CEO-88-024, Supplemental Application for Amend to License DPR-54, Consisting of Rev 1 to Proposed Amend 102,deleting App B of Tech Specs

Supplemental Application for Amend to License DPR-54, Consisting of Rev 1 to Proposed Amend 102,deleting App B of Tech Specs

ML20207C067
Person / Time
Site:	Rancho Seco
Issue date:	07/27/1988
From:	Firlit J SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20207C071	List: CEO-88-024, Supplemental Application for Amend to License DPR-54, Consisting of Rev 1 to Proposed Amend 102,deleting App B of Tech Specs ML20207C083
References
CEO-88-024, CEO-88-24, NUDOCS 8808050028
Download: ML20207C067 (7)

Text

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o.uuo SACRAMENTO MUNICIPAL UTluTY olSTRICT O 6201 s street, P.O. Box 1583o, sacramento CA 958521830,(916) 452 521i AN ELECTRIC SYSTEM SERVING THE HEART CF CAUFORNIA JUL 2 71988 C d 88-024 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Station Pl-137 Washington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 PROPOSED AMENDMENT NO.102, REVISION 1

Dear Sir:

In accordance with 10 CFR 50.90, the Sccramento Municipal Udlity District proposes to amend Operating License DPR-54 for Rancho Seco and therefore submits Proposed Amendment No.102, Revision 1. By letter to the Commissi3n dated December 12, 1984, the District submitted the initial version of Proposed Amendment flo.102 Revision 1 of Proposed Anendment No.102 replaces the initial Proposed Amendment No.102 submittal in its entirety.

Due to further review by the District and recently approved Amendre.ar.t No.c . 96 and 98, Proposed Amendment No.102 has t,een modified. Attachw nt. I includes a description of and reason for tha changes made by Proposed  :

Amendment No.102, Revis'un '. Also included in Attachant I is the L'o -

Significant Hazards Consioeration for these changes. All issues and concerns raised by the Commission regarding deletion of Appendix B from the inncho Seco Technical Specifications are addressed in Attachment I. Attachmont d lists the existing pages affected by Proposed Amendment No.1Ci, Revine 1 ind contains the page which replaces all of Appendix B to the Rancho Sm Technical Specifications.

Pursuant to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health Services has been informed of this proposed amendment by mailed copy of this submittal.

Members of your staff with questions requiring additional information or clarification may contact Mr. Richard Mannheime at (209) 333-2935, extension 4919.

8808050028 880727 I I PDR ADOCK 05000312 P PDC RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road, Herald, CA 95638 9799:(204) 333 2935

Director of NRR CEO 88-024 4

State of California '

SS County of Sacramento Joseph F. Firlit, being first duly sworn, deposes and says: that he is CEO, Nuclear of Sacramento Municipal Utility District (SMUD), the licensee herein; that he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said licensee.

ppdep!V F. Firlir.

Chief Executive Officer, Nuclear Subst.ribed and affirmed to before me this J 7 day of G a/t. ,1988.

Yf suu 1. /M Esther Hughes y Notary Public cc: A. D' Angelo, NRC, Rancho Seco J. B. Martin, NRC, Walnut Creek J. S. McGurk, State of California _

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I ATTACHMENT I Description of Change, Reason for Change, and No Significant Hazards Consideration for Proposed Amendment No. 102, Revision 1 4

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Proposed Amendment N3. 102, Revision 1 Log N3. 1069 :

Safety Analysis Page 1 of 4 l Safety Analysis Report RE00rjAt:.lon of Change Proposed Amendment No. 102, Revision 1 deletes the remaining non-radiological items contained within Appendix B of the Rancho Seco Technical Specifications (Tech Specs). Pages i, 11, and 1 through 50 of Appendix B to the Toch Specs are removed and repisced by new Page 1.

Reason for Chanae The non-radiological items remaining in Appendix B which were not deleted by Amendment No. 45 are eliminated based on the foliowing information. The Chemistry and Radiation Protection groups at Rancho Seco have been involved with a non-radiological environmental surveillance orogram for over 13 years.

This program consists of erosion protection, draft contaminant monitoring, noise monitoring, and fogging patterns associated with the cooling towers.

Samples obtained during the implementation of this program have not indicated any hazardous effects to the environment or the general public. Historical data shows that no severe erosion of the stream bed or degradation of soil banks surrounding the effluent stream has occurred. The only significant amount of erosion has taken place during the heavy winter and spring rains.

This would have occurred regardless of plant operation. The deletion of noise surveys from Appendix B can bt iustified since historical data shows that the suiveys have been within acce,'-ble limits. Monitoring of fogging patterns can also be deleted. Past observations of fogging patterns associated with the cooling towers has shown no significant fog increase. The only fog observed has been normal valley fog during the winter months. For these reasons, the District intends to delete these non-radiological items from Appendix B of the Tech Specs.

The Administrative Controls Tech Specs in Section 5 of Appendix B are bounded by the administrative controls established in Section 6 of Appendix A. The '

need for administrative controls in Appendix B no longer exists.

