ML20127F810

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Proposed TS 6.8.1.4 Re Submittal Frequency of Semiannual Radioactive Effluent Release Rept
ML20127F810
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 01/13/1993
From:
NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20127F802 List:
References
NUDOCS 9301210036
Download: ML20127F810 (29)
v • d • e


Text

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See attached markup of proposed changes to the Technical Specifications.

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INDEX 6.0 ADMINISTRATIVE CONTROLS c

SECTION PAGE 6.4 REVIEW AND AUDIT............................................ 6 6.4.1 STATION OPERATION REVIEW COMMITTEE'(50RC)'

Function............................................ .....- 6-6 Composition......................................... ..... 6-6 Alternates.............................................

Meeting Frequency.........................................

6-6 6-6 Quorum.......... .........................................

6-6 Responsibilities.......................................... .. 6-6 Records................................................... 6-8 6.4.2 NUCLEAR SAFET: AUDIT REVIEW COMMITTEE (NSARC)

Function.................................................. 6-8 Composition............................................... 6-8 Alternates................................................ 6-8 Consultants............................................... 6-8 Heeting Frequency......................................... 6-9 Quorum.................................................... 6-9 Review.................................................... 6-9 Audits.................................................... 6-9 Records................................................... 6-11 6.5 REPORTABLE EVENT ACTI0N..................................... 6-11' 6.6 S AF ETY LIMIT VIO LATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11 6.7 PROCEDURES AND PR0 GRAMS..................................... 6-12

6. 8 REPORTING REQUIREMENTS 6.8.11 ROUTINE REP 0RTS........................................... 6-14 Startup Report............................................ 6-14 A Annual Reports............................................ 6-15

/Innucl'3tAnnual Radiological Environmental .0perating Report. . . . . . . . 6-15 Semiannua!)RadioactiveEffluentReleaseReport............ 6-17 onsniy uperating_ Reports................................. . 6-18:

CORE OPERATING-LIMITS REP 0RT.............................. 6 6.8.2 SPECIAL REP 0RTS........................................... 6-19

. 6.9 RECORD RETENTION............................................ 6-19 6.10 RADIATION PROTECTION PR0 GRAM............................... 6-20 v_

SEABROOK - UNIT 1 xiv Amendment No. 9-

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INSTRUMENTATION MONITORING INSTRUMENTATION RADIOACTIVE LIOUID EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specification 3.11.1.1 are not exceeded. The Alarm /

Trip Setpoints of these channels shall be determined and adjusted in accordance with the methodology and parameters in the 0FFSITE DOSE CALCULATION MANUAL (00CM).

APPLI'CABILITY: At all times. ~

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation channel Alarm / Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable,
b. With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take-the ACTION shown in Table 3.3-12. Restore the inoperable instrumentation to OPERABLE-status ithin 30 days and, if unsuccessful, explain in the next ~

nnua dioactive Effluent Release Report pursuant to Specifica-gl tion 6.8.1.4 why this inoperability was not corrected in a timely manner.

c. The, provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.9 Each radioactive liquid effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION, and CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-5.

SEABROOK - UNIT 1 - 3/4 3-55 O]

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4 INSTRUMENTAT10N MONITORING INSTRUMENTATION ,

RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.10 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-13 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specifications 3.11.2.1 and 3.13.2.5 are not exceeded.

The Alarm / Trip Setpoints of these channels meeting Specification 3.11.2.1 shall be determined and adjusted in accordance with the methodology and parameters in the 00CM.

APPLICABILITY: As shown in Table 3.3-13.

ACTION:

a, With a radioactive gaseous effluent monitoring instrumentation channel Alarm / Trip Setpoint less conservative than required by.the above specification, immediately suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the channel inoperable.

b, With the number of OPERABLE radioactive gaseous effluent monitoring instrumentation channels less than the Minimum Channels OPERABLE, take the ACTION shown in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE status within 30 days or, if unsuccessful, explain in the next Sem' nua Radioactive Effluent Release Report pursuant to Specificatio 6.8.1.4 why this inoperability was not corrected in a timely ma r, s awad

c. The provisions of Specification 3.0.3 are. not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.10 Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-6.

4

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J' RADIOACTIVE EFFLUENTS LIQUID EFFLUENTS LIQUID HOLDUP 1ANKS*

LIMITING CONDITION FOR OPERATION 3.11.1.4 The quantity of radioact.ive material contained in each temporary unprotected outdoor tank shall be limited to less than or equal to 10 Curies, excluding tritium and dissolved or entrained noble gases.

APPLICABILITY: At all times.

ACTION:

a. With the quantity of radioactive material in any temporary unprotec-ted outdoor tank exceeding the above limit, immediately suspend all additions of radioactive material to the tank, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank contents to within the limi and describe the events leading to this condition in the next emi Radioactive Effluent Release Report, pursuant to Specification . 8.1. 4.

b.

And The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4,11.1.4 The quantity of radioactive material contained in each temporary unprotected outdoor tank shall be determined to be within the above limit by analyzing a ryresentative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

  • Tanks included in this specification are those outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System.

g SEABROOK - UNIT 1 3/4 11-4 6\

  • A RADIOLOGICAL ENVfRONMENTAL MONfTORING MONITORING PROGRAM LIMITING CONDITION FOR OPERATION 3.12.1 (Continued)

ACTION: ,

c. With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by the' Radiological Environ-mental Monitoring Program (REMP), identify specific locations for obtaining replacement samples and add them within 30 days to the REMP given in the ODCM. .The specific locations from which samples were j unavailable may then be deleted from the monitorina orocra Pur- ann 84 suant to Specification 6,13, submit in the nextT5emianr0a adioac-tive Effluent Release Report documentation for a changs in the 00CM including a revised figure (s) and table for the ODCM reflecting the new location (s) with supporting information identifying the cause of the unavailability of samples and justifying the selection of the new location (s) for obtaining samples. '
d. The provisions of Specification 3.0.3 are not applicaole.

