ML18153D393

Application for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7 to Implement Revised 10CFR20,revise Frequency of Radiological Effluent Release Repts from Semiannual to Annual & Clarify Site Maps

ML18153D393
Person / Time
Site:	Surry, North Anna
Issue date:	07/16/1993
From:	STEWART W L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18152A047	List: ML18152A046 ML18153D393
References
93-404, NUDOCS 9307230310
Download: ML18153D393 (13)

Text

f \ e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 16, 1993 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No. NL&P/RMN:

Docket Nos. License Nos. NORTH ANNA POWER STATION UNITS 1 and 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES 10 CFR 20 IMPLEMENTATION 93-404 R2 50-280

• 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 Pursuant to 1 O CFR 50.90, the Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Nos. NPF-4, NPF-7, DPR-32 and DPR-37 for North Anna Power Station Units 1 and 2 and Surry Power Station Units 1 and 2, respectively.

The proposed changes will implement the revised 1 O CFR 20, revise the frequency of the radiological effluent release reports from semi-annual to annual, and clarify the site maps. Discussions of the proposed Technical Specifications changes are provided in Attachment 1 for North Anna and Attachment 3 for Surry. The proposed Technical Specifications changes are provided in Attachment 2 for North Anna and Attachment 4 for Surry. It has been determined that the proposed Technical Specifications changes do not involve an unreviewed safety question as defined in 1 O CFR 50.59 or a significant hazards consideration as defined in 1 O CFR 50.92. The basis for our determination that these changes do not involve a significant hazards consideration is provided in Attachment

5. The proposed Technical Specifications changes have been reviewed and approved by the Station Nuclear Safety and Operating Committees and the Management Safety Review Committee.

r 9307230310 930716-PDR ADOCK 05000280 P PDR .[¥10 I \ I t ' ** ... e Should you have any questions or require additional information, please contact us. Very truly yours, 4pcy1~ r_. )N. L. Stewart F Senior Vice President

-Nuclear Attachments cc: U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W. Suite 2900 Atlanta, Georgia 30323 Mr. D. R. Taylor NRC Resident Inspector North Anna Power Station Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219

....... ' 'f,) e T I 'r' I,.,_ ... *~* . ' ,* .* ., COMMONWEAL TH OF VIRGINIA ) ) COUNTY OF HENRICO ) The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon who is Vice President

-Nuclear Operations, for W. L. Stewart who is Senior Vice President

-Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief. Acknowledged before me this \ \.o day of ~\ .. , , 19°\:). \ My Commission Expires: -. f\ \)~ \ , 19 <\ l\ (SEAL) 50-280/281/338/339 VEPCO SURRY & NORTH ANNA PROPOSED TECHNICAL SPECIFICATION CHANGES TO 10 CFR 20 IMPLEMENTATION REC'DD W/LTR DTD 07/16/93 .... 9307230310 -NOTICE-THE *ATTACHED FILES ARE OFFICIAL RECORDS OF THE INFORMATION

& REPORTS MANAGEMENT BRANCH. THEY HAVE BEEN CHARGEO TO YOU FOR A LIMITED TIME PERIOD AND MUST BE RETURNED TO THE CORDS & ARCHIVES SERVICES TION 1'1-22 WHITE FLINT. PLEASE DO NOT SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE FERRED TO FILE PERSONNEL. -NOTICE-

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• Attachment 1 Discussion of Changes North Anna Power Station . ,,.

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• Introduction Discussion of Changes North Anna Units 1 and 2 The proposed changes to North Anna Units 1 and 2 Technical Specifications support the revised 10 CFR 20 regulations for radiation protection published in the Federal Register on May 21, 1991 and the change in radiological effluent reporting requirements published in the Federal.Registeron August.31., 1.992 .. In addition, a proposed change is included for TS 5.1.1 and associated Figure 5.1-1 to correct information for identification of the unrestricted area for gaseous effluents, to replace the site map with a clearer and more legible copy, and to provide consistency in the identification of the site boundary and exclusion area as noted in TS 5.1.1 and Figure 5.1-1. Background The revision of Part 20 to Title 10 of the Code of Federal Regulations ( 10 CFR 20) incorporates advances and developments in radiation protection that have occurred since the original 10 CFR 20 was issued and implements a new philosophy of radiation protection based on the risk assessments and dose methodologies of the International Commission on Radiological Protection (ICRP) 26 and 30. As a result of this rule revision, several administrative changes are being made to Technical Specifications including reference changes to reflect the new 10 CFR 20 and terminology changes and additions associated with the revised rule.

