ML20058A265

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Proposed Tech Specs Re Limitations on Radioactive Matl Released in Liquid & Gaseous Effluents & New 10CFR21
ML20058A265
Person / Time
Site: Byron, Braidwood, Zion, LaSalle  File:ZionSolutions icon.png
Issue date: 11/10/1993
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20058A262 List:
References
NUDOCS 9312010009
Download: ML20058A265 (24)


Text

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) 2)

Identification of the procedures used to measure the values of the critical variables, 3)

Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-leakage, 4)

Procedures for the recording and management of data, 5)

Procedures defining corrective action for all off-control point chemistry conditions, and 6)

A procedure identifying: (A) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action.

d.

Post-accident Samplino A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions.

The program shall include the following:

1)

Training of personnel, 2)

Procedures for sampling and analysis, and 3)

Provisions for maintenance of sampling and analysis equipment.

e.

Radioactive Effluent Controls' Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by station procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded.

The program shall include the following elements:

1)

Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM, fg((u. g/(/L 2)

L mit 'tio s o /the conce'ntrption 'of adiodcti matdrial ele se in} qui eff/uenpsto NR TRIQtED$EASJonfo ng bef( A r

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y 3)

Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR N 108 and with the methodology and parameters in the ODCM, 4 N 20.1302 BYRON - UNITS 1 & 2 6-18 AMENDMENT NO.f# 3v D

KO P

BYRON L

INSERT A Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402, e

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ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) 4)

Limitations on th annual and quarterly doses or dose comitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR Part 50, 5)

Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, 6)

Limitations on the operability and use of the liquid and gaseous effluent treatment. systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactkity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose er dose commitment conforming to Appendix I to 10 CFR Part 50,

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7 thedose te r 'sulti/g f a radioact/ve

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o ate ial elesedfnga ous flueptst ared be nd e S TE 73Merf 3 -7 BOU DARY con,ctmipg to ed es aysoci ed with 1 CFR Part 20, Ap endi B,/Tably'II, lumn/1,

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8)

Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, 9)

Limitations on the annual and cuarterly doses to a MEMBER OF THE PUBLIC from Iodine-131, Iocine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, and

10) Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

f.

Radiological Environmental Monitorino Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways and 2 verification of the i

accuracyoftheeffluentmonitoring,progra(m)andmodelingof environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

1)

Monitoring, sampling, analysis, and reporting'of radiation and radionuclides in the environment in accordance with-the methodology and parameters in the ODCM, 4

BYRON - UNITS 1 & 2 6-19 AMENDMENT NO g 4

i

~

BYRON a

INSERT B i

1 1

7)

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,

)

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T I

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ATTACHMENT B (continued)

BRAIDWOOD AFFECTED PAGES i

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4

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ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) 2)

Identification of the procedures used to measure the values of the critical variables, 3)

Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in-leakage, 4)

Procedures for the recording and management of data, 5)

Procedures defining corrective action for all off-control point chemistry conditions, and 6)

A procedure identifying: (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action.

d.

Post-accident Samoling A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions.

The program shall include the following:

i 1)

Training of personnel, 2)

Procedures for sampling and analysis, and 3)

Provisions for maintenance of sampling and analysis equipment.

e.

Radioactive Effluent Controls Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable.

The program (1) shall be contained in the ODCM, (2) shall be implemented by station procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

1)

Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM, htnitationreihased i{on t'hhconcenhationsM radihqtive alterial

((4(" *g 2) n iquid )ffluenthto UNRESTRICTED' AREAS cBnforming to104FRPar(ts20,AppeqdixB,MableIlxColumiig,

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s Teegr A 3)

Monitoring, sampling, and analysis of radioactive liquid and l

gaseous effluents in accordance with 10 CFR 20.J0C and with the methodology and parameters in the ODCM,

2., n o t BRAIDWOOD - UNITS 1 & 2 6-18 AMENDMENT NO. JI f 1

BRAIDWOOD f

INSERT A Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402, I

f 1

I I

i i

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f ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued) 4)

Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR Part 50, 5)

Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, 6)

Limitations on the operability and use of the liquid and~

gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50,

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d te ra to reas,eyondsthe ma rial releasied i gase ps e luent ssocatedNithIQCFR\\Part{TE ARY nfo ' ing the\\ doses BOURO,4ixBATabi 20, nssar &

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8)

Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appe301,< I to 10 CFR Part 50, 9)

Limitations on the annual and quarterly doses to a MEMBER OF THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, and

10) Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

f.

Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant.

The program shall provide (1) representative measurements of radio' activity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways.

The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

j i

1)

Monitoring, sampling, analysis, and reporting of radiation and

'1 radionuclides in the environment in accordance with the methodology and parameters in the ODCM, BRAIDWOOD - UNITS 1 & 2 6-19 AMENDMENTNO.JV N

~

l BRAIDWOOD j

J INSERT B 7)

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, i

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ATTACHMENT B (continued)

ZION AFFECTED PAGES

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6.2 (Continued) 5.

Drills of the emergency procedures described in Specification 6.2.1.0 shall be conducted at the frequency specified in 'he Generating Station Emergency Plan. These drills will be planned so that during the course of the year, cximunication links are tested and outside agencies are contacted.

(

6.

The following programs shall be established, implemented, and maintained:

A.

Radioactive Effluent Controls ErAgr3m

[

A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and

(

for maintaining the doses-to HEMBERS OF THE.PUBLIC from radioactive effluents as low as reasonably

?

achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by station

(

procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

(

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1)

Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation

('

Including survelliance tests and setpoint determination in accordance with the methodology in the

)

OOCH, f

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Liditat 6ns o the oncer(tra 'ons f dio Iv ate al eleas 'd in[Colujn[n 2, lguld effl nt to

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0 CF Pa 20 App, dixj, Ta e IJ, tJ6eI/i

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Monitoring, sampilng, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20M06 and with the methodology and parameters in the OOCH,

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AG. /302 -

2 4)

Limitations on the annual and quarterly doses or dose commitment to a HEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR Part 50, 5)

Determination of cumulative and projected dose contributions from radioactive effluents for the 2

current calendar quarter and current calendar year in accordance with the methodology and

(

parameters in the ODCH at least every 31 days,

)

Limitations on the operability and use of the liquid and gaseous effluent treatment systems to

)

6).

ensure that the appropriate portions of these systems are used to. reduce releases of radioactivity when the projected doses in a 31-r;ay period would' exceed 2 percent of the guidelines for the annual ( '

dose or dose commitment conforming to Apper. dix I to 10 CFR Part 50,

(

310a Amendment Nos. ter d iM

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ZION INSERT A Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402, 2

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6.2 (Continued) haNst'/N 7kLimitationsonthekdosekrate esubting rorskradlokctiv'e material relea' sed kn ga couskeffluentk to with\\10CrRPakt20'kphendt' con oral g to the doses'assohlate

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Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous

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effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, d

9)

Limitations on the annual and quarterly doses to a HEHBER OF THE PUBLIC from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days In gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50,

(

3

10) Limitations on the annual dose or dose cormaltment to any MEMBER OF THE PUBLIC due to releases of

(

radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

B.

Radioloalcal Environmental Monitorina frocram

(

A program shall be provided to monitor the radiation and radionucildes in the environs of the plant. The i

program shall provide (1) representative measurements of radloactivity In the highest potential exposure

(

pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained in the 00CM, (2) conform to the guidance t of Appendix I to 10 CFR Part 50, and (3) include the following:

2 1)

Honttoring, snpling, analysis, and reporting of radiation and radionucildes in the environment in 2

accordance with the methodology and parameters in the ODCH,

}

(

2)

A Land Use Census to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are Identified and that modif kations to the monitoring program are made if required by the results of this (

census, and 1

3)

Parttclpation in a Interlaboratory Comparison Program to ensure that independent checks on the precision (

and accuracy of the measurements or radioactive materials in environmental sample matrices are performed j

as part of the quality assurance program for environmental monitoring.

