ML20117L325
| ML20117L325 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/04/1996 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20117L328 | List: |
| References | |
| GL-89-01, GL-89-1, NUDOCS 9609130110 | |
| Download: ML20117L325 (10) | |
Text
CH ARLES II. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby. Maryland 20657 410 495 4455 September 4,1996 U. S. Nuclear Regulatcry Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Clarification of License Amendment Request; Implementation of Changes to the Radiological Elliuent Technical Specifications as Proposed by Generic Letter 29-01 M i dm.nce (a), Baltimore Gas and Electric Company proposed a revision to the Calvert Cliffs Nuclear Power Plant Radiological Effluent Technical Specifications consistent with Generic Letter 89-01, Reference (b), and the Improved Standard Technical Specifications for Combustion Engineering Plants published in NUREG-1432, Reference (c), as modified by W. T. Russell's letter of October 25,1993, Reference (d). Reference (a) was submitted shortly after another License Amendment Request to revise the Administrative Controls Section of the Technical Specifications, Reference (e). The Administrative Controls changes were approvel in Reference (f). The purpose of this letter is to provide additional clarification and justification of changes proposed by Reference (a), in light of the approval of the Administrative Controls License. mendment.
The changes proposed in Reference (a) were marked-up on the Technical Specification pages which were
, current at the time of that submittal. Similarly, the justification for the proposed changes were based coon their effect on the current Technical Specifications. As Reference (e) also proposed changes to many of the same Specifications, particularly in the Administrative Controls section of the Technical Specifications, some confusion arose as to how the spproved version of the combination of these two License Amendment Requests would look. As the two License Amendments were not approved concurrently, the main purpose of titis letter is to submit marked-up pages based on the current Technical Specifications [ including the approval of Reference (e) in License Amendment Nos. 216/193].
Attachment (1) to this letter provides a detailed discussion and justification of each change proposed in Reference (a). Additionally, changes to Administrative Controls Technical Specifications are discussed in terms of how they affect the current Specifications, rather than addressing their effect on the Specifications which were current when Reference (a) was originally submitted.
9609130110 960904 PDR ADOCK 05000317 1 P PDR
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Document Control Desk September 4,1996 Page 2 This submittal provides a more detailed discussion and justification of the changes proposed in j
- Reference (a), but it does not change the content or conclusions of the " Determination of Significant 1 Ilazards" submitted in Reference (a). hiinor style and punctuation changes may be made to the final Technical Specification pages, and the pages may be renumbered to accommodate added and/or deleted pages.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
,f ,
Y f4 V CHC/NII/ dim Attachments: (1) Description and Justification of Proposed Changes (2) Unit 1 Technical Specifications hiarked-Up Pages (3) Unit 2 Technical Specifications hiarked-Up Pages
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cc: D. A. Brune, Esquire II. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate 1-1, NRC R. I. hiclean, DNR A. W. Dromerick, NRC J. H. Walter, PSC
REFERENCES:
(a) Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, ;
dated June 9,1995, " License Amendment Request; implementation of ;
Changes to the Radiological Effluent Technical Specifications as !
