ML18043A545

Forwards Proposed Changes to Tech Specs for License DPR-20 Re Radiological Effluents

ML18043A545
Person / Time
Site:	Palisades
Issue date:	03/12/1979
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Ziemann D Office of Nuclear Reactor Regulation
References
NUDOCS 7903150301
Download: ML18043A545 (33)

Text

• '

consumers Power_

company.

Gen.era! Offices: 212 West Michigan Avenue, Jackson, Michigan 49201

• Area Code 517 788-05~0 March 12, 1979 Director, Nuclear Reactor RegulatiREGLJLATQRY DOCKET FILE COPY, Att:

Mr Dennis L,Ziemann, Chief Operating Reactors Branch No 2 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR...:20 PALISADES PLAl1T -

PROPOSED TECHTHCAL SPECIFICATIONS CHAt'ifGES RELATED TO RADJOLOGICAL EFFLUENTS Transmitted herewith are three (3) original and thirty-seven (37) conformed copies of a prop~sed change to the Technical Specifications for.the Palisades Plant.

. The purpc:ise. of this ch13.Ege is to incorporate. the Title 10 CFR _Part 50, Appendix I implementation requirements into our current* Technical Specificati0ns -as requested by NRC letter. daled *-J:iily -li; 1978;. Consuiners Power Compe.ny has re-viewed the Draft Radiological Effluent Technical Specifications for Pl-<Rs (Appendix I model Technical Specifications) for applicability to the Palisades Plant.

In parallel with this effort, Title 10 CFR Part 50, Append.ix I -,ms e~-~

amined in order to identify specific Appendix I im~*lementation requi:re.ments not present in our.current Technical Specifications.

Two alternatives for ensuring compliance with Appendix I have been considered..

. These alternatives are discussed briefly below:

Alternative I - Standard Radiological Specifications This approach will entail approximately 100 pages of specification changes and additions.

Most of _these**chariges will severely.c.omplicate plant operation and (although unintentional) may be anticipated.to cause degraded performan2e in both plant operability o.nd effluent release control.

Practicality as well as plant safety and.ALARA concerns have been voiced by an AIF review committee (Ref I).

Our Company shares these concerns.

This alternative is. unacceptable

.to Consumers Power Company.

Alternative II - Basic kppendix I R0ouirernents

~i The Appendix I requirements net specifically stated in the current Palisades

~c.{O Technical Specifications reql:.ire e.pproximately seven pages of Technica2. Speci-*

~

fication changes.. These changes will ensure continuation of past perfonna!1<::e ~

.. ~

'i 9 0 3 15 o~\\

e "¢-'J,\\~

I

.i below Appendix I limits with minimal disruption of plant operation.

A Title 10 CFR 50.59 review of these proposed changes has indicated no-ALARA or safety con-cerns.

This alternative is acceptable and has been proposed previously by Consumers Power Company (Ref 2).

Changes necessary to incorporate all Appendix I requirements as well as require-ments of 10 CFR 50.36a; 10 CFR 50.34a; 10 CFR 20; 10 CFR 50, Appendix A, Criterion

. 60 and 64; and 40 CFR 190 in the current Palisades Technical Specifications are attached.

These changes represent a complete update of the proposed changes sub-mitted on June 4, 1976.

This updating includes consideration of dose pathways which have changed for airborne effluents since our 1976 submittal.

Current dose pathways were obtained from results of the 1978 survey described in Section 4.11.4 of our proposed Technical Specifications.* The results of this survey are given in Table 1.

Atmospheric dispersion and ground deposition co-efficients for current locations of maximum dose are provided in Table 2.

These updated parameters have been utilized to adjust the design objective quantity values (Table 3.9.15-1 of our Technical Specifications) to reflect current real dose pathways for gaseous effluents.

Liquid effluent pathways do Bot require up-

-da:ting.

Please consult the original submi tt.al (Ref -2) for description of.

the Appendix I analyses upon which the design objective quantity limits are based.

This change is similar in intent to our proposed change dated June 4, 1976,-

which was submitted prior to the issuance of 10 CFR 170.22.

No response to the earlier submittal has been received.

Accordingly, it is concluded that this change should be exempt from the licensing fees specified in 10 CFR 170.22.

References

1.

Atomic Industrial Forum; letter to M.r Harold Denton, USNRC, from Carl Walske,

• AIF Pre_sident; August 16, 1978.

2.

Consumers Power Company; Appendix I Submittal to Director of Nuclear Reactor

- Regulation, Docket 50-2555, License DPR-20 from D A Bixel; June 4, 1976.

David P Hoffman Assistant Nuclear Licensing Administrator CC:

JGKeppler, USNRC

-_t TABLE 1 Miles to the Nearest:

Meat Milk Sector Residence Animal Garden ~-500 So Ft Cows Goats l'iNE 1.2 None

1. 70 None 2.60

':NE

1. 65 2.90 1.80 4.30 None ENE 1.6 3.10 1.80 None None E

1.2 5.00 2.10 None 4.85 ESE

1. 00 LOO

1. 25 4.20 3.25 SE 1.2 2.10 1.40 4.20 None SSE 0.9 5.3 1.80 5.30 None s

o*. 63 5.10 1.40 None 3.20 SSW 0.7 None 4.90 None None SW None None None None None WSW None None None None None w

None None*

None None None WNW None None None None None NW None None None None None N

None None None None None TABLE 2 Current Locations of Maximum Dose Distance Location Normal Denosition No (Miles)

(Sector)

Descrintion xLg ~s[m 3 }

D{Q (l/m2) 1 o.63 s

Residence 5.56(-6) 3.08(-8) 2 1.25 ESE Garden 1.4 (-6) 9.6 (-9) 3 1.00 ESE Meat Animal 2.13(-6) 1.49(,...8) 4 2.6 NNE Goat Milk 1.17(-7) 1.1 (-9) 5 4.2 SE Milk Cow 1.78(-7) 7.2(-10)

CONSUMERS POWER COMPANY DOCKET NO 50-255 REQUEST FOR CHANGE TO THE TECHNICAL SPECIFICATIONS LICENSE DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Speci-fications contained in Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972 be changed as follows:

I.

CHA.l'iGES A.

