ML061720068
| ML061720068 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/09/2006 |
| From: | James Shea NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Kansler M Entergy Nuclear Operations |
| SHea J, NRR/DLPM,415-1388 | |
| References | |
| TAC MC5419 | |
| Download: ML061720068 (19) | |
Text
August 9, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:
ADMINISTRATIVE CHANGES AND RELOCATION OF CERTAIN TECHNICAL SPECIFICATION RESPONSIBILITIES (TAC NO. MC5419)
Dear Mr. Kansler:
The Commission has issued the enclosed Amendment No. 223 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated December 14, 2004.
The amendment deleted redundant Technical Specification (TS) administrative safety limit reporting requirements, relocated certain administrative responsibilities, changed certain administrative titles and included editorial corrections and clarifications. These changes were consistent with the improved STSs for Boiling Water Reactors (NUREG-1433 Revision 3).
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.
Sincerely,
/RA/
James J. Shea, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Amendment No. 223 to License No. DPR-35
- 2. Safety Evaluation cc w/encls: See next page
August 9, 2006 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - ISSUANCE OF AMENDMENT RE:
ADMINISTRATIVE CHANGES AND RELOCATION OF CERTAIN TECHNICAL SPECIFICATION RESPONSIBILITIES (TAC NO. MC5419)
Dear Mr. Kansler:
The Commission has issued the enclosed Amendment No. 223 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station. This amendment is in response to your application dated December 14, 2004.
The amendment deleted redundant Technical Specification (TS) administrative safety limit reporting requirements, relocated certain administrative responsibilities, changed certain administrative titles and included editorial corrections and clarifications. These changes were consistent with the improved STSs for Boiling Water Reactors (NUREG-1433 Revision 3).
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.
Sincerely,
/RA/
James J. Shea, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Amendment No. 223 to License No. DPR-35
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC RidsNrrDorlLpla RPowell, RI RidsOGC RP GMiller PDI-I R/F RidsNrrLASLittle RidsNrrPMJShea GHill (2)
RidsAcrsAcnwMail Package: ML061720083 Accession Number: ML061720068 OFFICE LPL1-1/PM LPL1-1/LA IHPB/BC ITSB/BC OGC LPL1-1/BC NAME JShea SLittle TFrye TKobetz RLaufer DATE 6/30/06 7/06/06 7/21/06 7/26/06 8/07/06 8/09/06 OFFICIAL RECORD COPY
ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.
DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 223 License No. DPR-35
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment filed by Entergy Nuclear Operations, Inc. (the licensee) dated December 14, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations; 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 Commission's 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 Commission's 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 3.B of Facility Operating License No. DPR-35 is hereby amended to read as follows:
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, 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 issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License and Technical Specifications Date of Issuance: August 9, 2006
ATTACHMENT TO LICENSE AMENDMENT NO. 223 FACILITY OPERATING LICENSE NO. DPR-35 DOCKET NO. 50-293 Replace the following page of the Facility Operating License with the attached revised page.
The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Remove Insert 3
3 Replace the following pages of the 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 1-5 1-5 2-1 2-1 3/4.5-2 3/4.5-2 3/4.7-5 3/4.7-5 3/4.8-2 3/4.8-2 3/4.9-2 3/4.9-2 3/4.9-4 3/4.9-4 3/4.11-3 3/4.11-3 3/4.13-1 3/4.13-1 3/4.13-2 3/4.13-2 5.0-1 5.0-1 5.0-2 5.0-2 5.0-3 5.0-3 5.0-6 5.0-6 5.0-8 5.0-8 5.0-9 5.0-9 5.0-14 5.0-14
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 223 TO FACILITY OPERATING LICENSE NO. DPR-35 ENTERGY NUCLEAR GENERATION COMPANY ENTERGY NUCLEAR OPERATIONS, INC.
