ML18096A777

Safety Evaluation Supporting Amends 133 & 112 to Licenses DPR-70 & DPR-75,respectively

ML18096A777
Person / Time
Site:	Salem
Issue date:	06/08/1992
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML18096A776	List: ML18096A775 ML18096A777
References
GL-83-43, GL-85-19, NUDOCS 9206160405
Download: ML18096A777 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.

133 AND 112 TO FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 PUBLIC SERVICE ELECTRIC & GAS COMPANY PHILADELPHIA ELECTRIC COMPANY DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 /

DOCKET NOS. 50-272 AND 50-311

1.0 INTRODUCTION

By letter dated July 7, 1989 and superseded by letters dated May 18 and 31, 1990, and revised by supplemental letters dated November 9, 1990, September 10, 1991, December 10, 1991, and April 20, 1992, the Public Service Electric & Gas Company, Philadelphia Electric Company, Delmarva Power and Light Company and Atlantic City Electric Company (the licensees) submitted a request for changes to the Salem Nuclear Generating Station, Unit Nos. 1 and 2, Technical Specifications (TS).

The requested changes would incorporate into the Technical Specifications the reporting requirements of Generic Letter 83-43, the primary coolant specific activity* reporting requirements of Generic Letter 85-19, organizational changes, and editorial corrections. The November 9, 1990, September 10, 1991, December 10, 1991, and April 20, 1992, letters provided clarifying information that did not increase the scope of the original amendment request or change the initial proposed no significant hazards consideration determination which was based on the May 31, 1990 letter.

2.0 EVALUATION For ease of understanding, the following is in the same order as contained in the licensee's request dated May 31, 1990.

The number in parentheses following each evaluation corresponds to the number of the licensee's request in the May 31, 1990 letter. Supplemental information was supplied by letters dated November 9, 1990, September 10, 1991, December 10, 1991, and April 20, 1992.

These letters are referenced in the affected sections. Unless otherwise specified, the changes described apply to both Salem Units 1 and 2.

A.

Licensee Request 1

1.

Definition 1.32, STAGGERED TEST BASIS, change "n" to "(n)" in two places. This is an administrative change and the staff finds it

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2.

Change definition 1.27 from "REPORTABLE OCCURRENCE" to "REPORTABLE EVENT" and change "Specifications 6.9.1.8 and 6.9.1.9 11 to "Section 50.73 to 10 CFR Part 50 11

• These changes are in accordance with the guidance provided in GL 83-43 and the staff finds them acceptable.

(1)

B.

Licensee Request 2 and 22

c.

1. Unit 2 only, Section 4.2.2.2c.2. replace the handwritten 110.3 11 with a typed 110.3 11

• This is an administrative change and the staff finds it acceptable.

(2)

2.

Unit 2 only, in Specification 4.2.2.2(e} change 116.9.1.10.

11 to 116.9.1.9." This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(2) (22}

3. Unit 2 only, Bases section 3/4.2.2 and 3/4.2.3, in the last.paragraph, change 116.9.1.10 11 to 116.9.1.9 11

• This change is in accordan~e ~ith the guidance provided in GL 83-43 and the staff finds it acceptable.

(2)

Licensee Request 3

1. Specification 3.3.3.9, change 11 (0DCM}

11 to 110CDM 11

• This is an administrative change and the staff finds it acceptable.

(3)

2.

In specification 3.3.3.8 and 3.3.3.9, ACTION item c., delete "and 6.9.1.9.b" and insert 11and 11 between "3.0.3 11 and 113.0.4 11

• These changes are in accordance with the guidance provided in GL 83-43 and the staff finds them acceptable.

(3)

3.

In specification 3.11.3, ACTION item b., delete "and 6.9.1.9.b". This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(3)

D.

Licensee Request 4

1. Specification 4.4.5.5.c {Unit 1) and 4.4.6.5.c {Unit 2), change to read as follows:

"Results of steam generator tube inspections which fall into Category C-3 shall be evaluated for reportability pursuant to 10 CFR 50.72 and 10 CFR 50.73.

The evaluation shall be documented, and shall provide...

11

• This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(4)

2. Table 4.4-2, under Result C-3, in the Action Required column for lST and 2ND SAMPLE INSPECTION, change the last sentence to read as follows:

"Notification to NRC pursuant to 10 CFR 50.72 and 10 CFR 50.73, as applicable." This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(4)

• 3.

