ML20118A684

Application for Amends to Licenses NPF-68 & NPF-81,changing TS to Facilitate Implementation of New 10CFR20 Requirements, Per GL 89-01 to Reflect Relocation of Procedural Details in RETS to ODCM & Process Control Program

ML20118A684
Person / Time
Site:	Vogtle
Issue date:	09/17/1992
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20118A685	List: ML20118A684 ML20118A686
References
ELV-3972, GL-89-01, GL-89-1, NUDOCS 9209240437
Download: ML20118A684 (18)

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,y Georgiti Power

y. p "*' /h "fl ( ,t s 7 September 17, 1992 ELV-03972 Docket Nos. 50-424 50-425 U. S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECIINICAL SPECIFICATIONS IMELijh1ENTAILOE OF T1!! MEW 10 CFR 20 REOUIREh1ENTS In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company hereby proposes to amend the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications, Appendix A to Operating Licenses NPF-68 and NPF 81.

As part of Georg. . wer Company's strategy to facilitate implementation of the new 10 CFR 20 requirements at VEGP, a response to Nuclear Regulr.toa/ Commission (NRC)

Generic Letter 89-01 was submitted on hiarch 4,1992. Generic Letter 89-01 allows the procedural details contained in the Radblogical Efiluent Techrical Specifications (RETS) to l be relocated to the Offsite Dose Calculation hianual (ODCL .) and the Process Control l Program (PCP) with appropriate programmatic controls hing incorporated into the Administrative Controls Section of the Technical Specifications. Accordingly, the programmatic controls will be used to revise the RETS requirements located in the ODChi and PCP to reflect the new 10 CFR 20 requirements. Ilowever, the RETS requirements that will be relocated to the ODChi and PCP in accordance with Generic Letter 89-01 do not represent all of the Technical Specification requirements that are impacted by the new 10 CFR 20 requirements.

The proposed changes and bases for the changes are described in enclosure 1 to this letter.

enclosure 2 provides an evaluation pursuant to 10 CFR 50.92 thowing that the proposed channs do not involve significant hazards considerations. A copy of the proposed changes is prov'Jed in enclosure 3 which represent the remaining scope of Technical Specihcation requirements that are impacted by the new 10 CFR 20 requircments. Several of the proposed 1

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L'. S. Nuclear Regulatory Commission ELV.03972 Page 2 Technical SpeciGcation changed pages submitted by Georgia Power Company letter dated Afarch 4,1992, in response to Generic Letter 89-01 are also affected by the revisions to i0 CFR 20. Thc.cfore, for completcness, the affected pr aposed Technical Specification changed pages provided in enclosure 3 also incorporate the Genetic Letter 89 01 changes.

In addition, sll of the proposed Technical Specification changes associated with the new 10 CFR 20 requirements have been " clouded" to distinguish them from the Generic Letter 89-01 changes. Accordingly, it is requested that a single license amendment be issued which combines the effect of this suMittal with .h: hiarch 4,1992, submittal.

Georgia Power Company requests that these proposed Technical Specification changes be approved by the NRC no later than December 1,1992, to facilitste implementatlon of the new 10 CFR 20 requirements at VEGP as early as January 1,1993. Based on the original publisned date of January 1,1993, Georgia Power Company has committed significant funding and manpower resources to meeting that'date. Postponing implementation could have budgetary impacts and impose conflicts with manpower resource allocation. In the event unforeseen circumstances delay implementation of the new 10 CFR 20 requirements past the January 1,199'$, date, it is requested that the conditions of the license amendment be made effective upon implementation of the new 10 CFR 20 requirements b) Cicorgia Power '

Company but no later than January 1,1994.

In accordance with 10 CFR 50.91, the designated state oflicial will be sent a copy of this letter and all enclosures.

hir. C. K. hicCoy states that he is a vice president of Georgia Power Company and is -

authorized to execute this oath on behalf of Georgia Power Cornpany and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

I GEORGIA POWER COMPANY

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By:

C. K. hicCoy V

Sworn to and subscribed before me this /7 ' day of f1=#nes.:R., 1992.

u h g/k k fbb CH Notary Public g/ca,3;33!nge,3gia e

U. S. Nuclear Regulatory Commission ELV-03972 Page 3 i

CKMfrMM Enclosures.

