ML20236X468

Safety Evaluation Supporting Amend 177 to License DPR-35

ML20236X468
Person / Time
Site:	Pilgrim
Issue date:	07/31/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236X465	List: ML20236X463 ML20236X468
References
NUDOCS 9808100032
Download: ML20236X468 (26)

Text

400 g

go 4

UNITED STATES g

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20655-0001

.....,o I

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j

RELATED TO AMENDMENT NO.177TO FACILITY OPERATING LICENSE NO. DPR-35 BOSTON EDISON COMPANY f

PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

1.0 INTRODUCTION

By letter dated September 19,1997, as supplemented on June 15,1998, the Boston Edison f

Company (BECo or the licensee) submitted a request to modify the Pilgrim Nuclear Power Station (PNPS) Technical Specifications (TS). The requested changes would relocate the Radioactive Effluent Technical Specifications (RETS) and the Radiological Environmental Monitoring Program to the Offsite Dose Calculation Manual (ODCM), in accordance with the I

recommendations of Generic Letter (GL) 89-01, " GUIDANCE FOR THE IMPLEMENTATION OF PROGRAMMATIC CONTROLS FOR RETS IN THE ADMINISTRATIVE CONTROLS SECTION OF TECHNICAL SPECIFICATIONS AND THE RELOCATION OF PROCEDURE DETAILS OF j

CURRENT RETS TO THE OFFSITE DOSE CALCULATION MANUAL OR PROCESS CONTROL PROGhAM." In addition, changes to other sections of the TS are being proposed to align the current TS with NUREG-1433, " STANDARD TECHNICAL SPECIFICATIONS (STS) GENERAL ELECTRIC PLANTS, BWR/4, Rev.1," to minimize changes in the future conversion to improved standard TS. The June 15,1998, letter provided clarifying information and additional changes that did not change the initial proposed no significant hazards consideration determination or expand the scope of the original Federal Reaister Notice. The staff has noted to the licensee that as part of the conversion to the improved Standard TS all sections of the TS will be reevaluated. While the staff has reviewed this amendment, it is not considered part of the conversion process to the improved standard TS.

GL 89-01 provides guidance for the preparation of a license amendment request to implement programmatic controls in TS for radioactive effluents and for radiological environmental monitoring conforming to the applicable regulatory requirements. This will allow the relocation of existing procedural details of the current RETS to the ODCM. Procedural details for solid radioactive wastes normally would be relocated to the Process Control Program (PCP) as part of this change. However, BECo has noted that by letter dated August 30,1985, TS Amendment #

89, the NRC approved the removal of the PCP from the TS and accepted the use of plant procedures in lieu of a PCP. By letter dated March 3,1988, the staff performed an audit of the PCP procedures and determined that they met the intent of TS 6.8 and current NRC guidelines delineated in SRP Section 11.4 and are acceptable for use when processing and packaging solid waste. Therefore, the PCP related changes with the proposed amendment have been previously implemented. The proposed amendment would (1) incorporate programmatic controls in the Administrative Controls section of the TS that satisfy the requirements of 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a and Appendix l to 10 CFR Part 50, (2) relocate the existing procedural details in current specifications involving radioactive effluent monitoring instrumentation, the control of liquid and gaseous effluents, equipment requirements for liquid and gaseous effluents, radiological environmental monitoring, and radiological reporting details from the TS to the ODCM, (3) simplify the associated reporting requirements, (4) simplify the 9808100032 980731 PDR ADOCK 05000293 P

PDR A

2 administrative controls for changes to the ODCM, (5) add record retention requirements for changes to the ODCM, and (6) update the definitions of the ODCM consistent with these changes.

The NRC staffs intent in recommending these changes to the TS and the relocation of procedural details of the current RETS to the ODCM is to fulfill the goal of the Commission Policy Statement for Technical Specification Improvements it is not the staffs intent to reduce the level of radiological effluent control. Rather, this amendment will provide programmatic controls for RETS consistent with regulatory requirements and allow relocation of the procedural details of current RETS to the ODCM. Therefore, future changes to these procedural details will be govemed by the controls for changes to the ODCM included in the Administrative Controls section of the TS. These procedural details are not required to be included in TS by 10 CFR 50.3Ga.

2.0 EVALUATION The evaluation is divided into 6 areas: 1. Definitions,2. Radioactive Effluents,3. Radioactive Material Sources,4. Major Design Features,5. Administrative Controls, and 6. Radiological Environmental Monitoring Program. The staff will determine whether the licensee has followed the guidance in GL 89-01.

2.1 RELOCATIONS-GENERAL Section 182A of the Atomic Energy Act (the Act) requires applicants for nuclear power plant operating licenses to include TS as part of the license. The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls, and states that the Commission may include such additional TS as it finds to be appropriate. However, the regulation does not specify the particular requirements to be included in a piant's TS.

Section 50.36 identifies four criteria to be used in determining whether particular safety furictions are required to be included in the TS, as follows: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor pressurc boundary; (2) a process variable, design feature, or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (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 the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. Existing TS requirements which fall within or satisfy any of the criteria in 10 CFR 50.36 must be retained in the TS, while those TS requirements which do l

not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.

l The staff has reviewed the RETS relocations associated with this proposed amendment and has concluded that:

(1) The RETS related relocations do not involve instrumentation used to detect or indicate in tL 3ontrol room, a significant abnormal degradation of the reactor coolant pressure b

adary,

{

I 1

\\

3 (2) The RETS related relocations do not involve a process variable, design feature, or operating restriction that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, (3) The RETS related relocations do not involve 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 the integrity of a fission product barrier, and (4) The RETS related relocations do not involve a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to L

public health and safety.

The RETS related relocations do not satisfy any of the four criteria or the intent of the criteria from 10 CFR 50.36, therefore,50.36 does not require the inclusion of the RETS in TS. Future changes to these procedural details will be govemed by the controls for changes to the ODCM included in the Administrative Controls section of the TS.10 CFR 50.36a does require various TS requirements to keep effluents from nuclear power plants as low as reasonably achievable.

The effluents are controlled administratively by TS 5.5.1 and 5.5.4. In particular, TS 5.5.4 was added to the TS to specifically conform with the requirements of 10CFR 50.36a. The staff has determined that relocation of the RETS is consistent with criteria in 10 CFR 50.36 and 36a, with the TS providing appropriate controls for future changes. Therefore, the proposed relocations are acceptable.

2.2.1 DEFINITIONS The Table of Contents will tie revised as necessary for the proposed changes. The staff has reviewed the Table of Contents and determined that the changes are consistent with the proposed TS changes and are editorialin nature. Therefore, these changes are acceptable.

l The Definition section has been reformatted to be consistent with NUREG-1433. Specifically, the alpha designations for the definitions are deleted, all the defined terms have been capitalized and l

are in alphabetical order, and footers have been revised. During this reformatting and renumbering process, no technical changes (either actual or interpretational) to the TS were I

made, unless they were identified and justified. The staff has reviewed the Definition section and determined that the changes made were administrative in nature. Therefore, these changes are acceptable.

The definition for the ODCM will be incorporated into Section 5.0, " Programs and Manuals",

i subsection 5.5.1 of the proposed PNPS TS. The requirements contained in the DEFINITION section are cacried forward, with minor editorial rewording to be consistent with NUREG-1433, f'

and result in no technical changes. The staff has reviewed this change and determined that it is i

consistent with NUREG-1433 and is administrative in nature. Therefore, this change is acceptable.

The definitions for Member (s) of the Public, Site Boundary, and Radwaste Treatment System will be relocated to the ODCM because the requirements corresponding to the specifications where these definitions are presently used. Although considered a less-restrictive change, the change from existing restrictions on plant operations is brought about by TS changes discussed I

elsewhere (changes to section 3/4.8) and omission of these definitions from the TS does not reduce existing restrictions on plant operation. The staff has reviewed the relocation of these l

1 u

4 e

4 definitions and concludes that these changes meet the intent of GL 89-01. Therefore, these changes are acceptable, The amendment proposes to delete..."(Definitions U and V apply)"...from the definition of Refueling Outage. The definition defines what constitutes a Refueling outage, not how often they occur. With respect to applying the maximum allowable extension of 25 percent of the specified surveillance interval allowed by Definitions U and V, there is no specified interval for a Refueling Outage. Definitions U and V contain sufficient guidance to ensure surveillance and tests are performed within their specified intervals and this staiement has no value added to this definition.

The proposed TS change is editorial in nature. Therefore, this change is acceptable.

The following is a summary of the changes to or relocations of the TS Definitions section. The staff has reviewed these changes as discussed above and determined that they are acceptable.

