ML20129D151
| ML20129D151 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/18/1996 |
| From: | Bajwa S NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20129D157 | List: |
| References | |
| NUDOCS 9610240212 | |
| Download: ML20129D151 (8) | |
Text
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r4 21 UNITED STATES
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NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20555-4001
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SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 21#0 FACILITY OPERATING LICENSE NO. DPR-53 AND AMENDMENT NO.194TO FACILITY OPERATING LICENSE NO. DPR-69 BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318
1.0 INTRODUCTION
By letter dated June 9,1995, as supplemented September 4,1996, the Baltimore Gas and Electric Company (the licensee) submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2, Technical Specifications (TSs) to implement the guidance in Generic Letter (GL) 89-01, l
" 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 Radiological Effluent Technical Specifications (RETS) to the Offsite Dose Calculational Manual or to the Process Control Program" and selected guidance contained in the Improved Technical Specifications (ITS) for Combustion Engineering Plants
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(NUREG-1432).
The requested changes would incorporate programmatic controls for radiological effluents and radiological environmental monitoring in the Administrative Controls section of the TSs consistent with the requirements of 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part
- 50. At the same time, the licensee proposes to transfer the procedural details of the RETS from the TSs to the Offsite Dose Calculation Manual (ODCM) or to the Process Control Program (PCP) for solid radioactive wastes as appropriate.
With these changes, the TSs related to RETS reporting requirements were simplified.
Finally, changes to the definition of the OCDM was proposed and the definition of the PCP and PCP control requirements, from the TSs was deleted.
In accordance with GL 89-01, the licensee marked and explained TS changes that are not consistent with the guidance contained in GL 89-01.
The deviations are reviewed in this safety evaluation. The September 4, 1996, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination or expand the scope of the initial Federal Reaister notice.
2.0 EVALVATION 2.1 Removal of RETS from the Technical Specifications Section 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the content of TSs.
Section 182a of the 9610240212 961019 PDR ADOCK 05000317 P
' Atomic Energy Act (the "Act") requires applicants for nuclear power plant 1
1 operating licenses to state TS to be included as part of the license. The Commission's regulatory requirements related to the content of TSs are set i
forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation j
(LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in the plant TSs.
i The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 Federal Register (FR) 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy J
statement satisfied 5 182a of the Act.
In particular, the Commission 1
indicated that certain items could be relocated from the TS to licensee-l controlled documents, consistent with the standard enunciated in Portland and i
General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that
" technical specifications are to be reserved for those matters as to which the J
imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving i
rise to an immediate threat to the public health and safety."
10 CFR 50.36, as amended, provides that those existing TS LCOs which do not satisfy the four criteria specified in 10 CFR 50.36(c)(2)(ii)(A)-(D) may be relocated to the Updated Final Safety Analysis Report (UFSAR), such that future changes could be made to these provisions pursuant to 10 CFR 50.59.
Other requirements may be relocated to more appropriate documents (e.g.,
Security Plan, Quality Assurance (QA) Plan, and Emergency Plan) and controlled by the applicable regulatory requirement.
Similarly, while the required l
content of TS administrative controls is specified in 10 CFR 50.36(c)(5),
i particular details of administrative controls may be relocated to licensee-controlled documents where 650.54, 550.59, or other regulations provide adequate regulatory control.
4 The RETS provide the release limits and monitoring and reporting criteria for gaseous, liquid, and solid radioactive effluents.
Such releases are a byproduct of the use of a nuclear reaction for power generation. The RETS are not related to the detection of abnormal degradation of the reactor coolant pressure boundary, boundary conditions for design basis accidents (DBAs) and i
transients, or functions determined to be important to risk or operating experience.
In GL 89-01, the NRC staff noted that it had examined the contents of the RETS in relation to the Commission's Interim Policy Statement of Technical Specifications Improvements and had determined that programmatic controls could be implemented in the Administrative Controls section of the TSs to satisfy the existing regulatory requirements for RETS. The staff had also determined that the procedural details of the TSs on radioactive effluents and radiological environmental monitoring could be relocated to the ODCM, while the procedural details for solid radioactive waste could be 3
relocated to the PCP. After relocation, future changes to these procedural 4
4.
details will be controlled by the controls for changes to the ODCM included in the Administrative Controls section of the TSs.
PCP changes will be controlled using plant procedures.
On this basis, the NRC staff concludes that the RETS do not need to be controlled by TSs, and changes to the RETS are adequately controlled by 10 CFR a
50.59, " Changes, tests, and experiments." Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an I
accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment a
would be required prior to implementation of the change. NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to Updated Final Safety Analysis Report (UFSAR) commitments j
and to take any remedial action that may be appropriate.