1. Basis for Proposed Ch nge

2. 10 CFR 50.92 Evaluation l 3. Proposed Technical Specification Changes l c(w): Qtorgi.a PoweIfump10y Mr. W. B. Shipman

Mr. M. Sheibani i

NORMS l

U. S. NucleaLRegulate:y Commission

, Mr. S. D. Ebneter, Regionai Administrator -

Mr. D. S. liood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle .

I i- State of Georgia Mr. J. D. Tanner, Commissioner, Department of Natural Resources l

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- t ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNIC AL SPECIFICATIONS IMPLEMENTATION Of THE NfdV 10 CFR 20 REOUIRiih1ENTS tlASISJLE.EROPOSED CIIANGE F

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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING .'LANT REQUEST TO REVISE TECilNICAL SPECIFICATIONS IMPLilMfiNTATION_OF Tile NEiV 10 CFR 2MEOUIREhiENTS BAS.lLERlLERDEOSED Cl{ANGli Plopased.Changd This proposed change revises the definitions of hiEh!BER(S) OF Tile PUBLIC (Technical ,

Specification 1.18) and UNRESTRICTED AREA (Technical Specification 1.39).

Ilatis The dermitions of h1EhiBER(S) OF THE PUBLIC and UNRESTRICTED AREA are being changed to be consistent with their respective defmitions contained 'r, the new 10 CFR 20.1003. These changes are simply administrative in naturs 'o facilitate implementation of the new 10 CFR 20 requirements at Vogtle Electiic Generating Plant (VEGP). The requirements of the VEGP Technical Specifications will :.ot be reduced by this change.

Pleposed Changd T is proposed change revices proposed footnote c to Technical Specification Table 3.3-3 w h was submitted by Georgia Power Company letter dated hiarch -4,1992, in response to Generic Letter 89-01.

BMis Footnote c to table 3.3-3 contains a referente to Specification 3.11.2.1, Georgia Power Company's response to Generic Letter 89-01 included a proposed change to the T echnical Specifications to change that reference to Specification 6.7.4.f. Upon further review of this proposed change to support implementation of the new 10 CFR 20 requirements at VEGP, it was determined that the footnote reference should have been more specific by referencing Specification 6.7.4.f.7, Specification 6.7.4.f, as proposed in the hiarch 4. t092, submittal, includes references to severallimits such as liquid and gaseous release rates, liquid and '

gaseous cumulative doses, and 40 CFR 190. However, footnote c deals with gaseous release rate limits only, which specifically relates to the reg'uiremesi ts found in proposed Specification .

6.7 4.f.7. Therefore, the footnote c reference to Specification 3.11.2J. :, oeing changed to proposed Specification 6.7.4.f.7 instead of 6.7.4.f.

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ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT 4 REQUEST TO REVISE TECl{NICAL S1 ECIFICATIONS l lhiPLEhiENTATION OF Tl!E NEW 10 CFR 203E.QUIREhiENTS i

i [MSJS FOR PilQERSED CIIANGE

! ELORDKd_ Change 3 This proposed change revises Technical Specification Bases 3/4.ll.l A to reference the acceptance criteria contained in the new 10 CFR 20, which is used to determine the activity l

4 Hmit for the radioactive efiluent liquid holdup tanks. '

1 Huis The discussion in Bases 3/4.11.1.4 is medi6ed to state that in the event of an uncontrolled release of the outside temporary holdup tanks, the resulting concentration would be less than

! the efIluent concentration limits (ECL) of the new 10 CFR 20.1302(b)(2)(i) in lieu of the

, limits speci0ed in the old 10 CFR 20, Appendix B, Table II, Column 2, which are based on I maximum permbsible concentration (h1PC) values.

