ML20215M203

Proposed Tech Specs,Changing Sections 3.3.6 & 6 Re Specific Activity & Administrative Controls,Respectively,Including Correction of Position Titles & Special Reporting Requirements

ML20215M203
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/15/1986
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20215M193	List: ML20215M190 ML20215M203
References
NUDOCS 8610300107
Download: ML20215M203 (26)

Text

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Table Page 4.17-1 Charcoal Filters 284 4.17-2 HEPA Filters 285 4.19-1 Failed Fuel Monitoring Instruments 295 i 4.21-1 Fire Protection Instruments" -

295p 4.21-2 Fire Suppression Water System 295r 4.21-3 Sprinkler Systems 295s 4.21-4 CO2 Systems 295t 4.21-5 Fire Hose Stations 295u l 6.6-1 Special Reports 323 l 6. 8-1 Boundary Doors for Flooding Protection 328 8610300107 861015 PDR P ADOCK 05000295 PDR i

List of Tables (Continued)

Xi TSC 84-03(4) 10140/10150

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS REACTOR C00 TANT SYSTEM 3.3.6 SPECIFIC ACTIVITY 4.3.6 The specific activity of the reactor coolant shall be sampled and analyzed in accordance

, l The specific activity of the reactor coolant with Table 4.3.6-1.

shall be limited to:

a. Less than or equal to 1.0 microcurie per gram DOSE EQUIVALENT I-131, and

b. Less than or equal to 100/E microcuries per

! g ram.

4 APPLICABILITY: Modes 1, 2, 3, 4, 5 and 7.

! ACTION: Modes 1, 2, 3* and 7*:

a. With the specific activity of the reactor coolant greater than 1.0 microcurie per gram j DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure

3.3.6-1, be in at least HOT SHUTDOWN with l Tavg less than 500*F within six hours.

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b. With the specific activity of the reactor coolant greater than 100/E micropuries per j gram, be in at least HOT SHUTDOWN with l

Tavg less than 500*F within six hours.

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• With T avg greater than or equal to 500*F.

i 10120/10130 123

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS ACTION: 4.3.6 Modes 1, 2, 3, 4, 5 and 7:

a. With the specific activity of the reactor coolant greater than 1.0 microcurie per gram DOSE EQUIVALENT I-131 or greater than 100/E microcuries per gram, perform the sampling l

and analysis requirements of item 4a) of Table 4.3.6-1 until the specific activity of l the primary coolant is restored"to within its limits.

b. A SPECIAL REPORT shall be prepared and submitted to the Commission as part of the Annual Report when Specification 3.3.6 has been exceeded. This report shall include l the following information:

1.~ Reactor power 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;

2. Results of the last isotopic analysis for radiciodine performed prior to 1 exceeding the limit, results of analysis 1

'while the limit was exceeded, and the i results of one analysis af ter the radioiodine activity was reduced to less 15.0a the limit. Each result should include date and time of sampl'ing and the radioiodine concentrations;

3. Clean-up flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> pr'for to the first sample in which the limit was exceeded; 10120/10130 124

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENTS 3.3.6 4. Graph of the I-131 concentration and one 4.3.6 other radiolodine isotope concentration, in microcuries per gram, as a function of time for the duration of the specific activity above the steady-state level;

5. The time' duration when the specific activity of the primary coolant exceeded the radioiodine limit.

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i 10120/10130 124a

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Bases: SPECIFIC ACTIVITY 3.3.6 The limitations on the specific activity of the

& primary coolant ensure that the resulting 2-hour 4.3.6 doses at the site boundary will not exceed an appropriately small f raction of 10CFR100 limits following a steam generator tube rupture accident in conjunction with an assumed steady ,

state primary-to-secondary steam generator -

i leakage rate of 1.0 GPM. The values for the limits on specific activity represent limits based upon a parametric evaluation by the NRC of typical site locations. These values are conservative in that specific site parameters of

the Zion site, such as site boundary location and meteorological conditions, were not considered in this evaluation. .

Reducing T a vg to less than 500*F prevents the release of activity should a steam generator tube rupture since the saturation pressure of

the primary coolant is below the lift pressure of the atmospheric steam relief valves. The surveillance requirements provide adequate i ~ assurance that excessive specific activity i levels in the primary coolant will be detected j

in sufficient time to take corrective action.

Information obtained on iodine spiking will be i used to assess the parameters associated with spiking phenomena.

