ML20042E880
| ML20042E880 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/27/1990 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20042E881 | List: |
| References | |
| NLR-N90081, NUDOCS 9005030356 | |
| Download: ML20042E880 (12) | |
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4 Pubhc Service Doctric and Gas Company St:nley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4000
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April 27, 1990 NLR-N90081 f
LCR 89-15 l
United States Nuclear Regulatory Commission Document Control Desk i
Washington, DC 20555 Gentlemen:
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SUPPLEMENTAL INFORMATION CONTROL OF HIGH RADIATION AREAS REQUEST FOR LICENSE AMENDMENT FACILITY OPERATING LICENSE NOS. NPF-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 l
This letter supplements License Change Request _89-15, which was submitted to the NRC via NLR-N89202, dated January 24, 1990.
This submittal does not affect PSE&G's determination of no significant hazards consideration for LCR 89-15.
l LCR 89-15 proposed incorporating the provisions of 10CFR20. 203 (c) (4 ) into Hope Creek Technical Specification 6.12.1.
10CFR20. 203 (c) (4) allows a high radiation area, established for.a period of thirty days or less, to be controlled using direct surveillance.
Based on NRC review of.a similar change proposed for the Salem Generating Station, NRC and PSE&G personnel participated in a telephone conference. call on March 13, 1990-and determined that existing. Technical Specifications'6.12.1 and 6.12.2 do not conflict with 10CFR20.203 (c) (4).. Therefore, LCR 89-15 is being modified.to withdraw that element of.the proposed change.
L l contains.the revised affected pages, which supersede those sent in PSE&G's January 24, 1990 submittal.
PSE&G requests that the NRC Safety Evaluation Report for LCR 89-15 include a discussion of the Technical Specification interpretation described above.
Oh 9005030356 900427
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I PDR ADOCK 05000354 P
PDC i
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Document Control Desk 4-27-90 NLR-N90081 Pursuant to the requirements of 10CFR50.91(b) (1), a copy of this I
letter has been sent to the State of New Jersey as indicated below.
Upon NRC approval, please issue a License Amendment which I
will be effective immediately and chall be implemented within 60 days of issuance.
Because LCR 89-15 contains organizational changes similar to those proposed for Salem via LCR 84-01, Revision 3, PSE&G requests concurrent issuance of the respective License Amendments.
Should you have any questions or comments regarding this transmittal,-do not hesitate to contact us.
Sincerely, y' " h&~7'n Affidavit Attachment C
Mr.
C.
Y. Shiraki Licensing Project Manager l
Mr. T.
P. Johnson Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief l
New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 l
Trenton, NJ 08625
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Ref:
NLR-N90081 LCR 89-15 STATE OF NEW JERSEY
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COUNTY OF SALEM
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S. LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company,.and as such, I find,the matters set' forth on our-letter dated 4/27/90 concerning the-Hope Creek Generating Station, are true to the best,of my' t
knowledge,-information and belief.
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Subscribed and Sworn tojbefore me this J7^
da of 8/ 4' 1990 yotary Pubfic of New g g g Notory Public of New Jen My Commission expires on u
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,,NLR-W90081 ATTACHMENT
' PROPOSED CHANGE TO' THE TECHNICAL SPECIFICATIONS FACILITY OPERATING LICENSE NO. NPF-57 1
-HOPE CREEK GENERATING STATION DOCKET NO. 50-354 I.
Descrintion of Change The proposed amendment to-the_ Hope Creek Generating 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 1
concentrations of I-131 for the radiological environmental monitoring program.
The changes,.will allow higher activity i
levels provided that drinking water pathways'are not i
involved.
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2.
Change " General Manager - Nuclear Safety Review" to " General
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Manager:- Quality Assurance and Nuclear Safety" throughout Chapter 6.
3.
Revise Section 6.2.2 to delete Specification 6.2.2 (c),.
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delete footnote, and provide editorial corrections.
Revise Table 6.2.2-1~to include the minimum shift staffing'-
requirements for the radiation protection technician.
l 4.
Revise Section 6.3.1 to read "..., except for the individual designated as.the Radiation Protection Manager..."
