TXX-9404, Application for Amends to Licenses NPF-87 & NPF-89, Consisting of LAR 94-004,incorporating New Requirements of 10CFR20 (20.1001-20.2402)

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Application for Amends to Licenses NPF-87 & NPF-89, Consisting of LAR 94-004,incorporating New Requirements of 10CFR20 (20.1001-20.2402)
ML20067C036
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/14/1994
From: William Cahill
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20067C039 List:
References
TXX-94045, NUDOCS 9402250274
Download: ML20067C036 (14)
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Text

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Log # TXX-94045

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File # 916 (3/4 11.0) 916 (1.0) clo E 3 916 (5.0) clo 916 (6.0) clo)

TUELECTRIC 10010 Ref. # 10CFR50.90 10CFR50.36 William j. Cahill. Jr.  !

Guwp vice Pmadent February 14, 1994 U. S. Nuclear Regulatory Commission Attn: Document Control Room Washington, DC 20555

SUBJECT:

COMAN' DEAK STEAM ELECTRIC STATION (CPSES) 00CKE 50-445 AND 50-446 SUBM' 't 0F LICENSE AMENDMENT REQUEST 94-004 INCf TATION OF THE NEW REQUIREMENTS OF 10 W ' ART 20 ( 20.1001-20. 2402) ,

Gentlemen:

Pursuant to 10CFR50.90, TV Electric hereby requests an amendment to the CPSES Unit I facility operating license (NPF-87) and CPSES Unit 2 facility operating license (NPF-89) by incorporating the attached changes into the CPSES Units 1 and 2 Technical Specifications. The purpose of this request is to incorporate appropriate references to and provisions of the new 10 CFR Part 20 regulations. These changes are equally applicable to CPSES Units 1 and 2.

The current CPSES Technical Specifications require amendment to provide references to the new regulations, revise a definition and aspects of radiological effluent technical specifications, clarify the administrative specification for reporting individual annual exposures greater than 100 mrem by work / job function, and revise the administrative specifications for providing alternative measures for control of access to high radiation areas and designating record retention for radioactive shipments.

Attachment 2 provides a detailed description and assessment of the proposed changes.

TU Electric implemented the new 10 CFR Part 20 regulations at CPSES effective January 1, 1993. Implementation was achieved by incorporating the '

new requirements of 10 CFR Part 20 directly into appropriate procedures of the CPSES Radiation Protection Program and the Offsite Dose Calculation Manual (00CM). This implementation is consistent with requirements of 10CFR20.1008 and has provided compliance that is equivalent or conservative in comparison to that required by the current technical specifications and the new 10 CFR Part 20.

,p4 1 1 M A 013. s I 9402250274 940214 PDR ADOCK 05000445 4m n ouve sirect LR 81 Danas, Texas 75201

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iXX 94045 Page 2 of 2 TU Electric now seeks to revise the CPSES Technical Specifications in order  :

to reflect the new regulations. Approval of this proposed license amendment is requested by June 30. 1994, with implementation of the Technical  :

Specification changes to occur within 30 days after NRC approval.

In accordance with 10CFR50.91(b). TV Electric is providing the State of Texas with a copy of this proposed amendment. .

Should you have any questions, please contact Mr. Connie L. Wilkerson at (214) 812-8819.

Sincerely, e,

e l/ .

William J. hill, Jr.

CLW/grp Attachments: 1. Affidavit

2. Description and Assessment
3. Affected Technical Specification pages (NUREG-1468) ,

revised by all approved license amendments.

c- Mr. L. J. Callan, Region IV Mr. L. A. Yandell, Region IV Resident inspectors, CPSES (2)

Mr. T. A. Bergman, NRR Mr. D. K. Lacker .

Bureau of Radiation Control Texas Department of Public Health 1100 West 49th Street Austin, Texas 78704 s

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Attachment 1 to TXX-9404S Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

In the Matter of )

)

Texas Utilities Electric Company ) Docket Nos. 50-445

) and 50-446 (Comanche Peak Steam Electric ) License Nos. NPF-87 Station, Unit 1 & 2) ) NPF-89 AFFIDAVIT j William J. Cahill, Jr. being duly sworn, hereby deposes and says that he is  !

