Text

Proposed Tech Specs,Incorporating Revs to 10CFR20
	ML20080K198
Person / Time
Site:	Summer
Issue date:	02/21/1995
From:	; SOUTH CAROLINA ELECTRIC & GAS CO.
To:	;
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ML20080K197	List: ML20080K198; RC-95-0045, Application for Amend to License NPF-12,incorporating Revs to 10CFR20;
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t k i i 4 [ t ATTACHMENT I i TSP 940002 i i LIST OF AFFECTED PAGES AND [ MARKED - UP TECHNICAL SPECIFICATIONS f r a 9 t s ? f t k i I 9502290418 950221 PDR ADOCK 05000395 P PDR 'w

e TSP 940002 - SCE&G ^[c*t d Br PAGE Description of Chance Reason for Change 3/4 11-1 3.11.1.1 1 Insert A: Added 3.11.1.1, 3.11.1.2, and This was added back in toeliminate 3.11.1.2 3.11.1.3 back in. confusion as to why page 3/411-1, LCO 3.11.1.3 started with Section 3.11.1.4 instead of 3.11.1.1. f 3.11.1.4 2 Third line,"or" was changed to "or'. To correct a typo from a previous Action a amendment. 4.11.1.1 3 Insert B: Added 4.11.1.1, 4.11.1.2, and This was added backin to eliminate 4.11.1.2 4.11.1.3 back in. cenfusion as to why the Surveillance 4.11.1.3 Requirements started with Section i 4.11.1.f. 3/4 11-2 3.11.1.5 1 Added "10" beside "C;". The Part 20 Rulelowered Gj values by a equntion factor of 10. The factor of10 maintains allowable limits. Aj 2 Changed " curie" to " curies". Typographical error. l' 4.11.1.5 3 Changed "0.6" to "6". The Part 20 Rule lowered C values by a J equation factor of 10. The factor of10 maintains existinglevel ofcontrols. 3/4 11-3 Qj 1 Added comma after " half-life". Punctuation correction. 1 3/4 11-4 3.11.2.1 1 Insert C: Added 3.11.2.1, 3.11.2.2, This was added back in to eliminate 3.11.2.2 3.11.2.3, and 3.11.2.4 back in. confusion as to why page 3/411-4, LCO 3.11.2.3 started with Section 3.11.2.5 instead of 3.11.2.4 3.11.2.1. 4.11.2.1 2 Insert D: Added 4.11.2.1, 4.11.2.2, This was added back in to eliminate 4.11.2.2 4.11.2.3, and 4.11.2.4 back in, confusion as to why the Surveillance 4.11.2.3 Requirements started with Section 4.11.2.4 4.11.2.5 instead of 4.11.2.1. 3/4 11-5 N/A N/A There were no changes. This page was There were no changes. This page was included because a new fontis being included because a new fontis being used. used. B 3/411-1 3/4.11.1.1 1 Insert E: Added 3/4.11.1.1, 3/4.11.1.2, This was added back in to eliminate 3/4.11.1.2 and 3/4.11.1.3 back in. confusion as to why page B 3/411-1, 3/4.11.1.3 started with Section 3/4.11.1.4 instead of 3/4.11.1.1. l 3/4.11.1.4 2 Added the words "10 times" to the third The Part 20 Rulelowered values by a line between "than" and "the" factor of10. The factor of10 maintains allowable limits. 3/4.11.1.5 3 Paragraph 1, Line 4: Changed the word This was an administrative change to " uncontrolled" to " unrestricted". more clearly define the area consistent with Part 20 Rule terminology. Paragraph 1, Line 4: Changed the word Note 4 is now the applicable note. The " Note 1" to " Note 4". Part 20 Rule renumbered Note 1 as Note 4. 1of4 g w

i o TSP 940002 -SCE&G AII* d Br PAGE Descrintion ofChange Reason for Change g cti 3/4.11.1.5 4 Paragraph 2, first line: removed words Removed words to ensure consistency in " of slurry to the chemical treatment definition of " settling ponds". ponds...". 3/4.11.1.5 5 Paragraph 2,last twolines: changed Reflects new Part 20 Rule dose words "... total body level to the 10 CFR terminology. l 20,105(a), whole body dose limitation, or that:" to "... total body level given in 10 CFR 50 Appendix I, Section II.A, to the Total Effective Dose Equivalent dose represented by the concentration in 10 CFR 20, Appendix B,TableII, Column 2., or that:" 3/4.11.1.5 6 Changed equation: "500 mrem /yr" Specification limits the consequence of changed to "50 mrem /yr" and "0.006" an uncontrolled release of slurry offsite changed to "0.06" by establishing a limit relative to 10 CFR 50 Appendix I design criteria. This limit is established by ratioing the dose corresponding to AppendixI whole body limits to the dose corresponding to 10 CFR 20 Appendix B Table II, Column 2, concentrations. Since the dose corresponding to the revised Part 20 Appendix B, Table II, Column 2, concentrations was lowered by a factor of 10, the 500 mrem value used previously was revised to 50 mrem and the resulting calculated limit was revised accordingly. 3/4.11.1.5 7 Last paragraph: Added comma after Punctuation correction. " area". 3/4.11.i.T, 8 Lastparagraph: Addedcommaafter Punctuation correction. " wet". B 3/411-2 3/4 11.1.5 1 Paragraph 1,line 1: spelled out "gr/ml" "gr/ml"was an incorrect notation. to" gram per milliliter" First 2 Changed "Qa" to "Q ". "Qa"was a typographical error. 4 Equation Changed "0.006" to 0.06". "0.006" was changed because the Part ~ Changed "gm" to "g". 20 Rule lowered values by a factor of10. The factor of10 maintains allowable limits. "gm" was incorrect notation for gram. Second 3 Changed ".6" to "6". " 6" revised because the Part 20 Rule Equation Changed "gm" to "g". lowered values by a factor of10. The factor of 10 maintains allowable limits. "gm" was incorrect notation for gram. 2of4

~ TSP 940002 -- SCE&G A d Br PAGE Description of Change Reason for Change g 1 3/4.11.2.1 4 Insert F: Added 3/4.11.2.1, 3/4.11.2.2, This was added back in to eliminate 3/4.11.2.2 3/4.11.2.3, and 3/4.11.1.4 back in. confusion as to why page B 3/411-2, j 3/4.11.2.3 started with Section 3/4.11.2.5 instead 3/4.11.2.4 of 3/4.11.2.1. l 6 11 6.8.4.a.1) 1 Renumbered subheadings 6.8.4.a.(i), Restructured subheads throughout 6.8.4.a.2) 6.8.4.a.(ii), 6.8.4.b.(i), 6.8.4.b.(ii), and Section 6 to achieve consistent outline 6.8.4.b.1) 6.8.4.b(iii). format. 6.8.4.b.2) 6.8.4.b.3) 6-12 6.8.4.c.1) 1 Renumbered subheadings 6.8.4.c.(i), Restructured subheads throughout 6.8.4.c.2) 6.8.4.c.(ii), 6.8.4.c.(iii), 6.8.4.c.(iv), Section 6 toachieve consistent outline 6.8.4.c.3) 6.8.4.c.(v), and 6.8.4.c.(vi). format. 6.8.4.c.4) 6.8.4.c.5) 6.8.4.c.6) 6.8.4.d.1) 2 Renumbered subheadings 6.8.4.d.(i), Restructured subheads throughout 6.8.4.d.2) 6.8.4.d.(ii), and 6.8.4.d.(iii). Section 6 to achieve consistent outline 6.8.4.d.3) format. 6.8.4.e.1) 3 Changed punctuation at the end of the Typographical error. sentence from a comma to a semi-colon. 6.8.4.e.2) 4 Added "10 times the concentration The Part 20 Rulelowered values by a values in " between " conforming to" and factor of10. The factor of10 maintains "10 CFR". allowable doselimits. 6-12a 6.8.4.e.3) 1 Changed "20.106" to "Part 20.1302". Part 20 r e relocated the requirements. 6.8.4.e.7) 2 Insert G Establishe Ne gaseous effluent dose rate limits..leselimits,in conjunction with 10 CFR 50 AppendixIlimits, maintain 10 CFR 20 dose limits. 6-12b 6.8.4.f N/A Repagination moved 6.8.4.f and 6.8.4.f.1) Repagination. and to page 6-12b. 6.8.4.f.1) 6-13 6.9.1.4 1 " March 1" was changed in two places to Reflects proposed generic letter changes " March 31" to reporting requirements. 6.9.1.5 2 Fourth line: Changed "manrem-Reflects new 10 CFR 20 Rule expoure" to " collective deep dose terminology. equivalent (reported in person-rem)" 1/ 3 Changed "$20.407" to "620.2206". Part 20 Rule relocated requirements. 6-14 6.9.1.8 1 Paragraph 1, Line 2: Chaaged "12 To clarify reporting criteria to mean months of operations" to' fiscal year". January 1 through December 31. Paragraph 1, Line 3: Changed "within To Nvide for allowable report 60 days aftenianuary 1" to " prior to May prepar.ition time, specified in 10 CFR 1". 50.36(a. limits, maintains 10 CFR 20 dose limits. I l 3 of 4 .;k

\\ TSP 940002 -SCE&G A ected PAGE Description of Change Reason for Change e j9n 6-18 Section 1 Insert H: Replace entire Section 6.12 To reflect Part 20 Rule changes and to 6-18a 6.12 (6.12.1 and 6.12.2) with " Insert H". annotate the measurement distance 3-18b changes for high radiation areas. j 6-19 n/a 1,2 Repagination from Section 6.12 above. Repagination from Section 6.12 above. 6-20 6.14.2.a.2) 1 Changed "20.106" to "20.1302". Part 20 Rule relocated requirements. i l 4 of 4 l 1

g --. j v 4: l I RADI0 ACTIVE EFFLUENTS i 3/4.11.1 LIQUID EFFLUENTS T LIQUID HOLDUP TANKS LIMITING CONDITION FOR OPERATION' Insert a -j A 3.11.1.4 The quantity of radioactive material contained in each of.the following tanks shall be limited to less than or e and dissolved or entrained noble gases. qual to 10 curies, excluding tritium i ~ a. Condensate Storage Tank ~ l b. Outside Temporary Storage Tank APPLICABILITY: At all times. ACTION: 5 With the quantity of radioactive material in any of the above listed a. tanks exceeding the above limit, immediately suspend all additions of af radioactive material to the tank and within 48 hours reduce the I tank contents to within the limit. b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. { r I SURVEILLANCE REQUIREMENTS Insst + ~ 4.11.1.4 The quantity of radioactive material contained in each of the above j g listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank. i i .I 1ssa.+ A 3.II. I. I Deldej h A m. J ma.nt lo Y. y 3.11. ). 7-

