ML18152A046

Proposed Tech Specs Implementing Revised 10CFR20,revise Frequency of Radiological Effluent Release Repts from semi-annual to Annual,& Clarify Site Maps

ML18152A046
Person / Time
Site:	Surry, North Anna
Issue date:	07/16/1993
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18152A047	List: ML18152A046 ML18153D393
References
NUDOCS 9307230320
Download: ML18152A046 (46)

Text

Attachment 2 Technical Specifications Changes North Anna Power Station

• ~307230320-930716- 1/\

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1.0 DEFINITIONS (Continued)

OFFSITE DOSE CALCULATION MANUAL (ODCM) 1: 17 The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain:the methodology and parameters used in. the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm/trip setpoints, and in the conduct of -the -Environmental Radiological Monitoring *Program. The* ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Monitoring Programs required by Section 6.8.4 and (2) descriptions of* the information that should . be included in the Annual *Radiological *-Environmental Operating and Annual Radioactive Effluent ..

Release Reports required by Specifications 6.9.1.8 and 6.9.1.9.

• OPERABLE - OPERABILITY 1.18 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system,

. subsystem, train, component, or device to perform its function(s) are also capable of performing their..related support function(s).

OPERATIONAL MODE - MODE 1 .19 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power. level, and average reactor coolant temperature specified in Table 1.1.

PHYSICS TESTS 1.20 PHYSICS TESTS shall be those tests performed to measure the fundamental -nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under the provisions of 1O CFR 50.59, or 3) otherwise approved by the Commission.

PRESSURE BOUNDARY LEAKAGE 1.21 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall.

PROCESS CONTROL PROGRAM 1.22 The PROCESS CONTROL PROGRAM (PCP) shall contain-the current-formulas, sampling, analyses, tests and determinations to be made to ensure that the processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 1O CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of the radioactive waste.

PURGE - PURGING 1 .23 PURGE or PURGING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is required to purify the confinement.

NORTH ANNA - UNIT 1 1-4 Amendment No.

' ' 1.0 DEFINITIONS (Continued)

STAGGERED TEST BASIS 1 . 3 2 .. A STAGGERED TEST BASIS shall consist of:

a A test schedule for n systems, subsystems, trains or other designated components obtained by dividing the specified test interval into n equal subintervals,

b. The testing of one system, subsystem; train or other. designated component. at.the beginning of each subinterval.

THERMAL POWER

., .1.33 "THERMAL POWER shall.be the-total.reactor core heat transfer rate . to.the reactor coolant...

UNIDENTIFIED LEAKAGE 1 .34 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE.

,., ***UNRESTRICTED AREA 1 .35 An UNRESTRICTED AREA shall be any area, access to which is neither limited nor.

controlled by the licensee.

VENTILATION EXHAUST TREATMENT SYSTEM 1.36 A VENTILATION EXHAUST TREATMENT SYSTEM is the system designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents).* Engineered Safety Feature (ESF) atmospheric cleanup systems are not.considered to be VENTILATION EXHAUST TREATMENT SYSTEM components .

... ,VENTING 1 .37 VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process.

NORTH ANNA - UNIT 1 1 -6 Amendment No.

' y PLANT SYSTEMS BASES The service life of a snubber is evaluated via manufacturer input and information through consideration of the snubber service conditions and associated installation and- maintenance records (newly installed snubber, seal replaced, spring replaced, *in high radiation area, in high temperature area, etc ... }. The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age

• *and operating conditions. -- These records will provide statistical* bases -for .future consideration of snubber service life. The requirements for the maintenance of records and the snubber

• service life review are not intended to affect plant operation.

, . 3/4:7. 11 SEALED SOURCE CONTAMINATION The limitations on sealed source removable contamination ensure that the total body or individual organ irradiation does not exceed allowable limits in the event of ingestion or inhalation of the source *material. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 1 O CFR 70.39(c} limits for plutonium. Sealed sources are classified into three groups according to their use, with

'surveillance requirements commensurate with the probability of damage to a source in that group. Those sources which are frequently handled are required to be tested more often than those which are not. Sealed sources which are continously enclosed within a shielded mechanism (i.e., sealed sources within radiation monitoring or boron measuring devices} are considered to be stored and need not be tested unless they are removed from the shielded mechanism.

NORTH ANNA - UNIT 1 B 3/4 7-7 Amendment No.

. '

• RADIOACTIVE STORAGE 3/4:11.1 LIQUID STORAGE

. BA.SES

.3/4,11,1.4 LIQUID HOLDUP TANKS The tanks listed in this Specification include all those outdoor tanks that are not surrounded .

by liners, dikes, or walls capable of holding the tank contents *and that *do-not have tank*

• , overflows and surrounding *area *drains connected -to the liquid ,radwast~ treatment system ..

• • ,-Restricting the quantity of. radioactive material .contained in the specified .tanks provides:..

• assurance 'that in* the *event*of *an *uncontrolled release of the tanks' . contents, the resulting-concentrations would be less than ten times the limits of 1 O CFR Part 20; Appendix B, Table 2, . I Column 2, at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA.

Specifications 3/4.11.2.1 through 3/4.11.2.4 have been deleted.

NORTH ANNA - UNIT 1 B 3/4 11-2 Amendment No.

