ML20058L437

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Proposed Tech Specs Amend 187 Including Changes Making PDTS Consistent W/New 10CFR20 Regulations
ML20058L437
Person / Time
Site: Rancho Seco
Issue date: 12/09/1993
From:
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20058L434 List:
References
NUDOCS 9312160351
Download: ML20058L437 (15)


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4 ATTACHMENT 1 Proposed License Amendment,No.187.-

l Permanently Defueled Technical Specification' Changes -

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PAGE BY PAGE REMOVAUINSERTION INSTRUCTIONS r

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_ Dl-3 BD3/4-9 BD3/4-9 D6-11 D6-ll

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D6-12

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D6-13 D6-13 D6 ' D6-14 --

i D6-15 D6-15 D6-18_

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D6-19 D6-19 j

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RANCilO SECO UNIT 1 PERMANENTLY DEFUELED TECIINICAL SPECIFICATIONS INDEX DEFINITIONS SECTION PAGE D1.0 DEFINITIONS.

D1-1 DI.1 ACTION D1-1 D1.2 PERMANENTLY DEFUELED MODE.

D1-1 DI.3 OPERABLE - OPERABILITY D1-1 DI.4 INSTRUMENTATION SURVEILLANCE D1-1 DI.4.1 INSTRUMENT CHANNEL D1-1 D1.4.2 CHANNEL TEST D1-1 DI.4.3 INSTRUMENT CHANNEL CHECK D1-1 D1.4.4 INSTRUMENT CHANNEL CALIBRATION D1-2 DI.4.5 FUNCTIONAL TEST.

D1-2 D1.5 SITE BOUNDARY.

DI-2 D1.6 PROCESS CONTROL PROGRAM (PCP)

DI-2 DI.7 OFF-SITE DOSE CALCULATION MANUAL (ODCM).

D1-2 DI.8 MEMBER OF THE PUBLIC D1-2 DI.9 LICENSEE EVENT REPORT.

D1-2 D1.10 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP)

MANUAL.

D1-3 D1.11 NUCLEAR SAFETY D1-3 D1.12 INDUSTRIAL AREA.

D1-3 DI.13 RESTRICTED AREA.

D1-3 DI.14 CONTROLLED AREA.

D1-3 DI.15 UNRESTRICTED AREA.

D1-3 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS SECTION PAGE D3/4.0 APPLICABILITY.

D3/4-1 D3/4.1 SPENT FUEL POOL LEVEL.

D3/4-2 D3/4.2 SPENT FUEL POOL TEMPERATURE.

D3/4-3 D3/4.3 FUEL STORAGE BUILDING LOAD HANDLING LIMITS D3/4-4 D3/4.4 SPENT FUEL STORAGE AREA RADIATION MONITOR.

D3/4-5 D3/4.5 SPENT FUEL POOL WATER CHEMISTRY.

D3/4-6 D3/4.6 LIQUID llOLD-UP TANKS D3/4-7 D3/4.7 SEALED SOURCE CONTAMINATION.

D3/4-8 BASES SECTION PAGE D3/4.0 APPLICABILITY.

BD3/4-1 D3/4.1 SPENT FUEL POOL LEVEL.

BD3/4-4 D3/4.2 SPENT FUEL POOL TEMPERATURE.

BD3/4-5 D3/4.3 FUEL STORAGE BUILDING LOAD HANDLING LIMITS BD3/4-6 D3/4.4 SPENT FUEL STORAGE AREA RADIATION MONITOR.

BD3/4-7 D3/4.5 SPENT FUEL POOL WATER CHEMISTRY.

BD3/4-8 D3/4.6 LIQUID HOLD-UP TANKS BD3/4-9 D3/4.7 SEALED SOURCE CONTAMINATION.

