUENCv<

1> ANALYSIS (µCi/ml)a Prior to each Prior to each Principal Gamma 1x1ff 4 release Emitters 9 Each Purgeb release Grab Sample Each Purgeb H-3 1 x1 a.a 31 daysb 31 daysb Principal Gamma 1x10" 4 Grab Sample Emitters 9 7 daysb.8 7 daysb,e H*3 1x1ff 6 Grab Sample 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sc 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sc Principal Gamma 1x10"" Grab Sample Emittersg 7 daysd 1-131 1x10*12 CONTINUOUS' Charcoal 1x10" 10 Sample 1-133 CONTINUOUS' 7 daysd Principal Gamma 1x10*11 Particulate Emitters 9 (I* 131, Sample Others) 31 days CONTINUOUS' Composite Gross Alpha 1x10*11 Particulate Sample 92 days CONTINUOUS' Composite Sr-89,Sr-90 1x10*11 Particulate Sample CONTINUOUS' Noble Gas Noble Gases, Gross Beta or 1x10*6 Monitor Gamma Page 1*12.4.1-2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1 (Page 2 of 5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION 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= 4.66Sb E

• V

• 2.22xl0 6

• Y *et-Adi> Where: LLD is the "a priori" lower limit of detection as defined above (as microcurie 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 rs =-B =background sum (counts) t = count time (minutes) is the counting efficiency (as counts per transformation), V is the sample size (in units of mass or volume), 2.22x10 6 is the number of transformations per minute per microcurie, Y is the fractional radiochemical yield (when applicable), A. is the radioactive decay constant for the particular radionuclide, and 6t is the elapsed time between midpoint of sample collection and time of counting (for plant effluents, not environmental samples).

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

Typical values of E, V, Y, and 6t shall be used in the calculation.

Alternate LLD Methodology An alternate methodology for LLD determination follows and is similar to the above LLD equation:

LLD= (2.71 +4.65Ji) *Decay E

• q*b* Y *t * (2.22x10 6) Page I* 12.4.1-3 Where: CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1(Page3 of 5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION B =background sum (counts) E = counting efficiency q =sample quantity (mass or volume) b = abundance (if applicable)

Y =fractional radiochemical yield or collection efficiency (if applicable)

=count time (minutes) 2.22 x 10 6 =number of disintegrations per minute per microcurie 2.71 + 4.65"8 = k 2 + (2k .../2 "B), and k = 1.645 Decay .1t RT (k=value of the t statistic from the single-tailed t distribution at a significance level of 0.95 and infinite degrees of freedom. This means that the LLD result represents a 95% detection probability with a 5% probability of falsely concluding that the nuclide is present when it is not or that the nuclide is not present when it is.) = eu.1 [l .. RT/(1 *e*i.AT)][A Td /(1 *e*i.Td)]

if applicable

=radioactive decay constant (units consistent with .1t, AT and Td) ="delta t", or the elapsed time between sample collection or the midpoint of sample collection and the time the count is started, depending on the type of sample (units consistent with A) =elapsed real time, or the duration of the sample count (units consistent with A) = sample deposition time, or the duration of analyte collection onto the sample media (units consistent with A.) The LLD may alternately be determined using installed radioanalytical software, if available.

In addition to determining the correct number of channels over which to total the background sum, utilizing the software's ability to perform decay corrections (i.e. during sample collection, from sample collection to start of analysis, and during counting), this alternate method will result in a more accurate determination of the LLD. It should be recognized that the LLD is defined as a before the fact limit representing the capability of a measurement system and not as an after the fact limit for a particular measurement.

b. Sampling and analyses shall also be performed following shutdown, startup, or a thermal power change exceeding 20 percent of RATED THERMAL POWER in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> unless (1) analysis shows that the dose equivalent I* 131 concentration in the primary coolant has not increased more than a factor of 5, and (2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3. Page I* 12.4.1 *4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1(Page4 of 5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION c. Whenever there is flow through the SGT. If SGT is run more than 2 hrs in a 24-hour period, ensure a noble gas sample is obtained prior to securing SGT and particulate and iodine samples are taken within 24 hrs after securing SGT. A 2-hour run ensures required sample lower limits of detection are met for particulates and iodine. A SGT run of less than 2 hrs is not a significant contribution to offsite dose and requires no sampling.

d. Samples shall be changed at least once per 7 days and the analyses completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after removal from the sampler. Sampling shall also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following each shutdown, startup, or thermal power level change exceeding 20% of RATED THERMAL POWER in one hour. This requirement does not apply if 1) analysis shows that the dose equivalent 1-131 concentration in the primary coolant has not increased by more than a factor of 5, and 2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3. When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are analyzed, the corresponding LLDs may be increased by a factor of 10. e. Tritium grab samples shall be taken at least once per 7 days from the plant vent to determine tritium releases in the ventilation exhaust from the spent fuel pool area whenever spent fuel is in the spent fuel pool. If there is no spent fuel in the fuel pool, sampling and analysis of tritium grab samples shall be performed at least once per 31 days. f. The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with RECs 12.4.1, 12.4.2 and 12.4.3. g. The principal gamma emitters for which the LLD specification applies include the following radionuclides:

Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissions and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions.

This list does not mean that only these nuclides are to be detected and reported.

Other peaks that are measurable and identifiable, at the 95% confidence level, together with the above nuclides, shall also be identified and reported.

h. The drywell tritium and noble gas samples and associated purge calculations are required when the Unit is at power (i.e. critical) and for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of purging activities following shutdown.

The drywell tritium and noble gas sample results are valid for 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> from sample time if 1) the drywall radioactivity monitors have not indicated an increase in airborne or gaseous radioactivity, and 2) the drywell equipment and floor drain sump pumps run times have not indicated an increase in leakage in the drywell since the sample was taken, and 3) conditions are such that activity can be calculated for the radionuclide concentration at the time of the release. If there is any reason to suspect that gaseous radioactivity levels have changed in the drywell that would compromise the calculated, or estimated, radionuclide concentrations at the time of the release, since the last sample (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />), a new sample and analyses should be requested prior to starting a drywell purge to meet the intent of providing current analyses to reflect actual activity released to the environment.

If a known steady state leakage condition exists in the drywell it is possible to calculate a safe and accurate release package. Final release quantification will be based on calculated radionuclide concentrations at the time of the actual release. Page I* 12.4.1 *5 Table R12.4.1-1 (Page 5 of 5) CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION If the drywall is PURGED in accordance with the ODCM definition, both noble gas and tritium analyses must be completed before the purge begins. If the drywell is simply VENTING in accordance with the ODCM definition, no sample is required before venting. i. The provisions of RSA 12.0.2 and RSA 12.0.3 are applicable to the Radioactive Gaseous Waste Sampling and Analysis Program. Page 1-12.4.1-6 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.2 Dose from Noble Gases REC 12.4.2 The air dose due to noble gases in gaseous effluents released from each reactor unit from the site shall be limited to the following:

a. For gamma radiation, 5 mrad during any calendar quarter and s 1 O mrad during any calendar year; and b. For beta radiation, s 1 O mrad during any calendar quarter and s 20 mrad during any calendar year. APPLICABILITY:

At all times. ACTIONS CONDITION REQUIRED ACTION A. --------------NOTE--------------

A.1 Submit a report to the NRC, Required Action A.1 shall pursuant to 1 OCFR50 be completed if this Appendix I Section IV.A, that Condition is entered. identifies causes for exceeding limits, defines ------------------------------------

corrective actions to be Calculated air dose not taken to reduce the within limits. and proposed corrective actions to assure that subsequent releases are within limits. 8. Calculated air dose B.1 Enter Condition A of REC exceeds two times (2x) the 12.4.7. limits. SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.4.2.1 Determine cumulative dose contributions for the current calendar quarter and current calendar year in accordance with the ODCM. Page 1-12.4.2-1 COMPLETION TIME 30 days following the end of the quarter in which the release occurred Immediately FREQUENCY 31 days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.3 Dose From Iodine -131, Iodine -133, Tritium, and Radioactive Materials in Particulate Form REC 12.4.3 The dose to a MEMBER OF THE PUBLIC from iodine-131, iodine-133, tritium and all radionuclides in particulate form, with half-lives

> 8 days, in gaseous effluents released from each reactor unit, to areas at and beyond the SITE BOUNDARY shall be limited to: a. s 7.5 mrem to any organ during any calendar quarter; and b. s 15 mrem to any organ during any calendar year. APPLICABILITY:

At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. --------------NOTE--**-----------

A. 1 Submit a report to the NRC, 30 days following the Required Action A.1 shall be pursuant to 1 OCFR50 end of the quarter in completed if this Condition is Appendix I Section IV.A, which the release entered. that identifies causes for occurred exceeding limits, defines --------------------------------------

corrective actions to be Calculated dose not within taken to reduce the limits. releases, and proposed corrective actions to assure that subsequent releases are within limits. B. Calculated dose exceeds B.1 Enter Condition A of Immediately two times (2x) the limits. REC 12.4.7. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.4.3.1 Determine cumulative dose contributions for the current 31 days calendar quarter and calendar year for iodine-131 , iodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days in accordance with the methodology and parameters in the ODCM. Page 1-12.4.3-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.4 GASEOUS RADWASTE TREATMENT SYSTEM REC 12.4.4 The GASEOUS RADWASTE (OFF-GAS)

TREATMENT SYSTEM shall be OPERABLE and in operation.

APPLICABILITY:

During Main Condenser Air Ejector system operation.

ACTIONS CONDITION REQUIRED ACTION A. GASEOUS RADWASTE A.1 Restore system to TREATMENT SYSTEM OPERABLE status. inoperable.

AND OR A.2 Place system in operation.

GASEOUS RADWASTE TREATMENT SYSTEM not in operation.

B. --------------NOTE--------------

B.1 Submit a report to the NRC Required Action B.1 shall that includes defective be completed if this equipment or subsystem Condition is entered. identification and inoperability cause, actions ------------------------------------

taken to restore the Required action and inoperable equipment to Associated Completion OPERABLE status, and Time not met. summary description of actions taken to prevent a recurrence.

SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.4.4.1 Verify the GASEOUS RADWASTE TREATMENT SYSTEM is in operation.

Page 1-12.4.4-1 COMPLETION TIME 7 days 30 days FREQUENCY 7days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.5 VENTILATION EXHAUST TREATMENT SYSTEM REC 12.4.5 The appropriate portions of the VENTILATION EXHAUST TREATMENT SYSTEM shall; a. BE OPERABLE; and b. be used to reduce radioactive materials in gaseous waste prior to their discharge when the projected doses from each reactor unit from the site would exceed 0.3 mrem to any organ, when average over 31 days. APPLICABILITY:

At all times. ----------------------------------------------------------N()TE-----------------------------------------------------------

Separate Condition entry is allowed for each VENTILATION EXHAUST TREATMENT system pathway. ACTIONS CONDITION REQUIRED ACTION COMPLETl()N TIME A. One or more required A.1 Restore system to 31 days VENTILATION EXHAUST OPERABLE status. TREATMENT SYSTEMS inoperable.

B. --------------NOTE--------------

B.1 Submit a report to the NRC 30 days Required Action B.1 shall that includes inoperable be completed if this equipment or subsystem condition is entered. identification and reason for inoperability, actions ------------------------------------

taken to restore the Untreated gaseous waste inoperable equipment to release in progress.

OPERABLE status, and summary description of AND actions taken to prevent a recurrence.

Projected dose not within limits. (continued)

Page 1-12.4.5-1 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. -------------NOTE---------------

C.1 Required Action C.1 shall be completed if this Condition is entered. Submit a report to the NRC 30 days that includes inoperable Required Action and associated Completion Time of Condition A not met. SURVEILLANCE REQUIREMENTS equipment or subsystem identification and reason for inoperability, actions taken to restore the inoperable equipment to OPERABLE status, and summary description of actions taken to prevent a recurrence.

SURVEILLANCE RSR 12.4.5.1 Project doses due to gaseous releases from the site in accordance with the ODCM. RSA 12.4.5.2 ------------------------------NOTE------------------------------

Not required to be performed if the VENTILATION EXHAUST TREATMENT SYSTEM has been used to process gaseous effluents in the last 115 days. OPERATE each required VENTILATION EXHAUST TREATMENT SYSTEM equipment for at least 30 minutes. Page 1-12.4.5*2 FREQUENCY 31 days 92 days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.6 MARK II Containment REC 12.4.6 VENTING or PURGING of the containment drywall shall be: a. through the Primary Containment Vent and Purge System, or b. through the Standby Gas Treatment (SGT) System. APPLICABILITY:

During drywall VENTING or PURGING. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A., Above requirements not met. A.1 Suspend all drywell Immediately VENTING and PURGING. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.4.6.1 Verify containment drywall is aligned for VENTING or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> PURGING through the Primary Containment Vent and Purge System or the SGT System. RS A 12 .4. 6.2 ---------------------------------NOTE--------------------------------

Only required to be met when in MODES 1, 2, or 3. Verify: a. Both SGT trains are OPERABLE, and b. Only one of the SGT System trains to be used for PURGING. Page 1-12.4.6-1 Prior to PURGING through the SGT System.

CY*LA-170-301 Revision 6 Part 1, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.7Total Dose REC 12.4.7 The dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and radiation from all uranium fuel cycle sources over 12 consecutive months shall be limited to: a. s 25 mrem to the total body; and b. s 75 mrem to the thyroid; and c. s 25 mrem to any other organ. APPLICABILITY:

At all times. ACTIONS CONDITION A. --------------NOTE---------------

Required Action A.1 and A.2 shall be completed if this Condition is entered. As required by Required Action B.1 of REC 12.3.2, 12.4.2, or 12.4.3. Calculated Total Dose not within limits. REQUIRED ACTION A.1 Submit a report to the NRC (Director, Nuclear Reactor Regulation) that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the limits to include estimates of radiation exposure to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for a 12 consecutive month period that includes the release(s) covered by this report. Page 1-12.4.7-1 COMPLETION TIME 30 days (continued)

ACTIONS CONDITION A. (continued)

SURVEILLANCE REQUIREMENTS CY *LA-170-301 Revision 6 Part I, Radiological Ettluent Controls REQUIRED ACTION --------------NOl"E---------------

Only applicable if the release condition resulting in violation of 40 CFR 190 has not been corrected.

COMPLETION TIME Submit a request for a 30 days variance in accordance with 40 CFR 190, including the specified information of 40 CFR 190.11 . SURVEILLANCE FREQUENCY RSA 12.4. 7 .1 Determine cumulative dose contributions from direct radiation and liquid and gaseous effluents in accordance with the ODCM. Page 1*12.4.7*2 31 days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.8 Main Condenser REC 12.4.8 The release rate of the sum of the activities from the noble gases measured prior to the holdup line shall be limited to 3.4 x 10 5 µCi/sec after 30 minutes decay. APPLICABILITY:

MODE 1, MODES 2 and 3 with any steam line not isolated and steam jet air ejectors (SJAE) in operation.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Release rate of the sum of A.1 Restore the release rate to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the activities from noble within limit. gases prior to the holdup line not within the limits. B. Required Action and B.1 Isolate all main steam 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion lines. Time not met. OR B.2 Isolate the SJAE. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR B.3.1 MODE3 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND B.3.2 MODE 4 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Page 1-12.4.8-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.4.8.1 Monitor the noble gas radioactivity rate prior to the holdup line in accordance with the ODCM and Table R12.2.2-1 RSA 12.4.8.2 -----------------------------NOTE------------------------------------

Not required to be performed until 31 days after any Main Steam line not isolated and SJAE in operation.

