structures / systems / components statustable 11.1-3 . equipment design codes, liquid radwaste...

San Onofre 2&3 UFSAR (DSAR)

RADIOACTIVE WASTE MANAGEMENT

November 2018 11-1 Rev 4

11. RADIOACTIVE WASTE MANAGEMENT

Plant Radioactive Waste Management Systems are described in this chapter in three separate areas: Plant Area, South Yard Area, and North Industrial Area (NIA). Monitoring and sampling of the radiological process and effluent for each area is discussed in detail in Section 11.4. Not all subsystems of the Radioactive Waste Management Systems are required to support permanent plant shutdown or defueled operations. The status of these subsystems is listed in the table below. Design Basis, Licensing Basis, and operational information contained in this chapter / section has been updated to reflect the current status. Although the subsystems removed or partially removed from service no longer support operation, they may still contain fluids, gases, or other hazards such as energized circuits, compressed air, radioactive material, etc. Equipment may not have been physically removed from the plant. See General Arrangement Drawings, P&IDs, and One Line diagrams for the current plant configuration.

STRUCTURES / SYSTEMS / COMPONENTS STATUS

Plant Area Radwaste Management Systems

Liquid Radwaste Partially Removed from Service

Gaseous Radwaste Partially Removed from Service

Solid Radwaste Removed from Service

South Yard Area Radwaste Management Systems

Liquid Radwaste Partially Removed from Service

Gaseous Radwaste Removed from Service

Solid Radwaste Available

North Industrial Area Radwaste Management Systems

Liquid Radwaste Available

Gaseous Radwaste Removed from Service

Solid Radwaste Removed from Service




11.1 PLANT AREA RADWASTE MANAGEMENT SYSTEMS

11.1.1 LIQUID RADWASTE

The liquid waste systems consisted of four subsystems:


Coolant Radwaste System (CRS) Removed from Service Coolant and Boric Acid Recycle System (CBARS) Removed from Service Miscellaneous Liquid Waste System (MLWS) Partially Removed from Service Mixed Waste Processing (MWP) Unit Removed from Service The equipment that remains powered and in-service includes sumps and tanks to facilitate storage until a processing skid is obtained and placed in service to allow more routine processing:

Radwaste sump and pumps

Outlying radioactive sumps and pumps

Chemical Waste Tank (T064) and one pump (P180)

Condensate Monitor Tanks (T075, T076) and one pump

Radwaste Primary Tanks (T065, T066, T067, T068)

Interconnecting piping for above

Discharge to Unit 2 Outfall via Salt Water Dilution System and associated Radiation Monitor (2/3RE7813)

A future processing skid that will meet the ODCM requirements 11.1.1.1 Design Basis of MLWS

The principal design objectives of the MLWS liquid waste system are:

A. Collection of all liquid wastes generated during plant shutdown which may contain radioactive nuclides.

B. Sufficient processing capability so that liquid waste may be discharged to the environment at concentrations below the regulatory limits of 10 CFR 20 and consistent with the As Low As Reasonably Achievable (ALARA) guidelines set forth in 10 CFR 50.




The auxiliary building radwaste area equipment layout is presented in General Arrangement Drawings 40000 through 40003. The seismic and quality group classifications for the liquid waste components and piping are provided in Controlled Document 90034, “Q-List” and in Controlled Drawings. Special equipment design provisions have also been incorporated for consideration of ALARA, reduce maintenance, equipment downtime, liquid leakage, or gaseous releases of radioactive materials to the building atmosphere. Where practicable, welded connections are used in lieu of flanged ones. Butt welds are used where justified in the liquid waste systems to reduce crud trap formation. Pumps are provided with mechanical seals to minimize leakage. The frequency of equipment maintenance is minimized by utilizing corrosion-resistant materials wherever feasible. Diaphragms in some radwaste tanks are provided to prevent release of tritium and dissolved noble gases to the building atmosphere, and prevent air from dissolving into the liquid. Tanks receive liquid until processing begins or until tank liquid volume reaches a predetermined level. The tank is then isolated from the feed while its contents are stored until processed. Appropriate alarms are utilized to alert operators of tank high or low level. Overflow lines are connected to the radwaste sump via a loop seal. Table 11.1-1 provides a list of potentially radioactive tanks and describes the design provisions to prevent and control tank overflow. The function of the MLWS liquid waste systems is to collect and process radioactive liquid wastes generated during plant shutdown and to reduce their radioactivity and chemical concentrations to levels acceptable for discharge. 11.1.1.2 System Description of MLWS

The MLWS, in permanently shutdown configuration, consists of sumps, seven tanks (T064, T065, T066, T067, T068, T075, and T076) and associated pumps. The future processing skid will consist of ion exchangers and supporting sample and process equipment to allow processing of waste water from the Miscellaneous Waste Evaporator Condensate Monitor Tanks (T075 and T076) to prepare for discharge. The pumping action is provided by the condensate monitor tank pump, P188. The future processing system will be capable of reducing activity to meet the isotopic limits in 10 CFR 20 App B, and discharge per the Offsite Dose Calculation Manual. Some of the components from the CRS, CBARS, and MLWS have been repurposed since plant shutdown and are listed in Table 11.1-2 which describes equipment sizes and/or capacities, process flow rates, storage capabilities, design temperatures, and design pressures. Design codes and standards are listed in Table 11.1-3. Features and procedures used to prevent inadvertent releases to the environment from the liquid waste systems include automatic discharge pump shutoff, administrative procedures, Certified Fuel Handler training, and discharge radiation monitors which provide alarms.




Table 11.1-1 RADIOACTIVE TANK OVERFLOW PROTECTION

Radioactive Tanks Outside Containment Location Level Monitoring Potential Overflow Alarm Method for Containing Overflow

Radwaste Primary Tanks

T 065 Radwaste Building EL-9' Local (LI 7585A) Overflow would accumulate in lower levels and the drain is piped to the radwaste building area sump. Sump is then pumped to chemical waste tank (T064).

