ML20056F725
| ML20056F725 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/23/1993 |
| From: | Simpkin T COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20056F726 | List: |
| References | |
| NUDOCS 9308300310 | |
| Download: ML20056F725 (8) | |
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August 23,1993 Dr. Thomas E. Murley, Director Oflice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Zion Station Units 1 and 2 Application for Amendment to Facility Operating License DPR-39 and DPR-48 NRC Docket Nos. 50-295, and 50-304
Dear Dr. Murley:
Pursuant to 10 CFR 50.90, Commonwealth Edison (CECO) proposes to amend Appendix A, Technical Specifications of Facility Operating License DPR-39 and DPR-48. The proposed amendment involves a revision to Technical Specification Sections 1,6 and the bases for Section 3/4.11 and 3/4.12.
The proposed amendment request provides the changes that reflect the revised requirements of 10 CFR 20, which become 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 in Attachment D.
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Dr. Thomas E. Murley August 23,1993 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 contained 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, W.
T.W. Simpkin Nuclear Licensing Administrator Attachments: A.
Description of Proposed Change B.
Revised Pages C.
No Significant Hazards Evaluation D.
Environmental Assessment cc:
J.B. Martin, Regional Administrator - RIII C.Y. Shiraki, Project Manager - NRR J.D Smith, Senior Resident Insepetor - Braiwood Document Control Desk - NRR-Office of Nuclear Facility Safety - IDNS sf.1 f n-
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A'ITACHMENT A DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGES TO APPENDIX "A" TECHNICAL SPECIFICATION OF FACILITY OPERATING LICENSES DRP-39 AND DPR-48 LICENSE AhENDAENT REQUEST NO. 93-08 t
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGES
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FACILITY OPERATING LICENSES t
DRP-39 AND DPR-48 l
LICENSE AMENDMENT REQUEST NO. 93-08 j
Description of the Proposed Chance j
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Commonwealth Edison Company's Zion Nuclear Station proposes to amend their Technical Specifications to include the changes necessary to implement the latest revision to 10 CFR Part 20 "Standardr. for Protection Against Radiation". The proposed amendment revises the definition of terms defined in Section 1.0
" Definitions", corrects references to the revised 10 CFR Part 20 standard, incorporates the new term " deep dose equivalent" as defined in 10 CFR Part 20, and provides conforming administrative and editorial changes consistent with the revised standard. A discussion of the proposed changes are as follows:
l 1.
Proposed Changes to Defined Terms Description and Bases of the Current Reauirement j
Section 1.0 of the Technical Specification contains definitions for i
" Member (s) of the Public" and " Unrestricted Area". The definition for
" Member (s) of the Public" was derived from NUREG-0472, " Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors". The definition for " Unrestricted Area" was adapted from 10 CFR Part 20. Both definitions were included in Zion's Technical Specifications l
l upon implementation of amendment numbers 96/86 (for Units 1 and 2 j
terpectively) to provide clarification to the specifications which address the release of radioactive material.
i Description and Bases of the Reauested Revision Zion Station proposes to revise the definition of " Member (s) of the Public" and " Unrestricted Area" to be consistent with 10 CFR Part 20, paragraph 20.1003, Definitions. The revised definition for " Member of the Public" is more conservative than the existing definition in Zicn's Technical Specifications since it specifies that an individual is considered a " Member t
of the Public" when the individual is in a controlled or unrestricted area and not receiving an occupational dose. As such, individuals which may have been excluded as a " Member of the Public" in the current defmition, j
may now be classified as a " Member of the Public".
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The revised definition for " Unrestricted Area" has been modified to include l
the area in which access is neither limited or controlled by the licensee.
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.The area at or beyond the site boundary, to which access is not controlled i
for the purpose of protection ofindividuals from exposure to radiation and radioactive material, is no longer specified in the definition.
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l Impact of the Proposed Change j
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The proposed change continues to provide clari5 cation of selected terms used in Zion's Technical Specifications. The revision of defined terms does not reduce the requirement of the specifications to which they apply.