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10120/10130 125

l LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENT 4.22. Shock Suppressors (Continued) 4.22. Shock Suppressors (Continued)

3. Snubber Service Life Monitorina 3. Snubber Service Life Monitorina A record of the service life of each mechanical and hydraulic snubber, the date at which designated service life commences and the installation and maintenance records on which the designated service life is based shall be maintained as required oy Specification 6.5.2.0.

l Concurrent with the first inservice visual inspection and at least once per 18 months thereaf ter, the installation and maintenance records for each snubber shall be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next scheduled snubber ser91te life review. If the indicated' service life will be exceeded prior to the next scheduled snubber service life review, the snubber service life shall be reevaluated or the snsbber shall be replaced or reconditioned so as to extend its

service life beyond the date of the next j

scheduled service life review. This reevaluation, replacement or reconditioning shall be indicated in the records, i

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10140/10150 295AA7 TSC 84-03(4) i

t l 6.0 ADMINISTRATIVE CONTROLS 4. Qualifications of the Station management and operating staff shall meet minimum l 6.1. Organization, Review, Investigation, and Audit acceptable levels as described in ANSI N18.1 l " Selection and Training of Nuclear Power

1. The Station Manager shall have overall Plant Personnel," dated March 8, 1971 with full-time responsibility for safe operations the exception of the Radiation-Chemistry of the facility. During periods when the Supervisor or Lead Health Physicist, who Station Manager is unavailable, he shall shall meet or exceed the qualifications of designate this responsibility to an Radiation Protection Manager of Regulatory established alternate who satisfies the ANSI Guide 1.8 September,1975. The Shift N18.1 experience requirements for plant Control Room Engineer shall have a j manager. bachelor's degree or equivalent in a scientific or engineering discipline with

2. The organization chart of the corporate specific training in plant design, and management which relates to the operation of response and analysis of the plant for j this station and the normal functional transients, and accidents. The individual J organization chart for operation of the filling the position of Services

! station is shown in Figures 1-6 of the Superintendent shall meet the minimum

! Commonwealth Edison Quality Assurance Manual. acceptable level for " Technical Manager" as

] described in 4.2.4 of ANSI N18.1, 1971.

3. The shift manning for the station shall be as

shown in Figure 6.1-1. The Assistant 5. Retraining and replacement trahTng of

! Superintendent Operating, Operating Engineer, Station personnel shall be in accordance i Shift Engineers, and Shift Foreman shall have with ANSI N18.1, " Selection anc Training of

{ a Senior Reactor Operators License. The Fuel Nuclear Power Plant Personnel," dated March

Handling Foreman shall have a Senior Reactor 8, 1971. A training program for the Fire j Operator or Limited Senior Reactor Operators Brigade shall be maintained un d. the

. License. The Assistant Vice President and direction of the Station Fira ;arshall and l General Manager Nuclear Stations on the shall meet or exceed the requiredents of

, corporate level has responsibility for the Section 27 of the NFPA Code - 1975 except Fire Protection Program. An Operating that Fire Brigade training wili v'e conducted Engineer at the station will be responsible quarterly.

for implementation of the Fire Protection Program. A Fire Brigrade of at least 5 6. Retraining shall be conducted at intervals i

members shall be maintained onsite at all not exceeding two years.

times. The Fire Brigade shall not include the

minimum shift crew necessary for safe shutdown 7. The Review and Investigative Function and l of the plant (4 members) or any personnel the Audit Function of activities affecting

{ required for other essential functions during quality during facility operations shall be a fire emergency. constituted and~have the responsibilities j and authorities outlined below:

4 10140/10150 300 TSC 84-03(4) i

6.1.7. (Continued) i

! Offsite Review and Investigative Function this responsibility to an established i

alternate who satisfies the formal training l A. The Supervisor of the Offsite Review and and experience requirements for the -

4 Investigative Function shall be appointed by Supervisor of the Offsite Review and i the Manager of Nuclear Safety. The Audit Investigative Function.

Function shall be the responsibility of the l Manager of Quality Assurance and shall be The responsibilities of the personnel I independent of operations, performing this function are stated below.

The Offsite Review and Investigative

1. The Supervisor of the Offsite Review and Function shall review:

Investigative Function shall: (1)

! provide directions for the review and (a) The safety evaluations for changes to investigative function and appoint a procedures, equipment or systems as senior participant to provide appropriate described in the safety analysis report direction (2) select each participant and for tests or experiments completed

! for this function, (3) select a under the provision of 10 CFR Section

! complement of more than one participant 50.59 to verify that such actions did j who collectively possess background and not constitute an unreviewed safety qualifications in the subject matter l

question. Proposed changes to the  ;

I under review to provide comprehensive Quality Assurance Program description j interdisciplinary review coverage under shall be reviewed and approved by the this function, (4) independently review Manager of Quality Assurance.

i and approve the findings and

) recommendations developed by personnel (b) Proposed changes to procedt.es,

! performing the review and investigative equipment or systems which involve an i function, (5) approve and report in a unreviewed safety question as defined

{ timely manner all findings of in 10CFR Section 50.59.

noncompliance with NRC requirements and

provide recommendations to the Station (c) Proposed tests or experiments which

Manager, Assistant Vice-President and involve an unreviewed. safety question j General Manager Nuclear Stations, Manager as defined in 10CFR Section 50.59.

