ML20127L260
| ML20127L260 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/19/1993 |
| From: | Stratman R CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20127L264 | List: |
| References | |
| PY-CEI-NRR-1571, NUDOCS 9301270064 | |
| Download: ML20127L260 (5) | |
Text
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CNTERIOR LNERGY PERRY NUCLEAR POWER PLANT Ma.1 Address PO DOX 97 Robert A. Stralman PE RnY, OHIO 44081 VICE PRESIDENT NUCLEAR o 4 ogi (216) 259 3737 January 19, 1993 PY CEI/NRR-1571 L U. S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Perry Nuclear Power Plaut Docket No. 50-440 Technical Specification Change Request Revising the Radioactive Effluent Release Report Submittal Frequency from Semiannual to Annual Gentlemen:
Enclosed is a request for amendment to the Perry Nuclear Power Plant (PNPP)
Unit 1 Facility Operating License NPF-58.
This License Amendment Application proposes an administrative amendment of the PNPP Technical Specifications to incorporate the recent changes to 10 CFR 50.36a, involving the change in submittal frequency (from semiannual to annual) for the formerly titled " Semiannual Radioactive Effluent Release Report." This change has been determined not likely to involve significant hazards considerations in accordance with the previously published Commission guidance (51 FR 7751, March 6, 1986). Attachment 1 provides a Summary, Safety Assessment, and the Significant llazards and Environmental Considerations for the proposed change. provides a copy of the marked-up Technical Specification pages.
If you have any questions, please feel free to call.
Sincerely,
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f l [,-:.<Nn w Robert'A. Stratman RAS:RAL:ss Attachments cci NRC Project Manager NRC Resident Inspector Office NRC Region III t
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PY-CEf/NRR-1571 L Page 1 of 4 SUMHARY In response to several Presidential memoranda on reducing the burden of government regulation, the Commission directed its Committee to Reviev Generic Requirements (CRGR) to review the existing NRC regulations to determine whether regulatory burdens could be reduced without in any way reducing the protection for the public health and safety and the common defense and security.
One change to the regulations, which was approved, involved changing the submittal frequency of the " Semiannual Radioactive Effluent Release Report" from semiannually to anntally as promulgated in 10 CFR 50.36a,
" Technical Specifications on Effluents from Nuclear Power Reactors." Since this report and it's submittal requirements are described in detail in i
Specification 6.9.1.7 and the report is referenced by name in many places throughout the Specifications, a Technical Specification amendment is required to implement this new annual submittal frequency.
SAFETY ASSESSMENT Description Of The Proposed Change The proposed change revises the PNPP Technical Specifications by changing those Specifications involving the Semiannual Radioactive Effluent Release Report, in order to be consistent with the newly revised requirements of 10 CFR 50.36a concerning submittal frequency. Refer to Attachment 2 for a marked-up copy of the subject Technical Specification pages.
The following Technical Specification changes are required:
Revise the submittal frequency stated in the first paragraph of a.
Specification 6.9.1.7 (on page 6-19) to require that an Annual e
Radioactive Effluent Release Report covering operation of the unit during the previous calendar year be submitted. A sentence is added which is taken directly from the revised regulation as to the allowed interval between reports.
A sentence that had been included to clarify what time period was to be covered in the first report submitted for the first year of operation is deleted by this change request, since it is no longer necessary, b.
Vithin the second and third paragraphs on page 6-20, information is L
listed that was only required to be included in the Semiannual l
Radioactive Effluent Release Report that was submitted in the spring of L
each year.
Since only one report (annual) is nov required, thic information vill be-included in every report.
Therefore, tSere is no l_
longer a need to identify which report contains-this information, and changes to these two paragraphs are made to delete specific references to the spring report.
Several other editorial ~ corrections are made to enhance readability, t
Throughout Specification 6.9.1.7 and various other specifications, this c.
report is currently referred to by name as the " Semiannual Radioactive Effluent Release Report." References to this report-vithin Specification
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6.9.1.7 and the_other specifications listed belov should nov be revised l
to refer to the " Annual Radioactive Effluent Release Report."
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PY-CEI/NRR-1571 L Page 2 of 4 Page Specification or Table-and Note 3/4 3-84 Specification 3.3.7.9 Action b.
3/4 3-89 Specification 3.3.7.10 Action b.
3/4 11-4 Table 4.11.1.1.1-1 Note d.
3/4 11-7 Specification 3.11.1.4 Action a.
3/4 11-11 Table 4.11.2.1.2-1 Note e.
