ML020530410

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License Amendment Relocating Designated Technical Specifications to the Licensing Requirements Manual
ML020530410
Person / Time
Site: Beaver Valley
Issue date: 05/21/2002
From: Dan Collins
NRC/NRR/DLPM/LPD1
To: Myers L
FirstEnergy Nuclear Operating Co
Collins D S, NRR/DLPM, 415-1427
Shared Package
ML020530416 List:
References
TAC MB2048, TAC MB2049
Download: ML020530410 (19)


Text

May 21, 2002 Mr. L. W. Myers Senior Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT RE: RELOCATING DESIGNATED TECHNICAL SPECIFICATIONS TO THE LICENSING REQUIREMENTS MANUAL AND THE OFFSITE DOSE CALCULATION MANUAL (TAC NOS. MB2048 AND MB2049)

Dear Mr. Myers:

The Commission has issued the enclosed Amendment No. 250 to Facility Operating License No. DPR-66 and Amendment No. 130 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated May 22, 2001.

In accordance with the Nuclear Regulatory Commissions (NRCs) Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal Register on July 22, 1993 (58 FR 39132), these amendments allow the relocation of the TS requirements associated with the curie content limit for liquid and gaseous waste storage and the TSs associated with the explosive gas concentration limits. These TSs will be placed in the BVPS-1 and 2 Offsite Dose Calculation Manual and the BVPS-1 and 2 Licensing Requirements Manual, respectively. Additionally, the amendments allow for revisions to the reporting requirements of BVPS-1 and 2, TS 6.9.3, Annual Radioactive Release Report.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Daniel Collins, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 250 to DPR-66
2. Amendment No. 130 to NPF-73
3. Safety Evaluation cc w/encls: See next page

May 21, 2002 Mr. L. W. Myers Senior Vice President Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT RE: RELOCATING DESIGNATED TECHNICAL SPECIFICATIONS TO THE LICENSING REQUIREMENTS MANUAL AND THE OFFSITE DOSE CALCULATION MANUAL (TAC NOS. MB2048 AND MB2049)

Dear Mr. Myers:

The Commission has issued the enclosed Amendment No. 250 to Facility Operating License No. DPR-66 and Amendment No. 130 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated May 22, 2001.

In accordance with the Nuclear Regulatory Commissions (NRCs) Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal Register on July 22, 1993 (58 FR 39132), these amendments allow the relocation of the TS requirements associated with the curie content limit for liquid and gaseous waste storage and the TSs associated with the explosive gas concentration limits. These TSs will be placed in the BVPS-1 and 2 Offsite Dose Calculation Manual and the BVPS-1 and 2 Licensing Requirements Manual, respectively. Additionally, the amendments allow for revisions to the reporting requirements of BVPS-1 and 2, TS 6.9.3, Annual Radioactive Release Report.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Daniel Collins, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Amendment No. 250 to DPR-66
2. Amendment No. 130 to NPF-73
3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC MO'Brien ACRS BPlatchek, RGN-1 PDI-1 Reading DCollins JLehning RHagar SRichards OGC PHearn RLaufer GHill (4)

RDennig

  • SEs provided, no major changes made Package: ML020530416 Amendment: ML020530410 Tech Spec: ML021420155 OFFICE PDI-1/PM PDI-1/LA DSSA/SPLB (A)SC DRIP/RORP PDI-1/SC OGC NAME DCollins MOBrien RHagar*

RDennig*

RLaufer RWeisman DATE 5/3/02 5/3/02 se dtd 3/13/02 se dtd 1/9/02 5/20/02 5/14/02 OFFICIAL RECORD COPY

Beaver Valley Power Station, Units 1 and 2 Mary OReilly, Attorney FirstEnergy Nuclear Operating Company FirstEnergy Corporation 76 South Main Street Akron, OH 44308 FirstEnergy Nuclear Operating Company Regulatory Affairs/Corrective Action Section Larry R. Freeland, Manager Beaver Valley Power Station Post Office Box 4, BV-A Shippingport, PA 15077 Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305 Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.