T 066 Radwaste Building EL-9' Local (LI 7586A)



Spent Fuel Makeup Tanks

T 055 (Unit 3) Radwaste Building EL-9' Local (3LI 7133A) Control Room / Command Center CDAS

Control Room / Command Center CDAS Same

T 056 (Unit 2) (see Chapter 9)

Radwaste Building EL-9' Local (2LI 7133A) Control Room / Command Center CDAS

Control Room / Command Center CDAS

Chemical Wastes Tank

T 064 Radwaste Building EL-9' Local (LI 7401) Control Room / Command Center CDAS Same

Miscellaneous Waste Evaporator Condensate Monitor Tanks

T 075 Radwaste Building EL-9' Local (LI 7459) Same

T 076 Radwaste Building EL-9' Local (LI 7458)




Table 11.1-2

MLWS EQUIPMENT DESCRIPTIONS

Component Quantity Size/Capacity For Each Component Material Design Press/Temp

(psig / °F)

Chemical waste tank, T-064 1 25,000 gal SS Atmospheric/180

Radwaste primary tanks T065, T066, T067 and T068 4 60,000 gal SS Atmospheric/180

Misc. wastes evaporator condensate monitor tanks, T-075 and T-076

2 25,000 gal SS Atmospheric/180

Chemical waste tank pumps, P-180 2 65 gal/min @ 180 psig

SS 200/180

Misc. wastes evaporator condensate monitor tank pump (Nuclear condensate tank pump, P-188)

2 100 gal/min @ 113 psig

SS 140/180




Table 11.1-3

EQUIPMENT DESIGN CODES, LIQUID RADWASTE SYSTEM (Sheet 1 of 2)

CODES

EQUIPMENT Design and Fabrication Materials(a) Welder Qualifications and Procedure Inspection and Testing

Tanks, Atmospheric BTP ASME Code Section(c)III, Class 3, or API 620 and 650, AWWA D-100

ASME Code(b) Section II

ASME Code Section IX

ASME Code(a) Section III, Class 3 or API 620; 650 AWWA D-100

All Atmospheric Tanks except Tanks T-055 and T-056

SONGS 2 & 3 Design to API 620 Fabricate to API 650

ASME Code Section II


API 620 and API 650

Spent Fuel Pool Make-up Tanks (T-055, T-056) See Chapter 9

(e) (e) (e) (e)

Tanks, Pressure BTP ASME Code Section VIII, Div. 1



ASME Code Section VIII, Div. 1

SONGS 2 & 3 ASME Code Section VIII, Div. 1



ASME Code Section VIII, Div. 1

Pumps BTP Manufacturer's(d) Standards

ASME Code Section II or Manufacturers Standard

ASME Code Section IX (as required)

ASME(c) Section III Class 3; or Hydraulic Institute

SONGS 2 & 3 Manufacturer's(d) Standards



Hydraulic Institute




Table 11.1-3 EQUIPMENT DESIGN CODES, LIQUID RADWASTE SYSTEM (Sheet 2 of 2)

CODES

EQUIPMENT Design and Fabrication Materials(a) Welder Qualifications and Procedure Inspection and Testing

Piping and Valves BTP ANSI B31.1 ASTM or ASME Code Section II

ASTM Code Section IX ANSI B31.1

SONGS 2 & 3 ANSI B31.1 ASTM ASTM Code Section IX ANSI B31.1

MLWS (Sump subsystem)

SCE and vendor Commercial B31.1 or Commercial

ASTM Code Section IX ANSI B31.1

(a) Material Manufacturer's certified test reports should be obtained whenever possible. (b) Fiberglass reinforced plastic tanks may be used in accordance with Part M, Section 10, ASME Boiler and Pressure Vessel

Code, for applications at ambient temperature. (c) ASME Code Stamp and material traceability not required. (d) Manufacturer's standard for the intended service. Hydro testing should be 1.5 times the design pressure. (e) The Spent Fuel Pool Makeup Tanks (formerly Primary Plant Make-up Storage Tanks) meet Seismic Category I requirements.

These tanks have been analyzed to withstand the effects of tornado depressurization.




The piping and instrumentation diagrams for the MLWS, including process flow, are shown in Controlled Drawings 40137B, 40137C, 40137D, 40138A, 40138B, 40138C, 40139A, 40139B, 40129A, and 40129B. Miscellaneous liquid wastes are piped into the chemical waste tank (T064). In addition, liquid waste from the radwaste sump is normally pumped into chemical waste tank (T064). The miscellaneous liquid waste system normally collects, stores, and processes liquids from the following major sources:

A. Radioactive chemical laboratory drains (chemical waste tank) B. Floor drains (miscellaneous wastes tank or chemical waste tank)

From the chemical waste tank (T064), the chemical waste passes through a duplex strainer in the suction line of the chemical waste pump (P180). The chemical waste tank can then be pumped to the condensate monitor tanks (T075 and T076). If sampling results so dictate, the chemical waste tank and / or condensate monitor tanks can be pumped to the Radwaste Primary Tanks (T065, T066, T067, and T068). Wastes are discharged to the Unit-2 outfall in accordance with Offsite Dose Calculation Manual (ODCM) specification limits. Fluid in the turbine plant area sumps is normally pumped to an oily waste holding sump and then discharged to the Unit 2 Outfall via the Salt Water Dilution System in accordance with the ODCM and the National Pollutant Discharge Elimination System (NPDES). Piping is also provided to pump liquid from the turbine plant area sumps to the radwaste area sump. From there, the turbine plant area sump water may be processed by the MLWS via the Chemical wastes tank. Storage and processing by the MLWS may be done when the turbine plant area sump water exceeds a predetermined specific activity (refer to Table 11.4-1). 11.1.1.3 Operation of MLWS

Operation of the MLWS consists of a series of automatic and operator-controlled operations. Sump water collection can be accomplished automatically, and storage tank(s) and processing paths, if needed, are selected by the operator. The MLWS is normally utilized to process floor and equipment drains. The MLWS may also receive wastes collected in the turbine building floor drains. The Chemical Waste Tank, T064, receives waste from the radwaste sump as well as various drains from the chemistry laboratory, decontamination shower, and other minor waste streams. From the chemical waste tank the waste water is pumped to the Condensate Monitor Tanks, T075 and T076. These tanks are used for processing water and preparing it for release. Water can be pumped from these tanks to a future process ion exchange system for reduction of radioactive isotope activity. Once activity levels are appropriately reduced, provisions are made for recirculation and sampling. The waste is then batch released via a monitored pathway with appropriate dilution in a process controlled by the ODCM to ensure compliance with 10 CFR 20, Appendix B, Table II, Column 2, and 10 CFR 50 App I.




