ML20065L220

Safety Evaluation Supporting Amends 148 & 134 to Licenses DPR-77 & DPR-79,respectively

ML20065L220
Person / Time
Site:	Sequoyah
Issue date:	11/16/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20065L219	List: ML20065L215 ML20065L220
References
NUDOCS 9012050322
Download: ML20065L220 (7)

Text

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ENCLOSURE 3 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENOMENT NO.148 TO FACILITY OPERATING LICENSE NO. OPR-77 AND AMENOMENT NO.134 TO FACILITY OPERATING LICENSE NO. OPR-79 TENNESSEE " ALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By letter dated March 9,1990, the Tennessee Valley Authority (TVA) proposeu changes to the Technical Specifications (TSs) for the Sequoyah Nuclear Plant (SQN), Units 1 and 2.

TVA stated that the proposed changes implement NRC's recommended alternative for the Radiological Effluent Technical Specifications (RETS) as contained in Generic Letter 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administra-tive Controls Section of the Technical Specifications end the Relocation of Procedural Details of RETS to the Offsite Dose Calcula cion Manual or to the Process Control Program."

Generic Letter (GL) 83-01 which was issued on January 31, 1989, resulted from the NRC staff examining the contents of the RETS in relation to the Commis-sion's Interim Policy Statement on Technical Specification Improvements.

The staff had determined that programmatic controls can be implemented in the Administrative Controls section of the TS to satisfy existing regulatorv requirements for RETS.

At the same time, the procedural detail. or the c'arrent TSs on radioactive effluen'.s and radiological environmental monitoring ct be relocated to the Offsite Dose Calculation Manual (ODCM).

Likewise, the proce-dural details of the current TSs on solid radioactive wastes can be relocated to the Process Control Program (PCP).

These actions which the staff concluded simplify the RETS, meet the regulatory requirements for radioactive effluents and radiological environmental monitoring, and are provided as a line-item improvement of the TSs, consistent with the goals of the Policy Statement.

2. 0 DISCUSSION TVA followed the guidance provided in GL 89-01 as shown in Table 1.

The proposed amendments would: (1) incorporate programmatic controls in the Administrative Controls Section of the TS that satisfy the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a and Appendix I to 10 CFR Part 50; (2) relocate the existing procedural details in current specifications involving radioactive effluent monitoring 1.strumentation, the control of liquid and gaseous effluents equipment requirements for liquid and gaseous l

. effluents, radiological environmental monitoring, and radiological reporting details from the TSs to the ODCM; (3) relocate the definition of solidi #ica-tion and existing procedural details in the current specification on sol'd 1

radioactive wastes from the TSs to the PCP; (4) simplify the associated report-ing requirements in the TSs; (5) simplify the administrative controls for changes to the ODCM and PCP; (6) add record retention requirements for changes to the ODCM and PCP in these two documents; (7) update the definitions of the 00CM and PCP consistent with these changes.

In addition, TVA proposed to relocate the definition for a source check from the TSs to the ODCM.

The definition of a source check is not being changed.

The GL was mute on the subject of a source unck.

TVA also proposed an addition to TS Section 6.10.2 specifying that records of reviews performed for changes made to the ODtM and PCP be retained along with

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other similar records of administrative activities for the duration of the operating license.

The GL does not address this issue.

TS Section 6.10 contains requirements for retention of records of fifteen other administrative functions, 3.0 EVALUATION l

Table 1 of this evaluation has been prepared to summarize TVA's proposed l

actions in the implementation of GL 89-01.

TVA's implementation complies with L

GL 89-01 guidance except for the relocation of the definition of cource check, b

the addition to Section 6.10.2, and retaining the procedure for reporting major changes in the radwaste-treatment systems in the TSs, SQN's license amendment request to implement GL 89-01 includes (1) the incorporation of programmatic I

controls for radioactive effluents and radiological environmental monitoring in the administrative controls section of the TS, (2), incorporation of the 1

procedural details of-the current-RETS in the ODCM and PCP as appropriate, and (3) confirmation that the guidance of the GL has been followed.

Therefore, based on Table 1, the staff finds this TS amendment request has met the guidance of GL 89-01, and is, therefore, acceptable.

The definition of source check is relocated to Paragraph 6.12 in the "Defini-tions" section of the ODCM.

The staff fine this change is acceptable.

TVA elected to add to the Technical Administrative Controls, Section 6.10.2.