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1 l i SUMER - UNIT 1 3/4 11-1 Amendment No. 104 ) l

I [ -r j q.. -.. RADIOACTIVE EFFLUENTS SETTLING POND LIMITING CONDITION FOR OPERATION 3.11.1.5 The quantity of radioactive material contained in each settling pond r 1 shall be limited by the following expression: A 264. I < 1. 0 y jj3 10 ~ excluding tritium and dissolved or entrained noble gases, where, A } j = Pond inventory limit;for single radionuclide "j", in curie 5 I ^ v C j = 10 CFR 20, Appendix B, Table II, column 2, concentration for single radionuclide "j", microcuries/ml. i V = design volume of liquid and slurry in the pond, in gallons. 264 = Conversion unit, microcuries/ curie per milliliter / gallon. APPLICABILITY: At all times. - t ACTION: With the quantity of radioactive material in the settling pond-a. exceeding the above limit, immediately suspend all additions of radioactive material to the pond and within 48 hours reduce the pond contents to within the limit. 1 b. The provisions of specifications 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REQUIREMENTS 4.11.1.5 The quantity of radioactive material contained in each batch of' slurry (used powdex resin) to be transferred to the settling ponds shall be determined to be within the above limit by analyzing a representative sample of the y slurry, and batches to be transferred to the settling ponds shall be limited by the expression: I <08 (o J j t l f i i SUMER - UNIT 1 3/4 11-2 Amendment No. 104 ,I

7: =- il?,- o i -RADI0 ACTIVE EFFLUENTS I .J SURVEILLANCE REOUIREMENTS (Continued) 1 where O = concentration of radioactive materials in wet, drained slurry (used j powdex resin) for radionuclide "j" excluding tritium, dissolved or entrained noble gas and radionucJides'with less than 8 day half-life, in microcuries per gram. The analysis shall include at least Ce-144, Cs-134, Cs-137, Sr-89, Sr-90, Co-58 and Io-60. Estimates of Sr-89,- Sr-90, batch concentrations shad be based on the most recently available quarterly composite analyses. 6 Cj = 10 CFR 20, Appendix B, Table II column 2 concentration for single radionuclide "j*, in microcuries/ milliliter. 1 l SUM ER - UNIT 1 3/4 11-3 Amendment No. 104

w 1 RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION Tw^ A C 3.11.2.5 The concentration of oxy limited to less than or equal to 2 ken in t.he waste gas holdup system shall be by volume whenever the hydrogen concentration exceeds 4% by volume. x APPLICABILITY: At all times. ACTION: With the concentration of oxygen in the waste gas holdup system a. greater than 2% by volume but less than or equal to 4% by volume, restore the concerteation of oxygen to within the limit within 48 hours. b. With the concentration of oxygen in the waste gas holdup system greater than 4% by volume, immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than 4% by volume within 1 hour and less than or equal to 2% by volume within 48 hours. c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. SURVEILLANCE REOUIREMENTS 1 pwtA D 4.11.2.5 The concentration of hydrogen and oxygen in the waste gas holdup system shall be determined to be within the above limits by continuously monitoring the waste gases in the waste gas holdup system with the hydrogen and oxygen monitors required OPERABLE by Table 3.3-13 of Specification 3.3.3.9. bob *YI ggC

3. fl. 2. l 3 tked d b7

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4. ll.1. 3 SUP9tER - UNIT 1 4. 11. 2. S 3/4 11-4 Amendment No. 104

Y,3 ' ' T. _ * ~' j s s \\ RADICACTIVE EFFLUENTS i GAS STORAGE TANKS" d t LIMITING CONDITION FOR OPERATION i f 1 3.11.2.6' The quantity of radioactivity contained in each gas storage tank' shall be limited:to less than or equal to 160,000 curies noble gases j (considered as Xe-133). 3 APPLICABILITY: At all times. 1 ACTION: With the quantity of radioactive material in any gas storage tank [ a. exceeding the above limit, immediately suspend all additions of. l radioactive material to the tank and within 48 hours reduce the tank i contents-to within the limit. I b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.' I SURVEILLANCE REQUIREMENTS l t l 4.11.2.6 The quantity of radioactive material contained in each gas storage tank-shall be determined to be within the above. limit at least once per 24 hours when radioactive materials are being added to the tank. I t 1 l i r i i i. i i i ll SUMMER - UNIT 1 3/4 11-5 Amendment No. ) e

7w 3 3/4.11 RADI0 ACTIVE EFFLUENTS BASES 3/V. //. l. / Delet<J p A*eal aea 3/4.11.1 LIQUID EFFLUENTS Insu+ E [ ji,,,, u m 3/4.ll.l.2. m ~ ~ ~ ~ ~ ~ ~ " ' ' " " ', In su+. 3/4.ll I l h E 3n.11.1. 4 LIQUID HOLDUP TANKS g Restricting the quantity of radioactiye material contained in the specified I tanks tanks'provides assurance that in the event-of an uncontrolled relense of the contents, the resulting concentrations would be less thanitiealinits of l-10 CFR Part 20, Appendix B, Table II, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area. -i 3/4 11.1.5 SETTLING PONDS The inventory limits of the settling ponds (SP) are based on limiting the i consequences of an uncontrolled release of the pond inventory. The expression i in Specification 3.11.1.5 assumes the pond inventory is uniformly mixed, that the-i "* SMd* pond is located in an,urrent--!!:d area as defined in 10 CFR 20, and that the concentration limit in NoteJ to Appendix B of 10 CFR 20 applies. V The batch limits ef !!urry te "e rHiral tre---t pr$ assure that l! radioactive material in the slurry transferred to the SP are "as low as is reasonably achievable" in accordance with 10 CFR 50.36a. The expression in Specification 4.11.1.5 assures no batch of slurry will be transferred to the SP unless the sum of the ratios of the activity of the radionuclides to their respective concentration limitation is less than the ratio of the 5 10 CTR 50, n;;;r.d' ' " " ' - "^ 3,;l; i:dy d;;; li;it:tien, Or th:t: '"-' 't; ire:I t; th; 10 Oi" 20,105(;), total bed l Su.4isn E. A, to de %+d E%.tive Don E :aalast da. eyn~+b eve.1 4 5ven in tocre so A.<.ee., te! i ff nJ q Ague 8, Tabfc1 c.6n 7.,,e +1s.+ : 1[J < {3 mres/yr =g .1

T**'Y Y 0.o t, where cI = unrestricted area SP, in microcuries/milliliterradioactive slurry co C3 = 10 CFR 20, App'j" dix B, Table II, Column 2, concentration for single l en radionuclide

, in microcuries/ milliliter. For the design of filter /demineralizers using powder resin, the slurry wash I volume and the weight of resin used per batch is fixed by the cell surface areaj l and the slurry volume to resin weight ratio is constant at 100 milliliters / gram of wet, drained resin with a moisture content of epproximately 55 to 60% (bulk density of about 58 pounds per cubic feet). The wet drained slurry density is ) y L SIMIER - UNIT 1 B 3/4 11-1 Amendment No. 104 i

1l y, i n RADI0 ACTIVE EFFLUENTS -l BASES i 3/4 11.1.5 SETTLING PONDS (Continued) . approximately 1 p/edpv m;llil.%c 3cr ,and the absorption characteristic for gamma' radiation is essentially that of water. Therefore, j y

y Qg.

0. 0 G

\\ l c ml/pr) # DdHF, and j fjC)(10 i 1-I < g pCi/a# j pct /ml j Where the tems are defined in Specification 4.11.1.5. The batch limits provide assurance that activity input to the SP will be [ ~ minimized, and a means of identifying radioactive material in the inventory limitation of Specification 3.11.1.5. .I m t F 3/4. ll. 2.. I DJeb) h Am.d.e.at 3/4.11.2 GASEOUS EFFLUENTS 3/4. it. 2.7_ j 3 lowi 3/4.11.2.5-EXPLOS'VE GAS MIXTURE .i 3 This specification is provided to ensure that the concentration of potentially explosive gas mixtures contained in the waste gas holdup system is maintained below the flammability limits of hydrogen and oxygen. Automatic- .t control features are included in the system to prevent the hydrogen and oxygen concentrations from reaching these flammability limits. These automatic control features include isolation of the source of hydrogen and/or oxygen i to reduce the concentration below the flammability limits. Maintaining the concentration of hydrogen and oxygen below their flammability limits provides assurance that the releases of radioactive materials will be-ccntrolled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50. / 3/4.11.2.6 GAS STORAGE TANKS h Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to an individual at the i nearest exclusion area boundary will not exceed 0.5 rem. This is consistent with Standard Review Plan 15.7.1, " Waste Gas System Failure". 1 j SUMER - UNIT I B 3/4 11-2 Amendment No. 104

'I. ADMINISTRATIVE CONTROLS Critical operation of the unit shall not be resumed until authorized { d. by the Commission. 6.8 P90CEDURES AND PROGPA"S 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below. The applicable procedures recommended in Appendix 'A' of Regulatory a. Guide 1.33 Revision 2, February 1978. b. Refueling operations. Surveillance and test activities of safety-related equipment. l c. d. Security Plan. e. . Emergency Plan. f. Fire Protection Program. g. PROCESS CONTROL PROGRAM. h. OFFSITE DOSE CALCULATION MANUAL. 1. Effluent and environmental monitoring program using the guidance in Regulatory Guide 4.15. Revision 1, February 1979. 6.8.2 Each procedure of 6.8.1 abova, and changes thereto, shall be reviewed prior to implementation as set forth in 6.5 above. 6.8.3 NOT USED. 6.S.4 The following programs shall be established, implemented and maintained: Primary Coolant Sources Outside Containment a. A program to reduce leakage from thoce portions of systems outside contairement that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the chemical and volume control, letdown, safety injection, residual heat removal, nuclear sampling, liquid radwaste handling, gas radwaste handling and reactor building spray system. The program shall include the following: t 0 ft1 Preventive maintenance and periodic visual inspection requirements, and 2.) ()47 Integrated leak test requirements for each system at refuel j cycle intervals or less. b. In-Plant Radiation Monitorina I l) Training of personnel, 2) Procedures for monitoring, and

3) MT Provisions for maintenance of sampling and analysis equipment.

