Text

Radiological Effluent Tech Specs for Facility,Revising Tech Spec Sections a & B
	ML19329D802
Person / Time
Site:	Davis Besse
Issue date:	03/16/1979
From:	; TOLEDO EDISON CO.
To:	;
Shared Package
ML19282C207	List: ML19282C206; ML19329D800; ML19329D801; ML19329D802;
References
	NUDOCS 8003180316
	Download: ML19329D802 (80)
	v • d • e

____ . . _ . .

Delete and/or insert, as indicated, the following pages of Appendix A to

, ehe Facility Operating License NPF-3.

.j DELETE INSERT DELETE INSERT I I 3/4 12-1 II II 3 /4 12-2

] IV IV 3/4 12-3

,XIII XIII 3 /4 12-4 XVI XVI 3/4 12-5 3/4 12-6

. 1-6 1-6 3/4 12-7

, 1-7 1-7 3 /4 12-8 1-8 1-8 3 /4 12- 9

\- 1-9 3/4 12-10 3/4 12-11 -

3/4 3-57 3/4 12-12 ,

\ 3/4 3-58 B 3/4 3-6 3/4 3-59 3/4 3-60 B 3/4 11-1 3/4 3-61 B 3/4 11-2 3/4 3-62 B 3/4 11-3 3/4 3-63 B 3/4 11-4 3/4 3-64 B 3/4 11-5 3/4 3-65 B 3/4 11-6 3/4 3-66 .

s 3/4 3-67 B 3/4 12-1 3/4 3-68 3/4 3-69 6-1 6-1 3/4 3-70 3/4 3-71 6-5 6-5 3/4 3-72 6-7 6-7 3/4 11-1 6- 13 6- 13 i

3/4 11-2 l 3/4 11-3 6-15 6- 15 j

3/4 11-4 3/4 11-5 6-17 6-17 3/4 11-6 3/4 11-7 6-18 6-18 3/4 11-8 i

3/4 11-9 6-19 6-19 3/4 11-10 3/4 11-11 6-20 6-20 3/4 11-12 3/4 11-13 6-21

, 3/4 11-14 6-22 3/4 11-15 -

6-23 3/4 11-16 3/4 11-17

' '( 3/4 11-18 3/4 11-19 3/4 11-20 gooMo3lk Revised 3/8/79

INDEX DEFINITIONS SECTION PAGE 1.0 DEFINITIONS DEFINED TERMS . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 THERMAL POWER . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 RATED T'HERMAL POWER . . . . . . . . . . . . . . . . . . . . . . . 1-1 OPERATIONAL MODE ........................ 1-1 ACTION . ........ ................... 1-1 OPERABLE - OPERABILITY ..................... 1-1 REPORTABLE OCCURENCE ...................... 1-2

} CONTAINMENT INTEGRITY . . . . . . . . . . . . . . . . . . . . . . 1-2 -

CHANNEL CHECK . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 CHANNEL FUNCTIONAL TEST . . . . . . . . . . . . . . . . . . . . . 1-3 CORE ALTERATION . . . . . . ................... 1-3 SHUTDOWN MARGIN . . . . . . . . . . . . . . . . ......... 1-3 f IDENTIFIED LEAKAGE ....................... 1-3 UNIDENTIFIED LEAKAGE ...................... 1-4 PRESSURE BOUNDARY LEAKAGE . . . . . . . . . . .'. . . . . . . . . 1-4 CONTROLLED LEAKAGE ....................... 1-4 QUADRANT POWER TILT . . . . . . . . . . . . . . . . . . . . . . . 1-4 DOSE EQU IVALENT I-131 . . . . . . . . . . . . . . . . . . . . . . 1-4

) E-AVERAGE DISINTEGRATION ENERGY . ................ 1-4 STAGGERED TEST BASIS ...................... 1-5 FREQUENCY NOTATION ....................... 1-5 AXIAL POWER IMBALANCE . . . . . . . . . . . . . . . . . . . . . . 1-5 SHIELD BUILDING INTEGRITY . . . . . . . . . . . . . . . . . . . . 1-5 REACTOR PROTECTION SYSTEM RESPONSE TIME . . . . . . . . . . . . . 1-5 i SAFETY FEATURE RESPONSE TIME .................. 1-6 l

PHYSICS TESTS . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6 l

l STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM RESPONSE TIME .... 1-6 l '

SOURCE CHECK .......................... 1-6 l y -

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n A A DAVIS-BESSE, UNIT 1 I i

.. e INDEX DEFINITIONS SECTION PAGE 1.0 DEFINITIONS (Continued)

. , y : M -

2 PROCESS CONTROL PROGRAM (PCP) . . . . . . . . . . . . . . . . . 1-6 SOLIDIFICATION 1-6 (

p ........................

!. OFFSITE DOSE CALCULATION MANUAL (0DCM) ........ .... 1-7

,, (/GASEOUSRADWASTETREATMENTSYSTEM....... 1-7 1-7 l (VENTILATIONEXHAUSTTREATMENTSYSTEM -

, OPERATIONAL MODES (TABLE 1.1) . . . . . N......q 1-8 FREQUENCY NOTATION'(TABLE 1.2) ................ 1-9 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS

', SECTION PAGE 2.1 SAFETY LIMITS Reactor Core ......................... 2-1

. Reactor Coolant System Pressure . . . . . . . . . . . . . . . . 2-1 2.2 LIMITING SAFETY SYSTEM SETTINGS Reactor Protection System Setpoints . . . . . . . . . . . . . . 2-4 BASES SECTION PAGE 2.1 SAFETY LIMITS l Reactor Core ......................... B 2-1 Reactor Coolant System Pressure . . . . . . . . . . . . . . . . B 2-3 2.2 LIMITING SAFETY SYSTEM SETTINGS Reactor Protection System Setpoints . . . . . . . . . . . . . . B 2-4 DAVIS-BESSE, UNIT 1 II

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INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS SECTION PAGE 7

j 3/4.2 POWER DISTRIBUTION LIMITS

,_. 3/4.2.1 AXIAL POWER IMBALANCE ................. 3/4 2-1 I 3/4.2.2 NUCLEAR HEAT FLUX HOT CHANNEL FACTOR - F ................. 3/4 2-4 Q

3/4.2.3 NUCLEAR ENTHALPY RISE

- HOT CHANNEL FACTOR - F /4 -6 H...............

, 3/4.2.4 00ADRANT POWER TILT .................. 3/4 2-8 3/4.2.5 DNB PARAMETERS . . . . . . . . . . . . . . . . . . . . . 3/4 2-11

, 3/4.3 INSTRUMENTATION 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION ....... 3/4 3-1 r 3/4.3.2 SAFETY SYSTEMS INSTRUMENTATION j Safety Features Actuation System . .... ....... 3/4 3-9 Steam and Feed Rupture Control System ......... 3/4 3-23 3/4.3.3 MONITORING INSTRUMENTATION Radiation Monitoring Instrumentation . . . ....... 3/4 3-31 Incore Detectors . . . . . . . . . . . . . . . . . . . . '3/4 3-35 Seismic Instrumentation ................ 3/4 3-37 Meteorological Instrumentation . . . . . . . . . . . . 3/4 3-40 Remote Shutdown Instrumentation ............ 3/4 3-43

, Post-Ac'cident Instrumentation ............. 3/4 3-46 r- Chlorina Detection Systems . . . . . . . . . . . . . . . 3/4 3-51 i

l Fire Detection Instrumentation . . . . . . . . ..... 3/4 3-52 Radioactive Liquid Effluent Instrumentation ...... 3/4 3-57 h (Radioactive Gaseous Effluent 3/43-65'/

= x Instrumentation . . . . . .

x

J 3/4.4

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REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS ................. 3/4 4-1 L 3/4.4.2 SAFETY VALVES - SHUTDOWN . ............... 3/4 4-3 3/4.4.3 SAFETY VALVES - OPERATING ............... 3/4 4-4 L ,

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- DAVIS-BESSE, UNIT 1 IV

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INDEX BASES 3ECTION PAGE

,i c- 'I 3/4.9.6 FUEL HANDLING BRIDGE OPERABILITY . . . . . . . . . . . . B 3/4 9-2 3/4.9.7 CRANE TRAVEL - FUEL HANDLING BUILDING . . . . . . . . . . B 3/4 9-2 3/4.9.8 COOLANT CIRCULATION . . . . . . . ......... . . B 3/4 9-2 3/4.9.9 CONTAINMENT PURGE AND EXHAUST ISOLATION ' -TEM .. . . . B 3/4 9-2 3/4.9.10 and 3/4.9.11 WATER LEVEL - REACTOR VESSEL AND STORAGE POOL WATER LEVEL ................ B 3/4 9-2 3/4.9.12 STORAGE P0OL VENTILATION ................ B 3/4 9-3 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.' GROUP HEIGHT, INSERTION AND POWER DISTRIBUTION LIMITS . . . . . . . . . . . . . . . . B 3/4 10-1 3/4.15.2 PHYSICS TESTS . . . . . . . . . . . . . . . . . . . . . . B 3/4 10-1 3/4.10.3 REACTOR COOLANT LOOPS . . . . . . . . . . . . . . . . . . B 3/4 10-1 3/4.10.4 SHUTDOWN MARGIN . .................... B 3/4 10-1 W ~ ^

3/4.11 RADI0 ACTIVE EFFLUENTS .

1 3/4.11.1 LIQUID EFFLUENTS 11-1 h

3/4.11.2 GASEOUS EFFLUEf'TS . . . . . . . . . . . . . . . . .. . ..- 11-9 }

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k3/4.11.3 SOLID RADI0 ACTIVE WASTE . . . . . . . . . . . . . . . . . . . 11-20

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3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING b 3/4.12.1 MONITORING PROGRAM ..................... 12-1 1

l 3/4.12.2 LAND USE CENSUS . . . . . . . . . . . . . . . . . . . . . . . 12-8

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INDEX ADMINISTRATIVE CONTROLS r

SECTION PAGE

-- Meeting Frequency . . . . . . ................. 6-9 i

Quorum . . . . . . . . . . . . ................. 6-9 I Review . . . . . . . . . . . . ............ ..... 6-10 Audits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11 r-Authority . . . . . . . . . . ......... . . . ..... 6-12 r- Records . . . . . . . . . . . ........... .. .... 6-12 I. .

6.6 REPORTABLE OCCURRENCE ACTION . . ................ 6-12 6.7 SAFETY LIMIT VIOLATION . . . . ........ . . . . ..... 6-13 6.8 PROCEDURES . . . . . . . . . . . . . . . . . . . . . . ..... 6-13 6.9 REPORTING REOUIR'EMENTS 6.9.1 ROUTINE AND REPORTABLE OCCURRENCES . . . . . . . . . . . . . . . 6-14 6.9.2 SPECIAL REPORTS . . . . . . . ... .............. 6-20 l

- L 6.10 RECORD RETENTION . . . . . . . ....... . . . . . .... 6-22 )

6.11 RADIATION PROTECTION PROGRAM . . . . . . . . . . .. . ....'. 6-23 6.12 HIGH RADIATION AREA . . . . . ............... . 6-23

_ 6.13 PROCESS CONTROL PROGRAM (PCP) ................. 6-24 1 6.14 0FFSITE DOSE CALCULATION MANUAL ................ 6-24 g

' = A A A A A

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-- DAVIS-BESSE, UNIT 1 XVI l-

'DEFINITI0"5

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[ SAFETY FEATURE RESPONSE TIME 1.26 The SAFETY FEATURE RESPONSE TIME shall be that time interval frem when the monitored parameter exceeds its SFAS actuation setpoint at the

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<- channel sensor until tne SF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, I pump discharge pressures reach their required values,'etc.). Times shall include diesel generator starting and sequence loading delays where applicable.

e-PHYSICS TESTS 1.27 PHYSICS TESTS shall be those tests performed to measure the funda-mental nuclear characteristics of the reactor core and related instru-

- mentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized j under the provisions of 10 CFR 50.59, or 3) otherwise approved by the Commission.

STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM RESPONSE TIME 7

1.28 The STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM RESPONSE TIME shal'.

- be that time interval-from when the monitored parameter exceecs its SFRCS actuation setpoint at the channel sensor until the equipment is

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capable of performing its safety function' (i.e. , the valves travel to

- their required positions, pump discharge pressures reach their required values,etc.).

1 0URCE CHECK

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f w 1.29 A SOURCE CHECK shall be the observation of channel upscale response when the channel sensor is exposed to a radioactive source.

> PROCESS CONTROL PROGRAM

- 1.30 A PROCESS CONTROL PROGRAM (PCP) shall provide details for the sampling, analysis, and evaluation from which SOLIDIFICATION of radioactive wastes from liquid systems is assured.

SOLIDIFICATION 1.31 SOLIDIFICATION shall be the conversion of radioactive wastes from liquid systems to an immobilized solid with definite volume and shape, bounded by a stable surface of distinct outline on all sides (free-standing).

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DEFINITIONS f

DOSE CALCULATION MANUAL (0DCM) l.32 The 0FFSITE DOSE CALCULATION MANUAL (0DCM) shall be a manual

- containing the methodology and parameters to be used in the calculation l of offsite doses due to radioactive gaseous and liquid effluents and in

'2 the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints. Requirements of the ODCM are provided in

[' Specification 6.14.

r- GASEOUS RADWASTE TREATMENT SYSTEM 1.33 The GASE0US RADWASTE TREATMENT SYSTEM is a system that is designed

-, and installed to reduce radioactive gaseous effluents by collecting

!! primary coolant system offgases and providing for decay for the purpose of reducing the total radioactivity prior to release to the environrent.

-

i fj VENTILATION EXHAUST TREATMENT SYSTEM 1.34 A VENTILATION EXHAUST TREATMENT SYSTEM is a system that is designed d and installed to reduce radioactive material in particulate form in .

