ML20082G545
| ML20082G545 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/13/1991 |
| From: | Cottle W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20082G548 | List: |
| References | |
| GL-89-01, GL-89-1, GNRO-91-00084, GNRO-91-84, NUDOCS 9108190206 | |
| Download: ML20082G545 (18) | |
Text
- _ - - -
$.: - Entergy 5 "'i ' " "~ """ * '"*-
Operations f
. -_,-~ --.
W. T. Cottle August 13, 1991
'J.S. Nnclear Regnint ory Cornmisnion Hall Station Pl-137 Washington, D.C.
20555 Attentfon:
11ocumen t Cont tol Denk S ubj ec t. !
Crnnd Gulf Nnclear St at inn lin i t 1 Pocket No. 50 416 1.icense No. N I'P-29 Gener ic l.et t er 89-01, Rolocnt ion of t he kl,TS to thn ODCM/PCP Pr opo%ed Ametidment to thn Operat itig License (PCOL-91/11)
GNRO-91/00084 Centlemon:
Entergy Oporat ions. Inc. 19 nubmittisin by this letter n proposed amt ndment. to t he Grntal Gulf Nuclear St at ion (GGNS) Opeint ing bleense.
Thn proposed nieendment requests the relocat irin of t he procedural det ails of the Rndiological Ef fluent Tnchnical Speci fient ions (RCTS) t o t he Of feit e Dosn Calculation linnnni (ODC'l) or to thn Ptocess Control Progrnm (PCP) nn approprinte.
In conjnnct ion with the relocnt f on of the RETS, new programmntic controls for the WETG nro added to the Administ rntivo Conttoln Section of the Technient Spncificat ions ( fS).
On Janonry 31, 1989, the NRC issnod Geectic het t e r (Gh) A9-01,
" implementation of Programmat ic Cont sola for Radiologicril Ef fluent Technical Specliications in t he Administint ivn Cont rols Sect ion of the Tnchnic.il Speci f tent lons and t hn Reincat lon of Procedural Detn ils of RETS to thn Of f sit e Dose Calcu191 f on Honon l or t o ilm Process Control Program".
Thin Gl. snmmnrized thn r esult s of t im St a f f'n examinnt ion of the content s of thn RE18 in reint ion t o t he Commission's Intnrim Policy Stntement on TS Improvements.
The NkC St nf f determined that programmatin cont roln could be impicment nd in t he Administ rat ive Cont rols Sect ion of the TS to antisfy existing rngulatoiy reqntromento for RETS.
Concurt ont ly, t be procednrni det n ils of the enrrant TS on rndioactive etflunnts and rndfologicni anvironmontal monitoring conld he relocntnd to thn ODCM and the piocedurni details of current. TS on solid rodinnetive vastes conid be rnlocnt ed t o the PCP.
The attnched proponed amendnent is colm ir.t ent. wI th and con forms ta t he guidance in Gb 89-01.
Thnrefore. Entergy Opetntions, Inc. is re<jnos t i ng that expedit ionn NRC review nf t his snhm t a l be conduct ed in accordonce M l\\
wit h Gl. 89-01.
6 G9105141/SNh1CrhR - 1
,4 9108190206 910613 I
PDR ADOCK 05000416 i
i^U--
P ppR n
.s. U
r August 13, IWA UNRO-41/00084 Page 2 of 3 in nccordance with the provisionn of 10CFR50.4. the sigemd original of i
t he t orpmnt ed nmetulment in encioned.
Attnehment 2 providen the technical just (ficat ton niid d.incussion to support the rerpmnt ed nmendment. contains the proposed TS revinions.
Proposed revisions of the ODCM and the PCP nre piovided for refer ence use nn At t nehments 4 neul 5, respectIvely.
l Thin omniulment han been reviewed and necept ed by the Plant Snfnty Review
[
Committee and the Sn f ety Review Commit t ee.
l t
linned on the guidelinen present ed in 10CrR50.92, Ent ergy Opnrnt ions han concluded that this proposed nmendment involves no nigolficant hnr.ntdn considorntlons.
~
Yours t uly, ce P dhtrl~
l WTC/SilM/mt c attachments: 1.
