Text

Proposed Tech Specs Pages Re Amends to Licenses DPR-39 & DPR-48,eliminating License Conditions No Longer Applicable & Replacing Existing Operational Custom TS with Permanently Defueled TS
	ML20154E344
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	10/02/1998
From:	; COMMONWEALTH EDISON CO.
To:	;
Shared Package
ML20154E342	List: A98020, Application for Amends to Licenses DPR-39 & DPR-48,to Eliminate License Conditions No Longer Applicable & Replace Existing Operational Custom TS with Permanently Defueled TS; ML20154E344;
References
	NUDOCS 9810080153
	Download: ML20154E344 (98)
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I TABLE OF CONTENTS SPECIFICATIONS

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i L TABLE OF CONTENTS L

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1.0 USE AND APPLICATION j

i. l l 1.1 Defin itio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...............................1-1 i l- ,

1.2 LogicaI Connectors... ... .. ..... ................. . ............... ....... ....... 1-2 l 1.3 Completion Times . ............. .... . ...........................................1-4 1.4 Freq u e n cy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -5 2.0 SA F ETY LI M ITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2- 1 i 4

3.0- LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY . . .. 3-1 !

SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .. . ...... .......... 3-2 l 1

. I 3.1 DEFUELED PLANT SYSTEMS I i

3.1.1 Spent Fuel Pool Water Level.. . . . . . . . . . . .... ..................3-3 ,

3.1.2 Spent Fuel Pool Boron Concentration... ....... ..... .. ....... . ....... ........ 3-4 3.1.2 Spent Fuel Assembly Storage..... . .. ....... ............. .. .... . ....... . .. 3-6 l -4.0 DESIGN FEATURES r

L 4.1 S ite . . . . . . . . . . . . . . ...........................................................4-1 l 4.2 F u e l S to ra g e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 -2 5.0 ADMINISTRATIVE CONTROLS 5.1 Re s p o n s i b ility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 l

5.2 O rg a n iza tio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 5.3 Facility Staff Qualifications . ..... ......... .. ... ............ ....... ..... .......... 5-5

! 5.4 Training ....... . . . . . .. . .. . . . .. .. . ... . ..... ....... 5-6 5.5 Procedures.. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 5-7 5.6 _ Programs and Manuals . . .. ... ... .... . . . . . . . . . . . . . . . . . . .. ....... 5-8 5.7 Reporting Requirements ... .. . . .. ..........,......5-14 5.8 H ig h Ra d lation Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-16 5.9 R e v iews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..................5-19 l

9810000153 98100p ~

PDR ADOCK 05000d95 P

PDR r

ZION Units 1 & 2 i Amendment Nos. and

D:finitions 1.1 1

1.0 USE AND APPLICATION l

1.1 Definitions

N OTE- -

j The defined terms of this section appear in capitalized type and are applicable throughout these Technica! Specifications and Bases.

l Term Definition l ACTIONS ACTIONS shall be that part of a Specification j that prescribes Required Actions to be taken i under designated Conditions within specified '

Completion Times.

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A Zion Station 1-1 Amendment Nos. and i

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Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings. l l

l BACKGROUND Several levels of logic may be used to state Required Actions.

These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number .

and by successive indentions of the logical connectors.

If logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

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1 Zion Station 1-2 Amendment Nos. and ;

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Logical Connectors i 1.2 )

1.2 Logical Connectors (continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 l 1

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Verify . . .

AND l A.2 Restore . . .

In this example, the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed.

EXAMPLE 1.2-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Trip . .

OR A.2.1 Verify .

AND A.2.2. Reduce. .

This example represents a more complicated use of logical connectors. Required Actions A.1 and A.2 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Either of the Actions may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND.

Zion Station 1-3 Amendment Nos. and

Completion Timss 1.3 l

1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe storage of irradiated fuel. The l ACTIONS associated with an LCO state Conditions that typically l describe the ways in which the requirements of the LCO can fail to )

be met. Specified with each stated Condition are Required Action (s) l and Completion Time (s).

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l DESCRIPTION The Completion Time is the amount of time allowed for completing a l Required Action. It is referenced to the time of discovery of a l situation (e.g., variable not within limits) that requires entering an ,

ACTIONS Condition unless otherwise specified. Required Actions l must be completed prior to the expiration of the specified Completion l Time. An ACTIONS Condition remains in effect and the Required l Actions apply until the Condition no longer exists or the unit is not l within the LCO Applicability.

IMMEDIATE When "Immediately"is used as a Completion Time, the COMPLETION Required Action should be pursued without delay and in a controlled l TIME manner.

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l f Zion Station 1-4 Amendment Nos. and

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Frequency

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1.0 USE AND APPLICATION 1.4 Frequency

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PURPOSE The purpose of this section is to discuss the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated LCO. An understanding of the correct application of the specified 1 Frequency is necessary for compliance with the SR. l The "specified Frequency" is referred to throughout this section and ,

each of the Specificationsof Section 3.0, Surveillance Requirement )

(SR) Applicability. The "specified Frequency" consists of the 1 requirements of the Frequency column of each SR as well as certain Notes in the Surveillance column that modify performance requirements.

EXAMPLES The following examples illustrate the various ways that Frequencies are specified, in these examples, the Applicabilityof the LCO (LCO not shown)is when irradiated fuelis stored in the spent fuel pool.

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Zion Station 1-5 Amendment Nos. and

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-1 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify parameteris within limits. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performanceof the Surveillance initiates the subsequentinterval. Although the Frequencyis stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time intervalto 1.25 times the stated Frequency is allowed by SR 3.0.2 for operationalflexibility.

The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when a variable is outside specified limits, or the facility is outside the Applicabilityof the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is the specified condition in the Applicabilityof the LCO, and the performance of the Surveillanceis not otherwise modified, then SR 3.0.3 becomes applicable.

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1 Zion Station 1-6 Amendment Nos. and

Frequency l 1.4 j 1.4 Frequency EXAMPLES EXAMPLE 1.4-2 1 (continued) . {

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l Verify parameteris within limits. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to moving irradiated fuel AND I l 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter l

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Example 1.4-2 has two Frequencies. The first is a one-time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector"AND" indicates that both Frequency requirements must be met. The use of " prior to" indicates that the surveillance must be performed once before the initiation of fuel handling activities. This type of Frequency does not qualify for 25% extension allowed by SR 3.0.2. "Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example).

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( Zion Station 1-7 Amendment Nos. and

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Safety Limits 2.0 t t

- 2.0 ' SAFETY LIMITS ,

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This section is not applicable to defueled facilities'. -

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LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

, l LCO 3.0.1 LCOs shall be met during the specified conditions in the y

Applicability, except as provided in LCO 3.0.2.

l LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met.

If the LCO is met or no longer applicable prior to expiration of the specified Completion Time (s), completion of the Required Action (s) is not required, unless otherwise stated.

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] Zion Station 3-1 Amendment Nos. and 1

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SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during specified conditions in the Applicability for the individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance whether such failure is experienced during performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO, except as provided in SR 3.0.3. Surveillances do not have to be performed on variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

SR 3.0.3 If it is die % +9tcd that a Surveillance was not performed within its specPri et e1.ency, then compliance with the requirement to decla: M 'MO not met may be delayed from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less. This delay per;od is permitted to allow performance of the Surveillance.

If the Surveillance is not performed within the delay period, the LCO must be immediately declared not met and the applicable Condition (s) must be entered. The completion times of the Required Actions begin immediately upon expiration of the delay period.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition (s) must be entered. The completion times of the Required Actions begin immediately upon failure to meet the Surveillance.

Zion Station 3-2 Amendment Nos. and I

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Sp::nt Fusi Pool Water Level 3.1.1 3.1 DEFUELED PLANT SYSTEMS 3.1.1 Spent Fuel Pool Water Level LCO 3.1.1 The spent fuel storage water level shall be 123 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the spent fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spent fuel pool water A.1 Suspend movement of Immediately level not within limit. irradiated fuel assemblies in the spent fuel pool.

I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify the spent fuel pool water level is 2 23 ft Within 24 '

above the top of the irradiated fuel assemblies hours prior to seated in the storage racks. movement of .

irradiated fuel assemblies, i

AND and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

Zion Station 3-3 Amendment Nos. and

l l- Spent Fuel Pool Boron Concentration

! 3.1.2 l

3.1 DEFUELED PLANT SYSTEMS '

l 3.1.2 Spent Fuel Pool Boron Concentration LCO 3.1.2 The spent fuel pool boron concentration shall be 2. 500 ppm.

APPLICABILITY: During movement of fuel assemblies in the spent fuel pool, or l l

l When fuel assemblies are stored in Region 2 of the spent fuel pool and a spent fuel pool verification has not been i performed since the last movement of fuel assemblies in the '

spent fuel pool.

l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Spent fuel pool boron A.1 Suspend movement of Immediately concentration not fuel assemblies in the within limit. spent fuel pool.

AND A.2.1 Initiate action to restore spent fuel pool immediately boron concentration to within limit.

_0_B A.2.2 Verify by administrative means immediately l Region 2 spent fuel pool verification has been performed since the last movement of fuel assemblies in the .

l spent fuel pool.

i Zion Station 3-4 Amendment Nos. and

Spent Fuel Pool Boron Concentration 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILANCE FREQUENCY SR 3.'1.2.1 Verify the spent fuel pool boron concentration is Within 31 days within limit. prior to movement of irradiated fuel essemblies.

AND 31 days thereafter.

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Zion Station 3-5 Amendment Nos. and :

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Spent Fual Assembly Storaga 3.1.3 l

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3.1.3 Spent Fuel Assembly Storage !

LCO 3.1.3 The combination of initial enrichment and discharge fuel burnup !

of each spent fuel assembly stored in Region 2 shall be within the Acceptable Burnup Domain of Figure 3.1.3-1. '

APPLICABILITY: Whenever any fuel assembly is stored in Region 2 of the spent l

fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION l

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l A. Requirements of the A.1 Initiate action to move the immediately LCO not met. noncomplying fuel assembly from Region 2.

l SURVEILLANCE REQUIREMENTS SURVEILANCE FREQUENCY J SR 3.1.3.1 Verify by administrative means the initial Prior to storing enrichment and discharge fuel burnup of the the fuel fuel assembly.is in accordance with Figure assembly in 3.1.3-1. Region 2 1

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- Zion Station 3-6 Amendment Nos. and 4 i

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1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 INITIAL EMICH1ENT, s0-235 Figure 3.1.3-1 (Page 1 of 1)

Fuel Assembly Burnup Limits in Region 2 Zion Station 3-7 Amendment Nos. and

Dasign Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location Zion Units 1 and 2 are located at the Zion Station which consists of a tract of land of approximately 250 acres located in the extreme eastern portion of the city of Zion, Lake County, Illinois, on the west shore of Lake Michigan approxirnately 6 miles NNE of the center ci the city of Waukegan, Illinoir, and 8 miles south of the center of the city of Kenosha, Wisconsin. It is located at longitude 87 48.1' W and latitude 42 26.8' N.

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Zion Station 4-1 Amendment Nos. and

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I Design Features 4.0 4.0 DESIGN FEATURES 4.2 Fuel Storage 1 4.2.1 Criticality 4.2.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.65 weight percent;

b. keff < 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties;

c. A nominal 9.14 inch center to center distance between fuel assemblies placed in Region 2 of the spent fuel storage racks; i

d. A nominal 10.54 inch north-south and 10.78 east-west center to center distance between fuel assemblies placed in Region 1 of the spent fuel storage racks;

e. One row of six storage cells with a nominal 18.75 inch l center to center distance between cells for storing failed fuel l canisters in Region 1 of the spent fuel storage racks;

f. Irradiated fuel assemblies with a discharge burnup in the j

" acceptable burnup domain" of Figure 3.1.3-1 allowed unrestricted storage in either Region 1 or Region 2 of the spent fuel storage rack (s); and

g. New or irradiated fuel assemblies with a discharge burnup in the

" unacceptable burnup domain" of Figure 3.1.3-1 stored in Region 1 of the spent fuel storage racks.

i Zion Station 4-2 Amendment Nos. and i

i Design Features 4.0 t 4.2 Fuel Storage 4.2.1 Criticality (continued -

4.2.1.2 The new fuel storage racks are designed and shall be maintained with:

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a. Fuel assemblies having a maximum U-235 enrichment of 4.65 weight percent; i

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b. keft 5 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties; and

c. A nominal 21 inches center to center distance between fuel assemblies placed in the storage racks.

4.2.2 Drainaae The spent fuel pool is designed and shall be maintained to prevent

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draining of the pool below elevation 598 ft.

4.2.3 Capacity The spent fuel pool is designed and shall be maintained with a storage capacity limited to no more than 3012 fuel assemblies.

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Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The Decommissioning Plant Manager shall be responsible for overall plant operations and shall delegate in writing the succession to this responsibility during his absence.

The Decommissioning Plant Manager or his designee shall approve, prio-to implementation, each proposed test, experiment, or modification to systems or equipment that affect the safe storage of nuclear fuel.

5.1.2 The Shift Supervisor shall be responsible for the shift command function.

Zion Station 5-1 Amendment Nos. and

1 Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 General Oraanizational Reauirements l

Onsite and offsite organizations shall be established for station and i corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting the safe storage and handling of nuclear fuel.

a. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the Quality Assurance Manual or a site specific quality assurance program description incorporated directly or by reference in the DSAR.

b. The Decommissioning Plant Manager shall be responsible for overall plant safety and shall have control over those onsite activities necessary for safe storage and handling of nuclear fuel.

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c. A Corporate Vice-President shall have corporate responsibility for the safe handling and storage of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure the safe handling and storage of nuclear fuel.

d. The individuals who train the Certified Fuel Handlers and those who carry out health physics and quality assurance functions may report to an appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

(continued)

Zion Station 5-2 Amendment Nos. and

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Organization l 5.2 5.2 Organization (continued) l 1

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 5.2.2-1.

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b. At least one person qualified to stand watch in the control room (non-certified operator or Certified Fuel Handler) shall be present in !

the control room when nuclear fuel is stored in the spent fuel pool. l

c. All fuel handling operations shall be directly supervised by a Cen;ried Fuel Handler,

d. Administrative procedures shall be developed and implemented to limit tl.e working hours.of personnel who perform functions important to the safe storage and handling of nuclear fuel assemblies (e.g., Certified Fuel Handlers, non-certified operators, radiation protection personnel, and key maintenance personnel) such that the heavy use of overtime is not routinely required.

e. The Shift Supervisor shall be a Certified Fuel Handler, i

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Zion Station 5-3 Amendment Nos, and

l Organization 5.2 E

Table 5.2.2-1 Minimum Shift Crew Composition (*)

I Position Minimum Crew Number Shift Supervisor 1 1

Non-certified operator 1 Total 2 l

(a) The shift crcw composition may be one less than the minimum i requiremerits of Table 5.2.2-1 for not more than two hours to accommodate unexpected absences of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within minimum requirements of Table 5.2.2-1. This provision does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crew member being late or absent.

