W3P90-1176, Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-112 Re Generic Ltr 89-01 Implementation

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Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-112 Re Generic Ltr 89-01 Implementation
ML20065N584
Person / Time
Site: Waterford Entergy icon.png
Issue date: 12/07/1990
From: Barkhurst R
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20065N588 List:
References
GL-89-01, GL-89-1, W3P90-1176, NUDOCS 9012120206
Download: ML20065N584 (8)
v • d • e


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' R. P. Barkhurst vce Presan twum ~

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December 7, 1990 U.S. Nuclear Regulatory Commission

' ATTN:l Document Control Desk

Washington, D.C.; 20555

Subject:

Waterford 3 SES Docket No. 50-382

. License No. , NPF-38 '

L Technical Specification Change Request NPF-38-112 implementation of Generic Letter 89-01

> Gentlemen:-

. On January 31, 1989, the Nuclear Regulatory Commission (NRC) published

  • thel subjectJ generic: letter summarizing the results of the NRC's study of

,l RETS as it -relates; to the Commission's Interim Policy Statement on Technical Specification Improvements. .This . study concluded that controls could be l- implemented in the Administrative Controls section.of the Technical l

L .Specificati.ons to satisfy- existing regulatory requirements for RETS. With t these L colitrols _in' place, Lproccuural details of the current technical

!: specifications 010 radioactive effluents and radiological environmental l' . monitoring ~could be. relocated to the' Offsite Dose Calculation Manual (ODCM).

LSirnitarly,; procedural details-of the current technical specification on solid.

i radioactive-wastes could be relocated to the Process Control. Program (PCP).

This simplification of the RETS is identified'in Generic Letter 89-01 as a -

gline-item improvement of the technical specifications ' consistent with the goals of the policy statement on Technical Specification Improvements. 1 i

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W3P90-117G 1 Generic Letter 89-01 =

Technical. Specification Change Request NPF-38-112 December 7, 1990 Page 2 The attached safety analysis justifies the removal of the RETS procedural details from and the incorporation of programmatic controls in the Waterford 3 Technical Specifications. This proposed amendment conforms with the guidance of Generic Letter 89-01. Should you have any questions or comments on this matter, please feel free to contact D. A. Rothrock at (504) 739-6693.

Very- truly yours, j 33A RPB/DAR/ssf Attachments: NPF-38-112 Affidavit cc: Messrs. R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR E.L. Blake R.B. McGehee NRC Resident Inspectors Office Administrator Nuclear Energy Division (State of Louisiana)

American Nuclear Insurers l.

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UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION-In the matter of- )

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Entergy Operations, Incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

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AFFIDAVIT R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory l Commission the attached Technical Specification Change Request NPF-38-112; that he is familiar' with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

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R.P. Barkhurst Vice President Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ORLEANS -)

l Subscribed -and sworn to before jpe, a Notary Aublic in apd for the Parish and State above named this ifX. day of d ##14 , 1990.

- parp Public My Commission expires .

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CilANGE NPF-38-112 In accordance with Generic Letter 89-01, this safety analysis justifies making technical specification line-item improvements relative to the Radiological Effluent Technical Specifications (RETS).

Existing Specifications See Attachment A.

Proposed Specifications See Attachment B.

Description This proposal requests NRC approval to relocate procedural details on radioactive effluents, solid radioactive wastes and radiological environmental monitoring from the Waterford 3 Technical Specifications (TS) to the Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP) and to implement controls in the Administrative Controls section governing these programs.

A summary of these changes is as follows:

Tech. Spec. # Change Index for Definitions Delete Definition 1.31 Index for LCOs Delete Section 3/4.12

.index for Administrative

Controls Renumber Sections 6.9 through 6.15 Index for List of Tables Delete Tables 3.3-12, 4.3-8 Change Tables 3.3-13, 4.3-9 Delete Tables 4.11-1 and -2, 3.12-1 and -2, 4.12-1 1.16 New definition for the ODCM.

I'. 22 ' New definition for the PCP.

1,31 Solidification definition moves to PCP and 1.31 is deleted.

3/4.3.3.10 Whole section moves to ODCM.

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Tech. Spec. # ' Change 3/4.3.3.11 References to explosive gas monitoring remain, all other references to radiological systems move to the ODCM.

3/4.11.1.1 Whole section moves t-o ODCM.

3/4.11.1.2 Whole section moves to ODCM.

3/4.11.1.3 Whole section moves to ODCM.

3/4.11.1.4 Does not change as per generic letter. l l

3/4.11.2.1 Whole section moves to ODCM.

l 3/4.11.2.2 Whole section moves to ODCM.

3/4.11.2.3 Whole section moves to ODCM.

3/4.11.2.4 Whole section moves to ODCM. )

3/4.11.2.5- Does not. change as per generic letter.

3/4.11.2.6_ Does not change as por generic letter.

3/4.11.3 Whole section moves to PCP.

3/4.11.4 Whole section moves to ODCM.

3/4.12 All three parts ' move to - ODCM.

B3/4.11.1.1 .3 Whole Bases section moves to the ODCM.

B3/4.11.2.1 .4 Whole Bases section moves to the ODCM.

B3/4.11.3 .4 Whole Bases section moves to the PCP or ODCM, as appropriate.

B3/4.12.1 .3 Whole Bases section moves to the ODCM.