Harrisburg, PA 17110-9364 Ohio EPA-DERR ATTN: Zack A. Clayton Post Office Box 1049 Columbus, OH 43266-0149 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 L. W. Pearce, Plant Manager (BV-IPAB)

FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077 Bureau of Radiation Protection ATTN: Larry Ryan P O Box 2063 Harrisburg, PA 17120 Mayor of the Borough of Shippingport P O Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 298 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station ATTN: M.P. Pearson, Director Services and Projects (BV-IPAB)

Post Office Box 4 Shippingport, PA 15077 Mr. J. A. Hultz, Manager Projects & Support Services FirstEnergy Corporation 76 South Main Street Akron, OH 44308 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mr. B. F. Sepelak Post Office Box 4, BV-A Shippingport, PA 15077

PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 250 License No. DPR-66 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated May 22, 2001, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-66 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 250, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance. Implementation shall include revision of the Offsite Dose Calculation Manual and Licensing Requirements Manual as set forth in the application by the licensee dated May 22, 2001.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 21, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 250 FACILITY OPERATING LICENSE NO. DPR-66 DOCKET NO. 50-334 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert IV IV IX IX X

X XIII XIII XIV XIV XV XV XVII XVII 3/4 3-53 3/4 3-54 3/4 3-55 3/4 3-56 3/4 3-57 3/4 3-58 3/4 11-1 3/4 11-2 3/4 11-3 3/4 11-4 3/4 11-5 3/4 11-6 3/4 12-1 6-16 6-16 6-17 6-17 6-18 6-18 6-19 6-19 6-20

PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 130 License No. NPF-73 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated May 22, 2001, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-73 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 130, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance. Implementation shall include revision of the Offsite Dose Calculation Manual and Licensing Requirements Manual as set forth in the application by the licensee dated May 22, 2001.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 21, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 130 FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert V

V IX IX X

X XIII XIII XIV XIV XV XV 3/4 3-60 3/4 3-61 3/4 3-62 3/4 3-63 3/4 3-64 3/4 3-65 3/4 3-66 3/4 11-1 3/4 11-2 3/4 11-3 3/4 11-4 3/4 11-5 3/4 11-6 3/4 12-1 6-16 6-16 6-17 6-17 6-18 6-18 6-19 6-19 6-20 6-20 6-21

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 250 AND 130 TO FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412

1.0 INTRODUCTION

By letter dated May 22, 2001, the FirstEnergy Nuclear Operating Company (FENOC, the licensee), submitted a request for changes to the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2), Technical Specifications (TSs). The amendment requests propose to relocate the TS requirements associated with the curie content limit for liquid and gaseous waste storage systems and the explosive gas concentration limit for gaseous waste storage systems. These TSs would be placed in the BVPS-1 and 2 Offsite Dose Calculation Manual (ODCM) or the BVPS-1 and 2 Licensing Requirements Manual (LRM). However, in accordance with the Improved Standard Technical Specifications (ISTS), key elements of the above requirements bases and methodology would be maintained within the Administrative Controls Section of the BVPS-1 and 2 TSs.

Additionally, revisions to BVPS-1 and 2 TS 6.9.3, Annual Radioactive Release Report, are proposed to include changes to the reporting requirements. The changes proposed also include various administrative revisions to support the relocations.

2.0 BACKGROUND

The licensee proposed these revisions to the BVPS-1 and 2 TSs in order to implement, in part, the improvements endorsed in the Nuclear Regulatory Commissions (NRCs), Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal Register on July 22, 1993 (58 FR 39132) (the policy statement). The policy statement addresses the benefits to be derived from the ISTS and encourages licensees to use the ISTS as the basis for plant-specific TS amendments. The policy statement also encourages the licensees to use the ISTS as the basis for complete conversions, but also notes that licensees may adopt portions of the ISTS without fully implementing all ISTS improvements.