SUW4ER - UNIT 1 6-11 Amendment tio. 28,0.72,D.117

ADMINISTRATIVE CONTROLS c. . Secondary Water Chemistry 1 ~ } A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation. This program shall include: ' i l) f4T Identification of a sampling schedule for the critical variables i and control points for these variables. l 7-) (.Hf Identification of the procedures used to measure the value the critical variables,

3) % Identification of process sampling points, including mon i

the discharge of the condensate pumps for evidence of condenser in-leakage. l

4) (R J Procedures for the recording and management of data,

5) pr)' Procedures defining corrective actions for all off-control point I

chemistry conditions,

6) pff A procedure identifying (a) the authority responsible for the I

interpretation of the data, and (b) the sequence and timing of t administrative events required to initiate corrective action. l d. Postaccident Samm11no A program which will ensure the capability to obtain and analyze s reactor coolant, radioactive iodines and particulates in plant i gaseous effluents, and containment atmosphere samples under accident conditions. The program shall incibde the following: I [ Training personnel, ! Procedures for sampling and analysis, j 7-3,(,1% Provisions for maintenance of sampling and analysis equipment. Radioactive Effluent Controls Procram i t e. A program shall be provided confonning with 10 CFR 50.36a for tha control of radioactive affluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably i achievable. The program (1) shall be contained in the 00CM, (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:

1) Limitations on the operability of radioactive liquid and gaseous L

monitoring instrumentation including surveillance tests and i setpoint determinations in accordance with the methodology in j the00CM/; 6

2) Limitations on the concentration of radioactive material i

p ;., A o u W r h.ea uku :a released in liquid effluents to unrestricted areas conforming to l 10 CFR Part 20. Appendix B, Table II, Column 2 SUW9ER - UNIT 1 6-12 ^*'" "'"* "

p i :[p. I - ADMINISTRATIVE CONTROLS - e. Radioactive Effluent Controls h m (Continued)-- 3) Monitoring, sampling, and analysis of radioactive liquid and gaseous affluents in accordance with 10 CFR 20J46'and with the methodology and parameters in the 00CM; 1302 4) Limitations on the. annual and quarterly doses or dose comeitsent to a member of the public from radioactive materials in liquid effluents released to unrestricted areas conforming to Appendix -I to 10 CFR Part 50; 5) Detemination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and i current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days; i 6) Limitations on the operability and use of;the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systees are used to reduce releases or radioactivity when the projected doses in a 31-day period would i exceed 2 percent of the guidelines for the annual or dose casaritment conforming to Appendix ! to 10 CFR Part 50; i t letb 1 t s th a x ; I 1 8) Limitations on the annual and quarterly air doses resulting from i noble gases released in gaseous effluents to areas beyond the site boundary conforming to Appendx 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 from with half-lives greater than 8 days in gaseous effluents released to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50; 10) Limitations on the annual dose or dose cosetituent to any member of the public due to releases of radioactivity and to radiation i from uranium fuel cycle sources confoming to 40 CFR Part 190. 7 f. Radiological Environmental Monitorino Procram A program shall be provided to monitor the radiation and. radionuclides in the environs of the plant. The program shall provide (1) representative measures of radioactivity in the ll highest potential exposure pathways, and 2 verification of the accuracy of the effluent monitoring progra(m)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 ll 50, and (3) include the following. I 1) Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the 00CM; St#94ER - UNIT 1 6-12a Amendment No. I M,117

INSERT G r i

7) Limitations on the dose rate resulting from radioactive material 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 mrems/yr to the total body and less than or equal. to a dose rate of 3000 mrems/yr to the skin; and e I -(b) 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 i of1500 mrems/yr to any organ; i I i i 1 -) i i l SUMMER - UNIT 1 6-12a Amendment No.104,117 i

ADMiNTSTPATTVE CONTROLS f. Padioloaical Environmental Monitoring Prwm (Continued) 2) A Land Use Census to ensure that changes in the use of areas at and beyond the site boundary are identified and that modifications to the monitoring program are made if required by i the results of the census; and 3) Participation in an Inter-laboratory Comparison Program to ensure that independent checks on the precision and accuracy of measurements of radioactive materials in environmental sample matrices are performed as part of the quality' assurance program 4 for environmental monitoring., 6 t l i l t S!M9ER - UNIT 1 6-12b Amendment No. Jaf,117

y ',['.j*> i y_ ADMINISTRATIVE CONTROLS ~ ~ 4 -Y 6.9 REPORTING REOUIREMENTS ROUTINE REPORTS l ~! 6.9.1 ' In addition to the applicable reporting reovirements of Title 10, Code of Federal Regulations the following reports snail be suositted to the Regional -{ Administrator Office of Inspection ano Enforcement unless otherwise noted. STARTUP REPORT-

6. 9.1.1 A summary report of plant startuo and power escalation testing shall be suositted following (1) receipt of an operating license, (2) amenament to the license involving a planned increase 1n power level,.(3) installation of fuel that has a different design or has been manufactured by a different fuel supolier, anc (4 thermal, or nyara)ulic performance of the plant. modifications that may ha

6. 9.1. 2 The startuo report shall address each of the tests identified in the Final Safety Analysis Report ano shall include a oescription of the measured.

+ values of the operating conditions or characteristics obtained during the test program ano a comparison of these values with design predictions and specifica-tions. Any corrective actions that were reovired to 00tain satisfactory i operation snail ciso De oescribed. I Any addition.s1 specific catails required in license concitions based on other commitments shall be included in t l report. t 6.9.1.3 Startup reports shall be suositted within (1) 90 days following i concletion of the startuo test program, (2) 90 days following resumption or criticality, whichever is earliest. commencement of commercial power operation, o i I If the Startuo Report does not cover all three events (i.e., initial criticality, completion of-startuo test program, -{ anc resumption or commencement of commercial operation) supplementary reports shall De suositted at least every three months until all three events have been completed. ANNUAL REPORT 6.9.1.4 Annual reports covering the activities of the unit as described below for the previous calencar year sna11 be suositted prior to March A of eacn The initial report shall be suositted prior to March 1of the year /y g year. following initial criticality. 6.9.1.5 Reports required on an annual basis shall include a tabulation on an cclNin. d Asc """"*' D*'N "I * """ *# '**U'"' "I epw.lmt (W +d contractors) receiving exposures greater than I'r3 mrg/yr and their a Y ""d **"'" ' " ""'I "I I ryer x __- x x x-accorning to work and job functions,- e.g., reactor operations I 8^f" " # and surveillance, inservice inspection, routine maintenance, special maintenance (descr1be maintenance), waste processing, and refueling. The cose assignments to vartous outy functions may be estimatea based on pocaet dosimeter, TLD, or film bange measurements. Small exposures totalling less than 20 percent of the incividual total cose neec not be accounted for. ~ In the aggregate, at least 80 percent of the total whole bocy cose received from external sources should be assigned to specific major worn functions. j i M This tabulation supplements tne recuirements of $20Mof 10 CFR Part 20. SUMMER - UNIT 1 6-13 Amenoment No. 79 f

ADMINISTRATIVE CONTROLS This report shall also include the results of specific activity analysis in which the primary coolant exceeded the limits of specification 3.4.8. i The i following infomation shall be included: (1) Reactor power history starting 48 hours prior to the first samole in which the limit was exceeded; (2) Results of the last isotopic analysis for radiciodine performed prior to exceeding the. limit,-results of analysis while limit was exceeded and results of one analysis after the radiciodine activity was reduced to less than limit. Each result i should include date and time of sampling and the radiciodine concentrations, (3) Clean-up system flow history starting 48 hours prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radiciodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radiciodine limit. i ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.6 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 an 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 and (2) Sections IV.8.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50. t 6.9.1.7 Not used. ANNUAL RADICACTIVE EFFLUEKT RELEASE REPORT 6.9.1.8 Annual radioactive effluent release report covering the operation of the unit during the previous 12 nnt: ;f -- ;;'.;. shall be submitted d th " 00 d:K y ft:r A =;., 1 of each year. G *^ Y d f er to t The report shall include a sununary of the quantities of radioactive liquid and gaseous effluent;. and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50. l i l i SutNER - UNIT 1 6-14 Amenoment No. 19,7 #,117 l i

x 1

J ~ 'I I + r ,fADMINISTRATIVE CONTROLS Records of transient or operational cycles for those unit components. e. identified. in Table 5.7-1. i ^ f. Records of reactor' tests and experiments. g. Records of training and qualification for current members of the unit l staff. h. Records of in-service inspections performed pursuant to these j Technical Specifications. ~ y i. Records of Quality Assurance act4vities-as specified in th'a NRC's-l approved SCE&G position on ReguTatory Guide 1.88, Rev. 2, October i 1976. j. Records of reviews performed for changes made to procedure's or N equipment or reviews;of tests and experiments pursuant to 10 CFR 50.59. i k. Records-of meetings of the PSRC and the NSRC. l 'a 1. Records of the service lives of all hydraulic and mechanical snubbers i defined in Section 3.7.7 including the date at which the service life l commences and associated installation and maintenance records. l m. Records of secondary water sampling and water quality. n. Records of analysis required by the radiological environmental l monitoring program. j o. Records of reviews performed for changes made to the Offsite Dose j Calculation Manual and the Process Control Program.- .l.] 6.11 RADIATION PROTECTION PROGRAM i Procedures for personnel radiation' protection shall be prepared consistent with i the requirements of 10 CFR Part T.0 ano shall be approved, maintained and -i adherea to for all operations ir.volving personnel radiation exposure. f f 6\\12 h1GH4ADIATIOkAR84 ptR .1 n1 uo th "c tr d ice or 'ala s na " re ui d phag ph' (c) ) 10 FR 0, ac hig ra iati n a a n w ich he 'nt si' o r la on-gr ate tha 1 m /h bu les th 1 00 r al be i a ic ed d c nsp uo ly ost d a a gh adi tio ar an e ra e i er to al be ont 11e b req iri i uan e o' a adi ion Wo P i i ( P).* y div'dua or ro of indi id ls era tte to nte.s h a 1 sha 1 p vi d w'th a omp nie by ne r m re ftef lo 'ng l A di tio mon ter ng evi wh h nt uo ly indi ate t l ad ti d erte'ntya j a. i \\ s i "H6(il t Ph-ic pe on el r rs nn es or d.yH lt. Ph ics pe son 1 { sh&; i e fr te ssu nc re ir du ing the er nce i he' a ig a. di io p te tio d ie p vi ed he oth rwi c 1 w'th a r d ad ti p t ti p oce ur f e tr int h h r dia io are s. i SUP9tER - UNIT 1 6-18 Amendment No. 35, 49, 75, 77, i 10a g

