ML20085D490
ML20085D490 | |
Person / Time | |
---|---|
Site: | Calvert Cliffs ![]() |
Issue date: | 06/09/1995 |
From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
Shared Package | |
ML20085D493 | List: |
References | |
GL-89-01, GL-89-1, NUDOCS 9506160251 | |
Download: ML20085D490 (9) | |
Text
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dy Rostar E.Dswrom Baltimore Gas and Electric Company
[.q Vice President Calvert Cliffs Nuclear Power Plant M
'fi Nuclear Energy 1650 Calvert Cliffs Parkway fS; Lusby, Maryland 20657 410 586-2200 Ext.4455 local
.jy 410 260-4455 Baltimore E.
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+y U. S. Nuclear Regulatory Commission 7;
Washington, DC 20555 M
ATTENTION:
Document Control Desk 5d
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SUBJECT:
Calvert ClifB Nuclear Power Plant
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Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 M
License Amendment Request; Implementation of Changes to the Radiological
!j Effluent Technical Specifications as Protv -M by Generic Letter (GL) 89-01 Cyo
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Pursuant to 10 CFR 50.90, the Baltimore Gas and Electric Company (BGE) hereby requests an f
Amendment to Operating License Nos. DPR-53 and DPR-69 by incorporating the changes described below
.x into the Technical Specifications for Calvert Cliffs Units 1 and 2.
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'$-h.j DESCRIPTION N
${ l This amendment request proposes to revise the Calvert Cliffs Nuclear Power Plant Radiological Effluent ff Technical Specifications (RETS) consistent with Generic Letter (GL) 89-01, Reference (a), and the R/
Improved Standard Technical Specifications for Combustion Engineering Plants published in g
NUREG-1432, Reference (b), as modified by Mr. W. T. Russell's letter of October 25,1993 (the Russell pl letter), Reference (c).
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.m Changes for relocating the procedural details of the current RETS to the Offsite Dose Control Manual 1
(ODCM) have been prepared in accordance with the proposed changes to the Administrative Controls h.D section of the Technical Specifications. A draft copy of the revised ODCM is attached for use as a reference. A final copy will be submitted as an attachment to the Radiological Efiluent Release Report M'
after the revised ODCM is approved.
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Document Control Desk i
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BACKGROUND The. "NRC Interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," published on February 6,1987 (52 FR 3788), proposed criteria for defining the scope of the Technical Specifications. He policy envisioned that many existing Technical Specification requirements could be relocated to other more appropriate programs and documents which would then be controlled by present regulations (e.g.,10 CFR 50.54 and 10 CFR 50.59). He relocation would result in more concise TechnicA Specifications focusing on the most safety significant requirements.
In relation w the Policy Statement, the Nuclear Regulatory Commission (NRC) staff examined the contents of the RETS. In GL 89-01, the staff stated that progmmneatic controls can be implemented in the 1
Administrative Controls section of the Technical Specifications to satisfy existing regulatory requirements for RETS. At the same time, the procedural details of the current Technical Specifications on radioactive r
l effluents and radiological environmental momtoring can be relocated to the ODCM. Likewise, the procedural details of the current Technical Specifications on solid radioactive wastes can be relocated to the Process Control Program (PCP). As proposed in GL 89-01, these actions simplify the RETS, meet the regulatory requirements for radioactive effluents and radiological emironmental monitoring, and are c
provided as a line-item improvement of the Technical Specifications, consistent with the goals of the Policy I
Statement.
NUREG-1432 was also based on the Policy Statement. Following publication of NUREG-1432, the NRC i
proposed in the Russell letter that significant reductions to the Administrative Controls section of the f
Standard Technical Specifications be made to climinate duplication with other requirements. In our Administrative Controls submittal (Reference d), BGE submitted a License Amendment Request implementing the majority of the Improved Standard Technical Specifications format for the Administrative Controls section and relocating present Technical Specification requirements to the appropriate BGE programs and documents. Hat License Amendment Request is consistent with NUREG-1432 and the Russellletter.
The License Amendment proposed in this letter follows the guidance provided in GL 89-01, except when superseded by NUREG-1432 or the Russell letter. In all such cases, our Administrative Controls submittal is consistent with the latest guidance, and this License Amendment Request is consistent with that submittal. Deviations from the guidance provided in GL 89-01, as described below, are identified by the Technical Specification numbers from GL 89-01, followed by the corresponding Calvert Cliffs Technical Specification number, and the proposed Technical Specification number from our Administrative Controls submittal in parentheses, when applicable.
