ML20203K298
| ML20203K298 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/15/1997 |
| From: | WISCONSIN ELECTRIC POWER CO. |
| To: | |
| Shared Package | |
| ML20203K296 | List: |
| References | |
| NUDOCS 9712220296 | |
| Download: ML20203K298 (9) | |
Text
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Attachment to'NPL 97-0804 i
Page1of2.
j A'ITACHMENT 3 SUPPLEMENT TO TSCR 174 ~
A review of the information contained in Attachment C items from NRC letter of August 15, 1997 has been completed. This review was based on the following cross-reference of the Attachment C items to proposed PBNP Technical Specifications in TSCR-174 and PBNP program sections:
ATTACliMENT C ITEM PROPOSED PBNP TS PBNP MANUAL a
TS 15.7.8.3.b RECM 5.7 i
TS 15.7.8.3.c RECM 2.3.1,5.2,5.4 b
TS 15.7.8.3.b RECM 5.2.2 c
TS 15.7.8.3.b RECM 6,0 4
d TS 15.7.8.3.c RECM 5.3, ODCM 4.0 e-TS 15.7.8,3.b RECM 5.7 f
TS 15.7.8.3.b RECM 5.8 g
TS 15.7.8.3.b RECM 5.6 h
TS 15.7.8.3.c RECM 5.5, ODCM 4.0 i
TS 15.7.8.3.b RECM 5.5 j
TS 15.7.8.3.c RECM 5.9, ODCM 4.4 This review identified that part of the Attachment C items, a, b, c, e, f, g, anu i, were not included in the TSCR 174 proposed Technical Specifications and associated program manual sections.
These new guidance items not already in PBNP TS 15.7.8 are incorporated in this addendum to TSCR 174, in the Technical Specification subsection describing the Radiological Efiluent Control Program Manual, TS 15.7.8.3.b, in proposed specifications 15.7.8.3.b.3) through 7). These modifications to TSCR 174 are provided in the attached edited Technical Specifications pages.
The revised program manuals are also provided as an attachment.
- Inclusion of the addi_tional items conforms with the new guidance provided in Attachment C to the RAI. Two of the adopted items will provide reliefin two of the current PBNP specifications.
These two items are described andjustified as follows:
- 9712220296 971-15 PDR ADOCK 050 p
PDR m
Attachment to NPL 97-0804 Page 2 of 2
- 1. - The revised TS 15.7.8.3.b.3) will limit the liquid effluent concentrations to ten (10) times the values in Column 2, Table 2, Appendix B to 10 CFR 20.100120.2402. The current
. specification adopts the Column 2, Table 2, Appendix B to 10 CFR 20.1001-20.2402 values with no modification. The 10X values are allowable because the ALARA dose guidelines of -
Appendix 1 to 10 CFR 50 are based on the fomier 10 CFR 20 whose maximum permissible effluent concentrations (the old MPCs) which were, on average,10X higher,
- 2. The new guidance only requires the reporting ofI 131,1 133, H 3, and radioactive material in particulate fonn with a half life >8 days released to the atmosphere. PBNP current'y uses all measured and identified radionuclides. Changing to the new guidance will elimina:e the need to report and calculate doses for radionuclides with a short half-life which make an insignificant contribution to offsite doses. This elimination of reporting short half life radionuclides is consistent with the reporting practices of other nuclear plants.
CONCLUSION The incorporation of new guidance items into the administrative controls section of the PBNP RETS (TS 15.7.8) will not affect the safe operation of PBNP.
The Wisconsin Electric Power Company (Leensee) previously evaluated TSCR 174, to remove the operational aspects of the PBNP RETS pursuant to the guidance of GL 89-01 as required by 10 CFR 50.91(a), against the standards of 10 CFR 50.92(c). The proposed modifications to this TSCR do not change the content or conclusions of the original"No Significant Hazards Consideration" because these proposed modifications merely insert additional administrative conditions for the control of effluents to the PBNP TS and modifies other conditions to be consistent with new guidance comained in Attachment C of the RAI.
t
15.7.8 ADMINISTRATIVE CONTROLS 15.7.8.1 Duties of the Manager's Supervisory Staff The duties of the Manager's Supenisory Staff with respect to these radiological effluent technical specifications are listed in Specification 15.6.5.1.8 at Ite.ns j. and k.
