ML20046D191

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Proposed Change to OL (PCOL-93/06) to License NPF-29, Revising TS to Support Compliance W/New Requirements of 10CFR20 & 10CFR50.36a
ML20046D191
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 08/11/1993
From: Hutchinson C
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046D192 List:
References
GNRO-93-00074, GNRO-93-74, NUDOCS 9308160281
Download: ML20046D191 (13)
v • d • e


Text

_ _ _ _ _ _ - --- _ - - - _ _ - _ - _ _ - -

e Ent2rgy Optrctions,Inc.

-:: "c am ENTERGY Rrt Gbs:n LG 091s0 L 60! 437 2833 C. R. Hutchinson 8

nesa.e h't* SI f'Cij August 11, 1993 axe ca n em ran U.S. Nuclear Regulatory Commission Mail Station PI-37 Washington, D.C. 20555 Attention: Document Control Desk

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Subject:

Grand GulfNuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Proposed Amendment to the Operation License for The Revised 10 CFR 20 and 10 CFR 50.36a  !

, (PCOL-93/06)

GNRO-93/00074 i

L Gentlemen:

Entergy Operations, Inc. is submitting by this letter a proposed amendment to the Grand Gulf Nuclear Station (GGNS) Operating License. This proposed amendment makes changes to the GGNS Technical Specifications (TS) to suppon compliance with the new requirements of Title 10 Code of Federal Regulations Part 20 and Part 50.36a.

Attachment 2 provides a detailed description of the proposed changes, associated justification, and the No Significant Hazards Considerations basis. - Attachment 3 is a copy of the marked-up TS pages, and Attachment 4 is an information copy of the Proposed TS.

In accordance with the provisions of 10CFR 50.4, the signed original of the requested amendment is enclosed. This amendment request has been reviewed and accepted by the Phnt Safety Review Committee and the Safety Review Committee.

Yours truly, j f' p/ 160051 C. R. Hutchinson Vice President, Operations, GGNS I

93081602e1 930s11 v \ l PDR ADOCK 05000426 N P ppy g

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l August 11:, 1993 'i GNRO-93/00074 i Page 2 of 2 .  ;

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- attachments: 1. Aflirmation per 10CFR50.30  ;

2. GGNS PCOL-93/06 t
3. Mark-up of Affected Technical Specification Pages ' i
4. Proposed Technical Specification Pages - Information Only  !

cc: Mr. R. H. Bernhard (w/a)

Mr. D, C. Hintz (w/a) l Mr. R. B. McGehee (w/a)

Mr. N. S, Reynolds (w/a)  !

Mr. H. L. Thomas (w/o) .(

Mr. Stewart D. Ebneter (w/a)

Regional Administrator  ;

U.S. Nuclear Regulatory Commission, Region II i 101 Marietta St., N.W., Suite 2900 ,

Atlanta, Georgia 30323 l Mr. P. W. O'Connor, Project Manager (w/2) ,

OfIice of Nuclear Reactor Regulation .

U.S. Nuclear Regulatory Commissir ne Mail Stop 13H3 ,

Washington, D.C. 20555 .

Dr. Alton B. Cobb (w/a)

State Health Oflicer ]

State Board ofHealth P. O. Box 1700 Jackson, Mississippi 39205 I

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Grand GulfNuclear Station Attachment I to GNRO-93/00074 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and ,

SYSTEM ENERGY RESOURCES, INC.

and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIAT!ON and ENTERGY OPERATIONS,INC.

MFIRMATION I, C. R. Hutchinson, being duly sworn, state that I am Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association 1 am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the i matters set forth therein are true and correct to the best of my knowledge, information and belief. .

/*

C. R. Ilutchinson STATE OF MISSISSIPPI COUNTY OF CLAIBORNE SUBSCRIBED AND SWORN TO before me, a Notary Public, in and for the County and State - '

above named,this //td day of /2aaful

,1993.

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(SEAL) b e h bal/stNadj-

//' Notag Public /

My commission expires: wggggg i

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i Grand GulfNuclear Station Attachment 2 to GNRO-93/00074 i PCOL 93/06 Page1 of10  !

