ML20084U584
| ML20084U584 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/12/1991 |
| From: | Myers T, Shelton D CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20084U579 | List: |
| References | |
| GL-89-01, GL-89-1, NUDOCS 9104190306 | |
| Download: ML20084U584 (13) | |
Text
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Docket Number 50-346-Licenso Number NPF-3 ,
Serial Numb 3r 1815' Enclosure-Page 1 APPLICATION FOR AMENDHENT TO I
-i FACILITY OPERATING LICENSE NUMBER NPF-3 1 DAVIS-BESSE NUCLEAR POWER STATION.
UNIT NUMBER 1
.i Attached is a requested change to the Davis-Besse Nuclear Power Station Unit
= Number 1 Facility Operating License Number HPF-3 Appendix A Technical
-Specifications. Also included are the Safety Assessment and'Significant Hasards Consideration and a copy of the offsite Dose Calculation Manual-which i has been revised to reflect the requested change, j p The preposed' change.(submitted under cover letter Serial Number 1815) concerns
-Relocation of Radiological Effluent Technical Specifications to the Offsite Dose Calculation Manual and Process Control Program.
For D. C. Shelton. Vice President Nuclear l
By: ([ II7Technical Services T. J. My Di re c to r. _
i Sworn and subscribed before me this 12th day of< April, 1991, cb.2?hh] Y /?O Notary Puylic. State of Ohio EVEl.YN L DRESS -
MfYPUBUC.STATEOF0H10
%ConsiusdonbpresMyse,tges 9104190306 910412 PDR ADOCK 050^O346 P PDR
Docket tiumber 50-346 License Number NPF-3 Serial Number 1815 Enclosure Page 2 The following information is provided to support issuance of the requested change to the Davis-Besse Nuclear Power Station, Unit Number 1 Operating License, !! umber NPF-3. Appendix A, Technical Specifications.
A. Time required to implement This change is to be implemented within 45 days following issuance of the amendment by the NRC.
B. Reason for change (License Amendment Request Nuraber 90-0023): HRC Genetic Letter 89-001 dated January 31, 1989, recommends relocation of the procedural details included in the current Radiological Effluent Technical Specifications (RETS) to the Offsite Dose Calculation Manual and Process Control Program. Future changes to the relocated RETS requirements will be made by the licensee in accordance with the proposed administrative controls without prior NRC approval.
C. Safety Assessment and Significant llazards Considerationi See Attachment 1.
D. Revised offsite Dose Calculation Manual: A copy of the revised Offeite Dose Calculation Manual reflecting the telocation of RETS procedural details f rom Technical Specir'1 cations is attached for information, as requested by Generic Letter 89-001. (Attachment 2).
Docket flumber 50-346 License Number NPF-3 Serial flumber 1815 l Attachment 1 Page 1 SAFETY ASSESSMENT At!D SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AHL!!DMEllT REQUEST 90-0023 TITLE:
Implementation of Programmatic controls for Radiological Effluent Technical Specifications (RETS) and Relocation of RETS Procedural Details to the Offsite Dose Calculation Manual (ODCM) and Process control Program (PCP)
DESCRIPTIOHi The proposed change would revise the Davis-Desse Nuclear Power Station (DBHPS)
Unit 1, Operating License HPF-3, Appendix A, Technical Specifications (TS) to relocate the procedural details of the current RETS to the Offsite Dose Calculation Manual (0DCM) and Process Control Program (PCP). New programmatic controls are added to the TS Section 6.0, Administrative Controls, to satisfy existing regulatory requirements for RETS.
The proposed change is consistent with the guidance provided by the Nuclear Regulatory Commission's January 31, 1989 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 RETS to the Offsite Dose Calculation Manual or to the Process Control Program (Log flumber 2824). Table 1 summarizes the disposition of RETS requirements affected by this change.
Copies of the affected TS sections marked up to illustrate the changes are attached.
