ML20092A237

Proposed Tech Specs,Consisting of Change Request TSP 940002, Incorporating Revs to 10CFR20

ML20092A237
Person / Time
Site:	Summer
Issue date:	08/31/1995
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20092A232	List: ML20092A237 RC-95-0226, Application for Amend to License NPF-12,consisting of Change Request TSP 940002,incorporating Revs to 10CFR20
References
NUDOCS 9509080271
Download: ML20092A237 (46)

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' Doc 5m:nt Control Desk

. Attachm:ntI

. TSP 940002 RC-95-0226 Pcge l of 4 SCE&G -- Explanation of Technical Specification Changes l for Part 20 Changes, Revision 1 i ed B Description of Change PAGE Reason for Change 3/4111 3/4.11 1 Title numbering added back in. Due to the repagination process of Amendment 104, the title was inadvertently omitted.

3/4 11-1 3.11.1.1 2 Insert A: Added 3.11.1.1, 3.11.1.2, and This was added back in to eliminate 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.

3.11.1.4 3 Third line,"or" was changed to "of". To correct a typo from a previous Action a amendment.

4.11.1.1 4 Insert B: Added 4.11.1.1, 4.11.1.2, and This was added back in to eliminate 4.11.1.2 4.11.1.3 back in. confusion as to why the Surveillance 4.11.1.3 Requirements started with Section 4.11.1.4. 1 3/4 11-2 Aj 1 Changed " curie" to " curies". Typographical error.

Cj 2 Changed "II" to "2" Reflects new notation given for 10CFR20, Appendix B, Table 2.

4.11.1.5 3 Changed ".6" to "1.0" ".6" changed to"1.0" based on ensuring Equation the consequences of an uncontrolled release of the pond inventory are within 10 CFR 20, Appendix B, Table 2, Column 2, limits.

3/4113 Qj 1 Added comma after " half-life". Punctuation correction.

Cj 2 Changed "II" to "2" Reflects new notation given for 10CFR20, Appendix B, Table 2.

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 None 0 None; this page was originally submitted No changes. Remove this page from the for font change only. NRC recommended original submittal per NRC we remove this change from our recommendation.

submittal.

9509080271 950831 PDR ADOCK 05000395 P PDR

T)oc0 ment Control Desk

. AttachmentI

. TSP 940002 ,

RC-95-0226  !

Page 2 0f 4 '

SCE&G -- Explanation of Technical Specification Changes for Part 20 Changes, Revision 1 PAGE A" d " Description of Chance g ti # Reason for Chance ,

)

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.

3/4.11.1.4 2 1) Added "10 times" between "less than" 1) The Part 20 Rule lowered values by a and "the limits of". factor of10. The factor of10 maintains allowable limits.

2) Changed "II" to "2". 2) Reflects new notation given for 10CFR20, Appendix B, Table 2.

3/4.11.1.5 3 1) Paragraph 1, Line 4: Changed the 1) This was an administrative change to word " uncontrolled" to more clearly derme the area

" unrestricted". consistent with Part 20 Rule terminology.

2) Paragraph 1, Line 5: Changed the 2) Note 4 is now the applicable note.

word " Note 1" to " Note 4". The Part 20 Rule renumbered Note 1 as Note 4.

3/4.11.1.5 4 Paragraphs 2,3, and 4 were replaced New paragraph 2 provides a direct with a new paragraph 2. comparison of radionuclide specific activity to the concentrations in 10 CFR 20, Appendix B, Table 2, Column 2.

B 3/411-2 3/4 11.1.5 1 Removed remainder of 3/4.11.1.5. Repagination process.

3/4.11.2.1 2 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, 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.

6-11 6.8.4.a.1) 1 Renumbered subheadings 6.8.4.a.(i), Restructured subheads throughout t 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 to achieve 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) i 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.c.1) 3 Changed punctuation at the end of the Typographical error, sentence from a comma to a semicolon.

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' Doc 6m:nt Control Desk 1

- Attachment I

. TSP 940002 RC-95-0226 Page 3 of 4 SCE&G -- Explan~ation of Technical Specification Changes  !

for Part 20 Changes, Revision 1 PAGE AII" d Br Description of Chance Reason for Change ggcti 6-12 6.8.4.o.2) 4 ,1) Added "'O times the concentration 1) The Part 20 Rulelowered values by a continued i values in " between " conforming to" factor of10. The factor of10 l and "10 CFR" maintains allowable dose limits.

2) Changed "II" to "2" 2) Reflects new notation given for 10CFR20, Appendix B, Table 2.

6-12a 6.8.4.e.3) 1 Changed "20.106" to "Part 20.1302". Part 20 rule relocated the requirements.

6.8.4.e.7) 2 Insert G Establishes the gaseous effluent dose rate limits. These limits, in conjunction with 10 CFR 50 Appendix Ilimits, maintain 10 CFR 20 dose limits.

612b 6.8.4.f N/A Repagination process caused 6.8.4.f and Repagination.

and 6.8.4.f.1) to move 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 exposure" to" collective deep dose terminology.

equivalent (reported in person-rem)".

1/ 3 Changed "620.407" to "620.2206". Part 20 Rule relocated requirements.

6-14 6.9.1.8 1 1) Paragraph 1, Line 2: Changed "12 1) To clarify reporting criteria to mean months of operations" to" calendar January 1 through December 31.

year"

2) Paragraph 1, Line 3: Changed 2) To provide for allowable report "within 60 days after January 1" to preparation time, specified in 10 CFR

" prior to May 1" 50.36(a) limits, maintains 10 CFR 20 dose limits.

6-18 6.12.1 1 1) Changed"20.203(c)(2)"to 1) To reflect Part 20 Rule changes and

[ "20.1601(a)" relocation.

l

2) Added asterisk (footnote) after 2) Footnotes added to annotate the l " mrem /ht" in two places. measurement distance changes for j high radiation areas.

6.12.1 2 Added old footnote into body of 6.12.1. Toimprove readability.

, Footnote 3 Added footnote to 6.12.1. Footnote added to annotate the I measurement distance changes for high i

radiation areas.

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'Dochm:nt Control Desk

. Att chmentI '

. TSP 940002 RC-95-0226 Pago4of4 SCE&G -- Explanation of Technical Specification Changes for Part 20 Changes, Revision 1 ted r Description of Change Reason for Change PAGE

^II[ti9n Se 6-19 6.12 .1.c 1 1) Repaginatedlast threelines. 1) Toimprove readability. '

2) Removed " Health Physicist" in the 2) To reflect plant administrative last line. control.

3) Changed " Radiation Work Permit" to 3) To improve readability.