If waste inventory exceeds the capacity of T075 and T076, the Radwaste Primary Tanks, T065, T066, T067, and T068 have been repurposed from the retired Coolant Radwaste System. Waste water from the MLWS can be stored in the primary tanks until it is appropriate to process and release the waste water per the process described above. The Condensate Monitor Tanks (T075, T076) are sampled and either discharged to the Unit 2 Outfall via the Salt Water Dilution System or stored for further processing. The primary function of the Chemical Waste Tank, T064, is to receive water from the radwaste sump. Area sumps where potentially contaminated liquids are routed to T064 as shown in controlled drawings. After filling a Miscellaneous Waste Evaporator Condensate Monitor Tank (T075 or T076), the tank is isolated and the influent is routed to the other Miscellaneous Waste Evaporator Condensate Monitor Tank. The contents of the isolated tank are analyzed for chemical and radiochemical contamination and, depending upon analytical results and plant water requirements, are either discharged offsite via a monitored path, or returned to the tank for further storage or processing. 11.1.1.4 Radioactive Releases of MLWS

During liquid processing by MLWS, radioactivity is reduced to appropriate levels by a future skid mounted ion exchanger before it is discharged to the environment. Before the liquid is to be discharged, the activity level must be consistent with the discharge criteria of 10 CFR 20 and 10 CFR 50 in accordance with the ODCM. Treatment in these systems is such that these liquids can be discharged from the plant while being monitored. The expected average annual liquid releases from the liquid waste systems are based on the following:

A. Direct discharge of Unit 2 East turbine building sump. B. Discharge of MLWS effluents meeting 10 CFR 20 limits and dose objectives of

10 CFR 50, Appendix I. The doses resulting from these releases are discussed in Section 11.1.1.4.3. 11.1.1.4.1 Release Points

The release point of liquid radwaste is via the Unit 2 Outfall via the Salt Water Dilution System as shown in Controlled Drawings. All discharges are either:

A. Continuously monitored through a monitored release path; or B. Batch released after activity levels are measured from samples taken.




11.1.1.4.2 Dilution Factors

Dilution factors are calculated per the ODCM and meet 10 CFR 20 limits. 11.1.1.4.3 Estimated Doses

The liquid radwaste system is designed to ensure that the design objectives of Section 11.1.1.1 are met. Estimates of the dose to the general public were calculated in accordance with 10 CFR 20, 10 CFR 50 and 40 CFR 190. Results for maximum whole-body dose to an individual, maximum organ dose to an individual, and whole-body and organ doses to the population within a 50-mile radius are tabulated in Table 11.1-4. Four possible pathways were used to determine doses to the general public: ingestion of aquatic foods (fish and other seafood invertebrates), sunbathing, boating, and swimming. The dose as a result of ingestion of aquatic foods is due to concentrations of radionuclides in aquatic foods due to release of contaminated liquid into the ocean and is directly related to the concentration of the radionuclides in water. The individual consumption rate for fish was assumed to be 21 kg/yr and seafood 5 kg/yr. Population doses resulting from ingestion of aquatic foods were based on published catch data and the year 2020 population projections. The dose received as a result of sunbathing is due to accumulation of radionuclides in shoreline sediments that have been washed ashore and deposited on the beach. The individual sunbathing occupancy time was based on the maximum age group usage (teenage) of 67 hr/yr. The population dose usage factor was based on the year 2020 population projections within a 50-mile radius of the facility. The individual doses received from boating (water surface) were based on a usage time of 52 hrs/yr. The individual doses received as a result of swimming were based on usages of 100 hrs/yr and 8 oz/day for 150 days, respectively. The population doses were based on the year 2020 population projections within a 50-mile radius of the facility.

Table 11.1-4 ANNUAL ESTIMATED DOSES DUE TO LIQUID RELEASES (PER UNIT)

Total Individual Dose Appendix I Limits Population Dose Total Body 1.34 x 10-5 mrem 3 mrem 1.0 x 101 man-rem Bone 9.37 x 10-6 mrem 10 mrem 3.5 x 10-2 man-rem Thyroid 3.60 x 10-4 mrem 10 mrem 8.7 x 10-1 man-rem GI Tract 2.34 x 10-5 mrem 10 mrem 4.4 x 10-2 man-rem Skin 6.28 x 10-6 mrem 10 mrem 1.2 x 101 man-rem




11.1.2 GASEOUS RADWASTE

The Gaseous Waste Management systems are not required to support permanent plant shutdown or defueled operations, with exceptions listed below. The operational information has been removed from the UFSAR (DSAR) to indicate that the system performs no licensing bases or design bases or safety function. Although the system does not support operation, the system may still contain fluids, gases or other hazards such as energized circuits, compressed air, radioactive material, etc. Equipment may not have been physically removed from the plant. See P&IDs, One-Line diagrams, and General Arrangement Drawings for current plant configuration.

Radioactive waste gases are collected and processed through the following systems depending upon their origin. These systems are:


High-activity reactor coolant gaseous radwaste system Removed from Service

Low-activity vent gas collection header Available

Main condenser evacuation system Removed from Service

Turbine gland seal system Removed from Service

Building ventilation systems Partially Removed from Service 11.1.2.1 Design Basis

The gaseous waste management systems collected and processed the radioactive noble gases, airborne halogens, and particulates to reduce the anticipated annual releases and personnel exposure in restricted and unrestricted areas to levels as low as is reasonably achievable. The design objective of the remaining gaseous waste management systems is the collection of potentially low-radioactive gaseous wastes. The equipment layout is presented as part of the radwaste building equipment layout in General Arrangement Drawing 40000.

11.1.2.2 System Description

As shown on Controlled Drawings 40135A, 40135B, 40135C, 40175A, 40175ASO3, 40175B, and 40175BSO3 and Figure 11.3-2, the vent gas collection system collects various low-activity gases from potentially radioactive liquid storage tanks, thereby minimizing radiation doses to plant operating personnel. These gases consist mainly of air collected in the vapor space above storage tanks and ventilation discharges from plant sample hoods.

