ML20091C842

Rev O.A to Odcm,Consisting of Pages Inadvertently Omitted from Previous Distribution

ML20091C842
Person / Time
Site:	Braidwood
Issue date:	04/30/1991
From:	COMMONWEALTH EDISON CO.
To:
References
PROC-910430, NUDOCS 9108070224
Download: ML20091C842 (28)

Text

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4 q REVISION 0.A APRIL 1991 BRAIDH000 12.4.3 QQit (Continued) ~ Bases ---The ODCM calculational methodology and parameters for calculating the doses due to the actual release rates of the subject materials _are consistent with the methodology provided in

Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents For the Purpose of L

Evaluating Compliance with 10 CFR Part 50, Appendix I" Revision i 1, October 1977 and Regulatory Guide 1.111, " Methods for Estimating Atmospheric Transport.and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," Revision 1, July 1977. These equations also provide for determining the actual doses based upon the historical average atmospheric conditions. The release rate specifications _ for Iodine-131 and 133, tritium, and radionuclides in particulate form with half-lives greater than 8 days are dependent upon the _ existing radionuclide pathways to man, in the areas at and beyond-the SITE BOUNDARY. The pathways that were examined in the i development of these calculations were: (1) individual inhalation of airborne radionuclides, (2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, (3)' deposition onto grassy areas where milk t animals and meat producing animal's graze with consumption of the milk and meat by man, and (4) deposition on the ground with subsequent exposure.to man. This section applies to the release of radioactive materials in gaseous effluents from each unit at the site. When shared Radwaste Treatment Systems are used by more than one unit on a j site,_the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the contributions from each unit based on input conditions, e.g.,_ flow-rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated i equally to each of the radioactive waste producing units sharing the Radwaste Treatment System. For determining conformance to ' Operability Requirements, these allocations from shared Radwaste_ l Treatment Systems are to be-added to the releases specifically-i attributed to each unit-to obtain the total releases per unit. v 12-35

i REVISION 0.A APRIL 1991 BRAIDH000 12.4.4 Galppus RadwlsifLiteAtmaat_Sy.Ltim (_S C) Q2erability Reauirements 12.4.4.A The VENTILATION EXHAUST TREATHENT SYSTEM and the HASTE GAS HOLOUP SYSTEM shall be OPERABLE and appropriate portions of these systems shall be used to reduce releases of radioactivity when the projected doses in 31 days due to gaseous effluent releases, from each unit, to areas at and beyond the SITE BOUNDARY (see Braidwood Station 00CH Annex, Appendix F, Figure F-1) would exceed: 1. 0.2 mrad to air f rom gamma radiation, or 2. 0.4 mrad to air from beta radiation, or 3. 0.3 mrem to any organ of a HEMBER OF THE PUBLIC, Applicability: At all times. Ardion: 1. With radioactive gaseous waste being discharged without treatment and in excess of the above limits, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that includes the following information: (,) V a. Identification of any inoperable equipment or subsystems, and the reason for the inoperability, b. Action (s) taken to restore the inoperable equipment to OPERABLE status, and c. Summary description of action (s) taken to prevent a recurrence. Surveillance Reauirements 12.4.4.1.8 Doses due to gaseous releases from each unit to areas at and beyond the SITE BOUNDARY shall be projected at least once per 31 days in accordance with the methodology and parameters in the OOCH when Gaseous Radwaste Treatment Systems are not being fully utilized. 12.4.4.2.B The installed VENTILATION EXHAUST TRlriMINT SYSTEM and HASTE GAS HOLDUP SYSTEM shall be considered OPiH.dLE by meeting Section -12.4.1 and 12.4.2 or 12.4.3. Bases 12.4.4.C The OPERABILITY of the HASTE GAS HOLOUP SYSTEM and the n VENTILATION EXHAUST TREATHENT SYSTEM ensures that the system will ( ) be available for use whenever gaseous effluents require treatment prior to release to the environment. 12-36 ( l