n4, } a ADMINISTRATIVE CONTROLS'- A radiation monitoring device which contin 0ously integrates i radiation oose rate in the area and alarms when a preset 1 rated ose is received. Entry into suen areas with this moni ng device be maos after the dose rate level in the area has een-ished and personnel have.been made knowledge e of them. es j c. A healt hysics qualified individual (i.e., ified in radiation -l protection ocedures) with a radiation dos ate 6,onitoring device who is respon 'ble.for providing positive ntrol over the activities with the area and shall p ora periodic radiation surveillance at t frequency sp_acifi -by the facility Health Physicist in the Ra tion Work Pe t.. j 6.12.2 In addition to the requir nts o 6.12.1, areas accessible to personnel I with radiation levels.such.that a a o ortion of the body could receive in one hour a dose greater than 1000 m shall be provided with locked doors to l prevent unauthorized entry, and t key sna11 be maintained'uncer the admin-istrative control of the Shift resan on uty and/or health physics supervision. 'i Doors snall remain locken ex t during peri s of_ access by personnel under an l approved RWP which shall s cify the dose ra levels in the immeciate work area. i The maximum allowable s time for individuals that area shall be established - i prior to entry. For ividual areas accessible v personnel with radiation i levels such that a jor portion of the body could eive in one hour a dose in excess of'1000 remaa tnat are located within'larg areas, such as'PWR containment, w no enclosure exists for purposes of cking, 'and no Paalosure can be reaso ly constructed around the individual areas, then that arar m all be roped o, conspicuously posted and a flashing light sha be activi m as - Ei a warnin device. In lieu of the stay time specification of e RWP d' *:t or remote such as use of closed circuit TV cameras) continuous s veillance shall be by personnel qualified in radiation protection procedure to provide p itive exposure control over the activities within the area. 'l 6.13 PROCESS CONTROL PROGRAM (PCp) 6.13.1 The PCP shall be approveo by the Commission prior to implementatinn. 6.13.2 Changes to the PCP: I a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.2.o. This documentation l shall contain: i 1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s); l and t 2) A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations. b. Shall become effective after review and acceptance b, the PSRC and [ approval of the General Manager, Nuclear Plant Operations. l h M o%a%c%i\\ 8% a 5 l SI M ER - UNIT I 6-19 Amenoment No. 25, 77 1 104 i J

M 3 v INSERT H - Page 1 of'3 l' ages 5-15. 5-158. 5-150,6-1U - 6.12 HIGHRADIATION AREAS As providedin aara ph 20.1601(c) of 10 CFR Part 20, the following controls shallbe appliec radiation areas in place of the controls required by - paragraph 20.1601( and(b) of10 CFR Part 20: 6.12.1. High radiation areas with dose rates not exceeding 1.0 rem / hour *: a. Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be breached only during periods of personnel entry or exit, b. Access to, and activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area (s) and other appropriate radiation protection equipment and measures. c. Individuals qualified in radiation protection procedures (e.g.,. health physics technicians) and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP-or equivalent while prforming their assigned duties provided that they are following p' ant radiation exit from, and work in such areas. protection procedures for entry to,. d. Each individual (whether alou or in a group) entering such an area shall possess: 1) A radiation monitoring device that continuously displays radiation dose rates in the area (" radiation monitoring and indicating device"), or 2) A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached (" alarming dosimeter"), with an appropriate alarm setpoint, or 3) A radiation monitoring device that continuously transmits dose rate and cumulative dose to a remote receiver monitored by radiation rotection personnel resge area,for controlling nsible personnelra iation exposure within or-4) A self-reading dosimeter and, (a) Be under the surveillance, as specified in the RWP or l equivalent, while in the area, of an individual at the r work site, qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controllmg personnel - radiation exposure within the area, or l e 9 i a- -.- - - - - -. +

,4 hi '*I y i i INSERT H ~ Pane 2 of 3 i rares e-Is. U-Isa, u-Iso, u-Is (b) Be under the surveillance, as specified in the RWP or i equivalent,~ while in the ares, by means of closed - c i; circuit television, of personnel qualified in i radiation protection procedures, responsible for controlling personnea radiation exposure in the area, j i e. Entry into such areas shall be made only after dose rates in the l area have been determined and entry personnel are knowledgeable - ofthem. 1 1 6.12.2 High radiation areas with dose rates greater than 1.0 rem / hour *, but less than 500 rads / hour **: !i a. Each entryway to such an area shall be conspicuously posted as a i high radiation area and shall be provided with a locked door. or gate that prevents unauthorized entry, and in addition: 1) All such door and gate keys shall be maintained under the I administrative control of the Shift Foreman or the health 1 physics supervisor on duty. l 2) Doors and gates shall remain locked except during periods of l personnel entry or exit. b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area (s) and other 'i appropriate radiation protection equipment and measures. l c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are l following plant radiation protection procedures for entry to, exit t from, and work in such areas. i d. Each individual (whether alone or in a group) entering such an area shall possess: j i 1) An alarming dosimeter with an appropriate alarm setpoint, or 2) A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure =! within the area with the means to communicate with and 1 control every individual in the area, or ) i - ~.

s., INSERT H -Pane 3 of 3

- rages s-15. U-Isa, c-180. 5-19

- 3). ; A self-reading dosimeter and, (a) Be under the surveillance, as specified in the RWP or . equivalent, of an individual qualified in radiation - protection procedures, equipped with a radiation monitoring and indicating device who is responsible y for controlling personnel exposure within the area, or .l (b) Be under the surveillance, as specified in' the RWP or equivalent, by means of closed circuit television, of j personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area,'and with the means to communicate with and control every individual in the area. - .J Entry into such areas shall be made only after dose rates in the e. area have been determined and entry personnel are knowledgeable l ofthem. I f. Such individual areas that are within a larger area that is 'i controlled as a high radiation area, where no enclosure exists for purpose oflocking and where no enclosure can reasonable be i constructed around the individual area need not be controlled by a locked door or ate, but shall be barricaded and consaicuously posted as a hi radiation area, and a conspicuous c: early visible flashingligh hall be activated at the area as a wa, rning device. i i At 30 centimeters from the radiation source or from any surface penetrated by the radiation.

- At 1 meter from the radiation source or from any surface penetrated by the radiation.

k I I e i t rc -

l y, ~, ADMINISTRATIVE CONTROLS 6.14 0FFSITEDOSECALCULATION, MANUAL (00CM) ~ 6.14.1 The ODCM shall be approved by the Commission prior to implementation. 6.14.2 Changes to the 00CM: Shall be documented and records of reviews performed shall be a. retained as required by Specification 6.10.2.o. This documentation shall contain: 1) Sufficient information to support the change together with appropriata analyses or evaluations justifying the change (s); and 13 02. 2) A deterdnation that the change will maintain the level of a radioactive effluent control required by 10 CFR 20.% 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and i not adversely impact the accuracy or reliability of effluent dose or setpoint calculations. b. Shall become effective after review and acceptance by the PSRC and the approval of the General Manager, Nuclear Plant Operations. Shall be submitted to the Comeission in the form of a complete c. legible copy of the entire 00CM as a part of or concurrent with the i Annual Radioactive Effluent Release Report for the period of the report in which any change to the 00CM was made. Each change shall 1 be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., menth/ year) the change was implemented. I i l SUMER - UNIT 1 6-20 Amencment No. #I,7E,104.117 { l

? -i -l 3/4.11-RADIOACTIVE EFFLUENTS i ? 3/4.11.1 LIQUID EFFLUENTS ~ f LIQUID HOLDUP TANKS . LIMITING CONDITION FOR OPERATION: 3.11.1.1 Deleted b Amendment : ? 4. 3.11.1.2 Deleted b Amendment 104. 3.11.1.3 Deleted b Amendment 104. .l 3.11.1.4 The q uantity of radioactive material contained in each of the following tanks shall be limited to less than or equal to 10 curies, excluding tritium and dissolved or entrained noble gases. l i a. Condensate Storage Tank b. Outside Temporary Storage Tank l APPLICABILITY: Atalltimes. f ACTION: a. With the quantity of radioactive material in any of the above listed i tanks exceeding the above limit, immediately suspend all additions I ofradioactive material to the tank and within 48 hours reduce the l! tank contents to within thelimit. b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. l SURVEILLANCE REQUIREMENTS 4.11.1.1 Deleted b Amendment 104. k 4.11.1.2 Deletedb Amendment 104. t 4.11.3.3 Deleted b Amendment 104. i 4.11.1.4 The quantity of radicactive material contained in each of the above listed tanks shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank. J i t SUMMER - UNIT 1 3/4 11-1 Amendment No.104,

