ML20058A259
| ML20058A259 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, Zion, LaSalle File:ZionSolutions icon.png |
| Issue date: | 11/10/1993 |
| From: | Bauer J COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20058A262 | List: |
| References | |
| NUDOCS 9312010006 | |
| Download: ML20058A259 (10) | |
Text
e
\\ Ccmmonwealth Edisen
- / 1400 Opus Place
( C '~ Downers Grove, Illinois 60515 November 10,1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Application for Amendment to Facility Operating Licenses Revised 10CFR20 Byron Station Units 1 and 2 NPF-37/66; NRC Docket Nos. 50-454/455 Braidwood Station Units 1 and 2 NPF-72/77; NRC Docket Nos. 50-456/457 Zion Station Units 1 and 2 DPR-39/48; NRC Docket Nos. 295/304 LaSalle County Station Units 1 and 2 NPF-11/18; NRC Docket Nos. 373/374
References:
See Attachment 1
Dear Dr. Murley:
Pursuant to 10CFR50.90, Commonwealth Edison Company-(CECO) proposes to amend Appendix A, Technical Specifications of Facility Operating Licenses NPF-37, NPF-66, NPF-72, NPF-77, DPR-39, DPR-48, NPF-11 and NPF-18. The proposed amendment request is prompted by the revision to 10CFR20 and involves changes to the " Radioactive Effluent Controls Program" described in Section 6.0 of the Byron, Braidwood, Zion and LaSalle Technical Specifications. ' The changes specifically address: 1) limitations on radioactive material released in liquid effluents;
- 2) updating a reference to the applicable paragraph of the new Part 20 and;
- 3) limitations on radioactive material released in gaseous effluents.
Please note that this proposed amendment is much reduced in scope from the previously submitted amendments that addressed the revision to 10CFR20. Based on conversations with Mr. Stephen Klementowicz of your staff, the previous amendments were withdrawn (see Reference 4) in lieu of this reduced scope amendment to effect a more expeditious approval by the NRC. A future more comprehensive amendment,-
addressing all changes in the new Part 20, will be forthcoming after the Generic Letter regarding the Part 20 revision is issued.
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9312010006 931110-I
-PDR ADDCK 05000295
-P PDR'
Dr. T. E. Murley 2
November 10,~1993 A detailed description of the proposed changes is presented in Attachment 'A.
The revised Technical Specification pages are contained in Attachment B.
l The proposed changes have been reviewed and approved by the On-site and Off-site Review Committees 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 as documented in Attachment C. An Environmental Assessment has also been completed and is contained in Attachment D.
CECO is notifying the State of Illinois of our application for these amendments by transmitting a copy of this letter and the associated attachments to the designated State Official.
CECO respectfully requests that the Staff review and approve this proposed amendment by January 1,1994, at which time the revision to 10CFR20 becomes effective.
To the best of my knowledge and belief, the statements contained in this document are true and correct. In some respects these statements are not based on my personal knowledge, but on information furnished by other CECO employees, contractor _ employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
Please address any comments or questions regarding this matter to this office.
Respectfully, rayr //.44 Joseph A. Bauer Nuclear Licensing Administrator gp/ JAB Attachments cc:
J. B. Hickman, Byron Project Manager - NRR h M*
'[
R. R. Assa, Braidwood Project Manager - NRR
/p.
93
""g[ j [J,f1[g C. Y. Shiraki, Zion Project Manager - NRR -
J. Kennedy, LaSalle Project Manager - NRR p
H. Peterson, SRI - Byron S. G. Dupont, SRI - Braidwood
^^^^^^"'^ * ^^ N OFFICIAL SEAL.
J. D. Smith, SRI - Zion D. Hills, SRI - LaSalle MARYELLEN D LONG.
B. Clayton, Branch Chief - Region ill E(($[sy[4"d*]ggofs
'^^^^^^" e u^x m Office of Nuclear Facility Safety - IDNS k\\nla\\allsta\\prt20..wpt\\2'
ATTACHMENT 1 1.
T. W. Simpkin letter to T. Murley dated June 29,1993, transmitting Commonwealth Edison's request to amend Byron and Braidwood Stations' Technical Specifications to reflect the revised 10CFR20.
l 2.
T. W. Simpkin letter to T. Murley dated August 23,1993, transmittir.g Commonwealth Edison's request to amend Zion Station's Technical Specifications to reflect the revised 10CFR20.
3.
D. Saccomando letter to T. Murley dated August 17,1993, transmitting Commonwealth Edison's request to amend LaSalle Station's Technical Specifications to reflect the revised 10CFR20.
4.