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Proposed Amendment No. 102, Revision 1 Log No. 1069 Safety Analysis Page 2 of 4 I i

No Sianificant Hazards __ Consideration The changes proposed in this Tech Spec amendment have no significant impact on plant safety or on site personnel, or public health and safety. Past implementation of the non-radiological Tech Specs has not indicated any hazardous effects to the environment or the general public due to the operation of Rancho Seco. These non-radiological operating restrictions were originally imposed because acceptable operation was not yet demonstrated regarding the environmental impact of Rancho Seco. The District believes relief from the non-radiological items in Appendix B of the Tech Specs should be granted because the non-radiological impact of Rancho Seco has been demonstrated as acceptable under the criteria established by the Commission.

In accordance with Amendment No. 45, the NRC is provided with a copy of any changes to the National Pollutant Discharge Elimination System (NPDES) permit and any permit violations. Appendix B Environmental Tech Specs which pertain to non-radiological water quality rec,uirements were deleted with Amendment No.

45. Water quality limits and monitoring programs associated with this permit are under the jurisdiction of the California Regional Water Quality Control Board. All non-radiological environmentai monitoring program changes and violations are handled by the appropriate federal, state, local and regional authorities.

Amendment No. 53 added several Administrative Controls Tech Specs which duplicate or exceed requirements contained in Section 5.0 of Appendix B. A letter from John F. Stolz, Chief Operating Reactor Branch #4 Division of Licensing dated September 11, 1985, asked for assurance that the administrative controls in Section b of the Appendix A Tech Specs duplicate or i exceed the following items:

1. Appendix B, Administrative Controls, deletion of Sections 5.3.A.2 and 5.3.B.2, requirements to review onsite tests and experiments and results thereof when such tests have environmental significance.

2. Appendix B, Administrative Controls, deletion of Section 5.6.3, reporting requirements and evaluation of plant design changes when the changes may adversely impact the environment.

3. Appendix 8, Administrative Controls, deletion of Section 5. , requirement to maintain environmental records.

Appropriate replacement Tech Specs exist for item 1 in several sections.

Deletion of Appendix B, Administrative Controls Section 5.3. A.2 is justified

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because of the review responsibilities required of th' Plant Review Committee (PRC) in Specification 6.5.1.6 cf Apoendix A. Part a. states that the PP.C

- will review the safety evaluations of all procedures required by Specification 6.8. Specification 6.8 includes: Process Control Program implementation procedures, Offsite Dose Calculation Manual implementation procedtres, Radiological Environmental Monitoring Program implementation procedures, and Effluent Control and Environmental Monitoring Quality Assurance Program proceduas. 1ho PRC reviews the safety evaluations of all proposed tests and meritients that affect nuclear safety, and the PRC also reviews facility

operryions to detect potential safety hazards.

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Proposed Amendment No. 102, Revision 1 Log No. 1069 Safety Analysis Page 3 of 4 Appendix B, Administrative Controls, Section 5.3.B.2 is no longer necessary because of Appendix A, Specification 6.5.2.6d. The Management Safety Review Committee (HSRC) reviews all changes to the Tech Specs or the Operating License. Tech Spec changes are all accompanied by a safety analysis evaluating the impact of the change.

The requirements of Administrative Controls Section 5.6.3 of Appendix B are

atisfied in Section 6 of Appendix A. The NRC requested that Specifications 5.6.3.1 and 5.6.3.2 of Appendix 8 be retained in Appendix A. These two Specifications were included in the District's submittal of Proposed Amendment No. 138, Revision 2 and approved as part of Amendment No. 96 by NRC letter dated February 19, 1988. In compliance with Appendix B, Specification 5.6.3.3, all Tech Spec changes are required to be submitted to the Director of Nuclear Reactor Regulation for Commission approval. All proposed Tech Spec amendments are submitted with a Safety Analysis Report, which contains a No Significant Hazards Determination.

The requirements of Section 5.7 to Appendix B (Records Retention) are satisfied by Section 6.10 of Appendix A.

Based on the above discussion, the probability of occurrence or consequence of an accident previously evaluated in the SAR will not be increased, the possibility of occurrence of an accident of a different type than previously evaluated in the SAR will not be created, and the margin of safety as defined in the basis for any Tech Spec is not reduced; therefore, an Unreviewed Safety Question is not involved.

The District has reviewed the proposed changes against each of the criterion of 10 CFR 50.92 and concluded that the changes to the Tech Specs discussed above would not:

a. Significantly increase the probability or consequences of an '

accident previously evaluated because the proposed Tech Spec changes will not change the way any plant system or component important to safety is operated. The proposed amendment eliminates unnecessary Tech Spec requirements. Administrative controls deleted in Appendix 8 which were of concern to the Commission are duplicated or exceeaed in Appendix A.

b. Create the possibility of a new or different type of accident than previously evaluated because implementation of the non-radiological Tech Specs is now considered to be unnecessary. Acceptable ,

operation of Rancho Seco with regard to environmental impact has l been demonstrated. All appropriate administrative controls exist 1 ir Appendix A of the Tech Specs.

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Proposed Amendment No. 102, Revision 1 Log N2. 1069 Safety Analysis Page 4 of 4

c. Involve a significant reduction in the margin of safety because the deletion of the remaining Appendix B Tech Specs does not affect any system or component important to safety. The proposed changes do not impact the margin of safety defined in any bases to the Tech Specs. The non-radiological impact of Rancho Seco has been d;monstrated acceptable under criteria established by the Commission.

On the basis of the above, the District concludes that the proposed changes do not constitute any significant hazard to the public, and in no way endanger the public's health and safety.

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