ML20036B964
| ML20036B964 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/26/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20036B962 | List: |
| References | |
| NUDOCS 9306070289 | |
| Download: ML20036B964 (9) | |
Text
'o UNITED STATES 8
N NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20S55 7,;
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SAFETY EVALUATION BV THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 43 TO FACILITY OPERATING LICENSE NO. DPR-73 GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION. UNIT N0. 2 DOCKET NO. 50-310
1.0 INTRODUCTION
By letter dated March 17, 1992, GPU Nuclear Corporation (GPUN or the licensee) requested the approval of a change to the Three Mile Island Nuclear Station (TMI-2) Appendix A and Appendix B Technical Specifications (A-TS and B-TS respectively).
The purpose of the amendment request is to relocate the TMI-2 technical specifications related to radiological effluents to the Offsite Dose Calculation Manual (0DCM) in accordance with the guidance in NRC staff Generic Letter 89-01 dated January 31, 1989. A copy of the proposed ODCM was enclosed for NRC staff review in the March 17, 1992 submittal. On June 18, 1992, the licensee submitted Revision 1 to their amendment request.
Revision 1 provided an updated copy of the TMI Site ODCM. The updated copy of the ODCM was identified as Revision 2.
On December 23, 1992, the licensee submitted Revision 2 to their amendment request. The revision requested that the requirements for quarterly dose assessment and semi-annual radioactive effluent release reporting contained in the TMI-2 technical specifications be changed to an annual reporting requirement in accordance with the provisions of 10 CFR 50.36a(a)(2) made effective on October 1, 1992.
2.0 DISCUSSION AND EVALUATION The staff has completed its review of the TMI ODCM, Revision 2, and finds it acceptable.
This license amendment removes radiological effluent technical specifications from the license and relocates them to the ODCM.
The license amendment also changes the reporting requirements for radiological effluents.
The staff evaluation of each of the licensee's proposed changes to the TMI-2 technical specifications are as follows:
(1) Add to A-TS, Section 1.0, " DEFINITIONS the definitions for "0DCM, MEMBER (S) 0F THE PUBLIC, UNRESTRICTED AREA and SITE BOUNDARY."
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Evaluation: Addition of the definition for ODCM is consistent with the requiremen' and definitions contained in NRC staff Generic Letter 89-01.
The definit 1ans of member (s) of the public, unrestricted area and site boundary are used elsewhere in the technical specifications and the addition provides clarity to the requirements. The staff finds the change acceptable.
(2) Change A-TS, Section 3.3.3.1, " Radiation Monitoring Instrumentation," by relocating the Limiting Condition for Operation (LCO) that requires operability of the TMI-2 radiation monitors to the OCDM.
Evaluation: The surveillance requirements for TMI-2, which are normally contained in Section 4 of the A-TS at other facilities, have been removed from the A-TS by a prior change to the license and placed in a separate document called the Recovery Operations Plan. A-TS Section 3.3.3.1 requires that the radiation monitors in Table 4.3-3 of the Recovery Operations Plan be operable.
In a separate document issued concurrently with this amendment the staff has approved a change to the TMI-2 Recovery Operations Plan. This change transfers the radiation monitoring requirements in the Recovery Operations Plan Table 4.3-3 to the ODCM. This change, relocating the radiation monitoring requirements to the ODCM, is consistent with the requirements of NRC staff Generic letter 89-01.
Since the radiation monitoring requirements will no longer be in Table 4.3-3 of the Recovery Operations Plan, there is no requirement to specify operability of the monitors in the A-TS.
The staff finds the change acceptable.
(3) Change A-TS, Section 3/4.3.3.1, " Radiation Monitoring Instrumentation,"
by relocating the Basis for the LC0 on radiation monitors to the ODCM.
Evaluation:
Section 3/4.3.3.1 of the A-TS provide the bases for the specification 4.3.3.1.
The licensee proposes relocating the bases to the ODCM since the actual specification is also being relocated to the ODCM (see Item 2 above).
This change is consistent with the requirements in NRC staff Generic Letter 89-01.
