ML20035F239
| ML20035F239 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/14/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20035F240 | List: |
| References | |
| NUDOCS 9304210071 | |
| Download: ML20035F239 (6) | |
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Consumers l
Power Patrick M DonneHy Mont Manager MPWHtNWE e
MnUNGAhrs MtlNiRL55 Big flock Point Nuclear Plant.10269 US-31 North, Charlevout MI 49720 April 14, 1993 t
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Nuclear Regulatory Commission i
l Document Control Desk i
Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
ADNINISTRATIVE CONTROL.10 CFR PART 20 - REVISION 1 At the request of the Office of Nuclear Reactor Regulation Big Rock Point Project i
Manager, a format revision to the original Technical Specification Change Request dated March 4,1993, is being submitted. This revision is expected to assist the l
Project Manager with.the review and approval of this change request.
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Patrick M Donnelly Plant Manager l
l CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point ATTACHMENT r
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190160 l
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L 9304210071.930414 k) l PDR-ADOCK 05000155 p
FDR A Gt5ENERGYCOMPAAfY
4 CGNSUMERS POWER COMPANY Docket 50-155 Request for Change to the Technical Specifications License DPR-6 i
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l For the reasons hereinafter set forth, it is requested that the Technical i
Specifications contaire: in the Facility Operating License DPR-6, Docket 50-155, issued to Consumers h er Company on May 1, 1964, for the Big Rock Point Plant be changed as descried in Section I be'ow:
l I. CHANGES The Technical Specification changes proposed herein are in conjunction with the scheduled January 1,1993 implementation of the revised 10 CFR l
20 (20.1001 - 20.2401) at Big Rock Point Plant.
The specific Technical Specifications changes are:
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A.
Revise d.3.2 of the Administrative Controls section from Chemistry and Radiation Protection Supervisor to Radiation Protection Supervisor. This reflects a change of title due to a separation of Chemistry and Radiation Protection responsibilities (Tech Spec Page 74).
B.
Change the reference in 6.12.1 from paragraph "20.203(c)(2)" to "20.1601(a)." Also change 6.12.1 and 6.12.2 from "1000 mR/h at 45 cm (18 in)" to "1000 mrem /h at 30 cm (12 in)" and "1000 mR/h" to "1000 mrem /h" (Tach Spec Pages 89 and 90).
C.
Change 13.1.2.1 from " Table II" to " Table 2" and from "2 x 10*" to 4
'1.4 x 10 ". Also change the bases for 13.1.2.1 to agree with the j
new 10 CFR 20 (Tech Spec Page 133).
C.
Change the bases for 13.1.3.1 to agree with the new 10 CFR 20 (Tech Spec Pages 134 and 135).
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E.
Change the reference in the action section of 13.1.6.1 from i
"20.405c" to "20.2'03(4)".
Also change the reference in the bases for 13.1.6.1 from *20.405c" to "20.2203(4)" (Tc ch Spec Pages 142 and j
143).
II. DISCUSSION Change,'. reflects a title change from the Chemistry and Radiation Protection Supervisor to Radiation Protection Supervisor. This is required because a separation of Chemistry and Radiation Protection responsib lities has occurred at the facility.
Change B. through E. are directly related to the requirements of the new 10 CFR Part 20 (20.1001-20.2401).
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NUCLEAR REGULATORY COMMISSION 2
B.IG ROCK POINT PLANT TECH SPEC CHANGE REQUEST - 10 CFR 20 - Revision HIGH RADIATION AREA The revised 10 CFR 20 definition of a high radiation area specifies that i
the dose of 100 mrem in one hour be measured at "30 centimeters from the l
radiation source or from any surface that the radiation penetrates." The Big Rock Point Technical Specifications specify a distance of "45 centimeters from the radiation source or from any surface which the radiation penetrates." The change of distance to "30 centimeters" (12 inches) is more conservative, providing a higher degree of protection for occupationally exposed workers.
The change from "mR/h" to mrem is solely a change in terminology since l
the revised 10 CFR 20 does not recognize or define the roentgen as a unit of radiation.
LIQUID EFFLUENTS CONCENTRATION This section and the associated bases is changed to agree with the i
revised 10 CFR 20. Maximum Permissible Concentration (MPC) terminology l
has been replaced with " Effluent Concentration". Most of the effluent concentrations have changed to reflect new scientific information and a i
change in the public dose limit from 500 mrem to 50 mrem.
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The limit for dissolved and entrained noble gases was changed from 2 x 10'to 1.4 x 10* microcuries/ml simply by r.ioning the old MPC for j
Xenon-135 and the new effluent concentration for Xenon-135 since this is the controlling radioisotope as explained in the bases.
l Effluent alarm setpoints were reviewed to determine any necessary changes and were found to be set appropriately.
No change will be necessary.
I The changes described above reflect lower effluent concentrations and therefore result ir a greater degree of protection to the general public.
Annual permissible doses to the public from plant effluents are actually based on 10 CFR 50, Appendix I limits, which have not changed.