REVISION 0.A APRIL 1991 BRAIDH000 fationLRadwti.te Treatment _Syitem (Continued) 12.4.4 J .- =-- Bases -The requirement that the appropriate portions of this system be used when specified provides reasonable assurance that the releases of radioactive materials in gaseous effluents will be= kept "as low as is reasonably achievable". This section 1 -implements the requirements of 10 CFR 50.36a, General Design i Criterion 60 of Appendix A to 10 CFR Part-50 and the design-objective given in Section 11.0 of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the Gaseous-Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II.B and II.C of Appendix I,10 CFR Part 50, for gaseous effluents. This section-applies to the release of radioactive materials in i gaseous effluents from each unit at the site. When shared i Radwaste Treatment.,/ stems are used by more than one unit on a site,=the wastes from all units are mixed for shared treatment; by such mixing, the effluent releases cannot accurately be ascribed to a specific unit. An estimate should be made of the -contributions from each unit based on input conditions, e.g., i flow rates and radioactivity concentrations, or, if not practicable, the treated effluent releases may be allocated equally to each of the radioactive waste producing units-sharing the Radwaste Treatment-System. For determining conformance to Operability Requirements, these allocations from shared Radwaste N Treatment' Systems are to be added to the releases specifically attributed to each unit to obtain the total releases per unit.- 1 0 12-37

i REVISION 0.A ( APRIL 1991 'x BRAIDH000 1: 12.4.5 lotal_ Dose Onerability Reauirements ~ ~

12. 4._5. A The annual-(calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to less than or equal to 25 mroms to the whole body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems.

Applinbility: At all times. &ction:- 1. With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Sections 12.3.2,12.4.2, or 12.4.3, calculations should be made including direct radiation contributions from the units and from outside storage tanks to determine whether the above limits of Section 12.4.5.A have been exceeded. If such is the case, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that defines the corrective action to be taken to reduce subsequent releases to prevent recurrence of exceeding the above limits and includes the schedule for achieving conformance with the above limits. This Special Report, as defined in 10 CFR 20.405c, shall include an analysis that estimates the radiation exposure (dose) to a MEMBER OF THE PUBLIC from uranium fuel cycle sources, including all effluent pathways -and direct radiation, for the calendar year that includes the release (s) covered by this report. It shall also describe levels of radiation and concentration of radioactive material involved, and the cause of the exposure levels or concentrations. If-the estimated dose (s) exceeds the above limits, and if the release condition resulting in violation of 40 CFR.Part 190 has not already been corrected, the Special Report shall-include a-request for a variance in accordance with the provisions of 40 CFR Part 190. Submittal of the report is considered a timely request, and a variance-is granted until staff action on the request is complete. Surveillance Reautrements 12.4.5.1.A Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with Sections 12.3.2, 12.4.2, c and 12.4.3, and in accordance with the methodology and parameters [ in the ODCH. p 12.4.5.2.B Cumulative dose contributions from direct radiation from the units and from radwaste storage tanks shall be determined in accordance with the methodology and parameters in the 00CM. This requirement is applicable only under conditions set forth in 4 ACTION 1 of Section 12.4.5.A. 12-38

} REVISION 0.A APRIL 1991 BRAIDWOOD r 12.4.5 Iotal_ Dose (Continued) (D V. Bases 12.4.5.C This section'is provided to meet the dose limitations of 40 CFR Part 190 that have been incorporated into 10 CFR Part 20 by 46 FR 18525. The section requires the preparation and submittal of a Special Report whenever the calculated doses due to releases of radioactivity and to radiation from uranium fuel cycle sources exceed 25 mrems to the whole body or any organ, except the thyroid, which shall-be limited to less than or equal to 75 [' mrems.- For_ sites containing up to four reactors, it is highly unlikely-that the resultant dose to a MEMBER OF THE PUBLIC will exceed the dose limits of 40 CFR Part 190 if the individual i-reactors remain within twice the dose design objectives of Appendix I, and if direct radiation doses from the reactor units and outside storage tanks are kept small. The Special Report will describe a course of action that should result in the 2 limitation of the annual dose to a MEMBER OF THE PUBLIC to within the 40 CFR Part 190 limits. For the purposes of the Special Report, it may be assumed that the dose commitment to the MEH8ER OF THE PUBLIC from other uranium fuel cycle sources 1s-negligible, with the exception that dose contributions from other nuclear fuel cycle facilities at the same site or within a radius of 8 km must be considered. If the dose to any MEMBER OF THE PUBLIC is estimated to exceed the requirements of 40 CFR Part n 190, the Special' Report with a request for a variance (provided the release conditions resulting in violation of 40 CFR Part-190 have not already been corrected),-in accordance with the Wa provisions of 40 CFR 190.11 and 10 CFR 20.405c, is considered to i. be a timely request and fulfills the requirements of 40 CFR Part. 190 until NRC staff action is completed. The variance only relates to the limits of 40 CFR Part 190, and does not apply in any way to the other requirements for dose limitation of 10 CFR Part 20, as addressed in Sections 12.3.1 and 12.4.1. An individual is not tonsidered a-MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation 4 that is part of the nuclear fuel cycle, h; o 12-39

