ML050870598
| ML050870598 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/01/2005 |
| From: | AmerGen Energy Co |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| %dam200604, +sispmjr200506 CY-OC-170-301, Rev 1, PORC Meeting 04-37 | |
| Download: ML050870598 (12) | |
Text
PORC Meeting 04-37 Page 7 of 16
__ __ __ __ _ _ _ _ _ _ AT A CH ME-N T __ _ _ _ _
PORC 04-37 Meeting Notes CY-OC-170-301, Rev 1, Oyster Creek Offsite Dose Calculation Manual Presenter. B. Artz 50.59 Safety Evaluation I ] Yes [XI No Disposition:
[ ]Approval Recommended
[X] Approval Recommended with Conditions (see below)
]Remanded
[]Review only Summary of Chances:
Currently the ODCM requires reporting both the type of shipping container as well as identification of solidification agent in the Annual Radioactive Effluent Release Report. This ODCM revision deletes these two requirements. The ODCM revision deletes an unnecessary administrative task and brings our ODCM in line wrth Corporate Procedure CY-AA-17o-2000, which also does not have the deleted requirements.
The ODCM is also being revised to add / delete TLD locations due to some existing locations being inaccessible.
Summary of Safety Significance:
CY-OC-170-301 is an administrative document (Offsite Dose Calculation Manual) and this revision has no impact on nuclear safety, plant operations, or any design bases I safety analysis, as described In the UFSAR. A 10CFR50.59 Screening or Evaluation for this revision was not required. The revision was processed in accordance with procedure CY-M-170-3100, Offsite Dose Calculation Manual Revisions.
Significant Questions / Comments by PORC, Including Resolutions-(1) PORC: The ODCM deletes current shipping requirements. Verify that there are no existing Oyster Creek Commitments, which could impact these deletions.
Response: The Oyster Creek Commitment Tracking Database was checked and there are no existing commitments.
PORC Meeting 04-37 Page 8 of 16 (2) PORC: Attachment2 to CY-AA-170-3100 is missing the "Determination No."
Response: The "Determination No." has.beeaddedtothe-Attachment-2.- --
PORC Open hems:
None
02/07/05 12:17:56 : a Exelen.- ATTACHMENT 1 Procedure Approval Form Page 1 of 1 AD-AA-1o1-1002 Revision 5 Nuclear Document Number: ( 4y - 0 rg0 - I o
Title:
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-0 roew-G-Canc -: -Revisbon -- - EC# ' PCRt. PPIS#: I Docurnen; -Resi -EEitoribl -
0 Batch ER#: ARt._ #:
o Supersade document(s) Ust Revision Summary:
Attach addl descript. If req'd Z ( it -. t ,3 . _01: Itz 4r,.-4:1 #A --t af-AWSZ%1704 IS4 K4 .14 . A- Print -- -
Originator: ' I D~ate - Ldcafion(U~
Applicable BR 0 DR 0 acO Site Contacts BY 0 LA E CL 3.
Check box and P80a -
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provide name TMIQ _ ZN O otthcwQ Validation Reqd: 0 No 0 Yes (attach)
Training ed: E&No 0OYes (Validation requirement see AD-AA-1 01) PrInLIagnature Change Management: 0 HU-AA-11O1 Change ChecgstAttactied EDocnent Traveler 0 None Required Level of Use: 0 Level 1 - Continuous Use J&Level 2 - Reference Use E Level 3 - Informatio n Use Approval CFAM (Standard Piocedures) P*nSki D~ate I rWn6,=
Approval l Site Document(s) to be superseded: _ 0&%-C Location: O . C I Use addion sheets e necessarY. A #tue that ON pending chadmes are dispoeifoned.