Current PNPS Technical Spectricatione Proposed Changes 1.0 DEFNTIONS 1.02 Oneite Dose Calculation Manuel (ODCM)

TS 5.6.1 ONeMe Does Calculation Manuel (ODCM) 1.0.85 Member (s)of the Publict ODCM 2.1 Member (s) of the Publici 1.0.CC Site Boundary ODCM 24 She Boundary i

1.0.00 Reakeste Treatment System ODCM 2.3 P=w= Treatment System 1.0.DO.1 Geesous Redweste Treatment System ODCM 2.3.e Geneous Redneste Treatment System 1.0.DD.2 Uguid Redweste Treatment System ODCM 2.3.b Uguid Redweste Treatment System 2.3 RAD EFFLUENTS The proposed changes affect those sections of TS dealing with the control of radiological effluents, including those sections dealing with gaseous effluents, liquid effluents, and environmental monitoring. Associated TS addressing definitions, administrative controls and reporting are also affected. The purpose of these specifications is to ensure compliance with regulatory requirements goveming radioactive effluents, including 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a, and Appendix l to 10 CFR 50. In addition, the proposed changes will involve renumbering, and rewording of the TS. These changes, since they do not involve technical changes to the TS are administrative. All editorial rewording (either adding or deleting) and renumbering is made to restructure the section accounting for the requirements relocated in accordance with GL 89-01. During the editorial rewording and renumbering of the TS, no technical changes (either actual or interpretational) to the TS were made unless they wero l

identified and justified.

l In accordance with the guidance of GL 89-01, the proposed changes add new programmatic requirements goveming radioactive effluents and radiological environmental monitoring to the i

Administrative Controls section of the TS. Existing TS containing procedural details on radioactive effluents, environmental monitoring, definitions and associated reporting requirements are being deleted. The staff has confirmed that the deleted procedural details have been incorporated into the Offsite Dose Calculation Manual (ODCM). All sections in TS 3/4.8

• RADIOACTIVE EFFLUENTS," were relocated to the ODCM except for the following:

3.8.F.1. " Hydrogen Concentration in the Augmented Offgas System"is relocated to the final safety analysis report (FSAR).

5 4.8.F.2 " Hydrogen Concentration in the Augmented Offgas System"is relocated to the FSAR.

3/4.8.G " Main Condenser"is revised to be consistent with NUREG-1433, section 3.7.6 " Main Condenser Offgas", as supported by PNPS specific design and licensing bases, and 3/4.8.H

" Mechanical Vacuum Pump" is revised to be consistent with NUREG-1433 and Supplemental TS drafted by the BWROG Technical Specification Committee - A.

T3.8-2 and T4.8-4 The " Augmented Offgas Treatment System Monitor" are relocated to the FSAR.

2.3.1 MAIN CONDENSER TS 3.8.G, " Main Condenser," has been renumbered to 3.8.1 and revised to be consistent with NUREG-1433, Section 3.7.6, " Main Condenser Offgas." Below is a discussion of the changes to TS 3.8.G:

.To reflect plant specific design the following deviations were taken from NUREG-1433. The limit of 500,000 uCl/sec as calculated in accordance with NUREG-0133 did not take credit for l

treatment, adsorption or delay. The proposed change deletes "(referenced to 30 minute l

holdup)". Although the limit for gross noble gas activity is not affected by this deletion, not taking l.

credit for a 30-minute delay is considered a more restrictive change. The staff has reviewed this deviation and determined the limit as calculated not taking credit for a 30 minute delay is consistent with the current TS. Therefore, the TS change is acceptable.

This proposed change revises existing Specification 4.8.G.b with a requirement to verify the gross gamma activity of noble gases within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after a a 50% increase in the nominal steady state fission gas release. Current requirements do not stipulate a time limit. The addition of a time limit is considered a more restrictive change. Current requirements also relate the increase to that of the previous day whereas the new requirements do not. The requirement was also editorially changed to be consistent with NUREG-1433 and allowances were added for factoring out increases due to hydrogen injection, The staff has reviewed this deviation and determined that the change meets the intent of NUREG-1433 and is more restrictive than the current TS as no time limit was previously stipulated. Therefore, the TS change is acceptable.

l.

TS 4.8.G.1 has been renumbered to 3.8.2 and modified to be consistent with NUREG-1433. In addition, details on how to determine that the limit on noble gas activity is met and where to take the sample have been relocated to the BASES. Any changes to these details will be controlled in accordance with Specification 5.5.6, "TS Bases Control Program". Also, this change proposes to revise the Specification and Surveillance Requirements to allow taking the sample used for isotopic analysis from either retreatment monitor station. PNPS has the capability of obtaining a sample either upstream of the offgas recombiner or down stream of the recombiner. The current sampling location (upstream of the recombiner) is subject to hydrogen ignition as discussed in General Electric Co. Service information Letter (SIL) No.150 and presents a personnel safety issue. Use of the sample location downstream of the recombiners as the

}

normal sample point will alleviate this personnel safety issue without affecting the objective of obtaining a sample prior to treatment, adsorption, or delay. This is considered a less restrictive change only because station personnel will now have a choice of where to sample. The staff has reviewed these changes and determined that they are consistent with NUREG-1433. Therefore, these TS changes are acceptable.

This prop,osed change replaces the existing requirements for actions in TS 3.8.G.A, to be taken when the gross gamma gas activity rate of the noble gases cannot be restored to allowable limits

e 6

1 within the required Completion Time. The proposed actions are more restrictive than current requirements; therefore, this is a more restrictive change. In addition, this change proposes to

- revise the specification to specify only measurement of gross gamma activity of noble gases instead of beta and/or gamma activity. Although this change would appear more restrictive, it is being proposed as less restrictive due to changes in technology which have allowed separation i

of close energy gamma emitters. Evaluations based solely on gamma activity are now faster and j

more represen:ative of the whole body dose that would be received by an individual at the site boundary should a release occur. The staff has reviewed these changes and determined that they are consistent with NUREG-1433. Therefore, these changes are acceptable.

The following is a summary of changes to or relocation of the T.S. Section 3.8.G.

l 3/4.8.G Mein Condenser T83/4.8.1 Mein Condeneer 3.84.1 Gross redsometivay noble genes release rate limit TS 3.8.1.1 Gross rodeosotivey noble genes rolesses limit 3.8.0.1 restore groes radioactivity retenee role to within the TS 3.8.1 A restore groes radiomativity reisease to within the limit ACTION limit TS 3.8.1.5 Requiremer s not met a

4.8.0.1.e Determine reisees role of nobel genes (31 days)

TS 4.8.1.1 Determme reisees rate of nobles genes (31 days) l 4.8.0.1.b 80% overese daily groes radioactively reisese rate 80% overage deHy proes.

' "; reisene rate incrosse increene

(,

2.3.2 MECHANICAL PUMP l

Although the existing specification implies the isolation signal is derived from the Main Steam Line Radiation Monitoring System, the proposed actions and surveillance requirements will more appropriately address instrumentation operability. This is a plant-specific system with no equivalent system in NUREG-1433. The addition of new requirements for the mechanical t

vacuum pump is therefore, a more restrictive change. The format change and the additional L

restrictions resulting from this change make improvements in the functionality of the TS. The staff considers this TS change beneficial from both a public safety and operational perspective.

1 i

Therefore, these TS changes are acceptable.

The following is a summary of the changes to or relocations of the T.S. Section 3.8.H.

3/4.8.H Medical Vacuum Pump TS 3/4.8.2 Medical Vm Pump i

3.8.H.1 Capability to isoiste & escure on high radioactivity T3 3.8.2A inoperable Channelu ei nel 9

(

3.8.H.2 limits of Specir, cation 3.8.H.1 are not met TS 3.8.2.5 M ' _ _ notmet TS 4A.2.1 Channel Check TS 4.8.2.2 Calibrees trip units TS 4.8.2.3 Channel Calibration 4.8.H.1 verWy automatic escuring & inciation TS 4.8.2.4 vertly automesic escunne & inciaison (LSFT) 2.3.3 HYDROGEN CONCENTRATION This change proposes to relocate the requirements (3/4.8.F.1,1s, and 2; Table 3.8.2 note 2, Table 3.8-2.4 and Table 4.8.4 Instrument # 4; and the notes for the Tables) for the main l

7 condenser offgas treatment system explosive gas monitoring system to licensee controlled documents (i.e., FSAR). This instrumentation is used to detect hydrogen in the main condenser offgas treatment system to ensure that hydrogen concentrations are maintained below the flammability limit. The offgas system is designed to confine detonat!ons without affecting safety-related equipment. The concentration of hydrogen in the offgas stream does not constitute a threat to the public health and safety and is not an initial assumption of any DBA or transient analysis.

Section 50.36 identifies four criteria to be used in determining whether a particular safety function is required to be included in the TS, as follows: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor pressure boundary; (2) a process variable, design feature, or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions er actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. Existing TS requirements which fall within or satisfy any of the criteria in 10 CFR 50.36 must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.

