ML20064E814

Proposed Tech Specs Incorporating Radiological ETS Into App a

ML20064E814
Person / Time
Site:	Davis Besse
Issue date:	12/23/1982
From:	TOLEDO EDISON CO.
To:
Shared Package
ML20064E793	List: ML20064E789 ML20064E804 ML20064E814 ML20064E835
References
NUDOCS 8301060144
Download: ML20064E814 (63)

Text

_

Docket No. 50-346 License No. NPF-3 Serial No. 887 December 23, 1982 Attachment I.

Changes to Davis-Besse Nuclear Power Station Unit 1. Appendix A Technical Specifications incorporating the Radiological Effluent.

Technical Specifications and deleting Appendix B.

A.

Time required to Implement.

This change is to be effective 120 days after NRC approval.

B.

Reason for Change _(Facility Change. Request 79-114.Rev. A).

Revision to Toledo Edison's submittal of March 16, 1979.

C.

Safety Evaluation i

(See attached) 4

@D01060144 821223 DR ADOCK 05000346 p

PDR

SAFETY EVALUATION Overview Revisions to the Davis-Besse Appendix A and Appendix B Technical Specifications are proposed which will supplement the regulatory requirement of 10 CFR 50, Appendix I on ALARA for radioactive effluents and other NRC regulations and criteria on radioactive material monitoring instrumentation, radioactive material control, and radiological environmental monitoring.

In keeping with NRC guidelines, all radiological requirements are being deleted from Appendix B and placed in Appendix A.

This proposed amendment is a revision to a previously submitted amendment to the NRC dated March 16, 1979.

Some of the changes reflect the NRC's relaxation of certain of the previous standard requirements; others reflect the outcome of a review meeting with the NRC on September 2, 1982 at the Davis-Besse Station. Overall, the revised submittal provides greater operational flexibility than did the original submittal.

The major areas that are addressed in the revised submittal are as follows:

o Liquid and gaseous effluent monitoring instrumentation--operation and periodic operability checks; Liquid and gaseous radioactive material releases--maximum o

release rates, quarterly dose limits, and yearly dose lielts o

Sampling and analysis requirements on batch and continuous radioactive material releases; o

Operation requirements on the liquid radwaste treatment system; o

Curie inventory limit on outside temporary liquid storage tanks; o

Maximum allowable oxygen concentration in the waste gas system; o

Requirements to assure all solid waste meets applicable burial site requirements; o

Radiological environmental monitoring program--minor revisions to reflect current program and current NRC guidelines.

Changes have also been made to Section 6 of Appendix A to reflect the applicable administrative controls needed for the Section 3/4 revisions.

A notable addition to the amendment is the inclusion of a requirement for an Off-site Dose Calculation Manual (ODCM) and a Process Control Program (PCP). The ODCM and PCP are not licensed documents but are referenced in the Technical Specifications as presenting acceptable methods for evaluating compliance with applicable Technical Specification requirements.

The ODCM provides calculational methods for determining radioactive effluent instrumentation alarm setpoints, and for evaluating releases of radioactive effluents and corresponding doses. The ODCM also includes the sampling locations for the environmental monitoring program. The PCP presents the methods used to verify that waste (dewatered resins) as processed for disposal meets appropriate shipping

and burial ground regulations. Changes may be made to these documents without NRC approval; review by the SRB is required.

Safety Evaluation An evaluation of the revised amendment has been performed to assure that the revisions as proposed do not involve an unreviewed safety question. The Safety Function of.the Radiological Effluent-Technical Specifications (RETS); is to monitor Effluent from Davis-Besse.

1) 1 Probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previsouly evaluated'in

~

the safety analysis report.

No plant equipment modifications are required by the' proposed amendemnt. Certain procedural requirements will need to be developed but these address routine radioactive material effluents and controls; no accident procedures are involved.

ii) Probability for an accident of malfunction of 'a different. type than any evaluated previously in the SAR may be created.

For reasons as stated in response to item (i) above, the proposed amendment does not directly or indirectly increase a probability for' an accident or malfunction. The amendment will implement the NRC regul-ations for routine releases and controls of radioactive material. The amendment does not address any engineered safety features of-the plant design.

iii) Margin of safety as defin'ed in the basis.for.any. technical specification is reduced.

[

The proposed amendment does not reduce the margin of safety. The proposed amendment addresses routine releases and control of radioactive material, no plant modifications are involved. Several operating procedure changes may be needed..but these changes will be only for routine operations and will have no impact on accident probability or consequences.

, Based on the above, the changes do not effect the safety function therefore, this is not an unreviewed safety questions.

DEFINITIONS The following DEFINITIONS vitt be added to this section SOURCE CHECK 1.29 A SOURCE CHECK shall be the observation of channel upscale response when the channel sensor is exposed to a radioactive source.

PROCESS CONTROL PROGRAM 1.30.

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

SOLIDIFICATION 1.31 SOLIDIFICATION shall be the conversion of wet radioactive wastes into a form that meets destination waste disposal site criteria by removal of freestanding water through chemical processes.

OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.32 The 0FFSITE DOSE CALCULATION MANUAL (0DCM) shall be a manual containing the methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints. Requirements of the ODCM are provided in Specification 6.14.

GASE0US RADWASTE TREATMENT SYSTEM 1.33 The GASEOUS RADWASTE TREATMENT SYSTEM is a system that is designed and installed to reduce radioactive gaseous effluents by collecting l

primary coolant system offgases and providing for decay fcr tha purpose of reducing the total radioactivity prior to release to the environment.

i VENTILATION EXHAUST TREATMENT SYSTEM 1.34 A VENTILATION EXHAUST TREATMENT SYSTEM is a system that is designed and installed to reduce radioactive material in particulate form in effluents by passing ventilation or vent exhuast gases through HEPA l

filters for the purpose of removing particulates from the gaseous exhaust stream prior to the release to the environment. Enaineered Safety Feature (ESF) atmospheric cleanup systems are not considered to be j

VENTILATION EXHUAST TREATMENT SYSTEM components.

DAVIS-BESSE, UNIT 1 l

DEFINITIONS PURGE-PURGING 1.35 PURGE or PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, con-centration or other operating condition, in such a manner that replacement air or gas is required to purify the confinement.

VENTING 1.36 VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process.

MEMBER (S) 0F THE PUBLIC 1.37 MEMBER (S) 0F THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational or other purposes not associated with the plant.

SITE BOUNDARY 1.38 The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise controlled by the licensee.

UNRESTRICTED AREA 1.39 An UNRESTRICTED AREA shall be any area at or beyond the SITE B0UNDARY access to which is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the SITE BOUNDARY used for residential quarters or for industrial, connercial, institutional, and/or recreational purposes. The definition of UNRESTRICTED AREA used in implementing the Radiological Effluent Technical Specifications has been expanded over th'at in 10 CFR 20.3 (a)(17). The UN-RESTRICTED AREA boundary may coincide with the exclusion (fenced) area bound-ary, as defined in 10 CFR 100.3(a), but the UNRESTRICTED AREA does not include areas over water bodies. The concept of UNRESTRICTED AREAS, established at or beyond the SITE B0UNDARY, is utilized in the LIMITING CONDITIONS FOR OPERATION to keep levels of radioactive materials in liquid and gaseous effluents as low as is reasonably achievable, pursuant to 10 CFR 50.36a.

DAVIS-BESSE, UNIT 1

TABLE 1.2 I

FREQUENCY NOTATION NOTATION FREQUENCY S

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

l D

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

l W

At least once per 7 days.

M At least once per 31 days.

Q At least once per 92 days,

^

i SA At least once per 6 months.

R At least once per 18 months.

S/U Prior to each~ reactor startup.

P

. Prior to each release.