O Temp. Change 0 Interim Change Temp or Intefrm Change s
- ^^r F.-n -_l. rn v 7 1U~I;-1-DW.~ ipP11Ca04e; UgJV5'o UT85 O0xernpt per (Or sakpcae regubaor pmeces reviews) 10CFRT2.43 Applicable: 3 No 0 Yes Tracting mirnmW PORC Required: 0 No~l Yes PORC 04-37 Hunmwe . . -
1ae -1'UtI ApPrOVgOM IFLI,, T,W O ifsupei a doomen contalinng rnnt notsyte Co* TTad CoorikWer o tLS-A110 se CTD can be uped asappropbiae.
SQR/ITRJRTR 0 N/A Reqgd Reviews/ o. Surveillance Coordinator Review Req'd 0 No 0 Yes (list)
Cross Discipline Reviews Pike _ _ _ _ _ _ 1 _ MRp" or Or
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F,.. we LNs$cpecc f 2 ed kd Temp Change Authorization Only SRO P1int/Sjq;wD= SOR PrinVSigrvDate, Impl. Date Exv. Date SOR Approval Indicates ftl all requir WI b'(W rformed ard the rev;m*rs have &VWthis form. ThM procedure Is technically and funct!
SOR Approval:
Its Date 0tSd:*m or Site Authorization: N 71,VA A0 Dd;e Plant Man Date I
o2/071i05 12:17:5G I I 50.59 REVIEW COVERSHEETFORM------ Ls-A-w-lo Revision I Page 1 of 2 Station: Oyster Creek Activity/Document Number- CY-OC-170-301 Revision Number: 1
Title:
Offsite Dose Calculation Manual for Oyster Creek Generatint Station NOTE: For 50.59 Evaluationsforiation on this form will provide the basis for ptiig the biennial summar report submitted to the NRC in accordance with the requirements of 10 CFR 5059(dX2).
Description of Activity:
This activity is a revision of the Oyster Creek ODCM, procedure CY-OC-170-301. The changes are.
- Elimination of reporting requirement for type of shipping container
- Elimination of identification of solidification agent
- Adding TLD locations per Table 3.12.1-1
. Adding wording that allows for a variance from banging REMP TLDs in inaccessible areas
. Revision of Figure B-1: REMP Samplinig Locations Wiithin 2 Miles
- Revision of Figure E-2. REMP Sampling Locations Beyond 2 Miles.
Reason for Activity:
This activity is being performed based upon CAP 02003-2206 Action 6. Section 6.226 of Oem ODCM requires reporting of type of shipping container for solid waste as well as the identification of solidification aget. The inclusion of the above two items eliminates an administrative task that is unnecessary as well as bringing Oyster Creek's ODCM in line with Corporate Procedure CY-AA-170-2000. In addition, the changes of the REMP TiD sample locations do not inhibit REMP monitoring program as five (5) additional TLD sampling locations were added to the REMP program.
Effect of Activity:
This change deletes an unnecessary administrative task from the Annual Radioactive Efuent Release Report. Corporate Procedure CY-AA-170-2000 "Annual Radioactive Effluent Release Report" has various requirements for the above report but does not require the types of shipping container nor the type of solidification agent. The inclusion of the REMP sample locations provides the procedure user with flexibility for TLD sampker locations in inaccessible locations. It also adds TLD locations to REMP sample stations. This enhances the procedure and this change does not in any way negatively impact plant operations, design bases, or safety analyses described in the UFSAR.
Summary of Conchusion for the Activity's 5059 Reykw:
(Provide justification for the conclusion, including sufficient detail to recognize and understand the essential arguments leading to the conclusion. Provide more than a simple statement that a 50.59 Screening. 50.59 Evaluation, or a License Amendment Request, as applicable, is not required.)
Screening indicates that 5059 is NOT applicable to the deletion of the shipping container and solidification agent requirement in the ODCM as well as addition of REMP sample locations. Question 8 in the Applicability Review Form was answered YES since this is a program controlled by the "...Technical Specifications (such as the ODCM). The Screening demonstrates a 5059 Evaluation is not required. The procedure change may be implemented without prior NRC approval, as the intent of the procedure has not changed. However, in compliance with CY-AA-170-3100, "Offsite Dose Calculation Manual Revisions," the revised ODCM will be forwarded to the NRC with the submission of the next Annual Radiological Effluents Release Report.
