ML17228A222
| ML17228A222 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie |
| Issue date: | 07/23/1993 |
| From: | FLORIDA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML17228A221 | List: |
| References | |
| NUDOCS 9308020158 | |
| Download: ML17228A222 (60) | |
Text
St. Lucie Unit 1 and Unit 2 Docket Nos.
50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation ATTACHMENT 1 ST.
LUCI UNIT 1 MARKED-UP TECHNICAL SPECIFICATION PAGES Pacaes 1-4 Insert g1 1-6 Insert g2 1-7 Insert g3 5-2
- 6-15
- Insert g4 Insert g4A, Insert g4B 6-16 6-22
- 6-23
- Insert g8 These pages were previously marked-up and submitted with Attachment 1 of FPL letter L-92-329, dated 1/22/93.
9308020158 930723 PDR ADQCK 05000335 P
DEFINITIONS IDENTIFIED LEAKAGE 1.15 IDENTIFIED LEAKAGE shall be:
a.
Leakage (except CONTROLLED LEAKAGE) into closed
- systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or b.
Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY LEAKAGE, or c.
Reactor Coolant System leakage through a steam generator to the secondary system.
LOW TEMPERATURE RCS OVERPRESSURE PROTECTION RANGE 1.16 The LOW TEMPERATURE RCS OVERPRESSURE PROTECTION RANGE is that. operating condition when (1) the cold leg temperature is
< 304'F during heatup on
~ 281'F during cooldown.and (2) the Reactor CooTant System has. pressure boundary Tntegrity.
The Reactor Coolant System does not have pressure boundary integiity when the Reactor Coolant System is open to containment and the minimum area of the Reactor Coolant System opening is greater than 1.75 square inches.
MEMBER S OF THE PUBLIC i~~ENBEltf&HI~&AIB~ad ~
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~~gggy 1.18 The OFFSITE DOSE CALCULATION MANUAL shall contain the current methodology and parameters used in the calculations of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm/trip setpoints, and shall include the Radiological Environ-mental-Sample point locations.
ST.
LUCIE - UNIT 1
Amendment No.$9,$ggg, Q.,
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1.17 Member of the Public shall mean an individual in a
controlled or unrestricted area.
- However, an individual is not a
member of the public during any period in which the individual receives an occupational dose.
DEFINITIONS RATED THERMAL POWER
',.25 RATED THERMAL POWER shall be a total reactor core heat transfer rate to the reactor coolant of 2700 MWt.
REACTOR TRIP SYSTEM RESPONSE TIME 1.26 The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until electrical power is interrupted to the CEA drive mechanism.
REPORTABLE EVENT 1.27 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.
SHIELD BUILDING INTEGRITY 1.28 SHIELD BUILDING INTEGRITY shall exist when:
a.
b.
C.
Each door is closed except when the access opening is being used for normal transit entry and exit; The shield building ventilation system is in compliance with Specification 3.6.6.1, and The sealing mechanism associated with each penetration (e.g.,
welds, bellows or 0-rings) is OPERABLE.
SHUTDOWN MARGIN 1.29 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full-length control element assemblies (shutdown and regulating) are fully inserted except for the single assembly of highest reactivity worth ',.
which is assumed to be fully withdrawn.
SITE BOUNDARY
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Awo R,c,IPLA~ m~ e ggggp y,y 1.31 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.
ST.
LUCIE - UNIT 1
1-6 Amendment No.t7,82,$ 9055
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INSERT g2 1.30 Site Boundary means that line beyond which the land or property is not owned,
- leased, or otherwise controlled by the licensee.
10EF INITIGNS I
ISTAGGEREO TEST BASIS
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A STAGGER O TEST BAS.S shall consist of:
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A test schedule for n systems, subsystems, trains or oc'er designated componen-s obtained by dividing the specified
- est interval into n equal suointervals, and b.
Tne testing of one system, subsystem, train or other designated comoonent at the beginning of each subinterval.
THER>tAL POWER I
) 1. 33 THERtAL POWER shal 1
be the total reactor core heat transfer rate to
~! the reactor coolant.
P I'
~ UNIOEHTIF IED LEAKAGE
',1.34 UNIDENTIFIED LEAKAGE shall be all leakage which is not IOENTIFIEO
,:LEAKAGE or CONTROLLED LEAKAGE.
/ I IJ iUNRESTRICTED AREA I
)UHRODOEO INTEGRATED RADIAL PEAKING FACTOR - Fr 1.36 The UNROOOED INTEGRATED RADIAL PEAKING FACTOR is the ratio of the peak pin power to the average pin power in an unrodded core, excluding tilt.
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LUCIE - UNIT 1
1-7 Amendment No. 5g ~Q, 109,
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INSERT g3 1.35 Unrestricted area means an area, access to which is neither limited nor controlled by the licensee.
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, Radius (0.97 mile) and. the Low'~opulation Zone (1 mile) are shown as beino the same size.
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ADM?NISTRATIVE CONTROLS 4DD +
{iv) Procedures for the recording and management of data, (v)
Procedures defining corrective actions for all off-control point chemistry conditions, and (vi)
A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action.
d.
