ML20058K139
| ML20058K139 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/06/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058K122 | List: |
| References | |
| NUDOCS 9312140431 | |
| Download: ML20058K139 (13) | |
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_ s evi($g 2 UNITED STATES k*'. 4. J NUCLEAR REGULATORY COMMISSION i's* '[
WASHINGTON, O C. 20555 4 001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. m TO FACILITY OPERATING LICENEE PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE. OREGON TROJAN NUCLEAR PLANT
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DOCKET NO. 50-344
1.0 INTRODUCTION
By letter dated April 1,1993, as supplemented June 9 and August 5,1993, Portland General Electric Company (PGE or the Licensee) requested the approval of a change to the Trojan Nuclear Plant (Trojan) Appendix A Technical Specification (A-TS). The purpose of the amendment request is to relocate the Trojan technical specifications related to radiological effluents to the Offsite Dose Calculations Manual (ODCM) in accordance with the guidance in NRC staff Generic Letter 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of TETS to the Offsite Dose Calculation Manual or to the Process Control Pregram." A copy of the proposed ODCM was enclosed for NRC staff review.
The June 9 and August 5, 1993 supplemental submittals proposed additional TS changes related to reducing the frequency for radiological effluents reports to annually.
The June 9 changes were described in the notice, but the submittal date was inadvertently omitted from the notice. All of the supplemental changes are consistent with Generic Letter No. 89-01, consistent witle the-reporting frequency in 10 CFR 50.36a, and within the scope of the initial notice.
Thus, the submittals ao not affect the staff's initial determination.
2.0 DISCUSSION AND EVALUATION This license amendment removes radiological effluent technical specifications from the license and relocates them to the ODCM. The licensee proposes to incorporate programmatic controls for radiological effluents and radiological environmental monitoring in the Administrative Controls section of the A-TS consistent with the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix 1 to 10 CFR Part 50. At the same time the licensee proposes to transfer the procedural details of the Radiological Effluent Technical Specifications (RETS) from the A-TS to the ODCM ur to the Process Control Program (PCP) for solid radioactive wastes as appropriate.
With these changes, the specifications related to RETS reporting are 9312140431 931206 PDR ADDCK 05000344 P
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simplified. Additionally, changes to the definitions of the ODCM and PCP are proposed consistent with these changes. Guidance on these proposed changes was provided to all reactor licensees by Generic Letter 89-01 dated January 31, 1989, where the staff concluded that (1) programmatic controls can be implemented in the administrative controls section of the Technical i
Specifications to satisfy existing regulatory requirements, (2) the procedural i
details of the current TS on radioactive effluents and radiological en/ironmental monitoring can be relocated to the ODCM, (3) the procedural details of the current TS on solid radio 0ctive wastes can be relocaed to the PCP, and (4) the new programmatic controls for radioactive effluents and i
radiological environmental monitoring are sufficient to neet the re41irements of 10 CFR 20.106,10 CFR 50.36a, 40 CFR Part 190, and 10 CFR Part 50, Appendix 1.
In a supplemental. submittal dated June 9,1993, the lit.ensee requested to change the reporting requirements for radiological effluents, consistent with the revision to 10 CFR 50.36a(a)(2) issued on August 31, 1992 (57 FR 39353).
The licensee currently is required by the A-TS to submit a Radiological Effluent Release Report for the Trojan plant semiannually. The licensee requested a change to the technical specifications cons stent with the August 31, 1992 revision to 10 CFR 50.36a(a)(2), which would reduce the frequency of reporting to annually.
l The staff evaluation of each proposed changes to the Trojan Technical Specifications is as follows:
(1) Change A-TS Section 1.0, " Definitions," by updating the definitions for
" Process Control Program" (PCP), A-TS Specification 1.28.
Evaluation: The licensee proposes to update the definition of the PCP in Section 1.0 of A-TS to reflect the changes in the scope of the PCP. This change is specified in Enclosure 2 of NRC staff Generic Letter 89-01. The staff finds the change acceptable.
(2) Change A TS Section 1.0, " Definitions," by relocating the definition for
" Solidification" to the PCP, A-TS Specification 1.29.
Evaluation: The licensee proposes to relocate the definition of Solidification to the PCP. This change is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the change acceptable.
