JSP-529-92, Application for Amend to License NPF-62,changing TS to Support Compliance W/New Requirements of 10CFR20,to Reflect Implementation of Radiation Protection Program

Application for Amend to License NPF-62,changing TS to Support Compliance W/New Requirements of 10CFR20,to Reflect Implementation of Radiation Protection Program

ML20115G024
Person / Time
Site:	Clinton
Issue date:	10/16/1992
From:	Jamila Perry ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115G027	List: JSP-529-92, Application for Amend to License NPF-62,changing TS to Support Compliance W/New Requirements of 10CFR20,to Reflect Implementation of Radiation Protection Program ML20115G028
References
JSP-0529-92, JSP-529-92, U-602052, NUDOCS 9210230315
Download: ML20115G024 (6)

Text

_ _ - _ __ _ _ _

luno4 Power Company e . e ,- .

Chnten Power Staten

.D .6, P O. Box 078 -

c' - ' .

Clinton,IL. 61727

., Te! 217 935-0226 '

_, Fax 217 935-4632 J. Stephen Perry . _ .

Senor Vtee Presidet ILLIN915 P4WER w6 2032 L47-92 (10-16)LP 8E.100a 10CFR50.90 Docket No. 50-461 JSP-0529-92 October 16, 1992 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Proposed Amendment of Facility. ~

Operatine License No. NPF-62

Dear Sir:

Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies'for amendment of Facility Operating License No. NPF-62, Appendix A' Technical Specifications, for Clinton Power Station (CPS), This request consists of proposed changes-to the CPS Technical Specifications to support' CPS compliance with the new requirements of Title 10 Code of Federal Regulations:Part 20 These proposed changes are necessary to reflect implementation of-the CPS Radiation Protection-Program.in accordance with 10CFR20.1101. A description of the proposed changes, the associated justifications (including a basis for-No Significant Hazards Consideration), and a marked-up copy'of the affected pages of the current Technical-Specifications are provided in Attachment 2.

.In addition, an affidavit supporting the facts _ set forth in thistletter and-its attachments 1s provided in Attachment 1.

CPS'is currently scheduled to fully-implement the requirements of the new 10CFR20 on April 1, 1993. Therefore, _IP requests that the license  !

amendment be approved p: lor t.c April 1, 1993, but'not be required-to be implemented until thr.c date.

-IP has reviewed the proposed change against the criteria of 10CFR51.22.

for categorical exclusion from_ environmental impact considerations. .The proposed c.hanges do not _ involve _ a significant hazards consideration, or.

significantly. increase the ataounts or change the - types of . effluents that may be-released offsite, nor do they significantly increase individual or-cumulative occupational rediation exposures, . Based on the; foregoing,~IP concludes the proposed changes meet the criteria given in 10CFR51.22(c)(9) for-a categor; cal exclusion from the requirement for an Environmental Impact -

Statement.

Sincerely yours, j

'NL S, Perry Mg S.nior Vice esident ,

9210230315 921016 een noom 03000461 ('

p PDR 3h -

] .

U-602052

, 1/,7-92(10-16)LP 4 8E.100a TAB /msh Attachments cc: NRC Clinton Licensing Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety w

,'* Attachment 1 to U- 602052 STATE OF ILLINDIS COUNTY OF DEVITT J. Stephen Perry, being first duly sworn, deposes and say.,:

That he is Senior Vice President of Illinois Power Company; that the application for amendment of Facility Operating License NPP-62 has been prepared under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said application and the facts contained therein are true and correct.

DATE: This 14 day of October 1992

~

Signed /

[

J(StephenPer v

Subscribed and sworn to before me this .O day of October 1992.

, _ : :::::::::::::: z ::::, ,

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Not Public g

Notny PuNir, State of IUinois  ;;

My Commission Expires 5/11/96 l

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. I

.,- 4 Attachmeat 2

. . to U-602052 LS-92 001 Page 1 of 16 nacktround On May 21, 1991,- the Nuclear Regulatory Conunission (NRC) issued a-revision to its standards for protection against ionizing radiation, 10CFR Part 20. The purpose of the revision to 10CFR20'was to modify the NRC's radiation protortion standards to reficct developments in the principles-and scientific knowledge underlying radiation protection and to reflect changes in the besic philosophy of radiation protection. In addition, the revision addresses International Radiation Protection Standards in order to achieve a better level of unitormity with the requirements of other nations.

Revised Part 20 became effective on June 20, 1991; however, in accordance with more recent provisions, licensees inay defer implementation of the revised rule until January 1,1994. In accordance with section 20.1008(b), "[alfter the time the licensee implements-20,1001-20.2401, the applicable section of 20.1001-20.2401 shall be used a lieu of any section in 20.1 20.601 of this part that is cited in t h mse conditions or Technical Specifications, except as specified in p .. graphs (c), (d) and (e) of this section." Notwithstanding, this request involves proposed changes to CPS Technical Specifications to-reflect implementation of the revised Part 20 at CPS.

