ML18011A549

Application for Amend to License NPF-63,incorporating Programmatic Controls for Radioactive Effluents,Radiological Environ Monitoring & Solid Wastes in Administrative Controls Section of TS & Relocating RETS to ODCM or Pcp,Per GL 89-01

ML18011A549
Person / Time
Site:	Harris
Issue date:	08/19/1994
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18011A550	List: ML18011A549 ML18011A551
References
GL-89-01, GL-89-1, HNP-94-025, HNP-94-25, HO-940281, NUDOCS 9408250029
Download: ML18011A549 (18)

Text

P H.IC3R.lWY (ACCELERATED RIDS PROCESSING~)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9408250029 DOC.DATE: 94/08/19 NOTARIZED: YES DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON,W.R. Carolina Power 6 Light Co.

RECIP.NAME RECXPXENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend, to license NPF-63,incorporating programmatic controls for radioactive effluents,radiological envl.ron monitoring 6 solid wastes in administrative controls DISTRIBUTION CODE: AOOSD COPIES RECEIVED:LTR TITLE: OR/Licensing Submittal: Appendix I (ODCM)

NOTES:Application for permit renewal filed.

j section of TS 6 relocating RETS to ODCM or PCP,per GL 89-01.

ENCL J SIZE: l 05000400 RECIPIENT COPIES RECXPIENT COPIES ID CODE/NAME LTTR ENCL XD CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 LE,N 2 2 INTERNAL: ACRS 3 3 NRR/DRSS/PRPB 1 1 NRR/PDV 1 1 1 0 OGC/HDS2 1 0 R G 01 1 1 RGN... DRSS/RPB 1 1 EXTERNAL EGGG AKERS i D 1 1 NRC/PDR 1 1 NUDOCS-ABSTRACT 1 1 PNL BAKER i D A 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS I'OR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 15

Carolina Power & Light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant AUG f 9 199'etter Number: HO-940281 SERIAL: HNP-94-025 10 CFR 50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washingt:on, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS Gentlemen:

In accordance with the Code of'ederal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP).

This license amendment requests a line-item improvement to the SHNPP Radiological Effluent Technical Specifications (RETS) pursuant to the guidance of Generic Letter 89-01. The proposed amendment will incorporate programmatic controls for radioactive effluents, radiological environmental monitoring and solid radioactive wastes in the Administrative Controls Section of the TS, and relocate the current procedural details of the current RETS into the Offsite Dose Calculation Manual or Process Control Program, as appropriate. This amendment will also incorporate 1) changes to the reporting requirements for Effluent Release Reports, 2) references to the new 10 CFR 20 for those sections of Technical Specifications included in the RETS TSCR, and 3) revised terminology for the gaseous effluent release rate limits.

This license amendment request supercedes and replaces in its entirety our July 21, 1992 RETS TSCR and its supplement on September 3, 1992. provides a detailed description of the proposed changes and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides an environmental evaluation which demonstrates that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment needs to be prepared in connection with the issuance of the amendment.

'740825002'P 9'40819

,PDR,'

P-' 'ADOCK 05000400

. PDR State Road1134 NewHill NC Tel 919362-2502 Fax 919362-6950

Document Control Desk HNP-94-025 / Page 2 provides page change instructions for incorporating the proposed revisions. provides the proposed Technical Specification pages.

In accordance with 10 CFR 50.91(b), CPSL is providing the State of North Carolina with a copy of the proposed license amendment.

In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued such that implementation will occur within 120 days of issuance of the amendment.

Please refer any questions regarding this submittal to Mr. D. C. McCarthy at (919) 362-2100.

Yours very truly, W. R. Robinson SDC/sdc

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Environmental Considerations

4. Page Change Instructions

5. Technical Specification Pages W. R. Robinson, having been first duly sworn, did depose and say that the information contained herein is true and correct to the be'st of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power 6 Light Company.