, of Quality Assurance, and the Executive

] Vice-President of Construction, (d) Proposed changes in Technical 1

Production, Engineering, Licensing and Specifications or NRC facility

! Environmental Affairs. During periods operating licenses.

when the Supervisor of the Offsite Review l and Investigative Function is (e) Noncompliance with NRC requirements, or unavailable, he shall designate of internal procedures or instructions having nuclear safety significance.

10140/10150 301 TSC 84-03(4)

i, 6.1.7.A.

6.1.7.A.1 (Continued)

2. Audit Function (f) Significant operating abnormalities or i deviations from normal and expected The Audit Function shall be the i

performance of plant equipment that responsibility of the Manager of Quality I affect nuclear safety as referred to it Assurance independent of the Production i

by the Onsite Review and Investigative Department. Such responsibility is Function. delegated to the Operations Quality Assurance Manager, to the Director of

! (g) Reportable Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Quality Assurance Operations and to the notification to the Commission. Director of Quality Assurance Maintenance.

i' (h) All recognized indications of an Either of the above, or designated Corporate i unanticipated deficiency in some aspect Staff or Supervision approved by the Manager l of design or operation of safety of Quality Assurance, shall approve the i related structures, systens or audit agenda and checklists, the findings components. and the report of each audit. Audits shall j

be performed in accordance with the Company (1) Review and report findings and Quality Assurance Program and Procedures.

recommendations regarding all changes Audits shall be performed to ae,sure that to the Generating Stations Emergency safety-related functions are covered within 3

Plan prior to implementation of such a period of two years or as designated below:

change.

(j) (a) Audit of the conformance of facility Review and report findings and operation to provisions contained recommendations regarding all items within the Technical Specifications and referred by the Technical Staff applicable license conditions at least Supervisor, Station Manager, Assistant once per year. '

Vice President and General Manager -

4 Nuclear Stations and Manager of Quality (b) Audit of the adherence to procedures, Assurance. training and qualification of the

station staff at least once per year.

(k) Changes to Offsite Dose Calculation Manual (ODCM). (c) Audit of the results of actions taken to correct deficiencies occurring in (1) Changes to the PROCESS CONTROL PROGRAM. '

facility equipment, structures, systems or methods of operation that affect nuclear safety at least once per six months.

r 10140/10150 302 I TSC 84-03(4)

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6.1.7.A.2 (Continued) (m) Report all findings of noncompliance j

with NRC requirements and l (d) Audit of the performance of activities recommendations and results of each required by the Quality Assurance audit to the Station Manager, the Program to meet the Criteria of 10 CFR Assistant Vice-President and General l j 50 Appendix *B".. Manager Nuclear Stations, Manager of Quality Assurance, Vice-President j

(e) Audit of the Generating Stations (Nuclear Operations), and Manager of Emergency Plan and Implementing Nuclear Safety.

I Procedures.

(n) Audit the Offsite Dose Calculation (f) Audit of the Facility Security Plan and Manual at least once per 24 months.

implementing procedures, j

6.1.7.A.3. Authority' (g) Audit Onsite and Offsite Reviews.

The Manager of Quality Assurance (h) Audit the Radiological Environmental reports to the Chairman and President j Monitoring Program at least once per 12 and the Supervisor of the Offsite j months. Review and Investigative Function reports to the Manager of Nucley l (1) Audit the Facility Fire Protection Safety who reports to the Chairman and Program and implementing procedures at President. Either the Manager of least once per 24 months. Quality Assurance or the Supervisor of the Offsite Review and Investigative (j) An independent fire protection and loss Function has the authority to order

prevention program inspection and audit unit shutdown or request any other shall be performed at least once per 12 action which he deems necessary to months utilizing either qualified avoid unsafe plant conditions. /

offsite licensed personnel or an j outside fire protection fim. 4. Records 2

(k) An inspection and audit of the fire (a) Reviews, audits and recomendations I protection and loss prevention program shall be documented and distributed as l shall be performed by a qualified covered in 6.1.7.A.1 and f,.l.7.A.2 outside fire consultant at least once per 36 months. (b) Copies of documentation, reports, and correspondence shall be kept or. file at (1) The PROCESS CONTROL PROGRAM and the station.

implementing procedures at least once per 24 months.

I 10140/10150 303 TSC 84-03(4)

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6.1.7.A.6 (Continued) 6.1.7.A.6.(b) (Continued)

(c) The Supervisor of the Offsite Review and (4) Power Plant Design Investigative Function shall have experience and training which satisfy Engineering graduate or equivalent with at ANSI N18.1 - 1971 requirements for plant least 5 years of experience in power plant managers.

design and/or operation.