"RWP" 6.12.2 2 Replaced by Insert II. To reflect Part 20 Rule changes.

Footnote 3 1) Changed first footnote to 6.12.2. 1) Footnote changed to annotate the measurement distance changes for high radiation areas.

2) Added second footnote to 6.12.2. 2) Footnote added to annotate the i measurement distance changes for high radiation areas.

6-20 6.14.2.a.2) 1 Changed "20.106" to "20.1302" Part 20 Rule relocated requirements.

l

RADIOACTIVE EFFLUENTS 3/4.11.1 LIOUID EFFLUENTS LIOUID HOLDUP TANXS l

LIMITING CONDITION FOR OPERATION Inset a ,

A 3.11.1.4 tanks shall be limitea to less than or equal to 10 curie and dissolved or entrained noble gases.

- ~

a. Condensate Storage Tank

b. Outside Temporary Storage Tank -

APPLICABILITY: At all times.

ACTION:  :

i

a.  !

With tne cuantity of raaicactive material in any of the aoove listed tanks exceeaing the aoove limit, immeaiately susoeno all auditions of,.cf' racioactive material to the tank and within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the I tank contents to within the limit, b.

The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REOUIREMENTS Insar W 3 4.11.1.4 The quantity of raaicactive material contained in each of the above l

listed tanks shall be ceterminea to be within the above limit by analyzing a representative samole of the tank's contents at least once per 7 days when radioactive materials are being added to the tank, k str+ A 3 .11. I. 1 D e l,$ d by A m e.n d m e.n + 104  !

5. a. I. L 3.11.1.3 '

i 1,3 sac + 3 Y. //. I I

4. ll I . 2-

4. l j . f . 3 sf SUMMER - UNIT 1 3/4 11-1 nmenament No. 104

l

. . I e

RADIOACTIVE EFFLUENTS SETTLING POND i

LIMITING CONDITION FOR OPERATION l 3.11.1.5 The quantity of radioactive material contained in each settling pond  !

shall be limited by the following expression: i i

A 264.j < 1. 0 J

~

excluding tritium and dissolved or entrained noble gases, where,  !

A j=Pondinventorylimitforsingleradionuclide"j",incuriei 4

C 2 <

j = 10 CFR 20, Appendix B, Table.W. column 2, concentration for single radionuclide "j", microcuries/ml.

V = design volume of liquid and slurry in the pond, in gallons.

264 = Conversion unit, microcuries/ curie per milliliter / gallon.

APPLICABILITY: At all times.

ACTION:

a. With the quantity of radioactive material in the settling pond exceeding the above limit, immediately suspend all additions of radioactive material to the pond and within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the pond contents to within the limit.

b. The provisions of specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REOUIREMENTS 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 slurry, and batches to be transferred to the settling ponds shall be limited by the expression:

I < .Or$' j . 0 J '

SUMMER - UNIT 1 3/4 11-2 Amenament No. 104

I l 4

RADIOACTIVE EFFLUENTS SURVEILLANCE RE0VIREMENTS (Continued) where Oj = concentration of radioactive materials in wet, drained slurry (used powdex resin) for radionuclide j" excluding tritium, dissolved or entrained noble gas and radionuc.lides 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 Co-60. Estimates of Sr-89, Sr-90, batch concentrations sha13 be bas ~ed on the most recently available quarterly composite analyses.

C j = 10 CFR 20, Appendix B, Table Jir' column 2, concentration for single  !

radionuclide "j", in microcuries/ milliliter. '

l SUMMER - UNIT 1 3/4 11-3 Amendment No. 104

I RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION 1aset 2

' C-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.

APPLICABILITY: At all times.

ACTION:

a. With the concentration of oxygen in the waste gas holduo system greater than 2% by volume cut less than or eoual to 4% by volume, restore tne concentration of oxygen to within the limit within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

J

b. With the concentration of oxygen in the waste gas holdup system i greater than 4% by volume, immeaiately suspend all additions of waste gases to the system ano reduce the concentration of oxygen to less than 4% by volume within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and less than or equal to 2%

by volume within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. .

c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

5 i

SURVEILLANCE REOUIREMENTS '

1 pdet -+  !

D 4.11.2.5 The concentration of hydrogen and oxygen in the waste gas holdup  !

system shall be oetermined to be within the aoove 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.

ggC 3. fl.1 l A.{eh.1 by b"01M M I 3 . l l . l . 2.

3.11. L . 3 i L . ll .1. 4 t b sart D 4.II.2.\

4. II .1.1

4. il.1. 3 SU MER - UNIT 1 4.11. 2. d 3/4 11-4 Amenoment No. 104

3/4.11 RADIOACTIVE EFFLUENTS BASES 3/4.11.1 LIOUID EFFLUENTS la"rt E 3 /Y. ll I I De W h A,,w ),.,<4 by

/4.11.1.3 Nut Used t' 2 "5" 3 . .3 y 3/4.11.1.4 LIOUID HOLDUP TANKS E .

io +; ,

Restricting the quantity of raaicactive mater tanks tanks'provides assurance that in the eventr-of an uialof contained ncontrolled release the in contents, the resulting concentrations would be less than'the limits of ~

10 CFR Part 20, Appendix B, Table Jr? 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 "asb;Aj pond is located in an ,cxvun viles area as defined in 10 CFR 20, and that the concentration limit in Note 2 to Appendix B of 10 CFR 20 applies.

\ he at'eq o si suh t at radica ti ryrrys Ko tra thqsfe c' remicb1tokheth abent\pok's

'rqasona ly ma hi n

'n e

ancq wi h 1 CF 50.'S6a.

P ate s w$ i Specific io The r si i s 4. M. u ba h f s or wil b trknsf re t th holess he um h at s t ac 'vi o the a 'onhcli s t theirxte ec iv en ti n imi tion i es th t e 'atio o the

'0 3 ct1gn .A, to 1 b' dy eve to he 10 FR 0,105x),

alFR50hA end{i 10 ,o a b y'dgs 11  :

x . \

< mram/v x

j u mr /y = .00 er x

\

s a 'oactivess ry co en at qn 'or rad onu lid "j' ent ri

c3 = uhre tri ed SP, mi ro ri /m 111 it e

C = 0CR 0, pgen y B, Table I, col n c ce tra ion or in le rhdi(oguli j" i m roburi mi\ li it r e es f ilter/ min ra 'zers us'ng owder si w h klue nd the el f resin ed er tc is fix d th ce teskr vrf e ahd t e lu ry lume .o sin we'ght at i co ta t a 10 mi ea\

we' c.a1qedresnwithN gram gf isture con nt\pf prb im tel den 't of\ab ut 58 pounds p r hpbi feet). \The we dr&ine55 to si ry one

