ML20137H786

Responds to 850911 Request for Addl Info Re Proposed Amend 102 Which Removes Unnecessary Items from Tech Spec App B. Record of Nonradiological Environ Surveillance Program Provides Justification for Removal of Items

ML20137H786
Person / Time
Site:	Rancho Seco
Issue date:	11/21/1985
From:	Latham W SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Stolz J Office of Nuclear Reactor Regulation
References
RJR-85-526, NUDOCS 8512020475
Download: ML20137H786 (3)

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SACRAMENTO MUNICIPAL UTILITY DISTRICT C 62o1 S Street, P.O. Box 15830, sacrarnento CA 95852 1830.1916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA RJR 85-526 November 21, 1985 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTN J F STOLZ CHIEF OPERATING REACTORS BRANCH 4 U S NUCLEAR REGULATORY COMMISSION WASHINGTON DC 20555 DOCKET N0. 50-312 LICENSE N0. DPR-54 PROPOSED AMENDMENT N0. 102, REQUEST FOR ADDITIONAL INFORMATION This letter is in response to your request for additional informaticd dated September 11, 1985, concerning Proposed Amendment No. 102. The purpose of Proposed Amendment No. 102 is to simplify Rancho Seco Technical Specifications by removing unnecessary items from Appendix B. Appendi>. B now contains radio-logical and nonradiological specifications.

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The remaining nonradiological items can be sliminated from Appendix B for the following reasons. First, the chemical and radiation group at Rancho Seco has been involved with a Nonradiological Environmental Surveillance Program for over 10 years. This program consists of effluent stream bed erosion pro-tection, drift contaminant monitoring, noise monitoring, and fogging patterns

associated with the cooling towers. The results of this analysis and surveys performed have never indicated any hazardous effects to the environment or the general public. In fact, historic data shows that no severe erosion of the stream bed or degradation of soil banks surrounding the effluent stream has ever occurred. The only significant amount of erosion that has taken place has been during the heavy winter and spring rains which would have occurred regard-less of plant operation. The deletion of noise surveys from Appendix B can be justified since all historic data shows that the surveys have been clearly within acceptable limits. Monitoring of fogging patterns can also be deleted.

Observations of fogging patterns associated with the cooling towers operation have shown no fog increase at the nearby State Route 104 The only fog observed has been normal valley fog during the winter months. The historical record of this program in conjunction with the Yellow Creek Decision (December 17,1978) that removed NRC jurisdiction over water quality monitoring pro-grams that are already regulated by federal and state authorities, should provide adequate justification for removing these requirements from Rancho Seco Tech-nical Specifications.

Since the addition of the Radiological Effluent Technical Specifications (RETS) in the Rancho Seco license, the need for administrative controls on radiologi-cal items in Appendix B no longer exists. Amendment No. 53 (RETS) significantly modified Appendix A, Section 6 of the Technical Specifications. Amendment No. 53 added the following radiological administrative controls specifications:

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6.5.2.8 K,i., M 6.5.2.9 6.8.1 G, H, I 6.9.2 '

6.9.5 6.10.2 6.14 6.15 6.16 6.17 This set of specifications duplicates and exceeds the requirements already contained in Section 5.0 of Appendix B. Specifically, your letter of September 11, 1985 asked for assurance of this fact on the following items:

1. Appendix B, Administrative Controls, deletion of Sections 5.3.A.2 and 5.3.B.2, requirements to review onsite tests and experiments and results thereof, when such tests have environmental significance.

2. Appendix B, Administrative Controls, deletion of Section 5.6.3, reporting requirements and evaluation of plant design changes when the changes may adversely impact the environment.

3. Appendix B, Administrative Controls,. deletion of Section 5.7, requirement

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to maintain environmental records , ,

Appropriate replacement technical specifications exist for item 1 in several sections. Deletion of Appendix B, Administrative Controls Section 5 3.A.2 is justified because of the review responsibilities required of the Plant Review Committee (PRC) in Specification 6.5.1.6 of Appendix A. Part A states that the PRC will review all procedures required by Specification 6.8.

Specification 6.8 includes: Process Control Program Implementation Procedures, Offsite Dose Calculation Manual Implementation Procedures, and Effluent and Environmental Quality Control Program Procedures In addition to this, the PRC Chairman reviews all Surveillance Test Procedures and facility operations to detect potential safety hazards.

Appendix B, Administrative Controls, Section 5.3 B.2 is no longer necessary because of Appendix A, Specification 6.5.2.70. The Management Safety Review Comittee (MSRC) reviews all changes to the technical specifications or the operating license. These type of changes are all accompanied by a safety analysis evaluating the impact of the change The process outlined in 10 CFR 50.59 effectively controls all changes associated with Appendix B, Specification 5.6.3.1.

In accordance with Amendment No. 45, the NRC is provided with a copy of any changes to the National Pollutant Discharge Elimination System (NPDES) permit and any permit violations. Appendix B Environmental Technical Specifications which pertain to nonradiological water quality related requirements were deleted with this amendment Water quality limits and monitoring' programs associated with this permit are under the jursidiction of the California Regional Water Quality Control Goard. All nonradiological environmental monitoring program changes and violations are handled by the appropriate federal, state, local and regional authorities.

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In compliance with Appendix B, Specification 5.6.3.3, all technical specifica-tion changes are submitted to the Director of the Division of Licensing.

Currently, all proposed amendments include a safety analysis. .

Appendix B, Section 5.7 requirements are addressed by Appendix A, Section 6.10 Specificat ior,s. Specifications 5.7.1A and 5.7.18 are satisfied by Specifica-tions 6.10.2A and 6.10.2M respectively. Also, Specifications G, H and I of Section 6.10.1 meet the intent of Specification 5.7.2.

SAFETY ANALYSIS Since the addition of the Radiological Effluent Technical Specifications (RETS) into the Rancho Seco license, radiological specifications are no longer required in Appendix B. Regulation of nonradiological environmental items is being per-formed by a variety of federal, state, local and regional authorities in accord-ance with applicable law. The only area of Appendix B which is not addressed elsewhere is the sampling of the miscellaneous water evaporator. Our December 12, 1984 letter has proposed placing these specifications in Appendix A. Therefore, operation of Rancho Seco in accordance with Proposed Amendment No. 102:

1. does not involve a significant increase in the probability or consequences of an accident previously evaluated,

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2. does not create the possibility of a new.or different kind of accident from any accident previously evaluated, and

3. does not involve a significant reduction in a margin of safety.

Therefore, significant safety hazards are not associated with this change.

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WILLIAM K. LATHAM ASSISTANT GENERAL MANAGER Subscribed and sworn to before me e this 3 /5 7- day of h =e ^ o -

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