Backu Method for Oeterminfn Subcoolin Mar in A program which will ensure the capability to accurately monitor the Reactor Coolant System subcooling margin.
This program shall include the following:
(i)
Training of personnel, and (ii)
Procedures for monitoring.
e.
Post-accident Sam lin A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions.
The program shall include.the following:
(i)
Training of personnel, (ii)
Procedures for sampling and analysis, and 5~<~
(iii) Provisions for maintenance of sampling and analysis
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6.9 REPORTING RE UIREMENTS ROUTINE REPORTS 6.9.1 In addition to.the applicable reporting requirements of Title-10, Code of federal'egulations, the following reports shall be submitted to the NRC STARTUP REPORT 6.9.1.1 A sumary report of plant startup and power escalation testing sha11 be submitted following (1) receipt of an operating license",
(2) amendment to the license involving a'lanned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel
- supplier, and (4) modifications 'that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant.
P ST.'UCIE - UNIT 1
6-15 Amendment No.+. 86
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0f ppL Radioactive Effluent Controls Pro ram flu.Isa A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably
'chievable.
The program (1) shall be contained in the
- ODCM, (2) shall be implemented by operating procedures, and (3) shall in-clude remedial actions to be taken whenever the program limits are exceeded.
The program shall include the following elements:
Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and set-point determination in accordance with the methodology in the
- ODCM, N
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5) oaves AND Monitoring, sampling, and analysis of radioactiv liquid and gaseous effluents in accordance with 10 CFR 2.
6 and with the ~,~
methodology and parameters in the
- ODCM, 30.
Aa>'imitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conform-ing to Appendix I to 10 CFR Part 50, Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radio-activity when the projected doses in a 31-day period would exawd 2 percent of the guidelines fop the annual dose or dose coaeitment conforming.Co"Appendix I to 10'FR Part 50, 4A eonfemkng-tea-d Append4-,,
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nd-the-RT~OUNBARY 8)
Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, 9)
Limitations on the annual and quarterly doses to a MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radio-.
nuclides in particulate fore with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix, I to 10 CFR Part 50, 10)
Limitations on the annual dose or dose coaeitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.
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INSERT 84A 2)
Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to ten times the concentration values in 10 CFR 20.1001 20.2401, Appendix B, Table 2, Column 2.
,.INSERT g4B 7)
Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at or beyond the SITE BOUNDARY shall be limited to the following:
a)
For noble gases:
Less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin, and b)
For Iodine-131, for Iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days:
Less than or egual to 1500 mrem/yr to any organ;
ADMINISTRATIVE CONTROLS 6.9.1.2 The startup report shall address each of the tests identified, in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a compari-son of these values with design predictions and specifications.
Any corrective actions that were required to obtain satisfactory operation shall also be described.
Any additional specific details required in license conditions based on other commitments shall be included in this report.
6.9.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest.
If the Startup Report does not cover all three events (i.e., initial criticality, completion of startup test program, and resumption or commencement of conmercial operation),
supplementary reports shall be submitted at least ever t
months until all three events have been completed.
PQQ ANNUAL REPORTS-Rmaeh 08KB 'Doss GewuA~V
'.9.1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year.
The initial report shall be submitted prior to March 1 of the year following initial criticality.
6.9.1.5 Reports required on an annual basis shail include a tabulation on an annual basis of th number of station, utility and other perso 1-inc u ing co ors receiving xpos res grea er an mre their associated man-rem exposure according to work and job functions, e.g.,
reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance),
waste processing, and refueling.
The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLO, or film badge measurements.
Small exposures totalling less than 20% of the individual total dose need not be accounted for.
In the aggregate, at least 80K of the total eceived from external sources should be assigned to specific mayor wor f nctions.
Annual reports shall also include the results of specific activity, analysis in which the
.".rimar y coolant exceeded the limits of S.ecification 3.4.8.
The following information shall be included:
,'i) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of the last DGI a'e P~O R.E'PLACE ~I~H Qfgg Dc@6 EQu<QALRHY sing e submittal may be made for a multiple unit station The submittal should combine those sections that are common to all units at the station.
2/
This tabulation supplements the requirements of f 10 CFR Part 20.
ST.
LUCIE - UNIT 1
6-16 Amendment No. gB,EP. PP, "o" DEI aTi=- WO.REVLeCK WW
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ADMINISTRATIVE CONTROLS
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'.12 HIGH RADIATION AREA 6.12.1 ieu of the "control device" or "alarm signal" reqpired by paragraph of 10 CFR Part 20, each high radiation area in which the intensit o
ra iat>on is greater than 100 mran/hr but less than 1000 mrem/h ha be barricaded and conspicuously posted as a high radiation area and entrance there-to shall be controlled by requiring issuance of a Radiation Work Permit (PWP)~.
Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
b.
C.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.
Entry into such areas with this monitoring device may be made after the dose rate level in the are'a has been established and personnel have been made knowledgeable of them.
A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the RWP.