Change Item (1) within the first paragraph of the objective of Section 3,9 as follows:

"(l) Radioactive wastes from the plant discharge mixing basin and from the plant vent to assure that any radioactive material released is kept as low as is reasonably achievable in con-formance with 10 CFR 50, Appendix I, and 1n any event, is within the limits of 10 CFR 20;"

B.

Delete the present text of Section 3.9.1 and replace with the following:

"3.9.1 The quantity of all radionuclides determined to be released during* any calendar quarter shall not exceed one half the design basis annual quantity calculated from values in Table 3.9.1-1.

Calculations shall be performed for each batch release, and weekly for continuous releases by the formula:

EA. /C. < O. 5

l.

l.

where:

A. =

l.

C. =

l.

Cumulative quarterly activity of nuclide i identified in liquid releases (Ci).

Design objective annual quantity of radionuclide i from Table 3,9.1-1 (Ci).

The design objective annual quantities of liquid radioactive effluent are based upon 3 millirem to the total body or 10 millirem to any organ of a real individual."

1

C.

Delete the present 'text of Section 3. 9. 5 and replace with the following:

"3.9.5 Under normal operating conditions, all radioactive liquids not meeting the limits of Appendix I as required by Technical Spec-ification Section 3.9.1 will be recycled or prepared for shipment in accordance with applicable rules, regulations and orders of governmental authorities having jurisdiction and turned over to a carrier or carriers licensed by governmental authorities having jurisdiction for shipment to an authorized disposal area or areas."

D.

Change the texts of Sections 3.9.11, 3.9.12 and 3.9.13 to read as follows:

"Gaseous Wastes 3.9.11 The average weekly release rates of gaseous and airborne par-ticulate wastes shall be limited in accordance with the fol-lowing equation:

Q.

11 L(MP~)..2. 5 x 10 (cc/s) l where Qi is the weekly release rate (µCi/ s) of any radioiso-*

tope, i, and (MPC): in the units of µCi/cc is defined in Column l

1, Table II, of Appendix B to 10 CFR 20.

Length of the actual interval over which this release rate may be allowed will be limited such that provisions of Section 3.9.15 are not exceeded.

3.9.12 The average gaseous release rate over any 15-minute period shall not exceed 10 times the weekly average limit.

3.9.13

• Following isolation and prior to release of gaseous wastes from the.waste gas decay tanks, the contents shall be sampled and analyzed to determine compliance with 3.9.11, 3.9.12 and 3.9.15."

E.

Add new Section 3.9.15 as follows:

"~.9.15 The quantity of all radionuclides determined to be released during any calendar quarter shall not exceed one *half the design basis annual quantity calculated from the values given 2

.J in Table 3. 9.15-1.

Calculations shall be performed for each batch release, each stack gas analysis and monthly for con-tinuous releases by the formula:

E A./C. < 0.5

1.

1. -

where:

A. = Cumulative quarterly activity of nuclide i

1.

identified in gaseous release (Ci).

C. = Design objective annual quantity of nuclide i

1.

from Table 3.9.15-1.

The design objective annual quantities of gaseous effluents, and radioiodines and radionuclides in particulate form re-leased to the atmosphere, are based on:

(1)

Air dose of 10 millirem from beta radiations or 20 millirem from gamma.

(2)

Dose.to a real individual of 5 millirem total body or 15 millirem to skin.

(3)

Dose to a reaI individual of 15 millirem to any organ from radioiodines and radionuclides in particulate form."

F.

Renumber the following sections specified below:

Present Number 3.9.15 3.9.16 Proposed Number 3.9.16 3.9.17 G.

Add new Section 3.9.18 as follows:

"3.9~18 In the event the quarterly values calculated for released nuclides exceed one half the design basis guides in Specifi-cations 3.9.6 or 3.9.15, the following actions shall be taken:

(1)

Perform an investigation to identify the cause for such release rates; (2)

Define and initiate a program of corrective action; and (3)

Report these actions to the Commission within 30 days from the end of the quarter during which the release occurred."

H.

Delete presently numbered Sections 3.9.17 and 3.9.18.

3

I.

Charige first sentence of first complete paragraph on Page 3-53 to read:

"Under normal operating conditions the expected release to the environ-ment from the modified liquid waste system will be less than the design objective quantities, as specified by Appendix I to 10 CFR 50."

J.

Delete the last two paragraphs on Page 3-53 and continuation of same on Page 3-53a.

Replace with the following basis for Appendix I Design Objective Annual Quantities in liquid effluents:

"Section II of Appendix I to 10CFR50 specified that the calculated annual total quantity of all radioactive material above background to be released from each light-water-cooled nuclear power reactor to unre-stricted areas will not result in an estimated annual dose or dose commitment from liqµid effluents for any individual in an unrestricted area from all pathways of exposure in excess of 3 millirems to the total body or 10 millirems to any organ.

In addition half these values shall not be exceeded in.any one quarter."

"Specification 3. 9. l* specified the design objective quantities and method of summation such that no individual in an unrestricted area will receive greater than 3 millirems to the total body or 10 millirems

• to any organ from liquid effluents by all pathways of exposure.

Liquid pathways considered in derivation of the design objective annual quanti-ties include fish and drinking water ingestion, immersion (swimming),

boating, and shoreline recreation."

K.

In the basis, omit the first paragraph on.Page 3-53a.

L.

Add after the last paragraph on Page 3-53a the following basis for Design Objective Annual Quant~ties in gaseous efflue~ts:

"Section II of Appendix I.specified that a licensee may not exceed quantities of gaseous effluent which would cause an air dose greater than 10 millirads fo~ gamma radiation or 20 millirads beta in a year or half that amount in a quarter.

It further stipulates that dose to a real individual shall not exceed 5 millirems to skin or 15 millirems to any organ, and not more than half the effluent quantity which would cause these effects may be released in any one quarter.

4

"Specification 3.9.15 specified the design objective quantities and method of summation such that Appendix I limits are not exceeded.

Gaseous pathways considered in derivation of the design objective annual quantities include plume submersion, inhalation, vegetable, meat and milk consumption and shine from ground-deposited radionuclides."

M.