15.7.8.2 Audits A.
An audit of the activities encompassed by the Ibdioactive Etfluent and
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Materials Control and Accountability Program (REMCAPL Ithe Offsite Dose Calculation Manual (ODCML the Radiological Effluent Control Program (RECPL the Radiological Environmental Monitoring Progran (REMPL and the Process Control Program (PCP)l and its implementing procedures shall be performed utilizmg either offsite licensee personnel or a consulting firm.
B.
The results of the audits above shall be transmitted to the Vice-President Nuclear Power and the Chairman of the Offsite Review Committee.
l 15.7.8.3 Plant Onerating Procedures and Procrams The Radioactive Effluent and Mate. rials Control and Accountability Program REMCAP) shall be establishedjmplemented. and maintained in accorimee with thtprovisions of Technical Specification 15.6 8 REMCAP shall assure that radioactiverfiluent and waste materialftom PBNP complies with_ applicable Federal.
State. and burial ground regulations while keening all exnosures to members of the public as low as reasonablv achievable ( AL ARAL This nrogram shall conform to and imntemenL1he requirements of PBNP GDC 70 and of 10 CFR 50.34a and 10 CFR 50.36a for the control of radioattive effluents uhile maintaining doses from these effluents ALAB2\\. shall implement the reauirements of 10 CFR 5014a and General Design Criterion 60 of Appendix A to 10 CFR 50 to suitably control.the telease and the crocessing of waste materials. shall conform to the guidance of Apperdil! to 10 CFR 50 and PBNP GDC 17 for the assessment of radioaclivity m the environs of PBNP. and shall include remedial actions to be taken whenevetthe program limits are exceeded. REMCAP shall be imnlemented and maintained under the n ocedures and.methodo!ogies specified in the four (4) manuals /orograms listed below and_ Supported. as required. bv other procedures. Effluent and environmental monitntingjiha!! bem{ dressed m the.Opality Assurance Program.
Unit 1 - Amendment No.
15.7.8-1 Unit 2 - Amendment No.
j
i 3
Environmental Manual (EMI-in order to assure conformance with PBNP GDC 17 and with the guidance of Accendix I to 10 CFR 50. this manual shall contain the Radiological Environmental Monitoring Program (REMP) j methodology. narameters. and administrative functions required for j
monitoring. sampling. analyzing. and reporting of_ radiation levels and j
radionuclidesoncentrations in the environment around PBNP. The REh2 shall require an annual milk sunEand shall require that ra_dicanalvses to be
'j scaducitd_blalaboratorv participating in an InterleborateLLComparnen
)
Program.
j E
Radiological Ef0uent Contml Program Manual (RECM) The RECM thall cortain the Radiological Effluent Control Program (RECP) parameters and methodologies needsd in order to assure conformance with 10 CFR 50.36a for the control of effluents and for maintaining doses to the nublic AL ARA and h.comeliance with 10 CFR 20l302 The following RECP items are
_nptained in the RECM:
g 1) radioact:ve effluent monitoring instrumentation operabilitv. with actions -
to be taken if operability _tcq tirements are not met. and surveillance requirement 1.
.7 2) radioactivr_ effluent sampling and analy reauirements:
3) limitations on the concentrations of radioactive malerials in liquid i
effluents to the unrrstricted area to 10_ times the concentration value.in Appendix B. Table 2. Column 2 to 10CFR20.1001-20.2402: and limitations on the concentrations of redioactive effluents released to_1hg atmosphere at the site boundarv to the limits of enlumn 1. table 2 of Appendix B to 10 CFR 20.1091 -2402.
41 determination of the cumulative and nroiected dose contributions from radioactive effluents for the current calendar quarter and current caleng year in accordance with ODCM methodology and parameters everv 3 L davs:
ST assurance that tJie anorocriate nortions of the lionid and gaseaus efnuert treatment system are used whenever the croiected doses in a period of 31 davs would exceed 2 cercent of the 10CFR50. Accendix I dose guidelines:
6) limitations to the release rate of radioactive etTuent to the atmosphere in order to assure that the fellowing dose rates would not be exceeded at or bevond the site boundarv a.
