ML20140H545

Requests Addl Info Re 961204 TS Change Request to Convert to Improved TS for Calvert Cliffs Nuclear Power Plant,Units 1 & 2

ML20140H545
Person / Time
Site:	Calvert Cliffs
Issue date:	05/07/1997
From:	Dromerick A NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-M97363, TAC-M97364, NUDOCS 9705130178
Download: ML20140H545 (19)

Text

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pm y 5 UNITED STATES g j NUCLEAR REGULATORY COMMISSION o, WASHINGTON, D.C. 3006H001

' May 7,1997 1

%,*****f i

I Mr. Charles H. Cruse Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL i SPECIFICATIONS FOR THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 1 AND 2 (TAC NO. M97363 AND M97364)

Dear Mr. Cruse:

On December 4,1996, Baltimore Gas and Electric Energy (BGE), submitted a  ;

4 license amendment to request to convert the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Current Technical specifications (CTS) to the Improved Technical Specifications (ITS). During the course of our review, we found 4

that we require additional information to complete our evaluation. Please respond to the enclosed request for information (RAI) that seeks to clarify  :

the ITS Chapter 4.0, Design Features and 5.0, Administrative Controls. We anticipate providing you our comments on additional sections the week of May 12, 1997.

We are enclosing for your consideration a copy of the letter, dated April 9, 1997, regarding an NRC proposed change (TSB-Oll) to the administrative controls section of the STS to better accommodate the staffing requirements in 10 CFR Part 50 and Part 55, and to include a new staff position regarding controls for the working hours of personnel who perform safety-related functions. The NRC recommends adoption of the details in this document.

The staff requests that you prepare your response to the enclosed comments in Wordperfect 5.1 with Universal 11 point font in the format used by the staff.

Your revision of the electronic files should be reflected in the filenames suffix as CC2, e.g., TABL50.CC2. The RAI response letter can be prepared with whatever word processing software BGE is accustomed to using (e.g., Microsoft Word).

9705130178 970507 PDR ADOCK 05000317 C FE CMS wy P PDR

j i l C. H. Cruse l To support the NRC staff's review schedule, your written and electronic response to this RAI is requested within 15 days of the receipt of this letter. Should you have any questions, please do not hesitate to contact me at (301) 415-3473.

l Sincerely,  ;

( -

Alexander W. Dromerick, Senior Project Manager Project Directorate I-1

Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosures:

1. RAI l

2. TSB-011 cc w/encis: See next page )

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C. H. Cruse -2 May 7, 1997 To support the NRC staff's review schedule, your written and electronic response to this RAI is requested within 15 days of the receipt of this letter.. Should you have any questions. please do not hesitate to contact me at (301) 415-3473.

Sincerely,

/S/

Alexander W. Dromerick, Senior Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 l and 50-318 '

Enclosures:

1. RAI

2. TSB-011 cc w/encls: See next page DISTRIBUTION: l Docket File PUBLIC PDI-1 Reading )

SVarga SBajwa Slittle ADromerick /

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ACRS LDoerflein, RI /

DOCUMENT NAME: G:\CCl-2\CCM97363.RAI To r ceive a copy of this document, indicate in the box: "C" - Copy without attachment /encloeure "E" - Copy with attachment / enclosure "N" = No copy 0FFICE PM:PM 1 f, Q lE LA PDI h Q l PMtPDI-1 , f f( l l l unne Apag.64KW stitt F' ss.Jwe 40%

DATE O!IJ7/97 05/9/97 05/77 /97 OS/ /97 05/ /97 Official Record Copy T.s ..

• OC

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• i Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos. I and 2

[ cc:

l President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of i Commissioners Maryland  ;

l 175 Main Street Engineering Division l

.' Prince Frederick, MD 20678 6 St. Paul Centre l Baltimore, MD 21202-6806 ,

James P. Bennett, Esquire 4 i 4

Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre ]

Baltimore, MD 21203 Suite 2102 i Baltimore, MD 21202-1631 '

) Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire i 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition i P.O. Box 33111 j Mr. Terrence J. Camilleri, Director, Baltimore, MD 21218 i

NRM ,

Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell i 1650 Calvert Cliffs Parkway NRC Technical Training Center l Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. Richard I. McLean Administrator - Radioecology Department of Natural Resources 580 Taylor Avenue Tawes State Office Building, B3 Annapolis, MD 21401 i

Regional Administrator, Region I i U.S. Nuclear Regulatory Commission  !

475 Allendale Road 4 King of Prussia, PA 19406

t CCNPP ITS 4.0 DESIGN FEATURES i

' 4.0 ' DOC JFD .. CHANGE / DIFFERENCE COMMENT.:, STATUS

1. -2'-- STS 4.2.2 includes details specifying the control Provide additional discussion and'~ .

element assembly control material. ITS 4.2.2 deletesc justification for.the STS deviation, based .

this detail, resulting in an STS deviation. - Adequate on system design,' operational.: ..

. justification is not provided for the deviation. constraints; or current licensing basis.  !

CGE Response:

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROt.S 5.O'. DOC i.JFD : ' CHANGE / DIFFERENCE . COMMENT! STATUS.

1 A.5 CTS G.2.1.a requires plant specific titles of Acceptance of this change to 5/5/97 TSTF-65 ,

personnel fulfilling the responsibilities of the CTS requirements is based on stiil pending.

positions delineated in the CTS documented in the the NRC acceptance of TSTF-Updated Final Safety Analysis Report (UFSAR). 65.

I sIInws ITS 5.2.1.s is consistent this information with theinCTS to be documented the but also

! " 4 plan. This change to CTS requirements is based on TSTF-65.