5.0 DESIGN FEATURES 5.1 SITE EXCLUSIOO AREA 5.1.1 The exclusion area (site boundary) shall be as shown in Figure 5.1-1 .

.LOW POPULATION ZONE 5.1.2 The low population zone shall be as -shown in Figure 5.1-2 .

.MAP DEFINING UNRESTRICTED AREAS FOR RADIOACTIVE GASEOUS'AND LIQUID EFFLUENTS 5.1.3

• Information regarding . radioactive -gaseous .and liquid effluents, which

• allows

• • • *identification *of structures -and release points as weir as definition of UNRESTRICTED AREAS within the SITE BOUNDARY that are accessible to MEMBERS OF THE PUBLIC, shall be as shown in Figure 5.1-1.

5.2 CONTAINMENT CONFIGURATION 5.2.1 The reactor containment building is a steel lined, reinforced concrete building of cylindrical shape with a dome roof and having the following design features:

a. Nominal inside diameter = 126 feet.

b. Nominal inside height = 190 feet, 7 inches.

c. Minimum thickness of concrete walls = 4.5 feet.

d. Minimum thickness of concrete roof = 2.5 feet.

e.

• Minimum thickness of concrete floor pad = 1O feet.

. f.

• Nominal thickness of the cylindrial portion of the steel liner = 3/8 inches.

g. Net free volume = 1.825 x 106 cubic feet.

h. Nominal thickness of hemispherical dome portion of the steel liner = 1/2 inch.

NORTH ANNA - UNIT 1 5-1 Amendment No.

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z z)> X Gaseous Releases

1. Process Vent - 157.5 Ft.

C 2. Vent - Vent A & B and other z release points considered

-; ground level releases.

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0 Liquid Release to the Discharge Canal A Liquid Release to the Unrestricted Area

• • *

• Buoy Barriers Site Boundary - Area at or beyond which is unrestricted for gaseous effluents.

Land Maximum Member of the Public Occupancy = 336 hrs/year 01 I I\) Lake Maximum Member of the Public Occupancy = 2232 hrs/year

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a. Site Boundary Figure 5.1.1 3

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, Map Defining Unrestricted

.......... Areas for Radioactive Gaseous 0 .................... and Liquid Effluents

-- --

SV644C

ADMINISTRATIVE CONTROLS

e. Radioactive Effluent Controls Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE.PUBLIC from radioactive effluents as low as reasonably achievable.

• The program (1) shall be

• • contained in -the ODCM, (2)-shall- be-implemented-by operating procedures, and (3) shall include -remedial actions to be taken whenever the program limits are exceeded.

'The program shall include the following elements:

1 ) Limitations on the operability of radioactive -liquid and gaseous monitoring instrumentation including surveillance .tests and ..-setpoint -determination in

• • accordance with the methodology in the ODCM,

-- 2 ) Limitations on the concentrations of radioactive material .released in liquid effluents to UNRESTRICTED AREAS conforming to ten times 1O CFR Part 20, Appendix B, Table 2, Column 2, 3 ) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM, 4 ) Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR Part 50,

5) Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, 6 ) Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 1O CFR Part 50, 7 ) Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at or beyond the SITE BOUNDARY shall be limited 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 lodine-131,

• lodine-133, Tritium, and 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 .

• NORTH ANNA - UNIT 1 6-13b Amendment No.

' .

ADMINISTRATIVE CONTROLS ANNUALREPOR,:s1/

6.9.1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted .prior. to March 1 of each year. The initial -report* shall be submitted prior -to March 1 *of the year following initial criticality.

6.9.1.5 Reports required on an annual basis shall include:

a. A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) receiving exposures greater than *100 -mrem/yr - and their associated man-rem exposure according to work and job functions,21 e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 20 percent of the individual total dose need not be accounted for. In the aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to

. '* - -' . .~-:'

' ., * * ,,-,specific .,majocwork. functions .

b. The complete results of the steam .generator tube inservice inspections performed.

during the report period (Reference Specification 4.4.5.5.b.).

c. The results of specific activity analysis in which* the primary coolant exceeded the-limits of Specification 3.4.8. The following information shall be included: (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 radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radioiodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3)

Clean-up system flow 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; (4) Graph of the 1-131 concentration and one other radioiodine isotope concentration in microcuries per gram as function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

j.J A single submittal may be made for a multiple unit station. The submittal should combine

• .. those sections that are *common to*all units at the station.

2.J This tabulation supplements the requirements of §20.2206 of 1O CFR Part 20 .

• ' NORTH ANNA - UNIT 1 6-1 5 Amendment No.

' .

ADMINISTRATIVE CONTROLS (Continued)

ANNUAL RADIOLOGICAL EFFLUENT RELEASE REPORT*

• 6.9.1.9 The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous*calendar year shall be submitted by April 1 of- each year. The report shall*

include a summary of the quantities of radioactive liquid' and gaseous effluents and solid waste released from the unit. The material provided shall be .(1) consistent with the objectives .

outlined in the ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50 .

• A single submittal may be made for a multiple unit station.* The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

NORTH ANNA - UNIT 1 6-2 0 Amendment No.

' '

,.

ADMINISTRATIVE CONTROLS 6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall . be . prepared consistent with __ _the requirements of 1O CFR Part 20*- and,,-shall be approved,-- maintained and adhered to .for_ all .