The staff finds the change acceptable.
(4) Change A-TS, Section, 5.1.3, " Site Boundary for Gaseous Effluents," is revised by relocating the figure that specifies the site boundary from the A-TS to the ODCM.
Evaluation:
Section 5 of the A-TS contains figure 5.1-3 which identifies the site boundary for gaseous effluents. The licensee proposes relocating the figure to the ODCM.
Relocation of the figure that specifies the site boundary for purposes of evaluating gaseous effluent releases from TMI-2 to the document that contains the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous releases is co.nsistent with the intent of NRC staff Generic letter 89-01. The staff finds the change acceptable.
(5) Change A-TS, Section, 5.1.4, " Site Boundary for' Liquid Effluents," is revised by relocating the figure that specifies the site boundary from the A-TS to the ODCM.
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Evaluation:
Section 5 of the A-TS contains figure 5.1-4 which identifies the site boundary for liquid effluents.
The licensee proposes relocating the figure to the ODCM.
Relocation of the figure that specifies the site boundary for purposes of evaluating liquid effluent releases from TMI-2 to the document that contains the methodology and parameters used in the calculation of offsite doses resulting from radioactive liquid releases is consistent with the intent of Generic Letter 89-01. The staff finds the change acceptable.
(6) Add to A-TS, Section 6.5.3, " Audits," the requirement to audit the ODCM and the implementing procedures at least once every 24 months.
Evaluation:
Current Quality Assurance requirements for radiological programs are contained in the TMI-2 Appendix B technical specifications (B-TS)
Section 5.5.2, Quality Assurance of Program Results. The licensee has requested in this license amendment to delete Section 5.5.2 of the B-TS.
The proposed audit requirement in Section 6.5.3.1. of the A-TS incorporates the to-be-deleted B-TS 5.5.2 and is consistent with the TMI-l technical specifications. The new section in the A-TS requires the periodic audit of the new ODCM. The staff finds the change acceptable.
(7)
Change the A-TS, title of Section 6.8 " Procedures" to " Procedures and Programs."
Evaluation: The current title of Section 6.8.1 is " Procedures." The licensee proposes changing the tile of this section to " Procedures and Controls." The licensee is proposing, in Item 8 below,.a new subsection in Section 6.8.1 entitled " Radioactive Effluent Controls Program."
Inclusion of the programmatic controls for the Radioactive Effluent Controls Program (RECP) and the Radiological Environmental Monitoring Program (REMP), both which are contained in the ODCM, necessitates the change in the title of this section.
This administrative change improves the clarity of the document and the staff finds it acceptable.
(8) Add to A-TS, Section 6.8, " Procedures," a new Subsection 6.8.4 which requires the establishment, implementation and maintenance of an RECP and an REMP.
Evaluation: The licensee is proposing to add a new subsection.to Section A-TS 6.8 entitled " Radioactive Effluent Controls Program." The addition of this subsection to Section 6.8 is specified verbatim by to NRC staff Generic letter 89-01. The staff finds this change acceptable.
(9)
Add to A-TS, Section 6.9, " Reporting Requirements," new Sections 6.9.1.1,
" Annual Radiological Environmental Operating Report," and 6.9.1.2,
" Annual Radioactive Effluent Release Report." The licensee also proposes to delete the requirement to submit reports to the NRC from the B-TS.
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Evaluation: Current radiological reporting requirements for THI-2 are contained in the B-TS.
The licensee proposes adding two new' sections to the A-TS Section 6.9.1.1 " Annual Radiological Environmental Operating Report" and Section 6.9.1.2 " Annual Radioactive Effluent Release Report." NRC staff Generic letter 89-01 provides guidance in relocating the reporting requirement for both reports from the B-TS to the A-TS.
The licensee's proposal.is consistent with the guidance in Enclosure 3.to NRC staff Generic Letter 89-01.