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i Zion Station 5-4 Amendment Nos. and

Unit Staff Qualifications 5.3 l

5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications l

l l 5.3.1 Staff Qualifications Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1, " Selection and Training of Nuclear Power

Plant Personnel," dated March 8,1971, with the following exceptions

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l Either the Manager of the Health Physics Department or the Lead l Health Physicist shall meet or exceed the qualifications of

" Radiation Protection Manager" of Regulatory Guide 1.8, September 1975.

The Decommissioning Operations Manager shall meet the requirement of Operations Manager in ANSI N18.1," Selection and Training of Nuclear Power Plant Personnel," dated March 8,1971, with the exception that this individual may be qualified as a Certified Fuel Handler at time of appointment in lieu of holding a Senior Reactor Operator license.

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t Zion Station 5-5 Amendment Nos. and ,

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Training l 5.4 !

i 5.4 Training 5.4.1- Trainina !

A training and retraining program for the Certified Fuel Handlers shall be maintained under the direction of the Decommissioning Plant Manager or l designee.

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i Zion Station 5-6 Amendment Nos. and j

Procedures 5.5 l 5.0 ADMINISTRATIVE CONTROLS 5.5 Procedures 5.5.1 Procedures l

Written procedures shall be established, implemented, and maintained covering the following activities:

l a. The procedures applicable to the safe storage of nuclear fuel recommended in Regulatory Guide 1.33, Revision 2, Appendix A, l February,1978; i

b. Fire Protection Program implementation; and

c. Al! programs specified in Specification 5.6.

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Programs and Manuals 5.6 5.0 Administrative Controls t

5.6 Programs and Manuals The following programs shall be established, implemented and maintained.

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5.6.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in i

the calculation of offsite doses resulting from radioactive gaseous

and liquid effluents, in the calculation of gaseous and liquid effluent l_ monitoring alarm and trip setpoints, and in the conduct of the

! radiological environmental monitoring program; and l b. The ODCM shall also contain the radioactive effluent controls and l radiological environmental monitoring activities, and descriptions of j the information that should be included in the Annual Radiological ;

! Environmental Operating and Radioactive Effluent Release )

Reports required by Specification 5.7.2 and Specification 5.7.3.

l c. Licensee initiated changes to the ODCM:

1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

i. Sufficient information to support the change (s) together with the appropriate analyses or evaluations justifying the change (s), and ii. A determination that the change (s) will maintain the levels of radioactive effluent control required by 10 CFR 20.1302,40 CFR 190,10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact l the accuracy or reliability of effluent, dose, or setpoint l calculations;

2. Shall become effective after the approval of the Decommissioning Plant Manager or designee; and (continued) 4 4

4 Zion Station 5-8 Amendment Nos. and

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Programs and Manuals 5.6 5.6 Programs and Manuals

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5.6.1 Offsite Dose Calculation Manual (ODCM) (continued) i

3. Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent l with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made effective. 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 (i.e., month and year) the change was implemented.

d. The ODCM shall contain the limits to be used for releasing solid material to unrestricted areas. Compliance with these limits shall be verified by instruments set at lower limits of detection (LLDs) and maximum allowable gamma activity concentration sensitivities contained in NRC Regulatory Guide 1.86, June 1974, and Nuclear Energy Institute Topical Report 97-02, May 1997, respectively.

Applicable radionuclide distributions, scaling factors, and sampling methods shall also be specified in the ODCM.

5.6.2 Radioactive Effluent Controls Proaram This program conforms to 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 shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shallinclude the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determinatior, in accordance with the methodology in the ODCM; (continued) l Zion Station 5-9 Amendment Nos. and

Programs and Manuals 5.6 5.6 Programs and Manuals 5.6.2 Radioactive Effluent Controls Proaram (continued

, b. Limitations on the concentrations of radioactive material released in l liquid effluents to unrestricted areas, conforming to ten times the concentration values in 10 CFR 20, Appendix B, Table 2, l

Column 2;

c. 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;

d. 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 10 CFR 50, Appendix I;

e. 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;

f. Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that 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 10 CFR 50.

(continued) l l

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Zion Station 5-10 Amendment Nos. and l

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Programs and Manuals 5.6 5.6 Programs and Manuals 5.6.2 Radioactive Effluent Controls Proaram (continued) ;

g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the site boundary i conforming to the following:

1. For noble gases: less than or equal to a dose rate of 500 mrem /yr to the whole body and less than or equal to a dose rate of 3000 mrem /yr to the skin; and

2. For tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: less than or equal to a dose rate of a dose rate of 1500 mrem /yr to any organ;

h. 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 l to 10 CFR 50;

i. Limitations on the annual and quarterly doses to a member of the public from 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 10 CFR 50; and

j. 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 190.

The provisions of SR 3.0.2 are applicable to Radioactive Effluent Controls !

Program surveillance frequencies.

(continued) l Zion Station 5-11 Amendment Nos. and

j .' i Programs and Manuals :

] 5.6 !

. 5.0 Administrative Controls !

A 5.6 Programs and Manuals :

5.6.3 Outdoor Storage Tank Radioactivity Monitoring Program l

This program provides controls for the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. This program is required if radioactive liquid is contained in unprotected (as defined below) outdoor . !

storage tanks. The liquid radwaste quantities shall be determined in i accordance with the ODCM :

1 The program shall include a surveillance program to ensure that the ;

quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system is less than the amount I that would result in concentrations less than the limits of 10 CFR 20, ;

Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Outdoor Storage Tank Radioactivity Monitoring Program surveillance frequencies.

(continued)

Zion Station 5-12 Amendment Nos. and

._ _ __ _~ _. _ _ - _ _ . . _ _ __ _ _ - _ .- _. _ . _ _ _ ._

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Programs and Manuals '

5.6 5.0 Administrative Controls 5.6 Programs and Manuals 5.6.4 Technical Specification (TS) Bases Control Proaram This program provides a means for processing changes to the Bases of these Technical Specifications. ;

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

1

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

1. A change in the TS incorporated in the license; or

2. A change to the DSAR or Bases that involves an unreviewed safety question as defined in 10 CFR 50.59.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the DSAR.

d. Proposed changes that meet the criteria of b(1) or b(2) above shall l be reviewed and approved by the NRC prior to implementation.

Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e) as modified by approved exemptions.

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Zion StaSon 5-13 Amendment Nos. and l

Reporting Requirements 5.7 5.0 Administrative Controls 5.7 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.7.1 Occupational Radiation Exposure Report NOTE A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station. ,

A tabulation covering the previous calendar year shall be submitted prior to April 30 of each year on the number of station, utility, and i other personnel (including contractors) receiving exposures greater than 100 mrem / year and their associated man rem exposure according to work ;

and job functions (e.g., fuel handling, surveillance, routine maintenance, !

l special maintenance (describe . maintenance), and waste processing).

This tabulation supplements the requirements of 10 CFR 20.2206. The i I

dose assignments to various duty functions may be estimates based on pocket dosimeter, TLD, or film 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.

5.7.2 Annual Radioloaical Environmental Operatina Report NOTE -

A single submittal may be made for a multiple unit station.

The Annual Radiological Environmental Operating Report covering unit I

, activities during the previous calendar year shall be submitted before May i 15 of each year. The report shall include summaries, interpretations, and I l

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 of 10 CFR Part 50.

(continued)

Zion Station 5-14 Amendment Nos. and l . _ - .

! Reporting Requirements l

5.7 5.7 Reporting Requirements 5.7.2 Annual Radioloaical Environmental Operatina Report (continued) l ,

l In the event that some individual results are not available for inclusion with l

the report, the report shall be submitted noting and explaining the reasons i l for the missing results. The missing data shall be submitted in a l l supplementary report as soon as possible.

1 5.7.3 Radioactive Effluent Release Report l

l NOTE A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Radioactive Effluent Release Report covering unit activities shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a.

The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid vcaste released from the unit. The i material provided shall be (1) consistent with the objectives outlined in the ODCM and Process Control Program and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix l to10 CFR Part 50. ;

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i Zion Station 5-15 Amendment Nos. and l

High Radiation Area ;

5.8 l 5.0 Administrative Controls 5.8 High Radiation Area 5.8.1 Pursuant to 10 CFR 20, paragraph 20.1601(c), in lieu of the " control '

device" or " alarm signal" required by 10 CFR 20.1601, each high radiation ,

area, as defined in 10 CFR 20, in which the intensity of radiation is equal

^

to or less than 1000 mrem /hr.at 30 cm (12 in) from the radiation source or j from any surface which the radiation penetrates, 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).

Individuals qualified in radiation protection procedures or personnel l continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in I high radiation areas with exposure rates equal to or less than l

.1000 mrem /hr, provided they are otherwise following plant radiation '

protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shat! I 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; or

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; or

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

(continued) i i

4 Zion Station 5-16 Amendment Nos. and

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l High Radiation Area l 5.8 I r

l 2

5.8 High Radiation Area 5.8.2 In addition to the requirements of Specification 5.8.1, areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 30 cm (12 in) from the radiation source or from any suiface which the radiation penetrates shall require the following:

a. Locked doors to prevent unauthorized entry. The keys shall be maintained under the administrative control of the operating shift supervision on duty and/or health physics supervision.

b. Personnel access and exposure control over activities being performed within these areas shall be specified by an approved RWP. During emergency situations which involve personnel injury or actions taken to prevent major equipment damage, continuous surveillance and radiation monitoring of the work area by an l individual qualified in radiation protection procedures may be ;

substituted for the routine RWP procedure.

l c. Each person entering the area shall be provided with an alarming radiation monitoring device which continuously integrates the radiation dose rate (such as an electronic dosimeter). Continuous coverage by a radiation technician may be substituted for alarming

, dosimetry.

5.8.3 For individual high radiation areas accessible to personnel with radiation i levels of greater than 1000 mrem /hr at 30cm (12 in.), that are located 1 within large areas (with the exception of 5.8.4), including the containment outside the missile barrier, where no enclosure exists for purposes of I locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded (by a more L substantial obstacle than a rope), conspicuously posted, and a flashing l . light shall be activated as a warning device.

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Zion Station 5-17 Amendment Nos. and

I High Radiation Area 5.8 i

5.8 High Radiation Area 5.8.4 For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mrem /hr at 30 cm (12 in.), that are located within the containment inside the missile barrier, where no enclosure exists for purposes of locking the individual area, the access control shall be per the following:

a. The missile barrier ingress / egress points shall be barricaded, locked and conspicuously posted to prevent access; or

b. 1. The missile barrier ingress / egress points shall be l conspicuously posted and have direct or electronic surveillance that is capable of preventing unauthorized entry; and i i

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2. Additional localized postings shall be provided in areas with j normal personnel access inside the missile barrier to inform i personnel of dose rates greater than 1000 mrem /hr at 30 cm (12 in.).

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l Zion Station 5-18 Amendment Nos. and

, Reviews 5.9 2

5.0 ADMINISTRATIVE CONTROLS '

5.9 Reviews 5.9.1 Paalified Technical Review Thorough reviews of the documents specified below shall be conducted l by a Qualified Technical Reviewer. Persons performing these reviews l shall be knowledgeable in the subject area being reviewed. Qualified Technical Reviews must be completed prior to implementation of l proposed activities, i l

a. Qualified Technical Reviewers shall be individuals without direct responsibility for the document under review; these reviewers may be from the same functionally cognizant organization as the individual or group performing the original work. l

b. Qualified Technical Reviewers shall have at least 5 years of professional experience and either a Bachelor's degree in Engineering or the Physical Sciences or shall have equivalent ;

qualifications evaluated on a case by case basis and approved by the Decommissioning Plant Manager. The Decommissioning Plant Manager shall document the appointment of Qualified Technical Reviewers. l

c. The following subjects shall be independently reviewed by a Qualified Technical Reviewer:

1. Safety evaluations for changes in the facility as described in the DSAR, changes in procedures as described in the DSAR, and tests or experiments not described in the DSAR to verify that such actions do not involve a change to the Technical Specifications or will not involve an unreviewed safety question as defined in 10 CFR 50.59;

2. Proposed changes to the programs required by Specification 5.6, to verify that such changes do not involve a change to the Technical Specifications and will not involve an unreviewed safety question as defined in 10 CFR 50.59; and

3. Proposed changes to the license, Technical Specifications, or Bases.

(continued) 1 Zion Station 5-19 Amendment Nos. and

Rcvi:ws 5.9 5.9 Reviews (continued) 5.9.2 Stat;on Review Committee (SRC)

The SRC is responsible for reviewing and advising the Decommissioning Plant Manager on matters related to the safe storage of nuclear fuel. This review function is independent of line organization responsibilities.

a. The SRC shallinclude a minimum of five members. Alternates may be substituted for regular members. The licensee shall designate in writing the chairman, the members, and alternates for the SRC.

b. The SRC shall collectively have experience and knowledge in the following functional areas:

1. Fuel handling and storage (including the potential for criticality),

2. Chemistry and radiochemistry,

3. Engineering,

4. Radiation protection, and

5. Regulatory assurance.

c. The SRC shall hold at least one meeting per quarter.

d. A quorum shall consist of three regular mernbers or their duly appointed alternates. Those members representing the line organizations responsible for the operation and maintenance of the facility shall not constitute a majority of the quorum. At least one member of the quorum shall be the chairman or the chairman's designated aiternate.

e. As a minimum, the SRC shall perform the following functions:

1. Advise the Decommissioning Plant Manager on all matters related to safe storage of nuclear fuel; and

2. Notify the responsible Corporate Vice-President of any safety significant disagreement between the SRC and the i Decommissioning Plant Manager within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

(continued)

Zion Station 5-20 Amendment Nos. and

Reviews 5.9 l

5.9 Reviews (continued) 5.9.2 Station Review Committee (SRC) (Continued) j i

f. The SRC shall be responsible for reviewing:

1. The safety evaluations for new documents or changes to documents completed under the provisions of 10 CFR 50.59 to verify that such actions do not involve an unreviewed

)

I safety question as defined in 10 CFR 50.59. This review may be completed after implementation of the affected procedure;

2. Changes to structures, systems, or components important to the safe storage of nuclear fuel to verify that such changes do not involve an unreviewed safety question as defined in 10 CFR 50.59. This review may be completed after implementation of the change;

3. Tests or experiments involving the safe storage of nuclear fuel to verify that such tests or experiments do not involve an unreviewed safety question as defined in 10 CFR 50.59. ,

This review may be completed after performance of the test !

or experiment;

4. Proposed changes to the license, Technical Specifications, or Bases. '

5. Violations of codes, regulations, orders, license requirements, or internal procedures / instructions having nuclear safety significance; l 6. Indications of unanticipated deficiencies in any aspect of

! design or operation of structures, systems, or components l that could affect safe storage of nuclear fuel;

7. Significant accidental, unplanned, or uncontrolled radioactive releases, including corrective action (s) to prevent recurrence; (continued)

Zion Station 5-21 Amendment Nos. and

- . - - - . - - - . -- . . . . - . . - _ . - . -~ --

Reviews 5.9 5.9 Reviews (continued).