An evaluation was performed to determine the activity that could be released from a tank

rupture based on ECL values as compared to the current Tecnnical Specification (3.11.1.4) j limit of 10 curies, which is based on hiPC values contained in the old 10 CFR 20. The

evaluation provided a larger allowable tank activity based on the ECL values. Since a higher activity limit can be determined based on the ECL values, it is conservative to retain the current activity limit of 10 curies. hiaintaining the activity limit at 10 curies is also consistent with the guidance contained in NUREG-0133, which states that the curic limit for a "

temporary tank shc ald be limited to less than or equal to 10 curies, excluding tritium and dissolv d or entrained gases, which is consistent with Technical Specification 3.11.1.4.

i Proposed Changt4 This proposed change revises proposed Technical Specification 6.7.4.f.2 submitted by Georgia Power Company letter dated hiarch 4,1992, in response to Generic Letter 89-01, in

- order to accommodate needed opers.tiona! nexibility to facilitate implementation of the new

10 CFR 20 requirements.

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l Proposed Technical Specification 6.7.4 f 2 submitted by Georgia Power Company letter dated h1 arch 4,1992, states that liquid efiluent releases to unrt.stricted' areas must conform to the old 10 CFR 20, Appendix B, Table II, Column 2. In accordance with the old 10 CFR 20, i El-2 '

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e ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECIINICAL SPECIFICATIONS IMPLEhihtffAllON_QEllliiEEW 10 CFR 20 REOUlitFMENIS BASIS FOR PROPOSED GIANGE -

the annual dose to a member of the public upon which sese concentrations are based is 500 mrem. Although the old 10 CFR 20.106 allows emuent concentrations to be averaged over a year, the Technical Specifications require that liquid emuent releases be limited to these concentrations at all times (i.e., for instantaneous releases). More restrictive limits w:re incorporated irto the Technical Specifications by the NRC to assure that the dose limits of 10 CFR 50, Appendix I or the dose limits of 40 CFR 190 are not exceeded.

The basic requirements for Techmcal Specifications on emuents 'com nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with emuent

Technical Specifications will keep nyerage annual releases of radiorctive material in emuents l at small percentages of the limits specified in the old 10 CFR M106. These requirements

further indicate that operational flexibility is allowed, compatible with considerations of 3

health and safety, which may temporarily result in releases higher than such small l percentages, but still within the limits specified in the old 10 CFR 20.106 which referencer Appendix B, Table 11 concentrations. 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 3 when using operational flexibility, best efrorts shall be exerted to keep levels of rascactive i

materials in emuents as low as is reasonably achievable as set forth in 10 CTR 50,

Appendix 1.

i In accordance with the introduction to Appendix B of the new 10 CFR 20, the liquid emuent ,

l concentration limits stated in Appendix B, Table 2, Column 2, are based on a dose of ,

! 50 mrem in a year. Therefore, the previous NRC position that emuent releases must be

! limited by Technica! Specifications to the concentrations stated in the old 10 CFR 20, Apperdix B, Table II, Column 2, at all times, does not appear to be warranted for the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 2, because the

iequirements of 10 CFR 50.36a are presented in terms of the old 10 CFR 20,106,_which relates to an annual dose of 500 mrem, not 50 mrem. Since a release concentration which corresponds to a limiting value of 500 mrem in a year (as a dose rate of 500 mrem / year) has I

been acceptable as a Technical Specification limit for liquid emuents and which app!ies at all times as an assurance that the limit:: of 10 CFR 50, Appendix I are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of ten.

i- In Subpart D,Section VI, of the Supplementan Information which accompanied the new l 10 CFR 20, it is stated that for power reactor l~ensees, compliance with the limits of El-3

ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECIINICAL SPECIFICATIONS lh1PLEMFN_TATION OF Tile NMV 10 CFR 20 REOUIREMENTS 1 DASIS FOR PROPOSED CilANGE 1

