View source for U-602099, Forwards Supplemental Info to 921016 Application for Amend to License NPF-62,per Addl Guidance Provided by NRC to Support Implementation of New 10CFR20 Requirements Covering Liquid & Gaseous Release Rate Limits

{{Adams
| number = ML20128M668
| issue date = 02/17/1993
| title = Forwards Supplemental Info to 921016 Application for Amend to License NPF-62,per Addl Guidance Provided by NRC to Support Implementation of New 10CFR20 Requirements Covering Liquid & Gaseous Release Rate Limits
| author name = Perry J
| author affiliation = ILLINOIS POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000461
| license number = 
| contact person = 
| document report number = JSP-071-93, JSP-71-93, U-602099, NUDOCS 9302220245
| package number = ML20128M672
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 9
| project = 
| stage = Supplement
}}

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        '                                                                    llhnois Power Company Chnton Power Stakin
* P O Dos 670 Chnton. IL 61727 Tel 217 935 6??6 J. Stephen Perry Wce Pre!. cent U-602099 POWER                                                        U47 93(02-17 )-LP 8E.100a JSP-071-93 February 17, 1993 10CFR50.90 Docket No. 50 461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Clinton Power Station Supplement to Proposed Amendment of Facility Operatipt License No. NPF 62

==Dear Sir:==

By letter d.ated October 16, 1992, Illinois Power (IP) applied for amendment of the Clinton Power Station (CPS) Technical Specifications to support CPS compliance with the new requirements of Title 10 Code of Federal Regulations Part 20. The proposed changes are necessary to reflect implementation of the CPS Radiation Protection Program in accordance with 10CFR20.1101.
Subsequent to IP's application for amendment, the NRC provided IP with additional guidance on necessary revisions to the Technical Specifications to support implementation of the new 10CFR20 requirements. IP is therefore providing a supplement to its October 16, 1992 Technical Specification amendment request to address the additional guidance on liquid and gaseous release rate limits, high radiation areas and annual report requirements.
A description of the proposed changes and the associated justifications (including a Basis for No Significant Hazards Consideration) are provided in Attachment 2. A marked-up copy of the affected pages from the current Technical Specifications are provi6ed in Attachment 3. For convenience, the attached Technical Specification pages include the changes which were originally requested and thus replace in their entirety the marked-up pages provided in IP's October 16, 1992 amendment request.         In addition, an affidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.
1901G0 3 l 9302220R45 PDR 930217                                                               '
P ADOCK 05000461                                                           '
PDR

Page 2 of 2
* to U 602099 The supporting environmental impact analysis is also provided in Attachment 2. Based upon the evaluation provided, IP has determined that pursuant to 10CFR51.22(c)(9), the proposed license amendment can be categorically excluded from the requirement for an environmental impact statement.
As stated in its October 16, 1992 amendment request, IP is currently scheduled to fully implement the requirements of the revised 10CFR20 on April 1, 1993. Therefore, IP requests that the license amendment, including the attached supplement, be approved prior to April 1, 1993, but not be required to be implemented until that date.
Sincerely yours,
                                                            . S. Perry nior Vice   sident TAB /msh Attachments cc:   NRC Clinton Licensing Project Manager NRC Resident Office, V 690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety

1 i
      .                                                                                   Attachtsnt 1 to U.602099 4
STATE OF ILLINOIS COUNTY OF DEWITT J. Stephen Perry, being first duly sworn,- deposes and says: .That he is Senior Vice President of Illinois Power Company; - that the c.pplication for amendment of Facility Operating Licens'e NPF 62.has been prepared under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said application and the facts contained therein are true and correct.
DATED:       This    I "7     day-'of February 1993 Signed;                          b          As Q
()         T-Subscribed and sworn to before me this /fMday of February 1993.
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9           . Linda S. Frencli -          ,
Notary Public. State of Ilinois '    s 4[ My Comminion Expires 9/1/96- [
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Attachment 2' to U 602099 i                                                                                                                   _Page 1 of 6
!                                                                                                                  LLS-92-001 3'
l                     Background and Description or Propor.ed Chane.es 4
On May 21, 1991, the Nuclear Regulatory Commission (NRC) issued a j                     revision to its standards for protection against ionizing radiation,                                                      j j                     10CFR Part 20. Revised Part 20 became effective on June 20, 1991 and                                                      '
j                     requires implementation on or before January 1,1994                                      Illinois Power j                     (IP) plans to implement the new 10CFR20 requirements on April 1 1993 4
and in support of this implementation schedule IP submitted proposed j                     changes to the CPS Technical Specifications in a letter (U-602052)-dated October 16, 1992.
Subsequent to IP's application for amendment, If participated in l                     discussions with the NRC on the content of generic guidance currently j                     being developed to support licensees ~in the implementation of 10CFR20 1                     and 10CFR50.36a as recent'.y amended. Based on the recommendations of the NRC, IP is supplementing its October 16, 1992 amendment request to' incorporate some of the generic guidance which was not included in the
;                     original submittal, i                     In accordance with 10CFR50.90, the followingichanges to the CPS
,                     Technical.Spacifications are being proposed in addition to those identified in the previously submitted amenument request:
J
.                     1.         Technical Specification 6.8.4.f.2 is being revised to read as
;                                follows:
{                                              "2. Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED 1
AREAS conforming to ten times the concentration values
}                                                      in 10CFR Part'20.1001 - 20.2401, Appendix B, table 2, i
column 2;"
i
: 2.         Technical Specification 6.8.4.f.7 is being revised to read as
;                                follows:
.                                              "7,     Limitations on the dose rate resulting from radioactive material released in gaseous effluents i                                                      from the site to areas at or beyond the SITE BOUNDARY i
shall be limited to the following:
: a. For noble gases: Less than or equal to 500 mrem /yr to the total body.and less than or equal to 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 1500 mrem /yr to any organ;"
1-                    3.         Technical Specification 6.9.1.5.a is being' revised ~to11ndicate
                               - that the annual tabulation of individuals receiving; greater than 100 mrem /yr. includes only those individuals for whom monitoring-was required.
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    ,                                                                     Attachment 2 to U-602099 Page_2 of 6
                                                                         -LS-92 001
: 4.      Technical Specifications 6.12.2 and 6.12.3 are being revised to delete " equivalent" (which was added in the previous IP amendment request) from_the term " dose equivalent"'and to identify the maximum dose associated with a high radiation area.
: 5.       Note "**" of Technical Specifications 6.12.2 and 6.12.3 is being revised to read as follows:
                        "** Measurements made at 30 cm (12 inches) from sources of rad'.oactivity."
(The footnote "*" in Technical Specification 6.12.3 is being replaced with footnote "**" as described in a separate amendment request                        '
submitted in a letter dated Octobar 16, 1992.        This change is included in this letter to provide clarification.)
Justification For Proposed Chances The basic requirements for Technical Specifications concerning effluents from nuclear power reactors are_ stated in 10CFR50.36a. These requirements indicate that compliance with effluent Technical Specifications will keep average annual releases of radioactive material in effluents to small percentages of the limits specified in the old 10CFR20.106 (new 10CFR20.1302). 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 10CFR20.106,     10CFR20.106 in turn refers to Appendix B. Table II, which-provides concentration limits for airborne and liquid effluents. The specified concentration limits are. specific values which ralate to an annual dose of 500 mrem. In addition, 10CFR50.36a states that when using operational flexibility, best efforts shall be exerted -
to keep levels of radioactive materials in effluents asilow as is reasonably achievable (ALARA) as set forth in 10CFR50, Appendix I.
Liould Effluents - (Technical Specification 6.8.4.f.2).
As stated in the. Introduction to Appendix B of;the_new 10CFR20, the liquid effluent concentration _ limits given in Appendix B, Table 2, Column 2, are based on an annual dose ~of 50 mrem. Since a release-
        - concentration corresponding' to a- limiting dose rate of 500 mrem / year has been acceptable as.a Technical Specification limit for liquid effluents under the old Part 20 it should not be necessary to reduce this limit by a factor of ten.
Operational history at CPS 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 limits of .
10CFR50, Appendix 1. Therefore, the use of concentration values which correspond to an annual 1 dose of 500 mrem (ten times the concentration values stated in the new 10CFR20, Appendix B, Table 2, Column 2) should-