6.1.7.B Onsite Review and Investiaative Function (5) Reactor Engineerina Engineering graduate or equivalent with at 1. The Onsite Review and Investigative Function least 5 years of experience in nuclear plant shall be supervised by the Station Manager.

engineering, operation, and/or graduate work in nuclear engineering or equivalent in The Station Manager or his designee, shall: l reactor physics. *(a) Provide direction for the Onsite Review and Investigative Function and appoint the 4 (6) Radiological Safety Technical Staff Supervisor, or other

comparably qualified individual as a senior j Engineering graduate or equivalent with at participant to provide appropriate

least 5 years of experience in Radiation direction; (b) Approve participants for this l Control and Safety function; (c) Assure that a complement of

! more than one participant who collectively

(7) Safety Analysis possess background and qualifications in the i

subject matter under review are selected to Engineering graduate or equivalent with at provide comprehensive interdisciplinary least 5 years experience in nuclear review coverage under this function; (d) engineering. Independently review and approve the

findings and recommendations developed by (8) Instrumentation and Control personnel performing the Review and Investigative Function; (e) Report all Engineering graduate or equivalent with at findings of noncompliance with NRC 4 least 5 years of experience in instrumentation requirements, and provide recommendations to j and control design and/or operation, the Assistant Vice-President and General 4

Manager-Nuclear Stations and the Supervisor I

(9) Metallurov of the Offsite Review and Investigative

) Function; and (f) submit to the Offsite

! Engineering graduate or equivalent with at Review and Investigative Function for

least 5 years of experience in the concurrence in a timely manner, those items i metallurgical field. described in Specification 6.1.7.A.1 which j have been approved by the Onsite Review and j Investigative Function.

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j 10140/10150 305 TSC 84-03(4) i l

1 l 6.1.7.8. (Continued) (h) Review of the Station Security Plan and shall

,! submit recommended changes to +he assistant Vice-President and General M uk ':elear

2. The responsibilities of the personnel performing Stations, i this function are stated below

j (1) Review of the Emergency Plan and station

(a) Review of procedures required by Specification Implementing Procedures and shall submit 6.2 and changes thereto, and any other reconnended changes to the Assistant proposed procedures or changes thereto as Vice-President and General Manager-Nuclear determined by the Station Manager to affect Stations.

nuclear safety.

(j) Review of Reportable Events and actions taken

, (b) Review of all proposed tests and experiments to prevent recurrence.

j that affect nuclear safety.

(k) Review of changes to the Offsite Dose (c) Review of all proposed changes to the Calculation Manual (00CN).

I Technical Specifications.

, (1) Review of changes to the PROCESS CONTROL i

(d) Review of all proposed changes or PROGRAM (PCP).

j modifications to plant systems or equipment ,

that affect nuclear safety.

(e) Investigation of all violations of NRC l requirements and shall prepare and forward a

! report covering evaluation and recommendations

! to prevent recurrence to the Assistant Vice i President and General Manager-Nuclear Stations

' and to the Supervisor of the Offsite Review and Investigative Function.

2 l (f) Review of facility operations to detect

! potential safety hazards.

i j (g) Performance of special reviews and i investigations and reports thereon as j requested by the Supervisor of the Offsite j Review and Investigative Function.

10140/10150 306 TSC 84-03(4)

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1 i 6.1.1.B (Continued) (a) Content and method of submission and presentation to the Station Manager, l 3. Authority Assistant Vice President and General i

Manager-Nuclear Stations and the I The Assistant Superintendent - Technical Services Superviser of the Offsite Review and

! is responsible to the Station Manager and shall Investigative Function.

make recommendations in a timely manner in all

! areas of review, investigation, and quality control (b) Use of committees.

t phases of plant maintenance, operation and i administrative procedures relating to facility (c) Review and approval.

operations and shall have the authority to request

the action necessary to ensure compliance with l (d) Detailed listing of items to be reviewed.

rules, regulations, and procedures when in his

' opinion such action is necessary. The Station (e) Procedures for administration of the Manager shall follow such reconnendations or select quality control activities, a course of action that is more conservative 1 regarding safe operation of the facility. All such (f) Assignment of responsibilities.  ;

j disagreements shall be reported immediately to the I Assistant Vice-President and General 6. Personnel l Manager-Nuclear Stations'and the Supervisor of the

{ Offsite Review and Investigative Function. (a) The personnel performing the Onsite Review and i Investigative Function, in addition to the j 4. Records Station Manager or his designee, shall consist of persons having expertise in:

(a) Reports, reviews, investigations, and (1) Nuclear power plant technology

, recommendations shall be documented with (2) Reactor operations i copies to the Assistant Vice President and (3) Reactor engineering i

General Manager-Nuclear Stations, the (4) Radiological safety Supervisor of the Offsite Review and (5) Instrumentation and control Investigative Function, the Station Manager (6) Chemistry and Radiochemistry and the Manager of Quality Assurance. (7) Mechanical and electric systems.

(8) Metallurgy (b) Copies of all records and documentation shall be kept on file at the station. (b) Personnel performing the Onsite Review and i

Investigative Function shall meet minimum 1 5. Procedures acceptable levels as described in ANSI N18.1 1971, Sections 4.2 and 4.4.