(3) Change A-TS Section 1.0, " Definitions," by updating the definitions for
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the "0DCM," A-TS Specification 1.30.
i Evaluation: The licensee proposes to change the definition of the ODCM in
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Section 1.0 of the A-TS by updating this definition to reflect changes in the ODCM by implementation of NRC staff Generic Letter 89-01. The ODCM now addresses the conduct of the Environmental Radiological Monitoring Program and with the proposed change the ODCM will contain the definitions for two new 1
programs, the Radioactive Effluent Controls Program and the Radiological l
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Environmental Monitoring Program. The definition will also include descriptions of the information required in the Radiological Environmental Monitoring and Annual Radioactive Effluent Release Reports. These changes to the definition of the ODCM are consistent with NRC staff Generic Letter 89-01, The staff finds the changes acceptable.
(4) Change A-TS Section 1.0, " Definitions" by relocating the definitions for
" Gaseous Radraste Treatment System" and " Ventilation Exhaust Treatment System" to the ODCM, A-TS Specification 1.31 and 1.32.
Evaluation: The licensee proposes to relocate the definitions for the Gaseous Radwaste Treatment System and for the Ventilation Exhaust Treatment Systems from Section 1.0 of the A-TS to the ODCH. These terms are used in Section 3.11.2.4 of the A-TE which was relocated to the ODCM (see Item 28 below) and is not used elsewhern in the A-TS.
Relocating these definitions to the ODCM is consistent with the intent of NRC staff Generic Letter 89-01, The staff finds the changes acceptable.
(5) Add to A-TS Section 1.0, " Definitions," two new definitions, A-TS Section 1.37 " Site Beundary," the definition for the site boundary, and 1.38 " Unrestricted Arecs," the definition for unrestricted area.
Evaluation: Section 1.0 contains the definitions used in A-TS.
The licensee proposes to change Section 1.0 of A-TS by adding the definitions for " Site Boundary" and " Unrestricted Areas." These definitions are referenced in Sections 6.8.4e and 6.8.4f added to the A-TS (Items 45 and 46 below). These additions to Section 1.0 of A-TS are consistent with NRC staff Generic Letter 89-01. The staff finds the changes acceptable.
(6) Relocate Section 3/4.3.3.10, Table 3.3-12 " Radioactive Liquid Effluent Monitoring Instrumentation," and Table 4.3-8 " Radioactive Liquid Effluent Instrumentation Surveillance Requirements" of A-TS to the ODCM.
Evaluation:
Section 3/4.3.3.10 of A-TS contains the LCO and Surveillance Requirements for the radioactive liquid effluent instrumentation. The
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licensee proposes to relocate this section as well as Table 3.3-12 and Table 4.3-8 which are only referenced by Section 3/4.3.3.10 to the ODCM. This is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the changes acceptable.
(7)
Relocate Section 3/4.3.3.11, " Radioactive Gaseous Process and Effluent Monitoring Instrumentation," Table 3.3-13 " Radioactive Gaseous Process and Effluent Monitoring Instrumentation," and Table 4.3-9 " Radioactive Gaseous Process and Effluent Instrumentation Surveillance Requirements" while retaining those portions of Section 3/4.3.3.11 and Table 3.3-13 and Table 4.3-9 pertaining to explosive gas mixture monitors and Process and Post-Accident Monitors of A-TS to the ODCM.
Change the reporting requirements from semiannual to annual.
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~ Evaluation: Section 3/4.3.3.11 of A-TS contains the LC0 and Surveillance Requirements for the radioactive gaseous process and effluent instrumentation.
The licensee proposes to relocate this section as well as Table 3.3-13 and Table 4.3-9 which are only referenced by Section 3/4.3.3.11 to the ODCM. This change is consistent with NRC staff Generic Letter 89-01. The licensee proposes to change references to radioactive effluent monitoring to explosive gas monitoring in Sections 3/4.3.3.11 and in the tables. This change is consistent with NRC staff Generic Letter 89-01, Enclosure 4.
Additionally, the licensee proposes to change the reporting requirements A-TS Section 3.3.3.11 from " Semiannual Radiological Environmental Report in lieu of any other report" to read "a Special Report to the Commission pursuant to Specification 6.9.2."
This change is specified in NRC staff Generic Letter 89-01, Enclosure 4.
The change in reporting requirements is in accore wce with 10 CFR 50.36(a).
These changes are consistent with NRC staff Generic Letter 89-01, Enclosure 4.
The staff finds the changes acceptable.