2.
Correction of References to 10 CFR Part 20 Description and Bases of the Current Requirement t
Zion's Technical Specifications make reference to several paragraphs contained in 10 CFR Part 20. These references provide additional information relative to the specification to which they apply. In addition, i
reference is also made to " Table II" in Appendix B of 10 CFR Part 20.
l Description and Bases of the Requested Revision j
i Zion Station proposes to revise the specifications which reference paragraphs contained in 10 CFR Part 20. The revision replaces paragraph i
l numbers, applicable ta the previous version of 10 CFR Part 20, with the corresponding paragraph numbers from the revised version of 10 CFR Part
- 20. In addition, reference to " Table II" in Appendix B of 10 CFR Part 20 i
has been changed to " Table 2". The specifications affected by this change l
include, 6.2.2.B.1, 6.2.6.A.2), 6.2.6.A.3), 6.6.2.A.2.b.4)a), 6.6.2.A.2.b.4)b),
l 6.6.2.B.1(a)(2)VIII, 6.6.2.B.1.(a)(2)IX, 6.7.a.2 and Bases 4.11.1. The l
proposed change is consistent with the numbering contained in the revised 10 CFR Part 20 standard.
1 Impact of the Proposed Chance l
i The proposed change is considered editorialin nature and does not reduce the requirements of Zion's Technical Specifications.
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3.
Incorporation of New Terminology i
Description and Bases of the Current Reanirement l
t Specification 6.6.1.B contains the required information which shall be included in the Annual Occupation Exposure Report. Speci5cally, the report requires a tabulation ofindividuals receiving exposures greater than 100 mrem / year. Individual exposures are based on external whole (total)
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body doses. Record keeping requirements, such as the Annual Occupational Exposure Report, permit annual evaluation by the NRC staff of operating i
and maintenance experience and fulfill information needs for regulations.
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i Description and Bases of the Reauested Revision Specification 6.6.1.B has been modified to include " deep dose equivalent",
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(defined in 10 CFR Part 20) as the whole body external exposure submitted j
in the Annual Occupational Exposure Report. Specifying the type of dose included in the annual report provides clarification of the requirements of l
Regulatory Guide 1.16, " Reporting of Operating Information - Appendix A Technical Specifications" and helps ensure consistency with the usage of 3
terminology contained in the revised 10 CFR Part 20 standard.
Impact of the Proposed Chance l
This change is considered administrative in nature and does not adversely l
impact the ability to meet applicable regulatory requirements. As a result l
of the revised 10 CFR Part 20 standard, new terms and definitions have been included in the standard. The proposed change merely provides i
clarification to the type of dose included in the Annual Occupational l
Report.
4.
Conforming Administrative and Editorial Changes Description and Bases of the Reauested Revision i
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Page "i", definition 1.24 - the word " Member" is shown in its singular form l
consistent with the defined term " Member of the Public".
l Specifications 6.6.2.A.2.b.4)a), 6.6.2.A.2.b.4)b), 6.6.2.B.1.(a)(2)VIII, 6.6.2.B.1.(a)(2)IX, and Bases 4.11.1 - the term " Unrestricted Area" is shown in full capitalization consistent with the usage rules for defined terms in Technical Specifications.
Bases 3.12 and 4.12 - the phrase " total body" has been replaced by "whole body". The use of"whole body" is an equivalent phrase and has been l
included as a defined term in the revised 10 CFR Part 20 standard.
Specification 6.2.2.B.1 - the phrase " intensity of radiation" has been replaced by " dose rate". The use of" dose rate" is an equivalent phrase and i
does not alter the intent of a high radiation area.
I Specification 6.2.6.A.3) - reference to "10 CFR 20.106" has been deleted.
The raonitoring, sampling and analysis of radioactive liquid and gaseous effluent described in the ODCM are in compliance V.th 10 CFR Part 20 l
requirements.' As such, deletion of"10 CFR 20.106" only results in the l
elimination of a redundant reference.