BD3/4-10 Proposed Amendment No. 187 DI-1

RANCilO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS l

DEFINITIONS (Continued)

U.4 INSTRUMENT CHANNEL CALIBRATION An INSTRUMENT CHANNEL CALIBRATION is a test, and adjustment (if necessary), to establish that the channel output responds with acceptable range and accuracy to known values of the parameter which the channel measures or an accurate simulation of these values.

INSTRUMENT CRANNEL CALIBRATION shall encompass the entire channel, including equipment actuation, alarm or trip, whichever are applicable, and shall be deemed to include the CHANNEL TEST.

D1.4.5 FUNCTIONAL TEST A FUNCTIONAL TEST shall be the determination or verification of the-capability of a system or component to meet specified requirements by subjecting the system or component to a set of physical or operating I

conditions.

D1.5 SITE BOUNDARY The SITE BOUNDARY shall be that line beyond which the land is neither owned, nor leased, nor otherwise controlled by the licensee.

DI.6 PROCESS CONTROL PROGRAM (PCP)

The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, state regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.

D1.7 OFF-SITE DOSE CALCULATION MANUAL (ODCM)

The OFF -SITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of off-site doses resulting from radioactive gaseous and liquid effluents, and in the calculation of gaseous and liquid effluent monitoring Alarm / Trip Setpoints.

The ODCM shall also contain the Radioactive Effluent Controls Program required by Specification D6.8.3a and descriptions of the information that should be included in the Semiannual Radioactive Effluent Release Report required by Specification D6.9.3.

D1.8 MEMBER OF THE PUBLIC MEMBER OF THE PUBLIC is defined as an individual in a CONTROLLED or UNRESTRICTED AREA.

However, an individual is not a MEMBER OF THE PUBLIC during any period in which the individual receives an occupational dose.

D1.9 LICENSEE EVENT REPORT Defined under Administrative Controls Specification D6.9.5.

Proposed Amendment No. 187 DI-2

RANCllO SECO UNIT 1 PERMANENTLY DEFUELED

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TECilNICAL SPECIFICATIONS DEFINITIONS (Continued)

D1.10 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP) MANUAL The RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP) MANUAL shall l

contam' a description of the Rancho Seco radiological environmental l

l monitet'ag program.

The REMP MANUAL shall also contain the REMP l

requirements of Specification D6.8.3b, a description of the environmental samples to be collected, sample locations, sampling frequencies, sample analysis criteria, and a description of the information to be included in the Annual Radiological Environmental Operating Report as required by Specification D6.9.2.3.

D1.11 NUCLEAR SAFETY l

NUCLEAR SAFETY shall refer to those systems, compnaents and j

administrative controls that have or may have an effect on the health l

end safety of the gencral public.

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DI.12 INDUSTRIAL ARLA l

The INDUSTRIAL AREA shall be that portion of the site property, the access to which is controlled as described in the NRC approved Security Plan by security fencing, equipment and personnel.

l D1.13 RESTRICTED AREA RESTRICTED AREA is defined. as an area, access to which is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

RESTRICTED AREA does not include areas used as residential quarters, but separate rooms in a residential building may be set apart as a RESTRICTED AREA.

D1.14 CONTROLLED AREA i

CONTROLLED AREA is defined as an arca, outside of a RESTRICTED AREA but inside the SITE BOUNDARY, access to which can be Ibnited by the licensee for any reason.

D1.15 UNRESTRICTED AREA f

UNRESTRICTED AREA is defined as an area, access to which is neither limited nor controlled by the licensee.

Proposed Amendment No. 187 Dl-3

RANCilO SECO UNIT 1

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PERMANENTLY DEFUELED TECilNICAL SPECIFICATIONS L

D3/4.6 LIOUID HOLD-UP TANKS BASES Restricting the quantity of radioactive material contained in the I

specified outdoor tanks provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting concentration at the nearest potable water supply and the nearest surface water supply in an unrestricted area would be less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2.

The limit applies to each tank.