Written administrative procedures shall be prepared and maintained for conduct of the Onsite Review and Investigative Function. These procedures shall l include the following:

10140/10150 307 TSC 84-03(4)

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• Statien Security Plan and implementing .

I 6.2. Plant Ooeratina Procedures procedures.

. 1. Written procedures including applicable K. Fire Protection Program implementation.

! checkoff lists covering items listed below shall be prepared, implemented, and maintained: L. Post Accident Sampling Program j A. Normal startup, operation, and shutdown M. Working hours of the Shift Engineer, 4 of the reactor and other systems and Shift Control Room Engineer, Shift

) components involving nuclear safety of Foreman, and Nuclear Station Operator i the facility. such that the heavy use of overtime is B. Refueling operations.

1 2. Radiation control procedures shall be

! C. Actions to be taken to correct specific prepared, implemented and maintained. These

and foreseen potential malfunctions of procedures shall specify permissible radiation i systems or components including exposure limits and shall be consistent with responses to alarus, suspected primary the requirements of 10 CFR 20. The radiation system leaks, and abnormal reactivity protection program shall meet the requirements changes. of 10 CFR 20.

D. Emergency conditions involving 3. Procedures for items identified in l

potential or actual release of Specification 6.2.1 and any changes to such

! radioactivity " Generating Stations procedures shall be reviewed and approved by l Emergency Plan" and station emergency the Operating Engineer and the Technical Staff

) and abnormal procedures. Supervisor in the areas of operation and fuel 1 handling, and by the Assistant Superintendent I E. Instrumentation operation which could Maintenance and Technical Staff Supervisor in l have an effect on the safety of the the areas of plant maintenance, instrument.

l facility. maintenance, and plant inspection. Procedures j for items identified in Specification 6.2.2 j F. Preventive and corrective maintenance and any changes to such procedures shall be l operations which could have an offect reviewed and approved by the Technical Staff i on the safety of the facility. Supervisor and the Radiation Protection j Manager (RPM). At least one person approving G. Surveillance and testing requirements. each of the above procedures shall hold a i

! valid Senior Reactor Operator's license. In l l H. Tests and experiments. addition, these procedures and changes thereto I must have the authorization of the Station

1. Procedures to ensure safe shutdown of Manager or cognizant Superintendent before l the plant. being implemented.

l 10140/10150 308 TSC 84-03(4)

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)

6.2.3. (Continued) -

1 1

Work and instruction type procedures which implement approved maintenance or modification procedures shall l be approved and authorized by the Production i Superintendent. The " Maintenance / Modification i

Procedure" utilized for safety related work shall be so approved only if procedures referenced in the

" Maintenance / Modification Procedure" have been approved as required by 6.2.1. Procedures which do not fall i within the requirements of 6.2.1 or 6.2.2 may be approved by the Department Heads.

t l l 4. Temporary changes to procedures identified in Specifications 6.2.1 and 6.2.2 above may be made provided:

1 l j A. The intent of the original procedure is not altered.

8. The change is approved by two members of the plant j management staff, at least one of whom holds a Senior

! Reactor Operator's License on the unit affected.

l C. The change is documented, reviewed by the Onsite

, Review and Investigative function and approved by the l l Station Manager or cognizant Superintendent within 14 t j days of implementation. I 1

5. Drills of the emergency procedures described in j

l Specification 6.2.1.0 shall be conducted at the frequency i i specified in the Generating Station Emergency Plan. These drills will be planned so that during the course of the year, communication links are tested and outside agencies l are contacted.

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10140/10150 309 TSC 84-03(4)

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8. Record of principal maintenance activities, 6.3 Action to be Taken in the Event of a Reportable including inspection, reptir 6M replacements, Event in Plant Doeration: regarding principal items of e(,eipment pertaining to nuclear safety.

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Any Reportable Event shall be promptly reported to l the Assistant Vice President and General C. Records and reports of Reportable Events and Manager-Nuclear Stations or his designated Safety Limit occurrences.

alternate. The incident shall be promptly reviewed i pursuant to Specification 6.1.7.8.1.(e) and a D Records and periodic checks, inspection and/or separate report for each reportable event shall be calibrations performed to verify the

, prepared in accordance with the requirements of Surveillance Requirements (Section 4 of these

l 10 CFR Part 50.73. Specifications) are being met. All equipment i failing to meet surveillance requirements and l l 6.4 Action to be Taken in the Event a Safety Limit is the corrective action taken shail be recorded.

i Exceeded:

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E. Records of changes made to procedures required If a safety limit is exceeded, the reactor shall be by Specifications 6.2.1 and 6.2.2.

j tripped immediately and reactor operation shall not be resumed until authorized by the NRC. The F. Records of radioactive shipments.

conditions of shutdown shall be promptly reported l to the Assistant Vice President and General G. Records of physics tests and other tests Manager-Nuclear Stations or his designated pertaining to nuclear safety.