500 mrem /vr. total bodv. from noble gases.
b.
- 3000 mrern/vr. skin. from noble gases c.
1500 mrem /vr. any organ. from I-131. I-133. H-3. and all radioactive particulates with a half-life greater than 8 davs:
Unit 1 - Amendment No.
15.7.8 2 Unit 2 - Amend' ment No.-
.m.
m.
e
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,7) limitations on the annual and auarteriv doses to a member of the public at or
- heyond the site boundarv from 1.131.1 133. H-3. and radioactive carticulates with a half-life >8 davs in effluents released to the atmosohere which confonn to 10CFR5f). Appendix I. dose _ guidelines. and l
- 8) _. Administrative functions andieporting requiremsnis, Onite Dose Calculation.Mamtal (ODChD The ODCM shall specify that the annual c.
pses from PBNP effluent shall conferm to the limits ofAppendixl to 10 CFR SD and of 40 CFR 100. shall cantalttihtparameters and metho.dology used to calculate the doses to members of the public from PBNP liquid.and atmospheric Igleases in utdcIitLdemonstrate compliance with these dose limits. andshalLtentam the methodology to calculate serpoints to ensure that the effluent radionuclide concentrationsin_untestricled_DItasJo not exceed the limit.ups.tilitd in the RECP.
d.
Process Control program (PCP)- The PChhall orovide the methodologies for assuringahat the proerssing and packaging of solid radioactive wastes will be actolnplished_in such a way as to assure compliance with 10 CFR Parts 20. 61 and
- 71. and all other applicable FederaLand State regulations governing the disposalef the radioactive waste.
- Unit 1 - Amendment No.
15.7.8-3 Unit 2 - Amendment No.
15.7.8.4-RETS Reoorting Reauirements The following written reports shall be submitted to the Administrator, U.S. Nuclear Regulatory Commission Region Ill with a copy to the Director, Office ofInspection and Enforcement, USNRC, Washington, D.C. 20555 within the time periods specified.
A.
Annual Monitoring Report A report covering the operation of PBNP for the previous twelve (12) month period or fraction thereof, ending December 31, shall be submitted by May 1 of each year containing:
1.
RECP Information relative to the cuantities of radioactive liauid and gaseous efnuents andsninLradioactive waste release.d from PBNP during the Irporting period The information shall be consistent with the obiectives outlined in the ODfM and RECM as well asSection IV.B.1 of gpendix I to 10 CFR 50 and 10 CFR 50.36a.
2, New and Sr.ent Fuel Receints and Shinments a.
Number and type of new fuel assemblies received during the reporting period, if any.
b.
Number of spent fuel assemblies shipped off site during the reporting period, if any.
3.
.REME Summaries and results fron the REMP for the reporting period. The information shall be consistent with the objectives outlined in the EN1 andjaSestions IV R 2. IV.B.3. and IV.C of Anpendix 1 to 10 CFR 50.
4.
Leak Testing of Scaled Sources Results of required leak tests performed on sealed sources if the tests reveal the presence of 0.005 microcuries or more of removable contamination.
5.
Nieteorological Data
- Meteorological data shall be kept in file on site for review by the NRC upon request. The data available wil' include wind speed, wind direction and atmospheric stability. The data will be in the form of strip charts or hour-by-hour averages stored m electronic form for each of the parameters.
Unit 1 - Amendment No.
15.7.8-4 Unit 2 - Amendment No.
6.
REMCAP Chances A description of changes to the REMCAP. OCCM. EM. RECM or PCP which were implemented and became effective during the l
teporting period shalLbuubmitted pursuant to Specification 1 S.7 8 L 7.
Snecial Circumstance Renorts l
In accordance with note 7 to RECM Table M, if the Waste Gas-a.
Holdup System Explosive Gas Monitor is out of service for greater than 14 days.
l b.
In accordance with the_Ehl, factors which render the LLDs unachievable.
l c.
In accordance with the EM, failure of the analytical laboratory to participate in an Interlaboratory Comparison Program.
