NRC Generic Letter 1989-01
| ML031290469 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1990 |
| From: | Partlow J G Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-1302 GL-89-001, Suppl 1, NUDOCS 9012040345 | |
| Download: ML031290469 (9) | |
0 °sUNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555November 14, 1990TO ALL BWR LICENSEES
SUBJECT: NUREG-1302 -'OFFSITE DOSE CALCULATION MANUAL GUIDANCE:STANDARD RADIOLOGICAL EFFLUENT CONTROLS FOR BOILING WATERREACTORS" (GENERIC LETTER 89-01, SUPPLEMENT NO. 1)Enclosed, for your information, is a copy of the subject NUREG report. ThisNUREG report does not impose any new requirements or staft positions; its useis therefore totally voluntary.The subject NUREG supersedes prior draft guidance for RETS (NUREG-0473)those licensees who elect to implement Generic Letter 89-01. Licenseeselecting to implement this Generic Letter should continue to follow thedraft RETS guidance.fornotpriornmes G. PartlowAssociate Director for ProjectsOffice of Nuclear Reactor Regulation
Enclosure:
As stated_i-2Oi 35 901 14m-o !
INRC tORri. 335 U.S. NUCLEAR REGULATORY COMMISSION 1. PEPORINUMBrEvNFC o85 3 IAssigied bv NAIC. Add Vol. SWPti. NOV..NRM1 102. end Addenldumi humilbs. If OnY.I3201. 3202 BIBLIOGRAPHIC DATA SHEET(see instructions on the reverse)2. TITLE AND SUBTITLE NUREG-1 302OFFSITE DOSE CALCULATION MANUAL GUIDANCE: STANDARD RADIOLOGICAL 3. DATE REPORT PUBL!SHEDEFFLUENT CONTROLS FOR BOILING WATER REACTORS MONTvi l ELASept. 1990Subtitle: Generic Letter 89-01, Supplement No. 1 4. FINORGRANTNUMBEFN/AS. AUTHOR(Si 6. TYPE OF REPORTW. Wayne Meinke and Thomas H. Essig Industry Guidance7. PERIOD COVERED fmnci,.w^u DarecN/A-ft -.. A --A _ n... -~ u s ~~ N Artt~~~t Co *irion *i^d m lr~a ddftis. oif tractr.rt Drw,,crnome and moilng addressJDivision of Radiation Protection and Emergency PreparednessOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionWashington, D.C. 205559.SPONSORING OR GAN IZATI ON-NAME AND ADDRESS (If NRC. trpe 'Samea, Baove-: if contracror provide NRC DOirion. Offse or Region. U.&NUClearRftujtorVCon.nMs*,on.and mailing eddress.)Same as above10. SUPPLEMENTARY NOTES11. ABSTRACT 1200 words or lrss'This report contains guidance which may be voluntarily used by licensees who chooseto implement the provision of Generic Letter 89-01, which allows Radiological Efflu-ent Technical Specifications (RETS) to be removed from the main body of the TechnicalSpecifications and placed in the Offsite Dose Calculation Manual (ODCM). Guidance isprovided for Standard Effluent Controls definitions, Controls for effluent monitoringinstrumentation, Controls for effluent releases, Controls for radiological environ-mental monitoring, and the basis for Controls.Guidance on the formulation of RETS has been available in draft form (NUREG-0472 and-0473) for a number of years; the current effort simply recasts those RETS intoStandard Radiological Effluent Controls for application to the 0DCM. Also includedfor completeness are: (1) radiological environmental monitoring program guidancepreviously which had been available as a Branch Technical Position (Rev. 1, November1979); (2) existing 00CM guidance; and (3) a reproduction of Generic Letter 89-01.12. KEY WORDSIDESCR !PTORS {Lasg words or e hrows reat will MJir fa"earcher 0n jloaring the ttopr ) 13. AVAILABILITY ST AT EMENTUnlimitedGeneric Letter 89-01 SEURIT_ Y CLA__Licensee Guidance _Effluent Controls UnclassifiedEffluent Monitoring UTls i ieeortRadiological Environmental Monitoring UnclassifiedBoiling Water Reactors 15. NUMBER OF PAGES12016. PRICENRC FORM 33512491 NUREG-1302Offsite Dose CalculationManual Guidance: StandardRadiological Effluent Controlsfor Boiling Water ReactorsGeneric Letter 89-01, Supplement No. 1U.S. Nuclear Regulatory CommissionOffice of Nuclear Reactor RegulationW. W. Meinke, T. H. Essig ABSTRACTThis report contains guidance which may be voluntarily used by licensees whochoose to implement the provision of Generic Letter 89-01, which allows Raoio-logical Effluent Technical Specifications (RETS) to be removed from the mainbody of the Technical Specifications and placed in the Offsite Dose CalculationManual (OUCK). Guidance is provided for Standard Effluent Controls definitions,Controls for effluent monitoring instrumentation, Controls for effluent releases,Controls for radiological environmental monitoring, and the basis for Controls.Guidance on the formulation of RETS has been available in craft fore (NUREG-0472anc -C473) for a number of years; the current effort simply recasts those RETSinto Standard Radiological Effluent Controls for application to the ODCN. Alsoincluded for completeness are: (1) radiological environmental monitoring programguidance previously which had been available as a Branch Technical Position(Rev. 1, November 1979); (2) existing ODCM guidance; and (3) a reproduction ofGeneric Letter 89-01.iii PREFACEThis compilation of Standard Radiological Effluent Controls (SREC) contains allof the controls addressed in Generic Letter 89-01, to be incorporated into alicensee's Offsite Dose Calculation Manual (ODCH) at the time the proceduraldetails of the current Radiological Effluent Technical Specifications (RETS)are transferred out of the licensee's Technical Specifications (TS). It hasbeen developed by recasting the RETS of the most