ML20045E987
| ML20045E987 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 06/29/1993 |
| From: | Simpkin T COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20045E988 | List: |
| References | |
| NUDOCS 9307060277 | |
| Download: ML20045E987 (10) | |
Text
F 2 } 1400 Opus Place Ccmmenwscith Ediscn l
Downers Grove, lilinois 60515 t
June 29,1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Application for Amendment to Facility Operating License NPF-37, NPF-66, NPF-72 and NPF-77 NRC Docket Nos. 50-454. 455. 456 and 457
Dear Dr. Murley:
Pursuant to 10 CFR 50.90, Commonwealth Edison (CECO) proposes to amend Appendix A, Technical Specification of Facility Operating License NPF-37, NPF-66, NPF-72 and NPF-77. The proposed amendment involves a revision to Technical Specification Sections 1, 3/4.3, 3/4.11, 5,6 and the bases for Section 3/4.11.
The proposed amendment request provides the changes that reflect the revised requirements of 10 CFR 20, which becomes effective on January 1,1994.
A detailed description of the proposed change is presented in Attachment A.
The revised Technical Specification and bases pages are contained in Attachment B.
The proposed changes has been reviewed and approved by both on-site and off-site review in accordance with CECO procedures. CECO has reviewed this proposed amendment in accordance with 10 CFR 50.92(c) and has determined that no significant hazards consideration exists. This evaluation is documented in Attachment C. An Environmental Assessment has been completed and is contained
.i in Attachment D.
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T Dr. Thomas E. Murley June 29,1993 CECO is notifying the State ofIllinois of our application for this amendment by transmitting a copy of this letter and its attachments to the designated State Official.
To the best of my knowledge and belief the statements centained herein are true and correct. In some respects, these statements are not based on my personal knowledge but upon information received from other Commonwealth Edison and contractor employees. Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please direct any questions regarding this matter to this office.
Sincerely, Meb. -
T.W. Simpkin Nuclear Licensing Administrator Attachments:
cc:
R. Assa, Project Manager - NRR J. Hickman, Project Manager - NRR S. DuPont, Senior Resident Insepctor - Braiwood H. Peterson, Senior Resident Inspector - Byron Document Control Desk - NRR J.B. Martin, Regional Administrator - RIII Office of Nuclear Facility Safety - IDNS afc-g "
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ATTACHMENT A i
DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGES Descrintion of the Pronosed Chances The proposed Technical Specification revisions include changes necessary to implement the revised 10CFR20 stamdards, changes to implement the revised 10CFR50.36a, and editorial changes. The changes include: (1) adding definitions for controlled area, deep dose equivalent, dose equivalent, high radiation area, and restricted area; revising definitions for member of the public and unrestricted area; (2) updating the radioactive efDuent holdup tank limit reference to reflect the upcoming 10CFR20 revision; (3) relocating certain information in Section 5; (4) adding high radiation area controls;(5) extending the Radioactive EfDuent Release Report submittal frequency from semiannual to annual; (6) revising radiation monitoring instrumentation requirements; and (7) editorial changes. The marked up Technical Specification pages indicating the proposed changes are provided in Attachment B. A discussion of each change follows.
1.
Proposed Changes and Additions to Definitions Descrintion and Bases of the Current Reanirement Technical Specifications defines member (s) of the public and unrestricted area. These definitions are based on the current 10CFR20 definitions.
Controlled area, dose equivalent, high radiation area, restricted area, and deep dose equivalent are not defined.
Descrintion and Bases of the Reauested Revision Commonwealth Edison (CECO) proposes to revise the definitions for member of the public and unrestricted area, and add definitions for controlled area, deep dose equivalent, dose equivalent, high radiation area, and restricted area.
i These definitions affect Section 1. The definitions are revised or added to be consistent with the definitions in the revised 10CFR20.1003. Adding definitions to the Technical Specifications provides assurance that the requirements are understood and met. These changes are administrative in nature and facilitate implementation of the revised 10CFR20 requirements.
The requirements of the Byron or Braidwood Technical Specifications will not be reduced by this change.
The revised definition for member of the public is more conservative because the definition no longer specifies the area to be occupied. Therefore, a member of the public may be closer than the site boundary. Because of this, references to member of the public need not specify his location. For this reason, the location is deleted from Bases 3/4.11.2.6, 6.8.4.e.4, 6.8.4.e.7, 6.8.4.e.9.
Specification 6.9.1.5 is revised to incorporate the new definition for deep dose equivalent.
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Y The definition of high radiation area is revised in 10CFR20. Section 6.12, which describes administrative controls for high radiation areas,is changed to apply when dose rates are above 1000 mrem /h at 30 cm (12 in.), rather than the previous 1000 mR/h at 45 cm (18 in.).