Verify the release rate of the sum of the activities from noble gases prior to the holdup line is within limits by performing an isotopic analysis of a representative sample of gases taken prior to the holdup line. Page 1-12.4.8-2 FREQUENCY CONTINUOUSLY Once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after a increase in the nominal steady state fission gas release from the primary coolant, as indicated by the off gas treatment Noble Gas Activity Monitor, after factoring out increases due to changes in THERMAL POWER level 31 days CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.9 Dose Limits for MEMBERS OF THE PUBLIC REC 12.4.9 Operations shall be conducted such that: a. Total Effective Dose Equivalent (TEDE) to individual MEMBERS OF THE PUBLIC does not exceed 100 mrem/year; and b. The dose in any unrestricted area from external sources does not exceed 2 mrem in any one hour. APPLICABILITY:

At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. --------------NOTE---------------

A.1 Submit a report to the NRC 30 days Required Action A.1 shall be in accordance with completed if this Condition is 10 CFR 20.2203. entered. -------------------------------------

Dose limit of REC Item a. exceeded.

B. --------------NOl"E------*-***----

B.1 Submit a report to the NRC 30 days Required Action B.1 shall be in accordance with completed if this Condition is 10 CFR 20.2203. entered. -------------------------------------

Dose limit of REC Item b. exceeded.

Page 1*12.4.9-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls FREQUENCY RSA 12.4.9.1 Calculate the TEDE to individual MEMBERS OF THE PUBLIC in accordance with the ODCM. 12 months RSA 12.4.9.2 Determine and/or evaluate direct radiation exposures in unrestricted areas. Page 1-12.4.9*2 12 months CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.1 Radiological Environmental Monitoring Program (REMP) REC 12.5.1 The REMP shall be conducted as specified in Table R12.5.1-1.

APPLICABILITY:

At all times. ACTIONS CONDITION A. --------------NOT'E--------------

Required Action A.2 shall be completed if this Condition is entered. Sample type or location(s) required by Table R12.5.1-1 permanently unavailable.

REQUIRED ACTION A.1 Initiate action to identify suitable, alternative sampling media and/or specific locations for obtaining replacement samples for the pathway of interest and add them to the REMP. Delete locations from which samples are unavailable.

A.2 Prepare and submit a controlled version of the ODCM, in the next Annual Radiological Environmental Operating Report (REOR) including revised figures and tables reflecting the new location(s) with supporting information identifying the sample unavailability cause and justification of the new sampling location(s).

Page 1-12.5.1-1 COMPLETION TIME Immediately In accordance with Technical Specification 5.6.2 (continued)

ACTIONS CONDITION

8. -------------NOTE--------------

Required Action B.1 shall be completed if this Condition is entered. ------------------------------------

Level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeds the reporting levels of Table R12.5.1-2 when averaged over any calendar quarter. c. -------------NOTE--------------

Required Action C.1 shall be completed if this Condition is entered. ------------------------------------

More than one radionuclide in Table R12.5.1-2 detected in the sampling medium. AND C1 C2 --+--+ ... 2: 1.0 RL1 RL2 where; C = concentration RL = reporting level. 8.1 C.1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION COMPLETION TIME Submit a report to the NRC 30 days that identifies the cause(s) for exceeding the limits and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year reporting level of REC 12.3.2, 12.4.2 or 12.4.3. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report. Submit a report to the NRC 30 days that identifies the cause(s) for exceeding the limits and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year reporting level of REC 12.3.2, 12.4.2 or 12.4.3. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report. (continued)

Page 1-12.5.1-2 ACTIONS CONDITION CJ. *------------NOTE--------------

Required Action D.1 and D.2 shall be completed if this Condition is entered. Radionuclides other than those in Table R12.5.1-2 are detected.

AND The potential annual dose to a MEMBER OF THE PUBLIC from all radionuclides is greater than or equal to the calendar year limits of REC 12.3.2, 12.4.2, or 12.4.3. CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION D. 1 -----------------NOTE---------------

Only required when the measured levels of radioactivity are the result of plant effluents.

COMPLETION TIME Submit a report to the NRC 30 days that identifies the cause(s) for exceeding the limits and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year reporting level. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report. D.2 -----------------NOTE;---------------

Only required when the radionuclides detected are not the result of plant effluents.

Describe the condition in the next Annual REOR. Page I* 12.5.1 *3 In accordance with Technical Specification 5.6.2. (continued)

ACTIONS CONDITION E. -----------NOTE----------

E.1 Required Action E.1 shall be completed if this Condition is entered. RSA 12.5.1.1 not met. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REQUIRED COMPENSATORY MEASURE Prepare and submit to the NRC, in the next Annual REOR, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

Page 1-12.5.1-4 COMPLETION TIME In accordance with Technical Specification 5.6.2.

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.5.1.1 --*****-******-------*-------**-NOTES-*-------*--*--*-**-*---------1 . Deviations to the sampling schedule for the following reasons may occur and the RSA still be considered met provided the deviations are described in the next Annual REOR: a. specimens are unobtainable due to hazardous conditions, seasonal unavailability, or malfunction of sampling equipment, or b. a person or business who participates in the program goes out of business or can no longer provide samples, or c. a contractor omission which is corrected as soon as discovered.

2. Malfunctioning equipment shall be corrected/replaced and replacement suppliers shall be found, as applicable, as soon as practicable.

Collect and analyze samples in accordance with Table R12.5.1-1 and the ODCM to the detection capabilities required by Table R12.5.1-3.

Page 1*12.5.1 *5 FREQUENCY In accordance with the Radiological Environmental Monitoring Program EXPOSURE PATHWAY AND/ OR SAMPLE 1. Airborne Radioiodine and Particulates Table R12.5.1-1 (Page 1 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION SAMPLE LOCATIONS 11> FREQUENCY 111> Samples from a total of eight locations:

CONTINUOUS sampler operation with particulate sample a. Indicator-Near Field collection once per 7 days , or more frequently if required due Four samples from locations within 4.0 km (2.5 mi) in to dust loading, and radioiodine different sectors. canister collection once per 14 days. b. Indicator-Far Field Four additional locations within 4.0 to 10 km (2.5 to 6.2 mi} in different sectors. c. Control One sample from a control location within 10 to 30 km (6.2 to 18.6 mi). Page 1-12.5.1-6 . ---**. --* -------CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls TYPE AND FREQUENCY OF ANAL YSIS 111> Radioiodine Canister:

1-131 analysis once per 14 days on near field samples and contro1<2> samples. Particulate Sam12ler:

Gross beta analysis following once per 7 day filter change<3 l and gamma isotopic analysis<4 l once per 92 days on composite filters by location on near field and samples. (continued)

EXPOSURE PATHWAY AND/ OR SAMPLE 2. Direct Radiation':.'

Table A12.5.1-1(Page2 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION SAMPLE LOCATIONS 11> FREQUENCY 111> Forty routine monitoring stations, either with a Field 92 days Dosimeter or with one instrument for measuring dose rate continuously, placed as follows: a. Indicator-Inner Ring (100 Series) One in each meteorological sector, in the general area of the SITE BOUNDARY (within 0.1 to 2.0 miles; 0.2 to 3.2 km}; b. Indicator-Outer Ring (200 Series} One in each meteorological sector, within 4.8 to 10 km (3 to 6.2 mi); c. Other One at each Airborne location given in part 1.a. and 1.b. The balance of the Field Dosimeters to be placed at special interest locations beyond the Restricted Area where either a MEMBER OF THE PUBLIC or Exelon Nuclear employees have routine access. d. Control One at each airborne control location given in part 1.c. Page 1-12.5.1-7 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls TYPE AND FREQUENCY OF ANAL YSIS 111> Gamma dose on each Field Dosimeters once per 92 days. (continued)

EXPOSURE PATHWAY AND/ OR SAMPLE 3. Waterborne

a. Ground/Well

b. Drinking"'

c. Surface Water 111 d. Control Sample

e. Sediment a. a. a. CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.5.1-1 (Page 3 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION TYPE AND FREQUENCY SAMPLE LOCATIONs<

1> FREQUENcv<

11> OF ANAL vs1s 111> Indicator 92 days Gamma isotopic 1" 1 and tritium analysis once per 92 Samples from two sources only if likely to be affected.<

61 days. Indicator Grab samples once per 7 days. Gross beta and gamma isotopic analyses 14' on once One Sample from each community drinking water per 31 day composite; supply that could be affected by the station discharge tritium analysis on once per within 10 km (6.2 mi) downstream of discharge.

92 day comoosite.

1-131 on each composite when calculated dose for water consumption

> 1 mrem/year.

If no community water supply (Drinking Water) exists Grab samples once per 7 days. Gross beta and gamma within 10 km downstream of discharge then surface isotopic analyses<4> on once water sampling shall be performed.

per 31 day composite; tritium analysis on once per Indicator 92 day composite.

One sample downstream

a. Control Grab samples once per 7 days. Gross beta and gamma isotopic analyses 141 on once One surface sample upstream of discharge.

per 31 day composite; tritium analysis on once per 92 day composite.

a. Indicator 184 days Gamma isotopic analysis 1" 1 At least one sample from downstream 17' area within 1 O once per 184 days. km (6.2 mi). (continued)

Page 1-12.5.1-8 EXPOSURE PATHWAY AND/ OR SAMPLE 4. Ingestion

a. Milk(B) b. Fish c. Food Products a. Table R12.5.1-1 (Page 4 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION SAMPLE LOCATIONSm FREQUENCY 1111 Indicator Once per 14 days when animals Samples from milking animals from a maximum of are on pasture (May through October), once per 31 days at three locations within 10 km (6.2 mi) distance.

other times (November through b. Control April). One sample from milking animals at a control location within 10 to 30 km (6.2 to 18.6 mi). a. Indicator Twice per 12 months. Representative samples of commercially and recreationally important species in discharge area, and representative samples from the LaSalle Lake. b. Control Representative samples of commercially and recreationally important species in control locations upstream of discharge.

a. Indicator 12 months Two representative samples from the principal food pathways grown in each of four major quadrants within 10 km {6.2 mi), if available:

At least one root vegetable sample 1'01 At least one broad leaf vegetable (or vegetation

)<101 b. Control Two representative samples similar to indicator samples grown within 15 to 30 km (9.3 to 18.6 mi). Page 1-12.5.1 *9 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls TYPE AND FREQUENCY OF ANALYSIS 1111 Gamma isotopic'"'

and 1-131 191 analysis on each sample. Gamma isotopic analysis'"'

on edible portions Gamma isotopic 1" 1 and 1-131 analysis on each sample.

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.5.1-1 (Page 5 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM TABLE NOTATIONS (1) Specific parameters of distance and direction from the centerline of the midpoint of the two units and additional description where pertinent, shall be provided for each and every sample location in Table R12.5.1 *1, except for vegetation. For vegetation, due to location variability year to year, the parameters of distance and direction shall be provided in the Annual Environmental Operating Report. (2) Far field samples are analyzed when the respective near field sample results are inconsistent with previous measurements and radioactivity is confirmed as having its origin in airborne effluents from the station, or at the discretion of the ODCM Specialist.

(3) Airborne particulate sample fitters shalt be analyzed for gross beta radioactivity 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples. (4) Gamma isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attributable to the effluents from the station. (5) One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation.

The 40 locations is not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations; e.g., if a station is adjacent to a lake, some sectors may be over water thereby reducing the number of dosimeters that could be placed at the indicated distances.

The frequency of analysis or readout for Field Dosimeter systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading. (6) Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

(7) The "downstream" sample shall be taken in an area beyond but near the mixing zone. The "upstream sample" shall be taken at a distance beyond significant influence of the discharge.

Upstream samples in an estuary must be taken far enough upstream to be beyond the station influence.

(8) If milking animals are not found in the designated indicator locations, or if the owners decline to participate in the REMP, all milk sampling may be discontinued.

(9) 1-131 analysis means the analytical separation and counting procedure are specific for this radionuclide.

(10) One sample shall consist of a volume/weight of sample large enough to fill contractor specified container.

(11) The provisions of RSA 12.0.2 and RSA 12.0.3 are not applicable to the REMP. Page 1-12.5.1-10 Table R12.5.1-2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES REPORTING LEVELS AIRBORNE PARTICULATE FOOD PRODUCTS ANALYSIS WATER (pCill) OR GASES (pCi/m 3) FISH (pCi/kg, wet) MILK (pCi/1) (pCi/kQ, wet) H-3 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-Nb-95 1-131 Cs-134 Cs-137 Ba-La-140 (1) (2) 20.000<1> 1,000 30,000 400 10,000 1,000 30,000 300 10,000 300 20,000 400 2(2) 0.9 3 100 30 10 1,000 60 1,000 50 20 2,000 70 2.000 200 300 For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCi/1 may be used. If no drinking water pathway exists, a value of 20 pCi/I may be used. Page 1-12.5.1-11 ANALYSIS Gross Beta H-3 Mn-54 Fe-59 Co-58,60 Zn-65 Zr-95 Nb-95 1*131 Cs-134 Cs-137 Ba-140 La-140 Table R12.5.1-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS 1 a> LOWER LIMIT OF DETECTION (LLD)lb> AIRBORNE PARTICULATE FISH FOOD PRODUCTS SEDIMENT /SOIL WATER (pCi/1) OR GASES <oCi/m 3) <oCi/ka, wet) MILK <oCi/I) (pCi/kg, wet) loCi/ka, drvl 4 0.01 2,000 15 130 30 260 15 130 30 260 30 15 1<c) 0.07 1 60 15 0.05 130 15 60 150 18 0.06 150 18 80 180 60 60 15 15 (a) All peaks identified at the 95% confidence level, shall also be analyzed and reported. (b) Most restrictive ODCM LLD requirement or technical requirement.

The reported minimum detectable concentration (MOC) shall be .5 these values. (c) If no drinking water pathway exists, a value of 15 pCi/I may be used (NUREG 1301/1302)

Page 1-12.5.1-12 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.2 Land Use Census REC 12.5.2 A Land Use Census shall be conducted and shall identify within a distance of 10 km (6.2 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence, and an enumeration of livestock.

For dose calculation, a garden will be assumed at the nearest residence.

---

NOTES-------------------------------------------------------

1 . The 16 meteorological sectors requirement may be reduced according to geographical limitations; e.g. at a lake site where some sectors will be over water. 2. The nearest industrial facility shall also be documented if closer than the nearest residence.

APPLICABILITY:

At all times. ACTIONS CONDITION A. -------------NOTE--------------

A. 1 Required Action A.1 and A.2 shall be completed if this Condition is entered. Land use census identifies AND a location which yields a calculated dose or dose commitment, via the same exposure pathway, that is at least 20% greater than at a location from which samples are currently being obtained in accordance with REC 12.5.1. REQUIRED ACTION Add the new location to the Radiological Environmental Monitoring Program (REMP). Page 1-12.5.2-1 COMPLETION TIME 30 days {continued)

ACTIONS CY*LA-170-301 Revision 6 Part I, Radiological Effluent Controls CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A .2 ---------------NOTE------------------

The sampling location(s), excluding the control location, having the lowest calculated dose or dose commitment(s), via the same exposure pathway, may be deleted from the REMP after October 31 of the year in which Land Use Census was conducted.

Submit the documentation for a change in the ODCM in the next Annual Radiological Environmental Operating Report and include the revised figures and tables for the ODCM reflecting the new location(s) with information supporting the change in . sampling locations.

