ML20046B569

Application for Amend to License DPR-49,incorporating Requirements of 10CFR20 Requirements

ML20046B569
Person / Time
Site:	Duane Arnold
Issue date:	07/28/1993
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20046B570	List: ML20046B569 ML20046B576
References
NG-93-2347, NUDOCS 9308050171
Download: ML20046B569 (13)

Text

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l Iowa Electric Light and Power Company sous r. rRANZ. JR. July 28, 1993 vn t mmm . "" ^^

NG-93-2347 j Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 l Washington, DC 20555 ]

1

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49  !

Request for Technical Specification Change (RTS-258): Incorporation of New 10 CFR 20 Requirements .

File: A-ll7

Dear Dr. Murley:

In accordance with the Code of Federal Regulations, Title 10, Sections 50.59 and 50.90, Iowa Electric Light and Power Company hereby requests revision of the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

The NRC revised 10 CFR Part 20 Standards for Protection Against Radiation, effective June 20, 1991, but has permitted licensees to defer implementation until January 1, 1994 (56 FR 23360 and 57 i FR 38588). -

The revision of Part 20 necessitates revision of the DAEC TS.

Most of the changes to the TS are minor and administrative in  !

nature. Some specific changes to release rate limits-for gaseous and liquid effluents are required to provide needed operational flexibility and are discussed in detail in Attachment 1.

We request that this' Amendment be made effective on' January 1,-_  ;

1994. This will allow implementation of the TS change'along with-  ;

other changes to various programs, procedures, etc., as directed ,

by the new 10 CFR Part 20 on this date.

This application has been reviewed by the DAEC Operations Committee and DAEC Safety Committee. Pursuant to the requirements of 10 CFR S 50.91, a copy of this submittal, l including the analysis which concludes that there'are no significant hazards considerations, is being forwarded to our appointed state official.

9308050171 930728 i

• PDR ADOCK 05000331 S l-

@di l P PDR il General offim

• P.O. Boy 351

• Cedar Itapids, Iowa 52406

• 319?398-4411

Dr. Thomas E. Murley  !

July 28, 1993 NG-93-2347 i Page 2 Should you have any questions regarding this matter, please contact this office. ,

This letter is true and accurate to the best of my knowledge.and belief.

IOWA ELECTRIC LIGHT AND POWER COMPANY By //m  !

/ _ Jdhn F/ Frdnz Vice President, Nuclear State of Iowa (County) of Linn Signed and sworn to before me on this day of B () .

, 1993, by ( M n b h f(i l l'l .

A o

$ MARY MICHELE O'NEAL .

NY COMMISSION EXPIRES {

p-v . tin l Notarp}Public 'in And for the State of Iowa

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~b Commis31on Expires JFF/TWP/pjv~

Attachments: 1) Evaluation of Change With Respect to 10 CFR S 50.92 '

2) Proposed Change RTS-258 to the Duane Arnold- ,

Energy Center Technical SpecifAcations

3) Safety Assessment

4) Environmental Consideration cc: T. Page L. Liu L. Root

. R. Pulsifer (NRC-NRR) '

J. Martin (Region III)

S. Brown (State of Iowa),

NRC Resident Office DCRC

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1 RTS-258 Attachment I to NG-93-2347 Page 1 of 5 EVALUATION OF CHANGE WITH RESPECT TO 10 CFR S 50.92

Background:

On May 21, 1991, the Nuclear Regulatory Commission (NRC) published the revised 10 CFR Part 20 (56 FR 23360). The revision- l necessitates revision of the Duane Arnold Energy Center (DAEC) 1 Technical Specifications (TS) with respect to release rate limits for gaseous and liquid effluents. It also necessitates some l changes in monitoring and reporting requirements, definitions, j and record retention requirements. The specific changes are ,

addressed below, i

'i Iowa Electric Light and Power Company, Docket No. 50-331, i Duane Arnold Energy Center, Linn County, Iowa  !

Date of Amendment Request: July 28, 1993 l

Description of Amendment Request:

The proposed license amendment incorporates the requirements i outlined in the revised 10 CFR Part 20 as noted below. l 1

Various references to 10 CFR Part 20 are being changed where l appropriate to reflect the new numbering. These changes are administrative in nature. l t

A change to the wording in the TS regarding the requirements of 10 CFR S 20.1601(a) is being made to clarify that DAEC does not i use control devices, alarm signals, or locked doors for high  !

radiation areas in which dose rates are less than 1000 mrem /hr. ,

This change is editorial and is consistent with the requirements  !

in 10 CFR Part 20. .