Bases 3/4.4.5 (Unit 1) and 3/4.4.6 (Unit 2), change the last paragraph to read as follows:

"Whenever the results of any steam generator tube inservice inspection fall into Category C-3, these results will be evaluated for reportability to the Commission pursuant to the applicable Sections of 10 CFR 50.72 and 10 CFR 50.73." This change is in accordance.

with the guidance provided in GL 83-43 and the staff finds it acceptable.

{4)

4.

Specification 4.6.1.6.2, change "... reported to the Commission pursuant to Specification 6.9.1. This report... " to "... evaluated for reportability pursuant to 10 CFR 50.72 and 10 CFR 50.73.

The evaluation shall be documented and... ". This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

{4)

5.

Unit 2 only, Specification 4.8.1.1.4, change the first sentence to read as follows:

"All diesel generator failures, valid or non-,valid~

• shall be reported to the Commission in a Special Report pursuant to Specification 6.9.2 within 30 days." This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(4)

E.

Licensee Request 5

1. Specification 3.4.8 {Unit 1) and 3.4.9 (Unit 2), under ACTION:, MODES 1, 2 and 3*, delete paragraph a. and reletter existing paragraphs b. and

c. to a. and b., respectively. These changes are in accordance with the guidance provided in GL 85-19 and the staff finds them acceptable. Also in the Unit 2 Specification, replace the words "greater than" with the ~

symbol; the words "less than" with the s symbol; and the words "greater than or equal to" with~ symbol. These changes are administrative and the staff finds them acceptable.

{5)

2.

Specification 3.4.8 {Unit 1) and 3.4.9 (Unit 2), under ACTION:, MODES 1, 2, 3, 4 and 5, in paragraph a. delete all but the first sentence. This change is in accordance with the guidance provided in GL 85-19 and the staff finds it acceptable.

(5)

3.

Bases, Section 3/4.4.8 (Unit 1) and 3/4.4.9 (Unit 2), delete the second paragraph. This change is in accordance with the guidance provided in GL 85-19 and the staff finds it acceptable.

(5)

F.

Licensee Request 6

1.

In Specification 3.11.1.2, 3.11.1.3, and 3.11.2.2, ACTION a., delete "in lieu of a Licensee Event Report". These changes are administrative and the staff finds them acceptable.

(6)

, 2.

In Specification 3.11.2.3, ACTION a., correct the spelling of "air" in the first line and delete "in lieu of a Licensee Event Report". These changes are administrative and the staff finds them acceptable.

(6)

3.

In Specification 3.11.2.4, insert a comma after "(see Figure 5.1-3)";

in ACTION a., delete "in lieu of a Licensee Event Report"; and in ACTION a.2. delete the second "equipment".

These changes are administrative and the staff finds them acceptable.

In ACTION b., insert "3.0.3 and" after "Specification". Specification 3.11.2.4 is applicable at all times, therefore, Specification 3.0.3 is not applicable.

The staff finds this change acceptable.

(6)

4.

In Specification 3.11.4, :ACTION a., delete "in lieu of a Licensee Event Report" and correct the spelling of the word "condition". These changes are administrative and the staff finds them acceptable.. (6)

(

5.

In Specification 3.12.1, ACTION a. and b., delete "in lieu of a Licensee Event Report"; and in ACTION c. delete "In lieu of a Licensee Event Report and" and capitalize the word "Pursuant". These changes are administrative and the staff finds them acceptable.

(6)

6.

In Specification 3.12.2, ACTION a., delete "in lieu of a Licensee Event Report"; in ACTION b., delete the ")" after the word "via", delete "In lieu of a Licensee Event Report and", capitalize the word "Pursuant",

and for Unit 1, delete the parenthesis from around "October 31". These changes are administrative and the staff finds them acceptable.

(6)

7.

Specification 3.12.1, ACTION a., change "6.9.1.11" to "6.9.1.7". This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(6)

8. Specification 3.12.1, ACTION c. and Specification 3.12.2, ACTION a.

and b., change "6.9.1.11" to "6.9.1.8". These changes are in accordance with the guidance provided in GL 83-43 and the staff finds them acceptable.