The NRC staff has concluded, therefore, that reli> cation of RITS is acceptable because (1) their inclusion in TSs is not specifically required by 10 CFR 50.36 or other regulations, (2) the RETS are not required to avert an immediate threat to public health ard safety, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
2.2 Implementation of RETS Requirements in ODCM and PCP In GL 89-01, the staff provided model specifications and encouraged licensees i
to propose changes consistent with the GL. The licensee's proposed changes to the TSs are in accordance with the guidance provided in GL 89-01 and are j
addressed below.
(1) The licensee has proposed to incorporate programmatic controls for radioactive effluents and radiological environmental monitoring in TS 6.5.5, " Radioactive Effluent Controls Program," as noted in the guidance provided in GL 89-01. The programmatic controls ensure that programs are established, implemented, and maintained to ensure that operating procedures are provided to control radioactive effluents consistent with the requirements of 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50.
(2) The licensee has confirmed that the detailed procedural requirements addressing limiting conditions for operation, their applicability, remedial actions, associated surveillance requirements, or reporting requirements for the following specifications have been prepared to implement the relocation of these procedural details to the ODCM or PCP.
These changes to the ODCM and PCP have been prepared in accordance with the new Administrative Controls in the TSs on changes to the ODCM and PCP so that they will be implemented in the ODCM or PCP when this amendment is issued.
SPECIFICATION TITLE 3/4.3.3.9 RADI0 ACTIVE GASE0US EFFLUENT MONITORING INSTRUMENTATION
4 d 3/4.3.3.10 RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION 3/4.11.1.1 RADI0 ACTIVE EFFLUENTS:
LIQUID EFFLUENTS CONCENTRATION 3/4.11.1.2 RADI0 ACTIVE EFFLUENTS:
LIQUID EFFLUENTS DOSE 3/4.11.1.3 RADI0 ACTIVE EFFLUENTS:
LIQUID RADWASTE TREATMENT SYSTEM 3/4.11.2.1 RADI0 ACTIVE EFFLUENTS:
GASE0US EFFLUENTS DOSE RATE f
3/4.11.2.2 RADI0 ACTIVE EFFLUENTS: DOSE-NOBLE GASES 3/4.11.2.3 RADI0 ACTIVE EFFLUENTS: DOSE, 10 DINE-131 AND RADIONUCLIDES IN PARTICULATE FORM 3/4.11.2.4 RADI0 ACTIVE EFFLUENTS: GASE0US RADWASTE TREATMENT SYSTEM s
3/4.11.3 RADI0 ACTIVE EFFLUENTS:
SOLID RADI0 ACTIVE WASTE 3/4.11.4 RADI0 ACTIVE EFFLUENTS: TOTAL DOSE 3/4.12.1 RADIOLOGICAL ENVIRONMENTAL MONITORING: MONITORING a
PROGRAM 3/4.12.2 RADIOLOGICAL ENVIRONMENTAL MONITORING:
LAND USE CENSUS i
3/4.12.3 RADIOLOGICAL ENVIRONMENTAL MONITORING:
INTERLABORATORY COMPARISON PROGRAM j
6.9.1.8 SEMI-ANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT 1
6.18 MAJOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS i
These procedural details that have been removed from the TSs are not required by the Commission's regulations to be included in TSs.
They have been 1
prepared for incorporation in the ODCM or PCP upon issuance of this license amend =cnt and may be subsequently changed by the licensee in accordance with 10 CFR 50.59 without prior NRC approval. Changes to the ODCM are documented i
and will be retained for the duration of the operating license in accordance 1
with Specification 6.5.1.c.
The licensee will control PCP using plant procedures.
(3) The following specifications that are included under the heading of Radioactive Effluents have been retained in the TSs. This is in 1
accordance with the guidance of GL 89-01.
SPECIFICATION TITLE 3/4.11.1.1 WASTE GAS HOLDUP SYSTEM (Retained applicable requirements from TS 3/4.11.2.5 and renumbered as
. TS 3/4.11.1) 3/4.11.1.2 GAS STORAGE TANKS (Retained applicable requirements from TS 3/4.11.2.6 and renumbered as TS 3/4.11.1.2)
(4) The following TS which deviated from the guidance in GL 89-01 were evaluated.
1.
TS 1.19: Definitions The licensee has propost.d to change the ODCM definition reference for the " semi-annual radioactive effluent release report" to " Radioactive Effluent Release Report." This change is in accordance with 10 CFR 50.36a and NUREG-1432. The licensee currently submits the report on an annual basis.
The change is consistent with 10 CFR 50.36a and is acceptable.
2.
TS 1.19: Definitions The licensee has proposed to change the ODCM definition to include wording from NUREG-1432 which discusses the radioactive effluent controls and radiological environmental monitoring activities that are to be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release Reports.
