ML20006B527

Application for Amend to License NPF-57,consisting of Change Request 89-15,revising Radiation Protection & Radiological Environ Monitoring Tech Specs to Reflect Changes in Organization

ML20006B527
Person / Time
Site:	Hope Creek
Issue date:	01/24/1990
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20006B528	List: ML20006B527 ML20006B533
References
LCR-89-15, NLR-N89202, NUDOCS 9002050029
Download: ML20006B527 (11)

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Public Service Electric and Gas Company Stiven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 -

q vice President and Chief Nuclear Officer JAN 2 41990 1

NLR-N89202 y

LCR 89-15 United States Nuclear Regulatory Commission' Document. Control Desk t

' Washington, DC 20555 Gentlemen:

q REQUEST FOR AMENDMENT

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. HOPE CREEK GENERATING STATION 1

FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354

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Public Service Electric and Gas Company (PSE&G) hereby submits a request to amend Facility Operating License--No. NPF-57 in'--

l accordance with the requirements of 10CFR50.90.

The attached License-Change Request (LCR) 89-15 revises the Radiation Protection and. Radiological Environmental Monitoring.

technical specifications.

It also includes changes to reflect S

the current organization, and--proposes changes.to the Nuclear Safety Review department 1 and the' Station. Operations Revi'ew Committee.

Pursuant to the requirements of 10CFR50.91(b) (1), a copy of this requent for amendment has been sent to the State.of New Jersey as i

indicated below.

Sincerely,

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Attachment' i

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PDR ADOCK.05000354~

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t Document Control Desk-2

. JAN 2 4 1600-

'NLR-N89202

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C Mr.'C. Y. Shiraki j

Licensing Project Manager i

Mr. T. Johnson Senior / Resident Inspector:

.Mr.-W.

T.. Russell, Administrator l

Region I Mr. Kent Tosch, Chief New Jersey Department of. Environmental Protection Division of Environmental Quality

. Bureau of Nuclear Engineering.

CN 415 Trenton, NJ ' 08625 i

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STATE OF NEW JERSEY

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i S.'Miltenberger, being duly sworn according to law-deposes.and.

says:

I am Vice President!and Chief Nuclear, Officer.of Public. Service Electric and Gas-Company, and as such,-I find the-matters. set forth in our letter dated January 24,.'1990

, concerning the-

]j Hope Creek Generating Station,.areLtrue-to-theibest of my knowledge, information and belief.

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.i Subscribed and Sworn to before me d

this 8bd.. day of b oa; u

,.1990 l l W16'

b. hillAAb AAd Notary Public of New Jersey _

l 1/ANITA M. MARSHALL - j NOTARY PUS!.10 0F NEW JERSEY .i Ny Commisska Expiros May 6,1993 = My Commission expires on-4 i i i t -).-

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r s, c n -LCR 89-15 NLR-N89202 s l ATTACHMENT . PROPOSED CHANGE TO THE TECHNICAL SPECIFICATIONS: 7ACILITY OPERATING LICENSE NO.'NPF-57-' HOPE CREEK GENERATING STATION DOCKET-NO. 50-354 I. Descriotion of Chance ] The proposed-amendment to the Hope Creek Generating l Station Technical Specifications (TSs) extensively revises-Section 6.0, '" Administrative controls." The changes are as follows: 1. Revise Tables-3.12.1-2 and 4.12.1-1:to change the reporting' levels'and-lower limits of detection of radioactivity i concentrations of I-131 for the radiological' environmental monitoring program.- The changes, will. allow higher activity 9 levels.provided that drinking water pathwaystare' noti j involved. 2. Change " General Manager -Nuclear Safety' Review" to " General i Manager - Quality Assurance and Nuclear Safety"'throughout-Chapter 6. 3. Revise Section 6.2.2 to delete SpecifiOation 6.2.2 (c), delete footnote, and provide editorial corrections; 1 Revise Table 6.2.2-1 to include'theLuinimum shift staffing requirements for.the radiation protection technician. 4. Revise Section 6.3.1 to read "..., except for the-individual designated as the Radiation Protection Manager..." Add insert 6.3.2, previously' item 6.2.2.f. Delete the position I of Senior Operating Supervisor from Section.6.3.2. 5. Revise Section 6.4.1 to replace reference [toL10 CFR Part 55, Appendix A and supplemental requirements, with a general reference to 10 CFR Part 55. 6. Revise Sections 6.5.1.2, 6.5.1.3 and 6.5.1.5 to change the SORC composition'and rules'concerning alternate members and quorum requirements, respectively, j o 7. Revise Section 6.5.1.6 to simplify'the SORC responsibilities with respect to internal distribution of reports and-i performance of reviews and investigations.. ; Revise Specification 6.5.1.6(a) to. require SORC review 'oftprocedure changes only if a 10CFR50.59, safety: evaluation is required. Revise Specification 6.5.1.'6(j) L to require ~ SORC review of changes to the Facility Security Plan'and-implementing procedures only if a 10CFR50.39 safety' evaluation is required -(or an evaluation under 10CFR50.54(p) for Security i Page 1 of 8