GL 89-01, Specification 1.17 / CCNPP Technical Specification 1.19 (6.6.2) ne ODCM dermition in GL 39-01 addresses the " Semi-annual Radioactive Efiluent Release l.
Report." However, in accordance with 10 CFR 50.36a (a)(2) and NUREG-1432, this report is
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now submitted on an annual basis; therefore, the title of this report is changed to " Radioactive Effluent Release Report." Also, as discussed below, GL 89-01 proposed that the Technical Specifications include a requirement that the Radiological Environmental Monitoring Program be contained within the ODCM. NUREG-1432 eliminated this proposed requirement; therefore, the change recommended by GL 89-01 has not been included.
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Document Control Desk June 9,1995 Page 3 GL 89-01, Specification 1.22 / CCNPP Technical Specification 1.24 GL 89-01 proposed a revised definition of the PCP. However, the rccommendation to delete the definition of the PCP, and the PCP control requirements, from the Technical Specifications was later made by the Russell letter; therefore, the PCP definition is deleted by this letter.
GL 89-01, Specification 3/4.11.2.5 / CCNPP Technical Specification 3/4.11.2.5 GL 89-01 recommended retaining the existing specification requirements for explosive gas mixture monitoring. However, the Surveillance Requirements were detailed in Table 4.112, which was to be deleted by GL 89-01. 'nerefore, the specific text in Table 4.11-2 relating to explosive gas mixture monitoring was relocated to the Surveillance Requirement such that the table may be deleted.
GL 89-01, Specification 6.8.4.g / CCNPP Technical Specification 6.18 (6.5.5)
GL 89-01 recommended references to 10 CFR Part 50, Appendix 1 and 40 CFR Part 190 for the initiation of remedial actions per the Radioactive Effluent Controls Program. However, specific program limits have already been specified in Section 3.11 of the Technical Specifications; therefore, the description of the Radioactive EfRuent Controls Program has been revised to include our existing action limits, when applicable.
Additionally, GL 89-01 addressed " limitations on the operability" of systems and components, but NUREG-1432 revised this tenninology to " limitations on the functional capability."
NUREG-1432 also made several editorial changes to the program requirements presented in GL 89-01, without affecting the intent of this Specification. The changes proposed in this letter include the revised terminology and editorial changes proposed in NUREG-1432.
GL 89-01, Specification 6.8.4.h GL 89-01 proposed the addition of a specification entitled " Radiological Emironmental Monitoring Program." This proposed specification was subsequently deleted by the Russell letter; therefore, the change recommended by GL 89-01 has not been included.
GL 89-01, Specification 6.9.1.3 / CCNPP Technical Specification 6.9.1.7 (6.6.2)
GL 89-01 proposed the addition of a Specification for the submittal of the Annual Radiological Environmental Operating Report. A more detailed description of the information to be prosided in the Annual Radiological Emironmental Operaung Report, as provided in NUREG-1432, is proposed by this letter.
GL 89-01, Specification 6.9.1.4 / CCNPP Technical Specification 6.9.1.8 (6.6.3)
As discussed previously (GL 89-01, Specification 1.17), the periodicity for the Radioactive Efiluent Release Report, as required by 10 CFR 50.36a(a)(2), has been revised to annually; therefore, the Russell letter revised this specification to refer to 10 CFR 50.36a directly, rather
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Document Control Desk June 9,1995 Page 4 than paraphrase the wording in that section of the Code. Additionally, for consistency with our Administrative Controls submittal, this letter proposes revising Specification 6.9.1.8 to relocate requirements for reporting major changes to the Radioactive Waste Systems from Technical Specification 6.18 and to include changes to the ODCM, in accordance with Specification 6.17.2.c (6.5.1.c).
GL 89-01, Specification 6.10 / CCNPP Technical Specification 6.10.2.m GL 89-01 proposed adding documentation associated with the ODCM and PCP to the list of records required to be retained for the duratiot. of the unit Operating License. However, the I
Russell letter deleted the entire Record Retention Section of the Technical Specifications; therefore, the change recommended by GL 89-01 has not been included.
GL 89-01, Specification 6.13 / CCNPP Technical Specification 6.16 GL 89-01 proposed the incorporation into the Technical Specifications of review and approval l
l requirements for changes to the PCP. Ilowever, as these process requirements can be adequately controlled by plant procedures, the Russell letter proposed elimination of the PCP control requirements from the Technical Specifications; therefore, the change proposed by GL 89-01 has not been included.
GL 89-01, Specification 6.14 / CCNPP Technical Specification 6.17 (6.5.1.c)
GL 89-01 proposed the incorporation into the Technical Specifications of review and approval requirements for all ODCM changes. However, NUREG-1432 clarified that this requirement only applies to licensee-initiated changes; therefore, the ODCM review and approval requirements proposed by this letter also apply only to licensee-initiated changes.