5.9.2 Station Feview Committee (SRC) (Continued)

8. Significant operating abnormalities or dev!ations from normal and expected performance of equipment that affect safe storage of nuciear fuel;

9. Internal and external experience information related to the safe storage of nuclear fuel that may indicate areas for improving facility safety; and

10. Reportable Events.

Reports or records of these reviews shall be forwarded to the Decommissioning Plant Manager within 30 days after completion of the review.

5.9.3 Becords

Written records of reviews shall be maintained. As a minimum, these i records shallinclude

a. Results of the activities conducted under the provisions of Specifications 5.9.1 and 5.9.2; and

b. Determination of whether each item considered under Specifications 5.9.2.f.1 through 5.9.2.f.3 involves an unreviewed safety question as defined in 10 CFR 50.59.

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i i Zion Station 5-22 Amendment Nos. and i

1 ZION :

NUCLEAR STATION i

PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS BASES

TABLE OF CONTENTS BASES l -!

TABLE OF CONTENTS i

B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY. .. . B 3.0-1 ,

SURVEILLANCE REQUIREMENT (SR) APPLICABILITY..................... B 3.0-3 j B 3.1 DEFUELED PLANT SYSTEMS-B 3.1.1 Spent Fuel Pool Water Level......... .......... ........ . ..... . ............. B 3.1-1 i B 3.1.2 Spent Fuel Pool Boron Concentration. ............ .. ... .. .... . ....B 3.1-4 '

B 3.1.3 Spent Fuel Assembly Storage ..... ......... ........ ............ .... ........ B 3.1-8 i i

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Zion Station i Amendment Nos, and

. _ _ - . - _ ~ - . - . - - . - . - . .

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY :

l BASES LCOs LCO 3.0.1 and LCO 3.0.2 establish the general requirements ;

applicable to all Specifications and apply at all times, unless I otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the facility is in the specified conditions of the Applicability statement of each Specification.)

LCO 3.0.2 LCO 3.0.2 establishes that, upon discovery of a failure to meet an ,

l LCO, the associated ACTIONS shall be met. The Completion Time i i of each Required Action for an ACTIONS Condition is applicable I from the point in time that an ACTIONS Condition is entered. The l Required Actions establish those remedial measures that must be taken within specified Completion Timas when the requirements of l

an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified l

Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time or is no longer applicable, unless otherwise specified.

(continued)

! Zion Station B 3.0-1

LCO Applicability B 3.0 BASES l

l LCO 3.0.2 The Completion Times of the Required Actions are also applicable (continued) when a specified condition in the Applicability is entered intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation

of problems. Entering ACTIONS for these reasons must be done in such a manner that does not compromise the safe storage of irradiated fuel. Intentional entry into ACTIONS should not be made l for convenience.

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Zion Station B 3.0-2 l

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SR Applicability B 3.0 1

8 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY l 1

BASES SRs SRs 3.0.1 through 3.0.3 establish the general requirements applicable to all Specifications and apply at all times, unless otherwise stated.

l SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met dunng )

the specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This Specification is to ensure that Surveillances are performed to verify that variables are within specified limits.

Failure to meet a Surveillance within the specified Frequency. ire accordance with SR 3.0.2, constitutes a failure to meet an LCO.

Surveillances do not have to be performed when the facility is in a condition for which the requirements of the associated LCO are not applicable, unless otherwise specified.

SR 3.0.2 SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. This extension facilitates Surveillance scheduling and considers facility conditions that may not be suitable for conducting the Surveillance (e.g., other ongoing Surveillance or maintenance activities).

l The 25% extension does not significantly degrade the reliability that I results from performing the Surveillance at its specified Frequency.

This is based on the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the SRs. Any exceptions to SR 3.0.2 are stated in the individual Specifications.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as a convenience to extend Surveillance intervals or periodic Completion Time intervals beyond those specified.

(continued)

Zion Station B 3.0-3 J

l SR Applicability B 3.0 l BASES SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring an affected i variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.

The basis for this delay period includes consideration of facility conditions, adequate planning, availability of personnel, the time i

required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognitio,1

! that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based, not on time intervals, but upon specified facility conditions or operational situation, is discovered not to have been performed when specified, SR 3.0.3 allows the full delay period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform the Surveillance.

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

(continued) 4 Zion Station B 3.0-4 l

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SR Applicability B 3.0 BASES SR 3.0.3 If a Surveillance is not completed within the allowed delay period, (continued) then the variable is considered outside the specified limits, and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period.

If a Surveillance is failed within the delay period, then the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

Zion Station B 3.0-5

Spent Fucl Pool Water Level B 3.1.1 B 3.1 DEFUELED PLANT SYSTEMS

- B 3.1.1 Spent Fuel Pool Water Level l BASES-BACKGROOND When the plant was operational, this specification provided assurance that the assumptions regarding the iodine decontamination factor would be met following a fuel ,

handling accident. Following the permanent defueling of the reactors, the fuel handling accident was re-analyzed based on the extended time since shutdown and corresponding t reductions in iodine activity that are consistent with the plant's permanently defueled condition. As described in Ref.

1 and 2, these new analyses determined that 10 CFR 100 and 10 CFR 50 App. A, Criterion 19 limits would still be met even with no decontamination by the spent fuel pool water.

Although the specification for spent fuel pool water level during fuel handling operations is no longer needed to ensure an adequate iodine decontamination factor, the specification continues to provide assurance of adequate cooling for the irradiated fuel being handled by ensuring that it remains covered by water and provides significant shielding for personnel safety. Therefore the specification was retained essentially unchanged from the operational

. Technical Specifications.

1 \

f The assumptions in the fuel handling accident analyses are given in Ref.1 and 2. j i

l APPLICABLE in the operational Technical Specifications, the specification SAFETY ANALYSES for minimum water level in the spent fuel poo! during fuel handling activities provided assurance of substantialiodine removalif a fuel handling accident were to occur. However, as indicated in Ref.1 and 2, the limits of 10 CFR 100 and 10 l

CFR 50 App. A, Criterion 19 would not be exceeded if a i

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Zion Station B 3.1-1 Rev. _

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l Spent Fuel Pool Water Levsl l B 3.1.1 l

l BASES l

l APPLICABLE fuel handling accident occurred even with no removal of i SAFETY ANALYSES iodine activity by spent fuel pool water. This is the result of l (continued) the decay of radioactive iodine during the lengthy period since the last reactor operation at the station.

However the specification for water level in the in the SFP also ensures that irradiated fuel which is not in the storage racks will be adequately cooled by ensuring that it remains covered with water during normal fuel handling operations, and provides significant shielding for personnel safety. I LCO The spent fuel pool water level is required to be 23 ft over the top of irradiated fuel assemblies seated in the storage '

racks. The 23 ft level was formerly based on preserving the ;

assumptions of the previous fuel handling accident analysis. )

Although this level is no longer needed for iodine !

decontamination following a fuel handling accident, past l practice indicates that this level provides assurance that the I irradiated fuel being handled will be covered by water and l consequently will be adequately cooled and provides significant shielding for personnel safety. The 23 ft level has i therefore been retained as the minimum required for l movement of irradiated fuel assemblies within the spent fuel !

pool.

APPLICABILITY This LCO applies during movement of irradiated fuel assemblies in the spent fuel pool since it is during such activities that irradiated fuel may be higher than the top of the fuel in the storage racks. An irradiated fuel assembly that is higher than that stored in the racks may not be protected against uncovery by design features which ensure that fuelin the racks remains covered with water. This design feature consists of the lowest pipe opening in the l spent fuel pool being at approximately 598' which is above the top of the fuel stored in the racks (approximately 590').

(continued)

Zion Station B 3.1-2 Rev. _

Spent Fuel Pool Water Leval !

B 3.1.1 BASES l

ACTIONS A.1 i When the initial conditions for an accident cannot be met, steps should be taken to preclude the accident from occurring. When the spent fuel pool water level is lower than the required level, the movement of irradiated fuel J assemblies in the spent fuel pool is immediately suspended.

This action effectively precludes the possibility of 4 withdrawing an irradiated fuel assembly above the water !

level which would result in a loss of cooling and shielding.

This does not preclude movement of a fuel assembly to a i safe position.

SURVEILLANCE SR 3.1.1.1 REQUIREMENTS 4 This SR verifies that the spent fuel pool water level is sufficiently high to ensure adequate cooling and shielding for the fuel being handled. The water level in the spent fuel pool must be checked periodically. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency ,

is appropriate because the volume in the pool is normally stable and is acceptable based on operating experience. In addition, water level changes are controlled by plant procedures.

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REFERENCES 1. Zion Station Calculation 22S-0-110X-0057, Fuel Handling Accident Offsite Dose Calculation with Extended Radioactive Decay and no AB Filtration

2. Zion Station Calculation 22S-0-110X-0059, Fuel Handling Accident Control Room Dose Calculation with Extended Radioactive Decay i

e j Zion Station B 3.1-3 Rev. _

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Spent Fuel Pool Boron Concentration B 3.1.2 l

i L B 3.1 DEF1UELED PLANT SYSTEMS l

B 3.1.2 Spent Fuel Pool Boron Concentration l.

L BASES BACKGROUND The spent fuel pool is divided into two separate and distinct regions which, for the purpose of criticality considerations, are considered as separate areas. Region 1, with j 336 storage positions, is designed to accommodate fuel with l a maximum initial enrichment of 4.65 wt% U-235, regardless of burnup. Region 2, with 2670 storage positions, is designed to accommodate fuel with various l initial enrichments which have accumulated minimum l burnups within the acceptable domain according to j Figure 3.1.3-1. Region 1 also contains six (6) defective fuel j assembly storage containers. ,

The water in the spent fuel pool normally contains dissolved i boron which results in large subcriticality margins.

However, the NRC guidelines specify thEt the limiting k,, of 0.95 be evaluated in the absence of soluble boron. Hence, the design of both regions is based on the use of unborated water. The design maintains each region in a subcritical l condition with the regions fully loaded.

The double contingency principle discussed in ANSI N16.1-1975 and an NRC letter dated April 14,1978 (Ref.1) allows credit for soluble boron under other abnormal or accident conditions since only a single accident or event need be considered at one time. For example, the most L severe scenario is associated with the movement of fuel from Region 1 to Region 2 and accidental mistoading of a fuel assembly in Region 2. This could potentially increase the reactivity of Region 2. To prevent criticality if an

. accidental mistoading event were to occur, boron is j dissolved in the spent fuel pool water.

! (continued) i Zion Station B 3.1-4 Rev. _

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Spent Fuel Pool Boron Concentration ;

B 3.1.2 l BASES-BACKGROUND Safe storage in the high density storage racks with no !

(continued) movement of assemblies may therefore be achieved by controlling the location of each assembly in accordance with i LCO 3.1.3," Spent Fuel Assembly Storage." Prior to {

movement of an assembly to Region 2, it is necessary to perform SR 3.1.3.1.

l APPLICABLE Events can be postulated that could increase the k, of the !

SAFETY ANALYSES spent fuel pool. However, the presence of dissolved boron ,

in the spent fuel pool water prevents criticality in both I regions of the pool.

These postulated events are of two types. A fuel assembly could be inadvertently misloaded in Region 2 (e.g., an unirradiated fuel assembly or an insufficiently depleted fuel assembly). The second type of postulated event is associated with a fuel assembly which is dropped adjacent to a fully loaded Region 2 storage rack. This could have a small positive reactivity effect on Region 2. However, the negative reactivity effect of the soluble boron compensates for the increased reactivity caused by either one of the two postulated event scenarios. Analyses of these two types of events are described in Ref. 2.

LCO The specified minimum spent fuel pool baron concentration t is 500 ppm. The specified concentration of dissolved boron in the spent fuel pool preserves the assumptions used in the i

analyses of the postulated event scenarios as described in Ref. 2.

l l APPLICABILITY This LCO applies during movement of fuel assemblies in the l spent fuel pool or whenever fuel assemblies are stored in Region 2 of the spent fuel pool until a spent fuel pool verification has been performed following the last movement

of fuel assemblies in Region 2 of the spent fuel pool.

(continued) j Zion Station B 3.1-5 Rev. __

i I

i Spent Fuel Pool Boron Concentration j B 3.1.2 BASES [

1 APPLICABILITY The LCO applies during movement of fuel assemblies in the l (continued) pool because the potential for a dropped fuel assembly

L exists during such movements. The LCO also applies when i fuel assemblies are stored in Region 2 of the spent fuel pool, ,

until a verification has been performed following the last movement because during movement there is the potential for an inadvertent misloading of an assembly that should be j in Region 1 into Region 2. However the independent i verification provides adequate assurance that no misloading ;

has occurred in Region 2. There is no restriction regarding storage of fuel assemblies in Region 1 since any fuel ;

j assembly meeting the limitations described under Design l l Features may be stored in Region 1. i 1

ACTIONS A.1. A.2.1. and A.2.2 i

When the concentration of boron in the spent fuel pool is )

less than required, immediate ac't ion must be taken to .

preclude the occurrence of a reactivity event or to mitigate j the consequences of a reactivity event in progress. This is i

most efficiently achieved by immediately suspending the !

movement of fuel assemblies in the spent fuel pool. This does not preclude movement of a fuel assembly to a safe l position. I Action must also be immediately initiated to restore the

, boron concentration simultaneously with suspending

[ movement of fuel assemblies. ;

L An acceptable alternative to restoring the boron concentration is to verify by administrative means that the spent fuel pool verification has been performed since the last movement of fuel assemblies in Region 2 of the spent fuel pool. However, prior to resuming movement of fuel assemblies, the concentration of boron must be restored.