SURVEILLANCE REQUIREMENTS 4.12.1 The radiological environmental monitoring samples shall be collected pursuant to the REMP from the specific locations given in the table and fig-ure(s) in the ODCM, and shall be analyzed pursuant to the requirements of and the detection capabilities required by the REMP. -

SEABROOK - UNIT 1 3/4 12-2 k{ ,

,i RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.2 LAND USE CENSUS LIMITING CONDITION FOR OPERATION 3.12.2 A Land Use Census shall be conducted and shall identify within a dis-tance of 8 km (5 miles) the location in each of the 16 meteorological sectors of the nearest milk animal the nearest residence, and the nearest garden

  • of greater than 50 m 2 (500 ft d) producing broad leaf vegetation.

APPLICABILI_TY: At all times. .

ACTION:

a. With a Land Use Census identifying a location (s) that yields a calcu-lated dose or dose commitment greater than the values currently being calculated in Specification 4.11.2.3, pursuant to Specifica-tion 6.8.1.4, identify the new location (s) in the next Qemiannua7 [

Radioactive Effluent Release Report.

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b. With a Land Use Census identifying a location (s) that yieldt a calcu-lated Gose or dose commitment (via the same exposure pathway) 20%

greater than at a location from which samples are currently being obtained in accordance with Specification 3.12.1, add the new loca-tion (s) within 30 days to the Radiological Environmentai Monitoring Program.given in the ODCM, if permission fro.n the owner to collect samples can be obtained and sufficient sample volume is available.

The sampling location (s), excluding the control station location, having the lowest calculated dose or dose commitment (s), via the same exposure pathway, may be deleted from this monitoring program after.  ;

October 31 of the year in which this Land Use Census was cond cte /}ml Pursuant to Specification 6.13, submit in the next6'emiannua adio-active Effluent Release Report documentation for a change-in he ODCM including a revised figure (s) and table (s) for the ODCM reflecting the new location (s) with information supporting the change in samp-ling locations.

c. The provisions of Specification 3.0.3 are not applicable.

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  • Broad leaf vegetation sampling of at least three different kinds of vegetation may be performed at the SITE BOUNDARY in each of two different direction sec-tors with the highest predicted relative deposition values (D/Qs) in lieu of the garden census. Specifications for broad leaf vegetation sampling in the-REMP, shall be followed, including analysis of control samples.

SEABROOK - UNIT 1 3/4.12-3

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]ADMINISTRATIVECONTROLS

)WN /b'* b Ca{cahoe ha ge*

p SEMIANNtlXb RADI0AC/IVE EFFLUENT RELEASE REPOR10J 6.8.1.44/outine, adioactive Effluent Relea Report ering the operation of_the station during the previous 6 month of ooeration_ shall be hlyC submittedWithirtbu cavs af ter Januarv 1 and Julgf_ eaC1 yep 7ne,,perlog f for the TTrst report snali cegan wun cne cate of ingial criticalityg

  1. M ~ summary TheemtT5Fdbhadioactive Effluent Release Re$oIts shall include a of the quantities of radioactive liquid and gaseous effluents and solid waste released from the station as outlined in Regulatory Guide 1.21,

" Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revisic,1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

For solid wastes, the format for Table 3 in Appendix B shall be supplemented with three additional categories: class of solid wastes (as defined by 10 CFR Part 61), type of container (e.g., LSA, Type A, Type B, Large Quantity) and SOLIDIFICnn IONbaentorabsorbent(e.g., cement).

, The tannurf Radioactive Effluent Release Report Qn hp EUbmitted with h L,50 days after JanuarV 1 of eacn yendshall include an annual summary of hourly meteorological data collected over the previous yea W This annual summary may be eitner in the form of an hour-by-hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured),

or in the form of joint tre ency distributions of wind speed, wind direction, and atmospheric stability. This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released

% from the unit or station during the prev ~ous calendar year. This same report
b. shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUhDARY (Figure S.1-3) during the report period. All assumptions usad in making these assessments, i.e., specific activity, exposure time, and location, shall be included in these reports. The meteorological conditions t.oncurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the OFFSITI DOSE LALCULATION MANUAL (0DCM).

Mn w r The15emiannui]ILRadioactive Ef fluent Release Report 6n he submitted withh th days after January 1 of facn yea.P shall also include an assessment of JV radiation doses to the likely most exposed MEMBER OF THE PUBLIC fro:n reactor

/ releases and other nearby uranium fuel cycle sources, including doses from primary effluent' pathways and direct radiation, for the previous calendar year

' "A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit. g ,

i **The dose calculations may be reoorted in a supplement submitted 30 days later,,A

  • M ieu of submission with the adioactive Effluent Release

.. Report, the licensee has the option of retaining this summary of required (3 meteorological data on site in a fil.e that shall be provided to the NRC upon request.

SEABROOK - UNIT 1 6-17 N

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_. _ . _ _ _ . _ _ . . _ _ _ _ _ . _ . _ ..._._.m . _ _ _ _ _ _ _ _ ..

$ ADMINISTRA71VE CONTROLS E ADI0 ACTIVE EFFLUENT RELEASE REPORT 6.8.1.4 (Continued) to show conformance with 40 CFR Part 190 " Environmental Radiation Protection .

