ML20206G065

Redistributed Application for Amend to License NPF-57, Incorporating Programmatic Controls in TS for Radioactive Effluents & for Environ Monitoring Conforming to Applicable Regulatory Requirements.Rev 18 to ODCM Also Encl

ML20206G065
Person / Time
Site:	Hope Creek
Issue date:	03/29/1999
From:	Eric Simpson Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206G068	List: ML20206G065 ML20206G211 ML20206G228
References
GL-89-01, GL-89-1, LCR-H99-02, LCR-H99-2, LR-N99096, NUDOCS 9905070050
Download: ML20206G065 (11)

Text

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CREDIsTRIBUTED April 30, 1999. ATTACHMENTS NOT INCLUDED ON ALL COPIES FOR ORIcINAL DISTRIBUTION.

Electne and Gas I Company E. C. Simpson i Public Service Electnc and Gas Cornpany PO Box 236 Mancocks Bnoge. NJ 08038 Seacr v ce P es cent %ciear Eagineemg 609 339 CC l i

IIAR S 91999 LR-N99096 LCR H99-02 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS RADIOACTIVE EFFLUENT TECHNICAL SPECIFICATIONS HOPE CREEK GENERATING STATION l FACILITY OPERATING LICENSE NPF 57 DOCKET NO. 50-354 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a revision to the Technical Specifications (TS) for the Hope Creek Generating Station (HC). In accordance with 10CFR50.91(b)(1), a copy of this submittal has been sent to the State of New Jersey. The changes proposed in this submittal consist of revisions to the Radiological Effluent Technical Specifications and Administrative Controls. This submittal is consistent with NRC Generic Letter (GL) 8 01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specification (RETS)in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program." The proposed amendment will incorporate programmatic controls in the Technical Specifications for radioactive effluents and for environmental monitoring conforming to the applicable regulatory /,

requirements.

Procedural 6etails associated with solid radioactive wastes will be relocated to the Process Control Program (PCP).

g The changes proposed in this submittal have been prepared in accordance with the proposed changes to the Administrative Controls section of the Technical Specifications as specified in GL 89-01. A complete copy of the revised ODCM is forwarded with this License Change Request (LCR) for NRC reference as specified in GL 89-01.

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M 2 91999 Document Control Desk LR-N99096 Changes to the ODCM have been prepared in accordance with the guidelines in NUREG-1302, Offsite Dose Calculation Manual Guideline: Standard Radiological {

l Effluents Controls,for Boiling Water Reactors - Generic Letter 89-01, Supplement '

No.1."

As a result of relocating the proposed RETS into the ODCM, the requirement currently contained in the ODCM to obtain NRC approval prior to any changes will be removed so as to meet the intent of GL 89-01. GL 89-01 states that the NRC staff does not intend to repeat technical reviews of the relocated procedural details because their consistency with the applicable regulatory requirements is a matter of record from past reviews of RETS.

Furthermore, PSE&G, Hope Creek Generating Station, intends to operate within the requirements of the "old" 10 CFR Part 20 requirements. By letter dated June 30,1993 from Thomas E. Murley, then Director, Office of Nuclear Reactor Regulation, to Thomas E. Tipton, formally NUMARC, the NRC responded to an industry inquiry on promulgation of a new Part 20. In the letter the NRC stated:

I After careful review of your position and other relevant factors, we have determined that it is acceptable to the staff for licensees to retain their existing level of effluent control as implementing the ALARA requirements after January 1,1994, without submitting individual requests for amending their technical specifications to comply with new 10 CFR 20.1101(b).

l The letter further states " .we are preparing a Generic Letter to provide model Technical Specification wording to ensure conformance with the revised Part 20 requirements." And "The model changes for Technical Specifications that will be in the Generic Letter are intended to eliminate possible confusion or improper implementation of revised Part 20 requirements."

Since then, the NRC has canceled its plan to issue a Generic Letter so as to devote more resources to conversion reviews and additional reviews to the Improved Standard Technical Specifications (ITS). PSE&G, Hope Creek Generating Station, will continue to comply with the requirements of "old" part 20, i.e., and its Appendices, for release of radioactive effluents. The method currently in use for controlling releases to within the "old" 10 CFR 20.106, Appendix B concentration MPC limits based on " instantaneous" concentration values is still suitable for demonstrating conformance to the requirements of "new" 10 CFR Part 20, Appendix B ECL concentration limits. Controlling radioactive effluents to within the MPC values based on an instantaneous release rate (i.e. no time averaging of effluent concentrations) is considered to be more conservative than the requirements of the "new" 10 CFR Part 20 which have limits stated as effluent concentrations averaged over a year.