Access requirements for high radiation areas are being revised to incorporate the revised radiation measurement distances and to i identify the maximum dose associated with a high radiation area- -

Additionally, the wording regarding "a major portion of the body"  ;

is being deleted to prevent confusion under the new requirements.  ;

These changes are administrative in nature and are consistent j with the requirements of the new 10 CFR S 20.1003. i i

The proposed changes to release rate limits for gaseous'and j liquid effluents are being made in order to accommodate needed i operational flexibility to facilitate implementation of the new 10 CFR Part 20 requirements, i

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d RTS-258 Attachment 1 to NG-93-2347 Page 2 of 5 The basic requirements for TS concerning effluents from nuclear power reactors are stated in 10 CFR S 50.36a. These requirements ,

indicate that compliance with effluent TS will keep average '

annual releases of radioactive material in effluents to small ,

percentages of the limits specified in the present  :

10 CFR S 20.106 (new 10 CFR S 20.1301). These requirements  !

further indicate that operational flexibility is allowed, l compatible with considerations of health and safety, which may l temporarily result in releases higher than such small  :

percentages, but still within the limits specified in the present l 10 CFR S 20.106 which references Appendix B, Table II maximum ,

permissible concentrations (MPCs). These referenced l concentrations are specific values which relate to an annual dose .

of 500 mrem. It is further indicated in 10 CFR S 50.36a that t when using operational flexibility, best efforts shall be exerted  !

to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR Part 50, $

Appendix I. ,

The gaseous effluent concentration limits given in the new  !

Appendix B, Table 2, Column 1, correspond to an annual dose of 50 i mrem for isotopes for which inhalation is limiting or 100 mrem for isotopes for which submersion (noble gases) is limiting.  !

Release concentrations corresponding to limiting dose rates less  ;

than or equal to 500 mrem / year to the whole body, 3000 mrem / year r to the skin from noble gases, and 1500 mrem / year to any organ ,

from Iodine-131, Iodine-133, tritium and all radionuclides in -

particulate form with half-lives greater than eight days at the  !

site boundary have been acceptable as a TS limit for gaseous effluents to assure that the limits of 10 CFR Part 50, Appendix I l' and 40 CFR Part 190 are not likely to be exceeded.. Therefore, it should not be necessary to restrict operational flexibility by-  :

incorporating the dose rate associated with the effluent

• concentration value for isotopes based on inhalation (50 mrem / year) or submersion (100 mrem / year).  !

As stated in the Introduction to Appendix B of the new f 10 CFR Part 20, the liquid effluent concentration limits given in j the new Appendix B, Table 2, Column 2 are equivalent to the

• concentrations which if ingested continuously over a year, would i

produce a total effective annual dose of 50 mrem. Since a release concentration corresponding to 500 mrem / year has been i acceptable as a TS liquid effluent limit to ensure that Part 50, l Appendix I values are not exceeded, it should not be necessary to reduce this limit by a factor of ten.  ;

i Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint l calculations. As discussed.above, the concentrations stated in )

the new 10 CFR Part 20, Appendix B, Table 2, Columns 1 and 2,

I RTS-258 Attachment 1 to NG-93-2347  :

Page 3 of 5 l relate to a dose of 50/100 mrem (inhalation / submersion) in a year j for airborne effluents or to a dose of 50 mrem in a year for  :

liquid effluents. Waen applied on an instantaneous basis, this l corresponds to a dose rate of 50/100 or 50 mrem / year,  !

respectively. These dose rates correspond to very low values when expressed as an hourly rate and fall well below background i levels. It is impractical to base effluent monitor setpoint  ;

calculations on these low values for many gaseous or liquid ,

effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account under all operational conditions.

Therefore, to accommodate the operational flexibility needed for '

effluent releases, the TS limits associated with gaseous effluent '

release rates will be maintained at the current instantaneous dose rate limits. For noble gases, this limit is 500 mrem / year

• to the whole body and 3000 mrem / year to the skin. For Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, this limit is 1500 mrem / year to any organ.