IIRC Generic Letter 89-01 provides the basis for relocation of RETS requirements to the ODCM and PCP. Relocation of the procedural details of the current RETS is a line item improvement resulting from the Commission's Policy statement for the Technical Specifications Improvement Program (TSIP). As part of Technical Specifications Improvement Program, the HRC defined criteria to be used in determining which requirements merit inclusion in Technical Specifications. The RETS, in general, do not satisfy the criteria for inclusion in Technical Specifications. However, 10 CFR 50.36a requires Technical Specifications for radioactive effluents from nuclear power reactors. The programmatic controls on effluents being added to Section 6.0, Administrative Controls, in accordance with Generic Letter 89-01 have been determined by the llRC to satisfy 10 CFR 50.368, 10 CFR 20.106, 40 CFR Part 190 and Appendix I to 10 CFR Part 50.
SYSTEMS, COMPONENTS AllD ACTIVITIES AFFECTED The proposed change involves radioactive 11guld, radioactive gaseous and solid radwaste treatment systems, radioactive liquid and gaseous effluent monitoring instrumentation, administrative controls en releases of radloactive waste from the plant, and monitoring of the impact of releases of radioactive material on the environment. flo hardware changes are involved. The proposed change affects only the relocation of procedural details of RETS and places them in the ODCH and PCP. Changes to the ODCH and PCP will be controlled by the Administrative Controls Section of TS. No changes to existing requirements are made by this proposed license amendment request.
Docket flamber 50-346 License Humber NPF-3 Serial Humber 1815 Attachment 1
, Page 2 l
SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS AND ACTIVITIESt The function of the radioactive liquid and gaseous radwaste treatment systems are to maintain the doses committed to individuals from offsite releases within regulatory limits, and the releases of radioactive materials in these effluents as low as reasonably achievable (ALARA). Radioactive liquid and gaseous radwaste treatment systems and effluent monitoring instrumentation, sampling and analysis requirements, and the radiological environmental monitoring program, provide the means for controlling, monitoring, quantifying, and assessing the effects of radioactive releases. The solid radweste treatment systems ensure that solid radwaste is prepared in accordance with regulatory requirements for transportation and disposal at a low level radioactive waste facility. The function of the RETS procedural details are to control the performance of these activities.
EFFECTS OH SAFETY:
The principle effect of this change is on the degree of regulatory control for future changes to current RETS requirements. Currently, even minor changes to existing RETS requirements included in Technical Specifications require prior HRC teview. approval, and issuance of a license amendment. This amendment request will transfer procedural details of the current RETS for radioactive liquids and gaseous effluents, and the environmental monitoring program to the ODCH and will transfer procedural details for solid radioactive waste requirements to the PCP, General programmatic requirements for radioactive liquid and gaseous effluents, and the radiological environmental monitoring program are being added to TS 6.0.4, Procedures and Programs, as 6.8.4,d,
' Radioactive Effluent Controls Program', and 6.8.4.e. "Rediological Environmental Monitoring Program".
Future changes to the PCP and ODCH, including the relocated RETS requirements, will be made in accordance with TS 6.14, Process Control Program, and 6.15, Offsite Dose Calculation Manual, respectively. These TS sections require ODCH and PCP changes to be documented with sufficient information to suppoct the change including appropriate analysis or evaluations to justify the changes.
In addition, for PCP changes, the documentation shall include a determination that the change will maintain the overall conformance of solidified waste products to existing Federal, State or other applicable regulations. For ODCH changes, the documentation shall include a determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR 190, 10 CFR 50.36a and 10 CFR 50 Appendix I, and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.
Changes to the PCP and ODCH shall become effective after review and acceptance by the Station Review Board (SRB) and approval of the Plant Manager. ODCH changes will continue to be submitted to the HRC with the Semlannual Radioactive Effluent Release Report for the period during which ODCH changes were made.
1
Docket Number 50 546 bicense Number NPF-3 Serial Number 1815 AttachmentlL Page 3 Certain existing RETS' requirements are retained in Technical Specifications.