Imnact of the Pronosed Chance The proposed changes support the station's effort to implement the revised 10CFR20 strmdards, which incorporat a updated scientific information, and to reflect changes in the basic philosop).y of radiation protection. The revision conforms to recommendations of natanal and international radiation protection organizations.
The proposed definitions are unique names for the previously undefined terms.
Use of these names reduces confusion and ensures that the quantities being recorded are clear. The requirements of the Technical Specifications are not he reduced by this change because the changes are administrative in nature.
2.
Proposed Change to Radioactive Effluent Holdup Tank Limits Descrintion and Bases of the Current Reauirement In Specification 3.11.1.4, the limit for radioactive material in the Primary Water Storage Tank is less than or equal to 2000 curies. This limit is based on original decign considerations and previous 10CFR20 limits. Technical Specification Bases section 3/4.11.1.4 refers to the limits in 10CFR20 for radioactive liquid holdup tanks. The same limits are referenced in the discussion of the radioactive effluent controls program described in 6.8.4.e.
Descrintion and Bases of the Reauested Revision The proposed change retluces the 2000 curie limit for the Primary Water Storage tank to 10 curies. Current operation of the trmk no longer requires the increased limit, so the limit is changed to that of the other tanks. The Specification and Basis are revised to clarify that the requirements are applicable to unprotected outside tanks, as defined in the basis.
l Basis 3/4.11.1.4 is revised to state that in the event of an uncontrolled release of the unprotected outside tanks, the resulting concentration would be less than the effluent concentration limits of the revised 10 CFR Part 20, Appendix B, Table 2, Column 2. This is in lieu oflimits specified in the previous 10CFR20, Appendix B, Table II, Column 2, which are based on maximum permissible concentration (MPC) values. The affected bases page is also revised to remove the word " listed" since no tanks are specifically named in the proposed specification.
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Imnact of the Pronosed Chance The previous limit of 2000 curies in the Primary Water Storage Tank was based on the MPC limits specified in the previous 10CFR20 requirements, which limits dose to less than 500 mrem / year to the public. Maintaining the activity limit at 10 curies is also consistent with the guidance contained in NUREG-0133, which states that the curie limit for an unprotected tank should be limited to less than or equal to 10 curies, excluding tritium and dissolved or entrained gases. It is no longer necessary to maintain the 2000 curie limit based on current tank use.
The use of the effective dose equivalent concept in the revised table reduces the importance of age-dependent intake-to-dose factors. Age dependency is of primary importance in calculating organ doses. Those organs for which age dependency is important, such as the thyroid gland, are oflesser importance because of w values used to calculate the effective dose. A factor of 2 is r
included in the calculation of concentration limits for release to air and water, which, in part, accounts for age dependency. In addition, the NRC believes that there is a lack of detailed age-dependent metabolic data for all but the most common radionuclides that will inhibit such attempts to increase the precision of the dose estimates. The NRC continues to accept the use of concentrations to demonstrate compliance with the dose limits.
3.
Relocation of Certain Section 5 Information Descrintion and Bases of the Current Reauirement Figure 5.1-1 shows the exclusion area and the location of the meteorological tower. Technical Specification 5.1.3 describes the map (Figure 5.1-1) and radioactive gaseous and liquid effluents. The definition of unrestricted area used in implementing these Technical Specifications has been expanded over that in 10CFR20.3(aX17).
Descrintion and Bases of the Reauested Revision Proposed changes delete Technical Specification 5.1.3 and Figure 5.1-1. The text in Specification 5.1.3 is no longer consistent with revised 10CFR20 definitions, described in item 1, for unrestricted area and member of the public. In addition, more complete information is maintained in Appendix F of the station's Offsite Dose Calculation Manual (ODCM), which is controlled by Technical Specification 6.14.1. The ODCM includes the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents. The ODCM also contains the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by 6.8.4.e and f. Changes to the ODCM are reviewed by the NRC.
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8 This type of change is permitted by NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Efiluent Technical Specifications (RETS)in the Administrative Controls Section of the Technical Specifications and Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual (ODCM) or to the Process Control Program (PCP).
The NRC approved Technical Specification Amendment 46 for Byron and Amendment 35 for Braidwood on April 13,1992. These amendments implemented the recommendations in the Generic Letter.
Technical Specifications 5.1.1 and 5.5.1 are deleted because they only refer to items in Figure 5.1-1, which is deleted in this proposal. The ODCM contains more detailed information, including a description of the meteorological tower location. Therefore, these two specifications are no longer required. The requirements of the Byron and Braidwood Technical Specifications will not be reduced by this change because the deleted information is maintained and controlled in the ODCM. Finally, the title of the map described in 5.1.3 is changed to include the newly defined control area. This infbrmation is also located in the ODCM.