(6)

9.

Specification 3.12.3, ACTION a., change "6.9.1.10" to "6.9.1.7". This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

{6)

10. Specification 4.12.2 and 4.12.3, change "6.9.1.10" to "6.9.1.7". This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

{6)

G.

Licensee Request 7 PSE&G's proposed change number 7 revises Tables 3.12-2 and 4.12-1 to change the reporting levels and lower limits of detection (LLD) of radioactive concentrations of Tritium (H-3) and 1-131 for the radiological environmental monitoring program. The TS changes will allow higher activity levels provided that drinking water pathways are not involved.

I The TS changes are in accordance with the guidance and intent of Tables 3.12-2 and 4.12-1 of NUREG-0472, "Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors", Revision 3 (draft). These guidelines permit higher LLDs when the drinking water pathway is not involved. The current LLDs for H-3 and I-131 are based on 40 CFR Part 141 limits for the drinking water pathway.

When this pathway does not exist, higher values for both the LLD and Reporting Level may be used.

The higher values requested by the licensee for the LLD (3000 pCi/l for H-3 and 15 pCi/l for I-131) and for the Reporting Level {30,000 pCi/l for H-3 and 20 pCi/l for 1-131) are the same as the guidance contained in NUREG-0472.

Also, an editorial correction to Table 4.12-1 is made to change "Cs-136" to "Cs-134".

(7)

The staff finds the above changes acceptable.

H.

Licensee Request 8 and 13 Throughout Section 6 of the Technical Specifications, change "General Manager - Nuclear Safety Review" to "General Manager - Quality Assurance and Nuclear Safety. Revise Section 6.5.2 to reflect the Nuclear Safety Department configuration.

In the current organization, the General Manager - Quality Assurance and Nuclear Safety, has replaced the General Manager - Nuclear Safety Review and will assume management oversight of the Nuclear Safety Department.

The Manager - Nuclear Safety will replace the Manager - Offsite Safety Review and the Manager - Onsite Safety Review and will have management responsibilities for both the Offsite Safety Review (OSR) staff and the Onsite Safety Review Group (SRG).

The Nuclear Safety Department now consists of the Manager - Nuclear Safety, the OSR and the SRG.

The OSR and SRG will each consist of at least four dedicated, full time engineers.

No change in the qualification requirements for members of the OSR or SRG

• is being made.

These changes consolidate the oversight of related activities and is intended to increase the overall management effective-ness. The staff finds these changes acceptable.

(8 and 13)

I.

Licensee Request 9 Revise Section 6.2.2 and Table 6.2-1 as follows:

a.

In Specification 6.2.2 b., insert "Reactor" between "licensed" and "Operator". This is an administrative change.

b.

Delete Specification 6.2.2 c., reletter the remaining Specifications, and delete reference to the health physics technician from the asterisked footnote.

Add to Table 6.2-1 the minimum staffing requirements for the Radiation Protection Technician.

Radiation protection technician is the title used by the }icensee, not health physics technician.

By including the radiation protection technician staffing requirements in Table 6.2-1, the minimum shift crew composition is contained in one table. These changes are administrative because they only change the location of the requirement in the TS and do not involve any changes in requirements.

c. Specification 6.2.2 c (revised section number), change 11 ALL 11 to 11All 11 This is an administrative change.

The staff finds the above changes acceptable. (9)

J.

Licensee Request 10

1. Specification 6.2.3.1, insert 11Senior Nuclear" between 11 the 11 and "Shift". The Shift Technical Advisor reports to the Senior Nuclear Shift Supervisor. This corrects the title and is an administrative change.

The staff finds this change acceptable. (10)

2.

Specification 6.3.1, change 11 *** except for the Radiation Protection Engineer.** " to ".*. except for the individual designated as the Radiation Protection Manager.*. ".

The person designated as the Radiation Protection Manager (RPM) is responsible to the General Manager - Salem Operations, for implementation of the Radiation Protection program. Therefore, the RPM is qualified in accordance with Regulatory Guide 1.8, September 1975. The Radiation Protection Engineer usually serves as the RPM.

The more generic 11designated Radiation Protection Manager 11 will allow another qualified person (e.g., Radiation Protection/Chemistry Manager) to serve as the RPM in the absence of the Radiation Protection Engineer. This change will allow more flexibility in staffing the position of RPM with qualified individuals.