3/4 12-1 Specification 3.12.1 Action c.
3/4 12-7 Table 3.12.1-1 Note (1).
3/4 12-13 Specification 3.12.2 Actions a and b.
6-19 Specification 6.9.1.7 - Title.
6-20 Specification 6.9.1.7 - Title.
6-20 Specification 6.9.1.7 - First Paragraph.
6-20 Specification 6.9.1.7 - Second Paragraph.
6-20 Specification 6.9.1.7 - Third Paragraph.
6-20 Specification 6.9.1.7 - Fourth Paragraph.
6-20 Specification 6.9.1.7 - Note *.
6-21 Specification 6.9.1.7 - Title.
6-21 Specification 6.9.1.7 - First Paragraph.
j 6-21 Specification 6.9.1.7 - Second Paragraph.
6-24 Specification 6.13.2.1 25 Specification 6.14.2.1 6-25 Specification 6.15.1.1 xxv1 Index Specificatiun 6.9.1 - Change Title of the Semiannual Radioactive Effluent Release Report.
Justification For The Proposed Change This administrative amendment would revise the Technical Specifications by changing those specifications involving the Semiannual Radioactive Effluent Release Report, in order to be consistent with the sub'alttal frequency requirements of 10 CFR 50.36a, effective October 1, 1992, (57 FR 39353, August 31, 1992). The proposed change is purely administrative in that it removes inconsistencies between the ptesent PNPP Technical Specifications and 10 CFR 50.36a following passage of the changes to this rule. The proposed change simply allows for the incorporation of the changes that vere codified by the 10 CFR 50.36a rulemaking. Being administrative in nature, the proposed changes have no impact on plant equipment or' methods of operation. This change has been determined not likely to involve significant hazards-considerations in accordance with previously puh <shed Commission guidance (51 FR 7751, March 6, 1986).
SIGNIFICANT 11AZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commission's Regulations, 10 CPR 50.92, which state that the operation of the facility in accordance with the proposed amendment vould not (1) involve a significant increase in the probability or consequences of an accident previously evaluated.(2) create.the possibility of a new or different kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety.
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=PY-CEI/NRR-1571 L Page 3 of 4 The proposed amendment has been revieved with respect to these three factors-and it has been determined that the proposed change does not involve a significant hazard becau.=e:
(1) The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed change is designed to conform the PNPP Unit 1-Technical Specifications to changes in the NRC regulations (in this case 10 CFR 50.36a). The proposed change results in no changes to plant systems.
The proposed change has'no effect on accident conditions or assumptions.
The proposed change does not affect possible initiating events for accidents previously evaluated, or any system functional requirements.
As described within the discussion of the final rule, the eight proposed actions (one of which involves the frequency of radiological effluent reports)... " vill not reduce the protection of the public 1.ealth and' safety or the common defense and security." Hence, the proposed change is purely administrative in that it is designed to remove inconsistencies between PNPP Unit 1 Technical Specifications and 10 CFF RO.36a and does not affect plant operation in any way. The re,f ore, the proposed change to the subject Specifications caanot increase th'e probability or consequences of an accident previously evaluated.
(2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
As stated above, the proposed change is administrative in nature and does ot increase the possibility of any new or different kind.of accident.
il.e p ofosed change does not create the possibility of a new or different-kind of accide.nt since it does not affect the reactor coolant pressure boundary or any other plant systems or structures nor does it affect any system functional requirements or operability requirements and hence could not in tiate any new nr different kind of accident. Consequen:ly, no new IcM ae modes are introduced as a result of the proposed change.
(3) The proposed change does not result in a significant reduction in the margin of safety.
The change does not involve a significant reduction in the margin of safety because it is administrative in nature, and does not affect any USAR design bases, accident ascumptions, or Technical Specification Bases. Therefore, the proposed change does not reduce the margin of safe *v as defined in the basis for any Technical Specification.
Based upon the above considerations, it has been concluded that the proposed change does not involve significant harards considerations.
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Page 4 of 4-ENVIRONMENTAL CONSIDERATION The NRC determined that the final regulation (part of which involves changing the frequency of radiological effluent report) is the type of action described in categorical exclusions to 10 CFR 51.22(c)(2) and (3). As shown above, the proposed change does not involve a significant hazards consideration, nor does it increase the types and amounts of effluents that may 13 released offsite, nor does it increase individual or cumulative occupational radiation exposures. Based on the foregoing, it has been concluded that the proposed Technical Specification change meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
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