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i PROPOSED CIIANGE TO TIIE  !

GRAND GULF NUCLEAR STATION OPERATING LICENSE  !

.i FOR TIIE REVISED 10 CFR PART 20 and 10 CFR PART 50.36a (GGNS PCOL 93/06) ,

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Grand Gulf Nuclear Station Attachment 2 to GNRO-93/00074  :

PCOL 93/06 Page 2 of 10 A. DESCRIPTION OF PROPOSED CHANGES:

Background [

The Standards for Protection against Radiation (10CFR20) have been revised by the Nuclear ,

Regulatory Commission with mandatory compliance as of January 1,1994. The revised i 10CFR20 provides an increase in the overall protection of the public safety and amounts to a ,

redefmition of adequate protection based on developments in underlying radiation protection  :

principles and scientific advancements in the last thiny years. The changes below are necessary; i to implement the revised 10CFR20 at Grand Gulf Nuclear Station (GGNS). .l Also,10CFR50.36a has been revised to allow an annual submittal for the Radioactive Emuent +

Release Report rather than semiannual, in response to Presidential memoranda on reducing l

regulatory burden. Therefore, GGNS Technical Specification references to the Semiannual  !

Radioactive EfHuent Release Report are being changed to the Annual Radioactive Effluent Release Report.

Details  !

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1. The proposed change to GGNS Technical Specification Definitions section updates:  !

a) Technical Specification 1.24 for MEMBER (s) OF THE PUBLIC l b) Technical Specification 1.40 for SITE BOUNDARY c) Technical Specification 1.46 for UNRESTRICTED AREA.  ;

2. The proposed change to GGNS Technical Specification 6.8.3.d.2 revises the reference to i the liquid concentration release rate limit. .j
3. The proposed change to GGNS Technical Specification 6.8.3.d,7 revises the reference to the gaseous release rate limits.  !
4. The proposed change to GGNS Technical Specifications updates the following sections to  ;

incorporate the corresponding references to the resised 10CFR20 paragraphs and to reflect the terminology change in 10CFR20, Appendix B, from Table 11 to Table 2:

a) The proposed change to GGNS Technical Specification 6.8.3.d.3 incorporates the. t corresponding reference in the revised 10CFR20 regarding monitoring, sampling and analysis ofliquid and gaseous efHuents.-

b) The proposed change to GGNS Technical Specification 6.9.1.5.1 updates footnote 2 to incorporate the corresponding reference in the revised 10CFR20 regarding the reports  ;

ofindividual monitoring. j c) The proposed change te GGNS Technical Specification 6.12.1 incorporates the corresponding reference in the revised 10CFR20 regarding high radiation areas.

d) The proposed change to GGNS Technical Specifications section 6.14.a.2 resises the reference regarding radioactive efIluent control to incorporate the corresponding paragraph in the new 10CFR20. j e) ne proposed change to GGNS Technical Specification Bases section 3/4.11.1.4 l reflects the terminology change in 10CFR20, Appendix B, from Table 11 to Table 2. i

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Grand Gulf Nuclear Station Attachment 2 to GNRO-93/00074 PCOL 93/06. Page 3 of10

5. The proposed change to GGNS Technical Specification 6.10.2.c requires records of radiation exposure, as required by 10CFR20, be retained for the duration of the unit operating license.
6. The proposed change to GGNS Technical Specification section 6.12.2 requires radiation measurements to be made at 30 cm from the source of radioactisity, as required by the new 10CFR20.1601(a).
7. The proposed change in GGNS Technical Specifications updates the following sections to where they refer to the submittal frequency requirements of the Radiological Efiluent

_ Release Report to be consistent with the requirements of the revised 10CFR50.36a:

a) Technical Specification Index 6.9 b) Technical Specification Definition 1.26 c) Technical Specification Section 3.11.1.4.a d) Technical Specification Section 6.9.1.8 e) Technical Specification Section 6.14.c B. DISCUSSION:

1. The proposed change to the MEMBER (s) OF THE PUBLIC and UNRESTRICTED AREA definitions are necessary to comply with the definitions in the resised 10CFR20.1003. The proposed change to the definition of SITE BOUNDARY is a clarification to be consistent with the definition in the revised 10CFR20.1003.
2. The proposed change to the liquid concentration release limit is being made in order to accommodate needed operational flexibility to facilitate implementation of the new 10CFR20 requirements.
3. The proposed change to the gaseous release rate limit is being made in order to accommodate operational flexibility to facilitate irnplementation of the new 10CFR20 requirements.
4. Several sections of the GGNS Technical Specifications require update to incorporate the corresponding references to the revised 10CFR20 paragraphs and to reflect the terminology changes.

a) The proposed change to GGNS Technical Specification 6.8.3.d.3 reflects the relocation of the old 10CFR20.106 requirements to the new 10CFR20.1302. This change is an administrative clarification and is consistent with the requirements of the resised 10CFR20.

b) Footnote 2 in 6.9.1.5.1 contains a reference to 10CFR20.407. The proposed change revises the reference in Footnote 2 to the corresponding paragraph in the new 10CFR20, paragraph 20.2206.

c) GGNS Technical Specifications section 6.12.1 contains a reference to paragraph 20.203(c)(2) of 10CFR20 regarding high radiation areas. The proposed change revises the reference to incorporate the corresponding paragraph in the new rule, 10CFR20.1601(a).

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i Grand Gulf Nuclear Station Attachment 2 to GNRO-93/00074 j PCOL 93/06 Page 4 of 10 d) GGNS Technical Specifications section 6.14.a.2 contains a reference to paragraph 20.106 of 10CFR20 regarding radioactive effluent control. The proposed change l revises the reference to incorporate the corresponding paragraph in the new rule,  ;

10CFR20.1302. i e) The proposed change to GGNS Technical Specification Base 3/4.11.1.4 reflects the - f terminology change from 10CFR20, Appendix B, Table 11 to Table 2. This change is i an administrative clarification and is consistent with the requirements of the resised 10CFR20.

5. The proposed change to GGNS Technical Specification 6.10.2.c.for radiation cqosure records is an administrative clarification. This is a change to retain records as required by j~

10CFR20 instead of retaining records for all individuals entering a radiation control area.

It is consistent with the requirements of the revised 10CFR20 for retention of radiation ,

exposure records. Further, it will allow the HP Dosimetery Group to implement work i practices and procedures to better utilize resources and personnel.- -j

6. GGNS Technical Specifications section 6.12.2 requires radiation measurements be made-at 18 inches. The proposed change incorporates the new 10CFR20 requirements to take  ;

measurements at 30 cm as required in 10CFR20.1601(a). y i

7. Revising the submittal frequency of the Radiological Effluent Release Report from semiannual to annual is an administrative change to be consistent with the requirements of  ;

I the revised 10CFR50.36a.

C. JUSTIFICATION FOR Tile PROPOSED CIIANGES

1. MEMBER (s) OF THE PUBLIC is not defined in the old 10CFR20. The revised -

10CFR20.1003 defines MEMBER (s) OF THE PUBLIC as "an individual in a controlled l or UNRESTRICTED AREA. However an individual is not a MEMBER (s) OF THE. j PUBLIC during any period in which the individual receives an occupational dose." The proposed change incorporates the MEMBER (s) OF THE PUBLIC definition of the revised 10CFR20 into section_ l.24 of GGNS Technical Specifications. This change is required .  ;

for compliance with the revised 10CFR20 and will not affect the safe operation of the plant or create a new radiological hazard to plant personnel or the public.

The current definition of SITE BOUNDARY in the GGNS Technical Specification section 1.40 makes reference only to land where the definition in the resised 10CFR20.1003 specifies land or property. This is an administrative clarification only.