Proposed by Generic Letter (GL) 89-01" (b) Mr. S. A. Varga (NRC) to All Power Reactor Licensees and Applicants, l dated January 31,1989, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the ^ ^ .inistrative Controls Section of the Technical Specifications ad the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or I the Process Control Program (Generic Letter 89-01)"
(c) NUREG-1432, " Standard Technical Specifications - Combustion Engineering Plants", dated September 1992 (d) Letter from Mr. W. T. Russell (NRC) to improved Technical Specification Owners Group Chairpersons, dated October 25, 1993,
" Content of Standard Technical Specifications" 1
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Document Control Desk 1 September 4,1996 Page 3 l (e) Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, i dated March 15,1995, " License Amendment Request: Administrative 1 Controls Section 6.0 Upgrade and Quality Assurance Policy Change" J
(f) Letter from Mr. A. W. Dromerick (NRC) to Mr. C. H. Cruse (BGE),
dated August 26,1996, " Issuance of Amendments for Calvert Cliffs Nuclear Power Plant, Unit No.1 (TAC No. M91854) and Unit No. 2 (TAC No. 91855)"
(g) Letter from Mr. A. E. Lundvall, Jr. (BGE), to Mr. J. R. Miller (NRC),
dated October 11,1984," Request for Amendment" i (h) Letter from Mr. J. R. Miller (NRC) to Mr. A. E. Lundvall, Jr. (BGE),
i dated February 22,1985, License Amendment Nos.100 and 82 (i) Letter from E. J. Butcher (NRC) to Mr. A. E. Lundvall, Jr. (BGE), dated July 1,1985, License Amendment Nos.105 and 86 l
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) ATTACHMENT (1) l 4
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DESCRIPTION AND JUSTIFICATION OF PROPOSED CHANGES 1
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant September 4,1996
l ATTACIIMENT (I)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CIIANGES Technical Specification Description and Justification of Proposed Change Number 1.19 DESCRIPTION OF CIIANGE: Revise Offsite Dose Calculation Manual (ODCM) definition.
JUSTIFICATION: The definition is revised to reflect the change in scope of the ODCM. Procedural details pertaining to monitoring instrumentation, radioactive effluents, and radiological environmental monitoring will be relocated from the Technical Specifications to the ODCM by the proposed License Amendment.
I.24 DESCRIPTION OF CIIANGE: Delete Process Control Program (PCP) definition.
JUSTIFICATION: Specification 6.16, Process Control Program (PCP), was l
deleted from the Technical Specifications by License Amendment Nos. 216/193.
The specific requirements for the use ofliigh Integrity Containers to meet the shipping and burial ground requirements for wet radioactive wastes are located in Calvert Cliffs procedure RSP 2-217, "CNSI lfigh Integrity Container," and requirements to implement a PCP for solidification of wet waste or dewatering of spent resins are located in Calvert Cliffs procedure RP-2-101, " Radioactive Waste Management." Since the regulations address the ansfer and disposal of
- licensed material, including the classification of waste and waste characteristics, the regulations provide adequate controls over the PCP. In addition, changes to plant procedures are controlled by 10 CFR 50.59. Because the controls are adequate, elimination of the PCP from the Specification is justified. As the Technical Specifications no longer provide controls for the PCP, the definition of the PCP may also be removed from the Technical Specifications. (This change is consistent with improved Technical Specifications guidance.)
I.31 DESCRIPTION OF CIIANGE: Delete " Solidification" definition.
JUSTIFICATION: Solidification is a process which is not currently in use at Calvert Cliffs. The requirement to establish a PCP for the solidification of wet waste has been relocated to Calvert Cliffs procedure RP-2-101. With this relocation, and the deletion of Technical Specification 3/4.11.3, as described below, the Technical Specifications will no longer provide controls for the solidification process. Therefore, the definition of solidification may also be removed from the Technical Specifications.
- 3/4.3.
3.9 DESCRIPTION
OF CIIANGE: Delete these Specifications in their entirety
& (including Tables 3.3-12 & 4.3-11). The associated sections of the Technical SPecifications Bases are deleted by this change.
l 3/4.3.3.10 JUSTIFICATION: The procedural details for the operability of the radioactive gaseous and liquid effluent monitoring instrumentation will be relocated from these Technical Specifications to the ODCM. Changes to these and.other 1
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NITACIIMENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CIIANGES Technical Specification Description and Justification of Proposed Change Number requirements in the ODCM are controlled by Technical Specification 6.5.1, thereby ensuring the levels of radiological control required by 10 CFR 20.1302, 10 CFR 50.36a,10 CFR Part 50, Appendix I, and 40 CFR Part 190 are maintained, and that the change does not adversely impact the accuracy or i reliability of effluent, dose, or setpoint calculations. Because the controls are adequate, elimination of this Specification isjustified.
3/4.