• operations involving -personnel .radiation. exposure .

. 6,12 HIGH RADIATION AREA 6:12.1 - In lieu of the "control device" or "alarm signal" required by *paragraph 20; 1601-(a)(1} ***

• of 1O CFR 20 and the additional controls. required by .20.1602,*_each high .radiation area in which the. intensity of radiation .is .. greater than 100 mrem/hr but *1ess than 1000 mrem/hr.

shall* be barricaded and conspicuously posted as a high radiation area and entrance thereto _shall

• be controlled by requiring issuance of a Radiation Work Permit.* Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in

. the.area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and* alarms when a preset integrated dose is received. Entry into such areas .

with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physicist in the Radiation Work Permit.

6.12.2 The requirements of 6.12.1, above, shall* also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr. In addition, locked doors shall be

• _provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shift Supervisor on duty and/or the Plant Health Physicist.

---

• Health Physics personnel shall be exempt from the RWP issuance. requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

. . NORTH ANNA - UNIT 1 6-24 Amendment No .

.,

ADMINISTRATIVE CONTROLS 6.15 OFFSITE DOSE CALCULATION MANUAL {OPCM)

Changes to the ODCM:

-,a. *Shall: be. documented. and. records of reviews. performed shall be retained as. required._

by Specification 6.10.2.r. This documentation shall..contain:

-1) Sufficient information to .support the ,change together with,the.-appropriate analyses or evaluations justifying the change(s) and 2 ) A determination that the change will maintain the level of radioactive effluent _

• control required by 1O CFR 20.1302, 40 CFR

• Part 190, 1O CFR 50.36a, and Appendix I to 1O CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b. Shall become effective after review and acceptance by the SNSOC and the approval of the Plant Manager.

-* c: '"Shall"be *submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release

-* Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g.,

month/year) the change was implemented.

6.16 DELETED NORTH ANNA - UNIT 1 6-2 6 Amendment No.

1.0 DEFINITIONS (Continued)

OFFSITE DOSE CALCULATION MANUAL (ODCM) 1.17 . The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of offsite doses .resulting from radioactive gaseous- and liquid

- -- ,:* - effluents, .in the :calculation .of.gaseous -and liquid-_effluent .monitoring _alarm/trip setpoints, and

'"in the conduct of the Environmental Radiological Monitoring Program. The ODCM shall also _

• -* contain (1) the Radioactive Effluent Controls -and Radiological Environmental Monitoring - -

Programs required by Section 6.8.4 and (2) descriptions of the -information -that should be

• included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent-Release Reports required by Specifications 6.9.1.8 and 6.9.1.9.

OPERABLE - OPERABILITY 1.18 .A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function{s), and when all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system,

- ,.,, ,,,subsystem,,-train, component, or device to perform its function{s) are also capable of'

• *

• perfor'ming--th*efr:-related _'.support function{s).

'OPERATIONAL MODE - MODE 1.19 An OPERATIONAL-MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level, and average reactor coolant temperature specified in Table 1.1.

PHYSICS TESTS 1 . 20 PHYSICS TESTS shall be those_. tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation and 1) described in Chapter 14.0 of the FSAR, 2) authorized under -the provisions of 1O* CFR 50.59, -or 3) otherwise -

approved by the Commission.

- PRESSURE BOUNDARY LEAKAGE 1.21 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator tube leakage) through a non-isolable fault in a Reactor Coolant System component body, pipe wall or vessel wall.

PROCESS CONTROL PROGRAM 1 . 22 -The PROCESS CONTROL PROGRAM (PCP) shall contain the currenUormulas, sampling,.

analyses, tests and determinations to be made to ensure that-the processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 1O CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of the radioactive waste.

PURGE - PURGING 1 . 23 PURGE or PURGING is the controlled process of discharging air or gas from a

.confinement to maintain temperature, pressure, humidity, concentration_ or other operating condition, in such a manner that replacement air or gas is required to purify the confinement.

NORTH ANNA - UNIT 2 1-4 Amendment No.

' ' 1.0 DEFINITIONS (Continued)

• . STAGGERED TEST BASIS 1 .3 2 A STAGGERED TEST BASIS shall consist of:

a

• A test schedule for n systems, subsystems, trains or other designated components

.*. obtained by dividing the-specified test interval into n equal subintervals, .

b. The **testing of one system, subsystem, train or .other designated component at the

• beginning of each subinterval.

THERMAL POWER 1 .33 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

UNIDENTIFIED LEAKAGE

. 1 .34 UNIDENTIFIED LEAKAGE shall be all leakage which is not IDENTIFIED LEAKAGE or CONTROLLED LEAKAGE.

• -, *~UNRESTRICTED AREA 1 ;35 An UNRESTRICTED"AREA-shall be any-area,, access -to which is. neither-limited nor controlled by the licensee.

VENTILATION EXHAUST TREATMENT SYSTEM 1.36 A VENTILATION EXHAUST TREATMENT SYSTEM is the system designed and installed to reduce gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers -and/or HEPA filters for the purpose of removing iodines or particulates from the gaseous exhaust stream prior to the release to the environment (such a system is not considered to have any effect on noble gas effluents). -Engineered Safety Feature (ESF) atmospheric cleanup systems are not.considered to be VENTILATION EXHAUST TREATMENT SYSTEM components.