Change the first paragraph on Page 3-54 to read as follows:

"3.9 EFFLUENT RELEASE (Contd)

If the activity level in the waste gas surge tank is such that the limits of Sections 3.9.11 through 3.9.15 are being approached by direct release to the plant stack, waste gas decay tanks will be utilized to store those gases until such time as releases may be assured as not to exceed those limits.

In any event, release of gaseous wastes will be maintained as low as is reasonably achievable in accordance with 10 CFR Part 50, Appendix I."

N.

Change the second paragraph on Page 3-54 to read as follows:

"The 15-minute limitation o~ gaseous release rates, not in excess of 10 times the weekly average limit, allows operational flexibility.

Quarterly releases will be maintained in conformanc*e with Specifica-tion 3.9.15."

0.

In the basis on Page 3-54, change the last line to read as follows:

"... nearest postulated cow 1.5 miles southeast of the plant.

Use of the l. 5-mile distance is conservative based upon present location of the nearest actual cow."

P~

In the basis on Page 3-55, change the first sentence of the first para-graph to read as follows:

"The formula of Specification 3.9.11 insures that 10 CFR 20 annual average dose rates will not be exceeded at the point of maximum off-site dose.

Application of this formula is contingent upon release quantities remaining within the limits of Specification 3.9.15."

Q.

In the basis on Page 3-56, add new paragraph following end of the first paragraph as follows:

5

"The annual design basis quantities specified in Tables 3.9.1-1 and 3.9.15-1 are based on models and data contained in the June 4, 1976 Appendix I submittal.

The design basis quantities are in accordance with* the guidelines of Appendix I to 10 CFR 50.

Conformance with Appendix I is deemed a conclusive showing of compliance with the "as low as is reasonably achievable" requirements of 10 CFR Sections 50.34a and 50.36a.

Design objective annual quantities are based on. mqdels and data such that the~annual exposure of an individual is unlikely to be substantially underestimated."

R.

Add new Section 4.11.4 as follows:

"4.ll.4 A survey will be performed annually, at the beginning of the agricultural season (May through July), to confirm locations of the nearest milk cow, milk goat, meat animal, vegetable garden (>500 square feet in area), and resident in each sector to a distance of 5 miles from the release point."

S.

Renumber the following sections as specified below:

Present Number 4.ll.4 4.1L5 4.11. 6 Proposed Number 4.11. 5 4.11. 6 4.ll.7 T.

In the basis on Page 4-56, change Item 1 to read as follows:

111.

Measurement of radiation levels in the sampled media is done in such a manner to assure compliance with 10 CFR 20 and 10 CFR 50, Appendix I."

U.

Add the following two tables to the basis of Section 3.9 (following Page 3-56):

Table 3.9.1-1 and Table 3.9.15-1.

V.

Change Section 3.9.6 to read:

"... shall not exceed the limits specified in the NPDES permit."

W.

Renumber pages as shown on the attached Technical Specifications pages.

6

TABLE 3.9.1-1 Liquid Effluent Design Ob,jective Annual Quantities Design Objective Dose Factor Annual Quantity Nuclide Organ (rnrern/Curie)

(Curies)

H-3 Tot Body

1. 31E-06 2.29E+06 Cr-51 GI

1. 49E-03 6, 730 Mn-54 GI 6.22E-02 161 Fe-55 GI l.21E-02 827 Fe-59 GI 3.77E-02 265 Co-58 GI

8. 38E-03

• 1,190 Co-60 Tot Body 4.50E-Ol 6.67 Rb-86 Tot Body 2.28E-Ol 13.2 Sr-89 Bone l.07E-02 935 Sr-90 Bone l.64E-Ol 61.0 Zr-95 GI

1. 72E-02 581 Nb-95 GI l.17E-02 855 Mo-99 GI l.llE-03 9,020 Te-99m GI 6.88E-05 145,000 Te-127m GI l.OlE-01 99.2 Te-127 GI 2.85E-02 259 Te-129m GI 2.57E-Ol 38.9 Te-13lm GI 3.73E-Ol 26.8 Te-132 GI 3.42E-Ol 29.2 I-130 Thyroid 5.28E-02 190 I-131 Thyroid

3. 2l~E-Ol 30.9 I-132 Thyroid l.32E-02 755 I-133 Thyroid 4.05E-02 254 I-135 Thyroid 2.83E-02 353 Cs-134 Tot Body 2.83E+OO 1.06 Cs-136 Tot Body 3.94E-Ol 7.61 Cs-137 Tot Body l.67E+OO 1.80 Ba-140 GI

1. 86E-03 5,390 La-140 GI 2.57E-02 390 Np-239 GI 2.66E-03 3,750 7

Nuclide H-3 C-14 Ar-41 cr...:51 Mn-54 Co..:.57 Co-58 Co-60 Fe-59 Kr-85m Kr-85

. Kr-87 Kr-88 Sr-89 Sr-90 Zr-95 Nb-95 I-131 I-133 I-135 Xe-131m Xe-133m Xe-133 Xe-135 Cs-134 Cs-137 TABLE 3.9.15-1 Gaseous and Particulate Design Objective Annual Quantities Dose Factor Organ

• (mrem/Curie)

Soft Tissue l.12E-04 Soft Tissue

l. 83E-02 Air Dose ( '.')

3.53E-03 GI 4.92E-03 GI 2.44E-Ol GI 2.83E-02 GI l.llE-01 GI 5.82E-Ol GI 2.30E-Ol

. Air Dose ( s)

l. 20E-03 Air Dose ( S) l.OlE-03 Air Dose ( s) 7.80E-03 Air Dose (y) 5.88E-03 Bone l.06E+Ol Bone 4.03E+02 GI

2. 27E-Ol.

GI l.54E-Ol Thyroid 9.45E+OO Thyroid l.60E-Ol Thyro_id 3.14E-02 Air Dose ( s) 4.02E-04 Air.Dose ( s) 8.08E-04 Air Dose ( s) 2.82E-04 Air Dose ( s)

l. 57E-03 Liver 7.17E+OO Liver 4.5 E+OO 8

Design Objective Annual Quantity (Curies) 133,929 820 2,830 3,049

61. 5 530 135 25.8 65.2 16,600 19,800 2,560 1,700 1.42 0.037 66.l 97.4 L59 93.8 478 49,700 24,800 70,900 12,800 2.09 3.33

.9 II.

