ML20006F470

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License Change Application 5,amending License NPF-82 by Revising Tech Specs to Incorporate Guidance in Generic Ltr 89-01 Re Implementation of Programmatic Controls for Radiological Effluent Tech Specs
ML20006F470
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 02/20/1990
From: Steiger W
LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20006F468 List:
References
GL-89-01, GL-89-1, NUDOCS 9002280063
Download: ML20006F470 (9)
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LONG~ ISLAND' LIGHTING COMPANY Operating License NPF-82 Docket No. 50-322 License Change Application f 5 This License Change Application requests modification to Operating License NPF-82.for the Shoreham Nuclear Power Station l

1. 'To incorporate changes in accordance with the guidance provided by Generic Lettter 89-01.-

The request and supporting. documentation are contained in

  • Attachments 1.through.4 to this License Change Application.

Long Island Lighting Company l

By: Mg ( i William E. (Steiger, J/.[v Assistant Vice President Nuclear Operations Subscribed and sworn to before me this 20 day of mey y 1990.

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. 4 >xu M eit(E, Notarb Rublic of"New York ,

N g My Commission Expires: [27au J

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ATTACHMENT 1 r.

SNRC-1666 .<

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f - SNRC-1666 Attachment ~l e

d- Page 1 of 3 Attachment 1-To License Change Application f 5 j Operating License NPF-82' l 1.0 Description of Change This proposed amendment (1) incorporates programmatic controls in the Administrative' Controls section (Section 6) of the SNPS Technical Specifications that satisfy the-requirements of 10CFR20.106, 40CFR190, 10CFR50.36a, and i Appendix I to 10CFR50, (2) relocates the existing procedural details in the current Technical Specifications involving

  • radioactive effluent monitoring instrumentation, the control 'i of liquid and gaseous effluents, equipment requirements for liquid and gaseous effluents, radiological environmental monitoring, and radiological reporting details from the Technical: Specifications to the Offsite Dose Calculation Manual (ODCM), (3) relocates the definition of solidification and existing procedural details in the current Technical Specifications on solid radioactive wastes to the Process Control Program (PCP), (4) adds record retention requirements i for changes to the ODCM and PCP, and (5) updates the definitions of the ODCM and PCP consistent with these changes. Additionally, this proposed amendment simplifies the associated reporting requirements and administrative controls for changes to the ODCM and PCP. (Refer to Table 1 for specific changes.)

2.0 Reason for Change To incorporate changes that are consistent with the guidance provided by Generic Letter 89-01, Implementation of~

Programmatic Controls for Radiological Effluent Technical Saecifications in the Administrative Controls Section of

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tae Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or_to_the Process Control Program, January 31, 1989.

3.0 Basis for No Significant Hazards Finding In addition to the basic criteria of 10CFR50.92(c) addressed below, this amendment request falls within the guidance and requirements provided by the Commission in Generic Letter 89-01 and addresses the Staff's recognition that implementation of this change simplifies the RETS, meets the regulatory requirements for radioactive effluents and radiological environmental monitoring, and provides a line-item improvement of the Technical Specifications, consistent with the goals of the Commission's Interim Policy Statement on Technical Specification Improvements.

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- SNRC-1666 Attachment-1 Page 2 of 3

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Based on the following reasoning, LILCO has determined that-the proposed amendment does not involve a significant hazards consideration.

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1. The proposed' amendment does not involve a significant increase in the' probability or consequences of an accident previously evaluated because the change does not affect the function or operation of any system or '

. equipment. The incorporation of new programmatic controls for RETS and REMP into the Technical Specifications and the relocation of procedural details fromathe' Technical Specifications to'the'ODCM and PCP do j i

not ' a f fect . plant operation. Additionally, the amendment will not reduce the. level of radiological effluent control at SNPS, and the NRC will' continue to be informed of changes to the ODCM through submission of 3 the Semiannual Radioactive Effluent Release Report.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change is administrative ~in nature, and no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed. The change does not affect the l function or operation of any system or equipment. 1
3. The proposed amendment does not involve a significant i reduction in a margin of safety because the proposed change does not increase risk of radiological exposure to the offsite general public. The procedural details covered in SNPS current RETS, consisting of the limiting conditions for operation, their applicability, remedial actions, surveillance requirements, and the Bases section of the Technical Specifications for these requirements, have been relocated to the ODCM or PCP, as i appropriate, without change in substance and in a manner that ensures that these details continue to be incorporated in plant operating procedures.

The' Commission has provided guidance concerning the applicability of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards considerations. Example (vii) relates to a change to make a license conform to changes in regulations where the license change results in very minor changes to facility operations clearly in keeping with the regulations. In this case, the proposed change is made to make the current Technical Specifications conform to Generic Letter 89-01 rather than a regulation. The change is consistent with the goals of the Commission's Interim Policy Statement on Technical Specification

- Improvements.

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, SNRC-1666 Attachment 1 Page 3 of 3 9

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- 4.0' Timing of Change Since this' change is administrative in-nature and in '

conformance~with Generic Letter 89-01, LILCO raquests that it become effective _upon issuance.