\

is \

The density of weMeMpproximiely thMme as w%(bulk dM of about 58 pouncfs per cubic foot); and the absorption characteristics for gamma radiation are essentially that of water. Therefore, direct comparison of radionuclide specific activity in wet, drained resin to the appropriate concentration in 10 CFR 20, Appendix B, Table 2, Column 2, ensures that the limit of Specification 3.11.1.5 will not be exceeded.

v v-SUMMER - UNIT 1 B 3/4 11-1 Amenament No. 104

7 l RADI0 ACTIVE EFFLUENTS BASES W4\11\1.) NETTLINGYdND ( n 'n d kpoi\mte g . d th a so pt'o c ra te i ti fo g mm l' di tion 's 9et il a o te . Te fa e, i

1U i gm 0.00 , d Gj _

/

Ct mi eete e sa ef f e if1 a io 4 11 1. .

at h 11 i t'v1 y in ut to he SP w 11 e h ss ra ce th t m 1 ie,a a t fy'n i t i ve t ry li ~ 'o f p c1 i to 3.1.1. .\raI iohet ve //.2.I ma e ia Dektej Ly Amujmut l0Y

,t F 3/f.

3/4.11.2 GASEOUS EFFLUENTS 3/'l.ll 1 L a

/ 3/4.11.2.5 EXPLOSIVE GAS MIXTURE 3/'/. ll. 2. 3 3/q,fl,z,t/ y F 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 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 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 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".

1

SUMMER - UNIT 1 B 3/4 11-2 Amendment No. 104

ADMINISTRATIVE CONTROLS d.

Critical by operation of the unit shall not be resume ~d until authorized the Consnission.

6.8 PROCEDURES AND PROGRAMS 6.8.1 covering Written procedures the activities shall be established, referenced below: imolemented ano maintained a.

Guide 1.33 Revision 2 February 1978.The "A" applicable of Regulatory proce

b. Refueling operations.

c.

d. Surveillance Security Plan.and test activities of safety-related equipment.

e. . Emergency Plan.

f. Fire Protection Program.

g. PROCESS CONTROL PROGRAM.

h.

OFFSITE DOSE CALCULATION MANUAL.

i. >

Effluent and environmental monitoring program using the guidance in Regulatory Guide 4.15, Revision 1, February 1979.

6.8.2 prior to implementation as set fortn in 6.5 above.Each proceoure of 6 -

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 containment 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:

0 K Preventive maintenance and periodic visual inspection requirements, and 2.)(}ti Integrated leakortest cycle intervals less.requirements for each system at refu

b. In-Plant Radiation Monitorino 0 Training of personnel,

2) Proceoures for monitoring, and

3) Provisions for maintenance of sampling and analysis equipment.

SU)HER - UNIT 1 6-11 Amencment No. IB,0.72.D,117

. . . - - - - -.- .... . - - - . _ - . . - . - . . ~ . - . . . - - - _. ._

J i

l ADMINISTRATIVE CONTROLS

c. Secondary Water Chemistry ~

A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation. This program shall include:

1) Jtf- Identification of a sampling schedule for the critical variables and control points for these variables, 2.) 94) Identification of the procedures used to measure the values of the critical variables.

I

3) (.14t)~ Identification of process sampling points, including monitoring i the discharge of the condensate pumps for evidence of condenser in-leakage, ,

i

4) pyy Procedures for the recording and management of data, S) fv7 Procedures defining corrective actions for all off-control point chemistry conditions, Q (vtf A procedure identifying (a) the authority responsible for the  !

interpretation of the data, and (b) the sequence and timing of -

administrative events required to initiate corrective action.

d. Postaccident Samplino A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shall include the following: i 0 Training personnel, 2.) 4 Procedures for sampling and analysis, 3).ptt) Provisions for maintenance of sampling and analysis equipment.

e. Radioactive Effluent Controls Procram A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable.

be implemented Thebyprogram operating(1) shall be contained procedures, and (3) shall ininclude the ODCM, (2) shall (

remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

1) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and c setpoint determinations in accordance with the methodology in the ODCMj; l

2) Limitations on the concentration of radioactive material

( released in liquid effluents to unrestricted areas conforming to

, v4.s W s10 CFR Part 20 Appendix C, Table Jr. Column 2; 2-SUMER - UNIT 1 6-12 A**" **"* "

',h) '

. ADMINTSTRATTVE CCNTROLS e.

Radioactive 3)

Effluent Centrols Precram (Continued) -  ;

Monitoring, sampling, and analysis of radioactive licuid and methodology ano parameters in the 00CM;gas i 1302 4)

Limitations on the annual and quarterly doses or dose coinnitment to a memoer of the puolic from radioactive materials in liquid effluents I to 10 CFR released Part 50;to unrestricted areas confoming to Appendix '

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 00CM at least every 31 days;  ;

6)

Limitations on the coerability and use of the liquid and gaseous effluent' treatment systems to ensure thac the appropriate portions of these systems are used to reduce releases or radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual or dose consmitment confoming to Appendix ! to 10 CFR Part 50; Mai t ns n qe o t' ate esbiting 'f MMb c fo i t se a raVio eMa r 1' at 0 F '

I lu , p x

%)

• 8)

Limitations on the annual and quarterly air doses resulting from '

noble gases released in gaseous effluents to areas beyond the site boundary confoming 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 confaming to Appendix I to 10 CFR Part 50; -

10)

Limitations on the annual dose or dose comitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190. '

f.

Radiolooical 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 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 00CM, (2) confom to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following: (

1)

Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the 00CM; SUMMER - UNIT 1 Amenoment No. IN,117 6-12a

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"DoEidnint'ControfIEsk

AttachmentII

, TSP 940002

' RC-95-0226 -

Revision 1 -

Page l of1 i i

INSERT G 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 mrem /yr to the total body and less than or equal i to a dose rate of 3000 mrem /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 mrem /yr to any organ; i

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t f

t I

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

P

ADMINISTRATTVE CONTROLS

~ I f.

Radiological Environmental Monitorino Procram (Continued)

2) .

i A Land Use Census to ensure that changes in the use of areas at j and beyone the site bounaary are identified and that modifications the results of to thethe monitoring census; and progren are made if required by 3)

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

l o

SUMMER - UNIT 1 6-12b Amenenent No. Igg,117

ADMINISTRATIVE CCNTROLS -

z

6. 9 REDORTIN* REOUIREMENTS # -

ROUTINE REPORTS 5.9.1 In accition to the acclicaole reporting recuirements of Title 10. Coce cf Feceral Regulations, the following recorts snail be suomitted to the Regional  !