B, hieasured Radioactivity Above Notification Levels If the confirmed level of radioactivity remains above the notification levels l
specified in the_EM, a written report describing the circumstance shall be prepared and submitted within thirty days of the confirma-tion that a notification level was exceeded.
C.
Radioactive Liauid Effluent Treatment if the radioactive liquid or gasecca effluent treatment system is inoperable and liquid cr_gasenus ef11uents are being discharged for 31 days without the treatment required to meet the release limits specified in the RECM, a special report shall be prepared and submitted to the Commission within thirty days which includes the following information:
1.
Identification of the inoperable equipment or subsystem and the reason for inoperability.
2.
Actions taken to restore the inoperable equipment to operable status.
3.
Summary description of actions taken to prevent a recurrence.
D.
Radioactive Effluent Releases If the quantity of radioactive material actually released in liquid or gaseous effluents during any calendar quarter exceeds twice the quarterly limit as l
specified in the RECM, a special report shall be prepared and submitted to the Commission within thirty days of determination of the release quantity.
Unit 1 - Amendment No.
15.7,8-5 Unit 2 - Amendment No.
15,7.8.5 Major Change to Radioactive Liould. Gaseous and Solid Waste Treatment Systems Licensee initiated major changes to the radioactive waste treatment systems (liquid, gaseous, and solid) shall be reported to the U.S. Nuclear Regulvory Commission with the annual update to the FSAR for the period in which the major change was complete.
The discussion 'of each change shall include:
A.
A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR Part 50.59; B.
Information necessary to support the reason for the change; b
C.
A description of the equipment, components and processes involved and the interfaces with other plant sptems; D.
An evaluation of the change, which shows how the predicted releases of radioactive materials in liquid effluents and gaseous effluents and/or quantity of solid waste will differ from those previously predicted in the license application 4'
and amendments thereto; E.
An evt.luation of the change, which shows the expected maximum exposures to an individual in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto; F.
An estimate of the exposure to plant operating personnel as a result of the change.
l 1S.7.8.6 Record Retention Records of reviews oerformed for changes made to the REMCAP Manual and to ths following REMCAP components: the EM. RECM. ODCM. and PCP: shall be kept for the duration of the operating licenses of Units 1 and 2 of the Point Beach Nuclear Plant.
15.7.8.7 Revisions
-tL_
Process Control Progran1 Revisions to the PCP shall be documented and records of reviews oerformed for the revision shall be retained as reouired by 15.7 8.6. -Tae documentation shall contain:
1.
luformation sufficient to suonort the change together with the nooropriate analyses or evaluations instifying the change (st and i
Unit 1 - Amendment No.
15.7.8-6 j
Unit 2 - Amendment No.-
2.
A determination that the change will maintain the overall confonnance of the solidified waste nroduct to existing reauirements of federal. State. or other applicable regulations.
3 Revisions shall become effective afler review and acceptance bv the Manager's Supervisory Staff and annroval by the Manager - PBNP.
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11 Revisions ta the EM. ODCM. RECM.and REMCAP 1.
Revisions to the EM, ODCM. RECM and REMCAP shall be documented and reviews performed of the revision shall be retained as required in 15.7.8.i_The documentation shall contain:
a.
Sufficient infomiation to support the change together with the appropriattanalvses or evaluations iustifying the revision. anf b.
A determination that the change will maintain the levels of radioactive effluent control requited nursuant to 10 CFR 20.1302.10 CFR 50.36a. Anpendix 1 to 10 C.ER 50. and 40 CFR 190.
2.
Shall become effective after review and acceptance by the Manager's Sipervisory Staff and the approval of the Manager-PBNP.
3.
Shall be submitted _to the Commission in the form of a con plele, legible cony of the entire manual either as nart of. or concurrent with.
the Annual Monitoring Report for the nerioQf the renort in which the revision was made. Each change shall be id;ntified by markings m the margin of the affected pages. clearly indicating the area of the page that was changd. Each conv shall indicate the date (e.g..
montMyear) the revision was imolemented.
4.
In addit:an to items 1-3 above. all changes regardir g exnlosive gas muSLbe made via the 50.59 nrocess.
Unit 1 - Amendment No..
15.7.8-7 Unit 2 - Amendment No.