6.3 Action to be Taken in the Event of a Renortable Event in Plant Operation:

Any Reportable Event shall be promptly reporte:I to the Vice President PHR Operations or his designated alternate.

l The incident shall be promptly reviewed pursuant to Specification 6.1.7.B.2.(k) and a separate report for each l

reportable event shall be prepared in accordance with the requirements of 10CFR 50.73.

310b Amendment Nos. Ned=13d

ZION INSERT B 7)

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 mrern/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, i

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f k\\nla\\allsta\\prt20.wpt\\14 u

ATTACHMENT B (continued)

LASALLE AFFECTED PAGES b

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ADMINISTRATIVE CONTROLS l

PLANT OPERATING PROCEDURES AND PROGRAMS (Continued) 4.

Radioactive Effluent controls Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

Limitations on the operability of radioactive liquid and gaseous a.

monitoring instrumentation including surveillance tests and set-point determination in accordance with the methodology in the

ODCM, f

yf' b.

Li tati so th con ntr ion of fadi ti e ma rf 1 re Cf #

1 sed li uid ffl nts oU ESTpCTE AR'AS c fo in to g

) CF ar+ 20, ppe ix, Ta eIJ,CoJumn Monitoring, sampling, and analysis of radioactive liquid and c.

gaseous effluents in accordance with 10 CFR 2 WLOW and with the methodology and parameters in the ODCM,

(

d.

Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conform-ing to Appendix I to 10 CFR Part 50, e.

Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, f.

Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 per-cent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50, 7i'ep/a< w,'tt eousefflu';ntshe d. se ra / re/uiti a fr 'a ra oact/ve =/iterifi g.

Limi atio on rel ased ng b ar as b ond e 5 TE B UNDA~Y In $m8' O -- ->

co forssi g to the oses soci ted ith 0 CF Par 20, Appe df'xB, able/II, { lumn,

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h.

Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, AmendmentNo.55,B5.,S[

LA SALLE UNIT 1 6-19

LASALLE (Unit 1)

INSERT A Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402, F

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LASALLE (Unit 1)

INSERT B g.

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:

1.

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 2.

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, b

i k\\nla\\allsta\\prt20.wpt.\\16

ADMINISTRATIVE CONTROLS PLANT OPERATING PROCEDURES AND PROGRAMS (Continued) 4.

Radioactive Effluent Controls Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a.

Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and set-point determination in accordance with the methodology in the

ODCM, Lim tati 6s on the ncen rati s of/ radi acti e ma rial /re-

}f[# Myf' b.

9 le sed th lig d ef luen s to NRES"RICT D AR AS co form}hg to

-7 1 CFR/artp,Ap,endi B,Tble/11,C 4 _-

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umn c.

Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20;t06-and with the methodology and parameters in the ODCM,

(

d.

Limitations on the annual and quarterly doses or dos comm ent to a MEMBER OF THE PUBLIC from radioactive materials in liquio effluents released from each unit to UNRESTRICTED AREAS conform-ing to Appendix I to 10 CFR Part 50, e.

Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, f.

Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity.

when the projected doses in a 31-day period would exceed 2 per-cent of the guidelines for the annual dose or dose connitment t

conforming to Appendix I to 10 CFR Part 50, Lim #itati ns the ose ate sult ng f om r dioa ive mat rial

}e[g 9,'d'

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eff ents to a as eyon the ITE OU ARY g.

r ease in seou a

c nforming the dose asso iated with 10 R Pa 2, Ap en-b4cf 4) g axB/Tabl II, 01, 1, h.

Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50, LA SALLE - UNIT 2 6-19 Amendment No. U,,78

LASALLE (Unit 2)

INSERT A Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20,1001-20.2402, i

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r LASALLE (Unit 2)

INSERT B i

g.

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:

1.

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 2.