Group Vice President, Nuclear Production for TV Electric, the licensee herein: that he is duly authorized to sign and file with the Nuclear Regulatory Commission this License Amendment Request 94-004: that he is familiar with the content thereof; and that the matters set forth therein ,

are true and correct to the best of his knowledge, information and belief.

. /

7 ts , ,e -  !

William J. t/ hill, Jr.  ;

Group Vice President, Nuclear l

STATE OF TEXAS )

) I COUNTY OF SOMERVELL ) j i

Subscribed and sworn to before me, on this 14th day of February ,

1994.

tfotary Public l PATE!C!A WidON l l i W l%s7630N EXPMS l l '..,f/

Mafs M. 29W l

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Attachment 2'to TXX-94045 Page I of 11 3

i DESCRIPTION AND ASSESSMENT I. BACKGROUND On May 21, 1991, the Nuclear Regulatory Commission (NRC) issued a revision to its standards for protection against ionizing radiation, i 10CFR20 (hereafter referred to as the "new 10CFR20'1 r

The purpose of the revision was to modify the Radiation Protection Standards to reflect developments in the principles and scientific ,

knowledge underlying radiation protection. In addition, the revision addresses International Radiation Protection Standards in order to attain more consistency with the requirements of other nations. The new ,

10CFR20 became effective on June 20, 1991 and requires implementation on ,

or before January 1, 1994. .!

l TV Electric programmatically implemented the new 10CFR20 regulations at i CPSES effective January 1, 1993. Implementation was achieved by .

+

incorporating requirements of the new 10CFR20 directly into appropriate  !

procedures of the CPSES Radiation Protection Program and the Offsite Dose Calculation Manual (0DCM). This implementation is consistent with requirements of 10CFR20.1008, and has provided. compliance that is equivalent or conservative in comparison to that required by' the current' technical specifications and the new 10CFR20.

TV Electric now seeks to ,

revise the CPSES Technical Specifications in order to reflect the new j regulations.

II. DESCRIPTION OF TECHNICAL SPECIFICATION CHANGE RE0 VEST l In accordance with 10CFR50.90, the following changes to the CPSES -

Units 1 and 2 Technical Specifications are proposed to reflect l requirements of the new 10CFR20:  !

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1. Technical Specification 1.18, " MEMBER (S) 0F THE PUBLIC." is being revised to reflect the new 10CFR20.1003 definition. 4
2. Technical Specification 3/4.11.1,
  • Liquid Holdup Tanks," for LCO 3.11.1 limits the quantity.of radioactive' material contained in i each unprotected outdoor tank. No change to the Technical  ;

Specification is required. The bases for the Technical '

Specification has been edited to reference the values given in Appendix B, Table 2, Column 2. to 10CFR20.1001-20.2402.

3. Technical Specification 5.1.3, ' Hap Defining UNRESTRICTED AREAS i and SITE BOUNDARY for Radioactive Gaseous and Liquid Effluents," i requires a change of reference from "10CFR20.3(a)(17)* to-
  • 10CFR20.1003". The map (Figure 5.1-3) is being updated to add a j clarifying note with respect to areas for which TV Electric ,

controls access. '

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Attachment 2 to TXX-94045 Page 2 of 11 l

4. Technical Specification 6.8.3e.2) defines the radioactive effluent '

control program limiting the concentration of radioactive material

" released in liquid effluents to UNRESTRICTED AREAS conforming to 10CFR20, Appendi x B, Tabl e ~ II, Col umn 2. " A change is required to change the quoted section of.the preceding sentence to " released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B. Table 2. Column 2, to-10CFR20.1001-20.2402".

E. Technical Specification 6.8.3e.3) defines the radioactive effluent control program for monitoring, sampling and analysis of ,

radioactive liquid-and gaseous effluents. A change is required to i change the reference "10CFR20.106" to "10CFR20.1302".