10 CFR 50, Appendix I and with the limits of 40 CFR 190 will demonstrate compliance with the limits of the new 10 CFR 20.1301, in which dose limits for members of the public are

specified. The limits in 10 CFR 50, Appendix I and 40 CFR 190 are specified as annual dose j limits, therefore. dose determinations to show compliance with these requirements are in j- terms of cumulative doses (doses in a quarter or year for Appendix I and dmes in a year for ,

40 CFR 190). If a dose limit of 50 mrem in a year were included in a Technical Specification as a limit which applies at all times (i.e., a dose rate of 50 mrem / year), operational flexibility would not be available because the dose rate limit would already be very close to the dose limits specified in 10 CFR 50, Appendix I and 40 CFR 190.

i Operational history al VEGP has demonstrated that the use of the concentration values j associated with the old 10 CFR 20.106 as Technical Specification limits which apply at all i times ha:; resulted in calculated doses to a member of the public that are small percentages of T

the limits of 10 CFR 50, Appendix 1. Therefore, the use of concentration values which correspond to annual doses 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 of 10 CFR 50, Appendix I and 40 CFR 190.

i llaving the operational flexibility discussed above is especially important in establishing a j basis for efiluent monitor setpoint calculations. As discussed above, the concentrations j stated in the new 10 CFR 20, Appendix B, Table 2, Colu:un 2, relate to a dose of 50 mrem in a year. When applied on an instantaneous basis, this correspondt to a dose rate of

. 50 mrem / year. Such a low value is impractical for use as a basis for efiluent moniter setpoint 4

calculations for many liquid effluent release situations when monitor background, monitor 4-sensitivity, and monitor performance must be taken it.to account.

Therefore, to accommodate operational flexibility needed for efiluent releases, r oposed ,

Technical Specification 6.7.4.f.2 submitted by Georgia Power Company letter cated .

March 4,1992, is being revised by restating the limit as 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 j ten is proposed 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 10 higher than the annual dose of 50 naem, 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 of 10 CFR 50, Appendix I and 40 CFR 190.

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ENCLOSURE 1 (CONTINUED)

GTLE ELECTRIC GENERATING PLANT REQUno T TO REVISE TECilNICAL SPECIFICATIONS lhiPLEhiENTATION OF Tile NEW 10 CEIL 2LBEOUIREhiliNIS IIASIS FOR PIM)fQSED CilANGE Pmposed Changd This proposed change revises propo,ed Technical Specifications 6.7.4.f.3 and 6.13.2.a.2 submitted by Georgia Power Company letter dated h{ arch 4,1992, in response to Generic Letter 89 01, to 6 orporate the new 10 CFR 20 reference regarding dose limits for individual members c the public.

lhsis Proposed Technical Specifications 6.7.4.f.3 and 6.13.2 a.2 submitted by Georgia Power '

Company letter dated hiarch 4,1992, contained the Generic Letter 89-01 reference to the old 10 CFR 20.106 regarding radioactivity in emuents to unrestricted areas. This reference is being revised to incorporate the new 10 CFR 20 reference to paragraph 10 CFR 20.1302 which supersedes the old 10 CFR 20 reference to paragraph 10 CFR 20.106. This change is .

simply administrative in nature in order to facilitate implementation of the new 10 CFR 20 requirements at VEGP.

Erspmed Changd This proposed change revises proposed Technical Specification 6.7.4.f.7 submitted by Georgia Power Company letter dated h1 arch 4,1992, in response to Generic Letter 89-01, in order to accommodate needed operational flexibility to facilitate implementation of the new 10 CFR 20 requirements.

BMin Proposed Technical Specification 6.7.4.f.7 submitted by Georgia Power Company letter dated hiarch 4,1992, states that gaseous emuent releases to areas beyond the site boundary must conform to the doses associated with the old 10 CFR 20, Appendix B, Table II,

- Colunu L In accordance with the old 10 CFR 20, the annual dose to a member of the public upon which these concentrations are based is 500 mrem. Al% ugh the old 10 CFR 20.106

% allows emuent concentrations to be averaged over a year, the rechnical Specifications .