The sources for the vent gas collection header include the gases from: A. Miscellaneous waste tank vent B. Chemical waste tank vent C. Miscellaneous waste evaporator condensate monitor tanks vents D. Radwaste area sump E. Sampling system vent hoods




The vent gas collection system is shared between Units 2 and 3. A continuous exhaust plenum is used to collect discharges from plant ventilation systems and remaining components (via gas collection header) for monitoring before discharge. 11.1.2.3 Operation

Remaining plant components and systems are vented to a gas collection header. The header is piped to the continuous exhaust plenum, where effluents are monitored. The HVAC systems servicing these rooms are also directed to the continuous exhaust plenum. The HVAC system operates continuously. 11.1.2.4 Radioactive Releases

11.1.2.4.1 Release Points

During normal operation, including transients associated with anticipated operational occurrences, the potentially significant points of airborne radioisotope releases are:


Containment Purge Vent Stacks Removed from Service

Continuous Exhaust Vent Stacks Available

Turbine Buildings Removed from Service

Main Condenser Evacuation System Exhausts Removed from Service

Turbine Gland Seal System Exhausts Removed from Service Continuous Exhaust Vent Stacks Effluents from the fume hoods, laboratories, waste gas discharge and vent headers, fuel handling, radwaste area, and safety equipment building and penetration buildings are routed to the continuous exhaust plenum. The effluents are discharged to the atmosphere through the Unit 2 and Unit 3 Continuous Exhaust Plant Vent Stacks. The Continuous Exhaust Vent stacks are located on the top of each containment structure. Each stack is 15 feet higher than the top of the containment structure which is itself 160 feet above grade. The continuous exhaust vent and the containment purge vent are included in a single stack with a divider down the middle. The containment purge vent path is normally isolated. The combined stack on each containment is sized to provide a minimum exit velocity of 3000 ft/min from each side at a temperature of 110°F.




11.1.3 SOLID RADWASTE

The solid waste management system (SWMS) was designed to provide holdup, transfer, solidification and packaging for radioactive wastes generated by plant operation, and to store these wastes until they are shipped offsite. Shipment offsite may be to an intermediate processor or directly to a licensed burial site depending on the method by which the wastes were packaged on site. The processing system is no longer in service and has been removed from the radwaste building. However, within the plant area, packaging, storing and shipping of solid radwaste is still available. Underwater demineralizers and filtration systems may be used in the spent fuel pools. Handling and Disposal Packaging of radioactive materials (filters), dry active waste, and radioactive sources may be by either encapsulation with an approved solidification agent (such as cement) in a liner or placement into a High Integrity Container (HIC). The liner/HIC is then normally transferred to the Multipurpose Handling Facility (MPHF), see Section 11.2.3, for temporary storage and is ultimately shipped to a licensed burial site or alternate processor for disposal of final waste form in an appropriate shielded shipping cask. Packaging, Storage, and Shipment All radioactive wastes will be prepared for shipment in containers which meet the requirements of the U. S. Department of Transportation (DOT) regulations and the U. S. Nuclear Regulatory Commission (NRC) regulations and burial site license requirements, as applicable. Shipping containers will be stored in appropriate storage areas onsite. Solid radwaste is stored in the high-level and low-level storage areas of the Auxiliary Building. In addition, solid radwaste is also stored in the radwaste staging area which is a fenced off area located east of the Units 2 and 3 Auxiliary Building. Filters and/or demineralizers may be stored for a limited time in the spent fuel pools prior to removal for packaging. After the radioactive waste has been packaged it is normally sent to the MPHF for offsite shipment. The MPHF has an in-process staging area for the accumulation of solid radwaste until it is released for shipment. Containers, solidification liners and HICs could be shipped promptly after filling, provided the proper shielding is available, without exceeding DOT radiation limits. If 49 CFR 173 dose limitations cannot be met with the available shielding, the containers (liners and/or HICs) are stored and allowed to decay until the appropriate shielding is available.




11.2 SOUTH YARD AREA RADWASTE MANAGEMENT SYSTEMS

Radioactive waste management systems can be found in the South Yard Facility (Areas T10 and T20) and in the Multipurpose Handling Facility, MPHF (Area T60). The South Yard Facility is located on the south side of the plant outside the Protected Area. The Radiological Work Area within the South Yard Facility includes the Radioactive Equipment and Materials System (REMS) Rebuild Area, Mixed Waste Room and REMS Work Area. The SYF also had a decontamination shop. The MPHF consists of an office building, a staging building and an equipment pad. The facility is surrounded by a chain link fence. The MPHF is located at the southern edge of the SONGS owner controlled area. Table 11.2-1 provides the allowable activity, quantity, and volume of radioactive waste allowed to be stored at the MPHF.

Table 11.2-1 MPHF Allowable Limits

Waste Type Total Volume

ft3(a) Total Activity

(Ci)

Spent Resin 5,175 16,120

Spent Resin (FFCPD) 7,935 225

Evaporator 20,227 86

Filter Water 4,301 18,269

Miscellaneous Waste 17,884 25

Total(b) 55,500 34,700 (a) Two-year waste generation. (b) Total volumes are rounded to the nearest 100 ft3 and 100 Ci.

SOUTH YARD AREA STATUS South Yard Facility Radiological Work Area Available Decontamination Shop Removed from Service Multipurpose Handling Facility (MPHF) Available




11.2.1 LIQUID RADWASTE

Currently no liquid radwaste is handled in the South Yard Area, except as discussed in 11.2.1.2 below for the MPHF area. 11.2.1.1 Design Basis

11.2.1.1.1 Mixed Waste Room of South Yard Facility Radiological Work Area

Mixed Waste is defined as a material that is both hazardous as defined by the EPA criteria in 40 CFR and by the State of California in 22 CCR, and radiologically contaminated with licensed radioactive material per 10 CFR. The South Yard Facility is designed to process non-Resource Conservation and Recovery Act (RCRA) mixed wastes, in particular used oil, generated by SONGS. Other examples of mixed waste generated at SONGS are paints, solvents, caustics, acids, and Freon. These wastes are collected at various satellite accumulation areas and brought to the hazardous materials pad for consolidation and storage. As treatment or disposal opportunities become available, these wastes are disposed of in accordance with all applicable regulations. 11.2.1.1.2 MPHF

The MPHF is designed for low-level solid radwaste staging in accordance with federal, state, and local permits for Class III combustible or non-combustible liquid radwaste staged in leak tight containers. 11.2.1.2 System Description

The MPHF provides storage and staging areas only. Within the MPHF, liquid radwaste containers are placed in either the High Specific Activity Waste area or the Low Specific Waste area. Any liquid radwaste leakage will be collected through floor trenches and underground drain lines within the building, sampled, processed, and disposed-of according to applicable site procedures. Liquid radwaste staged inside the MPHF must not be Class I flammable or Class II combustible. Any Class I flammable or Class II combustible liquids staged inside the MPHF must be in U.L. listed flammable liquid storage cabinets and be as far as possible from Class III combustible liquids. In addition, if class I flammable or Class II combustible liquids are to be staged inside the MPHF, an evaluation must be performed to demonstrate that fire protection features provided are adequate to mitigate a potential fire. 11.2.1.3 Operation

These areas are for storage and staging only. No other operations are currently conducted.