Add j
insert 6.3.2, previously item 6.2.2.f.,
Delete-the position of Senior Operating Supervisor'from Section 6.3.2.
5.
Revise Section 6.4.1 to replace reference to;10 CFR Part 55, Appendix A and supplemental requirements, with a general l
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 I
quorum requirements, respectively.
7.
Revise Section 6.5.1.6 to simplify the SORC responsibilities with respect to internal distribution of reports and performance of reviews and investigations.
Revise Specification 6.5.1.6(a) to require SORC review of procedure changes only if a 10CFR50.59 safety evaluation is required.
Revise Specification 6.5.1.6(j) to require SORC review of changes to the Facility Security. Plan and implementing procedures only if a 10CFR50.59 safety. evaluation is required (or an evaluation under 10CFR50.54(p) for Security Page 1 of 8 t
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,NLR-$90081 Plan changes). -Revise Specification.6.5.1.6(k) and 6.5.1.6(1) to require SORC review of changes to the Emergency Plan or Fire Protection Plan and their implementing procedures only if a'10CFR50.59. safety evaluation is required (or an evaluation under 10CFR50.54(q).
for Emergency Plan Changes).
Delete the 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 a reference to 10CFR50.59.
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 -1 Hope Creek Operations.
8.
Revise Section 6.5.2 to. reflect the proposed Nuclear Safety department configuration.
The Manager - Offsite Safety Review and the Manager - Onsite Safety Review will be replaced by the Manager - Nuclear Safety, who will have management responsibility for both the.Offsite Safety Review (OSR) staff and the Onsite Safety Review Group-(SRG).
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9.
Revise Section 6.5.2.3 to clarify the use of consultants by the Nuclear Safety Department.
Provide editorial revisions to Section 6.5.2.4.
10.
Revise Section 6.5.3-to replace "NSR" with "the OSR. staff".
11.
Revise Sections 6.9.1, 6.9.2 and.6,.9.3 to refer specifically 4
to the USNRC Administrator, Region I.
Revise Section 6.9.1.4 to delete requirements for submittal-of the initial Annual Report.
12.
Revise Section 6.9.1.5 to. replace " film badge measurements"
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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' Operating Report.
14.
Revise Section 6.10.3 to reflect the succession of the Nuclear Safety Review by the Offsite Safety Review staff and to provide editorial corrections.
15.
Deleted.
16.
Revise Section 6.15.1 to change "FSAR" to "UFSAR" and to provide editorial corrections.
Page 2 of 8
qNLR-N90081 II. Reason for the ProDosed Chance j
i This LCR is being submitted to reflect the recent management L
reorganization and to propose. additional changes to
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administrative controls.
The reasons for the specific changes are as follows:
1.
The changes are consistent with NUREG 0472, " Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors," Revision 3, draft.
The current i
values of allowable activity levels for I-131 are based on 1
40CFR141 limits for drinking water pathways.
Where such I
pathways are not potentially.affected, it is proposed that' l
the limits be increased.
As discussed in the Justification l
section below, these changes do not affect compliance of-.
PSE&G's Radiological Environmental Monitoring Program with 1
2.
In the current organization, the General Manager - Quality Assurance and Nuclear Safety Review has replaced the General J
Manager - Nuclear Safety Review with regard to responsibility for the onsite and'offsite Safety Review.
J Groups.
This License Change Request proposes changing-the 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).
3.
" Radiation protection technician" is being added to Table 6.2.2-1 to be consistent with the current requirement (Specification 6.2.2(c)) to have a technician present whenever fuel is in the reactor.
Specification 6.2.2(c) is being deleted to eliminate redundancy to revised Table 6.2.2-1, 4.
The Radiation Protection Manager is required to meet or exceed the personnel qualifications criteria of Regulatory I
Guide 1.8.
Insert Item 6.3.2, previously Item 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 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 requalification is still performed in accordance with the.
NRC-approved requalification program.
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LCR 89-15 NLR-N89202 i
i 6.
The title " Assistant Genagal Manager - Hope Creek Operations" position has been deleted in tJun recent L
reorganization.
Other changes to the SORC composition are being made to assure that SORC meetings provide for l
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equitable representation of the Hope Creek Station l
departments.