• The proposed changes to the effluent control program section of Technical Specifications are in response to the new dose limits to members of the gener~I public. The revision of Appendix 8, Table II, Columns 1 and 2, unrestricted Maximum Permissible Concentrations (MPC) to the effluent concentration values associated with the new dose limits, which are a factor of ten less than current public dose limits, necessitates changes in the liquid and gaseous release rate limits. These changes will provide the operational flexibility necessary to implement the new 10 CFR 20 requirements.

The proposed Technical Specification changes dealing with the change in radiological effluent reporting frequency are in response to a recent change in NRC regulations.

The requirements in 10 CFR 50.36a have been amended to reduce the frequency for submittal of the Radiological Effluent Release Reports from semiannually to annually.

These administrative changes are described in this proposed Technical Specification change request . North Anna Discussion of Changes 1 L-* r r

• The following proposed Technical Specification changes reduce the frequency of submitting the radiological effluent release report from semiannual to annual: TS 1.17, 6.9.1.9, 6.15.c for Unit 1 and 6.14.c for Unit 2. The revision of 10 CFR 50.36a reduces the frequency for submittal of reports *concerning the quantity of.

• principal nuclides released to unrestricted areas in liquid and gaseous effluents from semiannually to annually.

The time between submittal of the reports must be no longer than 12 months. We understand that the generic letter under development and review by the NRC supporting both the revised 10 CFR 20 and the change in effluent reporting frequency will specify that the Annual Radiological Effluent Release Report must be submitted by April 1 of each.year

... .Thisis.reflected.:in.the

.. proposed .change to TS 6.9.1.9. The following proposed Technical Specification changes are in response to the revised 10 CFR 20: 1. 1.35 -Revise the definition of unrestricted area. 2. 3/4. 7.11 Bases -Delete the old 10 CFR 20 terminology to avoid misinterpretation of the bases for the sealed source contamination limits. 3. 3/4.11.1.4 Bases -Revise the bases for the Liquid Holdup Tank activity limit. 4. 6.8.4.e.2

-Revise the liquid effluent release rate limit. 5. 6.8.4.e.3

-Reflect the relocation of the old 10 CFR 20.106 requirements for liquid and gaseous effluents to the new 10 CFR 20.1302. 6. 6.8.4.e. 7 -Revise the gaseous effluent release rate limit. 7. 6.9.1.5.a-Reflect the relocation of the old 10 CFR 20.407 requirements for annual reports to the new 10 CFR 20.2206 requirements.

8. 6.12.1 -Reflect the relocation of the old 10 CFR 20.203 requirements for high radiation area to the new 10 CFR 20.1601 requirements.

9. 6.14.a.2 for Unit 2 and 6.15.a.2 for Unit 1 -Reflect the relocation of the old 10 CFR 20.106 requirements for determining changes in effluent control to the new 10 CFR 20. 1302 requirements.

In addition, the site map defining unrestricted areas for liquid and gaseous effluents, Figure 5.1-1, is changed to make the identification of the unrestricted area for gaseous effluents consistent with NUREG-0472 and the ODCM . North Anna Discussion of Changes 2 I * *

• Technical Specification Changes 1. TS 1.17, Definition of the Offsite Dose Calculation Manual, refers to the Semiannual Radioactive Effluent*

Release Report. The-word* "Semiannual" is being changed to "Annual." This administrative change is consistent with the -. change in-effluent reporting frequency published -in the Federal Register, Vol. 57, No. 169, August 31, 1992 2. TS 1.35, Definition of Unrestricted Area, is being revised to adopt the new 10 CFR 20 definition for Unrestricted Area. The new definition is based on access not being limited or controlled by the licensee.

