ML17309A692

Application for Amends to Licenses DPR-67 & NPF-16,utilizing Guidance of GL 89-01, Implementation of Programmatic Controls for RETS & NUREG-1301, ODCM Guidance:Srec for Pwrs.

ML17309A692
Person / Time
Site:	Saint Lucie
Issue date:	01/22/1993
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17227A699	List: L-92-329, Application for Amends to Licenses DPR-67 & NPF-16,utilizing Guidance of GL 89-01, Implementation of Programmatic Controls for RETS & NUREG-1301, ODCM Guidance:Srec for Pwrs ML17227A698 ML17227A700
References
RTR-NUREG-1301 GL-89-01, GL-89-1, L-92-329, NUDOCS 9302010127
Download: ML17309A692 (22)

Text

ACCEI ERAT~ DOCUMENT DIST UTION SYSTEM REGULA INFORMATION DISTRIBUTIO YSTEM (RIDS)

ACCESSION NBR:9302010127 DOC.DATE: 93/01/22 NOTARIZED: YES DOCKET ¹ FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION SAGAR,D.A. Florida,.Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to licenses DPR-67 & NPF-16, respectively, utilizing guidance of GL 89.-01, "Implementation of Programmatic Controls for Radiological Effluent TSs" &

NUREG 1301, "ODCM:SREC for PWRs."

DISTRIBUTION CODE: A009D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR/Licensing Submittal: Appendix I NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 NORRISIJ 2 2, INTERNAL: ACRS 3 3 NRR/BRADFUTEgJ 1 1 NRR/DREP DIR10E 1 0 NRR/DREP/PRPB11 1 1 NUDOCS-ABSTRACT OGC/HDS3 RGN2 DRSS/RPB 1

1 1

1 0

1 OC/jsFMB EG F I 01 1

1 0

1 EXTERNAL EG&G AKERS I D 1 1 NRC PDR 1 1 PNL/BAKER,D.A. 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 15

'I f( $ 5 ~%

4 II l

P.O. Box 28, Ft. Pierce, FL 34954-0128

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L-92-329 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed L'icense Amendments Im lementation of Pro rammatic Controls for Radiolo ical Effluent Technical S ecifications Generic Letter 89-01 In accordance with 10 CFR 50.90, Florida Power 6 Light Company (FPL) submits a request to amend Facility Operating Licenses DPR-67 and NPF-16 for St. Lucie Units 1 and 2, respectively.

These proposed license amendments have been developed utilizing the guidance of GL 89-01, "Implementation of Programmatic Controls for Radiological Effluent Technical Specifications" and NUREG 1301, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors." As such, the procedural details of the Radiological Effluent Technical Specifications (RETS) have been relocated to the Offsite Dose Calculation Manual (ODCM) or Process Control Program (PCP) as appropriate per the Administrative Controls section of the Technical Specifications. In addition, new programmatic controls, for radioactive effluent and radiological environmental monitoring have been added to the Technical Specifications (TS).

The ODCM has been revised in accordance with the proposed changes to the Administrative Controls section of the TS so it may be implemented immediately upon issuance of the amendments. Wherever possible, the standard TS wording of NUREG 1301 was used in the controls section of the ODCM. Deviations from the NUREG 1301 wording are marked and explained in Enclosure 1. Current St. Lucie TS setpoints, LCOs, and surveillance requirements were not changed.

The TS bases of NUREG 1301 were used in the ODCM in lieu of St.

Lucie TS bases.

9302010127 930122 PDR ADOCK 05000335 P PDR Sll fpg Qroep cpmpfflQ A Og Jw

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St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of Pro rammatic Controls for Radiolo ical Effluent Technical S ecifications Generic Letter 89-01 Page two Attachments 1 and 2 to this letter include the proposed St. Lucie Units 1 and 2 Technical Specification changes, respectively. is a Safety Analysis in support of the proposed amendments. Attachment 4 is a "Determination of No Significant Hazards Consideration." Enclosure 1 is a copy of the revised ODCM and NUREG 1301 deviation document.

The proposed amendments have been reviewed by the St. Lucie Facility Review Group and the FPL Company Nuclear Review Board.

In accordance with 10 CFR 50.91 (b)(1), a copy of the proposed amendments are being forwarded to the State Designee for the State of Florida.

Please contact us if there are any questions about this submittal.

Very truly yours, D. A.

Vice Pr St L 'l S

DAS/JWH/kw ident DAS/PSL 0836-93 Attachments Enclosure cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant Mr. Jacob D. Nash, Florida Department of Health and Rehabilitative Services

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of Pro rammatic Controls for Radiolo ical Effluent Technical S ecifications Generic Letter 89-01 Page three STATE OF FLORIDA )

) SS ~

COUNTY OF ST. LUCIE )

D. A. Sager being first duly sworn, deposes and says:

That he is Vice President, St. Lucie Plant for the Nuclear Division of Florida Power & Light Company, 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 the document on behalf of said Licensee.