No changes are being made in the qualification requirements for the RPM.

The staff finds the proposed change to be acceptable.

(10)

3. Specification 6.4.1, delete reference to Appendix A of 10 CFR Part 55 and the March 28, 1980 NRC letter, but maintain a reference to 10 CFR Part 55.

Appendix A to 10 CFR Part 55 has been deleted. The requirements for the operator requalification program formerly contained in 10 CFR Part 55, Appendix A are now in 10 CFR 55.59. There is no change to the requalifi-cation program. Operator requalification continues to be performed in accordance with the NRC-approved requalification program.

The staff finds the proposed change to be acceptable. (10)

4. Specification 6.4.2, change "Nuclear Training" to "Site Protection".

The responsibility for Fire Brigade training has been transferred from the Manager - Nuclear Training to the Manager - Site Protection. This consolidates the administration of tbe fire protection program under a single manager.

No changes to the training requirements of the. Fire Brigade is involved. The staff finds the proposed change to be acceptable. (10)

K.

Licensee Request 11, as modified by letter dated September 10, 1991, and December 10, 1991 Specifications 6.5.1.2, 6.5.1.3, and 6.5.1.5 are being revised to change the Station Operations Review Committee (SORC) composition and quorum requirements.

The composition of the SORC is being revised to reflect organizational changes that have been made.

The position, Assistant Manager - Salem Operations was eliminated in a reorganization. The proposed listing of membership on SORC to be included in the TS is as follows:

Chairman:

Member and Vice Ch:

Member and Vice Ch:

Member and Vice Ch:

Member:

Member:

Member:

Member:

Member:

Member:

General Manager.- Salem Operations Maintenance Manager Operations Manager Technical Manager Radiation Protection/Chemistry Manager Operating Engineer Technical Engineer Maintenance Engineer Radiation Protection Engineer or Chemistry Engineer Onsite Safety Review Engineer The proposed changes to the SORC would make the membership consistent with the current organization by deleting the position of Assistant General Manager - Salem Operations, adding the Radiation Protection/Chemistry Manager, and changing the Manager - Onsite Safety Review Group to the Onsite Safety Review Engineer.

L.

• SORC membership would be reduced by removing the Senior Nuclear Shift Supervisor and the I&C Engineer.

Removing the "or his designee" following Onsite Safety Engineer specifies that alternates from the Onsite Safety Review Group are controlled in the same manner as for other departments

{i.e., in accordance with the requirements of Specification 6.5.1.3).

In the current organization, there are two Operating Engineers, five Technical Engineers and three Maintenance Engineers, each of whom report directly to their respective department managers.

In the proposed SORC membership, one Operating Engineer, one Technical Engineer and one Maintenance Engineer would be permitted to serve as a SORC member at any given time. Similarly, the Radiation Protection Engineer or the Chemistry Engineer would be permitted to serve as a member during a specified period.

Rotation of membership within these positions would be controlled by administrative procedure and subject to approval of the General Manager -

Salem Operations.

In order to assure continuity, the designated member will serve for at least 90 days. After 90 days, the indivi9ual may be replaced as a member, subject to the approval of the Salem General Manager (or acting GM)~

Because Vice Chairmen are specified by title, the statement "Vice Chairmen shall be members of Station Management" would be replaced by the more meaningful statement "Only designated Vice Chairmen or the General Manager

- Salem Operations may act as Chairman of a SORC meeting.

11 This would allow only the General Manager (or acting GM), or one of the three designated Vice Chairmen, to chair a SORC meeting.

Consistent with the changes to SORC membership, the minimum quorum would be reduced from Chairman plus five members, including alternates, to Chairman plus four members, including alternates. This would result in a minimum quorum of five, vs. a total membership of ten members, including the General Manager - Salem Operations.

The present restrictions on alternates (Specification 6.5.1.3), combined with the proposed changes, would allow no more that two votes per department at any one meeting, and no more than two voting alternates at any one meeting.

The SORC membership along with the revised quorum.requirements of the Chairman plus four members, including alternates results in an effective quorum 50% of the total membership.

The staff finds these proposed changes acceptable.

Licensee Request 12, as modified by letter dated September 10, 1991.