6. Technical Specification 6.8.3e.7) defines the radioactive effluent control program limiting the dose rate resulting from radioactive  :

material " released in gaseous effluents to areas beyond the SITE BOUNDARY conforming to the doses associated with 10CFR20, Appendix

  • B. Tabl e II Col umn 1," . A change is required to change the quoted section of the preceding sentence to:

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" released in gaseous effluents from the site to areas at or beyond the SITE BOUNDARY conforming 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, and j

b. For Iodine-131, for Iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater. ]i than 8 days: Less than or equal to a dose rate of 1500 mrem /yr to any organ,"

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7. Technical Specification 6.9.1.2a. defines annual reports.for j tabulation of personnel, by work group. receiving exposures j greater than 100 mrem /yr. The footnote referencing 10CFR20.407 is being changed to reference 10CFR20.2206. The wording of Technical +

Specification 6.9.1.2a. is clarified to be consistent with the  :

requirements of 10CFR20.2206, to change " personnel" to  !

" individuals", " exposures"'and "whole body dose" to " deep dose ,

equivalent", " man-rem exposure" to " collective deep dose  !

equivalent (reported in person-rem)", and to correct the units-(mrem /yr is a dose rate while cumulative mrem in one year:was .

intended). ,

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8. Technical Specification 6.10.2f., was moved to 6.10.3p. i 10CFR20.2108 requires longer retention.of records for disposal-of l licensed material. Technical Specification 6.10.3c. is edited'to-  !

be consistent with the record keeping requirements of j 10CFR20.2106. '

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i Attachment 2_to TXX-94045  :

Page 3 of 11 i i

9. Technical Specification 6.12, "High Radiation Area" requires  !

revision to change measurement distance. 10CFR20 references, add  ;

an upper bound to high radiation area and-make selected wording  ;

changes for consistency.

10, Technical Specification 6.14 defines administrative control of_ '

changes to the Offsite Dose Calculation Manual. In Technical  !

Specification 6.14a.2), revision is required to change the '

' reference "10CFR20.106" to "10CFR20.1302". i i

In preparing these _ proposed changes, TU Electric has reviewed and considered the NRC's recent Draft Generic Letter (GL), " Guidance for Modification of Technical Specifications. to Reflect (A) Revisions to '

10 CFR Part 20, ' Standards for Protection Against Radiation

  • and '

10 CFR 50.36a, ' Technical Specifications on Effluents from Nuclear Power j Reactors *, (B) Related Current Industry Initiatives, and (C)  ;

Miscellaneous Related' Editorial Clarification." Changes, as deemed I appropriate to ~ the exiting CPSES Technical' Specifications, have been  ;

-incorporated into this amendment request. '

III. ANALYSIS i

The proposed changes will provide consistency between the CPSES Technical Specifications and the new 10CFR20 and update selected radioactive effluent specifications established to comply with 10CFR50, Appendix I limits.  ;

The basic requirements concerning release of radioactive effluents from i nuclear power reactors are stated in 10CFR50.36a. These requirements j indicate that compliance-with effluent Technical Specifications will keep average annual releases of radioactive material in effluents to l

small percentages of the limits specified in the former 10CFR20.106 (revised 10CFR20.1301). The 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 10CFR20.106 which references Appendix B. Table 11 maximum permissible concentrations (MPCs). The limits correlate to an annual dose of i 500 mrem. 10CFR50.36a indicates 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 10CFR50, Appendix I. i The changes proposed to the CPSES Technical Specifications are consistent with the philosophy to keep dose to the- public as low as is reasonably achievable ( ALARA)' and below the limits set f orth in 10CFR50, Appendix 1.

I Attachment 2 to TXX-94045 Page 4 of 11 l'

Definitions - (Technical Specification 1.18)

MEMBER (S) 0F THE PUBLIC definition is being revised to correspond to the definition of 10CFR20.1003.