Standards for Nuclear Power Operation " , Acceptable methods for calculating t the dose contribution from liquid and gaseous of fluents are given in Regulatory  !

Gur de 1.109, Rev. 1, October 1977.

ThkejsTanRUUda ca$1veEffluentReleaseReport 11 include a list and description of unplanned releases frote the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting '

period.

g s T6e(fdi nnugPkdloacti e Effluent Relsse Report all include any charsghs made d'uH ng the reporting period to the PROCESS CONTROL PROGRAM and the t 00CM, pursuant to Specifications 6.12 and 6.13,.respectively, as well as any major change to Liquid, Gesecus, or Solid Radweste Treatment Systems pursuant to Specification 6.14. It shall also include a listing of new locations for dose calculations and/or environmental monitoring identified by the Land Use l 4

Census pursvarit to Spec ficati n 3.12.2.

Th[diRLtDiup dioactiveEffluentRelesseReport&N11alsoinclude '

I the following: an explanation as to why the inoperability of liquid or gaseous '

effluent monitoring instrumentation was not corrected within the time specified j in Specification 3.3.3.9 or 3.3.3.10, respectively; and description of the events leading to liquid holdup tanks or gas storage tanks exceeding the ,

lim' of Specification 3.11.1.4 or 3.11.2.6, respectively. ,

i HONTHLY OPERATING REPORTS <

6.8.1.5 Routine reports of operating statistics and shutdo.<n experiente shall-be submitted on a monthly basis to the U.S. Nuclear Regulatory Commission,  :

Washington, D.C. 20555, Attn: Document Control Desk, with a copy to the NRC j

, Regional Administrator, no later than the 15th of each month following the calendar month : overed by the report. -

CORE OPERATING LIMITS REPORT 6.8.1.6.a Core operating lialts shall be established and documented in the CORE OPERATING LIMITS REPORT prior to each reload cycle, or prior to any  !

remaining portion of a reload cycle, for the following:

1.. SHUTDOWN MARGIN 11. sit for MODES 1, 2, 3, and 4 for Specification 3.1.1.1,  ;

2. SHUTDOWN MARGIN limit for H00E 5 for Specification 3.1.L2, 3.- Moderator Temperature Coefficient BOL and E0L limits,-and 300 ppm surveillance limit for Specification 3.1.1.3,  !

.SEABROOK - UNIT 1 6-18. Amendment No. 9-

4 h ADMIN!5TRAT!VE CONTROLS HIGH RADIAT!0N AREA 6.11.1 (Continued) radiation arans. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area; or b.

A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them; or

c. An individual qualified in radiation protection procedures with-a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance t the frequency specified in the Radiation Work Permit.

6.11.2 In addition to the requirements of Specification 6.11.1, areas accessible to personnel with radiation levels greater than 1000 mR/h at 45 cm (18 in.)

from the radiation source or from any surface tnat the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Superintendent on duty and/or health physics supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification of the RWP, direct or remoto (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection-procedureswithin performed to provide positive exposure control over the activities being the area.

For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within large areas, such as PWR containment, where no enclosure exists for-purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

6.12 PROCESS CONTROL PROGRAM (PCP)-

6.12.1 The PCP shall be approved by the Commission prior to implementation.

6.12.2 Licensee-initiated changes to the PCP: _

M a.

Shall-be submitted to the Connaission in th (Semiannua dioactive Effluent Release Report for the period in which the change (s) was made. This submittal shalf contain:

se=00x - unit 1 4/

6-21 gg g

I ADMINISTRATfvE CONTROLS PROCESS CONTROL PROGRAM (PCp) 6.12.2 (Continued)

1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information;
2) A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and
3) Documentation of the fact that the change has been reviewed and found acceptable by the 50RC.

b',

Shall become effective upon review and acceptance by the 50RC.

6.13 0FFSITE DOSE CALCULATION MANUAL (ODCH) 6.13.1 The OOCH shall be approved by the Commission prior to implementation.

6.13.2 Licensee-initiated changes to the 00CH:

a. Changes to Part A shall be submitted to and approved by the NRC staff prior to implemegtation.

b.

AnMM Changes to [ art B shall be submitted to the Commission in the Qmianaga74 Radioactive Effluent Release Report for the period in the change (s) was made effective.This submittal shall

/[ whichcontain:

1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemer.tal information. Information submitted should consist of a package of those pages of the 00CM to be changed with each page numbered, dated and containing the revision number, together with appropriate analyses or evaluations justifying the change (s);
2) A determination that the change will not reduce the accuracy or reliability of dose calculations or Setpoint determinations;

' and. "

3)[ Documentation of the fact that the change has been reviewed and

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found acceptable by the 50RC.

c. Changes to Part B shall become effective upon review and acceptance by the 50RC.

l SEABROOK - UNIT 1 , 6-22 5

6

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% 4 s 4 ADMINISTRATIVF CONTROLS

[ 14 MAJOR CHANGES TO L10VfD, GASEOUS, AND SOLID RADWASTE TREATMENT SYSTEMS" 6.14.1 Licensee-initiated major changes to the Radwaste Treatment Systems (liquid, gaseous, and solid): j

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a. Shall be reported to the Commission in the eniAnndR/ Radioactive Effluent Release Report for the period in which the evaluation was reviewed by the 50RC. The discussion of each change shall contain:

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1) A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59;
2) Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;
3) A detailed description of the equiptent, components, and processes involved and the interfaces with other plant systems;
4) An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the License application and amendments thereto; i
5) An evaluation of the change, which shows the expected maximum exposures to a HEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously-estimated in the License application and amendments thereto;
6) A comparison of the predicteri releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the change is to be made;
7) An estimate of the exposure to plant operating personnel as a result of the change; and
8) Documentation of the fact that the change was reviewed and found acceptable by the 50RC.
b. Shall become effective upon review and acceptance by the 50RC. -

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  • Licensees may choose to submit the information called for in this Specifi'ation c y
as part of the annual FSAR update. .