'~, - effluents by passing ventilation or vent exhaust gases through HEPA 7- filters for the purpose of removing particulates from the gaseous exhaust lx stream prior to the release to the environment. Engineered Safety j Feature (ESF) atmosphe'ric cleanup systems are not considered to be /

VENTILATION EXHAUST TREATMENT SYSTEM components.

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TABLE 1.1 OPERATIONAL MODES r

REACTIVITY % RATED AVERAGE C 0LANI MODE CONDITION, K THERMAL POWER

TEMPERATURE _

J~ eff 6.

1. POWER OPERATION 3,0.99 > 5% > 280*F

2. STARTUP 3,0.99 < 5% 3,280*F

3. HOT STANDBY < 0.99 0 3,280*F J-1 '

4. HOT SHUTDOWN < 0.99 0 280*F > T avg > 200*F

5. COLD SHUTDOWN < 0.99 0 < 200*F k ,

-, 6. REFUELING ** < 0.95 0 < 140* F u

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Excluding decay heat.

F Reactor vessel head unbolted or removed and fuel in the vessel.

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[ TABLE 1.2 r FREQUENCY NOTATION

- NOTATION FREQUENCY c

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

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

['

D W At least once per 7 days.

e-M At least once per 31 days.

l

- Q At least once per 92 days.

SA At least once per 6 months.

I' R At least once per 18 months.

S/U Prior to each reactor startup.

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[- IP , Prior to each release w - _ _

r- N.A. Not applicable L

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INSTRUMENTATION RADI0 ACTIVE LIOUID EFFLUENT INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive licuid effluent monitoring instrumentation channels

[. shown in Table 3.3-15 shall 'be OPERABLE with their alarm / trip setpoints set

'; to ensure that the limits of Specification 3.11. 1 are not exceeded.

4 APPLICABILITY: As shown in Table 3.3-15.

l ACTION:

e

[ a. With a radioactive liquid effluent monitoring instrumentation channel alarm / trip setpoint less conservative than a value shown in the ODCM, suspend the release of radioactive liquid effluents

f. monitored by the affected channel or declare the channel inoperable.

b. With less than the minimum recuired radioactive liquid effluent 1_ monitoring instrumentation channels operable, take the ACTION L

shown in Table 3.3-15. [

c. With less than the minimum requircd radioactive liquid effluent

,M monitoring instrumentation channels operable beyond the continuation period specified in the applicable ACTION statement, precare and submit to the Cc= mission within 30 days, pursuant to Specification 6.9.2, a

' Special Report, in lieu of any other report, which identifies the cause(s), defines corrective actions to be taken to restore operability.

and provides an estimated date for return to OPERABLE status of the instrumentation channel (s). Effluent releases via this pathway may continue subject to the analysis and monitoring conditions of the a 71icable ACTION statement.

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

SURVEILLANCE REOUIREMENTS

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4.3.3.9 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE n CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations during the MODES and at the frequencies shown in Table 4.3-15.

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TABLE 3.3-15 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM c

CllANNELS y INSTRUMENT OPERABLE APPLICABILITY ACTION

1. Gross Radioactivity Monitors Providing Automatic Termination of Release ,

f a. Liquid Radwaste Effluent Line . (1) 18

{

2. Gross Radioactivity Monitors Not Providing Automatic Termination y of Release u

y a. Turbine Building (Floor Drains) g; Sumps Effluent Line 1 (2) 19

b. Condensate Demineralizer Backwash Receivino Tank Effluent Line 1 (2) 19

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TABLE 3.3-15 (Centinued)

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RADI0 ACTIVE LIQUID EFTLUENT M0flITORING INSTRUMENTATION MINIMUM CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTI0tl

3. Flow Rate Measurement Devices (3) y a. Liquid Radwaste Effluent Line 1 (1) 20

b. Dilution flow to Collection Box 1 (1) 20

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4. Tank Level Indicating DevicesI4)

a. Primary Water Storage Tank 1 (1) 21 N _ , -

p TABLE 3.3-15 (Continued)

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TABLE NOTATION 1

(1) During radioactive releases via this pathway P

(2) During radioactive releases via this pathway when condensate system activity exceeds 1 x 10-3 pCi/ml.

! (3) Pump curves may be used to estimate flow; in such cases, action statement 20 is not required.

r

{ (4) Tank (s) included in this Specification are those outdoor tank (s) that are not surrounded by liners, dikes, or walls capable of holding the tank contents. If a retaining dike is completed for a tank in this category, the Specification will cease to apply.

ACTION 18 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may be

. resumed for up to 14 days, provided that prior to initiating a release:

1. At least two independent samples are analyzed in accordance with Specification 4.11.1.1.3 for analyses performed with each batch; n

2. At 1sast two independent verifications of the release rate calculations are performed;

. 3. At least two independent verifications of the discharge valving are performed; Otherwise, suspend release of radioactive effluents via this pathway.

ACTION 19 With the numbers of channels OPERABLE less than required by the f Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided that at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months grab samples are collected and analyzed for gross radioactivity (beta or gamma) at a lower limit of detection of at least 10 7 uCi/ml for Cs-137.

g ACTION 20 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 14 days provided the flow rate is estimated at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during actual releases.

ACTION 21 With the numbers of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, liquid additions to this k_ tank may continue for up to 28 days provided the tank liquid level is estimated during all liquid additions to the tank.

DAVIS-BESSE, UNIT 1 3/4 3-60

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TABLE 4.3-15 RADI0 ACTIVE LIQUID EFFLUENT h0NITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CilANNEL SOURCE CHANNEL FUNCTIONAL INSTRUMENT CHECK CHECK CALIBRATION TEST

1. Gross Beta or Gansna Radioactivity Monitors Providing Alarm and iR Automatic Isolation

a. Liquid Radwaste Effluents Line }

D P R(5) g(3)

In

2. Gross Beta or Gamma Radioactivity Monitors Providing Alarm But Not Providing Automatic Isolation

a. Turbine Building (Floor Drains)

Sumps Effluent Line D(1) Q R(5) Q(4)

b. Condensate Demineralizer Backwasy Receiving Tank Effluent Line D(1) Q R(5) Q(4)

3. Tank Level Monitors (for tanks (7) outside the building)

a. Primary Water Storage Tank D(2} N.A. R Q o

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RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS E

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CHANNEL h

oi CHANNEL SOURCE CHANNEL FUNCTIONAL INSTRUMENT CilECK

-1 CHECK CALIBRATION TEST

5. Flow Rate Monitors -

l a. Liquid Radwaste Effluent Line D N.A. R Q

b. Dilution Flow to Collection Box }

0 N.A. R Q e

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,_ TABLE 4.3-15 (Continued) l TABLE NOTATION r

l r (1) During releases via this pathway.

(2) During liquid additions to the tank.

i (3) The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic F isolation of this pathway and control room alarm annunciation L occurs if the instrument indicates measured levels above the alarm / trip setpoint.

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(4) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if the instrument indicates measured f

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levels above the alarm / trip setpoint.

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(5) The initial CHANNEL CALIBRATION' for radioactivity measurement instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These

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standards should permit calibrating the system over its intended s range of energy and rate capabilities. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibra-tion should be used, at intervals of at least once per eighteen months.

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l DAVIS-BESSE, UNIT 1 3/4 3-63 l .-

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7 TABLE 4.3-15 (Continued) l r

{ (6) CHANNEL CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once daily

,- on any day on which continuous, periodic, or batch releases are made.

i

_ (7) Tank (s) included in this Specification are those tank (s) that are ,

not surrounded by liners, dikes, or walls capable of holding the tank contents. If a retaining dike is completed for a tank in this category, the Specification will cease to apply. ./

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RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION f~'

LIMITING CONDITION FOR OPERATION

- 3.3.3.10 The radioactive gaseous process and effluent monitoring instrumentation channels shown in Table 3.3-16 shall be OPERABLE with their alarm / trip setpoints set to ensure that the limits of Specification 3.11.2.1 are not exceeded.

I t APPLICABILITY: As shown in Table 3.3-16.

r ACTION:

I i

a. With a radioactive gaseous process or effluent monitoring

- instrumentation channel alarm / trip setpoint less conservative than a value which will ensure that the limits of 3.11.2.1 are met, declare the channel inoperable.

b. With less than the minimum required radioactive gaseous crocess or effluent ronitoring instrumentation channels operable, take the p- ACTION shown in Table 3.3-16.

c. With less than the minimum required radioactive liquid effluent monitoring instrumentation channels ;perable beyond the continuation i_f- period specified in che aDplicable ACTION statement, prepare and Ls. N submit to the Commission within 30 days, persuant to Specification 6.9.2 a Special Report, in lieu of any other report, which identifies the T~ cause(s), defines corrective actions to be taken to restore operability, L and provides an estimated date for return to CPERABLE status of the instrumentation channel (s). Effluent releases via this pathway may continue subject to the analysis and monitoring conditions of the applicable ACTION statement.

d. The provisions of Specifications 3.0.3 and 3.0.4 are not

s. applicable.

SURVEILLANCE REOUIREMENTS.

L, \ 4.3.3.9 Each radioactive gaseous process or effluent monitoring sj instrumentation channel shall be demonstrated OPERABLE by performance

f the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL

'NCTIONAL TEST operations at the frequencies shown in Tabie 4.3-16.

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x' DAVIS-BESSE Uh

1 3/4 3-65

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TABLE 3.3-16 RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION .

Y MINIMUM

$ CHANNELS g INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTIO

. 1. Waste Gas Decay System e

- a. Noble Gas Activity Monitor 1 (1) Radioactivity 25 Measurement

b. Effluent System Flow Rate 1 .

(1) System Flow Rate 26 Measuring Device Measurenent

2. Waste Gas Surge Tank

a. Oxygen Monitor I (2) % 0xygen 28

Y

3. Containment Purge Monitoring System

, a. Noble Gas Activity Monitor 1 (1) Radioactivity 27 Measurenent

b. Effluent System flow itate 1 (1) System Flow Rate 26 Measuring Device Measurement (Continued)

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m y' m y -

C

,N TABLE 3.3-16 (Continued)

E RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION Z

MINIMUM ,

CilANNELS INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTION

4. Station Vent Stack ,

a. Noble Gas Activity Monitor 1 (1) Radioactivity 27 Measurement

b. Iodine Sanpler Cartridge 1 (1) Verify presence of 29 R cartridge a

m c. Particulate Sempler Filter 1 (1) Verify presence of 29 a

u fil ter i

d. Effluent System Flow 1 (1) System Flow Rate 26 Rate Measuring Device Measurement t

e. Sampler Flow Rate Measuring 1 (1) Sampler flow Rate 26 Device Measurement

N A_

I K

TABLE 3.3-16 (Continued)

TABLE NOTATION i

(1) During radioactive waste gas releases via this pathway.

(2) During additions to the waste gas surge tank ACTION 25 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents -

of the tank may be released to the environment for up to 14 days provided that prior to initiating the release:

. 1. At least two independent samples are analyzed in l

accordance with Specification 4.11.2.1.3 for analyses per#)rmed with each batch;

2. At least two independent verifications of the release rate calculations are performed; t' 3. At least two independent verifications of the discharge L valving are performed; I ACTION 26 With the number of channels OPERABLE less than required by

/ the Minimum Channels OPERABLE requirement, effluent releases f I via this pathway may continue for up to 28 days provided the

[,

flow rate is estimated at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

L.

r ACTION 27 With the number of channels OPERABLE less than required by n the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue for up to 28 days provided grab f samples are taken at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and these samples are analyzed for gross activity within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ACTION 28 With the number of channels OPERABLE less than required by the

- Minimum Channels OPERABLE requirement, additions to the waste gas surge tank may continue for up to 14 days provided another method for ascertaining oxygen concentrations, such as grab sample analysis, is implemented to provide measurements at least once per four (4) hours.

_\

uie DAVIS-BESSE, UNIT 1 3/4 3-68

=

I'

'l

~

j TABLE 3.3-16 (Continued)

ACTION 29 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent i~ releases via this pathway may continue provided samples

.! are continuously collected with auxiliary sampling I equipment for periods on the order of seven (7) days r

and analyzed within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of the end of sample coll ec. tion.

t' 1

!~

.m i

Ir A

u f~

L p.

6 i

L=

w

, DAVIS-BESSE, UNIT 1 3/4 3-69

q = rm i

r ~ ~ ,

-- 7 --~1 -( -!

_ [

~

TABLE 4.3-16 k

0;

- RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS E

U CilANNEL CilANNEL SOURCE CilANNEL FUNCTIONAL INSTRUMENT CilECK CllECK CALIBRATION TEST l

1. Waste Gas Decay System -

a. Noble Gas Activity Monitor P(I} P R(5) q(3)

$ b. Effluent System Flow Rate P U} N/A R Q Y

y 2. Waste Gas Surge Tank

a. Oxygen Monitor D I2) N/A Q(6) gf3

3. Containnent Purg: Vent System

a. Noble Gas Activity Monitor D(I P R(5) Q(3)

b. Effluent System Flow Rate Measuring Device D(j) N/A R Q

+

(Continued ...)

l 4

,- --_----m--- . . .

-w 9 ~

h _

=

." TABLE 4.3-16 (Continued)

RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CilANNEL CIIANNEL '

SOURCE CilANNEL FUNCTIONAL INSTRUMENT CilECK CllECK CALIBRATION TEST

4. Station Vent Stack

a. Noble Gas Activity Monitor D III M R(5) Q(4) g b. Iodine Sampler W II) N/A N/A N/A

c. Particulate Sampler W(1) N/A N/A N/A d d. System Effluent Flow Rate Measurement Device D(j) N/A R N/A

e. Sampler Flow Rate Measurement Device W{j) N/A R N/A (Continued . . .)

r .. .-

W*

f i

TABLE 4.3-16 (Continued)

F l

TABLE NOTATION I.