SURVEILLANCE REQUIREMENTS RSA 12.5.2.1 SURVEILLANCE Conduct a land use census during the growing season, between June 1° and October 1, using information that will provide the best results, such as by a door-to-door survey, aerial survey, or by consulting local agriculture authorities.

The results of the census shall be included in the Annual Radiological Environmental Operating Report. Page 1*12.5.2*2 In accordance with Technical Specification 5.6.2. FREQUENCY RSR 12.0.2 and 12.0.3 are not applicable.

12 months CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.3 lnterlaboratory Comparison Program REC 12.5.3 Analyses shall be performed on radioactive materials supplied as part of an lnterlaboratory Comparison Program that is traceable to NIST. APPLICABILITY:

At all times. ACTIONS CONDITION A. -------------NOTE-------------

A.1 Required Action A.1 shall be completed if this Condition is entered. Requirements of the REC not met. SURVEILLANCE REQUIREMENTS REQUIRED ACTION Report corrective actions to prevent recurrence to the NRC in the next Annual Radiological Environmental Operating Report. SURVEILLANCE RSA 12.5.3 Include a summary of the results of the lnterlaboratory Comparison Program in the Annual Radiological Environmental Operating Report. Page 1-12.5.3*1 COMPLETION TIME In accordance with Technical Specification 5.6.2 FREQUENCY In accordance with Technical Specification 5.6.2 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.4 Meteorological Monitoring Program (NOT APPLICABLE)

Page 1-12.5.4*1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.1 Annual Radiological Environmental Operating Report 12.6.1.1 12.6.1.2 12.6.1.3 Routine Annual Radiological Environmental Operating Report covering the operation of the Units during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental monitoring program for the report period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual, and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.c. It should include, as found appropriate, a comparison of preoperational studies with operational controls or with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment.

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station. The Annual Radiological Environmental Operating Report shall include the results of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the tables and figures in Part II, Section 6 of the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual 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 as soon as possible in a supplementary report. The reports shall also include the following:

a summary description of the Radiological Environmental Monitoring Program; legible maps covering all sampling locations keyed to a table giving distances and directions from the midpoint between the two units; reasons for not conducting the Radiological Environmental Monitoring Program as required by REC 12.5.1, and discussion of all deviations from the sampling schedule of Table R12.5.1-1; a Table of Missed Samples and a Table of Sample Anomalies for all deviations from the sampling schedule of ODCM Part II, Table 6.1*1; discussion of environmental sample measurements that exceed the reporting levels of Table R12.5.1-2 but are not the result of plant effluents; discussion of all analyses in which the LLD required by Table R12.5.1-3 was not achievable; results of the Land Use Census required by REC 12.5.2; and the results of licensee participation in an lnterlaboratory Comparison Program and the corrective actions being taken if the specified program is not being performed as required by REC 12.5.3. (continued)

Page 1*12.6.1-1 CY -LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.1 Annual Radiological Environmental Operating Report (continued) 12.6.1.4 The Annual Radiological Environmental Operating Report shall also include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability.

In lieu of submission with the Annual Radiological Environmental Operating Report, the licensee has the option of retaining the summary of required meteorological data on site in a file that shall be provided to the NRC upon request. 12.6.1.5 The Annual Radiological Environmental Operating Report shall also include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. This report shall also include an assessment of radiation doses to the most likely exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the ODCM and in compliance with 1 O CFR 20 and 40 CFR 190,* "Environmental Radiation Protection Standards for Nuclear Power Operation." Page 1-12.6.1-2 CY-lA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.2 Annual Radioactive Effluent Release Report 12.6.2.1 12.6.2.2 12.6.2.3 The radioactive effluent release reports covering the operation of the unit during the previous calendar year of operation shall be submitted in accordance with 10 CFR 50.36a prior to May 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluent and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and the PROCESS CONTROL PROGRAM and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1. A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit. The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, "Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof. The radioactive effluent release report shall include the following information for each type of solid waste shipped offsite during the report period: 1. Container volume, 2. Total curie quantity (specify whether determined by measurement or estimate), 3. Principal radionuclides (specify whether determined by measurement or estimate), 4. Type of waste (e.g., spent resin, compacted dry waste, evaporator bottoms), 5. Type of container (e.g., LSA, Type A, Type B, Large Quantity), and 6. Solidification agent (e.g., cement, urea formaldehyde). (continued)

Page 1-12.6.2-1 CY-LA-170*301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.2 Radioactive Effluent Release Report (continued) 12.6.2.4 The radioacti_ve effluent release reports shall include unplanned releases from the site to unrestricted areas of radioactive materials in gaseous and liquid effluents on a quarterly basis. 12.6.2.5 12.6.2.6 The radioactive effluent release reports shall include any changes to the PROCESS CONTROL PROGRAM (PCP) made during the reporting period. The radioactive effluent release reports shall include a description of licensee initiated major changes to the radioactive waste treatment systems (liquid, gaseous and solid), as described in Section 12.6.3.) Page 1-12.6.2-2 CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.3 Offsite Dose Calculation Manual (ODCM) 12.6.3.1 The ODCM is common to LaSalle Unit 1 and LaSalle Unit 2. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and 12.6.3.2 12.6.3.3 The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release Reports required by Technical Specifications 5.6.2 and 5.6.3. Licensee-initiated changes to the ODCM: a. $hall be documented and records of reviews performed shall be retained as required by the Quality Assurance (QA) Manual. This documentation:

1. Shall contain sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s);

and 2. Shall contain a determination that the change(s) maintain the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and 10 CFR Part 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

3. Shall become effective after approval of the Plant Manager. 4. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

Page 1*12.6.3*1 12.6 REPORTING REQUIREMENTS CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.6.4 Major Changes to Radioactive Waste Treatment Systems (Liquid and Gaseous) 12.6.4.1 Licensee initiated major changes to the radioactive waste treatment systems (liquid and gaseous):

a. Shall be reported to the Commission in the Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the Plant Operations Review Committee (PORC). The discussion of each change shall contain: 1. A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; 2. Sufficient detailed information to totally support the reason for the change without benefit or additional or supplemental information;

3. A detailed description of the equipment, components and processes involved and the interfaces with other plant systems; 4. An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents waste that differ from those previously predicted in the license application and amendments thereto; 5. An evaluation of the change which shows the expected maximum exposures to individual in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto; 6. A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents, to the actual releases for the period to when the changes are to be made; 7. An estimate of the exposure to plant operating personnel as a result of the change; and 8. Documentation of the fact that the change was reviewed and found acceptable by the PORC. b. Shall become effective upon review and acceptance by the PORC. Page 1-12.6.4-1 BASES General CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls It is expected that releases of radioactive material in effluents will be kept at small fractions of the limits specified in Section 20.1302 of 1 O CFR, Part 20. At the same time, the licensee is permitted the flexibility of operation, compatible with consideration of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small fractions, but still within the limits specified in Section 20.1302 of 1 O CFR, Part 20. It is expected that in using this operational flexibility under unusual operating conditions the licensee will exert his best efforts to keep levels of radioactive material in effluents as low as practicable.

l-B-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.0 OFFSITE DOSE CALCULATION MANUAL (ODCM) RADIOLOGICAL EFFLUENT CONTROL (REC) APPLICABILITY BASES RE Cs REC 12.0.1 REC 12.0.2 REC 12.0.1 through REC 12.0.6 establish the general requirements applicable to all RECs in Sections 12.1through12.5 and apply at all times, unless otherwise stated. REC 12.0.1 establishes the Applicability statement within each individual REC as the requirement for when the REC is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Requirement).

REC 12.0.2 establishes that upon discovery of a failure to meet a REC, the associated ACTIONS shall be met. The Completion Time of each Required *Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of a REC are not met. This Requirement establishes that: a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a REC; and b. Completion of the Required Actions is not required when a REC is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the REC must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the REC is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)

The second type of Required (continued) 1-812.0-1 I

BASES REC 12.0.2 (continued)

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when a REC is met or is no longer applicable, unless otherwise stated in the individual RECs. The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Condition no longer exists. The individual REC's ACTIONS specify the Required Actions where this is the case. An example of this is in REC 12.4.2, "Dose from Noble Gases." The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally.

The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience.

Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a function are inoperable and limits the time conditions exist which may result in REC 12.0.3 being entered. Individual RECs may specify a time limit for performing a RSA when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another REC becomes applicable.

In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new REC becomes applicable and the ACTIONS Condition(s) are entered. (continued) 1-812.0-2 BASES (continued)

REC 12.0.3 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls REC 12.0.3 establishes the actions that must be implemented when a REC is not met and: a. An associated Required Action and Completion Time is not met and no other Condition applies; or b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering REC 12.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that REC 12.0.3 be entered immediately.

Upon entering REC 12.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to implement appropriate compensatory actions and verify the plant is not in an unanalyzed condition or that a required safety function is not compromised.

Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, Shift Operations Superintendent or designee approval of the compensatory actions and the plan for exiting REC 12.0.3 must be obtained.

The use and interpretation of specified times to complete the actions of REC 12.0.3 are cor:isistent with the discussion of Section 1.3, Completion Times. The actions required in accordance with REC 12.0.3 may be terminated and REC 12.0.3 exited if any of the following occurs: a. The REC is now met. b. A Condition exists for which the Required Actions have now been performed.

c. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time REC 12.0.3 is exited. (continued) 1-812.0-3 BASES REC 12.0.3 (continued)

REC 12.0.4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls In MODES 1, 2, and 3, REC 12.0.3 provides actions for Conditions not covered in other Requirements.

The requirements of REC 12.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition.

The requirements of REC 12.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual RECs sufficiently define the remedial measures to be taken. REC 12.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an REC is not met. It precludes placing the unit in a MODE or other specified condition stated in that Applicability (e.g., Applicability desired to be when the following exist: a. Unit conditions are such that the requirements of the REC would not be met in the Applicability desired to be entered; and b. Continued noncompliance with the REC requirements, if the Applicability were entered, would result in the unit being required to exit the Applicability desired to be entered to comply with the Required Actions. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation.

This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. The provisions of this REC should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of REC 12.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of REC 12.0.4 shall not prevent (continued) 1-812.0-4 BASES REC 12.0.4 (continued)

REC 12.0.5 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

Exceptions to REC 12.0.4 are stated in the individual RECs. The exceptions allow entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time. Exceptions may apply to all the ACTIONS or to a specific Required Action of a REC. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by RSA 12.0.1. Therefore, changing MODES or other specified conditions while in an ACTIONS Condition, either in compliance with REC 12.0.4, or where an exception to REC 12.0.4 is stated, is not a violation of RSA 12.0.1 or RSA 12.0.4 for those Surveillances that do not have to be performed due to the associated inoperable equipment.

However, RSRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected REC. REC 12.0.4 is only applicable when entering MODE 3 from MODE 4, MODE 2 from MODE 3 or 4, or MODE 1 from MODE 2. Furthermore, REC 12.0.4 is applicable when entering any other specified condition in the Applicability only while operating in MODE 1, 2, or 3. The requirements of REC 12.0.4 do not apply in MODES 4 and 5, or in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Requirements sufficiently define the remedial measures to be taken. REC 12.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed f ram service or declared inoperable to comply with ACTIONS. The sole purpose of this Requirement is to provide an exception to REC 12.0.2 (e.g., to not comply with the applicable Required Action(s))

to allow the performance of required testing to demonstrate:

a. OPERABILITY of the equipment being returned to service; or (continued) 1-812.0-5 BASES REC 12.0.5 (continued)

REC 12.0.6 b. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY.

This Requirement does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system. REC 12.0.6 establishes the applicability of each REC to both Unit 1 and Unit 2 operation.

Whenever a requirement applies to only one unit, or is different for each unit, this will be identified in the appropriate section of the REC (e.g., Applicability, RSR, etc.) with parenthetical reference, Notes, or other appropriate presentation within the body of the requirement.

1-812.0-6 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.0 ODCM RADIOLOGICAL SURVEILLANCE REQUIREMENT

{RSA) APPLICABILITY BASES RS Rs RSA 12.0.1 RSR 12.0.1 through RSA 12.0.5 establish the general requirements applicable to all Requirements in 12.1 through 12.5 and apply at all times, unless otherwise stated. RSA 12.0.1 establishes the requirement that RSRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the REC apply, unless otherwise specified in the individual RSRs. This REC is to ensure that RS Rs are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a RSA within the specified Frequency, in accordance with RSA 12.0.2, constitutes a failure to meet a REC. Systems and components are assumed to be OPERABLE when the associated RSRs have been met. Nothing in this RSA, however, is to be construed as implying that systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the RSRs; or b. The requirements of the RSR{s) are known to be not met between required RSA performances.

RSA do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated REC are not applicable, unless otherwise specified.

Unplanned events may satisfy the requirements

{including applicable acceptance criteria) for a given RSA. In this case, the unplanned event may be credited as fulfilling the performance of the RSA. (continued) 1-812.0-7 BASES RSA 12.0.1 (continued)

RSA 12.0.2 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls RSRs, including RSRs invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. RSRs have to be met and performed in accordance with RSA 12.0.2, prior to returning equipment to OPERABLE status. Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE.

This includes ensuring applicable RSRs are not failed and their most recent performance is in accordance with RSA 12.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established.

In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.

This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

RSA 12.0.2 establishes the requirements for meeting the specified Frequency for RSRs and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per ... " interval.

RSA 12.0.2 permits a 25% extension of the interval specified in the Frequency.

This extension facilitates RSA scheduling and considers plant operating conditions that may not be suitable for conducting the RSA (e.g., transient conditions or other ongoing RSA or maintenance activities).

The 25% extension does not significantly degrade the reliability that results f rem performing the RSA at its specified Frequency.

This is based on the recognition that the most probable result of any particular RSA being performed is the verification of conformance with the RSRs. As stated in RSA 12.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ...

• basis. The 25% extension applies to each performance after the initial performance.

The initial performance of the Required Action, (continued) 1-812.0-8 BASES RSR 12.0.2 (continued)

RSR 12.0.3 CY-LA* 170-301 Revision 6 Part I, Radiological Effluent Controls whether it is a particular RSR or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner. The provisions of RSR 12.0.2 are not intended to be used repeatedly merely as an operational convenience to extend RSR intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

RSR 12.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a RSR has not been completed within the specified Frequency.

A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time it is discovered that the RSR has not been performed in accordance with RSR 12.0.2, and not at the time that the specified Frequency was not met. This delay period provides adequate time to complete RSRs that have been missed. This delay period permits the completion of a RSR before complying with Required Actions or other r'emedial measures that might preclude completion of the RSR. The basis for this delay period includes consideration of unit conditions, adequate plann!ng, availability of personnel, the time required to perform the RSA, the safety significance of the delay in completing the required RSA, and the recognition that the most probable result of any particular RSA being performed is the verification of conformance with the requirements.

When a RSA with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to each release, or in accordance with the Radioactive Liquid Waste Sampling and Analysis Program, etc.) is discovered to not have been (continued) 1-812.0-9 BASES RSA 12.0.3 (continued)

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls performed when specified, RSA 12.0.3 allows for the full delay period of up to the specified Frequency to perform the RSA. However, since there is not a time interval specified, the missed RSA should be performed at the first reasonable opportunity.

RSA 12.0.3 provides a time limit for, and allowances for the performance of, RSRs that become applicable

• as a consequence of MODE changes imposed by Required Actions. Failure to comply with specified Frequencies for RSRs is expected to be an infrequent occurrence.

Use of the delay period established by RSA 12.0.3 is a flexibility which is not intended to be used as an operational convenience to extend RSR intervals.