2.1 Basis for Standard TS Requirements The policy statement defines four screening criteria for determining which of the TS requirements should be retained and which could be relocated from the license. The four TS screening criteria contained in the policy statement were subsequently incorporated into the regulations by an amendment to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, that was published in the Federal Register on July 19, 1995 (60 CFR 36953). The criteria were utilized by the NRC and industry working groups to develop the content of the ISTS for each of the industry owners groups. The resulting ISTS applicable to Westinghouse plants are contained in NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 2, dated October 2001. The four criteria are as follows:

Criterion 1 Installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to fission product barrier integrity.

Criterion 3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to fission product barrier integrity.

Criterion 4 A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

The policy statement describes the advantages of adopting the ISTS and applying the criteria for screening the existing TSs. The advantages denoted in the policy statement include the clarification of the scope and purpose of the TSs and the enhancing of safe plant operation by focusing the licensees and plant operators attention on those plant conditions most important to safety. In addition, the policy statement describes the improvement to the TSs as resulting in the more efficient use of NRC and industry resources.

The current version of the ISTS, contained in NUREG-1431, Revision 2, dated October 2001, was developed directly from these four criteria. The first phase of the licensees intended TS conversion consists of screening its current TSs against the above criteria, and, contingent upon NRC staff approval, relocating limiting conditions for operation (LCOs) that do not meet the criteria and their associated surveillance requirements (SRs) to licensee-controlled documents. The policy statement provides direction permitting both the screening methodology and the multi-phased approach for ISTS implementation employed by the BVPS-1 and 2 licensee.

The policy statement also explains that TS requirements that do not meet any of the four screening criteria may be proposed for removal from the TSs and relocated to licensee-controlled documents. On October 9, 1996, Administrative Letter 96-04, Efficient Adoption of Improved Standard Technical Specifications, was issued, which recommends that TS requirements found acceptable for relocation by the NRC staff be placed into licensee-controlled documents for which there is an applicable regulatory process for future changes.

One acceptable destination stated in Administrative Letter 96-04 is a program manual which is referenced in the Updated Final Safety Analysis Report (UFSAR).

2.2 Administrative Control of Radiological Effluent TSs In Generic Letter (GL) 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications [RETS] in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program, dated January 31, 1989, which was based upon the Commissions Interim Policy Statement on Technical Specification Improvements, the NRC staff recognized that the procedural details specified by certain RETS could be relocated to licensee-controlled documents, provided that licensees implement general programmatic controls in the Administrative Controls Section of their TSs. The staff noted in GL 89-01 that the relocation of certain RETS to licensee-controlled documents was not intended to reduce the level of radiological effluent control; rather, the relocation was to provide programmatic TS controls consistent with the applicable regulatory requirements, while allowing licensees flexibility concerning the procedures used to verify regulatory compliance. Based upon the guidance of GL 89-01, License Amendment No. 188 for BVPS-1 and License Amendment No. 70 for BVPS-2 to relocate certain RETS to licensee-controlled documents were issued on June 12, 1995.

Following the finalization of the Commissions policy on technical specification improvements, the NRC staff further considered the relocation of the RETS which had not been recommended for administrative control in GL 89-01. On December 15, 1995, GL 95-10, Relocation of Selected Technical Specifications Requirements Related to Instrumentation, was issued, which indicates that RETS concerning explosive gas monitoring instrumentation are not considered to meet the screening criteria of 10 CFR 50.36, and that licensees may propose their relocation.

Additional guidance on RETS was provided with the issuance of Revision 1 of NUREG-1431 in April 1995. This version of the ISTS did not include detailed TSs for the monitoring of radiological effluents, explosive gas, or storage tank radioactivity; instead, using the philosophy of GL 89-01 and NUREG-1431, Revision 1, the ISTS provided general programmatic controls in its Administrative Controls Section, while allowing procedural details to reside in licensee-controlled documents. The current version of the ISTS, NUREG-1431, Revision 2, was issued in October 2001, and is virtually identical to Revision 1 in its treatment of these matters.