6.12.2 In addition to the requirements of eci
.12 areas acces-sible to personnel with radiation levels su~a4~
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a be provi ed w t e
oors o prevent unaut orize en ry, an t e keys shall be maintained under the administrative control of, the Shift Foreman on duty and/or health physics supervision.
Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose-rate levels in the imnediate work area and the maximum allowable stay time for individuals in that area.
For individual areas accessibl rsonnel with radiat>on QJ 0
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are ocate w t n large a eas, such as R containment, w ere no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be roped off. conspicuously posted and a flashing light shall be activated as a
warning device.
In lieu of the stay time specification of the RWP, direct or,.
remote (such as use of closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.
Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiatio'n protection duties, provided they are otherwise fol-lowing plant radiation protection procedures for,entry into high radiation areas.
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ST.
LUCIE - UNIT 1
6-22 Amendment No. P/
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ADMINISTRATIVE CONTROLS 6.13 PROCESS CONTROL PROGRAM PCP i
see initiated changes to the PCP:
l.
Sha submitted to the Coamission in the Semiannual Efflue ase Report for the period in which the made.
Th s
ittal shall contain:
ive s) was l2eriaca.
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Sufficient d
fled information ly support the rationale for ange witho it of additional or supplemental info t
b.
A determination th h
e did not reduce the overall conformance of water resin to existing criteria for radio astes; and Co ation of the fact that the c ound acceptable by the FRG.
as been reviewed all become effective upon review and acceptance b
h RG.
'I 6.14 OFFSITE DOSE CALCULATION NNUAL ODCN censee initiated changes to the ODCN:.
be submitted to the Coaeission in the Semiannual Radf Ef Release Report for the period fn which the cha made e
ive.
This submittal shall contain:
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A determinat or relia tfons at the chang 1 not reduce the accuracy of dose calculatio setpoint determina-ntation of the fact that the change and found acceptable by the FRG.
een reviewed Suffic detailed information to tot upport the rationale he change without'ben additional or supplemental tion.
Info submitted should consist of a pa of those of the ODCN to be changed'ith each and provided with an approval and date box, er with appropriate analyses or evaluations )ust change(s);
Shall become effective upon review and acceptance by th ST.
LUCIE - UNIT 1 6-23 Amendment No. NAB~ 86
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Changes to the ODCM Shall be documented and records ofreviews performed shall be retained as required by Specification 6.10+. This documentation shall contain:
a)
Sufficient information to support the change together with the appropriate analyses or evaluations justifyingthe changes(s) and Q
Adetennitmtion that the change willmaintain the level ofradioactive effluent control required by 10 CFR 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adverse y unpact the accuracy or reliabilityofefflu'ent, dose, or setpoint calculations.
2.
Shall become effective after review and acceptance by the Facility Review Group and the apptovtd ofthe Plantganaget.
&c54ca l Q gtgtd Shall be submitted to the Commission in the form o complete, legible copy ofthe entire ODCM as a part ofor concurrent with the Sae&tual Radioactive Effluent Release Report forthe period ofthe report jn which any change to the ODCM was made. Each change shall be identified by markings in the margin ofthe affected pages, clearly indicating the area ofthe page that was changed, and shall indicate the date (e.g., month/year) the change was implemented.
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St. Lucie Unit 1 and Unit 2 Docket Nos.
50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation ATTACHMENT 2 ST.
LUCIE UNIT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES Pacaes 1-4 Insert ¹1 1-6 Insert ¹2, Insert ¹3 5-2
- 6-15
- Insert ¹4 Insert ¹4A, Insert ¹4B 6-16 6-17 6-22
- 6-23
- Insert ¹8 These pages were previously marked-up and submitted with Attachment 2 of FPL letter L-92-329, dated 1/22/93.
DEFINITIONS 0 LOW TEMPERATURE OVERPRESSURE PROTECTION RANGE -
RCS 1.16 The LOW TEMPERATURE OVERPRESSURE PROTECTION RANGE is that operating condition when tl) the RCS cold leg temperature is less than or equal to that specified in Table 3.4-3, and (2) the Reactor Coolant System is not vented to containment by an opening of at least 3.58 square inches.
DELETE. AAQ REPLfY U)M M656eV 4F MEMBER S OF THE PUBLIC
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~opposes-n&~ssorAa4eMMh-4he OFFSITE DOSE CALCULATION MANUAL ODCM 1.18 The OFFSITE DOSE CALCUL'ATION MANUAL shall contain the current methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm/trip setpoints, and shall include the Radiological Environmental Monitoring Sample point locations.
- 1. 19 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s),
and when all necessary attendant instrumentation, controls, electrical
- power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem,
- train, component or device to perform its function(s) are also capable of performing their related support function(s).
OPERATIONAL MODE - MODE l.20 An OPERATIONAL MODE (i.e.
MODE) shall correspond to any one inclusive "
combination of core reactivity condition, power level and average reactor coolant temperature specified in Table 1.2.
PHYSICS TESTS 1.21 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and (1) described in Chapter 14.0 of the FSAR, (2) authorized under the provisions of 10 CFR 50.59, or (3) otherwise approved by the Commission.