REVISION 0.A APRIL 1991 BRAIDHOOD 12.5 BAD 10LOGICALERVLRONENIALM0M1081NG 1D V 12.5.1 Monttoring ProEAm Ooerability-Reagirements i 12.5.1.A The Radiological Environmental Monitoring Program shall be conducted as spacified in Table 12.5-1. l Applinl21Lt.ty: At all times. 61t100: l 1. With the Radiological Environmental Honitoring Program not being conducted as specified in Table 12.5-1, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Technical Specification 6.9.1.6, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence. i 2. With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 12.5-2 when averaged over any calendar quarter, prepare and submit to the Commission within 30 days, pursuant to Technical Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the -\\ corrective actions to be taken to reduce radioactive effluents so that the potential annual dose

• to a HEMBER OF THE PUBLIC is less than the calendar year limits of Section 12.3.2, 12.4.2, or 12.4.3.

When more than one of the radionuclides in Table 12.5.2 are detected in the sampling i medium, this repor; shall be submitted if: concentration (1) concentratt0ILIU + .. 11.0 l + reporting level (1) reporting level (2) j \\ Hhen radionuclides other than those in Table 12.5-2 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose

• to A HEMBER OF THE PUBLIC from all radionuclides is equal to or greater than the calendar year limits of Section 12.3.2, 12.4.2. or i

12.4.3. This report is not required if the measured level l of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report required by Section 12.6.1.

• The methodology and parameters used to estimate the potential annual dose to a HEMBER QF THE PUBLIC shall be indicated in this

'T report. 12-40

REVISION 0.A a APRIL 1991 i BRAIDH000 - 12.5J RADIOLOGICAL ENVIRONMENTAL.HONLIORBG (Continued) M-3. With the milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 12.5-1, identify specific locations for obtaining replacement samples and add-them within 30 days to the Radiological Environmental Monitoring Program given in the ODCH. The specific locations from which samples were unavailable may_then be deleted from the monitoring program. Submit controlled version of the ODCM within 180 days including a revised figure (s) and table reflecting the new location (s) with supporting information identifying the causeoftheunavailabilityofsamplesandjustifyingthe selection of new location (s) for obtaining samples. Surveillance Recuirements f 12.5.1.8 The radiological environmental monitoring samples shall te-p collected pursuant to Table 12.5-1 from the specific iccations given in the table and-figure (s) in the ODCM, and shali be analyzed pursuant to the requirements of Table 12.6-1 and the.. 1 detection capabilities required by' Table 12.5-3. _[ gdes i 12.5.1.C-The Radiological Environmental Monitoring Program required by l-this section provides representative measurements of radiation and of radioactive materials in those exposure pathways and for j _those radionuclides that-lead to the highest potential radiation exposures _of MEMBERS OF THE PUBLIC resulting from the station i operation. -This monitoring program implements Section-IV.B.2 of j Appendix I to 10 CFR Part 50 and thereby supplements the i radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways. Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on_ Environmental Monitoring. The initially specifled monitoring program will be effective for at least the first 3 years of commercial operation. Following this period, program changes may be initiated based on operational experience. The required detection capabilities for environmental sample L J analyses are tabulated in terms of the lower limits-of detection (LLDs). The LLDs required by Table 12.5-3 are considered optimum for routine environmental measurements in industrial laboratories. It should be recognized that the LLD is defined-as a before the fact limit representing the capability of a measurement system and not as M after the fact limit for a particular measurement. h 12-41

REVISION 0.A APRIL 1991 BRAIDWOOD 12.5 BAQ10LQGLCALEMIRONMENTAL HONITORING (Continued) ,_.() Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, LA., " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry," Anal. Chem. 4Q, 586-93 (1968), and Hartwell, J.K., " Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975). + f f i 1 i N 1 I k 12-42

REVISION O ~ APRIL'1991:' BRAIDH000 TABLE 12.'5-1 i RADIOLOGICAL-ENVIRONMENTAL MONITORING PROGRAM -NUMBER OF REPRESENTATIVE-EXPOSURE PATHNAY SAMPLES.AND ' SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONSill' COLLECTION FRE00ENCY OF ANALYSIS

1. Direct Radiation (2) forty routine' monitoring stations.

Quarterly. Gamma. dose quarterly. either with two or more dosimeters or with one instrument ~for. measuring and: recording dose rate. continuously, placed as follows: An inner ring of ' stations, one in i each meteorological sector in the general area of the SITE B0UNDARY; i An outer ring of. stations, one in each meteorological sector.in the 6 to 8-km range from the site; and The balance of the stations to be placed in.special interest areas l such as population centers, nearby residences, schools,.and in one or two areas to serve as control stations. l! ? l