These include definitions of RETS related terms which continue to be used in Technical Specifications operability and surveillance requirements for Waste Gas System explosive gas monitoring instrumentation, 11mits on the quantity oi radioactive material which may be contained in certain liquid holdup tanks, limits on oxygen concentration in the Waste Gas System, and progransnatic administrative controls governing radiological effluents and environmental j monitoring.- Editorial changes have been made to the retained requirements to i maintain consistency in format.and to accommodate sections which have been deleted.
The relocation of existing REfS procedura. details to the ODCH and PCP does not alter existing technical-requirements. The programmatic controls defining the elements of the Radioactive Effluents Controls Program and the Radiological Environmental Honitoring Program require the licensee to reconcile future
-changes to the_PCP and ODCH with_the same regulatory standards that the NRC currently'uses as a basis for acceptance of RETS changes. Puture hardware modifications or procedure changes which formerly would have involved NRC review of changes to RETS requirements will continue to be evaluated in-accordance with 10 CFR 50.59. Consequently, it is determined that the _l proposed relocation of RETS procedural details does not have a significant '
impactoon safety. There. exist adequate TS programmatic controls that govern changes to the.PCP and ODCH.
SIGNIFICANT HAZARDS CONSIDERATION:
The Nuclear _ Regulatory Commission has provided standards in 10 CFR 50.92(c) i for determining whether a significant hazard exists due to a1 proposed ll amendment to an Operating bicense for a facility. A proposed amendment involves _no significant hazards consideration-if operation of the. facility in -l accordance with-the proposed change 90uld l(1) Not involve a significant '
increase.in.the probability or consequences'of an accident-previously evaluated: -(2) Not create the possibility of a new or different kind of 'l accident from any accident previously evaluated 0_or (3)_Not involve a l E significant reduction in a margin of safetyv 1 Toledo Edison has reviewed'the proposed change and determined that.the proposed change does not-involve a significant hazards consideration because operation of the Davis-Besse Nuclear Power Stat'lon, Unit No._1 ~in accordance with this change _would: I la. Not involve a-significant increase in the' probability of an-accident previously evaluated because the proposed change does not involve any changes to the configuration of the plant,-its operation and maintenance ~,
or. change any existing requirements governing -the amounts or types of radioactive material permitted to be released from the site. The principle effect.of the' proposed change is to transfer the review of most-future changes to RETS requirements from the NRC to the licensee.
Existing RETS requirements, which establish initial conditions or' prevent
.previously evaluated accidents are unaffected by this proposed change and remain in. Technical Specifications. Technical Specifications for the Waste: Gas System oxygen monitor and explosive gas mixture concentration )
limits are retained. The requirements are intended to prevent a hydrogen explosion frem rupturing the waste gas system. .
Docket Humber 50 346 License Humber HPF-3
- Serial Humber 1815 Attachment 1 Page 4 For RETS requirements which are relocated to the ODCH and PCP. changes can be made without prior NRC approval. However, Technical Specifications require the licensee to review such changes against the same' regulatory requirements as the HRC would use in reviewing license amendment requests. This limitation on the scope and flexibility of licensee changes to former RETS requirements ensures that any future
_ changes will not significantly affect the probability of any previously analyzed accident. Furthermore, any changes which formerly would have-required HRC-review and approval of a change to the RETS will continue to be subject to the requirements of 10 CFR 50.59.
Ib. Not involve a significant increase in the consequences of an accident previously evaluated because the proposed change does not involve any changes to the configuration of the plant or any existing requirements governing the amounts or types of radioactive material permitted to be released from the_ site. The principle effect of the proposed change is to transfer the review of most future changes to RETS requirements.from the HRC to the licensee. Fxisting restrictions which limit the consequences of postulated accidents are unaffected by this proposed Echange. Existing requirements limiting the inventory _of temporary 11guld holdup tank are' retained in Technical Specifications. These restrictions on the liquid holdup tank inventory limit the offsite dose consequences from a 11guld holdup tank failure. The consequences of this event are unaffected by the proposed change.
