ML20236S016
| ML20236S016 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/13/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20236S013 | List: |
| References | |
| NUDOCS 9807240084 | |
| Download: ML20236S016 (7) | |
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UNITED STATES s
NUCLEAR REGULATORY COMMISSION "g
wasnineron, u.c. sessuaos SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTO~R REGULATION RELATED TO AMENDMENT NO.184 TO FACILITY OPERATING LICENSE NO. DPR-24 AND AMENDMENT NO. 188 TO FACILITY OPERATING LICENSE NO DPR-27 WISCONSIN FI FCTRIC POWER COMPANY POINT BEACH NUCI FAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301
1.0 INTRODUCTION
By letter dated April 24,1996, as supplemented on December 15,1997, and June 22,1998, the Wisconsin Electric (WE) Power Compar.y (the licensee) requested amendments to the Technical Specifications (TS) appended to Facility Operating License No. DPR-24 for Point Beach Nuclear Plant, Unit 1, and Facility Operating License No. DPR-27 for Point Beach Nuclear Plant, Unit 2. The proposed amendments would incorporate programmatic controls for radiological emuent and radiological environmental monitoring in the Administrative Controls
' section of the TS consistent with the requirements of 10 CFR 20.1302,40 CFR Part 190, 10 CFR 50.36a, and Appendix ! to 10 CFR Part 50. At the same time, the licensee proposed to transfer the procedural details of TS Section 15.7, " Radiological Emuent Technical Specifications (RETS)." The proposed amendments are based on two new programs, the Radiological Effluent Control Program (RECP) and the Radiological Effluent and Materials Control and Accountability Program (REMCAP). The " Radiological Effluent Control Program Manual" (RECM) will contain the RECP. The REMCAP will link the RECM, the Offsite Dose Calculation Manual (ODCM), the Process Control Program (PCP), and the Radiological Environmental Monitoring Program (REMP). With these changes, the TS related to RETS reporting requirements were simplified. Revised definitions of the ODCM and PCP were proposed consistent with these changes. Additionally, WE proposed relocation of TS 15.7.5 explosive gas monitoring requirements from TS 15.7.5 to the RECP.
The December 15,1997, and June 22,1998, submittals provided additional clarifying information and updated TS pages. This information was within the scope of the original Federa/ Register notice and did not change the staff's initial no significant hazards considerations determination.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TS as part of the license. The Commission's regulatory I
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. i requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) 1 surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
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in addition, Section 50.36 contains four criteria to determine which of the design conditions and associated surveillance should be located in the TS as limiting conditions for operation:
1.
installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; I
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a process variable, design feature, or operating restriction that is an initial condition of a
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l 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 I
l assumes the failure of or presents a challenge to the integrity of a fission product
' barrier; and i
4.
a structure, system, or component which operating experience or probabilistic risk l
assessment has shown to be significant to public health and safety.
As a result, existing TS requirements that fall withb er satisfy any of the criteria in 10 CFR 50.36 must be retained in the TS, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
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3.0 EVALUATION WE proposes to revise the radiological effluent TS to include the programmatic controls and administrative requirements and to relocate the details to program manuals that are referenced in the proposed TS in accordance with 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," issued by the NRC on January 31,1989. Additionally, WE proposes to relocate the explosive gas monitors to a plant program manual referenced in the TS and to include in the proposed TS the requirement to control all changes regarding explosive gas monitoring via the 50.59 process.
These changes are in accordance with GL 95-10. " Relocation of Selected Technical Specifications Requirements Related to Instrumentation," issued December 15,1995.
GL 95-10 addresses relocation of the explosive gas monitoring requirements from TS 15.7.5 to other controlled documents such as the proposed RECM.
