ML20044D077

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Suppl to 920921 Application for Amends to Licenses DPR-57 & NPF-5,changing TS Administrative Controls Section Re Semiannual Radioactive Effluent Release Rept to Reflect New 10CFR50.36a,per GL 89-01
ML20044D077
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 05/03/1993
From: Beckham J
GEORGIA POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20044D078 List:
References
GL-89-01, GL-89-1, HL-3179, NUDOCS 9305170198
Download: ML20044D077 (11)


Text

ie %< Georg;a Power Company i

40 hvemess Center Patway Post Office Scx 1295 Birmingham. Alabama 35201 Telephone 205 877-7279

& I J. T. Beckham, Jr.

Vg,e Presdent . Nuclear Ge c.

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Hatch Pro,ect N N " C'K "C W ta May 3, 1993 ,

l Docket Nos. 50-321 HL-3179 I 50-366 U. S. Nuclear Regulatory Commission ,

ATTN: Document Control Desk 1 Washington, D. C. 20555 l l

Edwin I. Hatch Nuclear Plant l Request to Revise Technical Specifications  :

Semiannual Radioactive Emuent Release Renori j l

Gentlemen: l By letter dated September 21,1992, Georgia Power Company (GPC) submitted a response to Generic Letter 89-01 regarding Radiological Emuent Technical Specification l (RETS) changes. Included with the response were proposed changes to the Plant Hatch j Unit I and Unit 2 Technical Spacifications Administrative Controls section associated with I the Semiannual Radioactive Emuent Release Report. The proposed Technical i Specification changes were made consistent with the recommendations contained m Generic Letter 89-01. Since that time, the Nuclear Regulatory Commission (NRC) amended their regulations as noticed in 57 FR 39353 dated August 31,1992. Specifically, 10 CFR 50.36a, regarding Technical Specifications on efIluents from nuclear power j reactors, was one of the regulations revised whereby the frequency of reporting the l quantity of each of the principal radionuclides released to unres;ricted areas in liquid and  ;

gaseous emuents was changed from semiannual to annual. Such reponir.g at Plant Hatch l is currently made on a semiannual basis in the Semiannual Radioactive Emuent Release Repon.

In accordance with the new 10 CFR 50.36a, GPC has prepared proposed changes to the l Plant Hatch Unit I and Unit 2 Technical Specifications to incorporate the requirements for i an Annual Radioactive Efiluent Release Report in lieu of the current semiannual report. In i addition, several editorial corrections are being made to the Radioactive Efiluents sections i of the Unit i and Unit 2 Technical Specifications. Enclosure 1 provides a detailed description of the proposed changes and the reasons for the change request. Enclosure 2 details the bases for the determination that the proposed changes do not involve a significant hazards consideration. Enclosure 3 provides revised proposed changed Unit I and Unit 2 Technical Specification pages. A hand-markup of the proposed changed pages' i is included in Enclosure 4. As appropriate, the revised proposed changed pages which I were included in GPC's response to Generic Letter 89-01 were used for the hand- 1 markups.  !

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I U. S. Nuclear Regulatory Commission Page 2 i May 3, 1993 f

GPC requests these proposed changes be approved coincident with the Generic Letter 89-01 proposed Technical Specification changes. Following approval of this license r amendment request, the Annual Radioactive Efiluent Release Report will be submitted prior to May I of each year. ,

In accordance with the requirements of 10 CFR 50.91, a copy of this letter and all  !

applicable enclosures will be sent to the designated State ofIicial of the Emironmental  !

Protection Dhision of the Georgia Department ofNatural Resources. l I

Mr. J. T. Beckham, Jr. states he is duly authorized to execute this oath on behalf of GPC, [

and to the best of his knowledge and belief, the facts set forth in this letter are true.

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Sincerely.

/

h e J. T. Beckham, Jr.

l Sworn to and subscribed before me [

this 3 day of hl#4f/ ,1993.

U .[

O T K 27/a 4 J Nc/ary Public l

My Commission Expires: #NM34/U6 f

JTB/TMM 'j

Enclosures:

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1. Basis for Change Request  !

2.10 CFR 50.92 Evaluation }

3. Page Change Instructions and Revised Pages l
4. Hand-Marked Pages i i,

(Distribution - see next page)

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U. S. Nuclear Regulatory Commission Page 3 May 3, 1993 cc: Georgia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U. S. Nuclear Regulatory Commission. Washincton. D. C.  ;

Mr. K. Jabbour, Licensing Project Manager - Hatch U. S. Nuclear Reculatorv Commission. Region Il Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch State of Georgia Mr. J. D. Tanner, Commissioner - Department of Natural Resources i

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Enclosure 1 Edwin 1. Hatch Nuclear Plam Request to Revise Technical Specifications Semiannual Radioactive Efiluent Release Repon Basis for Change Reauest Proposed Change 1 Revise proposed Hatch Unit 1 Technical Specification 1.0.XX and Unit 2 Technical Specification 1.0, regarding the defmition of Offsite Dose Calculation hianual (ODCM),

submitted by Georgia Power Company (GPC) letter dated September 21,1992, in response to Generic Letter 89-01, to change the frequency of submittal of the Semiannual Radioactive Efiluent Release Report to an annual basis.