The current defmition of UNRESTRICTED AREA in the GGNS Technical Specification - section 1.46 is in compliance with the definition given in the old 10CFR20.103(17). Thel ..

revised definition of an UNRESTRICTED ATWA in the new 10CFR20.1003 is "an area, i access to which is neither limitco er mntrolled by the licensee." The proposed change ensures compliance with the definition of UMESTRICTED AREA in the revised 10CFR20. This change will not imposc a new radiological hazard to the plant staff or the ,

public. ,

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i Grand Gulf Nuclear Station Attachment 2 to GNRO-93/00074 1 PCOL 93/06 Page 5 of 10 [

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2. He proposed change to the liquid concentration release limit is being made in order to v I

accommodate needed operational flexibility to facilitate implementation of the new 10CFR20 requirements. j He basic requirements for Technical Specifications (TS) concerning emuents from nuclear power reactors are stated in 10CFR50.36a. These requirements indicate that compliance [

with efauent TS will keep average annual releases of radioactive material in effluents to i small percentages of the limits specified in the old 10CFR20.106 (new 10CFR20.1302). t Rese requirements further indicate that operational flexibility is allowed, compatible with ,

considerations of health and safety, which may temporarily result in releases higher than - l such small percentages, but still within the limits specified in the old 10CFR20.106 which  !

references Appendix B, Table 11 maximum permissible concentrations (MPCs). These {

referenced concentrations are specific values which relate to an annual dose of 500 mrem.

It is further indicated in 10CFR50.36a that when using operational flexibility, best efforts  :

shall be exerted to keep levels of radioactive materials as low as is reasonably achievable l (ALARA) as set forth in 10CFR50, Appendix 1. l As stated in the Introduction to Appendix B of the new 10CFR20, the liquid emuent  !

concentrations (EC) limits given in Appendix B, Table 2 Column 2, are based on an i annual dose of 50 mrem. Since a release concentration corresponding to a limiting dose rate of 500 mrem / year has been acceptable as a TS limit for liquid effluents, which applies l at all times as an assurance that the limits of 10CFR50, Appendix I are not likely to be .I exceeded, it should not be necessary to reduce this limit by a factor of 10. -

Operational history at Grand Gulf has demonstrated that the use of concentration values associated with the old 10CFR20.106 as TS limits has resulted in calculated maximum i individual doses to a member of the public that are small percentages of the limits of l 10CFR50 Appendix 1. Therefore, the use of concentration values which correspond to an-  !

annual dose of 500 mrem (ten times the concentration values stated in the new 10CFR20, Appendix B, Table 2, Column 2) should not have a negative impact on the ability to - t continue to operate within the limits of 10CFR50, Appendix I and 40CFR190.

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Having sufficient operational flexibility is also important in establishing a basis for effluent -

monitor setpoint calculations. As discussed above, the' concentrations stated in the new l 10CFR20, Appendix B, Table 2, Column 2, rela; to a dose of 50 mrem in a year. When j applied on an instantaneous basis, this corresponds to a dose rate of 50 mrem / year. The  !

concentrations associated with this low value are impractical to base effluent monitor setpoint calculations for many liquid concentration release situations _when monitor ,

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background, monitor sensitivity, and monitor performance must be taken into account. l

_ To accommodate operational flexibility needed for efIluent releases, the limits associated with j the liquid concentration release rate TS are based on ten times the concentrations stated in  !

the new 10CFR20, Ap,endix B, Table 2, Column 2, to apply at all times. The multiplier 1 of ten is proposed because the annual dose of 500 mrem, on which the concentrations in :  !

the old 10CFR20. Appendix B, Table II, Column 2 are based ', is a factor of 10 higher f

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Grand GulfNuclear Station Attachment 2 to GNRO-93/00074 l PCOL 93/06 Page 6 of10 l 3

than the annual dose of 50 mrem, that the concentrations in the new 10CFR20, Appendix l B, Table 2, Column 2, are based.

l Compliance with the limits of the new 10CFR20.1301 will be demondrated by operating  !

l within the limits of 10CFR50, Appendix 1 and 40CFR190.- j l 3. The proposed change to the gaseous release rate limit is being made in order to _

L acce.nnex! ate operational flexibility to facilitate implementation of the new 10CFR20 'i reoairements.

l- The basic requirements for TS conceming emuents from nuclear power reactors are stated in  !