The staff has reviewed the relocation of the explosive gas monitoring system to the FSAR and concluded that: (1) The explosive gas monitoring system does not involve instrumentation used to detect or indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary, (2) The explosive gas monitoring system does not involve a process variable, design feature, or operating restriction that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, (3) The explosive gas monitoring system does not involve 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 the integrity of a fission product barrier, and (4) The explosive gas monitoring system does not involve a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

The explosive gas monitoring system TS do not satisfy any of the four criteria of 10 CFR 50.36, therefore,50.36 does not require the inclusion of the explosive gas monitoring system in the TS.

Further, the facility and procedures described in the FSAR ( to which the TS and bases would be relocated) can only be revised under the provisions of 10 CFR 50.59, which ensures an auditable and appropriate control of the relocated requirements and future changes to these provisioas.

The staff has determined that relocation of the explosive gas monitoring system TS is consistent with criteria in 10 CFR 50.36, and with the 10 CFR 50.59 process providing appropriate controls j

for future changes. Therefore, these TS changes to relocate the explosive gas monitoring tystem from the TS to the FSAR are acceptable.

The following is a summary of the changes to or relocations of the T.S. Section 3/4.8 l

l Current PNPS Technical SpecTications Proposed Changes

$4.8 RADIOACTIVE EFFLUENTS

$4.8.A Uguid Emuents Concentrat,on oDCM W4.2.1 Uguid Emuents Conoontration 4

1 l

I

e s

8 3/4.8 A1 concentration of radioactive meterial reisesed at any OOCM 3.2.1 concentrebon of redmeetive meterial reiemoed at any time time 18A1 Action

" Limas escoeded, restore concentration within Emns" 00CM 3.2.1 Action "Limitse, restore concentrehon within henits" 8A1 determine radioactMty content of sech batch OOCM 4.2.14 determine rodeactivity content of each batch 4.8.A.2 Use pre-release analyses resulta lo assure within ODCM 4.2.1.b Une pre-reisene analyses resuns to assure within limits bmas 3/4.8.8 Radioactive Liquid Emuent Instrumerdation OOCM 3/4.1.1 Radioactive Liquid Emuent instrumentation 3.8.8.1 instrumentation channels shall be operabis OOCM 3.1.1 Instrumentation channels shall be operable 3.8.8.1.a Instrumentation channel alarm / trip setpoint less OOCM 3.1.1.s instrumentshon channel alarminp point lose conservative conservative 3.8.8.1.b one or more instrumentation channels inoperable OOCM 3.1.1.b one or more instrumentation channels Weble 4.8.8.1 determine setpoints for monitoring instrumentation OOCM 4.1.14 determine setpoints for monitoring instrumentation 4.8.B 2 instrumentation channel shall be demonstrated ODCM 4.1.1.b instrumentation channel shall be demonstrated operable operable 3/4 8 C Liquid Radweste Treatment OOCM 3/4.2.3 Liquid Radweste Treatment 3.8.C.1 Liquid redweste treatment system maintained & used OOCM 3.3.2 Liquid redweste treatment system maintained & used 3.8.C.1 Acton rooioactive liquid weste being discharged without ODCM 3.2.3 Action radioactive lequid weste being discharged without treatment treatmord 4.8.C.1 Calculate dosee due to liquid releases ODCM 42.3.s Calculate dones due to hquid relemmes 4.8,C.2 redweste treatment system schematic OOCM 4.2.3.b redweste treatment eyetem schematic 3/4.8.D Gaseous Emuents Dose Rate ODCM 3/43.1 Gaseous Emuents Does Rate l

3 8.D 1 Instantaneous dose rate reiease hmits ODCM 3.3.1 instantaneous dose rate reisene limas 3.8.D.1.a restore the release rate to within the limit (s).

OOCM 3.3.1.s restore the relenne rate to within the limit (s).

4 8.D.1 Dose rate due to noble gases determined to within ODCM 4.3.1.a Dose rate due to noble paese determined to be within hmits hmus 4 8 D.2 Obtain representative samples and perform analyses ODCM 4.3.1.b Otdain representative samples and perform analyses 3id.8 E Radioactive Gessous Emuent ODCM 3/4.1.2 Radmactree Gaseous Emuent l

3.8.E,1 Instrumentation channels shall be operable OOCM 3.1.2 Instrumentation channels shall be operable 3.8.E.1.s channel alarm / trip setpoint less conservative ODCM 3.1.2.s channel alarm / trip setpoint lees conservative i

3.8.E.1.b one or more instrumentation channels inoperable ODCM 3.1.2.b one or more instrumentation channels inoperable 4.8 E.1 determine setpoints 00CM 4.1.2.a determene eetpoints l

1

\\

4.8.E.2 Demonstrate rnonitoring instrumentaten channels 0004 4.1.2.b Demonstrate monnoring instrumentation channels operable operable 3,4.4.F Geneous Emuent Treatment OOCM 3/4.3.4 ha ENiuent Treatment 38F op es system in serwoo prior to 50% reactor power ODCM 3.34 oNoas syssem in service prior to 50% ruector pour g

3 8 F.a Action "geneous emuents being discharged without OOCM 3.3 4 Action "geoeous sNiuerde being doncharged withoai treatment?

treatment?

3.8 F.1 concentration limit on hydrogen in augmerded onges FSAR 9.44.1.7 Gaemous Radwease System (Requirements for Plant Operations) 3 87.1.a concentration a hmit on hydrogen 6n augmented oNgas FSAR 94.4.1.7 Gassous Radneste System (Requirements for Plant Operations)

9 4.8.F.1 Vertried ?q.

_' anges annunoistor operebiiny ODCM 4.3.4.e VertGod ?:_...a onges annunoistor operability 4.8 F.2 Desertrune hy trogen concentretic n in suomented FSAR 9.4.4.1.7 Geneous Reenste System (Requirements for Plant onges Operehens)

Figure 4.8 2

1. 1===a = ENiuent Treatment achemshc CDCM 4.3.4.b Geneous Estuent Treatment avstem echematic 2.4 RADIOACTIVE MATERIAL SOURCES This change proposes that the requirements of section 4.0,

• MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES", be relocated to the FSAR and implementing procedures. The bases for relocating these requirements are that they duplicate other regulatory requirements contained in 10 CFR 20 and 10 CFR 30 and changes to the licensee controlled documents to which they are relocated are adequately controlled by other regulatory requirements. In addition, these requirements do not fit in any of the categories specified in 10 CFR 50.36 for inclusion in TS.

The Miscellaneous Radioactive Materials Sources TS does not satisfy any of the four criteria from 10 CFR 50.36, therefore,50.36 does not require the inclusion of the Miscellaneous Radioactive Materials Sources section in the TS. Further, the facility and procedures described in the FSAR ( to which the TS and bases would be relocated) can only be revised under the provisions of 10 CFR 50.59, which ensures an auditable and appropriate control of the relocated requirements and future changes to these provisions. The staff has determined that relocation of the Miscellaneous Radioactive Materials Sources TS is consistent with criteria in 10 CFR 50.36 and with the 10 CFR 50.59 process providing appropriate controls for future changes. In accordance with these requirements, the FSAR and implementing procedures will contain adequate detail with respect to sealed source contamination, surveillance requirements, reports, and records retention. Changes to the FSAR and implementing procedures will be adequately controlled by the cited regulations and by the provisions of 10 CFR 50.59. Therefore, these TS changes to relocate the Miscellaneous Radioactive Materials Sources TS to the FSAR are acceptable.

The following is a summary of the changes to or relocations of the T.S. Section 4.0, 4.0 MISCELLANEOUS RADIOACTIVE FSAR 12.4.1 "Melonele Safety Program Use, Handling, and Storage or MATERnALS SOURCES Woensed Radioactrue Sources 4.1 Seeled Source Contamination FSAR 4.2 Surveillance Requiremones FSAR 4.3 Reports FSAR 4.3 Records Retention FSAR 2.5 MAJOR DESIGN FEATURES I

Section 5.0 has been renumbered to 4.0. All proposed reformatting and renumbering is intended to result in TS that are more readable and understandable by plant operators as well as other users. During the reformatting and renumbering of the TS, no technical changes (either actual or interpretational) to the TS were made unless they were identified and justified. Editorial rewording (either adding or deleting) is proposed to be consistent with NUREG-1433 to the extent possible, based on the PNPS specific licensing basis. These proposed changes resulted in no technical changes (either actual or interpretational) to the TS. The staff has reviewed these changes and agrees that they are administrative in nature. Therefore, the proposed TS changes are acceptable. Below is a discussion of changes, deviations, and relocation of the current TS to provide a format consistent with NUREG-1433.

t

10 The BASES for FUEL STORAGE has been deleted. It consists of BASES for only Section 5.5.C.

This section addressed the Spent Fuel Storage which stipulates maximum K-infinity and U-235 enrichment which will result in a K, s 0.95. FSAR Section 10.3.5 discusses spent fuel pool design for maintaining K, for both normal and abnormal conditions. Changes to these requirements / assumptions will require a 10 CFR 50.59 evaluation. The BASES, by definition in 10 CFR 50.36, are not a part of the TS. This change does not alter any design feature. The staff agrees with the licensee that the deletion of the BASES section is consistent with NUREG-1433 and the BASES are not part of the TS. Therefore, this change is acceptable.