-12-43

REVISION O.A \\. ' ^" 1 * '~ BRAIDH000 4 TABLE 12.5-1 (Continued) . RADIOLOGICAL ENVIRONMENTAL MONITORING' PROGRAM NUMBER OF. REPRESENTATIVE' EXPOSURE PATHNAY SAMPLES AND. 5AMPLING AND. TYPE.AND FREQUENCY AND/OR SAMPLE. SAMPLE LOCATIONSUI COLLECTION FRE00ENCY OF ANALYSIS

2. Airborne Radiolodine'and Samples from five locations:

Continuous sampler Radiciodine Cannister: Particulates operation with sample I-131 analysis weekly. Three samples.from close to the. ' collection weekly, or three SITE. BOUNDARY locations, more frequently if in different sectors, of the required by dust Particulate Samoler: highest calculated annual: average. loading. Gross beta radioactivity ground level D/Q;. ~ analysis following filter change;(3) and' One sample from the vicinity of. gamma isotopic analysisC,4) a community having the highest of composite (by location) calculated annual. average ground-quarterly. l 1evel D/Q; and One sample from.a control location, as for example 10 to 30 km distant and-in'the least prevalent wind direction.

3. Haterborne

a. Surface (5)

One sample upstream. Composite sample.over Gamma isotopic analysis (4) One sample downstream.. 1-month period by . monthly. Composite for . eekly grab samples. tritium analysis quarterly. w

b. Ground Samples from one or two sources Quarterly.

Gamma isotopic (4) and only if likely to be affected (7) tritium analysis quarterly. 1 12-44

/9 [p h REVISION O[' \\I V \\- APRIL 1991 BRAIDHOOD TABLE 12.5-1 (Continued) RADIOLOGICAL ENVIRONMENTAL HONITORIN_G PROGRAM NUMBER OF REPRESENTATIVE EXPOSURE PATH'AAY SAMPLES AND SAMPLING AND TYPE AND FREQUENCY AND/0R SAMPLE SAMPLE LOCATION 5111 CQLLECTION FRE00ENCY OF ANALYSIS

3. Haterborne (Continued) 5 1

c. Drinking One sample of each comunity Composite samp(6) when le over I-131 analysis on each drinking water supply within 2-week period composite when the dose 10 miles downstream of the I-131 analysis is calculated for the discharge.

performed, monthly consumption of the water composite otherwise. is greater than 1 mrem per One sample from a control year.(8) Composite for gross location. beta and gamma isotopic analyses (4) monthly. Composite for tritium analysis quarterly.

d. Sediment One sample from downstream area Semiannually.

Gama isotopic analysis (4) fi m choreline with existing or potential semiannually. recreational value.

4. Ingestion

a. Hilk Samples from milking animals Semimonthly wher*

Gamma isotopic (4) and I-131 in three locations within animals are on analysis semimonthly when 5 km distance having the highest pasture, monthly at animals are on pasture; dose potential. If there are other times. monthly at other times. none, then, one sample from milking animals in each of three areas between 5 to 8 km distant where doses are calculated to be greater than 1 mrem per yr(8). One sample from milking animals at a control location, 15 to 30 km distant and in the least prevalent wind direction. 1 12-45

p 7 1- ' REVISION O. APRIL 1991- - BRAI M TABLE 12.5-1-(Continued) , RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ( ' NUMBER OF -REPRESENTATIVE EXPOSURE PATHNAY' SAMPLES AND. SAMPLING AND TYPE AND FREQUENCY AND/OR SAMPLE

SAMPLE LOCATIONSUI'

' COLLECTION FRE00ENCY OF ANALYSIS

4. Ingestion (continued)

b. Fish and Representative samples'of.

Three times per year Gamma isotopic analysis (4} Invertebrates-commercially and recreationally (spring, summer and on edible portions. ^important species in vicinity fall).. .of plant discharge area. Representative samples of commercially and.recreationally important species in' areas not . influenced by plant discharge.

c. Food Products.

Repres'entative samples of the Atthe-{9)ime of Gamma isotopic analysis (4) principal. classes of food products harvest on edible portion. from any area within 10 miles of j the' plant that'is irrigated by water in which 11guld plant wastes have been discharged. i Samples of three different kinds Monthly when Gamma isotopic (4) and I-131 of broad leaf vegetation grown available. analysis. nearest each of two different offsite ' locations of highest predicted annual average ground- ) level D/0 if milk sampling is not performed. One sample of each of the similar Monthly when Gamma isotopic (4) and I-131 l broad leaf vegetation grown 15 to available.- analysis. i 30 km distant in the. least j prevalent wind direction if milk i . sampling.is'not performed. 12-46 l ~