DISCUSSION.

This Technical Specifications Change is proposed as required by 10 CFR 50, Appendix I and is based on a report titled, "Appendix I Analysis'-

Palisades Plant," prepared by the NUS Corporation.

The NUS report was transmitted'with our original Appendix I submittal dated June 4, 1976.

The proposed change will bring the present Technical Specifications into c.onformance with Appendix I; 10 CFR 50. 36a; 10 CFR 50. 34a; 10 CFR 20; 10 CFR 50, Appendix A, Criterion 60 and 64; and 40 CFR 190 as discussed below:

10 CFR 50.36a and 10 CFR 50.34a Meeting the gui~elines for design objectives and limiting conditions for operation of 10 CFR 50, Appendix I, is.deemed a conclusive showing of compliance with the "as low as i,s practicable" requirements of 10 CFR 50.34a and 10 CFR 50.36a.

This conclusion is expressly set forth in the third paragraph of Section I, "Introduction" to 10 CFR 50, Appendix I.

10 CFR 20 Quarterly and annual release quantities are limited by our proposed Technical Specifications to be within the guidelines o'K 10 CFR 50,

.Appendix I; Maximum release rates over short intervals are limited in accordance with concentration limits of 10 CFR 20, provided that those Tates are not continued to the extent that Appendix I limitations are exceeded.

Thus, Palisades effluents will be maintained well below the levels allowed by current Technical Specifications which reflect 10 CFR 20.

Such limitation is in accordance with the General Provisions Section 20.l(c) of 10 CFR 20.

10 CFR 50, Appendix A General Design Criteria 60 and 64 have been met in the design of the Palisades Plant.

Current operating requirements, per current Technical Specifications, are consistent with this design.

No changes are proposed in our submittal which wotild compromise either the current d~sign or operability of effluent control and monitoring systems.

9

III.

e.

40 CFR Part 190 The EPA hearing record, as well as the Environmental Radiation Protection Standards for Nuclear Power Operation, were reviewed to determine com-pliance of our proposed Technical Specifications.

The limits of 40 CFR 190 apply to the total nuclear fuel cycle, of which a single power reactor is a small part.

The EPA hearing record (Federal Register Vol 42, No 9, January 13, 1977) indicates that by EPA testimony, more than five power reactors would have to operate at one site under Appendix I limits before compliance with the EPA limits would be in question.

Recently, the ACRS (January 4, 1979) has determined that up to four units per site may be allowed within EPA standards.

Thus, both EPA and ACRS agree that compliance with Appendix I limits is conclusive showing of compliance with 40 CFR 190, provided that not more than four to five units exist at a given site.

Since only one unit exists at the Palisades site, our proposed Technical Specifications do satisfy 40 CFR 190.

CONCLUSIONS Based on the foregoing, both the Palisades Plant Review Committee and the Safety and Audit Review Board have reviewed these changes*and find them acceptable.

CONSUMERS POWER COMPANY.

Sworn and subscribed to before me this 12th day of March 1979.

My commission expires

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10

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3.9 EFFLUENT RELEASE Applicability 3,9.3 Applies to the controlled release of radioactive liquids and gases, heat, residual chlorine, and other chemicals from the plant.

Ob,j ectives To define the conditions for release of:

(1)

Radioactive wastes from the plant d~scharge mixing basin and from the plant vent to assure that any radioactive material released is kept as low as is reasonably achievable in conformance with 10 CFR 50, Appendix I, and j_n any event, is within the limits of 10 CFR 20; ( 2) chlorine res.iduals from the plant; (3) spent sulfuric acid from the.closed-cycle condenser cooling system; and (4) thermal discharges of the closed-cycle condenser cooling system.

Specifications Liquid Wastes The quantity of all radionuclides.. determined to be released during any calendar quarter shall not exceed one half the design basis annual quantity calculated from values in Table 3.9.1-1.

Calculations shall be performed for each batch release, and weekly for continuous releases by*the formula:

L.A. /C. < O. 5 l

l where:

A. = Cumulative quarterly activity of nuclide i identified l

in liquid feleases (Ci).

C. = Design objective annual quantity of radionuclide i l

froo Table 3.9.1-1 (Ci).

The design objective annual quantities of liquid radioactive effluent are based upon 3 millirem to the total body or 10 millirem to any organ of a real individual.

During release of radioactive liquids, the MPC, as defined in 10 CFR 20, shall not be exceeded at the point of discharge to the lake.

Prior to release of liquid wastes, a sample shall be taken from the tank to *be discharged and analyzed.-

The flow rate from the tank and the dis-charge rate from the mixing basin shall be determined in order to calcu-late the' concentration of radioactive materials in the mixing basin to deoonstrate compliance with 3.9.2 above.

3-50

3.9 3.9.4 3.9.6 3.9.7 3.9.8 3.9.9 EFFLUENT RELEASE (Contd)

During the release of liquid-radioactive wastes, the following conditions shall be met.

a.

Flow through the mixing basin shall be at least. 8,000 gpm.

b. *During any release, ~he discharge monitor shall be in operation with the exception that if it (RIA-1049) is down for maintenance, sampling of the discharge water shall be taken every four hours and each sample analyzed.

Under normal operating conditions, all radioactive liquids not meeting the limits of Appendix I as required by Technical Specification Section 3.9.1 will be recycled or prepared for shipment in accordance with applica~le rules, regulations and orders of governmental authorities having jurisdiction and turned over to a carrier or carriers licensed by governmental authorities having jurisdiction for shipment to an au:thorized disposal area or areas."

The concentration of residual chlorine in water discharged from the plant as a result of cleaning of the closed-cycle condenser cooling system shall not exceed the limits specified in the NPDES Permit.

In order to assure that releases shall be no greater than the total residual chlorine.limit, specified above, the discharge may be reduced or terminated, during and after chlorination, to allow the chlorine to decompose to the chloride ion due to exposure to light and air.

Simultaneous discharge from the closed-cycle condenseT cooling system and chlorination treatment of the closed-cycle condenser cooling system shall be limited to a total of not more than sixty*minutes in a period of*one day.

Because.of the use of sulfuric acid to neutralize the closed-cycle cooling system water and to control scaling of this cooling system, all discharges from the plant into Lake Michigan shall be limited to a range of 6.5 to 9.5 pH units.