- require that gaseous emuent releases be limited to a dose rate of 500 mrem / year (total body) which corresponds to these concentrations at all times (i e., for instantaneous releases).

hiore restrictive limits were incorporated into the Tv;hnical i jecifications by the NRC to assure that the dose limits of 10 CFR 50, Appendix I or the dose limits of 40 CFR 190 are not exceeded.

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ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECilNICAL SPECIFICATIONS IM11]iMENTATION Of_ Tile NEW 10 CFR 20 REOUIREMFEIS BASIS FOR PROPOSED CllANGE The basic requircraents for Technical Specifications on emuents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with emuent Technical Specifications will keep average annual releases of radioactive materialin emuents at small percentages of the limits specified in the old 10 CFR 20.106. These requirements further indicate that operational flexibility is allowed, compatible with considerations of '

health and safety, which may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10 CFR 20.106 which references Appendix B, Table 11 concentraticas. 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 .evels of radioactive 8

materials in emuents as low as is reasonably achievable as set forth in 10 CFR 50, Appendix 1.

In accordance with the Introduction to Appendix B of the new 10 CFR 20, the gaseous emuent concentration limits stated in Appendix B, Table 2, Column 1, are based on a dose of 50 mrem in a year. Therefore, the previous NRC position that emuent releases must be limited by Technical Specifications to the concentrations stated in the old 10 CFR 70, Appendix B, Table 11, Column 1, at all times, does not appear to be warranted for the concentrations stated in the new 10 CFR 20, Appendix B, Table 2, Column 1, because the requirements of 10 CFR 50.36a are presented in terms of the old 10 CFR 20.106, which relates to an annual dose of 500 mrem, not 50 mrem. Since a release concentration, which corresponds to a limiting value of 500 mrem in a year (as a dose rate of 500 mrem / year) has been acceptable as a Technical Specification limit for gaseous emuents, which applies at all times as an r. surance that the limits of 10 CFR 50, Appendix I are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of ten.

In Subpart D,Section VI, of the Supplementary Information which accompanied the new 10 CFR 20, it is stated that for power reactor licensees, compliance with the limits of 10 CFR 50, Appendix I and with the limits of 40 CFR 190 will demonstrate compliance with '

the limits of the new 10 CFR 20.1301, in which dose lindts for members of the public are specifiedJ The limits in 10 CFR 50, Appendix I and 40 CFR 190 are specified as annual dose limits; therefore, dose determinations to show compliance with these requirements are in terms of cumulative Joses (doses in a quarter or year Gr Appendix 1 and doses in a year for 40 CFR 190). If a dose limit of 50 mrem in a year were included in a Technical Specification; as a limit which applies at all times (i.e., a dose rate of 50 mrem / year), operational flexibility would not be available because the dose rate limit would already be very close to the dose limits specified in 10 CFR 50, Appendix I and 40 CFR 190.

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4 j ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT

REQUEST TO REVISE TECilNICAL SPECIFICATIONS LMPl.EMFMTATION OILTilE NEW 10 CFR 20 REOUIREMENTS

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MS_lS FOR PROPOSED CilANGF;  ;

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l Operational history at VEGP has demonstrated that the use of the concentration values i associated with the old 10 CFR 20.106 as Technical Specification limits which apply at all l times has resulted in calculated doses to a member of the public that are small percentages of

, the limits of 10 CFR 50, Appendix 1. Therefore, the use of concentration values which ,

1 correspond to annual doses of 500 mrem (ten time:, the concentration values stated in the l l new 10 CFR 20, Appendix B, Table 2, Column 1) should not have a negative impact on the ability to continue to cperate within the limits of 10 CFR 50, Appendix 1 and 40 CFR 190.

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llaving the operational flexibility discussed above is especially imponant in establishing a basis for emuent monitor setpunt calculations. As discussed above, the concentrations

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stated in the new 10 CFR 20, Appendix B, Table 2, Column 1, relate to a dose of 50 mrem in

a year. When applied on an instantaneous basis, this corresponds to a dose rate of j 50 mrem / year. Such a low value is impractical for use as a basis for emuent monitor setpoint calculations for many gaseous emuent release situations when monitor background, monitor '

sensitivity, and monitc.r performance must be taken into account.