While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed RSA, it is expected that the missed RSR will be performed at the first reasonable opportunity.

The determination of the first reasonable opportunity should include consideration of the.impact on plant risk (from delaying the RSA as well as any plant configuration changes required or shutting the plant down to perform the RSA) and impact on any analysis assumptions, in addition to unit conditions, planning, availability*of personnel, and the time required to perform the RSR. This risk impact should be managed through the program in to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown.

The missed RSR should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component.

Missed RSRs for important components should be analyzed quantitatively.

If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed RSRs will be placed in the station's Corrective Action Program. (continued) 1-812.0-10 BASES RSA 12.0.3 (continued)

RSA 12.0.4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls If a RSA is not completed within the allowed delay period, then the equipment is considered inoperable or the variable then is considered outside the specified limits and the Completion Times of the Required Actions for the applicable REC Conditions begin immediately upon expiration of the delay period. If a RSA is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable REC Conditions begin immediately upon the failure of the RSA. Completion of the RSA within the delay period allowed by this RSA, or within the Completion Time of the ACTIONS, restores compliance with RSA 12.0.1. RSA 12.0.4 establishes the requirement that all applicable RSRs must be met before entry into a MODE or other specified condition in the Applicability.

This RSA ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this RSA should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

However, in certain circumstances, failing to meet a RSA will not result in RSA 12.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated RSR(s) are not required to be performed per RSA 12.0.1 which states that RSRs do not have to be performed on inoperable equipment.

When equipment is inoperable, RSA 12.0.4 does not apply to the associated RSR(s) since the requirement for the RSR(s) to be performed is removed. Therefore, failing to perform the RSRs within the specified Frequency, on equipment that is inoperable, does not result in a RSA 12.0.4 restriction to changing MODES or other specified conditions of the Applicability.

However, since the REC is not met in this instance, REC 12.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. {continued) 1-812.0-11 BASES RSA 12.0.4 (continued)

RSA 12.0.5 CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls The provisions of RSA 12.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of RSA 12.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

The precise requirements for performance of RSRs are specified such that exceptions to ASA 12.0.4 are not necessary.

The specific time frames and conditions necessary for meeting the RSRs are specified in the Frequency, in the RSA, or both. This allows performance of RSRs when the prerequisite condition(s}

specified in a RSR procedure require entry into the MODE or other specified condition in the Applicability of the associated REC prior to the performance or completion of a RSA. A RSA that could not be performed until after entering the REC Applicability would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the RSA may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of RSRs' annotation is found in Section 1.4, Frequency.

RSA 12.0.4 is only applicable when entering MODE 3 from MODE 4, MODE 2 from MODE 3 or 4, or MODE 1 from MODE 2. Furthermore, RSA 12.0.4 is applicable when entering any other specified condition in the Applicability only while operating in MODE 1, 2, or 3. The requirements of RSA 12.0.4 do not apply in MODES 4 and 5, or in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Controls sufficiently define the remedial measures to be taken. RSA 12.0.5 establishes the applicability of each RSA to both Unit 1 and Unit 2 operation.

Whenever a requirement applies to only one unit, or is different for each unit, this will be identified with parenthetical reference, Notes, or other appropriate presentation within the RSA. 1*812.0-12 B 12.1 NOT USED CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls INTENTIONALLY BLANK 1-812.1*1 B 12.21NSTRUMENTATION CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.2.1 Radioactive Liquid Effluent Monitoring Instrumentation BASES The radioactive liquid effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents.

The alarm/trip setpoints for these instruments shall be calculated in accordance with the procedures in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of RECS. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. 1-812.2.1-1 B 12.21NSTRUMENTATION CY-LA-170-301 . Revision 6 Part I, Radiological Effluent Controls B 12.2.2 Radioactive Gaseous Effluent Monitoring Instrumentation BASES The radioactive gaseous effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents.

The alarm/trip setpoints for these instruments shall be calculated in accordance with the procedures in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of RECS. 1-B 12.2.2-1 8 12.3LIQUID EFFLUENTS 8 12.3.1 Liquid Effluent Concentration BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site will be less than ten (10) times the concentration levels specified in Appendix 8, Table 2, Column 2 to 1 O CFR 20.1001-2402.

This limitation provides additional assurance that the levels of radioactive materials in bodies of water outside the site will result in exposure within ( 1) the Section II.A design objectives of Appendix I, 10 CFR 50, to an individual, and (2) the limits of 1 O CFR 20.1301 to the population.

In addition, this limit is associated with 40 CFR 14 which states concentration limits at the nearest downstream potable water supply. The results of the analyses of RSA 12.3.1.1, 12.3.1.2, and 12.3.1.3 shall be used with the calculational methods in the ODCM to assure that the concentrations at the point of release are maintained within the limits of this REC. Refer to Technical Specification 5.5.9.b for the definition of an outside temporary tank. 1-812.3.1-1 B.12.3 LIQUID EFFLUENTS B 12.3.2 Dose From Liquid Effluents BASES CY*LA-170*301 Revision 6 Part I, Radiological Effluent Controls This control is provided to implement the requirements of Sections II.A, Ill.A and IV.A of Appendix I, 10 CFR Part 50. The REC implements the guides set forth in Section II.A of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable." Also, for fresh water sites with drinking water supplies which can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR 141. The dose calculations in the ODCM implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated.

The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. This control applies to the release of radioactive materials in liquid effluents from each reactor at the site. For units with shared radwaste treatment systems, the liquid effluents from the shared systems are proportioned among the units sharing that system. 1-612.3.2*1 B 12.3LIQUID EFFLUENTS B 12.3.3 Liquid Radwaste Treatment Systems BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The OPERABILITY of the liquid radwaste treatment system ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment.

The requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." A system bypass allows connection to portable waste treatment equipment.

This enables the efficient processing of liquid radwaste through the use of state-of-the-art radwaste processing technology.

The portable radwaste treatment system may be used in lieu of various portions of the liquid radwaste treatment system. When a portable waste treatment is not used, RSA 12.3.3.2 may be extended to 180 days. This control implements the requirements of 1 O CFR Part 50.36a. General Design Criterion 50 of Appendix A to 10 CFR Part 50 and the design objective given in Section 11.0 of Appendix I to 1 O CFR Part 50. The specified

.limits governing the use of appropriate portions of the liquid radwaste treatment system were specified as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

This specification implements Technical Specification Section 5.5.4.f for liquid effluents.

Page 1-812.3.3-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.1 Gaseous Effluent Dose Rates BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to ensure that the dose at any time at the site boundary from gaseous effluents from all units on the site will be within the annual dose limits of RECS for unrestricted areas. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual*

in an unrestricted area, either within or outside the site boundary exceeding the limits specified in 10 CFR 20.1301. For individuals who at times be within the site boundary, the occupancy of the individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the site boundary.

The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual at or beyond the site boundary to less than or equal to a dose rate of 500 mrem/year to the total body or to less than or equal to a dose rate of 3000 mrem/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background via the inhalation pathway to less than or equal to a dose rate of 1500 mrem/year.

This control applies to the *release of radioactive effluents in gaseous effluents from all reactors at the site. For units within shared radwaste treatment systems, the gaseous effluents from the shared system are proportioned among the units sharing that system. Page 1-812.4.1-1 8 12.4GASEOUS EFFLUENTS AND TOTAL DOSE 8 12.4.2 Dose from Noble Gases BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to implement the requirements of Sections 11.B, Ill.A and IV.A of Appendix I, 1 O CFR Part 50. The Operability Requirements are the guides set forth in Section 11.B of Appendix I. The ACTION statements provide the required operating and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man fror Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977 and Regulatory Guide 1.111, for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977. The ODCM equatiom provided for determining the air doses at the site boundary are based upon the historical average atmospheric conditions.

Page 1-812.4.2-1 CY-LA-170-301 . Revision 6 Part I, Radiological Effluent Controls B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.3 BASES Dose from lodine-131, lodine-133, Tritium and Radioactive Materials in Particulate Form The control is provided to implement the requirements of Sections 11.C, Ill.A and IV.A of Appendix I, 10 CFR Part 50. The operability requirements are the guides set forth in Section 11.C of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the Surveillance Requirements implement the requirements in Section lll:A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated.

The ODCM calculational methods* for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions.

The release rate specifications for radioiodines, radioactive materials in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area. The pathways which were examined in the development of these calculations were: 1 )" individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, 3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man. Page 1-812.4.3-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.4 GASEOUS RADWASTE TREATMENT (OFF-GAS)

SYSTEM BASES The OPERABILITY of the GASEOUS RADWASTE TREATMENT SYSTEM ensures that the system will be available for use whenever gaseous effluents require treatment prior to release to the environment.

The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable".

This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 1 O CFR Part 50, and the design objectives given in Section 11.0 of Appendix I to 1 O CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections 11.B and 11.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

Page 1-B 12.4.4-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.5 VENTILATION EXHAUST TREATMENT SYSTEM BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The OPERABILITY of the VENTILATION EXHAUST TREATMENT SYSTEM ensures that the system will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable".

This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 1 O CFR Part 50, and the design objectives given in Section 11.0 of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections 11.B and 11.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

This control implements Technical Specification 5.5.4.f for gaseous effluents.

Page 1-812.4.5-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.6 MARK II CONTAINMENT BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control provides reasonable assurance that releases from drywell purging operations will not exceed the annual dose limits of 1 O CFR 20 for unrestricted areas. Based on definition, VENTING would not release a volume resulting in significant contribution to gaseous plant effluents, nor resultant offsite dose. As such, there is no ODCM requirement for sampling.

Sampling is required for PURGING, however, since the entire drywall volume is potentially released.

Sampling prior to conducting a drywall PURGE provides a pre-release check to ensure release limits will not be exceeded, and allows for the subsequent calculation of offsite dose as a result of the drywall purge. Once the Unit is sub-critical following shutdown, the initial 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> purge will exchange multiple volumes of the drywall removing the pre-existing noble gas concentration, and the lack of any source term will yield no new concentration.

Likewise, there will be no source term until criticality has been achieved following startup. Page 1-812.4.6-1 8 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 8 12.4.7 Total Dose BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to meet the dose limitations of 40 CFR 190. The specification requires the preparation and submittal of a report whenever the calculated doses from plant radioactive effluents exceed twice the design objective doses of Appendix I. For sites containing up to 4 reactors, it is highly unlikely that the resultant dose to a member of the public will exceed the dose limits of 40 CFR 190 if the individual reactors remain within the reporting requirement level. The report will describe a course of action that should result in the limitation of dose to a member of the public for 12 consecutive months to within the 40 CFR 190 limits. For the purpose of the report, it may be assumed that the dose commitment to the member of the public from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 5 miles must be considered.

If the dose to any member of the public is estimated to exceed the requirements of 40 CFR 190, the report with a request for a variance (provided the release conditions resulting in violation of 40 CFR 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 , is considered to be a timely request and fulfills the requirements of 40 CFR 190 until NRC staff action is completed.

The variance only relates to the limits of 40 CFR 190, and does not apply in any way to the requirements for dose limitation of 10 CFR Part 20, as addressed in other sections of the RECS. An individual is not considered a member of the public during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle. Page 1-812.4.7-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.8 Main Condenser BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control provides reasonable assurance that the releases from the main condenser will not exceed the requirements of the LaSalle Technical Specifications 3.7.6. In addition, a sample is required within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if the increase is not due to thermal power changes. If the cause is known and not fuel related and less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in duration, then no sample is required.

[This is based on a letter from W. R. Huntington to Operating Engineers, Shift Engineers and F.R. Lawless, dated May 24, 1984.] Page 1-912.4.8-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.9 Dose Limits for MEMBERS OF THE PUBLIC BASES CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control applies to direct exposure of radioactive materials as well as radioactive materials released in gaseous and liquid effluents.

10 CFR 20.1301 sets forth the 100 mrem/year dose limit to members of the public; 2 mrem in any one-hour limit in the unrestricted area; and reiterates that the licensee is also required to meet the 40 CFR 190 standards.

10 CFR 20.1302 provides options to determine compliance to 1 O CFR 20.1301. Compliance to the above operability requirement is based on 1 O CFR 20, 40 CFR 190 and LaSalle Station Technical Specification 5.5.4.g. The Effluents Program shall implement monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters of the ODCM. Page 1-812.4.9-1 CY*LA-170-301 Revision 6 Part I, Radiological Effluent Control:;

B 12.5RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.1 Radiological Environmental Monitoring Program BASES The Radiological Environmental Monitoring Program required by this section provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation.

This monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50 and thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring.

The initially specified monitoring program will be effective for at least the first 3 years of commercial operation.

Following this period, program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table R 12.5.1-3 are considered optimum for routine environmental measurements in industrial laboratories.

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

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, LA., "Limits for Qualitative Detection and Quantitative Determination

-Application to Radiochemistry," Anal. Chem. 40, 586-93 (1968), and Hartwell, J.K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). Table R12.5.1-1 requires "one sample of each community drinking water supply downstream of the plant within 1 O kilometers." Drinking water supply is defined as water taken from rivers, lakes, or reservoirs (not well water) that is used for drinking.

Page 1-812.5.1-1 CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.2 Land Use Census BASES This control is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCM are made it required by the results of this census. This census satisfies the requirements of Section IV.B.3 of Appendix I to 1 O CFR Part 50. An annual garden census will not be required since the licensee will assume that there is a garden at the nearest residence in each sector for dose calculations.

Page 1-812.5.2-1 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls B 12.5RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.3 lnterlaboratory Comparison Program BASES The requirement for participation in an lnterlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental samples matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50. Page 1-812.5.3* 1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.5RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.4 Meteorological Monitoring Program (NOT APPLICABLE)

Page 1-812.5.4*1 GASEOUS RELEASE TYPE A. Containment Vent and Purge System ti B. Main Vent Stack c. Standby Gas Treatment System D. Main Vent Stack And Standby Gas Treatment Systemc CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1 (Page 1of5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM MINIMUM TYPE OF LOWER LIMIT OF SAMPLING ANALYSIS ACTIVITY DETECTION (LLD) FREQUENCv<'>

FREQUENCv<

1> ANALYSIS (µCi/ml)a Prior to each Prior to each Principal Gamma 1x1ff 4 release Emitters 9 Each Purgeb release Grab Sample Each Purgeb H-3 1 x1 a.a 31 daysb 31 daysb Principal Gamma 1x10" 4 Grab Sample Emitters 9 7 daysb.8 7 daysb,e H*3 1x1ff 6 Grab Sample 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sc 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sc Principal Gamma 1x10"" Grab Sample Emittersg 7 daysd 1-131 1x10*12 CONTINUOUS' Charcoal 1x10" 10 Sample 1-133 CONTINUOUS' 7 daysd Principal Gamma 1x10*11 Particulate Emitters 9 (I* 131, Sample Others) 31 days CONTINUOUS' Composite Gross Alpha 1x10*11 Particulate Sample 92 days CONTINUOUS' Composite Sr-89,Sr-90 1x10*11 Particulate Sample CONTINUOUS' Noble Gas Noble Gases, Gross Beta or 1x10*6 Monitor Gamma Page 1*12.4.1-2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1 (Page 2 of 5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION 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= 4.66Sb E

• V

• 2.22xl0 6

• Y *et-Adi> Where: LLD is the "a priori" lower limit of detection as defined above (as microcurie 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 rs =-B =background sum (counts) t = count time (minutes) is the counting efficiency (as counts per transformation), V is the sample size (in units of mass or volume), 2.22x10 6 is the number of transformations per minute per microcurie, Y is the fractional radiochemical yield (when applicable), A. is the radioactive decay constant for the particular radionuclide, and 6t is the elapsed time between midpoint of sample collection and time of counting (for plant effluents, not environmental samples).