l-LCR'89-15; NLR-N89202: o Plan changes). ' Revise Specification'6.5.1.6(k) and' [ ll' -6.5.1.6(1) to require SORC review of changes to the Emergency Plan or Fire Protection-Plan and.their. "( J i. implementing procedures only-if'a'10CFR50.59Esafety evaluation is required - (or an evaluation; under :10CFR50.54 (q) for Emergency Plan Changes).. Delete the; -i L phrase "and the Radwaste-Treatment Systems" from section-6.5.1.6(n). Revise Specification. 6.5.3.2 (d); to replace the reference to significant safety issues with as referenceito- '10CFR50.59. 3 j Provide editorial clarification to' Specification 6;5.1.8(a),. with regard to SORC recommendations.of approval or disapproval of items:to the General ~ Manager? ' Hope Creek ~ operations.- 8. Revise Section 6.5.2 to. reflect the proposed;N'uclear Safety ~ q department configuration. :The Manager - Offsite. Safety a Reviewfand the Manager - Onsite--Safety Review will be: replaced.by the Manager NuclearLSafety, who will'!have management responsibility:for both the Offsite Safety: Review ~ (OSR) staff and the Onsite Safety Review Group (SRG).- { 9. Revise Section 6.5.2.3 to. clarify the use-of consultantsLbyl j the Nuclear Safety Department. Provide l editorial revisions 'l to Section 6.5.2.4. 4 10. Revise Section'6.5.3 to replace "NSR"/with "the OSRl staff".- 11. Revise Sections 6.9.1, 6.9.2 and 6.9.3ito refer >specifically-to the USNRC. Administrator, Region:I. : Revise :Section =l 6.9.1.4 to delete-requirements for submittal'of therinitial. Annual Report. ~ ' q 12. Revise Section 6.9.1.5 to replace;"filmfbadge measurements" with "self-reading dosimeter, measurements."

13. - Revise the requirements of - Section 6.9.1.6 : regarding.

radiological ~ sampling' location maps ~ submitted with the Annual Radiological Environmental OperatingsReport.

14. ' Revise'Section 6.10.3 to reflect'the. succession of the Nuclear. Safety Review by the;Offsite SafetysReview staff and to provide editorial corrections.

15. Revise Section 6.12'.1 to reference 10CFR20.20'3 (c) (4), which - q -allows a high radiation area' established forLthirty days orf j 3 less to be controlled via direct surveillance.- 16.. Revise Section 6.15.1 to change "FSAR" to "UFSAR" and to provide editorial corrections. .i L Page 2'of 8 4 g

l LCR 89-15. NLR-N89202 II. Reason for the Prooosed Chance

This LCR is being submitted to reflect'the recent management reorganization and to propose additionalichanges to

