ML20246F099

Application for Amend to License DPR-54,resubmitting Rev 1 to Proposed Amend 102,deleting Remaining Nonradiological Items Contained in App B of Tech Specs.Shutdown of Facility on 890607 Makes Submittal of Improved Specs Impractical

ML20246F099
Person / Time
Site:	Rancho Seco
Issue date:	07/05/1989
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20246F104	List: ML20246F099 ML20246F124
References
SM-89-005, SM-89-5, NUDOCS 8907130119
Download: ML20246F099 (7)

Text

r . _ _ _ - - - -

,.W r.. ,'i .

esuun SACRAMENTO MUNICIPAL UTtuTY DISTRICT D P. O Box 1 30 S r en C 9585 , 91 452 SM 89-005 L JUL e 51999 U.-S. Nuclear Regulatory Commission Attn: Document Control Desk-Washington, DC 20555 Docket No. 50-312

< Rancho Seco Nuclear Generating Station License' No. DPR-54 PROPOSED AMENDMENT NO. 102, REVISION 1, RESUBMITTI' Attention: George Knighton In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District proposes to amend Operating License DPR-54 for Rancho Seco and therefore resubmits Proposed Amendment No. 102, Revision 1. By letter to the Commission dated December 12, 1984, the District submitted the initial version of Proposed Amendment No. 102. Revision 1 of Proposed Amendment No. 102, submitted July 27, 1988, replaced the initial submittal in its entirety.

At the Commission's request, by letter dated May 10, 1989, the District withdrew three Proposed Amendments including No. 102, Revision 1. The amendments ware withdrawn to allow the District and NRC to concentrate resources on the improved Techtilcal Specifications.

The shutdown of Rancho Seco on June 7, 19u9, has made the submittal of Improved Technical Specifications impractical. The District is therefore resubmitting Proposed Amendment No. 102, Revision 1.

Pursuant-to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health Services has been informed of this proposed amendment by mailed copy of this submittal.

Since this is a resubmittal of Revision 1 to Proposed Amendment No. 102, no additional license fees are required.

Members of your staff with questions requiring additional information or clarification may contact Mr. Richard Mannheimer at (209) 333-2935, extension 4919.

8907130119 890703 A003 PDR ADOCK 05000312 P PDC g DISTRICT HEADQUARTERS O 6201 S Street, Sacramento CA 95817-1899

George Knighton SM 89-005 State of California SS County of Sacramento I

Dan R. Keuter, being first duly sworn, deposes and says: that he is Assistant General Manager, Nuclear Plant Manager of Sacramento Municipal Utility District (SMUD), the licensee herein; that he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute this document on behalf of said licensee.

" i EU Zf b b YANDY ,

NOTA 8tV PUBUC-CALIFORNIA Dan R. Keuter I

sACRAMENM coVNU Assistant General Manager Nuclear Plant Manager gcoMM. m. N v. 20. m2:

Subscribed and affirmed to before me on this 8#day of b , 1989.

00 Y j Elig6ethL.Gandy Notary Public g

Attachment cc w/atch: A. D'Angelo, NRC, Rancho Seco J. B. Martin, NRC, Halnut Creek P. Szalinski, State of California INPO MIPC (2) i l

4 ATTACHMENT I Description of- Change, Reason for Change, and No Significant. Hazards Consideration for Proposed Amendment No. 102 Revision 1 l

I

Pr posed Amendment.No.'102 LRevision 1 Log No. 1069 Safety Analysis Page 1 of 4 a Safety Analysis Report Description of Change Proposed Amendment No.102, Revision 1 deletes the remaining non-radiological items contained within Appendix B of the Rancho:Seco Technical Specifications (Tech Specs). Pages.1, ii, and 1 through 50 of Appendix B to the Tech Specs are removed and replaced by new Page 1.

Reason for Change The non-radiological items remaining in Appendix B which were not deleted by Amendment No. 45 are eliminated based on the following information. The Chemistry and Radiation Protection groups at Rancho Seco have been involved with a non-radiological environmental surveillance program for over 13 years.

This program consists of erosion protection, draft contaminant monitoring,.

noise monitoring, and fogging patterns associated with the cooling towers.

Samples obtained during the implementation of this 'rogram have not indicated any hazardous effects to the environment or the general public. Historical data shows that no severe erosion of the stream bed or degradation of soil banks surrounding the effluent stream has occurred. The only significant amount of erosion has taken place during the heavy winter and spring rains.

-This.would have occurred regardless of plant operation. The deletion of noise surveys from Appendix B can be justified since historical data shows that the surveys-have been within acceptable limits. Monitoring of fogging patterns-can also be deleted. Past observations of fogging patterns associated with the cooling towers have shown no significant fog increase. The only fog observed has been normal valley fog during the winter months. For these reasons, the District intends to delete these non-radiological items from Appendix B of the Tech Specs.

The Administrative Controls Tech Specs in Section 5 of Appendix 6 are bounded by the administrative controls established in Section 6 of Appendix A. The need for administrative controls in' Appendix B no longer exists.