Attachments:
Attach all 50.59 Review forms completed, as appropriate.
(NOTE: if both a Screening and Evaluation are completed, no Screening No. is required.)
I
- 02/07/05 12:17:S6 1 1 50.59 APPLICABILITY REVIEW FORM - LS-AA-104-l002 Revision I Page I of I Activityl/locument Number CY-OC-170-301 Revision Number: I Address the questions below for all aspects of the Activity. if the answer is yes for any portion of the Activity, apply the identified process(es) to that portion of the Activity. Note that it is not unusual to have more than one process apply to a given Activit
-See Section 4 of the Resource-Manual-M)-for-addidonal guidance - --- - - - one p
-I Does the proposed Activity involve a change
- 1. Technical Spccifications or Operating License (IOCFR50.90)? X NO _ YES See Section 4.2.1.1 of the RM
- 2. Conditions of License Quality Assurance program (IOCFR50-54(a))? X NO _ YES Secuity Plan (IOCFR50.54(p))? X NO _ YES See Section 4.2.1.2 of the RM Emerency Plan (IOCFR50.54(q))? XNO _YES
- 3. Codes and Standards ISTProgram Plan (I OCFR5O55sa(f))? X NO _ YES See Section 4+/-1.3 of the RH
- 4. ECCS Acceptance Criteria (IOCFR5O.46)? X NO _YES Sec Section 4.2.1.4 of the RH
- 5. Specific Exemptions (IOCFR50.12)? X NO _YES See Section 4.2.15 of the RM
- 7. Fire Protetion Program (applicable UFSAR or opeatng license XNO _ YES See Section 4Z 1.7 of the RM co ndtion)?__ _ _ _ _ _
- 8. Programs controlled by the Operating License or the TechnicalNO X YESRMSee Section 4+/-1.7 of the Specifications (juch as the ODCM). _
- 9. Environnseftal Protection Progwra X NO _ YES See Section 4.2.1.7 of the RM
- 10. Otir programs controlled by otherregulatio. X NO _YES See Section 4+/-1 of the RM II. Does the proposed Activity involve maintenance which sto SSCs to their original condition or involve a tmiwipoy akteration supporting X NO YES See Section 4.2.2 of the RM maintenance that will be in effect during at-power operations for 90 days or less?
I_ Does the proposed Activity involve a change to the:
- 1. UFSAR (including.docurments incorporated by reference) that is excluded from the requirement to perform a 5059 Review by NEI 96-07 X NO _YES See Section 4.23 of the RM or NET 98-03?
- 2. Managerial or administrative procedures governing the conduct of X NO -YES Se Section 424 of the RM facility operations (subiect to the control of JOCFR5. Appendix B) __
- 3. procedures for performing maintenance activities (subiect to IO CFR X NO _ YES See Section 4Z4 ofthe RM 50.65(aX4))?
- 4. Regulatory commitment not covered by another regulation based change X NO _ r S Scton 4+/-3/4+/-4 of the RM process (see NET 99-04)? _0 -E SeSeto423/ 4ofheR IV. Does the proposed Activity involve a change to the Independent Spent Fuel X NO YES Sec Sectio 4 Storage Installation (ISFSI) (subiect to control by 10 CFR 72.48) _ __.26o___
Check one of the following:
X If all aspects of the Activity are controlled by one or more of the above processe then a 50.59 Screening is not required and the Activity may be implemented in accordance with its governing procedure (l If any portion of the Activity is not controlled by one or more of the above processes, then process a 50.59 Screening for the portion not covered by any of the above processes. The remaining portion of the activity should be implemented in accordance with its governing procedure.