Therefore, to accommodate operational flexibility needed for emuent releases, proposed

Technical Specification 6.7.4.f.7 submitted by Georgia Power Company letter dated j March 4,1992, is being revised by restating the limit as ten times the concentrations stated in the new 10 CFR 20, Appendix D, Table 2, Column 1, to apply at all times. The multiplier of i ten is proposed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix B, Table II, Column 1, are based, is a factor of en t higher than the

, annual dose of 50 mrem, upon which the concentrations in the new 10 CFR 20, Appendix B,  ;

i Table 2, Column 1, are based. - Compliance with the limits of the new 10 CFR 20.1301 will f

be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190; Eroposed Changs_2

This proposed change revises Technical Specification 6.8.1.2 by updating footnote

• to incorporate the new 10 CFR 20 reference regarding repons ofindividual monitoring.

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Footnote

• to Technical Specification 58.1.2 currently contains the old 10 CFR 20 reference to paragraph 20.407 regarding personnel monitoring reports. This reference is being revised to incorporate the new 10 CFR 20 reference to paragraph 20.2206 which supersedes the old -

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ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECllNICAL SPECIFICATIONS lhiE1EhiEBIAIlON OF TilfdEW 10 CFR 20 RE. OUIREMENTS DASJ1 EOR PROPOSED CilANGE 10 CFR 20 reference to paragraph 20.407. This change does not reduce the reporting requirements contained in Technical Specification 6.8.1.2. This change is simply _

administrative in nature to facilitate implementation of the new 10 CFR 20 requirements at VEGP.

ELOPred Chtnst.1 This proposed change revises Technical Specification 6.11.1 by incorporating the new 10 CFR 20 references related to the control of access to high radiation arcas BMis Technical Specification 6.11.1 currently contains the old 10 CFR 20 references to paragraphs 20.203(c)(5) and 20.203(c) regarding caution signs, labels, signals, and controls. These references are being revised to incorporate the new 10 CFR 20 references to paragraphs 20.1601(c) and 20.1601, resocctively, which supersede the old 10 CFR 20 references. This change will not decrease the efTectiveness of the radiation protection programs at VEGP to provide control of exposure from external sources in restricted areas. This change is simply administrative in nature in order to facilitate implementation of the new.10 CFR 20 requirements at VEGP.

Piepmr.LChusc 2 c This proposed change revises Technical Specifications 6.11.1 and 6.11.2 to incorporate the new 10 CFR 20 requirements regardiag the distance used to make measurements of a source ofradioactivity to determine the dose an individual might receive in I hour, lhill Technical Specifications 6.11,1 currently contains a requirement that measurements be mAde at 45 cm (18 in.) from a source of radiation to determine if radiation intensity is greater than-100 mrem /hr but less than 1000 mrem /hr. Similarly, Technical Specification 6.11.2 contains.

a requirement that measurements be made at 45 cm (18 in.) from a radiation source to determine if the radiation level is greater than 1000 mrem /hr. This distance is being changed El-8 a

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ENCLOSURE I (CONTINUED)

VOGTL E ELECTRIC GENERATING PLANT REQUEST TO PIVISE TECilNICAL SPECIFICATIONS Ih1PLEhiENTATION OF TliE NEW 10 CFR 20 REOUIREhiENTS 1 IlASIS FOR PROPOMID_CilANGE to a value of 30 cm (12 in.), consistent with the requirements of the new i 10 CFR 20.1601(a)(1). This represents a conservative change since 30 cm (12 in.)is a .I sheer distance that will result in higher dose measurements.

