ML20206P261

License Change Application 4 to License NPF-36,correcting Error in Listing of Types of Radwaste Shipping Containers & Solidification Agents & Clarifying Review of Operations Committee Responsibilities

ML20206P261
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/26/1986
From:	Leonard J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20206P250	List: ML20206P261 ML20206P274 SNRC-1258, Forwards License Change Application 4 to License NPF-36, Correcting Error in Listing of Types of Radwaste Shipping Containers & Solidification Agents & Clarifying Review of Operations Committee Responsibilities.Fee Paid
References
NUDOCS 8607020062
Download: ML20206P261 (4)

Text

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Long Island Lighting Company Operating License NPF -36 Docket 50-322 License Change Application 4 l

This License Change Application requests modification to Operating License NPF-36 for the Shoreham Nuclear Power Station

1) To correct an error in the listing of the types of radioactive waste shipping containers and solidification agents.

2) To correct a Technical Specification internal inconsistency regarding the approval process for the Process Control Program.

Long Island Lighting Company B '

M/W, Joh D. Leonard, Jr. g' Vic President (/

lear Operations Subscribed and sworn to before me this [ day of June 1906.

llNDA A.CRATTY NOTARY PUBUC, State of New York 1 -

No.4816267 - -

Qualifed in SuffMk County Ncit(ry Public of~New goh Comminen Empres March 30,19.f.T My Commission Expires: /kd/b/ Jd, / Qf 8607020062 860626 PDR ADOCK 05000322 P PDR

1.0 LICENSE CHANGE APPLICATION 4 The following changes to the Facility Operating License NPF-36 are requested in order to:

a. To correct an error in the listing of the types of radioactive waste shipping containers and solidification agents,

b. To correct a Technical Specification internal inconsistency regarding the approval process for the Process Control Program.

2.0 DESCRIPTION

OF CHANGES 2.1 Radwaste Shipping Containers Change Technical Specification 6.9.1.7 to read, "e.

Type of container (e.g., LSA box, HIC, steel liner, 55 gallon drum), and f. Solidification agent (e.g.,

cement, bitumen, Dow media) . " (See Attachment I) 2.2 Review of Operations Committee Responsibilities Change Technical Specification 6.5.1.7 a. to read,

" Specification 6.5.1.6a. through d. and m...." (See Attachment II).

3.0 REASON FOR CHANGES 3.1 Radwaste Shipping Containers This proposed change is being requested because the examples presently given for types of containers and solidification agents are not indicative of present technology. In the case of solidification agents, the presently listed urea formaldehyde is no longer permitted to be used.

3.2 Review of Operations Committee (ROC) Responsibilities Presently, there is a nominal conflict between sections 6.13.2b and 6.5.1.7a. The former section states,

"[LicenseeinitiatedchangestotheProcessControl Program (PCP)] shall become effective upon review and acceptance by the ROC." The latter section requires the ROC to recommend in writing to the Plant Manager changes to the PCP. This seeming conflict will be eliminated by no longer requiring the recommendation in section 6.5.1.7a.

ROC shall review and approve or disapprove all PCP changes in accordance with Tech Spec section 6.5.1.6k and 6.13.2b.

4.0 BASIS FOR NO SIGNIFICANT HAZARDS FINDING 4.1 Radwaste Shipping Containers In addition to the basic criteria of 10 CFR 50.92(c) addressed below, both these amendments fall within the guidance provided by the Commission (48 FR 14870) regarding examples of amendments that are not likely to involve significant hazards considerations.

Specifically, these pro osed amendments are

" administrative change s] to technical specifications:

for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature."

Ol: Does the change involve a significant increase in the probability of consequences of an accident?

A1: No. The changes merely correct errors in the examples given for typical containers and solidification agents to be used. The changes requested do not change the reporting reqairements.

02: Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

A2: No. The changes only clarify the solid waste reporting requirements, not change the requirements.

Q3: Does the change involve a significant reduction in margin of safety?

A3: No. The changes correct the nomenclature used in describing the types of waste container used and does not affect any margin of safety.

4.2 Review of Operations Committee Responsibilities 01: Does the change involve a significant increase in the probability or consequences of an accident?

A1: This change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed changes involve only administrative controls. Resolving the inconsistency in favor of ROC approval conforms to the practice of other BWR Tech Specs, which require approval of a collegial body equivalent to ROC. This ensures that a group of individuals, with broad expertise and background, will evaluate proposed PCP changes. LILCO may continue to exercise the option to have the Plant Manager approve the PCP changes as part of its internal approval process, in addition to the Tech Spec required ROC approval of PCP changes.

02: Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

A2: This change does not increase the possibility of a new or different kind of accident from any previously evaluated because this change only clarifies the administrative control requirements for licensee-initiated changes to the PCP. The proposed change will bring the SNPS Tech Specs into conformance with the Tech Specs of other BWRs.

However, LILCO reserves the option of requiring internal approval of the PCP changes by the Plant Manager, in addition to the Tech Spec requirement of ROC approval of PCP changes.

03: Does the change involve a significant reduction in the margin of safety?

A3: The proposed change does not involve a significant reduction in a margin of safety because this change is only administrative in nature, and resolves a contradiction within the Tech Specs. Resolving the contradiction in favor of ROC approval conforms to the practice in other plant's Tech Specs and ensures that a collegial body approves the Tech Specs. Collective approval is considered stronger than individual approval since a number of individuals, with a broad range of experience and backgrounds, will consider PCP changes. In addition, LILCO retains the option of requiring Plant Manager approval of PCP changes as part of its internal PCP approval procedure, in addition to the Tech Spec requirement of ROC approval.

5.0 Timing of Change 5.1 Radwaste Shipping Containers Since this is a nomenclature correction, it will become effective upon issuance of the revised Technical Specification.

5.2 Review of Operations Committee Responsibilities Since this an an administrative change, it will become effective upon issuance of the revised Technical Specification.

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