CY-04-227, Supplemental Information-Changes to Selected Radiological Requirements and Organizational Titles in Technical Specifications

Supplemental Information-Changes to Selected Radiological Requirements and Organizational Titles in Technical Specifications

ML043280540
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	11/15/2004
From:	Norton W Connecticut Yankee Atomic Power Co
To:	Document Control Desk, NRC/FSME
References
-RFPFR, CY-04-227, FOIA/PA-2005-0203
Download: ML043280540 (5)

Text

CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJ1lN HOLLOW ROAD

• EAST HAMPTON, CT 06424-3099 NOV 15 2GO4 Docket No. 50-213 CY-04-227 Re: 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Supplemental Information-Changes to Selected Radiological Requirements and Organizational Titles in Technical Specifications In a letter dated January 9, 20041,'.Connecticut Yankee Atomic Power Company (CYAPCO) proposed to amend its Operating License, DPR-61 by'revising the Haddam Neck Plant (HNP) Technical Specifications. Among other changes proposed, a change to Technical Specifications 6.6'A'.6and 6.6.3.a.2 was proposed to resolve a conflict between these'specifications and Te6hnical Specification 6.6.4.b. Technical Specification 6.6.4.b states that the Radioactive Effluent Controls Program (RECP) shall have limitations on' the concentrations of radioactive material released in liquid effluerits to unrestricted a'reas' These limitations shall conform to the pre-1994 concentration values in 10 CFR 20, Appendix B, Table II, Column 2.

Use of pre-1994 10 CFR 20, Appendix B values is consistent with the HNP Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM).

-In -contrast,-the-current-Technical-Specification.6.6.4.c states that monitoring,:.

sampling and analysis of radioactive liquid and gaseous effluents shall be in accordance with 10 CFR 20.1302. In the January Submittal, CYAPCO stated that compliance with this section would require use of the post 1994 10 CFR 20, Appendix B values and would not be in accordance with the HNP REMODCM.

Therefore, it was proposed to replace the words "10 CFR 20.1302" to "pre-1994 10 CFR 20.106" in Technical Specifications 6.6.3.a.2 and 6.6.4:c

However, during a discussion with the NRC Staff on November 8, 2004, the&NRC indicated that the current 10 CFR 20 .1302 allows to use of either pre-1994 10 CFR W. Norton (CYAPCO) letter to US NRC, "Haddam Neck'Plant - Technical Specification Change Request - Changes to Selected Radiological Relat6d Technical Specifications and Changes to Organizational Titles in Technical Specifications," dated January 9, 2004.

Document Control Center CY-04-227 / Page 2 20, Appendix B or post-1994 10 CFR 20 Appendix B values for monitoring, sampling and analysis of radioactive liquid and gaseous effluents. As such, changes to Technical Specifications 6.6.4.c and 6.6.3.a.2 are not required. CYAPCO concurs with the NRC Staff's position and is hereby withdrawing the above changes.

CYAPCO has revised the affected pages of Technical Specifications to reflect the above conclusion and are submitted herewith in Attachment 1.

The proposed changes included in this submittal do not impact the previously submitted Significant Hazards Consideration (SHC) discussion (see SHC provided in Attachment 1 of CYAPCO's submittal dated January 9, 2004).

There are no regulatory commitments contained in this letter.

If you should have-any.questions regarding this submittal, please-contact Mr. G.- P. - -'-

van Noordennen at (860) 267-3938.

Sincerely, CONNECTICUT Y E ATOMIC POWER COMPANY Wiyi.fon DAte I President Attachment cc: S. J. Collins, NRC Region I Administrator T. B. Smith, NRC Project Manager, Haddam Neck Plant R. R. Bellamy, Chief, Decommissioning and Laboratory Branch, NRC Region I E. L. Wilds, Jr., Director, CT DEP Monitoring and Radiation Division Subscribed and sworn to before me

-This~_- 15j . day of% g /2004 Notary Public

- Commission Expires: /- 3/-o7

Docket No. 50-213 CY-04-227 Attachment 1

-Haddam Neck-Plaff Supplemental Information-Changes to Selected Radiological Requirements and Organizational Titles in Technical Specifications Retyped HNP Technical Specifications Paqes November 2004

6.6 Programs and Manuals (continued) 6.6.3 Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)

The REMODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the Radiological Environmental Monitoring Program.

The REMODCM shall also contain the Radioactive Effluent Controls and Radiological Environmental Monitoring Program required by Specifications 6.6.4 and 6.6.5, respectively,-and descriptions of the-inf&rmation that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports required under Specifications 6.7.2 and 6.7.3.

Changes to the REMODCM:

a. Shall be documented and records of review shall be retained. This documentation shall contain:

1. sufficient information to support each change together with the appropriate analyses or evaluations to justify the change; and

2. a determination that each change maintains the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and that the change will not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

b. Shall become effective after the change is independently reviewed in accordance with administrative proceduresand approved by the designated manager or designee; and

c. Shall be submitted to the NRC in the form of a complete legible copy of the entire REMODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change was made to the REMODCM. A summary of each change shall be included.

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.

HADDAM NECK 6-9 Amendment No. 125,-155,-158, 170, 44 4192,196 TSSEC6

6.6 Programs and Manuals (continued) 6.6.4 Radioactive Effluent Controls Program 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 REMODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation, including surveillance tests and setpoint determinations, in accordance with the methodolodgyde&cribed in the REMODCM;

b. Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas, conforming to the pre-1994 concentration values in 10 CFR Part 20, Appendix B (to 20.1 to 20.602), Table II, 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 described in the REMODCM;

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 the facility to unrestricted areas, conforming to 10 CFR Part 50, Appendix I;

e. Determination of cumulative dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters described in the REMODCM performed at least every 92 days and determination of projected dose contributions from radioactive effiue-nhs in accoraance withfihe methodology in the REMODCM performed at least every 92 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 period of 31 days would exceed 2% of the guidelines for the annual dose or dose commitment, conforming to 10 CFR Part 50, Appendix l; HADDAM NECK 6-10 Amendment No. 4495 TSSEC6