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
By letter dated December 14, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML043560279), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Pilgrim Nuclear Power Station (Pilgrim or PNPS)
Technical Specifications (TSs). The requested TS amendment would delete redundant administrative safety limit reporting requirements, relocate certain administrative responsibilities, change certain administrative titles and make editorial corrections and clarifications. These proposed changes are consistent with the Improved Standard Technical Specifications (ISTS) for Boiling Water Reactors (BWRs) (NUREG-1433 Revision 3).
2.0 REGULATORY EVALUATION
The construction permit for Pilgrim was issued by the Atomic Energy Commission (AEC) on August 26, 1968; a low-power license was issued on June 8; 1972, and a full-power license was issued on September 15, 1972. The plant design approval for the construction phase was based on the proposed General Design Criteria (GDC) published by the AEC in the Federal Register (32 FR 10213) on July 11, 1967 (hereinafter referred to as "draft GDC"). The AEC published the final rule that added Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "General Design Criteria for Nuclear Power Plants," in the Federal Register (36 FR 3255) on February 20, 1971 (hereinafter referred to as "final GDC").
Differences between the draft GDC and final GDC included a consolidation from 70 to 64 criteria. In accordance with a Nuclear Regulatory Commission (NRC) staff requirements memorandum from S. J. Chilk to J. M. Taylor, "SECY-92-223 - Resolution of Deviations Identified During the Systematic Evaluation Program," dated September 18, 1992 (ADAMS Accession No. ML003763736), the Commission decided not to apply the final GDC to plants with construction permits issued prior to May 21, 1971, which includes Pilgrim. The Pilgrim Updated Final Safety Analysis Report (UFSAR), Appendix F, provides an evaluation of the design bases of Pilgrim against the draft GDC.
Although the original approval basis for Pilgrim was the draft GDC, the licensees for Pilgrim have made changes to the facility over the life of the plant that may have invoked some of the final GDC. The extent to which the final GDC have been invoked can be found in specific sections of the UFSAR and in other Pilgrim design and licensing basis documentation. For convenience, the licensee and the NRC staff usually refer to the final GDC rather than the draft GDC when discussing licensing actions.
The NRC staff reviewed proposed changes for compliance with 10 CFR 50.36 and with the precedent as established in the Standard Technical Specifications (STS). In general, licensees cannot justify TS changes solely on the basis of adopting the STS. To ensure this, the NRC staff makes a determination that proposed changes maintain adequate safety. Changes that result in relaxation (less restrictive condition) of current TS requirements require a detailed justification.
Licensees may revise the TSs to adopt STS format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensees current requirement, or (3) the change is less restrictive than the licensees current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards.
3.0 TECHNICAL EVALUATION
3.1 Proposed Changes to the Pilgrim TS Requirements 3.1.1 TS 2.0, Safety Limits The licensee proposed to remove the following parts of TS 2.2, Actions Taken Following Violation of a Safety Limit:
1.
TS 2.2.1 Within one hour notify the NRC Operations Center in accordance with 10 CFR 50.72.
2.
TS 2.2.3 The Station Director and Senior Vice President - Nuclear and the Nuclear Safety Review and Audit Committee (NSRAC) shall be notified within 24 Hours.
3.
TS 2.2.4 A Licensee Event Report shall be prepared pursuant to 10 CFR 50.73.
The Licensee Event Report shall be submitted to the Commission, the Operations Review Committee (ORC), the NSRAC and the Station Director and Senior Vice President - Nuclear within 30 days of the violation.
4.
TS 2.2.5 Critical operation of the unit shall not be resumed until authorized by the Commission.
3.1.2 Titles listed in TS 5.0, Administrative Controls The licensee proposed to modify parts of TS 5.0:
5.
TS 5.1.1 &
Station Director would be replaced with Plant Manager.
TS 5.2.1.b 6.
TS 5.1.2 Nuclear Operations Supervisor would be replaced with Control Room Supervisor, including their corresponding acronyms.
7.
TS 5.2.1.a The last sentence would be modified to read as follows: These requirements, including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Pilgrim Station Final Safety Analysis Report (FSAR).
8.