4anau+

Notary Seal) J 4

S. Y'Ieao My commission expires:

O NOTARY c; Mr. Dayne H. Brown Mr. S. D. Ebneter PUOLlC Mr. N. B. Le Mr. J. E. Tedrow ~ni coe+'

Document Control Desk HNP-94-025 / Page 3 bc: T. A. Baxter, Esq. Mr. R. D. Martin Ms. P. Brannan Admiral K. R. McKee Mr. R. K. Buckles (LIS) Mr. J. W. Moyer Mr. W. R. Campbell Mr. W. S. Orser Mr. J. W. Donahue Mr. H. A. Pollock Mr. H. W. Habermeyer, Jr. Mr. G. A. Rolfson Mr. E. M. Harris Mr. L. S. Rowell Ms. T. A. Head (GLS File) Mr. R. S. Stencil Mr. J. D. Heidt Honorable H. Wells Mr. W. J. Hindman Nuclear Records Mr. G. Honma (BNP) File: HI/A-2D Mr. R. M. Krich (RNP) File: H-X-0511

ENCLOSURE TO SERIAL'NP-94-025 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS BASIS FOR CHANGE RE UEST

~Back round The Shearon Harris Nuclear Power Plant (SHNPP) Technical Specifications include detailed requirements for controlling radiological effluents, solid radioactive wastes and radiological environmental monitoring. These requirements, located in Specifications 3/4.3, 3/4.11 and 3/4.12, are collectively referred to as the Radiological Effluent Technical Specifications (RETS). On July 21, 1992 (NLS 132), Carolina Power & Light Company (CP&L) submitted a Technical Specification Change Request (TSCR) that would have implemented the guidance of Generic Letter 89-01 relative to the RETS. The July 1992 TSCR proposed the relocation of procedural details of the current RETS into the Offsite Dose Calculation Manual (ODCM) or Process Control Program (PCP), as appropriate. It also proposed the incorporation of programmatic controls for radioactive effluents, radiological environmental monitoring and solid radioactive wastes into the Administrative Controls Section of t'e Technical Specifications (TS).

Since CP&L submitted the RETS TSCR in July 1992, a number of changes have occurred. Part 20 of the Code of Federal Regulations has undergone a major revamping, reporting requirements in Part 50 have also been revised, and subsequent technical specification changes have been approved for SHNPP, all of which have some effect on the RETS TSCR as submitted in 1992. Therefore, CP&L has updated the RETS TSCR to account for these changes and herein resubmits the updated TSCR. This resubmittal supersedes and replaces the July 21, 1992 submittal.

Pro osed Chan e This license amendment requests a line-item improvement to the RETS portion of the SHNPP TS pursuant to the guidance of Generic Letter 89-01. The proposed amendment will incorporate programmatic controls for radioactive effluents, radiological environmental monitoring and solid radioactive wastes in the Administrative Controls Section of the TS, and relocate the procedural details of the current RETS into the Offsite Dose Calculation Manual (ODCM) or Process Control Program (PCP), as appropriate. This amendment will also incorporate changes to the reporting requirements for Effluent Release Reports, references to the new 10 CFR 20 for those sections of Technical Specifications included in the RETS TSCR, and revised terminology for the gaseous effluent release rate limits.

Page El-1

ENCLOSURE TO SERIAL: HNP-94-025 Basis A. Radiological Effluent Technical Specifications As discussed in NRC Generic Letter 89-01, the NRC staff has examined on a generic basis the contents of the RETS 'in relation to the Commission's Interim Policy Statement on Technical Specification Improvements. The staff has determined that programmatic controls can be implemented in the Administrative Controls Section of the TS to satisfy existing regulatory requirements

"

for RETS. At the same time, the procedural details of the current TS on radioactive effluents and radiological environmental monitoring can be relocated to the ODCM. Likewise, the procedural details of the current TS on solid radioactive wastes can be relocated to the PCP.

These actions simplify the RETS, meet the regulatory requirements for radioactive effluents and radiological environmental monitoring, and are provided as a line-item improvement to the TS, consistent with the goals of the Policy Statement.

Pursuant to the guidance provided in Generic Letter 89-01, this amendment will provide programmatic controls for RETS consistent with regulatory requirements and allow relocation of the procedural details of current RETS to the ODCM or PCP.

The proposed programmatic controls for radioactive effluents and radiological environmental monitoring conform to the recommendations of the Generic Letter with two exceptions, both of which deal with the manner in which specific limits are referenced in the new Administrative Controls Section. First, the proposed liquid effluent limits in Paragraph 6.8.4.h.2, reflect the recently approved limits expressed in terms of the revised 10 CFR 20 requirements (see TS Amendment 40). The GL 89-01 wording references the old 10 CFR 20 requirements. Second, the proposed gaseous effluent limits in Paragraph 6.8.4.h.7 maintains the current TS use of specific numerical limits. Generic Letter 89-01 would replace the specific numerical limits with references to the limits in 10 CFR 20 (see Section D below). In both cases, the wording of the proposed Administrative Controls reflect the effluent limits of the current TS which they are replacing, and are in accordance with subsequent NRC guidance.

