ML20082G495
| ML20082G495 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 06/10/1991 |
| From: | Schuster T COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20082G498 | List: |
| References | |
| GL-89-01, GL-89-1, TAC-80542, TAC-80543, TAC-80544, TAC-80545, NUDOCS 9108190159 | |
| Download: ML20082G495 (8) | |
Text
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Downsrs Grove. Ilknots 60515 CU W H Di -- - - _.---
\\d June 10, 1991 Dr. Thomas E. Murley Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Application for Amendment to facility Operating Licenses NPF-37/66 & NPF-72/77 Appendix A, Technical Specifications Generic Letter 89-01 Changes TAC # 80542/80543 and 80544/80545 ffRC_Dsrhet Nos. 50 454/45LAnLAML451
Reference:
a) NRC Generic Letter 89-01 dated January 31, 1989, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and Relocation of procedural details of RETS to the Offsite Dose Calculational Manual (ODCM) or to the Process Control Program (PCP).
Dear Dr. Murley:
Pursuant to 10 CFR 50.90 Commonwealth Edison Company (CECO) proposes to amend Appendix A, Technical Specifications of Facility Operating Licenses NPF-37/66 and NPF-72/77 for Byron and Braidwood Stations respectively.
The proposed amendment consists of changes to 1) relocate the procedural details of the current radioactive effluent / radiological environmental monitoring program and solid radioactive waste program in Technical Specifications to the ODCM and PCP, respectively;
- 2) install programmatic controls into the Administrative Controls section of Technical Specifications.
These changes serve to simplify Technical Specifications to fulfill the goal of the i
Commission Policy Statement for Technical Specification Improvements, while they continue to meet the regulatory requirements for radioactive effluents l
and radiological environmental monitoring.
The proposed amendment was l
prepared in accordance with the guidance provided in Generic letter 89-01 l
(Reference a), except for two minor differences identified in Attachment A of l
this submittal.
A copy of the ODCM Chapter 12, to which the procedural details of the l
RETS have been transferred, is enclosed as Attachments E and F for Byron and l
Braidwood Stations respectfully.
The PCP containing the remainder of the l
transferred procedural details will be completed by August 31, 1991 and will i
be available upon request.
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Drr Thomas E.-Hurley June 10. 1991 The description _and bases of the proposed changes is presented in:
Attachment A.
The-revised _ Technical Specification pages are contained in Attachment B.
t The proposed changes have been reviewed and approved-by both on-site and
-off-site review in accordance with Commonwealth Edison procedures.
Comonwealth Edison has reviewed this proposed amendment in accordance with 10 CFR 50.92(c) and has determined that no significant hazards censideration exists.
This evaluation 15 documented in Attachment C.
An Environmental Assessment has been completed and 1s contained in Atte.chment D.
Also enclosed
-as Attachment-G, is a table identifying Technical-Specification pages which are affected by-both this proposed amendment and a previously submitted Generic letter 87-09 amendment which is currently under review by.the NRC staff.
Comonwealth Edison is notifying the State of Illinois of our application for this amendment by transmitting a copy of this letter and its attachments to the designated State Official.
To the best-of my knowledge and belief the statements contained herein are true and correct.
In some respects, these statements are not based on my personal knowledge but upon information received from other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please direct any questions you may have concerning this matter to this office.