.'ST.'UCIE:" UNIT 2 Amendment No. ~< ~ N'. ".,6'.
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>A ~ \\ INSERT gl 1.17 Member of the Public shall mean an individual in a controlled or unrestricted area.
- However, an individual is not a
member of the public during any period in which the individual receives an occupational dose. DEFINITIONS SHUTDOWN MARGIN 1.29 SHUTDOWN MARGIN shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming all full-length control element assemblies (shutdown and regulating) are fully inserted except for the single assembly of highest reactivity worth which is assumed to be fully withdrawn. SITE BOUNDARY eeNe hieh<4e-head-i ~ i~A SOURCE CHECK ~ ~YB ANN l.NCG tsbl~ ggt45f g;P +3 1.31 A SOURCE CHECK shall be the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source. STAGGERED TEST BASIS 1.32 A STAGGERED TEST BASIS shall consist of: a. A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals, and b. The testing of one system, subsystem, train or other designated component at the beginning of each subinterval. THERMAL POWER 1.33 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant. UNIDENTIFIED LEAKAGE 1.34 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE. UNRESTRICTED AREA 1. e$-44964 44lG Qo gg,~~ g~Q QQg'~~ ~%~ /88697 4 S ST. LUCIE - UNIT 2 ~ * ~ 'aalu ~Ia It OQNO ~a~ << ~ ay ~ <<y aa<<p<<QAA&o ~ y. r 1l aa ~ a ba ~<< ~ ~ I<<e~ ~ ~ a - tataatr vI oeat +aoaa a~+a~ tt ~ ~ ~I aa I. ~ a ~ r ~ a a eaatt+' INSERT g2 1.30 Site Boundary means that line beyond which the land or property is not owned,
- leased, or otherwise controlled by the licensee.
INSERT g3 1.35 Unrestricted area means an area, access to which is neither limited nor controlled by the licensee. ni'l cvON N C Ol) cs L Tn Tjl O h0 Te Ill aO Ii) v 4 FPSL s PROPERTY LIN E /ye tj~ set Detail ~ t8, jcj I W Qj r~ j ~w ~e< +0 l CR r v T r TO Nl 4l>c ~ CJ O Um Zl O 0 .v + L 0 EXCLUSION AREA (0.97 mi) AND LOW POPULATION ZONE (I mi) NOTES: I) L-Liquid Radwaste Release Point 2) Due to the scale of the Figure the Exclusion Area Radius (0.97 mile) and the Low Population 2one (I mile) shown as 'n the same s e. UN IT I UNIT 2 i~i lI '. O. ~ ~ east&;. FPBL s PROPERTY LINE (h~~);I f:I v uNTv.i" gl ~~' ~r ~ g ~ l al( j ~ ~Iv ~I 0 'J ~ j ~ 9),,'r"'. Tj l 0 FLORIDA POWER 8 LIGHT COMPANY ST. LUCIE PLANT rn ~rv SCALE IN MILES SITE AREA MAP FIGVRE S.i-i ST. LUCIE - UNIT 2 5-2 ~ 4 /. ~ ' 'l:~sBY.'. ) 4 W AOMINISTRATIVE CONTROLS PROCEOURES ANO PROGRAMS (Continued) C. Seconda Water Chemist A program for monitoring of secondary water chemistry.to inhibit steam generator tube degradation. This program shall include: (i) Identification of a sajapling schedule for the critical variables and control points for these variables, (ii) Identification of the procedures used to measure the values of the critical variables, (iii) Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-leakage, (iv) Procedures for the recording and management of data, (v) (vi) Procedures defining corrective actions for all off-control point chemistry conditions, and A procedure identifying (a) the authority responsible for the. interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action. d. Backu Method for Oeterrainin Subcoolin Mar in e. A program which will ensure the capability to accurately monito~ the Reactor Coolant System subcooling margin. This program shall include the following: (i) Training of personnel, and (ii) Procedures for monitoring. Post-accident S lin A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous efrluents, and containment atmosphere samples under accident conditions. The program shall include the following: Xw5KB< g.g.q.V a~i (.8.'I.g. ST. LUCIE - UNIT 2 Amendment No 25 6-15 (i) Tr aining of personnel, (it), Procedures for sampling and analysis, and (iii) Provisions for maintenance of sampling and analysis equipment. p&(5E MsG~~ 4 "l,Ss~Y g~5sa g~ V+OGR, WPL. ~SQQ. ~~<L +gal o~ g~g t4ggg p>(,7. aor R. 7iac,F I: vise~ ~~i~g ~~~~ +~4'~~ ~9> MQuA) ggA9 tPBA DHl ~t, PCK-gf'-J xN~ERT <<4 p> g<~<~<~ q Oe VSL. L'll-3>'L Oars,o Radioactive Effluent Controls Pro ram >l>>les A program shall be provided conforming. with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably 'chievable. The program (1) shall be contained in the
- ODCM, (2) shall be implemented by operating procedures, and (3) shall in-clude remedial actions to be taken whenever the program limits are exceeded.