N/A Not applicable l

J 1

A 0 AVIS-BESSE, UNIT-1

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INSTRUMENTATION RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-15 shall be OPERABLE with their alann/ trip setpoints set to ensure that the limits of Specification 3.11.1.1 are not exceeded. The alarm / trip setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the 0FFSITE DOSE CALCULA-TION MANUAL (0DCM).

APPLICABILITY: At all times.

ACTION:

With a radioactive liquid effluent monitoring instrumentation channel a.

alarm / trip setpoint less conservative than required by the above specification, without delay suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

b.

With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-15.

Exert best efforts tn return the instruments to OPERABLE status within 30 days and, it unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

c.

The provisions of Specifications 3.0.3, 3.0.4, and 6.9.1.9 are not applicabl e.

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

DAVIS-BESSE, UNIT 1

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TABLE 3.3-15 o

Eg RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION MINIMUM M

CHANNELS INSTRUMENT OPERABLE APPLICABILITY ACTION l

'Eq

1. Gross Radioactivity Monitors Providing Automatic Temination of Release

a. Liquid Radwaste Effluent Line 1

(1) 18

2. Flow Rate Measurement Devices

a. Liquid Radwaste Effluent Line 1

(1) 19

b. Dilution Flow to Collection Box 1

(1) 19 1

i l

TABLE 3.3-15 (Continued)

TABLE NOTATION (1) During radioactive releases via this pathway ACTION 18 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may be resumed, provided that prior to initiating a release:

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

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

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

ACTION 19 With the number of channels OPERABLE less than required by the Minimum Chanrels OPERABLE requirement, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during actual releases. Pump curves may be used to estimate flow.

DAVIS-BESSE, UNIT 1.

. _. =. - _.

TABLE 4.3-15 l

E RADI0 ACTIVE LIQUID EFFLUENT MDNITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS w

!n h

CHANNEL CHANNEL S0dRCE CHANNEL.

FUNCTIONAL INSTRUMENT CHECK CHECK CALIBRATION TEST c

i'i

1. Gross Beta or Ganna Radioactivity

+

Monitors Providing Alarm and Automatic Isolation

a. Liquid Radwaste Effluents Line D(I)

P R(3) q(2)

2. Flow Rate Monitors I4)

a. Liquid Radwaste Effluent Line D

N.A.

R Q

I4)

b. Dilution Flow to Collection Box D

N.A.

R Q

b 6

v

-m--

+

r

TABLE 4.3-15 (Continued)

TABLE NOTATION (1) During releases via this pathway.

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

(3) The initial CHANNEL CALIBRATION for radioactivity measurment instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards should permit calibrating the system over its intended range of energy and rate capabilities.

For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration should be used, at intervals of at least once per eighteen months. For high range monitoring instrumentation, where calibration with a radioactive. source is impractical, an electronic calibration may be substituted for the radiation source calibration.

(4) CHANNEL CHECK shall consist of verifying indication of flow during periods of release. CHANNEL CHECK shall be made at least once daily on any day on which continuous, periodic, or batch releases are made.

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DAVIS-BESSE, UNIT 1

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. INSTRUMENTATION RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.10 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-16 shall be OPERABLE with their alarm / trip setpoints set to ensure that the limits of Specification 3.11.2.1 are not exceeded. The alarm / trip setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 3.3-16 ACTION:

a. With a radioactive gaseous effluent monitoring instrumentation channel alarm / trip setpoint less conservative than required by the above Specification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable, or change the setpoint so it is acceptably conservative,

b. With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-16.

Exert best efforts to return the instruments to OPERABLE status within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.

c. The provisions of Specifications 3.0.3, 3.0.4, and 6.9.1.9.b are not applicable.

l l

SURVEILLANCE REQUIREMENTS 4.3.3.10 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-16.

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i DAVIS-BESSE UNIT 1 i

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TABLE 3.3-16 RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION MINIMUM g

CHANNELS f,

INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTION m

1. Waste Gas Decay System (provides automatic isolation)

a. Noble Gas Activity Monitor 1

(1)

Radioactivity Measurement 25

b. Effluent System Flow Rate 1

(1)

System Flow Rate Measurement 26 Measuring Device

2. Waste Gas System (provides alann function)

a. Oxygen Monitor 1

(2)

% 0xygen 28

3. Containment Purge Monitoring System (provides automatic isolation)

a. Noble Gas Activity Monitor 1

(1)

Radioactivity Measurement 27

TABLE 3.3-16 (Continued) 2-RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION T$

MINIMUM M

CHANNELS INSTRUMENT OPERABLE APPLICABILITY PARAMETER ACTION C*

4. Station Vent Stack

]

(provides alarm function) a.

Noble Gas Activity Monitor 1

(1)

Radioactivity Measurement 27 b.

Iodine Sampler Cartridge 1

(1)

Verify presence of 29 cartridge c.

Particulate Sampler Filter 1

(1)

Verify presence of 29 filter d.

Effluent System Flow 1

(1)

System Flow Rate 26 Rate Measuring Device Measurement e.

Sampler Flow Rate Measuring 1

(1)

Sampler Flow Rate 26 Device Measurement

TABLE 3.3-16 (Continued)

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

(2) During additions to the waste gas surge tank ACTION 25 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank may be released to the environment provided that prior to initiating the release:

1.

At least two independent samples are analyzed in accorance with Specification 4.11.2.1.3 for analyses perfonned with each batch; 2.

At least two independent verifications of the release rate calculations are perfonned; 3.

At least two independent verifications of the dis-charge valving are perfonned; ACTION 26 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this patnway may continue provided the flow rate is estimated at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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

ACTION 28 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, additions to the waste gas surge tank may continue provided another method for ascert-aining oxygen concentrations, such as grab sample analysis, is implemented to provide measurements at least once per four (4) hours during degassing and daily during other operations.

ACTION 29 With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided samples are continuously collected with auxiliary sampling equipment.

DAVIS-BESSE, UNIT 1

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TABLE 4.3-16 RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS g

S us CHANNEL k

CHANNEL SOURCE CHANNEL FUNCTIONAL g

.m INSTRUMENT CHECK CHECK CALIBRATION TEST C$

1. Waste Gas Decay System III R(5) g(3)

a. Noble Gas Activity Monitor P

P II)

b. Effluent System Flow Rate P

N/A R

Q

2. Waste Gas System D(2)

N/A Q(6)

N/A

a. Oxygen Monitor

)

3. Containment Purge Vent System

/

~

1 (5' Q(3)

a. Noble G, n tivity Monitor, ' --

D(1)

./

P R

J.

.,J.

k' l,'J.

,/.

) -

~

4. Station Van 5tacx U.

D(I}

M'.

R(5)

Q(4)

a. Noble Gas Activity Monitor

~ ~ - -

W(I)

"/A'

/

N/A

,N/Ap #-

f

~< ;,

b. Iodine Sampler p.,,-

~

W(1)

N/A N/A

.. N'/A

c. Particulate Sampler

_(

~

/

d. System Effluent Flow Rate D(j)

,N/A R

_ N/A

^

i, Measurement Device

~

e. Sampler Flow Rate Ij}

N/A7 R

N/,A Measurement Device W

r

't _j.

p

1. /

^

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~-

i E

j

' {, y.

^

m+

L.

TABLE 4.3-16 (Continued)

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

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

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

(4) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alarm annunciation occurs if the instrument indicates measured levels above the alarm / trip setpoint.

(5) The initial CHANNEL CALIBRATION for radioactivity measurement instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards should permit calibrating the system over its intended range of energy and rate capabilities.

For 2-subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration should be used, at intervals of at least once per eighteen months.

For high range monitoring instrumen-tation, where calibration with a radioactive source is imprac-tical, an electronic calibration may be substituted for th?

radiation source calibration.

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

1.

One volume percent oxygen, balance nitrogen; and 2.

Four volume percent oxygen, balance nitrogen.