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- ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TEC11NICAL SPECIFICATIONS lhiPJ2 MENTATION OF Tile NEW 10 CFR 20 REOUl.REMENTS 10 CFR 50.92 EVALUATION h

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! ENCLOSURE 2

VOGTLE ELECTRIC GENERATING PLANT f REQUEST TO REVISE TECifNICAL SPECIFICATIONS  ;

IMPIELiENTATION OF ' life NEW 10 CFR 20 REOUIREMENLS i

1(LER 50.92 EVALUAll.QE Pursuant to 10 CFR 50.92, Georgia Pewer Company has evaluated the proposed revisions to the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications and  :

has determined that operation of the facility in accordance with the proposed amendment would not involve any significant hazards considerations.

Ibs);gr.md By [[letter::ELV-02347, Application for Amends to Licenses NPF-68 & NPF-81,changing TS in Response to Generic Ltr 89-10 to Relocate Procedural Details of Radiological Effluent TS to ODCM & Process Control Program.Draft ODCM & Process Control Program Encl|letter dated March 4,1992]], Georgia Power Company submitted proposed changes to the Technical Specifications in response to Generic Letter 8M1 which allows the procedural details contained in the Radiological Efiluent Technical Si ,ecifications (RETS) to be relocated _to the, offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP) with appropriate programmatic controls being incorporated into the Administrative -1 Controls Section of the Technical Specifications. Following approval by the Nuclear Regulatory Commission, the programmatic controls will be used to revise the procedural details of the RETS, which will be incorporated into the ODCM and PCP to reflect the new 10 CFR 20 requirements. Ilowever, the scope of Generic Letter 89-01 does not encompass all of the Technical Specification requirements that are impacted by the new 10 CFR 20.

Additional Technical Specification changes have been identified, as discussed in enclosure 1, which are needed in conjunction with the Generic Letter 89-01 response to facilitate Georgia Power Company's goal cfimplementing the new 10 CFR 20 requirements at VEGP.

Analysis The proposed changes to the Technical Specifications are required in order to impic. ant the new 10 CFR 20 requirements at VEGP.- The proposed Technical Specification changes involve (1) revisions to the Bases and Administrative Controls Section to appropriately incorporate the new 10 CFR 20 references, (2) revisions to the Administrative Controls Section changes submitted by Georgia Power Company [[letter::ELV-02347, Application for Amends to Licenses NPF-68 & NPF-81,changing TS in Response to Generic Ltr 89-10 to Relocate Procedural Details of Radiological Effluent TS to ODCM & Process Control Program.Draft ODCM & Process Control Program Encl|letter dated March 4,1992]], in response to Generic Letter 89-01 to provide operational flexibility needed for liquid and gaseous releases, and (3) revisions to the Administrative Controls St.ction regarding the distance used to make measurements of radioactivity to determine if the major portion of a body can receive an excessise exposure. The details concerning each of these proposed changes are provided in enclosure 1.L The level of radiological' control wi!! not be reduced by -

these proposed changes since compliance with applicable regulatory requirements governing -

radioactive efiluents and radiological environmental monitoring, inc:uding 10 CFR 50.36a, .

10 CFR 50, Appendix I and 40 CFR 190, will continue to be maintained.

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ENCLOSURE 2 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TEC11NICAL SPECIFICATIONS IMPLEMENTATION OF TIIE NEW 10 CFR 20 REOUIREMENTS 10 CFR 50.92 EVALUATION Conclusion Based on the above considerations, Georgia Power Company has concluded the following concerning 10 CFR 50.92.

Ey.aluation of Proposed Changes 1. 2. 3. 5. 7. and 8 -

1. The proposed changes to the Technical Specifications do not involve'a significant increase in the probability or consequences of an accident previously evaluated because they are a sinistrative in nature since they correct specific definitions and old references to 10 CFR 20 in order to facilitate implementation of the new 10 CFR 20 requirements.

The proposed changes do not alter the conditions or assumptions in any of the (Final Safety Analysis Report) FSAR accident a:.alyses. Since the FSAR accident analyses remain bounding, the radiological consequences previously evaluated are not adversely affected by the proposed changes.

2. The proposed changes do not create the possibility of a new or different Lind of accident from any accident previously evaluated because they are administrative in nature and do not involve any change to the configuration or method of operation of any plant equipment. Accordingly, no new failure inodes have been defined for any plant system or compor.cnt important to safety nor has any new limiting single failure been identified as a result of the proposed changes. Also, there will be no change in types or iacrease in the amount of emuents released offsite.