I 10CFR50.36a. These requirements indicate that compliance with effluent TS will keep l average annual releases of radioactive material in emuents to small percentages of the t l- limits specified in the old 10CFR20.106 (new 10CFR20.1302). These requirements t

further indicate that operational flexibility is allowed, compatible with considerations of j health and safety, which may temporarily result in releases higher than such small- j percentages, but still within the limits specified in the old 10CFR20.106 which references Appendix B, Table 11 MPCs. These referenced concentrations are specific values which l

relate to an annual dose of 500 mrem. It is further indicated in 10CFR50.36a that when i using operational flexibility, best efforts shall be exerted to keep levels of radioactive  !

I materials as low as is reasonably achievable (ALARA) as set forth in 10CFR50, Appendix l l- I. {

As stated in the Introduction to Appendix B of the new 10CFR20, the gaseous EC limits  ;

given in Appendix B, Table 2, Column I, are based on an annual dose of 50 mrem for - )

isotopes for which inhalation or ingestion is limiting, or 100 mrem for isotopes for which ,

submersion (noble gases) is limiting. Release concentrations corresponding to limiting i dose rates at the site boundary from noble gases less than or equal to 500 mrem / year to the . j '

whole body and 3000 mrem / year to the skin; and 1500 mrem / year to any organ from .

lodine-131, lodine-133, for tritium and all radionuclides in particulate form with halflives - l greater than eight days have been acceptable as TS limits for gaseous emuents to assure  !

that limits of 10CFR50, Appendix I and 40CFR190 are not likely to be exceeded, it i should not be necessary to restrict the operational flexibility by incorporating the dose rate limit associated with the EC value for isotopes based on the inhalation / ingestion (50 j

i mrem / year) or the dose rate associated with the EC value for isotopes based on submersion  !

(100 mrem / year).

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i. . Having sufficient operational flexibility is also important in establishing a basis for i

- emuent monitor se: point calculations. . As discussed above, the concentrations stated in the l new 10CFR20, Appendix B, Table 2, Column 1, relate to a dose of 50 or 100 mrem in a year. When applied on an instantaneous basis, this corresponds to a dose rate of 50 or 100__

mrem / year The concentrations associated with these low values are impractical upon  !

which to base emuent monitor setpoint calculations for many gaseous release situations when monitor background, monitor sensitivity, and monitor performance must be taken ..

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Grand Gulf Nuclear Station Attachment 2 to GNRO-93/00074 PCOL 93/06 Page 7 of 10 To accommodate operational flexibility needed for efiluent releases, the limits associated with gaseous release rate TS 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 Iodine-131, Iodine-133, for tritium, and for all radionuclides in particulate form with halflives greater than eight days, an instantaneous dose rate limit of 1500 mrem / year to any organ.

Compliance with the limits of the new 10CFR20.1301 will be demonstrated by operating within the limits of 10CFR50, Appendix I and 40CFR190. Operational history at Grand Gulf has demonstrated that the use of the dose rate values listed above (i.e. 500,3000 and 1500 mrem /ycar) as TS limits has resulted in calculated maximum individual doses to a member of the public that are small percentages of the limits of 10CFR50 Appendix L

4. Changes are necessary to reflect the requirements of the revised 10CFR20 references and terminology-a) This administrative change is being made to GGNS Technical Specification 6.8.3.d.3
  • o reflect that the requirements in the old 10CFR20.106 are now located in the new 10CFR20.1302 for monitoring, sampling, and analysis ofliquid and gaseous efiluents.

b) Foott.ote 2 in GGNS Technical Specifications section 6.9.1.5.1 explains the required tabuation which supplements the requirements of 10CFR20.407. .He reference to 10CFR20.407, regarding personnel monitoring reports, is being changed to incorporate the corresponding paragraph in the revised rule,10CFR20.2206. His is .

an administrative change necessary to implement the requirements of the new 10CFR20 and does not reduce the reporting requirements in 6.9.1.5.1. No new radiological hazard is created by this change.

c) GGNS Technical Specifications section 6.12.1 lists the requirements for posting and controlling access to high radiation areas. Rese requirements are an approved alternative method of control as required by 10CFR20.203(c)(5) and -

10CFR20.1601(c). 10CFR20.203(c)(2) lists the controls that must be in place at the entrance or access point to a high radiation area. He corresponding paragraph (s) to 10CFR20.203(c)(2) in the new rule is 10CFR20.1601(a). Both revisions of 10CFR20 require:

1. A control device that reduces the radiation level to < 0.1 rem /hr (the new 10CFR20 requires the radiation measurements be taken at 30 cm.)
2. A control device that energizes a conspicuous visible or audible alarm signal so that the indhidual and the supervisor of the activity are made aware of the entry.
3. A locked entrance, except during periods when access is required, with positive control over each individual entry.

