ML18092A429

Safety Evaluation Supporting Amends 59 & 28 to Licenses DPR-70 & DPR-75,respectively

ML18092A429
Person / Time
Site:	Salem
Issue date:	12/05/1984
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML18092A428	List: ML18092A427 ML18092A429 ML20105C035
References
NUDOCS 8412130506
Download: ML18092A429 (13)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 59 TO FACILITY OPERATING LICENSE NO. DPR-70 AND AMENDMENT NO. 28 TO FACILITY OPERATING LICENSE NO. DPR-75 PUBLIC SERVICE ELECTRIC AND GAS COMPANY Introduction PHILADELPHIA ELECTRIC COMPANY DELMARVA POWER AND LIGHT COMPANY, AND ATLANTIC CITY ELECTRIC COMPANY SALEM NUCLEAR GENERATION STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated June 17, 1983 and supplemented by letters dated September 23, 1984, March 27, 1984, August 31, 1984, and November 6, 1984, the licensee

'requested three unrelated changes to the Technical Specifications.

Change (1) modifies the Radiological Effluent Technical Specifications to assure compliance with Appendix I of 10 CFR 50 and removes the current Radiological Effluent Technical Specifications from the Appendix 11B Technical Specifications.

The Safety Evaluation for change (1) is attached separately as Enclosure I to-this.document.

Change (2) forms a new, centralized Nuclear Department and adds requirements in the Administrative Controls section o~ the Technical Specifications concerning overtime limitations and power operated relief valve and safety valve challenge reporting requirements and audits.

Change (3) adds new testing, reporting, and surveillance requirements previously reviewed and accepted 'by the NRC for the Units* Reactor Trip and Bypass Breakers.

Evaluation and Summary Change (1) See Enclosure I Change (2) formed a new, centralized Nuclear Department and also add requirements to the Technical Specifications with respect to overtime limitations and reporting requirements. Specifically, evaluations were performed on the following Technical- *Specification sections:

Section 6.2.2.f - This is a new subsection added to the Technical Specifications.

It states that the amount of overtime worked by plant staff members performing safety-related functions must be 1 imited in accordance with the NRC Policv Statement on workino hours (Generic Letter No. 82-12).

• We conclude that the addition of the statement to the.Technical Specifications provides additional control over plant staff working hours and is in conformance with Generic Letter No. 82-12 and, therefore, is acceptable.

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Corporate Headquarters and Off-site - This -proposed change has become moot since the licensee has subsequently implemented a major reorganization of the Nuclear Department, effective August 27, 1984.

Section 6.5.1.2 - The composition of the Station Operations Review Committee (SORC) has been revised to add the Safety Review Engineer, and to add the Station Planning Engineer in place of the Senior Radiation Protectio*n Supervisor. Consistent with the increased number of members on the SORC, the quorum has been increased to the Chairman and five members.

We have reviewed these proposed changes and found them acceptable as they meet the guidance of Section 13.4 of the SRP (NUREG-0800).

Section 6.5.3 - Safety Review Group (SRG) - This section has been revised to show the SRG reporting to the new position of General Manager Nuclear Support.

We have reviewed this proposed change and find that it meets the guidance in Item I.B.1.2 of NUREG-0737 and, therefore, is acceptable.

Section 6.5.2.8 - PSE&G has revised the audit frequency fer the facility Security Pl an and the Facility Emergency Pl an from 24 months to 12 months to conform with 10 CFR 73.40(d) and 10 CFR S0.54(t), respectively

• We find this change acceptable as it brings the Technical Specifications into conformance with Federal Regulations.

Section 6.9.1.6 - Monthly Operating Reports - added to the routine monthly operating reports will be a report of all challenges to power operated relief valves and safety valves.

We have reviewed this proposed change and find that it meets our current requirements and, therefore, is acceptable.

Figure 6.2 Facility Organization - The facility staff has been reorganized to relieve the Manager - Salem Generating Station of some of his responsibilities for day-to-day activities by establishing the position Assistant General Manager.

Reporting to the Assistant General Manager are the Radiation Protection Engine~r, Maintenance Manager, Operations Manager, Technical Manager and the Statfon Planning Engineer.

The titles of the Maintenance Manager, Operating Manager and Technical Manager hcive been changed from Maintenance Engineer, Chief Engineer, Station Performance Engineer, respectively. Additionally, the reactor engineering function is now the responsibility of the Technical Mci.nager.

It formerly was the responsibility of the Chief Engineer.

The position of Station Planning Engineer is a new position, and there have been other title changes.

The revised station organizatfon is shovm in Figure 6. 2-2.

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.... _>.. ----* _,:. The position of STA has been retitled Shift Supervisor Engineer. A footnote to this position states:

"STA qualified and fulfills STA requirement of Table 6.2-1. If SRO licensed will be assigned shift supervisor duties. Position may be filled by STA who would report directly to the Operating Engineer." It is our understanding based on discussions with the licensee, and should be clarified to avoid any ambiguity, that the position of Shift Supervisor Engineer is a full time position in addition to the Senior Shift Supervisor and Shift Supervisor shown in Figure 6.2-2.