4 REVISION 0.A APRIL 1991 BRAIDH000 IABLL 12.5-1 Eontinuedl i IMLE NOTATIONS (1)- Specific parameters of distance and direction sector from the centerline of one unit, and additional description where pertinent, shall be provided for each and every sample location in Table 12.5-1 in t table and figure (s) in the ODCH. Refer to NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," October 1978,-and to Radiological Assessment Branch Technical l Position, Revision 1, November 1979. Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall l 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-Radiological Environmental Operating Report i pursuant to Section 12.6.1. It is_ recognized that, at times,.it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location or time. In these instances suitable specific alternative media and allocations may be chosen for the particular pathway in' question and appropriate substitutions made within 30 days in the Radiological Environmental Monitoring Program given in the ODCH. Submit controlled revisions of the ODCH within 180 days including a revised figure (s) and table reflecting the new location (s) with supporting information identifying _ _ _' p/ the cause of the unavailability of samples-for-that pathway and ( justifying the selection of the new location (s) for obtaining samples. (O One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters. For the purposes of this table, a thermoluminescent dosimeter (TLD) is considered to be one phosphor; two or.more phosphors in a packet are considered as two or more dosimeters. Film. badges shall not be used as dosimeters for measuring direct radiation. -The 40 stations is not an absolute number. The number of direct radiation monitoring stations may be i reduced according to geographical limitations; e.g., at an ocean site, { some sectors will be over water so that-the number of dosimeters may be reduced accordingly. The frequency of analysis or readout for TLD systems will depend upon the characteristics of the specific system used and should be selected to obtain optimum dose information with minimal fading. (3) ' Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours or more after sampling to allow for radon and thoron daughter decay. If gross beta activity in air particulate samples is greater than 10 times the yearly mean of control samples, . gamma isotopic analysis snall be performed on the individual samples. 1 O 12-47

REVISION 0.A APRIL 1991 BRAIDWOOD IABILlLS-LIContinuen 'u/ IABLLH0]ATIONS (4) Gamma isotopic analysis means the identification and quantification of i gamma-emitting radionuclides that may be attributable to the effluents i from the facility. (5) The " upstream sampie" shall be taken at a distance beyond significant influence of the discharge. The " downstream" sample shall be taken in an area beyond but near the mixing zone. l (6) A composite sample is one in which the quantity (aliquot) of liquid j sampled is proportional tu the quantity of flowing liquid and in which the method of sampling employed results in a specimen that is representative of the liquid flow. In this program composite sample aliquots shall be collected at time intervals that are very short (e.g., hourly) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sarrple. (7) Groundwater samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination. (8) The dose shall be calculated for the maximum organ and ele group, using the methodology and parameters in the ODCH. [ (9) If harvest occurs more than once a year, sampling shall be performed L during each discrete harvest. If harvest occurs continuously, sampling i shall be monthly. Attention shall be paid to including samples of tuberous and root food products. i 1-f i i n 12-48

,ey ,m C) (_) REVISIO1 .A BRAIDHTO TABLE 17a1-2 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRCNMENTAL SAMP!,E_S REPORTING LEVELS WATER AIRBORNE PARTICULATE FISH MILK FOOD PRODUCTS ANALYSIS (pCi/ ) OR GASES (pCi/m3) (pCi/kg, wet) (pCi/f!) (pCi/kg, wet) H-3 20,000' Hn-54 1.000 30,000 Fe-59 400 10,000 Co-58 1.000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 j I-131 2 0.9 3 100 Cs-134 30 10 1.000 60 1.000 C:-137 50 20 2,000 70 2,000 Ba-La-140 200 300

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

If no drinking water pathway exists, a value of 30,000 pCi// may be used. i 12-49

p f~. (- REVISION \\.d APRIL 1991 BRAIDH000 TABLE 12.5-3 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS (I) LOHER. LIMIT OF DETECTION (LLD)(2)(3) HATER AIRBORNE PARTICULATE FISH HILK FOOD PRODUCTS SEDIMENT ANALYSIS (pCi/4) OR GASES (pCi/m3) (pCi/kg, wet) (pCi/2) (pCi/kg, wet) (pCi/kg, dry) f Gross Beta 4 0.01 H-3 2000* Hn-54 15 130 Fe-59 30 260 Co-58,60 15 130 Zn-65 30 260 Zr-Nb-95 15 I-131 1(4) 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-La-140 15 15 1

• Ifnodrinkingwaterpathwayexists,avalueof3000pC1//maybeused.