Affirmation per 10CFR$0.30 2.
GGNS PC0h-41/11 3.
Proposed TS Revisions for PC0h-41/11 4.
Proposed Revision of the ODCM 5.
Proposed Revision of t he PCP cc:
Mr D. C. llintz (w/n)
Mr.
- 1. Mnt his (w/n)
M r. R. II. McGehee (w/n)
Mr. N. S. Reynolds (w/a)
Mr. 11.1.. Thomas (w/o)
Mr. F. W. Tit us (w/n)
Mr. Stewart D. Ebneter (w/n)
Regional Adminintrator U.S. Nuclonr Reguintory Commission Region 11 101 Marietta St..
N.W., Suite 2900 AtInnta. Georgin 30323 Mt. l.. l.. Kintner, Ptoject Manager (w/n)
Office of Nuclear Renctor RegnIntlon l
U.S. Nuclear Regulatory Commission Hall Stop 11021 Washington, D.C.
20555 Dr. Alton II. Cobb (w/a)
Stat e llen1th Of ficer State lionrd of Ilon t t h P.O. Ilox 1700
.inckson, Mississippi 39205 G9105141/SNI.1CFI.R - 2
BEPORE Tile i
11NITED STATES NUCl. EAR REGlil.ATORY COMMISSION 1.lCf.NSE NO. NPF-29 DOCKET NO. 50-416 IN Tile MATTER 0F MiSS1SSIPI'l POWEk & l.lGitT ':0MPANY nud SYSTF.M ENF.RGY RESO!!RCES, INC.
nrul SOUTil MISS]SS-
'l 1;t.ECTRIC POWER ACSOCIATION nnd EN..- Y OPERATIONS, INC.
AII1FMIlDN 1, W. T. Cottle, bning duly swor.1, state that I am Vice President, Operations GGNS of Entergy Opnrntions, Inc.; that on behnif of Entergy Operations, Inc., System hnergy Resources, Inc., and South Mississippi Elect-ic Power Associntion I am nuthorized by Entergy Operations, Inc. to sign and filo with the Nuclear Regnintory Commisr.lon, this appliention for amendment. of the Operr. ting 1.icense of the Grnnd Gul f Nucionr Station; that I signed thin application as Vice President, Operat ions GGNS of Entergy Operations, Inc.; nnd that the statements made nnd the matters set fort h t here in are true and correct to the best ;f my knowledge, informat ton and belinf.
C.d?l~ k W. T. Cottle STATE OF MISSISSIPPI C0 LINTY OF Cf.AIBokNR SilBSCRIBE0 AND SWORN TO before mn, a Notary Public, in and for the County and Stato above named, t h i s,_\\h__ da y o f,_QnD w d
, 1991.
(SEbl.)
Q w 0t W'
Notary ub1 i
- y commission expires:
My Commissbn EsNres My L 174 G9105141/SNI.1CFlR - 4
At t acliment. 2 t.o GNRO-91/00084 PROPOSED CilANGE TO Tl'" Ol'ERATING 1.lCENSE RET.0 CATION OF T!!E ~kt.TS TO Till'. ODCM AND Tile PCP (GGNS PCOI.-91/11)
G9105141/SNI.lCFI.R - 5
Attnchment 2 to GNRO-91/00084 l
l l
A.
SUBJECT 1.
PS-91/01 Generic 1,ett er 89 Relocation of the Procedorni Detalin of t he Radiological Ef fluent Technical Spec i f ica t. ions to the Of fsite Dose Calenintion tinnual anel the Process Control Program 2.
Af fected Technical Specificat lons:
n.
Index - pages 1.
41, v, x1, xill, xvi, xvit, xx b.
De finit ions :
1.17 page 1-3 1.26 - page 1-5 1.32 - pnge 1-6 1.41 page 1-8 1.42 - pngn 1-8 1,47 page 1-8 c.
TS:
3/4.3.7.11 - pages 3/4 3 3-95 3/4.3.7.12 - pages 3/4 3 3-104 3/4.3.8 pages 3/4 *-105 109 3/4.3.9 - page 3/4 3-110 3/4.11 - pages 3/4 11 11-19 3/4.12 - pages 3/4 12 12-12 1.