I Specifications 6.2.6.A.4), 6.2.6.A.6), 6.2.6.A.10) - the term " dose commitment" has been deleted to avoid confusion with the term " committed dose equivalent" which is defined in the revised 10 CFR Part 20 standard.
The elimination of" dose commitment" does not alter the intent of the affected specifications.
Specifications 6.2.6A4),6.2.6A7),6.2.6A8),6.2.6A9) and Bases 3.12 and j
4.12 - delete reference to an " unrestricted area" (6.2.6.A.4) and "the area beyond the site boundary" (6.2.6.A.7,6.2.6.A.8,6.2.6A9 Bases 3.12 and 4.12) as the limiting areas in which the dose rate resulting from radioactive 7
l material released in liquid or gaseous effluent would exceed federal i
requirements. As a result of the revised definition for " Member of the j
Public" (discussed as Item #1 of this amendment request), the proposed change builds in added conservatism since the revised definition no longer specifies the area to be occupied. As such, a Member of the Public may be j
j closer than an " unrestricted area" or "beyond the site boundary" and still be subject to the dose limitation specified in 10 CFh Ms 20 and 50.
f Specification 6.6.1.B - the term " man rem" has been changed to " person rem" to reflect current industry terminology. Footnote 1 has been deleted because the information in the reference is no longer included in 10 CFR Part 20. The phrase "(described maintenance)" has been deleted since it was originally a reviewers note intended to prompt the reviewer to include I
a description of special maintenance. The reference to " film badge" is i
deleted since Zion Station no longer utilizes film badges to measure i'
radiation exposure.
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Specifications 6.6.2.A.2.b.4)a),6.6.2.A.2.b.4)b),6.6.2.B.1(a)(2)VIII and 4
j 6.C.2.B.1.(a)(2)IX - have been modified to be consistent with 10 CFR Part i
50 paragraph 50.72, "Immediate Notification Requirements for Operating Nuclear Power Plants". Specifically, the limit on airborne and liquid radioactive releases specified in Appendix B of10 CFR Part 20 has increased from "2 times" the applicable concentration to "20 times" the l
applicable concentration. The increase in the release limit does not l
significantly alter the requirements of the specifications since the dose base associated with the revised version of 10 CFR Part 20, Appendix B has l
l been reduced from 500 mr/yr to 50 mr/yr. As such, the increase in the release limit by a factor of 10 is offset by the decrease of the applicable j
concentrations specified in Appendix B by a factor of 10. In addition, reference to the appropriate columns of 10 CFR Part 20, Appendix B and i
j the elimination of Maximum Permissible Concentration (MPC) have been made.
i Impact of the Proposed Chance l
These changes are administrative or editorialin nature and do not reduce the requirements of any Technical Specification. The changes do however
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improve readability and provide consistency with federal regulations.
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j Schedule Requirements i
4 Zion Station plans to implement the revised 10 CFR Part 20 requirements on 2
January 1,1994. Therefore, it is requested that the proposed amendment be received before this date with a provision that the amendment is to become i
effective on January 1,1994.
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t Identification and Discussion of any Irreversible Consecuences There were no irreversible consequences identified. 7, ion Station has implemented Generic Letter 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the i
Offsite Dose Calculation Alanual or to the Process Control Program".
Implementation of Generic Letter 89-01 resulted in the relocation of portions of the RETS involving radioactive effluent monitoring instrumentation, liquid and gaseous efnuent controls, liquid and gaseous efnuent equipment requirements, radiological environmental monitoring, and radiological reporting details from the Technical Specifications to the Offsite Dose Calculation Manual (ODCM). As a result, the impact of the 10 CFR Part 20 revision on Technical Specifications is primarily limited to revising definitions, correcting references and making minor editorial changes. In order to fully implement the revised 10 CFR Part 20 requirements, the station's ODCM will be updated. A revision to the ODCM will become effective on the same date the proposed Technical Specification amendment is implemented.
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