(I} During radioactive waste gas releases via this pathway, i

(2) During additions to the waste gas surge tank.

() The CHANNEL FUNCTIONAL TEST shall also demonstrate that automatic isolation of this pathway and control room alarm annunciation p occurs if the instrument indicates measured levels above the alarm / trio setpoint.

[

r () The CHANNEL FUNCTIONAL TEST shall also demonstrate that control

room alarm annunciation occurs if the instrument indicates measured levels above the alarm / trip setpoint.

(5) The initial CHANNEL CALIBRATION for radioactivity measurement I instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards should permit calibrating the system over its intended range of energy and rate capabilities. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration should be used, at intervals of at least once per

( eighteen months. This can normally be accomplished during h refueling outages.

(0) The CHANNEL CALIBRATION shall include the use of standard gas samples y containing a nominal:

1. One volume percent oxygen, balance nitrogen; and f 2. Four volume percent oxygen, balance nitrogen.

e t-DAVIS-BESSE, UNIT 1 3/4 3-72

-r Y [3/4.11RADI0 ACTIVE EFFLUENTS

( 3/4.11.1 LIOUID EFFLUENTS CONCENTRATION LIMITING CONDITION FOR OPERATION 3.11.1.1 The concentration of radioactive material released at anytime I from the site to unrestricted areas (see Figure 3.11-1) shall be limited to the concentrations specified in 10 CFR Part 20, Appendix B, Table II, f Column 2 for radionuclides other that dissolved or entrained noble gases.

For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10% uCi/ml total activity.

- APPLICABILITY: At all times.

i-ACTION:

a. With the concentration of radioactive material released from the site to unrestricted areas exceeding the above limits, restore concentration within the above limits and provide notification to the Commission pursuant to ps Specification 6.9.1.9.

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

SURVEILLANCE REOUIREMENTS F 4.11.1.1.1 The concentration of radioactive material at any time in I j liquid effluents released from the site shall be continuously monitored f f in accordance with Table 3.3-15. {

lr -

p 4.11.1.1.2 The liquid effluent continuous monitors having provisions for P automatic termination of liquid releases, as listed in Table 3.3-15, shall L be used to limit the concentration of radioactive material releases at i any time from the site to unrestricted areas to the values given in Speci-L fication 3.11.1.1.

4.11.1.1.3 The concentration of radioactive material in liquid effluent shall be determined to be within the limits in Specification 3.11.1.1 by g sampling and analysis in accordance with Table 4.11-1.

I L

i -

DAVIS-BESSE, UNIT 1 1 3/4 11 /

l

~

f TABLE 4.11-1

- RADI0 ACTIVE LIOUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limi Samoling Minimum of Detectio

[ i Liquid Release Type Frequency Analysis Frecuency Type of Activity Analysis (LLD)

(uCi/ml)a I A. Batch Waste Each Batch Each Batch Principal Gama 5 x 10 -7 b d

Release Tanks Emitte's r

l I-1 31 1 x 10-6 P

r One Batch /M M Dissolved and 1 x 10-5 1 Entrained Gases P H-3 1 x 10-5 Each Batch M c

Composite r Gross Alpha 1 x 10-7 f ,

P Each Batch Q I

-- Composite c Sr-89, Sr-90 5 x 10'8 l F

L' -

7 ..

s_,

r--

L I

L i

C' L

r, L

I DAVIS-BESSE, UNIT 1 /4 11-2 L. -

t.

,

i TABLE 4.11-1 (Continued \

TABLE NOTATION r

j 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 reoresents a "real"

! sicnal.

L For a particular measurement system (which may include radio-chemical separation):

]

r S

' b LLD =

l E V 2.22 Y where LLD is the lower limit of detection as defined above (as pCi 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 j per minute);

L E is the counting efficiency (as counts per transformation);

V is the samp.le si:e (in units of mass or volume);

p 2.22 is the number of transformation per minute per picocurie; Y is the fractional radiochemical yield (when applicable);

c w

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. In calculating the LLD for a radionuclide determined by gamma-ray spectrometry, the back-f

- ground shall include the typical contributions of other radionuclides normally present in the samples. For isotopic measurements using gamma F spectroscopy, the background count rate is calculated from the background L counts that are determined to be within + one full-width at half-maximum energy band absut the energy of the gamma ray peak used for the quantitative H analysis for that radionuclide'. Typical values of E, V, and Y should i be used in the calculation. ,

It should be recognized tnat the LLD is defined as an a_ oriori (before the fact)

L( limit representing the capability cf a measurement system and not as a_ oosteriori

- - (after the fact) limit for a particular measurement.

5 DAVIS-BESSE, UNIT 1 3/4 11-3 Y '

7 TABLE 4.11-1 (Continued) i TABLE NOTATION r- N

- b. The principal gamma emitters for which the LLD specification will apply

!' are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. Other peaks which are measured and identified shall also be reported.

! For certain radionuclides with low gamma yield or low energies, or for certain radionuclide mixtures, it may not be possible to measure radionuclides

in concentrations near the LLD. Under these circumstances, the LLD may be increased inversely proportional to the magnitude of the gamma yield (i.e.,

5x10 7/I, where I is the photon abundance expressed as a decimal fraction, r'

Nuclides which are below the LLD for the analysis should not be reported as being present at the LLD level. When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the semiannual l

Radioactive Effluent Release Report.

t

c. A composite sample is one in which the quantity of liquid sampled is I proportional to the quantity of liquid waste discharged and in which the L. method of sampling employed results in a specimen which is representative of the liquids released.

I' d. A batch release is the discharge of liquid wastes of a discrete volume.

r L

L.

F

(

L lF lL .-

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4 DAVIS-BESSE, UNIT 1 3/4 11-4

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r - RADI0 ACTIVE EFFLUENTS ,

'r DOSE LIMITING CONDITION FOR OPERATION

~

3.11.1.2 The dose or dose commitment to an individual from radioactive i materials in liquid effluents released from each unit to unrestricted areas (see Figure 3.11-1) shall be limited:

a. During any calendar quarter to $ 1.5 mrem to the total body and to i 5 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, prepare and r submit to the Commission within 30 days, pursuant to Specifica-

' tion 6.9.2, a Special Report, in lieu of any other report, which identifies the cause(s) for exceeding trie limit (s) and defines the corrective actions to be taken to reduce the releases of f~ \ radioactive materials in liquid effluents during the remainder L of the current calendar quarter and during the subsequent three calendar quarters so that the average dose or dose commitment to an individual from such releases during these four calendar t quarters will, if practical, be within 3 mrem to the total body and 10 mrem to any organ.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not appli-F cable.

SURVEILLANCE REQUIREMENTS s 4.11.1.2.1 Dose Calculations. Cumulative dose contributions from liquid effluents shall be determined in accordance with the Offsite Dose Calcu-lation Manual (0DCM) at least once per 31 days.

(

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DI0 ACTIVE EFFLUENTS LIOUID WASTE TREATMENT l -

t I' LIMITING CONDITION FOR OPERATION '

~

/ 3.11.1.3 An appropriate subsystem of the liquid radwaste treatment system shall be routinely used to reduce the radioactive materials in liquid J wastes prior to their discharge when the cumulative dose due to liquid

" effluent releases from each unit to unrestricted areas (see Figure 3.11-1)

when averaged over 31 days would exceed 0.25 mrem to the total body or 0.833 mrem to any organ.

APPLICABILITY: At all times during any quarter in which discharges to unrestricted areas of liquid effluents containing radioactive materials c

occurs or is expected.

ACTION:

a. With radioactive liquid waste being discharged without

[

L treatment and in excess of the above limits, prepare and submit to the Connission within 30 days, pursuant to r Specification 6.9.2, a Special Report, in lieu of any other report, which includes the following information:

t s 1. Identification of equipment or subsystems not OPERABLE and the reason for inoperability.

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

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

b. The provisions of Specification 3.0.3 and 3.0.4 are not

- r applicable.

t.

7 SURVEILLANCE REOUIREMENTS L. 4.11.1.3.1 Dosas due to liquid releases to unrestricted areas shall be calculated at least once per 31 days.

4.11.1.3.2 An appropriate subsystem to the liquid radwaste treatment system shall be demonstrated OPERABLE at least once per 92 days unless the liquid radwaste system has been utilized to process radioactive liquid effluents during the previous 92 days.

i s L-( .-

DAVIS-B.. E, UNIT 1 3/4 11-7 7

% /A _

l >

10 ACTIVE EFFLUENTS

, /

_( RADI0 ACTIVE LIOUID TANKS LIMITING CONDITION FOR OPERATION e

i 3.11.1.41/ The quantity of radioactive material contained in each of the following tanks shall be limited to < 10 curies, excluding tritium and r dissolved o- entrained noble cases, or to concentration levels which would result in less than the limits of 10 CFR Part 20, Appendix B, Table II, j Column 2 at the nearest drinking water supply in an unrestricted area. I r a. Primary Water Storage Tank

b. Temporary Tanks APPLICABILITY: At all times 1!

ACTION:

i

a. With the quantity of radioactive material in any of the above r listed tanks exceeding the above limit, suspcnd all additions

of radioactive material to the tank and within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months either reduce the tank contents to within the limit or provide prompt notification to the Commission pursuant to Specification 6.9.1.9.

The written followup report shall include a schedule and descrip-tion of activities planned and/or taken to reduce the tank contents to within the aoove limit.

b. The provisions of Specifications 3.0.3 anc 3.0.4 are not applicable.

SURVEILLANCE REOUIREMENTS 4.11.1.4 The quantity of radioactive material contained in each of the

- above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 31 days when radioactive materials are being added to the tank.

1/Tank(s) included in Specification are those outdoor tanks that are not surrounded by liners, dikes, or walls capabic. of holding the tank contents.

r If retaining dikes are completed for a tank in this catacory, this

- \ Specification will cease to apply. l 1

L DAVIS-BESSE, NIT 1 3/4 11-8 s'

.. .. - y 3 ___

i e RADI0 ACTIVE EFFLUENTS

, 3/4.11.2 GASE0US EFFLUENTS J '~

4 DOSE RATE LIMITING CONDITION FOR OPERATION 3.11.2.1 The dose in the unrestricted areas (see Figure 3.11-2) due to radioactive materials released in gaseris effluents from the site shall be limited to the following values:

r a. The dose limit for noble gases shall be 1 500 mrem /yr to iL the total body and 13000 mrem /y- to the skin, and

b. The dose limit for all radiciodines and for all radioactive f materials in particulate form, with half lives greater than i , 8 days shall be i 1500 mrem /yr to any organ.

F ~

APPLICABILITY: At all times.

9 ACTION:

(7 a. With the dose exceeding the above limits, decrease the release L rate to comply with the limit (s) given in Specification 3.11.2.1 and provide notification to the Commission pursuant to Specification 6.9.1.9.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not r applicable.

w

_ SURVEILLANCE REQUIREMENTS

( 4.11.2.1.1 The noble gas effluent continuous monitors have provisions for the automatic termination of gaseous releases, as listed in Table 3.3-12, j

shall be used to limit offsite doses within the values established in

{ Specification 3.11.2.1.a when monitor setpoint values are exceeded.

4.11.2.1.2 The release rate of radioactive materials, other than noble gaser, in gaseous effluents shall be determined by obtaining representative

- samples and performing analyses in acc rdance with the sampling and analysis program, specified in Table 4.11-2.

m N

n 1 DA -BESSE, UNIT 1 '

+

1

I T

7 SURVEILLANCE REOUIREMENTS

-( -

4.11.2.1.3 The dose in unrestricted areas, due to radioactive materials other than noble gases released in gaseous effluents, shall be determined to be within the required limits by using the results of the sampling and analysis program, specified in Table 4.11-2, in performing the calculations of dose in unrestricted areas.

1 l~

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DAVIS-BESSE, UNIT 1 3/4 11-10 e

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s E

Y

g. TABLE 4.11-2 sn

,$ RADI0 ACTIVE GASE0US WASTE SAMPLING AND ANALYSIS PROGRAM Minimum Lower Limit of

[ Gaseous Release Type Sampling Analysis Type of Detection (LLD)

Frequency frequency Activity Analysis (uCi/ml)a Waste Gas Decay Ea h Ea h * -Principal Gamma Emitters' 1 x 10 -4 Release Release Grab Sample 11- 3 1 x 10 -6 J

P P Containment Purge Each Purge Each Purge Principal Ganna Emitters c 1 x 10 -4 Grab Sample 1 x 10 -6 11- 3 c

$ Station Vent Stack M M Principal Ganna Emitters 1 x 10 ~4 Grab

& 1 x 10 -6 Sample 11- 3 Continuous h y I-131 1 x 10 -12 Charcoal Sample I-133 1 x 10 -10 W

h Continuous Particulate Principal Ganna Emitters c 1 x 10 -I Sample b

Continuous Co posite Gross Alpha 1 x 10'II Particulate Sample b

Continuous Composite Sr-89, Sr-90 1 x 10-II Particulate Sample .

m /w /

TABLE 4.11-2 (Continued) r 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.

I i For a particular measurement system (which may include radio-chemical separation):

" 4;65 s LLD =

E V 2.22 Y I where l

LLD is the lower limit of detection as defined above (as pCi per r 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);

i E is the counting efficiency (as counts per transformation);

V is the sample size (in units of mass or volume);

2.22 is the number of transformation ,

Y is the fractional radiochemical yield (when applicable);

L The system value shall of sh used b based on theinactual the calculation of theof LLD observed variance for a detection the background f counting rate or of the counting rate of the blank samples (as appropriate L rather than on an unverified theoretically pr2dicted variance. In (-

calculating the LLD for a radionuclide determined by gamma-ray \

li spectrometry, the background shall include the typical contributions 1 k of other radionuclides normally present in the samples. For isotopic }

measurements using gamma spectroscopy, the background count rate is p calculated from the background counts that are determined to be within

+ one full-width at half-maximum energy band about the energy of the

(~-

gama ray peak used for the quantitative analysis for that radionuclide.

