ML20045C828
| ML20045C828 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/14/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20045C829 | List: |
| References | |
| NSD930758, NUDOCS 9306240445 | |
| Download: ML20045C828 (11) | |
Text
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E-GENERAL OFFICE P.O. BOX 499. COLUMBUS, NEBRASKA 6800' 0499 c
jj Nebraska Public Power District
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NSD930758 June 14, 1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Proposed Change No. 117 to Technical Specifications 10 CFR Part 20 Implementation Cooper Nuclear Station NRC Docket No. 50-298, DPR-46 In accordance with the applicable provisions specified in 10 CFR 50, the Nebraska Public Power District (District) requests that the Cooper Nuclear Station (CNS)
Technical Specifications be revised as specified in the attachment.
This proposed change revises those portions of the Technical Specifications impacted by the implementation of the revised 10 CFR 20. These changes are administrative in nature, and involve changes to Part 20 subsection references, use of Effluent Concentrations, pCi/ml, as opposed to Maximum Permissible Concentrations (MPC),
and delineating new offsite dose limits to members of the public.
Additional changes, unrelated to the Part 20 changes, involve the removal of the Technical Specification (Section 3/4.8 and its associated bases section) governing the control of miscellaneous radioactive material sources.
The District plans to implement the revised Part 20 Rule on January 1,1994. For this reason, the District respectfully requests that the approved Technical Specification Change be given an effective date of January 1,1994, in order to provide for the revision of plant procedures and training requirements, and to coordinate the effective date of the subject Technical Specifications with the revised Part 20 implementation date.
The attached contains a description of the proposed change, the attendant 10 CFR 50.92 evaluation, and the CNS applicable revised Technical Specification pages in both final and marked up forms. This proposed change has been reviewed by the necessary Safety Review Committees and incorporates all amendments to the CNS Facility Operating License through Amendment 163 issued May 19, 1993.
By copy of this letter and attachment, the appropriate State of Nebraska official is being notified in accordance with 10 CFR 50.91(b)(1).
Copies to the NRC Region IV Office and the CNS Resident Inspector are also being sent in accordance with 10 CFR 50.4(b)(2).
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U.S. Nuclear Regulatory Commission Page 2 of 3 June 14, 1993 i
If you have any questions or require any additional information, please contact me.
Sin erely
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Horn N c1 ar Power Group Manager GRH/dnm Attachment cc:
H. R. Borchert' Department of Health State of Nebraska NRC. Regional Office Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Station d
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U.S. Nuclear Regulatory Commission Page 3 of 3 June 14, 1993 STATE OF NEBRASKA)
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PlATTE COUNTY
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G. R. Horn, being first duly sworn, deposes and says that.he is an authorized representative of the Nebraska Public Power District, a public corporation and-political subdivision of the' State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the stateme ts contained herein are true to the best of his = knowledge and belief.
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'G. R.' Horn Subscribed in my presence and sworn to before me this
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A Attachment to NSD930758 Page 1 of 5 REVISED TECHNICAL SPECIFICATIONS Proposed Change No. 117 Revised Pares 11 185 216z 216a26 iv 186 216a8 226 Sa 187-192 216a21 229 Sc 216x 216a22 231 I,
INTRODUCTION The' Nebraska Public Power District (District) requests that the NRC approve Proposed Change No, 117 to the Cooper Nuclear Station (CNS)
Technical Specifications described below.
The proposed change incorporates new requirements, contained in 10 CFR 20 (FR Vol. 56, No. 98, May 21,1991, as amended by FR Vol. 57, No.166, dated August 26, 1992 and FR Vol. 57, No. 236, dated December 8,
1992, hereafter known as the revised Part 20 Rule), into the applicable sections of the CNS Technical Specifications.
Currently, the CNS Technical Specifications contain numerous references, terminology, and numerical values that are consistent with 10 CFR 20 regulation (hereafter known as the old Part 20 Rule), as it existed prior to the effective date (June 30, 1991) of the revised Part 20 Rule. 10 CFR 20.1008 (as amended per the Federal Register dated August 26, 1992) requires, in part, that licensees implement the provisions of the revised 10 CFR Part 20 on or before January 1, 1994.
In response to this requirement, the District plans to implement the revised Part 20 Rule on January 1, 1994.
As part of the overall implementation effort, it is necessary to make the following proposed individual changes to the CNS Technical Specifications.
