ML19351F511

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Proposed ETS (Nonradiological) for Facility
ML19351F511
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 01/02/1981
From:
PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML19351F508 List:
References
NUDOCS 8101130398
Download: ML19351F511 (44)


Text

{{#Wiki_filter:O ATTACIDENT 6 PROPOSED APPENDIX B i l l l l l I i l l l l l 1 0101130 % $

} APPENDIX B ! 12 i OPERATING LICENSE NO. DPR-34 ENVIRONMENTAL TECHNICAL SPECIFICATIONS i 6 EU R TIIE FORT ST. VRAIN NUCLEAR GENERATING STATION PUBLIC SERVICE COMPANY OF COLORADO ECKET_No._50-267 i I I \ l i i l f I_ _ _ _. - et

Fort St. Vrain #1 Technical Specifications Appendix B Table of Contents Page 1 of 1 TABLE OF CONTENTS Environmental Technical Specifications

1.0 INTRODUCTION

2.0 DEFINITIONS 3.0 EFFLUENT DISPOSAL SYSTEM 3.1 Radiological Effluent Disposal System Specification ELCO 3.1.1 - Radioactive Caseous Effluent, Limiting Conditions for Operation Specification ESR 3.1.1 - Radioactive Gaseous Ef fluent, Surveil-lance Requirements Specification F.LCO 3.1.2 - Radioactive Liquid Ef fluent, Limiting Ccnditions for Operation Specification ESR 3.1.2 - Radioactive Liquid Effluant, Surveil-lance Requirements Specification ELCO 3.1.3 - Reactor Building Surp Effluent, Limiting Conditions for Operation Specification ESR 3.1.3 - Reactor Building Suep Ef fluent, Surveil-lance Requirements Reporting Requirements EAC 3.1.1 - Radiological Effluent Reports 3.2 Non-Radiological Effluent Disposal System Specification ESR 3.2.1 - Non-Radiological Ef fluent Surveillance Requirement

Reporting Requirements EAC 3.2.1 - Non-Radiological Effluent Reports 4.0 ENVIRONMENTAL SURVEILLANCE l

l 4.1 Environmental Surveillance Program ! Specification ESR 4.1.1 - Environmental Radiological Surveillance i Requirements Reporting Requirements EAC 4.1.1 - Environmental Reports 5.0 ENVIRONMENTAL ALMINISTRATIVE CONTROLS Specification EAC 5.1 - Recordkeeping Specification EAC 5.2 - Organization and Review Specification EAC 5.3 - Procedures Specification EAC 5.4 - Changes in Environmental Technical Specifica-tions l

Fore Se, Vrain #1 Technical Specifications Appendix a Page 1 of 41

1. 0 INTRODUCTION These Environmental Technical Specifications apply to the Fort St. Vrain Nuclear Generating Station Unit No.1. These specifications address the total environmental monitoring program; the Radiological Ef fluent Disposal System, the Non-Radiological Effluent Disposal System, the En-vironmental Radiological Surveillance Program, and the Environmental Administrative Controls.

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Fort S t. Vrain #1 Technical Specificationa Appendix B Page 2 of 41 ENVIR.ON! ENTAL,TEQiNICAL SPECIFICATIONS 2.0 DEFINITIONS The following frequently used terms are defined to provide a uniform basis for interpretation of the Technical Specifications. 2.1 Blowdown Blowdown is that effluent released f rom the open circulating water systems to control the concentration of chemical constituents. The release is normally made from the hot water side returning to the cooling towers. Provisions have been made to f acilitate re-lease of the blowdown f rom the cold unter side, leaving the circu-s lating water cooling tower. 2.2 Mon-Radioactive Effluent Non-radioactive effluent is an effluent released from the plant containing only background radioactivity; effluent not released from the plant radioactive effluent treatment system. 2.3 Normal Ef fluent Discharge Path Normal effluent discharge path is the effluent discharge path along the Goosequill Ditch, :l.he Jay Thomas Ditch, through the farm pond into the Platte River. 2.4 Alternate Effluent Discharge Path Alternate effluent discharge path is the effluent discharge path along the Goosequill Ditch through a drainage slough into the S t. Vrain River.

Fort St. Vrain #1 l Technical Specifications i Appendix B Page 3 of 41 2.5 Radioactive Effluent i J Radioactive effluent is an effluent released form the plant con-taining radioactivity above the background level in the environs of the plant.

2.6 Background

Background is the natural occurring radiation levels as determined from the prestartup phase of the Environmental Radiation Surveil-lance Program. 2.7 Exclusion Area Exclusion area is a one square mile area within the site boundary with the plant located near the center of the area, as defined in Section 1.2.1 of the FSA't. 2.8 Unrestricted Area Unrestricted area is the area outside the Exclusion Area. 2.9 composite Sample Composite sample is a single sample consisting of many separate l aliquots obtained at various times. The individual aliquots are collectred at time intervals which are very short (e.g., hourly) relative to the compositing period (e.g., monthly).

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  • Fort St. Vrain #1 Technical Specifications Appendix B Page 4 of 41 3.0 EFFLUENT DISPOSAL SYSTE't 3.1 Radiological Ef fluent Disposal System Objective To assure that the quantity of radioactive effluent released f rom the plant is maintained as low as reasonably achievable and, in any event within the limits of 10CFR20 and in accord with 10CFRSO. t Specification ELCO 3.1.1 - Radioactive Caseous Ef fluent, Limiting Conditions for Operation a) Analysis of gaseous effluents from the gas uaste surge tanks shall be made on an isotopic basis and releases shall be limited in accordance with the following equation:

Er i Ci g,3 x 10 10 en 3 (MPC)1 sec Where r is the release rate in std. cc/sec; Ci is the concen-tration in pCi/std. ec of any radioisotope,1; and (MPC)i is in units of pCi/ce, as defined in Table II, Column 1, of Ap-pendix B to 10CFR20. I b) For purposes of calculating permissible release rates by the

above formula, MPC for halogens and particulates with half lives 1

longer than 8 days will be reduced by a factor of 700 from their listed value in Table II, Column 1, of Appendix B to 10CFR20. If conditions a) and b) cannot be met, immediate action shall be taken to terminate release from the gas waste system. If con-ditions a) and b) cannot be met with this termination of gas waste system releases, the reactor shall be shutdown immediately.

