ML20058L135

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Safety Evaluation Supporting Amends 174 & 165 to Licenses DPR-77 & DPR-79,respectively
ML20058L135
Person / Time
Site: Sequoyah  
Issue date: 12/09/1993
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20058L118 List:
References
NUDOCS 9312160154
Download: ML20058L135 (5)


Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 174 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 165 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SE000YAH NUCLEAR PLANT. UNITS 1 AND 2 l

DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

i By application dated June 16, 1993, the Tennessee Valley Authority (the licensee) proposed amendments to the Technical Specifications (TS) for Sequoyah Nuclear Plant (SQN) Units 1 and 2.

The requested changes would support the licensee's plan to implement the revised 10 CFR Part 20.

2.0 Evaluation The licensee has revised the TS to include wording that is consistent with the i

revised 10 CFR Part 20, Standards for Protection Acainst Radiation, and will retain the same overall level of effluent control required to meet the design

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objectives of Appendix I to 10 CFR Part 50. An evaluation was not performed on item 2. regarding the definition of " UNRESTRICTED AREA" because this item is under review by the staff.

The proposed TS changes and evaluations follow:

a.

Technical Specification 1.17 The licensee has proposed to revise the definition of HEMBER(S) 0F THE PUBLIC to conform to the definition used in 10 CFR 20.1003.

The change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 definition and is acceptable.

b.

Technical Specification 1.37 The licensee has proposed to revise the definition of UNRESTRICTED AREA to conform to the definition used in 10 CFR 20.1003.

The staff is continuing t!'e evaluation of this item and, therefore, will not incorporate the proposed change at this time.

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c.

Technical Specification 3.11.1.4 The licensee has proposed to change the denominator in the TS equation from " maximum permissible concentration of isotope 1" to read " effluent concentration limit of isotope 1."

The licensee has also proposed to change the wording in the bases for the liquid holdup tanks 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 20.1001 - 20.2401, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area."

The changes are administrative in nature to incorporate the terminology and references used in the revised 10 CFR Part 20 and are acceptable.

d.

Technical Specification 6.8.5 The licensee has proposed to revise item f.2 of this TS to state that the Offsite Dose Calculation Manual effluent control program will contain

" Limitations on the concentration of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to ten times the concentrations stated in 10 CFR 20.1001 - 20.2401, Appendix B, Table 2, Column 2."

Also, the licensee proposes to revise item f.3 of this TS to replace the old "10 CFR 20.106" reference with "10 CFR 20.1302."

Regarding the " ten times" change, the licensee has proposed this change in order 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.

10 CFR 50.36a r

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 dose 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 staff to help maintain annual average releases of radioactive material in gaseous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part 50.

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For the purposes of this TS, 10 CFR Part 20 is used as a source of l

reference values only. These TS requirements 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 in radiation doses higher than specified in Appendix I of 10 CFR Part 50. However, these releases are within the implicit limits in 10 CFR 20.106 and the explicit limits in 10 CFR 20.1302 which references Appendix B, Table 2 concentrations.

These referenced concentrations in the old 10 CFR Part 20 are specific values which relate to an annual dose of 500 mrem. The liquid effluent radioactive concentration limits given in Appendix B, Table 2, Column 2 i

to 10 CFR 20.1001 - 20.2401 are based on an annual dose of 50 mrem total effective dose equivalent. Since an instantaneous release concentration corresponding to a dose rate 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 likely to be exceeded, it is not necessary to reduce this limit by a factor of ten.

The licensee states that operational history at Sequoyah 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 public 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 and 40 CFR Part 190.

Based on the above, it is acceptable that the instantaneous 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.

1 Regarding the change from "10 CFR 20.106" to "10 CFR 20.1302," this change is administrative in nature to incorporate the corresponding l

revised 10 CFR Part 20 section number and is acceptable.

e.

Technical Specification 6.8.5 The licensee has proposed to revise item f.7 of this specification to read as follows:

l

" Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the i

SITE B0UNDARY shall be limited to the following:

1.

For noble gases:

Less than or equal to a dose rate of 500 mrem /yr 2

to the total body and less than or equal to a dose rate of i

3000 mrem /yr to the skin, and I

__ 2.

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 mrem /yr to any organ."

The licensee has proposed this change in order to retain operational flexibility consistent with 10 CFR Part 50, Appendix I, concurrent with l'

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. 10 CFR 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluents to unrestricted areas, produced during normal raactor l

operations, to levels that are as low as reasonably achievable (ALARA).

l I<

For power reactors, Appendix I to.10 CFR Part 50 contains:the numerical guidance to meet'the ALARA requirement. The dose 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 specification.

were chosen by the staff to help maintain annual average releases of radioactive material in gaseous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part 50.

For purpose _of the bases of this TS,10 CFR Part 20 is used as a source of reference values only. These TS requirements allow operational flexibility, compatible i

with considerations of health and safety, which may_ temporarily result in release rates which, if continued for the calendar quarter, would result I

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 i

(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 times as an assurance that the values in Appendix I of 10 CFR Part 50 are not likely to be exceeded.

The licensee states that the use of the proposed TS will not have a negative impact on the ability to continue to operate within the design objectives in Appendix I of 10 CFR Part 50.

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

f.

The licensee proposed removal of " annual" from the note reference to

, Administrative Section 6.15 as it relates to the requirement.to submit Final Safety Analysis Report (FSAR) updates.

This change is consistent with a recent change to 10 CFR 50 to reduce the regulatory background on licensees that allows FSAR update submittals to be submitted-following refueling outages rather than annually.

Therefore, this proposed change is acceptable.

I !

3.0 STATE CONSULTATION

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

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a i

facility component located within the restricted area as defined in 10 CFR Part 20.

The amendments also incorporate certain administrative changes. 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 comment on i

such finding (58 FR 41514). 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 environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

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

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

Principal Contributor: S. Klementowicz Dated: December 9, 1993 e