GASE0US EFFLUENTS DOSE RATE The actual instantaneous dose r ate limits of this section have not chanaed. However, the bases section has. Under the former 10 CFR 20, these dose rates correspond roughly to the maximum permissible concentration and dose (s) received by the maximum exposed member of the i
public if allowed to continue for an entire year. These limits are used more as instantaneous limits (dose rates above which are not allowed to continue for more than one hour at a time) so as to provice assurance not l
to exceed 10 CFR 50, Appendix I limits. The first set of Questions and Answers on the new Part 20 published by the NRC supparts the bases in f
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NUCLEAR REGULATORY COMMISSION 3
BIG ROCK POINT PLANT TECH SPEC LHANGE REQUEST - 10 CFR 20 - Revision which they state, "The instantaneous release rate limits for airborne releases will not be changed because they are imposed on licensees as a control to ensure that licensees meet Appendix I requirements."
Alarm setpoints for these dose rate limits may change slightly due to changes in scientific data and will be reviewed and changed as appropriate prior to implementation, j
TOTAL DOSE Only reference changes have been made to this section and the bases for this section.
l III. ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION 1
Consumers Power Company finds, in compliance with 10 CFR 50.92(c), that activities associated with this change request involve no significant hazards. The following evaluation supports that finding.
1.
Will the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
This proposed change does not affect the probability or consequysces of an accident. The prorosed change is to the ADMINISTRATIVE and RADIOLOGICAL EFFLUENT RELEASES sections of the facility Technical Specifications, and are administrative in nature.
Change "Chemi st ry and Radiation Protection Supervisor" to
" Radiation Protection Supervisor."
The change from "mR/h" to mrem is solely a change in terminology since the revised 10 CFR 20 does not retagnize or define the roentgen as a unit of radiation.
The Liouid Effluents Concentration section and the ass iciated bases have been revised to conform with the revised 10 CFR Part
- 20. Maximum Permissible Concentration (MPC) terminclogy has been replaced with " Effluent Concentration".
l The actual instantaneous dose rate limits of the Gaseous Effluents Dose Rate section have not changed. However the bases section has. Under the former 10 CFR 20, these dose rates correspond roughly to the maximum permissible concentration and dose (s) received by the maximum exposed member of the public if allowed to continue for an entire year. ' These limits are used more as instantaneous limits (dose rates above which are not l
allowed to continue for more than one hour at a time) so as ta L
NUCLEAR REGULATORY COMMISSION 4
B'IG ROCK POINT PLANT l
TECH SPEC CHANGE REQUEST - 10 CFR 20 - Revision 4
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provide assurance not to exceed 10 CFR 50, Appendix I limits.
2.
Will the proposed change (s) create the possibility of a new or different kind of accident from any accident previously evaluated?
This proposed change is required by the implementation of the new 10 CFR Part 20 requirements (except for the title change) and are administrative in nature. Neither the material condition of the facility nor the accident analyses are affected by this proposed change.
Therefore, the proposed change does not create the possibility of a different type of accident than previously evaluated.
3.
Will the proposed change involve a significant reduction in the margin of safety?
Each limit that was affected increased the margin of safety by making the limit more conservative; or remained the same.
The change of distance to "30 centimeters" (12 inches) is more conservative, providing a
higher degree of protection for occupationally exposed workers.
Most of the effluent concentrations have changed to reflect new scientific information and a change in the public dose limit from 500 mrem to 50 mrem.
f The limit for dissolved and entrained noble gases was changed from 2 x 10* to 1.4 x 10* microcuries/ml. The changes described above reflect lower ef fluent concentrations and therefore result in a greater degree of protection to the general public.
Effluent alarm setpoints were reviewed to determine any necessary changes and were found to be set appropriately. No change will be necessary.
"The instantaneous release rate limits for airborne releases will not be changed because they are imposed on licensees as a control to ensure that licensees meet Appendix I requirements." Alarm setpoints for these dose rate limits may change slightly due to changes in scientific data and will be reviewed and changed as appropriate prior to implementation.
Therefore, the proposed change does not involve a reduction in the margin'of safety.
4 NUCLEAR REGULATORY COMMISSION 5
BIG ROCK POINT PLANT TECH SPEC CHANGE REQUEST - 10 CFR 20 - Revision i
1 IV.
CONCLUSION The Big Rock Point Plant Review Committee has reviewed this Technical l
Specification Change Request and has determined. this change does not involve an unreviewed safety question and, therefore, involves no significant hazards consideration. This change has been reviewed by the Nuclear Performance Assessment Department. A copy of this Technical i
l Specification Change Request has been sent-to the State of Michigan I
official designated to receive such Amendments to the Operating License.
i CONSUMERS POWER COMPANY l
To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.
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By y
David P Hoffman, Vice es e Nuclear Operations Sworn and subscribed to before me this 13th day of April 1993.
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Notary /ublic
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Jackson County, Michigan BEVERLY A AVcKY My commission expires NOTARY PUBLIC STATE OF MICIUGAN JACKSON COUNTY
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MY COMMISslON EXP. DFC. 3.1996 i
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(SEAL)
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