ML20044B858
| ML20044B858 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/04/1993 |
| From: | SOUTHERN NUCLEAR OPERATING CO. |
| To: | |
| Shared Package | |
| ML20044B857 | List: |
| References | |
| NUDOCS 9303110004 | |
| Download: ML20044B858 (19) | |
Text
{{#Wiki_filter:ll l .i t Attachment I Proposed Changes to the Farley T' d'.s I and 2 Technical Specifications t i i t .h31 o4 930304 P CK 0500034g PDR
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ADMINISTRATIVE CONTROLS reasonably achievable. The program (1) shall be contained in the 00CM, (?) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements: i) Limitations on the operability of radioactive liquid and i gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM,
- 11) Limitations at all times on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to ten times the concentrations stated in 10 CFR i
Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 2, iii) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM, i iv) Limitations 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 conforming to Appendix I to 10 CFR Part 50, v) Determination of cumulative and projected dose contributions j from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology j and parameters in the ODCM at least every 31 days, vi) 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 T_nsert releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I 1 to 10 CFR Part 50, vii)^ Limitat' ion at 11 ti s on 'e co entrat ns of dioact mate /t al ele ed i gase s eff ents t areas yond t sigeb ndar con in o te imes e conc tratiop ptat in CF art , Ap ndix to par raphs .1001 - '20. 401) Tabl 2, C umn
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vii) Limitations on the dose rate resulting from radioactive '?g material released in gaseous effluents from the site to areas at and beyond the site boundary as follows: a. For noble gases: Less than or equal to a dose rate of 500 mrem / year to the total body and less than or equal to a dose rate of 3000 mrem / year to the skin, and b. For Icdine-131, Iodine-133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to a dose rate of 1500 mrem / year to any organ. l l l
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t ADMINISTRATIVE CONTROLS reasonably achievable. The program (1) shall be contained.in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to t.e taken whenever the program limits are exceeded. The program shall include the following elements-l i) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM, ii) Limitations at all times on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to ten times the concentrations stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 2, iii) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM, iv) Limitations 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 conforming to Appendix I to 10 CFR Part 50, v) 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, vi) 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 radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for i the annual dose or dose commitment conforming to Appendix I i to 10 CFR Part 50, vii) Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at and beyond the site boundary as follows: a. For noble gases: Less than or equal to a dose rate of 500 mrem / year to the total body and less than or equal to a dose rate of 3000 mrem / year to the skin, and t b. For Iodine-131, Iodine-133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to a dose rate of 1500 mrem / year to any organ. FARLEY-UNIT 1 6-15a AMENDMENT NO.
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s ADMINISTRATIVE CONTROLS reasonably achievable. The program (1) shall be contained in the 00CM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:
- 1) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the 00CM,
- 11) Limitations at all times on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to ten times the concentrations stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401),
Table 2, Column 2, iii) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM, iv) Limitations 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 j unrestricted areas conforming to Appendix I to 10 CFR Part 50, j v) 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, vi) 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 Insevd releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50, vii)^ Limi)afions ' all t s on e conckntrat, tons of adioa9t'ive sef)fdents14 areas eyond he myttrial eased gase formi3 to t ntrati s RPar40,Ap[qntimejsfhecon ndary dite)in1 endix (to pa graphs 0.100 st3tfd J0.2401), ble 2 olumn r, any -, ten mes t conce rations tated i 10 CF Part Appen B (to aragra s 20. - 20.&4 ), T e 2, lumn to sponds,tb a dos rate 00 aremfyear t 1 eff tive se a uivalentt / FARLEY-UNIT 2 6-15a AMENDMENT NO.