CGE Response:

2 A.27 CTS 6.2.2.b requires at least one licensed Acceptance of this change to 5/5/97 TSTF-121 operator in the Control room when fuel is in the CTS requirements is based on modified, not yet reactor anc two licensed operators present in the the NRC acceptance of TSTF- approved.

Control room during reactor STARTUP, schedule 121.

reactor shutdown, and during trip recovery. ITS i 5.0 does not include this requirement. This deletion of CTS requirements is based on TSTF-121.

BGE Response: .

2.a A.3 CTS 6.2.2d states that an individual qualified in Acceptance of this change to 5/5/97 TSTF-65 radiation protection procedures shall be on site the CTS requirements is still pending. j when fuel is in the reactor. The ITS changes this based on the NRC acceptance  !

position to a radiation protection technician. The of TSTF-65. l changes to the CTS requirements is based on i TSTF-65 1 t

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.s CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 25;0f [ DOC [JFDj '

(CHANGE / DIFFERENCE ( '

(COMMENT 7- , - % STATUS $ -

CZE Response:

3 STS 5.2.2.f requires the [ operation manager or Provide justification for the assistant operations manager) to hold an SRO STS deviation based on license. ITS 5.2.2.f requires the operation current licensing basis, manager to hold or have he& an SRO license at system design, or operational CCNPP. There is no discussion or justification for constraints. l' this deviation from the STS requirement.

BEE Response:

i I 4 5 STS 5.2.2.g lists the Shift Technical Advisor Provide justification for the (STA) requirements. ITS 5.2.2.g replaces the STS deviation based on i

requirements entirely with a different list of STA current licensing basis, requirements. There is inadequate justification for system design, or operational the deviation from the STS requirements for constraints.

. STAS.

BGE Response:

l 5 LA.3 CTS 6.5.1.c.2 requires chan-as to the Offsite Provide discussion for this 5/5/97 TSTF-65 Dose Calculation Manual (ODCM) be reviewed by change to CTS requirements is still pending.

the onsite review function and the plant manager. to include the specific i ITS 5.5.1.c.2 requires changes to the ODCM be procedures that will control

• reviewed by the plant manager. The CTS the requirement. Acceptance requirement for the on. na review function to of this change to the CTS  !

review ODCM changes is moved to unspecified requirements is based on the j plant procedures. This change to the CTS is NRC acceptance of TSTF-65. j based on TSTF-65.

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS

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15.0; DOC- UFD ' . CHANGE / DIFFERENCE

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1COMMENTd s j STATUS 4 BGE Response:

6, 7, 8, 3 The ITS 5.4.4, Radioactive Effluent Controls Revise the CTS markups 9,10, Program, has been modified in accordance with changed by amendments 197 ,

11,12 CTS amendments 197 and 217. Amendment and 217 and replace the 217 was approved October 18,1996,and pages. l amendment 197 was approved March 7,1997. I BGE Response: l 13 CTS 4.7.6.1.e.1 requires verifying that the Provide discussion and pressure drop across the combined HEPA filters justification for the addition of '

and charcoal absorber banks is < 4 inches Water the profilters to the CTS Gauge while operating the ventilation system at a requirement.

flow rate of 2000 cfm i 10%. ITS 5.5.11.d ~

requires the same verification but adds the Classify this change as a I profilters to the HEPA filters and charcoal More Restrictive change. ['

absorber bank. There is no discussion or justification for the change to CTS requirements. .

BGE Response: ,

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 5.0 : DOC 1. JFD . CHANGE / DIFFERENCE;  ; COMMENTS + iSTATUS:

14 STS 5.5.11.c requires demonstrating for each of Provide justification for the i the ESF systems that a laboratory test of a STS deviation based on sample of the charcoal absorber, when obtained current licensing basis, as described in (Regulatory Guide 1.52, revision system design, or operational 21, shows the methyl iodide penetration less than constraints.

the value specified below when tested in accordance with [ ASTM D3803-1989) at a temperature of .5;. [30'Cl and greater than or equal to the relative humidity specified as follows. '

ITS 5.5.1.1.c has the same requirements but adds (elemental iodine for lodine Removal System (IRS)) and (103*C for IRS). There is no discussion or justification for the deviation to the STS.

CGE Response:

15 STS 5.5.12 requires determining the liquid Provide justification for the radwaste quantities in accordance with (Standard STS deviation based on Review Plan, Section 15.7.3, " Postulated current licensing basis, Radioactive Release Due to Tank Failures"). ITS system design, or operational '

5.5.12 does not include this STS requirement. constraints.

There is no discussion or justification for this STS r deviation. '

EGE Response:

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS

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5.0 DOC ;JFD: ~ TCHANGE/DIFFERENCEi/ COMMENTS iSTATUS-16 None STS 5.5.12.b requires a surveillance program to Provide justification for the t ensure that the quantity of radioactivity contained STS deviation based on in [each gas storage tank and fed into the offgas current licensing basis, treatment system) is less than the amount that system design, or operational would result in a whole body exposure of.2:. 0.5 constraints.

rem to any individual in an unrestricted area, in ,

the event of lan uncontrolled release of the tanks'  !

contents). ITS 5.5.12.b requires a surveillance program to ensure that the quantity of '

radioactivity contained in each gas storage tank is less than or equal to 58,500 curies noble gases (considered Xe-133). There is no discussion or justification for this deviation to the STS l requirements.  !

