ML20211N553
| ML20211N553 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/08/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20211N544 | List: |
| References | |
| NUDOCS 9909130020 | |
| Download: ML20211N553 (9) | |
Text
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UNITED STAT 7S
'j NUCLEAR REGULATORY COMMISSION j
t WASHINGTON. D.C. 2055H001 S
4
. SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
. RELATED TO AMENDMENT NO. 121 TO FACILITY OPERATING LICENSE NO. NPF-57 PUBLIC SERVICE ELECTRIC & GAS COMPANY ATLANTIC CITY ELECTRIC COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354
1.0 INTRODUCTION
By letter dated March 29,1999, as supplemented June 21,1999, the Public Service Electric &
Gas Company (the licensee) submitted a request for changes to the Hope Creek Generating Station (HCGS) Technical Specifications (TSs). The proposed amendment would revise the TSs by relocating the procedural details of the Radiological Effluent Technical Specifications (RETS) to the Offsite Dose Calculation Manual (ODCM). The TSs would also be revised to relocate procedural details associated with solid radioactive wastes to the Process Control Program (PCP). In addition, the Administrative Controls section of the TSs would be revised to incorporate programmatic controls for radioactive effluents and environmental monitoring.
Guidance on these proposed changes was provided to all power reactor licensees and applicants by Generic Letter (GL) 89-01, " 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 RETS to the Offsite Dose Calculation Manual or to the Process Control Program."
The June 21,1999, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination or expand the scope of the original Federal Reoister notice.
2.0 BACKGF)UND Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires TSs to be i
made part of any license issued to operate production or uGi::ation facilities. Section 50.36 of
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Title 10 of the Code of Federal Reculations (10 CFR)," Technical Specifications," implements Section 182a of the Act and delineates requirements for determining the contents of TSs.
Gection 50.36 requires that the TSs include items in specific categories, including (1) safeti limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. However, @ 50.36 does not specify the particular requirements to be included in a plant's TSs.
9909130020 990908 PDR ADOCK 05000354 P
I 2-The following four criteria are defined by 10 CFR 50.36 to determine whether particular items are required to be included in the TSs:
(1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to pub!ic health and safety.
As discussed in GL 89-01, the NRC staff examined the contents of the RETS in relation to the then existing Commission's
- interim Policy Statement on Technical Specification improvements for Nuclear Power Reactors"(52 FR 3788). The staff determined that programmatic controls could be implemented in the Administrative Controls section of the TSs to satisfy regulatory requirements for the RETS. Additionally, the staff determined that the procedural details of the current TSs on radioactive effluents and radiological environmental monitoring could be relccated to the ODCM. Likewise, the procedural details of the current TSs on solid radioactive wastes could be relocated to the PCP. These actions simplify the RETS, meet regulatory requirements for radioactive effluents and radiological environmental monitoring, and are provided as a line-item improvement, consistent with the goals of the Policy Statement.
As discussed in the licensee's submittal dated March 29,1999, the proposed changes were prepared consistent with the guidance contained in GL 89-01. The proposed items to be relocated are candidates for no loriger meriting inclusion in the TSs since they don't meet the four objective criteria specified in 10 CFR 50.36. Future changes to the relocated RETS, in l
either the ODCM or PCP, would be govemed by the programmatic and administrative controls specified in the Administrative Controls section of the TSs.
3.0 EVALUATION l
As discussed in Enclosure 1 to GL 89-01, the following items are to be included in a license amendment request to implement the RETS changes:
(1)
The model specifications -in Enclosure 3 to GL 89-01 should be incorporated into the TSs to satisfy the requirements of 10 CFR 20.106,40 CFR Part 190.10 CFR 50.36a, and Appendix i to 10 CFR Part 50. The TS definitions of the ODCM and PCP should be updated to reflect these changes.
m 3-(2)
The procedural details covered in the licensee's current RETS, consisting of LCOs, their applicability, remedial acilons, surveillance requirements, and the Bases section of the TSs for these requirements, are to be relocated to the ODCM or PCP as appropriate and in a manner that ensures that these details are incorporated in plant operating procedures.
(3)
The licensee should' confirm in the amendment request that changes for relocating the procedural details of the current RETS to either the ODCM or PCP have been prepared in accordance with the proposed changes to the Administrative Controls sections of the TSs so that they may be implemented immediately upon issuance of the proposed amendment. A complete and legible copy of the revised ODCM should be forwarded with the amendment request for NRC use as a reference.