The staff finds this change acceptable. The licensee also proposes to eliminate the Quarterly Radiological Releases'and Estimated Dose Report required by B-TS Section 5.6.1.C. and the Semi-annual Effluent Release Report, mentioned in several sections of the B-TS (i.e. Section 3.2.1 " ACTION") and required by the TMI-I technical specifications, but not specifically identified in a separate section of the THI-2 A-TS or B-TS as a routine reporting requirement.
These two submittals would, under the requirements of A-TS Section 6.9 " Reporting Requirements" be submitted annually instead of quarterly or semi-annually.
This requested. change in the frequency of submittals is consistent with recent (57 FR 169, August 31,1992) changes to 10 CFR 50.36a(2).
10 CFR 50.36a(2) specifies that the annual radioactive effluent release report must be submitted annually for the previous 12 months.
The regulations does not specify a fixed date to submit the report to the NRC.
In a memorandum from L. Cunningham (NRC), dated May 14,'1993, the NRC' staff specified " prior to May 1 of each year" as an acceptable submittal _date. The licensee approved the revised date change to A-TS Section 6.9.1.2 telephonically on May 25, 1993. The licensee's original. proposed wording for this section was "60 days after January 1 of each year." The staff finds these changes acceptable.
(10) Add to A-TS, Section 6.10, " Records Retention," the requirement to retain the records of reviews performed for changes made to the ODCM.
Evaluation: The current A-TS section 6.10.2 does not specify that records of reviews performed for changes made to the ODCM be retained. The licensee proposes adding this requirement to this section. This change is specified in to NRC staff Generic Letter 89-01. The staff finds this change acceptable.
(11) Add to A-TS, a new section, Section 6.13, "Off-site Dose Calculation Manual," which provides for administrative controls related to the newly developed ODCM.
Evaluation: The current A-TS does not specify any administrative controls for the ODCM.
The licensee proposes adding this new section which specifies controls for the ODCM.
This change is specified in Enclosure 3 to NRC staff Generic Letter 89-01.
The staff finds the change acceptable.
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. 4 (12)
Delete B-TS, Section 1.0, Definitions, the following Definitions:
" Accuracy, Aerial Remote Sensing, Batch Release, Calibration, Channel Check, Channel Functional Test, closed Cycle Cooling, Combined Available Chlorine, Composite Sample, Continuous Release, Daily Average Concentration, Daily Maximum Concentration, Free Available Chlorine, Grab Sample, Ground Truth or Ground Data Survey, Herbicides, Infrared, Photographic, Lake Federick, Manner'of Herbicide Application, Multispectrial or Multiband Photographs, Normal Operation, Precision, Protected Areas, Sampling Frequency, Scale, Spectral Band, Station or Unit, Total Residual Chlorine, and Surveillance Requirement."
Also the licensee proposes removing Table 1.1 on page 1-4, entitled " Sampling Frequency and Notation."
Evaluation: The definitions listed above either pertain to the nonradiological monitoring requirements which were deleted in Amendments 21 or 40, or radiological effluent monitoring and instrumentation, which is to be relocated from the B-TS to the ODCM by this amendment request.. With the changes proposed by this amendment request there is no need to include a table that defines sampling frequency and notation, since the B-TS no longer specifies any sampling. The staff finds these changes acceptable.
(13) Relocate B-TS, Section 2.0, " Limiting Conditions for Operation," from the B-TS to the ODCM as Part II, Sections 2.0 and 3.0.
The only changes made to this section are renumbering and typographic corrections.
Evaluation:
This change is consistent with the guidance presented in NRC staff Generic Letter 89-01. Minor changes in numbering and the correction of typographic errors are administrative in nature. The staff finds the change acceptable.
(14)
Relocate B-TS, Section 3.2, " Radiological Environmental Monitoring,"
from the B-TS to the ODCM as Part I, Section 8.0.
Since Part I of the
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ODCM applies to both TMI-l and TMI-2, there are instances where the current technical specification requirements for TMI-1 and TMI-2 were not the same.
In those cases the more restrictive requirement was incorporated in Part I of the ODCM. Additionally, there were other changes to this section consisting of renumbering sections and typographic corrections.