No bulk amounts of acids or bases shall be discharged into the lake without prior neutralization.

Thermal discharges of the total blowdown from the closed-cycle cooling system mixed with the dilution water shall be limited to an increase of no more than 5°F above the ambient temperature of the receiving 3-50a

3.9 3.9.10 3.9.12 EFFLUENT RELEASE (Contd) water at the shoreline of the lake to assure compliance with the Special Technical Specifications.

The heat rejection to the lake from the diluted total blowdown shall not exceed 0.5 billion British thermal units' (Btu) per hour.

If these limits are exceeded by more than 20% for more than 12*hours, the licensee shall take action to determine the cause of any excess temperature differential and heat rejectio.n rates and to modify plant operations to resolve the* problem.*.

If these iimits are exceeded for any period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (and up to 7 days on loss of one dilution pump), the licensee shall reduce power accordingly to restore complian.ce with the specifications to protect the aquatic biota.

Deviations of the limits beyond 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (or over 7 days on loss of one dilution pump) shall be reported in accordance with Specificaton 6.9.3.2.

Total plant discharge shall not increase the temperature of Lake Michigan at the edge.of a mixing zone equivalent to 72 acres (a defined area equivalent to that of a circle of radius of l,GOO feet) more than

. 3°F above the existing natural temperature or above the following monthly maximum temperatures (except when a higher temperature*. is permitted by the State Water Resources Commission):

Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec 45 45 45 55

60.

70 80 80 80 65 60 50 Gaseous Wastes The average weekly release rates of gaseous and airborne particulate wastes shall be limited in accordance with the following equation:

\\'

• Qi

_< 5 x 1011 (cc/ s)

L (MPC).

l where Qi is the weekly release rate (µCi/s) of any radioisotope, i, and (MPC). in the uni ts of µCi/ cc is defined in Column 1, Table *II, l

of Appendix B to 10 CFR 20.

Length of the actual interval over which this re+ease rate may be allowed will be limited such that provisions of Section 3.9.l~ are not exceeded.

The average gaseous release rate over any 15-minute period shall.not exceed 10 times the weekly average limit.

3-51

3.9 3.9.13 3.9.15 EFFLUENT RELEASE (Contd)

Follow.ing isolation and prior to release of gaseous wastes from the waste gas decay tanks, the contents shall be sampled and analyzed to determine compliance with 3.9.11, 3.9.12 and 3.9.15..

For purposes of calculating permissible releases by the above formula,.

MPC for halogens and particulates with half-lives longer than 8 days will be divided by a factor of 35 from their listed value in 10 CFR 20, Appendix B.

The quantity of all radionuclides determined to be released during any calendar quarter shall not exceed one.half the design basis annual qua..'1tity calculated fr.om the values given in Table 3.9.15-1.

Calcula-tions shall be performed for each batch release, each stack gas analysis and monthly for continuous releases by the formula:

E A./C. < 0.5 l

l where:

A. = Cumulative l

in gaseous quarterly activity of nuclide i identified release ('Ci).

C. = Design objective annual quantity of nuclide i from

.l Table 3.9.15-1.

The design objective annual quantities of gaseous effluents~ and radioiodines and radionuclides in particulate form released to the atmosphere, are basea on:

(1)

Air dose of 10 millirem from beta radiations or 20 millirem from gamma.

( 2) *Dose to a real individual of 5 millirem total body or 15 millirem to skin.

(3)

Dose to a real individual of 15.millirem to any organ from radioiodines.and radionuclides in p~rticulate forin.

During release of gaseous wastes to the plant vent stack, the following conditions shall be met:

a.

At least one main exhaust fan shall be in operation.

b.

The gaseous radioactivity monitor and the particulate monitor shall be in operation during discqarges with the exception that if RIA-1113 is down for maintenance, sampling of the stack effluent shall be taken every four hours and each sample analyzed.

3-52

3.9 3.9.17 EFFLUENT RELEASE (Contd)

During power operation, whenever the air ejector discharge monitor is inoperable, samples shall be taken from the air eject~r discharge and analyzed for gross radioactivity daily.

In the event the quarterly values calculated for released nuclides exceed one half the design basis guides in Specifications 3.9.6 or 3.9.15, the following actions.shall be taken:

(1)

Perform an investigation to identify the cause for such release rates.;

(2)

Define and initiate a program of corrective action; and (3)

Report these actions to the Commission within 30 days from the end of the quarter during which the release occurred.

Bases Liquid wastes from radioactive waste disposal system are diluted in the dischargemixing basin prior to release to the lake.(l)

A minimum flow of 8,000 gpm is provided for dilution.

The dilution can be achieved by use of any of the.three service water pumps or either of the,,cooling tower blowdown dilution pumps or a combination of any or all of these pumps.

Because of the low radioactivity levels in the.mixing basin, the concentrations in the mixing basin will be calculated from the measured concentrations in the various treated waste tanks, from the flow rate of the treated waste pumps and the discharge flow from the mixing basin.

The flow rate in the mixing basin will be determined by means of a flow meter or other suitable means.

See Section 4.11.

Under normal operating conditions the expected release to the environ-ment from the modified liquid waste system will be less than the de-sign objective quantities as specified*by Appendix I to 10 CFR 50.

All modified waste system liquids will be recycled or prepared for shipment to an authorized disposal area or areas in accordance with applicable NRC and DOT rules and regulations, if Specification 3.9.1 cannot be met.

Section II of Appendix I to 10 CFR 50 specified that the calculated annual total quantity of all radioactive material above background to be released from each light-water-cooled nuclear power reactor to unrestricted areas will not result in an estimated annual dose or 3-53

3.9 EFFLUENT RELEASE (Contd) dose cornrriitment from liquid effluents for any individual in an unre-stricted area from all pathways of exposure in excess of 3 millirems to the total body or 10 millirems to any organ:

In addition, half these values shall not be exceeded in any one quarter.

Specification 3.9.l specified the design.objective quantities and method of summation such that no individual in an unrestricted area will re-ceive greater than 3 millirems to the total body or 10 millirems to any organ from liquid effluents by all pathways of exposure., Liquid path-ways considered in derivation of the design objective annual quantities include fish and drinking water ingestion, immersion (swimming), boating, and shoreline recreation.