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. Document Control Desk LR-N99096 ,

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The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1),

using the criteria in 10CFR50.92(c), and a determination has been made that this request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 4. The revised ODCM is provided in Attachment 5.

I PSE&G has determined that LCR H99-02 meets the criteria of 10 CFR 51.22(c)(9) and  !

10 CFR 51.22(c)(10) for a categorical exclusion from the requirements for an Environmental impact Statement (see Attachment 3) i Upon NRC approval of this proposed change, PSE&G requests that the amendment be ' '

made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

i Should you have any questions regarding this request, please contact Dennis V.

Hassler at 609-339-1989.  ;

Sincerely, i l

l l Affidavit Attachments (5) l l

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i NAR 2 91999 I Document Control Desk LR-N99096 C Mr. H. Miller, Administrator - Region I i I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek l

U. S. Nuclear Regulatory Commission l One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. S. Pindale (X24)

USNRC Senior Resident inspector - HC Mr. K. Tosch, Manager IV l Bureau of Nuclear Engineering l P. O. Box 415 Trenton, NJ 08625  !

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l MAR 2 91999 Document Control Desk , LR-N99096 Changes to the ODCM have been prepared in accordance with the guidelines in NUREG-1302, Offsite Dose Calculation Manual Guideline: Standard Radiological Effluents Controls,for Boiling Watar Reactors - Generic Letter 89-01, Supplement No. 1."

As a result of relocating the proposed RETS into the ODCM, the requirement currently contained in the ODCM to obtain NRC approval prior to any changes will be removed so as to meet the intent of GL 89-01. GL 89-01 states that the NRC staff does not intend to repeat technical reviews of the relocated precedural details because their consistency with the applicable regulatory requirements is a matter of record from past reviews of RETS.

Furthermore, PSE&G, Hope Creek Generating Station, intends to operate within the requirements of the "old" 10 CFR Part 20 requirements. By letter dated June 30,1993 from Thomas E. Murley, then Director, Office of Nuclear Reactor Regulation, to Thomas E. Tipton, formally NUMARC, the NRC responded to an industry inquiry on promulgation of a new Part 20. In the letter the NRC stated:

After careful review of your position and other relevant factors, we have determined that it is acceptable to the staff for licensees to retain their existing level of effluent control as implementing the ALARA requirements after January 1,1994, without submitting individual requests for amending their technical specifications to comply with new 10 CFR 20.1101(b).

1 The letter further states " .we are preparing a Generic Letter to provide model Technical Specification wording to ensure conformance with the revised Part 20 requirements." And "The model changes for Technical Specifications that will be in the Generic Letter are intended to eliminate possible confusion or improper implementation of revised Part 20 requirements."

Since then, the NRC has canceled its plan to issue a Generic Letter so as to devote  ;

more resources to coriversion reviews and additional reviews to the Improved Standard  !

4 Technical Specifications (ITS). - PSE&G, Hope Creek Generating Station, will continue to comply with the requirements of "old" part 20, i.e., and its Appendices, for release of radioactive effluents. The method currently in use for cLntrolling releases to within the "old" 10 CFR 20.106, Appendix B concentration MPC limits based on " instantaneous" concentration values is still suitable for demonstrating conformance to the requirements of "new" 10 CFR Part 20, Appendix B ECL concentration limits. Controlling radioactive ,

effluents to within the MPC values based on an instantaneous release rate (i.e. no time averaging of effluent concentrations) is considered to be more conservative than the requirements of the "new" 10 CFR Part 20 which have limits stated as effluent concentrations averaged over a year.

MAR 2 91999 Document Control Desk LR-N99096 .

The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1),

using the criteria in 10CFR50.92(c), and a determination has been made that this request involves no significant hazards considerations. The basis for the requested change is provided in Attachment 1 to this letter. A 10CFR50.92 evaluation, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Technical Specification pages affected by the proposed changes are provided in Attachment 4. The revised ODCM is provided in Attachment 5.

PSE&G has determined that LCR H99-02 meets the criteria of 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10) for a categorical exclusion from the requirements for an Environmental Impact Statement (see Attachment 3)

Upon NRC approval of this proposed change, PSE&G requests that the amendment be '

made effective on the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, please contact Dennis V.