{,. + RADIOACTIVE EFFLUENTS ' SETTLING POND LIMITING CONDITION FOR OPERATION 3.11.1.5 The quantity ofradioactive materialcontained in each settling pond shall be limited by the following expression: 264 *5 Aj < 1.0 V .i 10 Cj excluding tritium and dissolved or entrained noble gases, where, Aj = Pond inventory limit for single radionuclide "j ", in curies. l Cj = 10 CFR20, Ap "ndixB,TableII, column 2,concentrationforsingle radionuclide , microcuries/ml. V = design volume ofliquid and slurry in the pond, in gallons. 264 = Conversion unit, microcuries/ curie per milliliter / gallon. APPLICABILITY: Atalltimes. ACTION: a. With the quantity of radioactive material in the settlin g pond exceeding the above limit, immediately suspend all adc.itions of radioactive material to the pond and within 48 hours reduce the pond contents to within thelimit. b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. SURVEII,I.ANCE REQUIREMENTS 4.11.1.5 The quantity ofradioactive material contained in each batch of slurry (used powdex resin) to be transferred to the settling ponds shall be determined to be within the above limit by analyzing a representative sample of the slurry, and batches to be transferred to the settling ponds shall be limited . by the expression: E b <6 ) Gj SUMMER-UNIT 1 3/4 11-2 Amendment No.104,-

~ l + { RADIOACTIVE EFFLUENTS SURVEILLANCE REQUIREMENTS (Continued) where i Qj = concentration of radioactive materials in wet, drained slurry (d or used powdex resin) for radionuclide "j " des with less than 8 day half-life excluding tritium, dissolve entrained noble gas and radionucli l in microcuries per gram. The analysis shall include at least Ce-144, Cs-134, Cs-137, Sr-89, Sr-90, Co.58 and Co-60. Estimates ofSr-89, Sr-90, batch concentrations shall be based on the most recently available quarterly composite analyses. Oj = 10 CFR 20, Ap "endix B, Table II, column 2, concentration for single e radionuclide ,in microcuries/ milliliter. I i l f 1 r l \\ SUMMER - UNIT 1 3/4 11-3 Amendment No.104,

s c RADIOACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS EXPLOSIVE GAS MIXTURE LIMITING-CONDITION FOR OPERATION l 3.11.2.1 Deleted b Amendment 104. 3.11.2.2 Deleted b Amendment 104. 3.11.2.3 Deleted b Amendment 104. 3.11.2.4 Deletedb Amendment 104. 3.11.2.5 The concentration of oxygen in the waste gas holdup system shall be limited to less than or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume. t t APPLICABILITY: At all times. ACTION: With the concentration of oxygen in the waste gas holdup system a. greater than 2% by volume but less than or equal to 4% by volume, restore the concentration of oxygen to within the limit within 48 hours, b. With the concentration of oxygen in the waste gae holdup system greater than 4% by volume, immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than 4% by volume within 1 hour and less than or equal to 2% byvolume within 48 hours. \\ The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. l c. SURVEILLANCE REQUIREMENTS 4.11.2.1 Deleted b Amendment 104. 4.11.2.2 Deleted b Amendment 104. t 4.11.2.3 Deleted b Amendment 104. 4.11.2.4 Deleted b Amendment 104. 4.11.2.5 The concentration of hydrogen and oxygen in the waste gas holdup system shall be determined to be within the above limits by continuously monitoring the waste gases in the waste gas holdu ) system with the hydrogers and oxygen monitors required OPERABLE by Tab:.e 3.3-13 of Specification 3.3 3.9. i i SUMMER -UNITI 3/4 11-4 Amendment No.104,

'7

(..

j i RADIO' ACTIVE EFFLUENTS -i j GAS STORAGE TANKS 1 LIMITING CONDITION FOR OPERATION I i 3.11.2.6 The quantity ofradioactivity contained in each gas storage tank shall l be limited to less than or equal to 160,000 curies noble gases (considered as Xe-133). APPIJCABILITY: At all times.

ACTION

With the quantity of radioactive material in anNll additions ofas storage ta a.

exceeding the above limit, immediately suspen i radioactive material to the tank and within 48 hours reduce the tank contents to within the limit. b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable. ] SURVEILLANCE REQUIREMENTS I 4.11.2.6 The quantity of radioactive material contained in each gas storage tank shall be determined to be within the above limit at least one per 24 hours when ~ .i radioactive materials are being added to the tank. l 1 i i i I L t P SUMMER - UNIT 1 3/4 11-5 Amendment No.104, l

x <3 3/4.11 RADIOACTIVE EFFLUENTS ' BASES 3/4.11.1 LIQUID EFFLUENTS 3/4.11.1.1 Deleted b Amendment 104. 3/4.11.1.2 Deleted b Amendment 104. 3/4.11.1.3 Deletedb Amendment 104. 3/4.11.1.4 LIQUID HOLDUP TANKS Restricting the quantity of radioactive material contained in the saecified tanks provides assurance that in the event of an uncontrolled release of tse tanks' contents, the resulting concentrations would be less than 10 times the limits of 10 CFR Part 20, Appendix B, Table II, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area. 3/4.11.1.5 SETTLING PONDS The inventory limits of the settling ponds (SP) are based on limiting the consequences of an uncontrolled release of the pond inventory. The expression in Specification 3.11.1.5 assumes the pond inventory is uniformly mixed, that the pond is located in an unrestricted area as defined in 10 CFR 20, and that the concentration limit in Note 4 to Appendix B of10 CFR 20 applies. The batch limits assure that radioactive materialin the slurry transferred l to the SP are "as low as is reasonably achievable" in accordance with 10 CFR 50.36a. The expression in Specification 4.11.1.5 assures no batch of slurry will be transferred to the SP unless the sum of the ratios of the activity of the radionuclides to their respec,tive concentration limitation is less than the ratio of the total body level pven m 10 CFR 50, Appendh I, Section II.A, to the Total Effective Dose squivalent dose represented by the concentrations in 10 CFR 20, Appendix B, Table II, Column 2., or that: S cj 3 mremlyr = 0.06 ). Gj 50 mremlyr where ej = radioactive slurry concentration for radionuclide "j" entering the unrestricted area SP, in microcuries/ milliliter Cj = 10 CFR 20, endix B, Table II, Column 2, concentration for single radionuclide ,in microcuries/ milliliter. For the design of filter /demineralizers using powder resin, the slurry wash volume and the weight of resin used per batch is fixed by the cell surface area, l and the slurry volume to resin weight ratio is constant at 100 milliliters / gram of wet, drained resin with a moisture content of approximately 55 to 60% (bulk density of about 58 pounds per cubic feet). The wet, drained slurry density is -l ) SUMMER-UNIT 1 B 3/411-1 Amendment No.104,

w- = e m ' RADIOACTIVE EFFLUENTS BASES-3/4.11.1.5 SErrLING PONDS (Continued) approximately 1 gram per milliliter and the absorption characteristic for gamma radiation is essentially that of water. Therefore, J J Gj(10 ml/g) E Qj pCilg .i & pCilmi Where the terms are defined in Specification 4.11.1.5. The batch limits provide assurance that activity input to the SP will be i minimized, and a means ofidentifying radioactive material in the inventory limitation ofspecification 3.11.1.5. 3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 Deletedb Amendment 104. 3/4.11.2.2 Deletedb Amendment 104. 3/4.11.2.3 Deleted b Amendment 104. 3/4.11.2.4 Deleted b Amendment 104. 3/4.11.2.5 EXPLOSIVE GAS MIXTURE This specification is provided to ensure that the concentration of potentially explosive gas mixtures contained in the waste gas holdu maintained below the flammability limits of hydrogen anc oxygen. p system is Automatic control features are included in the system to ?revent the hydrogen and oxygen concentrations from reaching these flammability limits. These automatic control features include isolation of the source of h drogen and/or oxygen to reduce the concentration below the flammabilit limits. Maintaining the concentration of hydrogen and oxygen below their ammability limits provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50. 3/4.11.2.6 GAS STORAGE TANKS Restricting the quantity of radioactivity contained in each gas storage tank provides assurance that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem. This is consistent with Standard Review Plan 15.7.1," Waste Gas System Failure". l SUMMER-UNIT 1 B 3/411-2 Amendment No.104,

ADMINISTRATIVE CONTROLS d. Critical operation of the unit shall not be resumed until authorized by the Commission. 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below: a. The applicable procedures recommended in Appendix "A" ofRegulatory Guide 1.33, Revision 2, February 1978. b. Refueling operations. c. Surveillance and test activities of safety-related equipment. d. Security Plan. e. Emergency Plan. f. Fire Protection Program. g. PROCESS CONTROL PROGRAM. h. OFFSITE DOSE CALCULATION MANUAL. i. Efnuent and environmental monitoring program using the guidance in Regulatory Guide 4.15, Revision 1, February 1979. 6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed prior to implementation as set forth in 6.5 above. i 6.8.3 NOT USED. 6.8.4 The following programs shall be established, implemented and maintained: a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside contamment that could contain highly radioactive fluids during a serious transient or accident to as low as practicallevels. The systems include the chemical and volume control, letdown, safety injection, residual heat removal, nuclear sampling, liquid radwaste handling, gas radwaste handling and reactor auildmg spray system. The program shall include the following: 1) Preventive maintenance and periodic visual inspection requirements, and 2) Integrated leak test requirements for each system at refueling cycle intervals orless, b. In Plant Radiation Monitoring 1) Training of personnel, 2) Procedures tor monitoring, and 3) Provisions for maintenance of sampling and analysis equipment. SUMMER - UNIT 1 6-11 Amendment No 10,40,72,70, +M

i#, (h[ y - ADMINISTRATIVE CONTROLS ~ ^ e + c. Secondary Water Chemistry 1 A program for monitoring of secondary water chemistry to inhibit. - steam generator tube degradation. This program shall include: H 1) Identification of a sampling schedule for the critical variables i and control points for these variables, i 2) Identification of the procedures used to measure the values of. the criticalvariables, j 3) Identification of process sampling points, including monitoring - 1 the discharge of the condensate pumps for evidence ofcondenser 4 in-leakage, 4) Procedures for the recording and management of data, 5) Procedures defining corrective actions for all off-control point chemistry conditions, l 6) A procedure identifying (a) the authority responsible for the interpretation of the data, and (b) the sequence and timing of - admmistrative events required to initiate corrective action. I i d. Postaccident Sampling A program which will ensure the capability to obtain and analyze j reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples 'under i accident conditions. The program shallinclude the following: } 1) Training personnel, 2) Procedures for sampling and analysis, 3) Provisions for maintenance of sampling and analysis equipment. e. Radioactive Effluent Controls Program. I I A program shall be provided conforming with 10 CFR 50.36a for the l control of radioactive efnuents and for maintaining the doses to members of the public from radioactive efnuents 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: 1) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation meluding surveillance tests and setpoint determinations in accordance with the methodology in the ODCM; l, s 2) Limitations on the concentration of radioactive material - h released in liquid efnuents to unrestricted areas conforming to j 10 times the concentration values in 10 CFR Part 20, Appendix B, Table II, Column 2; i i t SUMMER-UNIT 1 6-12 Amendment No. 35,57, - I 79,104,117,

p 4 j i ( ADMINISTRATIVE CONTROLS' j a i e. Radioactive Emuent Controls Program (Continued) 1

3).