By planing restrictions on the use of alternate members and quorum composition, the proposed i
change will requir0 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 to delete references to internal distribution of 6
reports, which is 44ddressed more appropriately in other sections.
For exanple, Section 6.5.1.9 addresses distributionofSORCmeetinyminutestotheGeneralManager
- QA and Nuclear Safety Rev.ew and to the Vice President and l
Chief Nuclear Officer; Section 6.5.2 addresses the Nuclear Safety Department's review responsibilities; Section 6.5.3 i
addresges rsview and control of activities.in general.-
i Therefore, references to SORC interfaces with other Nuclear Department entitles are being removed from Section 6.5.1.6.
l 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 l
process under the requiremwnts of 10CFR50.59.
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Current Specifications 6.5.1.6(j),
- 6. 5.1. 6 (k), and 6.5.1.6(1) requiro SORC review of all changes.to the i
Security Plan, Emergency Plan, and Fire Protection Program l
Plan respectively, and their implementing procedures.
The i
l phrase "and the Radwaste TreatF.ent Systems" is deleted from t
section 6.5.1.6(n) since SOA0 reviews of changes to Radwaste
,i Trsatment Systems for nuoloar safety are conducted under
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Section 6.5.1.6(d) and 6.5,1.6(e).
The proposed change is i
intended to waive SORC review if the revisions are not i
l cafety significant.
This will' eliminate unnecessary SORC l
l reviews of revisions that.are editorial or are otherwise i
insignificant with respect to safety.
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8.
Sectlan 6.5.2 currently describes the Onsite Safety Review Group (SRG) as consisting of the Onsite Safety Review i
Engineer and three dedicatad, full time engineers.
The Onsite Safety Review Engineer currently has review as well as management responsibilities within the Onsite Safety Review Group (SRG).
However, PSE&G is propcsing to replace the position of Manager - Offsite Safety Review with that of Manager - Nuclear Safety, who will have management responsibilf.ty for both the Onsite Safety Review Group (SRG)'
and the Offsite Safety Review staff (OSR).
In this proposed configuration, the SRG and OSR staff will each consist of at least four full time dedicated engineers.
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4 LCR 89-15 NLR-N89202 9.
The revision to Section 6.5.2.3 provides more flexibility to the Nuclear Safety Department with regard to the use of outside consultants / experts.
Per Section 6.5.2.2, reviewers from organizations external to the Nuclear Safety Department are required to meet the same qualification requirements as i
the OSR staff.
10.
"NSR" is being replaced by "the OSR staff" in Section 6.5.3 because the 10CFR50.59 review activities described therein are performed specifically by the Offsite Safety Review (OSR) staff, which is part of the Nuclear Safety Department.
11.
The changes are administrative in nature.
References to the initial submittal of the Annual report are being deleted since the reports have already been submitted for Hope Creek.
12.
TLDs are our primary dosimetry devices.
"Self reading.
dosimeter" is more accurate than " film badge" when describing dosimetry used at Hope Creek.
We have added Digital Alarming Dosimeters to enhance our dose tracking capability.
13.
This revision provides more specific information on radiological sampling location maps.
Dedicating one map to locations near the site boundary and another to include all locationa sssures that the maps will be scaled such that they are legible.
14.
"OSR" is the applicable group in the current organizational configuration; the Nuc2rar Safety Review no longer exists.
15.
Deleted.
16.
" Updated Final Safety Analysis Report" (UFSAR) is the document relevant to Section 6.15.1.
III. Justification for the Prorosed Chance The changes proposed in this LCR may be categorized and justified l
as follows:
a.
Changes related to PSE&G's organizational configuration, 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 management attentiveness to safety operation of the Hope l
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,,4 LCR 89-15 NLR-N89202 Creek Generating Station.
The recent reorganization of-PSE&G's Nuclear Department is intended to increase overall management effectiveness, 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.
The Manager - Nuclear Safety will assume management responsibility of the Onsite Safety Review staff, thereby allowing the Onsite Safety Review Engineer to dedicate his efforts to review activities.
The chahtes to SORC composition and voting quorum _
requirements will increase the level of assurence'that the various Station departments"are adequately represented in the SORC quorum.
By 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.