VENTING 1 .37 VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process .

• NORTH ANNA - UNIT 2 1-6 Amendment No.

. PLANT SYSTEMS BASES

• 3/4.7.11 SEALED SOURCE CONTAMINATION The limitations on sealed source removable contamination ensure that the total body or

• • individual* organ . irradiation does not* exceed* allowable* limits in *the event of ingestion or -

inhalation of the source, materiaL The limitations. on removable contamination for sources .

requiring leak testing,* including alpha emitters, is based on 1O CFR 70.39(c} limits for plutonium.

• Sealed sources are* classified into three groups according to their use, with surveillance requirements commensurate with the probability of damage to a source in that group.

• Those sources which are* frequently handled are required to be tested more often than those which are not. Sealed sources which are continuously enclosed within a shielded  !

mechanism (i.e.; sealed sources within radiation monitoring* or boron measuring devices) are 'I considered to be stored and need not be tested unless they are removed from the shielded mechanism.

3/4.7.12 SETTLEMENT OF CLASS 1 STRUCTURES In order to assure that settlement does not exceed allowable values, a program has been

- established to conduct a survey of a specified number of points at the site on a semiannual basis.

• -'** < **rhe first *survey **was -'conducted in May 1976 to establish baseline elevations for most of the points. Where applicable, the baseline elevations of points established subsequent to the May

• * * '". *

• 1976 survey have***been adjusted -to *the May 1976 survey by an evaluation of the .settlement--

records of settlement points on the same structure or on nearby structures. Baseline elevations

• • for points established on dates other than May* 1976 are indicated in Table 3.7-5. Additional surveys will be performed semiannually. The determination of the elevation of the points shall be by precise leveling with second order Class II accuracy as defined by the U.S. Department of Commerce National Oceanic and Atmospheric Administration. National Ocean Survey, 1974.

When any settlement point listed in Table 3.7-5 is inaccessible during a survey, comparison to allowable settlement shall be based on settlement of other points on the same structure or on nearby structures having similar foundation conditions. When any settlement point listed in Table 3.7-5 *is* dislocated or replaced, a documented review of the settlement records of points

- ** on the same structure and. additionally points on -nearby structures having similar foundation conditions shall provide a new reference elevation for the point that reflects the estimated settlement since the baseline survey. . If the* total settlement or differential settlement exceeds 75 percent of the allowable value, the frequency of surveillance shall be increased as dictated by the engineering review. Measurements of certain points are required to be performed at least once per 31 days for the first five years of facility operation to provide additional settlement information .

• NORTH ANNA - UNIT 2 8 3/4 7-7 Amendment No.

• RADIOACTfVESTORAGE

_3/4.11.1 LIQUID STORAGE BASES

_,_ - - - ===::::::=:=================================

_3/4.11.1.4 LIQUID HOLDUP TANKS The tanks listed in this Specification include all those outdoor tanks *that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains.connected to-the .liquid .radwaste-treatment system.

- Restricting the quantity of radioactive material contained in the specified tanks provides assurance that in the event of an uncontrolled release of the tanks' contents, the resulting concentrations would be less than ten times the limits of 1O CFR Part 20; Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an UNRESTRICTED AREA.

Specifications 3/4.11.2.1 through 3/4.11.2.4 have been deleted.

NORTH ANNA - UNIT 2 B 3/4 11-2 Amendment No.

5.0 DESIGN FEATURES 5.1 SITE EXCLUSION AREA 5.1.1 The exclusion area (site boundary) shall be as shown in Figure 5.1-1.

... LOW POPULATION ZONE

• 5.1.2 The low population zone shall be. as shown in Figure 5.1-2.

MAP DEFINING UNRESTRICTED AREAS FOR RADIOACTIVE GASEOUS AND LIQUID EFFLUENTS 5.1.3 Information regarding radioactive gaseous and liquid effluents, which allows identification of structures and release points as well as definition of UNRESTRICTED AREAS within the SITE BOUNDARY that are accessible to MEMBERS OF THE PUBLIC, shall be as shown in Figure 5.1-1.

5.2 CONTAINMENT CONFIGURATION 5.2.1 The reactor containment building is a steel lined, reinforced concrete building of

• . cylindrical shape with a dome roof and having the following design featµres: *

a. Nominal inside diameter = 126 feet.

b. Nominal inside height = 190 feet, 7 inches.

c. Minimum thickness of concrete walls = 4.5 feet.

• d. Minimum thickness of concrete roof = 2.5 .feet.

.. e. Minimum thickness of .concrete floor pad = 1O feet.

f. Nominal thickness of the cylindrial portion of the steel liner = 3/8 inches.

g. Net free volume = 1.825 x 106 cubic feet.

h. Nominal thickness of hemispherical dome portion of the steel liner = 1/2 inch.

DESIGN PRESSURE AND TEMPERATURE 5.2.2 The reactor containment building is designed and shall be -maintained for a maximum internal pressure of 45 psig and a temperature of 280°F .

• NORTH ANNA - UNIT 2 5-1 Amendment No.

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1. Process Vent - 157.5 Ft.