To further accommodate needed operational flexibility, the TS j limits associated with the release rate for liquid effluents are  :

based on ten times the concentrations stated in the new 10 CFR Part 20, Appendix B, Table 2, Column 2, to apply at all times. The multiplier of ten is proposed because the annual dose of 500 mrem, upon which the concentrations in the old

10 CFR Part 20, Appendix B, Table II, Column 2, are based, is a

factor of 10 higher than the annual dose of 50 mrem, upon which the concentrations in the new 10 CFR Part 20, Appendix B, Table 2, Column 2, are based.

Compliance with the limits of the new 10 CFR S 20.1301 will be demonstrated by operating within the limits of 10 CFR Part 50, Appendix I and 40 CFR Part 190. Operational history at the DAEC 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 well as ten times the new 10 CFR Part 20 liquid limits) as TS limits have resulted in calculated maximum individual doses to members of the public that are small percentages of the limits of j 10 CFR Part 50, Appendix I and 40 CFR Part 190. Therefore, the use of these concentration values should not have a negative impact on the ability to continue to operate within the limits of  ;

10 CFR Part 50, Appendix I and 40 CFR Part 190. 1 1

Various changes to requirements for records retention and =

reporting are being made. These include the requirement to  !

retain radiation exposure records for all individuals for whom l monitoring is required rather than all individuals entering radiation control areas, revised report due dates, and the d

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l RTS-258 Attachment I to NG-93-2347 l Page 4 of 5 '

revision to report titles or deletion of reporting requirements as appropriate. These changes are consistent with the new Part l 20.

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Basis for proposed no significant hazards consideration:

The Commission has provided standards (10 CFR S 50.92(c)) for i determining whether a significant hazards consideration exists.

A proposed amendment to an operating license for a facility J involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) ]

involve a significant increase in the. probability or consequences i of an accident previously evaluated; (2) create the possibility i of a new or different kind of accident from any accident i previously evaluated; or (3) involve a significant reduction in a i margin of safety.

i After reviewing this proposed request for Technical Specification  !

change, we have concluded:

1) Operation of the facility in accordance with the proposed I amendment would not involve any increase in the probability l of occurrence or consequences of an accident previously .

evaluated because there will be no change in the types or  :

amounts of effluents that will be released, nor will there l be an increase in individual or cumulative occupational i radiation exposures. l

2) Operation of the facility in accordance with the proposed -1 amendment would not create the possibility of a new or ,

different kind of accident from any accident previously i evaluated. The changes are administrative in nature and l will not change the types or amounts of effluents that will i

be released.

3) Operation of the facility in accordance with the proposed j amendment would not involve any reduction in a margin of  ;

safety. Maintaining the current instantaneous gaseous I release rate limits and the liquid ef fluent relear e limit ,

based on an annual dose of 500 mrem (basis for the old J 10 CFR Part 20, Appendix B criteria) are acceptable.

Compliance with the new 10 CFR Part 20 limits will be demonstrated by operating within the limits of 10 CFR Part 50, Appendix I and 40 CFR Part 190. l The proposed changes will not increase the probability or consequences of any previously r.nalyzed accident, introduce any new or different kind of accident, or reduce any existing margin of safety.

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r RTS-258 Attachment I to NG-93-2347  :

Page 5 of 5 l l

Based upon the above, we have determined that the proposed Amendment will not involve a significant hazards consideration.

• Local Public Document Room Location: Cedar Rapids Public j Library, 500 First Street SE, Cedar Rapids, Iowa 52401 l

Attorney for Licensee: Jack Newman, Kathleen H. Shea, Newman and Holtzinger, 1615 L Street NW, Washington, D.C. 20036 j l

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RTS-258 Attachment 2 to NG-93-2347 Page 1 of 2 PROPOSED CHANGE RTS-258 TO THE DUANE ARNOLD ENERGY CENTER TECHNICAL SPECIFICATIONS The holders of license DPR-49 for the Duane Arnold Energy Center propose to amend Appendix A (Technical Specifications) to said license by deleting certain current pages and replacing them with p the attached new pages. The List of Affected Pages and a l Description of Changes is given below.

LIST OF AFFECTED PAGES 3.14-3 6.11-2 6.9-1 6.11-6*

6.9-2 6.14-1*

6.10-2

• This page is common to RTS-259.

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SUMMARY

OF CHANGES:

The following list of proposed changes is in the order that the changes appear in the Technical Specifications.

Page Description of Changes 3.14-3 In the Bases for Sections 3.14.A and 4.14.A, references are changed to match the numbering of the new Part 20.