TS 5.2.1.c The Vice President - Operations would be replaced with A specified Corporate Officer.
9.
TS 5.2.2.h The Operations Department Manager would be replaced with operations manager or assistant operations manager, while the positions of Nuclear Watch Engineers and Nuclear Operations Supervisor would be removed from the list of those required to hold a Senior Reactor Operator License. Additionally, the requirement for the Nuclear Plant Operator to hold a Reactor Operator License would be removed.
6.
TS 5.2.2.i The TS section would be modified as follows: The reference to the Shift Control Room Engineer (SCRE) would be replaced with An Individual.
The Nuclear Operations Supervisor (NOS) will be replaced by the unit operations shift crew. Other editorial changes are made for consistency.
7.
TS 5.5.1 Review and acceptance by the Operations Review Committee would be removed and the approval responsibility of the Chemistry and Radiological Department Manager would be given to the plant manager.
8.
TS 5.7.1 Health Physics personnel would be replaced with radiation protection personnel.
9.
TS 5.7.1.c Radiation Protection Manager would be changed to all lower case letters.
10.
TS 5.7.2 the Nuclear Watch Engineer would be replaced with an SRO.
3.1.3 Operations Review Committee Responsibilities The licensee proposed to modify TS 3.7.A.2.a.5, Containment Systems to remove the responsibility of the Operations Review Committee (ORC) to approve the administrative controls for intermittent operation of normally closed containment isolation valves.
3.1.4 ASME OM Code Inservice Testing Requirements The licensee proposed to make the following changes to TS sections controlling the Pilgrim pump and valve inservice testing (IST) requirements. The changes would reflect testing in accordance with the American Society of Mechanical Engineers (ASME) Operations and Maintenance Code (OM Code) and to make the program description consistent with the Pilgrim IST program described as the, Inservice Code Testing Program:
1.
TS 1.0 The definition of REFUELING INTERVAL would be revised to change ASME Code,Section XI IWP and IWV to Inservice Code Testing Program.
2.
TS 3/4.13 or equivalent would be removed from the applicability statement.
Additionally, (Safety Related) or equivalent (important to safety) would be removed from the objective statement.
3.
TS 3.13.A.1.
Safety and safety related would be replaced with ASME Code Class 1, 2, and 3. Additionally, the reference to ASME Boiler and Pressure Vessel Code (and associated relief requests) would be replaced by a reference to the, Inservice Code Testing Program.
4.
TS 4.13.A.1 Combine as TS 4.13.A.1, delete the text of paragraph A.1 and TS 4.13.A.2 replace the 4.13.A.2 introduction Test Frequencies for Code with The ASME OM Code, The Code Terminology and associated Frequencies Table remains unchanged.
- 5.
TS Bases Bases details are corrected and draft changes are provided for information.
3.1.5 Radioactive Effluent Controls Program The licensee proposed to make the following changes to TS 5.5.4, Radioactive Effluent Controls Program:
4.
TS 5.5.4.b Replace 10 CFR 20, Appendix B, Table 2, Column 2" with ten times the concentration values in Appendix B, Table 2, Column 2, to 10 CFR 20.1001 - 20.2402.
5.
TS 5.5.4.e Remove and projected dose from the first sentence, and add Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM [Offsite Dose Calculation Manual] at least every 31 days as a second sentence.
6.
TS 5.5.4.g Replace effluents to areas beyond to read effluents from the site boundary to areas at or beyond.
7.
TS 5.5.4.j Add beyond the site boundary after member of the public.
3.1.6 Miscellaneous Editorial Changes The licensee proposed to make the following editorial changes throughout the TSs:
8.
TS 3.7.A.5 Remove the ** and associated footnote.
9.
TS 3.5.A.5 Correct the spelling of the word reactor.
10.
TS 3.8.2 Delete an extra period and correct the spelling of the word CHANNEL on page 3/4.8-2.
11.
TS 4.9.A.c Correct a reference in the last sentence on page 3/4.9-2 from 4.9.A.1.b.1 to 4.9.A.1.b.2.