f Respectfully, State el County of 10r/
a cWehe on this *f ggj } hyg.w gg
" l 13 9Y E ofj P$tary Pubne @
A' Terence K. Schuster
['7 Nuclear Licensing Administrator Attachments (A): Description and Bases of the Proposed Changes (B): Proposed Technical Specification Changes (C): Evaluation of Significant Hazards Consideration (D): Environmental Assessment Statement (E): ODCM Chapter 12 for Byron Station (F): ODCM Chapter 12 for Braidwood Station (G): Tech Spec pages affected by GL 87-09 cc:
W. Kropp - Resident Inspector. Byron (w/o attachments)
- 5. Dupont - Resident Inspector, Braidwood (w/o attachments)
A. Hsia - Project Manager (Byron), NRR R. Pulsifer - Project Manager (Braidwood), NRR W. Shafer - Branch Chief. Region III
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b Office of Nuclear Facility Safety - IDNS S
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AIIACHMERLA DESCRIPTION ANQ_ BASES OF THLlR020SID_CH6MGES QESCRIPT10N The proposed amendment for RETS is based on NRC Generic Letter 89-01 and would implement the following seven. changes (1) incorporate programmatic controls-in-the Administrative Controls section of the TS that satisfy the-requirements of 10CFR20.106, 40CFR Part-190, 10CFR50.36a and Appendix I to-10CFR Part 50, (2) relocate the existing procedural. details in current specifications involving radioactive effluent monitoring instrumentation, the control of liquid and gaseous effluents, equipment requirements for liquid and gaseous effluents, radiological environmental monitoring, and radiological reporting-details from the TS to-the ODCH, (3)-relocate the definition.of solidification =and existing procedural-details in the current specification on solid radioactive. wastes to the PCP.,-(4) simplify the associated reporting requirements, (5) simplify the administrative controls for changes to the ODCM and PCP, (6) add record retention requirements for changes.to the ODCM and PCP, and (7) update the definitions of the ODCH and PCP-consistent with these changes.
The following is a summary of the changes made to effect the above, y
presented in the order in which they would occur in Technical Specifications:
1.
Various Index page changes are necessary due to specification deletions and subsequent.page_ renumbering.
2.
Modify ODCH and'PCP definitions, specifications-1.18 and 1.23
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respectively, per GL 89-01 (Enclosure 3).
3.
Delete solidification definition from Tech Specs Section 1.32 per GL 89-01 (Enclosure 2).
j 4.
Delete the Radioactive Liquid Effluent Monitoring Instrumentation
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Technical-Specification-3/4.3.3.9 and Tables 3.3-12 and 4.3-8 per GL 89-01~(Enclosure 2).
5._ Delete the Radioactive Gaseous Effluent Monitoring Instrumentation Technical? Specification 3/4.3.3.10_with the exception of item 3, Gaseous i
Waste Management System. -Delete' Table 3.3-13 with the exception of 3
Action 38.
Delete Table 4.3-9 with the_ exception of functional unit 3 and Table Notations.
Changes were made in accordance with the-guidance of GL 89-01-(Enclosures 2 and 4) with'the exception of tho-wording of-notes 4 and'.5 of Table 4.3-9.
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AIIACIMEMLA
- DESCRIP.IIQMJul0_ BASES 0E._IHLPJ1020 SED _ CHANGES CDRIllfuED
- 6. Delete ~the fo110 wing' Radioactive Liquid Effluent Monitoring Instrumentation Technical Specifications per GL 89-01 (Enclosure 2):
l 3/4.11.1,1 3/4.11.3 Table 4.11-1 3/4.11.4-3/4.11.1.2 3/4.12.1 3/4.11.1.3 Table 3.12-1 3/4.11.2.1 Table 3.12-2 a-Table 4.11-2 3/4.12.2 3/4.11.2.2 3/4.12.3 3/4.11.2.3 Table 4.12-1 3/4.11.2.4
- 7. Delete bases for the Radioactive Liquid Effluent Monitoring Instrumentation deleted in specifications 3/4 in items #4. #5 and #6 above-per GL 89-01 (Enclosure 2):
Bases 3/4.3.3.9 3/4.11.2.3 2/4.1.3.10 (Partially deleted) 3/4.11.2.4 3/4.11.1.1 3/4.11.3 3/4;11.1.2 3/4.11.4 3/4.11.1.3 3/4.12.1
.3/4.11.2.1 3/4.12.2 3/4.11.2.2 3/4.12.3
- 8. Add Sections 6.8.4e Radioactive Effluent Controls Program and 6.8.4f Radiological Environmental Monitoring 'rogram as recommended _in GL 89-01 (Enclosure 3).
One minor change to-note is the word " Station" has_been substituted for the word " operating" in the first paragraph of section 6.8.4e.
- 9. Change 6.9.-l.6 Annual Radiological Environmental _ Operating Report to that
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recommended in GL 89-01-(Enclosure 3).
- 10. Change 6.9.1.7 Semiannual Radioactive Effluent Release Report to that recommended in GL 89-01 (Enclosure 3).