Bases:
3/4.3.7.11 - pnge B 3/4 3-6 3/4.3.7.12 - page il 3/4 3-6 3/4.11 - pnges B 3/4 11-1 and 11-6 3/4.12 pnges B 3/4 12-1 and 12-2 n,
Administrat.lve Controls:
6.8. 3 - pngo 6-15 6.9.1.6 - page 6-17 6.4.1.7 pnge 6-17
- 6. 9.1. 8 - page 6-17 6.9.1.9 pages 6-18 and 6-19 6.10.2 - page 6-20 6.13 - pnge 6-22 6.14 pages 6-22 and 6-23 6.15 pnges 6-2.3 and 6-24 09105141/SNI,1CFI,R - 6
At tachment 2 to GNRO-91/0008:4 B.
DISCUSSION 1.
Generic hetter (GI.) 89-01, dated Janunty 31, 1989, encournges thn implementation of programmatic controls in Technical Specifications (TS) for radioact ive ef fluent s and for radiological environmental monitoring and the rolocation of the procedural details of the Radiological Ef fluent Technical Specificctions (RPTS) into the Offsite Dose Calculation Mannni (ODCM) or tbn Process Control Program (PCP), as appropriate.
2.
The following GGNS TS changes which are consistent with the guidance providnd in GL 89-01 are proposod:
Spectficatipn Tit 1e Descripti.on_of Change INDEX Various changes to thn Index reflect the proposed changes to the TS.
1.17 Gnscous Radwnste This definition is deleted Treatment (Offgas) and relocated to the ODCH.
System Af ter the implementat ton of GL 89-01, it will not be referenced in the TS.
1.26 Offsite Doso This definition is revised in Calculation accordance with GL 89-01 and Manual (CDGM) reflects thn change in scope of 4
the ODCM.
1.32 Process Control This definition is revised in Program (PCP) accordance with GL 89-01 and reflects the change in scope of the PCP.
1,41 Solidification in accordance with Gb 89-01, this definition is dninted and relocated to the PCP.
1.42 Source Check This definition is deleted and rnlocated to thn ODCM. Af ter the implementation of GL 89-01, it wi11 not ho referenced in thn TS.
1.47 VentilnLion This definition is deleted and Exhnust Trnatment relocated to the ODCM.
After System the implementation of GL 89-01, it will not he referenced in the TS.
G9105141/SNLICFhR - 7
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ to GNRO-91/00084 Spectficalion Tit le i)es cript;io.n..o f Charygn 3/. 3.7.11 RadionetIve 1.iquid in accoidance with GL 89-01, Effluent this entite specification is Monitoring dolotnd and relocated to the Instrumentation DDCM.
The binnk pages are deleted from the TS.
3/4.3.7.12 Radioactive In accordanen with GL 89-01, Gaseous Effluent all the requirements, except Monitoring the specifications for the Instrumentat. ion offgas hydrogen monitor, are ralocated to the ODCH. The remaining specification and tables are conda1wd into one specification and renamed " Main Condensor Offgns Trentment System - Explosive Gas Monitoring System Instrumentatlon".
The model specifications provided in
'.nc l os u re 4 to GL 89-01 were used for this TS revision which deviates Nom GL 89-01 in format and t.itin ly.
Since several previous pri, are deleted due to relocatlon, t_his pnge is renumbnred.
3/4.3.8 Plant Systems Sinco severn1 previous pages Actuntion are deleted due to relocatlon, Instrumentation these pages arn renumbered. The contont of the TS is not changed.
3/4.3.4 Turbino Ovarspeed Since snveral previous pages Protect.fon System nrn deleted don to relocation, this pngn is renumbered.
The content of the TS is not changed.
Page 3/4 3-111 This blank pnge is deleted.
3/4.11.1.1 Liquid Effluents:
In accordance with GL 89-01, Concentration this entire specification la deleted and relocated to the ODCM.
The blank pa,es arn deleted from the (S.
3/4.I1.1.2 Liquid Effinents:
In accordance with GL 89-01, Dose this ontire specification is deleted and relocated to the ODCM.