, alternate. The incident shall be reviewed pursuant

! to Specification 6.1.7.A.1 and 6.1.7.8.1 and a H. Records of sealed source and fission detector separate report for each occurrence shall be leak tests and results.

l l prepared in accordance with of 10 CFR Part 50.36.

6.5 Plant Operatine Records J. By-product material inventory records.

1. Records relative to the following items shall j be retained for at least five years:

4 j A. Records of normal plant operation, i

including power levels and periods of l operation at each power level.

l q 10140/10150 310 TSC 84-03(4) i

6.5. (Continued) 1. Records of transient or operational cycling for those components that have been designed to operate safely for a limited number of

2. Records relative to the following items shall transient or operational cycles.

be retained for the duration of the Operatine License. J. Records of training and qualification for current members of the station staff.

A. Substitution or replacement of principal items of equipment pertaining to nuclear K. Inservice inspections and testing performed l safety. pursuant to the Technical Specifications.

8. Records and drawing changes reflecting L. Minutes of meetings and results of reviews plant design modifications made to performed by the Offsite and Onsite Review systems and equipment described in the Functions.

Safety Analysis Report.

M Records of secondary water sampling and water C. Records of new and irradiated fuel quality. '

i inventory, fuel transfers and assembly burnup histories. N. Records for environmental qualification of components required by the. Environmental D. Updated, corrected, and as-built drawings Qualification (EQ) Program.

l of the plant.

0. Records of the service lives of all snubbers E. Records of plant radiation and covered by Specification 3.22 including the contamination surveys. date at which the service life commences and associated installation and maintenance  ;

F. Records of offsite environmental records. '

i monitoring surveys.  !

P. Records of reviews performed for changes made  !

G. Records of radiation exposure for all to procedures or equipment or reviews of tests

plant personnel, including all and experiments pursuant to 10 CFR 50.59.

l contractors and visitors to the plant in

, accordance with 10 CFR 20. Q. Records of Quality Assurance activities

required by the Q.A. Manual.

j H. Records of radioactivity in liquid and gaseous wastes released to the Records of reactor tests and experiments.

R.

environment.

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) 10140/10150 311 TSC 84-03(4) 1

I l 6.6.1.C (Continued)

This report shall also include an assessment D. Semiannual Radioactive Release Report:

of radiation doses to the likely most exposed real individual f rmw reactor Within 60 days af ter January 1 and July 1 of releases and other nearby uranium fuel cycle each year a report shall be submitted i sources (including doses from primary covering the radioactive content of effluents j effluent pathways a.nd direct radiation) for released to unrestricted areas during the i

the previous 12 ccnsecutive months to show previous six months operation. The data conformance with 40 CFR 190, Environmental shall be in the format of Regulatory Guide i

Radiation Protection Standards for Nuclear 1.21, Rev.1 (June 1974) and shall be Power Operation. Acceptable methods for summarized on a quarterly basis and shall calculating the dose contribution from include as a minimum:

, liquid and gaseous effluents are given ic Regulatory Guide 1.109, Rev.1. 1. Gaseous Effluents (a) Gross Radioactivity Releases (9) This report shall also include a special report pursuant to the requirements of (1) Total gross radioactivity (in

Specification 3.3.6 whenever the reactor curies) primarily noble and coolant specific activity limits have been activation gases released.

exceeded.

(2) Maximum gross radioactivity release rate curing any one-hour period.

(3) Total gross radioactivity (in curies) by nuclide released, 3 based on representative j isotopic analyses performed.

(4) Percent of technical specification limit.

(b) Iodine Releases (1) Total iodine radioactivity (in curies) by nuclide released, based on representative isotopic analyses perforned.

(2) Percent of technical specification limit for 1-131 l released.

10140/10150 314 TSC 84-03(4)

6.6.1.D. (Continued)

5. The radioactive effluent release reports shall include any changes to the PROCESS CONTROL PROGRAM (PCP) made during the reporting period.

, E. Monthly Doerating Report Routine reports I

using the " Operating Data", " Unit Shutdowns i and Load Reductions" and " Average Daily Unit l

Power Level" report formats, shall be submitted on a monthly basis to the j;l Director, Office of Management and Program j Analysis, U.S. Nuclear Regulatory i Commission, Washington, D.C. 20555 with a copy to the appropriate NRC Regional Office l of Inspection and Enforcement, no later than j the 15th of each month following the calendar month covered by the report.

Included with the report will be a

" Narrative Summary of Operating Experience" that describes the operation of the facility, including major safety related maintenance, for the monthly report period.

] Any changes to the Offsite Dose Calculation j Manual shall be submitted with the monthly 1

Operating Report within 90 days of the effective date of the change.