Signoff:
- II E 50.59 Screener/SO. 5 9 Evaluator 1.) b *A- -b Sign: 8 L-Date:8JZ, (Circle One) --- (Print name) I (8isgnA1ure) -. -
3
02/07/05 12:17:56 1 1 50.59 SCREENING FORM LS-AA-1 04-1 0( 3 0:
Revision Page I of SOM9 Screening No. OC-2004-S-0312 Rev. No. 0
.1 Activity/Document Number: CY-OC-170-301 Revision Number: I J.-L--509 Screening Questions (Check correct response and provide separate written response pr yidinghe ais-for the-'--
- J answer to each question)(See Sectlon 5 5r tFe Resouce Manual (RM) for additional guidance):
- 1. Does the proposed Activity involve a change to an SSC that adversely affects an UFSAR .. YES x NO described design function? (See Section 5.22.1 of the RM)
- 2. Does the proposed Activity involve a change to a procedure that adversely affects how UFSAR YESx NO described SSC design functions are performned or controlled? (See Section 52;2.2 of the RM)
- 3. Does the proposed Activity involve an adverse change to an clement of a UPSAR described _ YES x NO evaluation methodology, or use of an alternative evaluation methodology, that is used in establishing the design bases or used in the safety analyses? CSc Section 5.2.23 of the RM)
- 4. Does the proposed Activity involve a test or experiment not described in the UFSAR, where an YES x NO I SSC is utilized or controlled in a manner that is outside the reference bounds of the design for that SSC or is inconsistent with analyses or descriptions in the UFSAR? (See Section 5224 of the RM)
- 5. Does the proposed Activity require a change in the Technical Specifications or Operating YES x NO License? (See Section 5.2.2.5 of the RM)
II. List the documents (e.g.. UFSAR. Technical Specifications otber licensing basis, technical, comritmens etc.) reviewed, includin sect num here relevant information was found (if not identified in the response to each question).
Orte Procedure CY-AA-17G-200 - "Annual Radioactive Effuent Rclease Report:.
USFAR (See next C y, -)Cf IlL Select the appropriate conditions:
If all questions arc answered NO. then complete the 50.59 Screening and impk-eent the Activity per the applicable X governing procedure.
If question 1, 2, 3, or 4 is answered YES and question 5 is answered NO, then a 50.59 Evaluation shall be performed.
If questions 1, 2. 3, and 4 are answered NO and question 5 is answered YES, then a License Amendment is required prior to implementation of the Activity.
If question 5 is answered YES for any portion of an Activity, then a license Amendment is required prior to implementation of that portion of the Activity. In addition, if question l, 2,3, or 4 is answered YES for the remaining portions of the Activity, then a 50.59 Evaluation shall be performed for the remaining portions of the Activity.
IV. Screening Signoffs:
50.59 Screener. 012 A"&t&
(Print name)
Sign: Date: kjQ 4 5059 Reviewer: 6 Jw ffi 1 ) Sign: Date: /j32./
(Print name) (irme)
02/07/05 12:17:56 1 1 50.59 SCREENING FORM S10103---
Revision I Page 2 of 2 50.59 Screening No. OC-2004S-0333 Rev. No. 0 Activity/Document Number CY-OC-170-301 Revision Number 1
. proposed ne activity. is aies elatively minor revisions to the Oyster CrekOff Site Dose Calculation Manual - ODCM (CY-OC-170-301). The change deletes two reporting requirements for identifying shipping containers and identifying solidifi agents. These requirements are not included in the Corporate Procedure CY-AA-170-934-Anjioactive Effluent Release Report." In addition, this revision provides for a variance from locating REP TLDs in the outer sectors that cannot be accessed due to a lack of an overland highway. Both NUREG 1302 and the Branch Technical Position provide for this variance if geological barriers prohibit TLD location. This change in no way changes the Annual Radioactive Effluent Release Report or any other requirement in the USFAR. Therefore, the activity does not involve a change that will adversely affect an UFSAR described SSC design function.