The blank page is deleted from the TS.
l l
G9105141/SNLICFI.R - 8
~
' to CNRO-91/00084 Speci fica t,3 orr T1_ tic Description of Chango 3/4.11.1.3-Liquid Effluents:
In accordanen with GL 89-01, Liquid Waste
.this.cntire specification 1s-Treatment doloted and-relocated to thn DDCH.
The blank page is dcInted
~
from the TS.
3/4.11.1.4 Liquid Effluents:
Sinco several previous pagen-Liquid !!oldup
-ara deleted due to relocation, Tanks-this page is renumbered and-the section title is added.
-3/4.11.2.1 Gascous Efflunnts:
In accordance with GL 89-01, Dose Ratn this entire specification'is deleted and relocated to the ODCH.
The blank pages nrn deleted from the TS.
3/4.11.2.2 Gaseous' Effluents:
In accordance with GL 89-01, Doso - Noble Gases this.entito specification is deleted and relocated to the ODCH.- The binnk pagn is deleted from the TS.
.3/4.11.2.3 Gaseous Effluents:
In accordanco with GL 89-01, Doan - Indinn-131 this entiro specification is Iodino-133, deleted and relocated to the Tritium and ODCH.
The blank page in Radionuclidos in deleted from the TS.
Particulate Form 3/4.11,2.4 Gasnous Effluents:
In accordance with GL 89-01, Gaseous-Radwnste this entire specification is Trnatment doloted and rolocated to the ODCM. The blank pago is doloted from the TS.
3/4,11.2.5 Gascous Effluents:
In accordance with GL 89-01, Vontilation
- this ontire spec 1ficaLion is Exhaust Trnatment' deleted and relocatnd to the
.0DCH. -The blank page is dnleted from the TS.
3/4.11.2.6; Goseous Effluent.s:
In accordance ~ with Gb 89-01, Explosive Gas this specification is retained Mixture in_the TS.
The reference _to the g
deleted Tobin 3.3.7.12-1-3s removed.
Since several previous pages are deleted dun to relocation, this page is-renumimred and the section title is ndded.
G9105141/SNLICFhR - 9
k Atiachmentc-2-to GNRO-91/00084
{
SPecirication Ti t 1.9 Dnsegip_ tion of Chango l
a 3/4.11.2.7!
Goseous Effluents:
In accordance wit.h GL l89-01, Main Condenser
.this specification is rntained' in the TS and.is revised to l
refer to tho 0DCM since TS i
3.3.7.12 Js relocated. Sinco I
several-previous pages arn deleted due to relocation, this l
pagn is renumbered, j
t 3/4.11.3 Solid Radioact.Jve In accordance with GL 69-01,
_ Waste this entire specification is i
- dninted and relocated to the l
PCP. The blank pagn is deleted from thn-TS, 3/4.11,4 l Total Dose In accordanco with GL 89-01, this entiro specification is doloted and relocatnd to the-ODCH. - The blank page is deleted from the TS.-
f 3/4.12.1 Monitoring Program
-In accordance with GL 89-01, this entire specification lis doloted and.rnlocated-to thn-
>[
ODCM.- The. blank pages arn i
dnleted f rom the TS, 3/4.12.2 hand Use Consus In accordance with Gb 89-01, this entire specification is
(
dainted and relocated to the
'j 100CH. The blank page.is deleted
[
from thn TS, j
3/4,- 12. 3 :
Interlaboratory in accordance with:GL 89-0l=,-
Comparison this entiro specificat. ion is l
Program deleted and relocated to the ODCM. - The blank page is dninted
[
f rone tho - TS.
[
t B 3/4.3.7.11-Radioactivo Since tho-assocint.ed TS is
[
hlquid Effluent rel~;ated to the ODCM, this
[
Monitoring.
Bases section is deleted and Instrumentation relocated to tho ODCM.:
)
B 3/4~3.7.12 Radioactive Sinco portions of thn assocInted-Gascons Effluent TS,are relocated to the-0DCM,-
}
Monitoring thoso applicabin Dases details j
Jnstrumentation are deletnd and -s olocated to the 1
ODCH. Thn-Bases for tho l
Explosive Gas Monitoring i
Instrumentation is retained and
}
the section is renamed to 4
reflnct that changn.