The program shall include the following elements: y~~ ) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and set-point determination in accordance with the methodology in the
- ODCM, 3) 4)
5) o~~~ ~~~+ n~~cHoact'fv ~~."H'& M t~NRERRunru p l t t Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 6 and with the ~~ methodology and parameters in the
- ODCM, lAL~
+ >o. Vga>'imitations on the annual and quarterly doses or dose commitmen to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conform-ing to Appendix I to 10 CFR Part 50, Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radio-activity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose comaitment conforming to Appendix I to 10 CFR Part 50, Ap M WCI 4~~~ ~.Mw IAh RV&BBIINBAR!" 8) Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents froN each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50,. 9) Limitations on the annual and quarter ly doses to a MBSER'OF THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radio-. nuclides in particulate form with half-,lives greater than 8 days in gaseous effluents released from each unit td area's beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, 10) Limitations on the annual dose or dose coeaitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190. J9". 9o g 1LQAQ~Atl n91 o~vo, ~ 4< -Cf"~ re z~f<gf t ~ 4 5 ~ t s l~ 1 8 e~ ~ ~ .C Cp + 4 AO ~%V tA Ãl'RAO ~u9.a9 ~lCM 4eff oX. + Cq ~ ~ ~ to ~ ~~ i. ~ s ~ er ~ a y ~iooo e ~ s t ~ + 0 ~ lyly\\ ~ ~ d'or ~ eg y ~ r v ~ ass os aa te ~ 0 ~ 1 4 ~ 0 ~ ~ t ~ 0 oa o INSERT 84A 2) Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to ten times the concentration values in 10 CFR 20.1001 20.2401, Appendix B, Table 2, Column 2. INSERT g4B 7) Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at or beyond the SITE BOUNDARY shall be limited to the following: a) For noble gases: Less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin, and b) For Iodine-131, for Iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to 1500 mrem/yr to any organ; AOHINISTRATIVE CONTROLS
- 6. 9 REPORTING RE UIREMENTS ROUTINE REPORTS 6.9. 1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the NRC.
STARTUP REPORT 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following (1) receipt of an operating license, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel
- supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant.
6.9. 1.2 The startup report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report. 6.9.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup -.eport does not cover all three events (i.e., initial criticality, completion "'tartup test program, and resumption or commencement of commercial operat:.n) supplementary reports shall be submitted at least every three months until all three events have = been completed. BOO ~ pggoALDESP Gosh FQLeNAL~~ 'NNUAL REPORTS-6.9. 1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to Harch 1 of the year following initial criticality. 6.9. 1.5 Reports required on an annual basis shall include: a. A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) eceivin exposure A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station. AAD RQ. MHoeh MoAggaigg ~y ~@~~ 'T. LUCIE - UNIT 2 6-16 Amendment No. ~ ~aors '~zgAtiugB 98oQ ~gOQpyglf fq' (HRluHM <ACv gee>o77A<M tvTo~~ >R OOA ADMINISTRATIVE ONTROLS ANNUAL REPORTS (Continued) greater than 100 mremslyr and their associated man"rem exposure according to work and job functions, e.g., reactor operations and 2/ surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20K of the individual total dose need not be accounted for. In the aggregate, at least 80K of the total received from external sources should be assigned to spec>>c major work functions. b. The results of specific activi ty analysis in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while the limit was exceeded and results of one analysis after the radioiodine activity was r educed to less than the limit. Each result should include date and time of sampling and the radioiodine concentra-tions; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Gr=ph of the I-131 concentration and one other radioiodine isotope . concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit. MONTHLY OPERATING REPORTS 6.9.1.6 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or safety valves, shall be submitted on a monthly basis to the
- NRC, no later than
-~e 15th of each month following the calendar month covered by the report. p6:.LSf6, @HO QRQU~M ~~~ QbSS E.Ques UKHV This tabulation supplements the requirements of 2/ of 10 CFR Part 20. OEU"M Axo RePLe5= ~GQ <QO,~go@ ST. LUCIE - UNIT 2 6-17 Amendment No. l8, )P, ~ g O'Dc@ -".DCSBQ QHA 9 fSJBO $ 42%/AkfkiPR BC~O W8Q f. 4 e ~@Le o~~h 8 F30 8~44 ~g" Qri~ 05.uk'. ANo SUAN w~VH ~ QQ.(40( (Q ~ AOHINISTRATIVE CONTROLS Aoo <<~~VILE,f)~ Q QfSfggCE Op so <~ (la 6.12 HIGH RADIATION AREA
- 6. 1
. 1 In lieu'he "control device" or "alarm signal" required by para-gra of 10 CFR Part 20, each high radiation area in which the intensi y of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)". Any individual or group of individuals permitted to enter such areas shall'e provided with or accompanied by one or more of the following: a. A radiation monitoring device which continuously indicates the radiation dose rate in the area. b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this. monitoring. device may be made after the dose rate level in the area has been" established and personnel have been made knowledgeable of them. c. A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the RWP. . 12.2 In addition to the requirements of S ecification 6. areas accessible Q to ersonnel with radiation levels 4e-bo hall be provided with locked oors to prevent unaut or ze
- entry, and the keys shall be maintained under the administrative control of the Shift Foreman on duty and/or health physics super-vision.