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1 Attachment 2 1       ..
* to U-602099 Page 3 of 6 LS-92 001
 )  '
not have a negative impact on the ability to continue to operate within the limits of 10CFR50, Appendix I and 40CFR190.
As discussed above, the concentrations stated in the new 10CFR20,
 !                 Appendix B. Table 2, Column 2, relate to a dose of 50 mrem in a year.
f When applied on an instantaneous basis, this corresponds to a dose rate i                  of 50 mrem / year.        It is impractical to base effluent monitor setpoint 4                  calculations for many liquid effluent release situations on this low
;                  value when monitor background, sensitivity, and performance must be
;                  taken into account. Therefore, to accommodate operational flexibility j                  needed for effluent releases, the limits associated with the liquid                          -
release rate are being revised to indicate ten times the concentrations                           -
stated in the new 10CFR20, Appendix B Table 2, Column 2.                                            The j                  multiplier of ten is proposed because the annual dose of 500 mrem, upon f                  which the concentrations in the old 10CFR20, Appendix B. Table II, 3                  Column 2 are based, is a factor of 10 higher than the' annual dose of 50 mrem, upon which the concentrations in the new 10CFR20, Appendix B, Table 2, Column 2 are based. The proposed change will retain operational flexibility consistent with 10CFR50 Appendix I, concurrent with the implementation of the revised 10CFR Part 20.
)                  Gaseous-Effluents - (Technical Specification 6.8.4 f.7)
Technical Specification 6.8.4.f.7 provides for a program which ensures 4                  the dose from gaseous effluents a t anytime, at and beyond the site boundary, will be within the annual dose limits for unrestricted areas 1
as specified by 10CFR20.                   The current annual dose limits are the doses associated with the concentrations in 10CFR20, Appendix B, Table II, Column 1 (10CFR20.106). These limits provided reasonable assurance that radioactive material discharged in gaseous effluents would not result in the exposure of a member of the public in an unrestricted area, either l                  within or outside of the site boundary, to annual average concentrations
;                  exceeding the limits specified in Appendix B, Table 11 of 10CFR20 (10CFR20.106(b)).          The CPS Offsite Dose Calculation Manual'(ODCM) currently specifies release rate limits which restrict', at all times, i                  the corresponding gamma and beta-dost rates above background' to a member of the public, at or beyond the-site boundary, to less than or-equal to 500 mrem / year to the whole body or to less than or-equal to 3000 mrem / year to the skin.            These release rate limits also-restrict, at all
}                  times, the correspor. ding thyroid dost rate above background to a child                             -
i via the inhalation pathway to less than or equal te 1500 mrem / year.
,                  The basis for the instantaneous release rate limits for gaseous releases-4 did not change with the revised 10CFR20. The instantaneous limits are based on a whole body dose limit of 500 mrem / year and a thyroid dose limit of 1500 mrem / year for gaseous releases and are imposed on
,                  licensees as a control to ensure that' licensees meet 10CFR50 Appendix I requirements. Appendix I of 10CFR50 and 10CFR50.36a were not revised as part of the 10CFR20 revision. .Therefore, for purposes of. maintaining effluent releases ALARA pursuant to 10CFR50.36a and 10CFR50., Appendix I, power reactor licensees-are restricted to instantaneous. limits as currently defined.
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Attachment 2
           .                                                                                             to U-602099 1
Page 4 of 6 LS 92 001:-
: i.               The proposed Technical Specification change does not revise the dose rate limits as identified in the Technical Specifications and implemented by the CPS ODCM. Based on the recommendation of the NRC, the proposed change deletes the reference to 10CFR20 Appendix B, Table 2 and instead explicitly identifies the instantaneous dose rates. This
;                 change vill help ensure CPS compliance with 10CFR50.36a and 10CFR50 Appendix 1. The proposed change to the Technical Specification is consistent with the CPS ODCM.
i                 High Radiation Area -(Technical Specification 6.12)
The revised 10CFR20 provides a new definition of a high radiation area j                 which is based on a radiation level measurement made at 30 cm.
;                 Therefore, the measurement distance identified in Technical
:                 Specification 6.12 footnote "**" is bein5 changed from 18_ inches to 30 cm (which is equivalent to 12 inches) to be consistent with
.                 10CFR20.1601(a)(1). This represents a conservative change _ since 30 cm 4
is a shorter distance than 18 inches.                      Implementing this change will j                 therefore-result in higher dose measurements and more conservative i                 identification of high radiation areas.
}                 The revised 10CFR20 also requires that additional controls be in place to prevent unauthorized or inadvertent access to very high radiation areas. Very high radiation areas are those areas where radiation levels could be 500 rads or more in one hour at one meter from a radiation
;                 source. Therefore, the Technical Specifications identifying controls on access to high radiation-areas are being revised to acknowledge the new upper limit (500 rads) on the determination of a high radiation area.
This will ensure that the measures which are adequate for controlling access to high radiation areas are not used for very high radiation
