ML20235Y387

Mod to Application for Amends to Licenses DPR-24 & DPR-27, Consisting of Tech Spec Change Request 108,incorporating Changes to Tech Spec 15.6.10, Plant Operating Records & Numerous Administrative Changes

ML20235Y387
Person / Time
Site:	Point Beach
Issue date:	07/17/1987
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20235Y389	List: ML20235Y387 ML20235Y413
References
CON-NRC-87-72 TAC-61308, TAC-61309, VPNPD-87-295, NUDOCS 8707250235
Download: ML20235Y387 (4)

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Wisconsin Electnc ne coumr 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 (414)221 2345 VPNPD-87-295 NRC-87-72 July 17, 1987 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D. C. 20555 Gentlemen:

DOCKETS 50-266 AND 50-301 MODIFICATION TO TECHNICAL SPECIFICATION CHANGE REQUEST 108 RECORDS RETENTION AND ADMINISTRATIVE CHANGES

_(TAC'S 61308 AND 61309)

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Our letter dated April 10, 1986, requested license maendments to Point Beach Nuclear Plant, Units 1 and 2, to incorporate changes to Technical Specification 15.6.10, " Plant Operating Records", as well as numerous changes of an administrative nature to other specifications. A letter from Mr. D. H. Wagner of your staff dated May 5, 1987, indicated that review of our request is complete; however, it also listed some items of concern to be resolved before the amendment can be issued. Mr.

Wagner also identified other items of concern, minor in nature, through informal discussion with Mr. C. W. Krause of our licensing staff. This submittal addresses those concerns and amends our original request.

The two items of concern stated in the May 5, 1987 letter are listed below, followed by our response.

1. "The proposed change relating to record retention of training and qualification for current NRC-licensed staff and key personnel, specifically TS 15.6.10.0, does not reflect a recent revision to 10 CFR 55 (which was approved after the amendment requests were submitted). The new 10 CFR 55, which becomes effective on May 26, 1987, requires that records be retained until the operators' license is renewed."

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NRC Document Control Desk July 17, 1987 l Page 2

Response

We have reviewed the revision to 10 CFR 55 and have altered our proposed wording of old TS 15.6.10.0 (which would now become 15.6.10.N) to be consistent with the regulation.

(See new TS 15.6.10.N on Page 15.6.10-2, attached.)

2. "The current TS 15.6.10.0 addresses records for current plant NRC-licensed staff and key personnel. ' Key personnel' is not defined in the specification; therefore, it cannot be determined if the proposed revision envelops the specification in place."

Response

Since the specifications do not, in fact, define the term

" key personnel", we have deleted this terminology from the proposed specification. The specification as now proposed is consistent with the NRC regulations at 10 CFR 55.

Two items of concern were identified which resulted from the issuance of amendments to pages which were part of our April 10, 1986, submittal. Amendment 102 to DPR-24 and Amendment 105 to DPR-27, dated June 27, 1986, deleted TS 15.6.9.2.D. As a result, TS 15.6.9.2.E and 15.6.9.2.F were relabeled 15.6.9.2.D and 15.6.9.2.E, respectively. Our original submittal proposed a change to TS 15.6.9.2.F. Our proposed specification (Page 15.6.9-5, attached) is now labeled properly as 15.6.9.2.E.

Similarly, Amendment 105 to DPR-24 and Amendment 108 to DPR-27, dated February 2, 1987, changed TS 15.3.3.C due to a modification which installed an additional heat exchanger in the Component Cooling System. Our April 10, 1986, submittal proposed the removal of a footnote to that specification which had become moot with the passage of time. The February 2, 1987, amendments, however, removed the footnote. The change to TS 15.3.3.C.2.b requested in our original submittal is, therefore, no longer needed.

Another problem identified is the reference provided as justification for modifying the retention period of records of off-site environmental surveys and analyses for radiological environmental monitoring (TS 15.6.10..H and TS 15.6.10.V). The reference we previously provided you (Westinghouse Standard Technical Specifications [STS), Revision 4, Section 6.10.2.n) does not exist. The reference provided does, however, exist in the draft of Revision 5 to the Westinghouse STS. We do not

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NRC Document Control Desk July 17, 1987 Page 3 wish to modify our proposed change to the specifications. The change we are proposing would alter the retention period of these records from " Permanent" to " Duration of Operating License". .This is consistent with other changes to j specification 15.6.10, and with the intent of STS Section  ;

6.10.1 that records designated for long-term vice short-term l retention should be retained for the duration of the Unit operating License and not, as in'our existing specifications, permanently.

Lastly, there is a question concerning the record of dilution of radioactive waste. Our-revision to TS 15.6.10.J proposes two changes from the existing specification. The first is a reduction in retention period from " permanent" to " duration of operating license", consistent with the Standard Technical Specifications. The second removes the requirement to retain records of dilution of radioactive wastes released to the environment. The concern is that while the proposed change relative to dilution is consistent with STS 6.10.2.d, it is not consistent with Regulatory Guide 1.21, Appendix A, Section B,

-which stipulates that records of dilution,-as well as activity release, be retained.

We agree that the specification should address dilution of radioactive effluents. While verbatim agreement with the Standard Technical Specifications is not achieved, consistency with Regulatory Guide 1.21 and with our own TS 15.7.8.4.A is achieved.. TS 15.7.8.4.A outlines RETS Reporting Requirements in the Semiannual Monitoring Report, specifying the reporting of the volume of dilution water used in radioactive liquid releases to the environment. We, therefore, have revised our proposed TS 15.6.10.J to include records of waste dilution (Page 15.6.10-2, attached).

As required by 10 CFR 50.90(A), we have evaluated this modification to our April 10, 1986, submittal in accordance with the standards specified in 10 CFR 50.92 to determine if the proposed changes constitute a significant hazards consideration. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

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NRC Document Control Desk July 17, 1987 Page 4 Upon examination of the administrative nature of these changes, there is nothing in their content which could have an effect on f '

a previously analyzed accident, create a new or different accident, or cause a significant reduction in a margin of safety. They either relate to records retention or correct ,

administrative errors. We, therefore, conclude that no  !

significant hazards consideration exists for this modification to our April 10, 1986, submittal.

Please contact us at once if you have any questions concerning this request.

V9ry truly yours, C. W. ay Vice P esident Nuclear Power Enclosures Copies to NRC Regional Administrator, Region III NRC Resident Inspector R. S. Cullen, Public Service Commission of Wis.

Subscribed and sworg tg before me this 20 0 day of \ th 3

, 1987.

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C< u Notary Public, State of Wisconsin My Commission expires 6- 2 7- 9 0 ,

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