ML17332A580
| ML17332A580 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/10/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17332A579 | List: |
| References | |
| GL-89-01, GL-89-1, NUDOCS 9502270361 | |
| Download: ML17332A580 (6) | |
Text
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UNlTED STATES NUCLEAR REGULATORYCOMMISSION WASHINGTON, D.C. 2055540M SAFETY EVALUATION BY THE OFF C
OF NUC R REACTOR REGULA I N
RELATED TO AMENDMENT NO.
TO FAC L TY OPERATING ICENSE NO. DPR-58 AND AMENDMENT NO.
TO FAC LITY OPERATING LICENSE NO. DPR-74 INDIANA MICHIGAN POMER COMPANY HALD C.
COOK NUC R
T OS.
DOCKET NOS. 50-315 AND 50-3 6
1.0 INTRODUCTION
By letter dated August 3, 1994, the Indiana Michigan Power Company (the licensee) requested amendments to the Technical Specifications (TS) appended to Facility Operating License Nos.
DPR-58 and DPR-74 for the Donald C. Cook Nuclear Plant, Unit Nos.
1 and 2.
The proposed amendments would incorporate programIatic controls for radiological effluents and radiological environmental monitoring in the Administrative Controls section of the TS consistent with the requirements of 10 CFR 20.1302, 40 CFR Part
- 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50.
At the same time, the licensee proposed to transfer the procedural details of the Radiological Effluent Technical Specifications (RETS) from the TS to the Offsite Dose Calculation Manual (ODCM) or to the Process Control Program (PCP) for solid radioactive wastes as appropriate.
Mith these
- changes, the specifications related to RETS reporting requirements were simplified.
Finally, changes to the definitions of the ODCM and PCP were proposed consistent with these changes.
Guidance on these proposed changes was provided to all power reactor licensees and applicants by Generic Letter (GL) 89-01, "Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program," dated January 31, 1989.
- 2. 0 EVALUATION 2.1 Removal of RETS from the Technical S ecifications Section 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the content of TS.
The rule requires that TS include items in specific categories, including safety limits, limiting conditions for operation, and surveillance requirements; however, the rule does not specify the particular requirements to be included in a plant's TS.
The NRC developed criteria, as described in the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors,"
(58 FR 39132) to determine which of the design conditions and associated q5pp27p
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~00 pose,'
surveillances need to be located in the TS because the requirement is "necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Briefly, those criteria are (1) detection of abnormal degradation of the reactor coolant pressure
- boundary, (2) boundary conditions for design basis accidents and transients, (3) primary success paths to mitigate design basis accidents and transients, and (4) functions determined to be important to risk or operating experience.
The Commission's final policy statement acknowledged that its implementation may result in the relocation of existing TS requirements to licensee-controlled documents and programs.
The RETS provide the release limits and monitoring and reporting criteria for
- gaseous, liquid, and solid radioactive effluents.
Such releases are a
byproduct of the use of a nuclear reaction for power generation.
The RETS are not related to the detection of abnormal degradation of the reactor coolant pressure
- boundary, boundary conditions for design basis accidents and transients, primary success paths to mitigate design basis accidents and transients, or functions determined to be important to risk or operating experience.
In GL 89-01 the staff noted that it had examined the contents of the RETS in relation to the Commission's Interim Policy Statement of Technical Specifications Improvements and had determined that programmatic controls could be implemented in the Administrative Controls section of the TS to satisfy the existing regulatory requirements for RETS.
The staff had also determined that the procedural details of the TS on radioactive effluents and radiological environmental monitoring could be relocated to the ODCH, while the procedural details for solid radioactive waste could be relocated to the PCP.
After relocation, future changes to these procedural details will be controlled by the controls for changes to the ODCH and PCP included in the Administrative Controls section of the TS.
On this basis, the staff concludes that the RETS do not need to be controlled by TS, and changes to the RETS are adequately controlled by 10 CFR 50.59, "Changes,
- tests, and experiments."
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to Updated Final Safety Analysis Report (UFSAR) commitments and to take any remedial action that may be appropriate.
The staff has concluded, therefore, that relocation of RETS is acceptable because (1) their inclusion in TS is not specifically required by 10 CFR 50.36 or other regulations, (2) the RETS are not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
2.2 Im lementation of R TS Re i
ments and PC In GL 89-01 the staff provided model specifications and encouraged licensees to propose changes consistent with the GL.
The licensee's proposed changes to the TS are in accordance with the guidance provided in NRC GL 89-01 and are addressed below.
The licensee has proposed to incorporate programmatic controls for radioactive effluents and radiological environmental monitoring in Specifications 6.8.4.a.,
"Radioactive Effluent Controls Program,"
and 6.8.4.b.,
"Radiological Environmental Monitoring Program," of the TS as noted in the guidance provided in GL 89-01.
The programmatic controls ensure that programs are established, implemented, and maintained to ensure that operating procedures are provided to control radioactive effluents consistent with the requirements of 10 CFR 20.1301, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50.
The licensee has confirmed that the detailed procedural requirements addressing Limiting Conditions for Operation, their applicability, remedial
- actions, associated surveillance requirements, or reporting requirements for the following specifications have been relocated to the ODCM or PCP, as appropriate.