Sections 5.3,5.4, and 5.6 have been relocated to the FSAR. Design features to be included in the TS are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in paragraphs 10 CFR 50.36(c)(1), (2), or (3). Detail relating to the reactor vessel and containment exists in LCOs to ensure any changes which may affect safety would require prior NRC review and approval. In addition, the design parameters of the reactor vessel and containment remain detailed in FSAR Section 4.2 and Appendix M for the reactor vessel; FSAR Section 5.2 and Appendix L for the primary containment; and FSAR Sections 5.3 and 12.2 for secondary containment. Any changes to these design parameters or requirements must conform to the requirements of 10 CFR 50.59. These features will continue to be described in the applicable sections of the FSAR and any changes will require review in accordance with 10 CFR 50.59. The details being relocated from TS sections 5.3 and 5.4 do not describe any design features and only reference the FSAR for the appropriate descriptions and design criteria. Therefore, TS sections 5.3 and 5.4 do not meet the criteria of 10 CFR 50.36(c)(4) for including as a design feature as none exist in these sections.

The seismic design requirements described in TS section 5.6 remain detailed in FSAR Sections 1.6.1.1.8,2.5.3.4,12.2.3.1.5, and Appendix C. Any changes to these design parameters or requirements must conform to the requirements of 10 CFR 50.59. Therefore, the seismic design features, are controlled in accordance with 10 CFR 50.59. NUREG-1433 describes those parameters which need to be in TS. The NUREG 1433 did not include the description of the seismic ground accelerations and therefore, these carameters do not meet the criteria of 10 CFR 50.36(c)(4) for including as a design feature. The staff has reviewed these changes and agrees with the licensee that these sections of the TS are not specifically required under 10 CFR 50.36(c)(4). Therefore, these TS changes to relocate sections 5.3,5.4, and 5.6 of the TS to the l

FSAR are acceptable, l

Below is a discussion of changes, deviations, reformatting, renumbering, and relocation of the l

current TS to provide a format consistent with NUREG-1433.

I The staff has reviewed the following proposed changes which delete the brackets from the NUREG-1433 standard TS and incorporate the PNPS plant specific words from the current TS.

4.1. Location based on latitude and longitude was replaced with wording taken from the FSAR to provide a more general description of location.

4.3.1.1.s This proposed change deletes the brackets and incorporates the PNPS plant specific words from the current TS as changed by Amendment 155. Additional wording for core geometry and average enrichment, as described in Section 10.3.5 of the FSAR, was added for clarification.

E________

a 11 4.3.1.1.b This proposed change deletes the brackets and inserts the PNPS plant-specific FSAR reference.

4.3.1.2.b This proposed change deletes the brackets and inserts the PNPS plant-specific FSAR reference. This section has been renumbered to 4.3.1.2.a.

I 4.3.1.2.c This proposed change deletes the brackets and incorporates the PNPS plant-specific value for K, of the new fuel storage vault for dry conditions from the current TS. This section has been renumbered to 4.3.1.2.b.

4.3.1.2.d This proposed change deletes the brackets and inserts the PNPS plant-specific value for the center-to-center distance between fuel assemblies in the new fuel storage vault, as described in Section 10.2.4 of the FSAR. This section has been renumbered to 4.3.1.2.c.

4.3.2 This proposed change deletes the brackets and inserts the PNPS plant-specific value for elevation, as calculated from drawing C-178, of the siphon-breakers on the fuel pool cooling retum lines. The purpose of these siphon breakers is to prevent inadvertent drain down of the spent fuel pool.

l 4.3.3 This proposed change deletes the brackets and inserts the PNPS plant-specific value for fuel assembly storage capacity from the current TS.

t l

The staff has reviewed the above changes and agrees that they are plant-specific parameters or l

words from the current TS and that the changes are administrative in nature. Therefore, the i

proposed changes to the TS are acceptable.

The following is a discussion of deviations between the proposed TS and NUREG-1433.

4.2.1 and 4.2.2 This proposed change replaces SpedCcations 4.2.1 and 4.2.2 with PNPS l

plant specific wording from the current TS. Amendment 133 to the PNPS TS removed all cycle-l specific requirements and placed them in the Core Operating Limits Report (COLR) in l

accordance with the guidance provided by GL 88-16.

4.3.1.1.c This proposed change deletes Speci'ication 4.3.1.1.c. The PNPS spent fuel storage rack design does not rely on canter-to-center spacing for maintaining subcriticality.

l 4.3.1.2.s This proposed change deletes Specification 4.3.1.2.a. The PNPS current design and licensing BASES do not impose K infinity limits for the new fuel storage vault.

4.3.1.2.b This proposed change replaces "if moderated with aqueous foam" with "when dry".

PNPS does not have the capability to flood the new fuel storage vault with aqueous foam.

L 4.3.4 (New) This proposed change adds Specification 4.3.4, " Heavy Loads", from the current PNPS TS. These requirements were added to the PNPS licensing BASES by the safety evaluation written in support of Amendment 33.

The staff has reviewed these deviations from NUREG-1433 and agrees with the licensee that they represent plant-specific design considerations previously approved by the staff or in the current TS, and have been maintained in the proposed TS. Therefore, the proposed changes are acceptable.

\\

{

12 The following is a summary of the changes to or relocations of the T.S. Section 5.0.

Current PNPS Technical Specifications

_' Changes 5.0 MMOR DES 4GN FEATURES TS 4.0 DESIGN FEATURES 5.1 See Features TS at She Location 5.2 Reactor Core TS 4.2 Reactor C ore 5.3 Reeciar Vessel FSAR 4 2 & App. M Remotor Vesent 5.4 Containtnent 5.4 A primary containment FSAR "5.2,12.2.2.8" prirnery :. _.... :.:

548 Secondary containment FSAR 5.3 Secondary Containment 5.4.C penetrations of primary containment FSAR 5.2.3.4 penetrations of primary conseinment 5.5 Fuel Storage TS 4.3 Fuel Store 0e 5.5 A new fuel storsee facility Koff TS 4.3.1.2.a & b new fuel storaes 8% Koff 5.5.8 spent fuel pool Keff TS 4.3.1.1.b spent fuel pool Koff 5.5 C fuel assembly max K. infinity TS 4.3.1.1.a fuel -- 61y max K.bfinity 5.5.D number of fuel ensemblies stored TS 4.3.3 number of fuel r T.biiss stored 5.5.E Loads in excess TS 4.3.4.a Loads in ----

f.5.F Fuel stored within are TS 4J.4.b Fuel stored within arc 6.6 Seismic Design FSAR

• 1.6.1.1.8.2.5.3.4.12.2.3.1.5 and A.ix C.*

2.6 ADMINISTRATIVE CONTROLS Section 6.0 has been renumbered to 5.0. All proposed reformatting and renumbering is intended to result in TS that are more readable and understandable by plant operators as well as other users. During the reformatting and renumbering of the TS, no technical changes (either actual or interpretational) to the TS were made unless they were identified and justified. Editorial rewording (either adding or deleting) is proposed to be consistent with NUREG-1433 to the extent possible, based on PNPS specific licensing basis. These proposed changes will result in no technical changes (either actual or interpretational) to the TS. The staff has reviewed the proposed TS changes and determined that they meet the intent of NUREG-1433 and are acceptable. Discussions of plant-specific changes and deviations are discussed below.

Below is a discussion of the editorial changes proposed to Section 5.0.

l Table 6.2.1 This proposed change transfers current requirements for non-licensed operator l

presence on site, as specified in existing Table 6.2.1, to proposed T.S. 5.2.2.a. This editorial reformatting and rewording resulted in no technical changes (either actual or interpretational) to the TS.

I L

i 13 6.9.A.3 This change proposes to modify the Occupational Exposure Tabulatien reporting requirements of exist 6g Specification 6.g.A.3 to reflect the revised 10 CFR 20 requirements and incorporate editorial rewording (either adding or deleting) to be consistent with NUREG-1433, Rev.1. Since the revised 10 CFR 20 requirements are currently applicable to PNPS, the change is considered to be administrative in nature.