INSERT vii) Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at and beyond the site boundary as follows: a. For noble gases: Less than or equal to a dose rate of 500 mrem / year to the total body and less than or equal to a dose rate of 3000 mrem / year to the skin, and b. For Iodine-131, Iodine-133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to a dose rate of i 1500 mrem / year to any organ. i I i
i L i r a i r t 't - 6 h - i ' h - 5t e t } 3 i 1 f Unit 2 - i P Typed Pages j 4 t .- t t 'if - i I h ) 9 t a I ' f I b t f .t s s s y- -n> t. t-1
. =-. .4 s-ADMINISTRATIVE CONTROLS .....................................................m. reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) l shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements: j i) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance-tests and setpoint determination in accordance with the j methodology in the ODCM,
- 11) Limitations at all times on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to' ten times the concentrations stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401),
Table 2, Column 2, l iii) Monitoring, sampling, and analysis of radioactive liquid and l gaseous effluents.in accordance with 10 CFR 20.1302 and with } the methodology and parameters in the ODCM, iv) Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive i materials in liquid effluents released from each unit to i unrestricted areas conforming to Appendix I to 10 CFR Part j 50, v) Determination of cumulative and projected dose contributions- 'I from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology i and parameters in the ODCM at least every 31 days, _ vi) Limitations on the operability and use of the liquid and 1 gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines-for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50, vii). Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to' areas 1 at and beyond the site boundary as follows: 1 a. For noble gases: Less than or equal to a dose rate of. l 500 mrem / year to the total body-and less than or equal to - j a dose rate of 3000 mrem / year to.the skin, and t b. For Iodine-131, Iodine-133, tritium, and for all radionuclides in particulate form with half-liL.,,reater than 8 days: Less than or equal to a dose rate of 1500 mrem / year to any organ. j i FARLEY-UNIT 2 6-15a AMENDMENT NO. i m-r r s, m,
.I s.1 31 7 ~! .J ?i it 2 I h C i'f l r I, h t Safety Assessment .-J i - i 1 1-) i .+ I
t Joseph M. Farley Nuclear Plant Units 1 and 2 Technical Specification Changes Associated With Implementation of the New 10 CFR 20 Requirements l Safety Assessment PLoposed Change Revise proposed Farley Technical Specification 6.8.3.e(vii) submitted by Southern Nuclear Operating Company (SNC) letter dated August 24,1992, as Proposed Change 5, and as response to Question 470.2 in letter dated December 17,1992, pertaining to gaseous emuent release rates, in order to accommodate needed operational flexibility to facilitate implementation of the new 10 CFR 20 requirements. Sfety Assessment The basic requirements for technical specifications concerning emuents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with emuent technical specifications will keep average annual releases of radioactive material in emuents at small percentages of the limits specified in the old 10 CFR 20.106. These requirements further indicate that operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than such small percentages, but still within limits specified in the old 10 CFR 20.106 which references Appendix B, Table H concentrations. These referenced concentrations are specific values which relate to an annual dose of 500 mrem. It is further indicated in 10 CFR 50.36a that when using operational flexibility, best efTorts shall be exerted to keep levels of radioactive materials in emuents as low as is reasonably achievable as set forth in 10 CFR 50, Appendix 1. As stated in the Introduction to Appendix B of the new 10 CFR 20, the gaseous emuent concentration values given in Appendix B, Table 2, Column 1, are based on an annual dose of 50 mrem for radionuclides for which inhalation or ingestion is limiting, or 100 mrem for radionuclides for which submersion is limiting. Release concentrations corresponding to a site boundary dose rate of 500 mrem / year (i.e.,500 mrem / year to the total body and less than or equal to 3000 mrem / year to the skin due to noble gases, and 1500 mrem / year to any organ due to lodine-131, Iodine-133, tritium, and particulates with half-lives greater than 8 days) have been accepted as technical specification limits for gaseous emuents in order to provide assurance that the limits of 10 CFR 50, Appendix I and 40 CFR 190 are not exceeded. Therefore, it should not be necessary to restrict the operational flexibility by incorporating the dose rates associated with the new 10 CFR 20 efiluent concentration values for radionuclides based on inhalation or ingestion (50 mrr -/ year), or the dose rate associated with the emuent concentration values for radiormelides based on submersion (100 mrem / year). 1 L