(continued) i 1

Zion Station B 3.1-6 Rev. _

l. . - , - _.

j

a . ._. -- .~a_-. n n.x- . .. ~. .. _...a.-- -ns. , - . w.-

l Spsnt Fuel Pool Boron Concsntration

l. B 3.1.2 l-BASES (continued)

SURVEILLANCE SR 3.1.2.1 REQUIREMENTS This SR verifies that the concentration of boron in the spent fuel pool is within the required limit. As long as this SR is

met, the analyzed events are fully addressed. The 31 day l Frequency is appropriate considering the volume of the spent fuel pool, the normally maintained boron concentration, and because no major dilution of pool water l is expected to take place over this period of time.

1

REFERENCES 1. Double contingency principle of ANSI N16.1-1975, as l specified in the April 14,1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

2. Letter from C. Y. Shiraki, NRC to T. J. Kovach, Comed, dated February 23,1993, Issuance of License Amendment 142/131, allowing increase of the Spent Fuel Pool storage Capacity to 3012 assemblies l

t l

l l

^

l l

Zion Station B 3.1-7 Rev. _

I

Spent Fuel Assembly Storaga B 3.1.3 B 3.1 DEFUELED PLANT SYSTEMS B 3.1.3 Spent Fuel Assembly Storage BASES BACKGROUND The spent fuel pool is divided into two separate and distinct regions which, for the purpose of criticality considerations, are considered as separate areas. Region 1, with 336 storage positions, is designed to accommodate fuel with a maximum initial enrichment of 4.65 wt% U-235, regardless of burnup. Region 2, with 2670 storage positions, is designed to accommodate fuel with various initial enrichments which have accumulated minimum burnups within the acceptable domain according to Figure 3.1.3-1. Region 1 also contains six (6) defective fuel assembly storage containers.

l The water in the spent fuel pool normally contains dissolved boron which results in large subcriticality margins. However, the NRC guidelines specify that the limiting k , of 0.95 be evaluated in the absence of soluble boron. Hence, the design of both regions is based on the use of unborated water. The design maintains each region in a suberitical condition with the regions fully loaded.

The double contingency prit:ciple discussed in ANSI N16.1-1975 and an NRC letter dated April 14,1978 (Ref.1) allows credit for soluble boron under other abnormal or accident conditions since only a single accident or event need be considered at one time. For example, the most severe scenario is associated with the movement of fuel from Region 1 to Region 2 and accidental misloading of a fuel assembly in Region 2. This could potentially increase the reactivity of Region 2. To prevent criticality if an accidental misloading event were to occur, boron is dissolved in the spent fuel pool water.

(continued)

Zion Station B 3.1-8 Rev. l

Spent Fuel Assembly Storago B 3.1.3 BASES BACKGROUND Safe storage in the high density storage racks with no (continued) movement of assemblies may therefore be achieved by controlling the location of each assembly in accordance with LCO 3.1.3," Spent Fuel Assembly Storage." Prior to movement of an assembly to Region 2, it is necessary to perform SR 3.1.3.1.

APPLICABLE The hypothetical accidents can only take place during or as SAFETY ANALYSES a result of the movement of an assembly. For these accident occurrences, the presence of soluble boron in the spent fuel pool (controlled by LCO 3.1.2, " Spent Fuel Pool Boron Concentration") prevents criticality in both regions.

By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time. During the remaining time period with no potential for accidents, the operation may be under the provisions of LCO 3.1.3.

LCO The restrictions on the placement of fuel asse nblies within the spent fuel pool, in accordance with Figure 3.1.3.-1, ensures that the kg of the spent fuel pool will always remain

< 0.95, assuming the pool to be flooded with unborated water. This is supported by the analyses described in Ref.

2.

APPLICABILITY This LCO applies whenever any fuel assembly is stored in Region 2 of the spent fuel pool. The provisions of Design feature 4.2.1 provide protection against criticality for fuel stored in Region 1 of the spent fuel pool.

(continued) i l

Zion Station B 3.1-9 Rev.__

Spent Fuel Assembly Storage B 3.1.3 BASES ACTIONS A.1 When the configuration of fuel assemblies stored in Region 2 the spent fuel pool is not in accordance with Figure 3.1.3-1, the immediate action is to initiate action to make the necessary fuel assembly movement (s) to bring the configuration into compliance with Figure 3.1.3-1.

SURVEILLANCE SR 3.1.3.1 REQUIREMENTS This SR verifies by administrative means that the initial enrichment and burnup of the fuel assembly is in !

accordance with Figure 3.1.3-1. For fuel assemblies in the unacceptable range of Figure 3.1.3-1, storage is only allowed in Region 1.

REFERENCES 1. Double contingency principle of ANSI N16.1-1975, as specified in the April 14,1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

2. Letter from C. Y. Shiraki, NRC to T. J. Kovach, Comed, dated February 23,1993, issuance of License Amendment 142/131, allowing increase of the Spent j Fuel Pool storage Capacity to 3012 assemblies Zion Station B 3.1-10 Rev. _

l ZION STATION LICENSE AMENDMENT REQUEST NUMBER 98-06; PERMANENTLY DEFUELED TECIINICAL SPECIFICATIONS

' ATTACIIMENT C EVALUATION OF SIGNIFICANT IIAZARD CONSIDERATIONS FOR PROPOSED CllANGES l

)

l l

ATTACHMENT C l 1 SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES l

l Comed has evaluated this proposed amendment and determined that it involves no significant hazards consideration. According to 10 CFR 50.92(c), a prope. sed amendment to an operating license involves no significant hazards consideration if operation of the l facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated; i

Create the possibility of a new or different kind of accident from any accident

previously evaluated; or '

Involve a significant reduction in a margin of safety.

I The proposed amendment would eliminate License Conditions that are no longer applicable with Units 1 and 2 permanently shutdown t.nd defueled, and replace the ,

existing operational Custom Technical Specifications (CTS) with Permanently Defueled l Technical Specifications (PDTS). The specific changes in the License Conditions and the CTS have been categorized as:

l Administrative Changes Editorial Changes l More Restrictive Chtnges l Redundancy or Relocation Changes !

l Less Restrictive Changes l I

The determination that the criteria set forth in 10 CFR 50.92 are met for these changes is indicated in the following table. In this table the changes in the first four categories have L been evaluated against the criteria of 10 CFR 50.92 on a categorical basis. Changes in l the last category, Less Restrictive Changes, have been addressed individually since the reasons that 10 CFR 50.92 criteria are satisfied differ between changes. Based upon the evaluations presented in this table, Comed has concluded that all changes involved in this proposed amendment involve no significant hazards consideration.

I 1

Page1of26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change Does the change involve a Does the change create Does the change involve a significant increase in the . the possibility of a new or significant reduction in a .

probability or consequences of a different kind 'of accident; margin ofsafety? -

previously evaluated accident? from any previously ..

~~

^

evaluated? -

Administrative Changes No. This type ofchange only No. Since the removal of . No. Since the removal of removes requirements that are no these requirements dces these requirements does These are changes in which a License Condition or longer used. Since the removal of not affect any SSCs or the not affect any SSCs or the CTS requirement has been eliminated because the these requirements does not affect conduct of activities, no conduct of activities, there mode of applicability or conditions which invoke any structures, systems, or new types of accidents are is no reduction in any -

the requirement will no longer occur. components (SSCs) or the conduct created. safety margin.

Consequently the License Condition or of activities with the units specification would never require or prohibit any permanently defineled, there is no action. For CTS Definitions, these are changes in change in the probability or which the definition has been eliminated because consequences of any accident.

the defined term is not used.

Editorial Changes No. This type ofchange does not No. Since there is no No. Since there is no alter the meaning of the change in requirements, no change in requirements, These are changes in format, word choice, specification. Since there is no new types of accidents are there is no reduction in any grammar, or terminology that do not alter any change in requirements, there is no created. safety margin.

requirement. change in the probability or consequences of any accident.

More Restrictive Changes No. This type of change adds new No. Since the change No. Since the change requirements, removes existing renders the specifications renders the specifications These are changes in which the resulting exceptions, or renders existing more restrictive, no new more restrictive, there is no requirement is more restrictive than the original limits more conservative. Such types of accidents are reduction in any safety License Condition or CTS requirement. changes do not change the created. margin.

probability or consequences of any accident.

Page 2 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change Does the change involve a Does the change create - Does the change involve a significant increase in the the possibility of a new or significant reduction in a probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? from any previously evaluated?

Redundancy or Relocation Changes No. In this type of change the No. Since there is no No. Since there is no requirement continues to exist but charp in requirements, no change in requirements, These are changes in which a License Condition or is no longer in the license or new types of accidents are there is no reduction in any CTS requirement is eliminated either because it is technical specifications. Since created. safety margin.

redundant to requirements in regulations or other there is no change in requirements, specifications, or because it does not meet the there is no change in the criteria of 10 CFR 50.36(c) and has been/will be probability or consequences of any relocated to Comed controlled documents. accident.

Less Restrictive Changes These are changes in which the resulting requirement is less restrictive than the original License Condition or CTS requirement. The individual changes in this category are identified below along with the basis for the change and a No Significant Hazards Consideration evaluation License condition 2.C.(5) (Safe Shutdown Fire No. The effect of the change is to No. The only events of No. The only margin of Protection Program) recognize that the objective of the concem are fires. The safety that could be fire protection program has been change program objectives attributed to the operational ,

This License Condition is no longer needed since, made relevant to the units defueled will not create any new fire protection program in accordance with 10 CFR 50.48(b)-(d), the condition. This will not change types of fires. would be a measure of the operational fire protection program was based on the probability of a fire. The ability to shutdown the maintaining the ability to achieve and maintain consequence of concern in the units. This margin of safe shutdown in the event of a fire. Comed has operational program was the safety is no longer relevant.

submitted the certifications of permanent inability to shutdown the units.

shutdown and defueling required by 10 CFR That consequence is no longer a 50.82(a)(1) and accordingly, the fire protection concern. Therefore the possible program is governed by 10 CFR 50.48(f). This change in consequences is not regulation requires a program that addresses the significant.

potential for fires which could cause the release or 1 j Page 3 of 26

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change Does the change involve a . Does the chan.ge create ' Does the change involve a significant increase in the the possibility of a new or significant reduction in a probability or consequences of a - different kind of accident margin of safety?

previously evaluated accident? from any previously.

evaluated?

spread of radioactive materials (i.e., which could result in a radiological hazard). Since the regulation is self-invoking, no new license condition is needed.

License Condition 2.C.(8) (Program for No. Neither the probability nor No. The only No. There are no longer Secondary Chemistry) the consequences of an accident accident / event of concern any margins of safety are afTected because the type of involving secondary concerning primary to This License Condition is no longer needed to accident / event which was the chemistry was the primary secondary leaks. l ensure safety because both the primary and concern of this progam,(primary to secondary leak.

secondary sides of the steam generators are to secondary leak)is no longer t depressurized for SAFSTOR conditions. credible with the primary and Consequently, the conditions promoting steam secondary sides of the steam generator tube degradation have been essentially generators depressurized and eliminated and the consequences of such vented.

degradation are no longer significant.

. License Condition 2.C.(9) (Program for Leakage No. Neither the probability nor No. This program was No. There are no longer From Systems Outside Containment Following An the consequences of an accident only concerned with any margins of safety Accident) are affected because the type of accidents resulting in post concerning post accident i accident / event which was the accident highly radioactive highly radioactive systems This License Condition is no longer needed to concern of this program,(leakage leakage from systems penetrating containment.

ensure safety because design basis accidents inside from systems penetrating penetrating containment.

containment are no longer credible. Additionally, containment containing highly all primary systems penetrating containment will radioactive fluids during an be depressurized for long term SAFSTOR accident) is not credible with the conditions. RCS depressurized and vented and the reactors defueled.

Page 4 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CHANGES Description of Change Does the changeinvolve a Does the change create Does the change involve a significant increase in the~ the possibility of a new or significant reduction in.a probability or consequences of a different kind of accident margin of safety?:

previously evaluated accident? frein any previously.

evaluated? -

License Condition 2.C.(10) (Program for Airborne No. Neither the probability nor No. The only No. Compliance with the Iodine Determination Under Accident Conditions) the consequences of an accident accident / events of concern margins ofsafety involving are affected because the condition involving this program post accident iodine stated This License Condition is no longer needed to which was the concern of this were those resulting in high in the regulations is ensure safety because sufficient time has elapsed program (high iodine levels post accident airbome achieved without this since the units were shut down for the radioactive prohibiting access to vital areas iodine levels. program iodine in the fuel to decay to levels that would not under accident conditions)is not result in exceeding the exposure limits for credible since the iodine has personnel in the control room stated in 10 CFR 50, undergone an extended decay Appendix A, General Design Criteria (GDC) 19 period.

following a fuel handling accident. The only remaining credible accident or event that could cause a breach of the fuel cladding is a fuel handling accident. Calculations have shown that the GDC 19 limits would be met for a fuel handling accident even without credit for the charcoal filters in the control room ventilation system.

License Condition 2.C.(1 l) (March 14,1983, No. All but one of these issues are No. The subject issues No. The accident analysis Order concerning certain NUREG-0737 Issues) limited to uccidents (such as a pertained only to the demonstrates that the LOCA) that are only credible for prevention and mitigation required margin of safety This license condition no longer needed since none operational units with fueled ofidentified accidents. (dose limit at the EAB) for of the issues subject to the order are relevant with reactors. Since these accidents are Even if the plant were still the only remaining credible the units permanently defueled. These issues are: no longer credible, their operational the elimination accident that could involve simulator examinations, plant shielding, post probability and consequences of these requirements any of the subject issues accident sampling of reactor coolant and cannot increase. The one issue would not create any new will remain well within Page 5 of 26

. _ _ _ _ - - _ - _ _ _ _ - _ _ _ - _ - _ - _ _ - _ _ _ _ _ _ - _ _ _ _ - . . . _ _ -. =_. .-_

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change Does the change involve a Does the change create Does the change involve a-significant increase in the . the possibility of a new or significant reduction in a probability or consequences of a different kind of accident margin of safety?

previously evalust'ed accident? from any previously evaluated?

containment atmosphere, training for mitigating that could potentially involve a type of accident. established limits.

core damage, auxiliary feedwater flow indication, fuel handling accident is that containment isolation dependability, post accident concerning post accident effluent containment radiation monitor, containment monitors for iodine and noble gas.

pressure indication, containment water level Such monitors have no affect on indication, containment hydrogen indication, and the probability of the accident.

post accident effluent monitors for iodine and The accident analysis shows that noble gas. Regarding the last issue, the above the consequences remain described accident analysis demonstrates that 10 acceptable even with no credit for CFR 100 limits would not be exceeded if a fuel the monitors.

handling accident were to occur. Therefore, inclusion of a license condition concerning these monitors is no longer appropriate.

