ML19269C780
| ML19269C780 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/02/1979 |
| From: | Counsil W NORTHEAST UTILITIES |
| To: | Reid R, Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| TAC-10857, TAC-11936, NUDOCS 7902120189 | |
| Download: ML19269C780 (6) | |
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February 2, 1979 Docket N'. 50-245 50-336 Director of Nuclear Reactor Regulation Attn: Mr. D. L. Ziemann, Chief Operating Reactors Branch #2 Mr. R. Reid, Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Gentlemen:
Millstone Nuclear Power Station, Unit Nos.1 and 2 Proposed Revisions to Environmental Technical Specifications On February 3, 1978 and October 20, 1978, pursuant to Section 5.6.3 of the Mill-stone Unit No.1 (License No. DPR-21) and Unit No. 2 (License No. DPR-65) Environ-nemtal Technical Specifications (ETS), Northeast Nuclear Energy Company (NNECO) proposed to incorporate various proposed revisions into the ETS.
On December 5,1978, you advised as that you plan to defer action on these requests so that they can be reviewed concurrent with radiological effluent specifications developed during Appendix I implementation for Millstone Nuclear Power Station.
We concur with that position with respect to our request of October 20, 1978; however, we request that certain portions of the February 3,1978 submittal be separately reviewed as they will not be affected by the radiological effluents chang es.
Also, on January 12, 1979, you approved changes to ETS Section 5.1 with respect to corporate reorganization and title changes. These approved changes have elim-inated the necessity for several of the revisions proposed on February 3, 1978.
Therefore, those changes are withdrawn as indicated in Enclosure 1.
All of the other changes proposed in our February 3,1978 submittal are listed in Enclosures 2 and 3. to this letter identifies those proposed changes for which your review may proceed because they will not be affected by the radio-logical effluents changes. We agree that proposed revisions to Sections 3.2 and 5.6, indicated on Enclosure 3, may be reviewed concurrent with radiological efflu-ents specifications review.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY y ' WN j 4
] $0A l2, 6 (f ]
J W. G. Counsil Enclosures Vice President wh f
. - Changes Superseded and Withdrawn (February 3,1978 Submittal)
Page Section Change 5.1-2 5.1.5.1, The title of "Vice President of Systems Operations," is 5.1-2 5.1.5.4, changed to "Vice President of Systems Production," to 5.1-2 5.1.5.5.1, be consistent with Company orgaaization.
5.1-2 5.1.5.5.2, 5.1-2 5.1.5.5.3 5.1-2 5.1.5.4, The title of "NUSCO, Manager of Generation Technical 5.1-2 5.1.5.5.1, Services," is changed to "NUSCO Director of Nuclear and 5.1-2 5.1.5.5.2, Environmental Engineering," to be consistent with Company 5.1-2 5.1.5.5.3 organization.
5.1-5 Figure 5.1-1 The organization chart is updated.
. - Changes not Affected by Appendix I implementation Review (February 3,1978 submittal)
Paydt Section Change 1.1-1 1.1 The definition of "Unreviewed Environmental Impact" is added and is required for Environmental Technical Speci-fication, Section 5.
5.1-1 5.1.2 "The plant Superintendent.
." is changed to "Each Unit Superintendent
.." to be consistent with Stiety Technical Specifications.
5.1-1 5.1.2 to an Assistant Plant Superintendent or.
is deleted to reflect current plant organization.
5.1-3 5.1.6,
. Plant Superintendent," is changed to ".
. Unit 5.1-3 5.1.6.1, Superintendent," to be consistent with Safety Technical 5.1-3 5.1.6.1.3 Specifications.
5.1-3 5.1.6.1
" Station Procedures.
." is changed to " Unit Procedures
." to be consistent with Safety Technical Specifica-tions.
5.1-3 5.1.6.1 except common site and Services Groups proce-dures.
." is added to clarify procedure review, in order to indicate the review required for procedures common to both Units.
5.1-3 5.1.6.1.3
. 7 days.
." is changed to ".
. 14 days.
to be consistent with Safety Technical Specifications.
5.1-3 5.1.6.2
. Unit except Services Groups.
." is added for 5.1-3 5.1.6.2 the same reason as the Section 5.1.6.1 change, above.
5.1-3 5.1.6.3 Original specification is deleted because sections 1 and 2 are now reviewed by SORC and section 5.1.6.4 through 5.1.6.7 are reuumbered.
5.1-3 5.1.6.4
. not common to both Units..." is added for clari-fication between PORC and SORC duties.
5.1-3 5.1.6.4
" Plant Superintendent" is added to improve the distribu-tion of reports.
5.1-3 5.1.6.5
. Unit.
." is added for clarity.
5.1-4 5.1.7
. or applicable to the Services Groups,
." is added for clarification of SCRC review duties.
5.1-4 5.1.7.1 Original specification is deleted and incorporated into the new section 5.1.7.1 which reads, " Perform all functions listed in Sections 5.1.6.1 through 5.1.6.5 which are common to both Units or applicable to the Services Groups."