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Tanks included in this specification are those outdoor tanks that contain radioactive liquid, are not surrounded by liners, dikes, or walls capable of holding the tank contents, or do not have tank overflows and surrounding area drains connected to a liquid radwaste treatment system.

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l RANCHO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS l

ADMINISTRATIVE CONTROLS (Continued)

AUDITS (Continued) m.

The PCP and implementing procedures for processing and packaging of radioactive wastes from liquid systems at least once per 2 years, n.

The performance of activities required by the Quality Assurance Program for Effluent Control and Environmental Monitoring at least once per year.

Audit reports of reviews encompassed by Specification D6.5.4 shall be forwar(ed to the DAGM, Nuclear, the MSRC Chairman and. the management positions responsible for the areas reviewed within 30 days after completion.

D6.6 LICENSEE EVENT REPORT ACTION l

l The following actions shall be taken for events which are reportable as I

LICENSEE EVENT REPORTS:

a.

The Commission shall be notified and a report submitted per Specification D6.9.5, pursuant to the requirements of l

10 CFR 20.2203, 50.73, and appropriate portions of 73.71 (as described in the Rancho Seco Physical Security Plan), and b.

Each LICENSEE EVENT REPORT shall be reviewed by the PRC and the results of this review submitted to the MSRC.

Each LICENSEE EVENT REPORT shall be reviewed and approved by the DAGM, Nuclear, or designee.

t D6.7

-NOT USED-D6.8 PROCEDURES. PLANS. MANUALS. AND PROGRAMS D6.8.1 Written procedures, plans, manuals, and programs shall be established, implemented and maintained covering the activities referenced below:

a.

The applicable procedures recommended in Appendix "A" of Safety Guide 33, November 1972 l

b.

Irradiated Core Component Storage, Fuel Movement Operations, Decommissioning, and Decontamination c.

Surveillance and test activities on equipment required for long-term safe storage of irradiated core components d.

Security Plan implementation e.

Emergency Plar implementation f.

Fire Protection Program Plan implementation g.

PCP implementation h.

ODCM implementation i.

REMP MANUAL implementation J.

Quality Assurance Program for Effluent Control and Environmental Monitoring using the guidance of Regulatory Guide 4.15, Revision 1, February 1979 k.

Certified Fuel Handler Training Program implementation 1.

Quality Assurance Program implementation m.

Radiation Protection Program implementation Proposed Amendment No. 187 D6-ll 1

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RANCHO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS i

ADMINISTRATIVE CONTROLS (Continued) i PROCEDURES. P LAN S. M ANU AL S. AND PROGRAMS (Continued)

D6.8.2 Each procedure, plan, manual, and program of Specification D6.8.1 above and changes thereto shall be reviewed and approved as set forth in Specification D6.5.

D6.8.3 The following programs shall be established, implemented, and maintained:

a.

Radioactive Effluent Controls Procram j

A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to a MEMBER 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 Administrative, Chemistry, and Operating 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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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, 2)

Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 CFR Part 20, Appendix B, Table 2, Column 2, l

3)

Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with l

the methodology and parameters in the ODCM, 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 i

UNRESTRICTED AREAS conforming to Appendix I to 10 CFR 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

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and parameters in the ODCM at least every 31 days, 6)

Limitations on the OPERABILITY and use of the gaseous effluent trea tment 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 50, Proposed Amendment No. 187 D6-12

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PERMANENTLY DEFUELED TECilNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Con ti nued)

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PROCEDURES. PLANS. MANUALS. AND PROGRAMS (Continued) i 7)

Limitations on the OPERABILITY and use of the liquid effluent trea tment system to ensure that the appropriate portions of i

this system are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 8 1/3 percent (1/12) of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR 50.

8)

Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the SITE BOUNDARY conforming to the doses associated with 10 CFR 20, Appendix B, Table 2, Column 1, l

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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 50, 10)

Limitations on the annual and quarterly doses to a MEMBER OF THE PUBLIC from Tritium and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents re)wased from each unit to areas beyond the SITE BOUNDARY i

conforming to Appendix I to 10 CFR 50, 11)

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

b.