The staff has reviewed the licensee's amendment request to ensure that the three items discussed above were properly addressed. The staff's evaluation for each of these items is included in sections 3.1,3.2, and 3.3 of this safety evaluation, respectively. In addition, in order tu address issues discussed in the licensee's submittal related to compliance with 10 CFR Part 20, a review of the applicable 10 CFR Part 20 requirements is provided in section 3.4.
3.1 Incorporation of Programmatic Controls in the Administrative Controls Section of the TSs to GL 89-01 provides model TS revisions to supplement or replace existing specifications. These model TSs provide programmatic controls for RETS and its associated reporting requirements. Also included in Enclosure 3 are model definitions for the ODCM and PCP to reflect the programmatic controls and reporting requirements changes.
The licensee has proposed to revise the following HCGS TSs to implement the guidance provided in Enclosure 3 to GL 89-01:
SPECIFICATION TITLE f
1.27 DEFINITIONS: OFFSITE DOSE CALCULATION MANUAL 1.33 DEFINITIONS: PROCESS CONTROL PROGRAM 6.8.4.g PROCEDURES AND PROGRAMS: RADIOACTIVE EFFLUENT l
CONTROLS PROGRAM 6.8.4.h PROCEDURES AND' PROGRAMS: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 6.9.1.6 REPORTING REQUIREMENTS: ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.7 REPORTING REQUIREMENTS: ANNUAL RADIOACTIVE EFFLUENT i
RELEASE REPORT e
.. 6.10.3
' RECORD RETENTION 6.13 PROCESS CONTROL PROGRAM (PCP) 6.14.
OFFSITE DOSE CALCULATION MANUAL (ODCM)
The proposed revisions to the above referenced TSs are consistent with the guidance provided in GL 89-01 except for the following item:
(1) to GL 89-01 indicates that the Radioactive Effluent Release Report is submitted on a semi-annual basis. The licensee's proposed changes to TSs 1.27, 6.9.1.7, and 6.14 Indicate that this report is submitted annually. The change in submittal frequency from semi-annually to annually was previously approved for HCGS in a safety evaluation dated April 15,1994, for Amendment No. 67. That change was approved consistent with a revision to 10 CFR 50.36a which became effective on October 1,1992.
Therefore, the staff finds that this deviation from the guidance in GL 89-01 is acceptable 3.2 incorporation of Procedural Details of Current RETS into the ODCM or PCP to GL 89 01 provices a listing of existing TSs included under the heading of RETS i
in the Standard Technical Specifications and includes a description of how each specification l
should be dispositioned (e.g., relocate procedural details of current RETS to the ODCM or PCP, retain existing requirement in the TSs).
The licensee has proposed tu delete the following HCGS TSs including the associated LCO's:
their applicability, action statements, surveillance requirements, and Bases. The procedural details contained in these TSs would be relocated to the ODCM or PCP as appropriate, in accoidance with the guidance in Enclosure 2 to GL 89-01:
SPECIFICATION TITLE 1.42 SOLIDIFICATION 3/4.3.7.10 RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION 3/4.3.7.11 RADIOACTIVE GASEOUS EFFLUENT MONlTORING INSTRUMENTATION 3/4.11.1.1 LIQUID EFFLUENTS: CONCENTRATION 3/4.11.1.2 LIQUID EFFLUENTS: DOSE 3/4.11.1.3-LIQUID EFFLUENTS: LIQUID WASTE TREATMENT 3/4.11.2.1 GASEOUS EFFLUENTS: DOSE RATE
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3/4.11.2.2 GASEOUS EFFLUENTS: DOSE - NOBLE GASES
! l 3/4.11.2.3 GASEOUS EFFLUENTS: DOSE - IODINE-131, IODINE-133, TRITlUM, AND RADIONUCLIDES IN PARTICULATE FORM 3/4.11.2.4 GASEOUS EFFLUENTS: GASEOUS RADWASTE TREATMENT 3/4.11.2.5 GASEOUS EFFLUENTS: VENTlLATION EXHAUST TREATMENT SYSTEM 3/4.11.2.8 GASEOUS EFFLUENTS: VENTING OR PURGING 3/4.11.3 SOLID RADIOACTIVE WASTE TREATMENT 3/4.11.4 RADIOACTIVE EFFLUENTS: TOTAL DOSE 3/4/12.1 RADIOLOGICAL ENVIRONMENTAL MONITORING: MONITORING PROGRAM l
3/4/12.2 RADIOLOGICAL ENVIRONMENTAL MONITORING: LAND USE CENSUS 3/4/12.3 RADIOLOGICAL ENVIRONMENTAL MONITORING:
INTERLABORATORY COMPARISON PROGRAM 6.15 MAJOR CHANGES TO RADIOACTIVE LIQUID, GASEOUS AND SOLID WASTE TREATMENT SYSTEMS The proposed deletion and relocation of the above referenced TSs is consistent with the guidance provided in GL 89-01. to GL 89-01 also lists two TSs which should be revised in accordance with, wh2e the existing procedural details are relocated to the ODCM or PCP as appropriate. The licensee has proposed to revise the following TSs (as evaluated in section 3.1 above) and to relocate the existing procedural details to the ODCM SPECIFICATION TITLE 6.9.1.6 REPORTING REQUIREMENTS: ANNUAL RADIOLOGICAL j
ENVIRONMENTAL OPERATING REPORT 6.9.1.7 REPORTING REQUIREMENTS: ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The proposed relocation of the existing procedural details to the ODCM for these two TSs is consistent with the guidance provided in GL 89-01.
i The procedural details that have been relocated are not required by the Commission's regulations to be included in the TSs (i.e., they don't satisfy the four criteria discussed in the Background section above). Future changes to these procedural details, in either the ODCM or i
PCP, will be governed by the programmatic controls included in the Administrative Controls section of the TSs.
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The licensee's submittal dated March 29,1999, states that one other change being made to the j
ODCM is the deletion of the requirement for prior NRC review and approval of all proposed 1
changes to the ODCM. As discussed in GL 89-01, the NRC staff does not intend to repeat technica 4 aviews of the relocated procedural details because their consistency with the applicable regulatory requirements is a matter of record from past NRC reviews of RETS.
l Consistent with the intent of the GL, the licensee rnay make future changes to the ODCM without prior NRC approvalin accordance with 10 CFR 50.59.
The licensee has proposed to retain the following HCGS TSs, in accordance with the guidance j
in Enclosure 2 to GL 89-61:
]
SPECIFICATION TITLE j
3/4.11.1.4 LIC'JID HOLDUP TANKS 1
3/4.11.2.7 MAIN CONDENSER 5.1 DESIGN FEATURES: EXCLUSION AREA AND MAP DEFINING UNRESTRICTED AREAS AND SITE BOUNDARY FOR RADIOACTIVE GASEOUS AND LlOUlD EFFLUENTS Note, E closure 2 to GL 89-01 states that the TS section 3/4.11.2 requirements for " Explosive Gas Mixture" and " Gas Storage Tanks" should also be retained. However, these two TSs are not applicable to the current HCGS TSs. Therefore. the proposed retention of the above referenced TSs is consistent with the guidance provided in GL 89-01.
3.3 Licensee Confirmation that Guidance in GL 89-01 has been followed The licensee confirmed in their submittal dated March 29,1999, that the changes for relocating the procedural details of the current RETS to either the ODCM or PCP were prepared in accordance with the proposed changes to the Administrative Controls section of the TSs as specified in GL 89-01. The changes to the ODCM and PCP.will be implemented when this amendment is implemented.
3.4 Review of Applicable 10 CFR Part 20 Requirements GL 89-01 was issued on January 31,1989, and referenced the requirements of 10 CFR 20.106 for control of releases of radioactive effluents. This is consistent with the current B?ses for HCGS TS 3/4.11.1, " Liquid Effluents" and TS 3/4.11.2, " Gaseous Effluents," which also reference 10 CFR 20.106.
Subsequent to the issuance of the GL,10 CFR Part 20," Standards for Protection Against Radiation," was revised. The revised Part 20 became effective for all NRC licensees on January 1,1994. The "old" Part 20 (i.e., prior to the revision) consisted of Sections 20.1 through 20.601 while the revised Part 20 consists of Sections 20.1001 through 20.2402.
Section 20.1008, " Implementation," of the revised Part 20 states that any existing license i
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condition or TS that is more restrictive than a requirement in the revised Part 20 remains in force until there is a TS change, license amendment, or license renewal.