12.
TS 3.9.B.2 Delete and the NRC is notified within one (1) hours as required be 10 CFR 50.72" from the last sentence on page 3/4.9-4.
13.
TS 4.9.A.4.b Correct a typographical error in the abbreviation of Hz (from HZ to Hz).
14.
TS 3.11.C.2 Correct a typographical error on page 3/4.11-3 (from 3.3-1" to 3.3.1").
3.2 Licensee Technical Analysis of Proposed Changes The proposed changes (1) to remove the administrative reporting and restart authorization requirements that apply in the event of a Safety Limit violation; (2) to replace plant-specific titles with generic titles; (3) to remove responsibilities of the ORC; (4) to delete regulatory detail for the Inservice Code Testing Program; and (5) other administrative corrections and clarifications; are administrative with no technical change in requirements. As such, no specific regulatory requirements or guidance applies. Additionally, the changes are consistent with the latest revision of the BWR/4 Standard Technical Specifications, NUREG-1433 (Revision 3, dated March 31, 2004).
3.2.1 TS 2.0, Safety Limits TS Section 2.2 provides notification, reporting, and restart requirements to be met in the event of a Safety Limit violation. TS Sections 2.2.1, 2.2.4, and 2.2.5, which are proposed for deletion, are addressed by the requirements of 10 CFR 50.36(c)(1)(i)(A). Furthermore, TS Section 2.2.1 is addressed by 10 CFR 50.72 and TS 2.2.4 is addressed by 10 CFR 50.73; however, the TS 2.2.4 30-day requirement to submit the Licensee Event Report (LER) is no longer consistent with the latest provisions of 10 CFR 50.73, which allow 60-day reporting. This change will correct that inconsistency. Also proposed for deletion is TS 2.2.3, which directs notification of the Station Director, Vice President - Nuclear, and the Nuclear Safety Review and Audit Committee within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Assurance of these administrative notifications is adequately controlled by plant procedures. TS 2.2.2.A and 2.2.2.B will be renumbered to 2.2.1 and 2.2.2 because of the deletion of the above TS sections.
Removal of duplicative reporting requirements from the TSs results in simplification of the TSs and Bases and less administrative burden to track duplicative reporting requirements. Adequate administrative controls exist in administrative programs at Pilgrim for the identification and necessary reporting of safety limit violations in accordance with 10 CFR 50.36, 10 CFR 50.72, and 10 CFR 50.73.
In summary, the necessary notification, reporting, and restart requirements to be met in the event of a Safety Limit violation are adequately addressed by existing regulations and plant procedures. As such, these changes are administrative with no technical change in requirements.
3.2.2 Titles listed in TS 5.0, Administrative Controls Replacing plant-specific titles with generic titles, and including a TS commitment (in TS 5.2.1) to retain specific titles in the Final Safety Analysis Report (FSAR) of those personnel fulfilling the responsibilities does not eliminate any qualifications, responsibilities or requirements for these positions. Members of the plant staff assigned to these positions shall continue to meet or exceed the minimum qualifications required by TS 5.3, "Unit Staff Qualifications."
Any change of the relocated specifications in the FSAR will be strictly controlled in accordance with the provisions of 10 CFR 50.59, "Changes, tests, and experiments" to determine if the proposed changes will require prior NRC review and approval. Additionally, reporting of any changes to the NRC will be made in accordance with 10 CFR 50.71(e), "Maintenance of records, making of reports."
Additional administrative plant staff position clarifications outlined in Section 2, Proposed Changes, are also consistent with NUREG-1433, and are discussed below.
In TS 5.2.2.h, the requirement for an Operations Department management position to hold a senior reactor operator license is clarified to include the flexibility of the "operations manager or assistant operations manager." Since both positions are responsible for directing the licensed activities of licensed operators, there is no adverse impact to safe plant operations due to this change.