SPECIFICATION 3/4.3.3.9 Table 3.3-12 Table 4.3-8 3/4.3.3.10 Table 3.3-13 Table 4.3-9 3/4.11.1.1 Table 4.11-1 3/4.11.1.2 3/4.11.1.3 3/4.11.2.1 Table 4.11-2 3/4.11.2.2 3/4.11.2.3 3/4.11.2.4 3/4.11.3 3/4.11.4 3/4.12.1 Table 3.12-1 Table 3.12-2 Table 4.12-1 T~IT E RADIOACTIVITYLIQUID EFFLUENT INSTRUMENTATION RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS RADIOACTIVE GASEOUS PROCESS AND EFFLUENT MONITORING INSTRUMENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUHENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS RADIOACTIVE EFFLUENTS LIQUID EFFLUENTS-CONCENTRATION RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM RADIOACTIVE EFFLUENTS DOSE RADIOACTIVE EFFLUENTS LIQUID WASTE TREATMENT RADIOACTIVE EFFLUENTS GASEOUS EFFLUENTS - DOSE RATE RADIOACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM RADIOACTIVE EFFLUENTS - DOSE, NOBLE GASES RADIOACTIVE EFFLUENTS DOSES, RADIOIODINES, RADIOACTIVE MATERIAL IN PARTICULATE FORM, AND RADIONUCLIDES OTHER THAN NOBLE GASES RADIOACTIVE EFFLUENTS - GASEOUS RADWASTE TREATMENT RADIOACTIVE EFFLUENTS - SOLID RADIOACTIVE WASTE RADIOACTIVE EFFLUENTS - TOTAL DOSE RADIOLOGICAL ENVIRONMENTAL HONITORING RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM REPORTING LEVELS FOR RADIOACTIVITYCONCENTRATIONS IN ENVIRONMENTAL SAMPLES MAXIMUM VALUES FOR THE LOWER LIMITS OF DETECTION
3/4.12.2 3/4.12.3 6.9.1.7 6.9.1.9 6.16 RADIOLOGICAL ENVIRONMENTAL HONITORING - LAND USE CENSUS RADIOLOGICAL ENVIRONMENTAL.MONITORING - INTERLABORATORY COHPARISON PROGRAM ADHINISTRATIVE CONTROLS - ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT ADMINISTRATIVE CONTROLS ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT ADMINISTRATIVECONTROLS MAJOR CHANGES TO RADIOACTIVE MASTE TREATMENT SYSTEMS (Liquid, Gaseous, and Solid)
These changes to the ODCH and PCP have been prepared in accordance with the proposed changes to TS 6.13, "Process Control Program (PCP),'nd TS 6.14, "Offsite Dose Calculation Hanual (ODCH)," and meet the specified criteria.
The
- RETS, as relocated to the ODCH and
- PCP, can be subsequently changed by the licensee in accordance with 10 CFR 50.59 without prior NRC approval.
As stated in new TS 6. 10.2.n, the licensee's records of reviews performed for changes made to the ODCM and PCP will be retained for the duration of the operating license.
The licensee has proposed replacing the existing specifications in the Administrative Controls section of the TS for the Annual Radiological Environmental Operating Report (TS 6.9.1.6 and 6.9. 1.7), for the Annual Radioactive Effluent Release Report (TS 6.9.1.8 and 6.9.1.9), for the PCP (TS
- 6. 14),
and for the ODCH (TS 6.15), with the updated specifications that were provided in GL 89-01, with some editorial changes.
Existing reporting details of TS 6.9.1.7 and TS 6.9.1.9 have been relocated to the DOCH.
The TS definitions of ODCH and PCP have been proposed for updating consistent with the guidance of GL 89-01 to reflect their change in scope.
The definition of Solidification was proposed for deletion from the TS consistent with the guidance of GL 89-01.
In addition, consistent with the guidance of GL 89-01, the licensee has proposed a consolidated specification for Explosive Gas Monitoring Instrumentation and associated tables.
The specifications addressing Liquid Holdup Tanks, Explosive Gas Mixture, and Gas Storage Tanks are also retained although renumbered.
Finally, changes to the Bases are proposed consistent with the above changes and certain editorial changes are proposed for clarity.
On the basis of the above, the staff finds that the changes included in the proposed TS amendments are consistent with the guidance provided in GL 89-01 and that the licensee has adequately relocated the RETS requirements.
Because the control of radioactive effluents continues to be limited in accordance with operating procedures that must satisfy the regulatory requirements 10 CFR 20.106, 40 CFR Part
- 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50, the staff concludes that these changes are administrative in nature and there is no adverse impact on plant safety as a consequence.
Accordingly, the staff finds the proposed changes acceptable.
0-
3.0 STATE ONSULT T ON In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 NV ONH NTA C
S RA The amendments change the requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.
The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released
- offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a
proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (59 FR 55873).
Accordingly, the amendments meet the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5 ~ 0 CONCLUSION The staff has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in ceapliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
M. Mayne Neinke Thomas G. Dunning John B. Hickman February 1P, 1995