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

/ It should be recognized that the LLD is defined as an a oriori (before the I

fact) limit representing the ca? ability of a measurement system and not as a costeriori (after the fact) limit for a particular measurement.

IS-BESSE, UNIT 1 3/4 11-12 m

.. .. l i

~

TABLE 4.11-2 (Continued)

TABLE NOTATION

_(

b. The ratio of the sample flow rate to the sampled stream flow rate shall

-- be known for the time period covered by each does or dose rate calculation made in accordance with Specifications 3.11.2.1 and 1 3.11.2.3.

I

c. The principal gamma emitters for which the LLD specification will apply are exclusively 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, 2n-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 i detected and reported. Other peaks which are measured and identified,

[' together with the above nuclides, shall also be identified and reported.

Nuclides which are below the LLD for the analyses should be reported as

- "less than" the nuclide's LLD and should not be reported as being present at the LLD level for that nuclide. The "less than" values shall l not be used in the required dose calculations. For certain radionuclides with low gamma yield or low energies, or for certain radionuclide mixtures, it may not be possible to measure radionuclides in concentrations near the LLD. Under these circums.ances, the LLD may be increased inv rsely proportionally to the magnitude of the gamma yield (i.e.,1 x 10 g/I, where I is the photon abundance expressed as a decimal fraction). When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the semiantual Radioactive Effluent Release Report.

c w

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L_ DAVIS-BESSE, UNIT 1 3/4 11-13 l

s_

m_

s DI0 ACTIVE EFFLUENTS

.> DOSE, NOBLE GASES .

( LIMITING CONDITION FOR OPERATION

, - 3.11.2.2 The air dose in unrestricted areas (see Figure 5.1-1) due to noble gases released in gaseous effluents from each unit shall be limited to the following:

During any calendar quarter, to 5 5 mrad for gamma radiation

/

and 5 10 mrad for beta radiation.

k APPLICABILITY: At all times ACTION:

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

, gaseous effluents exceeding any of the above limits, prepare and submit to the Commission within 30 days, pursuant to

,. Specification 6.9.2, a Special Report, in lieu of any other report, which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce the releases of radioactive noble gases in gaseous effluents during I the remainder of the current calendar quarter so that the average dose- during the quarter is within 5 mrad for gamma ra :ation and 10 mrad for beta radiation.

[ b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. {

T- 1 SURVEILLANCE REQUIREMENTS

.

I 4.11.2.2 Dose Calculations Cumulative dose contributions for the total time period shall be determined in accordance with the Offsite Dose Calculation Manual (0DCM) at least once every 31 days.

L_ \

1 L, DAVIS-BE ~E, UNIT 1 3/4 11-14 ll I

i

/

l W

s n l

~

FFLUENTS f j

/ DOSE, RADIOI0 DINES, RADI0 ACTIVE MATERIAL IN PARTICULATE FORM, A 4D

_\

RADIONUCLIDES OTHE.R THAN NOBLE GASES

)

LIMITING CONDITION FOR OPERATION 3.11.2.3 The dose to an individual from radiciodines and radioactive materials in particulate form, with half-lives f greater than 8 days in gaseous effluents released to unrestricted areas (see Figure 3.11-2)from each unit at the site shall be limited to the following:

r

[ During any calendar quarter to < 7.5 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radiciodines and radioactive materials in particulate form, in gaseous

. effluents excceding any of the above limits, prepare l

and submit to the Commission within 30 days,

- pursuant to Specification 6.9.2, a Special Report, in lieu of any other report which identifies the cause(s) for exceeding the limit and defines the corrective actions to be taken to reduce the releases of radioiodines, radioactive j materials in particulate form, and radionuclides other than L noble gases with half-lives greater than 8 days in gaseous i effluents during the remainder of the current calendar quarter

~'

so that the average dose or dose commitment to an individual

, from such releases du.ing the quarter is within (7.5) mrem to any organ.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not

r. applicable.

I

_ SURVEILLANCE REQUIREMENTS e- 4.11.2.3 Dose Calculations Cumulative dose contributions for the total time period shall be determined in accordance with the ODCM at least once every 31 days. ,

V DAVI - ESSE, UNIT 1 3/4 11-15 l_ w -

, - - - - , - - o - ,

- 0 ACTIVE EFFLUENTS

/

~

GASEOUS RADWASTE TREATMENT s

I LIMITING CONDITION FOR OPERATION

\

3.11.2.4 An appropriate subsystem of the gaseous radwaste treatment system and the ventilation exhaust treatment system shall be used to reduce radio-active materials in gaseous waste prior to their discharge when the cumulative gaseous effluent air doses due to gaseous effluent releases to unrestricted areas (see Figure 3.11-2) over 31 days would exceed'0.83 mrad for ganna radiation and 1.7 mrad for beta radiation, and ventilation exhaust treatment system shall be used to reduce radioactive materials in gaseous waste prior to their discharge when the cumulative doses due to gaseous effluent releases to unrestricted area (see Figure 3.11-2) when averaged over 31 days exceeds 1.25 mrem to any organ.

APPLICABILITY: At all times.

I '

ACTION:

a. With gaseous waste being discharged for more than 31 days without r

treatment and in excess of the above limits, prepare and submit to the Commission within 30 days, persuant to Specification 6.9.2, a .

Special Report, in lieu of any other report, which includes the

< following information: ,

1. Identi'fication of equipment of subsystems not OPERABLE and the reason for inoperability.

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

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

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

SURVEILLANCE REOUIREMENTS 4.11.2.4.1 Doses due to gaseous releases to unrestricted areas shall be determined at least once per 31 days.

~

4.11.2.4.2 The appropriate systems shall be demonstrated OPERABLE at least once per 92 days unless the appropriate system has been utilized to nrocess radioactive gaseous effluents during the previous 92 days.

DAVIS ESSE, UNIT 1 3/4 11-16

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RADIOACTIVE EFFLUENTS EXPLOSIVE GAS MIXTURE I

L LIMITING CONDITION FOR OPERATION 3.11.2.5 The concentration of oxygen in the waste gas holdup system shall be limited to 1 2% by volume.

F

.1 APPLICABILITY: At all times.

ACTION:

7 i With the concentration of oxygen in the waste gas holdup system a.

>2% by volume but 14% by volume, restore the concentration of oxygen to < 2% within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ,

]

b. With the concentration of oxygen in the waste gas holdup system

>4% by volume, suspend all additions of waste gases to the system and reduce the concentration of oxygen to $2% within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

I

c. The provisions of Specification 3.0.3 and 3.0.4 are not ' '

I applicable.

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i u SURVEILLANCE REQUIRENENTS t

[ 4.11.2.6 The concentrations of oxygen in the waste gas decay system

' shall be determined to be within the above limits by continuously monitoring the waste gases in the waste gas holdup system with the oxygen monitors required OPERABLE or by analysis of grab samples as indicated by L Table 3.3-16 of Specification 3.3.3.10.

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DI0 ACTIVE EFFLUENTS WASTE GAS DECAY TANKS LIMITING CONDITION FOR OPERATION 3.11.2.6 Thequantityofradioactigitycontainedineachwastegasdecay

' J tank shall be limited to < 4.5 x 10 curies noble cases (considered as

- ~

Xe-133).

APPLICABILITY: At all times k ACTION:

I \

a. With the quantity of radioactive material in any waste gas decay storage tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank and within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months either reduce the tank contents to within the limit or provide notification to the Commission, in lieu of any other report,

,_ pursuant to Specification 6.9.1.8. The written followup report i shall include a description of activities plannad and/or taken to reduce the tank contents to within the above limit.

I~ b. The provisions of Specifications 3.0.3 and 3.0.4 are not i applicable.

K SURVEILLANCE RE0VIREMENTS 4.11.2.7 The quantity of radioactive material contained in each waste gas decay tank shall be determined to be within the above limit at least once per 31 days, when radioactive materials are being added to the tank.

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P DI0 ACTIVE EFFLUENTS I 3/4.11.3 SOLID RADI0 ACTIVE WASTE c-LIMITING CONDITION FOR OPERATION N x

i 3.11.3.1 A solid radwaste system shall be provided for solidification and packaging of radioactive waste to ensure meeting the requirements of 10CFR Part 20 and of 10CFR Part 71 prior to shipment of radioactive waste from k the site.

APPLICABILITY: At all times ACTION:

1

[ a. With the requirements of 3.11.3.1 not satisfied, suspend shipment

- of defectively packaged solid radioactive wastes from the site.

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

SURVEILLANCE REQUIREMENTS l

r' 'N 4.11.3.1.1 Measurements shall be made to determine or estimate the total curie quantity of all radioactive solid waste shipped offsite.

4.11.3.1.2 Estimates shall be made of the principal gamma radionuclide composition of all radioactive solid waste shipped offsite.

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DAVIS-BESSE, UNIT 1 ,

3/4 11-20 L

.12 RADIOLOGICAL ENVIRONMENTAL MONITORING

(

3/4.12.1 MONITORING PROGRAM r

LIMITING CONDITIONS FOR OPERATIONS s 3.12.1 The radiological environmental program shall be conducted as specified p in Table 3.12-1.

.I APPLICABILITY: At all times.

I ACTION:

a. Any sit r.ificant deviation in conducting the radiological environmental J monito. ing programs from that specified in Table 3.12-1 shall be docu-L mented m the Annual Radiological Environmental Operating Report. The reasons for these deviations and appropriate plans for preventing a recurrence shall be stated. (Deviations are permitted from the required F- sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, or to malfunction of automatic r

sampling equipment. If the latter, every effort shall be made to complete corrective action prior to the end of the next sampling period.)

i-

b. If the confirmed-1/ measured levels of radioactivity in an environmental E{s ' '

sampling medium specified in Table 3.12-1 exceed the reporting level of Table 3.12-2 when averaged over any calendar quarter, a Special Report shall be submitted to the Commission within 30 days from the end of the affected calendar quarter, or after confirmation, whichever is later.

This report shall include an evaluation of any release conditions, environmental factors or other aspects which may have caused the

! reporting levels in Table 3.12-2 to have been exceeded. When more than

' one of the radionuclides in Table 3.12-2 are detected in the sampling medium, this report shall be submitted if:

_ concentration (1) concentration (2) -

i reporting level (1) + reporting level (2) + ...> 1.0 .

L 1/

A confirmatory reanalysis of the original, a duplicate, or a new sample

may be desirable, as appropriate. The results of the confirmatory

- analysis shall be completed at the earliest time consistent with the analysis, but in any case within 60 days.

L r DAVIS-BESSE, UNIT 1 3/4 12-1 1

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N 3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING

(' 3/4.12.1 MONITORING PROGRAM (Continued)

LIMITING CONDITIONS FOR OPERATIONS

~

This report is not required if the measured level of radioactivity was

] not the result of plant effluents; however, in such an event, the l condition shall be reported and described in the Annual Radiological 1 Environmental Operating Report.

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

SURVEILLANCE REQUIREMENTS 4.12.1 The radiological environmental monitoring samples shall be collected oursuant to Table 3.12-1 from the locations shown in Section 3.0 of the ODCM and snall be analyzed pursuant to the requirements of Tables

- 3.12-1 and 4.12-1. ,

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[ TABLE 3.12-1 .

OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMa E xposure Pathway Number of Sampling and Type and Frequency Sample

-i or Samples Samplesb Collection Frequency of Analysis Station b ,

AIRBORNE Radiolodine and Four (4) of six (6) Charcoal Filter 1,2,3,4 Particulates Indicators , analyze for 1-131 7,8 f locations Continuous sampler oper- following charcoal ation with sample collec- change j tion weekly or as required i by dust loading whichever comes first. Particulatt sar.pler:

Three (3) of five Gross beta radio-activity >24 hours 9 2' l, (5) control f 11 wing filter change, 23'27 U= locations comsite (by location)

, for gamma spec 7 analysis (CSA)grum w quarterly.

DIRECT RADIATION

7 indicator locations Quarterly Gamma dose quarterly 1,2 , 3 ,4 ,5 ,

6 control locations 7,8, 9,11,12, 23,24,27

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< TABLE 3.12-1 (con't) I h OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMa N

O! xposure Pathway Number of Sampling and Type and Frequency Sample

."' or Samples Samplesb Collection Frequency of Analysis - Station b

? - ,.

t WATERBORNE Surface One (1) of two (2) CompositeI sample collected GSA of monthly 3,28 indicator locations over a period of < 31 days composite. Tritium of one (1) of two (2) at location 28 onTy. each quarterly samples. 11,12 control locations Others Weekly grab composited monthly.

Ground One (1) of two (2) Once per 92 days GSA and tritium 7,17 indicator locations analysis of each and one (1) control sample. 27 Bottom One (1) of two (2) Once per 184 days GSA each sample. 29,30 Sediments 4 s

indicators and one 7 (1) control 27 INGESTION 1 Milk Two (2) indicatir.g Once per 15 days when GSA and I-131 for 8,20 and one (1) control animals are on pasture; each sample, once per 31 days at other 24 times.

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N OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ,

2

" xposure Pathway Sampling and Numbergf Type and Frequency Sample ~

Collection Frequency b of Samples -Samples of Analysis Station i

l-3 INGESTION (con't)

Fish One (1) sample each One sample in, season or GSA on edible portions. 33 of two (2) species at least once per 184 days 2 indicator of two species.