11.2.1.4 Radioactive Releases

No radioactive liquid releases are made from the South Yard Area. Liquid radwaste accumulated in the South Yard Area is transported to the plant for release. 11.2.2 GASEOUS RADWASTE

There is no Gaseous Radwaste System in the South Yard Facility (SYF) and the MPHF. HVAC systems in both buildings are capable of being monitored for radioactive effluent releases, via RE-7904 (SYF) and RE-1956 (MPHF). 11.2.3 SOLID RADWASTE

11.2.3.1 Design Basis

Radioactive material may be decontaminated, processed, or worked on in the South Yard Facility (SYF). The SYF is designed to have one potentially radioactive envelope with a monitored effluent pathway. The SYF is designed with radiological controlled area (RCA) of the building and has air samples taken in accordance with the ODCM when working with radioactive materials. The limiting contamination level which would not cause the annual off-site Effluent Concentration Limit to be exceeded is 3.66 x 1011 dpm/100 cm2. The source strength is based on the SONGS dry active waste composite. The SYF surface contamination limit is based on the decontamination of 1 square foot of material per second. The decontamination process is assumed to be performed continuously for the entire year. The MPHF is designed for solid radwaste staging in accordance with federal, state, and local permits for Class III combustible or non-combustible liquid radwaste staged in leak tight containers. The MPHF's HVAC system is designed such that there is only one release point. The release point will be monitored when handling radioactive waste that could release to the environment. 11.2.3.2 Operation

Operation conducted in the SYF include decontamination, processing, and working on contaminated equipment. The SYF is designed to have one potentially radioactive envelope with a monitored effluent pathway and has air samples taken in accordance with the ODCM when working with radioactive materials. The MPHF is designed for storage and staging of radioactive material. There are no other operations conducted in the MPHF. 11.2.3.3 Radioactive Releases

The limiting contamination level is 3.66 x 1011 dpm/100 cm2 which would not cause the annual off-site Effluent Concentration Limit to be exceeded. The source strength is based on the SONGS dry active waste composite.




The SYF surface contamination limit is based on the decontamination of one (1) square foot of material per second. The decontamination process is assumed to be performed continuously for the entire year. 11.3 NORTH INDUSTRIAL AREA RADWASTE management SYSTEMS

The NIA is located north of Units 2&3 on the land previously occupied by Unit 1 (see plant configuration drawing 40028). It is the present location for the Independent Spent Fuel Storage Installation (ISFSI). There is a sump on the property which directs surface drainage from the NIA and surrounding property to the Unit 2 outfall. On occasion, the sump also receives water from sampling wells. Sump effluent is monitored via RE-2101. 11.3.1 LIQUID RADWASTE

11.3.1.1 Design Basis

Drainage and monitoring well water in the NIA sump could potentially be radioactive. Sump effluent is monitored. Because remediation of Unit 1 is not complete, water from the soil or drainage pipes could potentially be radioactive. Monitoring well effluent has contained trace radionuclides, most notably tritium and Cs-137. 11.3.1.2 System Description

Effluent from the NIA sump is directed to the Unit 2 outfall. Radiation Monitor RE-2101 samples the NIA sump discharge flow. Upon detection of radiation RE-2101 trips the sump pumps. Overflow of the NIA sump is contained within the NIA site. Compensatory measure provide for batch release after sampling. 11.3.1.3 Operation

NIA pumps can be set in auto or manual. In auto they start and stop based on level. High radiation will trip the pumps and alarm in the Control Room / Command Center. 11.3.1.4 Radioactive Releases

The presence of ionic radioactivity, principally Cs-137, would indicate contamination of the normally non-contaminated rain water. Tritium has been detected in the ground monitoring wells. See Section 11.3.1.1. 11.3.2 GASEOUS RADWASTE

There is no Gaseous Radwaste System in the NIA.




11.3.3 SOLID RADWASTE

There is no Solid Radwaste System in the NIA. However, the NIA (Unit 1 Industrial Area) is used from time to time for temporary staging of large contaminated equipment from Units 2 and 3 as it is decontaminated or prepared for shipment to an off-site facility for treatment and / or disposal. Portions of NIA may be used to support SONGS 2/3 decommissioning activities. Appropriate contamination control, spill prevention, and effluent control measures, based on the activity, would be developed and implemented to prevent unplanned, unmonitored releases of radioactive liquids and/or radioactive airborne material during temporary storage, treatment, and packaging activities of the contaminated equipment. 11.4 PROCESS AND EFFLUENT RADIOLOGICAL MONITORING AND SAMPLING

SYSTEMS


Process Radiological Monitoring Removed from Service

Effluent Radiological Monitoring Partially Removed from Service The effluent radiological monitoring system monitors and provides information to operators concerning activity levels in selected plant effluents. The system consists of permanently installed sampling and/or monitoring devices together with a program and provisions for specific routine sample collections and laboratory analyses. The overall systems are designed to assist the operator in evaluating and controlling the radiological consequences of normal plant operation, anticipated operational occurrences, and postulated accidents such that resultant radiation exposures and releases of radioactive materials in effluents to unrestricted areas are maintained as low as reasonably achievable.




11.4.1 DESIGN BASES

11.4.1.1 Normal Operations

The effluent monitoring system is designed to perform the following functions in order to meet the requirements of 10CFR20, 10CFR50, and follow the recommendations of Regulatory Guide 1.21 during normal operations, including anticipated operational occurrences:

A. Provide continuous representative sampling, monitoring, and indication of liquid and gaseous radioactivity levels, and, as a minimum, continuous representative sampling of particulate and iodine radioactivity levels along principal effluent discharge paths.

B. Provide the capability, during the release of radioactive liquid wastes, to alarm and automatically secure liquid waste releases before the limits of the ODCM specifications are exceeded.

C. Provide radiation level indication and alarm annunciation to the Control Room / Command Center operators whenever ODCM specification limits for release of radioactivity are approached or exceeded.

D. For continuous effluent paths, provide a means for collection and laboratory analysis of required routine samples.

E. For batch releases, provide a means for collection and laboratory analysis of required routine samples prior to release.

11.4.1.2 Postulated Accidents

Radiation monitoring systems are designed to perform the following functions in order to meet the requirements of 10 CFR 50, for postulated accidents:

A. Effluent radiation monitors provide continuous gaseous monitoring during the remaining Chapter 15 accidents and those conditions, as well as during normal operating conditions, to quantify release rates for noble gases from all potential release points.