SEABROOK - UNIT l' 6-23 [ f

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. 4 111. Itetspe of Proposed Chunnen See the attached retype of the proposed changes to the Technical Specifications. The attached retype reflects the currently issued version of Technical Specifications, Pending Technical Specification changes or Technical Specification changes issued subsequent to tiils submittal are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.

Itevision bars are provided in the right hand margin to designate a change in the text.

1, 4

4 INDEX 6.0 ADMINISTRATIVE CONTROLS SECTION PAGE 6.4 REVIEW AND AUD11 . . . . . . . . . . . . . . . . . . . . . . 6-6 6.4.1 STATION OPERATION REVIEW COMMITTEE (SORC) function . ....................... 6-6 Composition. . . . . . ...... .......... 6-6 Alternates . . . . . . . . . . . . . . . . . . . . . . . 6-6 Meeting Frequency. . . . . . . . . ........... 6-6 Qunrum . . . . . . . . . . . . . . . . . . . . . . . . . 6-6 Responsibilities . . . . . . . . . . . . . . . . . . . . 6-6 Records. . . . . . . . . . . . . . . . . . . . . . . . . 6-8 6.4.2 NUCLEAR SAFETY AUDIT REVIEW COLMITTEE (NSARC)

Function . ...... . ,............. 6-8 Composition. . . . . . s ............ 6-8 Alternates . . . . . . . . . ............. 68 Consultants. . . . . . . . . . . . . . . . . . . . . . . 6-8 Meeting Frequency. . . . . . . . . . . . . . . . . . . . 6-9 Quorum . ........................ 6-9 Review . . . . . . . . . . . . . . . . . . . . . . . . . 6-9 Audits . . . . . . . . . . . . . . . . . . . . . . . . . 6-9 Records. . . . . . . . . . . . . . . . . . . . . . . . . 6 11 6.5 REPORTABLE EVENT ACTION . . . . . . . . . . . . . . . . . . 6-11 6.6 SAFETY LIMIT VIOLATION . . . . . . . . . . . . . . . . . . . 6-11 h.7 PROCEDURES AND PROGRAMS . . . . . . . . . . . , . . . . . . 6-12 6.8 REPORTING RE0VIREMENTS 6.8.1 ROUTINE REPORTS. . . .................. 6-14 -

Startup Report . . . . . . . . . . . . . . . . ..... 6-14 An n u al Re po r t s . . . . . . . . . '. . . . . . , . . . . . 6-15 Annual Radiological Environmental Operating Report . . . 6-15 Annual Radioactive Effluent Release Report . . . . . . . 6-17 l Monthly Operating Reports. . . . . . . . . . . . . . . . 6-18 CORE OPERATING LIMITS REPORT . . . . . . . . . . . . . . 6-18 6.8.2 SPECIAL REPORTS. . . . . . . . . . . . . . . . . . . . . 6-19 6.9 RECORD RETENTION . . . . . . . . . . . . . . . . . . . . . . 6-19 6.10 RADIATION PROTECTION PROGRAM. . . . . . . . . . . . . . . . 6-20 l

SEABROOK - UNIT 1 xiv Amendment No. G,

INSTRUMENTATIOR jiONITORING INSTRUMENTATION RADIDACTIVE L1001D EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.9 The radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3-12 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specification 3.11.1.1 are not exceeded. The Alarm /

Tri) Setpoints of these channels shall be determined and adjusted in accordance wit 1 the methodology and parameters in the OFFSITE DOSE CALCULATION MANUAL (0DCM).

APPLICABillTY: At all times.

ACTION:

a. With a radioactive liquid effluent monitoring instrumentation-channel Alarm / Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive liquid effluents monitored by the affected channel, or declare the channel inoperable.
b. With less than_the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-12. Restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, explain in the next Annual Radioactive Effluent Release Report pursuant to -l Specification 6.8.1.4 why this inoperability was not corrected in a timely manner,
c. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE0UIREMENTS 4.3.3.9 Each radioactive liquid effluent monitoring-instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CAllBRATION, and CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-5.

SEABROOK - UNIT 1 3/4 3-55-- Amendment No. l l

1 1

1

,, INSTRUMENTATION liQNITORING INSTRUMENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTAT10NL LlHITING CONDITION FOR OPERATION I

3.3.3.10 The radioactive gaseous effluent monitoring instrumentation channels 1 shown in Table 3.3-13 shall be OPERABLE with their Alarm / Trip Setpoints set to ensure that the limits of Specifications 3.11.2.1 and 3.11.2.5 are not exceeded. The Alarm / Trip Setpoints of these channels meeting Specification 3.11.2.1 shall be determined and adjusted in accordance with the methodology and parameters in the ODCM.

APPLICABILITY: As shown in Table 3.3-13.

ACTION:  :

a. With a radioactive gaseous effluent monitoring instrumentation channel Alarm / Trip Setpoint less conservative than required by the above specification, immediately suspend the release of radioactive gaseous effluents monitored by the affected channel, or declare the .

channel inoperable,

b. With the number of OPERABLE radioactive gaseous effluent monitoring instrumentation channels less than the Minimum Channels OPERABLE, take the ACTION shown in Table 3.3-13. Restore the inoperable instrumentation to OPERABLE status within 30 days or, if unsuccessful, explain in the next Annual Radioactive Effluent l:

Release Report pursuant to Specification 6.8.1.4 why this inoperability was not corrected in a timely manner.