1

. Proposed Amendment ND. 102, Revisicn 1 Log No. 1069 Safety Analysis Page 2 of 4 No Significant Hazards Consideration The' changes proposed in this Tech Spec amendment have no significant impact on plant safety or on site personnel, or public health and safety. Past implementation of the non-radiological Tech Specs has not indicated any hazardous. effects to the environment or the general public due to the operation of Rancho Seco. These non-radiological operating restrictions were originally. imposed because ac'aptable operation was not yet demonstrated regarding the environmental inipact of Rancho Seco. The District believes relief from the non-radiological items in Appendix B of the Tech Specs should be granted because the non-radiological impact of Rancho Seco has been demonstrated as acceptable under the criteria established by the Commission.

In accordance with Amendment No. 45, the NRC is provided with a copy of any changes to the National Pollutant Discharge Elimination System (NPDES) permit and any permit violations. Appendix B Environmental Tech Specs which pertain to non-radiological water quality requirements were deleted with Amendment No. j

45. Hater' quality limits and monitoring programs associated with this permit '

are under the jurisdiction of the California Regional Water Quality Control Board. All non-radiological environmental monitoring program changes and violations are handled by the appropriate federal, state, local and regional authorities.

Amendment No. 53 added several' Administrative Controls Tech Specs which duplicate or exceed requirements contained in Section 5.0 of Appendix B. A letter from John F. Stolz, Chief, Operating Reactors Branch #4, Division of Licensing dated September 11, 1985, asked for assurance that the administrative controls in Section 6 of the Appendix A Tech Specs duplicate or i exceed the following items:

1. Appendix B Administrative Controls, deletion of Sections 5.3.A.2 and 5.3.B.2, requirements to review onsite tests and experiments and results thereof when such tests have environmental significance.

2. Appendix B, Administrative Controls, deletion of Section 5.6.3, reporting requirements and evaluation of plant design changes when the changes may '

adversely impact the environment.

3. Appendix 8, Administrative Controls, deletion of Section 5.7, requirement to maintain environ 9 ental records.

Appropriate replacement Tech Specs exist for item 1 in several sections.

Deletion of Appendix 2, Administrative Controls, Section 5.3. A.2 is justified because of the review responsibilities required of the Plant Review Committee  ;

(PRC) in Specification 6.5.1.6 of Appendix A. Part a. states that the PRC will review the safety evaluations of all procedures required by Specification 6.8. Specification 6.8 includes: Process Control Program implementation procedures, Offsite Dose Calculation Manual implementation procedures, Radiological Environmental Monitoring Program impl? mentation procedures, and Effluent Control and Environmental Monitoring Quality Assurance Program procedures. The PRC reviews the safety evaluations of all proposed tests and experiments that affect nuclear safety, and the PRC also reviews facility operations to detect potential safety hazards.

Prcposed Amendment No.102, Revision 1 Log No. 1069

. Safety Analysis Page 3 of 4 Appendix B, Administrative Controls, Section 5.3.B.2 is no longer necessary because of Appendix A, Specification 6.5.2.6d. The Management Safety Review Committee (MSRC) reviews all changes to the Tech Specs or the Operating License. Tech Spec changes are all accompanied by a safety analysis evaluating the impact of the change.

The requirements of Administrative Controls Section 5.6.3 of Appendix B are satisfied in Section 6 of Appendix A. The NRC requested that Specifications 5.6.3.1 and 5.6.3.2 of Appendix B be retained in Appendix A. These two Specifications were included in the District's submittal of Proposed Amendment No. 138, Revision 2 and approved as part of Amendment No. 96 by NRC letter dated February 19, 1988. Per 10 CFR 50.90 and 10 CFR 50.4 all license amendments are required to be submitted to the NRC for approval. All proposed Tech Spec amendments are submitted with a Safety Analysis Report, which contains a No Significant Hazards Determination. Specification 5.6.3.3 in Appendix B is obsolete.

The requirements of Section 5.7 to Appendix B (Records Retention) are i satisfied by Section 6.10 of Appendix A. l Based on the above discussion, the probability of occurrence or consequence of an accident previously evaluated in the SAR will not be increased, the  !

possibility of occurrence of an accident of a different type than previously evaluated in the SAR will not be created, and the margin of safety as defined in the basis for any Tech Spec is not reduced; therefore, an Unreviewed Safety Question is not involved.

The District has reviewed the proposed changes against each of the criterion of 10 CFR 50.92 and concluded that the changes to the Tech Specs discussed above would not:

a. Significantly increase the probability or consequences of an accident previously evaluated because the proposed Tech Spec changes will not change the way any plant system or component important to safety is operated. The proposed amendment eliminates unnecessary Tech Spec requirements. Administrative controls deleted in Appondix B which were of concern to the Commission are duplicated or exceeded in Appendix A.

b. Create the possibility of a new or different type of accident than previously evaluated because implementation of the non-radiological Tech Specs is now considered to be unnecessary. Acceptable operation of Rancho Seco with regard to environmental impact has been demonstrated. All appropriate administrative controls exist in Appendix A of the Tech Specs.

% y Log No.1069 Pr posed Amendment No. 102, Revision 1 Safety Analysis Page 4 of 4

c. Involve a significant reduction in the margin of-safety because the deletion of.the remaining-Appendix B Tech Specs does not-affect any system or' component important to safety. The proposed changes do not impact'the margin'of safety defined in any basis-to the Tech

' Specs. The non-radiological impact of Rancho Seco has been demonstrated acceptable under criteria established by the Commission.

On'the basis of the above, the District concludes that the proposed changes do not constitute any significant hazard to.the public, and in no way endanger the public's health and' safety.

l l

l ---_-.--__.--_----____J