Hassler at 609-339-1989.

i Sincerely, Affidavit Attachments (5) e.

MAR S 91999 Document Control Desk LR-N99096 C Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 i 11555 Rockville Pike Rockville, MD 20852 Mr. S. Pindale (X24) l USNRC Senior Resident inspector - HC j l

Mr. K. Tosch, Manager IV l l

Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625

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REF: LR-N99096 LCR H99-02 STATE OF NEW JERSEY SS.

COUNTY OF SALEM E. C. Simpson, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Engineering of Public Service E!2)ctric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerninn Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.

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Subscribed and Swgn to before me this O k day of /dd 1999 i

/JA b1A Jn &

fotary Publid6f New Jersey My Commission expires on ;A / /, M3 d

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l-Document Control Desk LR-N99096 DVH BC Senior Vice President - Nuclear Operations (XO4)

Senior Vice President - Nuclear Engineering (N19) l General Manager - Hope Creek Operations (HO7)

Director- QA/NT/EP (XO1) l Director - Licensing / Regulation and Fuels (N21)

Director - Design Engineering Manager - Financial Control & Co-Owner Affairs (N07)

Program Manager - Nuclear Review Board (N38)

Manager - Hope Creek Operations (H01)

Manager - System Engineering - Hope Creek (H18)

Manager- Hope Creek Licensing (N21)

J. Keenan, Esq. (N21)

NBU RM (N64)

Microfilm Copy l Files Nos.1.2.1 (Hope Creek),2.3 (LCR H99-02) i l

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Drcument Crntrol De:k LR-N99096 Attachment 1 LCR H99-02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO, 50-354 ,

REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

. BASIS FOR REQUESTED CHANGE:

License Change Request (LCR) H99-02 proposes changes to Hope Creek Generating Station _ Radiological Effluent Technical Specifications (TS) and Administrative Controls section of the TS, as authorized in NRC Generic Letter (GL) 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specification (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dosa Calculation Msnual or to the Process Control Program."

RJOUESTED CHANGE. PURPOSE AND BACKGROUND:

The proposed LCR will incorporate programmatic controls in the TS for radioactive effluents and for environmental monitonng conforming to the applicable regulatory requirements. This will allow relocation of existing procedural details of the current RETS to the Offsite Dose Calculation Manual (ODCM). Procedural details associated with solid radioactive wastes will be relocated to the Process Control Program (PCP).

The proposed LCR changes are consistent with the guidance contained in NRC GL 89-01 .

JUSTIFICATION OF REQUESTED CHANGES:

The proposed LCR will provide programmatic controls for RETS consistent with regulatory requirements and allow relocation of procedural detail, consisting of the limiting conditions for operation (LCOs). their applicability, remedial actions. surveillance requirements and the Bases section of the TS for these requirements, to the appropnate licensee-controlled documents. Relocation of the procedural details to the appropnate licensee-controlled document is justified since they no longer meet the enteria of 10 CFR 50.36 for inclusion in TS In GL 89-01, the NRC examined the contents of the RETS in relation to the then existing Commission s intenm Policy Statement on Technical Specification improvements The NRC determined that programmatic controls could be implemented in the Administrative Controls Section of the TS to satisfy regulatory requirements Additionally. the NRC determined that the procedural Pace 1 of 3

Document Control Deck LR-N99096 Attachment 1 LCR H99-02 details of the current TS on radioactive effluents and radiological environmental monitoring could be relocated to the ODCM, likewise, the procedural details of the current TS on solid radioactive wastes could be relocated to the PCP.  ;

These actions sirpplify the RETS, meet the regulatory requirements for  ;

radioactive effluents and radiological environmental monitoring, and are provided as a line-item improvement.

Subsequent to NRC GL 89-01, the NRC revised 10 CFR 50.36 on July 19, 1995 to meet the intent of policy statement, " Final Policy Statement on Technical Specification improvements for Nuclear Reactors," (58FR39132),

which provided a specific set of four objective criteria to determine which of the design conditions and associated surveillances should be located in TS as limiting conditions for operation. The NRC recognized that implementation of these criteria may cause some requirements presently in TS to no longer merit inclusion in TS. The proposed RETS to be relocated are candidates for no longer meriting inclusion in TS since they do not meet the four objective criteria ,

specified in 10 CFR 50.36. The proposed changes in NRC GL 89-01 are l consistent with the four objective criteria and meet applicable regulatory requirements.