Basis for Proposed Change 1 Proposed Hatch Unit 1 Technical Specification 1.0.XX and Unit 2 Technical Specification 1.0, submitted by GPC letter dated September 21,1992, revised the definition of the ODCM in accordance with the requirements of Generic Letter 89-01.

Contained in the definition was a reference to the Semiannual Radioactive Efiluent Release Repon. It is proposed that the definition be revised to change the reference to an .

Annual Radioactive Efiluent Release Report to implement the new 10 CFR 50.36a reporting requirements.

This proposed change is administrative in nature to reduce an unnecessary burden of governmental regulation. This change willin no way reduce the protection for the public health and safety.

Proposed Change 2 Revise proposed Hatch Unit 1 and Unit 2 Technical Specification 6.9.1.8, submitted by GPC letter dated September 21,1992 in response to Generic Letter 89-01, and its index reference (Unit 2 only) to change the frequency of submittal of the Semiannual Radioactive Efiluent Release Repon to an annual basis. Also proposed is a change to the submittal date of the report from within 60 days after January l 'and July 1 of each year, to prior to May 1 of each year.

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i Enclosure 1 Basis for Change R.equest Basis for Proposed Change 2  !

Proposed Hatch Unit I and Unit 2 Technical Specification 6.9.1.8, submitted by GPC letter dated September 21,1992, contained the Generic Letter 89-01 requirement for  ;

submitting a Semiannual Radioactive Emuent Release Report within 60 days after January I and July 1 of each year. In accordance with the requirements of the new 10 CFR  ;

50.36a, GPC proposes to change the frequency of submittal of the report to an annual i basis thereby becoming the Annual Radioactive Emuent Release Repon. The  ;

corresponding Unit 2 index reference to the Semiannual Radioactive Emuent Release  ;

Repon has also been resised. 'l I

Although a schedule for submittal of an annual report is not stipulated in the new  !

10 CFR 50.36a, it is proposed the schedule be revised to require the report to be submitted prior to May I of each year. This change will be consistent with the prior to May I reporting requirement for the Annual Radiological Environmental Surveillance ,

Report currently contained in Hatch Unit I and Unit 2 Technical Specification 6.9.1.6 and proposed in GPC's response to Generic Letter 89-01 dated September 21,1992. j l

Proposed Hatch Unit I and Unit 2 Technical Specification 6.9.1.8 also require the quantity i' of radioactive solid wastes released to be reponed in the Semiannual Radioactive Emuent Release Report. However, the reporting requirement associated with solid wastes is not i addressed in either the old or new 10 CFR 50.36a. Therefore, to be consistent with the proposed reponing requirements for liquid and gaseous emuents, it is proposed that the  ;

quantity of solid waste rcleases also be reponed on an annual basis. .

i These proposed changes are administrative in nature to reduce an unnecessary burden of governmental regulation. This change willin no way reduce the protection for the public health and' safety.

i Proposed Change 3 t

Revise proposed Hatch Unit I and Unit 2 Technical Specification 6.17.1.c, submitted by  :

GPC letter dated September 21,1992 in response to Generic Letter 89-01, to change the frequency of submittal of the Semiannual Radioactive Emuent Release Repon to an  !

annual basis.  !

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-i Enclosure 1 l Basis for Change Request

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l Basis for Proposed Chance 3 l

Proposed Hatch Unit 1 and Unit 2 Technical Specification 6.17.1.c, submitted by GPC  !

letter dated September 21,1992, revised the Administrative Controls section requirements l for the ODCM in accordance with the requirements of Generic Letter 89-01. Contained [

in the proposed Technical Specification was a reference to the Semianneal Radioactive i EfIluent Release Report. Therefore, it is proposed that the Administrative Controls  !

section requirements be revised to change the reference to the Annual Rad.oactive i Efiluent Release Repon to implement the new 10 CFR 50.36a reporting requirements. t This proposed change is administrative in nature to reduce an unnecessary burden of  !

governmental regulation. This change will in no way reduce the protection for the public i health and safety.

Proposed Chance 4 I

Make the following editorial corrections to the listed specifications.  ;

t Unit 1, Specification 3.15.1.4, Liquid Holdup Tanks: Add a reference to footnote "a" f Also, delete Action "b" which references Specification 6.9.1.13(b). l I

Unit 1, Specification 3.15.2.6, Explosive Gas Mixture: Delete Action "b" which .

references Specification 6.9.1.13(b). Also, change the designation of Action "c" to "b" to  !

account for the deletion of the current Action "b" i

Unit 2, Specification 3.11.1.4, Liquid Holdup Tanks: - Change the footnote reference from i "d" to "a". Also, delete Action "b" which references Specification 6.9.1113(b).