Fort St. Vrain #1 Technical Specifications Appendix B Page 5 of 41 c) Except for air ejector discharge, secondary coolant system relief valves and deaerator vent, all normal releases of gaseous waste from the plant shall be filtered through the reactor building ventilation exhaust particulate and charcoal filters. d) The maximum amount of gaseous radioactivity in a gas vaste surge tank shall not exceed 370 equivalent curies of 88Kr. If condition d) cannot be met, immediate action shall be taken to terminate any operations which result in the production of radioactive gases for storage in the tank. e) Prior to the release of gaseous radioactivity from the gas waste surgc tanks, the contents shall be sampled and isotopi-cally analyzed to determine that releases are in compliance i with conditions a) and b). i f) Under normal operating conditions, tritium from the H2 getters shall be disposed of as solid waste on an adsorbent material. g) At least one reactor building exhaust fan shall be operating whenever releases from the gas waste system are taking place. h) Gaseous radioactive effluents released from the plant shall be continuously monitored and recorded.

1) During power operation and/or a release f rom the gaseous i vaste holdup system, one noble gas monitor, one halogen j monitor, and one particulate monitor and their associated recorders shall be operable.
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Fort Sta Vrain #1 Technical Specifications Appendix B Page 6 of 41

2) If the halogen monitor or the particulate monitor or their associated recorder becomes inoperable, gaseous effluent releases from the reactor building ventilation system may continue for up to 30 days provided the effluent stream is continuously monitored with auxiliary sampling equipment.
3) If both noble gas monitors or their recorder become i

inoperable, gaseous ef fluent releases fron the reactor building ventilation system, exclusive of releases from the gas waste holdup system, may continue for up to 30 days provided grab samples are taken at least once per 8 hours and these samples are analyzed for gross beta activity within 24 hours.

4) If both noble gas monitors or their recorder become inoperable, gaseous effluent releases f rom the gas vaste holdup system may continue for up to 14 days provided that prior to the release:

I

a. Duplicate samples of the gas waste holdup system con-1

) tents are analyzed; and

b. At least two technically qualified members of the facility staff independently verify the release rate calculations and discharge valve lineup.

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Fort St. Vrain fl Technical Specifications Appendix B Page 7 of 41

5) If the gaseous ef fluent system flow rate measuring device or a gaseous effluent monitor flow rate measuring device becomes inoperable, gaseous effluent releases may continue for up to 30 days provided the flow rate is estimated at least once per 4 hours.

Specification ESR 3.1.1 - Radioactive Gaseous Effluent, Surveillance Requirements Radioactive gaseous effluent equipment shall be demonstrated oper-able as follows: a) The gas waste header activity monitors and exhaust vent monitors shall be source checked prior to each release, functionally tested quarterly, and calibrated once per 13 months and following maintenance on the detector system, b) Automatic vent exhaust high activity blocking and transfer functions of the gaseous vaste system shall be tested prior i to each controlled release or once a month, whichever is more

,      frequent.

c) Flow recorders shall be functionally tested quarterly and cali-l brated once per 18 months.

Fort St. Vrain 31 Technical Specifications Appendix B Page 8 of 41 d) The on-line vent iodine / particulate monitor filter shall be analyzed for gross alpha and gross beta activity and gamma emitting nuclides once per week. e) The on-line vent iodine / particulate monitor charcoal cartridge shall be analyzed for gamma emitting nuclides once per week. Basis for Specification ELCO 3.1.1 The major source of gaseous radioactive was.te will be the regener-ation of the low temperature filter adsorbers of the Helium Puri-fication System. The design objective for the plant's ri.dioactive gas releases is 4160 curies per year; 4120 curies of this are pre-dicted to be icng lived Kr-85 (half lif e is 10.8 years) . Redundant noble gas, iodine, and particulate monitors are available; during power operations and/or release from the gas waste holdup system, only one of eaca type of monitor is required to be opera-tional, r The limiting value for radioactive gaseous release is based on (1/ annual average dilution f actor). The estimated 800 Ci per year of tritium evolved from H2 getter regeneration will normally be disposed of as solid waste. Under unusual conditions, such as a steam generator tube leak, it may be necessary to release the tritium to the atmosphere. l l l l l

Fort St. Vrain #1 Technical Specifications Appendix B Page 9 of 41 The limitation on the curie inventory of a waste gas surge tank is to limit potential site exclusion radius whole body doses to less than 0.5 rem in the event of a tank rupture. It is the intent that through these operating limits, the annual releases from this plant will be as low as reasonably achievable. At the same time, the licensee is permitted flexibility of oper-ation, compatible with considerations of health and safety, to as-sure that the public is provided a dependable source of power even under unusual operation conditions which may temporarily result in releases higher than small fractions of, but still within, limits specified in 20.106 of 10CFR20. It is expected that in using this operational flexibility under unusual operating conditions, the licensee will exert his best efforts to keep levels of radioactive material in effluents as low as reasonably achievable. Specification ELCO 3.1.2 - Radioactive Liquid Effluent, Limiting Conditions for Operation a) The maximum instantaneous release rate of radioactive liquid effluents from the site shall be such that the concentration of radionuclides in the blowdown does not exceed the values specified in Table II, Column 2, of Appendix B to 10CFR20. If plant conditions exist such that the concentration of radio-activity in the liquid effluent from the plant exceeds those specified in 10CFR20, Appendix B, immediate action shall be taken to terminate the release.