Aoministrator Office of Inspection anc Enforcement unless otherwise notec.

STARTUP REPORT

6. 9.1.1 A summary recort of Diant startuo anc power escalation testing'snall be suosittee following (1) receipt of an coerating license, (2) amenoment to  !

tne license involving a plannec increase in power level, (3) installation of fuel that has a different design or nas teen manufacturec by a cifferent fuel i supplier, anc (4) mocifications that may nave significantly alterec the nuclear, thermal, or nycraulic performance of tne plant.

6.9.1.2 The startuo report shall accress eacn of the tests icentifiec in the inal Safety Analysis Report ano snall incluce a oescriDtlen of the measurec values of the coerat1ng concitions or enaracteristics cota1nec curing the test Oregram tions. anc a comoartson of these vaiues witn cesign prec1ctions ano specifica-Any corrective actions that were reoutree to cotain satisfactory coeration snall also be cescribec. Any accitional sDecific cetails recuitec in license concit1ons basec on otner commitments snall be inclucea in th report.

6.9.1.3 Startuo reports snall be suosittee within (1) 90 days following completion of tne startuo test crogram (2) 90 days following resumotion or commencement criticality, of commercial

• ntenever power eperation, or (3) 9 months following initial is earliest. If the Startuo Report coes not cover all three events (i.e., initial criticality, completion of startuo test program, anc resumotion or commencement of commercial operation) supplementary reports snali completec.

Deen ce suomittec at least every three months until all inree events nave ANNUAL REDORT 5.9.1.4 Annual reports covering the activities of the unit as cescr10ec below for the previous calencar year snail be suositted prior to Maren / of eacn year.

following The initial initial report criticality.shall be suosittec prior to Maren lof the year yg f

6.9.1.5 Reports recuirec on an annual basis shall incluce a taculation on an Cchedive. beIJ ose annual basis of the numoer of station, utility, anc otner personnel (including ep* aleat (ryer+d = contractors) r=m accercingrecetving exoosures to work and joogreater inan 100 mrers/yr anc their associated functions,F i e.g., reactor operattons i

.* f"'** ~ *) anc surveillance, inservice inspection, routine maintenance, special maintenance (cescribe maintenance), waste processing, anc refueling. The cose assignments to various cuty functions may be estimatea baseo on pactet cosimeter, TLD, or film baoge measurements. Small exposures totalling less than 20 percent of the incivicual total cose neea not be accountec for. In the aggregate, at least 80 percent of the total wnole bocy cose receivec from external sources snould ce assignec to specific ma3er worn functions.

MThis taculation suoDiements tne recuirements of $20.MTof  ! 10 CF SUMMER - UNIT ; 22.0(a 6-13 Amenament No. 7:

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ADMINISTRATIVE CONTROLS '

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This report shall also include the results of specific act1vity analysis in which the primary coolant exceeded the limits of specification 3.4.8. The following information shall be included: (1) Reactor power history starting -

i l

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first samole in wnich the limit was exceeded; (2) Results i 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 should include date and time of sampling and the radiciodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 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.

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 sumaries, 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.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

6.9.1.7 Not used.

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT j

6.9.1.8 Annual radioactive effluent release report covering the operation of the unit during the previous -14mthe-of-o k

-w+ thin 604a f rlo r to Nay eU We yw f^i r Jarwary 1 of each year. %perettens-shall be submitted The report shall include a sumary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the 00CM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

SUMMER - UNIT 1 6-14 Anenement No. IP,I24,117

ADMINISTRATIVE CONTROLS

e. Records of transient or operational cycles for those unit components  ;

identified in Table 5.7-1.

1

f. Records of reactor tests and experiments.

g. Records of training and qualification for current members of the unit  !

staff.

h. Records of in-service inspections performed pursuant to these

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Technical Specifications.

i. Records of Quality Assurance activitieslas specified in the NRC's approved SCE&G position on ReguTatory Guide 1.88, Rev. 2, October 1976.

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.

m. Records of secondary water sampling and water quality.

n. Records of analysis required by the radiological environmental monitoring program.

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 of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph intensity of 20.Noi (*kC.203(u)(Et of 10than radiation is greater CFR10020,mrem each/hP highbutradiation less thanarea 1000inmrem which/hrthe,shall be o barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)./ Any individual or group of individuals permitted to enter such areas l shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area, indiv b ls 7 Health Physics personnel or perse = 1 escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned cedietici protest-ton duties, provided they otherwise comply with approved radiation protection procedures for entry into high radiation areas.

• /%sau n+ mok of 30em (n.io.) froa,, + l,e ra);a+;u w,ee ,, g,, _Y (

sac k p w+ra+ed by +L.caJ&+i . >

SUMMER - UNIT 1 6-18 Amencment No. 75, 47, 75, 77, 1nd

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ADMINISTRATIVE CONTROLS l

b. A radiation monitoring device which continuously integrates the I radiation oose rate in the area and alarms when a preset integrated dose is received. Entry into sucn areas with this monitoring device may be mace after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

c. A health physics qualified individual (i.e., qualified in radiation l protection procedures) with a radiation dose rate monitoring device )

who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency sp_ecified-by the f cilityhh l thysici:t in- the Radietion-Work-termit- AWi".

6 2. I a it'on o t e r)qut ernqnts\of .12 1, arh s cesib\e o ers nn(1 i r ia io le els suc tngt e ou a os gr ate th n ly00 matortort'on f he ad coldKeciv 1 cke d r in

\

re st)11 e p ov'de wi 5 to p vept naL ho ize en

's raF ve ce to of the y, hian t the remke n ns s ty all nd/

be ai ta ged r ear h nortehamIpio.

ys ps uphrvt os al r ai lo ked xc ot uri g eri ds f a ce b pe soryel under n ap ve R w ich sha 1 s ci y t e o se at le is in he inm oia r a a.

low 4 h xi um 11 ab e s ay ir o nt .