D. 'A. ger STATE OF FLORIDA COUNTY OF St. Lueie The foregoing instrument was acknowledged before me this 22nd day of January 19 93 by D. A. Sager, who is personally known to me and who did take an oath.

Karen West Name of Notary Public My Commission expires 4 >8 94 KAREN WEST Notay Pub&state at Pet8a Commission No. mt".shn Expltes APfl ts,t694 COMM tt CC 003222

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St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments Im lementation of Pro rammatic Controls for Radiolo ical Effluent Technical S ecifications Generic Letter 89-01 ENCLOSURE 1 OFFSITE DOSE CALCULATIONMANUAL AND DEVIATIONDOCUMENT FOR ST. LUCIE UNITS I AND 2 9302010127

DEVIATIONDOCUMENT FOR ST. LUCIE UNITS 1 AND 2 ODCM This deviation document is provided to assist in the review process since the ODCM submittal attempts to use the standard TS wording of NUIREG-1301 wherever possible. It explains the deviations from NUREG-1301 wording based on site specific design and instances where the current Plant Technical Specifications have additional or more restrictive requirements than those given in NUREG-1301. The St. Lucie ODCM submittal copy has margin notes keyed to these explanations.

St. L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 5 Naming CHANNEL FUNCTIONAL TEST as title instead of 1301's name of ANALOG CHANNEL OPERATIONAL TEST. The definition is identical. This is needed for human factors.

This will keep us from having a Common Effluent

& Accident Channel with two different names for a functional test.

5 CHANNEL CALIBRATION definition uses the current Plant TS wordin , not 1301's. Our's is about equivalent & even includes CHANNEL FUNCTIONAL TEST. Same human factors concern as the item immediately above.

14 12 TABLE 1.1 FREQUENCY 4/M* is our current TS.

29 39 We are not changing the frequency to that of 35 46 NUREG 1301.

37 48 14 12 ** To clarify when P is required. Our current 15 13 1301 TABLE 1.2 "OPERATIONAL MODES" is not in submittal. Effluents Monitors OPERABLE status are not affected by MODE changes. Therefore, the Table is not needed.

15 15 1301 3/4 CONTROLS & SURVEILLANCE REQUIREMENTS APPLICABILITY" for 3.0.3, 3.0.4, 4.0.3, 4.0.4, and 4.0.2.b are not included in submittal. See item immediately above for same reasons. The Surveillance Frequency maximum allowable extension in all other STS is 254 per interval only and not 254 per 3 consecutive intervals.

St.L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 16 15 1301's Action: "The provisions of Controls 21 24 3.0.3 and 3.0.4 are not applicable" is NOT 28 38 included in any Control Statement in the ODCM.

32 42 See above two items for reasons.

33 43 34 45 38 49 39 50 40 51 42 55 49 57 57 68 59 70 17- 18 The ODCM Inst. Table(s) ~onl include those 19 21 Monitors that are Design Base Applicable to 22 25 St. Lucie. Refer to the same 1301 Table No.

25 32 to see which exclusions were made for the Table of interest. Instruments same as our current lant TS.

17 18 MINIMUM CHANNELS OPERABLE in this Table is 18 20 N.A. due to Design Base Applicability. By 22 28 NOT having a 1301 instrument to measure Flow 23 29 Rate, the ACTION requirement specified in the 24 31 ODCM submittal is different than 1301's, and uniquely spells out what the plant must do to insure release conditions are controlled conservatively. The wordin of this ACTION Statement in this Table is our current 10 18 20 1301 specifies 1.E-07 micro-Curie/ml detection limit. Current Plant TS is 2.0E-07.

20 23 1301 has Notes (1) thru (4) and the ODCM omits the 1301 Note (2), which is N.A. since all our liquid effluent monitors fall under NOTE 1's type.

12 20 23 1301 suggest purchasing calibration sources 27 37 from vendors who participate in NIST cross check programs etc. We will kee the current Plant TS Note for this table which re uires vendors who are traceable to NIST.

St. L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 13 22 26 1301 APPLICABILITY is "*". By Design, PSL's 24 30 Air Ejectors may be, and are normally aligned, 27 32 to the Plant Vent(s) where the Plant Vent Monitor provides the required monitoring function at all times. The 'ODCM APPLICABILITY of "**" takes credit for this capability. See TABLE NOTATION for the actual statement.

14 22 26 1301 items b. thru e. N.A. to St. Lucie since 25 33 air ejector is only a Noble Gas Monitor.