Unit 2, Specification 3.11.2.6, Explosive Gas Mixture: Revise Action "b" to delete the reference to Specification 6.9.1.13(b).- t f

Basis for Proposed Chance 4  !

Unit 1, Specification 3.15.1.4, Liquid Holdup Tanks: Parentheses for the footnote  !

reference are already in place next to the specification numb'er, however the space withm  ;

the parentheses is blank.- The footnote reference was omitted due to a typographical error. )

Specification 6.9.1.13(b) no longer exists. This reference should have been deleted  !

concurrently with the deletion of Specification 6.9.1.13(b).  ;

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i Enclosure 1 l Basis for Change Request  !

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Unit 1, Specification 3.15.2.6, Explosive Gas Mixture: Specification 6.9.1.13(b) no ,

longer exists. This reference should have been deleted concurrently with the deletion of j Specification 6.9.1.13(b).  !

l Unit 2, Specification 3.11.1.4, Liquid Holdup Tanks: The reference to "d" is a typographical error as evidenced by the fact that the only footnote on the page is footnote ,

"a" Specification 6.9.1.13(b) no longer exists. This reference should have been deleted [

concurrently with the deletion of Specification 6.9.1.13(b). .;

l Unit 2, Specification 3.11.2.6, Explosive Gas Mixture: Specification 6.9.1.13(b) no longer exists. This reference should have been deleted concurrently with the deletion of i Specification 6.9.1.13(b). ,

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k Enclosure 2 j Edwin I. Hatch Nuclear Plant Request to Revise Technical Specifications l Semiannual Radioactive Efiluent Release Report i 10 CFR 50.92 Evaluation l

Proposed Changes j i

The proposed changes to the Plant Hatch Unit I and 2 Technical Specifications are  !

required to implement the new 10 CFR 50.36a reponing requirement related to the quantity of radioactive eflicents released from nuclear power reactors. Currently, such reporting for Plant Hatch is made on a semiannual basis in the Semiannual Radioactive Efiluent Release Report. The new 10 CFR 50.36a extends the reporting cycle to an annual basis. Also proposed are several editorial corrections to the Radioactive Efiluents sections of the Unit I and Unit 2 Technical Specifications.

Background

On August 31,1992, the Nuclear Regulatory Commission (NRC) placed a notice in the Federal Register (57 FR 39353) regarding several amendments to their regulations.

Specifically,10 CFR 50.36a was one of the regulations cited whereby the frequency of reporting the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents was changed from semiannual to annual. Such action was taken by the NRC in response to a Presidential memorandum requesting selecte'd Federal agencies to review and modify regulations to eliminate any unnecessary burden of governmental regulation, and insure the regulated community is not subject to duplicative or inconsistent regulation.

The reponing of the quantity of effluent releases is currently performed at Plant Hatch on a semiannual basis in accordance with the Semiannual Radioactive Efiluent Release Report contained in the Unit I and Unit 2 Technical Specifications. This reporting requirement continued to be maintained in Georgia Power Company's (GPC's) response to Generic Letter 89-01 dated September 21,1992. Therefore, as noticed in 57 FR 39353, GPC proposes to satisfy the new 10 CFR 50.36a reporting requirement in an' Annual Radioactive EfIluent Release Report which will replace the current semiannual repon.

The proposed Hatch Unit I and Unit 2 Technical Specifications submitted in response to Generic Letter 89-01 also require the quantity of radioactive solid wastes released be reported in the Semiannual Radioactive Efiluent Release Report. Although the reponing requirement associated with solid wastes is not addressed in either the old or new HL-3179 E2-1

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Enclosure 2 10 CFR 50.92 Evaluation 10 CFR 50.36a, GPC believes that the intent of the Presidential memorandum would be to  ;

allow for a change to the reporting requirement for solid wastes, similar to that being provided for liquid and gaseous efiluents to more effectively reduce the burden of i governmental regulation.