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I Land Maximum Member of the Public Occupancy = 336 hrs/year 01I Lake Maximum Member of the Public I\) Occupancy = 2232 hrs/year

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I SV644C

l ADMINISTRATIVE CONTROLS

e. Radjoactjve Effluent Controls Program A program shall be provided conforming with 1O CFR 50.36a for the control of radioactive effluents and for maintaining the doses to MEMBERS OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3)

• --*, shall include:remedial actions -to be taken whenever the. program limits are exceeded.

-The program shall include the following elements:

1 ) Limitations on the operability of radioactive

• liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM, 2 ) Limitations on the concentrations of radioactive material released* in liquid effluents to UNRESTRICTED AREAS conforming to ten times 10 CFR Part 20, Appendix 8, Table 2, Column 2, 3 ) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 1O CFR 20.1302 and with the methodology and parameters in the ODCM, 4 ) Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit

'to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR Part 50, 5 ) Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, 6 ) Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2-percent*of the-guidelines-for the annual dose or dose commitment conforming to Appendix I to 1O CFR Part 50, 7 ) Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at or beyond the SITE BOUNDARY shall be limited 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 lodine-131, lodine-133, Tritium, and 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.

NORTH ANNA - UNIT 2 6-13b Amendment No.

- - ---- -------

ADMINISTRATIVE CONTROLS

---6.9.1.2. The startup report shall address each of the tests identified in the* FSAR and shall include a description of the measured values of the operating conditions or characteristics

.. obtained during the..test. program and :a _comparison* o :these**values with' design *predictions and:

. specifications. Any corrective actions *that were required to obtain *satisfactory-operation shall _

also be' described.. Any additional specific details requested in license conditions based on _other *

• commitments shall be included in this report.

6.9.1.3 Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover all three events (i.e., initial criticality, completion of startup test program, and resumption or commencement of commercial power operation),

supplementary reports shall be submitted at least every three months until all three events have been completed.

ANNUALREPORJs1/

6.9.1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each. year. The initial report shall be_

• submitted prior to March 1 of -the year following initial criticality.

- . 6.9.1.5 Reports.required on an annual basis shall include:

a. A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) receiving exposures greater than 100 mrem/yr and their associated man-rem exposure -according to work and job functions,21 e.g., reactor

• operations and surveillance, inservice inspection, routine maintenance, special

• maintenance (describe maintenance), waste processing, and refueling. The dose assignments to various duty functions* may be estimated based on-pocket dosimeter, TLD, or film badge measurements. Small exposures totaling less than 20 percent of the individual'total dose need not be accounted for. In the aggregate, at least 80 percent

• of the total whole body dose received from external sources should be assigned to specific major work functions.

j.J A single submittal may be made for a multiple unit station. The submittal should combine -

those sections that* are common to all units at the station.

2.1 This tabulation supplements the requirements of §20.2206 of 1O CFR Part 20.

NORTH ANNA - UNIT 2 6-1 5 Amendment No.

_ ADMINISTRATIVE CONTROLS (Continued)

_ ANNUAL RADIOLOGICAL EFFLUENT RELEASE REPORT*

• .' ': 6;9.1.9

• The *.6tnnual -Radioactive Effluent Release Report covering ,the operation--of the unit .

• during the previous calendar year" shall be* submitted by April 1 of each year. The report shall

• include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste.

released from the unit. The material provided shall be (1) consistent -with the objectives outlined in the ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.8.1 of Appendix I to 10 CFR Part 50.

• A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

NORTH ANNA - UNIT 2 6-20 Amendment No.

• ADMINISTRATIVE CONTROLS (Continued)

g. Records of reactor tests and experiments.

h.

• Records of training and qualification for current members of the plant staff.

i.

• Records

• of in-service inspections performed

• pursuant to these Technical .

Specifications.

j . Records of Quality Assurance activities required by the QA Manual.

k. Records of the service life of all hydraulic* and mechanical snubbers required to be operable by Technical Specification 3.7.10 including the date at which the service life commences and associated installation and maintenance records.

I. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 1O CFR 50.59.

m. Records of meetings of the SNSOC.

n. Records of meetings of the System Nuclear Safety and Operating Committee to issuance of Amendment No. 11.

o. Records of secondary water sampling and water quality.

p. Records for Environmental Qualification which are covered under the provisions of Paragraph 2.C(4) (3) of License No. NPF-7.

q. Records of analyses required by the radiological environmental monitoring program that would permit evaluation of the accuracy of the analysis at a later date. This would included procedures effective. at specified times and QA records showing that these procedures were followed.

r. Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 1O CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA 6.12.1 In lieu of the "control device" or "alarm signal" required by paragraph 20.1601 (a)(1) of 1O CFR 20 and the additional controls required by 20.1602, each high radiation area in which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area and entrance NORTH ANNA - UNIT 2 6-23 Amendment No.

ADMINISTRATIVE CONTROLS 6.13 PROCESS CONTROL PROGRAM (PCP)

Changes to the PCP:

a

• Shall be documented and records of reviews performed shall-be retained-as required .

by Specification 6.10.2.r. This documentation shall contain:

1 ) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change{s) and 2 ) A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations.

b. Shall become effective after review and acceptance by the SNSOC and the approval of the Plant Manager.