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This revision provides clarity and is specifically intended for use with 10CFR20.1001-20.2402 In practice, the revised definition as applied l does not alter the monitoring requirements or exposure limits at CPSES. l Liquid Holdup Tanks - (Technical Specification 3.11.1)

No change is proposed to the Technical Specification. The bases of the l Technical Specification is being revised to reference the new 10CFR20  ;

Appendix B Effluent Concentration Limits (ECLs). The purpose for the ,

Technical Specification has been to restrict the radioactivity content l such that an uncontrolled release of the tank's contents would not ,

exceed the maximum permissible concentration (MPC) limits of old i 10CFR20, Appendix B, Table II, Column 2 at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA. i The Technical Specification bases should reflect that limiting tank contents to 10 Curies is a conservative and more realistic limit than a tank concentration that would result in the ECLs given in Appendix B.

Table 2. Column 2, to 10CFR20.1001-20.2402. Section 15.7.3 of NUREG- 2 0800 and Sections 2.4.12, 2.4.13.3 and 15.7.3 of the CPSES Final Safety '

Analysis Report (FSAR) indicate that the radioactive source term previously evaluated was significantly greater than 10 Curies for an l accidental tank rupture. The calculated concentrations offsite would  !

remain below the ECLs of Appendix B. Table 2. Column 2, to 10CFR20.1001- '

20.2402 even though the new ECLs correspond to an annual dose of 50 mrem <

and the old MPCs correspond to an annual dose of 500 mrem. This I reference revision simply indicates that the specified. total curie ,

content is still the limiting factor rather than allowed concentration i limits.

Site Maps - (Technical Specification 5.1.3)

The sentence referencing UNRESTRICTED AREA and 10CFR20.3(a)(17) was '

changed to reference 10CFR20.1003. The map (Figure 5.1-3) related to gaseous and liquid effluents was clarified to denote the areas for which  ;

TU Electric controls access. These changes are editorial or provide clarity only and, by themselves, do not alter the monitoring or dose ,

limits at CPSES. 4 i

Liquid Effluents - (Technical Specification 6.8.3e.2)) i

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Current wording: " Limitations on the concentrations of radioactive  ;

material released in liquid effluents to UNRESTRICTED AREAS conforming to 10CFR20. Appendix B, Table 11. Column 2." i I

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Attachment 2 to TXX-94045 '

Page 5 of 11  :

Proposed wording: " Limitations on the concentrations of radioactive >

material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentration values in Appendix B. Table 2. Column 2.

to 10CFR20.1001-20.2402." t The introduction to Appendix B of the new 10CFR20 indicates that the j liquid effluent concentration to limits given in Appendix B, Table 2, Column 2, to 10CFR20.1001-20.2402, are based on an annual dose of 50 ,

mrem. Under the old 10CFR20, maximum permissible concentration limits i

corresponded to a dose limit of 500 mrem in a year for liquid effluents, Operational history at CPSES has demonstrated that the use of the concentration values associated with the old 10CFR20.106 as Technical ,

Specification limits has resulted in calculated maximum individual doses  !

to a member of the public that are small percentages of the requirements '

of 10CFR50, Appendix 1. Since the effluent concentrations listed in the. i new Appendix B. Table 2, Column 2, to 10CFR20.1001-20.2402 correspond to  :

a dose of 50 mrem in a year, and when applied as a dose rate with respect to liquid effluent monitors, 50 mrem / year corresponds to a dose rate of 5.7 microrem/hr. Considering monitor background, sensitivity, l and performance, it is impractical to base liquid effluent monitor  ;

setpoints on this low value for many liquid effluent release situations.

l The operational flexibility needed for liquid effluent releases requires j that release rate limits be revised to allow ten times the  ;

concentrations stated in the new - Appendix B, Table 2, Column 2, to '

10CFR20.1001-20.2402. l The factor of ten is based on the ratio of the old annual dose limit of  !

500 mrem to the new annual dose limit of 50 mrem. The proposed change j provides operational flexibility consistent with 10CFR50 Appendix I, j concurrent with the use of the new 10CFR20 as a source of reference  :

values, i i

This proposed change is consistent with the model technical -I specifications provided in the referenced NRC Draft Generic Letter. The  ;

subject model technical specifications were crafted to allow licensees '

to maintain their same overall level of effluent control. Maintaining j the existing level of control for instantaneous release rates, combined - ,

with the more restrictive limits of 10CFR50, Appendix I, will assure  !

compliance with the new 10CFR20. 1 Effluent Monitoring - (Technical Specification 6 8.3e.3))

, Current wording: " Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10CFR20.106 and with the-methodology and parameters in the ODCM."

i Proposed wording: " Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10CFR20.1302 and with  !