The release limit of liquid wastes in the mixing basin is a selection based upon reasonable operating experience and will still result in a concentration at the nearest public water intake significantly below MPC. ( 2 ). It is intended that the liquid waste release limit of Specification 3.9.2 will normally be.restricted to single batches of waste.

The maximum amount of tritium in the discharge is limited to

_ the value given in 10 CFR Part 20 by imposing a limit on the tritium concentration in the primary coolant water bas~d on a minimum dilution of 8,000 gpm.

As there is no mechanism for concentrating tritium above the concentration in the primary coolant system, there is no safety requirement to monitor the liquid waste discharge for tritium.

Prior to release to the atmosphere, gaseous wastes from the radioactive waste disposal system are mixed with the plant ventilation flow from at least one of two main (60,000 cfm) exhaust fans. (6 )

Further dispersion then occurs in the atmosphere.

Section II of Appendix I specified that a licensee may not exceed quan-tities of gaseous effluent which would cause an air dose _greater than.

10 millirads for gamma radiation or 20 millirads beta in a year or-half that amount in a quarter.

It further stipulates that dose to a real individual shall not exceed 5 millirems to skin or 15 millirems to any organ, and not more than half the effluent quantity which would cause these effects may be released in any one quarter.

3-54

3.9.

EFFLUENT RELEASE (Contd)

Specification 3.9.15 specified the design objective quantities and method of summation such that Appendix I limits are not exceeded.

Gaseous pathways considered in derivation of the design objective annual quantities include plume submersion, inhalation, vegetable, meat and milk 'consumption and shine from ground-deposited radionuclides.

If the activity level in the waste gas surge tank is such that the limits of Sections 3.9.11 through 3.9.15 are being approached by direct release to the plant stack, waste gas decay tanks will be utilized to store those gases until such time as releases may be assured as not to exceed those limits.

In any event, release of gaseous wastes will be maintained as low as is reasonably achievable in accordance with.

10 CFR Part 50, Appendix I.

The 15-minute limitation on gaseous release rates, not in "excess of 10 times the weekly average limit, allows operational flexibility, Quarterly.releases will be maintained in conformance with Specifica-tion 3.9.15.

The low-radioactivity levels associated with the gaseous waste collected by the gas collection header allow it to be piped directly to the base of the piant ventilation tank.

The reduction in allowable release rate for particulates and halogens of 35 includes the value of 243 for I-131 as given in Regulatory Guide 1.42 plus credit for a six-month grazing period and the ratio of the x/Q value at the site boundary to that at the location of the nearest postulated cow 1.5 miles southeast of the plant.

Use of the 1.5-mile distance is conservative based upon present location of the nearest actual cow.

The formula of Specification 3.9.11 insures that 10 CFR 20 annual average dose rates will not be exceeded at the point of maximum off-si te dose.

Application of this formula is contingent upon release qua~tities remaining within the limits of Specification 3.9.15.

3-54a

3.9 EFFLUENT RELEASE (Contd)

The limit is based on the highest long-term value of x/Q, which occurs at the south edge of the site and is approximately 2 x l0-12 s/cc.

The following data were used to derive the formula pre-scribed in the specification:

Average Annual

?requency of Average Annual Distance to Site Wind Occurrence Wind Speed Boundary Downwind Direction m/s m

N 12.51 6.1 677 NNE 4.34 5.5 767 NE 3.46 4.1 Offshore ENE 3.48 4.1 Offshore E

4.20 4.4 Offshore ESE 4.41 4.4 Offshore SE 5.01 4.5 Offshore SSE 7.12 5.0 Offshore s

10.10 5.3 Offshore SSW 6.21 5.6 811 SW 7.12 6.4 1052 WSW 8.13 6.2 1402 w

7.85 6.8 1315 WNW 6.07 7.9 1227 NW 4.68 6.9 1008 NNW 4.60 6.3 767 Calm o.66

. 3-55

3.9 EFFLUENT RELEASE (Contd)

From the FSAR analyses, ( 7 ) the following long-term values can be obtained:

x.f._s_

3 m3

_g_ _E!_

Wind Direction*

Q xf s

N 2 x 10-6 5 x 105 NNE 5.64 x 10-1

1. 77 x 106 SSW*

7.39 x 10-7

1. 35 x 106 SW 5.23 x 10-7 1.91 x 106 WSW 3.91 x 10-7 2.56 x 106 w

3.88 x 10-7 2.58 x 106 WNW 2.82 x 10-7 2.54 x io6 NW 3.30 x 10-7 3.03 x 106 NNW 5.22 x 10-7 1.92 x 106 Therefore, the highest long-term value of x/Q at the site boundary

-6 s/m3

-12 is seen to be 2 x 10 or 2 x 10 s/cc.

The limits for the range of pH for discharge of acids and bases to the lake are consistent with the Michigan water quality standards and the NPDES permit.

The limits on the thermal discharges are consistent with thE'. Special T~chnical Specifications and the NPDES permit.

The annual design basis quantities specified in Tables 3.9.1-1 and 3.9.15-1 are based on models and data contained in the June 4, 1976 Appendix I submittal.

The design basis quantities are in accordance with the guide-lines of Appendix I to 10 CFR 50.

Conformance with Appendix I is deemed a conclusive showing of compliance with the 11as low as is reasonably achievable" requirements of 10 CFR Sections 50.34a and 50.36a.

Design objective annual quantities are based on models and data such that the annual exposure of an individual is unlike~y to be substantially under-estimated.