Imnact of the Pronosed Chance Removing the information from Section 5 has no impact because it is maintained in the ODCM. There are no changes to any requirements. The ODCM provides more detailed information than Section 5 of the Technical Specifications. Revisions to the ODCM must be reviewed by the NRC according to Technical Specification 6.14.1. This change is also consistent with Generic Letter 89-01, which allows relocation of this type ofinformation.
4.
Proposed Changes to High Radiation Area Controls Descrintion and Bases of the Current Reauirement Administrative controls for high radiation areas are described in Specification 6.12. These are based on current 10CFR20 requirements and CECO program requirements.
Descrintion and Bases of the Reauested Revision The text is reformatted and rewritten to more accurately reflect the station's radiation work permit and dosimetry programs. The provision in 6.12.1 that allows individuals to work without a radiation work permit (RWP)is deleted.
Station policy is that all work should be performed under an RWP, therefore, the statement is removed from the Technical Specifications for consistency.
A requirement is added that requires persons entering a high radiation area to have an ahirming radiation monitoring device or to have surveillance and radiation monitoring by a radiation protection technician. This ensures that exposure control is maintained, mawwnsa m
The revision removes the ability to establish a stay time in high radiation areas. Instead, personnel must have an alarming dosimeter, or surveillance and radiation monitoring. In emergency situations, continuous coverage would not be required. Instead, radiation protection will determine the appropriate level of surveillance and monitoring required, using remote cameras and instrumentation, if necessary. Removing the specific requirement that coverage be continuous provides flexibility and will not cause unnecessary dose to the person performing the monitoring.
Imnact of the Pronosed Chance The changes provide more exposure control over activities in high radiation areas by specifically requiring radiation work permits (RWPs) for such activities. The proposed change deletes the option to exempt certain ind.ividuals. Therefore, overall control is increased. The proposed changes are consistent with Standard Technical Specifications.
5.
Proposed Change to Submittal Frequency of Radiological Effluent Release Report Descrintion and Bases of the Current Renuirement The Radiological EfIluent Release Report is submitted semiannually based on the requirements of 10CFR50.36a (prior to August 31,1992).
Descrintion and Bases of the Reauested Revision Commonwealth Edison proposes to reduce the requirements for the submission of the Radiological Efiluent Release Report from semiannual to annual for i
Byron and Braidwood. This change affects the index, and Technical Specifications 1.18, 3.11.1.4, 3.11.2.6, 6.9.1.7, and 6.14.1. This change is consistent with the final rule for reducing the regulatory burden on nuclear licensees that was published in the Federal Register on August 31,1992. The -
rule changes include the frequency change to 10CFR50.36a.
Imnact of the Pronosed Chance This change is administrative in nature and makes the Technical Specifications consistent with the amended requirement of 10CFR.50.36a. The change does not adversely impact the ability to meet applicable regulatory requirements related to liquid and gaseous efIluents. The proposed change would also eliminate an unnecessary burden of gove nmental regulation without reducing the protection for public health and safety k:nla.Zton:cfrisc2.:11
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Proposed Change to Radiation Monitoring Instrumentation Requirements i
Descriotion and Bases of the Current Reanirement Technical Specification Table 3.3-6 lists radiation monitoring instr tmentation -
for plant operations. There is a footnote indicating that a setpoint is to be established based on certain criteria. This is in accordance with the l
methodology and parameters of the ODCM. The area radiation monitors
.i perform containment isolation for high containment radioactivity to prevent -
releases of high activity.
l Descriotion and Bases of the Reauested Revision The proposed change to Table 3.3-6 inserts a setpoint ofless than or equal to i
100 mR/ hour for containment isolation - containment radioactivity high j
instrumentation. A provision is added to temporarily increase the setpoint during planned evolutions that elevate the ambient background in the vicinity t
of the monitor. Providing a setpoint with some operating flexibility to change the setpoint reflects the logic applied from the existing note and it simplifies setpoint implementation.
i Imoact of the Pronosed Chance Including a numerical setpoint and revising the footnote regarding the radiation monitor setpoint provide clarity. The previous wording is more consistent with a process radiation monitor, rather than an area radiation monitor. The note is not clear because it describes the setpoint using three different types of measurements that are not directly related. It is also not clear why an area radiation monitor setpoint would be elevated during containment purges. This monitor continuously reeds the dose from the mr concentration in containment. A typical containment purge releases about 5%
l of the volume of air inside containment and has no impact on the area radiation monitor reading. In order to determine an appropriate setpoint for l
the containment area radiation monitor, calculations were performed taking l
different functions of the monitor into account. The most conservative value i
was selected as the Technical Specification setpoint.
l The first calculation method assumed that the monitor is needed during the l
fuel handling accident inside containment, as described in UFSAR subsection 15.7.4.2.2, to provide reliable and rapid detection of radioactivity released from the surface of the refueling cavity and to initiate action to close the containment purge / mini-purge system isolation valves. The monitor could also i
detectinadvertent criticality. The minimum expected dose rate from this o
accident scenario is 70 mR/ hour, and the maximum is 500 R/ hour. The normal background radiation levels in the area is 10 to 30 mR/ hour.