The

-i specific addition requires that records of review performed for changes made to the ODCM and PCP shall be. retained for the duration of the unit operating license.- Section 6.10.2 contains similar retention requirements for records

- of fifteen other categories of records.

The staff finds that this addition to q

< Section 6.10.2 of the TSs is acceptable.

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- TVA has retained in TS Section 6.15 the existing requirement for reporting i

major changes to Radioactive-Waste Treatment Systems (i.e., liquid, gaseous and solid).

GL 89-01 lists that reporting' major changes to these systems as

" existing procedural details which are relocated to the 00CM or PCP as appro-

- priate." TVA has also elected to incorporate into Section 6.11 of the PCP the same TS requirement for major changes to liquid, gaseous and solid Radioactive Waste Treatment Systems.

The change requirements located in the TS obviate the need for such requirements to be located elsewhere.

The staff finds acceptable TVA's retaining in.its TSs the existing requirements for reporting changes to

- Radioactive Waste Treatment Systems.

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4.0 ENVIRONMENTAL CONSIDERATION

These amendments involve a change to a requirement with respect to the ins'alla-tion or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements.

The amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements.

The staff ta3 determined that the amendments

' involve no significant increase in the.:nounts, and 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 expo-The Commission has previously issued a proposed finding that these sure.

amendments involve no significant hazards-consideration and there has been no public comment on such finding.

Accordingly, the amendments meet the eligibil-ity 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 nor environmental assessment need be prepared in connection with the issuance of these amendments.

5.0 CONCLUSION

The Commission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Register (55 FR 12601) on April 4, 1990 and consulted with the StLte of Tennessee.

No c

public comments were received and the State of Tennessee did not have any comments.

The staff 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 manr.er, and (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of'the amendments will not be inimical to the common defense and security nor to the health and safety of the public.

Principal Contributor:

D. H. Moran Dated:

November 16, 1990

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Enclosure:

Table 1

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Enclosure

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-TABLE 1 LINE-ITEM DESCRIPTION OF TVA's Peop0 SED is Camg m3 1SpecifIcatloa

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Description of Change Implementation 1.17 ~

Offsite Onse Calculatloa Blaamal (0008)

Espand deftalttoa to incorporate and=1 TSs Note 1 provided la GL 89-08.

h22 Process Control Program isTP) lipdate deftaltion to lacorporate andel TSs

' Note I provided la GL 8g-01.

1.31 Solidificatloa Deftalttoa is relocated to the PCP.

Note 1 1.32 Soerce (%eck Deflattlen is relocated to the 000s.

TVA elected.to relocate this' definition.

3.3.3.9 and Radioactive Ligeld Effloset 90satterlag Programmatic controls are facloded la Note 1 4.3.3.9

!.rhtaties /

TS 6.8.5f (Item 1). Entstlag TS details are relocated to the 0806.

3.3'.3.10 and Radioactive Geseems Effluent 90eimiterlag-Programmatic controls are lacleded la

'4.3.3.10 Instrussetation TS 6.8.5f (Item 1). Existlag is details for radioactive gaseces affleest osattoring lastrumentation are relocated to the ODOI.

TSs 3.3.3.10 and 4.3.3.10 have been revised to retala emplosive gas asaltorlag lastrumentation requirements.

3/4.11 Radioactive Effluents

. Programmatic controis.,re lacladed la Note 1 3/4.le.)

Liquid Effluents Osacentratloa

'TS 6.8.5f (Items 2 and 3). Esistlag is detalls are relocated to the 0000.

flote 1 - Complies with GL 89-01 Guidance 4

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Specification Title Description of M

'3.11.1.2 and 4.11.1.2 Radioactive Effluents: Dese Implementation

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Programmatic controls are included la Note 1 I

TS 6.8.5f,(Items 4 and 5). Emistlag 15' 3.11.1.3 and details are relocated to tlie 0000.

4.11.1.3.1 Radioactive Effloonts: Ligold IInste-Treatment Programmatic controls are lacleded la 15 6.8.5f (Item 5). Esistlag 15 details are Note 1 relocated to the 0000.

3.11.1.4 and 4."1.1.4 Radioactive Effluents:- Ligold IIsidsp Tasks

-Existleg 15 regelrements are retained Note 1 3.11.2.1, 4.11.2.1.1, and Radleactive Effluents 4.11.2.1.2 Gaseous Effloosts:- Bose Rate Programmatic controls are facloded in 15 6.8.5f (Items 3 and 7).