CCE Response:

17 12 STS 5.5.13.a.3 requires verifying the fuel oil has 5/5/97 The CCNPP Project 5/5/97 Closed a clear and bright appearance with proper color. Manager confirmed that FSAR i ITS 5.5.13.a.3 changes this requirement to Section 8.4.1, page 8.4-8 i verifying water and sediment.50.05%. states that sampling of .

incoming fuel oil is analyzed CCNPP does not utilize a clear and bright test for water and sediment. This j because the diesel fuel oil is dyed, and CCNPP is in the CCNPP design basis.

contains a CTS SR which allows the interval for determining particulates in the stored diesel ,

generator fuel oil to be 92 days.

. CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 5.02 DOC 'JFD

' CHANGE / DIFFERENCE ~ 5 COMMENTi . STATUS 17.a M.4 Relative to ITS 5.5.13, DOC M.4 could be Revise DOC M.4 to more improved by more completely addressing the completely address the additional requirements associated with the Diesel additional requirements Fuel Oil Program, associated with the Diesel Fuel Oi! Program.

BGE Response:  ;

17.b M.5 Relative to ITS 5.5.13, DOC M.5 could be Revise DOC M.5 to directly improved by a more direct discussion of the discuss fuel oil testing and testing performed on fuel oil and why such why such testing provides testing provides better assurance that the EDGs better assurance that the will function and is, therefore, a safety EDGs will function.

enhancement. The fact that these tests are currently performed as non-TS activities does not have the impact as the approach discussed above.

BCE Response:

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. i CCNPP ITS 5.0 ADMINISTRATIVE CONTROL.S +

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..il 5.0 ' DOC

.JFD. 1 CHANGE / DIFFERENCE - . COMMENT - i.. STAT.US'  !

17.c A.26 DOC A.26 is not correct. CTS SR 4.8.1.1.2.b Revise DOC A.2E to include  :

requires verifying DG operability "At least once deleting the 92-day per 92 days by verifying that a sample of diesel requirement as a Less fuel from the fuel ste 69e tank is within the Restrictive change and i acceptable limits specified in Table 1 of SSTM justification for the 31-day D975-81 when checked for viscosity, water and requirement. t sediment."

The corresponding ITS 5.5.13.b requires, "Within 31 days following addition of the new fuel oil, other than those addressed in a., above are within limits for ASTM 2D fuel oil: and..." The change, which involves deleting the 92 day requirement. '

is a Less Restrictive change.

BGE Response:

18 12 STS 5.5.13.c requires verifying total particulate Provide justifiestion for the concentration of the fuel oil is110 mgA when STS deviation based on tested every 31 days in accordance with ASTM current licensing basis, i D-2276, Method A-2 or A-3. The corresponding system design or operational ITS 5.5.13.c requires verifying total particulate constraints. f concentration of the fuel oil is110 mgA when tested every 92 days when determined by gravimetric analysis. JFD 12 contains no justification for this deviation of STS testing methods.

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS i5.0L DOC .{JFD} m

CHANGE / DIFFERENCE j .

l COMMENT! ;STATUSJ BGE Response:

19 12 STS 5.5.13.c requires verifying total particulate This justifmation should be concentration of the fuel oil is S 10 mg/l when revised to justify the 92 day [

tested every 31 days in accordance with ASTM interval between testing for l D-2276, Method A-2 or A-3. The corresponding impurities on its own merits,  !

ITS 5.5.13.c requires verifying total particulate or retain the STS frequency of  !

concentration of the fuel oil is & 10 mg/l when every 31 days. Provide [

tested every 92 days when determined by justification for the STS l gravimetric analysis. This extends the STS STI deviation based on current  ;

from 31 days to 92 days. licensing basis, system design, or operational  !

constraints. {

CGE Response:  !,

20 LA.6 CTS Surveillance Requirements 3/4.6.1.1.c Acceptance of this change to 4/11/97 TSTF requires verifying the equipment hatch is closed CTS requirements is based on plans to submit a i and sealed prior to entering MODE 4 by the NRC acceptance of TSTF- revision of TSTF- i performing a Type B test, and 3/4.6.1.1.d, 52. 52. 5/3/97 i requires verifying containment purge blind flanges TSTF-52, R.1 not are installed and sealed prior to entering MODE 4 yet received.  ;

by performing a Type B test. These surveillances }

are not included in the ITS, but are moved to the ,

Containment Leakage Rate Testing Program. This j change to CTS requirements is based on TSTF- i

52. ,

i BGE Response:

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROt.S  !

i 5.0 ; ~#

DOC JFD:  ! CHANGE / DIFFERENCE- ' - -: COMMENT 4  ? l;STATUSf 21 M.1 ITS 5.5.17, Battery inspection Program (BIP), is Acceptance of this change to TSTF-115 added to the CTS requirements. The BlP requires CTS requirements is based on withdrawn by battery tests recommended by IEEE-Std-450- the NRC acceptance of TSTF- TSTF and 1995, and is implemented by ITS SR 3.8.6.1. 115. replacaed with This change to CTS requirements is based on TSTF-198,199, t TSTF-115. 200,201,and 203.  !

5/5/97 these TSTFs are under i NRC review.

BGE Response:

22 CTS 6.6.1, Footnote *, requires reporting Provide discussion and i occupational dose from the independent Spent justification for deleting the Fuel Storage Installation (ISFSI) separately. The CTS requirement for reporting ITS does not include this requirement. There is exposure from the ISFSI no justification for this change to CTS separately. i requirements.