In TS 5.2.2.h, the discussion of the specific position titles of "Nuclear Watch Engineers" and "Nuclear Operations Supervisors" [NOS] holding a senior reactor operator (SRO) license, and the "Nuclear Plant Operators" holding a reactor operator (RO) license is also eliminated. The generic requirements for SRO and RO on-shift positions are adequately addressed in TSs 5.2.2.b, 5.2.2.c, and 5.2.2.e, as well as 10 CFR 50.54(k), 50.54(l), and 50.54(m). Elimination of these plant-specific titles from this Section is consistent with the intent of replacing plant-specific titles with generic titles.
In TS 5.5.1, the required management level for approval of the changes to the ODCM is made more restrictive by replacing the "Chemistry and Radiological Department Managers" with "the plant manager." This change is made for consistency with NUREG-1433, replaces plant-specific titles with generic titles, and does not preclude the continued approvals of the Chemistry and Radiological Department Managers. As such, there is no adverse impact to safe plant operations due to this change.
In TS 5.7.1 and 5.7.2 reference to "health physics" personnel and supervision is replaced with "radiation protection" to more appropriately reflect the departmental responsibilities. The title case presentation of the "Radiation Protection Manager" in 5.7.1.c is made a generic (i.e., lower case) title "radiation protection manager" consistent with other changes to generic titles.
In TS 5.7.2, "the Nuclear Watch Engineer on duty" is replaced with "an SRO on duty." The NUREG-1433 presentation of "shift supervisor" suggests the equivalent Pilgrim position of NOS. The proposed change allows maintaining the current requirement for Nuclear Watch Engineer (i.e., shift manager) to retain this responsibility, but also allows for future procedure revision to assign this responsibility to the NOS if desired. Since there is no actual change to existing requirements, and the possible allowed future change is consistent with the standard TS, there is no adverse impact to safe plant operations due to this change.
In summary, the necessary qualifications, responsibilities or requirements for these positions are adequately addressed by existing regulations and regulatory controls imposed for future changes to the FSAR. As such, these administrative changes do not adversely impact the public health and safety.
3.2.3 Operations Review Committee Responsibilities The ORC responsibilities were relocated from the Pilgrim TS in Amendment No. 177 dated July 31, 1998. However, two references to ORC review and approval responsibilities were overlooked for concurrent relocation.
TS 3.7.A.2.b, Footnote *, references ORC approval of the administrative controls used to intermittently open primary containment isolation valves closed to satisfy TS required actions.
The corresponding allowance in NUREG-1433, TS 3.6.1.3, Actions Note 1, does not include any reference to approval authority for the administrative control. Also, TS 5.5.1.b specifies requirements for implementing licensee-initiated changes to the ODCM, which include "review and acceptance by the Operations Review Committee." The corresponding requirement in NUREG-1433, Specification 5.5.1.b, does not specify the details of programmatic review(s) -
only the final approval required by the plant manager.
In summary, the necessary ORC responsibilities are adequately addressed in licensee controlled documents, without explicit TS requirements, as previously approved by the NRC.
As such, these changes are administrative with no technical change in requirements.
3.2.4 ASME OM Code Inservice Testing Requirements The proposed changes to the REFUELING INTERVAL definition and to TS 3/4.13.A reflect administrative changes only. References to ASME Code, Section Xl are revised to reflect current regulations and ASME OM Code and the Pilgrim specific program name, "Inservice Code Testing Program." The administrative reference to safety and safety related and "or equivalent" is corrected to match the regulation, which specifically addresses Code Class 1, 2, and 3 pumps and valves. Since the regulations of 10 CFR 50.55a already adequately enforce the requirements, eliminating detailed reference to the regulation, and explicit reference to regulations governing relief from the Code, the proposed Specification retains only the specific performance frequency definitions for Code terminology. These changes result in a Specification essentially equivalent to the BWR/4 Standard TS (NUREG-1433) Specification 5.5.7, "Inservice Testing Program." This change does not impact the April 30, 2004, NRC review of the Pilgrim Fourth 10-Year Inservice Code Testing Program, which remains the basis for the current program implementation.