1 the methodology and parameters in the ODCM."  ;

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Attachment 2 to TXX-94045  !

Page 6 of 11

  • The proposed change to Technical Specification 6.8.3e.3) is purely administrative, correcting the reference section of 10CFR20 as necessary for consistency with other changes to the Technical Specifications. No  ;

changes in programs or procedures are intended as a result of this  !

change.

i Gaseous Effluonts - (Technical Specification 6.8.3e.7))

Current wording: " Limitations on the dose rate- resulting from radioactive material released in gaseous effluents to areas beyond the SITE BOUNDARY conforming to the doses associated with 10CFR20, Appendix B. Table II. Column 1."

Proposed wording: " Limitations 'on the dose rate resulting f rom radioactive material released in gaseous effluents from the site to  !

areas at or beyond the SITE BOUNDARY conforming 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, and

b. For Iodine-131, for Iodine-133, for tritium, and _for all radionuclides in particulate form with half-lives greater than 8 ,

days: Less than or equal to a dose rate of 1500 mrem /yr to any-organ."  ;

Technical Specification 6.8.3e.7) provides for a program to limit the dose from gaseous effluents at anytime, at and beyond the site boundary,-

to within the annual dose limits for unrestricted areas as specified by 10CFR20. The current annual dose limits are the doses associated with the concentrations in old 10CFR20, Appendix B, -Table II, Column 1 (10CFR20.106) and correspond to 500 mrem in a year. These limits on radioactive material discharged in gaseous effluents provide reasonable assurance that a member of the public in an unrestricted area, Outside ';

of the site boundary, would not be exposed to annual average concentrations exceeding the limits specified in Appendix B, Table II, Column 1 of 10CFR20 (10CFR20.106(b)).

The CPSES Offsite Dose Calculation Manual (0DCM) currently establishes j release rate controls, at all times, to restrict gamma .and beta dose j rates to a member of the public, at or beyond the site boundary.. to less 1 than or equal to 500 mrem / year to the total body or to less than or equal to 3000 mrem / year to the skin. These release rate limits also ,

restrict, at all times, the corresponding thyroid dose rate via the. '

inhalation pathway to less than or equal to 1500 mrem / year. These  !

limits are consistent with the guida'nce provided in NUREG-0133, j

" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants.*

Attachment 2 to TXX-94045 i Page 7 of 11 The instantaneous dose rate controls, in conjunction ~ with the cumulative  :

dose controls in the ODCM, maintain annual average releases of ,

radioactive material in gaseous effluents to within the dose values  ;

specified in Appendix I of 10 CFR Part 50. For purpose of the bases of r this technical specification, Appendix B to the new 10CFR20 is used as a source of reference values only. This specification does not affect the F requirement to comply with the annual limitations of 10CFR20.1301(a). ,

This technical specification requirement allows operational flexibility, compatible with' considerations of health and safety, which may temporarily result in release rates which, if continued for the calendar quarter. would result in radiation doses higher than specified in Appendix I of 10 CFR Part 50. However, these_ releases are within the limits specified in 10 CFR 20.106 (10 CFR 20.1302).

The proposed change does not revise the dose rate controls identified in  :

the Technical. Specifications and implemented by the CPSES ODCM. The proposed change deletes the reference to old 10CFR20, Appendix B Table II, Column 1 and instead. explicitly identifies the dose rate controls.

The proposed change to the Technical Specification is consistent with the CPSES ODCM and the model technical specification provided in the referenced NRC Draft Generic Letter.

The phrase "from the site" and the words "at or" have been added for -i clarity only.

Annual Reports - (Technical Specification 6.9.1.2a.)