3. TS 3/4. 7 .11, Bases for Sealed Source Contamination, is being revised to delete the third sentence in the paragraph description of the bases for sealed source contamination.

The information contained in this sentence includes internal dose terminology, i.e., "maximum permissible body burden" from ICRP 2 which the internal exposure limits in the old 10 CFR 20 were based upon. The revised 10 CFR 20, which implements the guidance of ICRP 26 and 30, has eliminated this term from the regulation.

The bases for sealed source contamination is 10 CFR 70.39(c) which contains limits for plutonium which has not been affected by the 10 CFR 20 revision.

4. The proposed change to the activity limit bases for the Liquid Holdup Tanks addressed in TS 3/4.11.1.4, Bases for Liquid Holdup Tanks, revises the reference to the acceptance criteria contained in the revised 10 CFR 20. 5. TS 5.1.1, Exclusion Area, states that the exclusion area, which is a 10 CFR 100 term, is defined in Figure 5 .1-1. The map defining unrestricted areas for radioactive gaseous and liquid effluents, which is illegible, identifies the site boundary only. Since for North Anna the exclusion area and site boundary are the same location and in order to ensure consistency between TS 5.1.1 and Figure 5.1-1, the exclusion area is included in Figure 5.1-1 in addition.

to the site boundary designation.

This is an administrative change. 6. Figure 5.1-1 defines the area outside the security fence as unrestricted for gaseous effluents.

Based upon NUREG-0472, the Offsite Dose Calculation Manual and section 2.1.2 of the UFSAR, the unrestricted areas are defined for gaseous effluents at or beyond the site boundary.

In order to be consistent with the gaseous effluent dose calculations performed for the member of the public atsite boundary, which are based on continuous occupancy, i.e., access is not limited or controlled by the licensee, Figure 5. 1-1 is being revised to show that the unrestricted area for gaseous effluents is at or beyond the site boundary rather than at the security fence. Gaseous effluent dose calculations are not performed for individuals accessing areas between the security fence, North Anna Discussion of Changes 3

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• which is the boundary for the Protected Area and restricted area, and the site boundary.

7.

• The proposed change to the liquid*effluent release-rate limit in TS 6.8.4.e.2,is being made in order to accommodate needed operational latitude to facilitate implementation of the revised 10 CFR 20 requirements.

The limitations on liquid effluent concentrations in unrestricted areas is being changed from the current Maximum Permissible Concentration (MPC) values in 10 CFR 20, Appendix B, Table II, Column 2 to 10 times the effluent concentration values in 10 CFR_20, Appendix B, Table 2,_Column.

2. _The.Jigure

.. has .been redrawn for improved legibility.

8. The reference to the old 10 CFR 20.106 is being changed to the new 10 CFR 20.1302 in TS 6.8.4.e.3.

This administrative change is being made to reflect the fact that the requirements in the old 10 CFR 20. 106 are now located in the new 10 CFR 20. 1302. 9. The proposed change to the gaseous effluent dose rate limits in TS 6.8.4.e. 7 is being made to provide needed operational latitude in accordance with the revised 10 CFR 20 requirements.

The limitations on the dose rate resulting from gaseous .. effluents to areas at or beyond the site boundary is being changed from associated doses corresponding to the unrestricted airborne MPC values in 10 CFR 20, Appendix B, Table II, Column 1 to the following dose rate limits: for noble gases, dose rates of 500 mrem/yr to the total body and 3000 mrem/yr to the skin and for 1-131, 1-133, H-3, and particulate nuclides with half-lives greater than 8 days, dose rate of 1500 mrem/yr to the critical organ. 10. Footnote 2 to TS 6.9.1.5 references the old 10 CFR 20.407 requirements for submitting the annual exposure report to the NRC. The reference is being changed to reflect the new 10 CFR 20.2206 requirements.