Ooors shall remain locked except during periods of access by personnel under an'approved RWP which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area. individual areas accessible to personnel with radiation level se ~~ 0<< RIE&erem ~ at are located within large areas, suc as conta nment, ~he~e po enc osure exists for purposes of locking, and no enclosure can be reason-ably constructed around the individual areas, then that area shall be roped off, conspicuously posted and a flashing light shall be activated as a warning device. In lieu of the stay time specification of the RWP, direct or remote (such as use of closed circuit TV cameras) continuous'urveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within. the area. shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they are otherwise following plant radiation protection procedures for entry into high radiation areas. DEBTS ST. LUCIE - UNI 2 -22 Amen ment No 13 MLEfC @NO QEfLACQ. ~~~ 1N gYC655 n'F Laoo N&N/AL e c.~ Q3'<n 889 LK55 JVWt4'OO RAW Hg. QT' WHEE 0 ~ 4Q ~ ~ ~ ~ ~ ~ ~A ~ t M+ ~ ~ ~ ~ AOWNIST 'Fit CONTROLS g 1 5 ~ ~6. 13 PROC:;CONTROL PROGRAM PCP ggPi" g,f ce uport the rationale nal or supplemental e inftfated changes to the PCP: Sh be submitted to the Coaaissfon fn the Semfannual Radioac ue Release Report for the perfod fn which the chan made. h ubmfttal shall contain: a. Sufffcfe fled information to t for the chan w ut benefit of information; b. A determfnatfon tha conformance of for radio v s a dfd not reduce the overall atere a sfn to existing crit'erfi, tes; and tfon of the fact that the chang nd acceptable by the FRG. n reviewed and 4 Shall become effective upon review and acceptance by the
- 6. 14 OFFSITE NSE 'CALCULATION MANUAL ODCM fce e fnftfated changes to the ODCM:
1 be submitted to the Comfssfon fn the Seafannual Radfoa v fl t Release Report for the period fn which the change s mad f fve. This submittal shall contain: g.<~+A +p456+~ ao Sufff t etailed information to total port the ratfonal ~ r change without benet o ddftfonal or supple-mental fhfo on. Information s should consist of a package of those es the 0 be changed with each page red. and provide val and date box, together th appropriate analys luations )ustffyfng the change(s); termination e change 1 t reduce the accuracy or ,,.: relfabflfty d calculations or tp t determinations; and c: D ation of the fact that the change has acceptable by the FRG. fewed and all become effective upon review and acceptance by the FRG. ~.', ST. LUCIE - UNIT 2 6-23 AllendSent go, ~~ ~ Vs ~ o Age]@ Wa.g Q J9$ "Cp- ) AB'llag 3Bva'> Jog '9o,84'3"-os&'2 gptpgg A9TlBJ y~Q-9a a8AQ rwsN y>P wo p.,g~p-J a ~ Changes to the ODCM: INSERT g8 Fttnlv\\ AgtteH'tttdNT +t nt FPL tN& L-8>-'O'L, OaeO Shall be documented and records ofreviews performed shall be retained as required by Speci6cation 6. 10+. This documentation shall contain: a) SuKcient information to support the change together with the appropriate analyses or evaluations justifying the changes(s) and 4 I C Q Adetetmittation that the change willmaintain the level ofradioactive efQuent control required by 10 40 CFR Part 190, 10 CFR 50.36a, and Appendix Ito 10 CFR Part 50 and not adversely impact the accuracy or reliabilityofeQluent, dose, or setpoint calculations. 2. Shall become effective after review and acceptance by the Facility Review Group and the apptnval nf the p!anrp1anagen / &gqecal Shall be submitted to the Commission in the f o a complete, legible copy ofthe entire ODCM as a part ofor concunent withthekesi!lnnual Radioactive EKuent Release Report forthe period ofthe report jn which any change to the ODCM was made. Each change shall be identi6ed by markings in the margin ofthe affected pages, cleariy indicating the area ofthe page that was changed, and shall indicate the date (e.g., month/year) the change was implemented. J'R qa,~ TtthlIMQA pnaH Qafqo @gal -4P "J 4BPN gp tcA;jt ~I ~~933 Q~rtl NQJ3Q ,go~/, et/~ N7/ M St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation ATTACHMENT 3 EVALUATION OF PROPOSED TS CHANGES St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 3 Page 1 of 5 EVALUATION OF PROPOSED TS CHANGES Introduc tion Florida Power and Light Company (FPL) proposes to modify the St. Lucie Units 1 and 2 Technical Specifications (TS) to support implementation of the new Standards for Protection Against Radiation, 10 CFR Part 20.1001 20.2401. The proposed TS changes and justification for each change are described in the following sections. Compliance with the new regulations is mandatory as of January 1, 1994. Units 1 and 2 1. Descri tion of Chan es For TS 1.17, delete the current definition of MEMBER(S) OF THE PUBLIC and replace it with the new definition as defined in Insert ¹1. For TS 1.30, delete the current definition of SITE BOUNDARY and replace it with the new definition as defined in Insert ¹2. For TS 1.35, delete the current definition of UNRESTRICTED AREA and replace it with the new definition as defined in Insert ¹3. Justification The proposed definitions of MEMBER(S) OF THE PUBLIC, SITE BOUNDARY and UNRESTRICTED AREAS are consistent with 10 CFR 20.1003. 2. Descri tion of Chan es In Figure 5.1-1, delete Note 3) in its entirety. Justification The areas described in Note 3) to Figure 5.1-1 no longer meet the definition of UNRESTRICTED AREA. These areas are considered by FPL to be CONTROLLED AREAS as defined in 10 CFR 20.1003. Therefore the note is unnecessary since all areas within the FPL property line are controlled. St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 3 Page 2 of 5 3. Descri tion of Chan es TS 6.8.4.f.2 is being revised to read as stated in Insert g4A. This change is being proposed to retain operational flexibility consistent with 10 CFR Part 50, Appendix I, concurrent with the implementation of the revised 10 CFR Part 20. Justification The current requirements for the content of St. Lucie's TS concerning radioactive effluents are contained in 10 CFR 50.36a. Section 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluents to unrestricted
- areas, produced during normal reactor operations, to levels that are as low as reasonably achievable (ALARA).