The wording of Technical Specification 6.9.1.2a. is being revised by adding the underlined wordina as follows: l

[6.9.1.2] ,

a. A tabulation on an annual basis of the number of station, utility, and other individuals (including i contractors), for whom monitorina was reauired, l receiving an annual deep dose eauivalent greater than 100 mrem and thg associated collective deep dose.

ecuivalent (reported in Derson-rem 1..... In_the '

aggregate at least 80% of the total deeo dose i eauivalent received ...

Technical Specification 6.9.1.2a. requires a report to be submitted annually which includes'a tabulation of personnel receiving exposures greater than 100 mrem /yr and the associated person-rem exposure ,

according to work and job functions.

Since the new 10CFR20 (20.2206(b)) l only requires reporting for monitored individuals as defined. in l 10CFR20.1502, Technical Specification 6.9.1.2a. is being revised to -

clearly identify the individuals for whom tabulation in the annual report is required. This is an administrative change which clarifies. -j reporting requirements. This change does not alter CPSES requirements 1

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i Attachment 2 to TXX-94045 Page 8 of 11 or responsibilities for protection of the public and employees against radiation hazards. The footnote in this paragraph was edited to  ;

reference the revised criteria in 10CFR20.2206.

i Tne word " personnel" is revised to " individuals"; the words " man-rem  !

exposure" are revised to " collective deep dose equivalent (reported in  ;

person-rem)"; the words " exposures" and "whole body dose" have been revised to " deep dose equivalent". These changes are made to be consistent with new 10 CFR 20 dose terminology and the referenced NRC Draft Generic Letter. i The units " mrem /yr" have been revised to " mrem" as annual cumulative  !

dose was desired, not a dose rate.

i Records - (Technical Specification 6.10)  !

The retention period for records of disposal of licensed material changed from 5 years to the duration of the operating license as required by 10CFR20.2108. Technical Specification 6.10.2f. was -;

therefore moved to 6.10.3p. Technical Specification 6.10.3c. was edited, as shown below in underlined wordina, to be consistent with the t requirements of 10CFR20.2106. The proposed wording is:

[6.10.3]

c. Records of dases received by all individuals for whom '

monitorina was recuired:

The changes are administrative only. They are being made to make the l technical specifications consisterA with the new 10CFR20, but these .

changes do not change the CPSES programs in a way that impacts the  ;

monitoring or exposure limits at CPSES. i i

High Radiation Area - (Technical Specification 6.12)

The new 10CFR20 provides a new definition of a high radiation area which is based on a radiation measurement made at 30 cm (see 10CFR20.1601(a)).

Therefore, for consistency, the measurement' distance identified in Technical Specifications 6.12.1 and 6.12.2 is being changed from 18 inches to 30 cm (12 inches). This represents a conservative change-since 30 cm is a shorter distance than 18 inches. Imnlementing this change will result in higher dose measurements and more conservative identification of high radiation areas. An upper limit of 500 rad in i one hour at one meter was incorporated into this Technical Specification i to specify an upper bound to HIGH RADIATION AREA. The upper limit of 500 rad in one hour at one meter denotes a boundary between'HIGH RADIATION AREA and VERY HIGH RADIATION ' EA. Posting and r.ontrols for VERY HIGH RADIATION AREAS will be cons 13 cent with the requirements of 10CFR20.1602 and 10CFR20.1902(c) independent of the Technical Specifications. Other terminology changes are proposed in this '

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Attachment 2 to TXX-94045 l Page 9 of 11 i

Technical Specification for consistency (i.e., mR/h to mrem /h: exposure l to dose; personnel to individuals).

l ODCM - (Technical Specification 6.14a.2))

Technical Specification 6.14a.2) has been revised to change the reference of 10CFR20.106 to 10CFR20.1302. This change is an administrative change which will maintain consistency with the effluent j

i limitations in both liquid and gaseous effluents as was previously  ;

justified, and will make this section of the technical specifications  ;

consistent with the new 10CFR20.