3. The proposed changes do not involve a significant reduction in a margin of safety because they are administrative in nature and do not reduce the effectiveness of the radiation protection programs at VEGP. Also, the proposed changes do not involve any.

actual change in the methodology used in the control of solid radioactive wastes or radiological environmental monitoring. The methodology that will be used in the control of radioactive emuents will result in the same emuent release rate as the current methodology now being used.

Evaluation of Proposed Chitnges 4 and 6

1. The proposed changes to the Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated because the operational flexibility needed for emuent releases is needed to facilitate E2 2

ENCLOSURE 2 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATIOJJ GF THE NEW 10 CFR 20 REOUIR_IIMENTS 10 CFR 50 92 EVALUATION 3 imp;umentation of the new 10 CFR 20 remiremeats. Complhnce with applicable regulatoiy requirements willcontinue tr oe naiatained. TN yroposed changes do not alter the conditions or assumptions in a: y cthe FSAR accident analyses. Since the F'a.R accident analyses remai'i bounoW. che radiological consequences previously

- ' j. ewuated are not adversely affected by the proposed changes.

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,- . The proposed changes do not create the possibility of a new or different kind of accident fmm any acci: lent previously evaluated because 'he operational flexibility needed for efiluent releases does not involve any change to the configara.:en or method

of opeiation of any plant equipment. Accordingly, no new tailure modes have bcen

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defined foi any plant system or component important to safety ner has any new limithg .

single failure bee identified as a result of the proposed changes. Also, there will be no change in types or h. crease in the amount of efiluents released offsite. ~

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3. The proposed changes do not involve a significant reduction in a margin of safety g

because th ational flexibility needed for efiluent releases does not reduce tne effectivenen

.he radiation protection propmc at VEGP, The proposed chang n not involve any actual change in the r~thooAw used in the control of solid l radioactive wastes or radiological enmranmeutd +3nitoring. The methodology that will be used in the control of radioactive emu- :: ..!! result in the same efiluent release te e the current methodology now being taed. The opetdonal flexibil;.y needed for luent releases allov s the use of concentration values ten times the values given in the new 10 CFR 20. However, this is acceptable since annual doses will be limited to the doses specified in 10 CFR 50, Appendix I and 40 CFR 190.

Evaluation of Proposed Ch_ange 9

1. The proposed changes to the Technical Specifications do not involve a significant ir. crease in the probability or consequences of an accident previously evaluated because the proposed distance to be used to make measurements of a source of radioactivity to control access to high radiation areas is needed in order to facilitate implementation of the new 10 CFR 20 requirements. The proposed changes do not alter the conditions or assumptions in any of the FSAR accident analyses, Since the Ff AR accident analyses remain bounding, the radiological consequences previously evaluated a ;, ..ot adversely-affected it the pronosed changes.

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J l ENCLOSURE 2 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS i

I 10 CFR 50.92 EVALUATION l

2. The proposed changes do not create the possibility of a new or difTerent kind of

accident from any accident previously evaluated because they do not involve any change to the configuration or method of operation of any plant equipment. Only the distance to be used to ma!.: measurements of a source of radioactivity to control access to high radiation areas is being changed. Accordingly, no new failure modes have been dermed for any plant system er component important to safety nor has any new limiting single 4

failure been identified as a result of the proposed changes. Also, there will be no change in types or increase in tb amount of eflluents released offsite.

3. The proposed changes do not involve a significant reduction in a margin of safet:-

, because a shorter distance will be used to make measurements of a source of-

radioactivity to control access to high radiation areas. This is a conser c ve change i which will result in higher dose measurements. Therefore, the'effectivenen of the radiation protection programs at VEGP will not be reduced.

based on the preceding information, it has been determined that the proposed Technical Specification changes do not involve a significaat hazards consideration as defined by 10 CFR 50.92(c). ,

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