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I j 10140/10150 316 Tsc 84-03(4)

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! 6.6.3.B Special Reports l

Reports on the following areas shall be l

i submitted as indicated:

l' Topic SUBMITTAL DATE l a. In-Service Inspection Evaluation In accordance with the requirements of Section XI i 1 ASME Boiler Code (IWA-6000) i I b. (Deleted) i i c. Containment Building Structural Testing Within 90 days following completion of each test.

! Report (ILRT, Tendon) l

d. Changes to the Offsite Dose Calculation Within 90 days of effective date as part of the Manual (ODCM) Monthly Operating Report.

t

e. Waukegan Regional Airport Expansion The expansion plans and status of such plans for

['

! Plans. the Waukegan Regional Airport will be reported l 1 yearly in the Annual Report, including FAA form 35010 report.

f. Low Temperature Overpressure Protection Within 30 days of operation, j System operation i

j g. Primary Coolant Specific Activity As part of the Annual Report whenever l

Specification 3.3.6 has been exceeded. See page j 124 for required report content.

h. Pressurizer PORV or Safety Valve within 30 days as an LER.

Failure to Close

.i SPECIAL REPORTS Table 6.6-1 I 10140/10150 323 4

6.6.3.B Special Reports (Continued) l C

_TOPI_C SUBMITTAL DATE l

Pressurizer PORV or Safety Valve Document the event in the Annual Report i.

challenges l

i

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j. (Future) k .e Steam generator tube inspection and/or Per surveillance requirements 4.3.1.B.5 plugging.

J

1. Emergency Core Cooling System (ECCS) Within 30 days as LER - include nozzle usage i actuation and injection when RCS temp > factor per T.S. 3.3.2.F.3 350*F 1

m. Fire detector inoperability Within 30 days per T.S. 3.21.1.C

n. Fire pump system inoperability Within 30 days per T.S. 3.21.2.B

o. Fire suppression system inoperability Within 30 days per T.S. 3.21.2.C or 3.21.2.D 1

p. Sprinkler system inoperability Within 30 days per T.S. 3.21.3.C

q. Low pressure CO2 system inoperability Within 30 days per T.S. 3.21.4.C j SPECIAL REPORTS

! Table 6.6-1 (continued) i

! 10140/10150 324

i .'

\  ;

6.6.2. Reportable Events 6.6.2.A.2 Non-Enereency Reports:

A. Inunediate Notification:

i 1. Emergency Reports: a. One-Hour Reports - If not reported I

as a declaration of an Emergency

a. The licensee shall notify the NRC Class under paragraph 6.6.2.A.1 of Operations Center via the Emergency this section, the licensee shall Notification System (ENS) of: notify the NRC as soon as

1) The declaration of any of the practical and in all cases within l' . Emergency Classes specified in one hour of the occurrence of any the Generating Station of the following. ,

1 Emergency Plan (GSEP).

2) Those Non-Emergency events 1) The initiation of any nuclear j

specified in paragraph plant shutdown required by 6.6.2.A.2 below. the plant's Technical Specifications.

b. If the Emergency Notification System ,

) is inoperative, the required 2) Any deviation from the i notifications shall be made via plant's Technical

conumercial telephone service, other Specifications authorized I dedicated telephone system, or any pursuant to 10CFR50.54(x).

other method which will ensure that a report is made as soon as 3) Any event or condition during practical to the NRC Operations operation that results in the Center. condition of the nuclear powerplant, including its

c. The licensee shall notify the NRC principal safety barriers, il insnediately after notification of being seriously degraded, or j the appropriate state or local results in the nuclear power

agencies and not later than one hour plant being:

! after the time the licensee declares i one of the Emergency Classes. a) In an unanalyzed condition that

d. When making a report under paragraph significantly compromises i 6.6.2.A.1.c above, the licensee plant safety, shall identify:

, 1) The Emergency Classification b) In a condition that is i declared; or outside the design basis l 2) Either paragraph (2)(a), of the plant, or "One-Hour Report," or paragraph i (2)(b), "Four-Hour Report." as c)

~

In a condition not the paragraph of this section covered by the plant's requiring notification of the operating and emergency Non-Emergency Event. procedures.

10140/10150 317 TSC 84-03(4)

I ATTACHMENT 2 DESCRIPTION OF THE PROPOSED AMENDMENT A description of the individual segments of this proposed change is included below:

Pages 123, 124, 124a 125 These pages incorporate changes in accordance with the guidance contained in the referenced letter, Generic Letter 85-19. These changes will eliminate the requirement to shutdown if the coolant iodine exceeds one micro - curie per gram dose equivalent iodine 131 for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a twelve month period.

It also reduces the reporting requirements for exceeding this activity limits.

Page 295 AA7 This page merely incorporates the appropriate reference within Section 6.0 as a result of the changes approved by amendments 96 and 86.

Pages 300, 301, 302, 303, 306, 307, and 310 The pages all incorporate changes necessitated by corporate title changes.