(8) Relocate Section 3/4.11.1.1, and Table 4.11-1 " Radioactive Liquid Waste Sampling and Analysis Program," of A-TS to the ODCM. Change the reporting requirements from semiannual to annual.
Evaluation:
Section 3/4.11.1.1 of A-TS contains the LCO and Surveillance Requirements for the concentration of radioactive material released from the site to unrestricted areas from liquid effluent.
The licensee proposes to relocate this section as well as Table 4.11-1 which are only referenced by Section 3/4.11.1.1 to the ODCH. This is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
Changing the reporting requirements from semiannual to annual is in accordance with 10 CFR 50.36(a). The staff finds the changes acceptable.
(9) Change A-TS, Section 1.0, " Definitions," by relocating A-TS Specification 1.34, the definition for " Liquid Radwaste Treatment System," to the ODCM.
1 Evaluation: The licensee proposes to relocate the definition for liquid radwaste treatment system to the ODCH. This term is used only in Section 3.11.1.3 of the A-TS which was relocated to the ODCM (see Item 11 below). This change is consistent with NRC staff Generic Letter 89-01,.
The staff finds the change acceptable.
(10) Change A-TS Section 3/4.11.1.2 by relocating the LC0 and Surveillance Requirements on dose for liquid effluent.
Evaluation:
Section 3/4.11.1.2 of the A-TS provides the LG snd Surveillance Requirements for the dose or dose commitment to indiv' duals from radioactive materials in liquid effluent. The licensee proposes to relscat e this section of the A-TS to the ODCM. This is consistent with NRC stan Gen ric Letter 89-01, Enclosure 2.
The staff finds the change u ecteose.
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l l l (11) Change A-TS Section 3/4.11.1.3 by relocating the LC0 and Surveillance Requirements for the liquid radwaste treatment system to the ODCM.
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_i addition, change the frequency for reporting from semiannual to annual.
Evaluation:
Section 3/4.11.1.3 of the A-TS provides the LC0 and Surveillance l
Requirements for the liquid radwaste treatment system.
The licensee proposes to relocate this section of the A-TS to the OCDM.
This is consistent with NRC l
staff Generic Letter 89-01, Enclosure 2.
The licensee proposes to change the frequency for submittal of the radioactive effluent release report from i
semiannually to annually. This is consistent with the provisions of revised 10 CFR 50.36a(a)(2). Prior to October 1, 1992, the regulations specified a semiannual reporting requirement. The regulations were changed on August 31, 1992 (57 FR 39353), effective on October 1, 1992, specifying an annual reporting requirement.
The staff finds the changes acceptable.
(12) Change A-TS Section 3/4.11.1.4 by changing the reporting requirements from semiannual to annual.
i Evaluation:
Section 3/4.11.1.4 of the A-TS provides the LCO and Surveillance f
Requirements for the amount of radioactive material contained in the temporary radwaste storage tanks. The licensee proposes to retain this section of the A-TS and to change the reporting frequency in the Radioactive Effluent Release Report from semiannual to annual. Retaining this section in the A-TS is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
Change of the reporting frequency is consistent with 10 CFR 50.36(a). The staff finds the change acceptable.
(13) Change A-TS Section 3/4.11.2.1 by relocating the LCO and Surveillance Requirements to the ODCM.
Evaluation: Section 3/4.11.2.1 of the A-TS contains the LC0 and Surveillance Requirements for the dose rate in the unrestricted areas due to radioactive materials released in gaseous effluent from the site. The licensee proposes I
to relocate this section of the A-TS to the ODCH. This change is consistent with the intent of NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the change acceptable.
(14)
Relocate Table 4.11-2, " Radioactive Gaseous Waste Sampling and Analysis Program" of Section 3/4.11.2 of the A-TS to the ODCM. Change reporting requirements from semiannual to annual.
Evaluation: Table 4.11-2 contains the sampling frequency, minimum analysis frequency, type of activity analysis and lower limits of detection for the gaseous release tyoes. The licensee proposes to relocate this table to the ODCM. This change, relocating Table 4.11-2 to the ODCM, is consistent with the intent of NRC staff Generic Letter 89-01 in that this table is referenced and used only by Section 4.11.2.1.2 which has been relocated to the ODCM (sen Item 13 above). The change in reporting requirements'is in accordance with 10 CFR 50.36(a).
The staff finds the changes acceptable.