Future changes to the procedural details will be controlled by the controls for changes to the ODCM or PCP included in the Administrative Controls Section of the TS.

The change to each Technical Specification is outlined in the attached table, Page El-2

ENCLOSURE TO SERIAL: HNP-94-025 SUB4ARY OF PROPOSED C GES TO THE RETS ADHINISTRATIVE CONTROLS SPECIFICATION TITLE DISPOSITION OF EXISTING SPECIFICATION 1.20 OFFSITE DOSE CALCULATION Definition is updated to reflect the MANUAL change in scope of the ODCH.

1.25 PROCESS CONTROL PROGRAM Definition is updated to reflect the change in scope of the PCP.

1.34 SOLIDIFICATION Definition is relocated to the PCP.

3/4.3.3.10 RADIOACTIVE LIQUID Pzogranmatic controls are included in EFPLUENT HONZTORING 6.8.4 h. Item 1). Existing specifi.-

INSTRUMENTATION oation procedural details aro relocated to tho ODCH.

3/4 ' '. 11 RADIOACTIVE GASEOUS EFPLUENT MONITORING Pzogranmatic controls are included 6.8.4 h. Item 1). Existing specifi-in INSTRUMENTATION cation procedural details are relocated to tho ODCH. Existing requirements for explosive gas monitoring instrumentation aro retainod.

3/4.11.1.1 LIQUID EFFLUENTS: Pzogranmatic controls are included in CONCENTRATION 6.8.4 h. Item 2) and 3). Existing specification procedural details are relocated to the ODCH.

3/4.11. 1.2 LIQUID EFFLUENTS: Progranmatic controls are included in DOSE 6.8.4 h. Item 4) and 5). Existing specification pzoceduzal details are relocated to the ODCH.

3/4.11.1.3 LIQUID EFFLUENTS Pzogranxnatic controls are includod in LIQUID RADWASTE 6.8.4 h. Item 6) Existing

~

TREATHENT SYSTEH specification procedural details axe zelocated to the ODCH.

3/4.11.2.1 GASEOUS EFFLUENTS: Pzogranxnatic controls are includod in DOSE RATE 6.8 ~ 4 h. Item 3) and 7). Existing specification procedural details are relocated to the ODCH.

3/4.11.2.2 GASEOUS EFFLUENTSx Pzogranmatic controls are included in DOSE-NOBLE GASES 6.8.4 h. Ztom 5) and 8). Existing specification procedural dotails are relocated to the ODCH.

3/4. 11.2. 3 GASEOUS EFFLUENTS: Pzogranxnatic controls are includod in DOSE--ZODINE 131, 6.8.4 h. Item 5) and 9). Existing TRITIUH, AND RADIOACTIVE specification procedural details are HATERZAL IN PARTICULATE relocated to the ODCH.

FORM 3/4.11.2.4 GASEOUS EFFLUENTS: Progranxnatic controls are included in GASEOUS RADWASTE 6.8.4 h. Iten 6). Existing specifi-TREATHENT or VENTILATION cation procedural details are EXHAUST TREATMENT SYSTEM relocated to the ODCH.

3/4.11.3 SOLID RADIOACTIVE WASTES Existing specifications procedural dotails are relocated to tho PCP.

Page E1-3

ENCLOSURE TO SERIAL: HNP-94-025 SENARY OF PROPOSED CHANGES To THE RETS ADMINISTRATIVE CONTROLS (Cont.)

SPECIFICATION TITLE DISPOSITION OF EXISTING SPECIFICATION 3/4. 11. 4 RADIOACTIVE EFFLUENTS: Prograsmatic controls are included in TOTAL DOSE 6.8.4 h. Item 10). Existing specifi-cation procedural details are relocated to the ODCH.

3/4.12.1 RADIOLOGICAL ENVIRON- Prograanatic controls are included in MENTAL MONITORING: 6.8.4 i. Item 1). Existing specifi-HONITORING PROGRAH cation procedural details are relocated to the ODCH.

