ML20045D761

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Proposed Ts,Relocating Procedural Details of Current Radioactive Effluent/Radiological Environ Monitoring Program & Solid Radwaste Mgt Program from TS to ODCM
ML20045D761
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/21/1993
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20045D744 List:
References
NUDOCS 9306300031
Download: ML20045D761 (22)


Text

'

i ATTACHMENT B ZION NUCLEAR GENERATING STATION PROPOSED CHANGES TO APPENDIX A, TECHNICAL SPECIFICATION OF FACILITY OPERATING LICENSES DPR-39 AND DPR-48 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 91-04 Pages Modified i

4 302 111 5

310a tv 6

311a v

6a 314 vil 225a 316 1x 229a 322 x

234 323 I

xi 235 325 1

242a 326 i

2 3

h gg3 Added 222 - 225 226 - 229 230 - 233 236 - 242 275 - 280 310b i

haes Deleted 222 227b 233 241a 279b 223 228 236 241b 279c 223a 228a 236a 242 280 223b 228b 236b 275 280a 224 228c 237 275a 280b 225 229 238 276 280c 226 230 238a 277 295a 226a 231 239 278 295b 227 232 240 279 313 227a 232a 241 279a 315 ZOSR-333(14) 9306300031 930621 PDR ADOCK 05000295 P

PDR

ANNOTATED COPY OF CURRENT ZION TECHNICAL SPECIFICATIONS i

INDICATING PROPOSED CHANGES FOR l

J TECHNICAL SPECIFICATION CHANGE REQUEST NO. 91-04 l

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l-20SR-333(15)

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r Finure Eagn

.3.3.2-1.

Reactor Coolant System Heatup Limitations 84 3.3.2-2 Reactor Coolant System Cooldown Limitations 85 3.3.2-3 Fast Neutron Fluence (E > 1 MeV) as a Function of Full Power Service Life (EFPY) for Zion Unit 1 86 3.3.2-4 Fast Neutron Fluence (E > 1 MeV) as a Function of Full Power Service Life (EFPY) for Zion Unit 2 87 3.3.6-1 Dose Equivalent I-131 RC Limit versus Percent of

. Rated Thermal Power 124c Deleted 131a 3.11-1

-Restricted-Aree-Boundary-Detera.S 226 3.13.13-1 Fuel Assembly Bumup Limits in Region 2 247f 5.5.2-1 Spent Fuel Storage Pool.

299a 6.1-1 Minimum Shift Crew Composition 327 LIST OF FIGURES (Continued) vii Amendment Nos. -142-anti-131 m*-.

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1.0 DEFINITIONS 1.21 INSTRUMENT CHANNEL 1.25 0FF-SITE AC POWER SOURCES An INSTRUMENT CHANNEL shall be the combination of sensor (s), signal processing elements, output devices The OFF-SITE A.C. POWER SOURCES shall be the and other components and circuitry as required to System Auxiliary Transformer-142 - (Unit 1): 242 measure and evaluate a process variable for the

- (Unit 2).

ihe System Aux 111ary Transformer purpose of observation, control and/or protection of from the opposite unit (242 - Unit 1; 142 - Unit 2).

the process system. A channel may produce both I

analog signal outputs and discrete (signal or 1.26 0FFSITE DOSE CALCULATION MANUAL (00CM) electromechanical componefit operation) outputs. The channel terminates and loses its identity where individual channel outputs are combined, The DFFSITE DOSE CALCULATION MANUAL shall contain the methodology and parameters used h 1.22 LEAKAGE the calculation of offsite doses (doode % k radioactive gaseous and 11guld effluents, in the Refer to the following specific paragraphs, calculation of gaseous 11guld effluent 1.13 CONTROLLED LEAKAGE monitoring alare/ trip ~ setpoints, and in the 1.20 IDENTIFIED LEAKAGE conduct of the Environmental Radiological 1.32 PRESSURE SOUNORY LEAKAGE l*kA Monitoring Program.4

(

l.48 UNIDENTIFIED LEAKAGE 3

C 1.27 OPERA 8tE - OPERA 81LITY 1.23 MASTER RELAY TEST -

A system, subsystem, train, component or device A MASTER RELAY TEST shall be the energization of each shall be OPERABLE or have OPERASILITY when it is master relay and. verification of OPERASILITY of each capable of performing its specified function (s),

relay.