D. Saccomando letter to T. Murley dated November 5,1993, withdrawing the proposed license amendments addressing the revised 10CFR20 for Byron, Braidwood, Zion and LaSalle Stations.
l l
l l
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ATTACHMENT A l
DESCRIPTION AND SAFETY ANALYSIS OF THE' PROPOSED CHANGES q
DESCRIP TION OF THE PROPOSED CHANGES
'j The proposed changes to the Byron, Braidwood, Zion and LaSalle Technical Specifications are prompted by the revision to 10CFR20. These changes entail revisions-to the " Radioactive Effluent Controls Program" section, and specifically address:
- 1) limitations on radioactive material released in liquid effluents; 2) updating a reference to the applicable paragraph of the new Part 20 and; 3) limitations on radioactive material l
released in gaseous effluents.
t 1.
PROPOSED CHANGES TO LIQUID EFFLUENT RELEASE LIMITS (Section 6.8.4.e.2 for Byron and Braidwood)
(Section 6.2.6.A.2 for Zion)
(Section 6.2.F.4.b for LaSalle)
DESCRIPTION AND BASES OF THE CURRENT REQUIREMENT l
This Technical Specification section places a limitation on the concentrations of' radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming' to 10CFR20, Appendix B, Table 11, Column 2. This limit relates to-the annual dose limit of 500 mrem currently listed in 10CFR20.
DESCRIPTION OF THE PROPOSED CHANGE The proposed change revises the limitation on.the concentrations of radioactive material released in liquid effluent to UNRESTRICTED AREAS to ten (10) times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402. The proposed change allows operational flexibility for liquid release rates while maintaining compliance with 10CFR20.1302.
4 BASES FOR THE PROPOSED CHANGE l
The basic roquirements for Technical Specifications'concerning effluents from nuclear power reactors are stated in 10CFR50.36a. These requirements indicate ;
{
that compliance with effluent Technical Specifications will maintain average annual
' eleases'of radioactive material in effluents to small percentages of the limits.
r specified in the current 10CFR20.106 (revised 10CFR20.1302).10CFR50.36a j
further states that a licensee is. permitted the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a' dependable source of power,' even under unusual operating conditions which may
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' Attachment A Page 2 temporarily result in releases higher than such small percentages, but still within the limits specified in the current 10CFR20.106 which references Appendix B, Table Il concentrations. These referenced concentrations are specific values that relate to an annual dose of 500 mrem. It is further indicated in 10CFR50.36a that when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable, as set forth ln 10CFR50, Appendix 1.
The liquid effluent concentrations listed in 10CFR20, Appendix B, Table 2, Column 2 are concentrations which, if inhaled or ingested by a member of the public continuously over the course of a year, would produce a total effective dose equivalent of 50 mrem. Application of 10CFR20, Appendix B, Table 2, Column 2 limits, on an instantaneous basis, would correspond to a maximum dose limit cf 50 mrem / year, which is 10 times more restrictive than the current limit.
Operational history has demonstrated that the use of the concentration values associated with 10CFR20.106 as Technical Specification limits has resulted in calculated maximum individual doses to a member of the public that are small percentages of the limits of 10CFR50, Appendix 1. Since a release concentration corresponding to a lim ting dose rate of 500 mrem / year has been acceptable as a i
Technical Specification limit for liquid effluents to meat the requirements of 10CFR50 Appendix 1, ',t is therefore unnecessary to reduce the limiting dose rate to 50 mrom/ year (i.e. the concentration in 10CFR20, Appendix B, Table 2, Column 2).
Thus, a value of 10 times the concentrations listed in 10CFR20, Appendix B, Table 2, Column 2 on an instantaneous basis would allow operational flexibility as -
referenced in 10CFR50.36a, as well as maintain the current level of effluent control (i.e. small percentages on 10CFR50, Appendix I limits).
To accommodate operational flexibility needed for effluent releases, the limit associated with the liquid release rate is being revised to indicate ten times the concentration stated in the revised 10CFR20, Appendix B, Table 2, Column 2. This proposed revision will retain operational flexibility consistent-with, and as referenced in,10CFR50.36a. Additionally, the use of concentration values that correspond to ten times the concentration values stated in the revised 10CFR20, Appendix B, Table 2, Column 2 will not have a negative impact on the ability to continue to operate within the limits of 10CFR50, Appendix 1.
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- Attachment A Page 3 2.
PROPOSED CHANGE TO UPDATE A REFERENCE TO 10CFR20 (Section 6.8.4.e.3 for Byron and Braidwood)
(Section 6.2.6.A.3 for Zion)
(Section 6.2.F.4.c for LaSalle)
D_ESCRIPTION AND BASES OF THE CURRENT REQUIREMENT This Technical _ Specification section specifies that monitoring, sampling, and analysis of radioactive liquid and gaseous effluents should be conducted in accordance with 10CFR20.106 and with the methodology and parameters in the ODCM. This paragraph ensures that programmatic controls will be consistent with the constraints set forth in the appropriate section of 10CFR20.
DESCRIPTION AND BASIS OF THE PROPOSED CHANGE The proposed change updates the reference from 10CFR20.106 to the current paragraph (10CFR20.1302).
3.