The changes maintain the same level of control as the guidance in NUREG-1432 and are acceptable.
3.
TS 1.24: Definitions The licensee has proposed to delete the definition of the PCP.
The change is consistent with the guidance in NUREG-1432 and is acceptable.
4.
TS 3/4.11.2.5: Waste Gas Holduo System (Renumbered as TS 3/4.11.1.1 The licensee has proposed to relocate existing TS wording relating to explosive gas mixture monitoring from Table 4.11-2 to the Surveillance Requirement section (4.11.1.1), so that Table 4.11-2 can be deleted.
This change is administrative in nature and is acceptable.
5.
TS 6.18: Radioactive Effluent Controls Proaram (Renumbered as TS 6.5.5)
The licensee has proposed to use its existing explicit TS values, given in TS 3.11, instead of the GL 89-01 recommended references to Appendix I of 10 CFR Part 50 and 40 CFR Part 190.
. Additionally, the licensee has proposed to use the wording from NUREG-1432, " limitations on the functional capability" instead of the wording contained in GL 89-01.
The changes are consistent with the licensee's existing TS and the proposed phrase is consistent with the guidance in NUREG-1432. The proposed changes are acceptable.
6.
GL 89-01. TS 6.8.4.h: Radioloaical Environmental Monitorina Proaram The licensee has proposed to not include this specification recommended by GL 89-01, The change is consistent with the guidance in NUREG-1432 and is acceptable.
7.
TS 6.9.1.7: Annual Radioloaical Environmental Operatina Reoort (Renumbered as TS 6.6.2)
The licensee has proposed to use the wording given in NUREG-1432 instead of that contained in GL 89-01. NUREG-1432 provides a more i
detailed description of the information to be provided in the Annual Rhdiological Environmental Operating Report over that contained in GL 89-01.
The change is consistent with the guidance in NUREG-1432 and is acceptable.
8.
TS 6.9.1.8: Radioloaical Effluent Release Report (Renumbered as 6.6.3)
The licensee has proposed to change the title of the " Semiannual Radioactive Effluent Release Report" to " Radioactive Effluent Release Report" to be consistent with the revised 10 CFR 50.36a.
The change is consistent with 10 CFR 50.36a and the guidance in NUREG-1432 and is acceptable.
9.
TS 6.9.1.8: Radioloaical Effluent Release Report (Renumbered as TS 6.6.3)
The licensee has proposed to include additional related requirements into this TS on the reporting of major changes to the Radioactive Waste Systems, by relocating the requirements from TS 6.18 to TS 6.9.1.8.
This change is administrative in nature and is acceptable.
- 10. TS 6.10.2: Record Retention The licensee has proposed not to include the GL 89-01 proposed TS on record retention for documentation associated with the ODCM and PCP.
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The change is consistent with the guidance in NUREG-1432 and is l
acceptable.
- 11. TS 6.16: Process Control Proaram./CP)
The licensee has proposed not to include the GL 89-01 proposed TS on changes to the PCP. The licensee will control changes to the PCP using plant procedures.
The change is consistent with the guidance in NUREG-1432 and is acceptable.
- 12. TS 6.17: Offsite Dose Calculation Manual (ODCM) (Renumbered as TS 6.5.1.c l
The licensee has proposed to use wording consistent with the guidcnce in NUREG-1432 which clarifies that only licensee initiated changes i.o the ODCM need to be documented in accordance with the TS, as opposed to all changes.
l The change is administrative in nature and consistent with the guidance in NUREG-1432 and is acceptable.
- 13. Technical Soecifications which reference 10 CFR 20.106 The licensee has proposed to change sections of the TS which reference "10 CFR 20.106" with d10 CFR 20.1302."
The change is administrative in nature to implement the corresponding revised 10 CFR Part 20 section number and is acceptable.
On the basis of the above, the NRC staff finds that the changes included in the proposed TS amendment request are consistent, except as discussed above, l
with the guidance provided in GL 89-01 and that the licensee has adequately l
relocated the RETS requirements.
Because the control of radioactive effluents l
continues to be limited in accordance with operating procedures that must i
satisfy the regulatory requirements of 10 CFR 20.1302, 40 CFR Part 190, 10 CFR l
50.36a, and Appendix I to 10 CFR Part 50, the NRC staff concludes that these l
changes are administrative in nature and there is no adverse impact on plant I
safety as a consequence. Accordingly, the NRC staff finds the proposed i
changes acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments. The State official had no comments.
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4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no
)
significant change in the types, of any effluents, that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (60 FR 35062). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the consideration discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common I
defense and security or to the health and safety of the public.
1 Principal Contributors:
S. Klementowicz A. Dromerick Date: October 18, 1996 I
e