L 12-50 t

REVISION 0.A APRIL 1991 BRAIDH000 1 TABLE 12.5-3 (Continued) j TABLE NOTATIONS (1) This list does not mean that only these nuclides are to be considered. f Other peaks that are identifiable, together with those of the above nuclides, shall also bt analyzed and reported in the Annual Radiological Environmental Operating Report pursuant to Section 12.6.1. (2) Required detection capabilities for thermoluminescent dosimeters used l for environment measurements shall be in accordance with the recommendations of Regulatory Guide 4.13. (3) The LLD is defined, for purposes of these specifications, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only-5% probability of falsely _ concluding that a j blank observation represents a "real" signal. For a particular measurement system, which may include radiochemical separation: 4*003 -LLD - b E_* V *-2.22 x 10-6. y. exp (-lat) Where: LLD - the "a priori" lower limit of detection (picoCuries per unit mass or volume), sh the standard deviation of the background counting rate or of -l the ccunting rate of a blank sample as appropriate (counts per minute), E = the counting efficiency (counts per disintegration), V - the sample size (units of mass or volume), j 2.22 - the number of disintegrations per minute per picocurie, Y - the fractional radiochemical yield, when applicable, -A-thy)radioactivedecayconstantfortheparticularradionuclide (sec - , and AtI= the elasped time between sample collection, or end of the sample collection period, and the time of counting.(sec). 1 i -Typical values of.E. V, Y, and at should be used in the calculation. i It should be recognized that the LLD is defined as a before the fact L ,3 limit representing the capability of a measurement system and not as an after the fact limit for a particular measurement. l 12-51 L i p

REVISION 0.A APRIL 1991 BRAIDHOOD (7 TABLE 12.5-3 (Continued) TABLE NOTATI0tlS Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally, background fluctuations, unavoidable small sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable. In such cases, the contributing factors shall be iaentified and described in the Annual Radiological Environmental Operating Report pursuant to Section 12.6.1. (4) LLD for drinking water samples. If no drinking water pathway exists, the LLD of gamma isotopic analysis may be used. Iv 12-52

_. _. _. ~.. q REV1SION 0.A r APRIL 1991 12.5,2-LAD (llie_CeniM O V QDerabilitv Reautrements 12.5.2.A. A Land Use Census shall be conducted and shall-identify within a lf distance of 8 km (5 miles) the location in each of the 16 i meteorological sectors of the nearest milk animal, and the nearest residence. For dose calculation, a garden will be i assumed at the nearest residence. ADDllCability: At all times. Ac. tion: l 1. With a Land Use Census identifying a location (s) that yields a calculated dose or dose commitment greater than the values I, currently being calculated in Section 12.4.3, identify the new location (s) in the next Annual Radiological Environmental Operating Report, pursuant to Section-12.6 1 2. ' With a Land Use Census-identifying a-location (s)-that ylsids [ a calculated dose or dose commitment (via the same exposure pathway) 20% greater than at a location from which samples are currently being obtained in accordance with'Section 12.5.1. add the new location (s) within 30 days to the 1 Radiological Environmental Monitoring Program given in 'the 4 00CH. The sampling location (s), excluding the control station location, having the lowest calculated-dose or dose 1 commitment (s), via the same exposure pathway, may be deleted i from this monitoring program after October 31 of the yea-in which this Land Use Census was conducted. Pursuant to Section 12.6.1, submit-in the next Annual Radiological Environmental Operating Report documentation for a change in the ODCH Including a revised figure (s) and table (s) for the 00CH reflecting the new location (s) with information supporting the change in sampling locations. j Surveillance Reauirements 12.5.2.B The Land Use Census shall be-conducted d9 ring the growing season at least once per 12 months using that information that;will provide the best results, such as by.a door-to-door survey, aerial survey, or by consulting local agriculture authorities. The results of the Land Use Census shall be included in the-Annual Radiological Environmental Operating Report pursuant to Section 12.6.1. Bases 12.5.2.C This specification is provided,to ensure that-changes in the use of areas at and beyono the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCH are made if required by the results of this census. The best information from the door-to-door survey, from aerial survey, or from consulting with locai agricultural authorities shall be used. 12-53

REVISION 0.A APRIL 1991 BRAIDH000 i ~12.5.2 Land Use Centui (Continued) p, _ 9 x s' Bases This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. An annual garden census will not be required since the licensee will assuma that there is a garden at the nearest residence in each sector for dose calculations. H 99% N) (' i 12-54