11._ Add:Section 6.10.2o, record retention for changes to ODCH and PCP, per GL 89-01 (Enclosure 3).
- 12. Change 6.13 Process Control Program to that recommended in GL 89-01
_(Enclosure 3).
13.' Change 16.14 Offsite Dose Calculation Manual to that recommended in GL-89-01-(Enclosure 3).
Two minor changes were made to the wording of the model Generic Letter section tv clarify 1) when a revision is to become effective and placed in use, after review by the Onsite Review Group and
- 2) when the reporting requirements for an ODCM revision would go into effect.
- 14. Delete 6.15 Major Changes to Liquid, Gasecus, and Solid Radwaste Treatment Systems per GL 89-01 (Enclosure 2).
NOTE: Various pages affected by the page deletions will be renumbered.
ZNLD/651:17 -
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AU8CHENT A (continutO
- BASES OF THE PROPOSID CHANGES This amendment request-affects those sections of Tecnnical Specifications _ dealing with the control of radiological effluents, including those-sections dealing with gaseous effluents, liquid effluents, solid waste, and environmental monitoring, Associated Technical specifications addressing definitions,_ administrative controls and reporting are also affected.
The purpose of these specifications is to assure compliance with regulatory
- requirements governing radioactive effluents, including 10 CFR 20.106, 40 CFR Part 190,-10 CFR 50.36a, and Appendix I to 10 CFR 50.
-In accordance with the guidance of Generic Letter 89-01, this proposed change-adds new programmatic requirements governing radioactive effluents and radiological environmental monitoriitg to the Administrative Controls section of the Technical Specifications.
Existing Technical Specifications containing procedural details on radioactive effluents, solid radioactive wastes.
environmental monitoring, and associated reporting requirements are concurrently being deleted.- The procedural details which are to be deleted are being incorporated into the Offsite Dose Calculation Manual (00CH) or_
Process Control Program (PCP) as appropriate.
The Technical Specification definitions of the ODCM-and PCP are also revised to reflect these changes.
The proposed changes to the Technical Specifications are administrattve in nature and affect only the format and location of procedural details related to the' control of radioactive effluents, solid radioactive waste, and radiological environmental monitoring.
The proposed changes do not involve
_ physical modifications to plant equipment or c hnges in-the operation of the plant.
Although the. procedural details of RETS are being removed from the Technical Specifications, this information is being' relocated to the ODCH or PCP as appropriate, Additional administrative controls are being added to the Technical Specifications (6.13 and 6.14) to ensure that the PCP-and 00CM will maintain compliance with applicable regulatory requirements.
For example, per proposed Technical Specification 6.14 future changes to the 0_DCM will be reviewed to ensure that'such changes will " maintain the level of radioactive effluent. control required by 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR.50 and not adversely impact-the accuracy or-reliability of effluent, dose, or setpoint calculations." Similar controls are-applied to changes-in the PCP.
TheLtable provided at the end of this attachment includes a-listing of
-Technical Specification sections which are proposed for deletion.and their new location within the ODCM or PCP, -As specified in Enclosure I to the_ generic letter, such changes have been reviewed against the requirements of proposed specifications 6.13 and 6.14 and found to meet'the specified criteria.
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AUACHMENT A (continuedl l
As_' discussed above there are no physical changes to the plant or changes in plant operation associated with this proposed amendment, Therefore, there e
is no increase in the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety nor is the possibil_ity_for_an' accident or malfunction of a different type than any i
previously evaluated in the-safety analysis report created.
The amendment request is administrative in nature and is consistent with NRC guidance in Generic Letter 89-01.
New administrative controls are incorporated into the Technical Specifications which ensure that the relocated procedural detail is controlled in a manner which provides for continued compliance with applicable regulatory requirements.
Therefore there is no degradation cf the level of control provided over radioactive effluents, solid radioactive waste, or radiological environmental = monitoring and no reduction of the margin of safety as defined in the basis for any technical specification.
taken.