CTS 3.12 / 3.12 contain the requirements for No. The rupture of a gas decay No. Elimination of the No. Since the gas decay limiting the quantity of radioactivity in the gas tank is no longer credible, nor is a curie content and hydrogen tanks are no longer in use decay tanks and for limiting the hydrogen hydrogen explosion in the waste concentration limits does and since there is no longer concentration in the waste gas system. gas system. Since the accidents not involve new failure any source of hydrogen in are no longer credible, elimination mechanisms or modes the waste gas system, there The specifications in this section have not been of associated limits will not since there is no longer a is no longer any attribute to included in the PDTS since the gas decay tanks increase their probability of hazard. which a safety margin can have been vented and are no longer in use, and occurrence or consequences. be applied.

since there is no longer any source of hydrogen in the waste gas system.

Page 6 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CHANGES Description of Change Does the change involve a . Does the change create Does the change involve a significant increase in the _

the possibility of a new or significant reduction in a probability or consequences of a - different kind of accident margin of safety?

previously evaluated accident?- from any previously evaluated? -

CTS 3.13.2 / 4.13.2 contain the requirements for No. The probability of a fuel No. The inoperability of No. Due to the decay of operability, compensatory action, and surveillance handling accident is unafrected by the fuel building iodine since the units last of the fuel building ventilation exhaust system the operability of the ventilation ventilation exhaust system operated, the margins of including filters and charcoal adsorbers during system. The accident would not initiate any new safety for the consequences movement ofirradiated fuel or loads over consequences (doses due to accident, nor would it of a fuel handling accident irradiated fuel in the fuel building. radioactive iodine) which the fuel introduce any new failure established by the NRC in building ventilation exhaust mechanisms or modes 10 CFR 50, App. A, The specifications in this section have not been system was designed to mitigate involving the design and Criterion 19 and 10 CFR included in the PDTS since the radioactive iodine are no longer significant.

operation of other systems 100 have already been in the irradiated fuel has decayed such that the Therefore elimination of the structures, or components. satisfied.

dose limits for personnel in the control room given ventilation system operability in 10 CFR 50, App. A, Criterion 19 and the limits requirements will not significantly for dose at the site boundary given in 10 CFR 100 increase these consequences if the would not be e.vceeded in the event of a design accident should occur.

basis fuel Inndling accident even if no credit is assumed for any charcoal adsorbtion.

Page 7 of 26

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CllANGES Description of Change Does the change involve a . Does the change create - Does the change invohc a' significant increase .in the the possibility of a new or- significant reduction in a probability or cons 3quences of a different kind of accident - margin of safety?f previously evaluated accident? . froni any previously evaluated?

CTS 3.13.11/ 4.13.11 contain the limits, compensatory action, and surveillance requirements for the spent fuel pool water level.

The CTS applicability statement includes No. The accident of concern is No. The elimination of No. Due to the decay of movement of control rods in the SFP. This has not one in which fuel is damaged by a SFP water level iodine since the units last been included in the PDTS applicability statement falling object. The probability of requirements for handling operated, the margins of since the specification is no longer based on such an accident is not increased of control rods does not safety for the consequences scrubbing ofiodine in the event of a fuel handling by eliminating water level introduce any new failure of an accident involving a accident. There has been sufficient decay of requirements for handling of mechanisms or modes. dropped control rod, which iodine such that applicable post accident release control rods since the level has no are established by the NRC limits can be met without crediting iodine removal effect on the likelihood that the rod in 10 CFR 50, App. A, by the SFP water. The specification is now based will be dropped. The Criterion 19 and 10 CFR on ensuring that fuel being moved remains under consequences of such an accident 100 have already been water. Therefore, the applicability statement need are not significantly affected since satisfied.

no longer include movement of a control rod. there is no longer significant amount ofiodine for the water to remove. Also no credit was taken in the accident analyses for the slowing effect of the water.

The CTS requirement that the surveillance be No. Changing the timing of the No. The change only No. The margin of safety performed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of fuel initial SFP level verification in no afTects the timing of involved in this movement has been changed to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months way affects the likelihood of performance of the initial surveillance is defined by prior to the start of fuel movement. Since the whether a fuel assembly or other level surveillance. the minimum SFP water spent fuel pool water level is not subject to sudden object will be dropped. The Performance of the level. The level or frequent changes, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limit provides consequences are not affected surveillance by observing requirements are Page 8 of 26

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES

- Description of Change Does the change involve a Does the change create Does the change involve a significant increase in the - the possibility of a new or significant reduction in a probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? from any previously evaluated?

adequate assurance of safety. since operating experience has the SFP water level does unchanged. Only the shown there is a high degree of not involve any physical timing of the initiallevel certainty the water level in the SFP change in the plant or the verification is affected.

will not undergo large fluctuations manner in which any in a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. This structure, system, or substantiated by the existing component is operated.

frequency requirement for subsequent surveillances, which is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

CTS 3.13.14 / 4.13.14 contain the limits, compensatory action, and surveillance requirements for SFP boron concentration. The following changes were made to the CTS requirements:

The CTS applicability statement of No. The accident of concern is a No. The only accident No. The margin of safety criticality in the SFP. The involving boron accepted by the NRC is "Whenever fuel assemblies are in the spent probabilitf orthis accident has not concentration and fuel that the K,of the SFP will fuel storage pool" been significantly increased since assembly location is a remain below 0.95. The ,

sub-criticality continues to be criticality accident. criticality analyses show was modified to be consistent with Zion ITS ensured by the independent that this margin will still be 3.7.15 applicability statement of verification of Region 2, maintained with the regardless of boron concentration. proposed changes to the "When fuel assemblies are stored in Region The verification provides an applicability statement.

2 of the spent fuel pool and a spent fuel independent mechanism to ensure pool verification has not been performed that the assumptions of the Page 9 of 26

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CliANGES Description of Change Does the change involve a Does the change create - Does the change involve a significant increase in the the possibility of a new or significant reduction in a probability or consequences of a . different kind of accident margin of safety? -

previously evaluated accident? from any previously evaluated?

since the last movement of fuel assemblies criticality analyses are met. This in the spent fuel pool." verification is only needed for Region 2 since Region I can safely This is based on the Zion criticality analyses which accommodate any fuel authorized demonstrate that the K,,of the SFP will remain in the Design Features below 0.95 with any fuel assembly authorized for specifications. The consequences Zion stored in Region 1 of the SFP and with of a criticality accident are unborated water in the pool. unafTected since the function of the specification is to prevent the accident rather than to mitigate it.

A new Action (A.2.2) was included in the PDTS to No. This change provides an No. The only accident No. The margin of safety allow an altemative to suspending fuel movements alternative action that is as involving boron accepted by the NRC is and restoring boron concentration if the effective as the existing action in concentration and fuel that the K,y of the SFP will concentration is below the limit. The alternative providing assurance that a assembly location is a remain below 0.95. The action is to verify that only the proper fuel criticality accident will not occur. criticality accident. criticality analyses show assemblies are stored in Region 2. This provides This change only increases the that this margin will still be assurance that the K,y of the SFP will remain options for ensuring that the maintained with the below 0.95. even though the boron concentration accident will not happen and proposed changes to the is below limits and provides a compensatory therefore does not increase the action statement.

measure which is consistent with the Applicability probability of the accident. The statement. consequences of a criticality accident are unchanged since they are unaffected by the choice of actions taken to ensure that the accident will not happen. ;

Page 10 of 26

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CilANGES Description of Change Does the change involve a Does the change create Does the change involve a significant increase in the. the possibility of a new or significant reduction in a

~

probability or consequences of a different kind of accident inargin of safety? '

~

previously evaluated accident? from any previously evaluated? ~

CTS 3.14 / 4.14 contain the requirements for No. Elimination ofoperability _ No. The monitors are No. These monitors are operability, compensatory action, and surveillance requirements for these monitors reactive components that not needed to maintain post of various area and process radiation monitors. from the technical specifications sense radiation levels. The accident doses within the does not affect the probability of failure or inoperability of margins of safety The specifications for the monitors that are any accident since there are no these monitors does not established in 10 CFR 100 required by the CTS to be operable with both units initiating events associated with create any conditions that and 10 CFR 50, App. A defueled monitors have not been included in the the monitors. The analyses which can result in new accidents GDC 19.

PDTS since none of these monitors is credited in determined the consequences of or cause other SSCs to fail the analyses of the remaining credible accidents. the remaining credible accidents in such a manner that result These monitors are the SFP area, control room demonstrated acceptable results in new accidents.

area, Technical Support Center area, auxiliary without taking any credit for the building area, component cooling system, and the monitors.

service water system monitors.

Page 1I of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change Does the change involve a Does the change create - Does the change involve a significant increase in the . the possibility of a new or significant reduction in a -

probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? from any previously '

evaluated?

CTS 3.17 / 4.17 contain the requirements for No. Even when the units were No. Elimination of No. Due to the decay of operability, compensatory action, and surveillance operational, these filters and operability requirements iodine since the units last of the particulate filters and charcoal adsorbers in adsorbers did not serve to decrease for these filters and operated, these filters and various ventilation systems including the control the probability of an accident. adsorbers will not produce adsorbers are not needed to room and fuel handling ventilation systems. Since the iodine has decayed such any new failure modes in maintain doses within the that the dose limits in 10 CFR 50, the associated systems that margins of safety The specifications in this section have not been App. A, Criterion 19 and in 10 would result in any type of established in 10 CFR 100 included in the PDTS since no credit is taken for CFR 100 would not be exceeded in design basis accidents. and 10 CFR 50, App. A any ventilation system function in the analyses of the event of a design basis fuel GDC 19.

the accidents that are credible with both units handling accident, they have not permanently defueled been credited in any of the remaining accident analyses and i there are no significant i consequences from the climination of the operability requirements for i these filters and adsorbers.

Page 12 of 26

1 ATTACHMENT C SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES Description of Change Does the change involve a . Does the change create Does the change involve a significant increase in the the possibility of a new or . significant reduction in a probability or consequences of a - different kind of accident margin of safety? I previously evaluated accident? - froni any previously evaluated?

CTS 5.2 provides a general description of the No. The RCS is not involved in No. Eliminating design No. There is no longer any design and function of the RCS. the design basis accidents that restrictions on the RCS margin of safety associated remain credible with both units will not produce any new with the RCS.

This specincation has not been included in the permanently defueled. The type of accident since it no PDTS since the RCS no longer performs the stated probability of an accident longer serves any function functions of removing heat from the core or involving the integrity or related to design basis serving as a post accident boundary for Gssion ftmetionality of the RCS is accidents.

products. The RCSs of both units have been essentially zero. With no core in depressurized and vented for the SAFSTOR the reactor, the off site period. consequences of a accident involving the RCS are no longer signincant.

CTS 5.3 provides a general description of the No. The probability and No. There can be no new No. There is no longer any design and size of the core. consequences of an accident accident involving the margin of safety involving involving the reactor core have not reactor core since there no the reactor core since there This speciHcation has not been included in the been increased since there no longer is any core. no longer is any core.

PDTS since all fuel has been permanently longer is any core.

removed from both reactors. Consequently there is no longer any reactor core.

CTS 5.4 provides a general description of the No. There is no longer any fuel in No. Even when the units No. The containment no design and function of the containment. the containment so it is no longer were operational there was longer functions to limit needed to reduce the probability of no accident that would be parameters following a This specincation has not been included in the accidents caused by external created by a violation of design basis accident.

PDTS since the containments no longer perform sources. With the reactors any of the these design Therefore there is no the stated functions of serving as a post accident defueled, the containment is no features. Therefore reduction in safety margins Page 13 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CilANGES Description of Change - Does the change involve a' .Does the change create: Does the change involve a significant increase in the the possibility of a new or significant reduction in a -

probability or consequences of a : different kind of accident- margin of safety?;

previously evaluated accident? from any previously evaluated? ~.

boundary for fission products or biological shield. !onger needed to reduce the deleting these features can't from deleting the All fuel has been permanently removed from ben consequences of an accident by produce a new kind of description ofits design containments. serving as a post accident fission accident. features.

p.mdect barrier or radiation shield.

CTS 5.6 provides a general description of the No. The SSCs identified in the No. T he SSCs identified in No. There is no longer any Seismic Class I equipment vital to safe shutdown specification do not alTect the the specification are only safety margin associated or containment isolation, or whose failure might probability or consequences of the involved with accidents with the SSCs identified in cause or increase the severity of a Loss of Coolant accidents that remain credible with that could affect the specification. The Accident (LOCA). The specification also provides both units permanently defueled. operational units. DSAR requirements will a description of requirements for meeting a Design Consequently the seismic Elimination of seismic ensure that an adequate Basis Earthquake and special requirements for safe qualification of these systems also qualification requirements safety margin is provided shutdown equipment. The specification also notes has no afTect the probability or for these SSCs can only for those SSCs involved that other SSCs are designed to withstand an consequences of these accidents. affect their ability to with the accidents that Operational Basis Earthquake or per applicable respond the analyzed remain credible.

codes, and are defined as Seismic Class 2 or 3. Elimination of requirements operational accidents.

pertaining to an Operational Basis These descriptions have not been included in the Earthquake also has no affect the PDTS since safe shutdown, post accident probability or consequences of containment isolation, LOCAs, and the ability to these accidents since the units will withstand an earthquake and keep operating are no no longer be operational.

longer of concern.

The DSAR requirements will Those seismic design features that are relevant provide assurance that the seismic with the units permanently shutdown and defueled qualifications of SSC's are will be described in the DSAR. adequate to preclude increasing the probability or consequences of the accidents that do remain credible.

Page 14 of 26

ATTACilMENT C SIGNIFICANT llAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change . Does the change involve a Does the change create. Does the change involve a -

significant increase in the - the possibility of a new or significent reduction in a probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? - from any previously evaluated? ~-

CTS 6.1.1.a requires that lines of authority, No. This is an administrative No. The clwncy does not No. This change does not responsibility, and communication be documented change involving the location of directly etTect any directly involve any limits in the Quality Assurance Manual, which is also quality assurance requirements. structure, sy stem, oc or parameters and therefore used for Comed's operating sites. There is no mechanism for it to component or the manner cannot affect any margin of directly affect the probability or in which they are operated safety.