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c. The provisions of Specification 3.0.3 are not applicable.

SURVE1LLANCE RE0VIREMENTS 4.3.3.10 Each_ radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CilANNEL CllECK, SOURCE CHECK, CilANNEL CAllBRATION and CHANNEL OPERATIONAL TEST at the frequencies shown in Table 4.3-6.

SEABROOK - UNIT 1 3/4 3-60 Amendment No.

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,,RADIDACTIVE EFFLUENTS t!0VID EFFLUFNTS L10VID l!0LDUP TANKS

  • tlMITING CONDITION FOR OPERATION 3.11.1.4 The quantity of radioactive material contained in each temporary excluding tritium and dissolved or entrained noble gases. unprotected ou APPLICABillTY: At all times.

ACTION:

a.

With the quantity of radioactive material in any temporary unprotected outdoor tank exceeding the above limit, immediately sus]end 48 all additions of radioactive material to the tank, within 1ours reduce the tank contents to within the limit, and describe the events leading to this condition in the next Annual Radioactive Effluent Release Report, pursuant to Specification 6.8.1.4. l b.

The provisions of Specification 3.0.3 are not applicable.

SURVElltANCE REOUIREMENTS 4.11.1.4 The quantity of radioactive material contained in each temporary unprotected outdoor tank shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

  • Tanks included in this specification are those outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains connected to the liquid Radwaste Treatment System.

SEABROOK - UNIT 1 3/4 11-4 Amendment No.

,, RAD 10ACTIVC EFFLtg, nit 1 L10010 EFFl.UENTS L10010 HOLDUP TANKS

  • LIMITING CONDITION FOR OPERATION 3.11.1.4 The quantity of radioactive material contained in each temporary unprotected outdoor tank shall be limited to less than or equal to 10 Curies, excluding tritium and dissolved or entrained noble gases.

APPLICABit.1TY: At all times.

ACTION:

a. With the quantity of radioactive material in any temporary -

unprotected outdoor tank exceeding the above limit, immediately susoend all additions of radioactive material to the tank, within 48 lours reduce the tank contents to within the limit, and describe the events leading to this condition in the next Annual Radioactive l Effluent f.elease Report, pursuant to Specification 6.8.1.4,

b. .The provisions of Specification 3.0.3 are not applicable.

SURVElltANCE RE0VIREMENTS 4.11.1.4 -The quantity of radioactive material contained in each temporary unprotected outdoor tank shall be determined to be within the above limit by analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

  • Tanks included in this s)ecification are those outdoor tanks that are not surrounded by liners, dices,-or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment-System.-

SEABROOK - UNIT 1 3/4 11-4 Amendment No.

RADIOLOGICAL ENVIRONMENTAL MONITORING  !

... l MONITORING PROGRAM -;

i LIMITING CONDITION FOR OPERATION 3.12.1 (Continued)  !

ACTION:

i

c. With milk or fresh leafy vegetable samales unavailable from one or i more of the sample locations required ay the Radiological Environ- ,

mental Monitoring Program (REMP), identify specific locations for.

obtaining replacement sampics and add them within 30 days to the REMP given in the ODCM. The specific locations from which samples  ;

were unavailable may then be deleted from the monitoring program.-

Pursuant to Specification 6.13, submit in the next Annual Radioac- l ,

tive Effluent Release Report documentation for a change in the ODCM including a revised figure (s) and_ table-for the ODCM reficcting the  :

new location (s) with supporting information identifying the cause of the unavailability of samples and justifying the selection of thenewlocation(s)forobtaining_ samples,

d. The provisions of_ Specification 3.0.3 are not applicable.

SURVEILLANCE RE001REMENTS 4.12.1 The radiological environmental monitoring samples shall be collected pursuant to the REMP from the specific locations given in the table and fig-ure(s) in the ODCM, and shall be analyzed pursuant.to the requirements of and the detection capabilities required by the REMP.

l.

l l

SEABROOK - UNIT 1 3/4 12-2 Amendment No.

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-, ,. . - - - - . - . . - - . - . - _ - . - . -..- _. = _ .

,, RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.2 LAND USE CENSM1 LIMITING CONDITION FOR OPERATION 3.12.2 A Land Use Census shall be conducted and shall identify within a dis-tance of 8 km (5 miles) the location in each of the 16 meteorological sectors of the nearest milk animal, the nearest residence, and the nearest garden

  • of greater than-50 m* (500 ftz) producing broad leaf vegetation.

APPLICABillTY: At all times.

ACTION

a. With a Land Use Census identifying a location (s) that yields a y calculated dose or dose commitment greater than the values currently being calculated in Specification 4.11.2.3, pursuant to Specification 6.8.1.4, identify the new location (s) in the next Annual Radioactive Effluent Release Report. l
b. With a Land Use Census identifying a location (s) that yields a calculated dose or dose commitment (via the same exposure pathway) 20% greater than at a location from which samples are currently being obtained in accordance with Specification 3.12.1, add the new location (s) within 30 days to the Radiological Environmental' Monitoring Program given in the 00CM, if permission from the owner tc collect samples can be obtained and sufficient sample volume is-available. _The sampling location (s), excluding the control station location, having the lowest calculated dose or dose commitment (s),

via the same exposure pathway, may be deleted from this monitoring program after October 31 of the year .in which this Land Use Census was conducted. Pursuant to Specification 6.13, submit in the next-Annual Radioactive Effluent Release Report documentation for a l change in the ODCM including a revised figure (s) and table (s) for the 00CM reflecting the new location (s) with information supporting the change'in sampling locations.- - - - -

c. The provisions of Specification 3.0.3 are not applicable.
  • Broad leaf-vegetation sampling of at least three different kinds of vegetation ,

may be-performed at the SITE B0UNDARY in each of two-different direction sec-in:11eu'of tors with the the garden highest census. predicted relative'

. Specifications for broad deposition values'samp leaf vegetation (0/Qs) ling in the

.REMP, shall be followed, including analysis of control- samples.