The reasoning for the specific wording used in this proposed amendment _
l Only minor-exceptions to the wording of Generic Letter 89-01 have been is as follows:
r
- 1) The wording of-Notes 4 a'd 5 of Table 4,3-9 in the original n -
Technical Specifications has been retained, The gas analyzers are.
currently calibrated in accordance with the manufacturer's recommens tions.
This method of calibration assures an acceptable degree of accuracy while not unnecessarily restricting the standard gas samples to a specific value,
- 2) for section 6,14 two minor changes were made to the wording of the model Generic Letter section to clarify 1) when an OOCH revision is to'become effective and placed in use, after review by the Onsite-Review Group and 2) when the reporting requirements for an
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ODCH revision would go into effect.
The wording used in addition
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to that proposed in Generic Letter 89-01 for Technical i
Specification 6.14 only further clarifies when a reviewed revision to the.ODCM is to be used and when reporting relative to the change is necessary.
Some revisions to the Commonwealth Edison i
ODCM are generic in nature and hence require __ approval from six i
stations' Onsite Review Groups.
Therefore, a projected effective date for a proposed revision must be selected so that all six i
stattons'are allowed adequate review time. Hithout the additional wording the Technical Specification requirement may be incorrectly-interpreted as requiring immediate implementation after an Onsite Review has'been completed.
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AHACHMENT.A ltontinued)
- 3) In Technical Specification Section 6.8.4e (pronosed version) the word " station" has been substituted f or the word " operating" in the first partgraph.
The word " operating" his a very specific c anotation at Byron /Braidwoods Stations and refers to a specific group of procedures utilized by the Operating Department.
The majority of the implementing procedures for the Radioactive Effluent Coritrols Program fall under a different category of procedure used at the station.
The use of the word " station" is therefore nore accurate, though more general.
Ttese changes serve to simplify Technical Specifications to fulfill the goai of the Commission Policy Statement for Technical Specification improvements, while they continue to meet the regulatory requirements for radioactive effluents and radiological environmental monitoring.
The proposed amendment was prepared in accordance with the guidance provided in Generic Letter 89 01 (Reference a), except for three minor differences which were previously ' *ed in this submittal.
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CROSS REFERENCE FOR RELOCATED TECNNICAL SPECIFICATIONS CURRENT TECE 3.PEC RI QQCM QA P_GE I&.CATl.0M 1.18 Retained, revised definition for ODCM 1.23 Retained, revised definition for PCP 1.32 PCP 3/4.3.3.9 00CM Section 12.2.1 Table 3.3-12 ODCM Table 12.2-1 Table 4.3-8 ODCM Table 12.2-2 3/4.3.3.10 ODCM Section 12.2.2 (explosive gas retained)
Table 3.3-13 ODCM Table 12.2-3 (Action 38 retained)
Table 4.3-9 ODCM Table 12.2-4 (Functional Unit 3 and Tabic '
Notations retained) 3/4.11.1 ODCM Section 12.3 3/4.11.1.1 ODCM Section 12.3.1 Table 4.11-1 ODCM Table 12.3 '
3/4.11.1.2 ODCM Section 12.3.2 3/4.11.1.3 ODCM Section 12.3.3 3/4.11.2 ODCM Section 12.4 3/4.11.2.1 ODCM Section 12.4.1 Table 4.11-2 ODCM Table 12.4-1 3/4.11.2.2 ODCM Section 12.4.2 3/4.11.2.3 ODCM Section 12.4.3 3/4.11.2.4 ODCM Section 12.4.4 3/4.11.3 PCP
-3/4.11.4 ODCM Section 12.4.5 3/4.12 ODCM Section 12.5 3/4.12.1 ODCM Section 12.5.1 Table 3.12-1 ODCM Table 12.5-1 Table-3.12-2 ODCM Table 12.5-2 Table 3.12-3 ODCM Table 12.5-3 3/4.12.2 ODCM Section 12.5.2 3/4.12.3 ODCM Section 12,5.3 6.9.1.6 Retained, added to ODCM Section 12.6.1 6.9.1.7 Retained, added to ODCH Section 12.6.2 and PC:
6.10.2.o Retained but revised 6.13 Retained but simplified 6.14 Retained but simplified 6.15 ODCM Section 12.6.3 (Liquid and Gus)
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