ML20059E696
| ML20059E696 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/21/1993 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20059E675 | List: |
| References | |
| NUDOCS 9311030304 | |
| Download: ML20059E696 (9) | |
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[p*" %,yft UNITED STATES
[kgi j NUCLEAR REGULATORY COMMISSION (spg
- j WASHINGTON D C. 20555 0001 g ,.s j SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.190 TO FACILITY OPERATING LICENSE DPR-57 AND AMENDMENT NO.129 TO FACILITY OPERATING LICENSE NPF-5 GEORGIA POWER COMPANY. ET AL.
EDWIN I. HATCH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366
1.0 INTRODUCTION
By letters dated September 21, 1992; October 14, 1992, as supplemented January 15, March 26, and July 30, 1993; and May 3, 1993, as supplemented October 5,1993, Georgia Power Company, et al. (the licensee), submitted three separate requests for license amendments to change the Technical Specifications (TS) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2. The proposed changes would relocate the procedural details contained in the Radiological Effluent TS, incorporate the new Part 20 requirements, and revise the frequency of reporting the radiological effluent releases. The supplemental letters provided clarifying and additional information that was within the scope of the original requests and did not change the initial proposed no significant hazards consideration determination. The three ,
separate requests are detailed below. !
(1) The request dated September 21, 1992, proposed to incorporate the l programmatic controls for radiological effluent and radiological environmental ;
monitoring in the Administrative Controls section of the TS consistent with '
the requirements of 10 CFR Part 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50. At the same time, the licensee proposed to transfer the procedural details of the Radiological Effluent Technical Specifications (RETS) from the TS to the Offsite Dose Calculation Manual I (0DCM) or to the Process Control Program (PCP) for solid radioactive wastes, i as appropriate. Guidance on the above proposed changes was provided by i Generic Letter (GL) 89-01, dated January 31, 1989. I (2) The request dated October 14, 1992, as supplemented January 15, March 26, j and July 30, 1993, in response to the NRC staff's request for additional j information, proposed to revise the TS to allow for the implementation of the '
new 10 CFR Part 20, " Standards for Protection Against Radiation."
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(3) The request dated Stay 3, 1993, as supplemented October 5, 1993, proposed to revise th,: TS to decrease the frequency of the submittal of the Radioactive Effluent Release Report from semiannual to annual, and to incorporate several editorial corrections. The proposed changes are in respons- to the change in 10 CFR 50.36a, " Technical Specifications on effluents from nu' clear power reactors," which became effective October 1,1992.
Moreover, GPC had requested that the three revisions discussed above be issued by the NRC staff as a single license amendment for each unit of Plant Hatch.
2.0 EVALVATION The NRC staff's evaluation of the three revisions discussed above is divided in three sections as follows.
(1) TS revision reaardina RETS ,
The licensee's proposed changes to the TS are addressed below.
(a) The licensee has proposed to incorporate programmatic controls for radioactive effluent and radiological environmental monitoring in TS 6.8.3, " Procedures and Programs", as noted in the guidance provided in GL 89-01. The programmatic controls ensure that programs are established, implemented, and maintained' to ensure tnat operating procedures are provided to control radioactive effluent consistent with the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50.
(b) The licensee has confirmed that .the detailed procedural requirements addressing Limiting Conditions for Operation, their applicability, remedial actions, associated surveillance requirements, or reporting requirements for the TS changes have been prepared to implement the relocation of these procedural details to the ODCM or PCP. These changes to the ODCM and PCP have been prepared in accordance with the new Administrative Controls in the TS on changes to the ODCM and PCP so that they will be implemented in the ODCM or PCP when this amendment is issued. In addition, the bases associated with the TS changes will be deleted.
The procedural details that have been removed from the TS are not required by the Commission's regulations to be included in the ;
TS. They have been prepared for incorporation in the ODCM or PCP upon issuance of this license amendment and may be subsequently changed by the licensee without prior NRC approval. Changes to the ODCM and PCP are documented and will be included in the proposed TS 6.10.2.0 for the duration of the operating licensee in accordance with GL 89-01, Enclosure 3, item 6.10. ,
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(c) The licensee has proposed replacing other effected TS in the administrative controls section of the TS with the updated TS ;
provided by GL 89-01. The rest of TS have been retained in the .
TS under the heading of Radioactive Effluent, in accordance with '
the guidance of GL 89-01.