Monitoring, sampling, and analysis of radioactive liquid and - i gaseous effluents m accordance with 10 CFR 20.1302 and with lo the methodology and parameters in the ODCM; - l 4) Limitations on the annual and quarterly doses or dose comminnent - to a member of the public from radioactive materials in liquid - 1 effluents released to unrestricted areas conforming to Appendix Ito 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; j q 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 or l radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual or dose .l commitment conforming to Appendix I to 10 CFR Part 50; i 7) Limitations on the dose rate resulting from radioactive material j released in gaseous effluents from the site to areas at or beyond 1 the site boundary shall be limited to the following: (a) For noble gases: Less than or equal to a dose rate of l 500 mrems/yr to the total body and less than or equal to a dose rate of 3000 mrems/yr to the skin; and (b) 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 of1500 mrems/yr to anyorgan; 8) Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents to areas beyond the site boundary conforming to Appendix 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 from with half-lives greater than 8 days in gaseous effluents released to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50; q

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.

SUMMER-UNIT 1 6-12a Amendment No.104,117, ~ -~

y. '... 1 .c - j 1 i

ADMINISTRATIVE CONTROLS I

x 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 ~ measures 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 ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following: i 1) ' Monitoring, sampl,ing, analysis, and reporting of radiation and radionuclides m the environment in accordance with the 1 methodology and parameters in the ODCM; i 2) A Land Use Census to ensure that changes in the use of areas at and beyond the site boundary are identified and that - i modifications to the monitoring program are made if required by the results of the census; and i 3) Participation in an Inter-laboratory Comparison Pror .1 to ensure that independent checks on the precision an( a..uracy of measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program - for environmentalmonitoring. l 4 i f SUMMER-UNIT 1 612b Amendment No.104,117 F 4

w ae g MW ' ADMINISTRATIVE CONTROLS y 6.9 REPORTING REQUIREMENTS

ROUTINE REPORTS 16.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Regional

. Administrator Office ofInspection and Enforcement unless otherwise noted.- STARTUP REPORT 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted followmg (1) receipt of an operating license, (2) amendment to the license involving a planned merease m power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel y supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. i 6.9.1.2 The startup report shall address each of the testa, identified in the Final Safety Analysis Report and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program J and a comparison of these values with design predictions and specifications. I Any corrective actions that were required to o >tain satisfactory operation shall ) also be described. Any additional specific details required in heense conditions based on other cornmitments shall be included in this report. l 6.9.1.3 Startu > reports shall be submitted within (1) 90 days following f completion of t:1e startup test program,(2) 90 days following resumption or.. commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover alt three i events (i.e., initial criticality completion of startup test program, and resumption i or commencement of commer,cial operation) sup >1ementary reports shall be submitted at least every three months until all tiree events have been completed. ANNUAL REPORT t 6.9.1.4 Annual re > orts coverin the activities of the unit as described below' for the previous ca endar year skall be submitted prior to March 31 of each year. The initial report shall be submitted prior to March 31 of the year following initial criticality. 6.9.1.5 Reports required on an annual basis shall include a tabulation on an l annual basis of the number of station utility, and other personnel (including contractors) receiving exposures grea,ter than 100 mrem /yr and their associated collective deep dose equivalent (reported in person-rem) according to work and job l : functions, y e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and ' refueling. The dose assignments to various duty functions may be estimatec based i on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20 percent of the individual total dose need not be accounted for. In the ? aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions. r y This tabulation supplements the requirements of(20.2206 of10 CFR Part 20. i SUMMER-UNIT 1 6-13 Amendment No. 79 i i w

1 ADMINISTRATIVE CONTROLS } This report shall also include the results of specific activity analysis m -i which the primary coolant exceeded the limits ofspecification 3.4.8. The i following information shall be included: (1) Reactor power history starting i 48 hours prior to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radioiodine performed prior to exceeding the . limit, results of analysis while limit was exceeded and results of one analysis - l after the radiciodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history (starting 48 hours prior to the first sample 'inl other radioiodine isotope concentration in microcuries per gram as a function 1 of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant - exceeded the radiciodinelimit. i \\ ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.6 The annual radiological environmental operating report covering the i operation of the unit durin before May 1 of each year. g the previous calendar year shall be submitted The report shall include summaries, interpretations, and an analysis of trends I of the results of the radiological environmental monitoring pro 6 ram for the reporting period. The material provided shall be consistent with the objectives outlined m (1) the ODCM and (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50. i 6.9.1.7 Not used. ) ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT i J 6.9.1.8 Annual radioactive effluent release report covering the operation of the unit during the previous fiscal year shall be submitted prior to May 1 of each year. The report shallinclude a summary of the quantities ofradioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50. I i SUMMER - UNIT 1 6-14 Amendment No. 79,104,

117,

.t ADMINISTRATIVE CONTROLS i i j e. Records of transient or operational cycles for those unit components identified in Table 5.7-1. f. Records of reactor tests and experiments. g. Records of training and qualification for current members of the unit staff. h. Records ofin-service inspections performed pursuant to these ~ Technical Specifications. i. Records of Quality Assurance activities as specified in the NRC's approved SCE&G position on Regulatory Guide 1.88, Rev. 2, October 1976. t j. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59. k. Records of meetings of the PSRC and the NSRC. 1. Records of the service lives of all hydraulic and mechanical snubbers defined in Section 3.7.7 including the date at which the service life commences and associated installation and maintenance records, Records of secondary water sampling and water quality. m. Records of analysis re monitoring program. quired by the radiological environmental n. o. Records of reviews performed for changes made to the Offsite Dose Calculation Manual and the Process Control Program. 6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. 6.12 HIGH RADIATION AREAS As provided in ? ara aph 20.1601(c) of 10 CFR Part 20, the following controls shallbe appliet h radiation areas in place of the controls required by paragraph 20.1601(a and (b) of10 CFR Part 20: 6.12.1 High radiation areas with dose rates not exceeding 1.0 rem / hour:* Each entryway to such an area shall be barricaded and conspicuously 'i a. posted as a high radiation area. Such barricades may be breached only during periods of personnel entry or exit. i At 30 centimeters from the radiation source or from any surface penetrated by the radiation. j [ SUMMER-UNIT 1 6-18 Amendment No. 35,49,75 79,88,104,

m-1 1 ADMINISTRATIVE CONTROLS b. Access to, and activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) or equivalent that includes i specification of radiation dose rates in the immediate work area (s) i and other appropriate radiation protection equipment and measures. Individuals qualified in radiation protection procedures (e.g., c. health physics technicians) and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while aerforming their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and workin such areas. d. Each individual (whether alone or in a group) entering such an area shall possess: 1) A radiation monitoring device that continuously displays radiation dose rates in the area (" radiation monitoring and indicating device"), or 2) A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device % dose alarm setpoint is reached (" alarming dosimeter"), with an appropriate alarm setpoint, or 3) A radiation monitoring device that continuously transmits dose rate and cumulative dose to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or 4) A self reading dosimeter and, i (a) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual at the work site, qualified in radiation protection procedures, equ,ipped with a radiation monitoring and indicating device who is responsible for contrellmg personnel radiation exposure within the area, or (b) Be under the surveillance, as specified in the RWP or I equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personne; radiation exposure in the area, Entry into such areas shall be made only after dose rates in the e. areahave been determined and entry personnel are knowledgeable ofthem. At 30 centimeters from the radiation source or from any surface penetrated by the radiation. SUMMER-UNIT 1 6-18a Amendment No.

ADMINISTRATIVE CONTROLS less than g00 rads / hour:**6.12.2 Hi h radiation areas with dose rates greater than 1.0; Each entryway to such an area shall be conspicuously posted as a a. high radiation area and shall be provided with a locked door or gate that prevents unauthorized entry, and in addition: 1) All such door and gate keys shall be maintained under the administrative control of the Shift Foreman or the health physics supervisor on duty. 2) Doors and gates shall remain locked except during periods of personnel entry or exit. t b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area (s) and other appropriate radiation protection equipment and measures. Individuals qualified in radiation protection procedures may be c. exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas. d. Each individual (whether alone or in a group) entering such an area l shallpossess: 1) An alarming dosimeter with an appropriate alarm setpoint, or 2) A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure i within the area with the means to communicate with and control every individual in the area, or 3) A self-reading dosimeter and, (a) Be under the surveillance, as specified in the RWP or i equivalent, of an individual qualified in radiation protection procedures, equipped with a radiation i monitoring and indicating device who is responsible for controlling personnel exposure within the area, or At 30 centimeters from the radiation source or from any surface penetrated by the radiation.

- At 1 meter from the radiation source or from any surface penetrated by the radiation.