1 r

s DAVIS-BESSE, UNIT 1

3/4.11 RADIOACTIVE EFFLUENTS 3/4.11.1 LIQUID EFFLUENTS CONCENTRATION LIMITING CONDITION FOR OPERATION 3.11.1.1 The concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS (see Figure 3.11-1) shall be limited to the concentrations specified in 10 CFR Part 20.106 for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2 x 10 "microcuries/ml.

APPLICABILITY: At all times.

ACTION:

a.

With the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS exceeding the above limits, without delay restore the concentration to within the above limits.

b.

The provisions of Specifications 3.0.3, 3.0.4, and 6.9.1.9 are not applicable.

SURVEILLANCE REQUIREMENTS

~

4.11.1.1.1 Radioactive liquid wastes shall be sampled and analyzed according 'to the sampling and analysis program of Table 4.11-1.

4.11.1.1.2 The results of the radioactivity analyses shall be used in accordance with the methodology and parameters in the 00CM to assure that the concentrations at the point of release are maintained within the limits of Specification 3.11.1.1.

DAVIS-BESSE, UNIT 1

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_ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ______ _ _____ J

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. TABLE 4.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Liquid Release Type famp n9 l

Type of Activity yq ny ay s o Det on

. Analysis (LLD) (pCi/ml)a Frequency P

P A. Batch Waste Each Batch Each Batch Principal Gamma 5 x 10-7 b d

Release Tanks Emittersf I-131f 1 x 10-6 P

One Batch /M M

Dissolved and 1 x 10-5 Entrained Gases.

P H-3 1 x 10-5 Each Batch M

c Composite Gross Alpha 1 x.10-7 i

p Each Batch 0

c Sr-89, Sr-90 5 x 10-8 Comp 3 site Fe-55 1 x 10-6 B. Turb ne building Gr b Sample 8'

ur it r I-131f 1 x 10-6 C. Condensate Ea h Batch Eac Batch Principal Gamma 5 x 10-7 b Demineralizer Emittersf Backwash I-131f 1 x 10-6 DAVIS-BESSE, UNIT 1 sv e

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l TABLE 4.11-1 (Continued)

TABLE NOTATION a.

The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

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

4.66 s LLD =

b E

V 2.22 Y

where LLD is the lower limit of detection as defined above (as pCi per unit mass or volume);

s is the standard deviation of the background counting rate or b

of the counting rate of a blank sample as appropriate (as counts perminute);

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

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

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

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

b.

The principal gamma emitters for which the LLD specification will apply are exclusively the following radionuclides: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141, and Ce-144. Other peaks which are measured and identified shall also be reported.

Nuclides which are below the LLD for the analysis should not be reported as being present at the LLD level. When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the semi-annual Radioactive Effluent Release Report.

DAVIS-BESSE, UNIT 1

. TABLE 4.11-1 (Continued)

TABLE NOTATION A composite sample is one in which the method of sampling employed c.

results in a specimen which is representative of the liquids released.

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

e. These sampling and analysis requirements apply only when activity concentrations in the secondary system exceed 10-5 microcuries per milliliter and releases are being made from this system.

f. If an isotopic analysis is unavailable, gross beta or gamma measurement of batch release may be substituted provided the exceed 1 x 10 peleased to the unrestricted area does notpCi/ml and a composite sa concentration principal gamma emitters when instrumentation'is available.

l DAVIS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION 3.11.1.2 The dose or dose commitment to a MEMBER OF THE PUBLIC from radio-active materials in liquid effluents released, from each reactor unit, to UNRESTRICTED AREAS (see Figure 3.ll-1)shall be limited:

During any calendar quarter to less than or equal to 1.5 mrems a.

to the total body and to less than or equal to 5 mrems to any organ, and b.

During any calendar year to less than or equal to 3 mrems to the total body and to less than or equal to 10 mrems to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated dose from the release of radioactive materials in liquid effluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.2 Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

DAVIS-BESSE, UNIT 1 3

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RADI0 ACTIVE EFFLUENTS LIQUID RADWASTE TREATMENT SYSTEM LIMITING CONDITION FOR OPERATION 3.11.1.3 The liquid radwaste treatment system shall be used to reduce the radioactive materials in liquid wastes prior to their discharge when the projected doses due to the liquid effluent, from each reactor unit, to UNRESTRICTED AREAS (see Figure 3.11-1) would exceed 0.25 mrem to the~ total body or 0.833 mrem to any organ in a 31 day period.

APPLICABILITY: At all times ACTION:

a.

With radioactive liquid waste being discharged without treatment and in excess of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days pursuant to Specification 6.9.2 a Special Report that includes the following information:

1.

Explanation of why liquid radwaste was being discharged without treatment, identification of any inoperable equipment or subsystems, and the reason for the inoperability.

2.

Action (s) taken to restore the inoperable equipment to OPERABLE status, and 3.

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

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1.3 In any month in which radioactive liquid effluent is being discharged without treatment, doses due to liquid releases from each reactor unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM.

DAVIS-BESSE, UNIT 1 i

o n

e -,

RADI0 ACTIVE EFFLUENTS LIQUID HOLDUP TANKS

• LIMITING CONDITION FOR OPERATION 3.11.1.4 The quantity of radioactive material contained in each of the following unprotected outdoor tanks shall be limited to less than or equal to 10 curies, excluding tritium and dissolved or entrained noble gases.

a.

Outside temporary tank APPLICABILITY: At all times.

ACTION:

a. With the quantity of radioactive material in any of the above listed tanks exceeding the above limit, immediately suspend all additions of radioactive material to the tank within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank contents to within the limit, and describe the event leading to this condition in the next Semiannual Radio-active Effluent Release Report.

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

SURVEILLANCE REQUIREMENTS 4.11.1.4 The quantity of radioactive material contained in each of the above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

• Tanks included in this specification are those outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents or tnat do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system.

DAVIS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASE0US EFFLUENTS DOSE LIMITING CONDITION FOR OPERATION 3.11.2.1 The dose rate due to radioactive materials released in gaseous effluents from the site to areas at and beyond the SITE B0UNDARY (see Figure 3.11-2) shall be limited to the following:

a.

For noble gases: Less than or equal to 500 mrems/ year to the total body and less than or equal to 3000 mrems/ year to the skin, and b,

For iodine-131, for tritium, and for all radionuclides in particulate fann with half lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the dose exceeding the above limits, without delay restore the release rate to within the above limit (s).

b.

The provisions of Specifications 3.0.3, 3.0.4 and 6.9.1.9 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.1.1 The dose rate due to noble gases is gaseous effluents shall be detennined to be within the above limits in accordance with the methodology and parameters in the ODCM.

4.11.2.1.2 The dose rate due to iodine-131, tritium, cnd all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents shall be determined to be within the above limits in accordance with the methodology and parameters in the ODCM by obtaining representative samples and perfonning analyses in accordance with the sampling and analysis program specified in Table 4.11-2.

DAVIS-BESSE, UNIT 1

TABLE 4.11-2 g

5 RADI0 ACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM Y'

en Minimum Lower Limit of c;;

Gaseous Release Type Sampling Analysis Type of Detectiog(LLD)

Frequency Frequency Activity Analysis (pCi/ml) c Principal Gama Emitters 1 x 10-Haste Gas Decay Ea h Ea h Release Release 1 x 10 6 H-3 Grab Sample P

P c

Containment Purge Each Purge Each Purge Principal Gama Emitters 1 x 10 "

Grab Sample H-3 1 x 10-8 c

M M

Principal Gama Emitters 1 x 10-6 Station Vent Stack Grab Sample H-3 1 x 10-5 D

Continuous W

Charcoal I-1 31 1 x 10 12 Sample W

b c

Continuous Particulate Principal Gama Emitters 1 x 10-12 Sample M

Continuous Composite Gross Alpha 1 x 10-22 b

Particulate Sample Q

Continuous Composite Sr-89, Sr-90 1 x 10-2 2 D

Particulate Sample b

Continuous Noble Gas Noble Gases Monitor Gross Beta or Gama 1 x 10-5

TABLE 4.11-2 (Continued)

TABLE NOTATION a.