Technical _ Specifications require.that future changes to former RETS requirements which are transferred to the ODCH and PCP be reviewed by the licensee against the same regulatory standards as the Hhc would use in
_ reviewing license-amendment requests. This limitation on the scope and L,
flexibilitycof licensee changes to former RETS requirements ensures that future changes will not_significantly affect the consequences of any previously analyzed accidents. Furthermore, any hardware or procedure changes which'formerly would have required NRC review and approval of a change to the RETS will continue to be subject.to the requirements of 10.CFRJ50,59.
2a. Not' increase the possibility.of a new kind of accident from any accident previously evaluated, because the proposed change does not involve any hardware changes or change any existing requirements for the release of
, radioactive liquid, gaseous, or solid waste-from the site. Future changes to hardware or procedures used to implement former RETS requirements willicontinue to be ' eubject. to. the requirements of-10 CFR 50.59. Consequently, any such changes will individually require a finding:that the possibility of a new kind of accident from any accident g previously_ evaluated is not created, 2b. Not create the possibility of a different kind of accident from any accident previously evaluated because the proposed change does not
, involve any-hardware changes or change any existing requirements for radioactive releases from the plant. Future changes to hardware or procedures which implement former RETS requirements will continue- to be subject to the requirements of 10 CFR 50.59.
l-
Docket Humber 50-346 License Humber NPF-3 Serial Humber 1815 y Attachment 1 Page 5
- 3. Hot involve a significant reduction in a margin of safety because the Technical Specifications will require that tuture changes to former RETS requirements which are transferred to the ODCH and PCP, be reviewed against the same regulatory standards (for example, 10CFR20.106, 40CFR Part 190, 10CFR50.36a and 10CFR50 Appendix 1) as the HRC would use in reviewing license amendment requests. This limitation on the scope of licensee changes to former RETS requirements assures that future changes will not significantly affect a margin of safety.
CONCLUSIGH On the basis of the above, Toledo Edison has determined that the License Amendment Request involves no significant hatards consideration. As this License Amendment Request concerns a proposed change to the Technical Specifications that must be reviewed by the Nuclear Regulatory Comraission, this License Amendment E=ouest does not constitute an unreviewed safety question.
Attachment Attached is a table identifying the disposition of affected Technical Specifications and the proposed marked-up changes to the af f ected Technical Specifications.
Docket Number 50-346 License ilumber NPF-3 Serial Number 1815 Attachment 1 Page 6 TABLE 1 Disposition of RETS Requirements Affected by LAR 90-0023 E SPECIFICATION TITLE DISPOSIT1011 1.29 Source Check Relocated to ODCM. Term is no longer used in Technical Specifications.
1.30 Process Control Program kevised consistent with GL 89-01 1.31 Solidification Relocated to PCP. Term is no 1.onger used in Technical Specifications.
1.32 Offsite Dose Calcu- Revised consistent with GL 89-01 lation Manual 1.33 Gareous Radwaste Relocated to ODCH. Term is no Treatment System longer used in Technical Specifications.
1.34 Ventilation Exhaust Relocated to ODCM. Term is no Treatment System longer used in Technical Specifications.
1.35 Purge-Purging Relocated to ODCH. Term is no longer used in Technical Specifications.
1.36 Venting Reloceted to ODCH. Term is no longer used in Technical Specifications.
1.40 Dewatering Relocated to PCP. Term in no longer used in Technical Specificat.lons.
Table 1.2 Frequency llotation tiotation "P' deleted. This frequency is no longer used in Technical Specifications . The frequency notations used in sutveillance requirements relocated to the ODCil are defined in the ODCil consistent with the existing Table 1.2.
3/4.3.3.9 Rauivactive Liquid Relocated to the ODCll.
Effluent Monitoring Programmatic controls Instrumentation incorporated in TS 6.8.4.d.1.
Docket Number 50-346 License Humber NPF-3 Setlal Humber 1815 Page 7 TABLE 1 (Continued)
Disposition of RETS Requirements Affected by LAR 90-0023 SPECIFICATION TITLE DISPOSITION 3/4.3.3.10 Radioactive Ganeous Renumber-d as TS 3/4.3.3.9 and Effluent Monitoring retitled as ' Waste Gas System Instrumentation oxygen Monitor.' Existing requirements relating to the waste gas system oxygen monitor used for explosive gas monitoring are retained in TS in accordance with GL 89-01. Other tadioactive gaseous effluent monitoring instrumentation requirements are relocated to the ODCH.