SUMMARY

l The changes in this license amendment request make the CPSES Units 1 and' i 2 Technical Specifications consistent with the new 10CFR20. These j specifications will continue to ensure compliance with 10CFR50.36a, '

10CFR50 Appendix 1, and 40CFR190. The CPSES programs will continue to  ;

result in levels of radioactive materials in effluents being maintained as low as reasonably achievable. As a result, the changes will not  :

increase the types or amounts of effluents that may be released offsite.

l The revisions in the high radiation area definition will result _ in more  !

conservative controls. In summary, these changes will not increase-individual or cumulative occupational radiation exposures. l IV. SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS 5 TV Electric has evaluated whether or not a significant hazards i consideration is involved with the proposed change by focusing on the .

three standards set forth in 10CFR50.92(c) as discussed below- .I Does the proposed change:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed revisions to the liquid and gaseous effluent release limits will not change the type or amount of effluent released nor will there be an increase in individual or cumulative dose. The changes will result in levels of radioactive materials in effluents being maintained ALARA and comply with 10CFR50.36a and 10CFR50 Appendix I. The change to the high radiation area dose measurement distance will ensure that high radiation areas are conservatively posted per 10CFR20.1601(a)(1) and provide controls to minimize individual dose. 'The changes do not impact the operation or design of any plant structure, system or component.

Other proposed changes are administrative only. Therefore, the proposed changes do not involve an increase in the probability or consequences of an accident previously evaluated.

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Attachment 2 to TXX-94045 Page 10 of 11

2) ~ Create the possibility of a new or different kind of accident from l

any accident previously evaluatedi ,

i The proposed changes do not affect the plant design or operation ,

nor do they result in a change to the configuration of any i equipment. No change is proposed that will change the type or i quantity of effluents released off site or change the source terms  !

available for release. Therefore, the proposed changes do not ,

create the possibility of a new or different kind of accident from i any previously evaluated.

3) Involve a significant reduction in a margin of safety?

.f The proposed changes do not change the type or increase the amount of effluents released offsite. No change .n the methodology used to control radioactive waste or radiological environmental ,

monitoring is proposed. Control of radioactive effluents and  !

effluent monitor setpoints will be based on current dose to the  !

public limitations. Under the proposed change, high radiation l area measurements are more conservative and will not result in an  ?

increase in individual or cumulative occupational radiation  !

exposures. Compliance with the limits of the revised 10CFR20.1301 i will be demonstrated by operating within the limits of 10CFR50, i Appendix I and 40CFR190. Therefore, these changes do not reduce'-

the margin of safety. l Based upon the foregoing. TV Electric concludes that the proposed change does not involve a significant hazards consideration. -l V. ENVIRONMENTAL EVALUATION l

The proposed changes to the CPSES Technical Specifications have been f reviewed against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant '

hazards consideration; nor increase the types and amounts of effluents )

that may be released offsite; nor increase the individual or cumulative [

occupational radiation exposures. The proposed effluent concentration j limits requested will allow the liquid and ' gaseous effluent release  !

rates to correspond to the current annual dose limits. Compliance with l the annual dose limits of the new 10CFR20.1301 will be demonstrated by operating within the requirements of 10CFR50, Appendix I and 40CFR190. 1 Accordingly, the proposed Technical Specification changes meet the  !

criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the -

requirement for an Envir onmental Impact Statement. Therefore, pursuant {

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to 10CFR51.2(b), an environmental assessment of proposed' change is not required. I 1

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. 1 Attachment 2 to TXX-94045 Page 11 of 11 l

VI. REFERENCES

1. NUREG-0133, " Preparation of Radiological Effluent Technical -

Specifications f or Nuclear Power Plants, dated October,1978. i

2. NOREG-0800, " Standard Review Plan for the Review of Safety .

Analysis Reports for Nuclear Power Plants," Rev. 2. dated i July 1981.

3. NRC Draft Generic Letter (GL), " Guidance for Modification of Technical Specifications to Reflect ( A) Revisions to 10 CFR Part i
20.

' Technical Specifications on Effluents from Nuclear Power Reactors. (B) Related Current Industry Initiatives, and (f) l Miscellaneous Related Editorial Clarification." FR 58:68170;  :

December 23, 1993.  !

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