Fort St. Vrain #1 Technical Specifications Appendix B Page 10 of 41 b) Prior to release, duplicate samples of liquid effluent from the radioactive liquid waste system shall be analyzed for gross alpha activity, gross beta activity, a gamma spectral analysis shall be performed, and the samples will be analyzed for other radioisotopes of concern, as identified by previous operating experience. Liquid waste shall not be released to unrestricted areas from the liquid waste systen if the gross beta concen-tration exceeds 3 x 106 pCi/ce. c) All liquid effluent releases from the radioactive liquid waste holdup system shall be continuously monitored by two activity monitors and their associated recorder. Equipment shall be opar-able to automatically terminate the release on high specific activity or low circulating water blowdown flow. d) If one or both of the two activity monitors become inoperable, liquid effluent releases may continue for up to 14 days pro-l l vided that prior to initiating the release, at least two tech-nically qualified members of the f acility staff independently l verify the release rate calculations and discharge valve lineup. l e) If the recorder associated with the two activity monitors be-comes inoperable, liquid effluent releases may continue for l up to 30 days provided a gamma spectral analysis is perforned l l at least once per 4 hours during actual releases. f) If the blowdown flow measuring devices become inoperable, liquid effluent releases may continue for up to 30 days provided the flow rate is estimated at least once per 4 hours during actual I releases.

Fort St. Vrain #1 Technical Specifications Appendix B Page 11 of 41 Specification ESR 3.1.2 - Radioactive Liquid Effluent, Surveillance Requirements Radioactive liquid effluent equipment shall be demonstrated oper-able as follows: a) The level alarms and pump interlocks on the two liquid waste receiver tanks and monitoring tank shall be tested once per year. b) The liquid effluent discharge blocking valve shall be func-tionally tested prior to each release or once a mcuch, which-ever is more frequent. c) The activity monitors of the liquid waste disposal line and the low cooling water blowdown flow switch shall be functionally tested quarterly. The activity monitors shall be source checked prior to each release and calibrated once per 18 months and following maintenance on the detector system. d) Flow rate monitors and activity recorders shall be functionally tested quarterly and calibrated once per 18 months. Basis for Specification ELCO 3.1.2 Liquid waste from the radioactive waste disposal system is diluted in the cooling tower blowdown flow. Interlocks between the waste treatment system discharge valve, the discharge line radiation monitors, and the cooling tower blowdown flou meter will terminate the discharge of waste in the event of high activity and/or low blowdown flow.

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Fort St. Vrain #1 Technical Specifications Appendix B Page 12 of 41 It is expected that plant releases of radioactive materials and effluents will be small fractions of the limits specified in 10CFR20.106 and will be held as near to background levels as reasonably achievable. The design objective of the liquid waste treatment system was to limit annual liquid waste discharge from the plant to 0.2 curies (excluding tritium and dissolved noble gas). The liquid waste dis-charged f rom the plant will normally flow to a farm pond (Goosequill Pond) on the north end of the Public Service Company propertv near the confluence of the St. Vrain Creek and the South Platte River. Goosequill Pond drains to the South Platte River. An alternate flow path is to a slough which drains to the St. Vrain Creek. The oper-ational environmental surveillance program directs special attention to these areas so that possible buildup of radioactivity will be detected. It is expected that releases of radioactive materials in effluents will be only small fractions of the limits specified in 20.106 of 10CFR20. At the same time, flexibility of operation, compatible with considerations of health and safety, assure that the public is provided a dependable source of power, even under unusual operating conditions which may temporarily result in re-l l 1 eases higher than small fractions of, but still within, the limits specified in 20.106 of 10CFR20. It is expected that, in using this operational flexibility under unusual operating conditions, the licensee will exert his best ef-forts to keep levels of radioactivity in effluents as low as reasonably i achievable.

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Fort St. Vrain #1 Technical Specifications Appendix B Page 13 of 41 Specification ELCO 3.1.3 - Reactor Building Sunp Effluent, Limiting Conditions for Operation a) The discharge from the reactor building sunp pumps shall be con-tinuously sampled, filtered, .uht & thu ..imited to < 10 gpm when operated in the automat 1r role. an analysis shall be per-formed as soon as practical on the composite sample per ELC0 3.1.2.b). b) If effluent discharges from the reactor building sump at flow rates greater than 10 gpm are to be made, two grab samples shall be taken and analyzed per ELCO 3.1.2.b) prior to the start of the discharge. During the discharge, the pump outlet shall be sampled to assure compliance with Table II, Column 2, 10CFR20, Appendix B. c) Effluent discharges from the reactor building sump shall not occur simultaneously with discharge from the radioactive liquid waste system. d) All liquid effluent releases from the reactor building sump shall be continuously monitored by two activity monitors and their associated recorder. Equipment shall be operable to automatically terminate the release on high specific activity or low circulating water blowdown flow.

1 1 Fort St. Vrain #1 Technical Specifications Appendix B Page 14 of 41 i e) If one or both of the two activity monitors become inoperable, liquid effluent releases may continue for up to 14 days pro-vided that prior to initiating the release, at least two tech- ! nically qualified members of the f acility staf f verify the release rate calculations and discharge valve lineup. f) If the recorder associated with the two activity monitors be-ccmes inoperable, liquid effluent releases may continue fer up to 30 days provided a gamma spectral analysis is performed at least once per 4 hours during actual releases. g) If the blowdown flow measuring device becomes inoperable, liquid l effluent releases may continue for up to 30 days provided the flow rate is estimated at least once per 4 hours during actual-releases. h) If the continuous sampler should be inoperable, automatic dis-charge from the sump would be permitted provided daily samples are taken from the sump and analysis made of the composite sample as soon as practical af ter collection as described in ELCO 3.1.2.b). s Specification ESR 3.1.3 - Reactor Building Sump Effluent, Surveil-lance Requirement An analysis per ELCO 3.1.2.b) of the composite sample shall be made three times per week.