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, 4

i 1

9 i

k\\nla\\allsta\\prt20.wpt\\18

ATTACHMENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATIONS Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to 10CFR50.92(c), a proposed amendment to an operating license involves no significant hazards if operation of the facility in accordance with the proposed amendment would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2.

Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3.

Involve a significant reduction in a margin of safety.

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 revised Part 20, and; 3) limitations on radioactivo material released in gaseous effluents.

A.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes to the radioactive material concentration limits in liquid and gaseous effluent releases do not impact previously evaluated accidents tmcause there is no change in the types and amounts of effluents that will be released.

There will be no increase in individual or cumulative occupational radiation exposures.

B.

The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes have no effect on the probability of an accident. The changes are administrative in nature and do not affect plant design or operation.

There is no change to the types and amounts of effluent that will be released, nor is there an increase in individual or cumulative occupational radiation exposures.

k\\nla\\allsta\\prt20.wpt\\19

Attachment C Page 2 C.

The proposed changes do not involve a significant reduction in a margin of safety.

The proposed revision to the radioactive material concentration limits in the liquid effluents will not reduce a margin of safety. There is no change in the types and amounts of effluents released. The current 10CFR20, Appendix B, Table 11, Column 2 limits allow a maximum annual dose of 500 mrem. The revised 10CFR20 allows a maximum total effective dose equivalent of 50 mrem / year. Using a factor of 10 multiplier on the new Column 2 value* has no impact on the ability to meet the 10CFR50, Appendix I limits, or the e aual dose limit specified in 10CFR20. Use of the instantaneous dose limit, in con 3anction with the more restrictive quarterly and annual dose limits in 10CFR50, Appendix 1, will ensure that the requirements of 10CFR20.1302 are met. It also ensures continued operational flexibility. Controls are in place to prevent total dose from exceeding the 10CFR20 and 10CFR50 limits.

The proposed revision which specifies the limit of radioactive material concentration in the gaseous effluents will not reduce a margin of safety. There will be no change in the types and amounts of effluents released. The revision proposes a doss limit of 500 mrem / year to the whole body. This limit is currently used in the Commonwealth Edison Offsite Dose Calculation Manual (ODCM) and is also _

consistent with the current 10CFR20, Appendix B, Table ll, Column 1 limits. The revised 10CFR20 allows a maximum total effective dose equivalent of 50 mrem / year.

Using a value of 500 mrem / year as an instantaneous release limit has no impact on the ability to meet the 10CFR50, Appendix I limits, or the annual dose limit in.

10CFR20..Use of the instantaneous dose limit, in conjunction with the more restrictive quarterly and annual dose limits in 10CFR50, Appendix 1, will ensure that the requirements of 10CFR20.1302 are met it also ensures continued operational flexibility. Controls are in place to prevent total dose from exceeding the 10CFR20 and 10CFR50 limits.

The only other proposed change involves updating a 10CFR20 paragraph reference to the applicable paragraph in the revised 10CFR20. This revision entails no change to the types and amount of effluents that will be released and has no effect on the margin of safety related to erfaunt releases.

Based on-the above evaluation, Commonwealth Edison has concluded that these changes do not involve significant hazards considerations.

k\\nla\\allsta\\prt20.wpt\\20

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ATTACHMENT D ENVIRONMENTAL ASSESSMENT Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21. It has been determined that the proposed change mects the criteria for a categorical exclusion as provided for under 10CFR51.22(c)(9).

This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10CFR50 and the amendment meets the following specific criteria:

(i) the amendment involves no significant hazards considerations As demonstrated in Attachment C, this proposed amendment does not involve any significant hazards considerations.

(ii) there is no significant change in the types or significant increa.ce in the amounts of any effluents that may be released offsite As documented in Attachment A, there will be no change in the types or significant increase in the amounts of any effluents released offsite.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure The proposed change will not result in changes ;n the operation or configuration of the facility. There will be no '.:hange in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant Therefore there will be no increase in individual or cumulative occupational radiation' exposure resulting from this change.

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