P Analysis for Proposed Changes 1. 2. and 3 ,

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The proposed changes to the Hatch Unit I and Unit 2 Technical Specifications will allow for the implementation of the new 10 CFR 50.36a reporting requirement and fulfill the .

spirit of the Presidential memorandum. The proposed changes are administrative in nature  ;

and will not reduce the effectiveness of the radiological control programs at Plant Hatch. [

Compliance with applicable regulatory requirements governing radioactive efIluants, radiological environmental monitoring, and solid wastes, including 10 CFR 20, Appendix I [

to 10 CFR 50,10 CFR 61,10 CFR 71, and 40 CFR 190, will continue to be maintained. i GPC has reviewed the requirements of 10 CFR 50.92 as they relate to the proposed changes and has made the following determination: -

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1. The proposed changes do not involve a significant increase in the probability or  :

consequences of an accident previously evaluated. The proposed changes are j administrative in nature and do not involve any change to the configuration or ,

method of operation of any plant equipment used to mitigate the consequences of an  ;

accident. Also, the proposed changes do not alter the conditions or assumptions in any of the Final Safety Analysis Report (FSAR) accident analyses. Since the FSAR j accident analyses remain bounding, the radiological consequences previously evaluated are not adversely affected by the proposed changes. Therefore, it can be '

concluded the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. ,

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2. The proposed changes do not create the possibility of a new or different kind of 3 '

accident from any accident previously evaluated. The proposed changes are administrative in nature and do not involve any change to the configuration or i method of operation of any plant equipment used to mitigate the consequences of an accident. Accordingly, no new failure modes have been defined for any plant system-or component important to safety nor has any new limiting failure been identified as a result of the proposed changes. Also, there will be no change in the types or increase i

in the amount of efiluents released offsite. Therefore, it can be concluded the proposed changes do not create the possibility of a new or different kind of accident  ;

from any accident previously evaluated.  ;

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Enclosure 2 1 10 CFR 50.92 Evaluation a

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3. The proposed changes do not involve a signifiennt reduction in a margin of safety. -t The proposed changes are administrative in nature and do not adversely impact the i plant's ability to meet applicable regulatory requirements related to liquid and gaseous effluents, and solid waste releases. Therefore, the effectiveness of the i radiological control programs is not reduced. The proposed changes would also - l eliminate an unnecessary burden of governmental regulation without reducing l protection for public health and safety. Therefore, it can be concluded the proposed i changes do not involve a significant reduction in a margin of safety. }

Analysis for Proposed Chance 4 i

Make the following editorial correct ons to the listed specifications.

i Unit 1, Specification 3.15.1.4, Liquid Holdup Tanks: Add a reference to footnote "a" '!

Also, delete Action "b" which references Specification 6.9.1.13(b).

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Unit 1, Specification 3.15.2.6, Explosive Gas Mixture: Delete Action "b" which I references Specification 6.9.1.13(b). Also, change the designation of Action "c" to "b" to i account for the deletion of the current Action "b"  ;

Unit 2, Specification 3.11.1.4, Liquid Holdup Tanks: Change the footnote reference from i "d" to "a" Also, delete Action "b" which references Spedfication 6.9.1.13(b).

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Unit 2, Specification 3.11.2.6, Explosive Gas Mixture: Revise Action "b" to delete the reference to Specification 6.9.1.13(b). ,

i GPC has reviewed the requirements of 10 CFR 50.92 as they relate to the proposed changes and has made the following determination:

1. The proposed changes do not involve a significant increase in the probability or  ;

consequences of an accident previously evaluated. The proposed changes are purely  ;

editorial and correct administrative and typographical errors. These changes do not i alter the conditions or assumptions in any of the FSAR accident analyses. Therefore,  !

it can be concluded the proposed changes do not involve a significant increase in the -

probability or consequences of an accident previously evaluated.  ;

2. The proposed changes do not create the po_ssibility of a new or different kind of f accident from any accident previously evaluated.. The proposed changes are purely

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editorial and correct administrative and typographical errors. These changes do not -

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Enclosure 2  !

10 CFR 50.92 Evaluation i

l involve any change to the configuration or method of operation of any plant {

equipment used to mitigate the consequences of an accident. Accordingly, no new l failure modes have been defined for any plant system or component imponant to  !

safety nor has any new limiting failure been identified as a result of the proposed  ;

changes. Therefore, it can be concluded the proposed changes do not create the t possibility of a new or different kind of accident from any accident previously .{

evaluated.

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3. The proposed changes do not involve a significant reduction in a margin of safety.-

The proposed changes are purely editorial and correct administrative and  !

typographical errors. These changes do not adversely impact the plant's ability to meet applicable regulatory requirements related to radioactive efiluents. The  !

effectiveness of the radiological control programs is not reduced by these changes l

Therefore, it can be concluded the proposed changes do not involve a significant i reduction m a margm of safety. .l Conclusioa_

lt Based on the preceding analysis, GPC has detenni ted the proposed changes to the Plant Hatch Unit I and Unit 2 TS will not significantlyincrease the probability or consequences  ;

of an accident previously evaluated, create the possibility of a new or different kind of  :

accident from any accident previously evaluated, or involve a significant reduction in a j margin of safety. Therefore, GPC has determined the proposed changes meet the i requirements of 10 CFR 50.92(c) and do not involve a significant hazards consideration. .;

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