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i i (15) Relocate Section 3.11.2.2 of the A-TS " Radioactive Effluent-Dose, Noble Gases," to the ODCH.
l Evaluation:
Section 3.11.2.2 of the A-TS contains the LC0 aad Surveillance Requirements for the air dose in unrestricted areas due to noble gases i
released in gaseous effluent.
The licensee proposes to relocate this section of the A-TS to the ODCM.
This change ic consistent with hRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the change. acceptable.
(16)
Relocate Section 3/4.11.2.3 of the A-TS to the ODCH.
Evaluation:
Section 3/4.11.2.3 of the A-TS contains the LCO and Surveillance Requirements for the dose to an individual from iodine-131, tritium and radionuclides in particulate form with half-lives greater than 8 days in gaseous effluent releases to unrestricted areas. The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the changes acceptable.
j (17)
Relocate Section 3/4.11.2.4 of the A-TS to the ODCM.
In addition, change the reporting frequency in the Effluent Release Report from semiannual to annual.
Evaluation:
Section 3/4.11.2.4 of the A-TS contains the LCO and Surveillance Requirements for the gaseous radwaste treatment system and the ventilation exhaust treatment system.
The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic
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Letter 89-01, Enclosure 2.
In addition, the licensee proposes to change the required frequency for reporting a discharge for more than 31 days without treatment and in excess of limits in the Effluent Release Report from semiannual to annual. This change is in accordance with revised 10 CFR 50.36a(a)(2).
The staff finds the changes acceptable.
(18)
Relocate Section 3/4.11.2.5 of the A-TS to the ODCM.
Evaluation:
Section 3/4.11.2.5 of the A-TS contains the LC0 and Surveillance Requirements for the limits for the annual dose or dose commitment to any MEMBER OF THE PUBLIC due to releases of radioactivity and to radiation from uranium fuel cycle sources.
The licensee proposes to relocate this section of the A-TS to the ODCM.
This change is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the change acceptable.
(19)
Relocate Section 3/4.11.3, " Radioactive Effluents-Solid Radicactive Waste," to the PCP.
Evaluation:
Section 3/4.11.3 of the A-TS contains the LCO and Surveillance l
Requirements for the solid radwaste system. The licensee proposes to relocate l
this section of the A-TS to the PCP defined in the ODCM. This change is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the change acceptable.
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- (20) Change reporting frequency and relocate to the ODCM Section 3/4.12.1 of the A-TS " Radiological Environmental Monitoring-Monitoring Program."
Evaluation: Section 3/4.12.1 of the A-TS contains the LCO and Surveillance Requirements for the conduct of the radiological environmental monitoring program. The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic Letter 89-01,.
The licensee, also proposes to change the required reporting requirements from semiannual to annual. This change is consistent with 10 CFR 50.36a(a)(2). The staff finds the changes acceptable.
(21) Relocate Table 3.12-1, " Radiological Environmental Monitoring Program,"
Table 3.12-2 " Reporting levels for Radioactivity Concentrations in Environmental Samples," and Table 4.12-1, " Maximum Values for Lower Limit of Detection" of A-TS to the ODCM.
Evaluation:
Table 3.12-1 of A-TS contains the sampling and collection frequency and the type and frequency of analysis for the different exposure pathways. Table 3.12-2 gives the reporting levels for the different radionuclides. Table 4.12-1 contains the maximum values for the lower limits of detection for the radionuclides. The licensee proposes relocating these tables to the ODCM. These tables are referenced only by Sections 3.12.1 and 4.12.1 of A-TS which have been relocated to the ODCM (see Item 20 above).
This change is consistent with NRC staff Generic letter 89-01, Enclosure 2.
The staff finds the changes acceptable.
(22) Change reporting frequency and relocate to the ODCM Section 3/4.12.2 of the A-TS " Radiological Environmental Monitoring-Land Use Census."
Evaluation: Section 3/4.12.2 of the A-TS contains the LCO and Surveillance Requirements for the land use census.
The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff' Generic Letter 89-01, Enclosure 2.
The licensee also proposes to change the required reporting requirements from semiannual to annual. This change is consistent with 10 CFR 50.36a(a)(2). The staff finds the changes acceptable.
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(23)
Relocate Section 3/4.12.3 of the A-TS, " Radiological Environmental Monitoring-Interlaboratory Comparison Program," to the ODCM.
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Evaluation:
Section 3/4.12.3 of the A-TS contains the LC0 and Surveillance Requirements for the analyses that are performed on radioactive materials supplied as part of an Interlaboratory Comparison Program approved by HRC.