' 3.1 RETS WE proposes to incorporate programmatic controls for radioactive effluent and radiological environmental monitoring in TS 15.7.8 as noted in the guidance provided in GL 89-01. The programmatic controls ensure that programs are established, implemented, and maintained to ensure that operating procedures are provided to control radioactive effluents consistent with the requirements of 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a, and Appendix 1 to 10 CFR Part 50.
The licensee has confirmed that the detailed procedural requirements addressing limiting conditions for operation, their applicability, remedial actions, associated surveillance requirements, or reporting requirements for the following specifications have been prepared to implement the relocation of these procedural details to the RECM or REMCAP. After relocation, the licensee proposes to require all changes to the REMCAP, RECM, ODCM, Environmental Manual, and PCP be documented, reviewed by the Manager's Supervisory Staff, and approved by the Manager, PBNP, as stated in TS 15.7.8, " Administrative Controls." The r
required changes have been prepared in accordance with the new Administrative Controls in i
the TS so that they will be implemented when these amendments are implemented.
WE's proposed changes to the TS are consistent with the guidance provided in GL 89-01 and are addressed below.
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The procedural details that have been removed from the TS are not required by the Commission's regulations to be included in TS since the effluent monitors being removed are not the primary means of detecting degradation of the reactor coolant pressure boundary, do not provide an initial condition of a design-basis accident or transient analysis, are not part of the primary success path which is required to operate to mitigate a design-basis accident, and are not contributors to risk. The procedural details have been prepared for incorporation in the RECP and the REMCAP.
TS 15.7.1, " Definitions." Several definitions moved to REMCAP, REMCAP definition added to TS, and " equivalent curie" definition deleted.
TS 15.7.3, " Radioactive Effluent Monitoring Instrumentation Operability Requirements" moved to RECM.
TS 15.7.4, " Radioactive Effluent Monitoring Instrumentation Surveillance Requirements" moved to RECM.
TS 15.7.5, " Radioactive Effluent Release Limits" moved to RECM. References to
" equivalent curies" and " Tritium Adjustment" will be deleted because they are no longer used. Instead, dose calculations will be performed.
TS 15.7.6, " Radioactive Effluent Sampling and Analysis Requirements" moved to REMCAP Manual.
TS 15.7.7, " Operational Environmental Monitoring Program" moved to REMCAP.
TS 15.7.8, " Administrative Controls" reporting requirements will be moved to the RECM.
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. The following specifications that include programmatic requirements are retained and revised in the TS. This is in accordance with the guidance of GL 89-01.
TS 15.6.5, " Review and Audit" TS 15.6.5.1, " Manager's Supervisory Staff," item J, will be changed to provide the new location of the release limits. In addition, the review of effluents exceeding annual release limits will be added to this item.
TS 15.6.5.1, item k TS 15.7.8, " Administrative Controls." Revisions will be made to this TS; additional material will be added related to the REMCAP.
Additionally, WE proposed some edrtorial and administrative changes to support the GL 89-01 changes.
Table of Contents TS 15.3.9, " Effluent Release" revised to show new location of requirements.
Table TS 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, and Tests of Instrument Channels," Footnote 7. This footnote will be changed to reflect the new location for the items removed from TS 15.7.4.
TS 15.4.10, " Operational Environmental Monitoring" revised to reference REMCAP.
The reference to " effluent sampling" will be eliminated.
TS 15.7.1, " Operational Environmental Monitoring." The definition of " equivalent curie" will be eliminated because it will no longer used.
TS 15.7.2, " Site Description." A typographical error will be corrected in the text, and the map will be updated.
The staff finds that the changes included in the proposed TS amendments are consistent with the guidance provided in GL 89-01. Because the control of radioactive effluents continues to be limited in accordance with operating procedures that must satisfy the regulatory requirements of 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a, and Appendix I to 10 CFR Part 50, the staff concludes that the procedural details are not required to be included in the TS by 10 CFR 50.36, these proposed amendments are administrative in nature, and there is no adverse l
impact on plant safety as a consequence. Accordingly, the staff finds the proposed changes i
acceptable.