A provision has been added to the PDTS allowing consequences of an accident. or maintained. Therefore this documentation to be contained in a site- the change cannot specific quality assurance program description introduce any new failure incorporated directly or by reference in the DSAR. mechanism or create a new This provision would allow implementation of a accident initiator.

site-specific program approprir.te to the permanently defueled status oithe 7. ion units.

CTS 6.1.3 contains the requirements for minimum No. Single unit shutdown sites No. The number of No. This change does not shift manning. have been successfully functioning individuals on shift does directly involve any limits with a minimum shift crew of two not affect the failure mode or parameters and therefore The CTS Figure 6.1-1 requirement that at least two individuals. Since Zion has a of any equipment or create cannot affect any margin of ,

Non-certified operators be on shift has been shared SFP and support systems, any new accident initiators. safety.

changed in PDTS Table 5.2.2-1 such that one Non- the demands on the crew are no The credible accidents and certified operator is required, for a total of 2 greater than for a single unit site. operational events remain individuals required to be on shift. The proposed Therefore would be no significant limited to fuel handling manning has been found to be acceptable for other reduction in the ability of the crew accidents, low level permanently shutdown sites with a single spent to prevent accidents or operational radioactive waste handling fuel pool. events, nor would there be any accidents, and loss of significant reduction in the ability cooling to the spent fuel of the crew to mitigate an accident pool at normal and reduced or event. levels.

Page 15 of 26

ATTACHMENT C SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES Description of Change Does the change involve a - Does the change create ' Does the change involve si significant increase in the the possibility of a new or significant reduction in a probability 'or consequences of a different kind'of accident margin of safety? -

previously evaluated accident? from any previously evaluated?

CTS 6.1.5 requires that training / retraining of plant No. The on shift individuals No. There are no credible No. This change does not ,

personnel be in accordance with ANSI N18.1. having overall responsibility for mechanisms for changes in directly involve any limits preventing the few design basis training requirements to or parameters and therefore This specification has not been included in the accidents that remain credible or directly result in new or cannot affect any margin of PDTS since, with the units permanently shutdown mitigating their consequences are difTerent types of accidents. safety.

and defueled only the training / retraining program the Certified Fuel Handlers. The for the Certified Fuel Handlers need be specified training and retraining in the PDTS. Some of the ANSI N18.1 requirements for these individuals requirements, such as those for training in startup will be maintained in accordance and shutdown procedures and emergency with a program required by the shutdown systems, are no longer appropriate. PDTS. This program and the Moreover, the spectrum of credible accidents and Comed controlled programs the quantity and complexity of activities required training / retraining ofother plant ,

for safety has been greatly reduced from that at an personnel will provide adequate :

operating plant. Consequently it is only necessary assurance that there will be no that the PDTS specify the training / retraining increase in the probability or requirements for the personnel who are most consequences of an accident. ,

directly responsible for maintaining facility safety.

These personnel are the Shift Supervisors, who are required by PDTS 5.2 to be Certified Fuel I Ilandlers. The training and retraining program for Certified Fuel Handlers was reviewed and approved by the NRC and must be maintained as specified by PDTS Section 5.4. The training / retraining of other plant personnel will be governed by Comed controlled documents.

t i

Page 16 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CHANGES Description of Change Does the change involve a Does the change create; Does the change involve a significant increase in the the possibility af a new or. s_ignificant reduction in a probability or consequences of a different kind of accident margin of safety?:

previously evaluated accident? from any previously evaluated? -

CTS 6.1.6 requires that retraining of personnel be No. As discussed above it is only No. There are no credible No. This change does not conducted at intervals not to exceed two years. necessary that training / retraining mechanisms for changes in directly involve any limits requirements for the Certified Fuel training requirements to or parameters and therefore This specification has not been included in the Handlers will be maintained in the directly result in new or cannot alTect any margin of PDTS for reasons similar to that given for CTS PDTS by reference. This includes different types of accidents. safety.

6.1.5 above, i.e., inclusion in the PDTS of specific the periodicity of the retraining.

retraining requirements for personnel who are not The frequency of retraining for required to be Certified Fuel Handlers is not Certified Fuel Handlers is necessary. Only the retraining requirements for specified in the NRC approved the Certified Fuel Handlers need be specified in program. This provides adequate ,

the PDTS. The retraining program for the assurance that there will be no Certified Fuel Handlers (which includes biennial increase in the probability or retraining) was reviewed and approved by the consequences of the few design NRC and must be maintained as specified t y basis accidents that remain PDTS Section 5.4. The training / retraining ofother credible.

plant personnel will be governed by Comed controlled documents.

CTS 6.2.1.b requires that Emergency Operating No. The subject EOPs were only No. The deletion of EOP No. This change does not Procedures (EOPs) be prepared, implemented, and used in response to accidents that requirements cannot directly involve any limits maintained in accordance with NUREG-0737 and had already begun and therefore directly result in new or or parameters and therefore Generic Letter 82-33 (Supplement 1 to NUREG- had no effect on the probability of different types of accidents. cannot afTect any margin of 0737). an accident. The EOPs only safety, addressed operational accidents His specification has not been included in the and therefore had no efTect on the PDTS. In response to the requirements in the consequences of the accidents that above identified documents, Comed prepared and are credible with both units implemented a procedure generation package for defueled.

Page 17 of 26

ATTACllMENT C SIGNIFICANT liAZARDS CONSIDERATION FOR PROPOSEI) CIIANGES Description of Change Does the change involve a Does the change create Does the change involve a significant increase in the the possibility of a new or significant reduction in a probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? from any previously evaluated?

upgrading the EOPs when the plant was operational. However, none of the EOPs are applicable with the units permanently defueled.

CTS 6.2.1.c requires that Station Security Plan No. This change is an No. This change does not No. This change does not procedures be prepared, implemented, and administrative change involving directly alTect any plant directly involve any limits maintained. Since Station Security Plan the review of security procedures, equipment involved with , or parameters and therefore implementing procedures are listed in this and cannot directly affect the the safe storage and i cannot affect any margin of specification, their review requirements are probability or consequences of an handling of nuclear fuel or safety.

specified in CTS 6.2.3 and 6.2.4. accident. how such equipment is operated and maintained.

These review requirements may be excluded from Therefore it cannot produce the PDTS since the Station Security Plan contains a new or difTerent kind o review requirements for these procedures. accident.

CTS 6.2.1.d requires that Generating Station No. This change is an No. This change does not No. This change does not Emergency Response Plan procedures be prepared, administrative change involving directly affect any plant directly involve any limits implemented, and maintained. Since Generating the review of Generating Station equipment involved with or parameters and therefore Station Emergency Response Plan procedures are Emergency Response Plan the safe storage and cannot affect any margin of listed in this specification, their review procedures, and cannot directly handling of nuclear fuel or safety.

requirements are specified in CTS 6.2.3 and 6.2.4. afTect the probability or how such equipment is consequences of an accident. nonnally operated and These review requirements may be excluded from maintained. Therefore it the PDTS since the Station Security Plan contains cannot produce a new or review requirements for these procedures. difTerent kind of accident.

Page 18 of 26

ATTACllMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change - Does the change involve a Does the change create ' Does the change involve a sign'ficant increase in the - the possibility of a new or significant reduction in a probability or consequences of a different kind of accident . margin of safety?

pret iously evaluated accident? from any previously evaluated?

CTS 6.2.1.e requires that Process Control Program No. This change is an No. This change does not No. This change does not procedures be prepared, implemented, and adn'inistrative change involving directly alTect any plant directly involve any limits maintained. Since Process Control Program the icview of Process Control equipment involved with or parameters and therefore procedures are listed in CTS 6.2.1, their review Prog am procedures, and cannot the safe storage and cannot affect any margin of requirements are specified in CTS 6.2.3 and 6.2.4. direct?y affect the probability or handling of nuclear fuel or safety.

conseq.tences of an accident. how such equipment is These review requirements have not been included nomially operated and in the PDTS since, review requb ements for these maintained. Therefore it procedures are already contained in 10 CFR cannot produce a new or 71.113. ditTerent kind of accident.

CTS 6.2.1.h requires that procedures be preparea, No. Requir ments conceming No. This change does not No. This change does not implemented, and maintained for a Post Accident post occ.Jent sampling cannot directly affect any plant directly involve any limits Sampling Program which would ensure the affect the probability that any equipment involved with or parameters and therefore capability to obtain and analyze reactor coolant accident will occur. The the safe storage and cannot alTect any margin of and containment atmosphere samples, and collect consequences of the accidents that handling of nuclear fuel or safety.

and analyze or measure radioactive iodine and remain credible have been shown how such equipment is particulates in plant gaseous efiluents under to be within the criteria given in 10 normally operated and accident co ditions. CFR 100 and 10 CFR 50, App. A maintained. Therefore it ;

Criterion 19 with no credit for cannot produce a new or This specification has not been included in the sampling or active response by different kind of accident ,

PDTS since, with both units defueled, there are no station personnel. Therefore the credible accident scenarios that release significant consequences will not be radioactivity to the reactor coolant, containment significantly afTected by removal ;

atmosphere, or plant gaseous eflluents, or that will of these requirements for sampling result in severe accident conditions that would procedures from the technical preclude obtaining samples. specifications. ,

Page 19 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change: Does the change involve n - Does the change create - Does the change involve a significant increase in the the possibility of a new or significant reduction in'a probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? - from any previously' evaluated?'

Site procedures will be maintained, as part of the radiation protection program required by 10 CFR 20.1101, which are adequate to for sampling gaseous effluents under the conditions which would result from the accidents that remain credible with both units permanently defueled.

CTS 6.2.6 requires that the listed programs be established, implemented and maintained. I The Zion PDTS contain a new specification, No. This change does not affect No. The proposed LLDs No. The safety margin 5.6.1.d, that is not in the CTS. This any of the analyzed accidents. The are sufficiently low such involved in this change is specification requires that the ODCM contain change only alTects the LLD for that there is no threat to established by 10 CFR the limits for releasing solid material to unrestricted release of material and public health and safety 20.1402 at 25 mrem /yr.

unrestricted areas, and that the limits be based there is no analyzed accident involved. Consequently, The industry standards on the lower limits of detection (LLDs) involving such low level material. there is no new accident specified in the proposed established in accordance with certain NRC involved with use of the change would limit and industry standards. The specification also LLDs established by this exposures to 5 mremlyr.

requires that applicable radionuclide proposed change. Therefore the margin of distributions, scaling fhetors, and sampling safety would be methods be specified in the ODCM. maintained.

Inclusion of these requirements will establish approved, consistent, and explicit material release requirements that are independent of technological changes which can alter LLDs.

Page 20 of 26

ATTACIIMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change . Does the change involve :: - Does the change create- Does the change involve a significant increase in the . the possibility of a new or significant reduction in a probability or consequences of a different kind of accident' margin of safety?

previously es aluated accident? from any previously evaluated? -

Zion PDTS Section 5.6 includes a Technical No. This change is an No. This change does not No. This change does not Specification Bases Control Program that is not administrative change involving directly affect any plant directly involve any limits in the CTS. This program, which is contained the review of Bases changes , and equipment involved with or parameters and therefore in specification 5.6.4, provides a means for cannot directly affect the the safe storage and cannot affect any margin of processing changes to the Bases of the PDTS probability or consequences of an handling of nuclear fuel or safety.

without prior NRC approval provided the accident. how such equipment is change meets the criteria of 10 CFR 50.59. operated and maintained.

Therefore it cannot produce a new or different kind of accident.

6.2.6. A requires that a Radioactive Ellluent No. The change only involves the No. There is no No. There is no safety <

Controls Program established, implemented and . grace period allowed for mechanism for margin involved with the maintained in accordance with 10 CFR 50.36a, perfomiing surveillances required requirements concerning a grace period for performing and specifies the elements that the program is to by the Radioactive Efiluent surveillance grace period to surveillances required by contain. Controls Program. There is no create any accident. the Radioactive Effluent change in the nominal periodicity Controls Program A statement has been added to the end of Zion of the surveillances. The credible PDTS 5.6.2 to clearly indicate that the 25% accidents in no way involve the surveillance frequency allowance provided by SR frequency of these surveillances.

3.0.2 is also applicable to the Radioactive Ellluent Controls Program surveillances. This is consistent with the Zion ITS.

't Page 21 of 26

ATTACilMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CllANGES Description of Change Does the change involve a Does the change create Does the change involve a significant increase in the the possibility of a new or significant reduction in a !

probability or consequences of a different kind of accident - margin of safety?

previously evaluated accident? from any previously ;

evaluated?

CTS 6.6.1.B contains the requirements pertaining No. This change is an No. This change does not No. This change does not to the Occupational Exposure Report. administrative change involving directly affect any plant directly involve any limits the due date for an annual report, equipment involved with or parameters and therefore The due date for the report was changed from and cannot directly affect the the safe storage and cannot affect any margin of March I of each year, as specified in the CTS, to probability or consequences of an handling of nuclear fuel or safety.

April 30 of each year consistency with the accident. how such equipment is standard improved Technical Specifications. operated and maintained.

Therefore it cannot produce a new or different kind of accident.

CTS 6.6.1.C contains the requirements pertaining No. This change is an No. This change does not No. This change does not to the Annual Radiological Environmental administrative change involving directly affect any plant directly involve any limits Operating Report. the due date for an annual report, equipment involved with or parameters and therefore and cannot directly affect the the safe storage and cannot affect any margin of The due date for the report was changed from May probability or consequences of an handling of nuclear fuel or safety. ,

I of each year to May 15 of each year for accident. how such equipment is consistency with the standard Improved Technical operated and maintained. ;

Specifications. Therefore it cannot produce a new or different kind of accident. ,

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Page 22 of 26

ATTACllMENT C SIGNIFICANT llAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change . Does the change involve a Does the change create Does the change involve a significant increase in the the possibility.of a new or significant reduction in si probability or consequences of a - different kind of accident margin of safety?

previously evaluated accident?- from any previously evaluated?

CTS 6.6.1.E requires submittal of a monthly report No. This change is an No. This change dor s not No. This change does not containing operating data such as hours critical, administrative change involving directly affect any plant directly involve any hours on-line, net electrical energy produced, the need for a monthly report of equipment involved with changes to limits or shutdowns, daily power levels, etc. operating data, and cannot directly the safe storage and parameters and therefore affect the probability or handling of nuclear fuel or cannot affect any margin of This specification has not been included in the consequences of an accident. how such equipment is safety.