SEABROOK - UNIT 1 3/4 12-3 Amendment'No.

,, ADMINISTRATIVE CONTROLS ANNUAL RADI0 ACTIVE EFFLUENT RElfASE REPORT 6.8.1.4 A routine Annual Radioactive Effluent Release Report covering the operation of the station during the. previous calendar year of operation shall-be submitted by June 30 of each year.

The Annual Radioactive Effluent Release Reports shall include a summary of the cuantities of radioactive liquid and gaseous offluents and solid waste releasec from the station as outlined in Regulatory Guide 1.21. " Measuring.

Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof. For solid wastes, the format for Table 3 in Appendix B shall be supplemented with three additional categories: class of solid wastes (as defined by 10 CFR Part 61),

type of container (e.g., LSA, Typo A, Type B, large Quantity) and SOLIDIFICATION agent or absorbent (e.g., coment).

The Annual Radioactive Effluent Release Report shall include an annual summary of hourly meteorological data collected over the previous year. This annual summary may be either in the form of an hour-by hour listing on magnetic tape of wind speed, wind direction, atmospheric stability, and precipitation (if measured), or in the form of joint frequency distributions of wind speed,.

wind direction, and atmospheric stability. This same report shall include an .l assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year.

This same report shall also include an assessment of-the radiation doses from radioactive liquid and gaseous effluents- to MEMBERS OF THE PUBLIC due to their activities inside the SITE BOUNDARY (Figure 5.1-3) during the report period.

All assumptions used in making these assessments, i.e., specific activity, exposure time, and lor:ation, shall be included in these reports. The meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents, as determined by sampling frequency and measurement, shall be used for determining the gaseous pathway' doses. The assessment of radiation doses shall be performed in accordance with the methodology and parameters in the 0FFSITE DOSE CALCULATION MANUAL (0DCM).

The Annual Radioactive Effluent Release Report-shall also include an l assessment of radiation doses to the likely most exposed MEMBER OF THE PUBLIC-from reactor releases and other nearby uranium fuel cycle sources, including doses from primary effluent pathways and direct radiation, for the previous calendar year i

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licensee has the option of retaining this summary of required meteorological data on site in a file that shall be provided to the NRC upon request.

1

'l SEABROOK - UNIT 1 6-17 Amendment No.

i

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~ . , . . , . , ,.n.., .. .- , , , - - ,~J ,, ,c,,n.,,,, .,..v.

t ADMINISTRATIVE CONTROLS Ml@AL RADI0 ACTIVE EFFLUENT RELEASE REPORT l 6.8 i.4 (Continued) to show conformance with 40 CFR Part 190, " Environmental Radiation Protection Standards for Nuclear Power Operation." Acceptable methods for calculating the ,

dose contribution from liquid and gaseous effluents are given in Regulatory Guide 1.109, Rev. 1, October 1977.  ;

The Annual Radioactive Effluent Release Report shall include a list and l description of unplanned releases from the site to UNRESTRICTED AREAS of radioactive materials in gaseous and liquid effluents made during the reporting period.

The Annual Radioactive Effluent Release Report shall include any changes l ;

made during the reporting period to the PROCESS CONTROL PROGRAM and the 0DCM, pursuant to Specifications 6.12 and 6.13, respectively, as well as any major change to Liquid, Gaseous, or Solid Radwaste Treatment Systems pursuant to Specification 6.14. It shall also include a listing of new locations for dose calculations and/or environmental monitoring identified by the Land Use Census pursuant to Specification 3.12.2.

The Annual Radioactive Effluent Release Re) ort shall also-include the l .

following: an explanation as to why the inopera)ility of liquid or gaseous  ;

effluent monitoring instrumentation was not corrected within the time specified in Specification 3.3.3.g or 3.3.3.10, respectively; and description of the events leading to liquid holdup tanks or gas storage tanks exceeding the limits-of Specification 3.11.1.4 or 3.11.2.6, respectively.

MONTHLY OPERATING REPORTS 6.8.1.5 Routine reports of operating statistics and shutdown experience shall be submitted on a monthly basis to the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attn: Document Control Desk, with a copy to the NRC Regional Administrator, no later than the 15th of each month following the calendar month covered by the report.

CORE OPERATING LIMITS REPOR1 6.8.1.6.a Core operating limits shall be established and documented in the CORE OPERATING. LIMITS REPORT prior to each reload cycle, or. prior. to any remaining portion of a reload cycle, for the following:

1, SHUTDOWN MARGIN limit for MODES 1, 2,-3, and 4 for Specification 3.1.1.1,

2. SHUTDOWN MARGIN limit for MODE 5 for-Specification 3.1.1.2,
3. Moderator Temperature Coefficient =BOL and E0L limits, and 300 ppm
surveillance limit for Specification.3.1.l'.3, SEABROOK - UNIT 1 6-18 Amendment No. 9,  !

m _.u _ _ _.-a._._

.. ADMINISTRATIVE CONTROLS -

lilGH RADIATION AREA 6.11.1 (Continued) radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a.

A radiation monitoring device that continuously indicates the radiation dose rate in the area; or b.