This administrative change supports the relocation of the old 10 CFR 20.407 requirements to the new 10 CFR 20.2206. 11. TS 6.9.1.9, the word "Semiannual" is being changed to "Annual" in the title of this section. The frequency for submitting the Annual Radiological Effluent Release Report is being revised to reflect the April 1 submittal date of each year and the applicable reporting period for the previous calendar year rather than the previous six months. 12. TS 6.12.1 references the old 10 CFR 20.203(c)(2) for control requirements for a high radiation area. This reference is being changed to 10 CFR 20.1601 (a)(1 ). This administrative change supports the relocation of high radiation area control requirements from the old 10 CFR 20.203(c)(2) to the new 10 CFR 20.1601 (a)(1 ) . North Anna Discussion of Changes 4

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• 13. The reference to 10 CFR 20.106 in TS 6.14.a.2 for Unit 2 and TS 6.15.a.2 for Unit 1 is being* changed to 10 CFR 20. 1302. This administrative change is being made because the effluent control. requirements in the old 10 . CFR 20. 106 are now located in the new 10 CFR .20. 1302. 14.

• TS 6.14*:c forUnit 2 and TS 6;-15.c for* Unit 1 refer to the Semiannual Radioactive Effluent Release Report. The word "Semiannual" is being changed to "Annual." This administrative change is being made in support of the change in effluent reporting frequency.

Safety Significance A safety evaluation has been performed for this proposed Technical Specification change request. These Technical Specification changes do not 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 offsite. As a result, this proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Concerning the change in the activity limit bases for the Liquid Holdup Tanks, currently, the Liquid Holdup Tank curie limit is based on that quantity which would not exceed the Maximum Permissible Concentration (MPC) limits of 10 CFR 20, Appendix B, Table II, Column 2 at the nearest potable water supply, if the tank and components should fail, or will be limited to 10 curies. In order to allow for sufficient operational flexibility, the new Liquid Holdup Tank curie limit is based on that quantity which would not exceed 10 times the effluent concentration values of 10 CFR 20, Appendix B, Table 2, Column 2 at the nearest potable water supply if the tank and components should fail, or will be limited to 10 curies. Since a higher activity limit can be determined based on 10 times the effluent concentration values, it is conservative to retain the current activity limit of 10 curies. Maintaining the activity limit at 10 curies is also consistent with the guidance of NUREG-0133, which states that the curie limit for a Liquid Holdup tank should be limited to less than or equal to 10 curies, excluding tritium and dissolved or entrained noble gases. Proposed changes to the liquid effluent release rate limits are required to accommodate operational flexibility.

The basic requirements for Technical Specifications concerning effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with effluent Technical Specifications will maintain average annual releases of radioactive material in effluents to small percentages of the limits specified in the old 10 CFR 20. 106 and the new 10 CFR 20.1301. These requirements permit operational flexibility that is compatible with considerations of health and safety, including releases which are temporarily higher than the small percentages of average annual release rates, but still within the North Anna Discussion of Changes 5

l.

• limits specified in the old 10 CFR 20.106 which reference Appendix B, Table II MPC limits. These referenced concentrations are specific values which relate to an annual . dose of 500 mrem. It is further indicated in 10 CFR 50.36a that when using operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents as low as is reasonably achievable (ALARA) as set forth in 10 CFR 50, Appendix I. As stated in the Introduction to Appendix B of the revised 10 CFR *20, the liquid

• effluent concentration values given in Appendix B, Table 2, Column 2, are based on an integrated dose of 50 mrem in a year .. Since a . .release.concentration corresponding to a limiting instantaneous dose rate *of 500 mrem/year has been acceptable as a Technical Specification

• limit for liquid effluents, which applies at all times, as an assurance that the limits of 10 CFR 50, Appendix I, are not likely to be exceeded, it should not be necessary to reduce this limit by a factor of 10. Operational history at North Anna Units 1 and 2 has demonstrated that the use of the *****unrestricted

--MPC . .limits .. associated with the old 10 CFR 20.106 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 10 CFR 50, Appendix I. Therefore, the use of concentration values which correspond to an instantaneous dose rate of 500 mrem/year, which is 10 times the concentration values stated in the revised 10 CFR 20, Appendix B, Table 2, Column 2, should not have a negative impact on the ability to continue to operate within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations.

As discussed above, the concentrations stated in the revised 10 CFR 20, Appendix B, Table 2, Column 2, relate to a dose of 50 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem/year.

Because monitor sensitivity and background must be considered, it is impractical to use such a low value for liquid effluent monitor setpoints.