B. Effluent radiation monitors provide monitoring of particulate radionuclides collected by absorption on sampling media, followed by laboratory analysis.

C. Area radiation monitors in the Fuel Handling Building provide an indication of abnormal operating conditions (pool level, stored fuel damage, etc.).

11.4.2 SYSTEM DESCRIPTION

The requirements of the system design bases for continuous monitoring are satisfied by a system of monitors, including independent detector channels with their associated sampling and auxiliary equipment.




The following describes the features of the effluent radiation monitoring systems that apply to both analog and digital radiation monitors.

1. All airborne particulate and iodine monitors and samplers, sample isokinetically in accordance with the principles and methods of ANSI N13.1-1969, Guide to Sampling airborne Radioactive Materials in Nuclear Facilities.

2. The particulate sampler collection efficiency is greater than 95% for 0.3µ particulates. Table 11.4-1 is a tabulation of basic information describing each of the continuous effluent radiation monitors and sampler, including monitor location, type of monitor and measurement made, sampler and/or detector type, calibration isotope, range of activity concentrations to be monitored and expected concentrations, alarm setpoint, provisions for power supplies, and automatic actions initiated. Bases for the ranges of effluent monitors listed in Table 11.4-1 are as follows:

A. For effluent monitors, the ranges include: 1. Maximum calculated concentrations during normal operations and post-accident

conditions. 2. Minimum concentrations that must be detected in order to allow automatic and/or

manual actions to avoid exceeding ODCM specifications for the release of radioactivity.

For effluent monitors, the setpoint is chosen as an appropriate fraction of the applicable ODCM specification limit for the release of radioactivity in order to allow automatic and/or manual actions to avoid exceeding the limit. CDAS and Hallway Remote Monitors satisfy the redundancy, diversity, and independence design bases for postulated accident in the permanently defueled condition.




Table 11.4-1

CONTINUOUS EFFLUENT RADIATION MONITORING

Sampler/Monitor Location Quantity Sampler Type Detector Type Activity

Measured Calibration Isotope (f)(g)

Range (µCi/cm3)

Expected Concentrations

(µCi/cm3)(b)

Alarm(I) Setpoint

(µCi/cm3)

Power Supply(l)

Automatic Actions Initiated

Radwaste discharge line (RDL.) monitor (2/3RE7813; P&ID 40132C)(j)

1 Offline/liquid γ scintillation Gross β Cs-137 Ba-133 Co-60

10-6-10-1

7.2x10-4 Cs-137 1.0x10-3 Cs-134 4.4x10-5 I-131

ODCM, SP

Alarm and secure radwaste

discharge to outfall

Turbine plant sump (TPS) monitor (2RE7821; P&ID 40119A) (j)

1 Offline/liquid γ scintillation Gross γ Cs-137 Ba-133 Co-60

10-6-10-1 < LLD ODCM, SP

Alarm and secure turbine

plant area sump pumps

Plant vent stack airborne (PVSA) monitor (2/3RE7808; P&ID 40175B)(j)

1 Offline/gas β solid state Gross β

Kr-85 Xe-133 Cl-36

Cs-137

10-6-10-1 5.4x10-4/ <LLD Kr-85 ODCM Alarm

Fixed paper & charcoal cartridge Detector not used

Plant vent stack wide range (2RE7865-1 and 3RE7865-1; P&ID 40171C & 40171CS03)(j)

2 (1 per unit)

Offline/gas

Low range: plastic scintillator Gross γ Cl-36

Cs-137 10-7 to 10-1 (Xe-133)

5.4x10-4/ LLD Kr-85 ODCM Alarm

Mid-range: solid state Gross γ

Am-241 Cs-137 Ba-133

10-4 to 102 (Xe-133) < LLD

High range: solid state Gross γ

Cs-137 Am-241 Ba-133

10-1 to 105 (Xe-133) < LLD

Offline/isokinetic/ fixed particulate filter No detector

Offline/isokinetic fixed charcoal

cartridge No detector




Table 11.4-1

CONTINUOUS EFFLUENT RADIATION MONITORING

Sampler/Monitor Location Quantity Sampler Type Detector Type Activity

Measured Calibration Isotope (f)(g)

Range (µCi/cm3)

Expected Concentrations

(µCi/cm3)(b)

Alarm(I) Setpoint

(µCi/cm3)

Power Supply(l)

Automatic Actions Initiated

North Industrial Area Yard Drain Sump monitor (2/3RE2101; P&ID 40119C)(j)

1 Offline/liquid γ scintillation Gross γ Cs-137 10-6 to 10-1 < LLD ODCM, SP 2/3B58 Alarm and

initiate stop of sump pumps

* These are initial setpoints, methodology to derive setpoints is found in the Unit 2, and 3 Offsite Dose Calculation Manual (a) Deleted. (b) LLD is less than the lower limit of detection. (c) Deleted (d) Deleted (e) Deleted (f) Ba-133 is the calibration isotope for I-131. (g) Kr-85 is the calibration isotope for Xe-133. (h) Deleted (i) This column represented initial alarm/trip setpoints, based upon design calculations N-4098-1 & N-720-3, (J-SPA-219 & J-SPA-329 digital monitors) used for

commencement of plant operations. Subsequent setpoints are established in accordance with 90010A and the Setpoint Program letter, dated March 28, 1994 (Docket 50-361 & 50-362) in response to 50.54(f) and/or the Offsite Dose Calculation Manual (ODCM), as appropriate, and administratively controlled per station procedures.

(j) Effluent Radiation Monitor. Setpoints are calculated per ODCM methodology. Alarm value provided is only indicative of range. (l) Power supplies are from common Cold & Dark Electrical System 2/3Q2005 (Dwg 38873 Sheet 2) except where noted.




11.4.2.1 Gaseous Effluent Radiation Monitor Description

The effluent radiation monitoring system consists of Analog and Digital effluent monitors and CDAS display panels. 11.4.2.1.1 Unit Specific Gas Effluent (Plant Vent Stack) Monitoring

The following two (2) monitor loops comprise unit specific gas effluent plant vent stack radiation monitors: 2RE7865A1/B1/C1 and 3RE7865A1/B1/C1. The monitoring equipment is designed to function properly under the following environmental conditions:

• An ambient temperature range of 40oF to 120oF

• 0% to 100% relative humidity

• An external radiation field of 2.5 mR/hr (Co-60) [100 R/hr for wide range radiation monitors]. 2RE7865-1 and 3RE7865-1 have been analyzed to 115 R/hr external radiation field.