6.9.A.4 This change proposes to modify the COLR of existing Specification 6.9 A.4 to be consistent with NUREG-1433, Rev.1. The editorial rewording (either adding or deleting) resulted in no technical changes (either actual or interpretational) to the TS. Since the specifications listed under new requirement 5.6.5.a currently specify their operating limits to be "as specified in the Core Operating Limits Repoit", the change is consbered to be administrative in nature.

6.9.C.1.b This proposed change includes the sub nitial requirements for changes to the ODCM in the proposed requirements for the new section 5.5.1. This change is administrative in that the requirements to submit changes are still contained in TS.

The staff has reviewed the above propond changes and agrees that they are editorial or administrative in nature. Therefore, the proposed TS changes are acceptable.

Below is a discussion of those changes which provide new restrictions or limitations or more l

restrictive requirements:

5.1.1 This change proposes to add a requirement to the TS for the Station Director, or designee, to approve prior to implementation, each proposed test, experiment, or modification to systems l

or equipment that affect nuclear safety. This change ensures the Station Director, or designee, is aware of all changes with the potential to affect nuclear safety. This change adds additional-requirements to TS which constitutes a more restrictive change. This change is consistent with NUREG-1433.

5.1.2 This proposed change will add requirements to specify that the Nuclear Operations Supervisor (NOS) has responsibility for control room command functions and to list the qualifications of the individual to whom this responsibility may be designated in the absence of the NOS. The proposed change will require the designated individual to have an active Senior Reactor Operator (SRO) license in an operational mode other than cold shutdown or refueling, or i

an active Reactor Operator (RO) license in cold shutdown or refueling. The addition of specific requirements to the TS constitutes a more restrictive change. This change is consistent with l

NUREG-1433.

5.2.2.g This proposed change will add requirements to control evertime for the plant staff who perform safety-related functions in accordance with GL 82-12. Although BECo has established i

policies and procedures, in response to NUREG-0737, item 1.A.1.3.(1), to control safety-related overtime, the addition of these requirements to the TS is considered a more restrictive change.

This change is consistent with NUREG-1433.

5.2.2.i This proposed change will list specific duties of the Shift Control Room Engineer (SCRE) in the TS. The SCRE is the PNPS equivalent of the Shift Technical Advisor. In the current TS, i -

no specific duties are listed for the SCRE. The proposed TS will require the SCRE to meet the requirements of the NRC Policy Statement on Engineering Expertise on Shift and to provide advisory technical support to the Shift Supervisorin the areas of engineering and accident assessment. This change is considered to be a more restrictive change.

14 5.4.1.a,b,c,d, and e This change proposes additional requirements for procedures to be established, implemented, and maintained as follows:

Emergency Operating Procedures (EOPs)- Although the EOPs are identified as a necessary procedure type in Regulatory Guide 1.33, the additional procedures and changes made by Pilgrim in response to the guidance provided in NUREG-0737 and Supplement 1 are not currently included in the TS. Th;s change ensures these commitments, as made in response to GL 82-33, are maintained and that the guidance and commitments are appropriately considered for any changes to these procedures.

Quality assurance for the control of e* fluent and environmental monitoring -

These procedures are not listed in Regulatory Guide 1.33 and are added to

- ensure that effluent and environmental monitoring functions are property controlled.

All programs identified in Specification 5.5 ' Programs and Manuals'- This added requirement will ensure that procedures are implemented and maintained for each of the programs in TS Section 5.5.

The addition of these procedural requirements is considered a more restrictive change.

5.5 Th!s change proposes to add a new section 5.5, ' Programs and Manuals", to the TS as follows:

5.5.1 Offsite Dose Calculation Manual (ODCM)- This program provides controls associated with offsite doses resulting from radioactive gaseous and liquid effluents and the conduct of the radiological environmental monitoring program. Although Pilgrim has implemented an ODCM, this proposed change adds new programmatic requirements to the TS which constitutes a more restrictive change.

5.5.2 Primary Coolant Sources Outside Containment - This program provides controls to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. Although PNPS, in response to NUREG-0578 (2.1.6.A), already has controls in place to satisfy this requirement, adding this requirement to the TS constitutes a more restrictive change.

5.5.3 Post Accident Sampling - This program provides controls that ensure the capability to obtain and analyze reactor coolant, radioactive gases, and particulate in plant gaseous effluents and containment atmosphere samples under accident conditions. Although PNPS, in response to NUREG-0737, item II.B.3, already has procedures, training, and maintenance practices in place to satisfy this requirement, adding this requirement to the TS constitutes a more restrictive change.

5.5.4 Radioactive Effluents Control Program - This program provides controls in accordance with 10 CFR 50.36a, for radioactive effluents and for maintaining doses to members of the public from radioactive effluents as low as reasonably achievable. The addition of new requirements is considered a more restrictive change.

5.5.5 Component Cyclic or Transient Limit - This program provides contmis to track the cyclic and transient occurrences to ensure that components are maintained within the design limits as

~~ =

' '~ ~~~

15 specified in the FSAR. T his change adds new requirements to the TS which constitutes a more restrictive change.

5.5.6 TS Bases Control Program - This program is provided to specifically delineate the appropriate methods and reviews necessary for a change to the BASES of TS. This change dds new requirements to the TS which constitutes a more restrictive change.

5.6.3 This change proposes to add specific details for the content of the Radiological Emuent Release Report that are in addition to the reporting requirements of 10 CFR 50.36a(a)(2) and 10 CFR 50, Appendix 1,Section IV.B.1. The addition of specific requirements to the TS constitutes a more restrictive change.

The staff has reviewed the above changes and agrees with the licensee that they are new or more restrictive requirements than currently exist in the TS. The above TS changes provide a more restrictive 'S that willimprove plant operation and enhance safet by additional reporting j

requirements, improved procedural requirements, improved Bases maintenance program, etc.

Therefore, the proposed TS changes are acceptable.

Below is a discussion of changes which relocate various sections of the TS:

Table 6.2.1 This proposed change removes Table 6.2.1 from the TS.10 CFR 50.54(k), (1), and (m) provide the requirements for the shift complement regarding licensed operators. The regulations describe the minimum shift composition for operating modes, as well as cold shutdown and refueling. Additionally, proposed Specifications 5.1.2 and 5.2.2.c specify the conditions when a licensed operator is required to be in the control room. Non-licensed operator requirements will be maintained in Specification 5.2.2.a. Removing the Table from the TS will not jeopardize plant safety and is not necessary in order to ensure safe operation of the facility.

6.2.B.5 This change proposes to remove the requirement for an SRO to be present during fuel handling and to supervise all core alterations ' rom TS. Duplication of the regulation provided in 10 CFR 50.54(m)(2)(iv) is not necessary to ensure safe operation of the facility.

6.4 The details contained in TS 6.4 on training and replacement training for the unit staff are being relocated to the FSAR. These training provisions are adequately addressed by other TS 5.0 provisions and by regulations. TS Section 5.3, " Unit Staff Qualifications," provides l

requirements to ensure adequate, competent staff in accordance with ANSI N18.1-1971 and Regulatory Guide 1.8, September 1975. TS 5.2 details the unit staff requirements. TS 5.2.2.a, 5.2.2.b, and 10 CFR 50.54 state minimum shift crew requirements. Training and requalification for licensed positions are contained in 10 CFR 50.55. Relocating the training requirements to the FSAR ensures that training programs are property maintained in accordance with PNPS commitments and applicable regulations. Any changes to trairiing requirements will be adequately controlled in accordance with the provisions of 10 CFR 50.59 and 10 CFR 50.55.

The staff has reviewed the relocation of the training requirements TS section to the FSAR and l

has concluded that: (1) training requirements do not involve instrumentation used to detect or indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary, (2) training requirements do not involve a process variable, design feature, or 4

operating restriction that either assumes the failure of or presents a challenge to the integrity of a i

fission product barrier, (3) training requirements do not involve a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a i

e

16 design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier, and (4) training requirements do not involve a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Since the training requirements TS does not satisfy any of the four criteria from 10 CFR 50.36, it may be proposed for removal from the TS. Further, the facility and procedures described in the FSAR ( to which the TS and bases would be relocated) can only be revised under the provisions of 10 CFR 50.59, which ensures an auditable and appropriate control of the relocated requirements and future changes to these provisions. The staff has determined that relocation of the Training requirements TS is consistent with the intent of the criteria in 10 CFR 50.36, with the 10 CFR 50.59 process providing appropriate controls for future changes. In accordance with these requirements, the FSAR and implementing procedures will contain adequate detail with respect to training requirements, surveillance requirements, reports, and records retention.

Changes to the FSAR and implementing procedures will be adequately controlled by the cited regulations and by the provisions of 10 CFR 50.59. Therefore, these TS changes to relocate the training requirements TS to the FSAR are acceptable.

