ML20057D090

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Safety Evaluation Supporting Amends 66 & 45 to Licenses NPF-68 & NPF-81,respectively
ML20057D090
Person / Time
Site: Vogtle  
Issue date: 09/24/1993
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20057D089 List:
References
NUDOCS 9310010095
Download: ML20057D090 (6)


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NUCLEAR REGULATORY COMMISSION

%..g W ASHINGTON. D.C. 205$5-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 66 TO FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 45 TO FACILITY OPERATING LICENSE NPF-81 GEORGIA POWER COMPANY. ET AL.

V0GTLE ELECTRIC GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425 1.0 E{TRODUCTION By [[letter::ELV-03832, Application for Amends to Licenses NPF-68 & NPF-81,revising TS SR 4.5.2.b by Changing Frequency for Verifying That ECCS Piping Is Full of Water from Once Per 31 Days to Once Per 6 Months|letter dated September 17, 1992]], as supplemented January 22, February 26, and June 16, 1993, Georgia Power Company, et al. '.the licensee) proposed license amendments to change the Technical Specifications (TS) for Vogtle Electric Generating Plant (Vogtle), Units I and 2.

The proposed changes are in support of the licensee's plan to implement the revised 10 CFR Part 20.

The January 22, February 26, and June 16, 1993, letters provided clarifying information that did not change the initial proposed no significant hazards consideration determination.

2.0 EVALUATION The licensee has proposed to revise the Vogtle TS to include wording that is consistent with the revised 10 CFR Part 20, " Standards for Protection Against Radiation." The licensee wM' retain the same overall level of effluent control required to meet the design objectives of Appendix I to 10 CFR Part 50.

The NRC staff's evaluation of each specific TS change follows:

2.1 TS Section 1.0 DEFINITIONS The licensee has proposed to revise the definitions of " member (s) of the public" and " unrestricted area" to conform to the definitions of these terms used in 10 CFR 20.1003.

The NRC staff finds these changes are administrative in nature to im ~ porate the correspcuding revised 10 CFR Part 20 definition 1 and th *refore, acceptable.

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2.2 TS N 'e 3.3-3 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS The licensee has proposed to revise footnote c to TS Table 3.3-3 to read

" Specification 6.7.4.f.7" instead of " Specification 6.7.4.f."

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4 The NRC staff finds that this change is administrative in nature to correct a section reference when the licensee implemented Generic Letter 89-01, and is, therefore, acceptable.

2.3 TS BASES section 3/4.11.1.4 LIOUID HOLDUP TANKS The BASES section would be revised to read:

" Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations would be less than the limits of 10 CFR Part 20, Appendix B (to paragraphs 20.1001-20.2401), Table 2, Column 2 at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA."

The licensee performed an evaluation that demonstrates that the use of the revised effluent concentrations are conservative with respect to the tank activity limit that remains at 10 curies.

Based on the abave, the NRC staff finds it. acceptable that the liquid concentrations associated with the liquid holdup tanks are based on the effluent concentration values given in 10 CFR Part 20, Appendix B (to paragraphs 20.1001-20.2401),. Table 2, Column 2.

2.4 TS 6.7.4.f.2 Radioactive Effluent Controls Procram The licensee has proposed to revise item 2 of this TS waich specifies the limitations on the concentrations of radioactive material released in liquid effluents. The licensee has proposed that the TS be revised to allow " ten times the concentrations stated in 10 CFR 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 2."

The licensee has proposed this change to retain operational flexibility consistent with Appendix I to 10 CFR Part 50, concurrent with the implementation of the revised 10 CFR Part 20.

The current requirements for the content of the licensee's TS concerning radioactive effluents are contained in 10 CFR 50.36a. This regulation requires licensees to maintain control over radioactive material in gaseous and liquid effluents to unrestricted areas, produced during normal reactor operations, to levels that are as low as reasonably achievable (ALARA). For power reactors, Appendix 1 to 10 CFR Part 50 contains the numerical guidance to meet the ALARA requirement. The dose i

values specified in Appendix I of 10 CFR Part 50 are small percentages of the implicit limits in 10 CFR 20.106 and the explicit limits in 10 CFR 20.1301. As secondary controls, the instantaneous dose rates required by this TS were chosen by the NRC staff to keep annual average releases of radioactive material in gaseous and liquid effluents to within the doses j

specified in Appendix I of 10 CFR Part 50.

For purposes of this TS, 10 CFR Part 20 is used as a reference value only. These TS requirements allow operational flexibility, compatible with considerations of health and safcty, which may temporarily result in release rates which, if continued for the calendar quarter, would result in radiation doses

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higher than specified in Appendix I of 10 CFR Part 50. However, these i

releases are within the implicit limits in 10 CFR 20.106 and the explicit i

limits in 10 CFR 20.1302 which references Appendix B, Table II I

concentrations. These referenced concentrations in the old 10 CFR Part i

20 are specific values which relate to an annual dose of 500 mrem. The i

liquid effluent radioactive effluent concentration limits given in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2401 are based on an annual dose of 50 mrem total effective dose equivalent. Since a release concentration corresponding to a dose rtte of 500 mrem / year has been acceptable as a TS limit for liquid effluents, which applies at all times to assure that the values in Appendix I of 10 CFR Part 50 are not lii.ely to be exceeded, it is not necessary to reduce this limit by a factor of ten.

The licensee finds that the Vogtle operating history has demonstrated that the use of the concentration values associated with 10 CFR 20.106 as TS limits has resulted in calculated maximum individual doses to a member of the pub lic that are small percentages of the values given in Appendix I to 10 CFR Part 50. Therefore, the use of effluent concentration values that are ten times those listed in Appendix B, Table 2, Column 2 to 10 -

CFR 20.1001 - 20.2401 will not have a negative impact on the ability to continue to operate within the design objectives in Appendix I to 10 CFR Part 50.