current Standard TechnicalSpecifications from the LCO" format into the "Controls format of an ODCMentry. Note that these GE-SREC have been patterned after the W-SREC. Thefollowing text guidance incorporates the wording of the most recent SREC,however, no attempt has been made to translate REC numbering of the W-SRECinto that of the BWR numbering system.The following GE-SREC provide the latest version of staff guidance, and docu-ment current practice in the operating procedures required by 10 CFR 20.106,40 CFR Part 190, 10 CFR 50.36(a), and Appendix I to 10 CFR Part 50. Thisdocument contains no new requirements and its use is completely voluntar TABLE OF CONTENTS13/43/4.03/4.33/4.113/4.123/4ABSTRACT ............................. *.... *............PREFACE ................................................FOREWARD. *................... .................DEFINITIONS.............. 9.99...-.. -9 ...I.....9. 9*9 -CONTROLS AND SURVEILLANCE REQUIREMENTS.................Applicability1................................ ........Instrumentation.o.o.....................................9Radioactive Effluents............................. ..Radiological Environmental Monitoring.................BASES ..................................... ............Pageiii[1][5)[15i[163[18][39)[59)[74]APPENDIX A:APPENDIX B:APPENDIX C:Radiological Assessment Branch TechnicalPosition, Revision 1, November 1979General Contents of the Offsite DoseCalculation ManualGeneric Letter 89-01[85][94;[98]GE-SRECvii 11FOREWORDRADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONSLicensee Technical Specification (TS) amendment requests for incorporation ofRadiological Effluent Technical Specifications (RETS) pursuant to 10 CFR 50.36aand Appendix I to 10 CFR Part 50 were approved in the mid-1980s for mostoperating reactors licensed before 1979 (ORs). Plants licensed after 1979(NTOLs), included the RETS as part of their initial Technical Specifications.By November 1987, the RETS were implemented by all licensees of operating powerreactors. Detailed Safety Evaluation Reports (SERs) documented the accept-ability of the plant-specific RETS of the ORs, while the acceptance of the RETSfor the NTOLs followed the regular pattern of the Standard Technical Specifi-cations (STS). Thus, for all operating plants, the compliance of the licenseewith 10 CFR 50.36a and Appendix I to 10 CFR Part 50 is a matter of record.Early draft revisions of model RETS, distributed to licensees in mid-1978,contained equations for dose calculations, setpoint determinations and meteoro-logical dispersion factors, as well as the procedural details for complyingwith Appendix I to 10 CFR Part 50. In later revisions, including Revision 2used as the bench mark for the NRC staff's acceptance of OR RETS, the equationswere removed and incorporated into an Offsite Dose Calculation Manual (ODCM)prepared by the licensee and provided to NRC for review along with the proposedRETS.Early guidance for preparation of the Radiological Effluent Technical Specifi-cations (RETS) and Offsite Dose Calculation Manual (ODCM) was published inHUREG-0133, Preparation of Radiological Effluent Technical Specifications forNuclear Power Plants," October 1978. Copies of model RETS, however, have beenavailable only in draft form as NUREG-0472, Revision 2, "Radiological EffluentTechnical Specifications for PWRs," February 1, 1980; NUREG-0473, Revision 2,Radiological Effluent Technical Specifications for BWRs,: February 1, 1980;and succeeding draft revisions. Staff guidance for the RadiologicalEnvironmental Monitoring Program is contained in the Radiological AssessmentBranch Technical Position (RAB-STP), originally issued in March i978 andupgraded by Revision 1 in November 1979 as a result of the accident at ThreeMile Island. This Revision 1 to the RAB-BTP was forwarded to all operatingreactor licensees in November 1979 and remains in effect at the present time.Since this UIP was never incorporated into the Regulatory Guide System, a copyis reproduced in this document as Appendix A. Even though it has been usedextensively in reviewing ODCMs, guidance for the contents of the ODCM is foundonly in an appendix to a paper presented at an Atomic Industrial Forum confer-ence in 1981, and has had only informal distribution since that time.OFFSITE DOSE CALCULATION MANUALThe potential for augmentation of a licensee's ODCM through transfer of theprocedural details of the RETS following the guidance of Generic Letter 89-01,provides an opportunity to assemble in one set of documents the staff guidancefor the ODCM.GE-SRECt 1 The current overview guidance for development of the ODCM was prepared origi-nally in July 1978 and revised in February 1979 after discussions with commit-tees of the Atomic Industrial Forum. This guidance was made generallyavailable as "Appendix B -General Contents of the Offsite Dose CalculationManual (ODCM) (Revision 1, February 1979)" to the paper authored byC. A. Willis and F. J. Congel, "Status of NRC Radiological Effluent TechnicalSpecification Activities" presented at the Atomic Industrial Forum Conferenceon NEPA and Nuclear Regulation, October 4-7, 1981, Washington, D.C. -A copy ofthis guidance that continues in effect to date, is reproduced in this documentas Appendix B.During the discussions leading up to the implementation of the RETS