2.3 Proposed TS Changes

As shown below in Table 1, the licensee has proposed to relocate four current, detailed TSs for BVPS-1 and 2, to licensee-controlled documents. In lieu of these TSs proposed for relocation, the licensee would add TS 6.8.6.c to the Administrative Controls Section of the BVPS-1 and 2 TSs, to provide general programmatic controls for explosive waste gas and storage tank radioactivity monitoring in a manner consistent with the ISTS.

Table 1: BVPS-1 and 2 TSs Proposed for Relocation Specification Title Destination Document TS 3/4.3.3.11 Explosive Gas Monitoring Instrumentation Licensing Requirements Manual TS 3/4.11.1.4 Liquid Effluents - Liquid Holdup Tanks Offsite Dose Calculation Manual TS 3/4.11.2.5 Gaseous Effluents - Gas Storage Tanks (Unit 2's title is Gaseous Waste Storage Tanks)

Offsite Dose Calculation Manual TS 3/4.11.2.6 Explosive Gas Mixture Licensing Requirements Manual The ODCM and LRM are licensee-controlled documents that are referred to in the UFSAR and governed by the review process prescribed in 10 CFR 50.59.

Additionally, for both units, the licensee has proposed the following administrative TS changes:

(1) minor revisions to TS 6.9.3, Annual Radioactive Effluent Release Report, in accordance with TSTF-152, and (2) the removal of a number of TS pages which are blank, except for a note stating that a former TS has been removed or is no longer used.

3.0 EVALUATION As set forth below, the NRC staff determined that the explosive gas and storage tank radioactivity TSs do not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion in the TSs; therefore, the proposed changes to relocate these TSs are acceptable. These requirements include the LCOs, Action Statements, and associated SRs. In conducting the review, the NRC staff evaluated the proposed TS relocations and determined that they are consistent with the guidance of NRC Administrative Letter 96-04. These relocated provisions will continue to be implemented by appropriate plant procedures: i.e., operating procedures, maintenance procedures, surveillance and testing procedures, and work control procedures.

3.1 TS 3/4.3.3.11, Explosive Gas Monitoring Instrumentation The license amendment request (LAR) proposes to relocate the TS requirements for the explosive gas monitoring instrumentation to the LRM. The Explosive Gas and Storage Tank Radioactivity Monitoring Program requires that the concentrations of oxygen and hydrogen be maintained below flammable limits and a surveillance program be implemented to ensure that the limits are maintained.

TS 3/4.3.3.11 contains requirements applicable to the waste gas decay tank oxygen monitoring instrument channels. The TS requires that the instrument channels be operable with alarm/trip setpoints set to ensure the limits specified in TS 3/4.11.2.6, Explosive Gas Mixture, are not exceeded. When one or more of the channels are inoperable, TS 3/4.3.3.11 requires gas concentration sampling. Additionally, if the required channels cannot be restored within 30 days, the TS requires the submittal of an explanatory report in accordance with 10 CFR 50.4.

The TS also contains SRs to ensure that the instrumentation is periodically calibrated and functionally tested.

The explosive gas monitoring instrumentation TS contains requirements necessary to support TS limits on the concentration of potentially explosive gases. Although monitoring these explosive gas concentrations is significant, the monitoring instrumentation requirements in the TSs do not contain limits that are relied on in safety analyses to prevent or mitigate a design-basis accident. The explosive gas monitoring instrumentation requirements do address the detection of possible precursors to the failure of a waste gas system. These TS requirements do not meet the 10 CFR 50.36 criteria since the explosive gas monitoring instrumentation does not actuate to prevent or mitigate design-basis accidents or transients which assume the failure of or present a challenge to the fission product barrier. Since the explosive gas monitoring instrumentation TS does not conform to the regulatory criteria for inclusion in the TSs, the NRC staff finds it acceptable to relocate TS 3/4.3.3.11 to the LRM.