Therefore, to accommodate operational flexibility needed for effluent releases, the limits associated with the liquid concentration limits in TS 6.8.4.e.2 are based on 10 times the effluent concentration values stated in the revised 10 CFR 20, Appendix B, Table 2, Column 2, to apply at all times. The multiplier of 10 is proposed because the annual dose of 500 mrem, upon which the concentrations in the old 10 CFR 20, Appendix 8, Table II, Column 2, are based, is a factor of 10 higher than the annual dose of 50 mrem, upon which the concentrations in the revised 10 CFR 20, Appendix B, Table 2, Column 2, are based. Compliance with the limits of the new 10 CFR 20. 1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190. Proposed changes to the gaseous effluent dose rate limits is required to accommodate operational latitude under the revised 10 CFR 20. The basic requirements for North Anna Discussion of Changes 6

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• Technical Specifications concerning effluents from nuclear power reactors are stated in 10 CFR 50.36a. These requirements indicate that compliance with the effluent Technical Specifications will maintain average annual *releases of radioactive material in effluents to small percentages of the limits specified*-in the old* 10 CFR 20. 106 and the new 10 CFR 20.1301. These requirements permit operational flexibility consistent with considerations of health and safety, *which-may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10 CFR 20.106 which reference Appendix B, Table II MPC limits. These referenced concentrations are specific values which relate to an annual dose of 500 mrem. ltis further indicated in 10 CFR.50.36athat when using.operational flexibility, best efforts shall be exerted to keep levels of radioactive materials in effluents ALARA as set forth in 10 CFR 50, Appendix I. As stated in the Introduction to Appendix B of the revised 10 CFR 20, the gaseous effluent concentration values given in Appendix B, Table 2, Column 1, are based on an annual dose of 50 mrem for isotopes for which inhalation or ingestion are limiting --or-100 mrem. for.isotopes.

for which submersion (noble gases) is limiting.

Release concentrations corresponding to limiting dose rates less than or equal to 500 mrem/year to the whole body, 3000 mrem/year to the skin from noble gases, and 1500 mrem/year to any organ from 1-131, 1-133, H-3 and all radionuclides in particulate form with half-lives greater than 8 days at the site boundary have been acceptable as a Technical Specification limit for gaseous effluents to assure that the limits of 10 CFR 50, Appendix I and 40 CFR 190 are not likely to be exceeded.

Therefore, it should not be necessary to restrict the operational flexibility by incorporating the dose rate associated with the gaseous effluent concentration values for isotopes based on inhalation or ingestion (50 mrem/year) or the dose rate associated with the gaseous effluent concentration values for isotopes based on submersion (100 mrem/year).

Sufficient operational flexibility is especially important in establishing a basis for effluent monitor setpoint calculations.

As discussed above, the concentrations stated -in the revised 10 CFR 20, Appendix B, Table 2, Column 1, relate to a dose of 50 mrem or 100 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem or 100 mrem in a year. Use of these low values are impractical as a basis for gaseous effluent monitor setpoint calculations for many situations when monitor -background, monitor sensitivity, and monitor performance must be taken into account. Operational history at North Anna Units 1 and 2 has demonstrated that the use of the dose rate limits of 500 mrem/year, 3000 mrem/year, and 1500 mrem/year as Technical Specification limits has resulted in calculated maximum individual doses to members of the public that are small percentages of the limits of 10 CFR 50, Appendix I and 40 CFR 190. Therefore, to accommodate operational flexibility needed for gaseous effluent releases, the limits associated with the gaseous release North Anna Discussion of Changes 7

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• rates listed in the Offsite Dose Calculation Manual (ODCM) will be maintained at the current instantaneous dose rate limit for noble gases of 500 mrem/year to the whole ,body and 3000 mrem/year to the skin; and for 1-131, 1-133, H-3, and all radionuclides in particulate form with half-lives greater that 8 days, an instantaneous dose rate limit of 1500 mrem/year to any organ. Compliance with the limits of the new 10 CFR 20.1301 will be demonstrated by operating within the limits of 10 CFR 50, Appendix I and 40 CFR 190 . North Anna Discussion of Changes 8