BGE Response:

CCNPP ITS 5.0 AD8WilNISTRATIVE CONTROLS

)JFDj~

~

5.0f DOC ,

A CHANGE /DIFFERENCEf - ,,

$ COMMENT T - s en(STATUSi ,

23 14 STS 5.6.1 requires, in part, that the dose This change was made to 5/5/97 Closed assegnments to various duty functions may be reflect the actuel mechanisms estunated based on pocket dosemeter, used at CCNPP to measure thermoluminescent dosimeter (TLD), or film badge dose rates.

measurements. ITS 5.6.1 changes the mechanisms to measure dose rates by adding electronic personal dosemeter and deleting film badge measurements.

CGE Response:

24 16 STS 5.6.2 contains a bracketed statement that Clarify the deviation from the requiring the report ~ shall identify the TLD results STS described in JFD.16.

that represent collocated dosimeters in relation to the NRC TLD program and the exposure period associated with each result. JFD.16 states that this information is not adopted because the information is not consistent with CCNPP design or current licensing basis. However, this requerement is included in the CTS and ITS. This deviation of requerements requires clarification.

BGE Response:

CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS 5.0 -DOCc oJFD: . CHANGE / DIFFERENCE '

l COMMENT # < STATUS

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25 LA.8 CTS 6.6.3 includes a parenthetical statement Provide discussion of specific emphasizing that the submittal of the Radioactive procedures that include the i Effluent Release Reports must be no longer than CTS requirements.

I 12 months, and footnote * *, which allows a supplementary report to be submitted within 120 days. CTS 6.6.3 elso includes information for reporting licensee initiated major changes to the Radioactive Waste Systems. The ITS do not contain these requirements which are moved to unspecified plant procedures.

BGE Response:

26 18 STS 5.6.6 contains the requirements for the CCNPP does not anticipate 5/5/97 Closed Reactor Coolant System (RCS) and Pressure the temperature / pressure Temperature Limits Report (PTLRI. The ITS do values to change from cycle not include this requirement. to cycle, which would negate the benefits of the PTLR.

Therefore, CCNPP will retain the specific pressure /

temperature limits in the TS.

This is part of the CCNPP system design and therefore, the change is acceptable.

BGE Reponse:

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS i

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J5.0i DOC !JFDi  ; . (CHANGE /DIFFERENCEi, - LCOMMENTb ;;igwJ n[STATUSi 27 19 STS 5.6.7 includes the requerements for reporting Acceptance of this change to 5/5/97 TSTF-37 Emergency Diesel Generator failures. The ITS do CTS requirements is based on rejected. TSTF-  !

not include this requirement based on TSTF-37. the NRC acceptance of TSTF- 37, R.1 is

37. pending.

r BGE Response:  !

! 28 A.17 CTS 6.6, Reporting Requirements, does not Reclassify this change to CTS include the Post Accident Monitoring Report. ITS reporting requirements as a  :

5.6.7 is added to the CTS requwaments, and More Restrictive change and l requwes submitting a report within 14 days when justify. -

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requwed by Condition B or G of ITS 3.3.11, Post Accido.4 Monctonng instrumentation. This '

change to CTS requirements is documented as an

• Administrative change. The change is a More  !

Restrictive change.

! BGE Response:

t 29' A.22 ITS 5.5.15 describes the Safety Function Reclassify this change to CTS i Determination Program. CTS does not include requirements as a More i this requwement. This change to CTS Restrictive change and l requirements is documented as an Administrative provide discussion. -

4 change. The change is a More Restrictive change.

CGE Response:

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CCNPP ITS 5.0 ADMINISTRATIVE CONTROLS c5.0 : DOC JFDL CHANGE /DIFrt.aENCE : > l COMMENT; ^ ' 1 STATUS-30 LA.5 The referenced DOCS justify moving information Provide additional discussion LA.6 outside the ITS by referring to the plant change and justification including a LA.7 control process. There is no description nf this complete description of the LA.8 program or how changes to the program, or Plant Change Control Process procedures governed by the program, are and how changes are controlled. controlled.

CGE Response:

31 L.2 ITS 5.5.8.c, inservice Testing Program, adds a Change confirmed with the 5/5/97 Closed requirement allowing ITS SR 3.0.3 to be CCNPP Project Manager.

applicable to inservice testing activities. This requirement allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the Frequency, whichever is less, to perform inservice Testing upon discovery that inservice Testing requirements were not performed. CTS .

4.0.5 requires declaring the component inoperable if the Inservice Testing is not performed. This change is a relaxation from the CTS requirements.

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. i CCNPP iTS 5.0 ADMINISTRATIVE CONTROLS 5.0' DOC- IJFD> i CHANGE / DIFFERENCE '  : COMMENTi s . LSTATUS-34 A.8 CTS 3/4.6.1.6 includes surveillance requirements Provide additional discussion for monitoring tendon degradation. These and justification reclassifying ,

requirements are moved outside the ITS to the this change from an Concrete Containment Tendon Surveillance Administrative to a Less Program. ITS 5.5.6 describes the Concrete Restrictive Change including Containment Tendon Surveillance Program but how changes to the Concrete has no requirements or description of how Containment Tendon changes are controlled. This change is listed as Surveillance Program are an Administrative Change but is a Less Restrictive controlled. "

Change.

CGE Response:

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UNffSO STATES

! [ NUCLEAR REGULATORY COMMISSION l

8 wAnnmorow, o.c. mseseen j

\s.l,* April 9,1997 l

Mr. James Davis

Nuclear Energy Institute ,

i 1776 Eye Street, N. W.

i Suite 300 j Washington, DC' 20006-2496

Dear Mr. Davis:

i As you know, the NRC cancelled its plans to issue a Generic Letter for a line-item improvement to the technical specification administrative controls section, to devote more resources to conversion reviews and additional

! improvements to the improved standard technical specifications (STS).