3.2 TS 3/4.11.1.4, Liquid Effluent - Liquid Holdup Tanks The LAR proposes to relocate the requirements for the liquid effluent - holdup tanks to the ODCM. These requirements contain a curie limit for the radioactive material contained in each tank. Restricting the quantity of radioactive material contained in specified tanks provides assurance that in the event of an uncontrolled release of the content of the tanks, the resulting concentrations would be less than the limits of 10 CFR Part 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area. If the LCO cannot be satisfied, the required actions include instructions for reducing the amount of radioactivity in any affected tank, and the preparation of a special report in accordance with 10 CFR 50.4. This TS also contains an SR to ensure that representative sampling of the specified liquid storage tanks is performed with an appropriate frequency.

In addition to relocating the TS, the LAR provides for the addition of program requirements to the administrative controls section of the TSs that address the requirements of TS 3/4.11.1.4.

These administrative controls contain three key provisions that provide the required control and allow for the relocation of TS 3/4.11.1.4. First, the Explosive Gas and Storage Tank Radioactivity Monitoring Program broadly defines the liquid storage tanks to fully capture the intent of TS 3/4.11.1.4 and provides assurance that all the tanks previously covered by the TSs continue to be covered in the program. Second, the program provides the required guidance for determining the curie limit applicable to the affected storage tanks. And third, the program specifies the implementation of a surveillance program to ensure the quantity of radioactive material in each tank is limited such that any uncontrolled release will be within 10 CFR Part 20, Appendix B limits. Consequently, the remaining procedural details of TS 3/4.11.1.4 are not necessary to satisfy the screening criteria of 10 CFR 50.36, and, consistent with the guidance of the ISTS, TS 3/4.11.1.4 may be relocated to the ODCM.

3.3 TS 3/4.11.2.5 Gaseous, Unit 1, Effluent Gas Storage Tanks (Unit 2 - Gaseous Waste Storage Tanks)

The requirements of this TS include a specific curie limit for the waste gas storage tanks as well as actions to reduce the tank contents to within this limit when the tank limit is exceeded. If the tank contents cannot be adequately reduced expeditiously, the TS requires the licensee to submit a report with an action plan to reduce the tank contents within the limit.

The limits and requirements of TS 3/4.11.2.5 are intended to ensure that the uncontrolled release of the radioactivity contained in a waste gas storage tank or group of connected tanks would not result in a whole-body dose equivalent in excess of 0.5 rem at the nearest exclusion area boundary in the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following the release.

The changes proposed in this LAR include the relocation of the TS requirements and the addition of program requirements in the administrative controls section of the TSs to address the requirements of TS 3/4.11.2.5. These administrative controls contain three key provisions that provide the required control and allow for the relocation of TS 3/4.11.2.5. First, the program will continue to control the radioactive material content in the required tanks. Second, the program contains provisions that provide the required guidance for determining the curie limit applicable to the affected tanks. And third, the program specifies implementation of programs to limit the exposure of individuals in unrestricted areas in the event of an uncontrolled release of the tanks contents. Further, the program limit provides assurance that the quantity of radioactivity will be restricted to ensure that an uncontrolled release will be within the regulatory requirements. Consequently, the remaining procedural details of TS 3/4.11.2.5 are not necessary to satisfy the screening criteria of 10 CFR 50.36, and, consistent with the guidance of the ISTS, TS 3/4.11.2.5 may be relocated to the ODCM.

3.4 TS 3/4.11.2.6, Explosive Gas Mixture The explosive gas mixture TS contains requirements to limit the oxygen concentration to less than or equal to two percent by volume whenever the hydrogen concentration exceeds four percent by volume. The TS also contains actions to suspend the addition of waste gases to the decay tanks and reduce the oxygen concentrations in the decay tanks when these TS limits are exceeded. The TS surveillance requires the concentration of oxygen in the waste gas decay tank to be monitored continuously with oxygen monitors that are required to be operable by the Explosive Gas Monitoring Instrumentation, TS 3/4.3.3.11.