The MASTER RELAY TEST shall include a.

and when all necessary attendant continuity check of each associated slave relay.

Instrumentation, controls, electrical power, cooling or seal water, lubrication or other 1.24 MEMBER (51 0F THE PU8 tlc aux 111ery equipment that are r.tquired for then system.. subsystem, train, component ~,.or device MEMBER (S) 0F THE PUBLIC shall include all persons who to perform its function (s) are also capable of are not occupationally associated with the plant.

~

peforming their related support functlen(s),

This category does not include employees of the utility, its contractors or its vendors. Also The OPERASILITY requirement' for both normal and excluded from this category are persons who enter the emergency AC power supplies does not apply to AC site to service equipment or to make deliveries.

instrument busses and associated instruments.

This category does include persons who use portions of the site for recreational, occupational or other purposes not associated with the plant.

.09150/09180 Amendment Mos. 0;..i 0; 4

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The 00CN shall also contain (1) the Radioactive Effluent Controls and Radiological

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Environmental Monitoring Programs required by Section 6.2.6 and (2) descriptions of the information that 4

should be included in the Annual Raalological 4

Environmental Operating and C;":

=1 Radioactive Effluent Release Reports required by Specifications i

6.6.1.C and 6.6.1.D.

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stes _ at R. -,e.ct,.e Re,.....e.e,1r of r tien deses to the likel mest exposed real 1

% deal from reacter leases and other nea wreatus fuel le sources thin 60 dets after January I and July 1 of e

year a report shall be submitted cover og (including es from pr ry effluent the pathways and d t

tion) for the teactive content of effluents rete ed to un tricted areas during the previ sta previous 12 cens months to show months atten. The data shell be 1 the conformance with 4 FR 190, Environmental M

format of latory Guide 1.21. Rev.

Radiatten Protec en adards for 8hsclear S

1974) amt she be sumunertred on a rke(June Power Operstl Accep le methods for rly basis amt shall eclude as a mint calculating dose centr ten from 11guld and gaseos ffluents are 31 in segulatory 1.

seseems Eft 1 s

Guide 1.1

, Rev. 1.

(a) Gross Radlos twity eleases (g) Th1 report shall also incinde a spec rt pursuant to the requirements of (1) Total gross leectivity (in re ification 3.3.6 whenever the reactor cortes) pr 1.ly noble and coolant specific activity limits have been activetten s

released.

exceeded.

(2) Mentmum ress r eactivity releas rate dort any one-period.

5 (3) To 1 gross redloatti ty (in c ries) by nuclide rol sed, sed on representative 1setopic analyses perf

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Percent of techalcal specifitatten 11mit.

(b) ledine Releases (1) - Total tedine redteactivity (in curles) by nec11de released, based on representative 1setopic analyses performed.

(2) Percent of technical 11320/11330 specificatten limit for 5-131

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C.

Annual Radioloalcal Envircrantal Operatina Renort*

The Annual Radiological Environmental Operating Report covering operation of the Unit during the previous calendar year shall be subettted'before May 1 of each year.

The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period.

The naterial provided shall be cons 1 stent vith the objectives outlined in (1) the 00CM and (2) Sections IV.8.2 IV.B.3, and IV.C of Appendlx I of 10 CFR Part 50.

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A single subalttal may be made for a multi-unit station.

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i The Sentennua.1 Radioactive Effluent Release Report covering the operation of the Unit 1;.5 ; tt:

3 ge:rt s ; ; w ;t.; d' w.e: Le shall be submitted Ta am nL-e_ JA s u 6t 5 o. %,

etttt: i^ (4.; -a'ter 2 = er y I e.4 Jely i vi ;;d

. yeas.