Fort St. Vrain #1 Technical Specifications Appendix B Paga 15 of 41 Basis for Specification ELCO 3.1.3

 , Limiting the discharge flow rate from the reactor building sump to
   < 10 gpm provides for effluent monitoring sensitivity to assure con-formance with the limits of 10CFR20, in the highly unlikely event that the sump should contain any radioactive liquid.

Sampling and analysis performed prior to discharging from the sump at flow rates greater than 10 gpm and prohibiting discharge to the radioactive liquid waste discharge line simultaneously with a dis-charge from the radioactive liquid waste system will assure con-formance with the limits of 10CFR20. Reporting Requirements EAC 3.1.1 - Radiological Effluent Reports A report of the radioactive effluent released from the plant during the previous six months of operation will be submitted - to the Di-rector of the NRC Regional Office within 60 days af ter January 1 l and July 1 of each year. This report will include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released f rom the plant, as well as a summary of the meteor-l ological conditions concurrent with the release of gaseous effluent. L f

Fo rt S t . Vrain #1 Technical Specifications Aopendix B Page 16 of 41 3.? Non-Radiological Ef fluent Disposal System Objective The purpose of this specification is to ensure that chemical con-centrations in the effluent, and effluent temperatures, are main-tained sufficiently low so as to cause no unacceptable environmental impact. Specification ESR 3.2.1 - Non-Radiological _ Ef fluent Surveillance Requirement Non-radiological effluent monitoring shall be conducted in accordance with NPDES discharge permit number C0-0001121. If the limits speci-fied in this discharge permit are exceeded, immediate corrective action shall be initiated to re-establish acceptable chemical con-centrations or temperatures of the effluent. Basis for Specification ESR 3.2.1 The major sources of non-radioactive liquid effluent fron the plant are the two cooling water systems - circulating water and service water. The makeup water to these systems are the St. Vrain Creek, the South Platte River, and shallow well sources. The water utilized in these systems is treated with various chemicals to provide for pH control, algae and biological growth control, and to control the tendency for scale formation on heat transfer surfaces. Because the systems are recirculating and use mechanical induced draf t

Fort St. Vrain ill Technical Specifications Appendix B Page 17 of 41 cooling towers as a means for heat dissipation, concentration of the naturally occurring dissolved solids is brought about by evap-oration in the towers. The pcimary source of possible trace metal contamination for these systems would be the heat exchange surfaces and piping, due to corrosive attack by the cooling water. Corrosion is controlled by maintaining the proper pH level. The parameters included in the Technical Specification were selected because they are accepted indicators of water quality, are possibly introduced into the system due to corrosion or are introduced because of the particular type of water treatment used. The limits imposed upon the concentrations of dissolved constituents and range of pH were determined on the basis of normal expected operating concentrations and those concentrations which would be harmful to aquatic organisms in the rivers. The limits stated in the NPDES Discharge Permit are less than those limits published in the literature as being harmful to the aquatic organisms present in the South Platte River and the St. Vrain Creek. The operations of the systems, in excess of the limits stated in the Technical Specification for short periods of time, would not be harmful ecologically to the streams due to the conservative limits and the averaging effect of the farm pond. l l Because the normal path of discharge to the river is through the Goosequill Ditch and the farm pond, there would be no discharge to the St. Vrain Creek. To account for unusual circumstances, ! facilities are provided to discharge blowdown to the St. Vrain Creek - via a slough which drains into the creek. I -

Fort St. Vrain #1 Technical Specifications Appendix B Page 18 of 41 The sampling station locations for determination of effluent dis-charge water quality were specified so as to mir.imize '.he influence on the analytical results from the agricultural activities in the immediate region of the station. The sampling point locations pre-clude the introduction of chemical consituents due to field run off, irrigation tail water, fertilizers, and the like. Sampling at the diversion box also provides a common point of control for both the normal and alte nate discharge paths. AI temperature of 90*F has been established as the upper limit for water overflowing from the farm pond into the South Platte River and for water being discharged through the slough to the St. Vrain Creek. This limit is based on the past temperature history of both rivers and on the desire to minimize thermal effects of the effluent discharge. If the farm pond discharge temperature exceeds i 80*F, blowdown shall be from the cold side of the circulating water tower. This requirement serves to minimize thermal effects on the environment. Reporting Requirements EAC 3.2.1 - Non-Radiological Ef fluent Reports l Results obtained from the Non-Radiological Effluent Surveillance Pro-gram shall be summarized quarterly on the applicable discharge report forms. These quarterly reports shall be submitted to the Director of the NRC Regional Of fice (with a copy to the Director, Office of Nuclear Reactor Regulation) by the end of the month fol-lowing the completed reporting period. If any limit specified in

Fo rt S t . Vrain #1 Technical Specifications Appendix B Page 19 of 41 the discharge permit is exceeded for more than 24 hours, the li-censee shall submit a written report of the occurrence to the Di-rector of the NRC Regional Of fice (with a copy to the Director, Of fice of Nuclear Reactor Regulation) within 5 days. Basis for Reporting Requirements EAC 3.2.1 The Fort St. Vrain Non-Radiological Effluent Disposal Program is presently being conducted in accordance with two different sets of regulations: Those set forth by the U.S. Environmental Protec-tion Agency (EPA) in conjunction with the Colorado Department of Health, Water Q' ality Control Division, and those regulations pre-sently existing in Appendix B of the Technical Specifications, as set forth by the NRC. Although the programs analy=e for the same chemicals in most cases, the sampling frequency, limiting concen-trations, and reporting requirements are different. Specification ESR 3.2.1 provides for a single monitoring program conducted for the NRC and the EPA. NPDES Discharge Permit CO-0001121 is the document which defines the program. All sample locations, sample frequencies, types of analyses, and limiting conditions are clearly delineated in the Discharge Permit. The licensee will submit a copy of each quarterly discharge monitoring report to the NRC as required by Specification EAC 3.2.1. This report is described in the Discharge Permit. l