Evaluation: The current B-TS for THI-2 contain Section 3.2, " Radiological Environmental Monitoring" which defines the limits and conditions for the controlled release of radioactive effluents. The lice'nsee proposes removing this section from the B-TS and relocating it to the ODCM as Part I, Section 8.0.
This change is consistent with.the guidance presented in NRC staff Generic Letter 89-01. Minor changes in numbering and the correction of typographic errors are administrative in nature.
Examples of resolution of inconsistencies between the TMI-l and TMI-2 current programs include requiring an analysis for I-131 in the ODCM (not required by the current TMI-2 B-TS but required by the TMI-l technical specifications), specifying the maximum sampling period in days between semiannual samples in the ODCM (not specified i
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(15) Change B-TS, Section 5.4, " State and Federal Permits and Certifications," by deleting the reference to Sections 2 and 3 of the B-TS.
Evaluation:
Sections 2 and 3 are being deleted in their entirety from the B-TS and being relocated in the ODCM.
Section 5.4 of the B-TS states in part that "... the licensee shall comply with the requirements, with respect to Sections 2, if applicable, and 3 of these ETS, set forth in the 401 certification...".
The licensee proposes to reword the section to read "...
the licensee shall comply with the requirements set. forth in the 401 certi fi cati on... ".
Since neither section will exist in the B-TS references to these sections should also be deleted.
The staff finds the change acceptable.
(16) Change B-TS, Section 5.5, " Procedures," by deleting the section in its entirety and relocating revised text on this requirement to A-TS Section 6.8.4.
Evaluation: This section currently specifies radiological programmatic controls.
Programmatic controls of the radiological program have been moved to A-TS Section 6.8.4 (see Item 8 above).
The licensee is proposing to add a new subsection to section A-TS 6.8 entitled " Radioactive Effluent Controls Program." The addition of this subsection to Section 6.8 is specified verbatim by Enclosure 3 to NRC staff Generic Letter 89-01.
The staff finds this change acceptable.
(17) Change B-TS, Section 5.5.2, " Quality Assurance of Program Results," by deleting this section in its entirety and relocating revised text on this requirement to A-TS Section 6.8.4.
Evaluation:
Current technical specification B-TS Section 5.5.2 requires certain program controls to assure the quality of the radiological monitoring program. The licensee proposes relocating this section to the-A-TS Section 6.8.4.
The text has been altered consistent with the text taken verbatim from the NRC staff Generic Letter 89-01. The staff finds the change acceptable.
(18) Change B-TS, Section 5.5.3, " Compliance with Procedures," by deleting this entire section. The section requires that the facility is operated in compliance with the station procedures and in compliance with the B TS.
Evaluation: This requirement is redundant to Section 2.C.(2) of license DPR-73 which states that the licensee shall operate the facility in accordance with the Technical Specifications.
It is also redundant to Section 6.8.2 of the A-TS which requires that written procedures be established, implemented and maintained. Additionally, it is redundant to the new Section 6.8.4 to the
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A-TS (see Item 8 above) which provides the programmatic controls for the radiological requirements that are being transferred to the A-TS and the ODCM, consistent to NRC staff Generic Letter 89-01.
Removal of redundant requirements is considered an administrative change.
The staff finds the change acceptable.
(19) Change B-TS, Section 5.5.4, " Changes in Procedures, Station Design, or Operation," by deleting this entire section.
This section allows for changes to procedures, station design or operation as described in the B-TS Sections 2 and 5 or changes to the monitoring programs described in B-TS Section 3.
Evaluation:
Section 2, " Limiting Conditions for Operation", of the B-TS, limits the release of radiological effluents. This section is being relocated to the ODCM in its entirety by this license amendment (see item 13 above).
Section 3, Environmental Monitoring, specifies both radiological and non-radiological monitoring programs.
There are no nonradiological monitoring programs required under the current B-TS.
All nonradiological monitoring programs have been deleted by prior license amendments.
The radiological monitoring programs specified by this section have been transferred, by this license amendment to the ODCM (see Item 14 above).
Section 5, Administrative Controls, specifies programmatic controls for the B-TS.