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

Typical values of E, V, Y, and 6t shall be used in the calculation.

Alternate LLD Methodology An alternate methodology for LLD determination follows and is similar to the above LLD equation:

LLD= (2.71 +4.65Ji) *Decay E

• q*b* Y *t * (2.22x10 6) Page I* 12.4.1-3 Where: CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1(Page3 of 5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION B =background sum (counts) E = counting efficiency q =sample quantity (mass or volume) b = abundance (if applicable)

Y =fractional radiochemical yield or collection efficiency (if applicable)

=count time (minutes) 2.22 x 10 6 =number of disintegrations per minute per microcurie 2.71 + 4.65"8 = k 2 + (2k .../2 "B), and k = 1.645 Decay .1t RT (k=value of the t statistic from the single-tailed t distribution at a significance level of 0.95 and infinite degrees of freedom. This means that the LLD result represents a 95% detection probability with a 5% probability of falsely concluding that the nuclide is present when it is not or that the nuclide is not present when it is.) = eu.1 [l .. RT/(1 *e*i.AT)][A Td /(1 *e*i.Td)]

if applicable

=radioactive decay constant (units consistent with .1t, AT and Td) ="delta t", or the elapsed time between sample collection or the midpoint of sample collection and the time the count is started, depending on the type of sample (units consistent with A) =elapsed real time, or the duration of the sample count (units consistent with A) = sample deposition time, or the duration of analyte collection onto the sample media (units consistent with A.) The LLD may alternately be determined using installed radioanalytical software, if available.

In addition to determining the correct number of channels over which to total the background sum, utilizing the software's ability to perform decay corrections (i.e. during sample collection, from sample collection to start of analysis, and during counting), this alternate method will result in a more accurate determination of the LLD. It should be recognized that the LLD is defined as a before the fact limit representing the capability of a measurement system and not as an after the fact limit for a particular measurement.

b. Sampling and analyses shall also be performed following shutdown, startup, or a thermal power change exceeding 20 percent of RATED THERMAL POWER in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> unless (1) analysis shows that the dose equivalent I* 131 concentration in the primary coolant has not increased more than a factor of 5, and (2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3. Page I* 12.4.1 *4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.4.1-1(Page4 of 5) RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION c. Whenever there is flow through the SGT. If SGT is run more than 2 hrs in a 24-hour period, ensure a noble gas sample is obtained prior to securing SGT and particulate and iodine samples are taken within 24 hrs after securing SGT. A 2-hour run ensures required sample lower limits of detection are met for particulates and iodine. A SGT run of less than 2 hrs is not a significant contribution to offsite dose and requires no sampling.

d. Samples shall be changed at least once per 7 days and the analyses completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after removal from the sampler. Sampling shall also be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following each shutdown, startup, or thermal power level change exceeding 20% of RATED THERMAL POWER in one hour. This requirement does not apply if 1) analysis shows that the dose equivalent 1-131 concentration in the primary coolant has not increased by more than a factor of 5, and 2) the noble gas activity monitor shows that effluent activity has not increased by more than a factor of 3. When samples collected for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are analyzed, the corresponding LLDs may be increased by a factor of 10. e. Tritium grab samples shall be taken at least once per 7 days from the plant vent to determine tritium releases in the ventilation exhaust from the spent fuel pool area whenever spent fuel is in the spent fuel pool. If there is no spent fuel in the fuel pool, sampling and analysis of tritium grab samples shall be performed at least once per 31 days. f. The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with RECs 12.4.1, 12.4.2 and 12.4.3. g. The principal gamma emitters for which the LLD specification applies include the following radionuclides:

Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissions and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions.

This list does not mean that only these nuclides are to be detected and reported.

Other peaks that are measurable and identifiable, at the 95% confidence level, together with the above nuclides, shall also be identified and reported.

h. The drywell tritium and noble gas samples and associated purge calculations are required when the Unit is at power (i.e. critical) and for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of purging activities following shutdown.

The drywell tritium and noble gas sample results are valid for 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> from sample time if 1) the drywall radioactivity monitors have not indicated an increase in airborne or gaseous radioactivity, and 2) the drywell equipment and floor drain sump pumps run times have not indicated an increase in leakage in the drywell since the sample was taken, and 3) conditions are such that activity can be calculated for the radionuclide concentration at the time of the release. If there is any reason to suspect that gaseous radioactivity levels have changed in the drywell that would compromise the calculated, or estimated, radionuclide concentrations at the time of the release, since the last sample (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />), a new sample and analyses should be requested prior to starting a drywell purge to meet the intent of providing current analyses to reflect actual activity released to the environment.

If a known steady state leakage condition exists in the drywell it is possible to calculate a safe and accurate release package. Final release quantification will be based on calculated radionuclide concentrations at the time of the actual release. Page I* 12.4.1 *5 Table R12.4.1-1 (Page 5 of 5) CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM TABLE NOTATION If the drywall is PURGED in accordance with the ODCM definition, both noble gas and tritium analyses must be completed before the purge begins. If the drywell is simply VENTING in accordance with the ODCM definition, no sample is required before venting. i. The provisions of RSA 12.0.2 and RSA 12.0.3 are applicable to the Radioactive Gaseous Waste Sampling and Analysis Program. Page 1-12.4.1-6 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.2 Dose from Noble Gases REC 12.4.2 The air dose due to noble gases in gaseous effluents released from each reactor unit from the site shall be limited to the following:

a. For gamma radiation, 5 mrad during any calendar quarter and s 1 O mrad during any calendar year; and b. For beta radiation, s 1 O mrad during any calendar quarter and s 20 mrad during any calendar year. APPLICABILITY:

At all times. ACTIONS CONDITION REQUIRED ACTION A. --------------NOTE--------------

A.1 Submit a report to the NRC, Required Action A.1 shall pursuant to 1 OCFR50 be completed if this Appendix I Section IV.A, that Condition is entered. identifies causes for exceeding limits, defines ------------------------------------

corrective actions to be Calculated air dose not taken to reduce the within limits. and proposed corrective actions to assure that subsequent releases are within limits. 8. Calculated air dose B.1 Enter Condition A of REC exceeds two times (2x) the 12.4.7. limits. SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.4.2.1 Determine cumulative dose contributions for the current calendar quarter and current calendar year in accordance with the ODCM. Page 1-12.4.2-1 COMPLETION TIME 30 days following the end of the quarter in which the release occurred Immediately FREQUENCY 31 days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.3 Dose From Iodine -131, Iodine -133, Tritium, and Radioactive Materials in Particulate Form REC 12.4.3 The dose to a MEMBER OF THE PUBLIC from iodine-131, iodine-133, tritium and all radionuclides in particulate form, with half-lives

> 8 days, in gaseous effluents released from each reactor unit, to areas at and beyond the SITE BOUNDARY shall be limited to: a. s 7.5 mrem to any organ during any calendar quarter; and b. s 15 mrem to any organ during any calendar year. APPLICABILITY:

At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. --------------NOTE--**-----------

A. 1 Submit a report to the NRC, 30 days following the Required Action A.1 shall be pursuant to 1 OCFR50 end of the quarter in completed if this Condition is Appendix I Section IV.A, which the release entered. that identifies causes for occurred exceeding limits, defines --------------------------------------

corrective actions to be Calculated dose not within taken to reduce the limits. releases, and proposed corrective actions to assure that subsequent releases are within limits. B. Calculated dose exceeds B.1 Enter Condition A of Immediately two times (2x) the limits. REC 12.4.7. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.4.3.1 Determine cumulative dose contributions for the current 31 days calendar quarter and calendar year for iodine-131 , iodine-133, tritium, and radionuclides in particulate form with half-lives greater than 8 days in accordance with the methodology and parameters in the ODCM. Page 1-12.4.3-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.4 GASEOUS RADWASTE TREATMENT SYSTEM REC 12.4.4 The GASEOUS RADWASTE (OFF-GAS)

TREATMENT SYSTEM shall be OPERABLE and in operation.

APPLICABILITY:

During Main Condenser Air Ejector system operation.

ACTIONS CONDITION REQUIRED ACTION A. GASEOUS RADWASTE A.1 Restore system to TREATMENT SYSTEM OPERABLE status. inoperable.

AND OR A.2 Place system in operation.

GASEOUS RADWASTE TREATMENT SYSTEM not in operation.

B. --------------NOTE--------------

B.1 Submit a report to the NRC Required Action B.1 shall that includes defective be completed if this equipment or subsystem Condition is entered. identification and inoperability cause, actions ------------------------------------

taken to restore the Required action and inoperable equipment to Associated Completion OPERABLE status, and Time not met. summary description of actions taken to prevent a recurrence.

SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.4.4.1 Verify the GASEOUS RADWASTE TREATMENT SYSTEM is in operation.

Page 1-12.4.4-1 COMPLETION TIME 7 days 30 days FREQUENCY 7days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.5 VENTILATION EXHAUST TREATMENT SYSTEM REC 12.4.5 The appropriate portions of the VENTILATION EXHAUST TREATMENT SYSTEM shall; a. BE OPERABLE; and b. be used to reduce radioactive materials in gaseous waste prior to their discharge when the projected doses from each reactor unit from the site would exceed 0.3 mrem to any organ, when average over 31 days. APPLICABILITY:

At all times. ----------------------------------------------------------N()TE-----------------------------------------------------------

Separate Condition entry is allowed for each VENTILATION EXHAUST TREATMENT system pathway. ACTIONS CONDITION REQUIRED ACTION COMPLETl()N TIME A. One or more required A.1 Restore system to 31 days VENTILATION EXHAUST OPERABLE status. TREATMENT SYSTEMS inoperable.

B. --------------NOTE--------------

B.1 Submit a report to the NRC 30 days Required Action B.1 shall that includes inoperable be completed if this equipment or subsystem condition is entered. identification and reason for inoperability, actions ------------------------------------

taken to restore the Untreated gaseous waste inoperable equipment to release in progress.

OPERABLE status, and summary description of AND actions taken to prevent a recurrence.

Projected dose not within limits. (continued)

Page 1-12.4.5-1 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. -------------NOTE---------------

C.1 Required Action C.1 shall be completed if this Condition is entered. Submit a report to the NRC 30 days that includes inoperable Required Action and associated Completion Time of Condition A not met. SURVEILLANCE REQUIREMENTS equipment or subsystem identification and reason for inoperability, actions taken to restore the inoperable equipment to OPERABLE status, and summary description of actions taken to prevent a recurrence.

SURVEILLANCE RSR 12.4.5.1 Project doses due to gaseous releases from the site in accordance with the ODCM. RSA 12.4.5.2 ------------------------------NOTE------------------------------

Not required to be performed if the VENTILATION EXHAUST TREATMENT SYSTEM has been used to process gaseous effluents in the last 115 days. OPERATE each required VENTILATION EXHAUST TREATMENT SYSTEM equipment for at least 30 minutes. Page 1-12.4.5*2 FREQUENCY 31 days 92 days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.6 MARK II Containment REC 12.4.6 VENTING or PURGING of the containment drywall shall be: a. through the Primary Containment Vent and Purge System, or b. through the Standby Gas Treatment (SGT) System. APPLICABILITY:

During drywall VENTING or PURGING. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A., Above requirements not met. A.1 Suspend all drywell Immediately VENTING and PURGING. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY RSA 12.4.6.1 Verify containment drywall is aligned for VENTING or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> PURGING through the Primary Containment Vent and Purge System or the SGT System. RS A 12 .4. 6.2 ---------------------------------NOTE--------------------------------

Only required to be met when in MODES 1, 2, or 3. Verify: a. Both SGT trains are OPERABLE, and b. Only one of the SGT System trains to be used for PURGING. Page 1-12.4.6-1 Prior to PURGING through the SGT System.

CY*LA-170-301 Revision 6 Part 1, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.7Total Dose REC 12.4.7 The dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and radiation from all uranium fuel cycle sources over 12 consecutive months shall be limited to: a. s 25 mrem to the total body; and b. s 75 mrem to the thyroid; and c. s 25 mrem to any other organ. APPLICABILITY:

At all times. ACTIONS CONDITION A. --------------NOTE---------------

Required Action A.1 and A.2 shall be completed if this Condition is entered. As required by Required Action B.1 of REC 12.3.2, 12.4.2, or 12.4.3. Calculated Total Dose not within limits. REQUIRED ACTION A.1 Submit a report to the NRC (Director, Nuclear Reactor Regulation) that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the limits to include estimates of radiation exposure to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways and direct radiation, for a 12 consecutive month period that includes the release(s) covered by this report. Page 1-12.4.7-1 COMPLETION TIME 30 days (continued)

ACTIONS CONDITION A. (continued)

SURVEILLANCE REQUIREMENTS CY *LA-170-301 Revision 6 Part I, Radiological Ettluent Controls REQUIRED ACTION --------------NOl"E---------------

Only applicable if the release condition resulting in violation of 40 CFR 190 has not been corrected.

COMPLETION TIME Submit a request for a 30 days variance in accordance with 40 CFR 190, including the specified information of 40 CFR 190.11 . SURVEILLANCE FREQUENCY RSA 12.4. 7 .1 Determine cumulative dose contributions from direct radiation and liquid and gaseous effluents in accordance with the ODCM. Page 1*12.4.7*2 31 days CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.8 Main Condenser REC 12.4.8 The release rate of the sum of the activities from the noble gases measured prior to the holdup line shall be limited to 3.4 x 10 5 µCi/sec after 30 minutes decay. APPLICABILITY:

MODE 1, MODES 2 and 3 with any steam line not isolated and steam jet air ejectors (SJAE) in operation.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Release rate of the sum of A.1 Restore the release rate to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> the activities from noble within limit. gases prior to the holdup line not within the limits. B. Required Action and B.1 Isolate all main steam 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion lines. Time not met. OR B.2 Isolate the SJAE. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR B.3.1 MODE3 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND B.3.2 MODE 4 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Page 1-12.4.8-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.4.8.1 Monitor the noble gas radioactivity rate prior to the holdup line in accordance with the ODCM and Table R12.2.2-1 RSA 12.4.8.2 -----------------------------NOTE------------------------------------

Not required to be performed until 31 days after any Main Steam line not isolated and SJAE in operation.

Verify the release rate of the sum of the activities from noble gases prior to the holdup line is within limits by performing an isotopic analysis of a representative sample of gases taken prior to the holdup line. Page 1-12.4.8-2 FREQUENCY CONTINUOUSLY Once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after a increase in the nominal steady state fission gas release from the primary coolant, as indicated by the off gas treatment Noble Gas Activity Monitor, after factoring out increases due to changes in THERMAL POWER level 31 days CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 12.4.9 Dose Limits for MEMBERS OF THE PUBLIC REC 12.4.9 Operations shall be conducted such that: a. Total Effective Dose Equivalent (TEDE) to individual MEMBERS OF THE PUBLIC does not exceed 100 mrem/year; and b. The dose in any unrestricted area from external sources does not exceed 2 mrem in any one hour. APPLICABILITY:

At all times. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. --------------NOTE---------------

A.1 Submit a report to the NRC 30 days Required Action A.1 shall be in accordance with completed if this Condition is 10 CFR 20.2203. entered. -------------------------------------

Dose limit of REC Item a. exceeded.

B. --------------NOl"E------*-***----

B.1 Submit a report to the NRC 30 days Required Action B.1 shall be in accordance with completed if this Condition is 10 CFR 20.2203. entered. -------------------------------------

Dose limit of REC Item b. exceeded.