In addition to the individual changes related to the revised Part 20 Rule, the District also requests that proposed individual changes associated i
with the deletion of Technical Specifications (Section 3/4.8, associated 1
Bases
- section, and applicable administrative controls) governing miscellaneous radioactive material sealed sources also be approved. This request is based on guidance provided by NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4", which, unlike previous revisions of the BWR Standard Technical Specifications (STS), do not contain any Technical Specifications addressing the testing of radioactive sealed sources.
The proposed individual changes are detailed in Section II.
The Significant Hazards determination is provided in Section III.
The District's analysis has determined that approval of this proposed change involves no significant hazards consideration.
In order to facilitate the orderly revision of affected plant procedures and training requirements, and to accommodate the 10 CFR 20 implementation date of January 1,
1994,. the District requests that the amendment associated with this proposed change becomes effective on January 1,1994.
As an administrative note, Page 11 is subject to revision by Proposed Technical Specification Change No. 103.
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i Attachment to
.i NSD930758 Page 2 of 5 i
II.
DESCRIPTION OF CHANGES 4
Proposed Change No, 117 is divided into three parts.
The first part consist of those changes necessary to bring the CNS Technical 4
Specifications into conformance with the revised 10 CFR Part 20 Rule.
These individual changes are administrative in nature, and involve updating individual Technical Specification sections to reference the j
revised Part 20 sections, converting from the calculation of Maximum j
Permissible Concentrations (MPC) to Effluent Concentrations, pCi/ml, adding several new definitions (consistent with the. revised Part 20 definitions), and editorial changes to unit nomenclatura.
Several new Technical Specification limits are established, based on the revised Part 20 limits.
Details of the individual changes are identified in the j
attachment to this submittal.
The second part of Proposed Change No. 117 involves the removal of Technical Specification Section 3.8, its associated
- bases, and administrative control requirements (Section 6.4.3).
These sections I
currently govern the general testing and records retention requirements of miscellaneous radioactive material sealed sources c.uthorized per the license condition 2.B.(3) of the CNS Facility Operating License.
The District proposes that the testing and records retention requirements be controlled per CNS Procedure 9.5.2,
" Radioactive Source Control and Accountability". This procedure is part of a larger group of procedures utilized to meet the above referenced license condition.
Removal of the I
subject sections from the CNS Technical Specifications meets the guidance j
of NUREG-1433, and relieves CNS of the administrative burden of maintaining Technical Specifications (c.s opposed to maintaining 4
procedures) for the control of these materials.
The third part of Proposed Change No. 117 involve numerous editorial changes not directly related to the revised Part 20 or Miscellaneous 4
Radioactive Material Sealed Sources portion of this proposed change.
i These changes include, but are not limited to, page renumbering and the capitalization of defined terms. The specific changes are identified in l
the attachment to this submittal.
i III.
SIGNIFICANT HAZARDS DETERMINATION i
10 CFR 50.91(a)(1) requires that licensee requests for operating license
- i amendments be accompanied by an evaluation of significant hazards posed by the issuance of the amendment.
This evaluation is to be performed with 2
respect to the criteria given in 10 CFR 50.92(c). The following analysis i
meets these requirements.
Evaluation of this Amendment with Respect to 10 CFR 50.92 The enclosed Technical Specifications change is judged to involve no significant hazards based on the following:
I 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
j
Attachment to NSD930758 Page 3 of 5 Evaluation l
The first part of Proposed Change No.
117 involves numerous individual changes necessary to bring the CNS Technical l
Specifications into conformance with the revised 10 CFR 20 Rule, i
l These changes are both editorial and administrative in nature, and do not affect any accident initiators or change any assumptions of the accident evaluations.
These changes do not involve the modification or addition of any plant equipment, nor do they involve a change in plant settings that affect plant operation responses.
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Therefore, this part of the proposed change does uit involve a l
significant increase in the probability or consequences of an accident previously evaluated.
The second part of Proposed Change No,117 removes Section 3/4.8. A.
its associated bases, and records retention requirements (Section 6.4.3) from the CNS Technical Specifications.
These requirements will instead be addressed by CNS administrative procedures.
This change is administrative in nature and is in accordance with guidance provided in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4", which do not contain technical specifications for the control of miscellaneous sealed sources. The requirements of, and compliance to, License Condition 2.B.2.(3) of l
the CNS Facility Operating License are unaffected by this change.
l This proposed change does not affect any accident initiators or l
change any assumptions. There are no setpoint changes, changes to plant equipment, changes in maintenance, or changes in plant i
operations.