The following sections provide specific information for each effluent monitor.

Wide Range Radiation Monitors

Radiation monitors 2RE7865A1/B1/C1 and 3RE7865/A1/B1/C1 comprise the Wide Range Gas Monitors (WRGM). Refer to Table 11.4-1 for monitor specifications. The Plant Vent Stack is provided with wide range gas monitors. There are two sets of isokinetic samplers provided for each stack. Each isokinetic sampler consists of two sets of isokinetic nozzles, one for sampling during low concentration levels and one for sampling during high concentration levels. Each monitor has a flow transmitter that measures the total vent flow rate for each of the vents being sampled. This signal is used to control the sample flow rate so as to maintain true isokinetic sampling conditions. The vent flow rate signal also allows the operator to display the effluent radiation level in units of µCi/cc (Xe-133).

The sample conditioning assembly is connected to the isokinetic samplers and provides for both collection of particulate and iodine samples. There is one sample collector and it is low range operation. Filter holders are connected via quick disconnect fittings to allow rapid retrieval of particulate and iodine samples for isotopic analysis. Charcoal is used during normal operation. Sampling conditioning is provided to prevent contamination of the detection assembly by filtering out a major proportion of the iodine and particulate.




The wide range effluent monitor draws a sample from isokinetic probes located at elevation 152 ft. in the plant vent stacks. The isokinetic flow manifold, sample conditioning and sample detection skid are located at elevation 63 ft. 6 in. of the penetration area. The function of this monitor is to supplement the capability of the plant vent stack airborne monitor by providing high range capability (10-7 to 105 µCi/cc) for measuring noble gas concentrations. The monitor functions to alarm when the preset level is reached. The isokinetic nozzles sample properly with stack flows from 91,300 standard ft3/min to 66,400 standard ft3/min (+10%, -20%) of the 83,000 standard ft3/min design flow rate. The detector assembly contains three radioactive gas detectors that monitor the sample discharged from the sample conditioning assembly. Table 11.4-2 specifies the arrangement of the individual detectors. The 12 decades of noble gas concentrations are monitored by the three detectors with at least one decade overlap between ranges of the individual detectors. The low-range detector utilizes a plastic scintillation detector. The mid and high-range detectors are a solid state CdTe. Each detector has a solenoid-actuated check-source to verify proper operation.

Table 11.4-2

Wide Range Radiation Monitors

Range Plant Vent Stack Wide Range Radiation

Low Range 2RE7865A1 3RE7865A1

Mid Range 2RE7865B1 3RE7865B1

High Range 2RE7865C1 3RE7865C1

There are two flow paths through the detectors. During normal operation only the low-range detector is used and the mid-range and high-range detectors are offline. As the low-range detector reaches the concentration switch setpoint, the flow path is automatically changed to the mid and high-range detectors and the low-range detector is purged to prevent contamination of the low-range detector. Figure 11.4-3 and Controlled Drawings 40171C, 40171CS03, 40152D, and 40152DS03 show the sample detection skid flow diagram. The detector assemblies are shielded with lead and are designed to detect over their specified range in a 115 R/hr (Co-60) external field.




The monitor is operated by the Model RM-80 microprocessor located in the Control Room / Command Center. A digital readout located in the Control Room / Command Center provides a display of all monitored parameters including channel activity and flow rate, alarm status, check-source actuation, etc. The RM-80 also maintains history files of channel activity that are available for recall. The stack effluent (µCi/sec) and each detector output (µCi/cc) are continuously recorded.

11.4.2.1.2 Common Plant Vent Stack - PVS Monitor (2/3RE7808G)

The PVS channel samples for and monitors gaseous activity in the exhausted air and the PVS monitor functions to alarm when the preset level is reached. The PVS monitor is an one-channel off-line monitor for noble gas activity. It draws a sample from and returns it to the ventilation duct leading to the plant vent stack, downstream of the continuous exhaust plenum. The detector uses a beta-sensitive PIPS detector located in a lead shielded sample chamber. The monitor is located in the radwaste building at the 63 ft. 6 in. level. The detector skid contains the required piping, sample pump, valves, and fittings to draw an off-line sample from the plant vent stack.

11.4.2.2 Liquid Effluent Radiation Monitoring Systems

The following three (3) monitors are included in digital liquid radiation monitoring systems: 2/3RE7813, 2RE7821, and 2/3RE2101. Refer to Table 11.4-1 for monitor specifications. The digital liquid monitor detector configuration is off-line with the detector mounted in a lead shield. The lead shielded assembly contains a gamma-sensitive NaI scintillation crystal and photomultiplier tube. The scintillation detector is operated in the gross gamma detection mode. The Field Units (FU) consist of the radiation detection unit (RU), the local processing unit (LPU), the local display unit (LDU), and the remote display unit (RDU). This section describes the components of the FU. System equipment is designed to function properly under the following environmental conditions:

An ambient temperature range of 36oF to 110oF

0% to 100% relative humidity

An external radiation field of 2.5 mR/hr (Cs-137).

Each radiation channel is designed to indicate full scale readings in the range from its normal design range upper limit to a level 100 times this upper design limit.




The different types of detector assemblies used are described below. Radwaste Discharge Line (RDL) Monitor (2/3RE7813) The RDL monitor is installed on a bypass sample line off the radwaste discharge line, upstream of the radwaste discharge control valve. It is located at the 9-foot level. Sample low flow alarm is provided in the Control Room / Command Center CDAS, via the 2/3RE7813 Failure alarm, to indicate the sample flow rate in the sample line is below the specified setpoint, when the main process flow is present. During normal operation, the radwaste discharge line receives liquid from the miscellaneous wastes condensate monitor tanks and discharges to the Unit-2 outfall. The RDL channel continuously monitors this line for the presence of ionic radioactivity, principally Cs-137. The presence of an abnormally high level of radioactivity in this line may indicate improper operation of the radwaste system. The function of this monitor is to alarm on high-radiation level and to terminate radwaste discharge to the Unit-2 Outfall by securing the operating pump. Turbine Plant Sump (TPS) Monitor (2RE7821) The TPS monitor is installed on a bypass sample line off the turbine plant sump pump discharge line, upstream of the sump diverting valves to the oily waste separator and radwaste area sump. The monitor is physically located in the Unit-2 turbine building at the 7-foot level, along the west wall. Sample driving head is provided by sump pump discharge pressure in the main sump discharge line. Sample low flow alarm is provided in the Control Room / Command Center CDAS, via the 2RE7821 Failure alarm, to indicate the sample flow rate in the sample line is below the specified setpoint, when the main process flow is present. The turbine plant sump collects liquid leakage from various floor and equipment drains in the turbine area of the plant. The sump pumps normally discharge to the oily waste holding sump, and then to the Unit-2 Outfall. The TPS channel continuously monitors this discharge line to the oily waste holding sump. The presence of ionic radioactivity, principally Cs-137, would indicate the leakage of radioactive liquid from a normally nonradioactive system. The function of the monitor is to alarm on high radiation level and to terminate sump discharge by automatically securing the TSP discharge pump. Sump contents may then be diverted to the radwaste system for processing, storage, or may be treated using appropriate local methods.