Page 1*12.4.9-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls FREQUENCY RSA 12.4.9.1 Calculate the TEDE to individual MEMBERS OF THE PUBLIC in accordance with the ODCM. 12 months RSA 12.4.9.2 Determine and/or evaluate direct radiation exposures in unrestricted areas. Page 1-12.4.9*2 12 months CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.1 Radiological Environmental Monitoring Program (REMP) REC 12.5.1 The REMP shall be conducted as specified in Table R12.5.1-1.

APPLICABILITY:

At all times. ACTIONS CONDITION A. --------------NOT'E--------------

Required Action A.2 shall be completed if this Condition is entered. Sample type or location(s) required by Table R12.5.1-1 permanently unavailable.

REQUIRED ACTION A.1 Initiate action to identify suitable, alternative sampling media and/or specific locations for obtaining replacement samples for the pathway of interest and add them to the REMP. Delete locations from which samples are unavailable.

A.2 Prepare and submit a controlled version of the ODCM, in the next Annual Radiological Environmental Operating Report (REOR) including revised figures and tables reflecting the new location(s) with supporting information identifying the sample unavailability cause and justification of the new sampling location(s).

Page 1-12.5.1-1 COMPLETION TIME Immediately In accordance with Technical Specification 5.6.2 (continued)

ACTIONS CONDITION

8. -------------NOTE--------------

Required Action B.1 shall be completed if this Condition is entered. ------------------------------------

Level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeds the reporting levels of Table R12.5.1-2 when averaged over any calendar quarter. c. -------------NOTE--------------

Required Action C.1 shall be completed if this Condition is entered. ------------------------------------

More than one radionuclide in Table R12.5.1-2 detected in the sampling medium. AND C1 C2 --+--+ ... 2: 1.0 RL1 RL2 where; C = concentration RL = reporting level. 8.1 C.1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION COMPLETION TIME Submit a report to the NRC 30 days that identifies the cause(s) for exceeding the limits and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year reporting level of REC 12.3.2, 12.4.2 or 12.4.3. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report. Submit a report to the NRC 30 days that identifies the cause(s) for exceeding the limits and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year reporting level of REC 12.3.2, 12.4.2 or 12.4.3. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report. (continued)

Page 1-12.5.1-2 ACTIONS CONDITION CJ. *------------NOTE--------------

Required Action D.1 and D.2 shall be completed if this Condition is entered. Radionuclides other than those in Table R12.5.1-2 are detected.

AND The potential annual dose to a MEMBER OF THE PUBLIC from all radionuclides is greater than or equal to the calendar year limits of REC 12.3.2, 12.4.2, or 12.4.3. CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls REQUIRED ACTION D. 1 -----------------NOTE---------------

Only required when the measured levels of radioactivity are the result of plant effluents.

COMPLETION TIME Submit a report to the NRC 30 days that identifies the cause(s) for exceeding the limits and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose to a MEMBER OF THE PUBLIC is less than the calendar year reporting level. The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report. D.2 -----------------NOTE;---------------

Only required when the radionuclides detected are not the result of plant effluents.

Describe the condition in the next Annual REOR. Page I* 12.5.1 *3 In accordance with Technical Specification 5.6.2. (continued)

ACTIONS CONDITION E. -----------NOTE----------

E.1 Required Action E.1 shall be completed if this Condition is entered. RSA 12.5.1.1 not met. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REQUIRED COMPENSATORY MEASURE Prepare and submit to the NRC, in the next Annual REOR, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

Page 1-12.5.1-4 COMPLETION TIME In accordance with Technical Specification 5.6.2.

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls SURVEILLANCE REQUIREMENTS SURVEILLANCE RSA 12.5.1.1 --*****-******-------*-------**-NOTES-*-------*--*--*-**-*---------1 . Deviations to the sampling schedule for the following reasons may occur and the RSA still be considered met provided the deviations are described in the next Annual REOR: a. specimens are unobtainable due to hazardous conditions, seasonal unavailability, or malfunction of sampling equipment, or b. a person or business who participates in the program goes out of business or can no longer provide samples, or c. a contractor omission which is corrected as soon as discovered.

2. Malfunctioning equipment shall be corrected/replaced and replacement suppliers shall be found, as applicable, as soon as practicable.

Collect and analyze samples in accordance with Table R12.5.1-1 and the ODCM to the detection capabilities required by Table R12.5.1-3.

Page 1*12.5.1 *5 FREQUENCY In accordance with the Radiological Environmental Monitoring Program EXPOSURE PATHWAY AND/ OR SAMPLE 1. Airborne Radioiodine and Particulates Table R12.5.1-1 (Page 1 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION SAMPLE LOCATIONS 11> FREQUENCY 111> Samples from a total of eight locations:

CONTINUOUS sampler operation with particulate sample a. Indicator-Near Field collection once per 7 days , or more frequently if required due Four samples from locations within 4.0 km (2.5 mi) in to dust loading, and radioiodine different sectors. canister collection once per 14 days. b. Indicator-Far Field Four additional locations within 4.0 to 10 km (2.5 to 6.2 mi} in different sectors. c. Control One sample from a control location within 10 to 30 km (6.2 to 18.6 mi). Page 1-12.5.1-6 . ---**. --* -------CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls TYPE AND FREQUENCY OF ANAL YSIS 111> Radioiodine Canister:

1-131 analysis once per 14 days on near field samples and contro1<2> samples. Particulate Sam12ler:

Gross beta analysis following once per 7 day filter change<3 l and gamma isotopic analysis<4 l once per 92 days on composite filters by location on near field and samples. (continued)

EXPOSURE PATHWAY AND/ OR SAMPLE 2. Direct Radiation':.'

Table A12.5.1-1(Page2 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION SAMPLE LOCATIONS 11> FREQUENCY 111> Forty routine monitoring stations, either with a Field 92 days Dosimeter or with one instrument for measuring dose rate continuously, placed as follows: a. Indicator-Inner Ring (100 Series) One in each meteorological sector, in the general area of the SITE BOUNDARY (within 0.1 to 2.0 miles; 0.2 to 3.2 km}; b. Indicator-Outer Ring (200 Series} One in each meteorological sector, within 4.8 to 10 km (3 to 6.2 mi); c. Other One at each Airborne location given in part 1.a. and 1.b. The balance of the Field Dosimeters to be placed at special interest locations beyond the Restricted Area where either a MEMBER OF THE PUBLIC or Exelon Nuclear employees have routine access. d. Control One at each airborne control location given in part 1.c. Page 1-12.5.1-7 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls TYPE AND FREQUENCY OF ANAL YSIS 111> Gamma dose on each Field Dosimeters once per 92 days. (continued)

EXPOSURE PATHWAY AND/ OR SAMPLE 3. Waterborne

a. Ground/Well

b. Drinking"'

c. Surface Water 111 d. Control Sample

e. Sediment a. a. a. CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.5.1-1 (Page 3 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION TYPE AND FREQUENCY SAMPLE LOCATIONs<

1> FREQUENcv<

11> OF ANAL vs1s 111> Indicator 92 days Gamma isotopic 1" 1 and tritium analysis once per 92 Samples from two sources only if likely to be affected.<

61 days. Indicator Grab samples once per 7 days. Gross beta and gamma isotopic analyses 14' on once One Sample from each community drinking water per 31 day composite; supply that could be affected by the station discharge tritium analysis on once per within 10 km (6.2 mi) downstream of discharge.

92 day comoosite.

1-131 on each composite when calculated dose for water consumption

> 1 mrem/year.

If no community water supply (Drinking Water) exists Grab samples once per 7 days. Gross beta and gamma within 10 km downstream of discharge then surface isotopic analyses<4> on once water sampling shall be performed.

per 31 day composite; tritium analysis on once per Indicator 92 day composite.

One sample downstream

a. Control Grab samples once per 7 days. Gross beta and gamma isotopic analyses 141 on once One surface sample upstream of discharge.

per 31 day composite; tritium analysis on once per 92 day composite.

a. Indicator 184 days Gamma isotopic analysis 1" 1 At least one sample from downstream 17' area within 1 O once per 184 days. km (6.2 mi). (continued)

Page 1-12.5.1-8 EXPOSURE PATHWAY AND/ OR SAMPLE 4. Ingestion

a. Milk(B) b. Fish c. Food Products a. Table R12.5.1-1 (Page 4 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM NUMBER OF REPRESENTATIVE SAMPLES AND SAMPLING AND COLLECTION SAMPLE LOCATIONSm FREQUENCY 1111 Indicator Once per 14 days when animals Samples from milking animals from a maximum of are on pasture (May through October), once per 31 days at three locations within 10 km (6.2 mi) distance.

other times (November through b. Control April). One sample from milking animals at a control location within 10 to 30 km (6.2 to 18.6 mi). a. Indicator Twice per 12 months. Representative samples of commercially and recreationally important species in discharge area, and representative samples from the LaSalle Lake. b. Control Representative samples of commercially and recreationally important species in control locations upstream of discharge.

a. Indicator 12 months Two representative samples from the principal food pathways grown in each of four major quadrants within 10 km {6.2 mi), if available:

At least one root vegetable sample 1'01 At least one broad leaf vegetable (or vegetation

)<101 b. Control Two representative samples similar to indicator samples grown within 15 to 30 km (9.3 to 18.6 mi). Page 1-12.5.1 *9 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls TYPE AND FREQUENCY OF ANALYSIS 1111 Gamma isotopic'"'

and 1-131 191 analysis on each sample. Gamma isotopic analysis'"'

on edible portions Gamma isotopic 1" 1 and 1-131 analysis on each sample.

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Table R12.5.1-1 (Page 5 of 5) RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM TABLE NOTATIONS (1) Specific parameters of distance and direction from the centerline of the midpoint of the two units and additional description where pertinent, shall be provided for each and every sample location in Table R12.5.1 *1, except for vegetation. For vegetation, due to location variability year to year, the parameters of distance and direction shall be provided in the Annual Environmental Operating Report. (2) Far field samples are analyzed when the respective near field sample results are inconsistent with previous measurements and radioactivity is confirmed as having its origin in airborne effluents from the station, or at the discretion of the ODCM Specialist.

(3) Airborne particulate sample fitters shalt be analyzed for gross beta radioactivity 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples. (4) Gamma isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attributable to the effluents from the station. (5) One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. Film badges shall not be used as dosimeters for measuring direct radiation.

The 40 locations is not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations; e.g., if a station is adjacent to a lake, some sectors may be over water thereby reducing the number of dosimeters that could be placed at the indicated distances.

The frequency of analysis or readout for Field Dosimeter systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading. (6) Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

(7) The "downstream" sample shall be taken in an area beyond but near the mixing zone. The "upstream sample" shall be taken at a distance beyond significant influence of the discharge.

Upstream samples in an estuary must be taken far enough upstream to be beyond the station influence.

(8) If milking animals are not found in the designated indicator locations, or if the owners decline to participate in the REMP, all milk sampling may be discontinued.

(9) 1-131 analysis means the analytical separation and counting procedure are specific for this radionuclide.

(10) One sample shall consist of a volume/weight of sample large enough to fill contractor specified container.

(11) The provisions of RSA 12.0.2 and RSA 12.0.3 are not applicable to the REMP. Page 1-12.5.1-10 Table R12.5.1-2 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES REPORTING LEVELS AIRBORNE PARTICULATE FOOD PRODUCTS ANALYSIS WATER (pCill) OR GASES (pCi/m 3) FISH (pCi/kg, wet) MILK (pCi/1) (pCi/kQ, wet) H-3 Mn-54 Fe-59 Co-58 Co-60 Zn-65 Zr-Nb-95 1-131 Cs-134 Cs-137 Ba-La-140 (1) (2) 20.000<1> 1,000 30,000 400 10,000 1,000 30,000 300 10,000 300 20,000 400 2(2) 0.9 3 100 30 10 1,000 60 1,000 50 20 2,000 70 2.000 200 300 For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCi/1 may be used. If no drinking water pathway exists, a value of 20 pCi/I may be used. Page 1-12.5.1-11 ANALYSIS Gross Beta H-3 Mn-54 Fe-59 Co-58,60 Zn-65 Zr-95 Nb-95 1*131 Cs-134 Cs-137 Ba-140 La-140 Table R12.5.1-3 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS 1 a> LOWER LIMIT OF DETECTION (LLD)lb> AIRBORNE PARTICULATE FISH FOOD PRODUCTS SEDIMENT /SOIL WATER (pCi/1) OR GASES <oCi/m 3) <oCi/ka, wet) MILK <oCi/I) (pCi/kg, wet) loCi/ka, drvl 4 0.01 2,000 15 130 30 260 15 130 30 260 30 15 1<c) 0.07 1 60 15 0.05 130 15 60 150 18 0.06 150 18 80 180 60 60 15 15 (a) All peaks identified at the 95% confidence level, shall also be analyzed and reported. (b) Most restrictive ODCM LLD requirement or technical requirement.

The reported minimum detectable concentration (MOC) shall be .5 these values. (c) If no drinking water pathway exists, a value of 15 pCi/I may be used (NUREG 1301/1302)

Page 1-12.5.1-12 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.2 Land Use Census REC 12.5.2 A Land Use Census shall be conducted and shall identify within a distance of 10 km (6.2 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence, and an enumeration of livestock.

For dose calculation, a garden will be assumed at the nearest residence.

---

NOTES-------------------------------------------------------

1 . The 16 meteorological sectors requirement may be reduced according to geographical limitations; e.g. at a lake site where some sectors will be over water. 2. The nearest industrial facility shall also be documented if closer than the nearest residence.

APPLICABILITY:

At all times. ACTIONS CONDITION A. -------------NOTE--------------

A. 1 Required Action A.1 and A.2 shall be completed if this Condition is entered. Land use census identifies AND a location which yields a calculated dose or dose commitment, via the same exposure pathway, that is at least 20% greater than at a location from which samples are currently being obtained in accordance with REC 12.5.1. REQUIRED ACTION Add the new location to the Radiological Environmental Monitoring Program (REMP). Page 1-12.5.2-1 COMPLETION TIME 30 days {continued)

ACTIONS CY*LA-170-301 Revision 6 Part I, Radiological Effluent Controls CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A .2 ---------------NOTE------------------

The sampling location(s), excluding the control location, having the lowest calculated dose or dose commitment(s), via the same exposure pathway, may be deleted from the REMP after October 31 of the year in which Land Use Census was conducted.

Submit the documentation for a change in the ODCM in the next Annual Radiological Environmental Operating Report and include the revised figures and tables for the ODCM reflecting the new location(s) with information supporting the change in . sampling locations.

SURVEILLANCE REQUIREMENTS RSA 12.5.2.1 SURVEILLANCE Conduct a land use census during the growing season, between June 1° and October 1, using information that will provide the best results, such as by a door-to-door survey, aerial survey, or by consulting local agriculture authorities.

The results of the census shall be included in the Annual Radiological Environmental Operating Report. Page 1*12.5.2*2 In accordance with Technical Specification 5.6.2. FREQUENCY RSR 12.0.2 and 12.0.3 are not applicable.