Note 1 3.11.2.2 and details are relocated to flee 0008.Esisting 13

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4.11.2.2 Radleective Efflosets: Bose-nom e Gases t

Programmatic controls are tecluded la

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i TS 6.5.5f (Itses 5 and 8). Existleg 15 i

Note 1 detills are relocated to tile 6000.

3.11.2.3 and 4.11.2.3 Radleactive Effluents:

8ese-I-131, i

I-133. Trities, and Radleneclides is Programmatic controls are facloded la Particelate Form-T5 6.8.5f (Items 5 and 9). Existing TS detalls are relocated to tie cool.'

1 3.11.2.4 and 4.11.2.4.1 andloactive Efflesets:

l Treatment Gassess Andueste

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- r Programmatic controls are included la 15 6.8.5f.(Item 6).

Note 1 Esisting 15 j

3.11.2.5 and details are relocated to the 0000.

Radioactive Effleests: Esplestve Gas 4.11.2.5 litature Entstlag TS regstrements are retained.

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Specification Title 3.11.2.6 and Description of Change Implementatic Radloactive U iinents: Gas Decay Yanks-4.11.2.6 Entsting 15 regelrements are retained.

Note 1<

3.11.3 and Radioactive EF5 ents:

4.11.3.1 Itaste

. Solid Radioactive i

Eulsting 15 details are relocated to the PCP.

Note 1 4

3.11.4 and 4.11.4 Ridleactive Effluents: Total Dese Prograenstlc controls are included in Nott l' 15 6.5.5f (Ites 10).

' relocated to the 0000. Existing is details are 3.12.1 and 1

Radioactive Environmental llonttoring:

4.12.1 flontterlag Program Programmatic coptrols are included in TS 6.8.5g (Ites 1).

Note 1 i

Radioactlee Environmental lisattoring:'

relocated to the 600s,Eulsting TS details are.

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3.12.2 and 4.12.2 i

Land lise Conses Prograsmatic controls are included in 15 6.8.5g (Ites 2).

Note 1 3.12.3 and relocated *.o ^he 0D01.Esisting TS detalls are i ~

4.12.3 Radlonctive Environmental 80snitoring:

Interlaboratery Comparison Program Programmetfr controls are included in 15 6.8.5g ( Hem 3).

Note 1 relocated to the 0000.Esisting TS detalls are 6.8.4(c)

Procedures and Programs: Ilrltten Procedures I

Table 6.1-1 previously contained surveillance Note 1 requirements and environmental monitoring

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regelrements.

Table 6.1-1 uns removed under a prevlees TS amendment and is no longer applicable.

retained and is now telas deleted.TS 6.8.4(c) uns inadv 6.9.1.6 and

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6.9.1.7 Reporting Regelrements: Annual Radiological Eartrommental Operating Report Esisting reporting details of is 6.g.l.? are Note 1 k

relocated to the 0D00. Reporting requirements are stupitfled and consolidated under TS 6.9.1.6.

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4-Specificatles ittIe Descrietton of thance Implementation 6.9.8.8 and Reportleg Requirements: Seelannual

'Eststtag reporttag detatis of TS 6.9.l.9 are Note 1 6.9.1.9 Radloactive Effloset Release Report

- relocated to the 0000 and FCP'as.

appropriate. ReportIne regelrements are

. staptified and consetidated under TS 6.9.1.0.

6.lt.2(p)

Becere Setentles A requirement for retainlog records of TVA electe. to reviews performed for changes to the GODI and add this item tc the PCP has been added to section 6.10.

Section 6.10.2 dealing with record retention 6.13 Process Centrol % gras WCP)

Esistles is regelrements are staplifted to llote 1 i

incorporate model iss proelded la CI. 89-01.

6.14 Oft'se Gese Calculatles leannel (coop Entstles is requirements are sleplifled to Note 1 i

I lacorporate model iss provided in st. 89-01.

i 1.15 Nebr Chasses to Radteactive leaste Esisting TS regelrements are retaleed.

TVA elected to retai i l

Treatment Systems (Ligold, Gaseous, and.

existing IS require- ]

~5elld) ments and incorporat,;

in the PC), licensee :

initiated shanges to !

liguid. qaseous and solid radioactive i

waste systems.

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