The report shall include a summary of the quantitles of radioactive liquid and gaseous l

effluents and solid waste released from the Unit.

The material provided shall be (1) consistent with the ob.jectives outlined in the 0001 and PCP and (2)-

in conformance with 10 CFR 50.364 and Section IV.8.1 of Appendix I to 10 CFR Part 50.

i 1

Y A s'lagle submittal may be made for a multi-unit station.

The submittal should combine those Sections common to both units at the station; however, for units with separate radweste systems, the submittal shall specify the releases of radioactive material from each unit.

4 1

5.6.1 fD.

tlnued)

F.

CORE OPERATIllG LIMITS REPORL(COL 11 5.

The radios off release reports 1.

Core operating Ilmits shall be estab11shed and shall inc1 to the PIl0 CESS documented in the CORE OPERATING LIMITS REPORT -

(PCP) made the before each reload cycle or any remaining part eporting period.

of a reload cycle for the following:

j

~-

E.

Monthlv Operating Raport Routine reports using

)) Shutdown Bank Insertion Limit for the " Operating Data", " Unit Shutdowns and Load Specifications 3.2.1.C.2 and 0.1.

Reductions" and " Average Dolly Unit Power Level"

1) Control Bark Insertion Limit for report formats, shall be submitted on a monthly Specifications 3.2.1.C.2 and 0.1, and

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basis to the Director, Office of Management and 3.2.3.8.4. 5.

I-Program Analysis U.S. Nuclear Regulatory

3) AXIAL FLUX OIFFERENCE Limits Target Sand Commission, Nashington, D.C. 20555 with a copy For Specifications 3.2.2.A.2.2.c.(2),

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to the appropriate IRC Regional Office of 3.2.2.A.4, and 3.2.2.A.6.1.

Inspection and Enforcement, no later than the

() Neat Fluu Not Channel Factor and K(Z) for l

15th of each month following the calendar month Specification 3.2.2.A.1.1.

covered by tl'e report.

5) Nuclear Enthalpy Rise Not Channel Factor and i

Power Factor Multiplier for-Specification l

Included with the report will be a "Itarrative 3.2.2.A.I.1.

Summary of Operating Expertence" that describes the operation of the facility, including major 1

The analytical methods used to determine the sifety related maintenance, for the monthly core operating Ilmits shall be those previously report' period, revleved and approved by the IIRC in the following documents:

3

'A b hange.s to the OffsIto Dose Calculatton Manual shall be submitted with'the monthly

1) MCAP-9272-P-A, "Mestinghouse Reload Safety Operating _ Report within 90 days of-the effectly Evaluation Methodology". July 1985 i

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date-of'the change.

)

(Mestinghouse Proprietary).

(Methodology for Specifications: Shutdown Bank Insertion i

Limit, Control Bank Insertion Limit, Antal Flum Difference, Neat Flux Not Channel

[

i Factor, and leuclear Enthalpy Rise Not i

Channel Factor.)

I 31 6 Amendment Mos. O end M S-

c 6.6.3.8 Special Reports Reports on the following areas shall be submitted as indicated:

TOPIC SUBMITTAL DATE a.

In-Service Inspection Evaluation In accordance with the requirements of Section XI ASME Boiler Code -(IWA-6000) b.

(Deleted) c.

Containment Building Structural Testing Within 90 days following completion of each test.

Report (ILRT, Tendon) d.

Changes to the Offsite Dose Calculation M*th'

^^ d;y: Of :ff :th; d:t: ::

-t :S th

"- ^---^'

Manual (00CM)

M"ke,V e(d'8EAMrrIE4's&

  • EJteacbe GWlutafE. Epor+

3 e.

Waukegan Regional Airport Expansion The expansion plans and status of such plans for Plans.

the Waukegan Regional Airport will tie reported yearly in the Annual Report, including FAA form

  1. 5010 report.

f.