We further concluded, during our review of the changes to the facility staff, that there were no deletions of any of the technical support for the nuclear station.

In addition, the station organization*meets our guidance found in Section II of NUREG-0731, and Seetion 13.1.2-3 of NUREG-0800, the Standard Review Plan. Therefore, we find the proposed changes acceptable

• Change (3) adds new testing and reporting requirements into the Technical Specifications regarding the Units* Reactor Trip Breakers and Bypass Breaker.

Specifically, TABLE 4.3-1 was modified to add surveillance testing requirements and maintenance requirements, and TABLE 3.3. was modified to add an NRC notification requirement.

These changes incorporate requirements committed to the NRC as part of the PSE&G corrective action program associated with the Reactor Trip and Bypass Breakers and which \\'/ere reviewed and accepted by the NRC in NUREG-0995.

As such we find these chqnges acceptable.

Environmental Consideration These amendments involve a change in the installation or use of the facilities components located within the restricted areas as defined in 10 CFR 20.

The staff has determined that these 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 these amendments involve no significant hazards consideration and there has been no public comment on such finding.

Accordingly, these amendments meet the eli9ibility criteria for categorical exclusion set forth in 10 CFR Sec 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 these amendments.

Conclusion We have 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, and (2) such activities will be conducted in compliance with the

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• .: Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Dated:

December 5, 1984 Principal Contributors:

W. Meinke F. Allenspach D. Fischer

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ENCLOSURE 1 SAFETY EVALUATION. FOR RnDIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS

1.0 INTRODUCTION

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To comp1y with Section V of Appendix I of 10 CFR Part 50, the Public Service Electric and Gas Company has filed with the Commission plans and proposed technical specifications developed for the purpose of keeping releases of radioactive materials to unrestricted areas during normal operations, including expected operational occurrences. as low as is reasonably achievable.

The Public Service Electric and Gas Com-pany filed this information with the Commission by letter dated June 17, 1983. W'lich requested changes to the Technical Specifications appended to Facility Operating License Nos.

DPR-70 and DPR-75 for Salem Gener-ating Station Unit Nos. 1 and 2.

The proposed technical specifications update those portions of the technical specifications addressing radio-active waste management and make them consistent with the current staff positions as expressed in NUREG-0472.

These revised technical specifi-cations would reasonably assure compliance, in radioactive waste manage-ment. with the provisions of 10 CFR Part 50.36a, as supplemented by Appendix I to 10 CFR Part 50, with 10 CFR Parts 20.lOS(c), 106{g), and 405(c): with 10 CFR Part 50, Appendix A, General Design Criteria 60, 63, and 64: and _with..10 CFR Pa rt 50, Append1 x B.

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2.0 BACKGROUND

AND DISCUSSION 2~1 Regulations 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities", Section 50.36a, "Technical Specifications on Effluents frcxn Nu~lear Power Reactors", provides that each license au~horizi~g operation of a nuclear power reactor will include technical specifications that (1) require compliance wi'th applicable provisions of Part 20.106, "Radioactivity in Effluents to Unrestricted Areas"; (2) require that operating procedures developed for the control of effluents be established and followed; (3) require that equipment installed in the radioactive waste system be maintained and used; and (4) require the periodic submission of reports to the NRC specifying the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents, any quantities of radioactive materials released that are significantly above design objectives, and such other information as may be required by the Commission to estimate maximum potential radiation dose to the public resulting from the effluent releases.

10 CFR Part 20, 11 Standards for Protect ion Against Ra di at ion, 11 paragraphs 20.lOS(c) 20.106(g), and 20.405{c), require that nuclear power plant and other licensees comply with 40 CFR Part 190, "Environmental Radiation Protection Standards for Nuclear Power Operations 11 and submit reports

.,to *the NRC when the-AO CFR Pa.rt 1-90 -1; mits have been or may be exceeded.

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.. 10 CFR Part 50, Appendix A - General Design Criteria for Nuclear Power Plants, contains Criterion 60, Control of releases for radioactive materials to the environment; Criterion 63, Monitoring fuel and waste storage; and Criterion 64, Monitoring radioactivity releases. Criterion 60 requires that the nuclear power unit design include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during nonnal reactor operatio.n, including anticipated operational occurrences.

Criterion 63 requires that appropriate systems be provided in radioactive waste systems and associated handling areas to detect conditions that may result in excessive radiation levels and to initiate appropriate safety actions. Criterion 64 requires that means be provided for monitoring effluent discharge paths and the plant environs for radioactivity that may be released from nonnal operations, including anticipated operational occurrences and postulated accidents.