The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

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

4.66 sb E

V 2.22 Y

where LLD is the lower limit of detection as defined above (as pCi per unit mass or volume);

s is the standard deviation of the background counting rate or b of the counting rate of a blank sample as appropriate (as counts perminute);

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

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

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

It should be recognized that the LLD is defined as an a_ priori (before the fact) limit representing the capability of a measurement system and not as a posteriori (after the fact) limit for a particular measurement.

b.

The ratio of the sample flow rate to the sampled stream flow rate shall be known for the time period covered by each dose or dose rate calculation made in accordance with Specifications 3.11.2.1 and 3.11.2.3.

l DAVIS-BESSE, UNIT 1

TABLE 4.11-2 (Continued)

TABLE NOTATION l

c.

The principal gamma emitters for which the LLD specification will apply are exclusively the following radionuclides: Kr-87, Kr-88, Xe-133, Xe-133m, Xe-135, and Xe-138 for gaseous emissions and Mn-54, Fe-59, Co-58, Co-60, Zn-65, Mo-99, Cs-134, Cs-137, Ce-141 and Ce-144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measured and identified, L

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

Nuclides which are below the LLD for the analyses should be reported as "less than" the nuclide's LLD and should not be reported as being present at the LLD level for that nuclide. The "less than" values shall not be used in the required dose calculations. When unusual circumstances result in LLD's higher than required, the reasons shall be documented in the Semiannual Radioactive Effluent Release Report.

1 DAVIS-BESSE, UNIT 1

~

t 1

RADI0 ACTIVE EFFLUENTS DOSE - NOBLE GASES LIMITING CONDITION FOR OPERATION 3.11.2.2 The air dose due to noble gases released in gaseous effluents to areas at and beyond the SITE BOUNDARY (see Figure 3.11-2) shall be limited to the following:

a.

During any calendar quarter: Less than or equal to 5 mrads for gamma radiation and less than or equal to 10 mrads for beta radiation and, b.

During any calendar year: Less than or equal to 19 mrads for gamma radiation and less than or equal to 20 mrads for beta radiation.

APPLICABILITY: At all times.

i ACTION:

a.

With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that subsequent releases will be in compliance with the above limits.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.2 Cumulative dose contributions for the current calendar quarter and current calendar year for noble gases shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

DAVIS-BESSE,-UNIT 1

4 RADI0 ACTIVE EFFLUENTS DOSE - 10 DINE-131, TRITIUM, AND RADIONUCLIDES IN PARTICULATE FORM LIMITING CONDITION FOR OPERATION 3.11.2.3 The dose to a MEMBER OF THE PUBLIC from iodine-131, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released, from each reactor unit, to areas at and beyond the SITE B0UNDARY (see Figure 3.11-2) shall be limited to the following:

a.

During any calendar quarter: Less than or equal to 7.5 mrems to any organ and, b.

During any calendar year: Less than or equal to 15 mrems to any organ.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated dose from the release of iodine-131, tritium, and radionuclides in particulate form with half lives greater than 8 days, in gaseous effluents exceeding any of the above limits, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit and defines the corrective actions that have been taken to reduce the releases and the proposed corrective actions to be taken to assure that sub-sequent releases will be in compliance with the above limits.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.3 Cumulative dose contributions for the current calendar quarter and current calendar year for iodine-131, tritium, and radionuclides in i

particulate form with half lives greater than 8 days shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days.

DAVIS-BESSE, UNIT 1

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18511415! Rit[R stai r r-= r9 DAVIS-BESSE NUCLEAR POWER STATION UNRESTRICTED AREA B0UNDARY FOR GASEOUS EFFLUENTS Fig. 3.11-2

' '-RADICACTIVE EFFLUENTS EXPLOSIVE GAS MIXTURE (Hydrogen rich systems not designed to withstar.d a hydrogen explosion)

LIMITING CONDITION FOR OPERATION 3.11.2.4 The concentration of oxygen in the waste gas system shall be limited to less than or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume.

APPLICABILITY: At all Times.

ACTION:

a.

With the concentration of oxygen in the waste gas system greater than 2% by volume but less than or equal to 4%

by volume, reduce the. oxygen concentration to the above limits, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

b.

With the concentration of oxygen in the waste gas system greater than 4% by volume and the hydrogen concentration greater.than 2%

by volume, immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or equal to 2% by volume without delay.

~

c.

The provisions of Specifications 3.0.3, 3.0.4 and 6.9.1.9 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.4 The concentrations of oxygen in '.he waste gas system shall be determined to be within the above limits by monitoring the waste gases in the waste gas system as required by Table 3.3-16 of Soecification 3.3.3.10.

DAVIS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS 3/4.11.3 SOLID RADIOACTIVE WASTE LIMITING CONDITION FOR OPERATION 3.11.3 The solid radwaste system shall be used in accordance with a PROCESS CONTROL PROGRAM to process wet radioactive wastes to meet shipping and destination burial ground requirements.

APPLICABILITY: At all times.

ACTION:

a.

With the provisions of the PROCESS CONTROL PROGRAM not satisfied, suspend shipments of defectively processed or defectively packaged solid radioactive wastes from the site.

b.

The provisions of Specifications 3.0.3, 3.0.4, and 6.9.1.9 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.3 THE PROCESS CONTROL PROGRAM shall be used to verify the SOLIDIFICATION or DEWATERING of at least one representative test specimen from at least every tenth batch of each type of wet radioactive waste (e.g., filter sludges, spent resins,evaporatorbottoms,boricacidsolutions,andsodiumsulfatesolutions).

a.

If any test specimen fails to verify SOLIDIFICATION, the SOLIDIFI-CATION of the batch under test shall be suspended until such time as additional test specimens can be obtained, alternative SOLIDIFI-CATION parameters can be determined in accordance with the PROCESS CONTROL PROGRAM, and a subsequent test verifies SOLIDIFICATION.

SOLIDIFICATION of the batch may then be resumed using the alterna-tive SOLIDIFICATION parameters determined by the PROCESS CONTROL PROGRAM.

b.

If the initial test specimen from a batch of waste fails to verify SOLIDIFICATION, the PROCESS CONTROL PROGRAM shall provide for the collection and testing of representative test specimens from each consecutive batch of the same type of wet waste until at least 3 consecutive initial test specimens demonstrate SOLIDIFICATION.

The PROCESS CONTROL PROGRAM shall be modified as required, as pro-vided in Specification 6.14, to assure SOLIDIFICATION of subsequent batches of waste.

DAVIS-BESSE, UNIT 1

~

RADI0 ACTIVE EFFLUENTS 3/4.11.3 SOLID RADI0 ACTIVE WASTE c.

If any test specimen fails to verify DEWATERING, the DEWATERING of that batch under test shall be suspended. Alternate DEWATERING parameters can be determined using the PROCESS CONTROL PROGRAM.

If a subsequent test verifies DEWATERING, DEWATERING of the batch may be resumed using the alternative parameters determined by the PROCESS CONTROL PROGRAM.

d.

If the test specimen fails to verify DEWATERING, the PROCESS CONTROL PROGRAM shall provide for the testing of a representative specimen of the same type wet waste from consecutive batches until at least 3 test specimens demonstrate DEWATERING. The PROCESS CONTROL PRO-GRAM shall be modified as provided in Specification 6.14 to assure DEWATERING of subsequent batches of waste.

4 DAVIS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS 3/4.11.4 TOTAL DOSE LIMITING CONDITION FOR OPERATION 3.11.4 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 mrems to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems.

APPLICABILITY: At all times.

ACTION:

a.