- 2. The proposed activity. the revision of the ODCIA is a very minor change and merely brings Oyster Creek's ODCM in line with Corporate Procedures, NUREG 1302 and the Branch Technical Position. It does not involve a change to a procedure that adversely affects how UFSAR descnibed SSC design functions are performed or controlled. The deletion of a section that the calls out solidification agent and the type of shipping container eliminates an administrative task. This revision also provides for a variance from locating REMP TLDs when the original location is inaccessible. Therefore, this activity in no way adversely affects how UFSAR described SSC design functions are performed or controlled.
- 3. The proposed activity, the revision of the Oyster Creek ODCM by eliminating shipping container reporting requirements and solidification agent is not delineated in the UFSAR and does not require revising or replacing an UFSAR described evaluation methodology that is used in establishing the design bases or used in safety analyses for a SSC.
- 4. Deletion of the above two reporting requirements, addition of REMP sampling locations, as well as providing a variance in hanging TLDs in inaccessible locations is neither an experiment nor a test as described in the UTSAR where the SSC is utilized or controlled in a manner that is outside the reference bounds of SSC design or is inconsistent with analyses or descriptions in the UFSAR.
- 5. The proposed activity is not discussed in the Technical Specifications althouigh is discussed in the ODCM.
This activity in no way alters or changes any other license requirement. Therefore, this activity will not require a change to either the Operating License or Technical Specifications.
References:
UFSAR 1.9.24 Sampling and Analysis of Plant Effluents 2.1.1 Effluent Dose Limits 2.4.10 Release of Liquid Effluents 3.1.51 Release of Radioactive Materials to the Environment 3.1.54 Monitoring Fuel and Waste Storage 9.2.12.3 System Description of NRW and AOG 11.2.3.3 Dilution Factor for Radioactive Releases 11.5.2.2 Process Liquid Monitoring 1.9.17 Post Accident Sampling Capability Table 11.2.26 Population Doses from Liquid Effluents 113 Gaseous Waste Management System Table 113.12 Population Doses The term "Solidification" is discussed extensively in Section 11.5. but not in the context of reporting the_ _
solidification agent as required in the "Annual Radioactive-Effluent Release Report."
CY-AA-1 70-3100 Revision 0 Page 5 of 9 ATTACHMENT 1 ODCM Change Summary Matrix REMP Changes - Determination A Annual Radiological Effluents Release Report- Determination B Item (old) (new) Description of Change No. Rev. 0 Rev. 1 page page No. No.
1 All . All Changed header 2 61 61 Eliminated type of shipping container and type of solidification agent as reported in the Annual Effluents Report.
42 42 Changed number of kand-based sampling stations for the REMP Program from 11 (eleven) to 9 (nine).
114 112 Added sampling stations 4 115 113 Added sampling stations 6 119 118 Figure E-2 updated with samppling locations
CY-AA-1 70-3100 Revision 0 Page 6 of 9 ATTACHMENT 2 ODCM Change Determination Station: Oyster Creek Page 1 of 4
- VOD IM Revision No. 1 Determination NO.C-204-D-OOO1 I. Determination Questions (Check correct response)
- 1. Does the ODCM change maintain the level of radioactive effluent control X NO required by 10CFR20.1301 ? YES Explain: (provide sufficient information including appropriate analyses justifying the ODCM change)
The document 10CFR20.1301 deals with dose limits to individual members of the public. Deleting the type of shipping containers and the type of solidification agents in no way affects dose to the public. Furthermore, deleting two (2) TLD field sampling stations and adding four (4) more stations has no effect on calculated dose to the public since these stations are REMP stations and dose to the public is not calculated with these stations.
- 2. Does the ODWM change maintain the level of radioactive effluent control X YES - NO required by 1ICFR20.1302?
Explain: (provide sufficient information including appropriate analyses justifying the ODCM change) 10CFR20.1302 deals with compliance with dose limits for individual members of the public. As stated above these changes to the ODCM do not affect dose to the public as doses are not calculated using the REMP sampling TLDs.