3/4.12.2 RADIOLOGICAL ENVIRON- Prograsmatic controls are included in MENTAL HONITORING: 6.8.4 i. Item 2). Existing specifi-LAND USE CENSUS cation procedural details are zelocated to the ODCH.

3/4.12.3 RADIOLOGICAL ENVIRON- Pzogzenxnatic controls aze included in HENTAL MONITORING: 6.8.4 i. Item 3). Existing specifi-INTERLABORATORY cation procedural details are COMPARISON PROGRAM relocated to the ODCH.

6.8.4.h PROCEDURES AND PROGRAHS Added Radioactive Effluent Control Program.

6.8.4.i PROCEDURES AND PROGRAMS Added Radiological Environmental Honitoring Program.

6.9.1.3 REPORTING REQUIREMENTS: Specification simplified and existing ANNUAL RADIOLOGICAL reporting details are relocated to ENVIRONMENTAL OPERATING the ODCH.

REPORT 6.9.1.4 REPORTING REQUIREMENTS: Specification simplified and existing ANNUAL RADIOACTIVE reporting details are relocated to EFFLUENTS RELEASE REPORT the ODCH or PCP, as appropriate.

6.13 PROCESS CONTROL PROGRAM Specification requirements are simplified.

6.14 OFFSITE DOSE CALCULATION Specification requirements are HANUAL simpliiied.

6.15 MAJOR CHANGES TO LIQUID, Existing procedural details are GASEOUS, AND SOLID relocated to the ODCH or PCP, as RADWASTE TREATMENT appropriate.

SYSTEMS Effluent Release Report In accordance with Technical Specifications and prior 10 CFR 50.36a(a)(2) requirements, the Effluent Release Report for the SHNPP has been submitted to the NRC every six months (within 60 days after January 1 and July 1 of

'each year). As published in the Federal Register (57FR39353, August 31, 1992), the NRC revised the 10 CFR 50.36a required Effluent Release Report frequency from once every six months to annually and revised the required report submission date to May 1. The Rule became effective on October 1, 1992, This TSCR supplement proposes to revise the Technical Specifications such that they are consistent with the revised 10 CFR 50.36a reporting requirements.

Page El-4

0 l

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ENCLOSURE TO SERIAL: HNP-94;025 Revised 10 CFR 20 References Effective June 20, 1991, the NRC published a revised 10 CFR Part 20, which among other changes, affected the arrangement of requirements within the Regulation. SHNPP implemented the new Part 20 requirements effective January 1, 1993. This administrative change is being made to reflect that the requirements in the old 10 CFR 20.106 are now located in the new 10 CFR 20.1302.

This TS change request deals only with those Technical Specifications within the scope of the RETS (Generic Letter 89-01). Updating the SHNPP TS to incorporate the remainder of the 10 CFR 20 references is awaiting NRC staff guidance in a forthcoming Generic Letter.

Gaseous Effluent Release Limit This submittal also revises the terminology for the gaseous effluent release rate limits in a manner which differs from the proposed wording of GL 89-01. This proposal maintains the gaseous effluent release rate limits as currently specified in the SHNPP Technical Specifications. A similar change for the Liquid Effluent Concentration Technical Specification 3/4.11.1.1 has already been approved by the NRC on December 14, 1993 as Amendment 40 to the SHNPP Operating License, Technical Specification 3/4.11.2.1, Gaseous Effluents - Dose Rate, ensures that the dose rate at any time at and beyond the site boundary from gaseous effluents will be less than the effective dose rate limits of (the old) 10 CFR Part 20. The annual dose rate limits of 10 CFR 20, Appendix B, Table II, Column 1 Maximum. Permissible Concentrations (MPC), are expressed in terms of concentrations, which if not exceeded, ensure that the annual exposure to any member of the public will be less than 500 mrem dose in a year. The current SHNPP Technical Specification 3/4.11.2.1 implements the Part 20 limits by directly stating the specific dose rate limits (500 mrem/year whole body, etc).