The licensee further states that compliance with the limits of 10 CFR 20.1301 will be demonstrated by operating within the design objectives in Appendix I of 10 CFR Part 50 and 40 CFR Part 190.

Based on the above, the NRC staff finds it acceptable that the limits associated with the liquid release rate TS are based on ten times the effluent concentration values given in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2401, to apply at all times.

2.5 TS 6.7.a.f.3 Radioactive Effluent Controls Procram The licensee has proposed to revise item 3 of this TS to replace the reference to "10 CFR 20.106" with "10 CFR 20.1302."

The NRC staff finds that this change is administrativ9 in nature to incorporate the corresponding revised 10 CFR Part 20 section number and is, therefore, acceptable.

1 2.6 TS 6.13.2.a.2 0FFSITE DOSE CALCULATION MANUAL The licensee has proposed to revise this TS by replacing the reference to "10 CFR 20.106" with "10 CFR 20.1302."

The NRC staff finds that this change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 section number and is, therefore, acceptable.

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f 2.7 TS 6.7.4.f.7 Radioactive Effluent Controls Proaram The licensee has proposed to revise this TS which specifies the limitations on tne concentrations of radioactive material released in gaseous effluents. The TS would be revised to read as follows:

" Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the SITE BOUNDARY as follows:

a.

For noble gases:

Less than or equal to a dose rate of 500 mrems/ year to the total body and less than or equal to a dose rate of 3000 mrems/ year to the skin, and b.

For Iodine-131, Iodine-133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: Less than or equal to a dose rate of 1500 mrems/ year to any organ."

The licensee has proposed this change concurrent with the implemer,tation of the revised 10 CFR Part 20 to retain operational flexibility consistent with 10 CFR Part 50, Appendix I.

i The present requirements for the content of the licensee's TS on radioactive effluents are contained in 10 CFR 50.36a.

10 CFR 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluents to unrestricted areas, produced during normal reactor operations, to levels that are as low as reasonably achievable (ALARA).

For power reactors, Appendix I to 10 CFR Part 50 contains the numerical guidance to meet the ALARA requirement. The doses specified in Appendix I of 10 CFR Part 50 are small percentages of the implicit limits in 10 CFR 20.106 and the explicit limits in 10 CFR 20.1301.

As secondary controls, the instantaneous dose rates required by this specification were chosen by the staff to keep annual average releases of radioactive materials in gaseous and liquid effluents to within the doses specified in Appendix I of 10 CFR Part 50.

For the bases of this TS,10 CFR Part 20 is used as a reference value only.

l These TS requiremerts allow operational flexibility, compatible with considerations of health and safety, which may temporarily result in release rates which, if continued for the calendar quarter, would result J

in radiation doses higher than specified in Appendix I of 10 CFR Part 50.

However, these releases are within the limits specified in 10 CFR 20.106 (10 CFR 20.1302).

This specification, which is based on guidance contained in NUREG-0133, is acceptable as a TS limit for gaseous effluents, which applies at all i

times as an assurance that the values in Appendix I of 10 CFR Ptrt 50 are i

not likely to be exceeded.

The licensee finds that the operating history at Vogtle 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 TS limits has resulted in calculated maximum individual doses to members of the public that are J

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( small percentages of the limits of Appendix I to 10 CFR Part 50 and 40 CFR Part 190.

The licensee states that compliance with the limits of 10 CFR 20.1301 will be demonstrated by operating within the limits of Appendix I to 10 CFR Part 50 and 40 CFR Part 190.

Based on the above, the NRC staff finds it acceptable that the gaseous release rate TS for radioactive material is based on the stated dose rates.

2.8 TS 6.8.1.2 ANNUAL REPORT The licensee has proposed to revise this TS to replace the reference to "20.407" with "20.2206."

The NRC staff finds this change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 section number and is, therefore, acceptable.

2.9 TS 6.11.1 HIGH RADIATION AREA The licensee has proposed to revise this TS to replace the references to "20.203(c)(5)" and "20.203(c)" with "20.1601(c)" and "20.1601(a),"

respectively.

The NRC staff finds that these changes are administrative in nature to incorporate the corresponding revised 10 CFR Part 20 section numbers and are, therefore, acceptable.

2.10 TS 6.11 HIGH RADIATION AREA The licensee has proposed to revise TS Sections 6.11.1 and 6.11.2 to change the distance used to make measurements from a source of radioactivity to determine the dose an individual might receive in I hour. The distance would change from 45 centimeters (18 inches) to 30 centimeters (12 inches).

The NRC staff finds that this change is consistent with the requirement in 10 CFR 20.1601 and is, therefore, acceptable.

2.11 TS 6.11 HIGH RADIATION AREA In response to an NRC request, the licensee has proposed adding an upper limit of 500 rads in one hour as measured at-1 meter from the radiation source or from any surface which the radiation penetrates. This will ensure that the measures that are in place for controlling access to high radiation areas are not used for very high radiation areas (10 CFR 20.1602), which require additional controls.

The NRC staff finds that this change is consistent with the requirement of 20.1602 and is, therefore, acceptable.

3.0 STATE CONSULTATION

In accordance with the Comission's regulations, the Georgia State official was notified of the proposed issuance of the amendments. The State official had no coments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Comission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public coment on such finding (57 FR 41733 dated October 14,1992).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no j

environmental impact statement or environmental assessment need be prepared in connection with the issuance cf the amendments.

The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Pursuant to 10 CFR 51.22(b), no environmental impact statement y

or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 [0NCLUSION The Comission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the i

public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.

Principal Contributcr:

S. Klementowicz

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Date:

September 24, 1993 i

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