For power reactors, Appendix I to 10 CFR Part 50 contains the numerical guidance to meet the ALARA requirement. The dose values specified in Appendix 'I of 10 CFR Part 50 are small percentages of the implicit limits in 10 CFR 20.106 and the explicit limits in 10 CFR 20.1301. As secondary
- controls, the instantaneous dose rates required by this TS were chosen by the NRC staff to keep annual average releases of radioactive material in gas'eous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part 50.
For the purpose of this TS, 10 CFR Part 20 is used as a source of reference values only. These TS requirements allow operational flexibility, compatible with considerations of health and
- safety, which may temporarily result in release rates which, if continued for the calendar
- quarter, would temporarily result in radiation doses higher than specified in Appendix I of 10 CFR Part 50.
- However, these releases are within the implicit limits in 10 CFR 20.106 and the explicit limits in 10 CFR 20.1302 which references Appendix B, Table II, concentrations.
These referenced concentrations in the old 10 CFR Part 20 are specific values which relate to an annual dose of 500 mrem. The liquid radioactive effluent concentration limits given in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 20.2401 are based on an annual dose of 50 mrem total effective dose equivalent. Since a release concentration corresponding to a dose rate of 500 mrem/year has been acceptable as a TS limit for liquid effluents, which applies at all times to assure that the values in Appendix I of 10 CFR Part 50 are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of ten. The operational history of the St. Lucie Plant has demonstrated that the use of the concentration values associated with 10 CFR 20.106 as TS limits has resulted in calculated maximum individual. doses to a member of the public that are small percentages of the values given in Appendix I of 10 CFR Part 50. Therefore, the use of effluent concentration values that are ten times those listed in Appendix B, Table 2, Column 2 St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 3 Page 3 of 5 to 10 CFR 20.1001 - 20.2401 should not have a negative impact on the ability to continue to operate within the design objectives in Appendix I of 10 CFR Part 50 and 40 CFR Part 190. 4. Descri tion of Chan e In Section 6.8.4.f.3, the reference to 20.106 will be replaced with 20.1302. Justification This change is administrative in nature and represents the proper reference to the revised-10 CFR 20. 5. Descri tion of Chan es TS 6.8.4.f.7 is being revised to read as stated in Insert g4B. This change is being proposed to retain operational flexibility consistent with 10 CFR Part 50, Appendix I, concurrent with the implementation of the revised 10 CFR Part 20. Justification The current requirements for the content of St. Lucie's TS concerning radioactive effluents are contained in 10 CFR 50.36a. Section 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluents to unrestricted
- areas, produced during normal reactor operations, to levels that are as low as reasonably achievable (ALOD.).
For power reactors, Appendix I to 10 CFR Part 50 contains the numerical guidance to meet the ALARArequirement. The dose values specified in Appendix I of 10 CFR Part 50 are small percentages of the implicit limits in 10 CFR 20.106 and the explicit limits in 10 CFR 20.1301. As secondary
- controls, the instantaneous dose rates required by this TS were chosen by the NRC staff to keep annual average releases of radioactive material in gaseous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part 50.
For the purpose of this TS, 10 CFR Part 20 is used as a source of reference values only. These TS requirements allow operational flexibility, compatible with considerations of health and
- safety, which may temporarily result in release rates which, if continued for the calendar
- quarter, would temporarily result in radiation doses higher than specified in Appendix I of 10 CFR Part 50.
- However, these releases are within the limits specified in 10 CFR 20.106 (20.1302).