) 2 control 35 2

3 Vegetation Two(2) varieties At time of harvest one GSA on edible portions. 8,25 sample each of two > 10 miles varieties. Trom site

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TABLE 3.12-1 (con't) 4, OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 0

$ xposure Pathway Numbergf Sampling and Type and Frequency Sa p of Samples Samples Collection Frequency of Analysis Station E

M Vegetation One (1) indicator Broad leaf vegetation I-131 analysis 36 (con't) sample and one (1) grown off-site near un-control restricted area boundry in

' highest cqlculated annual average ground-level D/Q sector. Monthly -

July through September 9,h

' Similiar broad leaf vegetation, I-131 analysis 37 w grown 10-20 miles distant in i least prevalent wind direction.

Monthly - July through Septemberg ,h Edible Meat One (1) indicator One sample of Domestic meat: GSA on edible portions. 32, 33 and one (1) control poultry, beef, or pork.

Semi-annually. 34

" Deviations are permitted from the specified sampling schedule if specimen is unobtainable due to hazardous conditons, !

inclement weather, seasonable unavailability, malfunctions of equipment or other legitimate reasen.

b Sample locations are shown in the ODCM.

C Particulate sample filters shall be analyzed for gross beta 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more af ter sampling to allow for radon and thoron daughter decay. If gross beta activity in air or water is greater than 10 times the mean of control samples for any medium, gamma spectrum analysis (GSA) shall be preformed on the individual samples.

d GSA means the identification and quantification of gamma-emitting radionuclides that may be attributable to t.he effluents from the facility.

"for the purpose of this table a thermoluminescent dosimeter (TLD) is considered to be one chip, and two or more

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1 7 q j - -i TABLE 3.12-1 (con't) a :

a

$ OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM V'

Ri S:

.m ips in a packet or a multiple area TLD are considered as two or more dosimeters.

E Composite sample shall be collected with equipment (or equivalent) which is capable of collecting an aliquot

-4 at intervals not exceeding 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Should the' automatic sampling eo"'pment become in operative, grab samples will be collected weekly or at other appropriate intervals and composited.

9 Where access to edible green leafy vegetables is not possible, non-edible plants with similar leaf characteristics from the same sector may be substituted.

I h /

When broad leaf vegetation grown offsite near unrestricted area boundry is not available, a garden census will be i

f> conducted. ,1

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.N TABLE 4.12-1 e N z

LOWER LIMITS OF DETECTION (LLD)^

Airborne Particulate Fish Water Milk Analysis (pci/1) or Gas (pci/m )3 (pCi/kg, wet) (pCi/1)

Food Products (pci/kg, wet)

Sediment (pCf/kg, dry)

\1 1 x 10 -2 b

gross beta 4 3 b 11 2000 (1000 )

g 54 Mn 15 130 w

, 59 30 260 Fe Y Y m 58, 60 s C0 15 130 65 30 260 Zn 95 Zr 15 131 g I

c 7 x 10 -2 jc 60 I 134, 137 15(10b ), 18 -2

\ 0s 1 x 10 130 15 60 150

\

j 140 15 15 Ba NOTE: This list does not mean that only these nuclides are to be detected and reported.

Other peaks which are measureable and identifiable, together with the above nuclides, shall be identifled and reported.

/ s

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TABLE 4.12-1 (Continted)

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 7 of falsely concluding that a blank observation represents a "real"

[ signal.

r For a particular ri.1surement system (which may include radiochemical 1

separation):

v @

LLD = -- .

I E V 2.24 . Y exp(-uT) where p LLD is the lower limit of detection as defined above (as pCi per unit mass or volume).

./ sbis the standard deviation of the background counting rate or of the j counting rate of a blank sample as appropriate (as counts per minute).

i E is the counting efficiency (as counts per transformation).

F L V is the sample size (in units of mass or volume).

p 2.22 is the number of transformations per minute per picocurie L

l Y is the fractional radiochemical yield (when applicable)

!, A is the radioactive decay constant for the particular radionuclide.

H b AT is the elapsed time between sample collection (or end of the sample

! collection period) and time of counting (for environmental samples, not )

L plant effluent 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. In calculating the LLD for a radion' clide determined by gamma-ray spectrometry, the background shall include

, the typical contributions of other radionuclides normally present in the samples (e.g. , potassium-40 in milk samples). Typical values of b i E, V, Y and AT should be used in the calculations.

A.

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DAVI ESSE, UNIT 1 3/4 12-9 l

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TABLE 4.12-1 (Continued) g TABLE NOTATION 1

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

Analyses shall be performed in such z. manner that the stated LLDs will be achieved under routine conditions. Occasionally background ,

,. fluctuations, unavoidably small sample sizes, the presence of interfering I

nuclides, or uncontrollable circumstances may render these LLDs unachiev-able. In such cases, the contributing factors will be identified and .

described in the Annual Radiological Environmental Operating Report.

. For more complete discussion of the LLD and other detection limits, see the following:

r

[ (1) HASL Procedures Manual, HASL-300 (revised annually).

/ (2) Currie, L. A., " Limits for Qualitative Detection and Quantitative I'

L Determination - Application to Radiochemistry' Anal. Chem. 40, 586-93 (1968):

[ (3) Hartrwell, J. K. , " Detection Liiaits for Radioisotopic Counting L Techniques", Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).

b. LLD for drinking water.

c. LLD only when specific analysis for I-131 required, t

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DAVIS-BESSE, IT 1 3/4 12-10 l

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.12 RADIOLOGICAL ENVIRONMENTAL MONITORING I 3/4.12.2 LAND USE CENSUS LIMITING CONDI' IONS FOR OPERATIONS s

3.12.2 A land use census of the nearest milk aninalgall andbe conducted and shcilresidence identify the location

! the nearest permanent in each of I

the 16 meteorological sectors witnin a distance of five (5) miles.

[ APPLICABILITY: At all times.

ACTION:

a. Should a land use census identify a location (s) which yields a calculated dose or dose commitment greater than the value currently calculated in Specification 4.11.2.3.1, a revision in f_ Section 3.0 of the ODCM reflecting the new location (s) shall l be submitted to the Commission as an inclusion in the Monthly Operating Report pursuant to Specification 6.14.2.

F

b. Should a land use census identify a location (s) which yields a calculated dose or dose commitment (via the same exposure path-way) greater than at a location from which samples are currer.tly being obtained in accordance with Specification 3.12.1, a revision in Section 3.0 of the ODCM reflecting the new location (s) shall

/ be submitted to the Commission as an inclusion in the Monthly

{N Operating Report pursuant to Specification 6.14.2. The new location

' shall be added to the radiological environmental monitoring programs within 60 days if samples are available. The sampling point having I the lowest calculated dose or dose commitment (via the same exposure L pathway) may then be deleted from this monitoring program.

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

t SURVEILLANCE RE0VIREMENTS t 4.12.2 The land use census shall be conducted at least once per 12 months by door-to-door survey, visual survey, aerial survey, consulting local P agriculture authority, or by any combination of these methods.

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! \ -IA milk animal is a cow or goat that is producing milk forhuman consumption.

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,M TABLE 3.12-2 E REPORTING LEVELS FOR RADI0 ACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES U

Reporting Levels hater AirborneParticujate Fish Hilk Vegetables Analysis (pCi/1) or Gases (pCi/m ) (pCi/Kg, wet) (pCi/1) (pCi/Kg, wet) o II- 3 3 x 10 ,

I Mn-54 1 x 10 3 3 x 10 4 Fe-59 4 x 10 2 1 x 10 4

4 Co-58 1 x 10 3 3 x 10 Co-60 3 x 10 2 1 x 10 4

Zn-65 3 x 10 2 2 x 10 '

Zr-Nb-95 4 x 10 2 1-131 2 0.9 3 1 x 10 2 3 3 Cs-134 30 10 1 x 10 60 1 x 10 3

Cs-137 50 20 2 x 10 70 2 x 10 3 2 2 Ba-la-140 2 x 10 3 x 10 /

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- I STRUMENTATION

, BASES r '

h i 3/4.3.3.9 RADI0 ACTIVE LIOUID EFFLUENT INSTRUMENTATION

- The raiioactive liquid effluent instrumentation is provided to monitor and cont-ol, as applicable, the releases of radioactive materials in liquid effi ents during actual or potential releases. The alarm / trip setpoints for these instruments shall be calculated in accordance with methods in the f ODCM to ensure that the alarm / trip will occur prior to exceeding the limits

! of 10 CFR Part 20.

'~ -C.

r 3/4.3.3.10 RADIOACTIVE GASE0US EFFLUENT INSTRUMENTATION I

I Tiie radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive ma'.erials in gaseous

[, effluents during actual or potential releases. The alarm / trip setpoints i for these instruments shall be calculated in accordance with methods in the f ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. This instrumentation also includes provisions for monitoring the concentrations of potentially explosive gas mixtures in the waste gas holdup system. The OPERABILITY and use of this instrumentation r/ is consistent with the requirements of General Design Criteria 60, 63 and

!N 64 of Appendix A to 10 CFR Part 50.

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_ I0 ACTIVE EFFLUENTS

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_( BASES x

-/ 3/4.11.1 LIOUID EFFLUENTS 3/4.11.1.1 C01. ?NTRATION This specification is provided to. ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified in 10 CFR Part 20, Appendix B, Table II. This limitacion provides addi-tional assurance that the levels of radioactive naterials in bodies of water outside the site should not result in exposures exceeding (1) the Section II.A design objectives of Appendix I,10 CFR Part 50, to an individual and (2) the limits of 10 CFR Part 20.106(e) to the population. The con-j centration limit for noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its MPC in air (submersion) was con-

~

verted to an equivalent concentration in water using the methods described

, in International Commission on Radiological Protection (ICRP) Publication 2.

3/4.11.1.2 DOSE b i This specification 4.; provided to implement the requirements of j Sections II. A, III. A and IV. A of Appendix I,10 CFR Part 50. The

p. Limiting Condition for Operation implements the guides set forth in L \ Section II. A of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set r forth in Section IV. A of Appendix I to assure that the releases of L 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 III. A of Appendix I L[ that conformance with the guides of Appendix I is to be shown by cal-3 culational procedures based on modes and data such that the actual

{ exposure of an individual through appropriate pathways is unlikely L to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of t- radioactive materials in liquid effluents are consistent with the k methodology provided in Regulatory Guide 1.109, " Calculation of Annual b Doses to Man from Routine Releases of Reactor Effluents fer the Purpose

,_ of Evaluating Compliance with 10 CFR Part 50, Appendix I, " Revision f 1, October 1977.

L 9"

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!s DAVIS-BESSE, UNI 1 B 3/4 11-1 i

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.. . DI0 ACTIVE EFFLUENTS BASES i[ k F-This specification applies to the release of liquid effluents from each unit at the site. For units with shared radwaste treatment

[ systems, the liquid effluents from the shared system are proportioned among the units sharing that system.

3/4.11.1.3 LIOUID WASTE TREATMENT

- The OPERABILITY of the appropriate 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 requirements that the appropriate portions of this system be used when specified provides assurance that the releases of radicactive materials in liquid effluents will be kept "as low as is reasonably achievable". This specification implements the requirements of 10CFR Part 50.36a, General Design Criterion 60 of Appendix A to 10CFR Part 50 and design objective Section II.D of Appendix A to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the liquid radwaste treatment system were

- specified to implement Section II.A of Appendix I,10CFR Part 50, for liquid effluents.

3/4.11.1.4 LIQUID HOLDUP TANK 5 L Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations woulo be /

f less than the limits of 10 CFR Part 20, Appendix B, Table II, Column 2, L

at the nearest potable water supply and the nearest surface water

.- supply in an unrestricted area.

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f 3/4.11.2 GASE0US EFFLUENTS 7-3/4.11.2.1 DOSE RATE j This specification is provided to ensure that the dose at the i exclusion area boundary from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for r unrestricted areas. The annual dose limits are the doses associated

{ with the concentrations of 10 CFR Part 20, Appendix B, Table II.

These limits provide reasonable assurance that radioactive material r discharged in gaseous effluents will not result in the exposure of an l individual in an unrestricted area to annual average concentrations exceeding the limits specified in Appendix B, Table II of 10 CFR 7

_ Part 20 (10 CFR Part 20.106(a)). For individuals who may at times be within the unrestricted area boundary, the occupancy of the individual will be sufficiently low to compensate for any increase in the {

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I DI0 ACTIVE EFFLUENTS r'[ BASES l

,r- atmospheric diffusion factor above that for the unrestricted area boundary.

j The specified release limits restrict the corresponding ganma and beta .

doses above background to an individual at or be

- j mrem / year area boundary to 1500 mrem / year to the total bo' yond the unrestricteddy or to < 3000 to the skin. These release limits also restrict, at all times, the corresponding thyroid dose above background to an infant via the cow-milk-infant pathway to 5 5001 mrem / year for the nearest cow to the plant.

I i This specification applies to the release of gaseous effluents from all units at the site. For units with shared radwaste treatment r- systems, the gaseous effluents from the shared system are proportioned n among the units sharing that system.

3/4.11.2.2 DOSE, NOBLE GASES F

^

This specification is provided to implement the requirements of Sections II.B, III.A and IV.A of Appendix I, 10 CFR Part 50. The I Limiting Condition for Operation implements the guides set forth in e Section II.B of Appendix I. The ACTION statements provide the required operating flexibility and at the same time implement the guides set

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

[' radioactive material in . gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirenents implement the requirements. in Section III. A of Appendix I that conform with the guides of Appendix I to be shown by calculational procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated.