Radioloaical Environmental Monitorina Procram (REMP)

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 accuracy of the effluent monitoring program and modeling of environmental exposure pathways.

The program shall (1) be contained in the REMP MANUAL, (2) conform to the guidance of Appendix I to i

10 CFR 50, and (3) include the following.

1)

Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the I

methodology and parameters in the REMP MANUAL, 1

2)

A Land Use Census to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that

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modifications to the monitoring program are made if required j

by the results of this census, and Proposed Amendment No. 187 D6-13

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RANClio SECO UNIT 1

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PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)

PROCEDURES. PLANS. MANUALS. AND PROGRAMS (Continued)

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Participation in an Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

D6.8.4 Each program in Specification D6.8.3 and changes thereto shall be reviewed and approved as set forth in Specification D6.5 and D6.14.

D6.9 REPORTING REOUIREMENTS D6.9.1 ROUTINE REPORTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional Administrator of the Region V Office unless otherwise noted.

D6.9.2 ANNUAL RADIOLOGICAL REPORTS Annual reports covering the activities of the unit, as described below, for the previous calendar year shall be submitted as follows:

D6.9.2.1 Annual Individual Monitorina Results Reoort The Annual Individual Monitoring Results Report for the previous calendar year shall be submitted to the Commission by April 30 of each l

year in compliance with 10 CFR 20.2206.

D6.9.2.2 Annual Ernosure Reoort The Annual Exposure Report for the previous calendar year shall be submitted to the Commission within the first calendar quarter of each calendar year in accordance with the guidance contained in Regulatory Guide 1.16.

D6.9.2.3 Annual Radioloaical Environmental Ooeratina Reoort The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year.

The report shall include summaries, interpretations, and analysis of trends of the results of.the Radiological Environmental Monitoring Program for the reporting period.

The material provided shall be consistent with the objectives outlined in (1) the ODCM, (2) the REMP MANUAL, and (3) Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR 50.

Proposed Amendment No. 187 D6-14 l

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RANCIIO SECO UNIT 1 PERMANENTLY DEFUELED TECIINICAL SPECIFICATIONS ADMINISTRATIVE CONTROLS (Continued)

D6.9.3 SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Semiannual Radioactive Effluent Release Report covering the l

operation of the unit during the previous 6 months shall be submitted within 60 days after January 1 and July 1 of each year.

The report shall include a summary of the quantities of radioactive' liquid and gaseous effluents and solid waste released-from the unit.

The material provided shall be (1) consistent with the objectives outlined in.the l

ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section l'

IV.B.1 of Appendix I to 10 CFR 50.

D6.9.4 ANNUAL REPORT A routine report consisting of shutdown statistics, a narrative summary of shutdown experience, major maintenance of structures, systems, and components required for long-term safe storage of irradiated fuel j

assemblies, and tabulations of facility changes,~ tests or experiments i

required pursuant to 10 CFR 50.59(b) shall be submitted on an' annual l

basis to the U.

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Nuclear Regulatory Commission, Document Control Desk, j

Washington, D.C.

20555, with a copy to the Regional Office, postmarked i

no later than 30 days following the twelve month period covered by the j

report.

j D6.9.5 LICENSEE EVENT REPORT

.I The types of events listed in 10 CFR 20.2203, 50.73'and the appropriate l

i portions of 73.71 (as described in the Rancho.Seco Physical Security f'

Plan) shall be the subject of LICENSEE EVENT REPORTS, submitted to the U.S.

Nuclear Regulatory Commission (NRC), Document Control' Desk, Washington, D.C.

20555, within the time requirements - of 10 CFR 20.2203,

.l 50.73 and 73.71.

An additional copy shall also be submitted,to the l

Regional Administrator of the Region V Office.