6.5 This change proposes that the review and audit functions (Section 6.5) be relocated from tia TS on the basis that they duplicate other regulatory requirements. Changes to the licensee controlled documents to which they are relocated are adequately controlled by other regulatory requirements. The review and audit functions performed by the Operations Review Committee (ORC) and the Nuclear Safety Review and Audit Committee (NSRAC) are required by ANSI N18.7. Additional audit requirements are contained in 10 CFR 50.54(p); 10 CFR 50.54(t); 10 CFR Part 50, Appendix B, Criterion XVill; 10 CFR Part 73, and ANSI N45.2-10. These review and audit activities are addressed in adequate detail in the Boston Edison Quality Assurance Manual (BEQAM), the FSAR, and the implementing procedures, and do not need to be repeated in the TS. Any changes to these review processes as they are described in the BEQAM, FSAR, or delineated in plant implementing procedures will be adequately controlled by the cited regulations and by the provisions of 10 CFR 50.54(a) and 10 CFR 50.59.

6.6 This change proposes that the requirements for Reportable Event Action, to notify the Commission of all reportable events, be relocated from TS. These requirements are duplicates of 10 CFR 50.72 and 10 CFR 50.73. In addition, this change proposes to relocate the intemal review requirements for Reportable Events. These requirements are adequately addressed in current plant procedures or other licensee controlled documents.

6.8b,c, and d This change proposes to relocate the details of procedure reviews and approvals, including temporary changes contained in TS 6.8.B and 6.8.C, to the FSAR and implementing procedures. This proposalis based on the existence of requirements which are duplicative of 10 CFR 50.36(c)(5)in these areas and which assure opers, tion of the facility in a safe manner. The requirement for procedures is mandated by 10 CFR 50, Appendix B, Criterion ll (second sentence) and ANSI N18.7-1972, Criterion V (an NRC staff-endorsed document used in the development of the QA Program).

1 ANSI N18.7-1972, Section 5.2.2 discusses procedure adherence. This section clearly states that procedures shall be followed and the requirements for use of procedures shall be prescribed in writing. ANSI N18.7-1972 also discusses temporary changes to procedures and requires review and approval of procedures to be defined.

a

17 ANSI N18.7-1972, Section 5.2.15 describes the review, approval, and control of procedures.

The section describes the requirements for the licensee's Quality Assurance Program to provide measures to control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities affecting quality. The section further states that each procedure shall be reviewed and approved prior to initial use. The reviews required are also described. ANSI N45.2-1971, Section 6 also requires the Quality Assurance program to describe procedure requirements.

BECo can continue to implement the requirements of 10 CFR 50, Appenriix B, regarding procedures without duplicating the necessity of procedure requirements in the TS. Safe operation of the plant will continue to be maintained; therefore, the requirements for procedures and their control need not be addressed in the TS. Duplication of the provisions related to procedures is not necessary to ensure safe operation of the facility.

{

6.9.A.1 The requirements in TS 6.9.A to submit a start-up report will be relocated to FSAR l

Section 13.5 "REACl OR STARTUP AND POWER TEST PROGRAM". The report is a summary of plant startup and power escalation testing following receipt of the Operating License, an increase in licensed power level, the installation of nuclear fuel with a different design or manufacturer than the current fuel, and modifications that may have significantly altered the nuclear, thermal or hydraulic performance of the facility. The report provides a mechanism for j

the staff to review the appropriate'ess of licensee activities after-the-fact, but contains no l

requirement for staff approval. Given that the report is required to be provided to the Commission no sooner than 90 days following completion of the respective milestone, report completion and submittalis clearly not necessary to ensure operation of the facility in a safe manner for the interval between completion of the startup testing and submittal of the report.

Additionally, given there is no requirement for the Commission to approve the report, the startup report is not necessary to ensure operation of the facility,in a safe manner.

6.9.A.4.d This change proposes to relocate the requirements which state where to send NRC l

Reports, Program Revisions, etc., out of the TS. These requirements will be relocated to plant procedures or other licensee controlled documents. These requirements are a duplicate of 10 j

CFR 50.4. The NRC and the industry have agreed to remove requirements from the Administrative Controls Section which are duplicates of other regulatory requirements. This change is consistent with NUREG-1433.

(

6.9.C.2 This change proposes to relocate the details for the Radiological Environmental Monitoring Report to the ODCM. These items are relocated to the ODCM per GL 89-01 which allowed RETS to be relocated from the TS. Fw.aore details, see changes for Section TS 3/4.8.

l

• Radioactive Msterials." Editorial rewording (either adding or deleting)is proposed to be consistent with NUREG-1433.

6.10 This change proposes to relocate the requirements on record retention from TS on the basis that they duplicate the requirements of 10 CFR 50, Appendix B, Criterion XVil and are adequately addressed by the QA Program Facility operations are performed in accordance with approved written procedures. Areas include normal startup, operation and shutdown, abnormal conditions and emergencies, refueling, safety related maintenance, surveillance and testing, and radiation control. Facility records document appropriate station operations and activities.

18 Retention of these records provides document retrievability for review of compliance with requirements and regulations. Numerous other regulations, such as 10 CFR 20, Subpart L and 10 CFR 50.71, also require the retention of certain records related to operation of the nuclear plant.

6.11 This change proposes to relocate the requirements for the Radiation Protection Program out of the TS on the basis that they duplicate other regulatory requirements and changes to the licensee controlled documents to which they are relocated are adequately controlled by other regulatory requirements. The requirement to have procedures to implement Part 20 is contained within 10 CFR 20.1101(b). Periodic review of these procedures is addressed under 10 CFR 20.1101(c).

Table 6.9.1.a This change proposes to relocate the requirements for the Secondary Containment Leak Rate Testing Report out of the TS. The requirements to perform secondary containment leak rate testing are contained in 10 CFR 50, Appendix J, Section IV and implemented via Specification 4.7.C.1 of the current PNPS TS. The procedures required by Specification 4.7.C.1 are required to be maintained on file for a minimum of 5 years and are available for inspection as required by Appendix J. In addition, failure to meet the leakage requirements specified in Specification 4.7.C.1 would require a Licensee Event Report in accordance with 10 CFR 50.73.

The staff has reviewed the above and concluded that the relocations are consistent with the guidance in GL 89-01 and 10 CFR 50.36. Therefore, the proposed TS change is acceptable.

Below is a discussion of those proposed changes which are less restrictive than the current TS.

5.2.2.d and e This change proposes to relax the requirement to maintain the crew composition as specified in 10 CFR 50.54(m)(2)(l) and 5.2.2.a and 5.2.2.i. The proposed change will allow temporary deviations from these requirements for up to 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 immediate action is taken to fill the required position. This change is consistent with 10 CFR 50.54(m)(2)(1) note 1. The impact on plant safety will be minimal because 10 CFR 50.54(m)(2)(ii) and (iii) requiremee must be met so there will always be licensed personnel present when required, in addition, tne, period allowed for positions to be unfilled is small and the probability that the minimum staff will be unfilled (since normal staffing is above the levels required by 10 CFR 50.54(m)(2)) is small, This change is consistent with NUREG-1433. This change also maintains current TS allowances for meeting the requirements for lower grade licenses with personnel holding a higher grade license.

5.2.2.f This change proposes to relax the re.quirement to have an individual qualified in radiation protection procedures to be onsite when fuelis in the reactor. The proposed change will allow the position to be vacant for up to 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 immediate action is taken to fill the required position. This change will not have any impact on plant safety because the presence of a person qualified in radiation protection procedures is not required for the mitigation of any accident. The only impact may be if entries into radiation areas are required to repair equipment. However, this impact will be slight because the allowed outage time of equipment is usually longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the chance of a problem occurring within the 2-hour period this position is unfilled is small, and the probability that the position will be unfilled (since usually more than one person qualified in radiation protection procedures is located on site)is small. This change is consistent with NUREG-1433.

}

19 6.9.C.1 This change proposes to revise the Radioactive Effluent Release Report requirements in accordance with 10 CFR 50.36a. This will change the reporting requirements from semi-annual to annual and relocate details to the ODCM and process control procedure. These items are relocated to the ODCM per GL 89-01, which allowed RETS to be relocated from the TS. Fer more details, see change for section 3.8.4 CTS 3/4.8. " Radioactive Materials." This change is consistent with NUREG-1433.

l 6.13 Existing Specification 6.13, which provides high radiation area access control altematives pursuant to 10 CFR 20.203(c)(2) (revised 10 CFR 20.1601(c)), has been significantly revised as a result of the changes to 10 CFR 20, the guidance provided in RG 8.38 (Control of Access to High and Very High Radiation Areas in Nuclear Power Plants), and current industry technology in l

controlling access to high radiation areas. The changes include a capping dose rate to i

differentiate a high radiation area from a very high radiation area, additional requirements for groups entering high radiation areas, and clarification of the need for communication and control l

of workers in high radiation areas. This change provides acceptable attemata methods for controlling access to high radiation areas. As a result, this change will not decrease the ability to provide control of exposures from extemal sources in restricted areas. This change is consistent l

with NUREG-1433.