10 CFR Part SO, Appendix B, establishes quality assurance requirements for nuclear power plants.

10 CFR Part SO, Appendix I,Section IV, provides guides on technical specifications for 1 imi ting condi°tions for operation for 1 i ght-wa ter-cooled nuclear power reactors licensed under 10 CFR Part 50.

. ' 2.2 Standard Radiological Effluent Technical Specifications NUREG-0472 provides radiological effluent technical specifications for pressurized water reactors which the staff finds to be an acceptable standard for licensing actions. Further clarification of these accept-(

able methods is provided in NUREG-0133, "Preparation of Radiol.ogical Effluent Technical Specifications for Nuclear Power Plants." NUREG-0133 describes methods found acceptable to the staf~ of the NRC for the cal-culation of certain key values required in the preparation of proposed radiological effluent technical specifications for light-water-cooled

• nuclear power plants.

NUREG-0133 also provides guidance to licensees in preparing requests for changes to existing radiological effluent technical specifications for operating reactors. It al so describes current staff positions on the methodology for estimating radiation exposure due to the release of radioactive materials in effluents and on the administrative control of radioactive waste treatment sytems.

The above NUREG documents address all of the radiological effluent technical specifications needed to assure compliance with the guidance and requirements provided by the regulations previously cited. However, alternative approaches to the preparation of radiological effluent technical specifications and alternative radiological effluent technical specifications may be acceptable if the staff detennines that the alternatives are in compliance with the regulations and with the intent oJ _the r~gutatocy.gutdance_.

~ The standard radiological effluent technical specifications can be grouped under the following categories:

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Instrumentation (2) Radioactive effluents (3) Radiological environmental monitoring

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Design features (5) Administrative controls.

Each of the specifications under the first three categories is comprised of two parts: the limiting condition for operation and the surveillance requirements. The limiting condition for operation provides a statement of the limiting condition, the times wh~n it is applicable, and the actions to be taken in the event that the limiting condition is not met.

In general. the specifications established to assure compliance with 10 CFR Part 20 standards provide, in the event the limiting conditions of operation are exceeded, that without delay conditions are restored to within the limiting conditions. Otherwise, the facility is required to effect approved shutdown procedures.

In general, the specifications established to assure compliance with 10 CFR Part 50 provide, in the event the limiting conditions of operation are exceeded, that within specified times corrective actions are to be taken, alternative means of operation are to be employed, and certain reports are to be submitted to the NRC describing these conditions and actions.

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. *. The specifications concerning design features and administrative controls contain no limiting conditions of operation or surveillance requirements.

Table 1 indicates the standard radiological effluent technical specifications that are needed to assure compliance with the particular provisions of the regulations described in Section 1.0.

3. 0 EVALUATION The enclosed report (TER-C5506-111/112) was prepared for us by Franklin Research Center (FRC) as part of our technical assistance contract program

• Their report provides their technical evaluation of the compliance of the Licensee 1 s submittal with NRC provided criteria. The staff has reviewed

.this TER and agrees with the evaluation.

3.1 SAFETY CONCLUSIONS The proposed radiological effluent technical specifications for Salem Generating Station Unit Nos. 1 and 2 have been reviewed, evaluated, and found to be in compliance with the requirements of the NRC regulations

• and with the intent of NUREG-0133 and NUREG-0472 (the Salem Generating Station is comprised of two pressurized water reactors} and thereby fulfill all the requirements of ~~e regulations related to radiological effluent technical specifications.

The proposed changes will not remove or relax any existing requirement related..to... the pro.b.abil i ty or consequences of accidents previously considered and do not involve a significant hazards consideration.

Table 1.

Ion Between Provisions of the Regulations and the Standard and Bbl ling Waler Reactori

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logical Effluent Technical Specif icatlons for Pressurize er Reactors

'.>tanclanl Hacl1olog1ca1 lff luent Technical Specif 1cat1ons Radioactive [fl uents j

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Design Administrative Control

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§ S0.36a Technical specifications on effluents from nuclear power reactors Remain within limits of § 20.106 Establish anJ follow procedures to control effluents Hatntaln and use radioactive waste system equipment Submit re~orts, semi-annual and other B 20.IOS(c, 20.106(9). 20.405(c) Compliance with 40 CFR 190 Part !JO Append llt A - Gener a I Des 1 gn [rt ler ia Crtterlon 60 - Contr61 of releases of radioactive 0 e materials to the environment Criterion 61 - Fuel storage and handling and radioactivity control 0

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Part 5.(J f1ppendrx C.uides to Meet '°Aslo~1 As Is I Reasonably Achievable (ALARA)"

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(lj qu~nt1tles or rad. malls. In effluents (2j r1diation & rad. ~alls. in the environment (J) chan<JP.'> in use of unrestricted areas

[xert best efforts to keep releases "ALARA" Submit report if calculated doses exceed the design objective Demonstrate conform. to des. obj, by calc. proced.

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