Low Temperature Overpressure Protection Within 30 days of operation.

System Operation g.

Primary Coolant Specific Activity As part of the Annual Report whenever Specification 3.3.6 has been exceeded. See page 124 for required report content.

h.

Pressurizer PORY or Safety Valve Within 30 days as an LER.

l Failure to Close SPECIAL REPORTS Table 6.6-1 11320/11330 323 Amendment Nos. 103 & 93

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b krs.1 W{ IOCF#- 2D,104, 4o crat. (

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. Ass <9J h gg 6.7 0FFSITE DOSE CALCULATION "?'.u.L (00CM) io cFF-So.5sa. '~J A M W I b ' ( 8 E

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2,)Y.

A determination that the l'T he 00CM shall describe the methodolo d

chanye wilijnot Alodesse the par to'be used in the ca ton of dose (3'.culat1%y'of *E '

accuracy or reliabilit i

offsite doses o radt we gaseous and

tpointy, 11guld effluents and calculation of

.--......... ;;f gaseous and 11 effluent ng

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^^ ^ ~ -' " 'r d 05: feit instrument on alarm / trip s'etpoints c tent with applicable LCO's contained in these 15" ' ': : M... :. _. _ _..

1 cal Specifications.

re"* r f rf f d ;;;;p'./ h-i by i;'t it: t ;'^_ _ l y.Any hages to the 00CMht:1; we ummee ey vii;...-

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l Commission initiated chanees2 i

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Shall be determined y the 1.

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"-tee.a

  • .*k site Review Fun ton to be C _ J;;%. by bik;b.. % th a

11 cable to t fac111ty

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26.,; d ;;r: rt afte consider ton of l

to 9--trate*a. 5,t.?r utekt-en fac111 des n.

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dawe a' t Q det e t' s:._-._ ^ a i = s 2.

The 11cen shall provide

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3,s. s i s the Conse 51 with written fM.

Sufficient?-; 2; ^._ ^. : ^

notift tion o heir information to support the dete ination of change _

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app cability inc1 Ing any m(m...r "tte? f...i. s

.ini v" n essary revisions

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vi, eflect facility desig vi use

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Shall be reviewed by the evaluations justifying the offsite Review Function.

change (s); W

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Shallbecomeeffect)'veafterreviewandacceptanceby b.

the Onsite Review pnd Investigative Function, and the approval of the N Manager on the date specified by the Onsite Review and Investigative function.

c.

Shall be submitted to the Commission in the form of a complete, legible copy of the entire 00CM as a part of, or concurrent with, the :::';;;;;! Radioactive Effluent Release Report for the period of the' report in which any change to the 00CM was made effective.

Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented.

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l TYPED COPY OF i

PROPOSED CHANGES TO ZION TECHNICAL SPECIFICATIONS ~

FOR TECHNICAL SPECIFICATION CHANGE REQUEST NO. 91-04 l

f ZOSR-333(16) er wy--i e

O Ficure

_P_agg 3.3.2-1 Reactor Coolant System Heatup Limitations 84 3.3.2-2 Reactor Coolant System Cooldown Limitations 85 3.3.2-3 Fast Neutron Fluence (E > 1 MeV) as a Function of 86 Full Power Service Life (EFPY) for Zion Unit 1 3.3.2-4 Fast Neutron Fluence (E > 1 MeV) as a Function of 87 Full Power Service Life (EFPY) for Zion Unit 2 3.3.6-1 Dose Equivalent I-131 RC Limit versus Percent of Rated Thermal Power 124c Deleted 131a 3.11-1 Deleted

.226 l

3.13.13-1 Fuel Assembly Burnup Limits in Region 2 247f 5.5.2-1 Spent Fuel Storage Pool

'299a 6.1-1 Minimum Shift Crew Composition 327 LIST OF FIGURES (Continued)

ZOSR-333(21)

.vi l Amendment Nos.

~.