12 months CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.3 lnterlaboratory Comparison Program REC 12.5.3 Analyses shall be performed on radioactive materials supplied as part of an lnterlaboratory Comparison Program that is traceable to NIST. APPLICABILITY:

At all times. ACTIONS CONDITION A. -------------NOTE-------------

A.1 Required Action A.1 shall be completed if this Condition is entered. Requirements of the REC not met. SURVEILLANCE REQUIREMENTS REQUIRED ACTION Report corrective actions to prevent recurrence to the NRC in the next Annual Radiological Environmental Operating Report. SURVEILLANCE RSA 12.5.3 Include a summary of the results of the lnterlaboratory Comparison Program in the Annual Radiological Environmental Operating Report. Page 1-12.5.3*1 COMPLETION TIME In accordance with Technical Specification 5.6.2 FREQUENCY In accordance with Technical Specification 5.6.2 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 12.5.4 Meteorological Monitoring Program (NOT APPLICABLE)

Page 1-12.5.4*1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.1 Annual Radiological Environmental Operating Report 12.6.1.1 12.6.1.2 12.6.1.3 Routine Annual Radiological Environmental Operating Report covering the operation of the Units during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental monitoring program for the report period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual, and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.c. It should include, as found appropriate, a comparison of preoperational studies with operational controls or with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment.

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station. The Annual Radiological Environmental Operating Report shall include the results of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the tables and figures in Part II, Section 6 of the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual 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 as soon as possible in a supplementary report. The reports shall also include the following:

a summary description of the Radiological Environmental Monitoring Program; legible maps covering all sampling locations keyed to a table giving distances and directions from the midpoint between the two units; reasons for not conducting the Radiological Environmental Monitoring Program as required by REC 12.5.1, and discussion of all deviations from the sampling schedule of Table R12.5.1-1; a Table of Missed Samples and a Table of Sample Anomalies for all deviations from the sampling schedule of ODCM Part II, Table 6.1*1; discussion of environmental sample measurements that exceed the reporting levels of Table R12.5.1-2 but are not the result of plant effluents; discussion of all analyses in which the LLD required by Table R12.5.1-3 was not achievable; results of the Land Use Census required by REC 12.5.2; and the results of licensee participation in an lnterlaboratory Comparison Program and the corrective actions being taken if the specified program is not being performed as required by REC 12.5.3. (continued)

Page 1*12.6.1-1 CY -LA* 170-301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.1 Annual Radiological Environmental Operating Report (continued) 12.6.1.4 The Annual Radiological Environmental Operating Report shall also include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability.

In lieu of submission with the Annual Radiological Environmental Operating Report, the licensee has the option of retaining the summary of required meteorological data on site in a file that shall be provided to the NRC upon request. 12.6.1.5 The Annual Radiological Environmental Operating Report shall also include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. This report shall also include an assessment of radiation doses to the most likely exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the ODCM and in compliance with 1 O CFR 20 and 40 CFR 190,* "Environmental Radiation Protection Standards for Nuclear Power Operation." Page 1-12.6.1-2 CY-lA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.2 Annual Radioactive Effluent Release Report 12.6.2.1 12.6.2.2 12.6.2.3 The radioactive effluent release reports covering the operation of the unit during the previous calendar year of operation shall be submitted in accordance with 10 CFR 50.36a prior to May 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluent and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and the PROCESS CONTROL PROGRAM and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1. A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit. The radioactive effluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, "Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof. The radioactive effluent release report shall include the following information for each type of solid waste shipped offsite during the report period: 1. Container volume, 2. Total curie quantity (specify whether determined by measurement or estimate), 3. Principal radionuclides (specify whether determined by measurement or estimate), 4. Type of waste (e.g., spent resin, compacted dry waste, evaporator bottoms), 5. Type of container (e.g., LSA, Type A, Type B, Large Quantity), and 6. Solidification agent (e.g., cement, urea formaldehyde). (continued)

Page 1-12.6.2-1 CY-LA-170*301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.2 Radioactive Effluent Release Report (continued) 12.6.2.4 The radioacti_ve effluent release reports shall include unplanned releases from the site to unrestricted areas of radioactive materials in gaseous and liquid effluents on a quarterly basis. 12.6.2.5 12.6.2.6 The radioactive effluent release reports shall include any changes to the PROCESS CONTROL PROGRAM (PCP) made during the reporting period. The radioactive effluent release reports shall include a description of licensee initiated major changes to the radioactive waste treatment systems (liquid, gaseous and solid), as described in Section 12.6.3.) Page 1-12.6.2-2 CY *LA* 170*301 Revision 6 Part I, Radiological Effluent Controls 12.6 REPORTING REQUIREMENTS 12.6.3 Offsite Dose Calculation Manual (ODCM) 12.6.3.1 The ODCM is common to LaSalle Unit 1 and LaSalle Unit 2. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and 12.6.3.2 12.6.3.3 The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release Reports required by Technical Specifications 5.6.2 and 5.6.3. Licensee-initiated changes to the ODCM: a. $hall be documented and records of reviews performed shall be retained as required by the Quality Assurance (QA) Manual. This documentation:

1. Shall contain sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s);

and 2. Shall contain a determination that the change(s) maintain the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and 10 CFR Part 50, Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

3. Shall become effective after approval of the Plant Manager. 4. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

Page 1*12.6.3*1 12.6 REPORTING REQUIREMENTS CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls 12.6.4 Major Changes to Radioactive Waste Treatment Systems (Liquid and Gaseous) 12.6.4.1 Licensee initiated major changes to the radioactive waste treatment systems (liquid and gaseous):

a. Shall be reported to the Commission in the Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the Plant Operations Review Committee (PORC). The discussion of each change shall contain: 1. A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; 2. Sufficient detailed information to totally support the reason for the change without benefit or additional or supplemental information;

3. A detailed description of the equipment, components and processes involved and the interfaces with other plant systems; 4. An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents waste that differ from those previously predicted in the license application and amendments thereto; 5. An evaluation of the change which shows the expected maximum exposures to individual in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto; 6. A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents, to the actual releases for the period to when the changes are to be made; 7. An estimate of the exposure to plant operating personnel as a result of the change; and 8. Documentation of the fact that the change was reviewed and found acceptable by the PORC. b. Shall become effective upon review and acceptance by the PORC. Page 1-12.6.4-1 BASES General CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls It is expected that releases of radioactive material in effluents will be kept at small fractions of the limits specified in Section 20.1302 of 1 O CFR, Part 20. At the same time, the licensee is permitted the flexibility of operation, compatible with consideration of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small fractions, but still within the limits specified in Section 20.1302 of 1 O CFR, Part 20. It is expected that in using this operational flexibility under unusual operating conditions the licensee will exert his best efforts to keep levels of radioactive material in effluents as low as practicable.

l-B-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.0 OFFSITE DOSE CALCULATION MANUAL (ODCM) RADIOLOGICAL EFFLUENT CONTROL (REC) APPLICABILITY BASES RE Cs REC 12.0.1 REC 12.0.2 REC 12.0.1 through REC 12.0.6 establish the general requirements applicable to all RECs in Sections 12.1through12.5 and apply at all times, unless otherwise stated. REC 12.0.1 establishes the Applicability statement within each individual REC as the requirement for when the REC is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Requirement).

REC 12.0.2 establishes that upon discovery of a failure to meet a REC, the associated ACTIONS shall be met. The Completion Time of each Required *Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of a REC are not met. This Requirement establishes that: a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a REC; and b. Completion of the Required Actions is not required when a REC is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the REC must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the REC is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.)

The second type of Required (continued) 1-812.0-1 I

BASES REC 12.0.2 (continued)

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when a REC is met or is no longer applicable, unless otherwise stated in the individual RECs. The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be completed even though the associated Condition no longer exists. The individual REC's ACTIONS specify the Required Actions where this is the case. An example of this is in REC 12.4.2, "Dose from Noble Gases." The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally.

The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience.

Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead. Doing so limits the time both subsystems/divisions of a function are inoperable and limits the time conditions exist which may result in REC 12.0.3 being entered. Individual RECs may specify a time limit for performing a RSA when equipment is removed from service or bypassed for testing. In this case, the Completion Times of the Required Actions are applicable when this time limit expires, if the equipment remains removed from service or bypassed.

When a change in MODE or other specified condition is required to comply with Required Actions, the unit may enter a MODE or other specified condition in which another REC becomes applicable.

In this case, the Completion Times of the associated Required Actions would apply from the point in time that the new REC becomes applicable and the ACTIONS Condition(s) are entered. (continued) 1-812.0-2 BASES (continued)

REC 12.0.3 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls REC 12.0.3 establishes the actions that must be implemented when a REC is not met and: a. An associated Required Action and Completion Time is not met and no other Condition applies; or b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, possible combinations of Conditions are such that entering REC 12.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that REC 12.0.3 be entered immediately.

Upon entering REC 12.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to implement appropriate compensatory actions and verify the plant is not in an unanalyzed condition or that a required safety function is not compromised.

Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, Shift Operations Superintendent or designee approval of the compensatory actions and the plan for exiting REC 12.0.3 must be obtained.

The use and interpretation of specified times to complete the actions of REC 12.0.3 are cor:isistent with the discussion of Section 1.3, Completion Times. The actions required in accordance with REC 12.0.3 may be terminated and REC 12.0.3 exited if any of the following occurs: a. The REC is now met. b. A Condition exists for which the Required Actions have now been performed.

c. ACTIONS exist that do not have expired Completion Times. These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time REC 12.0.3 is exited. (continued) 1-812.0-3 BASES REC 12.0.3 (continued)

REC 12.0.4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls In MODES 1, 2, and 3, REC 12.0.3 provides actions for Conditions not covered in other Requirements.

The requirements of REC 12.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition.

The requirements of REC 12.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual RECs sufficiently define the remedial measures to be taken. REC 12.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an REC is not met. It precludes placing the unit in a MODE or other specified condition stated in that Applicability (e.g., Applicability desired to be when the following exist: a. Unit conditions are such that the requirements of the REC would not be met in the Applicability desired to be entered; and b. Continued noncompliance with the REC requirements, if the Applicability were entered, would result in the unit being required to exit the Applicability desired to be entered to comply with the Required Actions. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation.

This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions. The provisions of this REC should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of REC 12.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of REC 12.0.4 shall not prevent (continued) 1-812.0-4 BASES REC 12.0.4 (continued)

REC 12.0.5 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

Exceptions to REC 12.0.4 are stated in the individual RECs. The exceptions allow entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time. Exceptions may apply to all the ACTIONS or to a specific Required Action of a REC. Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by RSA 12.0.1. Therefore, changing MODES or other specified conditions while in an ACTIONS Condition, either in compliance with REC 12.0.4, or where an exception to REC 12.0.4 is stated, is not a violation of RSA 12.0.1 or RSA 12.0.4 for those Surveillances that do not have to be performed due to the associated inoperable equipment.

However, RSRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected REC. REC 12.0.4 is only applicable when entering MODE 3 from MODE 4, MODE 2 from MODE 3 or 4, or MODE 1 from MODE 2. Furthermore, REC 12.0.4 is applicable when entering any other specified condition in the Applicability only while operating in MODE 1, 2, or 3. The requirements of REC 12.0.4 do not apply in MODES 4 and 5, or in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Requirements sufficiently define the remedial measures to be taken. REC 12.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed f ram service or declared inoperable to comply with ACTIONS. The sole purpose of this Requirement is to provide an exception to REC 12.0.2 (e.g., to not comply with the applicable Required Action(s))

to allow the performance of required testing to demonstrate:

a. OPERABILITY of the equipment being returned to service; or (continued) 1-812.0-5 BASES REC 12.0.5 (continued)

REC 12.0.6 b. CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY.

This Requirement does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system. REC 12.0.6 establishes the applicability of each REC to both Unit 1 and Unit 2 operation.

Whenever a requirement applies to only one unit, or is different for each unit, this will be identified in the appropriate section of the REC (e.g., Applicability, RSR, etc.) with parenthetical reference, Notes, or other appropriate presentation within the body of the requirement.

1-812.0-6 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.0 ODCM RADIOLOGICAL SURVEILLANCE REQUIREMENT

{RSA) APPLICABILITY BASES RS Rs RSA 12.0.1 RSR 12.0.1 through RSA 12.0.5 establish the general requirements applicable to all Requirements in 12.1 through 12.5 and apply at all times, unless otherwise stated. RSA 12.0.1 establishes the requirement that RSRs must be met during the MODES or other specified conditions in the Applicability for which the requirements of the REC apply, unless otherwise specified in the individual RSRs. This REC is to ensure that RS Rs are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits. Failure to meet a RSA within the specified Frequency, in accordance with RSA 12.0.2, constitutes a failure to meet a REC. Systems and components are assumed to be OPERABLE when the associated RSRs have been met. Nothing in this RSA, however, is to be construed as implying that systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the RSRs; or b. The requirements of the RSR{s) are known to be not met between required RSA performances.

RSA do not have to be performed when the unit is in a MODE or other specified condition for which the requirements of the associated REC are not applicable, unless otherwise specified.

Unplanned events may satisfy the requirements

{including applicable acceptance criteria) for a given RSA. In this case, the unplanned event may be credited as fulfilling the performance of the RSA. (continued) 1-812.0-7 BASES RSA 12.0.1 (continued)

RSA 12.0.2 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls RSRs, including RSRs invoked by Required Actions, do not have to be performed on inoperable equipment because the ACTIONS define the remedial measures that apply. RSRs have to be met and performed in accordance with RSA 12.0.2, prior to returning equipment to OPERABLE status. Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE.

This includes ensuring applicable RSRs are not failed and their most recent performance is in accordance with RSA 12.0.2. Post maintenance testing may not be possible in the current MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established.

In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.

This will allow operation to proceed to a MODE or other specified condition where other necessary post maintenance tests can be completed.

RSA 12.0.2 establishes the requirements for meeting the specified Frequency for RSRs and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per ... " interval.

RSA 12.0.2 permits a 25% extension of the interval specified in the Frequency.

This extension facilitates RSA scheduling and considers plant operating conditions that may not be suitable for conducting the RSA (e.g., transient conditions or other ongoing RSA or maintenance activities).

The 25% extension does not significantly degrade the reliability that results f rem performing the RSA at its specified Frequency.

This is based on the recognition that the most probable result of any particular RSA being performed is the verification of conformance with the RSRs. As stated in RSA 12.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per ...

• basis. The 25% extension applies to each performance after the initial performance.

The initial performance of the Required Action, (continued) 1-812.0-8 BASES RSR 12.0.2 (continued)

RSR 12.0.3 CY-LA* 170-301 Revision 6 Part I, Radiological Effluent Controls whether it is a particular RSR or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the inoperable equipment in an alternative manner. The provisions of RSR 12.0.2 are not intended to be used repeatedly merely as an operational convenience to extend RSR intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

RSR 12.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a RSR has not been completed within the specified Frequency.

A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time it is discovered that the RSR has not been performed in accordance with RSR 12.0.2, and not at the time that the specified Frequency was not met. This delay period provides adequate time to complete RSRs that have been missed. This delay period permits the completion of a RSR before complying with Required Actions or other r'emedial measures that might preclude completion of the RSR. The basis for this delay period includes consideration of unit conditions, adequate plann!ng, availability of personnel, the time required to perform the RSA, the safety significance of the delay in completing the required RSA, and the recognition that the most probable result of any particular RSA being performed is the verification of conformance with the requirements.

When a RSA with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to each release, or in accordance with the Radioactive Liquid Waste Sampling and Analysis Program, etc.) is discovered to not have been (continued) 1-812.0-9 BASES RSA 12.0.3 (continued)

CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls performed when specified, RSA 12.0.3 allows for the full delay period of up to the specified Frequency to perform the RSA. However, since there is not a time interval specified, the missed RSA should be performed at the first reasonable opportunity.

