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Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement To Eliminate Requirements on Post Accident Sampling Systems Using the Consolidated Line Item Improvement Process
Note: EPA no longer updates this information, but it may be useful as a reference or resource.
[Federal Register: August 11, 2000 (Volume 65, Number 156)]
[Notices]
[Page 49271-49277]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr11au00-108]
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NUCLEAR REGULATORY COMMISSION
Notice of Opportunity To Comment on Model Safety Evaluation on
Technical Specification Improvement To Eliminate Requirements on Post
Accident Sampling Systems Using the Consolidated Line Item Improvement
Process
AGENCY: Nuclear Regulatory Commission.
ACTION: Request for comment.
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SUMMARY: Notice is hereby given that the staff of the Nuclear
Regulatory Commission (NRC) has prepared a model safety evaluation (SE)
relating to the elimination of requirements on post accident sampling
imposed on licensees through orders, license conditions, or technical
specifications. The NRC staff has also prepared a model no significant
hazards consideration (NSHC) determination relating to this matter. The
purpose of these models is to permit the NRC to efficiently process
amendments that propose to remove requirements for the Post Accident
Sampling System (PASS). Licensees of nuclear power reactors to which
the models apply could request amendments confirming the applicability
of the SE and NSHC determination to their reactors and providing the
requested plant-specific verifications and commitments. The NRC staff
is requesting comments on the model SE and model NSHC determination
prior to announcing their availability for referencing in license
amendment applications.
DATES: The comment period expires September 11, 2000. Comments received
after this date will be considered if it is practical to do so, but the
Commission is able to ensure consideration only for comments received
on or before this date.
ADDRESSES: Comments may be submitted either electronically or via U.S.
mail.
Submit written comments to: Chief, Rules and Directives Branch,
Division of Administrative Services, Office of
[[Page 49272]]
Administration, Mail Stop: T-6 D59, U.S. Nuclear Regulatory Commission,
Washington, DC 20555-0001.
Hand deliver comments to: 11545 Rockville Pike, Rockville,
Maryland, between 7:45 a.m. and 4:15 p.m. on Federal workdays.
Copies of comments received may be examined at the NRC's Public
Document Room, 2120 L Street, NW (Lower Level), Washington, DC.
Comments may be submitted by electronic mail to CLIIP@nrc.gov.
FOR FURTHER INFORMATION CONTACT: William Reckley, Mail Stop: O-8E2,
Division of Licensing Project Management, Office of Nuclear Reactor
Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-
0001, telephone 301-415-1323.
SUPPLEMENTARY INFORMATION:
Background
Regulatory Issue Summary 2000-06, ``Consolidated Line Item
Improvement Process for Adopting Standard Technical Specification
Changes for Power Reactors,'' was issued on March 20, 2000. The
consolidated line item improvement process (CLIIP) is intended to
improve the efficiency and transparency of NRC licensing processes.
This is accomplished by processing proposed changes to the Standard
Technical Specifications (STS) in a manner that supports subsequent
license amendment applications. The CLIIP includes an opportunity for
the public to comment on proposed changes to the STS following a
preliminary assessment by the NRC staff and finding that the change
will likely be offered for adoption by licensees. This notice is
soliciting comment on a proposed change to the STS that removes
requirements for the PASS. The CLIIP directs the NRC staff to evaluate
any comments received for a proposed change to the STS and to either
reconsider the change or to proceed with announcing the availability of
the change for proposed adoption by licensees. Those licensees opting
to apply for the subject change to technical specifications are
responsible for reviewing the staff's evaluation, referencing the
applicable technical justifications, and providing any necessary plant-
specific information. Each amendment application made in response to
the notice of availability would be processed and noticed in accordance
with applicable rules and NRC procedures.
This notice involves the elimination of requirements for PASS and
related administrative controls in technical specifications. This
proposed change was proposed for incorporation into the standard
technical specifications by the Westinghouse Owners Group (WOG) and the
Combustion Engineering Owners Group (CEOG) participants in the
Technical Specification Task Force (TSTF) and is designated TSTF-366.
Applicability
This proposed change to remove requirements for PASS from technical
specifications (and other elements of the licensing bases) is
applicable to plants with Westinghouse and Combustion Engineering
designs.
To efficiently process the incoming license amendment applications,
the staff requests each licensee applying for the changes addressed by
TSTF-366 using the CLIIP to address the following plant-specific
verifications and regulatory commitments. The CLIIP does not prevent
licensees from requesting an alternative approach or proposing the
changes without the requested verifications and regulatory commitments.
Variations from the approach recommended in this notice may, however,
require additional review by the NRC staff and may increase the time
and resources needed for the review. In making the requested regulatory
commitments, each licensee should address: (1) That the subject
capability exists (or will be developed) and will be maintained; (2)
where the capability or procedure will be described (e.g., severe
accident management guidelines, emergency operating procedures,
emergency plan implementing procedures); and (3) a schedule for
implementation. The amendment request need not provide details about
designs or procedures.