1.0 DEFINITIONS 1.21 INSTRUMENT CHANNEL 1.25 0FF-SITE AC POWER SOURCES An INSTRUMENT CHANNEL shall be the combination of The OFF-SITE A.C. POWER SOURCES shall be the System sensor (s), signal processing elements, output devices Auxiliary Transformer - 142 - (Unit 1); 242 - (Unit and other components and circuitry as required to 2).

The System Auxiliary Transformer from the i

measure and evaluate a process variable for the opposite unit (242 - Unit 1; 142 - Unit 2).

purpose of observation, control and/or protection of the process system. A channel may produce both 1.26 0FFSITE DOSE CALCULATION MANUAL (ODCM) analog signal outputs and discrete (signal or electromechanical component operation) outputs.

The The OFFSITE DOSE CALCULATION MANUAL shall contain the channel terminates and loses its identity where methodology and parameters used in the calculation of individual channel outputs are combined.

offsite doses resulting from radioactive gaseous and l liquid effluents, in the calculation of gaseous i

1.22 LEAKAGE liquid effluent monitoring alarm / trip setpoints, and in the conduct of the Environmental Radiological Refer to the following specific paragraphs.

Monitoring Program.

The ODCM shall also contain (1) 1.13 CONTROLLED LEAKAGE the Radioactive Effluent Controls and Radiological 1.20 IDENTIFIED LEAKAGE Environmental Monitoring Programs required by Section 1.32 PRESSURE BOUNDRY LEAKAGE 6.2.6 and (2) descriptions of the information that 1.48 UNIDENTIFIED LEAKAGE should be included in the Annual Radiological Environmental Operating and Radioactive Effluent 1.23 MASTER RELAY TEST Release Reports required by Specifications 6.6.1.C and 6.6.1.D.

A MASTER RELAY TEST shall be the energization of each master relay and verification of OPERABILITY of each 1.27 OPERABLE - OPERABILITY relay.

The MASTER RELAY TEST shall include a continuity check of each associated slave relay.

J. system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of 1.24 MEMBER (S) 0F THE PUBLIC performing its specified function (s), and when all necessary attendant instrumentation, controls, i

MEMBER (S) 0F THE PUBLIC shall include all persons who electrical power, cooling or seal water, lubrication are not occupationally associated with the plant.

or other auxiliary equipment that are required for i

This category does not include employees of the the system, subsystem, train, component, or device to utility, its contractors or its vendors. Also perform its function (s) are also capable of peforming excluded from this category are persons who enter the their related support function (s).

site to service equipment or to make deliveries.

This category does include persons who use portions The OPERABILITY requirement for both normal and of the site for recreational, occupational or other emergency AC power supplies does not apply to AC purposes not associated with the plant.

Instrument busses and associated instruments.

ZOSR-333(29) 4 Amendment Nos.

a 6.6.1 (Continued)

C.

Annual Radioloaical Environmental Ooeratina D.

Radioactive Effluent Release Reoort**

Report

  • The Radioactive Effluent Release Report covering the The Annual Radiological Environmental operation of the Unit shall be submitted in Operating Report covering operation of the accordance with 10 CFR 50.36a. The report shall Unit during the previous calendar year shall include a summary of the quantities of radioactive be submitted before May 1 of each year.

The liquid and gaseous effluents and solid waste released ~

report shall include summaries, from the Unit. The material provided shall be (1) interpretations, and analysis of trends of the consistent with the objectives outlined in the ODCH results of the Radiological Environmental and PCP and (2) in conformance with 10 CFR 50.36a and Monitoring Program for the reporting period.

Section IV.B.1 of Appendix I to 10 CFR Part 50.

The material provided shall be consistent with the objectives outlined in (1; the ODCM and l

(2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I of 10 CFR Part 50.

Z A single submittal may be made for a multi-unit station.

A single submittal may be made for a multi-unit station.

The submittal should combine those Sections common to both units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material frca each unit.

ZOSR-333(50) 314 Amendment Nos.