Programmatic controle governing effluent monitoring instrumentation are incorporated in TS 6.8.4.d.1.
3/4.11.1.1 Liquid Effluents- Relocated to the ODCH.
Concentration Progra amatic controls governing concentration and sampling and analysis requiremento are incorporated in TS 6.8.4.d.2 and TS 6.8.4 d.3.
3/4.11.1.2 Dose Relocated to the ODCH.
Programmatic controle limits on dose commitmente to members of the public in unrestricted areas incorporated in TS 6.8.4.d.4 and TS 6.8.4.d.5. Figure 3.11-1 is relocated to TS Section 5. Design Features, as Figure 5.1-3 referred to by TS 5.1.3.
" Site Boundary." consistent with Generic Letter 89-01 guidance.
3/4.11.1.3 Liquid Redwaste Relocated to the ODCH.
Treatment System Programmatic controls governing the operability and use of liquid effluent treatment systems are incorporated in TS 6.8.4.d.6.
3/4.11.1.4 Liquid Holdup Tanks Existing Specification is retained but tenumbered on 3/4.11.1.
Docket Number 50 346 License Number llPF.3 '
I Serial Number 181$ l Attachment 1-Page 8 TABLE 1 (Continued)
Disposition of RETS Requirements Af fected by LAR 90 0023 1
SPECIFICATION TITLE DISPOSITION 3/4.11.2.1 Gaseous Effluents. Relocated to the 0DCH. l Dose Rate Programmatic controle governing i offsite dose rates sie included in TS 6.8.4.d.3 and TS 6.8.4.d.7.
314.11.2.2 Gaseous rifluents Relocated to the ODCH.
Dose.Hoble cases Programmatic controle governing noble gas doses are incorporated in TT 6.8.4.d.$ and TS 6.8.4.d.8.
Figure 3.11 2 is relocated-to T.S. Section 5. Design Features, as Figure 5 1 4 referred to by TS 5.1.3, " Site Boundary * !
consistent with Generic Letter ;
89 01 guidance. l 3/4.11.2.3 Dose. Iodine.131, Relocated to the ODCH. ,
Tritium and Radio. Prograinmatic controls are "
r nuclides in . incorporated in TS 6.8.4.d.$ and Particulate Form TS 6.8.4.d.9.
3/4.11.2.4 Caseous Radwaste Relocated to the 0DCH.
Treatment System Programmatic controls governing-operability and use of gaseous ;
radwaste-treatment systems are
. included in TS b.8.4.d.6.
3/4.11.2 5 T,xplosive' Gas ' Retained in Technical
.Hixture- Specifications as:TS 3/4.11 2.to accommodate relocation of'other specifications from Section 3/4,11.
3/4.11.3 Solid Radioactive Relocated to-the PCP. :TS 6.14- !
Waste- establishes controis for changes to the PCP.
H- f3/4.11.4 Total Dose- Relocated to the ODCM.
Programmatic controls governing annual dese or-dose' commitment to
.a member of the public are= l included in TS 6.8.4.d.10.
q 3/4.12.1 Radiologieri Environ- Relocated to the ODCl!.
mental Monitoring ~ Programmatic controls governing
-Program monitoring'. sampling, analysis:
and reporting of radiation and.
radionuclides in the environment ;
are included in TS 6.8.4.e'.1. i a
Docket Number 50 346 )
License Number NPF.3
- 1
) Serial Number 1815 )
Attachment I l I
l' age 9 ,
TABLE 1 (Continued) ;
Disposition of Rl"TS Requirementa Affected by ,R 90 0023 SPECI T ICA,T10tl TITLE QPOSITION 3/4.12.2 Land Use Census R4 located to the ODCM.