1. Specification 6.5.1.6 1 which defines the Station Operations Review Committee's {SORC) responsibilities, is being revised to redefine when SORC review of procedures is required. Also, report distribution requirements are being removed from this section because they are defined in other sections of the TS.

-. 9 -

Specification 6.5.1.6.a is being revised to more accurately describe the administrative procedures requiring SORC review.

The proposed change would specify that upper tier administrative procedures and changes thereto, within the scope of Regulatory Guide 1.33 (Februa,ry 1978),

require SORC review.

Nuclear Administrative Procedures (NAPs) and Station Administrative Procedures are the procedures which presently fall under the proposed Specification 6.5.J.6.a. The term "upper tier administrative procedures" is used to clarify that subordinate procedures, such as Department Administrative Procedures, are not required to be reviewed by SORC unless a 10 CFR 50.59 evaluation is required. Reference to Regulatory Guide 1.33 is made in order to exclude the administrative procedures for activities such as business administration, administration of employee benefits, etc. Procedures and changes requiring a 10 CFR 50.59 evaluation will continue to require SORC review. This change does not change the current requirements for SORC review of procedures, the staff finds the proposed changes acceptable.

/

Currently, PSE&G uses a screening process to reduce the number of procedures and changes that require SORC review.

The criteria that is currently used is if a procedure or change involves a significant safety issue, then SORC review is required.

PSE&G has proposed to discontinue the use of the significant safety issue determination as a screening criteria in favor of consolidating the procedure revision screening and review process under the requirements of 10 CFR 50.59. For procedures and changes that do not require a 10 CFR 50.59 safety evaluation, review and approval by SORC would not be required.

However, for procedures that have a 50.59 review, and that determination concludes that a 50.59 safety evaluation is not required, a review by a Station Qualified Reviewer (SQR) is performed. As part of that review, the SQR determines if a multi-discipline review is required. This process provides a degree of independent review for those procedures and changes that do not require the preparation of a 10 CFR 50.59 safety evaluation. The staff finds the proposed change to use the 10 CFR 50.59 criteria as a screening criteria acceptable.

2. Specification 6.5.1.8 a. and b. is being revised to provide editorial clarification with regard to SORC recommendations to the General Manager -

Salem Operations and to change titles to match the current organization.

These changes are administrative and the staff finds them acceptable.

(12)

M.

Licensee Request 14

1. Specification 6.5.2.3, Consultants, is being revised to clarify that experts as well as consultants may be used by the Nuclear Safety Department.

The consultants or experts are required to meet the same qualification requirements as the OSR staff. Also, the title is changed to reflect the Nuclear Safety Department configuration. The staff finds the proposed changes acceptable. (14)

2.

Specification 6.5.2.4, Offsite Review Group, is being revised to reflect the change in title to Offsite Safety Review.

The activities listed at the end of Specification 6.5.2.4.1. (revised section number) are being deleted because they are the responsibility of the Onsite Safety Review Group.

A number of administrative changes are being made to Specifications 6.5.2.4, 6.5.2.4.1, 6.5.2.4.2 and 6.5.2.4.3 (revised section numbers) that includes renumbering of the sections and combining of sections.

Specification 6.5.2.4.2.g. (revised section number) is being revised to indicate that OSR review of anticipated deficiencies includes aspects of design or operation that may not necessarily be classified as safety related but may still affect nuclear safety. The staff finds the proposed changes acceptable.

(14)

N.

Licensee Request 15 Specification 6.5.2.4.3 i. and j. (revised section numbers) are being revised to specify that either offsite fire protection engineers of independent fire protection consultants will be utilized for the fire protection and loss prevention program implementation audits, with an outside consultant being used at least once every 36 months.

The staff finds the proposed changes acceptable.

(15)

0.

Licensee Request 16 Specification 6.5.2.7 that describes record requirements for reviews and audits performed, is being deleted. A new Specification 6.5.2.4.4 is being added that contains the record requirements for reviews and audits performed to show it is the responsibility of the OSR to maintain the records and distribute copies. Also, the time requirements for report distribution is being changed from 14 days to 30 days for audits conducted by the Quality Assurance Department and from 30 days to 60 days for audits conducted by independent consultants. The change in the time for report distribution is in agreement with the current Hope Creek Technical Specifications. The OSR serves both Salem and Hope Creek, therefore the change will make the report distribution time the same for both facilities. The staff finds the proposed changes acceptable.