Description of Proposed Channes In accordance with 10CFR50.90, the following changes to the CPS Technical Specifications are being proposed:

t 1. Definitions 1.24, MEMBER (S) OF THE PUBLIC,_and 1.4S, UNRESTRICTED AREA, are being revised to conform to the definitions of these terms as provided in section 20.1003.

2. Technical Specification 6.8.4.f is bein5 revised to provide proper references to-10CFR20 as a result of-the-new section numbers.

i Specifically, Specifications-6.8_4.f.2 and 7 are being revised to l

reference Appendix B. Table 2 as' opposed to the currently

~

referenced Table II, and Specification 6.8.4,f.3 is being revised l, 'to reference 10CFR20.1302 as opposed to-10CFR20.106. 1

3. Note "*" of Technical Specification 6.9.1.5.a is being revised to reference section 20.2206 vice section 20.407.

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4. Technical Specification 6.10.2.f is being deleted and moved to 6.10.3.o. The remaining items in Specification 6.10,2 are being.-

relettered as appropriate.

5. Technical Specification 6,10.3.c-_is being revised'to provide clarification consistent with the requirements in the revised 10CFR20. Specifically, the revision requires retention of dose records only for those individuals for whom monitoring is required as opposed to all individuals who enter radiation control areas as is_ currently identifled.

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Attachmsnt 2 to U-602052 LS-92-001 Page 2~of 16

6. Technical Specification 6.12.1 is being revised to reference paragraph 20.1601 as opposed to the current reference of 20.203(c)(2).

7. Technical Specifications 6.12.2 and 6.12.3 are being revised to provide wording consistent with the definition-ot hi Sh radiation-area as provided in section 20.1003,

8. Technical Specification 6.14.a.2 is being revised to reference 10CFR20.1302 as opposed to 10CFR20.106,

9. In addition to the above changes, the Bases section for Technical Specification 3/4.7.7 is being revised to reference Appendix B, i Table 2 as oppos. to the currently-referenced Table II. l 1

Justification For Proposed Channes In accordance with 10CFR20.1101, IP is required to "... develop, document and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part." Revision of the CPS Technical Spec!fications is required to ensure consistency with the requirements in 10CFR20 and is part of t he CPS program to implement revised Part 20.

Upon issuance of Amendment 40 to the CPS Operating License. IP completed its impleme.'tation of Cencric Letter 89 01, " Implementation of Programmatic Controls for .adiological Effluent Technical Specifications in the Administrative Controts Section of the Technical Specifications and the Relocation of Procedural Details of RETS ' to the Offsite Dose Calculation Manual or to the Process Control Program." The implementation of Ceneric Letter 89-01 resulted in the relocation of portions of the Radiological Effluent Technical Specifications'(RETS) involving radioactive effluent monitoring. instrumentation, the control-of liquil and gaseous' effluents, equipment requirements for liquid and:

gaseous effluents, radiological environmental monitoring, and radiological reporting details from the Technical Specifications to the Offsite Dose Calculation Manual (ODCM). As a result, the impact of revised 10CF.120 on the CPS Technical Specifications is primarily limited to the -revision of definitions and the correction of references- to conform to-the new or renumbered sections of 10CFR20. .In addition,' the-Technical Specifications will be revised to recognize,the new monitoring and record-keeping requirements as identified in 10CFR20. This overall' change to,the CPS. Technical Specifications does not alter any of IP's requirements or r. ponsibilities for protection of the_public and employees against radiation hazards. Consequently, this change is editorial only.

Basis for No SInnificant Hazards Consideration In accordance with 10CFR50.92, a proposed change to the Operating License (Technical Specifications) involves no significant hazards considerations if operation of the fa ility in accordance with the proposed change would not: (1) invoh e a significant increase in tae

Attechmsnt 2 to U-602052-LS-92 001 Page 3 of-16 proposed change would not: (1) involve a significant increase in the probability or consequences of any accident previously evaluated,_or (2) create the possibility of a new or different kind of accident from any .

accident previously evaluated, or (3) involve a significant reduction in a margin of safety. The proposed change is evaluated against each of these criteria below:

(1) The proposed changes only consist of revisions to 10CFR20 references to recognize-the now section numbers, definitions to ensure consistency with 10CFR20, and administrative controls for record keeping to maintain compliance with the new Part 20. Since these are editorial changes which do not impact the operation or design of any plant structures, systems or components, this proposed change cannot increase the probability or the -

consequences of any accident previously evaluated.

_(2) The proposed changes are editorial only and do not affect the plant design or operation. As a result, this proposed change.

cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) The proposed changes are editorial in nature and do not affect the plant design or-operation. The changes will not increase the amounts or change ths types of effluents that may be released offsite, nor do they significantly increase individual or cumulative. occupational radiation exposures. These' changes only ensure compliance with revised 10CFR20. These changes do not alter any of the requirements or responsibilities for protection of the public and employees against radiation hazards. As a result, these changes cannot reduce a margin of safety.

Based upon the foregoing, IP concludes that these proposed changes - do not involve a significant hazards consideration.

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