Generic Letter 89-01 proposed changes to be made to the Technical Specifications that would remove the procedural details in the TS Limiting Conditions of Operation that control radioactive effluents and replace them with programmatic controls in the Administrative Controls Section of the Technical Specifications. Part of the proposed programmatic controls included a reference to the limitations on dose rates associated with 10 CFR 20, Appendix B, Table II, Column 1 ~ Given the Part 20 in effect at the time, implementation of the RETS TSCR would have had no effect on the level of effluent controls. The change would simply have replaced the numerical limits in the SHNPP Technical Specification's with a reference to Part 20 limits. However, the new Part 20 reduced the annual dose permitted for a member of the public from the previous MPC-based 500 mrem/year to an Effluent Concentration (EC) based 100 mrem/yr. The net effect of implementing the new 10 CFR 20 and the GL 89-01 proposed verbiage would have been an unnecessary forced reduction in effluent release rates by a factor of 5.

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ENCLOSURE TO SERIAL: HNP-94-025 This forced reduction applies to the entire nuclear industry. The revised release rate limits would effectively force releases at levels comparable to instrument background. Subsequent NUMARC (NEI) discussions with the NRC resulted in draft NRC guidance to modify the new limits.

I This supplemental Technical Specification change request revises the GL 89-01 proposed wording such that it maintains operational flexibility while retaining the same overall level of effluent control required to meet the design objectives of Appendix I to 10 CFR 50. The revised wording is consistent with draft guidance issued by NRC for comment regarding the modification of Technical Specifications to reflect revisions to 10 CFR Part 20 and it provides the same level of protection to the public that currently exists in the license.

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ENCLOSURE TO SERIAL: HNP-94-025 ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (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. Carolina Power & Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination. The bases for this determination are as follows:

Pro osed Chan e This license amendment requests a line-item improvement to the RETS portion of the SHNPP TS pursuant to the guidance of Generic Letter 89-01. The proposed amendment will incorp'orate programmatic controls for radioactive effluents, radiological environmental monitoring and solid radioactive wastes in the Administrative Controls Section of the TS, and relocate the current procedural details of the current RETS into the Offsite Dose Calculation Manual (ODCM) or Process Control Program (PCP), as appropriate. This amendment will also incorporate changes to the reporting requirements for Effluent Release Reports, references to the new 10 CFR 20 for those sections of Technical Specifications included in the RETS TSCR, and revised terminology for the gaseous effluent release rate limits.

Basis This change does not involve a significant hazards consideration for the following reasons:

II

1. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Transferring the procedural details from the TS to the ODCM and PCP and their replacement with programmatic controls have no impact on plant operation or safety. No safety-related equipment, safety function, or plant operation will be altered as a result of this proposed change. The changes are unrelated to the initiation and mitigation of accidents and equipment malfunctions addressed in the Final Safety Analysis Report.

The proposed revisions to the reporting requirements for Effluent Release Reports, the gaseous effluent release rate limit and the relocation of the old 10 CFR 20.106 requirements to the new 10 CFR 20.1302 have no impact on plant systems, plant operations or accident precursors. The changes to Page E2-1

ENCLOSURE TO SERIAL: HNP-94-025 the Effluent Report requirements and the updated reference to 10 CFR 20.1302 are administrative in nature. The change to the gaseous effluent release limit is also administrative in nature in that it will allow the continued operation of the facility with the same release rate limits as are currently implemented by the Technical Specifications.

Therefore, there would be no increase in the probability or consequences of an accident previously evaluated.

The proposed amendment" does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Transferring the procedural details from the TS to the ODCM and PCP and their replacement with programmatic controls have no impact on plant operation or safety. No safety-related equipment, safety function, or plant operation will be altered as a result of this proposed change. No changes to plant components or structures are introduced which could create new accidents or malfunctions not previously evaluated.

The proposed revisions to the reporting requirements for Effluent Release Reports, the gaseous effluent release rate limit and the relocation of the old 10 CFR 20.106 requirements to the new 10 CFR 20.1302 have no impact on plant systems, plant operations or accident precursors. The changes to the Effluent Report requirements and the updated reference to 10 CFR 20.1302 are administrative in nature. The change to the gaseous effluent release limits is also administrative in nature in that it will allow the continued operation of the facility with the same release rate limits as are currently implemented by the Technical Specifications.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment does not involve a significant reduction in the margin of safety.

The procedural details of the current RETS will be transferred to the ODCM and PCP and replaced with programmatic controls consistent with regulatory requirements, including controls on revisions to the ODCM and PCP. Thus, no requirements or controls will be reduced.