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 from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111. " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors,"

Revision 1. July 1977. The CDCM equations provided for determining the

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, air doses at the unrestricted area boundary will be based upon the historical average atmospheric conditions. f 3/4.11.2.3 DOSE, RADIOI0 DINES,,RADI0 ACTIVE MATERIAL IN PARTICULATE FORM AND RADIONUCLIDES OTHER THAN NOBLE GASES This specification is provided to implement the requirements of '

Sections II.C, III.A and IV.A of Appendix I, 10 CFR Part 50. The Limitin; l- DAVIS-3 ESSE, UNIT 1 B-3/4 11 4_ l l 2 l l

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r Conditions for Operation are the guides set forth in Section II.C of Appendix I. The ACTION statements provide the required operating flexi-bility and at the samt time implement the guides set forth in Section IV.A I of Appendix I to assure that the releases of radioactive materials in i gaseous effluents will be ke;t "as low as is reasonably achievable." The ODCM calculational methods specified in the surveillance requirements implement the requirements in Section III. A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure of an individual through p appropriate pathways is unlikely to be substantially underestimated. The ODCM methods for calculating the doses due to the actual release rates of l

the subject materials are consistent with the methodology provided in Regulatory Guide 1.109, " Calculating of Annual Doses to Man from Routine

[ Releases of Reactor Effluents for the Purpose of Evaluating Compliance t with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport and Dispersion r of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors,"

l' 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 radiciodines, radioactive material 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 are examined in the development of these calculations -

are: 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) deposi-tion on the ground with subsequent exposure of man.

3/4.11.2.4 GASE0US UASTE TREATMENT w

- The OPERABILITY of the appropriate 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 this system be used when specified provides reasonable assurance that the releases of radioactin materials in gaseous effluents will be kept "as low as is reasonably schievable". This specification implements the requirements of 10CFR Part 50.36a, General Design Criterion 60 of Aopendix A to 10CFR Part 50, and design objective Section IID of Appendix I to 10CFR Part 50. The specified limits governing

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the use of appropriate portions of the system were specified as en appropriate I

fraction of the guide' set forth in Sections II.B and II.C of Appendix I, 10CFR Part 50, for gaseous effluents.

s b DAVIS-BESSE, UNIT 1 B 3/4 11-5 t

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_ l 3/4.11.2.5 EXPLOSIVE GAS MIXTURE This specification is provided to ensure that the concent ion of potentially explosive gas mixtures contained in the waste gas L.eatment f,

system is maintained below the flammability limits of hydrogen with

! oxygen. Maintaining the concentration of hydrogen or oxygen below

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their flammability limits provides assurance that the releases of radio- f active materials will be controlled in conforJance with the requirements t of General Design Criterion 60 of Appendix A to 10CFR Part 50.

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2 3/4.11.2.6 WASTE GAS DECAY TANKS Restricting the quantity of radioactivity contained in each waste gas decay tank provides assurance that in the event of an uncontrolled

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release of the tank's contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem.

[ This is consistent.with Standard Review Plan 15.7.1, " Waste Gas System Failure".

3/4.11.3.1 The requirements for solid radioactive waste handling and /

disposal given under this specification provide assurance that solid radioactive materials stored at the plant and shipped offsite are packaged in conformance with 10CFR Part 20,10CFR Parc 71, and 49CFR

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Parts 170-178.

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N 3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING

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If 3/4.12.1 MONITORING PROGRAM rl The radiological monitoring program required by this specification pro-vides measurements of radiation and of radioactive materials in those 1[ expos"re pathways and for those radionuclices which lead to the highest r' . potential radiation exposures of individua?s resulting from the station i operation. This monitoring program thereby supplements the radiological effluent monitoring program by measuring concentrations of radioactive materials and levels of radiation which may be compared with those

expected on the basis of the effluent measurements and modeling of the environmental exposure pathways. The initially specified monitoring program will be effective for at least the first three years of commercial

[ operation. Following this period, program changes may be initiated based r on operaticr.al experience.

3/4.12.2 LAND USE CENSUS I

This specification is provided to ensure that changes in the use of

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unrestrictec' areas are identified and that modifications to the monitoring 1 program are made if required by the results of this census. This I census satisfies the requirements of Section IV.B.3 of Appendix I to p 10 CFR Part 50.

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l,l [3 llll{N i LA 1.25 IA 1.6 < 6" , c MICROCOPY RESOLUTION TEST CHART 4% + sp l'*Iik h. $d,[d 4,,, . i .. l ADMINISTRATIVE CONTROLS T

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-6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY l shall be responsible for overall ! 6.1.1 The tation Suoeri - facility operation ano sna t i celegate in writing the succession to this responsibility during his absence. j 6.2 ORGANIZATION OFFSITE 6.2.1 The offsite organization for facility management and technical support shall be as shown on Figure 6.2 1 r 1-- FACILITY STAFF [' 6.2.2 The Facility organization shall be as shown on Figure 6.2-2 and:

a. Each on duty shift shall be composed of at least the minimum

~, 7 shift crew composition shown in Table 6.2-1. ~

u. At least one licensed Operator shall be in the control room when fuel is in the reactor.

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c. At least two licensed Operators shall be present in the control room during reactor start-up, scheduled reactor 7 shdtdown and during recovery from reactor trips.

d. An individual qualified in radiation protection procedures F shall be on site when fuel is in the reactor.

L ALL CdRE ALTERATIONS shall be directly supervised by either a e. licensed Senior Reactor Operator or Senior Reactor Operator f Limited to Fuel Handling who has no other concurrent responsi-y bilities during this operation.

f. A Fire Brigade of at least 3 members shall be maintained onsite at all times. The Fire Brigade shall not include the minimum shift crew shown in Table 6.2-1 or any personnel required for other essential functions during a fire emergency.

I' L: I DAVIS-BESSE, UNIT 1 6-1

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'L ADMINISTRATIVE CONTROLS I 6.3 FACILITY STAFF OUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the(Chemisf and Hlalth,Pnv51cist]who shall meet or exceed the qualifica- - tions at neguia1.ory uuice 1.6, aptember 1975. _ 6.4 TRAINING , 6.4.1 A retraining and replacement training program for the facility q staff shall be maintained under the direction of the Training Supervisor and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55. -~ 6.4.2 A training program for the Fire Brigade shall be maintained , ~ '~ under the direction of the Fire Marshall and shall meet or exceed the requirements of Section 27 of the NFPA Code-1976. I L 6.5 REVIEW AND AUDIT i 6.5.1 STATION REVIEW BOARD (SRB) L FUNCTION p(. L, 6.5.1.1 The Statioo Review Board (SRB) shall function to advise the Station Superintendent on all matters related to nuclear safety. r-L E u u L c L - E' b'?_ ~ . . i L: DAVIS-BESSE, UNIT 1-6-5 i ADMINISTRATIVE con (ROLS I~ '

c. Review of all proposed changes to Appendix "A" Technical Specifications.

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d. Review of all proposed changes or modifications to plant systems or equipment that affect nucler safety.

I e. Investigation of all violations of the Technical Specifications i including preparation and forwarding of reports covering evalua-tion and recommendations to prevent recurrence to the Vice [~ President - Energy Supply and to the Chairman of the Ccmpany i Nuclear Review Board. r- f. Review of events requiring 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months written notification to the [ Commission. ,_, g. Review of facility oper#ations to detect potential safety I hazards. t

h. Performance of special reviews, investigations and analyses i~ and reports thereon as requested by the Chairman of the

[ Company Nuclear Review Board. r i. Review of the Plant Security Plan and implementing procedures l and shall submit recommended changes to the Chairman of the Company Nuclear Review Board. h L.

j. Review of the Emergency Plan and implementing procedures and shall submit recommended changes to the Chairman of the Company Nuclear Review Board.

p _ r m L k. Review of unplanned release to the environs as defined in Section 6.9.1.9.e; evaluate the event, ensure that remedial action is identified to prevent recurrence, ensure that the event is 1 [ documented as required in Section f 1.9.e. w ] % JQ [ AUTHORITY A - i 6.5.1.7 Th. Station Review Board shall:

a. Reconnend to the Station Superintendent written approval or disapproval of items considered under 6.5.1.6(a) through (d)

, above.

b. Render determinations in writing with regard to whether or not i- each item considered under 6.5.1.6(a) through (e) above constitiutes an unreviewed safety question.

c. Provide written notification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the Vice DAVIS-BESSE, UNIT 1 u

6-7 .. .0 i ADMINISTRATIVE CONTROLS r AUTHORITY F[ 6.5.2.9 The Company Nuclear Review Board shall report to and advise the Executive Vice President, Operations on those areas of responsibility i specified in Sections 6.5.2.7 and 6.5.2.8. F RECORDS I 6.5.2.10 Records of Company Nuclear Review Board activities shall be prepared, approved and distributed as indicated below:

a. Minutes'of each CNRB meeting shall be prepared, approved and forwarded to the Executive Vice President, Operations and CNRB members within 14 days following each meeting.

b. Reports of reviews encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Executive Vice

- President, Operations and CNRB members within 14 days following completion of the review.

c. Audit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Executive Vice President, Operations and CNRB members and to the management positions responsible for the areas audited within 30 days af ter completion of the audit.

1 6.6 REPORTABLE OCCURRENCE ACTION 6,6.1 The following a ions shall be taken for REPORTABLE OCCURRENCES: n.

a. The Commissi all be notified and/or a report submitted pursuant to the requirements of Specification 6.9.

b. Each REPORTABLE OCCURRENCE requiring 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months notification to the Commission shall be reviewed by the SRB and submitted

? to the CNRB. u m r f E Unless otherwise specified, notification and reporting requirements stated as to the " Commission" shall be submitted to the Director of F( the Office of Inspection and Enforcement, Region III. s( DAVIS-BESSE, UNIT 1 l 6-12 ' 1 ADMINISTRATIVE CONTROLS , 6.7 SAFETY LIMIT VIOLATION { ~ 6.7.1 The following actions shall be taken in the event a Safety Limit I is violated: p a. The facility shall be placed in at least HOT STANDBY within [ one hour.

b. The Safety Limit violation shall be reported to the Commission, h the Vice President, Energy Supply and to the CNRB within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

. c. A Safety Limit Violation Report shall be prepared. The report

1. shall be reviewed by the SRB. This report shall describe (1) applicable circumstances preceding the violation, (2) r effects of the violation upon facility components, systems or j structures, and (3; corrective, action taken to prevent recurrence.

r~ d. The Safety Limit Violation Report shall be submitted to the Commission, the CNRB and the Vice President, Energy Supply [- within 14 days of the violation. t 6.8 PROCEDURES x 6.8.1 Written procedures shall be established, implemeted and main-tained covering the activities referenced below: - a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November,1972.

b. Refueling operations.

c. Surveillance and test activities of safety.related equipment.

d. Security Plan implementation.

e. Emergency Plan implementation. l

! f. Fire Protection Program implementation. - r - - _ . g. The radiological enviromental monitoring program. - h. The Proress Control Program ~ sw m 6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed by the SRB and approved by the Station Superintendent prior to

{ implementation and reviewed periodically as set forth in administrative procedures.

DAVIS-BESSE, UNIT 1 L 6-13 t ADMINISTRATIVE CONTROLS power operation), supplementary reports sha'll be submitted at least every three months until all three events have been completed. ~f ? ANNUAL OPERATING REPOR ' 6.9.1.4 Annual reports covering the activities of the unit during the p previous calendar year shall be submitted prior to March 1 of each year. {~ The initial report shall be submitted prior to March 1 of the year following initial criticality. 6.9.1.5 Reports required on an annual basis shall include: - a. A tabu'ation on an annual basis of the number of station, j utility and other personnel (including contractors) receiving i exposures greater than 100 mrem /yr and their ass iated man rem exposure according to vork and job functions - e.g., F reactor operations and surveillance, inservice inspection, e routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to .- various duty functions may be estimates based on pocket

dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20% of the individual total dose need

_ not be accounted for. In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions. / , -== .N. p- b.f(The results of steam generation tube inservig \ performed during the report period)ppecification .o.a.o). oections m W Jw f MONTHLY OPERATING REPORT 6.9.1.6 Routine reports of operating statistics and shut _down exoerience shall be submitted on a monthly basis to the Director /JiffTce of Manage-J n [ Cneiit_ aifd PrJgngs) U.S. Nuclear Regulatorv Commission _.-pg@h, u Insoec_ tion and Enforc D.C. 20 sos, witn a copy [RieiiEhno later than the IRth o to the Regional gnonth c _ f r l.1,p Office @QAdagDn y_ vered by the recort.Maltion, any changes to the Offsite Dose C'al-E - cuTationar Maffual~of Specification 6.14 shall be submitted with the f Monthly Operating Report within 90 days in which the change (s) was made I l @3ffective. - - A - A y av' - 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. This tabulation supplements the requirements of 820.407 of " f3 C 10 CFR Part 20. =, F 4' r s . DAVIS-BESSE, UNIT 1 '- 6-15 [ ADMINISTRATIVE CONTROLS

e. Failure or malfunction of one or more components which prevents

r. or could prevent, by itself, the fulfillment of the functional j .' requirements of system (s) used to cope with accidents analyzed in the SAR.

I f. Personnel er or or procedural inadequacy which prevents or could l- prevent, by itself, the fulfillment of the functional require-ments of systems required to cope with accidents analyzed in ~ the SAR.

g. Conditions arising from natural or man-made events that, as a direct result of the event require plant shutdown, operation of safety systems, or other protective measures required by technical specifications.