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. l 3.2 Relocation of Exolosive Gas Monitors TS 1
l 3.2.1 Background l
The staff evaluation for relocation of the explosive gas monitor TS is included in GL 95-10. This generic letter addresses the relocation of selected TS requirements related to instrumentation.
As a result of applying the 10 CFR 50.36 criteria, the NRC determined that several specifications did not warrant inclusion in TS. The staff also concluded that the instrumentation addressed by these specifications is not related to dominant contributors to plant risk.
3.2.2 Relocation of Explosive Gas Monitoring instrumentation l
l The proposed relocation of the explosive gas monitoring instrumentation is in accordance with GL 95-10. Since the requirements related to explosive gas monitoring instrumentation do not conform to the 10 FR 50.36 criteria for inclusion in the TS, GL 95-10 recommended that the
- requirements be relocated to licensee-controlled documents as long as any proposed changes to the explosive gas monitoring instrumentation are controlled in accordance with i
The relocation of most of the instrumentation related to radioactive gaseous effluent monitoring was addressed in GL 89-01. Relocation of the requirements for explosive gas monitoring instrumentation was not addressed in the guidance provided by GL 89-01. Staff positions regarding the monitoring of explosive gases within the radioactive waste management systems are outlined in Standard Review Plan Section 11.3 and Branch Technical Position ETSB-11-5,
" Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure."
l The actions required by existing TS typically require alternate sampling, limited operation of the gaseous waste system, and submittal of a special report if the explosive gas monitoring i
instrumentation does not conform to the limiting condition for operation. The explosive gas monitoring instrumentation requirements address detection of possible precursors to the failure of a waste gas system but do not prevent or mitigate design-basis accidents or transients that assume a failure of or present a challenge to a fission product barrier. Acceptable j
l concentrations of explosive gases are actually controlled by other limiting conditions for operation (e.g., Gaseous Effluents, Explosive Gas Mixture) or by programs described in the l-
" Administrative Controls'section of TS. The requirements related to explosive gas monitoring instrumentation do not conform to the 10 CFR 50.36 criteria for inclusion in the TS. Therefore, licensees may propose to relocate the explosive gas monitoring instrumentation to the UFSAR.
WE has proposed to keep explosive gas concentration limits in TS 15.7.5, incorporate the explosive gas monitoring instrumentation requirsc:tt, into the RECM and added to TS 15.7.8
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l-that the control of changes to explosive gas requirements will be made in accordance with 10 CFR 50.59.
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WE proposed relocating the following TS requirements:
TS 15.7.3, " Radioactive Effluent Monitoring Instrumentation Operability Requirements."
All material pertaining to explosive gases will be moved to the RECM as listed in the revised TS.
l TS 15.7.4, " Radioactive Effluent Monitoring instrumentation Surveillance Requirements."
All material pertaining to explosive gases will be moved to the RECM as listed in the revised TS.
TS 15.7.5, " Radioactive Effluent Release Limits" moved to RECM. The title of this TS will be changed and the explosive gas concentration limits will be copied to the RECM as listed in the revised TS.
i TS 15.7.8.7.B.4. will require that any changes related to explosive gases will be made subject to a 10 CFR 50.59 evaluation.
The requirements related to the explosive gas monitoring instrumentation do not meet the criteria for inclusion in the TS under 10 CFR 50.36. These proposed changes are consistent with the guidance provided in GL 95-01 and are acceptable to the staff.
4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Wisconsin State official was notified of the proposed issuance of the amendments The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve 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 mMonal radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (61 FR 28620). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). The amendments
- also change recordkeeping, reporting, or administrative procedures or requirements.
Accordingly, with respect to these items, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). 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 CONCLUSION
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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 operation in the proposed manner, (2) such activities will be conducted in compliance with the
9 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 Contributors: A. Hansen L. Gundrum j
Date: July 13, 1998 l
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