• 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)

Changes to the ODCM:

a Shall be documented and records of reviews performed shall *be retained as required by Specification 6.10.2.r. This documentation shall contain:

1 ) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change{s) and 2 ) A determination that the change will -maintain the level of radioactive effluent control required by 10-CFR 20.1302, 40-CFR--Part 190, 10 CFR.50.36a, and Appendix I to 1o CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b. Shall become effective after review and acceptance by the SNSOC and the approval of the Plant Manager.

c. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change-to the ODCM.was made. Each ..

change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date {e.g.,

month/year) the change was implemented.

NORTH ANNA - UNIT 2 6-25 Amendment No.

Attachment 3 Discussion of Changes Surry Power Station

• Discussion of Changes Surry Power Station Units 1 and 2 Introduction The proposed changes to Surry 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 Register on August 31, 1992. 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.

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 general public. The revision of Appendix B, 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.

The following proposed Technical Specification changes reduce the frequency of

• submitting the radiological effluent release report from semiannual to annual: TS Surry Discussion of Changes 1

--- ---

• 1.M, 6.6.B.3, and 6.8.B.3. 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. This is reflected in our proposed change to TS 6.6.B.3.

The following proposed Technical.Specification.chan.ges..arejn.response to ;the revised 10 CFR 20:

1. 1.U - Revise the definition of unrestricted area.

2. 4. 16 Objective and Bases - Delete the old 10 CFR 20 terminology to avoid misinterpretation of the bases for the sealed source contamination limits.

3. 6.4.N.2 - Revise the liquid effluent release rate limit.

4. 6.4.N.3 - Reflect the relocation of the old 10 CFR 20.106 requirements for liquid and gaseous effluents *to the new -10 CFR 20. 1302.

5. 6.4.N. 7 - Revise the gaseous effluent release rate limit.

6. 6.6.A.2 - Reflect the relocation of the old 10 CFR 20.407 requirements for annual reports to the new 10 CFR 20.2206 requirements.

7. Page TS 6.6 Reflect the correct page number in the Note at bottom of this page.

8. 6.4.8.1 - Reflect the relocation of the old 10 CFR 20.203 requirements for high radiation area to the new 10 CFR 20.1601 requirements.

9. 6.8.8.1.b - 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 .

• Surry Discussion of Changes 2

Technical Specification Changes

1. TS 1.M, 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 ..being made

- consistent with -the-change in effluent reporting frequency published- in .the Federal Register, Vol. 57, No. 169, August 31, 1992

2. TS 1.U, 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 4.16, Objective for Leakage Testing of Miscellaneous Radioactive Materials Sources, is being revised to delete the obsolete term "maximum permissible body burden." The revised objective is "to maintain doses due to ingestion or inhalation within the limits of 10 CFR 20."

4. TS 4. 16, Bases for Leakage Testing of Miscellaneous Radioactive Materials Sources, 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 ..

5. Figure 5.1-1 defines the area outside the security fence as unrestricted for gaseous effluents. Based upon NUREG-0472 and the Radiological Effluent Technical Specifications (RETS), which have been transferred to the ODCM in accordance with Generic Letter 89-01, 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 a member of the public at the site boundary, and 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, which is the boundary for the Protected Area and restricted area, and the site boundary.

6. TS 6.4.B.1 references the old 10 CFR 20.203(c)(2) for control requirements for a high radiation area. This reference is being changed to the 10 CFR 20.1601 (a)(1 ). This administrative change supports the relocation of high Surry Discussion of Changes 3

radiation area control requirements from the old 10 CFR 20.203(c)(2) to the new 10 CFR 20.1601(a)(1). TS 6.4.B.1 is also being revised to acknowledge the additional controls established under the new 10 CFR 20.1602. This will ensure that the measures which, are in place for . controlling -access to high radiation areas are- not, used for very high** radiation areas which require additional controls.

7. The proposed change to the liquid effluent release rate limit in TS 6.4.N.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 8, Table 2, Column 2.

8. The reference to the old 10 CFR 20.106 is being changed to the new 10 CFR 20.1302 in TS 6.4.N.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 6.4.N. 7 is being made*to provide 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 8, 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. The page number TS 6.6-17 reported in the Note on page TS 6.6-2 is being changed to page number TS 6.6-12.

11. Footnote 2 to TS 6.6.A.2.a references the old 10 CFR 20.407 requirements for reporting 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.

12. TS 6.6.8.3, 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 date of each year and the applicable reporting period for the previous calendar year rather than the previous six months.

Surry Discussion of Changes 4

13. The reference to 10 CFR 20.106 in TS 6.8.B.1.b 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 6.8.B.3 refers to the Semiannual Radioactive Effluent Release Report. The word "Semiannual" is being changed to "Annual." This administrative change is being made consistent with 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.

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 limits specified in the old 10 CFR 20.106 which reference Appendix 8, 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 8, 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.

Surry Discussion of Changes 5

Operational history at Surry Power Station 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 6.4.N.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 B, 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*

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 1O 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. 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 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 8, Table 2, Column 1, are based on Surry Discussion of Changes 6

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 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_efflueot 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 Surry Power Station 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 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.

Surry Discussion of Changes 7

Attachment 4 Technical Specifications Changes

• Surry Power Station

TS 1.0-7 K. Low Power Physics Tests Low power physics tests conducted *below *5% of rated power which -measure fundamental characteristics of the core and related instrum.entation.