Programmatic controls requiring a +
land use census and appropriate changes to the radiological :
environmental monitoring program are incorporated in TS 6.8.4.e.2.
3/4,12.3 Interlaboratory Relocated to the ODCH.
Comparison Program Programmatic controle requiring participation in an :
interlaboratory comparison program are incorporated in
. TS 6.8.4.e.3.
B3/4.3.3.9 Radioactive Liquid Deleted.
Effluent Honitoring ?
Instrumentation B3/4.3 3.10-
. Radioactive G.teous Renumbeted an B3/4.3.3.9'and
. Effluent instrumenta- retitled ' Waste One System '
tion Oxygen Monitor.' Revised to reflect function of Waste cas System Oxygen Honitor for which TS requirements are retained.
- B3/a.11.1 Liquid Effluents On'ly. bases for Liquid lloldup Tanks (formerly B3/4.11.1.4) is retained and renumbered as B3/4.11.1. All other Liquid Effluent bases are deleted. -
~
.B3/4.11.2 Gaseous-Effluents Only bases-for Explosive Gas niat9te (formerly B3/4.11.2.$) 18--
retained end-renumbered as B3/4.11.2. All other Gaseous. #
. Effluents bases are deleted. .
. -t B3/4.11.3. Solid Radioactive . Deleted.
Weste B3/4'.11.4 ' Total Dose Deleted.
~
B3/4.12 Radiological Enviren- Deleted. .
mental Monitoring 5.143 Design Features:- T6.5.1.3 is added to define the t- Site Boundary unrestricted area and site boundary for radioactive liquid
, u...-._-. - . - _ _ . - . . . . -...=_----.._.---._..---.a_.-_. . . _ .
Docket Number $0 346 )
License Number HPF.3 Seriol Humber 1815 Attachment 1 Page 10 TABLE 1 (Continued 1 Disposition of RETS Requirements Affected by 1.AR 90 0023
- SPECIFICATION TITLE DISPOSITION effluent and radioactive gaseous effluents as shown on Figure 5.1 3 (formerly Pigure 3.11-1) ,
and Figure 5.1-4 (formerly Figure !
3.11-2). j 6.0.4 Procedures and New sections 6.0.4.d ' Radioactive ;
Programs Effluent Controls Program.' and l 6.8.4.e. ' Radiological Environmental Honitorjng Program', are incorporated as
' recommended by GL 09-01, to establish program elements to be addressed-in the ODCH. and to satisfy 10 CFR.50.36a requirements for RETS.
6.9.l.10- Annual Radiological Requirements are simplified ~to I Environmental be consistent with GL 89 01.
Operatin6 Report Reporting detalla are relocated ]
to the ODCH.
~
l 6.9.1.11- Semiannual Radioactive Reporting details are relocated Effluent Release' to the ODCH. Retained Report requirements are simplified to be consistent with GL 69 01.
=
6.9.2 Special Reports 6.9.2.g through'6.9.2.m are I deleted because referenced TS l sections:are relocated to the l ODCH and removed-from TS.
Requirements for special reports are relocated to the-0DCH.
6.10- Records Retention 6.10,2.p is added requiring that records of reviews performed for l changes made to the ODCH and PCP be retained for the duration of l I
the license.
. . i 6.14 Process Control Revised to be consistent with.
Program (PCP) GL 89 01 controls for-changes-to-the PCP, Adds a requirement for l Plant Manager approval of changes in addition to SRB acceptance. .
t l?
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Docket Number $0 346 1.Acense Number NPF-3 Setlal 14 umber 1815
- Attachment-1 Page 11 TAltLE 1 (Continued)
Disposition of RETS Requirements Affected by 1.AR 90-0023 SPECIFICATION TITLE DISPOSITION 6.15 Offsite Dose Calcu. Revised to be consistent with lation Manual (ODCH) GL 89 01 controls for changes to the ODCH. Adds a requirement for Plant Manager approval of changes in addition to $RB acceptance. l 6.16 Hajor changes to Relocated to ODCH and PCP.
Radioactive Liquid, Gaseous and Solid Weste Treatment Systems, t
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