15 24 30 1301 has a Notation "**", but it does apply on 1301's Table 3.3-13 list of NOT Instrumentation.

16 24 30 1301 Notation "* At all times" vs the ODCM 27 32 submittal's "* At all times while making releases via this pathway" to take credit for being able to administratively tag out some ventilation system fans, etc.

17 29 39 1301 has SAMPLING FREQUENCY as Continuous vs ODCM Daily. Design Base of St. Lucie does not provide for Continuous collection of a composite sample.

1301 has Note (6). We use the current lant TS.

18 29 39 1301 has SAMPLING FREQUENCY "M" Grab Sample vs ODCM Daily Grab Sample for dissolved and entrained gases as er current lant TS.

1301 has MINIMUM ANALYSIS FREQUENCY of "M" (for Monthly) vs ODCM 4/M from the composite as er the current lant TS.

19 32 42 1301 in the ACTION Statement "Control 6.9.2" 33 43 vs ODCM "Plant TS 6.9.2" where TS 6.9.2 deals 38 49 with Special Reports. We prefer TS to be the 39 50 recognized document.

40 51 42 55 48 56

St. L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 20 32 42 1301 Drinking Water Analysis, etc. is not in the current lant TS or ODCM due to St. Lucie not being a fresh water site. Therefore, Footnote "*" was omitted from ODCM.

21 35 46 1301 "Type of Activity Analysis" specifies Principal Gamma Emitters. The ODCM says "Noble Gas P.G.E" as our current lant TS Note "e" for this table "exclusivel " list certain Nuclide LLD's for gaseous samples.

Our Design Bases is that the Plant Vent Particulate and Charcoal Continuous Sampling device is a common collection point for all Waste Gas Storage Tank and Containment Purge release pathways, hence we meet the NRC's requirement to perform all analysis required by 1301's Table 4.11-2.

22 35 46 1301's Note (3) is Note (6) in the ODCM.

i.e., extra samples required within one hour of a > 15 a Reactor power change ...."~ae er current lant TS wordin 23 35 46 1301's Note (4) is not included in ODCM.

24 hour frequency Tritium Sample when the It is refueling canal is flooded. This is not in current Plant TS. Tritium Levels have not been observed above 1.E-06 uCi/cc for years under any Operational Mode. We sample 4/M at a sensitivity of 4.E-OS uCi/cc, well below the required LLD of 1.E-06 etc.

24 35 46 1301 "4. All Release Types as listed in 1, 2, and 3 above" vs ODCM's "in 3. above". This is explained by Deviation g [ 21 ], where Waste Gas Storage Tanks 6 Containment are 25 35 '6 covered by Plant Vent Continuous Collection.

1301's wording is confusing on this line, but the ODCM is usin the current Plant TS wordin under respective column topics. This is the continuous analyses for Noble Gases by a monitor etc.

St. L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 26 40 51 1301' 3. 11. 2.4. states "c. 0. 3 mrem to any organ of a MEMBER OF THE PUBLIC".

ODCM uses "c. 0.3 mrem to any organ." as our current Plant TS is worded. "at or beyond the site boundary" is inclusive of all, including MEMBERS OF THE PUBLIC.

26a 40 51 The GASEOUS RADWASTE TREATMENT Control Statement 3.11.2.4 Surveillance Statement 4.11.2.4.1 The Deviation briefl stated is:

There is an Editorial Difference, concerning the physical description for the location(s) of where the Limit(s) apply for the St. Lucie Site, between the Current Tech Spec and NUREG-1301.

What the Current Tech S ec states: Page 3/4 11-13

"..when the projected gaseous effluent air doses due to gaseous effluent releases from the site to UNRESTRICTED AREAS see Fi ure

~5.1-1 when averaged over 31 days, would exceed:"

What the ODCM Submittal states: Page 40

"..when the projected doses in 31 days due to gaseous effluent releases, from each unit, to areas at and be ond the SITE BOUNDARY see Fi ure 5.1-1 would exceed:".

Ex lanations:

The ODCM wording is as per page [51] of NUREG-1301 "ODCM Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors". The Plant Staff feels that NUREG-1301's guidance in specifying "to areas at and be ond the SITE BOUNDARY see Fi ure 5.1-1 " is correct for this St. Lucie Plant ODCM Control. To further support this position, (continued)

St. L

~ NUREG Dev.

~ ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION The GASEOUS RADWASTE TREATMENT Limits for operability are tied to LCOs 3.11.2.2 "DOSE NOBLE GASESii and 3.11 2 3 >>DOSE IODINE 131 IODINE 133'RITIUM~ AND RADIONUCLIDES IN PARTICULATE FORM" where each of the LCO's use "to areas at and be ond the SITE BOUNDARY" see Fi ure 5.1-1 " as their controlling location for applicability. Logically, related LCOs should also have the same point of applicability.