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In addition to other deviations from GL 89-01 described above, references to 10 CFR 20.106 were l
revised to 10 CFR 20.1302, which agrees with the current revision of the Code of Federal Regulations.
REOUESTED CIIANGE Change the Technical Specifications and Bases for CcRert Cliffs Nuclear Power Plant Units 1 and 2 as shown on the attached marked-up pages contained in Attachments (1) and (2). The attachments also include changes to the Technical Specification Bases pages required to maintain consistency with the proposed Technical Specification changes.
SAFETY ANALYSIS Currently, procedural details for the RETS, consisting of the Limiting Conditions for Operation, their applicability, remedial actions, and Surveillance Requirements are located in Technical Specifications 3/4.11, Radioactive Effluents, and 3/4.12, Radiological Environmental Monitoring, and their
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June 9,1995 Page 5 Bases section. The most significant ponion of this change involves relocating the procedural details from these Specifications to the ODCM. Attachment (3) contains a draft copy of the revised ODCM, which was prepared following the requirements of proposed Specifications 6.1.7a.(1) and (2). The programmatic controls necessary to ensure that changes to the ODCM maintain the level of radioactive emuent control required by 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a, and 10 CFR Part 50, Appendix 1, will be included in Technical Specification 6.18, Radioactive Effluent Controls Program.
Since sufficient regulatory controls exist for the ODCM, relocating the requirements from the Technical Specifications to the ODCM provides an appropriate level of control so that the proposed relocations will not impact plant i
safety. Similarly, requirements which are contained in plant procedures controlled by our procedure change control process will provide adequate control to ensure plant safety.
The proposed changes do not decrease requirements and provide an appropriate level of change control for relocated requirements so that plant safety remains unaffected. The changes proposed by this amendment request will provide programmatic controls for RETS consistent with regulatory requirements and allow relocation of the procedural details of current RETS to the ODCM. Therefore, future changes to these procedural details will be governed by the controls for changes to the ODCM included in the Administrative Controls section of the Technical Specifications. All requirements relocated from the Technical Specifications have been evaluated with respect to the four criteria of the NRC " Final Policy Statement On Technical Specification Improvements," and found to meet none of the criteria for inclusion in the Technical Specifications. The proposed changes result in Technical Specifications which focus on the most important requirements without sacrificing safety.
DETERMINATION OF SIGNIFICANT IIA 7,ARDS The proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendments:
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Would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes will provide human factor improvements for the Technical Specifications by 1
relocating existing procedural details of the current Radiological Effluent Technical Specifications to the OfTsite Dose Control Manual (ODCM). Procedural details for solid radioactive wastes will be relocated to the Process Control Program. The proposed amendment (1) incorporates programmatic controls in the Administrative Controls section of the Technical Specifications that satisfy the requirements of 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a,10 CFR Pan 50, Appendix I, and our current Technical Specifications; (2) relocates the existing procedural details in current specifications involving radioactive emuent monitoring instrumentation, the control of liquid and gaseous emuents, equipment requirements for liquid and gaseous emuents, radiological environmenta' monitoring, and radiological reporting details from the Technical Specifications to l
the ODCM; (3) simplifies the associated reporting requirements; (4) simplifies the administrative controls for changes to the ODCM; and (5) updates the definitions of the ODCM consistent with these changes.
Document %wol Desk June 9,1995 Page 6 Relocating existing requirements and eliminating requirements which duplicate regulatory requirements provide Technical Specifications which are easier to use.
Because existing requirements are relocated to established programs where changes to those programs are controlled by regulatory requirements, there is no reduction in commitment and adequate control is still maintained. Likewise, the elimination of requirements which duplicate regulatory requirements erhances the usability of the Technical Specifications without reducing commitments. The additional improvements being proposed neither add nor delete requirements, but merely clarify and improve the readability and understanding of the Technical Specifications.
Since the requirements remain the same, these changes only affect the method of presentation, and as such, would not affect possible initiating events for accidents previously evaluated or any system functional requirement.
Furthermore, no safety-related equipment, safety function, or plant operation will be altered as a result of this proposed change. The changes are unrelated to the initiation and mitigation of accidents and equipment malfunctions addressed in the Updated Final Safety Analysis Report.
Therefore, the proposed changes do act ir. olve a significant increase in the probability or consequences of an accident previously evaluated.
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Would not create the possibility of a new or dferent type of accident from any accident previously evaluated.