This specification, based on the guidance contained in NUREG-0133, should be acceptable as a TS limit for gaseous effluents which applies at all times as an assurance that the values in Appendix I of 10 CFR C. St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 3 Page 4 of 5 Part 50 are not likely to be exceeded. The proposed TS change does not revise the dose rate limits as implemented by the St. Lucie Offsite Dose Calculation Manual. Therefore, the use of the proposed TS will not have a negative impact on the ability to continue to operate within the design objectives in Appendix I of 10 CFR Part 50. 6. Descri tion of Chan es In TS 6.9.1.5, add the words "for whom monitoring was required" after the words "(including contractors)" and add the words "Annual Deep Dose Equivalent" after the word "receiving". Delete "whole body dose" and replace it with "Deep Dose Equivalent". In footnote 2/, the reference to 20.407 will be replaced with 20.2206. Justification Regulatory Guide 1.16, Appendix A, explicitly describes the individual workers who need to be monitored and included in the annual report. The addition of the
- words, "for whom monitoring was required",
is being proposed to clarify that not all personnel on the plant site are, or need to be, included in the annual report. The addition of this phrase is consistent with the new 10 CFR Part 20. The addition of the
- words, "annual deep dose equivalent",
is being proposed to clarify the type of dose that is reportable in the annual report. Deep dose equivalent is a term defined in the new 10 CFR Part 20 that specifically represents the type of dose that is referred to in TS 6.9.1.5 of the St. Lucie Unit 1 and Unit 2 Technical Specifications. Deleting the words, "whole body dose", and replacing it with the words, "deep dose equivalent", is proposed to properly clarify the type of dose that is reportable in the annual report. Deleting the reference to 20.407 and replacing it with 20.2206 will represent the proper section in the new 10 CFR Part 20. 7. Descri tion of Chan es In TS 6.12.1, delete the reference to 20.203(c)(2) and replace it with 20.1601(a) Within the same
- sentence, add the words "measured at a
distance of 30 cm (12 in)" after "1000 mrem/hr" and before the words "shall be". St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 3 Page 5 of 5 Justification Deleting the reference to 20.203(c)(2) and replacing it with 20.1601(a) will represent the proper section in the new 10 CFR Part 20. The addition of the words, "measured at a distance of 30 cm (12 in)", is proposed to make the measurement distances consistent with the definition of high radiation area, as defined in 10 CFR 20.1003. 8. Descri tion of Chan es In TS 6.12.2, delete the words "such that a major portion of the body could receive in one hour a dose greater than 1000 mrem", and replace it with, "in excess of 1000 mrem/hr at 30 cm (12 in) and less than 500 rads/hr at 1 meter". In the same paragraph, delete the words, "such that a major portion of the body could receive in one hour a dose in excess of 1000 mrem**", and replace with, "in excess of 1000 mrem/hr at 30 cm (12 in) and less than 500 rads/hr at 1 meter". Delete the footnote at the bottom of page 6-22, "**Measurement made at 18 inches from the source of radioactivity." Justification The proposed changes incorporate the measurement distance prescribed for dose rates consistent with High Radiation Areas per 10 CFR 20.1003. A
- limiting, maximum dose rate for application of TS 6.12.2 is also proposed which is compatible with the new classification of "Very High Radiation Area".
Measures previously found acceptable for High Radiation Area access control will thereby be distinguished from the additional controls required for Very High Radiation Areas pursuant to 10 CFR 20.1602. 9. Descri tion of Chan es FPL letter L-92-329, dated January 22, 1993, proposed that the existing parts 1 and 2 of TS 6.14, OFFSITE DOSE CALCULATION MANUAL, be deleted and replaced with Insert g8. For TS 6.14.1.b, as shown in Insert N8, 20.106 will be deleted and replaced with 20.1302. Justification Deleting the reference to 20.106 and replacing it with 20.1302 will represent the proper section of the new 10 CFR Part 20. St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation ATTACHMENT 4 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION o St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 4 Page 1 of 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10 CFR 50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an 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. Each standard is discussed as follows: (1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated. Revisions to the St. Lucie Units 1 and 2 Technical Specifications, proposed in this submittal, are consistent with the regulations of the new 10 CFR Part 20. The 'changes being proposed are administrative in nature to revise definitions, 10 CFR 20 references and area classifications. These changes are necessary to ensure compliance with the new 10 CFR Part 20 requirements. Assumptions, methods and conclusions contained in the plant safety analyses have not been altered. Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated. (2) Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed amendment will not change the physical plant, the configuration or method of operation of any plant equipment or the modes of plant operation defined in the Facility License. Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of New Standards for Protection A ainst Radiation L-93-144 Attachment 4 Page 2 of 2 (3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety. The changes proposed to the St. Lucie Unit 1 and 2 Technical Specifications are administrative in nature and assure compliance with the new 10 CFR Part 20. The existing levels of radiological control will not be reduced by these proposed changes and compliance with applicable regulatory requirements governing radioactive effluents and radiological environmental monitoring, including 10 CFR 50.36a, 10 CFR 50, Appendix I and 40 CFR 190, will continue to be maintained. Specifications provided to establish or maintain margins of safety have not been changed. Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety. Based on the discussion presented above and on the supporting Evaluation of Proposed TS Changes, FPL has concluded that this proposed license amendment involves no significant hazards consideration.