SUMMEll-UNIT 1 6-18b Amendment No.

yq ~ '~ ~~-- ~' ' w. *. ; :4. ,g, 9.-, r- . ADMINISTRATIVE CONTROLS. l ~ .) 3-1 (b) Be under the surveillance, as specified in the RWP or l equivalent, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate R~ with and control every individual in the area. lt Entry into such areas shall be made only after dose rates in the l e. area have been determined and entry personnel are knowledgeable ofthem. L f. Such individual areas that are within a larger area that is ~ controlled as a high radiation area, where no enclosure exists for purpose oflocking and where no enclosure can reasonable be i constructed around the individual area need not be controlled by a locked door or ate, but shall be barricaded and cons >icuously I posted as a hi radiation area, and a conspicuous, c: early visible .i flashingligh all be activated at the area as a warning device.- 6.13 PROCESS CONTROL PROGRAM (PCP) j y 6.13.1 The PCP shall be approved by the Commission prior to implementation. 6.13.2 Changes to the PCP: I Shall be documented and records of reviews performed shall be j a. retained as required by Specification 6.10.2.o. This documentation i shallcontain: t 1) Sufficient information to su > port the change together with the l appropriate analyses or eva: untionsjustifym, g the change (s); j and .p t 2) A determination that the change will maintain the overall -l conformance of the solidified waste product to existing i requirements of Federal, State, or other applicable regulations. 1 a b. Shall become effective after review and accep'tance by the PSRC and approval of the General Manager, Nuclear Plant Operations, t At 30 centimeters from the radiation source or from any surface penetrated by l the radiation.

At 1 meter from the radiation source or from any surface penetrated by the 1

radiation. i i SUMMER-UNIT 1 6-19 Amendment No. 35,79,

104, i

, _.. ~. -

e ADMINISTRATIVE CONTROLS 6.140FFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation. 6.14.2 Changes to the ODCM: a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.2.o. This documentation shallcontain: 1) Suflicient information to su? port the change together with appropriate analyses or evaluations justifying tne change (s); and 2) A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.1302,40 CFR l Part 190,10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent dose or setpoint calculations. b. Shall become effective after review and acceptance by the PSRC and the approval of the General Manager, Nuclear Plant Operations. Shall be submitted to the Commission in the form of a complete c. legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Efiluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented. SUMMER - UNIT 1 6-20 Amendment No.16,35, 41,79,104,117

E. AttachmentII' M.N# TSP 940002 Prg21 cf 5 ' E . DESCRIPTION OF AMENDMENT REQUEST and the supporting ' - SAFETY EVALUATION s I Description of Proposed Chance and Safety Evaluation ~ South Carolina Electric & Gas Company proposes to modify the Virgil C. Summer - ' Nuclear Station (VCSNS) Technical Specifications (TS) to reflect changes to 10 CFR 20, including Appendix B, Table ll concentrations, and provide additional administrative-corrections. This Tech Spec change will: '1. Amend references from the old 10 CFR 20.106 requirements to the new 10 CFR ' 20.1302,

2.. Amend references from the old 10 CFR 20.203(c)(2) requirements to the new 10 CFR 20.1601(a),

3. Amend references from the old 10 CFR 20.407 requirements to the new 10 CFR ;

20.2206(b),

4. Revise the liquid release rate limit,

5. Revise the gaseous release rate limit,

6. Revise the settling pond radioactive material quantity,

7. Revise the TS Bases for the Liquid Holdup Tank activity limit, and

8. Revise the distance at which dose rates are measured to determine whether an area will be posted as a High Radiation Area.

f items 1 through 3 are administrative changes to reflect that the new 10 CFR 20 ~ sections are relocated requirements from the old 10 CFR 20 sections. Items 4,5, and 7 are being revised to maintain the existing level of effluent control by reflecting changes in the dose rate associated with the new 10 CFR 20 Appendix B concentrations. Item 6 is being revised to reflect administrative changes to the algorithm used to calculate the radioactive material quantity in the settling pond due to 10 CFR 20, Appendix B, Table 11 concentration changes. Item 8 is being revised to reflect a change in the distance from the source or surfcce, as required by 10 CFR 20.1601, at which dose rates are measured to determine whether an area will be posted as a High Radiation Area.

N ~ #" * 'Attachmentil i TSP 940002 1 Pcga 2 cf 5 i Safety Evaluation i

1. Amend references from the old 10 CFR 20.106 requirements to the new 10 CFR 20.1302,-

This administrative change is being made to reflect that the requirements in the old 10 CFR 20.106 are now located in the new 10 CFR 20.1302. l t

2. Amend references from the old 10 CFR 20.203(c)(2) requirements to the new 10 l

CFR 20.1601(a), This administrative change is being made to reflect that the re$uirements old 10 CFR 20.203(c)(2) are now located in the new 10 CFR 20.1 01(a). s

3. Amend references from the old 10 CFR 20.407 requirements to the new 10 CFR 20.2206(b),

\\ This administrative change is being made to raflect that the requirements in the l old 10 CFR 20.407 are now located in the new 10 CFR 20.2206(b). l

4. Revise the liquid release rate limit, i

The proposed change to the liquid release rate limit is bei,ng made in order to accommodate needed operational flexibility to facilitate implementation of the i new 10 CFR 20 requirements. j The basic requirements for Technical Specifications / Selected Licensee Commitments (TS/SLCs) concerning effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent TS/SLCs will keep average annual release of radioactive effluents to small percentages of the limits specified in the old 10 CFR 20.106 (new 10 CFR 20.1302). These requirements further indicate that the operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than small percentages, but still within the - limits specified in the old 10 CFR 20.106, which references Appendix B. Table ll concentrations (MPCs). These referenced concentrations are specific values which j relate to an annual dose of 500 mrem. It is further indicated in 10 CFR 50.36a that. when using operational flexibility, best efforts shall be exerted to keep levels of 1 radioactive materials in effluents as low as is reasonably achievable (Al. ARA) as set forth in 10 CFR 50, Appendix 1. I As stated in the introduction to Appendix B of the new 10 CFR 20, the liquid effluent concentration (EC) limits given in Appendix B, Table ll, Column 2, are ' based on an annual dose of 50 mrem. Since a release concentration corresponding to a limiting dose rate of 500 mrem / year has been acceptable as a l TS/SLC limit for liquid effluents, which applies at all times as an assurance that the limits of 10 CFR 50, Appendix I are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of ten. i Operational history at V. C. Summer has demonstrated that the use of the concentration values associated with the old 10 CFR 20.106 as TS/SLC limits has resulted in calculated maximum doses to a member of the public that are small i <= -m-v .m o ..m,, ,3 -,.,,_vg- ---y,- F -w,y m. 99'

-C i . 1 d"*- TSP 940002 Pag 23 of 5 percentages of the limits of 10 CFR 50, Appendix 1. Therefore, the use of concentration values which correspond to an annual dose of 500 mrem (ten times the concentration values stated in the new 10 CFR 20, Appendix B, Table 11, Column 2) should not have a negative impact on the ability to continue to operate within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Having sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations. As discussed above, the concentrations stated in the new 10 CFR 20, Appendix B, Table ll, Column 2, relate to a dose of 500 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem / year. This low value is impractical upon which to base effluent monitor setpoint calculations for many liquid effluent release situations when monitor background, monitor sensitivity, and monitor performance are taken into account. Therefore, to accommodate operational flexibility needed for effluent releases, the limits associated with the liquid release rate TS/SLC are based on ten times the concentrations stated in the new 10 CFR 20, Appendix B, Table 11, Column 2, to apply at all times. The multiplier of ten is proposed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix B. Table ll, Column 2, are based,is a factor of ten higher than the annual dose of 50 mrem, upon which the concentrations in the new 10 CFR 20, Appendix B, Table 11, Column 2, are based. Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by ' operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. t

5. Revise the gaseous release rate limit, The proposed change to the gaseous release rate limit is being made in order to accommodate needed operational flexibility to facilitate implementation of the new 10 CFR 20 requirements.

The basic requirements for Technical Specifications / Selected Licensee Commitments (TS/SLCs) concerning effluents from nuclear power reactors are i stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent TS/SLCs will keep average annual release of radioactive effluents to i small percentages of the limits specified in the old 10 CFR 20.106 (new 10 CFR 20.1301). These requirements further indicate that the operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than small percentages, but still within the limits specified in the old 10 CFR 20.106, which references Appendix B. Table ll concentrations (MPCs). These referenced concentrations are specific values which relate to an annual dose of 500 mrem. It is further indicated in 10 CFR 50.36a that when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix 1. As stated in the introduction to Appendix B of the new 10 CFR 20, the gaseous effluent concentration (EC) limits given in Appendix B, Table ll, Column 1, are based on an annual dose of 50 mrems for isotopes for which inhalation or ingestion is limiting or 100 mrems for isotopes for which submersion (noble gases)is limiting. Since release concentrations corresponding to limitir:g dose ?

.-.= 1:( t. a'Wm*

AttachmentII:

1 TSP 940002 J v I Page4cf 5; rates less than or equal to 500 mrems/ year to the whole body,3000 mrems/ year to the skin from noble gases, and 1500 mrems/ year to any organ from lodine-131,

lodine-133, tritium, and all radionuclides in particulate form with half-lives greater than eight days at the site boundary has been acceptable as a TS/SLC limit for gaseous effluents to assure that the limits of 10 CFR 50, Appendix I and 40 CFR 190 are not likely to be exceeded, it should not be necessary to restrict the -

operational flexibility,by incorporating the dose rate associated with the EC value for isotopes based on mhalation/ ingestion (50 mrems/ year) or the dose rate associated with the EC value for isotopes based on submersion (100 mrems/ year). j Having sufficWnt operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations. As discussed above,the 1 concentrations stated in the new 10 CFR 20, Appendix B, Table 11, Column 1, relate j to a dose of 50 or 100 mrems in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100 mrems/ year. These low values are - -l impractical upon which to base effluent monitor setpoint calculations for many r gaseous effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account. j i Therefore, to accommodate operational flexibility needed for effluent releases, r the limits associated with the gaseous release rate TS/SLCs will be maintained at the current instantaneous dose rate limit for noble gases of 500 mrems/ year to-i the whole body and 3000 mrems/ year to the skin; and for lodine-131, for lodine-133, for tritium, and for all radionuclides in particulate form with half-lives A greater than eight days, an instantaneous dose rate limit of 1500 mrems/ year to l any organ. Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Operational history at V. C. Summer has demonstrated that the use of the dose rate values i listed above (i.e.,500 mrems/ year,3000 mrems/ year,1500 mrems/ year) as TS/SLC limits has resulted in calculated maximum individual doses to members of the l public that are small percentages of the limits of 10 CFR 50, Appendix 1 and 40 CFR 190. g

