ML20217Q091
| ML20217Q091 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/05/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20217Q094 | List: |
| References | |
| GL-89-01, GL-89-1, NYN-98028, NUDOCS 9803110367 | |
| Download: ML20217Q091 (3) | |
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1 North North Atlantic Energy Service Corporation tty Atlantic Seat root Nii O3s74 P.O. Box 300 0
(603) 474-9521 The Northeast Utilities System March 5,1998 w
Docket No. 50-443 NYN-98028 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Seabrook Station License Amendment Request 97 08,
" Radioactive EfTluent Technical Specifications i
LiDdtem Imnrovements Per Generic Letter 89-01" N
North Atlantic Energy Service Corporation (North Atlantic) has enclosed herein License Amendment Request (LAR) 97-08. LAR 97-08 is submitted pursuant to the requirements of 10 CFR 50.90 and 10
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CFR 50.4.
LAR 97-08 proposes changes to the Seabrook Station Radiological Effluent Technical Specifications (TS) and Administrative Controls section of the Technical Specifications, as authorized by NRC Generic Letter (GL) 89-01, " Implementation Of Programmatic Controls For Radiological Effluent Technical Specifications (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 Cont 5. Program." The proposed amendment will ir. corporate programmatic controls in the Technical Specifications for radioactive effluents and for environmental monitoring 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 radioacthe wastes will be relocated to the Process Control Program (PCP).
These changes, including those associateu with the PCP, have been prepared in accordance with the I
proposed changes to the Administrative Controls section of the Technical Specifications, as specified in GL 89-01. A coinplete copy of the revised ODCM is forwarded whh the License Amendment Request for NRC reference, as specified i.< GL 39-01.
c Changes to the ODCM have been prepared in accordance with the guidance of NUREG-1301, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluents Controls for Pressurized Water Reactors - Generic Letter 89-01, Supplement 1."
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U.S. Nuclear Regulatory Commission NYN-98028/Page 2 As a result of relocating the proposed RETS into the ODCM, the requirement currently contained in Part A of the ODCM to obtain NRC approval pdor to any changes to Part A 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 NRC reviews of RETS.
Furthermore, North Atlantic intends to continue 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 Reactot Regulation, to Thomas E. Tipton of NEl, formally NUMARC, the Nuclear Regulatory Commission responded to an industry inquiry on promulgation of a new Part 20. In the letter the Nuclear Regulatory Commission 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 requireraent after January 1,1994, without submitting individual requests for amending their technical specifications to comp ly with new 10 CFR 20.1101(b).
The letter goes on to say, ".. we are preparing a Generic Letter to provide model Technical Specification wordmg 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 Pan 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).
North Atlantic will continue to comply to the requirements of"old" Part 20, i.e.,10 CFR 20.1 - 20.601, and its Appendices, for release of radioactive effluents, until North Atlantic convens to ITS. The method currently in use for controlling releases to within the "old" 10 CFR 20.106, Appendix B concentration MPC limits based c.n " instantaneous" concentration values is still suitable for demonstrating conformance to the requirements of the "new" 10 CFR Part 20, Appendix B ECL concentration limits.
Controlling radioactive efiluents 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 Pan 20 which have limits stated as effluent concentrations averaged over a year.
LAR 97-08 has been reviewed and approved by the Station Operation Review Committee and the Nuclear Safety Audit Review Committee.
As discussed in the enclosed LAR Section IV, the proposed changes do not involve a significant hazard f
consideration pursuant to 10 CFR 50.92. A copy of this letter and the enclosed LAR have been forwarded to the New ilampshire State Liaison Officer pursuant to 10 CFR 50.91(b). North Atlantic requests NRC review of LAR 97-08 and issuance of a license amendment by September 30,1998 (see l
Section V enclosed).
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i U.S. Nucler Regulitory Commission NYN.98028 p ge 3
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l North Atlantic has determined that LAR 97-08 meets the criteria of 10 CFR Sl.22(c)(9) and 10 CFR 51.22(c)(.10) for a categorical exclusion from the requirements for an Environmental Impact Statement (see Section VI enclosed).
Should you have any qtestions regarding this letter, please contact Mr. Terry L. Harpster - Director of Licensing Services, at (603) 773-7765.
Very truly yours, i
NORTH ATLANTIC ENERGY SERVICE CORP.
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f f-ff l
fed C. Feigenbaum
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i Executive Vice President and Chief Nuclear Officer l
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Enclosure cc:
11.J. Miller,NRC Regional Administrator Craig W. Smith, NRC Project Manager R. K. Lorson, NRC Senior Resident inspector Mr. Woodbury P. Fogg, P.E., Director New llampshire Office of Emergency Management State Office Park South 107 Pleasant Street Concord, Nil 03301-3809 J