The written report shall include a completed copy of a LICENSEE EVENT REPORT" form, pursuant to i

10 CFR 20.2203, 50.73 and 73.71 and the guidance of NUREG-1022, and a l'

-l description of corrective actions and measures to-prevent recurrence.

Supplemental reports may be required to fully describe fina; resolution-of the. occurrence.

For corrected or supplemental reports, a LICENSEE EVENT REPORT shall be completed and reference shallRbe made to the'

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original report date, pursuant to the requirements of 10 CFR 20.2203, l1 50.73 or 73.71 as appropriate.

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f D6.9.6 ENVIRONMENTAL REPORTS a.

When a change to the plant design or to the' plant' operation is f

j planned which would have a significant adverse effect on the:

'l environment or which involves an environmental matter or question.

not previously reviewed and evaluated by the NRC, a report on the change will be made to the NRC prior to implementation.

The' report will include a description and evaluation of the change, including a'

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supporting benefit-cost analysis.

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Proposed

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Amendment No. 187 D6-15.

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RANCHO SECO UNIT 1 PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS e

J A DM"N T STRATIVE CONTROLS (Continued)

D6.12 HIGH RADIATION AREA 1

D6.12.1 In lieu of the " control device" or " alarm signal" required by l

10 CFR 20.1601.

a.

Each High Radiation Area in which the intensity of radiation is equal to or greater than 100 mrem /hr but less than 1,000 mrem /hr-shall be barricaded and conspicuously posted as a High Radiation 1

Area, and entrance thereto shall be controlled by issuance of a Radiation Work Permit.

Any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose i

rate in the area.

b.

Each High Radiation Area in which the intensity of radiation is equal to or greater than 1,000 mrem /hr shall be subject to the t

provisions of Specification D6.12.la above, and, in addition, locked doors shall be provided to prevent unauthorized entry into such' area.

The keys shall be maintained under the administrative control of the on duty Shift Supervisor.

In lieu of locked doors, certain areas within the Reactor Building, where no enclosure exists for the purpose of locking, and where no enclosure can be reasonably constructed, shall be barricaded, conspicuously posted, and a conspicuous visible or audible signal shall be activated such that an individual is made aware of the presence of the High Radiation Area (>1,000 mrem /hr).

D6.13 PROCESS CONTROL PROGRAM (PCP)

D6.13.1 The required content of the PCP is defined in Specification D1.6.

D6.13.2 Licensee-initiated changes to the PCP:

a.

Shall be documented and records of reviews performed shall be retained as required by Specification D6.10.2.o.

This documentation shall contain:

1)

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s) and 2)

A determination that the change will maintain the overall conformance of the processed waste product to existing requirements of Federal, State, or other applicable regulations.

b.

Shall become effective after review and acceptance by the PRC and approval by the DAGM, Nuclear.

Proposed Amendment No. 187 D6-18

RANCIIO~SECO UNIT 1

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PERMANENTLY DEFUELED TECilNICAL SPECIFICATIONS i

E ADMINISTRATIVE CONTROLS (Continued) i D6.14 OFF-SITE DOSE CALCULATION AND' RADIOLOGICAL ENVIRONMENTAL.

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MONITORING PROGRAM MANUALS l

D6.14.1 The required content of the ODCM is defined in Specification

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l D6.14.2 The required content of the REMP MANUAL is-defined in'D1.10.

D6.14.3 Licensee-initiated _ changes - to-the ODCM or REMP ' MANUAL:

l a.

Shall be documented and records of reviews performed shall be.

retained as required by Specification D6.10.2.o.

This. docume'ntation :

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shall contain:

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Sufficient information to support the change'together with the.

1 appropriate analyses or evaluations justifying the change (s),

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and b

2)

A determination that the change will maintain the level'of f

radioactive effluent control required by 10 CFR 20.1302, l:

40 CFR 190, 10 CFR 50.36a, and Appendix I to 10 CFR 50.and not-

.j adversely impact the accuracy or reliability of effluent dose or setpoint cal cula tions.