A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been -

established and personnel have been made knowledgeable of them; or c.

An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified in the Radiation Work Permit.

6.11.2 In addition to the requirements of Specification 6.11.1, areas accessible to personnel with radiation levels greater than 1000 mR/h at 45 cm (18 in.) from the radiation source or from any surface that the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Superintendent on duty and/or health physics supervision. Doors shall remain locked except during periods of access by personnel under an approved RWP that shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area, in lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation 3rotection procedures to provide acing performed within the area. positive exposure control over the activities For individual high radiation areas accessible to personnel with radiation levels of greater than 1000 mR/h that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that light individual area shall shall be activated asbe barricaded, a warning conspicuously posted, and a flashing device.

6.12 PROCESS CONTROL PROGRAM (PCP) 6.12.1 The PCP shall be approved by the Commission prior to implementation.

6.12.2 Licensee-initiated changes to tb PCP:

a.

Shall be submitted to the Commission in the Annual Radioactive l Effluent made.

Release Report for the period in which the change (s) was This submittal shall contain:

i SEABROOK - UNIT 1 6-21 Amendment No.

e-

,, ADMINISTRATIVE CONTROLS EBOCESS CONTROL PROGRAM (PCP) 6.12.2 (Continued)

1) Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information;
2) A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and
3) Documentation of the fact that the change has been reviewed and found acceptable by the 50RC.
b. Shall become effective upon review and acceptance by the SORC.

6.13 0FFSITE DOSE CALCULATION MANUAL (0DCM) 6.13.1 The OCDM shall be approved by the Commission prior to implementation.

6.13.2 Licensee-initiated changes to the ODCM: ,

a. Changes to Part A shall be submitted to and approved by the NRC staff prior to impicmentation,
b. Changes to Part B shall be sub*nitted to the Commission in the -  !

Annual Radioactive Effluent Re' case Report for the 3eriod in which thechanpe(s)wasmadeeffective. This submittal s1all contain: l-

1) Sufficiently detailed irformation to totally support the e

rationale for the chance without benefit of additional or supplemental information. Information submitted should consist of a package of those pages of the ODCM to be changed ,

with each page numbered, dated and containing the revision number, together with appropriate analyses or evaluations justifyingthechange(s);

2) A determination that the change will not reduce the accuracy or reliability of dose calculations or Setpoint ,

determinations; and  ;

3) Documentation-of the fact that the change has been reviewed and found acceptable by the 50RC.
c. Changes to Part B shall become effective upon review and acceptance by the 50RC.

i SEABRG0K UNIT _1- 6-22 Amendment No..

]

,, ADMINISTRATIVE CONTROLS j.14 MAJOR Cl1ANGES TO L10VID. GASE0US, AND SOLIO RA0 WASTE TREATMEN1 SYSTEMS

  • i 6.14.1 Licensee-initiated major changes to the Radwaste Treatment Systems j (liquid, gaseous,andsolid):
a. Shall be reported to the Connission in the Annual Radioactive l .

Effluent Release Report for the period in which the evaluation was reviewed by the 50RC. The discussion of each change shall contain:

1) A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; ,
2) Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;
3) A detailed description of the equipment, components, and processes involved and the interfaces with other plant i systems;
4) An evaluation of the change, which shows the predicted releases of radioactive materials in liquid and gaseous t effluents and/or quantity of solid waste that differ from those previously predicted in the License application and  :

amendments thereto;

5) An evaluation of the change, which shows the expected maximum-exposures to a MEMBER OF Tile PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the Liccise application and amendments thereto;
6) A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for:the period prior to when the change is to be_made;
7) An estimate of the exposure to plant operating personnel as a result of the change; and 8)- Documentation of the fact that the change was reviewed and found acceptable by the 50RC. ,
b. Shall become effective upon review and acceptance by the SORC.

i t

l l

  • Licensees may choose to submit the information called for-in this l Specification as part of the annual FSAR update.

L SEABROOK - UNIT:1 6-23 Amendment No.

1 1

I V, Snfety ihaluallor.of 1.frense Amendment Hrouest 92 01.4 pronohed Channes  !

The proposed Technical Specification change does not adversely affect the safe operation .

of Seabrook Station, l.icense Amendment Request 92 015 proposes a revision to Technical r Specification 6.8.1.4, " Semiannual Radioactive Effluent Release Report,' to change the submittal frequency of the Radioective Effluent Release Reports from semiannually to annually, in addition, it is also proposed that this Technical Specification be revised to j require the Annual Radioactive Release Reports to be submitted by June 30 of each year to address the data collected during the previous calendar year. Editorial revisions to other Technical Specifications are also proposed for consistency with the aforementioned changes.

The proposed changes it .echnical Specifications are consistent with the revir.cd 10 CPR 50.36a,

  • Technical specil ations on effluents from nuclear power reactors.' As described in Federal Register Volume 57, Number 169 at 39353, the revised 10 CFR 50.36a states the following:

.(a) ...

1 (2) Each licensee shall submit a report to the Con.:nission annually that specifics the quantity of each of the principal radionuclides released to unrestricted areas in _

liquid and in gascous ef fluents during the previous 12 months of operation, including _  ;

any other information as may be required by the Commission to estimat_c maximum potential annual radiation doses to the public resulting from effluent releases. -The ,

report must be submitted as specified in 6 50.4, and the time between submission of-the reports must be no longer than 12 months, if quantitics of radioactive material released during the seporting period are significantly above design objectives, the report must cover this specifically. On the busis of these reports and any additional 4 information the Commission may obtain from the licensee or others, the Commission may require the lleensee to take action as the Commission deems appropriate."

