ML16342C302

Forwards License Amend Request 93-04 to Licenses DPR-80 & DPR-82,revising TS 5.1.3, Map Defining Unrestricted Areas & Site Boundary for Radioactive Gaseous & Liquid Effluents, for Consistency w/10CFR20

ML16342C302
Person / Time
Site:	Diablo Canyon
Issue date:	07/07/1993
From:	Rueger G PACIFIC GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML16342A168	List: ML16342A167 ML16342C302 ML20045H648
References
DCL-93-169, NUDOCS 9307210082
Download: ML16342C302 (14)

Text

ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULSTQ INFORMATION DISTRIBUTION+STEM (RIDE)

ACCESSION. NBR:9307210082 DOC:DATE: 93/07/07 NOTARIZED: YES DOCKET FACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific Ga 05000275 50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific Ga 05000323 AUTH. NAME AUTHOR AFFILIATION RUEGER,G.M. Pacific Gas & Electric Co.

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

SUBJECT:

Forwards License Amend Request 93-04 to Licenses DPR-80 &

DPR-82,revising TS 5.1.3, "Map Defining Unrestricted Area's &-

Site Boundary for Radioactive Gaseous -& Liquid Effluents,"

for consistency w/10CFR20.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDV LA 1 1 PDV PD 1 ~

1 PETERSONFS 2 2 INTERNAL: ACRS 6 6 NRR/DE/EELB 1 "-1 NRR/DRCH/HICB 1 1 NRR/DRPW/OTSB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 0 OGC/HDS1 1 0 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1, 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2065) TO ELIMINATEYOUR i LAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

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TOTAL NUMBER OF COPIES REQUIRED: LTTR ~X ENCL

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Pacific Gas and Electric Company 77 Beale Street, Room1451 Gregory M. Rueger P.O. Box 770000 Senior Vice President and San Francisco, CA 94177 General Manager 415/973-4684 Nuclear Power Generation Fax 415/973-2313 July 7, 1993 PG&E Letter No. DCL-93-169 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Re: Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 License Amendment Request 93-04 Revision of Technical Specification 5. 1.3 Change Due to Revision of 10 CFR 20 Gentlemen:

Enclosed is an application for amendment to Facility Operating License Nos. DPR-80 and DPR-82. The enclosed license amendment request (LAR) proposes to revise Technical Specification (TS) 5. 1.3, "Hap Defining Unrestricted Areas and Site Boundary for Radioactive Gaseous and Liquid Effluents," to be consistent with a recent interpretation of the restricted area definition in 10 CFR 20.

The changes proposed in this LAR are not required to address an immediate safety concern. 'PG&E believes the NRC should assign a low priority to the review of the proposed changes. However, to maintain consistency between the TS and 10 CFR 20, PG&E requests that the revised TS be made effective on January 1, 1994.

Sincerely, Gregor M. Rueger CC: Edgar Bailey, DHS Bobby H. Faulkenberry Ann P. Hodgdon f4ary H. Hiller Sheri R. Peterson CPUC Diablo Distribution Enclosure 6170S/85K/PTN/263 rOf (IF' 9307ZR008Z 930707 05000275 PDR ADOCK P PDR

PG Letter No. DCL-93-169 ENCLOSURE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

) Docket No. 50-275 In The Hatter of ) Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY ) No. DPR-80

)

Diablo Canyon Power Plant ) Docket No. 50-323 Units 1 and 2 ) Facility Operating License No. DPR-82 License Amendment Request No. 93-04 Pursuant to 10 CFR 50.90, Pacific Gas and Electric Company hereby applies to amend its Diablo Canyon Power Plant Facility Operating License Nos. DPR-80 and DPR-82 (License).

The proposed changes revise the Technical Specifications (TS) (Appendix A of the Licenses) regarding TS 5. 1.3, "Hap Defining Unrestricted Areas and Site Boundary for Radioactive Gaseous and Liquid Effluents." Information on the proposed changes is provided in Attachments A and B.

These changes have been reviewed and are considered not to involve a significant hazards consideration as defined in 10 CFR 50.92 or an unreviewed environmental question. Further, there is reasonable assurance that the health and safety of the public will not be endangered by the proposed changes.

Sincerely, Gregory M. Rueger Subscribed and sworn to before me Attorneys for Pacific Gas and this 7th day of July 1993. Electric Company Howard V. Golub Christopher J. Warner Adriane D. ee, otary Public Christ pher . Warner ADPIANE D. TOLEFPEE COMM. 4 979198 Notary Pubtio California 6170S/85K ~ sANFPANceco coUNIY g

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ATTACHMENT A REVISION OF TECHNICAL SPECIFICATION 5.1.3 CHANGE DUE TO REVISION OF 10 CFR 20 A. DESCRIPTION OF AMENDMENT REQUEST This license amendment request (LAR) proposes to change Technical Specification (TS) 5. 1.3, "Map Defining Unrestricted Areas and Site Boundary for Radioactive Gaseous and Liquid Effluents," to remove two references to a restricted area.

The proposed changes to the TS are noted in the marked-up copy of the applicable TS (Attachment B).