(16)

P.

Licensee Request 17 Specification 6.5.3 and 6.6.1 are being revised to replace "NSR with "the OSR staff". Also, delete "Assistant", so the term becomes General Manager - Salem Operations". Additional corrections, typographical, and clarifications, are also being made. These are administrative changes associated with a reorganization and the staff finds the proposed changes acceptable.

(17)

Q.

Licensee Request lB Specification 6.9 is being revised to delete reference to "REPORTABLE OCCURRENCES".

Specifications 6.9.1, 6.9.1.6 and 6.9.2 are being revised to include the correct address for mailing reports to the conunission and to refer specifically to the USNRC Region I Office. Specification 6.9.1.4 is being revised to delete reference to the initial Annual Report, the superscript 1 is being replaced with an asterisk and the footnote is being changed accordingly. These changes are administrative and the staff finds them acceptable.

(18)

R.

Licensee Request 19

1. Add a new paragraph c. to Section 6.9.1.5, that incorporates the requirement to include, in the annual report, incidences in which the activity of the primary coolant exceeded the limits. This change is in accordance with the guidance provided in GL 85-19 and the staf¥finds it acceptable. (19)

2. Specification 6.9.1.5.a. is being revised by changing 11film badge" to "self reading dosimeter". Self reading dosimeters more accurately describes the dose measurement devices in use at Salem, in conjunction with thermoluminescent dosimeters (TLD).

The staff finds this change acceptable. The superscript 2 is being replaced with an asterisk and the footnote is being changed accordingly. This is an editorial change and the staff finds it acceptable.

(19)

S.

Licensee Request 20 Delete Specifications 6.9.1.7, 6.9.1.8, and 6.9.1.9 because they have been superseded by 10 CFR 50.73(g). Specifications 6.9.1.10 and 6.9.1.11 have been renumbered. These changes are in accordance with the guidance provided in GL 83-43 and the staff finds them acceptable.

{20)

T.

Licensee Request 21 This proposed chan9e revises the requirement of Specification 6.9.1.7 (formerly 6.9.1.10) regarding radiological sampling location maps submitted with the Annual Radiological Environmental Operation Report.

This revision is acceptable because it provides more specific information on radiological sampling location maps. Dedicating one map to locations near the site boundary and another to include all other locations assures that the maps will be scaled such that they are legible. The staff finds the change to be ~cceptable. This change also provides an administrative change by deleting a footnote that was inadvertently included in Specification 6.9.1.7. The staff finds this change acceptable. (21)

U.

Licensee Request 22 Add a new Specification 6.9.1.9 that requires the submission of the Radial Peaking Factor Limit Report to the NRC upon issuance. The report is considered issued when it is approved for use by the Salem station. "The Fxy limits are determined in conjunction with the Reload Safety

• Evaluation. Current practice is to submit the report to the NRC at least 60 days prior to the date the limit would become effective. The additional time will provide some flexibility in the fuel cycle licensing process.

Also, the report is submitted to the NRC for information, not for staff approval.

The staff finds the change acceptable.

(22)

V.

Licensee Request 23

1. Specification 6.10.1, change "REPORTABLE OCCURRErlCES" to "REPORTABLE EVENTS".

This is an administrative change and the staff finds it acceptable.

( 23)

2. Specification 6.10.J is being revised to clarify that record retention requirements for procedure changes, and reviews of tests and experiments will be in accordance with the requirements of 10 CFR 50.59. This change is administrative and the staff finds it acceptable.

(23)

I W.

Licensee Request 24 Specification 6.10.2 is being revised by:

a. referencing 10 CFR 50.59 in Specification 6.10.2.a. for record storage requirements.

b.

deleting Specification 6.10.2.j. that addresses retention of records of procedure changes, tests and experiments. These requirements are addressed in Specification 6.10.1.

c.

changing.Specification 6.10.2.k. to refer to the OSR as the replacement for the Nuclear Review Board and making some administrative changes to the section.

The above changes are administrative and the staff finds them acceptable.

(24)

X.

Licensee Request 25 The proposed changes to Specification 6.12, HIGH RADIATION AREA, include:

a.