'me for ind'vi al in tha a ea hal b es b s d "o ind vid 1 rea at es 'bl to er on el ith ra 'a pn g A l ve s uc t t ma'or ort n f t e b dy ou r cei e 'n o e h ur doge a 'n ex e o 1 0 rem ** t at e oca ed ith'n i rg a as su h a P n ai m t, wh e o e clo ure x1 ts or urp ses of lo in , a d n enlo\ re c e e son b) co st ete ar n the in 'vi al re s, the th t a ea 1 eroegof, on ic ou ly p ste an a las ing li t ha 1 b ac iva ed (a w r 'n vi e. In ie of he ta tim spci"ca(o of he RWP dir et r mo e sc as use of lo ed 'rcu t c era ) c ntTpu s rv ill nce sha be m 'e y so ne qu li 'ed ra ac ivi ies rotctihn iat'on o du s o p ovi e po itive ex a[s,ure co tro o rt wi in th r9 6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approvea by the Commission prior to implementation. ,

6.13.2 Changes to the PCP: <

a. Shall be documented and records of reviews performed shall be )> >

retained as required by Specification 6.10.2.o. This documentation

, shall contain: <,

1) Sufficient information to support the change together with the /

appropriate analyses or evaluations justifying the change (s); g and j

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 by the PSRC and /

approval of the General Manager, Nuclear Plant Operations. /

d "iM3 crc =cweace-et-IS" frca scurce of resicsctiv+tyv l SUMMER - UNIT 1 6-19 Amencment No. 25. 79 104

Docum ntControlD:sk

- AttachmentII TSP 940002 RC-95-0226 Revision 1 Insert H Page 1 of1 INSERT H 6.12.2 In addition to the requirements of 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mrem /hr* but less than 500 rads /hr**

shall be provided with locked doors to prevent unauthorized entry, and the keys -

shall be maintained under the administrative control of the duty Shift Supervisor and/or health physics supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work area. The maximum allowable stay time for individuals in that area shall be established prior to entry. In lieu of the stay time specification of the RWP, direct or remote continuous surveillance (such as closed circuit TV cameras) shall be made by personn el qualified in radiation protection procedures to provide positive exposure control over the activities within the area.

For individual areas accessible to personnel with radiation levels greater than 1000 mrem /hr* but less than 500 rads /hr** that are located within larger areas (such as PWR containment) where no enclosure can be reasonably constructed around the individual areas, then those areas shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

Measurement made at 30 cm (12 in.) from the radiation source or from any surface penetrated by the radiation.

Measurement made at 1 meter from the radiation source or from any surface penetrated by the radiation.

ADMIN 1STRATTVE CCNTROLS

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6.14 0FFSITE DOSE CALCULATION MANUAL (ODCM) .-

6.14.1 The 00CM shall be approved by the Ccmission prior to implementation.

6.14.2 Char.ges to the 00CM:

a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.2.o.

shall contain: This documentation

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

and

2) 13 02.

A determination that the change will maintain the level of w radioactive effluent control required by 10 CFR 20.19 % 40 CFR ,

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.

c. Shall be submitted to the Comission in the fom of a complete legible copy of the entire 00CM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the 00CM 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.

SDHER - UNIT 1 6-20 Amencment No. 4I,73,204,117

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3/4.11 RAUIOACTIVE EFFLUENTS l 3/4.11.1 LIQUID EFFLUENTS LIQUID HOLDUP TANKS ,

LIMITING CONDITION FOR OPERATION 3.11.1.1 Deleted b Amendment 104.

3.11.1.2 Deleted b Amendment 101 3.11.1.3 Deleted b Amendment 104.

3.11.1.4 The q uantity ofradioactive 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.

a. Condensate Storage Tank

b. Outside Temporary Storage Tank APPLICABILITY: Atalltimes.

ACTION:

a. With the quantity of radioactive material in any of the above listed tanks exceeding the above limit, immediately suspend all additions of radioactive material to the tank and within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the l tank contents to within the limit.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REOUIREMENTS 4.11.1.1 Deleted b Amendment 104.

4.11.1.2 Deleted b Amendment 104.

4.11.1.3 Deleted b Amendment 104.

4.11.1.4 The quantity of radioactive 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.

l SUMMER - UNIT 1 3/4 11-1 Amendment No.104,

RADIOACTIVE EFFLUENTS SETTLING POND LIMITING CONDITION FOR OPERATION 3.11.1.5 The quantity of radioactive material contained in each settling pond shall be limited by the following expression:

264 'g Aj j < 1.0 V Cj excluding tritium and dissolved or entrained noble gases, where, Aj = Pond inventory limit for single radionuclide "j ",in curies.

Cj = 10 CFR 20, Apf"endix radionuclide B, Table 2, column 2, concentration for singlel

, microcuries/ml.

V = design volume ofliquid and slurry in the pond,in gallons.

264 = Conversion unit, microcuries/ curie per milliliter / gallon.

APPLICABILITY: At all times.

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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the pond contents to within the limit,

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 slurry, and batches to be transferred to the settling ponds shall be limited by the expression:

J f b < 1.0 Cj SUMMER - UNIT 1 3/4 11-2 Amendment No.104, l I

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RADIOACTIVE EFFLUENTS SURVEILLANCE REQUIREMENTS (Continued) where I Qj = concentration of radioactive materials in wet, drained slurry (used powdex resin) for radionuclide "j " excluding tritium, dissolved or entrained noble gas and radionuclides with less than 8 day half-life, 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 of Sr-89, Sr-90, batch concentrations shall be based on the most recently available quarterly composite analyses.

Cj = 10 CFR 20, App"endix B, Table 2, column 2, concentration for single l radionuclide ' j ,in microcuries/ milliliter.

SUMMER - UNIT 1 3/4 11-3 Amendment No.104,

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l RADIOACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS 1

EXPLOSIVE GAS MIXTURE '

LIMITING CONDITION FOR OPERATION .

l 3.11.2.1 Deleted by Amendment 104.  !

3.11.2.2 Deleted b Amendment 104.

3.11.2.3 Deleted b Amendment 104.

3.11.2.4 Deleted b Amendment 104.

3.11.2.5 The concentration of oxygen in the waste gas holdup system shall be I limited to less than or equal to 2% by volume whenever the hydrogen concentration exceeds 4% by volume. i l

APPLICABILITY: At all times.

ACTION:

a. With the concentration of oxygen in the waste gas holdup system 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

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 I hour and less than or equal to 2%

by volume within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

c. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.2.1 Deleted by Amendment 104.

4.11.2.2 Deleted b Amendment 104.

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 hydrogen and oxygen monitors required OPERABLE by Tab: e 3.3-13 of Specification 3.3.3.9.

SUMMER - UNIT 1 3/4 11-4 Amendment No.104,

l I

3/4.11 RADIOACTIVE EFFLUENTS BASES 3/4.11.1 LIQUID EFFLUENTS 3/4.11.1.1 Deleted by Amendment 104.

3/4.11.1.2 Deleted by Amendment 104.

3/4.11.1.3 Deleted by Amendment 104.