North Industrial Area Yard Drain Sump Monitor 2/3RE2101 The NIA Yard Drain Sump monitor is installed on a bypass sample line off the sump pumps P1059 and P1060 discharge lines. The monitor is located on the roof of the sump. Sample driving head is provided by the sump pump’s discharge pressure. Sample low flow alarm is provided in the CDAS to indicate whether the flow rate in the sample line is below the specified setpoint when the pumps are in operation. The NIA Yard Drain Sump collects water from within the NIA and the surrounding areas via Catch Basin (CB) 5. The sewage treatment plant overflow is routed to the sump. On occasion the sump receives effluent from ground monitoring wells located in the NIA. The sump discharges to the Unit 2 outfall. Because portions of the area have a history of previous contamination, the sump discharge is required to be continuously monitored. The presence of ionic radioactivity, principally Cs-137, would indicate contamination of the normally non-contaminated rain water. The function of the monitor is to alarm on high radiation level and to terminate sump pump operation. The NIA Yard Sump monitor is comprised of an LPU and LDU which displays alarms and displays on the CDAS. 11.4.2.3 Area Radiation Monitoring

Three Area radiation monitors are in service;

2RE7850 located in the Unit 2 Fuel Handling Building

3RE7850 located in the Unit 3 Fuel Handling Building

2/3RE7851 located in the Control Room / Command Center All three area radiation monitors are standalone single channel area radiation monitors. They provide local strobe and audio alarming in addition to remote CDAS indication, status and alarming in the Control Room / Command Center.




11.4.3 CONTROL ROOM / COMMAND CENTER PANELS

The radiation monitoring system (RMS) instrumentation display and control equipment located in Control Room / Command Center control panels listed below. Control Room / Command Center Hallway Panels1

Panel 2L405 - Unit 2 RMS 2RI7865A1,B1,C1 Plant Vent Stack/ WR Rad Panel 2/3L104 - Common RMS 2/3RIC7808G Plant Vent Stack Radiation 2/3RIC7813 Radwaste Discharge Line Rad 2RIC7821 Turbine Sump Discharge Radiation Panel 3L405 - Unit 3 RMS 3RI7865A1,B1,C1 Plant Vent Stack WR Rad

11.4.4 RECORDERS

In-service radiation monitors output is displayed and trending data is on the Control Room / Command Center Data Acquisition System (CDAS). CDAS provides trend indications for the in-service radiation monitors. 11.4.5 INSPECTION, CALIBRATION AND MAINTENANCE

11.4.5.1 Maintenance

Plant radiation and effluent monitors are inspected, calibrated and maintained in accordance plant procedures to ensure ODCM compliance. 11.4.5.2 Calibration and Inspection

Plant radiation and effluent monitors are inspected, calibrated and maintained in accordance plant procedures to ensure ODCM compliance Table 11.4-1 provides the isotopes used for calibration. For the initial calibration, additional isotopes were used to verify the detector energy response. The calibration sources used, duplicate to the extent practicable, the source to detector geometry expected during normal operation.

1 NIA Yard Sump monitor 2/3RIC2101 is on the CDAS and not in hallway.




11.4.6 ROUTINE SAMPLING

The requirements of the system design bases for routine continuous and discrete sampling of radioactivity are satisfied by a system of liquid, gaseous, and airborne samplers, laboratory equipment for sensitive radiochemical analyses, and a program of procedures for obtaining and analyzing representative samples when and where appropriate in accordance with the requirements of the Offsite Dose Calculation Manual (ODCM). 11.4.6.1 Sampling Equipment and Procedures

The following text discusses representative procedures to be used as needed to meet requirements of the Offsite Dose Calculation Manual (ODCM). Actual procedures may vary provided that ODCM-established control and accuracy commitments are maintained. Sampling equipment and procedures are provided to assure that representative samples are obtained. Prior to sampling, batch liquid tanks such as radwaste tanks are properly isolated, recirculated, and sample lines purged to assure that individual samples are representative of the effluent mixture prior to discharge to the outfall. For the NIA Yard sump, proportional samples are taken manually from the sump itself. For continuous flow paths, such turbine plant sump, liquid proportional samplers are installed to assure that samples, representative of the effluent mixture, are collected during discharge to the outfall. During initial crediting of the release point in the ODCM, a series of samples were taken during the interval of discharge to determine whether any differences existed as a function of time and to assure that individual samples were indeed representative of the effluent mixture. Polyethylene collection bottles are used to preclude the loss of radioactive material by deposition on the walls of the sample container or volatilization of potentially volatile material. Plant Vent Stack ventilation stacks are continuously monitored for radioactive gases and sampled isokinetically in accordance with ANSI N13.1-1969 for particulates and iodines. The particulate and iodine samples are collected and analyzed once a week. Gas and tritium samples are collected and analyzed once a week. South Yard Facility Work Area effluent ventilation stacks are continuously monitored for particulates and sampled isokinetically in accordance with ANSI N13.1-1969 for particulates and iodines (see Section 11.2). The particulate and iodine samples are collected and analyzed weekly. Liquid composite samples are collected in proportion to the volume of each batch of effluent releases or in proportion to the rate of flow of the effluent stream. Prior to analysis, the composite is thoroughly mixed so that the sample is representative of the average effluent release. Gaseous particulate samples are mixed in proportion to the volume of release or in proportion to the rate of flow from each effluent pathway. Samples are composited and analyzed at an off-site facility in accordance with standard procedures. 11.4.6.2 Analytical Procedures

Samples of effluent gases and liquids are analyzed in accordance with plant procedures to meet the requirements of the ODCM.

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