The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic letter 89-01, Enclosure 2.
The staff finds the change acceptable.
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(24) Relocate Section B3/4.3.3.10 of the A-TS, " Radioactive Liquid Effluent Instrumentation," to the ODCM.
Evaluation:
Section B3/4.3.3.10 of the A-TS contains the bases for the i
radioactive liquid effluent instrumentation. The licensee proposes to reloc. ate this section of the A-TS to the ODCM.
This change is consistent with j
NRC staff Generic Letter 89-01, Enclosure ?
The steff finds the change acceptable.
(25) Relocate applicable portions of Section B3/4.3.3.11 of A-TS,
" Radioactive Gaseous Process and Effluent Instrumentation," to the ODCM.
Evaluation:
Section 83/4.3.3.11 contains the bases for the radioactive gaseous process and effluent instrumentation. The licensee proposes to retain the portions of Section B3/4.3.3.11 which pertain to explosive gases in the A-TS and relocate those portions pertaining to radioactive gaseous process to the ODCH. This change is consistent with NRC staff Generic Letter 89-01,.
The staff finds the changes acceptable.
(26) Relocate Section B3/4.11.1.1 of the A-TS, " Liquid Effluents Concentration," to the ODCM.
Evaluation:
Section B3/4.11.1.1 of the A-TS, contains the bases for the liquid effluent concentration. The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic Letter 89-01, Enclosure 2.
The staff finds the change acceptable.
(27) Relocate Section B3/4.11.1.2 of the A-TS, " Liquid Effluents Dose,"
to the ODCM.
Evaluation: Section B3/4.11.1.2 of the A-TS contains the bases for the liquid effluent dose. The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic Letter 89-01,.
The staff finds the change acceptable.
(28)
Relocate Section B3/4.ll.1.3 of the A-TS, " Liquid Waste Treatment," to the ODCH.
Evaluation: Section B3/4.11.1.3 of the A-TS contains the bases for the liclsid waste treatment. The licensee proposes to relocate this section of the A-TS to the ODCH.
This change is consistent with NRC staff Generic Letter 89-01,.
The staff finds the change acceptable.
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(29) Relocate Section B3/4.ll.2.1 of the A-TS, " Gaseous Effluents Dose Rate,"
to the ODCH.
i Evaluation:
Section 83/4.11.2.1 of the A-TS contains the bases for the gaseous effluents dose rate. The licensee proposes to relocate this section of the A-TS to the ODCM.
This change is consistent with NRC staff Generic Le+.ter 89-01, Fnclosure 2 apalies to 26-29.
The staff finds the change acctptable.
(30)
Relocate Section B3/4.11.2.2 of the A-TS, " Dose, Noble Gases," to the ODCM.
Evaluation: Section 83/4.11.2.2 of the A TS contains the basas for the dose from noble gases.
The licensee proposes to relocate this section of the A-TS to the ODCH. This change is consistent with NRC staff Generic Letter 89-01.
The staff finds the change acceptable.
s (31) Relocate Section B3/4.11.2.3 of the A-TS, " Dose I-131, H3 and Particulates," to the ODCM.
i Evaluation: Section B3/4.11.2.3 of the A-TS contains the bases for the dose from I-131, H3 and particulates.
The licensee proposes to relocate this section of the A-TS to the ODCM.
This change is consistent with NRC staff Generic Letter 89-01. The staff finds the change acceptable.
(32) Relocate Section B3/4.11.2.4 of the A-TS, " Gaseous Waste Treatment," to 1
the ODCM.
Evaluation: Section 83/4.11.2.4 of the A-TS contains the bases for the gaseous waste treatment and ventilation exhaust treatment systems. The licensee proposes to relocate this section of the A-TS to the ODCM.
This change is consistent with NRC staff Generic Letter 89-01.
The staff finds the change acceptable.
(33)
Relocate Section B3/4.ll.2.5 of the A-TS, " Gaseous Waste Treatment," to the ODCM.
Evaluation:
Section B3/4.11.2.5 of the A-TS is provided to meet the reporting requirements of 40 CFR Part 190. The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent _with NRC staff Generic Letter 89-01. The staff finds the change acceptable.
(34) Relocate Section B3/4.ll.3 of the A-TS, " Solid Radioactive Waste."
to the ODCM.