3/4.11.1.4 LIQUID HOLDUP TANKS Restricting the quantity of radioactive material contained in the saecified tanks le tanks'provides contents,assurance that the resulting in the event would concentrations of an uncontrolled be less than 10release times of thet limits of10 CFR Part 20, Appendix B, Table 2, 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 density of wet, drained resin is approximately the same as water (bulk density of about 58 pounds per cubic foot); and the absorption characteristics for gamma radiation are essentially that of water. Therefore, direct comparison of radionuclide specific activity in wet, drained resin to the appropriate concentration in 10 CFR 20, Appendix B, Table 2, Column 2, ensures that the limit of Specification 3.11.1.5 will not be exceeded.

SUMMER - UNIT 1 B 3/411-1 Amendment No.104,  ;

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RADIOACTIVE EFFLUENTS BASES l.

3/4.11.2 GASEOUS EFFLUENTS 3/4.11.2.1 Deleted b Amendment 104.

3/4.11.2.2 Deleted b 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 maintained below the flammability limits of hydrogen anc. gas oxygen. holdup system is Automatic control features are included in the system to arevent the hydrogen and oxygen concentrations from reaching these flammability limits. These automatic control features include isolation of the source of hydrogen and/or oxygen 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 controlled in  !

conformance with the requirements of General Design Criterion 60 of Appendix A to 10 CFR Part 50.

• 3/4.11.2.6 GA3 STORAGE TANKS i

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".

i SUMMER - UNIT 1 B 3/411-2 Amendment No.104,

ADMINISTRATIVE CONTROLS

d. Critical operation of the unit shall not be resumed until authorized l by the Commission. '

6.8 PROCEDUR$S AND PROGRAMS I 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. <

b. Refueling operations. t

c. Surveillance and test activities of safety-related equipment.

d. Security Plan.

e. Emergency Plan. <

f. Fire Protection Program.

g. PROCESS CONTROL PROGRAM.

a. OFFSITE DOSE CALCULATION MANUAL. i

i. Effluent and environmental monitoring 3rogram using the guidance i in Regulatory Guide 4.15, Revision 1, Fe 3ruary 1979. l 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.

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 th at 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 sam?li ng, liquid radwaste handling, gas radwaste handling and reactor auilding spray system.

The program shall include the following:

1) Preventive maintenance and periodic v ;ualinspection requirements, and

2) Integrated leak test requirements for each system at refueling cycle intervals or less.

I

b. In-Plant Radiation Monitoring l l

1) Training of personnel,

2) Procedures for monitoring, and

3) Provisions for maintenance of sampling and analysis equipment.

t SUMMER - UNIT 1 6-11 Amendment No. 18,49,72,79, l 117, l

o ADMINISTRATIVE CONTROLS

c. Secondarv Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation. This program shallinclude:

1) Identification of a sampling schedule for the critical variables and control points for these variables,

2) Identification of the procedures used to measure the values of '

the critical variables,

3) Identification of process sampling points, including monitoring the dischar in-leakage,ge of the condensate pumps for evidence ofcondenser

4) Procedures for the recording and management of data,

5) Procedures defining corrective actions for all off-control point chemistry conditions,

6) A procedure identifying (a) the authority responsible for the  :

interpretation of the data, and (b) the sequence and timing of administrative events required to initiate corrective action. '

d. Postaccident Sampline A program which'will ensure the capability to obtain and analyze ,

reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under i accident conditions. The program shall include 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  !

A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shallinclude 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;

{

2) Limitations on the concentration of radioactive material released in liquid effluents to unrestricted areas conforming to 10 times the concentration values in 10 CFR Part 20, Appendix B, Table 2, Column 2; SUMMER - UNIT 1 6-12 Amendment No. 35,57, 79,104,117,

ADMINISTRATIVE CONTROLS

o. Radioactive Emuent Controls Program (Continued)

3) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with l the methodology and parameters in the ODCM;

4) Limitations on the annual and quarterly doses or dose commitment l 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) Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and )

parameters in the ODCM at least every 31 days;

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

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 mrem /yr to the total body and less than or equal to a dose rate of 3000 mrem /yr to the skin; anc (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 mremlyr to any organ;

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 bevond the site boundary conforming to Appendix I to 10 CFR Part 50;

10) Limitations on the annual dose or dose commitment to any member

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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, l

ADMINISTRA'n1VE CONTROLS

f. Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides l 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: -

1) Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM;

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 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 for environmental monitoring.

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

ADMINISTRATIVE CONTROLS l 6.9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9.1 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 l l

6.9.1.1 A summary I be submitted followm, report g (1) of plant receipt startup and of an operating power license, (2)escalation amendmenttesting to shall the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant.

6.9.1.2 The startup report shall address each of the tests identified in the Final Safety Analysis Report and shallinclude a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications.

Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report.

6.9.1.3 Startua reports shall be submitted within (1) 90 days following 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 all three events (i.e., initial criticality, completion of startup test program, and resumption or commencement of commercial operation) sup11ementary reports shall be submitted at least every three months until all t iree events have been completed.

ANNUAL REPORT 6.9.1.4 Annual re1 orts covering the activities of the unit as described below for the previous ca endar year shall 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 shallinclude a tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mrem /yr and their associated collective deep dose equivalent (reported in person-rem) according to work andjob l functions,l/ e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and i refueling. The dose assignments to various duty functions may be estimated based 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.

1/ This tabulation supplements the requirements of s20.2206 of 10 CFR Part 20.

SUMMER - UNIT 1 6-13 Amendment No. 79

ADMINISTRATIVE CONTROLS l

This report shall also include the results of specific activity analysis in l which the primary coolant exceeded the limits of specification 3.4.8. The l following information shall be included: (1) Reactor power history starting i 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results I 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 after the radioiodine 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the hmit was exceeded; (4) Graph of the I-131 concentration and one other radioiodine 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 radioiodine limit.

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 shallinclude 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.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

6.9.1.7 Not used.

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6.9.1.8 Annual radioactive effluent release report covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

The report shallinclude a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the 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.

SUMMER - UNIT 1 6-14 Amendment No. 79,104, 117,

O o

ADMINISTRATIVE CONTROLS

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. Record's of training and qualification for current members of the unit i staff. l

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.

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 instcllation and maintenance records.

m. Records of secondary water sampling and water quality.

n. Records of analysis required by the radiological environmental monitoring program.

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 l 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 1

20.1601(a) of10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr* but less than 1000 mrem /hr* shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Health Physics personnel or individuals escorted by Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned duties, provided they otherwise comply with approved radiation protection procedures for entry into high radiation areas.

Any individual or group ofindividuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

Measurement made at 30 cm (12 in.) from the radiation source or from any surface penetrated by the radiation.