Therefore, the alert and high alarm levels would be 75 mR/ hour and 100 i
mR/ hour, respectively.
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The second method is based on a comparison of the normal operational and maximum allowable concentrations. A relation between noble gas i
concentration and dose was determined to directly compare the normal and maximum concentrations. The normal operational level based on noble gas i
concentration is 1 MPC, which calculates to a dose rate of 0.30 mR/ hour. This j
compares to the 1 MPC predicted containment gas concentration in the UFSAR. The maximum allowable ecmcentration that could be purged is 7000 MPCs, which calculates to 2100 mR/ hour. This is based on administrative
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release limits and a dose limit to the public of 500 mrem / year. The provision of the Technical Specification that the area radiation monitor does not exceed J
10% of the value above would require the setpoint to be 210 mR/ hour.
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- 1herefore, the appropriate setpoint for this approach would be approximately L
200 mR/ hour based on the intent ofisolating a release prior to exceeding the limits of Technical Specification 3/4.11.2.1.a.
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The final method involved the criticality monitor setpoint. This was I
considered a non-viable n ethod because previous calculations produced a non-conservative setpoint of 2300 mR/ hour.
Based on these calculations, setpoints of 75 mR/ hour and 100 mR/ hour Ibr the alert and high alann levels, respectively, are appropriate setpoints for this i
monitor. These ialues allow the monitor to indicate both the postulated dropped fuel 1 undle and the unusually high airborne activity during containment purge.
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Proposed editorial changes Descrintion and Bases of the Reauested Revision In the Bynm Technical Specifications, Pages 1-2 and 1-2a have " BYRON -
UNIT 1" at the bottom. The pages si nuld show that they are applicable to both units. A proposed change to page B 3/411-2 replaces "3.4" with "3/4" for consistency.
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Technical Specification 6.8.4.e.3 refers to 10CFR20.106. In the revised 10CFR20, the infonnation is located in 10CFR20.1302. The monitoring, i
sampling, and analysis of radioactive liquid and gaseous effluents described in the ODCM are in compliance with the revised 10CFR20 requirements.
10CFR20.203 is also replaced by 10CFR20.1601.
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The term, dose commitment, is deleted from 6.8.4.e.4, 6.8.4.e.6, and 6.8.4.e.10.
The term was not defined in the previous 10CFR20, and deleting it avoids any confusion with " committed dose equivalent", which is defined in the revised
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i The text of 6.9.1.4 is reworded for clarity and renumbered as 6.9.1.5 because it is an introduction to the paragraphs that follow. The reference to the initial report is deleted since it has been submitted already, and the station now 1
provides the reports annually as required.
In Technical Specification 6.9.1.5, the term, man-rem, is changed to person-rem to reflect company terminology. Typographical errors are corrected in
" mrem" and " totaling" The reference to film badges is deleted because the station no longer uses film badges to measure radiation exposure. The asterisk and associated footnote are deleted because the information in the reference is no longer included in 10CFR20.
In Technical Specification 6.10.c, the term, radiation control area,is changed to radiologically posted area to reflect company terminology.
Imnact of the Pronosed Chance The changes are administrative in nature, and do not reduce the requirements of any Technical Specification. They improve readability, and provide t
consistency with federal regulations and company programs.
Schedule Reouirements i
i Commonwealth Edison plans to implement the revised 10CFR20 requirements on January 1,1994. Therefore, it is requested that the amendment be issued prior to this date with a provision that the changes involving the 10CFR20 update will take effect on January 1,1994.
Identification and discussion of any irreversible conseouences There were no irreversible consequences identified. Byron and l'raidwood implemented Generic Letter 89-01, when Technical Specificat on Amendments 46 and 35, respectively, were issued. Implementation of Generic Letter 89-01 resulted in the relocation of portions of the RETS involving radioactive effluent monitoring l
instrumentation, liquid and gaseous effluent controls, liquid and gaseous efIluent l
equipment requirements, radiological environmental monitoring, and radiological l
reporting details from the Technical Specifications to the Offsite Dose Calculation Manual (ODCM I. As a result, the impact of the revised 10CFR20 on the Technical T
Specifications is primarily limited to revising definitions and references that have changed. In order to fully implement the revised 10CFR20 requirements, the station's Offsite Dose Calculation Manual (ODCM) will be updated. An ODCM i
revision that implements the revised 10CFR20 requirements will reflect the new definitions when the revised requirements are implemented. The ODCM revision will take effect on the same date as the Technical Specification amendment implementation date.
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