However, the proposed Generic Letter would have included several changes to the administrative controls to accomodate changes to 10 CFR 20 and l 10 CFR 50.36a. In addition, since the issuance of Administrative Letter 95-46 i on the relocation of administrative controls related to quality assurance, the

staff has identified additional changes to the administrative controls to better accomodate the staffing requirements in 10 CFR Part 50 and Part 55, and

, to include a new staff position regarding controls for the working hours of

personnel w'no pericra safety-related functions.

Enclosure 1 it an NRC proposed change, TSB-011, to the administrative controls

, section of the STS to reflect the changes described above. In addition, the Technical Specifications Task Force (TSTF) has proposed similar changes to the STS in TSTF-86 and TSTF-121. We request that the TSTF c dify their proposals in these travelers, or withdraw those changes and submit a new traveler, to l reflect consistent changes to the administrative controls for all versions of 1 the STS. Should you have any questions regarding this matter, please contact  !

BobTjaderat 301-415-1187.

Sincerely, M

Christopher I. Grimes, Chief Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation

Enclosure:

as stated cc: C. Szabo, BWOG L. Bush, WOG

8. Mann, CEOG A. Maron, SWROG

8. Ford, SWROG D. Hoffman, EXCEL mu , o . . . nici m e 2

? ' " N _ . . _

TSBFORM2 U.S. CuckIAR REQULATORY COMM18580N PACKAQt Nb. CATE

' ' TSB-NRC Pr:ptsed Change to the STS 011 04/02/97 Originator: R. Tjader Mgr Approved: Date: 11/07/96 Purpose of Update STS to Reflect 10 CFR 20 and 10 CFR 50.36a Changes Change:

NUREGs Changed 1430: X 1431: X 1432: X '

1433: X 1434: X Teahnieel Specifieetione Changed:

1) Change Admin Centrole SecWene 5.2 and 5.3 en unit steffing -Cses

2) Change Admin Centrola Section 5.5.4. RedieseWve Effluent Centrole Program al Replace Admin Controle Section 5.7. 04gh Radiation Ared L;,, tion of Change:

Redee STS Admin controle Sectione 5.2 en Urdt Staff and EJ en Unit Staff Quennoetiene to remove requiremente redundant with regulet>one Change /repteos STS Admin Controle SeeWene 5.5.4 aNd 5.T. :::,:1;'y. to reflect 10 CFR 20 and 10 CFR 50.3Se ehenges, to maintain ooneistency between the STS end regulation.

JueWfication of Change:

Redeion of TS 5.2.2.e en ordt staff working hours reflects recent CRGR-epprend ehenges to the STS. Revleton of TS 5.3 en staffing requirements removes requiremente redundant to regulations while retaining elemente required in TS by regulations. Revisione of 10 CFR Port 20 and 10 CFR 50.36e have superooded related information in the TS and other reguistione, thereby prorrupting NRC to propose this generic change traveller to update the STS. The model STS prov6ded in this peakege are specmcelly intended to eliminste posolbie confusion et 6mproper nmplementation of the revised 10 CFR Part 20 toquiremente. (See ettsched kotification.)

Entered Database Deto: 11f1/96 Fileneme: gAformsWpe.mdb NRC REVIEW OF PROPOSED STS CHANGE TSB Rev6 ewer: R. Tieder Tech Reviewer: S.10ementowica Of redew required)

Recommendation Date: 11/7/96 Rememmendellen: Date: 11/8/96 1X l APPROVE I IMODIFY I l REJECT IX] APPROVE I IMOOlFY [ ] REJECT Commente: Commente:

See above Justification as ettschmente to trevotier. S/3/97 pkg wee incorporated as en enclosure to e letter to NEl and prodded to C. Grirnos for signature. This change wee to hwe been prodded under e Generic Letter, which wee concelled. 4r2/97 TS 5.2 and 5.3 edded to package: pecaepe forwerded to C. Grimes for Cepesition.

l An a PROPOSED STS CHANGE DISPOSmON TSB Action f /M\ Date : Q Q'5 TSTF Action of applicablel Date:

f led APPROWD IMODM ( )REECTID[ t l APPROVED I l REVISED l l APPEALED Comnwnte: Commente:

STS FILE AND RECORD DATA CHANGES ACTION SY DATE ACTION SY DATE WP Finee Changes Updated Certifie d Changes Aseees Detsbese Proofed Updated Rosamed for Comment ResoluWen Correctione f Ostabeoe Updated ConvolSeeke Clee+wout Latter q

Updated .

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Sent to TSTF BSS me <

Peekese Updated Nd SVORMS\T&8-fdC.01 t

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l Justification of Changes: ~

Revision of TS 5.2 and TS 5.3 on staff work hours and' staffing i requirements removes requirements redundant to regulations while retaining i elements required in TS by regulations. Revisions of 10 CFR Part 20 and 10 CFR 50.36a have superseded related infonnation in the TS and other regulations. thereby prompting NRC to propose this pneric change traveller to l update the STS. The model STS provided in this pactage are specifically

intended to elimir, ate possible confusion or improper implementation of the revised 10 CFR Part 20 requirements.

2 Staffino Recuirenents and Workino Hours TS C%ances (TS 5.2 & TS 5.3) -

1 Revision of TS 5.2.2.e on unit staff worting hours re"lects recent CRGR-l approved changes to the STS. This change. to existing STS paragraph 5.2.2.e.

i from specific working hour limits to administrative procedures to control j working hours will provide reasonable assurance that impaired performance

caused by excessive working hours will not jeopardize safe )lant o)eration.