I' h. Errors discovered in the transient or accident analyses or in ( the methods used for such analyses as described in the safety analysis report or in the bases for the technical specifications ~ that have or could have permitted reactor operation in a manner less conservative than assumed in the analyses. r i. Performance of structures, systems, or components that requires j remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident c( analyses in the safety analysis report or technical specifica-l' tions bases; or discovery during plant life of conditions not ' specificallf considered in the safety analysis report or technical specifications that require remedial action or cor-F rective measures to prevent the existence or development of an L unsafe condition. ,- - w - r4 j. Occurrence of radioactive material contained in liquid or l gaseous holdup tanks in excess of that permitted by the ~ limiting condition for operation established in the technical , specifications. A su A A . THIRTY DAY WRITTEN REPORTS L 6.9.1.9 The types of events listed below shall be the subject of written reports to the Director of the Regional Office within thirty days of I occurrence of the event. The written report shall include, as a minimum, a L completed copy of a licensee event report form. Information provided on the licensee event form shall be supplemented, as needed, by additional narrative , material to provide complete explanation of the circumstances surrounding the event.

a. Reactor protection system or engineered safety feature instrument settings which are found to be less conservative than those p l y , ,

, e DAVIS-BESSE, UNIT F 6-17 l ADMINISTRATIVE CONTROLS g ,m r W m < blished by the technical specifications but which do not prevent _( ment of the functional requirements of affected systems u A q A s -

b. Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a f limiting condition for operation.

I

c. Observed inadequacies in the implementation of administrative or r procedural controls which threaten to cause reduction of degree of

, redundancy provided in reactor protection systems or engineered safety feature systems, i d. Abnormal degradation of systems other than those specified in

6.9.1.8.c above designed to contain radioactive material resulting from the fission process. ,

r - f An unplanned offsite release of 1) more than 1 curie of radioactive f material in liquid effluents, 2) more than 150 curies of noble gas - in gaseous effluents, or 3) more than 0.05 curies of radioiodine f in gaseous effluents. The report of an unplanned offsite release of radioactive material shall include the following information:

1. A description of the event and equipment involved.

2. Cause(s) for the unplanned release.

..N _ 3. Actions taken to prevent recurrence.

4. Consequences of the unplanned release, j

' k , f. Exci.eding the liiiting concentration of radioactive materials I released in liqu1 i and gaseous effluents as defined in Specifications 3.11.1.1 and 3.11.2.1. g b sk x - / RADIOLOGICAL PORTION OF THE ANNUAL ENVIRONMENTAL OPERATING REPORT U L / 6.9.1.10 Routine radiological environmental operating reports covering . the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year. 6.9.1.11 The radiological portion of the annual environmental operating reports shall include summaries, interpretations, and statistical evaluation '~ of the results of the radiological environmental surveillance activities for the report period, including a comparison with preoperational studies, operational controls (as appropriate), and previous environmental surveil- - lance reports and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of the land use censuses required by Specification 3.12.2. / The radiological portion of the annual environmental operatin'g reports shall l I 4 i include suninarized and tabulated results'of all radiological environmental i [ ( s samples ta, ken during the report period. In the event that some results are j DAVIS-BESSE, UNIT 1 6-18 V TIVE C0fRROLS I~ i, RADIOLOGICAL PORTION OF THE ANNUAL ENVIRONMENTAL OPERATING REPORT (Continued) i ~( 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. I - SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORTE 6.9.1.12 Routine radioactive effluent release reports covering the j operating of the unit during the previous 6 months of optration shall be submitted within 60 days after January 1 and July 1 of each year. The period of the first report shall begin with the data of initial

criticali ty.

T 6.9.1.13 The radioactive effluent release reports shall include a [ summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from tne unit as outlined in Regula. tory Guide 1.21,- Rev.1, June 1974, " Measuring, Evaluating, and Reporting Radio-7 activity in Solid Wastes and Releases of Radioactive Materials in Liquid j - and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants:, with data sumarized on a quarterly basis following the format of Appendix B thereof. The radioactive effluent release reports shall include a summary of the 7 meteorological consfitions concurrent with the release of gaseous effluents during each quarter as outlined in Regulatory Guide 1.21, Rev.1, June 1974, with data summarized on a qua:-terly basis following the format of j Appendix B thereof. L The radioactive effluent release reports shall include the following information for all unplanned releases to unrestricted areas of radioactive materials in gaseous and liquid effluents:

a. A description of the event and equipment involved

b. Cause(s) for the unplanned release

c. Actions taken to prevent recurrence

~

d. Consequences of the unplanned release.

\. L. S Asingle submittal may be made for a multiole unit station. The j submittal should combine those sections tnat are common to all units at the station; however, for units with separate radwaste systems, the l- g l submittal shall specify the releases of radioactive material from each 1 unit. , DAVIS ~ SE', UNIT 1 6-10 y a l ADMINISTRATIVE CONTROLS ~~ _ ll

l-

[ SEMIANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT (Continued) -( The radioactive effluent release reports shall include an assessment of 7 radiation doses from the radioactive liquid and gaseous effluents released from the unit during each calendar quarter as outlined in Regulatory Guide 1.21, Rev.1, June 1974. In addition, the unrestricted area r boundary maximum noble gas gamma air and beta air doses shall be evaluated.

The meteorological conditions concurrent with the releases of effluents sba.ll be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the Offsite Dose s

@ulation % Manual (00CM).- / / p SPECIAL REPORTS N _/ I 6.9.2 Special reports shall be submitted to the Director of the Office of Inspection and Enforcement Regional Office within the time period , specified for each report. A Special Report is submitted in lieu of other i reports related to the same event; duplicate reporting is not required. These repo-ts shall be submitted covering the activities identified below r pursuant to the requirements of the applicable reference specification:

a. ECCS Actuation, Specifications 3.5.2 and 3.5.3.

b. Inoperable Seismic Monitoring Instrumentation, Specification 3.3.3.3

,, c. Inoperable Meteorological Monitoring Instrumentation, Specification -3.3.3.4

d. Seismic event analysis, Specification 4.3.3.3.2

e. Fire Detection Instrumentation, Specification 3.3.3.8

f. Fire Suppression Systems, Specifications 3.7.9.1 and 3.7.9.2 y - w w 4 _ Inoperable Liquid Effluent Instrumentaticn, Specification 3.3.3.9.c

/

h. Inoperable Gaseous Efiluent Instrumentation, Specification 3.3.3.10.c I 1. Liquid Effluent Quarterly Dose, Specification 3.11.1.2 1

j. Inoperable Liquid Waste Treatment System, Specification 3.11.1.3 \

k. Gaseous Effluent Noble Gases, Specification 3.11.2.2

1. Gaseous Effluent Radioiodines and Particulates, Specification 3.11.2.3 e

m. Inoperable Gaseous Waste Treatment System, Specification 3.11.2.4 ,

" A l n. Environmental Reporting Level, Specification 3.12.1 f t [ \ DAVIS-BESSE, UNIT 1 M y k- .l .. .o , ADMINISTRATIVE CONTROLS I-t r-b 1 ~6.10 RECORD RETENTION 6.10.1 The following records shall be retained for at least five years: _ - a. Records and logs of facility operation covering time interval { at each power level.

b. Records and logs of principal maintenance activities, inspections,

i repair and replacement of principal items of equipment related

- to nuclear safety, r c. ALL REPORTABLE OCCURRENCES submitted to the Commission.

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e. Records of changes made to Operating Procedures,

f. Records of radioactive shipments.

g. Records of sealed source and fission detector leak tests and results.

~

h. Records of a'nnual physical inventory of all sealed source material of record.

6.10.2 The following records shall be retained for the duration of the . Facility Operating License:

a. Records and drawing changes reflecting facility design modifi-cations made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers i and assembly burnup histories.

c. Records of radiation exposure for all individuals entering radiation control areas.

.( l - DAVIS-BESSE, UNIT 1 ) 6-21 i w j l + u. ..

ADMINISTRATIVE CONTROLS - l 1 l - Records of gaseous and liquid radioactive material released to -(_' ' d. the environs.

e. Records of transient of operational cycles for those facility components identified in Table 5.7-1.

f. Records of reactor tests and experiments.

l' g. Records raining and qualification for current members of ~the plant staff. f h. Records of in-service inspections performed pursuant to these l Technical Specifications, r 1. Pecords of Quality Assurance activities required by the QA ! Manual. r j. Records of reviews performed for changes made to procedures or i equipment or reviews of tests and experiments pursuant to 10 I- CFR 50.59.

k. Records of meetings of the SRB and the CNRB.

m 6.11 RADIATION PROTECTION PROGRAM \ Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained - and adhered to for all operations involving personnel radiation exposure. 6.12 HIGH RADIATION AREA l 6.12.1 In lieu of the " control device" or " alarm signal" required bv L paragraph 20.203(c) (2) of 10 CFR 20, each high radiation area in which the intensity of radiation-is 1000 mrem /hr or less shall be barricaded and r conspicuously posted as a high radiation - be controlled by requiring issuance of a. Ad entrancA tgeto ehaliation Exposurel e Any individual or group of individuals permi1~t'ea to ent.er suctrareas snal p be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the arec.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset inte-

? grated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them. / 0 f 5/ Health Physics personnel shall be exempt from the issuance require-(- % mert during the performance of their assigned radiation protection duties, l provided they comply with approved radiation protection procedures for j entry into high radiation areas. l l g -ll DAVIS-BESSE, UNIT 1 6-22 ' ~ ~ m_ gas. ~ .. ADMINISTRATIVE CONTROLS , c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This -(. individual shall be responsible for providing positive control over the activities within the area and shal' perform periodic radiation surveillance at the frecuency specifiori hv tha ~ ~ ~ , facility Health Physicist in the@iadiation Exposure Pehnit] 6.12.2 The requirements of 6.12.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than I 1000 mrem /hr. In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the acministrative control of the Shift Foreman on duty and/or r the Health Physicist. I r R0 CESS CONTROL PROGRAM (PCP) { / ~ / 6.13.1 The PCP shall be a manual containing selected operational information w concerning the solidification of radioactive wastes from liquid systems. F 6.13.2 The PCP shall be maintained at the station consistent with these Technical Specifications and approved station procedures. {x l 6.14 0FFSITE DOSE CALCULATION MANUAL (0DCM) ,._ 6.14.1 The ODCM shall describe the methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluents monitoring instrumentation alarm / trip setpoints consistent with the applicable LCO's s contained in these Technical Specifications. ' ~ 6.14.2 The ODCM shall be naintained at the station and will reflect accepted methodologies and calculational procedures.

- I F

C F b' k i DAVIS-BESSE, UNIT 1 [6-23 r e -- Delats cnd/cr inscrt, cc indicatsd, th2 following pagis of App:ndix B to the Facility Operating License NPF-3. .- DEIffE INSEAT .( i i 11 11 111 iv ' 2.4-1 2.4-2 2.4-3 2.4-4 2.4-5 2.4-6 2.4-7 2.4-8 2.4-9 2.4-10 2.4-11 2.4-12 2.4 -13 2.4-14 2.4-15 2.4-16~ 2.4-17

7 2.4-18 -

3.2-1 - 3.2-2 3.2-3 3.2-4 3.2-5 3.2-6 3.2-7 3.2-8 3.2-9 . 3.2-10 3.2-11 P 5.4 5.4-1 5.4-2 5.4-2 5.4-2a 5.4-3 5.4-4 5.5-1 5.5-1 ( u. n [ DB-1 l ENVIRONMENTAL TECHNICAL SPECIFICATIONS TABLE OF CONTENTS ,. PAGE l- \ LIST OF TABIIS . . . . .. . . . . . ... .. . . . ........ 11 LIST OF FIGURIS . . . .............. . ........ 11 1.0 DEFINITIONS .. . . ........... .. . . . ........ 1.0 2.0 LIMITING CONDITIONS FOR OPERATION .... .... . ........ 2.1-1 2.1 Thermal . . . . ...... ..... .. . . . ........ 2.1.1 Maximum Discharge Temperature Difference . ....... 2.1-1 2.2 (Reserved) 2.3 Chemical . . . . ..... . .. .. ..... ........ 2.3-1 2.3.1 Biocides . .... .. .... .. . . . ........ 2.3-1 2.3.2 pH . . . . .. . . . ...... . . . . ........ 2.3-lb 2.3.3 Other Chemicals . . .... . . . . . . ........ 2.3-2 3.0 ENVIRONMENTAL SURVEILLANCE . . .. ... . ..... ........ 3.1-1 3.1 Non-radiological Surveillance . ... . ... . ........ 3.1-1 3.1.1.a Abiotic - Aquatic . .... . ..... ....... 3.1-1 3 .1. 2 . a Biotic - Aquatic . ..... .. . . . ........ 3.1-4 (\ 3 .1. 2 . b Bioti. - Terrestrial . . . . ... . . ........ 3.1-12 4.0 SPECIAL SURVEILI NCE, AND STUDY ACTIVITIES . . . . . ........ 4.1-1 4.1 Operational Noise Surveillance . .. ..... ........ 4.1-1 4.2 Fish Impingement Study . ..... ....... ....... 4.2-1 4.3 Chlorine Toxicity Study . ............ ....... 4.3-1 5.0 ADMINISTRATIVE CONTROIS . . . ................... 5.1-1 . -_} 5.1 Review and Audit .............. . . ....... 5.1-1 r 5.1.1 Station Review Board . . .... .... . ....... 5.1-1 5.1.2 Company Nuclear Review Board . .. . . . . ....... ( 5.1-1 5.1.3 Quality Assurance Manager . . ...... ....... 5.1-1 5.2 Action To Be Taken In The Event Of Violation Of An r Environmental Technical Specification . . r. . ....... 5.2-1 f 5.3 Operating Procedures . . .. .... . ..... ....... 5.3-1 5.4 Unit Reporting Requirements . . . . . . . . . . . . . . . . . . 5.4-1 5.4.1 Routine Reports . .. ... . . ... . . ....... 5.4-1 5.4.2 Non-Routine Reports ..... . . . . . . ....... 5.4-1 ( 5.4.3 Changes . .... . ... .. . . .. . . ....... 5.4-2 L 5.5 Records Retention . . . . .. .. . ... .... ....... 5.5-1 N Revised 2/27/79 \ , _ - , ,, , -,,--,,,--w , -m_-,-g-- l 1 i i LB-1 1 I ENVIRONMEh7AL TECHNICAL SPECIFICATIONS LIST OF TABLES , N Table # Title Pace 3.1-1 Chemical Usage 3.1-10 DB-1 ENVIRONMEhTAL TECHNICAL SPECIFICATIONS LIST OF FIGURES Figure # Title Pace . 3.1-1 Aquatic Sampling Locations 3.1-9 3