Transferring the procedural details of radiological effluent monitoring and reporting from the Technical Specifications to the ODCM has no impact on plant operation or safety. No safety-related equipment, safety function, or plant operation will be altered as a result of this proposed change. No changes to plant components or structures are introduced which could create new accidents or malfunctions not previousiv evaluated.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
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Would not imelve a sigmficant reduction in a margin ofsafety.
The margin of safety associated with the affected Technical Specifications is to provide assurance that the releases of radioactive materials during actual or potential releases of liquid or gaseous efiluents do not exceed the limits of 10 CFR Part 20. This license amendment request relocates the methodology and parameters used to ensure that the 10 CFR Part 20 limits are maintained, but does not change any of these requirements. Thus, no methodology and parameters for controlling radioactive effluent releases will be changed.
The procedural details of the current Radiological Efiluent Technical Specifications will be transferred to the ODCM and replaced with programmatic controls consistent with regulatory requirements, including controls on revisions to the ODCM. Thus, no requirements or controls will be reduced.
Document Control Desk June 9,1995 Page 7 The proposed revisions to the reporting requirements for Radiological Emuent Release Report and the revision from the old 10 CFR 20.106 requirements to the new 10 CFR 20.1302 have no impact on plant systems, plant operations or accident precursors. The changes to the emuent reporting requirements and the updated reference to 10 CFR 20.1302 do not change either the means of controlling radioactive releases or the effluent release limits. Therefore, there will be no change in the types and amounts of effluents that will be released, nor will there be an increase in individual or cumulative radiation exposures to any member of the public.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
ENVIRONMENTAL ASSESSMENT ne proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area as defmed in 10 CFR Part 20 or changes to an inspection or Surveillance Requirement. We have determined that the proposed amendment involves no significant hazards considerations, and that operation with the proposed amendment would result in no significant change in the types or significant increases in the amounts of any efiluents that may be released offsite, and in no significant increase in individual or cumulative occupational radiation exposu e, Therefore, the proposed amendment is eligible for categorical exclusion as set forth in 10 CFR 5122(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or emironmental assessment is r, ceded in connection with the approval of the proposed amendment.
SCIIEDULE This change is requested to be approved and issued by January 1,1996. However, isst.ance of this amendment is not currently identified as having an impact on outage completion or continued plant operation.
The Administrative Controls submittal, Reference (d), was originally intended to be approved before this submittal; however, since that change implements the Improved Technical Specification format, it is requested that this change be approved concurrently with that change. Accordingly, we request that upon NRC approval of the license amendments or QA Policy, whichever is later, it be implemented within 60 days.
SAFETY COMMITTEE REVIEW These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Safety Review Committee and Offsite Safety Review Committee. They have concluded that implementing these changes will not result in an undue risk to the health and safety of the public.
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Document Control Desk June 9,1995 Page 8 Should you have questions regarding this matter, we will be pleased to discuss them with you.
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STATE OF MARYLAND
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COUNTY OF CALVERT I hereby certify that on the Ylk) day of OUAtv
.19fj, before me, the subscriber, a Notary Public of the State of Maryland in anc(jfor LdlA>fA1) EMuhive
., personally appeared Robert E. Denton, being duly swom, and states that he is Vice President of tye Baltir.iore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing resynse for the purposes therein set forth; that the statements made are true and correct to the best of his i:nowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS mylland and Notarial Seal:
! lA'llltJ h tui dA)
Notary Public My Commission Expires:
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'l DAte RED /NH/dlm Attachments:
(1)
Unit 1 Technical Specifications Revised Pages (2)
Unit 2 Technical Specifications Revised Pages (3)
Offsite Dose Control Manual, DRAFT Revision 2
- Document Control Desk June 9,1995 Page 9
REFERENCES:
(a)
Mr. S. A. Varga (NRC) to All Power Reactor Licensees and Applicants, dated January 31, 1989, Implementation of Programmatic Controls for Radiological Efiluent 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 the Process Control Program (Generic Letter 89-01)
(b)
NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants," dated September 1992 (c)
Letter from Mr. W. T. Russell (NRC) to improved Technical
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Specification Owners Group Chairpersons, dated October 25, 1993, Content of Standard Technical Specifications (d)
Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated March 15, 1995, License Amendment Request: Administrative Controls Section 6.0 Upgrade and Quality Assurance Policy Change l
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(With Attachments) l D. G. Mcdonald, Jr., NRC R. I. McLean, DNR (Without Attachments)
D. A. Brune, Esquire J. E. Silberg, Esquire L. B. Marsh, NRC T. T. Martin, NRC P. R. Wilson, NRC J. H. Walter, PSC i
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