L. Fire Suppression Water System A Fire Suppression Water-System *shall**consist of:- a water*source(s);*gravity tank(s) or pump(s); and distribution piping with associated sectionalizing control or isolation valves. Such valves shall include yard hydrant curb valves, and the first valve ahead of the water flow alarm device on each sprinkler, hose

• standpipe or spray system riser.

M. Offsite Dose Calculation Manual The OFFSITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the .calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm/Trip Setpoints, and in the conduct of the Radiological Environmental Monitoring Program. The ODCM shall also contain (1) the .Radioactive Effluent Controls and Radiological Environmental Monitoring. Programs required by Section 6.4* and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.6.B.2 and 6.6.B.3.

N. Dose Equivalent 1-131 The dose equivalent 1-131 shall be that concentration of 1-131 (microcurie/gram) which alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table Ill of TID-14844, "Calculation of Distance Factors for Power and Test Reactor Sites" or in NRC Regulatory Guide 1.109, Revision 1, October 1977.

Amendment Nos.

TS 1.0-10 U. Unrestricted Area An unrestricted area shall,be an area access .to which .is .. neither limited nor

• controlled by the licensee.

V. Member(s) of the Public Member(s) of the ,public shall -include -all -individuals--who by virtue of their occupational status have no formal association with the plant. This category shall include non-employees of the licensee who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with plant functions. This category shall not include non-employees such as vending machine servicemen or postmen who, as part of their formal job function, occasionally enter an area that is controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials .

• Amendment Nos.

TS 4.16-1 4.16 LEAKAGE TESTING OF MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES Applicability Applies to miscellaneous radioactive materials sealed sources not subject to core flux and that are not stored and out of use.

Objective To maintain doses due to ingestion or inhalation within the limits of 10 CFR 20.

Specifications A. Source Leakage Test

... Radioactive.sources shall be leak tested for contamination. The leakage test

• • shall *be* capable 'of'*detecting the presence of 0.005 *microcurie of- radioactive

,.. * ... ,. .. material on the test sample. If the test reveals the presence of 0.005 microcurie or more of removable contamination, it shall immediately be withdrawn from use, decontaminated, and repaired or be disposed of in accordance with Commission regulations.

Those quantities of byproduct material that exceed that quantities listed in 10 CFR 30.71 Schedule B are to be leak tested in accordance with the schedule shown in Surveillance Requirements. All other sources (including alpha emitters) containing greater than 0.1 microcurie are also to be leak tested in accordance with the Surveillance Requirements.

Amendment Nos.

TS 4.16-2 Commission or an agreement State as follows:

a. Each sealed source, except-startup sources subject to core flux,

• containing radioactive material other than-Hydrogen 3 with a half-life greater than thirty days and in any form other than gas shall be tested for leakage and/or contamination at intervals not to exceed six months.

b. The periodic leak test required does not apply to sealed sources that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to another user unless they have been leak tested within six months prior to the date of use or transfer. In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, sealed sources shall not be put into use until tested.

c. Startup sources shall be leak tested prior to and following any repair or maintenance and before being subjected to core flux.

2. A complete inventory of radioactive materials in possession shall be maintained current at all times.

Ingestion or inhalation of source material may give rise to total body or organ irradiation. This specification assures that leakage from radioactive materials sources does not exceed allowable limits. The limits for all other sources (including alpha emitters) are based upon 1O CFR 70.39(c) limits for plutonium.

Amendment Nos.

I1 Inch = Approximately 1,000 Feet I STATION A. Gaseous Release

1. Process Vent - 131 Ft. - Mixed Mode JAMES 2. Vent-Vent Stacks RIVER Ground Level B. Liquid Leaves Site RADWASTE FACILITY C. Gaseous Release Ground Level

--- --- - ..... - - - - Site Boundary - Area At or Beyond is

~

Unrestricted for Gaseous Effluents I

Site Boundary I 1- - - ........... *** Security Fence I '

I I Land Maximum Individual Occupancy Within Site

- --- ' Boundary:

1. Canal Bank Fishing = 160 Hr/Yr Liquid Maximum Individual Occupancy Within Site Boundary:

1. Boat Fishing Discharge Canal = 800 Hr/Yr I

' '

'

' '

'

,

..... _,,,'

'

' I JAMES

I I RIVER

'

'

Site Boundary ' ,

---

- - - - -------------------~

---

----- - - - - - - - -

'

-i en "Tl FIGURE 5.1-1 co*

C MAP DEFINING UNRESTRICTED AREAS FOR RADIOACTIVE @

GASEOUS AND LIQUID EFFLUENTS 01

......

......'

l .. TS 6.4-2

1. In lieu of the "control device" or "alarm signal" required by paragraph 20.1601 (a)(1) of 1O CFR 20 and the additional controls required by paragraph 20.1602, each high radiation area in which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. Any individual or group of individuals permitted to enter such areas shall be*providedwith-*or-*accompanied*by one-or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate* monitoring device. This individual is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by Health Physics in the RWP.

• Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved plant radiation protection procedures for entry into high radiation areas.

Amendment Nos.