PROPOSED CHANGES TO GASEOUS EFFLUENT RELEASE LIMITS (Section 6.8.4.e.7 for Byron and Braidwood)
(Section 6.2.6.A.7 for Zion)
(Section 6.2.F.4.g for LaSalle)
DESCRIPTION AND BASES OF THE CURRENT REQUIREMENT This Technical Specification section places a limitation on the dose rate of radioactive material released in gaseous effluents to the SITE BOUNDARY conforming to 10 CFR Part 20, Appendix B, Table 11, Column 1. This limit relates -
to the annual dose limit of 500 mrem currently listed in 10CFR20.
DESCRIPTION OF THE PROPOSED CHANGE The proposed change clarifies the limitation on the dose rate of radioactive material released in gaseous effluents to the SITE BOUNDARY to 500 mrem /yr whole body,3000 mrem /yr skin, and 1500 mrem /yr organ dose. The proposed change allows operational flexibility for gaseous release rates while maintaining compliance with 10CFR20.1302.. The wording 1or the proposed change had formerly been located in the ODCM and is being relocated back to the Technical Specifications to heighten visibility of the limitations ensuring compliance with 10CFR20. The proposed change to this section reads as follows:
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Attachment A Page 4 l'
" Limitations on the dose rate resulting from radioactive materials released in gaseous effluents from the site to areas at or beyond the SITE BOUNDARY shall be limited to the following:
a)
For noble gases: less than or equal to a dose rate of 500 mrem /yr to the whole body and less than or equal to a dose rate of 3000 mrem /yr to the skin, and b)
For lodine-131, lodine-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 mrem /yr to any organ."
1 BASES FOR THE PROPOSED CHANGE The basic requirements for Technical Specifications concerning effluents from nuclear power reactors are stated in 10CFR50.36a. These requirements indicate that compliance with effluent Technical Specifications will maintain average annual releases of radioactive material in effluents to small percentages of the limits specified in the current 10CFR20.106 (revised 10CFR20.1302).10CFR50.36a further states that a licensee is permitted the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a i
J dependable source of power, even under unusual operating conditions which may temporarily result in releases higher than such small percentages, but still within the limits specified in the current 10CFR20.106 which references Appendix B, Table 11 concentrations. ~ These referenced concentrations are specific values that '
l relate to an annual dose of 500 mrem. It is further indicated in 10CFR50.36a 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, as set forth in 10CFR50, Appendix 1.
The gaseous effluent concentrations listed in 10CFR20, Appendix B, Table 2, Column 1 are concentrations which, if inhaled or ingested by a member of the public continuously over the course of a year, would produce a total effective dose equivalent of 50 mrem. Application of 10CFR20, Appendix B, Table 2, Column 1 l
limits, on an instantaneous basis, would correspond to a maximum dose limit of 50 mrem / year, which is 10 times more restrictive than the current limit.
l Operational history has demonstrated that the use of the concentration values associated with 10CFR20.106 as Technical Specification limits has resulted in calculated maximum individual doses to a member of the public that are small-percentages of the limits of 10CFR50, Appendix 1. Since a release concentration corresponding to a limiting dose rate of 500 mrem / year has been acceptable as a Technical Specification limit for gaseous effluents to meet the requirements of-10CFR50 Appendix 1, it is therefore unnecessary to reduce the limiting dose rate 'to 50 mrem / year (i.e. the concentrations in 10CFR20, Appendix B, Table 2, Column 1). A dose rate of 500 mrem / year on an instantaneous basis will allow k\\nla\\allsta\\prt20.wpt\\7
Attachment A Page 5 operational flexibility consistent with 10CFR50.36a, as well as maintain the current level of effluent control (i.e. small percentages on 10CFR50, Appendix I limits).
To accommodate operational flexibility needed for effluent releases, the limit associated with the gaseous release rate is being revised to indicate ten times the concentration stated in the revised 10CFR20, Appendix B, Table 2, Column 1.
This proposed revision will retain operational flexibility consistent with, and as referenced in,10CFR50.36a. Additionally, the use of concentration values that correspond to ten times the concentration values stated in the revised 10CFR20, Appendix B, Table 2, Column 1 will not have a negative impact on the ability to continue to operate within the limits of 10CFR50, Appendix 1.
Additionally, instantaneous dose rate limit guidance is provided in NUREG-0133 for gaseous effluent releases. This change is consistent with the approach provided in NUREG-0133 and also ensures the limits of Appendix I from 10CFR50 are not '
exceeded.
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'l 1
ATTACHMENT B
.1 J
PROPOSED CHANGES TO APPENDlX A, TECHNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES i
FOR
. j BYRON, BRAIDWOOD, ZION AND LASALLE AFFECTED PAGES INDEX Byron (NPF-37/66):
Pages 6-18, 6-19 i
Braidwood (NPF-72/77):
Pages 6-18, 6-19
[
Zion (DPR-39/48):
Pages 310a,310b LaSalle (Unit 1; NPF-11): Pages 6-19 t.
LaSalle (Unit 2; NPF-18): Pages 6 i f
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ATTACHMENT B (continued)
~
BYRON AFFECTED PAGES b
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