11.1 DESCRIPTION
OF CIIANGE: Delete Specifications 3/4.11.1 and 3/4.11.2,
& EXCEPT 3/4.11.2.5 & 3/4.11.2.6 (as discussed below). The associated sections 3/4.11.2 f the Technical Specifications Bases are deleted by this change.
JUSTIFICATION: The procedural details for the control of radioactive gaseous and liquid effluents will be relocated frt.m Technical Specifications 3/4.11.1 and 3/4.11.2 to the ODCM. Changes to these and other requirements in the ODCM are controlled by Technical Specification 6.5.1, thereby ensuring the levels of radiological control required by 10 CFR 20.1302, 10 CFR 50.36a, 10 CFR Part 50, Appendix I, and 40 CFR Part 190, are maintained, and that the change does not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations. Because these controls are adequate, elimination of these Specifications isjustified.
l 3.11.
2.5 DESCRIPTION
OF CIIANGE: Renumber Limiting Caadition for
& Operation (LCO) 3.11.2.5 and Surveillance Requirement 4.11.2.5 to 3.11.1.1 and 4.11.2.5 4.11.1.1, respectively. Also, revise the Surveillance Requirement to read, "The concentration of oxygen in the Waste Gas IIoldup System shall be determined to be within the above limit by collecting and analyzing a sample from the Waste Gas Decay Tank once per week on the in-service tank and following tank isolation. Waste Gas Surge Tank samples shall be collected and analyzed daily during power escalation from MODE 6 through MODE 3, and once per week at all other times." The associated sections of the Technical Specifications Bases are also renumbered by this change.
JUSTIFICATION: Surveillance Requirement 4.11.2.5 currently references Table 4.11-2 for the sampling program acceptance limits. Table 4.11-2 is referenced in other Surveillance Requirements which will be deleted by this I License Amendment Request. Therefore, to maintain the same Surveillance j Requirements, the text has been extracted from the table and rewritten in '
" paragraph" format. This change revises the format of the text in the table, without changing its content. The renumbering of this Specification is necessitated by the deletion of 3/4.11.1 through 3/4.11.2.4. Renumbering tilis Specification does not affect its content.
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ATTACHMENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CilANGES Technical Specification Description and Justification of Proposed Change Number 3.11.
2.6 DESCRIPTION
OF CHANGE: Renumber LCO 3.ll.2.6 and Surveillance
& Requirement 4.11.2.6 to 3.11.1.2 and 4.11.1.2, respectively. The associated 4.11.2.6 sections of the Technical Specifications Bases are also renumbered by this change.
JUSTIFICATION: The renumbering of these Specifications is necessitated by the deletion of 3/4.ll.1 through 3/4.11.2.4. Renumbering this Specification
- not affect its content. ,
3/4.
11.3 DESCRIPTION
OF CHANGE: Delete Specification 3/4.11.3 in its entirety.
The associated sections of the Technical Specifications Bases are deleted by this ;
change. l JUSTIFICATION: The specific requirements for the use of High Integrity Containers to meet the shipping and burial ground requirements for wet radioactive wastes are located in Calvert Cliffs procedure RSP 2-217.
Additionally, Calvert Cliffs procedure RP-2-101 delineates the requirements for a PCP for solidification of wet waste or dewatering of spent resins. The process controls provided by these procedures are sufficient tojustify the elimination of Technical Specification 3/4.11.3.
3/4.
11.4 DESCRIPTION
OF CHANGE: Delete Specification 3/4.11.4 in its entirety.
The associated sections of the Technical Specifications Bases are deleted by this change.
JUSTIFICATION: The procedural details for maintaining the total dose within the specified limits will be relocated to the ODCM, and the process controls will ,
be relocated to Technical Specification 6.5.5.1, Radioactive Effluent Controls Program. Changes to the ODCM are controlled by Technical Specification 6.5.1, thereby ensuring the annual dose or dose commitment conforms to the regulatory requirements of 40 CFR Part 190, and that the change does not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations. Because these controls are adequate, elimination of this Specification isjustified.