The changes to the Effluent Report requirements and the updated reference to 10 CFR 20.1302 are administrative in nature and therefore have no effect on the margin of safety. The proposed revisions to the gaseous effluent release limits will maintain the release rate limits at the same level as currently implemented by, the Technical Specifications.

Therefore, there will be no change in the types and amounts of effluents that will be released, nor will there be an increase in individual or cumulative radiation exposures to any member of the public.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Page E2-2

ENCLOSURE TO SERIAL: HNP-94-025 ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS ENVIRONMENTAL CONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3) result in an increase in individual or cumulative occupational radiation exposure. Carolina Power 6 Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e This license amendment requests a line-item improvement to the RETS portion of the SHNPP TS pursuant to the guidance of Generic Letter 89-01. The proposed amendment will incorporate programmatic controls for radioactive effluents, radiological environmental monitoring and solid radioactive wastes in the Administrative Controls Section of the TS, and relocate the current procedural details of the current RETS into the Offsite Dose Calculation Manual (ODCM) or Process Control Program (PCP), as appropriate. This amendment will also incorporate changes to the reporting requirements for Effluent Release Reports, references to the new 10 CFR 20 for those sections of Technical Specifications included in the RETS TSCR, and revised terminology for the gaseous effluent release rate limits.

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed change does not reduce the level of radiological effluent control. This change is administrative in nature and is requested in Page E3-1

ENCLOSURE TO SERIAL: HNP-94-025 conformance with Generic Letter 89-01 as part of the line-item improvement program. It will provide programmatic controls of for RETS consistent with procedural details of regulatory requirements and allow relocation the the current RETS to the ODCM or PCP. Relocating the procedural details of the current RETS to the ODCM and PCP will not reduce the level of radiological effluent control.

The proposed revisions to the reporting requirements for Effluent Release Reports and the relocation of the old 10 CFR 20.106 requirements to the new 10 CFR 20.1302 have no impact on plant systems or plant operations that would influence the type or quantity of effluents released from SHNPP. The change to the gaseous effluent release limits allow the continued operation of the facility with the same release rate limits as are currently implemented by the Technical Specifications. This change has no impact on the type of effluent.

As such, the change can not affect the types or amounts of any effluents that may be released offsite.

The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure.

This change is administrative in nature and is requested in accordance with Generic Letter 89-01 as part of the line-item improvement program.

Relocating the procedural details of the current RETS to the ODCM and PCP will not reduce the level of radiological effluent control. This change provides programmatic controls for RETS consistent with regulatory requirements. The removal of procedural details from the TS has no impact on plant operation or occupational radiation exposure.

The changes to the Effluent Report requirements and the updated reference to 10 CFR 20.1302 are administrative in nature and therefore have no effect on individual or cumulative occupational radiation exposure. The change to the gaseous effluent release limits would allow the continued operation of the facility with the same release rate limits as are currently implemented by the Technical Specifications, there should be no affect on either individual or cumulative occupational radiation exposure.

Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

Page E3-2

ENCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS PAGE CHANGE INSTRUCTIONS Removed Pa e Inserted Pa e vi xii xii xvi xix Xix xx XX 1-4 thru 1-4 1-6 1-5 1-6 3/4 3-75 thru 3/4 3-75 3/4 3-81 3/4 3-82 and 3/4 3-82 3/4 3-83 3/4 3-83 3/4 3-84 3/4 3-85 and 3/4 3-85 3/4 3-86 3/4 3-86 3/4 3-87 3/4 3-88 3/4 3-88 3/4 11-1 thru 3/4 11-1 3/4 11-6 3/4 11-7 3/4 11-7 3/4 11-8 thru 3/4 11-8 3/4 11-14.

3/4 11-16 3/4 11-16 3/4 11-17 and 3/4 11-17 3/4 11-18 3/4 11-19 3/4 11-19 3/4 12-1 thru 3/4 12-1 3/4 12-14

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Removed Pa e Inserted Pa e B 3/4 3-5 and B 3/4 3-5 B 3/4 3-6 B 3/4 3-6 B 3/4 11-1 thru B 3/4 11-1 B 3/4 11-6 B 3/4 11-2.

B 3/4 12-1 and B 3/4 12-1 B 3/4 12-2 6-19a 6-19b 6-21 thru 6-21 6-23 6-22 6-23 6-26 thru 6-26 6-29 6-27 6-28