The requirements for the control device referenced in 10CFR20.203(c)(2) and .

10CFR20.1601(a) are essentially the same. GGNS will continue using the approved alternate method of controlling access to High Radiation areas listed in Technical Specification 6.12.1 in lieu of the " control device" or " alarm signal" required by 10CFR20.1601(a). His change will not decrease the ability of GGNS radiation protection programs to provide control of exposure from external sources in restricted areas. Changing the paragraph reference to correspond to the new 10CFR20 is an -

administrative change only.

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Grand GulfNuclear Station Attachment 2 to GNRO-93/00074 PCOL 93/06 Page 8 of 10 d) GGNS Technical Specifications section 6.14.a.2 contains a reference to paragraph 20.106 of 10CFR20 regarding radioactive effluent control. The proposed change revises the reference to incorporate the corresponding paragraph in the new rule, 10CFR20.1302. This is an administrative change necessary to implement the requirements of the new 10CFR20. No new radiological hazard is created by this change, e) This administrative change is being made to GGNS Technical . Specification Basis 3/4. I1.1.4 to revise the reference to the old 10CFR20, Appendix B, Table II, Column 2, to the new 10CFR20, Appendix B, Table 2, Column 2. He limit for the liquid holdup tanks will remain unchanged at 10 Curies, excluding tritium and dissolved or entrained noble gases. This limit is consistent with guidance contained in NUREG ,

0133, which states that the Curie limit for a temporary liquid storage tank be less than  ;

or equal to 10 Curies, excluding tritium and dissolved or entrained gases.  ;

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5. GGNS Technical Specifications section 6.10.2.c. requires exposure reco.-ds be maintained for the duration of the operating license for all individuals entering radiation control areas. l GGNS proposes to amend the record-keeping requirement to retain exposure records "as required by 10CFR20." Neither the old revision of 10CFR20 nor the new revision ,

requires exposure records be maintained for all individuals who enter a radiation control  ;

area. The new 10CFR20.2106(a) requires licensees to " maintain records of doses received j by individuals for whom monitoring is required pursuant to 10CFR20.1502, and records of doses received during planned special exposures, accidents, and emergency conditions." i 10CFR20.2106(f) requires the licensee to " retain each required form or record until the i Commission terminates cach pertinent license requiring the record " Entrance into a 1 radiation control area is not included in the criteria requiring individual monitoring listed in -l 10CFR20.1502. GGNS will continue to comply with the monitoring, reporting and record  !

keeping criteria O OCFR20 and applicable Regulator; Guides. This change will not -l create a new radiological hazard to plant personnel or the public.

6 Changing the distance at which radiation measurements are made in high radiation areas f from 18 inches to 30 cm as required by the new 10CFR20.1601(a) is a conservative change. 30 cm is a shorter distance than 18 inches resulting in higher dose measurements .

for a given radiological source. His change will not create a new radiological hazard to l plant personnel or the public.  ;

7. The annual submittal of the Radiological Efiluent Release Repon is in accordance with report submittal frequency stipulated in 10CFR50.36a. It is an administrative change and  ;

as such, has no impact on plant equipment or methods of operation. Where they occur, j technical specification references to the Semiannual Radioactive Efiluent Release Report  :

have been changed to Annual Radioactive Efiluent Release Report. -j D. NO SIGNIFICANT IIAZARDS CONSIDERATIONS: l i

This proposed amendment to the GGNS Technical Specifications has been evaluated for - ,

significant hazards considerations. In accordance with 10CFR50.91(a), Entergy Operations, l Inc. is providing the analysis of the proposed amendment against the three standards found in  !