This category includes the proposed change to requite SORC review for procedure changes and changes to the Sec2rity Plan, Emergency Plan and Fire Protection Program Plan only if a 10CFR50.59 safety evaluation is involved.
This approach will consolidate the screening and review process for procedure changes by doing away with the significant safety issue determination currently in use at the Hope Creek Generating Station.
Screening for safety significance will be performed by determining 10CFR50.59 applicability (10CFR50.54(p) for Security Plan changes and 10CFR50.54(q) for Emergency Plan changes), which is cor.sistent with NRC regulations regarding procedure changes (10CFR50.59 and 10CFR50.54).
b.
PSE&G's current practice of preparing and submitting the Annual Radiological Environmental Operating Report includes the two sampling location maps explicitly described by the proposed change (item no. 13).
This LCR clarifles the current practice, which is acceptable to the NRC, in order to remove any ambiguity from the Technical Specifications.
c.
- Deleted, d.
Changes to reporting levels of radioactivity concentrations and lower limits of detection (LLD) for the radiological envbronmental monitoring program are consistent with NUREG 0472, " Standard Radiological Environmental Technical Specification for Pressurized Water Reactors", Revision 3, draft (item 1).
These changes propose allowing higher Page 6 of 8 l
S.,.6 LCR 89-15' NLR-N89202 levels of I-131 if a drinking water pathway is not potentially affected by the effluent he.fg monitored.
The provisions of 40CFR141 will still be cc.'711ed with where applicable.
10CFR20.106 requires that effluents released to unrestricted areas are maintained within the limits of
. Appendix B, Table II of 10CFR20. -Table-II specifies a limit of 300 pCi/l for soluble I-131 and 60,000 pCi/l for the insoluble form.
Using 300 pCi/l for c,omparison purposas, the proposedz reporting level and LLD for I-131 are respectively G.7% and 3.3% of the Table II limits.
Therefore, the proposed changes will not affect compliance with 10CFR20.106 and will not allow for an increase in radiation dose to any member of the public.
e.
Changes to the. description of Nuclear Safety Review-(NSR) responsibilities (item nou. 8, 9, 10).
These changes include consolidating the management of the offsite and onsite Safety Review Groups and revising the description of NSR activities to increase specificity Phd eliminate redundancy.
Changes in this category will not lessen the scope of NSR activities and will increase the effectiveness of the Onsite Safety Review Group by allowing the Onsite Safety Review Engineer to dedicate his time to review activities, since the Manager - Nuclear Safety will have management responsibility.
None of the changes in this category will reduce the effectiveness of NSR review and audit functions.
f.
Changes deleting references to outdated requirements or 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 Technical Specifications:
1.
Do not involve a significant increase in the probability or 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 Stations.
Purthermore, 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.
Consequently, the reliability of the performance of plant 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 the probability or Page 7 of 8 4
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4 LCR 89-15 NLR-N89202 consequences of an accident.
Since the current values are based on 40CFR141 requirements for drinking water supplies, this proposod change revises those levels in cases where no drinking water pathways are potentially affected.
The reporting levels and LLD for I-131 will continue to be a small fraction of the levels allowed by 10CFR20.
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.
The proposed changes do.not adversely affect the design or operation of any systems or, components important to safety.
No physical plant modifications or new operational configurations will result from these proposed changes.
Therefore, it may-be concluded that the proposed changes do not create the possibility of a new or different kind of 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, the changes proposed herein potentially affecting parameters defining margins of safety affect only their administrative aspects and do not allow for any reduction in a margin of safety.
The p:coposed change to the radiological environmental monitorirg program does not involve a significant reduction in a margin of safety.
The program will still implement Section IV.B to 10CFR50, Appendix I.
As stated above,-the changes do not affect the limits specified by 10CFR20.
The proposed change deletes radioactivity concentration values associated with 40CFR141 in cases where it is not applicable (i.e., no drinking water pathways are involved).
Therefore, it may be concluded that the proposed changes do not involve a significant reduction in a margin of safety.
b V.
Conclusions As discussed above, PSE&G has concluded that the proposed changes to the Technical Specifications.do not involve a significant 4
hazards concentration since the changes (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety.
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<o LCR 89-15 NLR-N89202 6
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