In a letter dated April 28,1993, the Nuclear Management and Resources Council (NUMARC),
requested the NRC to review NUMARC's characterization of the generalintent and applicability of the implementation of the revised Part 20 with regard to Part 50 licensee's RETS.
Specifically, the NUMARC letter provided their position which included the following general principles:
(1)
The generalintent of the revised Part 20 irnplementation requirements with regard to TSs is to assure that applicable requirements in the revised Part 20 are met and, where more restrictive, that the existing TSs remain in force.
(2)
The general intent of the revised Part 20 is that radiation doses to members of the public not exceed 100 mrems per year, which is more restrictive than the 500 mrems per year limit in the "old" Part 20, and that fuel cycle licensees also comply with 40 CFR 190. The revised Part 20 does not include a requirement on limiting radioactive concentrations in effluents, which is less restrictive than the "old" Part 20.
(3)
The generalintent of the RETS issued in Part 50 licenses is to assure that annual radiation doses to any member of the public due to effluents will not exceed 25 I
mrems to the whole body,75 mrems to the thyroid, and 25 mrems to any other organ, as required by 40 CFR 190: and that radiological effluents when averaged over one hour, will not exceed the maximum permissible concentrations in the "old" Part 20, Appendix B, Table ll, for liquid effluents and the dose rate l
associated with that table for gaseous effluents.
(4)
The Part 50 licensee RETS, as referenced to the "old" Part 20, are generally more restrictive than the comparable requirements in the revised Part 20.
l The NUMARC letter concluded that RETS that reference the "old" Part 20 are generally more restrictive than the comparable requirements of the revised Part 20, and therefore, in accordance with 10 CFR 20.1008, the existing RETS could remain in force af ter1hTIIEErlsee implements the revised Part 20 until there is a change to the applicable TSs through a license amendment. The letter stated that the existing RETS that reference the "old" Part 20 would maintain the level of required protection of public health and safety and would be consistent with the requirernents of the revised Part 20.
The licensee's submittal dated March 29,1999, states that HCGS intends to continue to operate within the requirements of the "old" 10 CFR Part 20 and its Appendices for release of radioactive effluents. The submittal states that the inethod currently in use for controlling releases to within the "old" 10 CFR 20.106, Appendix B maximum permissible concentration limits based on " instantaneous" concentration values is still suitable for demonstrating conformance to the requirements of the revised 10 CFR Part 20, Appendix B effluent concentration limits.
.6,
The submittal references a letter dated June 30,1993, from Thomas E. Murley, then Director of the Office of Nuclear Reactor Regulation, to Thomas E. Tipton of NUMARC, which provided the NRC's response to the NUMARC letter dated April 28,1993. The NRC response states in part that:
Af ter 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 requirement after January 1, 1994, without submitting individual requests for amending their technical specifications to comply with new 10 CFR 20.1101(b). Therefore, the instantaneous release rate limits, which are specified by reference to the values in Appendix B, will continue to be the values in Appendix B prior to the revision, until the technical specifications are changed.
Based on the above, the staff finds it acceptable for the existing HCGS RETS, which reference the requirements of 10 CFR 20.106 for control of releases of radioactive effluents, to be relocated to the ODCM without revision to the revised Part 20 requirements.
3.5 Summary a
Based on the above evaluation, the staff finds that the proposed TS amendment is consistent,
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except as discussed above, with the guidance provided in GL 89-01. All deviations from the j
guidance in GL 89-01 were found to be acceptable. Since the control of radioactive effluents
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and radiological environmental monitoring continue to be limited in accordance with operating procedures that must satisfy the requirements of 10 CFR 20.106,40 CFR Part 190,10 CFR 50.36a, and Appendix I to 10 CFR Part 50, the staff concludes that these changes are administrative in nature and that there is no adverse irnpact on plant safety as c consequence.
Accordingly, the NRC staff finds that the proposed changes are acceptable.
4.0 STATE CONSlJLTATION In accordance with the Commission's regulations, the New Jersey State Official was notified of the proposed issuance of the amendment. The State official had no comments.
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5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes 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 changes surveillance requirements. The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (64 FR 27324). Accordingly, the amendmerit meets 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 amendment.
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6.0: CONC' USION L
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by i
operation in the proposed nianner,-(2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
~ Principal Contributor: - R. Ennis Date: September 8, 1999 i
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