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b.

Shall become effective after review and acceptance by the PRC and l

approval by the DAGM, Nuclear.

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Shall be submitted to the Commission in-the form of a complete, i

legible copy of the entire ODCM and/or REMP-MANUAL as a part of_or

-l concurrent with the Semiannual Radioactive Effluent-Release Report for the period of the. report in which any change to the.ODCM and/or

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REMP MANUAL was made.

Each change shall be identified by markings

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in the margin of the affected pages, clearly' indicating _the area-of

j the page that was changed, and shall indicate the date-(e.g.,

j mon th/ yea r) the change was implemented.

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Proposed Amendment No. 187 D6-19

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l ATTACHMENT 2' i-A i

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4-Safet ' Analysis Report arid No Significant Hazards Consideration for-Proposed License ' Amendment.No. I87.L v.

I Proposed License Amendment No.187 Log No.1095 Safety Analysis Report Page 1 of 2 SAFETY ANALYSIS REPORT i

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I Descrin_ tion of Chan_ne Proposed License Amendment No.187 (PA-187) makes one reporting ?

requirement change and several definition and.10 CFR 20 reference changes in j

accordance with the regulations contained in the new 10 CFR 20, " Standards for j

Protection against Radiation."

i These changes: (1) Add two new definitions and revise two existing definitions.

in PDTS Section D1.0, " Definitions," (2) Revise one 10 CFR 20 reference in the -

Bases section for PDTS D3/4.6, " Liquid Hold-Up Tanks," and (3) Revise several.

.i 10 CFR 20 references in many sub-sections of PDTS Section D6.0, -

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" Administrative Controls."

i Rennon for Change The proposed Rancho Seco Permanently Defueled Technical Specification (PDTS) changes represent the PDTS changes that are needed to make the PDTS -

consistent with the new 10 CFR 20 regulations. - The required PDTS changes are relatively few, are editorial and administrative in nature, and only act to make the PDTS consistent with the new 10 CFR 20.'

Evaluation and Basis for Safety Findings

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i PA-187 does not alTect any systems, subsystems, or components. The proposed PDTS changes add two new definitions, change' two existing definitions in the -

i Definitions section, and change several references in the Bases and Administrative Controls sections only. The new 10 CFR 20 regulations become-effective on January 1,1994, and take precedent over the PDTS at this time,. The '

j new 10 CFR 20 may be fully implemented prior to PA-187 approval. - No other ?

-l PDTS changes are required to make the PDTS consistent with the new 10 CFR 20 regulations.

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Proposed License Amendment No.187 Log No.' 1095 i

Safety Analysis Report Page 2 of 2 j

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.-f NO SIGNIFICANT HAZARDS CONSIDERATION 3

The District has reviewed the proposed changes against each of the criteria in.

10 CFR 50.92, and, based on the above safety analysis report, concludes:

l A significant increase in the probability or consequences of an accident previously evaluated in the SAR will not be created, because :

the proposed PDTS changes are editorial in nature, are designed to implement the 10 CFR 20 regulations, and have no affect on any -

accidents evaluated in the Rancho Seco Defueled Safety; Analysis Report (DSAR), i.e., the dropped fuel assembly accident, the loss of -

off-site power condition, or.a radwaste tank rupture.

PA-187 will not create the possibility of a new or different. type of '

accident than previously evaluated in the SAR, because the changes.

are editorial in nature, implement the new 10 CFR 20 radiation protection regulations, and do not provide any new mechanisms by which an accident can occur, i

l The proposed PDTS amendment' will not involve a significant :

reduction in the margin of safety, because the District will continue to i

maintain the appropriate radiation protection controls, through -

implementation of the new 10 CFR 20 regulations, that are necessary l

to ensure Rancho Seco continues to be operated safely from a l

personnel radiation exposure standpoint during the Permanently-'

Defueled Mode.

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