10CFR50.92(c). A description of the no significant hazards considerations follows:

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i Grand GulfNuclear Station Attachment 2 to GNRO-93/00074 "

PCOL 93/06 Page 9 of10 l l

- 1. The proposed changes do not significantly increase the probability or consequences of an I accident previously evaluated.-  !

t The proposed resisions to the liquid and gaseous release rate limits and the relocation of the old 10CFR20.106 requirements to the new 10CFR20.1302 and the revision to the TS -

Bases for the Liquid Holdup Tank activity limit will im olve no change in the types or amounts of effluents that will be released, nor will there be an increase in individual or - l cumulative occupational radiation exposures.

The changes of definitions, terminology, paragraph references, and report submittal frequency are necessary to keep GGNS Technical Specifications consistent with resised federal regulations (i.e.10CFR20 and 10CFR50.36a). Record retention and reporting requirements will continue to meet NRC regulations. These changes are administrative in  :

nature and do not affect plant hardware or operation.

Decreasing the distance at which radiation measurements are taken is conservative, and  !

will result in higher measured dose rates for a given radiological source. This change is '!

required by the revised 10CFR20. j i

Based on the above, the proposed changes do not significantly increase the probability or i consequences of an accident previously evaluated. l

2. He proposed changes would not create the possibility of a new or different kind of accident from any previous analyzed.

The proposed changes will not affect plant equipment or operation, nor will they result in a l

change to the configuration of any plant equipment. There will be no change in the types  !

or increase in the amount ofeffluents released offsite. Herefore, these changes will not j create the possibility of a new or different kind of accident from any previously evaluated.  !

3. The proposed changes do not involve a significant reduction in a margin of safety. l

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l The proposed revisions do not involve any changes in the types or mercases m the amounts -- i of efiluents released offsite. The methodology used to control radioactive effluents and 1 calculate effluent monitor setpoints will result in the same effluent release rate as the  :

current methodology. The basic requirements for TS conceming effluent releases ,1 (10CFR50.36a) indicate that compliance with TS will keep average annual releases to 'l small percentages of 10CFR20 limits. For liquid effluent releases, the annual dose of 500 mrem, upon which the concentrations in the old 10CFR20 are based, is a factor of 10 -

higher than the annual dose upon which the concentrations in the new 10CFR20 are based.

The 50.36a requirements further indicate that operational flexibility is allowed, compatible with considerations of health and safety, which may temporarily result in releases higher than such small percentages, but still within the limits specified in the old 10CFR20.106

which references Appendix B maximum permissible concentrations (MPCs). For gaseous effluent releases, the limits associated with the gaseous release rate TS will be maintained 1- et the current instantaneous dose rate limits. Compliance with the limits of the new I i
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Grand GulfNuclear Station Attachment 2 to GNRO-93/00074 l PCOL 93/06 Page 10 of10  ;

i 10CFR20.1301 will be demonstrated by operating within the limits of 10CFR50, f Appendix I and 40CFR190.  !

Use of a shorter measurement distance for determining high radiation areas is a -

conservative change, and will not result in an increase in indisidual or cumulative  !

occupational exposures. '[

The administrative changes are necessary to keep GGNS Technical Specifications i consistent with revised federal regulations. Record retention and reporting requirements .f will continue to meet NRC regulations. These changes will not affect plant hardware,'

operation, or configuration. l Therefore, the proposed changes will not involve a significant reduction in a margin of j safety. l Based on the above evaluation, operation in accordance with the proposed amendment involves no f significant hazard. [

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REFERENCES:

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1. Grand Gulf Nuclear Station Unit 1 Technical Specifications and Bases, Updated through f Amendment 105 i i
2. Title 10, Code of Federal Regulations, Part 20

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3. NRC Questions and Answers on New Part 20 - Sets No.1,2,3, & 4 l i
4. Title 10, Code of Federal Regulations, Part 50.36a .l
5. Letter from F.J. Congel (NRR) to J.F. Schmitt (NUMARC)  !
6. NUREG 0133, section 4.8, pages 17-18;3.e  ;

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'7. Illinois Power Technical Specification Change Submittal

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8. Duke Power Techn; cal Specification Change Submittal & NRC Approval i

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