SUMMER - UNIT 1 6-18 Amendment No. 35,49,75, 79,104,

ADMINISTRATIVE CONTROLS ,

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levelin the area has been established and personnel have been made knowledgeable of them.

c. A health physics qualified individual (i.e., qualified in radiation i l

protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the RWP.

6.12.2 In addition to the requirements of 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mrem /hr* but less than 500 rads /hr**

shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the duty Shift Supervisor and/or health physics supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work area. The maximum allowable stay time for individuals in that area shall be established prior to entry. In lieu of the stay time specification of the RWP, direct or remote continuous surveillance (such as closed circuit TV cameras) shall be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities within the area.

For individual areas accessible to personnel with radiation levels greater than 1000 mrem /hr* but less than 500 rads /hr** that are located within larger areas (such as PWR containment) where no enclosure can be reasonably constructed around the individual areas, then those areas shall be barricadecf, conspicuously posted, and a fiashing light shall be activated as a warning device.

6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 The PCP shall be approved by the Commission prior to implementation.

6.13.2 Changes to the PCP:

a. Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.2.o. This documentation shall contain:

1) Sufficient information to su? port the change together with the appropriate analyses or eva uationsjustifying the change (s);

and

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 by the PSRC and approval of the General Manager, Nuclear Plant Operations.

• Measurement made at 30 cm (12 in.) from the radiation source or from any surface penetrated by the radiation.

• • Measurement made at 1 meter from the radiation source or from any surface penetrated by the radiation.

SUMMER - UNIT 1 6-19 Amendment No. 35,79, 104,

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 shall contain:

1) Sufficient information to support the change together with appropriate analyses or evaLuationsjustifying the 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.

c. Shall be submitted to the Commission in the form of a complete legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Efnuent 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.

l l

SUMMER - UNIT 1 6-20 Amendment No.16,35, 41,79,104,117

. Docum:nt Centrol D:sk Att chm:ntII

. TSP 940002 Revision 1 RC-95-0226 Page 1 of 6 SAFETY EVALUATION FOR REVISING THE SPECIFICATIONS TOINCORPORATE REVISIONS TO 10 CFR PART 20 VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS Description of Amendment Request South Carolina Electric & Gas Company proposes to modify the Virgil C. Summer l Nuclear Station (VCSNS) Technical Specifications (TS) to reflect changes to 10 CFR 20, including Appendix B, Table 2 concentrations, and provide additional administrative corrections. This Technical Specification 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 settling pond radioactive material quantity,

8. Revise the TS Bases for the liquid holdup tank activity limit, and

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

Items i through 3 are administrative changes to reflect that the new 10 CFR 20 sections ar e relocated requirements from the old 10 CFR 20 sections.

Items 4,5, and 8 are being revised to maintain the existing level of efnuent control by reflecting changes in the dose rate associated with the new 10 CFR 20 Appendix B concentrations.

Items 6 and 7 are being revised to reflect changes to the radioactive material quantity in the settling pond due to 10 CFR 20, Appendix B, Table 2 concentration changes.

Item 9 is being revised to reflect a change in the distance from the source or surface, 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.

Document Control Desk Attachment II TSP 940002 Revision 1 RC-95-0226 Page 2 of 6 Safety Evaluation

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 m 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),

This administrative change is being made to reflect that the requirements in the old 10 CFR 20.203(c)(2) are now located in 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),

This administrative change is being made to reflect that the requirements in the old 19 CFR 20.407 are now located m the new 10 CFR 20.2206(b).

4. Revise the liquid release rate limit, The proposed change to the liquid 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 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 o:d 10 CFR 20.106 (new 10 CFR 20.1302).

These requirements further indicate that the operational flexibility is allowed, compatible with considerations ofhealth 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 II 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 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 2, Column 2 are based on an annual dose of 50 mrem. Since a release co,ncentration corresp,onding to a limiting dose rate of 500 mrem / year has been acceptable as a TS/SLC Limit for liquid effluents, which applies at all times as an assurance that the limits of 10 CFR 50, Ap?endix I are not likely to be exceeded, it should not be necessary to reduce this :imit by a factor of ten.

l

Docum>mt Control Desk AttachmentII )

l TSP 940002 I Revision 1 RC-95-0226 i Page 3 of 6 j 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 percentages of the limits of10 CFR 50, Appendix I. There1 ore, 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 2, Column 2) should not have a negative impact on the ability to continue to operate within the limits of10 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 2, 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 lic uid effluent release situations when monitor background, monitor sensitivity, anc. 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 2, Column 2, to apply at all times. The multiplier of ten is pro 30 sed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix B, Table II, 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 2, Column 2, are based.

Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of10 CFR 50, Appendix I and 40 CFR 190.

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 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 hmits 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 ofhealth 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 II 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 I.

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Document Control Desk AttachmentII TSP 940002 Revision 1 RC-95-0226 i Page 4 of 6 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 2, Column 1, are based on an annual dose of 50 mrem for isotopes for which inhalation or ingestion is limiting or 100 mrem for isotopes for which submersion (noble gases) is limiting. Since release concentrations corresponding to limiting dose rates less than or equal to 500 mrem / year to the whole body,3000 mrem / year to the skin from noble gases, and 1500 mrem / year to any organ from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than eight days at the site boundary has been acceptable ns a TS/SLC Limit for gaseous effluents to assure that the limits of10 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 inhalation / ingestion (50 mrem / year) or the dose rate associated with the EC value for isotopes based on submersion (100 mrem / year).

Having suflicient 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 2, Column 1, relate to a dose of 50 or 100 mrem in a year. Waen applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100 mrem / year. These low values are impractical upon which to base effluent monitor setpoint calculations for many gaseous effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account.

Therefore, to accommodate operational flexibility needed for effluent releases, 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 mrem / year to the whole body and 3000 mrem / year to the skin; and for Iodine-131 for Iodine-133, for tritium, and for all radionuclides in particulate form with half fives greater than eight days, an instantaneous dose rate limit of1500 mrem / year to any organ.

Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of10 CFR 50, Appendix I and 40 CFR 190.

Operational history at V. C. Summer has demonstrated that the use of the dose rate values listed above (i.e.,500 mrem / year,3000 mrem / year,1500 mrem / year) as TS/SLC limits has resulted in calculated maximum individual doses to members of the public that are small percentages of the limits of10 CFR 50, Appendix I and 40 CFR 190.

6. Revise the settling pond radioactive materialquantity, The proposed revision to the radioactive material quantity in the settling pond will not change the ty3es of effluents that will be released, nor cause an increase in individual or cumulative occupational radiation exposures. This is only a change to the quantity of radioactive material in the settling pond due to 10 CFR 1 20, Appendix B, Table 2 concentration changes and will conservatively lower net i limits. There are no equipment or operational procedure changes required due to i the proposed revision. l

Document Control Desk Attachment II TSP 940002 Revision 1 RC-95-0226 Page 5 of 6 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 CFR 20.