6.6.1. (Continued)

F.

CORE OPERATING LIMITS REPORT (COLR)

E.

Monthlv Oneratino Rcoort Routine reports 1.

Core operating limits shall be established and using the " Operating Data", " Unit Shutdowns documented in the CORE OPERATING LIMITS REPORT and Load Reductions" and " Average Daily Unit before each reload cycle or any remaining part Power Level" report formats, shall be of a reload cycle for the following:

submitted on a monthly basis to the Director, Office of Management and Program Analysis, 1)

Shutdown Bank Insertion Limit for U.S. Nuclear Regulatory Commission, Specifications 3.2.1.C.2 and D.I.

Washington, D.C. 20555 with a copy to the 2)

Control Bank Insertion Limit for appropriate NRC Regional Office of Inspection Specifications 3.2.1.C.2 and D.1, and and Enforcement, no later than the 15th of 3.2.3.B.4, 5.

each month following the calendar month 3)

AXIAL FLUX DIFFERENCE Limits, Target Band covered by the report.

For Specifications 3.2.2.A.2.2.c.(2),

3.2.2.A.4, and 3.2.2.A.6.1.

Included with the report will be a " Narrative 4)

Heat Flux Hot Channel Factor and K(Z) for Summary of Operating Experience" that Specification 3.2.2.A.1.1.

describes the operation of the facility, 5)

Nuclear Enthalpy Rise Hot Channel Factor including major safety related maintenance, and Power Factor Multiplier for for the monthly report period.

Specification 3.2.2. A.1.1.

2.

The analytical methods used to determine the core operating limits shall be.those previously reviewed and approved by the NRC in the following documents:

1)

HCAP-9272-P-A, " Westinghouse Reload Safety Evaluation Methodology", July 1985 (Westinghouse Proprietary).

(Methodology for Specifications: Shutdown Bank Insertion Limit, Control Bank Insertion Limit, Axial Flux Difference, Heat Flux Hot Channel Factor, and Nuclear Enthalpy Rise Hot Channel Factor.)

ZOSR-333(52) 316 Amendment Nos.

t l

6.6.3.8 Soecial Reports

~

Reports.on the following areas shall be submitted as indicated:

TOPIC SUBMITTAL QAIE 4

a.

In-Service Inspection Evaluation In accordance with the requirements of Section XI

~

ASME Boller Code (IR4-6000) b.

(Deleted) c.

Containment Building Structural Testing Within 90 days following completion of each test.

Report (ILRT, Tendon) d.

Changes to the Offsite Dose Calculation As part of, or concurrent with, the Radioactive Effluent Manual (ODCM)

Release Report in accordance with Specification 6.7.C.

e.

Haukegan Regional Airport Expansion The expansion plans and status of such plans for the Plans.

Haukegan Regional Airport-will be reported yearly in the Annual Report, including FAA form #5010 report.

f.

Low Temperature Overpressure Protection Within 30 days of operation.

System Operation g.

Primary Coolant Specific Activity As part of the Annual Report whenever Specification 3.3.6 has been exceeded.

See page 124 for required report content.

h.

Pressurizer PORV or. Safety Valve Within 30 days as an LER.

Failure to Close t

SPECIAL REPORTS Table 6.6-l' ZOSR-333(54) 323 Amendment Nos.

e 6.7 OfF.ESITE DOSE CALCULATION MANUAL (ODCH)

Changes to the ODCM:

4 a.

Shall be documented and records of b.

Shall become effective after review and acceptance"by reviews performed shall be retained as the Onsite Review and Investigative Function, and the required by Specification 6.5.2.S.

The approval of the Station Manager on the date specified' documentation shall contain; by the Onsite Review and Investigative Function.

1)

Sufficient information to support c.

Shall be submitted to the Commission in the form of a the change together with appropriate complete, legible copy of the entire 00CM as a part analyses or evaluations justifying of, or concurrent with, the Radioactive Effluent the change (s); and Release Report for the period of the report in which any change to the ODCM was made effective.