Pages 305, 307, and 308 The changes create the option of designating an alternate for the Zion Station Manager as a participant in the onsite review process.

Pages xi, 306, 307, 308, 309, 310, 311, 316, and 317 These pages all contain changes which correct minor wording deficiencies or provide clarification.

Pages 314, and 323 These pages incorporate the modified reporting requirements for primary coolant specific activity.

Pages 323, and 324 These pages delete the special reporting requirements for the loose parts monitoring system and the service water leaks inside of containment. The service water leak-report requirement was prematurely included as part of Amendments 96 and 86. The remainder clarifies other special reporting requirements.

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ATTACHMENT 3 1

EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION PROPOSED CHANGES TO ZION TECHNICAL SPECIFICATION APPENDIX A - SECTIONS 3.3.6 AND 6.0 SPECIFIC ACTIVITY AND ADMINISTRATIVE CONTROLS DESCRIPTION OF AMENDMENT REOUEST An amendment to the Zion Facility Operating License is proposed to modify the Zion Technical Specifications in accordance with Generic Letter 85-19 and to incorporate minor administrative changes.

BACKGROUND 10 CPR 50.92 states that a proposed amendment will involve a no significant hazards consideration if the proposed amendment does not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

In addition, the commission has provided guidance in the practical applica-tion of these criteria by publishing eight examples in 48 FR 14870.

The discussion below addresses each of these three criteria and demonstrates that the proposed amendment involves a no significant hazards consideration.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Does the proposed amendment (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety?

DISCUSSION - ITEM #1

This change involves incorporating the guidance contained in NRC Generic Letter 85-19. It also involves a number of minor administrative changes that are either associated with Generic Letter 85-19 or are intended to clarify and update Section 6.0 of the Zion Technical Specifications.

i There will be only one aspect of this proposed change that will have an effect on the operation of Zion Station. Generic Letter 85-19

' Provides for the deletion of the requirements to shutdown a reactor that has experienced in excess of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of high coolant iodine activity. The existence of high iodine activity in the primary coolant system has no effect on any other system at Zion Station. That is, the existence of higher specific activity does not affect the integrity of Zion Station nor the ability of its safety related systems to perform their intended functions.

The existing Zion PSAR typically assumes operation with one percent i failed fuel for those accidents which involve a release of primary coolant.

For example, the analysis of a steam generator tube rupture event contained in the Zion PSAR assumes that a 172 curies of equivalent iodine is contained

in 125,000 lbs of reactor coolant. Thus, the assumptions contained in the Zion safety analysis continue to bound the restrictions of the Zion Technical Specifications. This results in the consequences of previously analyzed events being unaltered by this proposed change.

The remaining changes constitute minor modifications in the plant's 4

administrative controls. These alterations have been prompted by either the reporting requirements suggested in 85-19, or by the need to clarify a pre-existing requirement contained in Section 6.0 of the Zion Technical Specifications.

, None of the administrative clarifications discussed above has any l effect on the operation of Zion Station. Thus, these changes can have no l effect on either the integrity of Zion Station nor on the ability of its safety related systems to perform their intended function.

{

Thus, this proposed amendment has.no affect on the probability or consequences of any previously evaluated accident.

DISCUSSION - ITEM #2 Neither the implementation of the guidance contained in Generic Letter 85-19 nor the clarification of administrative controls at Zion i

Station has any effect on the operation of Zion Station. These proposed i amendments have no effect on any of Zion's systems nor on their ability to perform. These changes will not produce any effects or pertubations that might induce the failure or malfunction of another component.

I

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

Based upon the above discussion, this proposed change will not create the possibility of a new or different kind of accident from any previously evaluated.

DISCUSSION - ITEM #3 The margin of safety at Zion Station is unaffected by this proposed amendment. As discussed above, the assumptions contained in the Zion safety analysis still bound the restrictions on Zion specific coolant activity.

In addition, the minor administrative clarifications have no effect on the operation of Zion Station. They cannot have any detrimental affect on any of Zion Station's systems ability to perform their intended safety functions.

Therefore, the proposed amendment will not involve a reduction in the margin of safety.

The implementation of the guidance contained in Generic Letter 85-19 will make the Zion Station Technical Specifications conform to the current NRC policy. Thus example (vii) is applicable in this instance.

Example (vii) states:

(vii) A change to make a license conform to changes in the regulations, where the license changes results in very minor changes to facility operations clearly in keeping with the regulations.

The minor administrative clarifications are intended to correct terminology and to clarify the various requirements contained in Section 6.0 I of the Zion Technical Specifications. Thus, example (1) is applicable in this instance. Example (i) states:

(i) A purely administrative change to Technical Specifications: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.

1 Therefore, since the application for amendment satisfies the criteria specified in 10 CFR 50.92 and is similar to examples for which no significant hazards consideration exists, commonwealth Edison Company has made a determination that the application involves no significant hazards consideration.

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