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Fort S t. Vraia #1 Technical Specifications Appendix B Page 20 of 41 4.0 ENVIRONMENTAL SURVEILLANCE 4.1 Environmental Surveillance Program Objective An environmental radiological monitoring program shall be conducted to provide data on levels of radiation and radioactive material in the site environs. The program shall discriminate between those changes in environmental radiation and radioactivity levels re-sulting from radioactive releases from the nuclear generating station and those changes attributed to other sources, such as world-wide fallout from weapons testing. The program shall evalu-ate the relationship between quantities of radioactive material released in liquid and gaseous effluents, and resultant radiation doses to individuals from principal pathways of exposure. The results of this program shall be used to verify the effectiveness of in-plant measures applied to control the release of radioactive materials. Specification ESR 4.1.1 - Environmental Radiological Surveillance i Requirements t a) An environmental radiological surveillance program shall be j conducted in accordance with Table 4.1-1. l I i

Fort St. Vraia #1 Technical Specifications Appendix B Page 21 of 41 b) Environmental samples of radionuclides released from the plant into the surrounding environment shall be collected and analyzed according to Tables 4.1-1 and 4.1-4. c) Analytical techniques used shall be such that the detection capabilities in Table 4.1-2 are achieved. d) Radiological sampling station locations shall be delineated in maps and in written descriptions contained in each annual environmental radiological monitoring report. All changes in sampling station locations which occur through the year shall be explained in each annual report. e) Deviations are permitted f rom the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automstic sampling equipment, and other legitimate reasons. If specimens are un-obtainable due to sampling equipment malfunction, every effort i shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the annual report. f) The laboratories of the licensee's contractors which perform analyses shall participate in the Environmental Protection Agency's (EPA's) Environmental Radioactivity Laboratory Inter-comparisons Studies (cross-check) Program, or equivalent pro-gram. This participation shall include the determinations _g

Fo rt S t. Vrain #1 Technical Specifications Appendix B Page 22 of 41 (sample medium-radionuclide combination) that are offered by the EPA, which are also included in the monitoring program. The results of analyses of these croas-check samples shall be in-cluded in the annual report. If the results of a determination in the EPA cross-check program (or equivalent program) are outside the specified control limits, the laboratory shall in-vestigate the cause of the problem and take steps to correct it. The results of this investigation and corrective action shall be included in the annual report. g) A census shall be conducted annually during the growing season to determine the location of the nearest milk animal and nearest garden greater than 50 square meters (500 square feet) producing broad leaf vegetation in each of the 16 meteorological sectors within a distance of 8 km (5 miles). The census shall also identify the location of all milk animals, and gardens greater than 50 square meters producing broad leaf vegetation out to a distance of 5 km (3 miles) for each radial sector. If it is learned from this census that the milk animals or gardens are present at a location which yields a calculated thyroid dose greater than those previously sampled, or if the census results in changes in the location used in the Techni-cal Specifications for dose calculatione, a written report shall be submitted to the Director of Operating Reactors, NRC (with a copy to the Director of the NRC Regional Office) within

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Fort St. Vrain #1 Technical Specifications Appendix B Page 23 of 41 30 days, identifying the new location (distance and direction).

     ! Elk animals or garden locations resulting in higher calculated doses shall be added to the surveillance program as soon as practicable.

Die sampling location (excluding the control sample location) having the lowest calculated dose may then be dropped from the surveillance progran at the end of the grazing or growing season during which the census was conducted. Any location from which milk can no longer be obtained may be dropped from the surveil-lance program af ter notifying the NRC in writing that milk samples are no longer obtainable at that location. The results of the land-use census shall be reported in the annual report. Basis for Specification ESR 4.1.1 A preoperational environmental radiation surveillance program for the Fort St. Vrain Station environs has been conducted for the Pub-lic Service Company of Colorado by Colorado State University. Con-tinuous operation of this program since March of 1969 has provided baseline data which will be utilized as control values for statisti-cal analysis of the results of the operational radiological sur-l veillance program. These Environmental Technical Specifications specify the require-ments for the environmental radiological surveillance program which I will continue to be the responsiblity of Public Service Company of

Fort St. Vrain #1 Technical Specifications Appendix B Page 24 of 41 Colorado. Additional monitoring in the vicinity of the facility is conducted or coordinated by other organizations, notably the Colo-rado Department of Health. The results of the radiological environmental surveillance are in-tended to supplesent the results of the radiological effluent sur-veillance by verifying that the measurable concentrations of radio-active materials and levels of radiation are not higher than ex-pected on the basis of the effluent measurements and modeling of the environmental exposure pathways. Th us , the specified environmental surveillance program provides measurements of radiation and of radio-active materials in those exposure pathways and for those radio-nuclides which lead to the highest potential radiation exposures to individuals resulting from the station operation. Sampling lo-cations were selected on the basis of local meteorological conditions and airborne concentrations calculated from those conditions, proxi-mity to the reactor of residences and communities, and other con-siderations in accordance with Table 4.1-1. Each radiological en-vironmental monitoring report shall contain a map and tables which present detailed information regarding sampling station locations. I The sampling and collection frequencies indicated in Table 4.1-1 were selected on the basis of filter loading, crop harvest time, I calculated potential human doses from plant effluents, and other . { considerations. i i a