Each 2)

A determination that the change will change shall be identified by markings in the margin maintain the level of radioactive of the affected pages, clearly indicating the area of effluent control required by 10 CFR the page that was changed, and shall indicate the 20.106, 40 CFR Part 190, 10 CFR date (e.g., month / year) the change was implemented.

50.36a and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose or setpoint calculations.

1 Amendment Nos.

ZOSR-333(55) 325

.. ~,

ATTACHMENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATIONS FOR PROPOSED CHANGES TO APPENDIX A. TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES DPR-39 and DPR-48 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 91-04 l

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Il ZOSR-333 (57) l i

1

  • o EVAL.UATION OF SIGNIFICANT HAZARDS CONSIDERATION i

Evaluation of this proposed amendment has resulted in the determination that it involves no significant hazards consideration. According to 10CFR50.92(c),

l a proposed amendment to an Operating License involves no significant safety l

hazards consideration if operation of the facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability or consequences of a.

an accident previously evaluated; or i

b.

Create a possibility of a new or different kind of accident from any accident previously evaluated; or l

c.

Involve a significant reduction in a margin of safety.

1.

The proposed changes only alter the format and location of procedural l

details and administrative controls of the radioactive effluents, radiological environmental monitoring and solid radioactive waste programs.

In addition, the periodicity of the reporting of radioactive effluent releases is being changed to conform with the requirements of 10CFR50.36a.

The changes are administrative in nature and do not involve any change to the' configuration or-operation of plant equipment.

The Radiological Effluent Technic,* 'pecifications (RETS) procedural details are being moved to the Offsite

.,se Calculation Manual (ODCM), and the l

Process Control Program (PCP).

However, the contents of the RETS are not

)

being changed. The purpose of the RETS is to assure that the proper controls for the radiological effluent system are in place.

The programs containing the procedural details of_RETS will continue to perform the j

same functions. Any future changes.to the programs containing the RETS i

i procedural details would require an onsite' review and approval.

l Therefore, the RETS will continue to receive a high level of consideration even though they will no longer be part of the Technical Specifications.

l All the current provisions of the RETS are being retained, so none of the assumptions used in the accident analysis will be affected.

Based on-this evaluation, it has been determined that the changes do not affect the probability or consequences of a previously evaluated accident.

2.

The procedural _ requirements of the RETS will be maintained in the ODCM and the PCP.

The change in the periodicity of radioactive effluent release reports meets the requirements of 10CFR50.36a. Operation of the plant will not be al_tered by the changes proposed to the administration.of the RETS or the periodicity of radioactive effluent release reports.

These changes will not place the plant in any new condition or introduce any mode of operation not previously analyzed.

Therefore, these changes will not create the possibility.of a new or different kind of accident from any accident previously evaluated.

1 ZOSR-333 (58) l.

l

EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION (Continued) 3.

The proposed changes relocate the procedural details and bases of RETS from the Technical Specifications to the ODCM or PCP.

The RETS procedural details and bases will be maintained by these programs.

Changes to these programs will require an onsite review.

In addition, new administrative controls have been added to the Technical Specifications which assure the proper control and maintenance of these documents and provide an equivalent level of assurance that activities involving radioactive i

effluents, solid radioactive waste, and radiological environmental monitoring are conducted in full compliance with regulatory requirements.

In addition, the change in the periodicity of radioactive effluent release l

reports conforms with regulatory requirements and is administrative in nature.

Therefore, there is no reduction in the margin of safety.

NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

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In conclusion, based on the previous consideration (Standards Categories l

1-3), Commonwealth Edison Company submits that the activities associated with this Technical Specification amendment request satisfy the Significant Hazards Consideration standards of 10 CFR 50.92(c) and, accordingly, a finding that l

this Technical Specification Change Request does not represent a Significant l

Hazards Consideration is justified.

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l ZOSR-333 (59) l i-