 ~
areas which require much more stringent control. This-change will ensure individuals are not exposed to potentially lethal doses as a-result of insufficient controls on access to a very high radiation area.
This change will ensure that the CPS programs for controlling access to
;                 high radiation areas recognize the requirements for very high radiation
[                 areas.
{                Annual Report - (Technical Specification 6.9.1.5) l-                Technical Specification 6.9.1.5 requires a report to be submitted
,                 annually which includes a tabulation of individuals receiving exposures
!                _ greater than-100 mrem /yr and their associated man-rem-exposure according to work and job functions. ' Since the revised 10CFR20 only requires.
monitoring for certain individuals as defined in 10CFR20.1502, Technical Specification 6.9,1.5.a is being revised to clearly identify the individuals who are tabulated in the annual report. - This is jul administrative change which provides clarification and-consistency i
between all reporting requirementa. This change will not alter any of
;_                IP's requirements or responsibilities-for protection of the public and                                                           ;
,                 employees against radiation hazards.                                                                                             I 1
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?           -
LS 92-001 Basis for No Sinnificant Hazards Consideration
;          In accordance with 10CFR50.92, a proposed change to the Operating
;         License (Technical Specifications) involves no significant hazards considerations if operation of the-facility in accordance with the proposed change would not:        (1) involve a significant increase in the probability or consequences of any 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.       The propos0d change is evaluated against each of
;         these criteria below:
I          (1)     The proposed revisions to the liquid and gaseous release rate limits will not result in a change in the types or amounts of effluents released nor will there be an increase in individual or cumulative radiation exposures.       In addition, these changes do not impact the operation or design of any plant structures, systems or
;                  components. These changes ensure compliance with 10CFR50.36a and 10CFR50 Appendix I and result in levels of radioactive materials in effluents being maintained ALARA, The revision tc the high radiation area controls and dose measurement distance will ensure araas are conservatively posted as high radiation area in j                  compliance with 10CFR20.1601(a)(1) and provide controls to ensure individuals are not overexposed. This change will not result in a i                  change to plant design or operation. Therefore, it can be                    "
concluded that the proposed changes do not involve an increase in
!                  the probability or consequences of an accident previously
;                  evaluated.
(2)     The proposed changes do noc affect the plant design or operation nor do they result in a change to the configuration of any equipment. There will be no change-in types or increase in the amount of effluents released off-site. As a result, this proposed change cannot create the possibility of a new or'different kind of j                  accident from any previously evaluated.
I j          (3)     The proposed revisions do not involve any change in the types or increase in the amount of effluents released off-site.         The proposed changes do not involve any actual change in the methodology used in the control of-radioactive wastes'or radiological environmental monitoring. The methodology that-will i
i                  be used in the control of radioactive effluents and calculation of
                  . effluent monitor setpoints 'will result 'in the same effluent-release rate as the current methodology now being used. The operational flexibility needed for effluent releases allows the
,                  use of limits as proposed. In addition, the changes-in measurement distances for determination of high radiation areas
                  .will not result in an increase in individual or cumulative occupational radiation exposures since it will result'in a more conservative ide tification of high radiation areas. Compliance with the limits oC the new 10CFR20.1301 will be demonstrated by operating within the limits of 10CFR50 Appendix I and 40CFR190.
Therefore, these. changes cannot reduce a margin of safety.
l

t Attachment 2
          .                                                                                             to U 602099 Page 6 of 6 LS 92-001:
;             Based upon the foregoing, IP concludes that these proposed changes do-not involve a significant hazards consideration.                                                                    j Environmental Impact Analysis
  .           The proposed changes to CPS Technical Specifications have been reviewed i             against the criteria of 10CFR51.22 for environmental considerations.
l             The proposed char.ges do not involve a significant hazards consideration;
,             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 limits requested will allow the liquid and gaseous effluent release rates to l             correspond to the current annual dose limits. Compliance with the d
annual dose limits of the new 10CFR20.1301 will be demonstrated by s             operating within the limits of 10CFR50 Appendix I and 40CFR190.
l             Therefore, the proposed Technical-Specification changes meet the
.             criteria given in 10CFRSI.22(c)(9) for a categorical exclusion from the
!             requirement far an Environmental Impact Statement.
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