Therefore, this part of the proposed change does not l
involve a significant increase in the probability or consequences of l
an accident previously evaluated.
i I
The third part of Proposed Change No. 117 consists of editorial changes not directly related to the revised Part 20 portion of this proposed change. These changes include, but are not limited to, page renumbering and the capitalization of defined terms. These changes are editorial in nature and have no impact on plant equipment, plant design, or operations. These editorial changes do not modify or add any initiating parameters.
Therefore, this part of.the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed change create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation The first part of the proposed change involves numerous editorial and administrative changes related to the implementation of the revised 10 CFR 20.
These individual changes do not result in the modification of any structure, system, or component, nor do these changes introduce or change any mode of plant operation. This part of the proposed change does not create the possibility for a new of different kind of accident from any accident previously evaluated.
4 1
Attachment to I
NSD930758 Page 4 of 5 l
The second part of the proposed change removes Section 3/4.8. A,its associated bases, and records retention requirements (Section 6.4.3) i from the CNS Technical Specifications.
This part of the proposed change is administrative in nature and does not involve the modification, addition, or deletion of any plant equipment, nor does it change or introduce any new mode of plant operation. This part of the proposed change does not create the possibility'for a new of different kind of accident from any accident previously evaluated.
~
The third part of the proposed change consists of editorial changes not directly related to the revised Part 20 portion of this proposed change.
These individual changes do not involve any alteration to plant design, setpoints, or operating parameters, nor do they introduce or change any mode of plant operation.
Therefore, this part of the proposed change does not create the possibility for a new different kind of accident from any accident. previously evaluated.
3.
Does the proposed change create a significant reduction in the j
margin of safety?
Evaluation The first part of the proposed change involve the updating of l
applicable sections of the CNS Technical Specifications to be in
{
t agreement with the revised 10 CFR 20 Rule.
The NRC has concluded j
that " incorporation of these changes will ensure that. Part 20 continues to provide adequate protection of public health and 1
i safety" (FR Vol. 56. No.98, May 21, 1991). The revised Part 20 Rule contains several enhanced radiation safety requirements for members 1
of the public and individuals exposed to occupational radiation.
Implementation of the new regulation has no effect on plant safety setpoint settings or overall operation of the station, as it pertains to maintaining plant safety margins. Therefore, this part of the proposed change does not create a significant reduction in
]
the margin of safety.
I The second part of the proposed change removes Section 3/4.8. A,its associated bases, and records retention requirements (Section 6.4.3)-
]
from the CNS Technical Specifications.
This part of the proposed change is administrative in nature and does not impact the operability determination of installed plant equipment, has no effect on plant safety setpoint settings, and does not have any 4
effect on plant operations.
Therefore, this part of the proposed change does not create a significant reduction in the. margin of safety.
The third part of the proposed change consists of editorial changes not directly related to the revised Part 20 portion of this proposed change. These individual changes do not involve any change to plant design, equipment, instrument setpoints, or operation.
Therefore, this part of the proposed change does not create a significant reduction in the margin of safety.
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t Attactnent to NSD930758 Page 5 of 5 2
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IV.
CONCLUSION
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The District has evaluated the individual parts of the proposed change described above against the criteria given in 10 CFR 50.92(c) in j
accordance with the requirements of 10 CFR 50.91 (a)(1). This evaluation has determined that this proposed change will nga 1) involve a significant increase in the probability or consequences of an accident previously evaluated, 2) create the possibility for a new or different kind of accident from any accident previously evaluated, or 3) create a a
significant reduction in the margin of safety. Therefore, for the reasons detailed above, the District requests NRC approval of this Prr.pased Change No. 117.
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l Attachment to j
NSD930758 Page 1 of 3 REVISED TECHNICAL SPECIFICATIONS Proposed Change No. 117 The following is a detailed listing of individual changes associate with Proposed Change No. 117.
I i
I 1)
Revised Part 20 Related Channes Pace No.
Description of Chances Sc The following definitions moved from Page Sa; 2
Definition 1.0.Z.B. Offsite Add the word " Nuclear" between the 1
words " Cooper" and " Station".
Add five new terms, consistent with the revised 10 CFR 20 Rule.
These new terms are as follows:
j 1.0.Z,B.1, Controlled Area 1.0.Z.B.2 Occupational Dose 1.0.Z.B.3 Restricted Area 1.0.Z.B.4 Unrestricted Area 1.0.Z.B.5 Site Boundarv i
Definition 1.0.Z.C, Member of the Public - Replace with new 5
definition of term that is consistent with the new 10 CFR 20 Rule.