3.2.5 Radioactive Effluent Controls Program The following administrative changes involve no technical change and serve to enhance the consistency of the PNPS TS with the NUREG-1433 Standard TS for consistent use and application for the PNPS operating staff and NRC regulator:
1.
TS 5.5.4.b, replace "10 CFR 20, Appendix B, Table 2, Column 2" with "ten times the concentration values in Appendix B, Table 2, Column 2, to 10 CFR 20.1001 - 20.2402."
These values provide reasonable assurance that the levels of radioactive materials in bodies of water in unrestricted areas will result in exposures within (1) the Section II.A design objectives of appendix I to 10 CFR Part 50 and (2) restrictions authorized by 10 CFR 20.1301(e).
The existing PNPS TS 5.5.4.b, references the old Part 20.1 - 20.602, Appendix B, Table II (typographically presented as Table 2"), as allowed by 10 CFR 20.1008. Current requirements for the content of TS concerning radioactive effluents are contained in 10 CFR 50.36a. 10 CFR 50.36a requires licensees to maintain control over radioactive material in gaseous and liquid effluents to unrestricted areas, produced during normal reactor operations, including expected occurrences, to levels that are as low as reasonably achievable (ALARA). For power reactors, Appendix I to 10 CFR Part 50 contains the numerical guidance to meet the ALARA requirement. The dose values specified in Appendix I of 10 CFR Part 50 are small percentages of the implicit limits in the old 10 CFR 20.106 and the explicit limits in 10 CFR 20.1301. As secondary controls, the instantaneous concentration release rates required by this TS were chosen by the NRC to help maintain annual average releases of radioactive material in gaseous and liquid effluents to within the dose values specified in Appendix I of 10 CFR Part 50.
For the purposes of STS 5.5.4.b, 10 CFR Part 20 is used as a source of reference values only. These TS requirements allow operational flexibility, compatible with considerations of health and safety, which may temporarily result in release rates which, if continued for the calendar quarter, would result in radiation doses higher than specified in Appendix I of 10 CFR Part 50. However, these releases are within the implicit limits in the old 10 CFR Part 20.106 and the explicit limits in 10 CFR Part 20.1302, which references 10 CFR Part 20, Appendix B, concentrations. These referenced concentrations in the old 10 CFR Part 20 are specific values, which relate to an annual dose of 500 mrem. The liquid effluent radioactive effluent concentration limits given in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2402 are based on an annual dose of 50 mrem total effective dose equivalent. Since an instantaneous release concentration corresponding to a dose rate of 500 mrem/year has been acceptable as a TS limit for liquid effluents, which applies at all times to assure that the values in Appendix I of 10 CFR Part 50 are not likely to be exceeded, it is not necessary to reduce this limit by a factor of 10.
The use of effluent concentration values that are 10 times those listed in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2402 will not have a negative impact on the ability to continue to operate within the design objectives in Appendix I to 10 CFR Part 50. Thus, the change to STS 5.5.4.b maintains the same overall level of liquid effluent control while retaining the operational flexibility that exists with TS under the previous 10 CFR Part 20. This limitation (i.e., less than 10 times the concentration values... ) provides reasonable assurance that the levels of radioactive materials in bodies of water in Unrestricted Areas will result in exposures within (1) the Section Il.A design objectives of Appendix I to 10 CFR Part 50 and (2) restrictions authorized by 10 CFR 20.1301(e).
2.
TS 5.5.4.e, delete "and projected dose" from the current sentence and add second sentence "Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days." This change is an administrative clarification approved by the NRC in TSTF-308, and presented in NUREG-1433, Revision 3. This avoids possible misinterpretation that projecting doses for the current calendar quarter, as well as for the current calendar year, are required every 31 days. This clarification does not reflect any change in requirements or procedures.
3.
TS 5.5.4.g, reword "effluents to areas beyond" adding clarifying phrases to read effluents from the site boundary to areas at or beyond." Also the staff requested that the term total body be replaced by whole body, These changes are an administrative clarification approved by the NRC in TSTF-258, and presented in NUREG-1433, Revision 3. This clarification does not reflect any change in requirements or procedures.