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- 3 A*+=rtament 1 Table 1-niser=ition of Specifirwtions and Artainistrative Controls InclndM Undar the Hamairn of RETS in the 9torehami Tedinical Wfir=tions Specification Title Disposition of Existing Technical' Specification l.25 Offsite Dose Calculation Manual Definition has been updated per GL 89-01 to reflect the change,in scope of the OD04.

1.31 Process Control Program Definition has been updated per GL 89-01 to reflect the change in smpe of the PCP.

1.40 Solidification Definition has been relocated to Appendix C of the PCP. .

.,/4.3.7.10 Instrunentation (See NCrfE 1)' Additionally, title has been revised to read " Radio- '

RMinactive Liquid Effluent active Liquid and Gaseous Effluent Monitoring Instrument-Monitoring Instrumentation aticn" to assure continued traceability of Technical Specification

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(TS) 3/4.3.7.11.

3/4.3.7.11 Instrumentation (See NOIE 1)

Radioactive Gaseous Effluent TS 3/4.3.7.11 has been revised to retain existing requirenents Monitoring Instrumentation for explosive gas monitoring instrumentation and has been retitled.

" Explosive Gas Monitorina Instrumentation."

3/4.11.1.1 Radioactive Effluents (See NOPIE 1)-

Liquid Effluents: Concentration 3/4.11.1.2 Radioactive Effluents (See NCTTE 1)

Dose 3/4.11.1.3 RMirw-tive Effluents (See NOTE 1)

Liquid Radwaste Treatment Systen 3/4.11.1.4 Radioactive Effluents The existing TS requirenents have been retained.

Liquid Ibidup Tanks 3/4.11.2.1 F M W tive Effluents (See NOIE 1)

Gaseous Effluents: Dose Rate

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niann=dtion of shr ifieinna and Wnis*rative controls Tnt hvisvi rkwh- the naarHarr of 1855 in the Shorpham Dar4inimi 53bar i fir =*inna -

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Specification Title Disposition of Existing Technical Specification 3/4.11.2.2 Radioactive Effluents (See NCf1E 1) ,

Dose - Noble Gases 3/4.11.2.3 Radioactive Effluents (See 'NOIE 1)

Dose - Iodine-131, Iodine-133, Tritium, and Radionuclides in Particulate Form 3/4.11.2.4 RMimetive Effluents (See NOIE 1)

Gaseous Radwaste Treatment System .

3/4.11.2.5 RMimctive Effluents (See ND1E 1)

Ventilation Exhaust Treatment -

System 3/4.11.2.6 Radioactive Effluents Existing TS requirements have been retained. '

Explosive Gas Mixture s (Gas Storage Tanks) N.A. to Shoreham.

I 3/4.11.2.7 RMimetive Effluents Existing TS requirements have been retained.

Main Condenser 3/4.11.2.8 RMimetive Effluents (See NOTE 1)

Contaiment Purging and Venting 3/4.11.3 RMimetive Effluents Existing TS procedural details have been relocated to Solid Radioactive Wastes Appendix D of the PCP.

3/4.11.4 Radioactive Effluents (See NCTIE 1)

Total Dose l

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niannaition of WfiM- and Administrative Controls Irw hwbri Under the naariinrr of luns in the Shoreham medmical sg=r-ifih Specification Title Disposition of Existina Technical Specification 3/4.12.1 Radiological Environmental '(See NME 1) .

Monitoring.

Monitoring Program 3/4.12.2 Radiological Environmental (See NCTIE 1)

Monitoring Land Use Census 3/4.12.3 Radiological' Environmental (See N M E 1)

Monitoring Interlaboratory Ccmparison '

Program 5.1.3 Design Features ..

Existing TS requirements have been retained.

Site Bcundary for Rulimctive (NOTE: an extended TS figure 5.1.3-1 has been provided on Gaseous and Liquid Effluents pages I.5-3 and I.5-4 of the Draft ODCM).

6.9.1.6 Administrative Controls TS has been cinplified in accordance with GL 89-01 and Anntal Radiological Environ-' existing rem edng det-M1n have been relocated to the ODO4, mental Operating Report Part I, Section 6.

6.9.1.7 Administrative Controls TS has been sinplified in accordance with GL 89-01 and existing Semiannual Radioactive reporting details have been relocated to the CDCM, Part I,- ,

Effluent Release Report Section 6 and the PCP, Section 9.4, as wwp1.iate.

6.13 Administrative Controls TS has been sinplified in accordance with GL 69-01.

Process Control Program (PCP) 6.14 Adninistrative Controls TS has been simplified in accordance with GL 89-01.

Offsite Dose Calculation Manual (ODCM)

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Table 1 JOont# d.)

Diannaition of heifimtions and Administrative Controls Inclnriarl Uhder the naartinrr of agrS in the Shoreham 9 tar 4=ir=1 m==-ifis=e-4<==

Specification Title- Disposition of Existing Technical Specification ' ~

6.15 paminintrative Controls Existing pro dural details have been relocated to the ODCM, Part -

Major Changes to Radioactive I, Section 6 and PCP, Section 9.3, as awtw1.iate. -

Liquid, Gaseous, and Solid Waste Treatment Systems m

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s IUrE 1: Fwpaunctic controls per GL 89-01 have been included ., ,

in TS Section 6.8.4. Existirig Technical Speification ,

procedural details have been relocated.to the'ODCN, -

Part I, Section 3.

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