With the calculated doses from the release of radioactive materials in liquid or gaseous effluents exceeding twice the limits of Specification 3.ll.l.2.a, 3.ll.l.2.b, 3.ll.2.2.a, 3.ll.2.2.b, 3.11.2.3.a, or 3.11.2.3.b, evaluations should be made including direct radiation contributions from the reactor units and from out-side storage tanks to determine whether the above limits of Specification 3.11.4 have been exceeded.

If such is the case in lieu of a Licensee Event Report, prepare and submit to the commission within 30 days, pursuant to 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 confonnance with the aoove-limits. This Special Report, as defined in 10 CFR Part 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 concentrations of radioactive material involved, and the cause of the exposure levels l

or concentrations.

If the estimated dose (s) exceeds the above limits, i

and if the release condition resulting in violation of 40 CFR Part 190 has not already been corrected, the Special Report shall include a l

request for a variance in accordance with the provisions of 40 CFR l

Part 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.4.1 Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with Specifications 4.11.1.2, 4.11.2.2, and 4.11.2.3, and in accordance with the methodology and parameters in the ODCM.

l i

DAVIS-BESSE, UNIT 1

g 3f4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM LIMITING CONDITIONS FOR OPERATIONS 3.12.1 The radiological environmental monitoring program shall be conducted as specified in Table 3.12-1.

APPLICABILITY: At all times.

i ACTION:

a.' With the radiological environmental monitoring program not being conducted as specified in Table 3.12-1, in lieu of a Licensee Event Report, prepare and submit to the Commission, in the Annual Radiological Environmental Operating Report required by Specifica-tion 6.9.1.11, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

2 b.

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 3.12-2 when averaged over

)-

any calendar quarter, in lieu of a Licensee Event Report, prepare I

and submit to the Comission within 30 days, pursuant to Specification i

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 MEMBER ~

OF THE PUBLIC is less_ than the calendar year limits of Specification 3.11.1.2, 3.11.2.2, and 3.11.2.3.

When more than one of the radio-i nuclides in Table 3.12-2 are detected in the. sampling medium, this' report shall be submitted if:

concentration (1) concentration (2?

reporting level-(1)

• reporting level (2? +.. 21.0 When radionuclides other than those in Table 3.12-2 are detected and are the result of plant effluents, this report shall be submitted if -

the potential annual dose to A MEMBER OF THE PUBLIC is equal to or greater than the calendar year limits of Specifications 3.11.1.2, 3.11.2.2 and 3.11.2.3.

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

c.

With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 3.12-1, identify locations for obtaining replacement samples and if practical add them to the radiological environmental monitoring program within 30 days. The locctions from which samples were unavailable may then be deleted from the monitoring program.

In lieu of a Licensee Event Report and pursuant to Specification 6.9.1.11, identify the cause of the unavailability of samples and identify the new location (s) for obtaining replacement samples in the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

I DAVIS-BESSE, UNIT 1

RADIOLOGICAL ENVIRONMENTAL MONITORING d.

With specimens unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons, every effort will be made to complete corrective action prior to the end of the next sampling period.

All deviations from the sampl'ing schedule will be documented in the Annual Radiological Environmental Operating Report pursuant to Specification 6.1.1.10.

e.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.1.1 The radiolcgical environmental monitoring samples shall be collected pursuant to Table 3.12-1 from the specific locations given in the table and figure (s) in the ODCM and shall be-analyzed pursuant to the requirements of Table 3.12-1, and the detection capabilities required by Table 4.12-1.

4.12.1.2 Cumulative potential dose contributions for the current calendar year from radionuclides detected in environmental samples shall be determined in accordance with the methodology and parameters in the ODCM.

i I

r l

i DAVIS-BESSE, UNIT 1

3 5

TABLE 3.12-1 T

g' RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM U;

Number of Representative Exposure Pathway Samples and Sample Type and Frequency c:

55 and/or Sample Locationsa Collection Frequency of Analysis b

1. DIRECT RADIATION

27. routine monitoring stations either Quarterly Gamma dose quarterly with two or more dosimeters or with one instrument for measuring and recording dose rate continuously, placed as follows:

an inner ring of stations, generally one in each meteorological sector in the general area of the SITE B0UNDARY; an outer ring of stations, one in each meteorological sector in the 6-to 8-km range from the site, except the sectors over Lake Erie; the balance of the stations to be placed 'in special interest areas such as population centers, nearby residences, schools, and in 1 or 2 areas to serve as control stations.

E

5 TABLE 3.12-1 (Continued) y RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM l

E Exposure Pathway Number of Representative Type and Frequency M

and/or Sample Samples and Sample Locations, Collection Frequency of Analysis 2.

AIRBORNE Radiolodine and Samples from 5 locations Continuous sampler.

Radioiodine Cannister:

Particulates operation with sample I-131 analysis weekly.

3 samples from close to the 3 SITE collection weekly, or BOUNDARY locations, in different more frequently if sectors, generally from areas of required by dust Particulate Sampler:.

higher calculated annual average loading Gross beta radioactivity groundlevel D/Q.

analysis following filter change;c Gamma isotopic d

1 sample from the vicinity of a analysis of composite nearby community, generally in the (by location) quarterly.

area of higher calculated annual average groundlevel D/Q.

t 1 sample from a control location, 15-30 km distant.

3.

WATERBORNE a.

Surface 2 samples Weekly composite Composite for tritfum sample and gamma isotopic analysis quarterly.

d b.

Ground Sample from one source Quarterly Gamma isotopic and only if likely to be tritium analysis affectede.

quarterly.

1

TABLE 3.12-1 (Continued)

[

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM m

Exposure Pathway Number of Representative Type and Frequency and/or Sample Samples and Sample Locations, Collection Frequency of Analysis

• EQ c.

Drinking 1 sample from the nearest Weekly composite Gross beta on monthly source.

sample.

composite. Tritium and gamma isotopicd 1 sample from a control location analysis on quarterly composite.

d d.

Sediment from i sample from area with existing Semiannually Gamma. isotopic analysis shoreline or potential recreational value seimannually.

4.

INGESTION d

a.

Milk If available, samples from milking Semimonthly when Gamma isotopic and animals up to 2 locations within animals are on I-131 analysis semi-8 km distance having the highest pasture, monthly monthly when animals dose potential.

at other times are on pasture; monthly at other times.

I sample from milking animals at a control location 15-30 km distant and generally in a less prevalent wind direction.

1

o E

TABLE 3.12-1 (Continued RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM N

Exposure Pathway Number of Representative Type and Frequency a

and/or Sample Samples and Sample Locations Collection Frequency of Analysis c5 d

H b.

Fish 1 sample each of 2 commercially 1 sample in season.

Gamma isotopic analysis and/or recreationally important on edible portions.

species in vicinity of site.

1 sample of same species in 4

areas not influenced by plant discharge.

d c.

Food Products Samples of up to 3 different kinds Monthly when avail-Gamma isotopic and of broad leaf vegetation grown in abl e.

1-131 analysis.

two different offsite locations of higher predicted annual average ground-level D/Q if milk sampling is not performed.

d 1 sample of each of the similar Monthly when avail-Gamma isotopic and broad leaf vegetation grown abl e.

1-131 analysis.

15-30 km distant in a less prevalent wind direction if milk sampling is not performed.

f

TABLE 3.12-1 (Continued) i TABLE NOTATION aspecific parameters of distance and direction sector from the centerline of. one reactor, and additional description where pertinent, shall be provided for each and every sample location in Table 3.12-1 in a table and figure (s) in the ODCM. Refer to NUREG-0133, " Preparation of Radio-logical Effluent Technical Specifications for Nuclear Power Plants".

October 1978, and to Radiological Assessment Branch Technical Position, Revision 1, November 1979. 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 alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made within 30 days in the radiological environmental monitoring program.