PDTS since this information is no longer relevant operated and maintained.

with the units permanently shut down. Therefore it cannot produce Elimination of this specification is consistent with a new or different kind of Generic Letter 97-07 which prescribes the contents accident.

of the Monthly Operating Report and which is addressed to:

"All holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel."

Comed has submitted this certification.

Page 23 of 26

ATTACHMENT C SIGNIFICANT llAZARDS CONSIDERATION FOR PROPOSED CIIANGES Description of Change . Does the change involve a Does the change create - Does the change involve a significant increase in the . the possibility of a new or significant reduction in a .

probability or consequences of a different kind of accident margin of safety?

previously evaluated accident? from any previously evaluated?

CTS 6.6.3.B.e requires an annual report regarding No. The elimination of the No. The change in No. The change in expansion plans for Waukegan Regional Airport reporting requirement will not reporting requirements reponing requirements including FAA form # 5010 (Airport Master affect the probability of an aircraft does not affect the manner does not change limits or Record). crash at the site. The apparent in which any SSC parameters and therefore probability of an aircraft crash functions or fails to cannot affect any margin of This specification has not been included in the affecting the fuel building remains function, or the manner in safety.

PDTS since it is not necessary to ensure safety. A acceptably low. The elimination which it is operated.

1989 study supporting License Amendment of the reporting requirement does Consequently, the change 119/108 evaluated the probability of aircraft not affect the extent of damage produces no new accident crashing in the vicinity of certain important plant that could be caused by such a initiators.

structures and causing fires that threatened safety crash. Therefore the consequences related components. This study detennined that of the accident are unchanged.

the probability of such an event for the Crib Ilouse air intakes, including the entire roof area and a 40 foot zone around the air intakes was 7.5 x 10* per year. As documented in the NRC SER for the amendment, this probability would remain below 1.0 x 10# per year even allowing for estimated growth of the airport through 2008. With both units pennanently defueled, the Crib Ilouse and its components are no longer safety related. Ilowever the target area is comparable to that of the fuel building. Based on this low apparent probability combined with the fact that the FAA form # 5010 has not changed since 1990, Comed considers that this specification is no longer needed to ensure safety and can be excluded from the PDTS.

Page 24 of 26

ATTACIIMENT C

' SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CIIANGES -

Description of Change: Does the change involve a; Does the change create Does the change involve a significant increasein the the possibility of a new or - significant reduction in a:

probability or consequences of a . different kind of accident - margin of safety?

previously e+aluated accident? from any previously evaluated?

CTS 6.8 requires that all doors listed in a CTS No. Elimination of this No. This change is No. This change does not Table be closed if there is the possibility of requirement does not alTect the concerned solely with directly involve any flooding. probability of a flooding event flooding events and does changes to limits or since that is an act of nature. The not involve any other type parameters and therefore This specification has not been included in the consequences of a credible flood ofevent. cannot affect any margin of PDTS since there is no significant safety concern event are not increased since, with safety.

from a flooding event with the units permanently the both units permanently defueled. The most significant flooding threat to defueled, there are no significant the site would be that caused by a seiche on Lake safety consequences.

Michigan. This could potentially result in a water level 2 feet above grade (592.0') for about 20 minutes. This is well below the top of the spent fuel pool (approx. 617'). If any components involved in spent fuel pool cooling were affected there would be adequate time to restore the components or to take other actions to compensate for their unavailability.

CTS 6.9 requires that: No. This change is an No. This change does not No. This change does not administrative change involving directly affect any plant directly involve any Documentation for changes to the PCP contain the review of changes to the PCP, equipment involved with changes to limits or sufficient information to support the change and cannot directly affect the the safe :;iorage ard parameters and therefore together with the appropriate analyses or probability or consequences of an handling of nuclear fuel or cannot affect any margin of evaluationsjustifying the change (s); accident. how such equipment is safety.

operated and maintained.

Documentation for changes to the PCP contain Therefore it cannot produce a detennination that the change will maintain a new or different kind of the overall conformance of the solidified waste accident.

Page 25 of 26

ATTACilMENT C SIGNIFICANT IIAZARDS CONSIDERATION FOR PROPOSED CHANGES Description of Change Does the change involve a Does the change create Does the change involve a significant increase in the ~. the possibility'of a new or significant reduction in a:

probability or consequences of a ~ different kind of accident L margin of safety? -.

previously evaluated accident? ' from any previously -

evaluated? -

product to existing requirements of Federal, State, or other applicable regulations; and

- Changes to the PCP become effective aller review and acceptance by the Onsite Review ,

and Investigative Function and the approval of the Decommissioning Plant Manager.

r These requirements have not been included in the PDTS since adequate review requirements will be incorporated into the ODCM.

i Page 26 of 26

ZION STATION LICENSE AMENDMENT REQUEST NUMBER 98-06; PERMANENTLY DEFUELED TECIINICAL SPECIFICATIONS ATTACllMENT D ENVIRONMENTAL ASSESSMENT STATEMENT FOR PROPOSED CilANGES Comed has evaluated this proposed operating license amendment request against the criteria for identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. Comed has determined that this proposed license amendment request meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9) and as such, has determined that no irreversible consequences exist in accordance with 10 CFR 50.92(b). This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or that changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:

(i) the amendment involves no significant hazards consideration.

As demonstrated '1 Attachment C, this proposed amendment does not involve any significant hazards consideration.

(ii) there is no significant change in the types or significant increase in the amounts of any effluent that may be released olTsite.

As documented in Attachment A, there will be no change in the types or significant increase in the amounts of any effluents released offsite.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure.

As documented in Attachment A, there will be no increase in individual or cumulative occupational rad:ation exposure resulting from this change.

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l ZION STATION LICENSE AMENDMENT REQUEST NUMBER 98-06; PERM ANENTLY DEFUELED TECIINICAL SPECIFICATIONS ATTACIIMENT E

' i TABLE SUMMARIZING TILE DISPOSITION OF TIIE ZION CTS IN l TILE ZION PDTS AND COMPARING TIIE DISPOSITION WITII TIIE MAIN YANKEE PDTS l

l l

l

ATTACHMENT E TABLE SUMMARIZING THE DISPOSITION OF THE CTS IN THE ZION PDTS AND COMPARING THE DISPOSITION WITH THE MAIN YANKEE PDTS l

Zion CTS Section/ Specification Equivalent Maine Proposed Disposition in !

Yankee PDTS Zion PDTS*

Definitions -

1.1 ACTION 1.1 Definitions 1.1, Definitions 1.2 ACTUATION DEVICE None Not included 1.3 ACTUATED EQUIPMENT None Not included 1.4 ACTUATION LOGIC TEST None Not included 1.5 AXIAL FLUX DIFFERENCE None Not included 1.6 Previously deleted N/A N/A 1.7 CHANNEL CAllBRATION, INSTRUMENT None Not included 1.8 CHANNEL CHECK None Not included l 1.9 CHANNEL FUNCTIONAL TEST None Not included 1.10 Previously deleted N/A N/A 1.11 CONTAINMENT INTEGRITY None Not included 1.12 Previously deleted N/A N/A 1.13 CONTROLLED LEAKAGE None Not included 1.14 CORE ALTERATION None Not included 1.14A CORE OPERATING LIMITS REPORT None Not included 1.15 DEFINED TERMS 1.1 Definitions Note 1.1, Definitions Note 1.16 DEGREE OF REDUNDANCY None Not included 1.17 DOSE EQUIVALENT l-131 None Not included 1.18 E-AVERAGE DISINTEGRATION None Not included ENERGY 1.19 Previously deleted I N/A N/A 1.20 IDENTIFIED LEAKAGE None Not included 1.21 INSTRUMENT CHANNEL None Not included 1.22 LEAKAGE Ncne Not included 1.23 MASTER RELAY TEST None Not included 1.24 MEMBER (S) OF THE PUBLIC None Not included 1.25 OFF-SITE AC POWER SOURCES None Not included 1.26 OFFSITE DOSE CALCULATION 5.6.2 Offsite Dose Calculation 5.6.1, Offsite Dose Calculation MANUAL (ODCM) Manual (ODCM) Manuai(ODCM) 1.27 OPERABLE- OPERABILITY None Not included 1.28 OPERATING None Not included 1.29 OPERATING CYCLE None Not included ,

I l 1.30 OPERATIONAL MODE-MODE None Not included 1.31 PHYSICS TESTS None Not included t

1.32 PRESSURE BOUNDARY LEAKAGE None Not included ,

1.32A PRESSURE AND TEMPERATURE None Not included l

LIMITS REPORT (PTLR) 1.33 PROCESS CONTROL PROGRAM (PCP) None Not included i 1.34 PROTECTION LOGIC CHANNEL None Not included ;

1.35 PROTECTION SYSTEM None Not included i 1.36 PURGE-PURGING None Not included 1.37 QUADRANT POWER TILT RATIO None Not included 1.38 RATED THERMAL POWER None Not included 1.39 REACTOR PRESSURE None Not included 1.39 REFUELING CYCLE OR OUTAGE None Not included 1.41 REPORTABLE EVENT None Not included Page 1 of 6

ATTACHMENT E TABLE SUMMARIZING THE DISPOSITION OF THE CTS IN THE ZION PDTS AND COMPARING THE DISPOSITION WITH THE MAIN YANKEE PDTS Zion CTS Section/ Specification Equivalent Maine Proposed Disposition in Yankee PDTS Zion PDTS*

1.42 SHUTDOWN MARGIN None Not included 1.43 SITE BOUNDARY None Not included 1.44 Previously deleted N/A N/A 1.45 SOURCE CHECK None Not included 1.46 SURVEILLANCE FREQUENCY None Not included NOTATION 1.47 THERMAL POWER None Not included 1.48 UNIDENTIFIED LFAKAGE None Not included 1.49 UNRESTRICTED AREA None Not included 1.50 Previously deleted N/A N/A 1.51 VENTING None Not included Safety Limits / Limiting Safety System Settings 1.1/ 2.1 Reactor Core None Not included 1.2 / 2.2 Reactor Coolant System Pressure None Not included Limiting Conditions for Operation / Surveillance Requirements 3.0.1 (LCO/ Action Applicability) LCO 3.0.1 (Applicability) LCO 3.0.1 (Applicability) 3.0.2 (LCO/ Action Compliance) LCO 3.0.2 (Actions) LCO 3.0.2 (Actions) 3.0.3 (Failure to comply -LCO/ Action) None Not included 3.0.4 (Mode change re. LCO/ Action) None Not included j 3.0.5 (AC power availability) None Not included j 4.0.1 (Surveillance applicability) SR 3.0.1 (Applicability) SR 3.0.1 (Applicability) 4.0.2 (SR interval / extension) SR 3.0.2 (Frequency) SR 3.0.2 (Frequency) 4.0.3 (Failure to comply - SR) SR 3.0.3 (Non-performance) SR 3.0.3 (Non-performance) 4.0.4 (Mode change re. SR) None Not included 4.0.5 (ISI &lST Surveillance Rules) 5.6.5 Inservice Testing Not included Program 3.1/ 4.1 Reactor Protection Instrumentation None Not included and Logic 3.2 / 4.2 Reactivity Control and Power None Not included Distribution 3.3 / 4.3 Reactor Coolant System (per unit) None Not included l 3.4 / 4.4 Safeguards Instrumentation and None Not included Control 3.5 / 4.5 Reactor Containment Fan Coolers None Nat included 3.6 / 4.6 Containment Spray None Not included 3.7 / 4.7 Steam Generator E nergency Heat None Not included Removal 3.8 / 4.8 Emergency Core Cooling and Core None Not included Cooling Support 3.9 / 4.9 Containment isolation Systems None Not included 3.10/4.10 Containment Structural Integnty None Not included 3.11 /4.11 Radioactive Liquids None 5.6.3, Outdoor Storage Tank Radioactivity Monitoring Program Page 2 of 6

ATTACHMENT E l TABLE SUMMARIZING THE DISPOSITION OF THE CTS IN THE ZION PDTS AND

( COMPARING THE DISPOSITION WITH THE MAIN YANKEE PDTS Zion CTS Section/ Specification Equivalent Maine Proposed Disposition in Yankee PDTS Zion PDTS*

l 3.12 /3.12 Gaseous Effluents None Not included l 3.13/4.13 Refueling Operations l 3.13.1/4.13.1 Core Reactivity None Not included l 3.13.2/4.13.2 Protection from Damaged None Not included Spent Fuel 3.13.3/4.13.3 Containment Status None Not included l 3.13.4/4.13.4 Radiation Monitoring None Not included 3.13.5/4.13.5 Refueling Equipment None Not included Operability

_ 3.13.6 / 4.13.6 (Refueling Actions) None Not included 3.13.7 / 4.13.7 (Spent Fuel Pit Cooling None Not included l System) 3.13.8 / 4.13.8 (Fuel inspection Program) None Not included 3.13.9/4.13.9 Residual Heat Removal None .Not included System Operation 3.13.10/4.13.10 Water Level Reactor None Not included Vessel 1 3.13.11/4.13.11 Water Level-Storage Pool 3.1.1 Fuel Storage Pool 3.1.1, Spent Fuel Pool Water !

Water Level Level l 3.13.12/4.13.12 Previously deleted N/A N/A i 3.13.13/4.13.13 Spent Fuel Pool Storage 4.2.3 Capacity 3.1.3, Spent Fuel Assembly Storage 3.13.14/4.13.12 Spent Fuel Storage Pool 3.1.2 Fuel Storage Pool 3.1.2, Fuel Storage Pool Boron Baron Conm Boron Concentration Concentration 3.13.15 / 4.13.15 (Spec. 3.0.3 Non- None Not included applicability) 3.13.16 / 4.13.16 (Spec. 3.0.4 Non- None Not included applicability) 3.14 /4.14 Plant Radiation Monitoring None Not included 3.15/4.15 Auxiliary Electrical Power System None Not included i 3.16 Previously deleted N/A N/A )

3.17/4.17 Ventilation None Not included 3.18/4.18 Steam Generator Activity None Not included '

3.19/4.19 Failed Fuel Monitoring None Not included 3.20 Previously deleted N/A N/A 3.21 Previously deleted N/A N/A 3.22 /4.22 Shock Suppressors (Snubbers) None Not included 3.23 Previously deleted N/A N/A 3.24 / 4.24 Sealed Source Contamination None Not included Design Features .