The staff finds that the changes included in the proposed TS amendment request are consistent with the guidance provided in GL 89-01. Because the control of radioactive effluent continues to be limited in accordance with operating procedures that must satisfy the regulatory requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50, the NRC staff concludes that these changes are administrative in nature and there is no ..
adverse impact on plant safety. Accordingly, the staff finds that the proposed changes are acceptable.
(2) TS revision reaardina the new 10 CFR Part 20 The licensee has requested a revision to the TS to include wording that is consistent with the revised 10 CFR Part 20, " Standards for Protection Against Radiation" and that retains the same overall level of effluent control required to meet the design objectives of Appendix I to 10 CFR Part 50.
l The specific TS changes proposed by the licensee and the NRC staff's evaluations are provided in the following paragraphs.
(a) Unit 1/2 TS 1.0 " DEFINITIONS" The licensee has proposed to revise the definitions of MEMBER (S) !
0F THE PUBLIC and UNRESTRICTED AREA to conform to the definitions l of these terms used in 10 CFR 20.1003. )
The changes are administrative in nature to incorporate the corresponding revised 10 CFR Part 20 definitions and are acceptable.
(b) Unit 1 TS Table 3.2-8 Unit 2 TS Table 3.3.6.1-1 The licensee has proposed to revise these tables to delete the reference to the Environmental Technical Specifications (ETS) and replace it with a specific reference to TS 6.18 (7). These !
changes stem from the licensee's response to Generic Letter 89- l
- 01. l The changes are administrative in nature and are acceptable.
(c) Unit 1 TS Table 3.2-8 The licensee has proposed to delete the stated reference for the Refueling Floor Exhaust Vent Radiation Monitors from the ETS and replace it with a specific trip setting value of 120 mr/hr. I
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The monitors are not intended for the control of routine releases, but rather serve to perform an emergency safety feature function associated with Standby Gas Treatment System operation and primary and secondary containment isolation. This change will make the TS consistent with those of Unit 2. The change will not affect the ability of the monitors to continue to activate the Standby Gas Treatment System and to perform their primary containment and secondary containment isolation function in the event a high radiation condition exists in the refueling floor ventilation exhaust.
Based on the above, the change is acceptable.
(d) Unit 1 TS 3.15.1.4 " LIQUID HOLDUP TANKS" Unit 2 TS 3.11.1.4 " LIQUID HOLDUP TANKS" The footnote designation for Unit 1 TS 3.15.1.4 is missing and is being corrected to reference footnote (a) found at the bottom of page 3.15-8. The footnote designation for Unit 2 TS 3.11.1.4 is also being corrected since it contains a reference to (d) instead of (a) found at the bottom of page 3/4 11-8.
These changes correct typographical errors and are acceptable.
(e) Unit 1 TS 3.15.1.4 " LIQUID HOLDUP TANKS" Unit 2 TS 3.11.1.4 " LIQUID HOLDUP TANKS" The licensee has proposed to delete action statement b from the .
TS, which states "The provisions of Specification 6.9.1.13(b) are not applicable."
This change corrects an error that existed in the TS since issuance of license amendments 149 (Unit 1) and 86 (Unit 2). The license amendments modified the TS to incorporate revised reporting requirements, including those in 10 CFR 50.73.
The change is administrative in nature and is acceptable.
(f) Unit 1 BASES 3/4.15.1.4 "LI(UID HOLDUP TANKS" Unit 2 BASES 3/4.11.1.4 " LIQUID HOLDUP TANKS" The licensee has proposed to revise the BASES to replace the reference to " Appendix A, Table II (column 2)" with " Appendix B (to paragraphs 20.1001 - 20.2401), Table 2 (Column 2)."
The change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 table number and is acceptable.
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(g) Unit 1/2 TS 6.9.1.5 " ANNUAL REPORTS" The licensee has proposed to revise section 6.9.1.5a of the Unit I and Unit 2 TS to replace the reference to "20.407" with "20.2206."
The change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 section number and'is acceptable.
(h) Unit 1/2 TS 6.12 "HIGH RADIATION AREA" The licensee has proposed to revise section 6.12.1 of this TS to replace the reference to "20.203(c)(2)" with "20.1601(a)."
This change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 section number and is acceptable.
(i) Unit 1/2 TS 6.12 "HIGH RADIATION AREA" In response to an NRC request, the licensee has proposed to revise TS 6.12.2 by adding an upper limit for a high radiation area of 500 rads in one hour and specifying with a footnote that the measurement is made at a distance of 1 meter from the source or from any surface that the radiation penetrates. This will ensure that the measures which are in place for controlling access to high radiation areas are not used for very high radiation areas (20.1602), which require additional controls. A footnote has also been added to the existing lower limit of 1000 mrem /hr which states that the measurement is made at a distance of 30 centimeters from the radiation source or from any surface that the radiation penetrates.