One proposed change concerns the addition of a footnote to the TS stating that radiation intensity measurements {to determine whether an area should be designated as a High Radiation Area) shall be measured at a distance of 18 inches from the source or accessible surface. Because 18 inches is the same distance referenced in the Standard Technical Specification 6.12, the staff finds this change acceptable.

b. The change in title from "Health Physics" to "Radiation Protection" is an administrative change and the staff finds this acceptable.

• c.

The current TS states that "... each high radiation area in which the intensity of radiation is greater than 100 mrem/hr but less that 1000 mrem/hr shall be barricaded and conspicuously posted as a High Radiation Area... ".

The use of barricades for high radiation areas is in lieu of the "control device" or "alarm signal" required by paragraph 20.203(c)(2) of 10 CFR Part 20.

Paragraph 20.203(c)(4) of 10 CFR Part 20 contains provisions for use of direct surveillance (as opposed to use of barricades) to control access to high radiation areas if these areas exist for a period of 30 days or less. The provisions of paragraph 20.203(c)(4) of 10 CFR Part 20 can be applied to high radiation areas at Salem without changing the current TS and therefore it is not necessary to reference this paragraph in Section 6.12 of Salem's TS.

(25)

Y.

Licensee Request 26

1. Section 6.15.1.1., change "FSAR" to "UFSAR".

This is an ad~inistrative change and the staff finds it acceptable.

(26)

2. Section 6.15.1.1.a., insert the phrase "that the change" between "determination" and "could". Also change "10 CFR Part 50.59" to "10 CFR 50.59 11 These are administrative changes and the staff finds them acceptable.

(26)

Z.

Licensee Request 27

1.

Unit 1 only, Section 6.16.1,in the first sentence, delete "By no later than June 30, 1982" and change "all" to "All". These are administrative changes and the staff finds them acceptable.

(27)

2.

Unit 1 only, Section 6.16.2, in the first sentence, delete "By no later than December 1, 1980, 11

change "complete" to "Complete"; and change "must" to "shall".

In the second sentence, delete "Thereafter" and change "such" to Such".

These are administrative changes and the staff finds them acceptable.

(27)

AA. Licensee Request in Letters dated November 9, 1990, September 10, 1991, December 10, 1991, and April 20, 1992.

1. Table 3.3-1, TABLE NOTATION,###, change to read 11 *** NRC reporting shall be made within 30 days in accordance with Specification 6.9.2.

11 This change is in accordance with the guidance provided in GL 83-43 and the staff finds it acceptable.

(11/9/90 and 9/10/91 letters from PSE&G)

2.

Table 3.3-1, Table Notations, Action 2 c. insert the word "POWER" after "THERMAL" in the second line. This is an administrative change and the staff finds it acceptable.

(12/10/91 letter from PSE&G)

3. Section 3.3.3.8, ACTION b, and Section 3.3.3.9, ACTION b, change "operable" to "OPERABLE."

OPERABLE is a defined term in the TS.

This change will make the use of the term consistent within the ACTIO~

statement.

The staff finds this acceptable (4/20/92 letter from PSE&G).

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I BB. Other Changes

1.

The index has been updated to reflect the changes made including entries for new sections added/renamed and revised page numbers.

2.

The following pages include the latest approved revisions which differ from those submitted in the application:

a. Unit 1, Page 3/4 4-11, revised page includes changes approved by Amendment 118.

b.

Unit 2, Page 3/4 4-13, revised page includes changes approved by Amendment 98.

c. Unit 2, Page B 3/4 2-5, revised page includes changes approved by Amendment 72.

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3. Typographical and administrative errors, (e.g., word misspelled, word missing), and punctuation errors were corrected by the licensee and staff.

Also, changes were made to bring the two unit's technical specifications into agreement with each other. Before corrections were made by the staff, the licensee was consulted and they agreed to the change.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Jersey State official was notified of the proposed issuance of the amendments.

The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

The NRC 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 h~zards consideration, and there has been no public comment on such finding (55 FR 42097). Accordingly, the amendments meet the eligibility criteria 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.

The amendments also involve changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c){l0). 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.

_I _5. 0 CONCLUSION The Commissfon 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 compliance 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: J. L. Minns J. C. Stone Date: June 8, 1992

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