In lieu of a Licensee Event Report and pursuant to Specification 6.9.1.11, identify the cause of the unavailability of samples for that pathway and identify the new location (s) for obtaining replacement samples in the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

b ne or more instruments, such as a pressurized ion chamber, for measuring 0

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 number of direct radiation monitoring stations may be 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.

c Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling to allow for radon and thoron daughter decay.

If gross beta activity in air particulate samples is greater than ten.. times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples.

dGamma isotopic analysis means the identification and quantification of gamma emitting radionuclides that may be attributable to the. effluents from the facility.

" Groundwater samples shall b~e tiken when this source is tapped for drinking or irrication purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

DAVIS-BESSE, UNIT 1

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

h{

Reporting Levels k

${

Water Airborne Particulate Fish Milk Vegetables Analysis (pCi/1) or Gases (pC1/m3)

(pC1/kg, wet)

(pCi/1)

(pCi/Kg, wet) 4 H-3 3 x 10

~"

Mn-54 1 x 103 3 x 104 4

Fe-59 4 x 102 1 x 10 3

4 Co-58 1 x 10 3 x 10 2

4 Co-60 3 x 10 1 x 10 2

4 Zn-65 3y 10 2 x 10 2

Zr-Nb-95 4 x 10 2

I-1 31 2

0.9 3

1 x 10 3

3 Cs-134 30 10

~1 x 10 60 1 x 10 3

Cs-137 50 20 2 x 10 70 2 x 103 i

Ba-La-140 2 x 102

~-

3 x 102

\\

e e

4 a

4 o

E TABLE 4.12-1 T

LOWER LIMITS OF DETECTION (LLD)a

.M -

c Water Airborne Particulate 5

Analysis (pCi/1)*

Or Gas Fish Milk Food Products Sediment 3

]

(pCi/m )

(pCi/kg, wet)

(pCi/1)

(pCi/kg, wet)

(pCi/kg. dry) b gross beta 4

1 x 10-2 c

3 20,000 H

54 15 130 Mn 59Fe 30 260 58, 60 Co 15 130 65 30 260 Zn 95 15 Zr 131; l'

7 x 10-2 1

60 b

134, 137 15(10 ),18 6 x 10" 130 15 60 150 Cs 140 15 15 Ba 4

r NOTE: This list does not mean that.only these nuclides are to be detected and reported.

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

s kh

TABLE 4.12-1 (Continued)

TABLE NOTATION a.

The LLD is the smallest concentration of radioactive material in a sample that will be detected with 95% probability with 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

4.66 s b E ~ V 2.22 Y

exp(-AAT) where LLD is the lower limit of detection as defined above (as pCi per unit mass or volume).

s is the standard deviation of the background counting rate or of the h

counting rate of a bisnk sample as appropriate (as counts per minute).

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

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

2.22 is the number of' transformations per minute per picocurie Y is the fractional radiochemical yield (when applicable)

A is the radioactive decay constant for the particular radionuclide.

AT is the elapsed time between end of the sample collection period and l

time of counting.

~~

~

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

I 1

DAVIS-BESSE, UNIT 1

TABLE 4.12-1 (Continued)

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

Analyses shall be perfonned in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of inter-fering nuclides, or uncontrollable circumstances may rer. der these LLDs unachievable.

In such cases, the contributing factors will be identified anc described in the Annual Radiological Environmental Operating Report.

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

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

(2) Currie, L.A., " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry" Anal. Chem. 40, 586-93 (1968).

(3) Hartwell, J.

K., " Detection Limits for Radioisotopic Counting Techniques", Atlantic Richfield Hanford Company Report ARH-2537 (June 22,1972).

b. LLD for drinking water.

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

d. LLD only when specific analysis for I-131 required.

DAVIS-BESSE, UNIT 1

l 3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING i

3/4.12.2, LAND USE CENSUS LIMITING CONDITIONS FOR OPERATIONS 3.12.2 A land use census shall be conducted and shall identify within a distance of 8 km (5 miles) the location in each of the 16 meteorological sectorsofthenearestmilkAnimal,tgenearestresidenceandthenearest m' (500 ft ) producing broad leaf vegetation.

garden of greater than 50 e

i APPLICABILITY: At all times.

4 ACTION:

a.

With a land use census identifying a location (s) that ~ yields a calculated dose or dose connitment greater than the values currently being calculated in Specification 4.11.2.3, in lieu of a Licensee Event Report, identify the new location (s) in the next Semiannual Radioactive Effluent Release Report, j

pursuant to Specification 6.9.1.11.

b.

With a land use census identifying a location (s) that yields a calculated dose or dose commitment (via the same exposure pathway) 20 percent greater than at a location from which samples are currently being obtained in accordance with Specification 3.12.1, add the new location (s) if practical to the radiological environmental' monitoring program within 30 days. The sampling location (s)..egpluding the control station location, having a lower calculated dose or dose i

commitment (s), via the same exposure pathway, ray be deleted from this monitoring program.

In lieu of a Licensee Event Report and pursuant to Specification 6.9.1.11, identify the new location (s) in the next Semiannual Radioactive Effluent Release Report and also include in the report a revised figure (s) and table for the ODCM reflecting the new location (s).

c.

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

SURVEILLANCE REQUIREMENTS 4.12.2 The land use census shall be conducted during 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 3

consulting local agriculture authorities. The results of the land use-t census shall be included in the Annual Radiological Environmental Operating Report pursuant to Specification 6.9.1.10.

DAVIS-BESSE, UNIT 1

RADIOLOGICAL ENVIRONMENTAL MONITORING

- 3/4.12.3 INTERLABORATORY COMPARISON PROGRAM LIMITING CONDITION FOR OPERATION 3.12.3 Analyses shall be performed on radioactive materials supplied as part of an Interlaboratory Comparison Program that has been approved by the Commission.

APPLICABILITY: At all times.

ACTION:

a.

With analyses not being performed as required above, report the corrective actions taken to prevent a recurrence to the Commission in the Annual Radiological Environmental Operating Report pursuant to Specification 6.9.1.10.

b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.12.3 A summary of the results obtained as part of the above required 4

Interlaboratory Comparison Program shall be included in the Annual Radio-logical Environmental Operating Report pursuant to Specification 6.9.1.10.

i DAVIS-BESSE, UNIT 1 9

e:--

g

I. M DI0 ACTIVE EFFLUENTS BASES 3/4.11.1 LIOUID EFFLUENTS 3/4.11.1.1 CONCENTRATION This specification is provided to ensure that the concentration of radioactive materials released in liquid waste effluents from the site to unrestricted areas will be less than the concentration levels specified in 10 CFR Part 20.106.

This limitation as implemented by the ODCM pro-vides additional assurance that the levels of radioactive materials in bodies of water.outside the site should not result in exposures exceeding (1) the Section ILA desion ob.i.e.ctives of Appendix I,10 CFR Part 50, to an indivi. dual. and (2) the limits of 10 CFR Part 20.106(e) to the population.

The concentration limit for, noble gases is based upon the assumption _thAt

~

Xe-135 is the' controlling radioisotope and its MPC in air (submersion) was converted to an equivalent concentration in water using the methods described,

in International Commission on Radiological Protectlon (ICRP) Publication 2.

3/4.11.1.2 DOSE This specification is provided to implement the requirements of Sections II. A. III. A and IV. A of Appendix 1,10 CFR Part 50.

The Limiting Condition for Operation implements the guides set forth in Section II. A of Appendix I.

The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of rcdioactive material in liquid effluents will be kept "as low as is reasonably achievable".

Also, for fresh water sites with drinking water supplies which can be potentially affected by plant operations, there is reasonable assurance that the operation of the facility will not result l

in radionuclide concentrations in the finished drinking water that are in excess of the requirements of 40 CFR 141. The dose calculations in l

the ODCM implement the requirements in Section III.A of Appendix I that conformance with the guides of Appendix I is to be shown by cal-i culational orocedures based on modes anc data such that the actual exposure of an individual through appropriate pathways is unlikely to be substantially underestimated.