. administrative controls. The reasons for tho; specific changes are as follows: 1. .The changes are consistent with.NUREG10472i " Standard. Radiological Effluent Technical Specifications;for Pressurized Water Reactors,"~ Revision 3,; draft. 'The currenti values of allowable' activity levels for I-131'are. based on-j 40CFR141 limits for drinking water pathways. ~ Where'such; 'i pathways are not potentially affected,- it is proposed that the' limits be increased. As discussed intthe Justification. section below, these changes do not affect' compliance of: ] 'PSE&G's Radiological Environmental Monitoring Program with" ' I 10CFR20. 2. In the current organization, the General. Manager - Quality < q Assurance and Nuclear Safety-Review has replaced 1the General. Manager - Nuclear Safety Reviewiwith regard'to responsibility for the Onsite and'Offsite SafetyLReview 1 Groups. This License Change Request proposes' changing.the-j title'to " General Manager - Quality Assurance and Nuclear Safety" to more accurately reflect the responsibilities of-the position (i.e., safety related review and audit functions). l 3. " Radiation protection technician"'is beingradded:toLTable' i 6.2.2-1 to be consistent with the current requirement 1 l (Specification 6.2.2(c)) to have a technician'present whenever fuel ic in the reactor. Specification 6.2.2 (c) is being deleted to eliminate redundancy lto revised Table 6.2.2-1. 4. The Radiation. Protection Manager is required.to. meet ~or exceed the personnel qualifications"criteriafof' Regulatory Guide 1.8., Insert Item 6.3.2,-previouslyJItem'6.2.2.f. This is actually a qualifications item and-belongs as'part. of the UNIT STAFF QUALIFICATIONS, Section 6.3. The. position. of Senior Operating Supervisor is deleted due to reassessment and reallocation of resources. 5. Appendix A to 10CFR Part 55 has'been deleted. The U requirements for the operator'requalification program formerly contained in 10CFR55 Appendix A are now contained in 10CFR55.59. The: proposed change references the applicable requirements (i.e., 10CFR'Part 55)-and reduces the likelihood of requiring an additional Technical Specification change by not being too specific. Operator l requalification is still performed in accordance'with'the NRC-approved requalification program. l Page 3 of 8 . i l f ._,___..-..u--_ = dec* =s

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i LCR 89-15 NLR-N89202 'i 6. The title " Assistant General Manager . Hope Creek-Operations". position has been deleted in the recent reorganization. Other changes.to.the SORC composition are being.made to assure that SORC meetings provide for equitable rapresentation_of the. Hope Creek Station departments. :Ry planing restrictions:on the:use of , alternate members and quorum composition;'the. proposed change:willTrequire.that at least three departments.are. represented in the voting quorum for any'given SORC meeting. 7. 'The SORC responsibilities of Section.6.5.1.6 are.being' revised to1 delete; references,to internal distribution of reports, which is addressed more appropriately 7in other sections.. For example, Sectionf6.5.1.9' addresses. distribution of SORC meeting'ainutes to the General Manager - QA and Nuclear Safety; Review;and'to:theLVice President and Chief. Nuclear: Officer;cSection 6.5.2 addresses the Nuclear Safety Department's review responsibilities;.-Section 6.5.3 q addresses review and control.of activities'in general. n .Therefore,; references-to SORC: interfaces-with other Nuclear: R Department entities are being removed from'Section <5.5.1.6. i specifications 6.5.1.6(a) and 6.5.3.2(d) are being revised to reflect PSE&G's intention'to discontinue use.of the significant safety issue determination in favor'of consolidating the procedure revision screening'and review process!under the' requirements of'10CFR50.59. 4 Current Specifications.6.5.1.6(j), 6.5.1.6(k), and 6.5.1.6(1) require SORC' review'of all-changes 1to the' i Security Plan, Emergency Plan,Jand Fire Protection Program Plan respectively,'and'their implementing procedures. 1 he T phrase."and the Radwaste Treatment Systems" isideleted fromi l section 6.5.'1.6(n) since SORC' reviews'of-changes t'lRadwaste-d o Treatment Systems for: nuclear. safety are-conducted under .Section 6. 5.'1'. 6 (d) and.6.5.1.6(e)'. -The; proposed. change is-1 intended to waive SORC' review if:the revisions are not safety significant..This will1 eliminate ~unnecessaryxSORC reviews of revisions that.are editorial /or'are'otherwise, insignificant'with' respect'to safety. ] 8. Section 6.5.2 currently describes the Onsite Safety Review Group (SRG)<as consisting of the1Onsite Safety Review 3 Engineer and three dedicated, full time engineers._ d The Onsite Safety Review Engineer.currentlyihas review-as-2 well as management responsibilities within'the-Onsite Safety l Review Group (SRG)'. However, PSE&G'is-proposing to< replace = j the position of. Manager l 'Offsite Safety Review 1with that of' 'y Manager - Nuclear Safety, who;wil1~have management responsibility for both the<Onsite Safety Review Group (SRG). i e and the Offsite Safety Review staff (OSR). In this proposed configuration, the SRG.and OSR' staff will each-consist of at i least four full time dedicated engineers. I s Page 4 of 8 l

l e li LCR 89-15. j NLR-N89202 L 9.. The revision to Section 6.5.2.3 provides more flexibility-to- .i the Nuclear Safety-Department _withcrogard to the usetof outside consultants / experts. Per Section 6.5.2.2, reviewers from organizations external to-the Nuclear Safety Department-L are required to-meet the'same qualification requirementscas + z L the OSR staff. "NSR"'is being replaced by "the OSR staff" inLSection 6.5.3 I