DESCRIPTION OF CHANGE: An exception to the Generic Letter (GL) 89-01 l recommendation to retain the Technical Specification on " Liquid Holdup Tanks" is proposed.
i JUSTIFICATION: The Calvert Cliffs Technical Specifications do not currently i include a Technical Specification on Liquid Holdup Tanks; therefore, the GL 89-01 recommendation to retain such a specification does not apply. It should be noted that the Radiological Effluent Technical Specifications, as l
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ATTACHMENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CHANGES Technical l Specification Description and Justification of Proposed Change Number proposed by Baltimore Gas and Electric Company (BGE) in Reference (g), and l approved for implementation in References (h) and (i), have never included a specification on Liquid Holdup Tanks. Furthermore, the Improved Technical ;
Specifications, which BGE plans to adopt in the near future, do not have a Liquid Holdup Tanks Technical Specification; therefore, we do not intend to implement such a specification at this time.
3/4.12 DESCRIPTION OF CHANGE: Delete Specification 3/4.12 in its entirety. The associated sections of the Technical Specifications Bases are deleted by this change.
JUSTIFICATION: The procedural details for the Radiological Environmental Monitoring Program (REMP) will be relocated to the ODCM. The process controls for the REMP will be relocated to Technical Specification 6.5.1, Offsite Dose Calculation Manual, and the submittal requirements for the REMP will be maintained in Technical Specification 6.6.2, Annual Radiological Environmental Operating Report. Changes to the ODCM are controlled by Tecimical Specification 6.5.1, thereby ensuring that the requirements of 10 CFR Part 50, Appendix I, are met. Because these controls are adequate, elimination of these Specifications isjustified.
6.
5.5 DESCRIPTION
OF CHANGE: License Amendment Nos. 216/193 added a new Specification entitled," Radioactive Effluent Controls Program." This program provides the programmatic controls to satisfy the existing procedural details contained in the Radiological Effluent Technical Specifications (i.e., Specification 3/4.11). However, whereas the program specified in Amendment Nos. 216/193 provides limits in terms of the governing regulation, j the programmatic controls in 3/4.11 provide the actual numeric limits to be met. l Reference (a) proposed specifying the numeric limits in this Specification, rather ,
than providing references to the governing regulations. A discussion of this l deviation from the suggested wording in GL 89-01 is provided on page 3 of Reference (a). The following changes are proposed for this License Amendment Request:
- 1) Capitalize the terms " MEMBERS OF THE PUBLIC" and
" UNRESTRICTED AREAS".
- 2) The correct reference for the limitations on the concentrations of radioactive material released in liquid effluents is 10 CFR Part 20,
- Appendix B, Table 11, Column 2. Reference (a) incorrectly referenced j " Table 2", rather than " Table 11".
! 3) Revise Specification 6.5.5.d to retain the quarterly and annual dose limits
! currently in LCO 3.11.1.2.
- 4) Revise Specification 6.5.5.f to retain the limits currently in LCO 3.11.1.3.
f 5) Revise Specification 6.5.5.g to retain the limits currently in LCO 3.11.2.4 l
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ATTACIIMENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CIIANGES Technical l Specification Description and Justification of Proposed Change l Number for the Gaseous Radwaste Treatment System.
- 6) Revise Specification 6.5.5.h to retain the limits currently in LCO 3.11.2.4 i for the Ventilation Exhaust Treatment System.
- 7) Revise Specification 6.5.5.i to retain the limits currently in LCO 3.11.2.1.
- 8) Revise Specification 6.5.5.j to retain the limits currently in LCO 3.11.2.2.
l 9) Revise Specification 6.5.5.k to retain the limits currently in l LCO 3.I 1.2.3.
- 10) Revise Specification 6.5.5.1 to retain the limits currently in LCO 3.11.4.