The staff has reviewed the above and agrees with the licensee that the proposed changes while less restrictive than the current TS, are consistent with NUREG-1433. Therefore, the proposed changes are acceptable.

Below is a discussion of changes, deviations, reformatting, renumbering, and relocation of the

)

current TS to provide a format consistent with NUREG 1433.

5.0 The PNPS plant-specific titles were incorporated into this requirement. This proposed deviation is based on PNPS plant-specific licensing basis and/or organization.

i 5.2.1.a, 5.6.1, 2, and 3. This proposed deviation removes the brackets and adopts the wording of NUREG-1433.

5.2.2 This proposed deviation deletes the contents enclosed in brackets. PNPS is a single unit plant; therefore, the bracketed information is not applicable.

l 5.2.2.f This proposed deviation replaces bracketed words with plant-specific wording from the current TS. This wording is also consistent with terms used in Specification 5.7 - High Radiation Area.

5.2.2.e This proposed devietion adopts the second bracketed option. In response to I

NUREG-0737, item I.A.1.3.(1), the NRC, by letter dated March 31,1982, concluded that the policy and procedures BECo uses to limit overtime are in conformance with NUREG-0737 guidelines and are acceptable.

6.3 Reviewer's Note The bracketed information

• Reviewer's Note"is deleted. This information was provided to clarify options available.

5.5.5 This proposed deviation replaces the brackets with plant-specific information from the PNPS FSAR.

1

\\

f 20 5.5.6 of NUREG-1433 The bracketed requirement is deleted. PNPS does not have any Pre-Stressed Concrete Containment Tendons.

5.6.1 This proposed deviation replaces the bracketed information with plant-specific information contained in the currer.t TS. This proposed deviation deletes the bracketed information. PNPS l

has already submitted the initial report.

t 5.6.2 This proposed deviation deletes the bracketed requirements to identify TLD results that represent collocated dosimeters in relation to the NRC TLD program and the exposure period associated with each result. Current PNPS repoding requirements do not require this l-information.

5.6.4 This proposed deviation deletes the bracketed information conceming relief valve l

i challenges. Current PNPS TS do not require reporting these challenges.

5.6.5.a and b This proposed deviation replaces the bracketed information with plant-specific TS inat address core operating limits.

5.6.7 This proposed deviation does not adopt the EDG Failure Report requirements. EDG failures are repoded in accordance with the PNPS Emergency Diesel Generator Reliability Program.

The staff has reviewed the above changes and agrees that they are plant-specific parar,1eters or l

{

l words from the current TS and the changes are administrative in nature. Therefore, the l

proposed changes to the TS are acceptable.

The following is a discussion of deviations between the proposed TS and NUREG-1433.

5.0 This proposed deviation incorporates wording from 10 CFR 50.54 to maintain consistency with Definition 1.0.K of the existing TS which defines MODE by the mode switch position. PNPS has not yet adopted the NUREG method of defining MODES.

5.2.2 This proposed deviation replaces existing words with plant-specific wording. PNPS is a single unit plant, therefore, " assigned to each reactor containing fuel", "for each control room i

from which", or "from each unit" is not applicable.

5.2.2.c This proposed deviation adds the requirement "at least two licensed Ros shall be j

present in the control room during reactor startup, scheduled reacter shutdown, and during rec >very from reactor trips." This deviation is based on the current PNPS licensing basis.

l 5.0 Renumbering is proposed to incorporate plant-specific licensing requirements being retained and to incorporate the TS Bases Control Program. STS programs 5.5.6 through 5.5.10 are not being adopted at this time because thcy are currently addressed in other specifications not being revised by this change, or they are not applicable because of plant specific design / licensing basis.

I

(

5.2.2.e This proposed deviation carries forward current TS allowances that higher grade l

licensed operators may take the place of lower grade licensed or unlicensed personnel.

]

l

)

21 5.0 The PNPS plant-specific titles were incorporated into this requirement. This proposed deviation is based on the PNPS plant-specific organization.

5.2.2.i This proposed deviation replaces areas of expertise with wording consistent with PNPS's commitment to NUREG-0578 item 2.2.1.b, NUREG-0737 item I.A.1.1, and the NRC policy statement on providing engineering expedise on shift.

5.2.2.1 This proposed deviation carries forward current TS allowances that a SCRE with an SRO license may simultsaeously serve as SCRE and SRO.

5.3.1 This proposed deviation replaces NUREG wording, including bracketed information, with plant-specific wording from the current T3.

5.5.2 This proposed deviation revises the program requirements for Primary Coolant Sources Outside Containment to be consistent with PNPS's commitment to NUREG-0578, item 2.1.6.a.

This deviation is not represented as a bracketed deviation because the deviations include scope outside the brackets.

5.5.4.g This proposed deviation replaces limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the site boundary with the requirements currently contained in Specification 3.8.D.a and 3.8.D.b forinstantaneous dose rate limitations.

This deviation is made to be consistent with requirements relocated to the ODCM.

5.5.4.k This proposed deviatio, deletes the requirement to have limitations on venting and purging containment. PNPS has a Mark 1 containment and the NRC has determined, by letter dated August 22,1986, that limitations on purging and venting containment during reactor operations is unnecessary at PNPS.

5.5.7 This proposed change does not adopt specification 5.5.7 - Inservice Testing Program.

The PNPS Inservice Testing Program is currentig,vi.?ained in Specification 3/4.6.G - Structural Integrity, 3/4.6.1 - Shock Suppressors (Snubbers), and 3/4.13 - INSERVICE CODE TESTING.

5.5.8 This proposed change does not adop Specification 5.5.8 - Ventilation Filter Testing Program (VTIP). The PNPS VTIP is currer.tly contained in Specifications 3/4.7.B.1 for Standby Gas Treatment System and 3/4.7.B.2 for.ie Control Room High Efficiency Air Filtration System.

v 5 5.9 This proposed change does not adopt Specification 5.5.9 - Explosive Gas and Storage Tank Radioactive Monitoring Program. There are no waste gas storage tanks or unprotected, outside, liquid waste storage tanks at PNPS.

5.5.10 This proposed change does not adopt Specification 5.5.10 - Diesel Fuel Oil Testing Program. The PNPS Diesel Fuel Oil Testing Program is currently contained in Specification 4.9.A.1.e.

J j

5.5.12 This proposed change does not adopt Specification 5.5.12 - Safety Function i

l Determination Program. This Specification requires, upon entry into LCO 3.06, a determination

)

of whether a loss of function exists. PNPS does not, at this time, have an LCO 3.06. PNPS is bound by the various system LCOs and must take the actions associated with the most limiting condition.

l l

1

~s 22 5.6.3 This proposed deviation adds a due date for the Radioactive Effluent Release Report.

This due date is consistent with the due date for the Annual Radiological Environmental Operating Report.

5.6.3 This proposed deviation replaces the Process Control Program (PCP) with process control procodures. The NRC accepted the use of plant procedures in lieu of a PCP as documented in the Safety Evaluation supporting TS Amendment No. 89.

5.6.6 This proposed change does not adopt Specification 5.6.6 - Reactor Coolant System (RCS)

Pressure and Temperature Limits Report (PTLR). The reactor coolant pressure and temperature limits are currently contained in Specification 3/4.6.A.

5.6.8 This proposed deviation does not adopt Specification 5.6.8 - PAM Report. The requirement to issue this report is currently contained in Note 7 to Table 3.2.F.

The staff has reviewed these deviations from NUREG-1433 and agrees with the licensee that they represent plant-specific design considerations in the current TS or previously approved by the staff, and have been maintained in the proposed TS. Therefore, the proposed changes are acceptable.

The following is a summary of changes to or relocations of the T.S. Section 6.0.