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because the 10CER50.59' review activities described'therein are performed specifically by theLOffsite. Safety Review (OSR) staff,Jwhich is:part'of.the Nuclear Safety! Department. t L 11. The changes are administrative.in nature. Referencesito the initial submittal of the Annual report are being: deleted-since the reports have already been submitted for Hope i creek. 12. TLDs are our primary dosimetry' devices. "Self reading f dosimeter"Lis more accurate than." film: badge";when' describing dosimetry.used at' Hope-Creek.. We have added Digital Alarming Dosimeters to-enhance our' dose tracking a capability. 13. - This revision provides more specific'information.on ~ t radiological: sampling location maps.. Dedicating one map to. locations near the site boundary and another tocinclude=all locations assures that the maps will1be scaled such that they are legible. r 14. "OSR" is.the applicable group-in the current' organizational configaration; the Nuclear Safety Review no longer exists. 15. When a high radiation area-is-established for a short period. ~ of time (i.e., 30 days or less), it'is~often more-practical to control the area using direct surveillance.than to erect a barricade surrounding the area. Thiszapproach'is. consistent with 10CFR20.203 (c) (4).~ 16. " Updated Final Safety Analysis Report"' (UFSAR) :is the document relevant to Section 6.15.1. III. Justification for the Pronosed Chance-The changes proposed in this IIR may. be cat'egorized and justified. as.follows: a. Changes related to PSE&G's organizati'nal configuration, o which reflect titular changes, changes in management' responsibility, changes: to the SORC 'and those: included in item nos. 2, 3, 4, 5, 6, 7, 8, 10 and.14. This category is administrative in nature and does not adversely impact ~ l management attentiveness to safety operation of the Hope l-Page 5 of 8 d

'LCR 89-15 ~ ~ NIR-N89202: Creek Generating Station'. The recent reorganization of ~ PSE&G's Nuclear Department is-intended to increase overall management effectiveness,t in some cases by consolidating-oversight of?related activities.- For example, quality assurance and nuclear: safety. review and' audit activities will both be under the direction of one general-manager.' 1The Manager - Nuclear Safety will assume-management. q responsibility'of.the Onsite-Safety Review staff, thereby-allowing the Onsite Safety Review Engineer to' dedicate-his efforts to review activities. The changes to SORC composition and voting quorum. i requirements will increase.the level of assurance thatfthe l various Station departments are adequately; represented-in the-SORC quorum.. By1 placing a two vote per' department limit on the quorum and restricting the use of alternates,.at least three departments will; comprise the quorum of each SORC meeting. 1 This-category includes the'proposedLchange to require SORC '] review for procedure changes and. changes to the Security: S Plan, Emergency Plan and Fire Protection Program' Plan:only .L F if a 10CFR50.59 safety evaluation is involved. ~This j approach-will consolidate.the screening and review process l for procedure changes by doingnaway with theJsignificant-q safety issue' determination currentlyLin userat the Hope'. Creek Generating Station. Screening for' safety' significance i l will be performed'by determining-10CFR50.59l applicability (10CFR50.54 (p) for Security' Plan. changes and!10CFR50.54 (q) for Emergency Plan changes), which-is consistent with,NRC i regulations _regarding procedure changes (10CFR50.59_and-J 10CFR50.54). b. PSE&G's current practice of preparing and= submitting the l Annual Radiological Environmental Operating! Report includes the two sampling location maps explicitly. described by.the. l l proposed change (item no. '13). This.-LCR clarifies the' l current practice, which'is acceptable to'the NRC, in order to_ remove any ambiguity from the Technical-Specifications. i I c. The change to the-method of preventing unauthorized access I l to'high radiation' areas-established for-thirty' days or less L! I is in direct compliance with 10CFR20;203 (c) (4). - The' change 1 is being requested in order to address those cases where itf-1 is more feasible to use direct surveillance, instead of a physical. barrier, to provide access control (item no. 15). 'd. Changes to reporting levels of radioactivity concentrations 1 and lower limits of detection"(LLD)1for the radiological! l environmental monitoring program are consistent'with'NUREG 0472,f" Standard Radiological Environmental Technical j Specification for Pressurized Water Reactors",, Revision 3, l draft-(item 1). These changes propose allowing higher r Page 6 of 8 i