The sections of-Section 5 that pertain to certain administrative controls of the radiological programs are being relocated to the A-TS by this amendment (see items 17 and 18 above). Therefore, the sections identified by this technical specification are no longer in the B-TS.
Additionally, technical review involving modifications or changes to procedures, or station design, which would include radiological requirements is addressed in the A-TS existing Section 6.5.1.
Deletion of Section 5.5.4 of the B-TS removes a.section that no longer pertains to requirements in the B-TS.
The referenced sections are transferred to the ODCM or the A-TS.
The existing A-TS, along with several new sections will prescribe how future changes can be made.
The staff finds the change acceptable.
(20) Change B-TS, Section 5.6.1., " Routine Reports," by relocating the i
sections which pertains to radiological reporting, to the A-TS, and/or the ODCM.
B-TS Section 5.6.1. A.(2), which pertains to radiological reporting, is being relocated to the A-TS, Section 6.9.1.1 and the ODCM, Part 111, Section 1.0.
B-TS Section 5.6.1.C. which requires a quarterly report entitled " Quarterly Radiological Releases and Estimated Dose Report," is being relocated to A-TS Section 6.9.1.2 and the ODCM Part III, Section 3.0 and changed from a quarterly reporting requirement to an annual reporting requirement.
It is also being retitled as the
" Annual Radioactive Effluent Release Report."
Evaluation: The relocation of B-TS Section 5.6.1.A.(2) to A-TS Section 6.9.1.1 and the ODCM is consistent with the guidance contained in NRC staff Generic letter 89-01.
Relocation of the requirement for a Quarterly Radiological Releases and Estimated Dose Report to the A-TS and the ODCM is consistent with the guidance in NRC staff Generic letter 89-01.
Changing the reporting requirement from a quarterly report to an annual report is
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- I consistent with the recent change (57 FR 169, August 31, 1992) to 10 CFR 50.36a which now requires an annual release and dose report.
See also the response to item 9 above. The staff finds the changes acceptable.
(21) Change B-TS, Section 5.6.2, Nonroutine Reports, by deleting the reference to Section 2 in the technical specification. The phrase "a Technical Specification Limiting Condition for Operation (Section 2), if applicable, is exceeded or if" is deleted.
Evaluation: As described in Item 13 above Section 2 of the B-TS are being relocated to the ODCM as prescribed by NRC staff Generic letter 89-01. The proposed change improves the clarity of the B-TS by removing a reference to a section that no longer exists in the revised B-TS.
The staff finds the change acceptable.
(22) Change A-TS, "INDEX," by changing pages ii, iii, vi, ix, x of the table of contents to reflect the sections either added or deleted by the above detailed changes.
Evaluation: A number of sections have been added and several deleted from the A-TS by this amendment request. The licensee has updated pages ii, iii, vi, ix and x of the A-TS table of content, called "INDEX." The staff finds this an administrative change and therefore finds it acceptable.
(23) Change B-TS, " TABLE OF CONTENTS" by changing pages i and ii of the table of contents to reflect the sections deleted.
Evaluation:
Subsections of Sections 2 and 3 of the Table of Contents have been removed to reflect the changes proposed by this amendment.
The staff finds this an administrative change and therefore finds it acceptable.
Based on the above evaluation, we find that the licensee's changes to the Appendix A and B Technical Specifications for THI-2, as described in Revision 2 dated December 23, 1992 are consistent with NRC issued Generic Letter 89-01 dated January 31, 1989. The staff finds the proposed changes accept abl e,
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of Pennsylvania cognizant individual was notified of the proposed issuance of this amendment.
The State official had no comment.
4.0 fNVIRONMENTAL CONSIDERATION This anendment involves changes in the location of specific surveillance requirements and changes in reporting requirements..The NRC staff has determined that the amendment involves 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 change in individual cumulative occupational exposure or exposure to the public. The Commission has previously issued a
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proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (58 FR 16226) dated March 25,1993).
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CQNCt.USION 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 Commission's regulations and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Michael T. Masnik Date:
May 26, 1993 4
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