Currently, the s,ettling pond limit is based on that quantity which would not exceed the maximum permissible concentration limits of10 CFR 20, A?pendix B, Table II, Column 2, at the nearest potable water supply if an uncontrolled release of settling pond inventory should occur. The new setthng pond limit is based on that quantity which would not exceed the effiuent concentration limits (ECLs) of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply if an uncontrolled release of settling pond inventory should occur. This change adds conservatism to the quantity ofradioactive materialin the settling pond, lowering netlimits.

7. Revise the TS Bases for the settling pond radioactive material quantity, The proposed revision to the radioactive material quantity in the settling pond will not change the ty 3es of effluents that will be released, nor cause an increase in individual or cumulative occupational radiation exposures. This is only a change to the quantity of radioactive material in the settling pond due to 10 CFR 20, Appendix B, Table 2 concentration changes and will conservatively lower net limits. There are no equipment or operational procedure changes required due to the proposed revision.

The proposed change to the quantity of radioactive material in the settlinpond revises the reference to the acceptance criteria contained in the new 10 CIP 20.

Currently, the settling pond limit is based on that quantity which would not exceed the maximum permissible concentration limits of10 CFR 20, A? pendix B, Table II, Column 2, at the nearest potable water supply if an uncontrolled release of settling pond inventory should occur. The new setthng pond limit is based on that quantity which would not exceed the ECLs of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water su? ply if an uncontrolled release of settling pond inventory should occur. This change adds conservatism to the quantity of radioactive material in the settling pond, lowering net limits.

8. Revise the TS Bases for the liquid holdup tank activity limit,

, 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.

l Currently, the Liquid Holdup Tank curie limit is based on that quantity which would not exceed the maximum permissible concentration limits of10 CFR 20, Appendix B, Table II, Column 2, at the nearest potable water supply if the tank and components should fail, or will be limited to 10 curies. As discussed 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 efiluent concentration limits (ECLs) ofl0 CFR 20, Appendix B, Table 2, 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.

7.

Docum:mt Control Desk Attachment II TSP 940002 Revision 1 RC-95-0226 Page 6 of 6

9. 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 rf radiation is equal to or less than 1000 ,

mrem / hour is being made as a remalt 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.

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. TSP 940002 Revision 1 RC-95-0226 Page 1 of 4 l

NO SIGNIFICANT HAZARDS EVALUATION FOR REVISING THE SPECIFICATION TOINCORPORATE REVISIONS TO 10 CFR PART 20 VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS Description of Amendment Request and No Significant 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, including Appendix B, Table 2 concentrations, and provide additional administrative corrections. This Technical Specification 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. R.evise the TS Bases for the settling pond radioactive material quantity,

8. Revise the TS Bases for the liquid holdup tank activity limit, and

9. 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 requis ements from the old 10 CFR 20 sections.

Items 4,5, and 8 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.

Items 6 and 7 are being revised to reflect changes to the radioactive material quantity in the settling pond due to 10 CFR 20, Appendix B, Table 2 concentration changes.

Item 9 is being revised to reflect a chang in the distance from the source or surface, 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.

> 1 Document Control Desk '

AttachmentIII ,

TSP 940002 Revision 1 RC-95-0226 Page 2 0f 4 t

Basis for No Significant Hazards Consideration Determination  ;

10 CFR 50.91 requires that the following analysis be provided concerning whether the proposed amendment request involves a significant hazards consideration as ,

defined 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 ,robability or conseauences of an accident previously evaluated does not

}nvo ve a significant increase.

The proposed TS changes showing the relocation of the old 10 CFR 20.106 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 requirements to the new 10 CFR 20.2206(b) will not involve a si piificant increase ,

in the probability or consequences of an accident previously evaluated because there will be no change in the types and amounts ofeffluents that will be released, nor will there be an increase in individual or cumulative occupational radiation exposures.

The proposed revision to the liquid and gaseous release rate limits 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 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 quantity in the settling pond and its ascociated TS Bases will not involve a significant increase in the

?robability or consequences of an accident previously evaluated because there will 3e no change in the types of effluents that will be released, nor will there be an increase in individual or cumulative occupational radiation exposures. This is i only a change to the quantity ofradioactive material in the settling pond and will conservatively lower netlimits.

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 accident previously evaluated because there will be no change in the types and amounts of l efiluents that will be released, nor will there be an increase in individual or i

cumulative occupational radiation exposures. The curie limit is not affected, therefore, the change does not represent a decrease in the level ofcontrol  :

l previously evaluated.

ff The proposed revision to the distance at which dose rates are measured from the I radiation source or surface will not involve a significant increase in the probability or consequences of an accident previously evaluated because there will t

>e 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.

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Document Control Desk AttachmentIII TSP 940002 Revision 1 RC-95-0226 Page 3 of 4

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

The proposed TS changes showing the relocation of the old 10 CFR 20.106 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 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 previously evaluated because the revisions are administrative and will not change the types and amounts of effluents that willbe released.

The proposed revision to the liquid and gaseous release rate limits 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 ofeffluents that will be released.

The proposed revision to the quantity of radioactive material in the settling pond and its associated TS Bases will not create the possibility of a new or different kind of accident from any previously evaluated because the revision will not change the types of effluents that will be released. This is only a change to the quantity of radioactive material in the settling pond and will conservatively lower not limits.

The proposed revision to the TS bases for the liquid holdup tank activity limit will not create the possibility of a new or different kmd 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.

3. A sienificant reduction in a marcin of safety is not involved.

The proposed revisions due to the location of requirements will not reduce a 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 proposed revision to liquid and gaseous release rate limits will not reduce a margin of safety because it is admimstrative in nature. These revisions preserve the existing level of ef1luent control. No changes to the more restrictive 10 CFR 50 Ap?endix I dose limits are made. There are no equipment or operational prococ ure changes, therefore, no accidents of any kind will be created by this change.

The proposed revision to the quantity of radioactive material in the settling pond and its associated TS Bases will not reduce a margin of safety because it is conservative in nature and preserves the existing level of effluent control. There are no equipment or operational procedure changes required, therefore, no accidents of any kind will be created by this change.

- .i Document Control Desk AttachmentIII TSP 940002 Revision 1 RC-95-0226 Page 4 of 4 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 equ,ipment or procedural changes are ,

postulated. There is no impact on any margm of safety.

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 therefore minimize exposure.

Accordingly, this proposed change does not involve a significant hazard.

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