6. Revise the settling pond radioactive material quantity, The proposed revision to the radioactive material quantity in the settl will not change the types and amounts of effluents that will be releaski pond

[ nor-cause an increase m individual or cumulative occu This is only a change to the method of (algorithm)pational radiation exposures. ~! determining the quantity of radioactive material in the settling pond due to 10 CFR 20, Appendix B, Tab' e ll e l-concentration changes and will not change net limits. There are no equipment or operational procedure changes due to the proposed revision. The proposed change to the quantity of radioactive material in the settling pond revises the reference to the acceptance criteria contained in the new 10 CF 120. i Currently, the settling pond limit is based on that quantity which would not exceed the maximum permissible concentration limits m' 10 CFR 20, Appendix B, Table 11, Column 2, at the nearest potable water supply if an uncontrolled release of settling pond inventory should occur. As discussed m the justification for the l liquid release rate limit, in order to allow for sufficient operational flexibility, the new settling pond limit is based on that quantity which would not exceed 10 l I i l L

-n,.. ~ i .. * + Attachment ti TSP 940002 i Paga 5 cf 5 j times the effluent concentration limits (ECLs) of 10 CFR 20, Apaendix B, Table 11, Column 2, at the nearest potable water supply if an uncontrol ed release of settling pond inventorysaould occur. An evaluation was performed to determine the activity that could be released from a failure based on 10 times the ECL values. The evaluation provided a larger allowable pond activity using 10 times the ECL values as a basis. Since 10 times the ECL concentration m 10 CFR 20, Appendix B, Table 11. Column 2, represent the same dose as the MPC concentration in the old 10 CFR 20, Appendix B, Table 11, Column 2, it is no less conservative to base the settling pond limit on 10 times the new 10 CFR 20, Appendix B, Table 11, Column 2 concentrations.

7. Revise the TS Bases for the Liquid Holdup Tank activitylimit, The proposed change to the activity limit bases for the Liquid Holdup Tanks revises the reference to the acceptance criteria contained in the new 10 CFR 20.

Currently, the Liquid Holdup Tank curie limit is based on that quantitywhich would not exceed the maximum permissible concentration lin:!ts of 10 CFR 20, Appendix B, Table ll, Column 2, at the nearest potable water su pply if the tank and components should fail, orwill be limited to 10 cmles. As d iscussed in the justification for the liquid release rate limit,in order to allow for sufficient operational flexibility, the new Liquid Holdup Tank curie limit is based on that quantity which would not exceed 10 times the effluent concentration limits (ECLs) of 10 CFR 20, A ppendix B, Table 11, Column 2, at the nearest potable water supply if the tank and components should fail, or will be limited to 10 curies. The tank curie content is not changed, therefore, the existing level of effluent control is maintained.

8. Revise the distance at which dose rates are measured to determine whether an area will be posted as a High Radiation Area.

The proposed change to the distance at which dose rates are measured in order to determine whether the intensity of radiation is equal to or less than 1000 mrem / hour is being made as a result of the new 10 CFR 20.1601 requirements. The distance from the radiation source or from any surface which radiation penetrates is being changed from 45 cm (18 in.) to 30 cm (12 in.). This change is more conservative in its effect on worker protection in that it reduces the threshold for classification as a High Radiation Area. P 1-

i ',. 4 - Attachm:ntll1 i

4?' ' 1

TSP 940002 j

+ Pags 1 of 4 i \\ DESCRIPTION OF AMENDMENT REQUEST and the associated NO SIGNIFICANT HAZARDS EVALUATION t Description of Proposed Chance and No Sionificant Hazards Analysis South Carolina Electric & Gas Company proposes to modify the Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS) to reflect changes to 10 CFR 20, i including Appendix B, Table ll concentrations, and provide additional administrative corrections. This Tech Spec change will:

1. Amend references from the old 10 CFR 20.106 requirements to the new 10 CFR 20.1302,

2. Amend references from the old 10 CFR 20.203(c)(2) requirements to the new 10 CFR 20.1601(a),

i

3. Amend references from the old 10 CFR 20.407 requirements to the new 10 CFR 20.2206(b),

9

4. Revise the liquid release rate limit,

5. Revise the gaseous release rate limit, i

6.' Revise the settling pond radioactive material quantity,

7. Revise the TS Bases for the Liquid Holdup Tank activity limit, and

8. Revise the distance at which dose rates are measured to determine whether an area will be posted as a High Radiation Area.

Items 1 through 3 are administrative changes to reflect that the new 10 CFR 20 sections are relocated requirements from the old 10 CFR 20 sections. Items 4,5, and 7 are being revised to maintain the existing level of effluent control. by reflecting changes in the dose rate associated with the new 10 CFR 20 Appendix B l concentrations. Item 6 is being revised to reflect administrative changes to the algorithm used to calculate the radioactive material quantity in the settling pond due to 10 CFR 20, Appendix B, Table ll concentration changes. Item 8 is being revised to reflect a chan e in the distance from the source or surface, as required by 10 CFR 20.1601, at which dose rates are measured to determme whether an area will be posted as a High Radiation Area. [ l l l a

3,-&

Attachment lil' t h

* *~

TSP 940002 l Pags 2 cf 4 ' No Sianificant Hazards Analysis .10 CFR 50.91 requires that the following analysis be provided concerning whether 1 the pro sosed amendment request involves a significant hazards consideration as definec in 10 CFR 50.92. SCE&G has evaluated the proposed change to the VCSNS TS described above and has determined that the changes do not involve any significant hazards for the following reasons:

1. The probability or conseauences of an accident previously evaluated does not invo ve a sianificant increase.

The proposed TS changes showing the relocation of the old 10 CFR 20.106 I requirements to the new 10 CFR 20.1302, the old 10 CFR 20.203(c)(2) requirements to the new 10 CFR 20.1601(a), and the old 10 CFR 20.407 i requirements to the new 10 CFR 20.2206(b) will not involve a significant increase in the probability or consequences of an accident previously evaluated because there will be no change in the types and amounts of effluents that will be J released, nor will there be an increase in individual or cumulative occupational radiation exposures. The proposed revision to the liquid and aseous release rate ts will not invo ive a significant increase in the probability or consequences of an accident i previously evaluated because there will be no change in the types and amounts of effluents that will be released, nor will there be an increase m individual or cumulative occupational radiation exposures. This is only a change to the method of (algorithm) determining release rate limits and will not change net limits or change the more restrictive 10 CFR 50 Appendix i dose limits. The proposed revision to the radioactive material quantityin the settling pond will not involve a significant increase in the probability or consequences of an accident previously evaluated because there will be no change in the types and amounts of effluents that will be released, nor will there be an increase in i individual or cumulative occu to the method of (algorithm)pational radiation exposures. This is only a cha the settling pond and will not change net limits. The proposed revision to the TS bases for the Liquid Holdup Tank activity limit will not involve a significant increase in the probability or consequences of an i accident previously evaluated because there will be no change in the types and amounts of effluents that will be released, nor will there be an increase in I individual or cumulative occupational radiation exposures. The curie limit is not affected, therefore, the change does not represent a decrease in the level of l control previously evaluated. The proposed revision to the distance at which dose rates are measured from the l radiation source or surface will not involve a significant increase in the probability or consequences of an accident previously evaluated because there will be no increase in the individual or cumulative occupational radiation exposures. The change in distance is conservative in its effect on worker protection and is in conformance with 10 CFR 20.1601 requirements. i 4 ) , ~ - -

1 h.?? "T,- Attachmentlli a TSP 940002 . Pag 23 of 4 -

2. The possibility of a new or different kind of accident from any previously evaluated is not created.

- The proposed T5 changes showing the relocation of the old 10 CFR 20.106 - j requirements to the new 10 CFR 20.1302, relocation of the old 10 CFR 20.203(c)(2). requirements to the new 10 CFR 20.1601(a), and relocation of the old 10 CFR J 20.407 requirements to the new 10 CFR 20.2206(b will not create the possibility. of a new or different kind of accident from any pr)eviously evaluated becaus i revisions are administrative and will not change the types and amounts of j effluents thatwill be released. The proposed revision to the liquid and gaseous release rate limits will not create. i the possibility of a new or different kind of accident from any previously evaluated because the revision is administrative and wiu not change the types - and amounts of effluents that will be released. The proposed revision to the quantity of radioactive material in the settling pond will not create the possibility of a new or different kind of accident from any - 1 previously evaluated because the revision is administrative and will not change the types and amounts of effluents that will be released. The proposed revision to the TS bases for the Liquid Holdup Tank activity limit will not create the possibility of a new or different kind of accident from any previously evaluated because the revision is administrative and will not change the types and amounts of effluents that will be released. Implementation of the more conservative distance at which dose rates are measured will not create the possibility of a new or different kind of accident from any previously evaluated. 1

3. A sianificant reduction in a marain of safety is not involved, The proposed revisions due to the location of requirements.will not reduce a j

margin of safety because they are administrative in nature.' No equipment or procedural changes are postulated. There is no impact on any margin of safety. The p,roposed revision to liguid and gaseous release rate limits will not reduce a l margin of safety because it is administrative in nature. These revisions preserve the existing level of effluent control. No changes to the more restrictive 10 CFR - l ' 50 Appendix l dose limits are made. There are no equipment or operational procedure changes, therefore, no accidents of any kind will be created by this change. The proposed revision to the uantity of rac'ioactive material in the settiin will not reduce a margin of sa1ety because it is administrative in nature an3 pond i preserve the existing level of effluent control. There are no equipment or l operational procedure changes, therefore, no accidents _of any kind will be created by this change. i The proposed revision to the TS bases for the Liquid Holdup Tank activity limit will not reduce a margin of safety because it is administrative in nature and preserve the existing level of effluent control. No equipment or procedural i changes are postulated. There is no impact on any margin of safety. l 1; i a +

P- ~.'1 e ' o J ^ x n.o-11 TSP 940002 - Pago4 of 4 The change in distance for a High Radiation Area classification from 18 in.(45 cm) to (30 cm)12 in. from the radiation source or surface will not reduce the margin of safety because this change will reduce the worker's stay time in the area and r therefore minimize exposure. Accordingly, this proposed change does not involve a significant hazard.' i t i 5 i l k I 9'

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ML20080K198

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