6.8.4 Add sections f. and g. for RETS administrative purposes.

6.9.1.7 A change to the Annual Radiological Environmental Operating Report description.

6.9.1.8 A' change to the Semi-Annual Radioactive Effluent Release Report description.

6.10.3 Insert a section for record retention.

6.13.2 Changes how PCP revisions are made in accordance with Generic Letter 89-01.

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Tech. Spec. # Change 6.14.2 Changes how ODCM revisions are made in accordance with Generic Letter 89-01, 6.15 Whole section moved to the ODCM or PCP, as appropriate.

Generic Letter 89-01 provides guidance for the preparation of an amendment to add programmatic controls of the ODCM and the PCP to the administrative section of the TS. This allows for relocation of procedural details on the control of radioactive effluents and solid wastes from the TS to the relative program in order to simplify the RETS. These changes conform to the Commission's Policy Statement for TS Improvements, i This proposed amendment has been prepared in accordance with the guidance of Generic Letter 89-01. As such, this amendment will:

1. Incorporate programmatic controls in the Administrative Controls section of the TS that satisfy the requirements of 10 CFR 20.106, 40 CFR Part 190,10 CFR 50.36a. and Appendix I to 10 CFR Part 50;
2. Relocate existing procedural details from current specifications involving radioactive effluent monitoring instrumentetion, the control of liquid and gaseous effluents, equipment requirements for liquid and gaseous effluents, radiological environmental monitoring, and radiological reporting details from the TS to the ODCM;
3. Relocate the definition of solidification, and existing procedural details from the current specification on solid radioactive wastes to the PCP;
4. Simplify associated reporting requirements; 5.- Simplify administrative controls for changes to the ODCM and PCP;
6. Add record retention requirements for changes to the ODCM and PCP; and
7. Update definitions of the ODCM and PCP in the TS consistent with these changes.

Enclosuro 1 to Generic Letter 89-01 states this amendment request is to l . demonstrate three things. First, it should demonstrate tha correct incorporation of programmatic controls for radioactive effluents and radiological environmental monitoring. Enclosure 3 to the generic letter gives the specific verbiage to be used in the administrative section of the TS. As suggested in the generic letter, this amendment has incorporated the model specification text from Generic Letter 89-01 Enclosure 3 to replace existing requirements (Attachment B to this safety analysis) without revision of the text. Additionally, the definitions of the ODCM and PCP have been updated as stipulated in the generic letter. The amendment also removes I

the gaseous effluent monitoring instrumentation requirements but retains the 3

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1 requirements for explosive gas monitoring instrumentation (consistent with Enclosure 4 for the generic letter). Only changes in format have been made to keep the proposed specifications in agreement numerically with the Waterford 3 TS.

Secondly, the amendment request is to demonstrate the correct incorporation of procedural details of the current RETS into the ODCM and the PCP.

Specifically, this consists of the TS limiting conditions for operation, their applicability, remedial actions, surveillance requirements, and the bases section of the technical specifications for these requirements. This too, has been done in accordance with Generic Letter 89-01 Enclosure 1. Finally, this amendment is to demonstrate that the guidance of Generic Letter 89-01 has been correctly followed. As support to these two items, approved copies of the ODCM and the PCP are provided as Attachments C and D to this amendment request.

Safety Analysis The proposed change discussed abcVe shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequence of an accident previously evaluated?

Response: No The proposed amendment relocates procedural details from the Waterford 3 TS to the ODCM or the PCP without revision.

Administrative controls are to be placed in the TS to control these programs. As a result, all aspects of the FSAR safety analyses will remain unchanged and there will be no physical change to the facility.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of any accident previously l evaluated.

2. Will operation of the facility in accordance with this proposed change l create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change relocates conformance details bam the TS to the ODCM and PCP. This relocation of the RETS progtum does not reduce l the controls on radiological effluent. No plant design changes are necessary to implement these line-item improvements. Therefore, the b current plant safety analynes remain complete and accurate in addressing the licensing basis events, and analyzing the plant I response and consequences, and the proposed amendment cannot create the possibility of a new and different kind of accident than previously evaluated.

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'3. Will operation of the facility in accordance with this proposed change involvo a significant reduction in a margin of safety?

Response: No Radiological regulatory requirements are established in 10 CFR 20.106, 40 CFR Part 190,10 CFR 50.36a., and Appendix I to 10 CFR Part 60.  :'

The-limits defined for Waterford 3 based on these requirements will be relocated from the TS to the ODCM and- PCP, unchanged. All '

technical content will be preserved. Since there will be no change to I the physical design or operation of the plant, the proposed amendment (

will not involve a reduction in a safety margin.

The Commission had provided guidance concerning the application of standards for determining whether a significant hazards consideration exists I by providing certain examples (48 FR 14870) of amendments that are l considered not likely to involve significant hazarda considerations. This proposal most closely resembles example (vil): j l

(vil) A change to make a licenso conform to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

This proposal most closely resembles example (vil) since the changes conform with Generic Letter 89-01 to support the Commission's Interim Policy Statement on Technical Specification Improvements. These changes, '

considered to be line-item changes, preserve all regulatory requirements and have negligible impact on the operation of Waterford 3.

1 Safety and Significant IInzards Determination Based on the above Safety Analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is a reasonable assurance that the health and '

. safety of the public will not be endangered by the proposed change; and l (3) this action will not result in a condition which significantly alters the L impact of the station on the environment as described in the NRC Final Environmental Statement.

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