Page Section Change 5.1-4 5.1.7.2 Specification 5.1.7.2 is renumbered. Previously was numbered 5.1.7.3.
5.1-4 5.1.7.3
" Review all proposed changes to the Environmental Technical Specifications" is added for clarification between PORC and SORC duties.
5.3-1 5.3 The entire Review and Audit section is revised to clarify Environmental Review Board duties including the elimina-tion of inconsistencies in the area of procedure review.
5.5-1 5.5.3 Entire section is revised for the same reason as above.
5.5-1 5.5.4 Section 5.5.4 is added for the same reason as above.
The ERB, being similar to the NRB, should not be responsi-ble for the routine review of new and revised procedures.
Rather, the ERB function is to provide a semi-annual audit of procedures.
5.7-1 5.7.1.b
"... processed..." is added for clarity.
O
. - Proposed Changes Held for Radiological Effluents Specification (February 3, 1978 Submittal)
Page Section Change 3.2-1 3.2.3.1
"... thyroid..." is added for clarity.
3.2-1 3.2.3.1 The reference to Regulatory Guide 1.42 is deleted since it became obsolete with the development of new Guides (1.109 and 1.111). No reference to the never Guides is made in order to eliminate the need for similar changes in the future.
3.2-2 3.2.3.2
"... dispersion..." is changed to ".
. deposition
..." since, with new models, the milk pathway doses are calculated at the location of maximum deposition rather than 'X/Q.
3.2-2 3.2.6 Report frequency was changed from " semi-annual" to
" annual".
3.2-2 3.2.8 The following words are added, "... and can be attri-buted to an increase in plant related radioactivity,
..." This will eliminate the requirement to submit anomalous measurement reports for situations similar to the Chinese fallout situation of October,1976.
3.2-3 3.2.9(a)
"... plant related..." is added for the same reason as above.
3.2-3
- 3. 2.9 (a)
"... of I-131..." is added for clarity.
3.2-3 3.2.9 (a)
"... from the end of the quarter..." is added for clarity.
3.2-3
- 3. 2.9 (b)
"... plant related..." is added for the same rea-son as the Section 3.2.8 change, above.
3.2-3 3.2.9 (b)
"... one week..." is changed to "..
10 days from confirmation of results..." for clarity.
3.2-5 Figure 3.2-2 Changed location #24 to reflect the change in goat farm location used.
3.2-7 Table 3.2-1 Changed goat farm distance and direction for same reason as above.
3.2-7 Table 3.2-1 Footnote added, "j. Due to sample collection arrange-ment, air particulate filters may be changed less frequently than once per week." Sample collection is done by outside individual on Fisher's Island. This change prevents a Technical Specification violation if the filter is not changed at precise weekly intervals.
5.6-1 5.6.1.a
-Eliminate "... preoperational studies, operation con-trols (as appropriate), and..." The preoperational studies are now seven years old. Comparisons are tot always appropriate or'possible due to changes in the program. The proposed wording, "... comparison with previous environmental surveillance reports..." per-mits relevant comparisons.
5.6-1 5.6.1.a The reference to Table 5.6-1 is eliminated and replaced with a new paragraph. Table 5.6-1 is based on the re-porting of data in a "less than" (< ) technique. The data is now reported as statistically nalid and thus the format is different. It is better to simply list the required data as done in the new psragraph to allow for flexibility.
5.6-2 5.6.1.b 60 days.
." is changed to "..
90 days.
Due to the time required to obtain Sr results and the extensive dose modeling required by Regulatory Guide 1.109, this change is necessary based on the desirability of a complete and accurate report.
5.6-3 5.6.2.b(1)
. during any annual report period,..." is eliminated for clarity.
/
/
5.6-3
- 5. 6. 2.b (1)
The following is added. ".
. and can be attributed to an increase in plant related activity.
." This will eliminate the requirement to submit anomalous measurement reports for situations similar to the Chinese fallout situation of October,1976.
5.6-3
- 5. 6. 2.b (2)
"... plant related..." is added for the same reason as above.
5.6-3
- 5. 6. 2.b (2)
. of I-131..." is added for clarity.
5.6-3
- 5. 6. 2.b (3)
. plant related..." is added for the same reason as the Section 5.6.2.b(1) change, above.
5.6-3
- 5. 6. 2.b (3)
. one week..." is changed to "..
10 days from confirmation of results.
.." for clarity.
5.6-4 5.6.3.a
"... would have a significant effect on the environ-ment or involve an environmental matter or question not previously reviewed and evaluated by the NRC," is replaced with, "... constitutes an Unreviewed En-vironmental Impact." This change clarifies reporting requirements since an Unreviewed Environmental Impact is defined in 1.1.
5.6-5 Table 5.6-1 Table 5.6-1 is eliminated for the reason discussed in the Section 5.6.1.a change, above.