Future changes to the relocated RETS, in either the ODCM or PCP, will be governed by the programmatic and administrative controls specified in the Administrative Controls section of TS. Therefore, a comparable level of administrative control will continue to be applied to those design conditions and l associated surveillances being relocated to the ODCM or PCP.

One other change is made to the ODCM is the reference to the requirement that requires prior NRC review and approval of all proposed changes made to the ODCM The requirement to obtain NRC review and approval prior to implementation of the proposed changes predates the NRC initiative in GL 89- l 01 to place the responsibility for the procedural details of the required effluent and environmental monitoring programs directly with the licensee. GL 89-01 states that the NRC staff does not intend to repeat technical reviews of the l related procedural details because their consistency with the applicable requirements is a matter of record from past NRC reviews of RETS. The procedural details associated with these programs, which are currently contained in the ODCM. are addressed in GL 89-01, Supplement 1, as procedural details which merit relocation to the ODCM. Therefore, since the procedural details for sampling and analysis associated with the aforementioned programs are presently contained in the ODCM the requirement to obtain NRC approval prior to any changes is no longer Pace 2 of 3

Document Control DTk LR-N99096 Attachment 1' LCR H99-02 applicable and will be removed so as to meet the intent of GL 89-01. As previously stated, future changes to the ODCM will be governed by the programmatic controls specified in the Administrative Controls section of TS. i

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CONCLUSIONS:

The proposed changes transfer procedural requirements for radiological effluent and environmental monitoring for the TS to other licensee-controlled documents, ODCM and PCP, along with the addition of programmatic and administrative controls for these procedural requirements being placed in the Administrative Controls section of the TS.

The content of existing technical requirements concerning RETS is not affected by the proposed changes. The proposed changes will not reduce the accuracy or reliability of the dose calculations or setpoint determinations performed under the existing ODCM l since none of these methods are affected by the proposed changes i 1

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i Drcumcnt Contr:l De:k LR-N99096 Attachment 2 LCR H99-02 k i

HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 )

DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS) 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Hope Creek Generating Station (HC) Technical Specifications do not involve a '

significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

REQUESTED CHANGE License Change Request H99-02 proposes changes to Hope Creek Generating .

Station's Radiological Effluent Technical Specifications (RETS) and Administrative Controls section of the Technical Specifications (TS), as authorized by NRC Generic Letter (GL) 89-01, " Implementation of Programmatic Controls for Radiological Effluent  :

Technical Specification (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program." The proposed amendment has been prepared in accordance with the guidance specified in GL 89-01. The proposed amendment incorporates the programmatic controls in the TS for radioactive effluents and for environmental monitonng conforming to the applicable regulatory requirements.

This will allow relocation of existing procedural details of the current RETS to the Offsite Dose Calculation Manual (ODCM) Procedural details associated with solid radioactive wastes will be relocated to the Process Control Program (PCP).

BASIS 1 The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated The proposed changes do not affect accident initiators or precursors and do not alter the design assumptions. conditions, configuration of the facility or the manner in which the plant is operated The proposed changes do not alter or prevent the ability of structures, systems, or components to perform their intended function to mitigate the consequences of an initiating event within the acreptance limits assumed in the Updated Final Safety Analysis Report (UFSAR) The proposed changes are administrative in nature and do not change the level of programmatic controls and procedural details relative to radiological effluents Pace 1 of 2

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Decument Cantrci De2k Att chm:;nt 2 LR-N99096 LCR H99 02  !

Implementation of programmatic controls for RETS in TS will assure that the applicable regulatory requirements pertaining to the control of radioactive effluents will continue to be maintained. Since there are no changes to previous accident analysis, the radiological consequences associated with these analyses remain unchanged, therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not alter the design assumptions, conditions, configuration of the facility or the manner in which the plant is operated. The proposed changes have no impact on component or system interactions. The proposed changes are

administrative in nature and do not change the level of programmatic controls and j

procedural details relative to radiological effluents. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously i evaluated.

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

There is no impact on equipment design or operation and there are no changes being made to the TS required safety limits or safety system settings that would adversely affect plant safety as a result of the proposed changes. The proposed changes are administrative in nature and do not change the level of programmatic controls and procedural details relative to radiological effluents. A comparable level of administrative control will continue to be applied to those design conditions and associated surveillances being relocated to the ODCM or PCP. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

CONCLUSION Based on the above. PSE&G has determined that the proposed changes do not involve a significant hazards consideration i

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