JUSTIFICATION: l
- 1) " Members of the Public" and " Unrestricted Areas" are still defined terms, per Technical Specification Section 1.0, until the Improved l
Technical Specifications are adopted. Defined terms are bold and capitalized in the Technical Specifications.
- 2) The Radioactive Effluent Controls Program was incorporated in the
! Technical Specifications by Reference (f), and correctly references the use of Table 11 for limitations on the concentrations of radioactive
! material released in liquid. Changing this reference to Table II is in I agreement with current plant practices, as well as with the remainder of l the discussions presented throughout Reference (a); therefore, we request that the proposed Technical Specification 6.5.5.b retain the reference to
" Table 11."
l 3) through 10) All of the numeric limits to be transferred from -
l Specification 3/4.11 to Specification 6.5.5, as discussed above, are less l than or equal to the corresponding limits in the regulations. However, for l these particular Specifications, BGE finds it advantageous to specify the i actual numeric limits in the Technical Specifications rather than referring to the applicable regulations, due to our familiarity with these values, and the way in which they are presented in Specification 3/4.11. As these values were approved for our current Technical Specifications, and adherence to these limits will ensure the regulatory requirements are met, this change isjustified.
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6.2 DESCRIPTION
OF CIIANGE: License Amendment Nos. 216/193 revised the existing 6.9.1.7, Annual Radiological Environmental Operating Report, in its entirety. The following changes are proposed for this License Amendment Request:
- 1) Change reporting date from " prior to May 1" to "by May 15" per NUREG-1432.
- 2) Add a requirement to " identify the TLD results that represent the collocated dosimeters in relation to the NRC TLD program and the exposure period associated with each period" in the Annual Radiological Environmental Operating Report.
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ATTACIIMENT (I) l DESCRIPTION AND JUSTIFICATION OF PROPOSED CIIANGES l Technical 1 Specification Description and Justification of Proposed Change Number
- 3) Make the following editorial changes:
a) Combine the first and second paragraphs; i b) Clearly specify that the new second paragraph is addressing the
" Annual Radiological Environmental Operating Report"; and c) Clarify the last sentence of the second paragraph by relocating the words,"in a supplementary report."
l JUSTIFICATION: The changes described above arejustified as follows:
- 1) The change to the reporting date makes this Specification agree with the 1 wording in NUREG-1432, while having no effect on the content or l accuracy of the report. No specific reporting date is provided in 10 CFR 50.36a(2), with the only restriction being that the interval I between reports must not exceed 12 months. Because the reporting date l is consistent with the requirements, this change is justified.
l 2) Thermoluminescent dosimeter [TLD) results have been reported in past l Annual Radiological Environmental Operating Reports, although not specifically required by 10 CFR 50.36a. The addition of this requirement to the Technical Specifications formalizes an existing process, and is consistent with the guidance provided in NUREG-1432.
- 3) The three editorial changes addressed above clarify the content of the l Technical Specifications, without changing their intent.
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6.3 DESCRIPTION
OF CIIANGE: Add an annotated NOTE after the first sentence indicating that the Sr" and Sr* analyses results may be submitted in a supplementary report within 120 days after the submittal of the Radioactive l Effluent Release Report. Make minor editorial changes, including combining l the first and second paragraphs and adding commas to separate the phrase,
" including the safety analysis," in the new second paragraph.
l l JUSTIFICATION: License Amendment Nos. 216/193 revised the discussion of l the Radioactive Effluent Release Report and provided justification that the i report content will either be specified by regulations or will be incorporated into l the ODCM. However, the footnote for the supplementary report for Sr" and Sr* analyses results should not have been deleted from the Technical l Specifications, as it does not specify the content of the report, but rather allows a schedular exception for a portion of the report. This note was part of the original Radiological Effluent Technical Specifications for Calvert Cliffs, as approved in i
License Amendment Nos.100/82, and implemented in License Amendment Nos.105/86, and as such is not addressed as a change to the Technical Specifications. The two editorial changes addressed above clarify the content of i
the Technical Specifications, without changing their intent.
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