. _ _ _ _ _ _ ~ _ _ ~ ~ G: REVISION 0.A N !BRAIDHOOD 12.5.3 I n t e r l a bo r a t aty_Comatis oILfrogrAm n-_ 3,j-Ooerabilitv Reauirements 12.5.3.A-Analyses shall be performed on radioactive materials, supplied as + -part of-an Interlaboratory Comparison Program that has been approved by the-Commission, that correspond to samples required -by Table 12.5-1. Aeolicability: At all times. Rt10D: I 1. With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the i. Commission in the Annual Radiological-Environmental j. Operating Report pursuant to Section 12.6.1. Surveillance Reauirements -12.5.3.B The Interlaboratory Comparison Program shall be described in..the ODCH. A summary of the results obtained as part of-the above required Interlaboratory Comparison Program shall be included in the Annual Radiological-Environmental _0perating Report pursuant i.o Section 12-6.1. Rases p 12.5.3.C The requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that-independent checks on the precision.and accuracy of the measurements of radioactive material in environmental samples matrices are_ performed as part of the quality assurance-program for environmental monitoring in Lorder to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50. l l l O I L 12-55

REVISION 0.A BRAIDWOOD APRIL 1991 12.6 REPORTING _ REG)lREMEET_s V 12.6.1 60 Dual Radiolo91 Cal 10ylr20mtil_DaerMing Report

• Routine Annual Radiological Environmental Operating Reports covering the operation of the Unit during the previous calendar year shall be submitted prior to May 1 of each year.

The initial report shall be submitted prior to May 1 of the year following initial criticality. The Annual Radiological Environmental Operating Reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with preoperational studies, with operational controls as appropriate, and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the results of the Land Use Census reouired by Section 12.5.2. The Annual Radiological Environmental Operating Reports shall-include the results of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the tables and figures in the ODCH, as well as summarized and tabulated results of these analyses and measurements in the format of the table '.o the Radiological Assessment Branch Technical Position, Revision ,q f 1, November 1979. In the event that some individual results ars i V not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the misshg results. The missing data shall be submitted as soon as possible in a supplementary report. The reports shall also include the following: a summarv description of the Radiological Environmental Monitor'ing Program; at least two legible maps ** covering all sampling locations kored to a table giving distances and directions from the centerline of one reactor; the results of licensee participation in the Interlaboratory Comparison Program and the corrective actions being taken if the specified program is not being performed as required by Section 12.5.3; reasons for not conducting the i~ Radiological Environmental Honitoring Program as required by Section 12.5.1, and discussion of all deviations from the sampling scheaule of Table 12.5-1; discussion of environmental sample measurements that exceed the reporting levels of Table 12.5-2 but are not the result of plant effluents, pursuant to Section 12.5-1; and discussion of all analyses in which the LLO required by Table 12.5-3 was not achievable.

• A single submittal may be made for a multiple unit station.

q

• • 0ne map shall cover stations near the SITE BOUNDARY; a second b

shall include the more distant stations. 12-56

l REVISION 0.A AN' # BRAIDHOOD 12.6 BIEORIlhGJ E00l R EM E N T S (Con t i n u e d ) L' ) J 12.6.1 annua 13mtinlogic aLIny_i ronsenhL0pentin9J1ep.ottiContinu e d ) The Annual Radiological Environmental Operating Report shall also include an annual summary of hourly meteorological data collected over the previous year. This annual sumary may be either in the form of an hour-by-heur listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind spced, wind direction, and atmospheric stability.* 1his same report shall include an assessment of the radiation doses due.to the radioactive liquid and gaseous eff' m.. released from i the Unit or Station during the previous calendar year. This same report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PJBLIC due to their activities inside the SITE BOUNDARY (Braidwood Station ODCM Annex, Appendix F, Figure F-1) during the report period. All assumptions used in making these assessments, i.e., specific activity, exposure time and location, shall be inclu@d in these reports. The meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the ODCH. !,") The Annual Radiological Environmental Operating Report to be submitted prior to May 1 of each year shall also include an assessment of radiation doses to the most likely exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel ,i cycle sources, including doses from primary effluent pathways and uirect radiation, for the previous calendar year to show conformance with 40 CFR Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operation." Acceptable methods for calculating the dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev.1, October 1977. In lieu of submission with the Annual Radiological Environmental Operating Report, the licensee has the option of retaining this summary of required meteorological data on site in z. file that shall be provided to the NRC upon request. m) 12- 0

I _ REVISION o,A 3, v' APRIL 1991-BRAIDWOOD 12.6 REPORTING REQUIRDiERIS (Continued)

12. 6'. 2 '