The equations seecified in the l

ODCM for calculating the doses due to the actual release rates of I

radioact1ve materials in liquid effluents are consistent with the l

methodology provided in Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, " Revision 1, October 1977.

l DAVIS-BESSE, UNIT 1 l

INSTRUMENTATION BASES 3/4.3.3.9 RADIOACTIVE LIOUID EFFLUENT INSTRUMENTATION The radioactive liquid effluent instrumentation is provided to monitor and control, as acplicable, the releases of radioactive materials in liquid effluents during actual or potential releases. The alarm / trip setpoints for these instruments shall be calculated in accordance with methods in the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20, 3/4.3.3.10 RADIOACTIVE GASEOUS EFFLUENT INSTRUMENTATION The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases. The alarm / trip setpoints for these instruments shall be calculated in accordance with methods in tne ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR Part 20. This instrumentation also includes provisions for monitoring the concantrations of potentially explosive gas mixtures in the waste gas holdup system. The OPERABILITY and use of this instrumentation is consistent with the requirements of General Design Criteria 60, 63 and 64 of Appendix A to 10 CFR Part 50.

4 I

O DAVIS-BESSE, UNIT 1 y

(ADIDACTRVE EFILUENTS BASES 3/4.11.1.3 LIOUID WASTE TREATMENT The requirements that the appropriate portions of.this system.be used when specified provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable". This specification implements the req'uirements of 10CFR Part 50.36a, General 9esign Criterion 60 of Appendix A to 10CFR Part 50 and design objective section II.D of Appendix A to 10 CFR Part 50. Based on a cost analysis of treating liquid radwaste, the specified limits governing the use of sppropriate portions of the liquid radwaste treatment system were specified as the dose design" objectives as set forth in Section II.A of Appendix I,

^

~

10CFR Part 50, for liqu1d effluents.

~

3/4.11.1.4 LIOUID HOLDUP TANKS Restricting the cuantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations woulo be less than the limits of 10 CFR Part 20, Appendix B, Table II, Column 2, at the nearest potable water supply and tne nearest surface water supply in an unrestricted area.

i t.

f DAVIS-BESSE, UNIT 1 wee e

RADIOACTIVE EFFLUENTS BASES 3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 DOSE RATE This specification is provided to ensure that the dose at the SITE BOUNDARY from gaseous effluents from all units on the site will be within the annual dose limits of 10 CFR Part 20 for unrestricted areas. The annual dose limits are the doses associated with the concentrations of 10 CFR Part 20, Appendix B, Table II.

These limits provide reasonable assurance that radioactive material

~

discharged in gaseous effluents will not result in the exposure of a member of the public outside the site boundary to annual average con-centrations exceeding the. limits specified in Appendix B, Table II of 10 CFR Part 20 (10 CFR Part.20.106(a)).

For members of the public who may at times be within the site boundary, the occupancy of that member of the public will,be sufficiently low to compensate for any increase in the atmospheric diffusion factor above that for the site boundary.

The specified release limits restrict the corresponding gamma and beta doses above background to an individual at or beyond the unrestricted area boundary to < 500 mrem / year to the total body or to < 3000 mrem / year 1

[ to the skin. These release limits also restrict, at all times, the corresponding thyroid dose above background to a child via the inhalation pathway to < 1500 mrem / year.

i s

4 DAVIS-BESSE, UNIT 1 e

RADI0 ACTIVE EFFLUENTS BASES 3/4.11.2.2 DOSE, NOBLE GASES This specification is provided to implement the requirements of Sections II.B. III.A and IV.A of Appendix I,10 CFR Part 50. The Limiting Condition for Operation implements the guides set forth in Section II.B of Appendix 1.

The ACTION statements provide the required operating flexibility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive material in gaseous effluents will be kept "as low as is reasonably achievable." The Surveillance Requirements implement the requirements in Section III.A of Appendix I that conform with the guides of Appendix I to be shown by calculation procedures based on models and data such that the actual exposure of an individual through the appropriate pathways is unlikely to be substantially underestimated. The dose calculations established in the ODCM for calculating the doses due to the actual release rates of radioactive noble gases in gaseous effluents are consistent with the methodology provided in Regulatory Guide 1.109,

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

l 3/4.11.2.3 DOSE, RADI0I0 DINES, RADI0 ACTIVE MATERIAL IN PARTICULATE FORM l

AND RA.DIONUCLIDES OTHER THAN NOBLE GASES l

This specification is provided to implement the requirements of l

l Sections II.C, III.A and IV.A of Appendix I,10 CFR Part 50. The Limiting l

l l

1 iDAVIS-BESSE, UNIT 1 l

)

RADIOACTIVE EFFLUENTS BASES Conditions for Operation are the guides set forth in Section II.C of Appendix I.

The ACTION statements provide the recuired operating flexi-bility and at the same time implement the guides set forth in Section IV.A of Appendix I to assure that the releases of radioactive materials in gaseous effluents will be kept "as low as is reasonably achievable." The ODCM calculational methods specified in the surveillance requirements implement the' requirements in Section III.A of Appendix I that conformance with the guides of Appendix I be shown by calculational procedures based on models and data such that the actual exposure cf an individual through appropriate pathways is unlikely to be substantially underestimated. The ODCM methods 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, " Calculating of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision I, October 1977 and Regulatory Guide 1.111, "Me.thods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Lignt-Water-Cooled Reactors,"

Revision 1, July 1977.

The release rate specifications for radioiodines, radioactive material in particulate form and radionuclides other than noble gases are dependent on the existing radionuclide pathways to man, in the unrestricted area.

The pathways which are examined in the development of these calculations are:

1) individual inhalation of airborne radionuclides, 2) deposition of radionuclides onto green leafy vegetation with subsequent consumption by man, 3) deposition onto grassy areas where milk animals and meat producing animals graze with consumption of the milk and meat by man, and 4) deposi-tion on the ground with subsequent exposure of man.

3

.=%

DAVIS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS BASES 3/4.11.2.4 EXPLOSIVE GAS MIXTURE This specification is provided to ensure that the concentration of I

potentially explosive gas mixtures contained in the waste gas treatment system is maintained below the flammability limits of hydrogen with oxygen. Maintaining the concentration of hydrogen or oxygen below their flammability limits provides assurance that the releases of radio-active materials will be controlled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10CFR Part 50.

3/4.11. 3.1 SOLID RADI0 ACTIVE WASTE The requirements for solid radioactive waste handling and disposal given under this specification provide assurance that solid radioactive materials shipped offsite, meet destination disposal site.reouirements and are packaged in conformance with 10CFR Part 20,10CFR Part 71, and 49CFR Parts 170-178.

3/4.11.4 TOTAL DOSE This specification is provided to meet the dose limitations of 40 CFP.

Part 190 that have been incorporatedinto 10 CFR Part 20 by 46 FR 18525.

The specification requires the preparation and submittal of a Special Renort whenever the calculated doses from olant oenerated radioactive effluents and direct radiation exceed 25 mrems to the total body or any organ, except the thyroid, which shall be limited to less than or equal to 75 mrems.

For sites containing up to 4 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 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 limitation of the annual dose to a MEMBER OF THE DAVIS-BESSE, UNIT 1

RADI0 ACTIVE EFFLUENTS BASES 3/4.11.4 TOTAL DOSE (continued)

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 MEMBER OF THE PUBLIC from other uranium fuel cycle sources is neglibible, 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 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 provisions of 40 CFR Part 190.11 and 10 CFR Part 20.405c, is considered to 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 Specifications 3.11.1.1 and 3.11.2.1.