216x LCO 3.21.B.l.a Line 6 - Replace the term "10 CFR Part 20.106" with "10 CFR 20, Appendix B, Table 2, annual averaged concentrations".
4 216z Notes for Table 4.21.B.1, Paragraph (2), Line 6 - Remove the term "MPC" and replace the term'"value" with " values". Line 7 - Replace the term " Table II" with " Table 2".
216a8 Notes for Table 4.21.C.1, Paragraph (2), Line 7 - Remove the term "MPC" and replace the term "value" with " values".
Replace the reference to " Table II" with a reference to " Table 2".
216a21 3.21 & 4.21, EASES, - Replace reference to "10 CFR Part 20.106" with reference to "10 CFR Part 20, Appendix B, Table 2" in all locations where reference to 10 CFR Part 20.106 is shown. Replace reference i
to "10 CFR Part 20.106(e)" with reference to "10 CFR 20.1301 and 20.1302(b)(2)(1)" in Line 7 to 3.21.B.1 & 4.21.B.1, Concentration.
1 Add the term " annual average dose concentrations" in line 3, first paragraph in BASES, 3.21.B.1 & 4.21.B.l.
216a22 3.21.B.1 & 4.21.B.1, Concentration (Cont'd), Line 1 Replace reference to 10 CFR 20.106 with reference to 10 CFR 1302(b)(2)(i).
3.21.B.2 & 4.21.B.2, Liauid Dose, Line 6 - Replace reference to "10 l
CFR Part 20.106" with reference to "10 CFR Part 20.1301".
216a26 3.21.C.1 & 4.21.C.1, Concentration, Paragraph 2, Line 4 - Replace reference to "10 CFR Part 20.106" with reference to "10 CFR Part 20.1302(b)(2)(i)".
i Attachment to NSD930758 Page 2 of 3 226 6.3.A, High Radiation Area, Line 2 - Replace reference from
" paragraph 20.203(c)(2)" of 10 CFR Part 20, to "20.1601".
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226 Replace a portion of the 3rd line, first paragraph under.Section 6.3.A, containing the phrase " dose rate is greater 1000 mrem /hr*" with " deep dose equivalent in excess of 100 mrem but less than 1000 mrem in one hour *".
In the second paragraph (mid-page),
line 3, replace the term " dose greater than" with the term " deep dose equivalent in excess of".
226 Change first footnote to read " Measurement made at 12 inchec from source of radiation". The current requirement is at 16 inches.
231 Change footnote 1 from reference "$20.407" to "920.2206" of 10 CFR J
Part 20.
2)
Deletion of Miscellaneous Radioactive Material Sealed Source Reauirements 1
i ii Table of Contents, Section Listing 3.8 - Replace title with the term A
" DELETED".
iv Table of Contents, Section Listing 6.4.3 - Delete this listing due to deletion of Section 3/4.8 from the Technical Specifications.
d 185 Delete page Miscellaneous Radioactive Materials Sources not i
addressed in Standard Technical Specifications.
4 186 Delete page - Miscellaneous Radioactive Materials Sources not addressed in Standard Technical Specifications.
l 187, 188, Relabel page no. to read "-185, 186, 187, 188, 189, 190, 191, 192-189, 190, 191, 192 229 Section 6.4.3, 2 Year Retention - Delete this section.
231 6.5.1.C.3 - Delete this paragraph; renumber Paragraph 6.5.1.C.4 to 6.5.1.C.3.
l 3)
Editorial Channes 1
4 216x capitalize all the letters in the defined terms "0FFSITE" (two
]
locations) and " SITE BOUNDARY" (one location).
216a21 Capitalize the term " Service Water" (four locations).
216a22 Capitalize all the letters in the defined terms " UNRESTRICTED".(one location) and " LIMITING CONDITIONS FOR OPERATION" (two locations).
216a26 Capitalize all the letters in the defined term "0FFSITE" (two locations).
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i Attachment to NSD930758 i
Page 3 of 3' 231 Replace the term " functions, 1/= e.g.,"
with the new term 1
" functions, e.g.," in line 4 of Paragraph 6.5.1.C.1.
Ref.T ec t ~. the change in the superscript natation in the footnote numbering at the bottom of the page. Capitalize all the letters in the defined terms i
" MEMBER OF THE PUBLIC" and "0FFSITE" (both one location). Add the word " Nuclear" between the words " Cooper" and " Station".
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