5.1 Site 4.1.1 Site Description 4.1.1, Site Desenption 5.2 Reactor Coolant System None Not included I

5.3 Reactor Core None Not included

! 5.4 Containment System None Not included l 5.5 FuelStorage l 5.5.1 New Fuel Storage None 4.2 Fuel Storage

5.5.2 Spent fuel storage 4.2 Fuel Storage 4.2, Fuel Storage Page 3 of 6

l ATTACHMENT E TABLE SUMMARIZING THE DISPOSITION OF THE CTS IN THE ZION PDTS AND COMPARING THE DISPOSITION WITH THE MAIN YANKEE PDTS Zion CTS Section/ Specification Equivalent Maine Proposed Disposition in Yankee PDTS Zion PDTS*

5.6 Seismic Design None Not included Administrative Controls 6.1 Organization l 6.1.1 (Onsite and Offsite organizations) 5.2.1 General Organizational 5.2.1, General Organizational i Requirements Requirements j 6.1.2 Previously Deleted N/A N/A j 6.1.3 (Shift manning) 5.2.2 Unit Staff 5.2, Shift Staff l l 6.1.4 (Management and operating staff 5.3 Unit Staff Qualifications 5.3, Staff Qualifications i l qualifications) !

6.1.5 (Retraining and replacement of station None Not included 1 personnel) l 6.1.6 (Retraining interval) None Not included )

6.1.7 (Certified Fuel Handler training and 5.4 Training 5.4, Training retraining program) 6.2 Procedures and Programs j

! 6.2.1 (Procedures) 5.5.1 Procedures 5.5.1, Procedures 6.2.1.a (Procedures per R.G.1.33, App. A) 5.5.1.a (R.G.1.33 5.5.1.a (R.G.1.33 procedures) procedures) 6.2.1.b (Emergency Operating procedures None Not included

, per NUREG-0737, Sup.1, and G.L.

l 83-33) 6.2.1.c (Secunty Plan procedures) None Not included 6.2.1.d (GSEP procedures) 5.5.1.b (Emergency Plan Not included.

implementation) 6 2.1.e (PCP procedures) None Not included

6.2.1.f (ODCM procedures) 5.5.1.f (Programs specified in 5.5.1.c (Programs specified in Specification 5.6) Specification 5.6) 6.2.1.g (Fire Protection procedures) 5.5.1.e (Fire Protection 5.5.1.b (Fire Protection procedures) procedures) 6.2.1.h (Post Accident Sampling None Not included procedures) 6.2.1.i (Overtime procedures) 5.2.2.e (Overtime procedures) 5.2.2.e (Overtime procedures) 6.2.2.A (Radiation Control procedures) 5.6.1 Radiation Protection Not included Program 6.2.2.B. High Radiation Area 5.8 High Radiation Area 5.8. High Radiation Area 6.2.3 (Technical review and control of None Not included procedures) 6.2.4 (Temporary changes to procedures) None Not included 6.2.5 (GSEP Dnlis) None Not included 6.2.6 Programs 5.6 Programs and Manuals 5.6, Programs and Manuals 6.2.6.A Radioactive Effluent Controls 5.6.3 Radioactive Effluent 5.6.2, Radioactive Effluent j Program Controls Program Controls Program l 6.2.6.B Radiological Environmental None Not included Monitoring Program I 6.3 Actions to be Taken in the Event of a None Not included Reportable Event in Plant Operation 6.4 Previously deleted N/A N/A

! 6.5 Plant Operating Records None Not included Page 4 of 6

- . . __. . .- -_ -_ -_ ~ -- - -

ATTACHMENT E TABLE SUMMARIZING THE DISPOSITION OF THE CTS IN THE ZION PDTS AND COMPARING THE DISPOSITION WITH THE MAIN YANKEE PDTS Zion CTS Section/ Specification Equivalent Maine Proposed Disposition in Yankee PDTS Zion PDTS*

6.6 Reporting Requirements 5.7 Reporting Requirements 5.7, Reporting Requirements 6.6.1 Routine Reports 6.6.1.A Startup Report None Not included 6.6.1.B Annual Occupational Exposure 5.7.1 Occupational Exposure 5.7.1, Occupational Exposure Report Report Report 6.6.1.C Annual Radiological Environmental 5.7.2 Annual Radiological 5.7.2, Annual Radiological Operating Report Environmental Operating Environmental Operating Repod Repod 6.6.1.D Radioactive Effluent Release 5.7.3 Radioactive Effluent 5.7.3, Radioactive Effluent Report Release Report Release Report 6.6.1.E Monthly Operating Report None Not included l 6.6.1.F Core Operating Limits Report None Not included (COLR) 6.6.1.G Reactor Coolant System (RCS) None Not included Pressure and Temperature Limits Report (PTLR) 6.6.2 Reportable Events None Not included 6.6.3 Unique Reporting Requirements 6.6.3.A Previously deleted lN/A lN/A 6.6.3.B Special Reports 1 6.6.3.B.a in-Service Inspection Evaluation None Not included 6.6.3.B.b Previously deleted N/A N/A 6.6.3.B.c Containment Building Structural None Not included Testing Report (ILRT. Tendon) 6.6.3.B.d Changes to the Offsite Dose 5.6.2 Offsite Dose Calculation 5.6.1, Offsite Dose Calculation Calculation Manual (ODCM) Manual Manual 6.6.3.B.e Waukegan Regional Airport None Not included Expansion Plans 6.6.3.B.f Low Temperature Overpressure None Not included Protection System Operation 6.6.3.B g Primary Coolant Specific Activity None Not included 6.6.3.B.h Pressurizer PORV or Safety None Not included Valve Failure to Close 6.6.3.B.i Pressurizer PORV or Safety Valve None Not included challenges 6.6.3.B j (not used) N/A N/A 6.6.3.B.k Steam generator tube inspection None Not included and/or plugging 6.6.3.B.I Emergency Core Cooling System None Not included (ECCS) actuation and injection I

when RCS temp > 350 F

, 6.6.3.B.m Diesel generator failures None Not included l 6.6.3.B.n Post Accident Radiation monitor None Not included l inoperable greater than 7 days 6.7 Offsite Dose Calculation Manual (ODCM) 5.6.2 Offsite Dose Calculation 5.6.1, Offsite Dose Calculation Manual Manual 6.8 Flooding Protection None Not included 6.9 Process Control Program (PCP) None Not included i

Page 5 of 6

ATTACHMENT E TABLE SUMMARIZING THE DISPOSITION OF THE CTS IN THE ZION PDTS AND COMPARING THE DISPOSITION WITH THE MAIN YANKEE PDTS

! : Zion CTS Section/ Specification Equivalent Maine Proposed Disposition in Ya'nkee PDTS ~ Zion PDTS*

j 6.10 Containment Leakage Rate Testing None Not included Program 1

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In some instances, CTS specifications that have been included in the PDTS have been modified to be applicable to the units' permanently defueled status.

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ZION STATION LICENSE AMENDMENT REQUEST NUMBER 98-063 PERMANENTLY DEFUELED TECIINICAL SPECIFICATIONS ATTACIIMENT F REFERENCES FOR PROPOSED AMMENDMENT

1) Letter from M. K. Webb, NRC, to M. J. Meisner, Maine Yankee Atomic Power Company, dated March 30,1998, Issuance of License Amendment No.161, Permanently Defueled Technical Specifications

2) NUREG 1431, Standard Technical Specifications for Westinghouse Plants, Revision 1, dated April 7,1995.

3) Letter from O D. Kingsley, Comed, to U.S. NRC, dated February 13,1998, Certification of Permanent Cessation of Operations

4) Letter from O. D. Kingsley, Comed, to U. S. NRC, dated March 9,1998, Certification of Permanent Fuel Removal

5) Letter from C. Y. Shiraki, U. S. NRC, to O. D. Kingsley, Comed, dated December 19, 1997, Issuance of Amendments 178/165 to Facility Operating Licenses DPR-39 and DPR-48, Improved Technical Specifications

6) Letter from R. R. Assa, U. S. NRC, to O. D. Kingsley, Comed, dated July 24,1998, Issuance of Amendments 179/166 to Facility Operating Licenses DPR-39 and DPR-48, Restoration of Custom Technical Specifications, Reinstatement of Previous License Conditions, Changes in Management Titles and Responsibilities, Use of Certified Fuel liandlers, Changes to Shift Staffing and Crew Composition, and Elimination of Verbiage Implying the Units are Operational

7) Letter from M. J. Meisner, Maine Yankee, to U. S. NRC, dated October 20,1997, under Docket 50-309, concerning Proposed Technical Specification Change No. 207, Permanently Defueled Technical Specifications

8) Letter from J. C. Brons, Comed, to U. S. NRC, dated March 16,1998, Request for Approval of Certified Fuel Handler Training and Retraining Program

9) Letter from R. R. Assa, U. S. NRC, to O. D. Kingsley, Comed, dated July 20,1998, Accepting Comed's Proposed Certified Fuel IIandler Program i

Page 1 of 2 L

ZION STATION LICENSE AMENDMENT REQUEST NUMBER 98-063 l PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS t

ATTACIIMENT F REFERENCES FOR PROPOSED AMMENDMENT l

l 10) Letter from John C. Brons, Comed, to U. S. NRC, dated March 30,1998, Application for Amendment to Restore Custom Technical Specifications, Reinstate Previous License Conditions, Change Management Titles and Responsibilities, Use Certified Fuel l Handlers, Change Shift Staffing and Crew Composition, and Eliminate Verbiage Implying the Units are Operational

11) Letter from J. C. Brons, Comed, to U. S. NRC, dated March 12,1998, Application for Exemption from the 24 Month Update Requirement of 10 CFR 50.71 l l l

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f Page 2 of 2

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i i ZION STATION l LICENSE AMENDMENT REQUEST NUMBER 98-06; l PERMANENTLY DEFUELED TECllNICAL SPECIFICATIONS i

ATTACIIMENT G BASIS FOR REDUCTION IN MINIMUM NUMBER OF NON-CERTIFIED OPERATORS REQUIRED ON SilIFT Com Ed considers that, consistent with the Maine Yankee PDTS, two operators (Certified fuel handler and non-certified operator) constitute adequate shift manning to ensure the safe storage l and handling of nuclear fuel at Zion during routine, non-routine, and abnormal conditions.

Routine Conditions Although Zion is a two unit site, the units share a single spent fuel pool with a common cooling system. Major support equipment such as service water pumps, component cooling pumps and heat exchangers, and makeup sources are located together in common areas regardless of unit assignment. Consequently, the routine functions of periodically monitoring pool level and the status of support equipment, and adding makeup for evaporative losses can readily be accomplished by one operator while the other operator staffs the control room. The number of individuals needed to perform these functions is no greater for a two unit site than for a single unit site.

Non-Routine Conditions ,

l With five other nuclear plants, Comed can augment the minimum shift crew if necessary to support non-routine operations (i.e. planned operations other than the routine monitoring of stored fuel). If movement of fuel or other components in the spent fuel pool were to be undertaken, additional personnel would be assigned on shift to assist with the operation. For example, during recent operations in and around the spent fuel pool in support of shipping unirradiated fuel for reprocessing, a dedicated fuel movement crew was used in addition to the normal minimum shift crew. Additional personnel would also be assigned if significant !

operations not involving the spent fuel pool are undertaken, as is currently being done to support l l

synchronous condenser operation.

I Abnormal Conditions As described in Attachment A to this letter, the remaining credible accidents and operational ,

events include only two that could result in a release of radioactivity; a fuel handling accident !

and a low level radioactive waste handling accident. The analyses of both these accidents have shown that the potential releases are within the requirements of 10 CFR100 with no operator action. The operator functions during these or similar events would likely be limited to initial l

Page 1 of 2

s ATTACilMENT G BASIS FOR REDUCTION IN MINIMUM NUMBER OF NON-CERTIFIED OPERATORS REQUIRED ON SillFT communication and co-ordination activities. The tasks required would be no greater for a two unit site than for a single unit site. Therefore, two operations personnel would be adequate shift manning if such events were to occur.

The operational events described in Attachment A to this letter involve loss of cooling to the spent fuel pool at nonnal and reduced levels. As a result of the long heatup times for the spent fuel pool, there is ample time to restore cooling prior to reaching a limiting condition, even if additional personnel needed be called in to respond to these events. Therefore, the number or i personnel needed on shift to respond to such events is not critical and is no greater for a two unit site than for a single unit site.

Ilased on the above, Comed considers that the minimum shift crew at Zion need be no larger than at single unit permanently shutdown sites such as Trojan and Maine Yankee, and that as a licensee of multiple nuclear power stations, Comed may be better able to augment the minimum shin crew for non-routine operations. l l

i Page 2 of 2 l

1 ZION STATION i LICENSE AMENDMENT REQUEST NUMBER 98-06; ;

PERMANENTLY DEFUELED T ECIINICAL SPECIFICATIONS !

1 ATTACilMENT II LIST OF COMMITMENTS IDENTIFIED IN Tills AMENDMENT REQUEST Tne following table identifies those actions committed to by Comed in this document. Any other actions discussed in this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.

Commitment Committed Date The following current License Conditions and CTS requirements will be In the initial issue relocated to the DSAR: of the DSAR prior to implementation License Condition,2.C.(7)(b) (Control Of Loads Over the SFP) of the PDTS CTS 3.24/4.24 (Seuled Source Contamination)

CTS 5.1 Descriptions of the exclusion area and the low population zone CTS 5.5 Information on the capacity of the new fuel racks, the number of sections and rows, the distance berveen each section, the U235 gram / centimeter loading, and the vault drain CTS 5.5 Information concerning the SFP stainless steel liner and vertical array, the U235 gram / centimeter loading, and the figure showing a diagram of the SFP CTS 5.6 The seismic design features that are relevant with the units permanently shutdown and defueled )

l i

The prohibition of temporary procedure changes will continue. At least until a (CTS 6.2.4) change is made to l the Quality i l

Assurance Manual l The CTS 6.1.3 descriptions of responsibilities of the Decommissioning Prior to :

l Plant Manager and the Decommissioning Operations Manager regarding implementation of the Fire Protection Program will be relocated to site documents. the PDTS l

1 t !

l Page 1 of 2 j j

ZION STATION LICENSE AMENDMENT REQUEST NUMBER 98-06; PERMANENTLY DEFUELED TECIINICAL SPECIFICATIONS o

ATTACIIMENT II Commitment Committed Date Adequate review requirements for changes to the PCP will be Prior to incorporated into the ODCM. (CTS 6.9) implementation of I the PDTS l

)

The gas decay tanks will be vented and removed from service. (CTS Prior to 3.12/4.12) implementation of I the PDTS i

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ML20154E344

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