Evaluation: Section B3/4.11.3 of the A-TS is provided to ensure that transported radioactive wastes meet the solidification requirements. The licensee proposes to relocate this section of the A-TS to the ODCM. This i
change is consistent with NRC staff Generic Letter 89-01.
The staff finds'the change acceptable.
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(35)
Relocate Section B3/4.12.1 of the A-TS, " Radiological Environmental Monitoring: Monitoring Program," to the ODCM.
Evaluation: Section B3/4.12.1 of the A-TS contains the bases for the radiological environmental monitoring program. The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic Letter 89-01. The staff finds the change acceptable.
(36)
Relocate Section B3/4.12.2 of the A-TS, " Radiological Environmental Monitoring:
Land Use Census," to the ODCM.
Evaluation: Section B3/4.12.2 of the A-TS contains the bases for the land use census.
The licensee proposes to relocate this section of the A-TS to the ODCM.
This change is consistent with NRC staff Generic Letter 89-01.
The staff finds the change acceptable.
(37) Relocate Section 83/4.12.3 of the A-TS, " Radiological Environmental Monitoring:
Interlaboratory Comparison Program," to the ODCM.
Evaluation:
Section B3/4.12.2 of the A-TS contains the bases for the interlaboratory comparison program.
The licensee proposes to relocate this section of the A-TS to the ODCM. This change is consistent with NRC staff Generic Lett v 89-01.
The staff finds the change acceptable.
(38)
Replace Section 6.9.1.5.1 and Section 6.9.1.5.2 of A-TS, " Annual Radiological Environmental Monitoring Report," with a new A-TS Section 6.9.1.5.1, and relocate the old Section 6.9.1.5.2 of A-TS to the ODCM.
Evaluation:
Section 6.9.1.5.1 of A-TS contains the date prior to which the Routine Radiological Environmental Monitoring Reports shall.be made.
Section 6.9.1.5.2 governs the contents of the Annual Radiological Environmental Monitoring Reports. The licensee proposes to replace Section 6.9.1.5.1 and 6.9.1.5.2 with a new Section 6.9.1.5.1, which simplifies this specification in the A-TS.
Further, the licensee proposes to relocate the old A-TS Section 6.9.1.5.2 in its entirety to the ODCM with all references made to appropriate sections in the ODCH. This change is consistent with NRC-staff Generic letter 89-01, Enclosure 2.
The staff finds the changes acceptable.
(39)
Replace Section 6.9.1.5.3 and Section 6.9.1.5.4 of A-TS, " Radioactive i
Efflueni Release Report," with a new A-TS Section 6.9.1.5.2, and relocai6 are old Section 6.9.1.5.4 of A-TS to the ODCM.
Change the reporting requirements.
Evaluation:
Section 6.9.1.5.3 of A-TS contains the date prior to which the Routine Radiological Environmental Monitoring Reports shall be made.
Section 6.9.1.5.4 governs the contents of the Radioactive Effluent Release-Report.
The licensee proposos to replace Section 6.9.1.5.3 and 6.9.1.5.4 with a new Section 6.9.1.5.2, which simplifies this specification in the A-TS.
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. This change is in accordance with NRC staff Generic Letter 89-01, Enclosure 2.
The licensee also proposes to change the reporting requirements from semiannually to annually.
Changing the reporting frequency is in accordance with 10 CFR 50.36a(a)(2).
Further, the reporting date was changed from "within 60 days after January 1 of each year" to "before May 1 of each year,"
to be consistent with the Generic Letter 89-01 date for submittal of the Annual Radiological Environmental Monitoring Report. The staff finds these changes acceptable.
(40) Relocate Table 6.9-1, " Radiological Environmental Monitoring Program Summary," of Section 6.9.1.5.2 of the Administrative Controls section of the A-TS to the ODCM.
Evaluation: Table 6.9-1 contains summarized and tabulated results of all radiological environmental samples taken during the report period. The licensee proposes to relocate this table to the ODCM. This change, relocating Table 6.9-1 to the ODCM, is consistent with the intent of NRC staff Generic Letter 89-01 in that this table is referenced and used only by Section 6.9.1.5.2 of A-TS which has been relocated to the GDCM (see Item 38 above). The staff finds the change acceptable.
(41) Change Section 6.9.2 of A-TS, "Special Reports," by relocating Items p and q to the ODCM and adding a new Item p.