by the ORs,it became important to record in a "living" document certain interpretationsand understandings reached in these discussions. The ODCM thus became arepository for such interpretations, as well as for other information requestedby the staff in connection with its evaluation of licensee's commitments andperformance under 10 CFR 50.36a and Appendix I to 10 CFR Part 50.TECHNICAL SPECIFICATION IMPROVEMENT PROGRAMRecently, the NRC staff has examined the contents of the RETS in relation tothe Commission's Interim Policy Statement on Technical Specification Improve-ments. The staff has determined that programmatic controls can be implementedin the Administrative Controls section of the Technical Specifications (TS) tosatisfy existing regulatory requirements for RETS. At the same time, theprocedural details of the current TS on radioactive effluents and radiologicalenvironmental monitoring can be relocated to the Offsite Dose CalculationManual (ODCM).To initiate the change, new programmatic controls for radioactive effluents andradiological environmental monitoring are incorporated in the TS to conform tothe regulatory requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a,and Appendix I to 10 CFR Part 50. The procedural details included inlicensees' present TS on radioactive effluents, environmental monitoring, andassociated reporting requirements will be relocated to the ODCM. Licenseeswill handle future changes to these procedural details in the ODCM under theadministrative controls for changes to the ODCM. Detailed guidance to effectthe transfer of the RETS to the ODCM is given in Generic Letter 89-01, repro-duced in Its entirety as Appendix C.GUIDANCE FOR THE TRANSFER OF RETS TO ODCMEnclosure 1 of Generic Letter (GL) 89-01 of Appendix B provides detailedguidance for the preparation of a license amendment request to implement thetransfer of RETS to ODCM. Page 1 of the enclosure states:OThe NRC staff's intent in recommending --- the relocation of proceduraldetails of the current RETS to the ODCM is to fulfill the goal of theCommission Policy Statement for Technical Specification Improvements. Itis not the staff's intent to reduce the level of radiological effluentcontrol. Rather, this amendment will provide programmatic controls forRETS consistent with regulatory requirements and allow relocation of theprocedural details of current RETS to the ODCM."GE-SREC[2]
Page 2 of Enclosure 1 states:'...the procedural details covered in the licensee's current RETS,consisting of the limiting conditions for operation, their applica-bility, remedial actions, surveillance requirements, and the Basessection of the TS for these requirements, are to be relocated to theODCM --- in a manner that ensures that these details are incorporatedin plant operating procedures. The NRC staff does not intend to repeattechnical reviews of the relocated procedural details because theirconsistency with thE applicable regulatory requirements is a matterof record from past NRC reviews of RETS."DISCUSSIONFor the purpose of the transfer described in GL 89-01 of Appendix B, the RETSwill consist of the specifications from the STS listed in Enclosure 2 of Appen-dix B of GL 89-01. Licensees with nonstandard TS should consider the analogousTS in their format.It is suggested that the most straightforward method of transferring a licensee'scommitments in the RETS to the ODCM in accordance with GL 98-01 is to recastthe RETS in the licensee's present TS from the uLimiting Condition for Opera-tion (LCO)u format of the TS into the 'Controls' format of the ODCM entry. Theaccompanying package provides an example of this recasting into Standard Radio-logical Effluent Controls (SREC) from the model RETS for Boiling Water Reactors(BWRs). This recasting is in format only. The TS pages have been transferredto the ODCM without change except for the substitution of 'Controls' for 'LCO.3Plants that have RETS that closely follow the STS format will be able to usethe accompanying examples directly as guidance. For plants with nonstandardRETS, the transfer of TS commitments to the ODCM should be made similarly pageby page, again with the substitution of 'Controls' for ULCO.UThis NUREG report contains no new requirements; licensee implementation of thisguidance is completely voluntary.SUMMARYAs part of the license amendment request for TS improvement relative to theRETS, a licensee confirms that the guidance of Generic Letter 89-01 has beenfollowed. This guidance includes the following:The procedural details covered in the licensee's current RETS, con-sisting of the limiting conditions for operation, their applicability,remedial actions, surveillance requirements, and the Bases section ofthe TS for these requirements, are to be relocated to the ODCM --- ina manner that ensures that these details are incorporated in plantoperating procedures.'The Standard Radiological Effluent Controls (SREC) compiled in this reportdocument current staff practice in the operating procedures required by10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36(a), and Appendix I to 10 CFRPart SO. Thus they contain all of the controls required by Generic Letter89-01, to be incorporated into a licensee's ODCM at the time the proceduraldetails of the current RETS are transferred out of the licensee's TS.GE-SREC[3]