Semi-Annpal RadiotttiyLEffluent Release Reoort** .1 Routine Semiannual Radioactive Effluent Release Reports covering the operation of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each year. The period of the first report shall begin with the date of initial criticality. i The Semiannuai Radioactive Effluent Release Reports chall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21. "Heasuring Evaluating, and Reporting Radioactivity in Solid Hastes and Releases of Radioactive Materials in Liquid and Gaseous Efficents from Light-Hater-Cooled Nuclear Power Plants," Revision 1. June 1974, with data [ summarized on a quarterly basis following the format of Appendix .B thereof. For solid wastes, the format for Table 3 in Appendix B shall be supplemented with. three additional categories: class of solid wastes (as defined by 10 CFR Part 61) type of container (e.g., LSA, Type A, Type B, large. Quantity), and SOLIDIFICATION agent or i absorbent (e.g cement, urea formaldehyde). IL I The. Semiannual Radioactive Effluent Release Reports shall include-I a list and description of unplanned releases from the site to I UNRESTRICTED AREAS of radioactive materials'in gaseous and 11guld 's effluents made during the reporting period. L The Semiannual Radioactive Effluent Release Reports shi.11' include j any changes made during the reporting period to the PCP, as well t-as'any major changes to Liquid, Gaseous or Solid Radwaste Treatment Systems, pursuant to Section 12.6.3.- The Semiannual Radioactive Effluent Release Reports shall'also L include the following: an explanation-as to why the i inoperability of liquid or gaseous eff)uent monitoring instrumentation was not corrected within the time specified in - Section 12.2.1 or 12.2.2, respectively; and description-of the events leading to liquid holdup tanks or gas storage tanks exceeding the limits of Technical Specification 3.11.1.4 or 3.11.2.6,.respectively.

• • A single submittal may be made for a multiple unit station.

The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.- O 12-58 ~

_. - ~ ~ REVISIOfLO.A-APRIL 1991 BRAIDH000 12.6-REPORTING REOUIREMENTS'(Continued) 12.6.3-Qffsite Dose Calculation (ODCH)_ 12.6.3.1 The 00CH shall be approved by the Commission prior to . implementation. 12.6.3.2 Licensee-initiated changes to the ODCH: a.- Shall be documented and records of reviews performed shall be Specification 6.10.2. This documentation shall contain: 1. Sufficient information to support the change together with the appropriate analyses or evaluations-justifying the changes (s); and 2. A determination that the char.ge will maintain the level of radioactive effluent control. required by 10 CFR 20.-160, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversel,y impact the accuracy or reliability of effluent, dose, or setpoint calculations. b. Shall become effective after review and acceptance by the Onsite Review and Investigative function-and the approval of the Plant Manager on the date specified by hc. the Onsite Review and' Investigative _ Function, c. Shall be submitted to the Commission in the form of a compl'ete legible copy of-the entire ODCH as part of or concurrent.with the Semiennual Radioactive Effluent. Release Report for the period of'the report in which any change to-the 00CM was made effective. Each change-shall be. indentified by markings in the margin of the affected pages, clearly indicating lthe area of the page that was changed,-and shall indicate the date (e.g., -month / year) the change was implemented. 7 O 12-59 t-2.

REVISION 0.A APRIL 1991 BRAIDWOOD e 12.6 REEORIM.RLOUIREMLrs (Continued) V 12.6.4 Major _Ch an g tL to_Lig gjia nLG attou s.la d n sie_lte atmenL S yltim1* Licensee-initiated major changss to the Radwaste Treatment Systems (liquid and gaseous): a. Shall be reported to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the Onsite Review and Investigative function. The discussion of each change shall contain: 1) A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; 2) Sufficient detailed information to totally support the reason for the change without benefit of additional and Supp1 mental information; 3) A detailed description of the equipment, components, and processes involved and the interfaces with othat plant systems. p Licensees may choose to submit the information called for in this section as part of the annual FSAR update. g e ) 12-60

REVISION 0.A APRIL 1991 BRAIDWOOO t i 12.6 REPORTIN(LR[.WIRM@li (Continued) 4 4) An evaluation of the change which shows the predicted releases of radioactive materials in 11guld and gaseous effluents and/or quantity of se'61d waste that differ from thote previously predicted in the License application and amendments thereto; 5) An evaluation of the change, which shows the expected maximu exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the License appilcation and amendments thereto; 6) A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid-waste, to the actual releases for the period prior to when the changes are to be raade; 7). An estimate of the exposure to plant operating personnel as a retult of the change; and 8) Documentation of the fact that the change was reviewed and found acceptable by the Onsite Review and c Investigative. Function. b. Shall become effective upon review and acceptance by the i Onsite Review and Investigative function. f& O 12-61 ~ ~ _ _. _.... _ -. _. _. _ _ _ _.... _... _ _. _. _ _., _.. _ _ _ _ _}}