Current PNPS Technical Specirmations Pr - e.__

6 ADMINISTRATE CONTROLS TS 5

ADhANi$TRATNE CONTROLS s.1 Responsibiiny TS 5.1 Rempamibility 6.1 Station Director TS 5.1.1 Station Dwector T5 5.1.2 Shift Supervisor 82 Organization TS 6.2 C:._intion 6.2A Onsae and oNone Orsenizations TS 6.2.1 Onese and Osene W--%

8.2.8 Unit St.aff TS 5.2.2 Unit Stat j

8.3 Unit StaN Qualifications TS 5.3 Una Sten Quellfications 6.4 Training FSAR 13.3 6.5 Review and Audit FSAR 13.8 6.5 A Operations Review Committee (ORC)

FSAR 13.8.3 FSAR % Request Required i

5.5.8 Nuclear Safety Review and Audit Committee (NSRAC)

FSAR 13.8.5 FSAR Change Request Required j

8.6 Reportable Event Action Reg 10CFR50.72/73 PW e 6.7 DELETED 8.8 Procedures TS 5d Procedures 1

8.9 Reporting " ' _.___

TS 5.8 Reporane " ' _ ----

8.9 A.1 Startup Report FSAR 13.5 REACTOR STARTUP AND POWER TEST PROGRAM

(

8.9A.3 Occupational Esposure Tabuletion TS 5.8.1 Occupational Radinhon 8 ; m Report 6.9.C.2 Annuel Radiological Environmental TS 58.2 Annual Rescal Environmental Operatino Report

• ~

8

,4 23 s.s.C.1 semi. Annual Red,ancteve Emuent Reisee. Report TS 5.s.3 ph v Ement Report S.9A2 Monthly Operating Report TS 5.6.4 Monthly Operstme Reporte 0.9A4 i Core Operatine Limits Report TS 5.4.5 Core Operatsng Umme Report (COLR)

T4 91.e Secondary Cr_.-. c._c.: Leek Rate Testing

• 10 CFR 50. Appendix J and 10 CFR 50.73" 6.10 Record Rotention FSAR 13.7.5 (Identicello TS) 8.11 Redishon Protection Program FSAR 13.6.6 6.12 DELETED 8.13 High Radiation Aree TS 5.7 High Radiation Area TS 5.5 Programs and Manuels TS 5.5.2 Primary Cooient Sources Outside C- --_ -. c; TS 5.5.3 Post Accident Sampling TS 5.5.4 Radioactive Emuent Controle Program TS 5.5.5 Component Cyclic or Transient Limit TS 5.5.6 Technical Specir, cations (TS) Bases Control Program 2.7 fMQlOACTIVE MATERIALS This proposed change affects those sections of TS dealing with the control of radiological effluents, including those sections dealing with gaseous effluents, liquid effluents, solid waste, and environmental monitoring. Associated TS addressing definitions, administrative controls, and reporting are also affected. The purpose of these specifications is to ensure compliance with regulatory requiremen'.s goveming radioactive effluents, including 10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a, and Appendix I to 10 CFR 50.

In accordance with the guidance of GL 89-01, this proposed change adds new programmatic requirements goveming radioactive effluents and radiological environmental monitoring to the Administrative Controls section of the TS. Existing TS containing procedural details on radioactive effluents, solid radioactive wastes, environmental monitoring, definitions, and associated reporting requirements are concurrently being deleted. The procedural details which are to be deleted are being incorporated in the ODCM.

The proposed changes to the TS are administrative in nature and affect only the format and location of procedural details related to the control of radioactive effluents, solid radioactive l

waste, and radiological environmental monitoring. The proposed changes do not involve physical modifications to plant equipment or changes in the operation of the plant. The staff has determined the relocation of this section is consistent with the guidance in GL 89-01. Therefore, the proposed TS changes are acceptable.

,a

• ?

24 The following is a summary of the changes to or relocations of the T.S. Section 7.0.

Current PNPS Technical Specircations Proposed Changes 7/80 RADIOLOGICAL ENVIROfeENTAL MONITORING PROGRAM 7/8.1 Monitoring Program ODCM 3/4.5.1 Monnoring Program 7.1 A Conduct Environmental Monnoring Program ODCM 3.5.1 Conduct Env6ronmental Monitoring Program 7.1 A1 Program nnt being conducted ODCN 3.5.1 a Program not being conducted

{

7.1 A2 Radioactivity exceeds reporting level ODCM 3.5.1.b Radioactivity exceeds reportang level 7.1 A3 Milk and Leefy vegetable Samples unavailable OOCM 3.5.1.c Milk and Leafy vegetable Samples unavailable 8.1A determine cumulative dose contributions ODCM 4.5.1 determine cumulative does contributions 7/8.1.8 Land Us.e census ODCM 1/4.5.2 Land Use census 7.1.B Conduct Land Use census ODCM 3.5.2 Conduct Land Use census 7.1.8 Achon 1 Cemitted dose

• values calculated OOCM 3.5.2 Action a Committed dose > values calculated 7.1.B Ac6on 2 Committed dose 20% > values calculated OOCM 3.5.2 Action b Committed dose 20% e values calculated 8.1.B Conduct land use census ODCM 4.5.2 Conduct land use census 7/8.2 Dose - Liquids ODCM 3/4.2.2 Dose. Liquids 7.2A Dose commitment to member of public ODCM 3.2.2 Done commhment to mornber of pubic 7.2A Action Report ODCM 3.2.2 Report 1

8.2A Determine cumulative dose contribution ODCM 4.2.2 Determine cumulative dose contribution k

7/8.3 Done - Noble Gases ODCM 3/4.3.2 Dose. Noble Gases j

7.3A Air dose limits ODCM 3.2.2 Air done limits 1

7.3 A Act ion Report ODCM 3.2.2 Report i

8.3A Determine cumulative dose contribution ODCM 4.3.2 Determine cumulative dose contribution 7/8.4

• l-131,1 133. Rad Material in Partculate ODCM 3/4.3.3 "k131, b133, Rad Material in Particulate Form. & Trnium" 7.4A Dose to member of pubic ODCM 3.33 Doce to member of public 7.4A Action Report ODCM 3.3.3 Report 8.4A Dr4 ermine cumulative dose contribution OOCM 4.3.3 Determine cumulative done contribution 7/85 Total Done ODCM 3/4.4.1 Total Does I

7.5A Dose commMment to member of public ODCM 34.1 Done commament to member of public 7.5 A Action Report ODCM 34.1 Report 8.5A Determine cumulative dose contribution OOCM 441 Determine cumulative does contributed Table 7.1 1 Reporbng Levels for Radioactive Concentrations ODCM Table 3.5-4 Reporting Levels for Radioactive Concentrations in Environmental Samples Table 8.1 1 Operatonal Radiological Enviror, mental Monitoring ODCM T tie 3.5-1 Operational Radiological Environmental Monitoring Program Program T8.1 1 Note 1 gross Beta radioactivity

• 10 times control value ODCM l T3.5-1 Note (3) gross Beta radioactivity

• 10 times control value

ae

?

,e

',)

25 78S1 Note 2 gamma isotopic means ODCM T351 Note (4) gamma isotopic means T811 Note 3 integrated gamma activity > 10 times control value ODCM T351 Note (Q integrated gamme octnnfy

• 10 times contrei value T8.1 1 Note 3 indicates control location CDCM T351 Note (2) indicates controllocation TSS1 Note 5 fish analysis will be performed on a minimum ODCM T351 Note (8) fish onelysis will be performed on a minimum T8Si N We 8 mussel samples from four locations ODCM T351 Note (7) mussel samples from fourlocations T8.1 1 Note 7 mediment sampies from four locations ODCM T351 Note (6) eedement semples from four locations 78.11 Note 8 these locations may be aNered ODCM T351 Note (g) these locations may be altered T8S1 Note 9 minimum sensMivities for psmme exposure ODCM T351 Note (1) minimum eens4w6 ties for gamme exposure Table 812 Air Particulate Geseous Radioiodine and Soil ODCM lable 353 Air Particulate Gaseous Radiciodene and Soil Surveillance surveillance Stations Table 8S3 Extemal Gamma Surveillance Stations COCM Tabee 352 Environmental TLD Lacetions T813 Note 1 Thermoluminescent dosimeters (TLDs)

Deleted Notes ned required T8S3 Note 2 Control Station Deleted Notes not required T8S3 Note 3 TLDs for this location will be provided Deleted Not.e not required Tab 4 8.1-4 Menimum Values for the Lower Umits of Detection ODCM Table 4 5-1 Detection Capai4!Mies for Environmental Sample Analysis Lower Limit of Detection (LLD)

T8.1-4 Note a Refer to ODCM ODCM T4 5-1 Note (1)

Refer to ODCM T81-4 Note b LLD for surface water ODCM T4 51 Not (2)

LLD for Service water T8-14 Note e LLD for leafy vegetables ODCM T4 51 Note (4)

LLD for leafy vegetables 78-14 Note d if no drinking water pathway ODCM T4 5-1 Note (3)

If no drinking water pathway 3.0 BASES SECTION The licensee has revised the associated BASES Sections related to the above TS changes. The proposed changes reflect the changes due to relocation, adoption of standard TS wording, and modification of certain TS. As noted above, the proposed TS changes are consistent with NUREG-1433 and the BASES sections have been changed to reflect the revised TS.

4.0 STATE CONSULTATION

l 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

l 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 (63 FR 9591). This amendment also relates to changes in record-keeping, reporting, or administrative procedures or requirements. Accordingly, the amendment

4

• r

'?

26 meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(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 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 Contributor: A. Wang Date: July 31,1998 l

I

-_