3-56

e 3.9 EFFLUENT RELEASE (Contd)

TABLE 3.9.1-1 Liguid Effluent Design Ob,jective A!:lnual Quantities Design Objective Dose Factor Annual Quantity Nuclide Organ (mrem/Curie)

(Curies)

H-3 Tot Body

1. 31E-06 2.29E+06 Cr-51 GI l.49E-03 6, 730 Mn-54 GI 6.22E-02 161 Fe-55 GI l.2IE-02 827 Fe-59 GI 3.77E-02 265 Co-58 GI 8.38E-03 1,190 Co-60 Tot Body 4.. 50E-Ol 6.67 Rb-86 Tot Body 2.28E-Ol 13.2 Sr-89 Bone l.07E-02 935 Sr-90 Bone l.64E-Ol 61.0 Zr-95 GI

1. 72E-02 581 Nb-95 GI l.17E-02 855 Mo-99 GI l.llE-03 9,020 Te-99m GI 6.88E-05 145,000 Te-127m GI l.OlE-01 99.2 Te-127 GI 2.85E-02 259 Te-129m GI

2. 57E-Ol 38.9 Te-131m GI 3.73E-Ol 26.8 Te-132 GI 3.42E-Ol 29.2 I-130 Thyroid 5.28E-02 190 I-131 Thyroid 3.24E-Ol 30.9 I-132 Thyroid l.32E-02 755 I-133 Thyroid 4.05E-02 254 I-135 Thyroid 2.83E-02 353 Cs-134 Tot Body

2. 83E+OO *

1. 06

• cs-136 Tot Body 3.94E-Ol 7.61 Cs-137

• rot Body l.67E+OO 1.80 Ba-140 GI l.86E-03 5,390 La-140 GI 2.57E-02 390 Np-239 GI 2.662-03 3,750 3-56a

e 3.9 EFFLUENT RELEASE (Contd)

TABLE 3.9.15-1 Gaseous and Particulate Design Objective Annual' Quantities Design Objective Dose Factor Annual Quantity Nuclide Organ (mrem/Curie)

(Curies)

H-3 Soft Tissue l.12E-04 133,929 C-14 Soft Tissue

1. 83E-02 820 Ar-41 Air Dose (-',')

3.53E-03 2,830 Cr-51 GI 4.92E-03 3,049 Mn-54 GI 2.44E-Ol

61. 5 Co-57 GI.

2.83E-02 530 Co-58 GI l.llE-01 135 Co-60 GI 5.82E-Ol 25.8 Fe-59 GI 2.30E-Ol 65.2

.Kr-85m Air Dose ( s) l.20E-03 16,600 Kr-85 Air Dose ( s) l.OlE-03 19,800 Kr-87 Air Dose ( s) 7.80E-03 2,560 Kr-88 Air Dose (y) 5.88E-03 1,700 Sr-89 Bone l.06E+Ol 1.42 Sr-90 Bone 4.03E+02 0.037 Zr-95 GI 2.27E-Ol 66.1 Nb-95 GI

1. 54E-Ol 97.4 I-131 Thyroid 9.45E+OO

1. 59 I-133 Thyroid l.60E-Ol 93.8 I-135 Thyroid 3*~ 14E-02 478 Xe-13lm Air Dose ( s) 4.02E-04 49,700 Xe-133m Air Dose ( s) 8.08E-04 24,800 Xe-133 Air Dose ( s)

2. 82E-04.

70,900 Xe-135 Air Dose ( s) l.57E-03 12,800 Cs-134

• Liver 7.17E+OO 2.09 Cs-137 Liver 4.5*:2+00 3.33 3-56b

ENVIRONMENTAL MONITORING PROGRAM (Contd) 4.11. 3 4.11. 4 4.ll. 5 Plant equipment shall be used in conjunction-with developed operating procedures to maintain surveillance of radioactive gaseous and liquid effluents produced during normal reactor operations and expected operational occurrences in an effort to maintain radioact_ive releases to unrestricted areas as reasonably achievable.

A survey will be performed annually, at the beginning of the agri-cultural season (May through July), to confirm locations of the nearest milk cow, milk goat, meat animal, vegetable garden (>500 square feet in area), and resident in each sector to a distance of 5 miles from the release point.

After the conversion of a closed-cycle cooling system utilizing evaporative cooling towers, aquatic samples shall be taken according to the following schedule:

(a)

( b)

Sample Service water or dilution water intake tempera-ture.

Mixing bas.in water temperature prior to dis-charge to the lake.

(c)

Thermal plume study.

(d1 )

Cooling tower suction basin overflow.

Frequency Measure hourly during co~ling system operation.

Measure continuously during cooling system operation and record hourly.

At least once, as per the plan submitted 1/6/75 to Michigan Water Resources Com-mission and approved 7/22/75.

Measure daily during cooling sytem operation.

4-50 Objective To determine ambient lake*temperature con-ditions offshore of the plant.

To determine increase in discharge water tempera-ture over service or dilution water intake temperature'.

To determine size of plume isotherms for compliance with NPDES permit.

To determine service and condens'er water discharge flow rate.

ENVIRONMENTAL.MONITORING PROGRAM (Contd)

Sample (d2 )

Blowdown water flow rate from blowdown piping.

(d3)

Discharge water flow to lake.

(e)

Closed-cycle Frequency Measure daily during cooling system opera-tion and during Ob,jective To determin*e the total residual chlorine con-centration reaching the chlorination treatment. mixing basin and the heat content of discharge into the lake.

Measure (or calculate based.on pumphead To determine water dis-charge flow rates for curves and above daily determination of the readings) hourly heat rejection and during cooling system chlorine discharge rates.

operation.

Daily*during closed-To determine concentra-condenser cooling cycle condenser tion of dissolved salts system conduc-tivity or TDS.

(f)

Total residual cooling system operation.

Seven times weekly.

chlorine of blow-_ Three grab samples down water from equally spaced in outfall over the time during each weir and blowdown treatment.

piping when dis-charging into mixing basin.

(g}

pH of mixing basin water (prior to dis-charge to the lake).

Daily during closed-cycle conden*ser cool-ing system discharge.

4-51 in the condenser cooling system water a*nd dis-charge to the lake.

To determine that the total residual chlorine concentration in the discharge is below per-missible limits by using amperometric titration methods.

To determine that pH is within the permis-sible limits.

ENVIRONMENTAL MONITORING PROGRAM (Contd)

Sample ireguency Objective (h)

Heavy metals (Mn)

Daily during suspected To determine that re-in the mixing basin water.

(i) Fish in dis-charge.

discharge.

During and after chlorination.

lease of toxic com-pounds is minimal.

To identify gross effects on fish populations re-siding in vicinity of the discharge to lake.

4.11.6 During chlorination treatment of the closed-cycle condenser cooling system water, samples shall be taken of the total blowdown water and analyzed with an analytical accuracy capable of detection of +/- 0.1 ppm to verify compliance with discharge concentration limits using appro-priate dilution factors.