G9105141/SNLICFLR --10 ti
~.
- _ _ - _ ___-___-_-__ ___ _ - _ _. to GNRO-91/00084 Specification Title Description of_Ch_ange 11 3/4.11.1.1 1.iquid Effluents:
Since the associated TS is Concentration relocated to the ODCM, this Bases sect ion is deleted and relocated to the ODCH.
Il 3/4.11.1. 2 hiquid Ef fluents:
Since the associnted TS is Dose relocated to the ODCM, this Bases section is deleted and relocated to the ODCM.
'/ 4.11.1. 3 Liquid Effluents:
Since the associated TS is Liquid Waste relocat ed to t he ODCM, this Treatment Bases section is deleted and relocated to the ODCM.
B 3/4.11.1.4 1.iquid Effluents:
This Bases section is moved to Liquid lloldup Page B 3/4 11-1 to eliminatn Tanks blank pages.
B 3/4.11.2.1 Gaseous Effluents:
Since the associated TS is Dose Rate relocated to the ODCM, this Bases section is deleted and relocated to t he ODCM.
B 3/4.11.2.2 Gaseous Effluents:
Since the associated TS is Dose - Noble Gases relocated to the ODCM, this Bases sectton is deleted and relocated to the ODCM.
B 3/4.11.2.3 Gaseous Effluents:
Since the associated TS is lodine-131, relocated to the ODCM, this louine-133 Bases section is deleted and Ttitium and relocated to the ODCM.
Radionuclides i t.
Particulate Form B 3/4.11.2.4 Gaseous Radwnste Since the associated TSs are and Treatment and relocated to the ODCM, this B 3/4.11.2.5 Ventilation Dases section is deleted and Exhaust Trentment relocated to the ODCM.
11 3/4.11.2.6 Gaseous Effluents:
This Bases section is moved to Explosive Gas page B 3/4 11-2 to eliminate Mixture blank pages.
B 3/4.I1.2.7 Gaseous Erfluents:
This Bases sectton is moved to Main Condenser page B 3/4 11-2 to eliminate blank pages.
G9105141/SNh1CFLR - 11 I
- _ _ _ _ _ _ _ - - to GNWO-91/00084 Specif_icat f on T i t 1.9 Descriptiottof_ Change B 3/4.11.3 Solid Radioactive Since the associated TS is Wasto relocated t o the PCP, this llases sect ion is deleted and relocated to the PCP.
B 3/4.11.4 Total Dose Since the associated TS is relocated to the ODCM, this Bases sect. ion Is deleted and relocated to the ODCM, NOTE:
Pagen B 3/4 11-3 through 11 3/4 11-6 are deleted to eliminate blank
- pages, 11 3/4.12.1 Monitoring Program Since the associated TS is relocated to the ODCM, this Basen section is deleted and relocat.ed to the ODCH.
11 3/4.12.2 Land Uso Census Since the associated TS is relocated to thn ODCM, this Basna sectton is deleted and relocated to the ODCM, d
B 3/4.12.3 Interlaboratory Since the associated TS is Comparison relocated to the ODCM, this Program Bases section is deleted and relocated to t.he ODCM.
i-NOTE:
Pages B 3/4 12-1 and B 3/4 12-2 are deleted to eliminate blank pages.
6.8.3.d.
Procedures and in accordance with Gl. 89-01, (new)
Programs:
this specification is added Radioactive to include the programmatic Ef fluent Cont rols controls for the effluent Program requirement.s relocated t.o the ODCH.
6.8.3.c.
Procedurns and in accordance with GI 89-01, (new)
Programs:
this specification is added Radiological to include the programmatic Environmental controls for the monitoring Monitoring Report requirements relocated to the ODCH.
6.9.1.6 and Report.ing In accordance with GI 89-OL, 6.9.1.7 Requirements:
this specification is Annual simptifind and the ex.isting Radiological reporting details arn Environmental relocated to the ODCM.