RSA 12.0.3 provides a time limit for, and allowances for the performance of, RSRs that become applicable

• as a consequence of MODE changes imposed by Required Actions. Failure to comply with specified Frequencies for RSRs is expected to be an infrequent occurrence.

Use of the delay period established by RSA 12.0.3 is a flexibility which is not intended to be used as an operational convenience to extend RSR intervals.

While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed RSA, it is expected that the missed RSR will be performed at the first reasonable opportunity.

The determination of the first reasonable opportunity should include consideration of the.impact on plant risk (from delaying the RSA as well as any plant configuration changes required or shutting the plant down to perform the RSA) and impact on any analysis assumptions, in addition to unit conditions, planning, availability*of personnel, and the time required to perform the RSR. This risk impact should be managed through the program in to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown.

The missed RSR should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component.

Missed RSRs for important components should be analyzed quantitatively.

If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed RSRs will be placed in the station's Corrective Action Program. (continued) 1-812.0-10 BASES RSA 12.0.3 (continued)

RSA 12.0.4 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls If a RSA is not completed within the allowed delay period, then the equipment is considered inoperable or the variable then is considered outside the specified limits and the Completion Times of the Required Actions for the applicable REC Conditions begin immediately upon expiration of the delay period. If a RSA is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable REC Conditions begin immediately upon the failure of the RSA. Completion of the RSA within the delay period allowed by this RSA, or within the Completion Time of the ACTIONS, restores compliance with RSA 12.0.1. RSA 12.0.4 establishes the requirement that all applicable RSRs must be met before entry into a MODE or other specified condition in the Applicability.

This RSA ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit. The provisions of this RSA should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

However, in certain circumstances, failing to meet a RSA will not result in RSA 12.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated RSR(s) are not required to be performed per RSA 12.0.1 which states that RSRs do not have to be performed on inoperable equipment.

When equipment is inoperable, RSA 12.0.4 does not apply to the associated RSR(s) since the requirement for the RSR(s) to be performed is removed. Therefore, failing to perform the RSRs within the specified Frequency, on equipment that is inoperable, does not result in a RSA 12.0.4 restriction to changing MODES or other specified conditions of the Applicability.

However, since the REC is not met in this instance, REC 12.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. {continued) 1-812.0-11 BASES RSA 12.0.4 (continued)

RSA 12.0.5 CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls The provisions of RSA 12.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of RSA 12.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

The precise requirements for performance of RSRs are specified such that exceptions to ASA 12.0.4 are not necessary.

The specific time frames and conditions necessary for meeting the RSRs are specified in the Frequency, in the RSA, or both. This allows performance of RSRs when the prerequisite condition(s}

specified in a RSR procedure require entry into the MODE or other specified condition in the Applicability of the associated REC prior to the performance or completion of a RSA. A RSA that could not be performed until after entering the REC Applicability would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the RSA may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of RSRs' annotation is found in Section 1.4, Frequency.

RSA 12.0.4 is only applicable when entering MODE 3 from MODE 4, MODE 2 from MODE 3 or 4, or MODE 1 from MODE 2. Furthermore, RSA 12.0.4 is applicable when entering any other specified condition in the Applicability only while operating in MODE 1, 2, or 3. The requirements of RSA 12.0.4 do not apply in MODES 4 and 5, or in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Controls sufficiently define the remedial measures to be taken. RSA 12.0.5 establishes the applicability of each RSA to both Unit 1 and Unit 2 operation.

Whenever a requirement applies to only one unit, or is different for each unit, this will be identified with parenthetical reference, Notes, or other appropriate presentation within the RSA. 1*812.0-12 B 12.1 NOT USED CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls INTENTIONALLY BLANK 1-812.1*1 B 12.21NSTRUMENTATION CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.2.1 Radioactive Liquid Effluent Monitoring Instrumentation BASES The radioactive liquid effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents.

The alarm/trip setpoints for these instruments shall be calculated in accordance with the procedures in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of RECS. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63, and 64 of Appendix A to 10 CFR Part 50. 1-812.2.1-1 B 12.21NSTRUMENTATION CY-LA-170-301 . Revision 6 Part I, Radiological Effluent Controls B 12.2.2 Radioactive Gaseous Effluent Monitoring Instrumentation BASES The radioactive gaseous effluent monitoring instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents.

The alarm/trip setpoints for these instruments shall be calculated in accordance with the procedures in the ODCM to ensure that the alarm/trip will occur prior to exceeding the limits of RECS. 1-B 12.2.2-1 8 12.3LIQUID EFFLUENTS 8 12.3.1 Liquid Effluent Concentration BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site will be less than ten (10) times the concentration levels specified in Appendix 8, Table 2, Column 2 to 1 O CFR 20.1001-2402.

This limitation provides additional assurance that the levels of radioactive materials in bodies of water outside the site will result in exposure within ( 1) the Section II.A design objectives of Appendix I, 10 CFR 50, to an individual, and (2) the limits of 1 O CFR 20.1301 to the population.

In addition, this limit is associated with 40 CFR 14 which states concentration limits at the nearest downstream potable water supply. The results of the analyses of RSA 12.3.1.1, 12.3.1.2, and 12.3.1.3 shall be used with the calculational methods in the ODCM to assure that the concentrations at the point of release are maintained within the limits of this REC. Refer to Technical Specification 5.5.9.b for the definition of an outside temporary tank. 1-812.3.1-1 B.12.3 LIQUID EFFLUENTS B 12.3.2 Dose From Liquid Effluents BASES CY*LA-170*301 Revision 6 Part I, Radiological Effluent Controls This control is provided to implement the requirements of Sections II.A, Ill.A and IV.A of Appendix I, 10 CFR Part 50. The REC implements the guides set forth in Section II.A of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in liquid effluents will be kept "as low as is reasonably achievable." Also, for fresh water sites with drinking water supplies which can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR 141. The dose calculations in the ODCM implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated.

The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977. This control applies to the release of radioactive materials in liquid effluents from each reactor at the site. For units with shared radwaste treatment systems, the liquid effluents from the shared systems are proportioned among the units sharing that system. 1-612.3.2*1 B 12.3LIQUID EFFLUENTS B 12.3.3 Liquid Radwaste Treatment Systems BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The OPERABILITY of the liquid radwaste treatment system ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment.

The requirement that the appropriate portions of this system be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." A system bypass allows connection to portable waste treatment equipment.

This enables the efficient processing of liquid radwaste through the use of state-of-the-art radwaste processing technology.

The portable radwaste treatment system may be used in lieu of various portions of the liquid radwaste treatment system. When a portable waste treatment is not used, RSA 12.3.3.2 may be extended to 180 days. This control implements the requirements of 1 O CFR Part 50.36a. General Design Criterion 50 of Appendix A to 10 CFR Part 50 and the design objective given in Section 11.0 of Appendix I to 1 O CFR Part 50. The specified

.limits governing the use of appropriate portions of the liquid radwaste treatment system were specified as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR Part 50, for liquid effluents.

This specification implements Technical Specification Section 5.5.4.f for liquid effluents.

Page 1-812.3.3-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.1 Gaseous Effluent Dose Rates BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to ensure that the dose at any time at the site boundary from gaseous effluents from all units on the site will be within the annual dose limits of RECS for unrestricted areas. These limits provide reasonable assurance that radioactive material discharged in gaseous effluents will not result in the exposure of an individual*

in an unrestricted area, either within or outside the site boundary exceeding the limits specified in 10 CFR 20.1301. For individuals who at times be within the site boundary, the occupancy of the individual will be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the site boundary.

The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to an individual at or beyond the site boundary to less than or equal to a dose rate of 500 mrem/year to the total body or to less than or equal to a dose rate of 3000 mrem/year to the skin. These release rate limits also restrict, at all times, the corresponding thyroid dose rate above background via the inhalation pathway to less than or equal to a dose rate of 1500 mrem/year.

This control applies to the *release of radioactive effluents in gaseous effluents from all reactors at the site. For units within shared radwaste treatment systems, the gaseous effluents from the shared system are proportioned among the units sharing that system. Page 1-812.4.1-1 8 12.4GASEOUS EFFLUENTS AND TOTAL DOSE 8 12.4.2 Dose from Noble Gases BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to implement the requirements of Sections 11.B, Ill.A and IV.A of Appendix I, 1 O CFR Part 50. The Operability Requirements are the guides set forth in Section 11.B of Appendix I. The ACTION statements provide the required operating and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section Ill.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man fror Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977 and Regulatory Guide 1.111, for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1, July 1977. The ODCM equatiom provided for determining the air doses at the site boundary are based upon the historical average atmospheric conditions.

Page 1-812.4.2-1 CY-LA-170-301 . Revision 6 Part I, Radiological Effluent Controls B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.3 BASES Dose from lodine-131, lodine-133, Tritium and Radioactive Materials in Particulate Form The control is provided to implement the requirements of Sections 11.C, Ill.A and IV.A of Appendix I, 10 CFR Part 50. The operability requirements are the guides set forth in Section 11.C of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the Surveillance Requirements implement the requirements in Section lll:A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data, such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated.

The ODCM calculational methods* for calculating the doses due to the actual release rates of the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, "Revision 1, October 1977 and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions.

The release rate specifications for radioiodines, radioactive materials in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area. The pathways which were examined in the development of these calculations were: 1 )" individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, 3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposition on the ground with subsequent exposure of man. Page 1-812.4.3-1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.4 GASEOUS RADWASTE TREATMENT (OFF-GAS)

SYSTEM BASES The OPERABILITY of the GASEOUS RADWASTE TREATMENT SYSTEM ensures that the system will be available for use whenever gaseous effluents require treatment prior to release to the environment.

The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable".

This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 1 O CFR Part 50, and the design objectives given in Section 11.0 of Appendix I to 1 O CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections 11.B and 11.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

Page 1-B 12.4.4-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.5 VENTILATION EXHAUST TREATMENT SYSTEM BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls The OPERABILITY of the VENTILATION EXHAUST TREATMENT SYSTEM ensures that the system will be available for use whenever gaseous effluents require treatment prior to release to the environment. The requirement that the appropriate portions of these systems be used, when specified, provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable".

This specification implements the requirements of 10 CFR Part 50.36a, General Design Criterion 60 of Appendix A to 1 O CFR Part 50, and the design objectives given in Section 11.0 of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the systems were specified as a suitable fraction of the dose design objectives set forth in Sections 11.B and 11.C of Appendix I, 10 CFR Part 50, for gaseous effluents.

This control implements Technical Specification 5.5.4.f for gaseous effluents.

Page 1-812.4.5-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.6 MARK II CONTAINMENT BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control provides reasonable assurance that releases from drywell purging operations will not exceed the annual dose limits of 1 O CFR 20 for unrestricted areas. Based on definition, VENTING would not release a volume resulting in significant contribution to gaseous plant effluents, nor resultant offsite dose. As such, there is no ODCM requirement for sampling.

Sampling is required for PURGING, however, since the entire drywall volume is potentially released.

Sampling prior to conducting a drywall PURGE provides a pre-release check to ensure release limits will not be exceeded, and allows for the subsequent calculation of offsite dose as a result of the drywall purge. Once the Unit is sub-critical following shutdown, the initial 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> purge will exchange multiple volumes of the drywall removing the pre-existing noble gas concentration, and the lack of any source term will yield no new concentration.

Likewise, there will be no source term until criticality has been achieved following startup. Page 1-812.4.6-1 8 12.4 GASEOUS EFFLUENTS AND TOTAL DOSE 8 12.4.7 Total Dose BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control is provided to meet the dose limitations of 40 CFR 190. The specification requires the preparation and submittal of a report whenever the calculated doses from plant radioactive effluents exceed twice the design objective doses of Appendix I. For sites containing up to 4 reactors, it is highly unlikely that the resultant dose to a member of the public will exceed the dose limits of 40 CFR 190 if the individual reactors remain within the reporting requirement level. The report will describe a course of action that should result in the limitation of dose to a member of the public for 12 consecutive months to within the 40 CFR 190 limits. For the purpose of the report, it may be assumed that the dose commitment to the member of the public from other uranium fuel cycle sources is negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 5 miles must be considered.

If the dose to any member of the public is estimated to exceed the requirements of 40 CFR 190, the report with a request for a variance (provided the release conditions resulting in violation of 40 CFR 190 have not already been corrected), in accordance with the provisions of 40 CFR 190.11 , is considered to be a timely request and fulfills the requirements of 40 CFR 190 until NRC staff action is completed.

The variance only relates to the limits of 40 CFR 190, and does not apply in any way to the requirements for dose limitation of 10 CFR Part 20, as addressed in other sections of the RECS. An individual is not considered a member of the public during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle. Page 1-812.4.7-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.8 Main Condenser BASES CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control provides reasonable assurance that the releases from the main condenser will not exceed the requirements of the LaSalle Technical Specifications 3.7.6. In addition, a sample is required within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if the increase is not due to thermal power changes. If the cause is known and not fuel related and less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in duration, then no sample is required.

[This is based on a letter from W. R. Huntington to Operating Engineers, Shift Engineers and F.R. Lawless, dated May 24, 1984.] Page 1-912.4.8-1 B 12.4GASEOUS EFFLUENTS AND TOTAL DOSE B 12.4.9 Dose Limits for MEMBERS OF THE PUBLIC BASES CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls This control applies to direct exposure of radioactive materials as well as radioactive materials released in gaseous and liquid effluents.

10 CFR 20.1301 sets forth the 100 mrem/year dose limit to members of the public; 2 mrem in any one-hour limit in the unrestricted area; and reiterates that the licensee is also required to meet the 40 CFR 190 standards.

10 CFR 20.1302 provides options to determine compliance to 1 O CFR 20.1301. Compliance to the above operability requirement is based on 1 O CFR 20, 40 CFR 190 and LaSalle Station Technical Specification 5.5.4.g. The Effluents Program shall implement monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters of the ODCM. Page 1-812.4.9-1 CY*LA-170-301 Revision 6 Part I, Radiological Effluent Control:;

B 12.5RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.1 Radiological Environmental Monitoring Program BASES The Radiological Environmental Monitoring Program required by this section provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation.

This monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50 and thereby supplements the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring.

The initially specified monitoring program will be effective for at least the first 3 years of commercial operation.

Following this period, program changes may be initiated based on operational experience.

The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs required by Table R 12.5.1-3 are considered optimum for routine environmental measurements in industrial laboratories.

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

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, LA., "Limits for Qualitative Detection and Quantitative Determination

-Application to Radiochemistry," Anal. Chem. 40, 586-93 (1968), and Hartwell, J.K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). Table R12.5.1-1 requires "one sample of each community drinking water supply downstream of the plant within 1 O kilometers." Drinking water supply is defined as water taken from rivers, lakes, or reservoirs (not well water) that is used for drinking.

Page 1-812.5.1-1 CY *LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.2 Land Use Census BASES This control is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCM are made it required by the results of this census. This census satisfies the requirements of Section IV.B.3 of Appendix I to 1 O CFR Part 50. An annual garden census will not be required since the licensee will assume that there is a garden at the nearest residence in each sector for dose calculations.

Page 1-812.5.2-1 CY *LA* 170-301 Revision 6 Part I, Radiological Effluent Controls B 12.5RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.3 lnterlaboratory Comparison Program BASES The requirement for participation in an lnterlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental samples matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50. Page 1-812.5.3* 1 CY-LA-170-301 Revision 6 Part I, Radiological Effluent Controls B 12.5RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM B 12.5.4 Meteorological Monitoring Program (NOT APPLICABLE)

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