Fort St. Vrain #1 Technical Specifications Appendix R Page 25 of 41 Samples will be analyzed in accordance with Table 4.1-1 for radio-nuclides which may be attributable to effluents released from :he acility. Table 4.1-2 indicates the achievable detection capabili-ties for environmental sample analysis based upon the instrumenta-tion and analytical procedures utilized. The requirement for participation in the EPA cross-check program, or similar program, is, based on the need for independent checks on the precision and accuracy of the measurements of radioactive mater-ial in environmental sample matrices as part of the quality assur-ance program for environmental monitoring, in order to demonstrate that the results are reasonably valid. The census of milk animals and gardens producing broad leaf vege-a tation is based on the requirement in Appendix I of 10CFR part 50 to " Identify changes in the use of unrestricted areas (e.g., for agricultural purposes) to permit modifications in monitoring pro-grams for evaluating doses to individuals from principal pathways of exposure." The consumption of milk fron animals grazing on con-taminated pasture and of leafy vegetation contaminated by airborne l radiciodine is a major potential source of exposure. Samples from i milk animals are considered a better indicator of radioiodine in the environment than vegetation. If the census reveals milk animals

are not present or are unavailable for sampling, then vegetation must be sampled.

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Fort St. Vrain #1 Technical Specifications - Appendix B Page 26 of 41 The 50 square meter garden, considering 20I used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and a vege-tation yield of 2 kg/m ,2 will produce the 26 kg/yr assumed in Regu-latory Guide 1.109 for child consuwtion of leafy vegetation. _. J

TABLE 4.1-1 OPERATIONAL RADIOLOGICAL ENVIRONf!Et!TAL If0NITORING PROGRAft Exposure Pathway Number of Samples Sampling Type and Prequency and/or Sample and Locations Collection Frequency of Analysis AIRBORNE Tritium Oxide Radioiodine and Samples from 7 locations: Continuous sampler operation Radiofodine Cannister: Pa rticula tes with sami.le collection Analyze weekly for I-131 4 samples f rom o f f-site locations (in weekly or as required by Liquid scintillation dif ferent sectors) of the highest cal- dust loading, whichever is counting for 11-3 on water culated annual average ground level more frequent. vapor extracted from D/Q. silica gel on each sample collected. I sample f rom the vicinity of a com-munity having the highest calculated Particulate Sampler: annual average ground level D/Q. Gross beta radioactivity following filter change, 2 samples from control locations composite (by location) 15-30 km (10-20 miles) distant and for gamma isotopic in the least prevalent wind direc- quarterly.a tion. DIRECT RADIATION 40 stations with two or more Quarterly exposure with one Gamma dose quarterly. dosimeters or one instrument for third of TLD's collected measuring and recording dose rate and replaced each month, continuously to be placed as fol-lows: 1) an inner ring of stations 2 l7 @ 2 in the general area of the site  % % E" boendary and an outer ring in the w E. 3. m 4 to 5 mile range from the site E 0 ." with a station in each sector of R, m "' < each ring (16 sectors x 2 rings t. Ef2

                                     = 32 stations) . The balance of                                                                         "'
                                                                                                                                                   $7 the stations, 8, shall be placed                                                                              [w .

in special interest areas such as E"" population centers, nearby resi-  % dences, schools, and in 2 or 3 $7 areas to serve as control s tations. @ aIf gross beta activity in air or water is greater than ten times the yearly mean of control sample for any medium, gamma isotopic analysis should be performed on the individual samples.

TABLE 4.1-1 OPERATIONAL RADIOLOGICAL EINIRONMENTAL ff0NITORING PROGRAft Exposure Pathway Number of Samples Sampling Type and Frequency and/or Sample and locations Collection Frequency of Analysis WATERBORNE 1 sample upstream, each stream, Sanples collected monthly. Gamma isotopic analysis 1 sample downstream. and composite for tritium monthly. Surface 1 sample in immediate area of discharge. Composite sample over one Gamma isotopic analysis week period, weekly. Composite for tritium weekly. Ground Samples from 2 sources most likely to Ouarterly Camma isotopic and triti-be af fected. um analysis quarterly. Drinking 1 sample from the nearest water supply Composite sample over two Composite for tritium, which could be affected by facility's week period. gross beta and gamma iso-discharge. topic analyses every two weeks. 1 sample f rom a control location. S2diment from I sample from downstream area with Semiannually Gamma isotopic and tritium Shoreline existing or potential recreational analyses semiannually. value. INGESTION Milk Samples from milking animals in all Semimonthly when animals Camma isotopic, Sr-89, 90 locations, up to a total of 3 loca- are on pasture, monthly at analyses, and I-131 analysis tions, within 5 km. other times. semimonthly when animals are on pasture; monthly at other times. 1 sample from milking animals in each

                                                                                                                    %ENnW5
                                                                                                                    ,J 2 ] 4 @. 4 of 3 areas between 5 to 8 km distant                                                          "' n 8 $7 E v3 having the highest dose potential.b                                                              co p g g ,n b                                                                                                                        W      <

The dose shall be calculated for the maximum organ and age group using the methodology contained in Regulatory Guide jfg 1.109 and the actual parameters particular to the site.