Operating Report G9105141/SNLICH.R - 12
Attnchment 2 to GNRO-91/00084 Spec 1fIcation T.i t I n Doscriptinn.of Chnngo 6.9.1.8 and Report itig In accordanen with Gb 89-01, 6.9.1.9 Rorpii remen t s :
this specification is Seminnnual simplified and the existing Radioactive reporting details nro Effluent Release relocat ed t o t hn ODCM or t hn Report PCP, as appropriate.
6,10.2.n.
Record Ret ent ion This spec! ficnt ion is revised (ne-to add record retention requirements for changes to the ODCM and PCP por Gl. 89-01.
6.13.2 Process Control In nccordance with Gb 89-01, Program (PCP) thn requiremnnts of this specificetion are simplifind such that the records of rnviews of PCP changes are retained in lieu of submit. ting this informntion to the NRC in the Seminnnun1 Rndionetivn Effluont Knicaso Report.
Add i t iona l ly,
changes to the PCP will require thn approval of the General Manager, Pinut Operations as well as the PSRC.
6.14.2 Offsite Dose in accordance with Gb 89-01, Calculation thn requirements of this Manuni (ODCM) specification arn simplified.
Instend of submitt ing justificat.lon for changen made to the ODCM to thn NRC, this information is retained and a compInto copy of the revised ODCM.is submitted as part of or concurrent with the Seminnnual Ef fluent Release Report.
Addit lonally, changes to the ODCM will requirn the approval of thn General Manager, Plant Operat ions ns wel1 as thn PSRC.
6.15 Major Changes to in accordanco with Ch 89-01, Radionctivn Waste this specification is doloted Treatment Systems and relocnted to the ODCM and/or thn PCP, as appropriate.
Page 6-24 is deleted sinco it in blank.
3.
The affected TS and associnted Bases pages are attached and marired up to reflect the proposed changes described nhove.
The requested revisions arn consistent with thn guidanen in Gb 89-01.
G9105141/SNh1CFhR - 13 to GNRO-91/00084 C.
JUSTIFICATION I
1.
Thn simplification of the RETS in accordance with GL 89-01 is identified by the NRC Staf f as a line-item improvement of the TS, consistent with the goals of the Commission's Interim Policy Statement on TS Improvements.
The proposed TS additions for new programmatic controls for radioactive effluents and radiological environmental monitoring conform to the regulatory requirements of 10CFR20.106, 40CFR Part 190, 10CFR50.36a, and 10CFR50 Appendix 1.
2.
This amendment request has been prepared in accordance with the guidance provided in Gb 89-01.
This proposed amendment:
a.
incorporates programmatic controls into the Administrative Controls section of the TS that satisfy the regulatory requirements of 10CFR20.106, 40CFR Part 190, 10CFR50.36a and Appendix 1 to 10CFR Part 50, b.
rnlocates the existing procedural details in the current TS involving radioactive effluent monitoring instrumentation, the control of liquid and gaseous effluents, equipment requirements for 1Iquid and gaseous offluents, radiologfeal environmental monitoring, and radiological reporting details from the TS to the ODCM, c.
relocates the definition of solidification and existing procedural details in the current TS on solid radioactive wastes to the PCP, d.
simplifies the reporting requirements and relocates the existing procedural details in the current TS to the ODCM or the PCP, e.
simplifins the administrative controls and adds record retent. ion requirements for changes to the ODCM and the PCP, and f.
updates the definitions of the ODCM and the PCP consistent with these changes.
3.
The intent of the proposed amendment is not to reduce the level of radiological effluent control but to provide prograrmiatic controls for RETS consistent with regulatory requirer ants and allow relocation of the procedural details of the current RETS to the ODCM or the PCP.
10CFR50.36a does not require that these procedural details be included in the TS.
Future changns to these details will be conducted in accordance with the proposed controls for changes to the ODCM or the PCP included in the Administrative Controls section of the TS.
I G9105141/SNhlCFI,R - 14
- _ - _ - - _ -. to GNRO-91/00084 l
4.
This amendment request incorporates the three requirements of i
Gb 89-01:
I a.
The proposed changn incotporates the pregrammatic controls for radioactive effluents and radiological environmental monitoring in t he Administ rat ive Controls section in TS as recommended by Gb 89-01.