- 3. Does the ODCM change maintain the level of radioactive effluent control X YES NO required by 40CFR1 90?
Explain: (provide sufficient information including appropriate analyses justifying the ODCM change) 40CFR1 90 deals with radiation doses received by members of the public in the general environment and to radioactive materials introduced into the general environment as the result of operations that are part of a nuclear fuel cycle. It is an Environmental Protection Agency regulation. Again, doses to the General Pubic are not calculated by the above criteria.
- 4. Does the ODCM chanae maintain the level of radioactive effluent control X YES -NO
_ _Revision 0 Page 7 of 9 ATTACHMENT 2 ODCM Change Determination required by 10CFR50.36a?
Explain: (provide sufficient information including appropriate analyses
-justifyingtheODCMM-hanr) - -
10CFR50.36a deals with Technical Specifications on effluents from nuclear power reactors. The section also deals with the plant operator developing operating procedures for dealing with operating the radioactive waste system at the plant. More specifically, for effluents, 50.36a also deals with the Annual Radiological Effluents Report. The changes to the ODCM, while affecting the Annual Radiological Effluents Report in deleting the two requirements for shipping containers and solidification agents, in no way affect dose to the public.
- 5. Does the ODCM change maintain the level of radioactive effluent control X YES NO required by Appendix I to 10CFR50?
Explain: (provide sufficient information Including appropriate analyses justifying the ODCM change) 10CFR50 Appendix I deals with offsite dose limits as calculated for the Annual Radiological Effluents Report. We are not changing the affected sections of the ODCM which are Section 3.11.2.1, which spells out the limits to whole body, skin and organ dose. Neither are we changing Section 3.11.2.2 which spells out annual air dose limits. Neither are we changing Section 3.11.2.3 which deals with dose due to radioactive iodine, tritium and particulates. Nor are we changing Section 3.11.4 which deals with calculated organ and total body doses from effluents.
CY-AA-I 70-3100 Revision 0 Page 8 of 9 ATTACHMENT 2 ODCM Change Determination Page .3 of 4
- 6. Does the ODCM change maintain the accuracy or reliability of effluent, dose, X YES NO or setpoint calculations?
Explain: (provide sufficient information including appropriate analyses justifying the ODCM change)
Setpoint calculations are not being changed. Furthermore, dose calculations are performed by the SEEDS program, controlled by Procedure 820.4 and the changes to the ODCM do not involve any changes to these items.
- 7. Does the ODCM change maintain the accuracy of radioactive effluent control X YES NO required by the SAR?
Explain: (provide sufficient information including appropriate analyses justifying the ODCM change)
The FSAR was searched and 'hits' were obtained in the following sections but in no case were the changes being made to the ODCM contraindicating to accuracy of radioactive effluent control:
1.9.24 Sampling and Analysis of Plant Effluents 2.1.1 Effluent Dose Umits 2.4.10 Release of Liquid Effluents 3.1.51 Release of Radioactive Materials to the Environment 3.1.54 Monitoring Fuel and Waste Storage 9.2.1.2.3 System Description of NRW and AOG 11.2.3.3 Dilution Factor for Radioactive Releases 11.5.2.2 Process Uquid Monitoring 1.9.17 Post Accident Sampling Capability Table 11.2.26 Population Doses from Uquid Effluents 11.3 Gaseous Waste Management System Table 11.3.12 Population Doses
CY-AA-1 70-3100
- Revision 0 Page 9 of 9 ATTACHMENT 2 ODCM Change Determination (example format)
Page 2 of 2 11.If all questions are answered-Y-ES,-then-complete-the-ODCM Change Determination-u--d Implement the Change per this procedure. -_
Ill. If any question is answered NO, then a change to the ODCM is not permitted IV. Signoffs:
Determination Preparer. 1.: :>-- I>> _) __________ Date:
(Printed Name) j Sgr ttu e)
Reviewer (Printed Name) re)
Date:4 4+/-- /