Evaluation:
Section 6.9.2 of A-TS covers the activities for which a Special Report shall be submitted to the Document Control Desk. The licensee proposes to relocate Items p and q to the ODCM. The licensee also proposes to change Item r by changing references to Effluent Monitoring Instrumentation to Explosive Gas Monitoring Instrumentation consistent with changes made earlier (see Item 7 above). The licensee proposes an administrativ:s change by changing the numbering of the items listed under Section 6.9.2 to reflect these changes. These changes are consistent with the intent of NRC staff Generic Letter 89-01.
The staff finds the changes acceptable.
(42) Change Section 6.14 of A-TS, " Administrative Controls-Process Control Program," by simplifying the definition of the Process Control Program.
Evaluation: Section 6.14.1 of A-TS defines the Process Control Program.
Section 6.14.2 determines how licensee-initiated changes to the Process Control Program are reviewed and implemented. The licensee proposes to simplify these sections of the A-TS as specified verbatim by Enclosure 3 to NRC staff Generic Letter 89-01. The staff finds this change acceptable.
(43) Change Section 6.15 of A-TS, " Administrative Controls-Offsite Dose Calculation Manual," by simplifying the definition of the Offsite Dose Calculation Manual.
Change reporting requirements from semiannual to annual.
Evaluation: Section 6.15.1 of A-TS defines the Offsite Dose Calculation Manual.
Section 6.15.2 determines how licensee-initiated changes to the Offsite Dose Calculation Manual are reviewed and implemented. The licensee
4-I proposes to simplify these sections of the A-TS as specified verbatim in to NRC staff Generic letter 89-01. The licensee also proposes to change the reporting requirements from semiannually to annually.
Changing the reporting frequency is in accordance with 10 CFR 50.36a(a)(2). The staff finds these changes acceptable.
(44)
Change Section 6.16 of A-TS, " Administrative Controls-Major Changes to Radioactive Waste Treatment Systems," by relocating this entire section to the ODCM and PCP (0DCM).
Evaluation:
Section 6.16 of the A-TS determines how licensee-initiated major changes to radioactive waste treatn.ent systems are summarized, documented, and reviewed. The licensee proposes to relocate this section of the A-TS to the ODCM and PCP (0DCM). This change is specified by Enclosure 2 of NRC staff i
Generic Letter 89-01. The staff finds this change acceptable.
(45) Add to A-TS, Section 6, " Administrative Controls," a new Subsection 6.8.4e which requires the establishment, implementation and maintenance of an RECP.
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 in to NRC staff Generic Letter 89-01. The staff finds this change acceptable.
(46) Add to A-TS, Section 6, " Administrative Controls," a new Subsection 6.8.4f which requires the establishment, implementation and maintenance of an REMP.
Evaluation: The licensee is proposing to add a new subsection to Section A-TS 6.8 entitled " Radioactive Environmental Monitoring Program." The addition of this subsection to Section 6.8 is specified verbatim in to NRC staff Generic Letter 89-01.
The staff finds this change acceptable.
(47)
Add to A-TS, Section 6.10, " Record Retention," a new Subsection 6.10.20, which requires that records of reviews performed for changes made to the ODCH and PCP be retained for the duration of the facility operating license.
Evaluation: The licensee is proposing to add a new subsection to Section A-TS 6.10.2 concerning the recordkeeping requirements for the ODCM and the PCP.
The addition of this subsection to Section 6.8 is specified verbatim j
in Enclosure 3 to NRC staff Generic Letter 89-01. The staff finds this change acceptable, i
4 + cw (48) Change A-TS, "INDEX," by changing pages Ia, IV, VIII, VIIIa, XIV, and XVII c' the table of contents to reflect the section either added or delets., 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 of the A-TS table of contents, called "INDEX." The staff finds this an administrative change and therefore finds it acceptable.
Based on the above evaluation, we find that the licensee changes to the Appendix A Technical Specifications for Trojan, as descriLed in Specification Change Request No. 232, dated April 1, 1993, are consistent with NRC Generic Letter 89-01, dated January 31, 1989. The staff finds the proposed changes acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission regulations, the appropriate member of the Oregon Department of Energy was notified of the proposed issuance of this amendment.
The State official had no comment.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The amendment also relates to changes in recordkeeping, reporting, or administrative procedures or requirements. The NRC staff has determined that the amendment involves no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (58 FR 36442) dated July 7, 1993. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (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 CONCLUSION
The Commission has 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, (2) such activities will be conducted in compliance with the Commission 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:
Clay Mayberry Date:
December 6, 1993