6.9-1 Reference to S 20.203(c)(2) is changed to l

S 20.1601(a) to reflect the new 10 CFR Part 20 l numbering. A wording change is being made to reference the " requirements of" S 20.1601(a) rather than list specific items from the requirements. The distance at which radiation is measured is changed from 18" to 30 cm.

Information is added to identify the maximum dose (500 rads at 1 meter) associated with a High Radiation Area. The wording dealing with "a major portion of the body" is being deleted to prevent confusion. These changes are consistent with the new Part 20.

6.9-2 The concentration limits for liquid effluents were changed to " ten times (10 x) the concentrations listed in" Part 20. The concentration limits for

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l RTS-258 Attachment 2 to I NG-93-2347 )

Page 2 of 2 l l

-t gaseous effluents are being maintained at the current dose rate limits, thus the wording was revised to reflect the specific limits rather than  ;

referencing Part 20. The proposed change affects l the instantaneous release rate only.  !

Additionally, references are changed to match the new Part 20 organization and make the wording consistent with the revised Part 20.

6.10-2 A change is made to the wording regarding  !

Individual radiation exposure records to reflect i the new Part 20. Specifically, the revision j requires retention of radiation exposure records for monitored individuals rather than all l individuals entering radiation control areas.

6.11-2 The reference in the footnote is corrected to j match the revised numbering of the new Part 20. i The date for submitting the Annual Exposure Report l 1s revised to reflect the new requirements.

6.11-6 In Table 6.11-1, a reference is corrected to i reflect the new Part 20 numbering. The dates for i submitting reports are revised to reflect the new .

requirements. The title of one report is revised .

to the " Individual Exposure Monitoring" report and the " Personnel Exposure on Termination of '

Employment or Work" report is deleted since this l requirement was eliminated by the revision to ,

Part 20.

t 6.14-1 A reference is corrected to reflect the revised Part 20 numbering. -

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t RTS-258 Attachment 3 to l NG-93-2347 j Page 1 of 3  ;

I SAFETY ASSESSMENT Introduction '

, By letter dated July 28, 1993, Iowa Electric Light and Power  !

Company (IELP) submitted a request for revision to the Technical '

Specifications, Appendix A to Operating License No. DPR-49, for the Duane Arnold Energy Center (DAEC). The proposed change would revise references to sections of Part 20, revise various report titles, due dates and record retention requirements, revise the  !

high radiation area description, and revise the release rate limits for gaseous and liquid effluents at the DAEP. j Assessment '

s )

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Many of the changes are minor and administrative in nature.

These include such items as revising references to be consistent l with the new Part 20 numbering, changing titles of periodic t reports and due dates, and revising record retention ,

requirements.

) The proposed changes to the effluent release rate limits will 1 provide neeiad operational flexibility to facilitate implementation cf the new Part 20 requirements.  !

1 The basic requirements for TS concerning effluents from nuclear power reactors are stated in 10 CFR S 50.36a. These requirements  :

indicate that compliance with effluent TS will keep' average

• annual releases of radioactive material in effluents to small

percentages of the limits specified in the present >

10 CFR S 20.106 (new 10 CFR S 20.1301). 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 j percentages, but still within the limits specified in the present  !

J 10 CFR S 20.106 which references Appendix B, Table II maximum permissible concentrations (MPCs). These referenced concentrations are specific values which relate to an annual dose  !

of 500 mrem. It is further indicated in 10 CFR S 50.36a that,  ;

i when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR Part 50, Appendix I. ,

i The gaseous effluent concentration (EC) limits given in the new f Appendix B, Table 2, Column 1, correspond to an annual dose of 50 i mrem for isotopes for which inhalation is limiting or 100 mrem l for isotopes for which submersion (noble gases) is limiting.  ;

Release concentrations corresponding to limiting dose rates less ,

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9 RTS-258 Attachment 3 to NG-93-2347 Page 2 of 3 than or equal to 500 mrem / year to the whole body, 3000 mrem / year to the skin from noble gases, and 1500 mrem / year to any organ' from Iodine-131, Iodine-133, tritium and all radionuclides in particulate form with half-lives greater than eight days at the I site boundary.have been acceptable as a TS limit for gaseous l effluents to assure that the limits of 10 CFR Part 50, Appendix 1 i and 40 CFR Part 190 are not likely to be exceeded. Therefore, it ,

should not be necessary to restrict the operational flexibility by incorporating the dose rate associated with the effluent

concentration value for isotopes based on inhalation (50 j mrem / year) or submersion (100 mrem / year).  ;