The changes are consistent with the requirements of 20.1602 and are acceptable.
(j) Unit 1/2 TS 6.17 "0FFSITE DOSE CALCULATION MANUAL" Unit 1/2 TS 6.18 "RADI0 ACTIVE EFFLUENT CONTROLS PROGRAM" The licensee has proposed to revise these TS to replace the reference to "10 CFR 20.106" with "10 CFR 20.1302."
This change is administrative in nature to incorporate the corresponding revised 10 CFR Part 20 section number and is acceptable.
(k) Unit 1/2 TS 6.18 "RADI0 ACTIVE EFFLUENT CONTROLS PROGRAM" l l
The licensee has proposed to revise item 2 of this TS which '
specifies the limitations on the concentrations of radioactive material released in liquid effluent. The licensee has proposed that the TS be revised to allow "10 times the concentrations 1
stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 -
20.2401), Table 2, Column 2."
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 effluent are contained in 10 CFR 50.36a.
10 CFR 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluent 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 effluent to within the dose values specified in Appendix I of 10 CFR Part 50. For the purposes of this TS,10 CFR Part 20 is used as a source of 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 II 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 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 rate of 500 mrem / year has been acceptable as a TS limit for liquid effluent, 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 Plant Hatch has demonstrated that the use of the concentration values associated with 10 CFR 20.106 as TS limits has resulted in calculated individual doses to a member of the public that are well below 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, it is acceptable that the instantaneous limits associated with the liquid release rate TS are based on 10 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) Unit 1/2 TS 6.18 "RADI0 ACTIVE EFFLUENT CONTROLS PROGRAM" The licensee has proposed to revise item 7 of this TS which specifies the limitations on the concentrations of radioactive material released in gaseous effluent. The licensee has proposed that the TS be revised to read as follows:
Limitations on the dose rate resulting from radioactive material released in gaseous effluent'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 mrem / year to the total body and less than or equal to a dose rate of 3000 mrem / year to the skin, and
- b. For Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days, less than or equal to a dose rate of 1500 mrem / year 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 the implementation of the revised 10 CFR Part 20.
The current requirements for the content of the licensee's TS concerning radioactive effluent are contained in 10 CFR 50.36a.
10 CFR 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluent 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 specification were chosen by the staff to help maintain annual average releases of radioactive material in gaseous and liquid effluent 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
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J operational flexibility, compatible with considerations of health l 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 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 effluent, 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. -i The licensee states that operational history at Plant Hatch has demonstrated that the use of the dose rate values lirted 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 small percentages of the limits of ,
Appendix I to 10 CFR Part 50 and 40 CFR Part 190.
The licensee also 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. ,
i Based on the above, it is acceptable that the gaseous release
rate TS for radioactive material be based on the stated dose rates.
i (3) TS revision reaardina the freauency of reportina the radioactive releases and several editorial corrections The NRC amended 10 CFR 50.36a, as noticed in 57 FR 39353 dated August 31, 1992, regarding the frequency of reporting the quantity of each of the principal radionuclides released to unrestricted areas in liquid and ' gaseous ,
effluents. Specifically, the revised rule now requires the licensees to submit their radioactive effluent reports on an annual basis in lieu of semiannually. The most recent report was submitted by letter dated August 24, 1993, under the current TS recairemant, and covered the period from January 1 -
through June 30, 1993. The proposed TS requires the licensee to submit the report of the releases for the previous t alendar year prior to May 1 of each year. In addition, several editorial corrections are being made to the radioactive effluents sections of Units 1 and 2 TSs.
Based on its review of the licensee's submittal, the NRC staff finds that the requested TS change regarding the frequency of reporting the radioactive releases is consistent with'the new rule, and the several corrections to the TS radioactive effluents sections are editorial in nature. Therefore, the ;
staff finds that the licensee's proposed changes are acceptable. !
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3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
I The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. 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 Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding 58 FR 19481 dated April 14, 1993 (two Notices), and 58 FR 48384 dated September 15, 1993. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10). 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 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 sto the common defense and security or to the health and safety of the public.
Principal Contributors: E. Wang S. Klementowicz K. Jabbour Date: October 21, 1993 i
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