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Specific working hour limits are not otherwise required to >e in tte technical specifications under 10 CFR 50.36(c)(5). Specific controls for working hours L of reactor plant staff can be described in a licensee

! a deliberate decision making process to minimize the >otential procedure for that requires impaired

! personnel performance, and that a licensee's establisted procedure control i

processes will provide sufficient control for changes to that procedure. -

i These programs have a level of detail necessary to satisfy the policy i

! statement (SECY-93 067) guidance and are retained in the Administrative

Controls section of the TS. Therefore, the procedures and details can be I relocated outside the TS.  !

! Existing STS paragraph 5.2.2.b is deleted because it is redundant to '

i 10 CFR 50.54(m)(2)(111).

i Existing STS paragraphs 5.2.2.c is revised and a new STS paragraph 5.3.2 i is added to ensure that there is no misunderstanding when complying with

10 CFR 55.4 requirements.

I Chanoes to TS resulti1o from 10 CFR N Cianoes (TS 5.5.4 & TS 5.7)

! Revisions o" 10 C R Part 20 and M C R 50.36a have superseded related

information in the TS and other regulations. thereby prompting NRC to propose i this generic change traveler to update the STS. While 10 CFR Part 20 allows t

licensees to implement the rule without having to make any changes to their i approved TS. the NRC has crafted the enclosed model STS sections to provide acceptable language that correlates with the wording in the revised 10 CFR l Part 20 and 10 CFR 50.36a. Additionally. in accordance with

10 CFR 20.1601(c), the proposed model STS for high radiation areas contain updated acceptable alternate controls to those given in 10 CFR 20.1601 and Regulatory Guide 8.38. Licensees may propose other alternate high radiation area controls based on their plant specific needs.

i in the case of gaseous and liquid effluent release rates, the model STS l were crafted to allow licensees to maintain their same overall level of i effluent control while retaining the o>erational flexibility that exists with I current STS under the previous 10 CFR ) art 20. The model STS continue to l require that radiation doses to members of the public from gaseous and liquid

effluent releases from nuclear power glants be within the values given in Appendix I to 10 CFR Part 50 and the Gmits in 10 CFR Part 20.

i The model STS provided in this letter are specifically intended to

! eliminate.possible confusion or improper implementation of the revised 10 CFR

, Part 20 requirements.

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5.2 Organization 5.2.2 Unit Staff i The unit staff organization sis l1 include the following:

a. A non Licensed Operator shall be assigned to each reactor containing fuel and an additional non-Licensed Operator shall be assigned for each unit when a reactor is operating in MODES 1.2.3. or 4 l [Two unit sites with both units shutdown or defueled, a total of three non-Licensed operators are required for the two units.)

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. rein and in30 CFR 50.54(m)T"5hift 'cresco' mpos'ition 'ma ess' than"th(" min'im0m requirement of 10 CFR 50.54(m)(2)(1)y be and 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accomnodate unexpected absence of on-duty shift crew members provired innediate action is taken to restore the shift crew composition to within the minimum requirements. '

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A [ Health Physics Technician] shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to provide for unexpected absence, provided 1 mediate action is taken to fill the required position.  ;

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~ Ads 1NiitFatiWFf55lRiures ashi1176E~de7EliMiBTnif4iihliiiientid W11mit?the working hours 7effpersonnel h^perfornisafety ~