                                                                                                                               * [[

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TAllLE 4.1-1 OPERATIONAL RADIOLOGICAL1 ENVIRONIfENTAL !!OllTTORIllG PROGRAlf Exposure Pathway Number of Samples Sampling Type and Frequency _snd/or Sample and Locations Collection Frequency and Analysis 1tilk (Cont'd) I sample f rom milking animals at a con- " emimonthly when animals are S Camma isotopic, Sr-89, 90 trol location (15 to 30 km distant and on pasture, monthly at other analyses and I-131 analysis in the least prevalent wind direction). times. semimonthly when animals are on pasture; monthly at other timas. Aquatic Biota Sample commercially or recreationally Sample in season or semi- Gamma isotopic, Sr-89, 90 impor tant fish, as well as vascular annually if they are not analyses semiannually. plants and aeston in vicinity of dis- seasonal. charge point, upstream and downstream. Food Products I sample of each principal class of At time of harvest. Camma isotopic analysis on food products from any area which is edible portion. irrigated by water in which liquid plant . wastes have been discharged. 3 samples of broad leaf vegetation  !!onthly when available. grown nearest offsite locations of highest calculated annual average ground-level D/Q if milk sampling is not performed. I sample of each of the similar fionthly when available. vegetation 15 to 30 km distant 2R # o$ in the least prevalent wind di- 9 '$ y. ? rection if milk sampling in not u 8, 6 m performed. *p0" is es " < E= n o 8

TABLE 4.1-2 DETECTION CAPABILITIES FOR EliVIRONMENTAL SAttPLE A!!ALYSIS LOWElt LittIT OF DETECTicil l Analysis Water Airborne Particulate or Cas Fish tiilk Food Products Sediment (pci/2) (p,C1/m3 ) _ (pCi/M, wet) (pci/2) (pci/kg, wet) (pCi/kg, dry) gross beta 4 1 x 10-2 311 2000 95Zr 30 95Nb' 15 1311 1 7 x 10" 1 60 134Cs 15 5 x 10-2 130 15 60 150 137 Cs 18 6 x 10-2 150 18 80 180 89Sr '1.0 2.0 x 10~3 4.0 1.0 90Sr- 1.0 2.0 x 10-3 4.5 1.2 200 54 tin 15 130 59Fe 30 260 73gy 58 , 60 Co $3"N 15 130 wRkm GB" 65Zn 30 260 o,~ y 140Ba 60 60 140La 15 15 n N NOTE: This list does not mean that only these nuclides are to be detected and reported. Other peaks which are y measurable and identifiable, together with the above nuclides, shall also be identified and reported. @

i TABLE 4.1-3 REP 0_RT_ING LEVELS FOR NONRollTIME OPERATING REPORTS REPORTING LEVEL (RI.) Analysis Water Airborne Particulate of Gas Fish 1111k Broad Leaf Vegetation (pCi/L) (pC1/m3 ) __ _ _ p Ci/kL wet) jpC1/t) (pCi/kg, wet) 311 2 x 104 ("} S4Hn 1 x 103 3 x 104 59Fe 4 x 102 1 x 10 4 58Co 1 x 103 3 x 104 60 Co 3 x 102 1 x 104 652n 3 x 102 2 x 104 95 Zr, Nb 4 x 102 131I 2 0.9 3 1 x 102 1 134Cs 30 10 1 x 103 60 1 x 103 137Cs 50 20 2 x 103 70 2 x 103 I40 Ba, La 2 x 102 3 x 102 gg y y

                                                                                                                                        $E EN a

For drinking water samples. This is 40CFR Part 141 value.

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TABLE 4.1-4 Sampling Site Descriptions (See Tabic 4.1-1) (F: Facility Ar_ca 0-1.6 km. A: Adjacent Area 1.6-8 km. R: Reference Area) Exposure Pathway Site No. (Old Site No.) Location Description (see map) Sector Distance, km

                                     . Airborne            F-16                                    F-1          Potato celler                              16        1.2 A-19                                    F-2          Ilunting cabin.                             1        1.7 F-7                                     F-3          Old dairy shed.                             7        1.2 F-9                                     F-4          First shed niong drive.                     8        1.5 A-20                                                 Roof of PSC Of fice, 131/2 thin Street              10.5 Johnstown, CO.

R-3 Colorado State University Dairy W Drake 45.1 Road, Ft. Collins, CO. R-4 Intersection of US 66 and US 287. 21.7 Direct Radiation F-1 F-7 1.3 km. NNE, pole by gate at corner of 1 1.3 Goosequill Road. F-2 0.5 km. NE pole on top 1cvel. 2 1.1 F-3 On first pole N of E-W road. 3 0.7 F-4 Pole 19,71 100 m. N of E line 2nd pole 4 0.7 S of pump road. F-5 F-47 Pole near drive to pump house. 5 0.6 F-6 Pole on E-W concrete ditch, S of bridge. 6 0.8 ,, 3. g es moo O F-7 F-3 Old dairy barn, 1st pole N of drive. I 1.2 %3mn@@ F-8 F-9 2nd pole W of pump house. 8 1.3 7 .$ kj y: m F-9 F-4 First shed along drive. 9 1.5 2, .m ~ < va n F-10 F-11 0.5 km. W of intersection of 191/2 and 10 1.5 $ 3 S.

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o' TABI.E 4. I: ,, Exposure Pathway Site tio, (Old S i t e 11o.} ,1.o ct map) Sector Distance, km Weterborne Sediment from A-22 D-40 S Platte at CO 60 Slioreline 2 10.0 Ingestion Milk A-23 F-44 Ie roy Odenhaugh dai ry. 5 2 . ') A-24 A-6 C. Winn t er da i ry 4.0 km. S of Plat te- 8 8.8 ville. A-6 A-50 Ilendrickson dairy on 32, 1.3 km. E o f 6 6.6 Platteville. R-7 A-48 Bill Ray dairy, 17376 Weld County Itoad 3 9.6 46, 0.8 km. E of US 85 on 46. R-8 R-16  !!o unt a in Vi ew Fa rms , N s i de o f CO 402 W 22.5 of I-25. R-9 R-22 Ilagan Brothers Dairy, 6.8 km. S of 17.9 Platteville. R-3 CSil dairy, W Drake Itoad, Fort Collins, 45.1 CO. Attua tic Biota A-25 E-38 Conse<inill Pond outlet. t 2.2  ! F-19 11-43 S Platte at dam and inlet pond. 4 1.1 A-22 D-40 S PlaLte at CO 60.