L c LCR 89-151 NLR-N89202. levels'of'I-131 if'a' drinking' water: pathway-is not potentially affected by.the. effluent 1being monitored.. The: ( provisions of 40CFR141 will stillibe compiled with where H applicable. '10CFR20.106 requires that-effluents released to j . unrestricted. areas are maintained within the~ limits-of n . Appendix B,: Table.II of 10CFR20. Table.II specifies a111mit, of.300 pCi/1 for soluble 'I-131 and 60,000 pci/1 for the 1 . insoluble form. Using 300.pci/1 for comparison purposes,c 'the proposed reporting-level andLLLD for I-131~are respectively'6.7% and 3.34'of-the Table II;11mits.- l Therefore, the proposed' changes =willinot'affectLcompliance with 10CFR20.106 and will' not allow for an increase irr

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radiation' dose to any. member of the public. e. Changesito the description of Nuclear'SafetyjReview (NSR) i responsibilities (item nos. 8, : 9, - 10).. These changes: _ d include consolidating the management 1oflthe Offsite and' L Onsite Safety Review Groups and revising the description 1of-NSR' activities to increase specificity.and' eliminate redundancy. Changes in this category will'not les en~the' scope of-NSR activitiesLand will increase the effectiveness of the'onsite ~ Safety Review Group by allowing the-Onsite Safety Review-Engineer to dedicate lhisitime to review activities,.since l the Manager - Nuclear Safety will'have management' responsibility. None of the changes;in this'. category will reduce.the effectiveness of NSR reviewland audit functions. 1 f. Changes deleting references to outdated requirementsLor + documents are justified on the basis that'they are:largely editorial and provide clarification without: reducing'any commitments (item nos. 4,.11,.12, 16 ) '. IV. Sianificant Hazards Analysis Consideration-The proposed changes to the TechnicaliSpecifications: l l l 1. Do not involve a significant increase in thel probability or j l consequences of an accident previously evaluated. Those proposed change which are administrative in nature'do-not impact any accident analyses'used to support operation-of the Nuclear Generating l Stations. Furthermore, the proposed changes do not involve any reduction in management effectiveness, nor do they adversely' affect:the. design:or: operation of any systems or components'important to-safety. l Consequently, the reliability:of the performance of plant j safety' functions is not adversely affected.. The proposed increases to the reporting levels of radioactivity and lower limits of detection for I-131 (Section 3/4.12).do not~ increase 1the probability or Page 7 of:8

.y LCR 89-15 NLR-N89202 consequences of an accident. Since the current. values are- ] ~ based on 40CFR141 requirements for drinking water supplies,- 1 this proposed change revises thoserlevels in; cases where no drinking water pathways are-potentially.affected. The j reporting levels and LLD for I-131 will continue'to be a-q small fraction of the levels allowed by 10CFR20. i Therefore, it'may be concluded'that the proposed changes do not involve a significant increase in the probability or. consequences of an accident previously evaluated. 2. Do not create the. possibility.of'a new'or different kind of accident-from any accident previously evaluated.. i The proposed changes'do not. adversely affect the design or operation of any. systems or components.importantLtoJsafety. ] No physical plant modifications or new operational configurations will'resultifrom these proposed changes. .Therefore, it may be concluded that the proposed changes do 1 L I not create the possibility.of a new or different kind of t accident from any previously: evaluated. 3. Do not involve a significant reduction in a. margin of: safety. The revision of' radiological environmental' monitoring. parameters discussed in Section IV.1 above, the1 changes proposed herein potentially affecting parametersidefining margins of safety affect only their administrative! aspects? and do not-allow for any reduction in'a margin 1of safety.. The proposed change to the radiological environmental f monitoring program does not' involve a significant' reduction-in a margin-of safety. -The program will still1 implement 1 l l Section IV.B to.10CFR50, Appendix I.. As str.ted above, the changes do not affect.the limits specified by:10CFR20.; The proposed change deletes'radioactivityLeoncentration' values associated with 40CFR141 in casesswhere:it is'notiapplicable i (i.e., no drinking water pathways are involved)'. LTherefore, 1 it may be concluded that the proposed changes do not involve. 4 1 a significant reduction inLa margin of safety. l ' V. Conclusions As discussed above, PSE&G has concluded that the proposed changes n to the Technical Specifications do not. involve a significant-hazards concentration since the changes.(1) do not involve' a significant increase in the probability or consequences ~of an. 3 accident previously evaluated, (ii) do not create.the' possibility of a new <n different kind of accident ~from any accident previously evaluated, and1(iii)'do not' involve a significant reduction in a margin of safety. i Page 8 of 8 i 's . ~.. m . -.}}