The NRC amended this regulation to reduce the regulatory burden on nuclear licensees.

This action reflects an initiative on the part of.the NRC and responds to the spirit of a presidential memorandum, which requested that selected Federal agencies review and modify regulations that will reduce unnecessary burden of regulation and ensure that the regulated community is not subject to duplicative or inconsistent regulation. As stated in the Federal Rrgister (57 FR 39353), the'NRC concluded that this' change would result in a reduction in burden without reducing protection for the public health and safety and common defense and security. Furthermore, the NRC encouraged licensees to take advantage of the recent 10 CFR 50.36a rule change by stating that administrative changes may be requested for' the affected technical specifications.

Deleting the requirement to submit Semiannual Radioactive Effluent Release Reports and replacing it with a requirement to submit Annual Radioactive Effluent Release Reports, in addition to associated schedular. and administrative Technical Specification changes, does not alter the design or operation of any plant system, component, or structure, it does not change the way any plant system is operated and it does not introduce any new failure mode.

This proposed change does not affect any previously analyzed accident or malfunction, and does not create the possibility of a different accident or malfunction not previously analyied;

Additionally, the submittal of reports to the NRC is an administrative function and is not-included in the bases of any Technical Specification to define or establish a margin of safety. ,

Therefore, this proposed change does not reduce the margin of safety as defined in the bases i of any Technical Specification. +

5 h _ _ . - _ _._ _ _ . - _-

o .

so V. Determination of Slunificant llula rd s for I.lcense Amendment Request 92 015 Proposed Chnnen (1) The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed revision to the submittal frequency of the Radioactive Effluent Release Reports, along with the associated schedular and administrative Technical Specification changes, modifies an NRC administratise requirement for report submittals. Tbc proposed change does not affect the operation of the plant nor does it revise any plant design, configuration, or procedures related to the operation of the plant. Since the physical plant is not affected and the only change is the frequency in which reports are submitted to the NRC, the probability of an accident previously evaluated is not affected by the changes proposed in License Amendment Request 92 015. Additionally, since the proposed change affectr, only the frequency of report submittal to the NRC, it does not have any affect upon

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the radiological consequences of an accident previously evaluated.

The proposed change is consistent with a recent revision to 10 CFR 50.36a, " Technical specifications on effluents from nuclear power reactors," which allowed for the submittal of one Radioactive Effluent Release Report per year. As stated in th( Federal Register (57 FR 39353), the NRC concluded that this change to 10 CFR 50.36a would result in a reduction in burden to licensees without reducing protection for the public health and safety and common defense and f.ecurity. Furthermore, the NRC encouraged licensees to take advantage of the recent 10 CFR 50.36a rule change by stating that administrative changes may be requested for the affected technical specifications.

Based on the foregoing, the proposed change does rat have any affect on the probability or consequences of any previously evaluated accident.

(2) The proposed change does not create the possibility of a new or_ different kind of accident from any_ accident previously evaluated.

The proposed change to Technical Specification 6.8.1 A, and other associated Technical.

Specifications does not atfect the design or function of any plant system, structure, or -

component. It does not affect procedures related to plant operation nor the way any plant equipment is operated. Since the revision to the submittal frequency for Radioactive Effluent Release Reports does not affect the operation of equipment, change its reliability, nor revise the requirements for maintenance or repair, the proposed change does not have the potential to introduce any new failure mechanism. Similarly, the proposed revisions do not increase the types and arnounts of effluents that may be released offsite, nor increase =

individual or cumulative occupational radiation exposures. As a result, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated, (3) The proposed change does not result in a significant reduction in the margin of safety.

The proposed revision to the submittal frequency of the Radioactive Effluent Release Reports, along with the associated schedular and administrative Technical Specification changes, modifies an NRC administrative requirement for report submittals, it does not alter the design or operation of any plant rystem, component, or structure, it does not change the way any plant system is operated and it does not introduce any new failure mode.

This proposed change does not affect any previously analyzed accident or malfunction, and 6

s

1 e

does not create the possibilliy of a different accident or malfunction not previously analyicd.

Additionally, the submittal of report 5 to the NRC is an administrative function and is not _

included in the bases of any Technical Specification to define or establish a margin of safety, Therefore, this proposed change does not reduce the margin of safety as defined in the bases of any Technical Specification.

5 7

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$s c g

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d VI, frosiosed schedule for Ileense Amendment issututte and I:ffretliene**

North Atlantic requests Nit / 'eview of ' ! cense Amendment flequest 92 015 and issuance of a license amendinent havin mtnediate effectiveness by July 30, 1993. North Atlantic anticipates that the first Ant. _I fladioactive !!Ifluent llelease Iteport will be submitted in 1 June 1994 for 1993. In order to facilitate continuity of reporting, North Atlantic will submit l Serniannual fladioactive liffluent itelease Iteports in both February and August 1993. Note,  !

however, that if the arnendment is issued prior to the requested date,it snuy be possible to j omit the August 1993 report and include that data with the first annual report to be submitted in Jure 1994 l

8

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. 7 Yll. 1:nslennnental linpart Staltinent North Atlantic has reviewed the proposed license amendment against the criteria of 10 CFit

$1.22 for environmental considerations. The proposed change does not involve a significant harards consideration, nor increase the types and amounts of effluents that may he released of f site, nor increase individual or cumulatise occupational radiation exposures. Ilased on the foregoing, North Atlantie contludes that the proposed change meets the criteria delineated in 10 CI'It $1.22(c)(9) for a categorical exclusion f rom the requirements for an linsironine nt al impact State ment.

R 9

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