w

11 1 t

! Revised 2/27/79

.4

, e.: DB-1 . 5.0 ADMINISTRATIVE CONTROLS l ,, 5.4 Unit Reporting Requirements 5.4.1 Routine Reports A. Annual Environmental Operatine Report Part A - Nonradiological Reoort - A report on the environmental surveillance j programs / conducted curing the previous calendar year shall be submitted prior [to May 1 of each year. This report shall be submitted to the Director of th - T Regional Office of Inspection and Enforcement, and shall include results of routine radiological (Refer to Appendix A. Sections 6.9.1.10, 6. 9.1.11) and sann-radiolocical monitoring erograms./'The period of the first report shall' begin with the date of commercial operation. The report shall include descrip-tive summaries and presentation of results, if available, of the special surveillance and study activities (Section 4), summaries , interpretations , and statistical evaluation of the results of the nonradiological environmental surveillance activities (Section 3) and the environmental monitoring programs required by li=iting conditions for operation (Section 2) for the report period, including a comparison with preoperational studies , operational contro}s (as appropriate), and previous environmental surveillance reports and an assessment of the observed impacts of the unit operation en the en-vironment. In the event that some results are not available the report'shall be submitted noting and explaining the reaso[n{fior to May II) for the missing results. The missing data shall be submitted as soon as possible in g a supplementary report. If harmful effects or evidence of irreversible (~'-- damage are detected by the monitoring, the licensee shall provide an analysis of the problem and a. proposed course of action to alleviate the problem. J 5.4.2 Nouroutine Reports A. Nonroutine Environmental Operating Reports A report shall be submitted in the event that (a) a limiting condition for operation is exceeded (as specified in Section 2, " Limiting Conditions for Operation"), or (b) an unusual or important event occurs that causes a sig-nificant environmental impact, that affects potential environmental impact from unit aperation, or that has high public or potential public interest concerning environmental impact from unit operation. Reports shall be sub-mitted under the report schedule described below:

1. Prompt Report. Those events requiring prompt reports shall be reported within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by telephone, telegraph, or facsimilt transmission to the Director of the NRC Regional Office and within 10 days by a written report to the Director of the Regional NRC Office (with a copy to the Director, Office of Nuclear Reactor Regulation). r f.

t

' 5.4-1 i

Revised 3/1/79 l , DB-1 - 2. 30-Day Report. Those events not requiring prompt reports shall be reported within 30 days by a written report to the Director of the NRC Regional Office (with a copy to ( the Director, Office of Nuclear Reactor Regulation). The reporting schedule for reports concerning it=iting conditions for operation specified in t j)(b) above shall be on the pro =pt schedule. Written 10-day reports shall (a) describe, analyze, and evaluate the occurrence, including extent and magnitude of the impact, (b) describe the cause of the occurrence, and (c) indicate the corrective action (including any significant changes made in procedures) taken to preclude repetition of the occurrence and to prevent si=ilar occurrences involving similar components or systems. The significance of an unusual or apparently important event with regard to environmental impact may not be obvious or fully appreciated at the time of occurrence. In such cases, the NRC shall be informed promptly of changes ~ in the licensee's assessment of the significance of the event and a corrected report shall be sub=itted as expeditiously as possible. c , 5.4.3 Change in Environm ntal Technical Specifications A. A report shall be made to the NRC prior to implementation of a change in unit design, in unit operation, or in procedures described in \ Section 5.3 if the change would have a significant effect on the environment or involves an environmental matter nr question not pre- l viously reviewdd and evaluated by the NRC. The report shall include a description and evaluation of the change and a supporting benefit-cost analysis. B. Request for changes in environmental technical specifications shall be submitted to the Director, Office of Nuclear Reactor Regulation, l for review and cuchorization. The request shall include an evalua-tion of the environmental impact of the propor i change and a supporting benefit-cost analysis, o ? I .. s - l 5,4-2 1 Revised 2/27/79 l i l l yu Db - 5.0 ADMINISTRATIVE CONTROIS 5.5 Records Retention (~. 5.5.1- Records and logs relative to instrument calibration and s che. analysis shall be retained for five years except as describes Section 5.5.2. 5.5.2 ' All records and logs relative to the following areas shall be retained for the life of the unit: 5.5.2.1 Records and drawing changes reflecting unit design modifications made to systems and equipment described in the unit's Environmental Report. 5.5.2.2 Records of environmental monitoring surveys. w a 5.5.2.h Minutes of Station Review Board and Company Nuclear Review Board meetings. [4l Copies of all superseded operating procedures which affect 5.5.2.d the environment. V . ~_ 5.5-1 Revised 2/27/79 i ~ ' / l . 3 G - SEP 01 t373 ..~ Toledo Edison Coupany Docket No. 50-346 ATTd: !!r. J. Willianson President and Chief Exccutive Edison Plaza l 300 Madison Avenue Toledo, 0!! 43552 Gentlemen: Inspectors from our F.sgion III (Chicago) office recently completed a spacial insacc: ion to revicu a rcortable occurrence involving design , and installation defects associated witn the sequcacer logic of the I , Safety Featuro Actuation System. The findings of this inspection, which included itus of noncompliance, were raviewed with the Plant Superin- {j} v tendent during the inspection and vero discussed by Mr. Keopicr, I)irectar, Region III and acr.bers of his staff with Toledo Edison ! Corporate canagecent on nugust 15, 1973. The iters of noncorpliance ) identified during the inspection are listed in Appendix A to this letter. Our findings indicated that modifications nado to the sequencer logic' ) portions of the Safety Feature Actuation System wero 'conpleted on ~ . ~ February 12, 1977, and that tne startup check-out was conpleted en A .. February 14, 1977. This startuo check-out did not detect the existing utring errors. Tae preoperational test perforned on tnis systaa was completed on Fet,ruary 23, 1977, and did not indicato any systc; opera-bility probicas. In adJition a scheme check was nade on the nodifica-tion, which indicated no~Giring errors. However, on June 2,1573, during the performance of a surveillanca test on a portion of '.nt. Safaty Feature Actuation System, the problem with the sequencer was i finally identified. - Because of the significance of the defects with the sequencer logic of the Safety Feature Actuation Systen, the enforcerent aspects of this case have been ascalatad frca the Regional Office to Headquarters for handling. -

la addition to the need fcr corrective actions regarding the specific items of noncocplia::ce listed in appendix A, we are concerned about the 73-effectivenass of your nanagement control over testing activitics. Consequently, in your reply, you should discuss the actions taken or ( ) d N'/ C OTIFIT" " il- ~

tLYuM :1dIW REOUESTED _g ./

( 0018 0 Qf l l ~U . f 4 \ w/ Toledo Edison Cor sny 2-planned to irarove this area. ' action plar.ned or taken to ensure shat:Soecifically descr%c the additicnal ~.. Q pJ

2) system test procedures are written and review ocedures and, ssure that plant operaticns corponents. are not dependent on undertested systras

, equip:ent, or Your written reply to this letter and fictice of Violatio of our continuing inspections of your activities acti determining whether further escalated enforcenentered uillin be considn Penalties or Orders ray be required to assure futuras Civil on such e cocpliance. 1 l ' Title In accordance 10, Code of Federal with Section Regulations, 2.790 a copy cf theof this itRC's Rul lettractice, enclosure will .be placed in the tiRC's Public er . Docurent and the Room Sincerely, O ' "j ' N. C. Ifoseley, Director Division of Reactor Coerations Inspection Office of Inspection and Enforcecent

Enclosure:

. i Appendix A, !!otice Distribution:

of Violation PDR MSIC IE Files i LPDR

- TIC Central X005 Files File Reading (uollow)

State of Ohio EDO Reading File J. G. Davis IE Reading File N. C.110seley, OLE C. Norelius, RIII F. Ingram PA J. P. : urr,ay, ELD

\

J. Lieberman ELD \

M. Grossman,,EL3 L. Engle. 00R:f.3 !

j -

J. Crooks, !!IPC .i

) .)

T. J. IfcTiernan, IA .

W. P. Ellis -

i T. W. Brockett G. R. Klingler, ROI:IE

\

m LT "" ) ROI ROI ROI GX11ngler JSniezek HCUoseley L 9/ /78 9/ /78 g/ /73 1

b

_ + - - __

1 i

(n.

Q Annendix A il0TICE OF VIOLATICM Toledo Edison Company Docket No. 50-3G 1

. ;

This refers t6 the inspection conducted by representatives of the Region hi (Chicago) affice at the Davis-l: esse Nuclear Pcwer Station, ;

Unit 1, Oak Itarhor, Ohio, of activitics authorized by f;RC License i

!!o. !;FF-1 During this inspection conducted on June 6-8, 13-15, 20-23, and July 17-19, 1973, the follcwing aoparent itens of noncompliance were ,

identified. Iten 1 is a violation. Itces 2 and 3 are infractions. 1 I

1. Section 3.8.1.1.b of the Technical Specifications requires that '

two separate and independent AC diesel generators be operable when )

the reactor is in 1:cdes 1, 2, 3, and 4. Section 4.0.1.1.2.c.3, which states the requirecent for deconstrating operability, requires that the diesel generator start on a loss of offsito power in con-junction with a safety injection signal, de-energize and load <

shed the essential buses and energize the auto-connected essential l loads through the load sequencer. Section 3.3.2.1, Table 3.3-3, Q

\* r iten 4 of the Technical Specifications reoutres sequence logic channels of the SFAS to be operable when the reactor is in Mcdes 1, 2, 3 and 4.

Contrary to the above, two separate and independent AC diesel generators were not operable when the reactor was operated in Modes 1, 2, 3, and 4 for startup testing purposes during the pcried August 12, 1977 through April 28, 1978 Because of inoperability of the scquence logic char.ncis of the SFAS, the diesel generators were not canable of auto-connecting essential loads to essential buses C-1 and L-1 for all conditions of safety injection signals in con-ju;.ettor with a loss of offsite power.

This violation had the potential for contributing to an cccurrence related to health and safety.

2. The r6quirements of 10 CFR Part 50, Anpendix B, Criterion XI, and Section 17.2.11 of the F5AR as implemented by the Toledo Edison Quality Assurance Procedure i;o. 2110. " Test Control," state that l

a test progran shall be established to assure that all testing l

required to der.onstrate that structures, systems and components will -

perfarn satisfactorily in service is identified and perfcreed in '

accordance with vritten test procedures which incorpoiate the requirements and acceptance limits contained in applicable desicn t

docucents.

l C l

~

8003 18o(30 _

% e l (/)

-Appendix A .

Contrary to the above, a test program was not adequately establish 2d.

Specifically,

n. The preoperational test TS 310.02, ' Integrated SFAS Tast,'

perfort.:cd February 19-23, 1977 rtid not adequately test the feature of the SFAS designed to ceae with a loss of offsite power followed by a safety injection (SFAS) signal.

b. The schene check dated March 15, 1977, perfor.ned in cen.iunc-tion with the design rodifications to the Safety Features Actuation System co~pleted under Systen Revision I:ctice C21C dated February 14, 1977 did not rect the recuiremnts of the Cali*c ration and Functional Testing Procedures 1-C, 'Schere Verification Procedure," Pevision 1 steps 6.5 and 6.6 in that the scheme check did not identify the circuit abnorralities discovered in June 1973 nor insure proper control over codifications of the diesel generator circuitry.

3. Section G.3.1 of the Technical Specifications requires that written procedures be established, irplemented and r.ajntained.

' Adr.inistrative Procedure 1823.00 'Jur.per and lift Wire Control

)j Procedure requires a conthly review by the Operations i'ngineer or .

v his representative of the j=per and lifted wire log to prevent j carrying entries for a long period. ;

Contrary to the above, renthly reviews of the jumper and lifted wirc log were not adequate to prevent carrying entries for a long period in that during Jure 1970, lifted wire tags which had toen installed in Parch 1977 for testing purposes were found in cabinets CDF 11A-2 and CDC ? C on open slide links.. The quality of the

' monthly. reviews was not adequate in that these open slida links would have preventad valves ;'S 105 and ::S 106A from closing in the event that the stcaa supply lines to the au.tiliary feedwater punps ruptured.

As you are aware from the "Critoria for Deteminir.g Enforectent Action.'

which was provided to the ::P.C licensces by letter dated December 31, 1974, the enforce.~.nt actions available to the MRC include administra-tive actions in the fem of written notices of violation, civil ccnetary

cnalties, and orders pertaining to the redification, susnension or revocation of the license. After careful evaluation of the iter.s of noncompliance set forth above and the enforcement history at the -

Davis-Losse facility, we conclude that this : otico of Violation is the -

appropriate action at this tir.e.

Q' 1

i j --

2

-~ ,

.;

\p)

M Appendix /s .2 -

j

0" 2*2 I o h ::.h hu e o Pagulations. Section 2 no Pf,tce' .t 'f ' 0' C ca of Vcalcral cc wRhin twenty (20)dayscfyouYre)ccfp o t ks r t{ , sn'itttn st:te' cr.t er explanation in reply, includino' (1) tl " # UPS hich have been taken and tha results achi i ( ) CWective steps ethich t;ill i Le takan to avoid furth nn liancc and (3) the date when full co,. m

'- Pliance will be achieve t

9 6

4 08 S

l

~

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FACIUTY REQUESTED COMP.tETION DATE REQUESTOR D -

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7 8 C N O R E L I UlS ACTION REQUESTED RECOMMENDED HEADQUARTERS NOTICE OF VIOLATION m

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REFERENCES:

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Enclosure:

REFERENCES:

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