4.
TS 5.5.4j, add "beyond the site boundary" after "member of the public." This change is an administrative clarification approved by the NRC in TSTF-258, and presented in NUREG-1433, Revision 3. This clarification does not reflect any change in requirements or procedures.
3.2.6 Miscellaneous Editorial Changes The following editorial changes, corrections, or clarifications involve no technical change and serve to clarify the use and application of TS for the operating staff:
- 1.
Remove the ** note from TS 3.7.A.5 since it was only applicable through 1998.
2.
TS 3.5.A.5 misspelled word "rector" is corrected to "reactor." During the processing of License Amendment No. 200, dated April 22, 2003, "reactor" was misspelled in TS 3.5.A.5.
3.
TS 3.8.2, on page 3/4.8-2, has two periods in the APPLICABILITY statement. The extra period at the end of the sentence is removed and the misspelled word "CHANNEl" in TS 4.8.2.3 is corrected to "CHANNEL." These typographical errors were inadvertently introduced during License Amendment No. 177, dated July 31, 1998.
4.
TS 4.9.A.c, on page 3/4.9-2, has a typo in the last sentence reference to 4.9.A.1.b.1,"
which is corrected to "4.9.A.1.b.2." This typographical error makes incorrect reference to the Specification, which was inadvertently introduced during License Amendment No.
179, dated December 18, 1998.
5.
TS 3.9.B.2 last sentence on page 3/4.9-4, "and the NRC is notified within one (1) hour as required by 10 CFR 50.72" is deleted. This is adequately required by the 10 CFR 50.72 and applicable plant procedure implementation of the regulation.
6.
TS 4.9.A.4.b, on page 3/4.9-4 correct the abbreviation for the unit hertz to "Hz" (without subscripting the "z"). This was a typographical error only.
7.
TS 3.11.C.2, on page 3/4/11-3, reference to Table 3.3.1" is revised to correctly reference "Table 3.3-1." This was a typographical error only.
Elimination of duplicative regulatory reporting requirements will avoid future, and eliminate existing, inconsistent or conflicting regulatory requirements. The proposed use of generic personnel titles will allow Pilgrim the flexibility to revise position titles while still meeting the appropriate personnel qualifications required by TS 5.3, "Unit Staff Qualifications."
Additionally, the use of generic personnel titles will reduce and/or eliminate the need for future license amendments related to revised position titles. Administrative corrections and enhancements serve to clarify the use and application of TS for the operating staff.
These proposed changes are considered administrative with no adverse impact on the public health and safety.
3.3 Staff Evaluation of Proposed Changes 3.3.1 TS 2.0, Safety Limits The licensee proposed changes to delete the administrative reporting requirements of TS Section 2.0. Specifically, TS Sections 2.2.1, 2.2.3, 2.2.4 and 2.2.5 are redundant to other regulatory required notifications and approvals. Removing these statements will not materially alter the licensee reporting requirements and the requirement for Commission approval upon resuming operation following a safety limit violation. This change was generically applied to all nuclear power plants as outlined in the Technical Specification Task Force change five (TSTF-
- 5) which was approved for BWRs on June 11, 1996. The NRC staff therefore, finds that these proposed changes to the Pilgrim TS Section 2.0 are acceptable and consistent with the ISTS.
3.3.2 Titles listed in TS 5.0, Administrative Controls The licensee proposed to change specific organizational titles in TS Section 5.0 with generic titles and titles that better fit the current organizational structure. These proposed changes do not materially alter the licensee organizational responsibilities, functions, or qualifications for the specified positions. Lines of authority, responsibility, and communication are defined and established throughout all management levels and all operating organization positions in the Pilgrim FSAR as required by the Pilgrim TS 5.2.1.a. The proposed change to TS 5.2.1.a only clarifies these requirements.