The 11guld effluent concentration limits given in the new l

, Appendix B,. Table 2, Column 2 are equivalent to the  !

concentrations which, if ingested continuously over a year, would i

produce a total effective annual dose of 50 mrem. Since a l release concentration corresponding to 500 mrem / year has been l

acceptable as a TS 11guld effluent limit to ensure that Part 50, l Appendix I values are not exceeded, it should not be necessary to j reduce this limit by a factor of ten.  ;

4 Having sufficient operational flexibility is especially important l in establishing a basis for effluent monitor setpoint calculations. As discussed above, the concentrations stated in j the new 10 CFR Part 20, Appendix B, Table 2, Columns 1 and 2,  !

relate to a dose of 50/100 mrem (inhalation / submersion) in a year for airborne effluents or to a dose of 50 mrem in a year for

11guld effluents. When applied cn an instantaneous basis, this j corresponds to a dose rate of 50/100 or 50 mrem / year, >

respectively. These low values are impractical upon which to  ;

base effluent monitor setpoint calculations for many gaseous or  ;

liquid effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into ,

, account. I i

Therefore, to accommodate the operational flexibility needed for [

effluent releases, the TS limits associated with gaseous release i rates will be maintained at the current instantaneous dose rate ,

limits. For noble gases, this limit is 500 mrem / year to the  ;

whole body and 3000 mrem / year to the skin. For Iodine-131, i Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, this limit is 1500 mrem / year l to any organ. '

To further accommodate needed operational flexibility, the TS l limits associated with the liquid release rate are based on ten I

, times the concentrations stated in the new Part 20, Appendix B, Table 2, Column 2, to apply at all times.

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RTS-258 Attachment 3 to NG-93-2347 Page 3 of 3 Compliance with the limits of the new 10 CFR S 20.1301 will be demonstrated by operating within the limits of 10 CFR Part 50, Appendix I and 40 CFR Part 190. Operational history at the DAEC 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 well as ten times the new 10 CFR Part 20 liquid limits) as TS limits have resulted in calculated maximum individual doses to members of the public that are small percentages of the limits of 10 CFR Part 50, Appendix I and 40 CFR Part 190.

Based on the above evaluation, we conclude that the proposed Technical Specification changes are acceptable.

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RTS-258 Attachment 4 to NG-93-2347 J Page 1 of 1 l l

ENVIRONMENTAL CONSIDERATION 10 CFR S 51.22(c)(9) identifies.certain licensing and regulatory  ;

actions eligible for categorical exclusion from the requirements  !

for an environmental assessment. A proposed amendment to an ,

operating license for a facility requires no environmental ,

assessment if operation of the facility in accordance with the  ;

proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may i be released offsite; and (3) result in an increase in individual  ;

or cumulative occupational radiation exposure. Iowa Electric j Light and Power has reviewed this request and determined that the t proposed amendment meets the criteria for categorical exclusion '

set forth in 10 CFR S 51.22(c)(9). Ptrsuant to 10 CFR S 51.22(b), no environmental impact st.atement or environmental i assessment needs to be prepared in connection with the amendment.  ;

The basis for this determination follows:

Basis l The change meets the criteria for categorical exclusion set forth [

in 10 CFR S 51.22(c)(9) for the following reasons.

1. As demonstrated in Attachment 1, the proposed amendment does not involve a significant hazards consideration.

2. The proposed changes to the release rate limits for gaseous  !

and liquid effluents, administrative changes and revised  !

references will have no effect on the types or amounts of l effluents released offsite. l The effluent concentration multiplier of ten proposed in  ;

this submittal will allow the lignid effluent release rates -

to correspond to 500 mrem /yr as is the case in the current  :

Part 20. The proposed limits associated with the gaseous i release rate TS will be maintained at the current '

instantaneous dose rate limits. Compliance with the annual i dose limits of the new 10 CFR S 20.1301 will be demonstrated  !

by operating within the limits of 10 CFR Part 50, Appendix I f and 40-CFR Part 190.  :

3. The proposed changes to the release rate limits for gaseous and liquid effluents, administrative changes and revised i references will have no effect on individual or cumulative I occupational radiation exposures. j l

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