  • 2 10.1 g##2 Food Products F-21 Fa rm, N o f F-1 %EEn 1 1.5 g g, 3 y, F-22, Farm at F-14, fields S and E. v. d**

yon 15, 0.8, o 23 **

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  • 25, 0.9, *7 .

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Fort St. Vrain #1 Technical Specifications Appendix-B Page 37 of 41 Reporting Requiremen_t_ EAC ',. l.,1 - Environmental _ Surveil _ lance Pro-gram a) Annual Environmental Operation Report, Radiological A report on the environmental radiological surveillance program for the previous calendar year shall be submitted to the Di-rector of the NRC Regional Of fice (with a copy to the Director, Of fice of Nuclear Reactor Regulation) as a separate document by May 1 of each year. The reports shall include a summary, inter-pretations, and an analysis of trends for the results of the radiological environmental surveillance activities for the report period, including a comparison with operational controls, preoperational studies (as appropriate), and previous environ-mental surveillance reports and an assessment of the observed impacts of the station operation on the environment. In the event that some results are not available, the report shall be submitted, noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report. The reports shall also include the following: a s ummary de-scription of the environmental radiological surveillance pro-gram; a map of all sampling locations keyed to a table giving distances and directions from the reactor; the results of land use censuses; and the results of licensee participation in a laboratory cross-check program if not participating in the EPA cross-check program. j

T Fort St. Vrain fl Technical Specifications Appendix R Page 38 of 41 b) Nonroutine Radiological Environmental Operating Reports If a confirmed measured radionuclide concentration in an en-vironmental sampling medium averaged over any quarter sampling period exceeds the reporting level given in Table 4.1-3, a writ-ten report shall be submitted to the Director of the NRC Regi-onal Office (with a copy to the Director, Office of Nuclear Reactor Regulation) within 30 days from the end of the quarter. A confirmatory re-analysis 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 30 days. If it can be demonstrated that the level is not a result of plant effluents (i.e., by comparison with control station or preoperational data), a report need not be submitted l but an explanation shall be given in the annual report. When more than one of the radionuclides in Table 4.1-3 are detected in the medium, the reporting level shall have been exceeded if: Concentration (1) + Concentration (2) + ...>1.0 Reporting Level (1) Reporting Level (2) l l l If radionuclides other than those in Table 4.1-3 are de-tected and are from plant effluents, a reporting level is l exceeded if the potential annual dose to an individual is l l equal to or greater than the design objective doses of - l 10CFR Part 50, Appendix I. This report shall include an - evaluation of any release conditions, environmental. factors, i or othar aspects necessary to explain the result. I

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Fort St. Vrain #1 Technical Specifications Appendix B Page 39 of 41 5.0 ENVIRONMENTAL ADMINISTRATIVE CONTROLS Objective Administrative controls described in this section specify the record keeping, review and audit systems, and procedures required to ascertain the effects of the Fort St. Vrain Nuclear Generating Station on the en-vironment. Specification EAC 5.1 - Record Keeping Records and logs pertaining to environmental surveillance required by

 ,       these Environmental Technical Specifications shall be retained for at least five years. Baseline data from the preoperational environmental monitoring programs (both radiological and non-radiologocal) shall be retained for the life of the plant.

Specification EAC 5.2 - Organization and Review The organisation and lines of authority and responsibility which govern environmental monitoring shall be as follows: l Senior Vice President-Operations l Vice Presiden;, Engineering Vice President and P'.anning Produc. tion Manager Nuclear Project Manager Nuclear Production [ _ _ . _ . . _ . . . . . _ _ . . . _ . . . ,j

Fort St. Vrain #1 Technical Specifications Appendix B Page 40 of 41 The Nuclear Project Manager is responsible f or the coordination and administration of the Environmental Surveillance Program. He is re-l sponsible for the review and timely submittal of reports associated with  ! this program, described in EAC 4.1.1. The !!anager of Nuclear Production i l

 . is responsible for the coordination and administration of the Effluent Dicposal System, described in Section 3.0, consisting of both the Radio-logical and Non-Radiological Ef fluent Disposal Systems. He is responsible for the review and timely submittal of all reports associated with these programs, described in Specification EAC 3.1.1 and Specification EAC 3.2.1.

Specification EAC 5.3 - Procedures The environmental surveillance programs shall be conducted under the guidance of approved written procedures. These procedures shall direct the processes of obtaining samples, sample preparation, sample analysis, and calibration of the analytic instrunentation. l Specification EAC 5.4 - Changes in Environmental Technical Specifications a) A report shall be made to the NRC prior to the implementation of a change in plant design, in plant operation, or in procedures if the change would have a significant effect on the environment or i l involves an environmental matter or question not previously reviewed and evaluated by the NRC. The report shall include a description , and evaluation of the change and supporting cost-benefit analysis.

Fort St. Vrain #1 Technical Specifications Appendix B Page 41 of 41 b) Requests for changes in Environmental Technical Specifications chall be reviewed by the Plant Operations Review Committee and the Nuclear Facility Safety Committee per AC 7.1.2 and AC 7.1.3 of Appendix A. The request shall then be submitted to the Division of Project Management, NRR, for review and authorization. The request shall include an evaluation of the environmental impact of the proposed change and a supporting cost-benefit analysis.

h ATTACIU!ENT 7 FINAL R4 PORT ECOLOGICAL If0NITORING FORT ST. VRAIN GENERATING STATION l I l

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