The limits and requirements of TS 3/4.11.2.6 are intended to prevent the failure of a waste gas system due to an explosive combustion of oxygen and hydrogen.

The changes proposed in this LAR include the relocation from the TSs of the requirements of TS 3/4.11.2.6 and the addition of program requirements in the administrative controls section of the TS, TS 6.8.6.c, to limit the concentrations of hydrogen and oxygen in the waste gas system.

Consequently, the remaining procedural details of TS 3/4.11.2.6 are not necessary to satisfy the screening criteria of 10 CFR 50.36, and, consistent with the guidance of the ISTS, TS 3/4.11.2.6 may be relocated to the LRM.

3.5 Addition of TS 6.8.6.c This proposed TS, entitled Explosive Gas and Storage Tank Radioactivity Monitoring Program, would provide general programmatic controls in lieu of the four current TSs proposed for relocation. The licensees proposed TS 6.8.6.c, which is essentially an improved, plant-specific version of TS 5.5.12 from NUREG-1431, contains the following important safety provisions:

1.

Quantities of gaseous radioactivity shall be determined in accordance with Branch Technical Position ETSB 11-5, Postulated Radioactive Release due to Waste Gas System Leak or Failure 2.

Quantities of liquid radioactivity shall be determined in accordance with NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, dated June 1987, Section 15.7.3, Postulated Radioactive Release due to Liquid Containing Tank Failures 3.

The concentrations of hydrogen and oxygen in the waste gas system shall be maintained below their flammability limits 4.

A surveillance program shall ensure that the contents of each gas storage tank, in the event of an uncontrolled release, would not result in a whole-body dose equivalent exceeding 0.5 rem to any individual in an unrestricted area 5.

A surveillance program shall ensure that the contents of all storage tanks containing radioactive liquids located outdoors and not equipped with specified spill protection measures, in the event of an uncontrolled release, would not result in effluent concentrations greater than the limits of 10 CFR Part 20, Appendix B, Table 2, Column 2, to the nearest potable and surface water supplies in an unrestricted area As proposed, TS 6.8.6.c captures the key requirements and limits specified in the four current TSs which the licensee has proposed to relocate (see Table 1 of this SE on page 4), and its addition to the BVPS-1 and 2 TSs would maintain the licensees compliance with 10 CFR 50.36.

Therefore, consistent with the guidance of the ISTS, the NRC staff finds the addition of TS 6.8.6.c acceptable.

3.6 Additional Administrative TS Changes The licensee also proposed changes to TS 6.9.3, Annual Radioactive Effluent Release Report. The Annual Radioactive Effluent Release Report summarizes the quantities of radioactive material released from each unit during the previous year and must be submitted by BVPS-1 and 2 before April 1 of each year. The licensee proposed in this LAR to make editorial changes and to change the due date of the report to prior to May 1. The licensees proposed changes are consistent with those introduced by the NRC-approved TSTF-152 to NUREG-1431. These changes conform with the ISTS, and are consistent with the requirements of 10 CFR 50.36a. Therefore, the changes to TS 6.9.3 are acceptable.

The licensee has also proposed to delete a number of TS pages which are blank, except for a note stating that a former TS has been removed or is no longer used. As these TS pages do not meet the TS screening criteria of 10 CFR 50.36 and otherwise serve no regulatory purpose, the staff finds their deletion acceptable.

Finally, the revisions and additions discussed above will result in repagination of text included in TS pages 6-16 through 6-20 for BVPS-1 and TS pages 6-16 through 6-21 for BVPS-2. This repagination also requires updating of the index pages to accurately reflect the content and location of material within the TSs, and a new BVPS-1 TS index page XV and new BVPS-2 TS index pages XIV and XV will be included with this amendment. These editorial changes do not alter the requirements of the TSs and are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (66 FR 50467). The amendments also change recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: P. Hearn J. Lehning Date: May 21, 2002