The total time of each chlorination treatment of the closed-cycle condenser cooling system and the service water system, the total quan-tity of chlorine compound used, the closed-cycle condenser cooling system discharge rate, the ~ilution flow rate and the time*of the holdup of the c~osed cycle condenser cooling system discharge to allow chemical decomposition of residual chlorine shall be recorded for each chlorina-tion treatment and reported in accor4ance with Specification 6.9.3.1.

During simultaneous chlorination treatment of the clcsed-cycle condenser cooling system water and releases from the closed-cycle condenser cooling system, any evidence of detrimental effects of chlorine on aquatic life, such as dead fish or fish in distress, shall be noted and a record of such evidence shall be maintained with the records of the chlorination treatment and reported in-accordance with Specifica-tion 6.9.3.1.

4-52

ENVIRONMENTAL MONITORING PROGRAM (Contd) 4.11.7 A

t l

1

- "t

( 2 )

l d.

me eoro ogica moni oring program shal be conducte in the vicinity of the plant site for at least two years after conversion to co~ling towers to document effects of cooling tower operation on meteorological variables.

Data on the following'meteorological variables shall be obtained from the station network shown in Figure 4.11.l:

Precipitation, temperature, humidity, solar radiation, downcoming radiation, visibility, wind direction and wind speed.

In addition, studies shall be conducted for at least two years to mea-sure effects of cooling tower drift on vegetation by associated salt d

. t.

th

( 3 )

0 t.

h 11 b d

f eposi ion, icing or o er causes.

bserva ions s a e ma e o a series of sample vegetation plots, and chemical analyses.shall be made of representative samples of vegetation, soil and collected moisture to establish relative amounts of drift at various locations and influences on plant life.

The incidence of icing and fogging on nearby transportation arteries shall be determined.

Noise measure-ments shall be taken with and without the cooling tower in operation at different locations on site and around the surrounding areas.

The study program to assess the meteorological and terrestrial effects of cooling tower operation on site and off site shall be carried out as follows:

'4-53

ENVIRONMENTAL MONITORING PROGRAM (Contd)

METEOROLOGICAL STUDY Sample (a)

Precipitation (b)

Temperature (c)

Relative Humidity

( d)

Total Solar Radia-

• tion

( e)

Total Solar Plus At-mospheric Radiation (f) Visibility (g)

Wind Direction (h)

Wind Speed (i)

Icing

• ct = Cooling Towers Frequency Continuously Continuously Continuously Continuousl'y Continuously Continuously Continuously Continuously During Winter Months 4-54 Objective To determine if the ct influence natural precip-itation processes.

To establish ct* plume influences on temperature if any.

To determine if the ct plume produces an increase in RH.

To determine if the ct plume inhibit total solar radiation.

To determine the presence of nocturnal ct* plume.

To detect the presence of fog.

To determine, the direction of movement to the ct*

plume and alterations in wind patterns.

To determine if the ct plume affects local wind speeds.

To determine if ct* plume creates icing problems of nearby highways and roads.

ENVIRONMENTAL MONITORING PROGRAM (Contd)

Sample (a)

Precipitation Col-1.ected and Analyzed for so4 and Ca Analysis of Vegeta-( b) tional Composition

( c)

Vegetation Chemical Analysis (d)

Soil Chemical Analysis

( e) *Icing

• ct =*Cooling Towers DRIFT STUDY Frequency Monthly Survey 3 Times per Year (Spring, Sum-mer, Fall)

Yearly Yearly Winter Months 4-55 Objective To establish pattern and rate of drift deposited ions.

To determine if ct* drift is altering the vegeta-tional composition.

To determine if drift deposited elements are concentrating in vege-tation.

To determine if drift deposited elements are concentrating in soils.

To determine if ct dr.ift (ice) is physically dam-aging to vegetation.

N r

r Vl Pl

(~

~

Figure 4-11.l Loca.tions of climatological stations

()

0 ::s c+

p.,*

... *-*-*~-:~---***-.-::-.-. *:-***~*!";'.."**-*-.-~-.:~:---*-- *----*----**"":'"--- ***** *- **-*

.i:-

I

\\.JI

'61' I

():)

I

-1 ~

! I.

I --l I s;-

-I I

Q

.. I

. I t

-..i---...1.-'----...J--'--'- 0 I

I I

I

. ~.

Figure 4.11.2

\\ '

11nrr1 rt**nf hUl*UI r.... r.

ll*lf~lol ICrll et**W1

'I ~ ' ' i I "

, ~I.,,

. (~1~1

\\~

• b

• .I

.e

\\{j~

-.f ) ENVIRONMENTAL MONITORING PROGRAM (Contd)

Deleted Basis - Radiological The radiological environmental monitoring program for the plant is designed to meet the following objectives:

1.

Measurement of radiation levels in the sampled media is done in such a manner to assure compliance with 10 CFR 20 and 10 CFR 50, Appendix I.

2.

Survey design is such that releases of plant origin can be differ-entiated from natural or other sources of environmental radiation.

3.

This is accomplished in two ways.

First of all, the commonly called "reference area approach to environmental surveillance" is used.

This makes use of a calculation that shows whether or not a statistical difference exists between the levels* of radio-activity detected near the site and those detected remote from the site.

Secondly, *specific isotopic analyses are performed.

In this manner, concentrations of specific isotopes in the sampled.

environmental media can be related to known plant releases of the same nuclide.

Dose estimates to man are made if significant increases in radia-tion levels have been found to occur as a result of (2) above.

This is meaningfully done by.(a) requiring detection sensitivity to be far below any effective maximlirn permissible concentration, and (b) planning the survey with sample colrection*designed to estimate dose.

The survey consists of 12 stations.. Nine are near and three are remote from the site.

In addition, nine extra film-TLD stations are located at the site bound~ry and lake water, biota and bottom sediment are further collected at the site.

In this way, inhalation, ingestion and direct dose can be estimated and because of the Lake Michigan sampling,

'food-chain parameters can be determined.

Meeting the objective of providing assurance that the facility's con-tribution to the naturally existing radioactivity in the environment is negligible requires analyses to be performed such that sensitivities 4-56