An individual is not considered a MEMBER OF THE PUBLIC during any period in which he/she is engaged in carrying out any operation that is part of the nuclear fuel cycle.

l DAVIS-BESSE, UNIT 1

3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING BASES 3/4.12.1 MONITORING PROGRAM The radiological monitoring program required by this specification pro-vides measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclioes which lead to the highest potential _ radiation exposures of individuals resulting from the station

. operation. This monitoring program thereby supplements the radiological effluent monitoring program by measuring concentrations of radioactive materials and levels of radiation which may be compared with those expected on the basis of the effluent measurements and modeling of the environmental exposure pathways.

3/4.12.2 LAND USE CENSUS This specification is provided to ensure that changes in the use of unrestricted ardas are identified and that modifications to the monitoring program are made if required by the results of this census. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 5u. Mestricting the census to gardens of greater than 50 mz provides assurance that significant exposure pathways via leafy vegetables will be identified ana monitoried since a garden of this size is the minimum required to produce the quantity (26 kg/ year) of leafy vegetables assumed in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were made: 1) 20% of the garden was used for and cabbage), and 2) growing broad leaf vegetation (i.e., similar to lettuce 2

a vegetation yield of 2 kg/m,

3/4.12.3 INTERLABORATORY COMPARISON PROGRAM The requirement for participation in an approved Interlaboratory Compari-

' son Program is provided to ensure that Independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50.

DAVIS-BESSE. UNIT 1

\\

ADMINISTRATIVE CONTROLS 6.5 REVIEW AND AUDIT 6.5.1 STATION REVIEW BOARD (SRB)

RESPONSIBILITIES 6.5.1.6 The Station Review Board shall be responsible for:

The follouing SRB responsibilities vill be added.

k.

Review of any unplanned accidental or uncontrolled radioactive releases, evaluation of the. event, ensurance that remedial action is identified to prevent recurrence, review of a report covering the evaluation and forwarding of the report to the Station Superintendent and to the CNRB.

1.

Review of the OFFSITE DOSE CALCULATION MANUAL and implementation of procedures at least once per 24 months.

m.

Review of the PROCESS CONTROL PROGRAM.and implementation of procedures for processing and packaging of radioactive wastes at least once per 24 months.

n.

Review of the Annual Radiological Environmental Operating Report.

o.

Review of the Semiannual Radioactive Effluent Release Report.

DAVIS-BESSE, UNIT 1

ADMINISTRATIVE CONTROLS 6.5 REVIEW AND AUDIT 6.5.2 COMPANY NUCLEAR REVIEW BOARD (CNRB)

AUDITS 6.5.2.8 Audits of facility activities shall be perforned under the cognizance of the CNRB. These audits shall encompass:

[The following CNRB audit responsibility will be added.]

k.

The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

DAVIS-BESSE, UNIT L

ADMINISTRATIVE CONTROLS 6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented and maintained -

covering the activities referenced below:

The follouing pangmphs vilt be added to this section.

.g.

The radiological environmental monitoring program.

h.

The Process Control Program.

i. Offsite Dose Calculation Manual implementation.

DAVIS-BESSE, UNIT 1

t t

ADMINISTRATIVE CONTROLS 6.9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1.In addition to the applicable reporting requ'irements of Title 10, Code of Federal' Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted.

h1 The fottccing pangmphs uitt be added to this section.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT i

6.9.1.10 Routine Radiological Environmental Operating Reports covering the operation of the unit during the previous calendar year shall be submitted i

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 t

radiological environmental surveillance activities for the report period, i

including a comparison with the preoperational studies, with operational controls, as appropriate, and with previous environmental surveillance 4

reports and an assessment of the observed impacts of the plant operation on the environment. The reports shall also include the.results of land use censuses required by Specification 3.12.2.

The Annual Radiological Environmental Operating Reports shall include the.

results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the Table and Figures in the ODCM, as well as sumar-ized and tabulated results of these analyses and measurements.

In the event that some individual results are not-available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the -

missing results. The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following: a summary description of the radiological environmental monitoring program; at least two legible maps covering all sampling locations keyed to a table giving distances and directions from the centerline of one reactor; the results of licensee I

participation in the Interlaboratory Comparison Program, required by^

Specification 3.12.3; and discussion of all analyses in which the LLD required by Table 4.12-1 was not achievable.

f DAVIS-BESSE, UNIT ~1 i

.. =

ADMINISTRATIVE CONTROLS SEMIANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT 6.9.1.11 Routine 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.

The Radioactive Effluent Release Reports shall 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

" Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The Radioactive Effluent Release Report to be subitted within 60 days after January 1 of each year shall include an annual sumary of hourly meteorological data collected over the previous year. This annual sumary may be either in the form of an hour-by-hour 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 speed, wind direction, and atmospheric stability. This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from 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 PUBLIC due to their activities inside the SITE B0UNDARY (Figures 3.11-1 and 3.11-2 during the report period. All assumptions used in making these assessments, i.e., specific activity, exposure time and location, shall be included in these reports. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the 0FFSITE DOSE CALCULATION MANUAL (0DCM).

The Radioactive Effluent Release Report to be submitted 60 days after January 1 of each year shall also include an assessment of radiation doses to the likely most exposed MEMBER OF THE PUBLIC from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year to show conformance with 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operation.

DAVIS-BESSE, UNIT 1

ADMINISTRATIVE CONTROLS SEMIANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT (Continued)

The Radioactive Effluent Release Reports shall include the following information for each class of solid waste (as defined by 10 CFR Part 61) shipped offsite during the report period:

a.

Container volume, b.

Total curie quantity (specify whether determined by measurement orestimate),

Principal radionuclides (specify whether determined by c.

measurement or estimate.

d.

Source of waste and processing employed (e.g., dewatered spent resin, compacted dry waste, evaporator bottoms),

Type of container (e.g., Type A, Type 8, large Quantity), and i

e.

f.

Solidification agent or absorbent (e.g., cement, urea formaldehyde).

The Radioactive Effluent Release Reports shall include a list and description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

Th'e Radioactive Effluent Release Reports shall include any changes made during the reporting period to the PROCESS CONTROL PROGRAM (PCP) and to the l

OFFSITE DOSE CALCULATION MANUAL (00CM), as well as a listing of new locations for dose calculations and/or environmental monitoring identified by the land l

(

use census pursuant to Specification 3.12.2.

i l

1 0 AVIS-BESSE, UNIT 1

ADMINISTRATIVE CONTROLS

)

6.10 RECORD RETENTION 6.10.2 The following records shall be retained for the duration of the Facility Operating License.

The following ynngmph vitt be added to this Section.

r m.

Records of analyses required by the radiological environmental monitoring' program that would permit evaluation of the accuracy of the analyses at a later date. This should include procedures effective at specified times and QA records showing that these procedures were followed.

I i

4 i

i i

DAVIS-BESSE, UNIT 1 e-

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ADMINISTRATIVE CONTROLS The foltoving pangmpha vitt be added to the Abiniatmtive Controla secticn.

6.14 PROCESS CONTROL PROGRAM (PCP) 6.14.1 Licensee initiated changes to the PCP:

1.

Shall be submitted to the Comission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made. This submittal shall contain:

a.

Information to support the rationale for the change.

b.

A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and c.

Documentation of the fact that the change has been reviewed and found acceptable by the SRB.

2.

Shall become effective as reviewed and accepted by the SRB. 6.15 0FFSITE DOSE CALCULATION MANUAL (0DCM) 6.15.1 Licensee initiated changes to the ODCM:

1.

Shall be submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change (s) was made effective. This submittal shall contain:

a.

Information to support the rationale for the change.

b.

A determination that the change will not reduce the accuracy or reliability of dose calculations or setpoint determinations; and c.

Documentation of the fact that the change has been reviewed and l

found acceptable by the SRB.

2.

Shall become effective as reviewed and accepted by the SRB.

l

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l DAVIS-BESSE, UNIT 1