B. BACKGROUND On May 21, 1991, revisions to 10 CFR 20 were published in the Federal Register. Included in the changes to 10 CFR 20 were the addition of the definition of member(s) of the public and the removal of residential quarters from the definition of unrestricted area.

Member(s) of the public, unrestricted area, and restricted area are defined in the TS for the purpose of personnel protection from radiation and radiological materials during normal plant operations.

In accordance with the definitions in the original version of 10 CFR 20, a restricted area is any area that is controlled by a licensee for the purpose of protecting individuals from exposure to radiation or radioactive materials. Any dose that is received in a restricted area is considered occupational exposure. An unrestricted area is any area in which access is not controlled or limited by the licensee for purposes of protection of individuals from exposure to radiation or radioactive materials, and any area used for living quarters.

In accordance with the new revision to 10 CFR 20, an unrestricted area is any area to which access is neither controlled nor limited by the licensee. A member of the public is any individual outside a restricted area not receiving occupational dose. A member of the public is controlled to more restrictive radiation exposure limits than an individual that receives occupational radiation exposure. The definition of restricted area did not change as a result of the revision to 10 CFR 20.

A recent NRC interpretation of 10 CFR 19. 12 (Reference 1) resulting from the recent revision of 10 CFR 20 was provided to NUMARC in a letter dated September 14, 1992. This interpretation was contained in a series of question and answer sets concerning the revision of 10 CFR 20 that were primarily intended for training NRC inspectors. From information in the question and answer sets, it would appear that the NRC expects that in the future, individuals that infrequently enter a restricted area must be provided (1) some instruction concerning radiation and 6170S/85K

radioactive materials, and (2) must be informed that they are subject to occupational dose limits, regardless of the potential radiological health protection concerns.

In order to limit the number of infrequent visitors that require training concerning radiation and radioactive materials, and to allow them to be more appropriately controlled to member-of-the-public dose limits, the size of the restricted area is being reduced to eliminate areas where exposure is well below allowable member-of-the-public dose limits.

C. JUSTIFICATION Redefining the restricted area will allow Diablo Canyon Power Plant (DCPP) to comply with recent interpretations of 10 CFR 19. 12 expected to be implemented in the future. Additionally, the deletion of the restricted area from TS 5. 1.3, Figure 5. 1-3, allows radiation exposure for members of the public and certain classifications of employees to be more appropriately controlled to member-of-the-public dose limits when on portions of the site where no radiological health protection concerns exist.

D. SAFETY EVALUATION The restricted area is currently defined in Figure 5. 1-3 of TS 5. 1.3 as all property within the site boundary. Upon removal of the reference to restricted area from Figure 5. 1-3, a new, smaller restricted area will be established. The new restricted area will be defined and controlled in plant procedures in accordance with the requirements of the recent revision to 10 CFR 20.

Environmental monitoring of the area between the unrestricted area and the new, smaller restricted area has demonstrated that dose in the proposed controlled area resulting from normal plant operations is well below the member-of-the-public dose limits. Consequently, a radiological health protection concern does not exist, and the removal of the restricted area from Figure 5. 1-3 will have no affect on the dose that a member of the public receives.

The removal of the restricted area from Figure 5. 1-3 will have no impact on the determination of effluent release doses since the effluent release dose rates are based on the site boundary. The removal of the restricted area will have no impact on the emergency plan, since emergency plan limits are based on the exclusion area boundary.

Finally, the removal of the restricted area will have no impact on the security plan since the area previously designated as a restricted area will still be controlled by PG&E. Current security procedures are adequate to limit access to the area between the unrestricted area and the new, smaller restricted area.

Based on the above evaluation, PGKE believes there is reasonable assurance that the health and safety of the public will not be adversely affected by the proposed TS changes.

6170S/85K

E. NO SIGNIFICANT HAZARDS EVALUATION PGLE has evaluated the no significant hazards considerations involved with the proposed amendment, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or a testing facility involves no significant hazards considerations, 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; 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 following evaluation is provided for the no significant hazards consideration standards.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

A change to the defined restricted area has no affect on any plant operating parameters. Consequently, a change to the defined restricted area will not affect the probability or consequences of an accident occurring.

Therefore, the proposed changes does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed revision to the DCPP TS is administrative in nature.

Further, the proposed changes would not result in any physical alteration to any plant system, and there would not be a change in the method by which any safety-related system performs its function.

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

3. Does the change involve a significant reduction in a margin of safety?

The proposed revision to the DCPP TS does not affect the margin of safety of any accident analysis since it does not affect the parameters for any accident analysis, and has no effect on the 6170S/85K s

current operating methodologies or actions which govern plant performance.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above safety evaluation, PG&E concludes that the changes proposed by this LAR satisfy the no significant hazards consideration standards of 10 CFR 50.92(c) and, accordingly, a no significant hazards finding is justified.

G. ENVIRONMENTAL EVALUATION PGLE has evaluated the proposed changes and determined the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed changes is not required.

H. REFERENCES

1. Letter from F. Congel to J. Schmitt dated September 14, 1992 6170S/85K

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