elated ifmettonsWe.i.911 censed Dior3eactor? rators lSR0s)R11 censed;ReactorAperators?tR0s)$ health icists.

~~~1 lux 111_arjitiperatorspend Lttylaaintenagfjonne iWiWhi11NHiS155s'iUf 5F1 EisTaiiijworkingws1%if ure7 adequate shift;;coveragephalldeez aaintained ~~

without

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. .- msbrtingmurl' gut 561(neswhill?N horizedMnA,.dvance)o lant 3uperintendent for the Plant'SupeHntendent's]y designee 4he'JP,#in accordance with)appr;o

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inistrative procedurts sandytthDoomentattoit of the basis rantingshe'4eviation2 continued 4

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Organization 5.2 5.2.2 -

Unit Staff (Continued) 15ntF61stshaTNe anciudid3iiM.fie rocidifi 3i9i7that

$'sonthly3[y4hejiPJant individus14evertimehhal kbe'aviewed speHntendent] Me the;1Plantj3uperintendentl.shdesignee sto msure that excesshe ; fours :have:not.:been assigned MSoutine leviationif MlML _tqm ithe'@3 flour edelines $shal bg3be, '

4{. The (Operations Manager or Assistant Operations Manager) shall hold an SRO license, gf.

~ The . Shift Technical Advisor (STA) .shall provide advisory technical support to the Shift Suprvisor (SS) in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. In addition, the STA shall meet the qualifications specified b" the Comission Policy Statement on Engineering Expertise on Ibift.

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Unit Staff Qualifications i

5.3 j 5.0 ADMINISTRATIVE CONTROLS .

5.3 Unit Staff Qualifications i

[ Reviewer'sNote: Minimum qualifications for members of the unit staff shall be i specified'by use of an overall qualification statement referencing an ANSI

! Standard acceptable to the NRC staff or by specifying individual position

! qualifications. Generally. the first method is preferable: however, the second l

method statements is because adaptable to those of unique unit staffsstructures.

organizational requiring)special qualification l .

5.3.1 Each member of the unit staff shall meet or exceed the minimum

qualifications of [ Regulatory Guide 1.8. Revision 2.1987, or more recent .

revisions, or ANSI Standard acceptable to the NRC staff]. The staff not

' covered by [Regulato Guide 1.8) shall meet or exceed the minimum

! qualifications of [Re ulations. Regulatory. Guides or ANSI Standards

acceptable to NRC staf J.

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! ind 2491 censed %ctorsi;>erator3(RO) Ware sthose Windivi. duals Swho win

! addittori to.seeting theirequirementsjefJJ.13 Liperform <th!Llun_ctigs; lescribed in30.CFR 50.54(m)

[0Reviewer *siNotsMiThe minimbii1staffihsTiWiioiremintiistljiiilitid'ih^!

CFR 50.54(m)nfor1.cnitimembers; actively performing the functions 6f :ih

! @ratorlorseniorieperatoretan be exceeded),rgtipulating the enhanced

[ta ffing_ requirements in p ragraph;5.3.2,)

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5.5.4 *-diametive E M1 ment rmtrols - r==

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This program eenferns to 10 CFR 50.36a for the control of radioactive efnuents and for maintaining the doses to members of the public from radioactive efnuents as low as reasonably achievable. The pro i 6e contained in the CDCM, shall be laplemented by procedures, gram shall and shall l include remedial actlens to. he taken whenever W program limits are

!. . exceeded. 1he program shall laclede the following elements:

e. Muitattens on W functional capability of radioactive Itquid and

< gaseous moniterlag instrumentation including surveillance tests and eetpoint determination la accordance with the methodology in the l 1

i S CM; e ,

l 6. Limitations en the concentrations of radioactive material released i la licoid ofnuents to unrestr l Appenc lx B, Table 2, Column (icted areas, confomine

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! Monitoring, sampling, and analysis of radioactive liquid and gaseous i

! efnuents in accordance with 10 CFR 20.1302 and with the methodology l j and parameters in the CDCM; i

d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in 11guld

! efnuents released from each unit to unrestricted areas, conforming j to 10 CFR 50, Appendix I; -

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e. Soterstantion of cumulative and projected dose contributions from radioactive efnuents for the current calendar quarter and current

! calendar year in accordance with the methodology and parameters in l the CDCM at least every 31 days;

f. Limitations on W functional capability and use of the liquid and

gaseous effluent treatment systems to ensure that appropriate i portions of Wse systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would 4

exceed 25 of the guidelines for the annual dose or dose commitment, senforming to 30 CFR 50, Appendix I: -

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g. Limitations en & dose estei resulting loactive material l released la gaseous ofnuentsh'to areas beyond the lhboundary i nC: ?M i:: ri:: -t P.. :: 0T; ;;, -#s.....

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t. tiettations en the annual and guarterly air doses resulting from anble gases released in espond the site boundary,eenferming gaseous efnuents to 10 CFRfrom each unit I;to areas 50, Appendix.

4 . . 4. Limitattens en & annual and guarterly doses to a esuber of the eshite f>en iedlee-131, dedine-133, tritius, and all radienuclides la particulate form with half lives > 8 days .

la gaseous ofnuents released from each unit to areas beyond the site boundary, eenforming to 10 CFR 50, Appendix I; and l

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J. Limitations [on W annual dose or dose cannitaent to any member of

! W public,jdue to releases of radioactivity and to radiation from '

. eranium fdel cycle sources, conforming to 40 CFR 190. ,  !

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5.5.4 Radioactive Effluent Centrols program .

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l i This proiram eenfoming to 10 CFR 50.36a provides for the control of j radioacttva effluents and for maintaining the doses to members of

the public from radioactive effluents as low as reasonably

! achievable. The program shall be contained in the CDCM, shall be ,

1 Seplemented by operettag precadures, and shall include remedial l l actions to be taken whenever the program Itaits are exceeded. The i program shall include the fellering elements:

l 1 l a. timitattens en the functional capability of radioactive liquid l

! and gaseous monitoring instrumentation including surveillance 1

! "' tests and setpoint detemination in accordance arith the j enthodology in the CDCM; I 6. Liettations en the concentrations of radioactive enterial l released in 11guld effluents from the site to WRESTRICTED i AREAS, eenfoming to 10 times the concentration values in i Appendix 8. Table 2 Column 2 to 10 CFR 20.1001-20.2402; I

l c. Monitoring, sampling, and analrais of radioactive liquid and

! gaseous affluents pursuant to 10 CFR 20.1302 and with the j , methodology and parameters in the ODCM; i

! d. Limitations en the annual and quarterly doses or dose i

commitment to a assber of the public from radioactive materials in liquid effluents released from each unit to unrestricted areas, conforming to 10 CFR 50, Appendix I;

e. Detemination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the CDCM at least every 31 days;

f. Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2 preent of the evidelines for the annual dose er dose comm' taent, conforslag to 10 CFR 50, Appendix I; )

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g. Limitations on the dose rate resulting from radioactive esterial released in gaseous effluents from the site to areas

. at er beyond the SITE 900 MARY shall be 11mited to the following:

. 3. For noble gases: less than er equal to a dose rate of 400 aress/yr to the total body and less than er equal to l 4 dese rate of 2000 aress/yr to the skin, and i

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2. For ledine-131, todine-133, tritium and for all  !

radionuclides in particulate form w,ith half-lives I greater than 8 days: less than er equal to a dose rate 4

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. of 1500 aress/yr to any organ;

h. Liettations en the annual and quarterly air doses resulting

hem noble gases released in gaseous effluents from each unit l

to areas .at er beyond the site boundary, confoming to j 10 CFR 50, Appendix I;

f. Admit.ations en the annual and

.,j the public from iodine-131,sodine-133, quarterly doses tritium,t'sanda member all of j cadionuelldes la particulate fem with half-lives greater than i ,

8 days la gaseous effluents released from each unit to areas 4eyond the site boundary, confoming to 10 CFR 50, Appendix I; i -

and .

l J. .Lieftations on the annual dose er dose commitment to any esuber of the public, beyond the SITE SOUNDARY, due to teleases of radioactivity and to radiation from uranium fuel

.!' cycle sources confoming to 40 CFR 190.-

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! Nigh Radiation Area j y 5.7 i .

i 5.0 j ADNINISTRATIVE CONTROLS

{ 5.7 j Nigh Radiation Area As ided in paragraph 20.1601 sha he applied to high radiatio (c) of 10 CFR Part to the following controlsn are j paragraph to.1401(a) and (b) of 10 CFA part 20:

1 i .5.7.1 Mlah Radiation Areas with Bene Rates Not Exceedine 1.0 rem / hour at 30 I

Cartimeters from the Radiation Source er from Any surface Penetrated by the Rat intion!

l a. 'Esch entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such i barricades may be opened as necessary to permit entry or i exit of personnel er equipment.

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b. Access to, and activities in, each such area shall be

, controlled by means of Radiation Work permit (RWP or

. equivalent that includes sweification of radtatio)n dose i

radiationprotectionequipment'and)esasures. rates in the immed

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c. Individuals qualified in radiation protection procedures

(e.g.,healthphysicstechnicians)andpersonnel l continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while perfoming their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.

. d. Each individual er group entering such an area shall possess:

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1. A radiation monitoring device that continuously

displays radiation dose rates in the area; or

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m oEL SPECIFICATION 5.0-16 ADNINISTRATIVE CONTROLS l

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, Nigh Radiation Area l 5.7 j 5.7 Nigh Radiation Area 5.7.1 2. A radiation monitoring device that continuously (continued) fotogrates the endiation dose rates in the area and ala ms when the dsvice's dose alars setpoint is reached, with an appropriate alarm setpoint, or

3. A radiation annitoring device that continuously transaits dose rate and emulative dose to a remots receiver monitored by radiation protection personnel responsible for controlling personnel radiation

' exposure within the area, or

4. A self-reading desimeter fe.g., pocket tonization chamber er electronic desdester) and, (1) Se under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual procedures,equipped qualifiedwith in radiation protection a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (11) Se under the surveillance as specified in the SWP or ecluivalent, while in the area, by means of closec circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area.

e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.

3.7.3 mich Radiation i rean <rit o tese mates armater than 1.c reerhaur at 10 Centimeters ' 'ree t is tae intion Source or from Anv Surface penetrated by t w and' at< on. but tens than 500 rada/ hour at 1 Ester frem the adiat< en Source or frem Any Surface Penetrated by she andiation!

a. Each entryway to such an area shall be conspicuously posted

.as a high radiatten area and shall be provided with a locked cent {nued i

fl00EL SPECIFICATION 5.0-17 ADMINISTRATIVE CONTROLS l

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Nigh Radiation Area 5.7 5.7 Nigh Radiation Area 5.7.2 door er gate that prevents unauthorized entry, and, in (continued) addition: -

1. All such' door end gate keys shall be maintained under the administrative control of the shift supervisor, radiatica protection annager, or his or her designee.

2. Doors and gates shall remain locked except during

• perleds of personnel or equipment entry or exit.

b. Access to, and activities in each such area shall be controlled by means of an RWh or equivalent that includes specification of radiation dose rates in the ismediate work area (s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures may

, be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are following plant radiation protection '

procedures for entry to, exit from, and work in such areas.

d. Each individual er group entering such an area shall possess: ,

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1. A radiation monitorinti device that continuously integrates the radiat<on rates in the area and alarms when the device's dose alars setpoint is reached, with  :

an appropriate alarm setpoint, or  !

2. A radiation monitoring device that continuously transaits dose rate and cumulative dose' information to a remote receiver monitored by radiation protection personnel responsible for contro111nli u rsonnel radiation exposure within the area v'ti the means to communicate with and control overy individual in the eres, er tantinued IIODEL SPECIFICATION 5.0-18 ADNINISTRATIVE CONTR01.S

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Nigh Radiation Area 5.7 l 5.7 Nigh Radiation Area l

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! 5.7.1 3. A self-reading dosimeter Co.s., pocket tenization  ;

i '(continued) dauber er electronic des < meter) and,

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~ (1) Se ender the serve 111ance as specified in W i EP er equivalent dile In the area, of an individual

, precedures, qualified equipped with ain'rediation radiation monitoring protection i device that continuously displays radiation dose i rates in the area d o is responsible for 1 controlling person;nel exposure within the area, i l er -

! (11) Se under the surveillance as specified in the  ;

} RWP or equivalent, while in the area, by means '

i of closed circuit television, of personnel i

! qualified in radiation protection procedures,

! responsible for controlling personnel radiation i exposure in the area and with the means to 4

connunicate with and, control every individual in  ;

i the area, or  !

! 4. In those cases d ere tions 2 and

! impractical or detemNed to b(e)incons(3), istent above,with the are j 'As Low As is Reasonably Achievable' principle, a '

i radiation monitoring device that continuously displays l radiation dose rates in the area.

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e. Except for individual qualified in radiation protection

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procedures, entry into such areas >> hall be made only after I dose rates in the area have been determined and entry personnel are knowledgeable of them. ,

f. Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for the purpose of locking and dere no enclosure can reasonable be constructed around the individual area need act be controlled by a locked door er gate, but shall be barricaded and conspicuous, clearly visible flashin shall be activated at the area as a warning device.g light SCOEL SPECIFICATION 5.0-1g ADMINISTRATIVE CONTR01.5

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