The revised dnfinitions of thn ODCM and the PCp duplicatn the model specifications in Enclosure 3 o f Gb 89-01.
Thn current TS for the explosive gas monitoring instrumentation is retained, b.
The procedural details of t he current RETU, consisting of the limit ing conditions for operation, their applicability, remedini actions, surveillance requirements and the Bases are relocated to the ODCM or t he PCP, as approprintn.
The relocation of t hesn details is accomplished without a chnnge in technical substance to ensure that thesn details are incorporated in plant operating procedures.
Becanse of the large number of relocated specifications and to enhance thn transition, the current TS numbering is retained for the relocated requirnments in the new Appendix A of t he ODCM.
The specifications relocated to the PCP arn numbered consistent with the current PCP because of the small number of relocated TS.
Only editorial changes hnve been made in transferring the procedurni details to the ODCM and the PCP; t.he re fo re, these documents do not. cont.nin markings in the margin to identify changes, c.
The proposed revisions of the ODCM and the PCP (Attachments 4 and 5) have been prepared in accordance with the proposed changns to the Administrative Controls section of the TS and have been reviewed and accepted by the PSRC and the General Manager, Plant Operations.
The proposed ODCM and PCP resisions maintain the current overall degree of radtonctivn 11guld and gaseous ef fluent and solldified waste product control requirnd by the approprinto regulations.
These proposed documents will be finalized and implemented upon approval of this amendment request.
Complete copies of t.hese proposed revised documents demonstrating the correct incorporation of the procedural details of thn current RETS are provided for reference uso in Attachments 4 and 5.
G9105141/SNhlCFhR - 15
_ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ to GNRO-91/00084 5.
The following specifications and associnted linses are retained in the TS in accordance with the guidance of GL 89-01:
Specification Titln 3/4.3.7.12 Mnin Condenser Of fgas Treatment System - Explosive Gas Monitoting System Instrumentation 3/4.I1,1.4 1.iquid lloldup Tanks 3/4.11.2.6 Explosivo Gas Mixture 3/4.11.2.7 Main Condenser 6.
Some of the proposed chnnges dnvinto sl.lghtly f rom tho guidanco in GL 89-01 but are desirnhin and do not affect the technical content.
Also, minor changes not addressed in GL 89-01 are proposed which clarify and complement the various changes in this amendment requesL. These additionn1 changes are descrlhed and justifled below:
n.
TS Definition 1.17, GASEOUS RADWASTE TREATMENT (OFTGAS)
SYSTEM, is deleted and relocated to the ODCM.
Although this changn is not addressed in GI 89-01, GL 89-01 does relocate TS 3/4.11.2.4 which is tho only specification that uses this de fin i t ion.
b.
TS Definition 1.42, SOURCE CHECK, is deleted and relocated to tho ODCM. Although this change is not addressed in GL 89-01, GL 89-01 does relocat e TS 3/4.3.7.11 and TS 3/4.3.7.12 which are the only specifications that use this definit ion.
In the proposed TS 3/4.3.7.12, a source check is not performed on the explosive gns monitoring instrumentation and is not.
needed for the retained specification.
c.
TS Defin.iLion 1.47, VENTILATION EXilAUST TREATMENT SYSTEM, is deleted and relocatnd to the 00CM. Although this change is not addressed in GL 89-01. GL 89-01 does relocate TS 3/ 4.11. 2. 5 wh ich 1.s the only specif! cation that uses this dnfinitlon.
d.
Proposed TS 3.3.7.12 deviates f rom GL 89-01 in that thn instrumentation associated with explosivn gas monitoring is nnmed "Mnin Condensor Of fgas Treatment System - Explosive Gas Monitoring System instrumentation" instead of simply "Explosivo Gas Monitoring Instrumentation".
The proposed chango is the current system designation and is retained for clarity. Another deviation from the guidanco in GL 89-01 on this specification is that the instrumentation for explosive gas monitoring does not have nn associated trip setpoint; therefore, " trip" la dninted from proposed TS 3/4.3.7.12.
G9105141/SNI.lCFLR - 16
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Attachmont 2 to GNRO-91/00084 e.