? Safety Assessmeni Page 2 If aving sufficient operational flexibility is especially important in establishing a basis for emuent monitor setpoint calculations. As discussed above, the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 1, relate to a dose of 50 or 100 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100 mrem / year. Such low values are impractical for use as bases for emuent monitor setpoint calculations for many gaseous efIluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account. Therefore, to accommodate operational flexibility needed for efiluent releases, proposed technical specification 6.8.3.e(vil), provided as Proposed Change 5 in SNC letter dated. August 24,1992, is being revised to maintain the current instantaneous dose rate limits for noble gases of 500 mrem / year to the total body and 3000 mrem / year to the skin; and for lodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, an instantaneous dose rate limit of 1500 mrem / year to any organ. t Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating l within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Operational history at Plant Farley has demonstrated that the use of the dose rate values listed above -{ (i.e.,500 mrem / year,3000 mrem / year, and 1500 mrem / year) as technical specification limits has resulted in calculated maximum individual doses to members of the public that are small percentages of the limits of 10 CFR 50, Appendix I and 40 CFR 190. ? q J 4
A', Significant IIazards Evaluation Pursuant to 10 CFR 50.92 i
L o Joseph M. Farley Nuclear Plant Units 1 and 2 Technical Specification Changes Associated With Implementation of the New 10 CFR 20 Requirements 10 CFR 50.92 Evaluation Proposed Changes The proposed changes to the Farley Unit I and Unit 2 Technical Specifications are required in order to implement the new 10 CFR 20 requirements at Farley Nuclear Plant. The proposed technical specification changes previously submitted by Southern Nuclear Operating Company (SNC) letters dated August 24 and December 17,1992, are being revised to address a concern regarding the limits upon gaseous radioactive emuents. Specifically, the proposed change to Administrative Controls Section 6.8.3.e(vii) pertaining to gaseous emuent release rates is being revised to maintain the current instantaneous dose rate limits contained in Farley Unit I and Unit 2 Technical Specification 3/4.11.2.1 for noble gases of 500 mrem / year to the total body and 3000 mrem / year to the skin; and for Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, an instantaneous dose rate limit of 1500 mrem / year to any organ.
Background
By letters dated August 24 and December 17,1992, SNC submitted proposed changes to the technical specifications regarding implementation of the new 10 CFR 20 requirements. Based on subsequent telephone conversations with members of the Nuclear Regulatory Commission (NRC) staff regarding the submittal, SNC was informed that the proposed changes related to gaseous release rates must be revised in order to demonstrate compliance with emuent limitations. Two alternatives acceptable to the NRC were discussed, one based on a concentration methodology and the other based on a dose rate methodology similar to what is currently required by Farley Unit 1 and Unit 2 Technical Specification 3/4.11.2.1. SNC has elected to implement the dose rate methodology for determining compliance with gaseous emuent release rate limits, the details of which are discussed in Attachment 1. Analysis The proposed changes to the technical specifications will allow for the implementation of the new 10 CFR 20 requirements. The level of radiological control will not be reduced by the proposed changes since compliance with applicable regulatory requirements governing radioactive emuents, including 10 CFR 50.36a, Appendix I to 10 CFR 50, and 40 CFR 190, will continue to be maintained. i j
b '. L 10 CFR 50.92 Evaluation Page 2 l i i SNC has reviewed the requirements of 10 CFR 50.92 as they relate to the proposed changes and has made the following determination:
- 1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes will facilitate the implementation of the new 10 CFR 20 requirements. Compliance with other applicable regulatory requirements will continue to be maintained. Also, the l
proposed changes do not alter the conditions or assumptions in any of the Final Safety j Analysis Report (FSAR) accio: analyses. Since the FSAR accident analyses remain bounding, the radiological consequences previously evaluated are not adversely l affected by the proposed changes. Therefore, it can be concluded that the proposed i changes do not involve a significant increase in the probability or consequences of an j accident previously evaluated.
- 2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated The proposed changes do not involve any change to the configuration or method of operation of any plant equipment.
Accordingly, no new failure modes have been defined for any plant system or j component important to safety nor has any new limiting single failure been identified j as a result of the proposed changes. Also, there will be no change in types or increase in the amount ofgaseous efIluents released offsite. Therefore, it can be concluded that the proposed changes do not create the possibility of a new or different kind of I accident from any accident previously evaluated. i
- 3. The proposed changes do not involve a significant reduction in a margin of safety.
The proposed changes do not involve any change in the methodology that will be used in the radiological efiluent monitoring of gaseous releases since current technical l specification requirements will continue to be employed Accordingly, the methodology that will to be used in the control of gaseous effluents will remain unchanged. Additionally, annual doses will be limited to the doses specified in 10 CFR 50, Appendix I and 40 CFR 190. Therefore, it can be concluded that the proposed changes do not involve a significant reduction in a margin of safety. Conclusion Based on the preceding analysis, SNC has determined that the proposed changes to the technical specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or ditTerent kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, SNC has determined that the proposed changes meet the requirements of 10 CFR 50.92(c) and do not involve a significant hazards consideration. l 1 l. v}}