Conclusion:

The Plant Staff feels that the wording differences between current TS and NUREG-1301 are editorial in nature and that the intent of the Tech Spec GASEOUS RADWASTE TREATMENT LCO is not, diminished by using the wording of NUREG-1301 in the ODCM Submittal.

Surveillance 4.11.2.4.1 was not discussed since must follow the wording of the Control Statement.

it 27 48 56 1301 ACTION b.

Our ODCM uses "With the confirmed* level..."

This is our current TS wordin 28 50 58 1301 specifies 40 Monitoring Locations and the ODCM submittal states only 27 Locations.

Seven of 16 Sectors are over water; Locations are based on 1, 5, and 10 mile Rings, each Sector over land, proximity to residences and accessibility. This is our current TS wordin 29 50 59 1301 specifies composite and the ODCM submittal states Grab Samples Weekly/Monthly.

The effluent flow (Circ Water) by parameters of the Ocean are fairly constant, a grab sample would suffice. This is our current TS wordin 30 50 60 1301 Table 3.12-1 Item 3d is ODCM Item 3b.

1301 requires one location, ODCM uses two locations. This is our current TS wordin

,ODCM uses 1 for indicator and 1 for a control.

Same situation for ODCM Table 3.12-1 Item 4a.

for Crustacea and Fish.

St. L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 31 50 60 1301 Table 3.12-1 Item 4a: Milk Samples:

ODCM does not address as no suitable milk animal within 5 km, no sizable milk animal herd from 5 to 8 km. Our current TS wordin 32 50 61 1301 Table 3.12-1 4b/ODCM 4a 1 & 2; 1301 specifies "Edible Portion", ODCM does not. Although for fish the edible portion is about 504 of the weight, the organs are excellent. indicators of contamination. For the crustacea sampled the same logic is applied (organs as indicators}. Our current TS wordincr, 33 50 61 1301 Table 3.12-1 4c: Food Products irrigated by effluent affected watersl the current TS wordinc[ or ODOM do not address as St. Lucie Effluent is discharged to the Ocean which is not used for irrigation.

34 50 61 1301 Table 3.12-1 4c/ODCM 4b 1: 1301 specifies "3 kinds" of broad leaf vegetation (BLV), Current Plant TS and ODCM have no "kinds" s ecified.

Other than decorative foliage, the area close to the plant (the island) is limited on the variety of BLV although the sampling program permits a variety of BLV to be sampled.

Basically, mangrove is the only plant common to the plant area.

35 53 64 ODCM Table 3.12-2 "Re ortin Levels for Radioactivit Concentrations in Environmental Sam les" uses the current Plant Tech S ec Re ortin Level Values. There are no differences in 1301 and the current Plant TS, its just how the limit is listed relative to Drinking Water being present or not. Using the current TS wording avoids giving the appearance .that a limit has been changed in the ODCM submittal process. Drinking Water is not applicable to the St. Lucie Site.

St. L NUREG Dev. ODCM 1301 PAGE PAGE DESCRIPTION OF DEVIATION 36 54 65 ODCM Table 4.12-1 "Detection Ca abilities.."

uses current Plant TS LLDs rescribed for Tritium and I-131 and their res ective footnotes "*" and "**". There are no differences in 1301 and the current Plant TS, its just how the limit is listed relative to Drinking Water being present or not. Using the current TS wording avoids giving the appearance that a limit has been changed in the ODCM submittal process.

37 57 -

68 1301's 3.12.2 includes wording for: "if elevated releases then ...etc. This was not included in ODCM since by Design Bases we do not have any elevated release points by definition.

38 57 68 1301 3/4.12'.2 LAND USE CENSUS, the footnote of 1301 page 68 includes "of at least three kinds of vegetation." The ODCM does not s ecif three kinds but uses current Plant TS. See Deviation 34 above for explanation.

39 59'0 ODCM the in ODCM 3.12.3 has an "*" on "Commission" for footnote, and 4.12.3 explains the description of the Interlaboratory Comparison Program not being included in the ODCM as long as the Environmental Protection Agency is the ILC Program of record.

The EPA program is a well known NRC approved program and the requirement for a description of the EPA program should not be needed.

We, the State of Florida (HRS), participate in the EPA ILC Program. The ODCM uses the current Plant TS wordin 40 65 75 ODCM in BASES for 3/4 11.2.1 DOSE RATE, does not include the NUREG 1301 sentence "Examples of calculations for such MEMBERS OF THE PUBLIC, with appropriate occupancy factors, shall be given in the ODCM" because current Plant TS Semiannual Re ort re uires us to do actual visitor assessment for each annual re ortin interval.