In the new Administrativo Controla 6.8.3d.4, 8 and 9, the statements have been changed from the guidance in the GI, to reflect only one unit.
Also, the note on pago 6-17 for-the Annual Radiological Environment Operating and the Semiannual Radioactive Ef fluent Rolmse Reports has been dninted to reflect only onn unit. These changes arn proposed for clarity.
f.
Administrative Controla 6.13 and 6.14 arn revised to deleto the statomonts that tho ODCM and the PCP shall bn approved by the Commission prior to impicmentation since this requirement has already been satisfied and will not he used again.
D.-
NO SIGNIFICANT llAZARDS CONSIDERATIONS 1.
The proposod. amendment, in response to and in accordance with Gb 89-01, relocates the procedural details of the current RETS to the ODCM or the PCP and replaces those details with programmatic L
controls containnd in the Administrative Controls sect ion of tho 7
TS.
2.
The Commission has provided standards for determining whether a no significant. hazards consideration exists as stated in 10CFR50.92(c). A proposed amendment to an operating licenso involves no significant hazards consideration if oporation of the facility-in accordanen with the proposed amendment would not:
[
(1) involvn a signifiennt increase.in thn prohnhil.ity or l
consequences of an accident previously evaluated; or (2) creat.e the possibility of a new or dif ferent kind of accident from any accident previously evaluated; or (3) involve a significant L
reduction in a margin of safety.
3.
Entergy Opnrations has nvaluated thn no significant hazards considerations in it.s request for a license amendment.
In accordance with 10CFR50.91(a), Entergy Operations is providing
[
the analysis of the proposed amendment.against the threo standards in 10CFR50.92:
n.
No significant increase in the probability or consequences of an accident previously esaluated rnsults from this changn.
(1)
The relocation of the existing procedural requirements of the current, TS-for radioacttvc offluents, radiological environmental monitoring and solid radioactive wastes to the ODCM or t.hn PCp, an appropriato, and the addition of administrativo controls for thene 'rnlocat.od requirnments will not reduco the requirements associated with the exist.ing TS.
G9105141/SNLICFhR - 17
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~(2)
This chanan will not impact plant design _ or the operation of plant systems.
Ilenen, thn'snmo degren of equipment.tollability is maintained and the probability of a prov.f ously annlyzod accident is not increased.
(3)
Since the proposed chango does not. require thn modification of equipment _ designed to mitigatn the ovents of an accident, thn consequences of an accident niready cynlunted will not change.
(4)
Therefore, the probability or consequences of previously analyzed accidents are not incronsed.
.b.
The changn-would not' create the possibility of a new or-di f ferent kind of accident - f rom _any previously analyzed.
(1)
Thn proposed chango will not requirn tho addition,-
dolotion or modification of any plant hardware and no new modes of plant opernt.f on or testing nrn introduced, f
(2)
The method by_which any safety-rnlat.ed system performs its function will_not be changed.
In addition, the methods for verifying component or system operability will not chango.
(3)
The relocation of thn RETS to t.hn ODCH or the PCP will not reduce the controls on radlological offluents and-any changes to the ODCM or the PCP will.be accomplished in accordance with the
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administrativo controls added to TS.
(4)
Thnreforn, operating the plant. with t.ho proposed chanan will not create the possibility of a new or dif ferent kind of accident from any accident previously cynlunted.
l' c.
This change would not involyn a significant rnduction in tho margin of sa fety.
(
('
j-(1)
This chango will~not chango any existing l'
rodlological limits. All techoical content of thn-b current TS will be preserved'when the procedural dotnils are rolocated to the ODCM or the PCP, Administrativo controls are added to TS to ensure that futurn changen to thn ODCM nnd the PCP de not -
result in a reduction to the margin of safety associated with those limits.
G9105141/SNI.ICFLR - la
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(2)
The propossul chnnges do not affeet the methodology used in the offsite dose annlysis nor the nceeptance criterin associnted with any accident annlysis.
(3)
Therefore, this change will not involve a reduction in the margin of safety.
4.
Based on the above evaluntion, operation in accordance with the proposed amendment involver. no significant hnzards c on s id o r n t. i on s,
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i G9105141/SNLICFI.R - 19
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