TS 6.4-8

• N. Radioactive Effluent Controls Program A program *shall be provided conforming*with c1 O* CFR *50.36a for_the control of radioactive effluents and for_ maintaining the doses to MEMBERS OF THE

• * **PUBLIC from* radioactive**effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits-are-exceeded.-~--The--progfam-shall -include the following elements:

1) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM,

• 2) Limitations on the concentrations of radioactive material* released in liquid effluents to UNRESTRICTED AREAS conforming to ten times 1O CFR 20, Appendix B, Table 2, Column 2,

3) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 1O CFR 20.1302 and with the methodology and parameters in the ODCM,

4) Limitations on the annual and quarterly doses or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released from each unit to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR Part 50,

5) Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days, Amendment Nos.

TS 6.4-9

6) Limitations on the operability and use* of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these

.* systems are used to reduce releases of- radioactivity when* the projected doses in a 31-day period would exceed 2 percent of the guidelines for"*

• .:the annual-doseor dose commitment conforming-to Appendix:lto 10 CFR Part 50,

7) Limitations on the -dose rate- resulting --from--radioactive- material released in gaseous effluents to areas at or beyond the SITE BOUNDARY shall be limited 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 lodine-131, lodine-133, Tritium, and 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.

8) Limitations on the annual and quarterly air doses resulting from noble

. . gases released in gaseous effluents . from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part 50,

9) Limitations on the annual and quarterly doses to a MEMBER OF THE PUBLIC from lodine-131, lodine-133, Tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from each unit to areas beyond the SITE BOUNDARY conforming to Appendix I to 1O CFR Part 50,

10) Limitations on the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

• Amendment Nos.

.. , I-TS 6.6-2

• resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup

--Report does not cover all three events,(i.e., initial criticality, completion of

• . startup -test program, and .resumption or commencement of commercial

• power :operations), supplementary reports shall be* submitted at least every 3 months until all three events have been completed.

2. Annual Reports 1

a. A tabulation on an annual basis of the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mrem/yr and their associated man-rem exposure according to work and job functions2, e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The .dose assignment to various duty functions may be estimates based on pocket .dosimeter, TLD, or f.ilm badge measurements. Small exposures totaling less than 20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of the total whole body dose received from external

.. sources*shall be assigned to specific major work functions.

Note: Footnotes 1 and 2 are located on page TS 6.6-12 .

• Amendment Nos.

TS 6.6-10 B. Unique Reporting Requirements

1. - -, -lnservice Inspection Evaluation Special summary technical report shall be submitted **to *the Director-of Reactor Licensing, Office of Nuclear Reactor Regulation, NRC, Washington, D.C. 20555, after 5 years of operation. This report shall include an evaluation *of -the results--of--the inservice-inspection program and will be reviewed in light of the technology available at that time.

2. Annual Radiological Environmental Operating Report1

. The .Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries,

• interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

3. ** Annual Radioactive Effluent Release Report3 The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year shall be submitted by April 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance with 1O CFR 50.36a and Section IV.B.1 of Appendix I to 1O CFR Part 50 .

• Amendment Nos.

I* * - * ..;

TS 6.6-12

• analysis and interpretation of the test data, the least squares fit analysis of the test data, the instrument error analysis, and the structural

• conditions of the containment or components, if any, which contributed to

.the failure in meeting the acceptance criteria. Results and analyses of

• the supplemental verification test employed to demonstrate the validity of the leakage rate test measurements shall also be included."

C. Special Reports In the event that the Reactor Vessel Overpressure Mitigating System is used to mitigate a RCS pressure transient, submit a Special Report to the Commission within 30 days. The report shall describe the circumstances initiating the transient, the effect of the PORVs or the administrative controls on the transient and any corrective action necessary to prevent recurrence.

FOOTNOTES

1. A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station.

2. This tabulation supplements the requirements of Section 20.2206 of 1O CFR Part 20.

3. A single submittal may be made for a multi-unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

Amendment Nos.

TS 6.8-2

• b. A determination that the change will maintain the level of radioactive effluent control required by *1 O CFR 20.1302, 40 CFR Part 190, 1O CFR 50.36a,. and Appendix .I to 1O CFR Part. 50. and

• • • not adversely impact the accuracy or reliability of effluent, dose, or

'Setpoint calculations.

2. Shall require review and acceptance by the SNSOC and the approval of the Station Manager prior- to implementation.

3. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which

... any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area

• . of the page that was changed, and shall indicate the date (e.g.,

• *month/year) the change was implemented.

Amendment Nos.

, ' I

,. ',i

Attachment 5 Significant Hazards Consideration

(J ., .. l,t--. . . . . . . . .

Significant Hazards Consideration In accordance with 10 CFR 50.92, 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 proposed changes are administrative changes which are necessary due to regulatory changes and will not result in significant changes to the facility or its operation. The proposed change has been evaluated against each of the following criteria:

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 10 CFR 50.36a and 10 CFR 50, Appendix I and result in levels of radioactive materials in effluents being maintained As Low As Reasonably Achievable (ALARA).

2. The proposed 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.

3. Due to the operational flexibility provided by the limits given in this Technical Specification change request, the proposed amendments do not involve any actual change in the methodology used in the control of radioactive wastes or radiological environmental monitoring. Therefore these changes do not reduce the margin of safety.

Virginia Electric and Power Company concludes that the activities associated with these proposed Technical Specification changes satisfy the no significant hazards consideration criteria of 10 CFR 50.92 and, accordingly, a no significant hazards consideration finding is justified.