The generic change in TS 5.2.1.c, from The Vice President - Operations to A specified corporate officer was approved in TSTF-65 for BWRs on December 2, 1997.
All the proposed changes in TS Section 5.0 are consistent with the ISTS and do not change Pilgrims organizational responsibilities for safe plant operation and no requirements are materially altered. Therefore, the NRC staff finds these administrative changes acceptable.
3.3.3 Operations Review Committee Responsibilities The Pilgrim TS references to the ORC were relocated along with the references to the NSRAC in Amendment No. 177 approved on July 31, 1998. It was determined, at that time, that these functions provided by these plant specified review committees were duplicated by other regulatory requirements. There are two remaining references in TS that were inadvertently not removed when Amendment No. 177 was approved. The removal of these two remaining references to the ORC is administrative in nature, no requirements are materially altered and the proposed changes are consistent with the ISTS. Therefore, the NRC staff finds these administrative changes acceptable.
3.3.4 ASME OM Code Inservice Testing Requirements The proposed changes to the refueling interval definition and to TS 3/4.13.A are administrative changes that provide clarification to reflect current regulations and current ASME OM Code requirements for IST. 10 CFR 50.55a, Codes and standards specify the ASME Code requirements for plant operations, maintenance and testing of ASME Code Class 1, 2, and 3 safety-related components. Testing requirements for ASME Code 1, 2, and 3 pumps and valves are defined in 10 CFR 50.55a(f). The requirements specified in the Pilgrim TS are therefore redundant to NRC regulations and ASME Code requirements. The Pilgrim TSs will maintain the current specific performance frequency definitions. The proposed changes to Pilgrim TS Section 3.13 would be essentially equivalent to the ISTS Section 5.5.7. Because the proposed changes are administrative and will not materially alter the licensee IST requirements, the NRC staff finds these changes are acceptable.
3.3.5 Radioactive Effluent Controls Program The changes made to the Pilgrim TS Section 5.5.4 are administrative and provide clarification to reflect regulatory changes made to Part 20 of 10 CFR since Pilgrim was licensed under the old Part 20.1-20.602, Appendix B, Table II. The use of effluent concentration values that are 10 times those listed in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2402 was approved by the NRC staff in TSTF-258-A, Revision 4 on June 29, 1999. The proposed changes maintain the same overall level of effluent control while retaining the operational flexibility that exists with current TS under the previous 10 CFR Part 20. This limitation (i.e.,
less than 10 times the concentration values) provides reasonable assurance that the levels of radioactive materials in bodies of water in Unrestricted Areas will result in exposures within the Section II.A design objectives of Appendix I to 10 CFR Part 50 and restrictions authorized by 10 CFR 20.1301(e). These changes are intended to eliminate possible confusion or improper implementation of the revised 10 CFR 20 requirements. The change to Pilgrim TS Section 5.5.4.b will not change the requirements for liquid effluent limits as prescribed by the current NRC Part 20. Because the proposed changes are administrative, provide clarification of current regulations, will not materially alter the licensee technical requirements related to Pilgrims radioactive control programs and are consistent with the ISTS, the NRC staff finds these changes are acceptable.
3.3.6 Miscellaneous Changes The proposed changes as outlined in Section 3.2.6 of this safety evaluation, specifically items numbered 1, 2, 3, 6, and 7 are typographical corrections that do not materially alter any TS requirements, therefore, the NRC staff finds these proposed editorial changes to be acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Massachusetts State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes 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 changes surveillance requirements. The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (70 FR 9990). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: J. Shea, G. Miller Date: August 9, 2006 Pilgrim Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 MA Department of Public Health Radiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129 Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108 Director, Massachusetts Emergency Management Agency Attn: James Muckerheide 400 Worcester Road Framingham, MA 01702-5399 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Mr. Kevin H. Bronson General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Michael A. Balduzzi Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Stephen J. Bethay Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Bryan S. Ford Manager, Licensing Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Pilgrim Nuclear Power Station cc:
Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Oscar Limpias Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Christopher Schwarz Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306 Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348