Each licensee should verify that it has, and make a regulatory
commitment to maintain (or make a regulatory commitment to develop and
maintain):
a. contingency plans for obtaining and analyzing highly radioactive
samples from the reactor coolant system, containment sump, and
containment atmosphere;
b. a capability for classifying fuel damage events at the Alert
level threshold (typically this is 300 Ci/ml dose equivalent
iodine). This capability may use the normal sampling system and/or
correlations of sampling or letdown line dose rates to coolant
concentrations; and
c. the capability to monitor radioactive iodines that have been
released to offsite environs.
Public Notices
The staff issued a Federal Register Notice (64 FR 66213, November
24, 1999) that requested public comment on the NRC's pending action to
approve topical reports submitted by the WOG and the CEOG in which they
proposed to eliminate regulatory requirements for PASS. In particular,
the staff sought comment from offsite emergency response organizations
so that any impact of the elimination of PASS on their response could
be factored into the staff's evaluation. Appendices to the staff's
safety evaluations for topical reports submitted by the CEOG and the
WOG contain a synopsis of the public comments received and the staff's
evaluation of the comments. The safety evaluations for the topical
reports are available on the NRC website posting for this change
(www.nrc.gov/NRR/sts/sts.htm) and the official record copies are
available on the NRC's Agencywide Documents Access and Management
System (ADAMS) (Accession Numbers ML003715250 dated May 16, 2000, for
the CEOG topical report and ML003723268 dated June 14, 2000, for the
WOG topical report).
This notice requests comments from interested members of the public
within 30 days of the date of publication in the Federal Register.
Following the staff's evaluation of comments received as a result of
this notice, the staff may reconsider the proposed change or may
proceed with announcing the availability of the change in a subsequent
notice (perhaps with some changes to the safety evaluation or proposed
no significant hazards consideration determination as a result of
public comments). If the staff announces the availability of the
change, licensees wishing to adopt the change will submit an
application in accordance with applicable rules and other regulatory
requirements. The staff will in turn issue for each application a
notice of consideration of issuance of amendment to facility operating
license(s), a proposed no significant hazards consideration
determination, and an opportunity for a hearing. A notice of issuance
of an amendment to operating license(s) will also be issued to announce
the elimination of the PASS requirements for each plant that applies
for and receives the requested change.
Proposed Safety Evaluation
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor
Regulation; Consolidated Line Item Improvement, Technical Specification
Task Force (TSTF) Change TSTF-366, Elimination of Requirements for Post
Accident Sampling System (PASS)
[[Page 49273]]
1.0 Introduction
In the aftermath of the accident at Three Mile Island (TMI), Unit
2, the Nuclear Regulatory Commission (NRC) imposed requirements on
licensees for commercial nuclear power plants to install and maintain
the capability to obtain and analyze post-accident samples of the
reactor coolant and containment atmosphere. The desired capabilities of
the Post Accident Sampling System (PASS) were described in NUREG-0737,
``Clarification of TMI Action Plan Requirements.'' The NRC issued
orders to licensees with plants operating at the time of the TMI
accident to confirm the installation of PASS capabilities (generally as
they had been described in NUREG-0737). A requirement for PASS and
related administrative controls was added to the technical
specifications (TS) of the operating plants and was included in the
initial TS for plants licensed during the 1980s and 90s. Additional
expectations regarding PASS capabilities were included in Regulatory
Guide 1.97, ``Instrumentation for Light-Water-Cooled Nuclear Power
Plants To Assess Plant and Environs Conditions During and Following an
Accident.''
Significant improvements have been achieved since the TMI accident
in the areas of understanding risks associated with nuclear plant
operations and developing better strategies for managing the response
to potentially severe accidents at nuclear plants. Recent insights
about plant risks and alternate severe accident assessment tools have
led the NRC staff to conclude that some TMI Action Plan items can be
revised without reducing the ability of licensees to respond to severe
accidents. The NRC's efforts to oversee the risks associated with
nuclear technology more effectively and to eliminate undue regulatory
costs to licensees and the public have prompted the NRC to consider
eliminating the requirements for PASS in TS and other parts of the
licensing bases of operating reactors.
The staff has completed its review of the topical reports submitted
by the Combustion Engineering Owners Group (CEOG) and the Westinghouse
Owners Group (WOG) that proposed the elimination of PASS. The
justifications for the proposed elimination of PASS requirements center
on evaluations of the various radiological and chemical sampling and
their potential usefulness in responding to a severe reactor accident
or making decisions regarding actions to protect the public from
possible releases of radioactive materials. As explained in more detail
in the staff's safety evaluations for the two topical reports, the
staff has reviewed the available sources of information for use by
decision-makers in developing protective action recommendations and
assessing core damage. Based on this review, the staff found that the
information provided by PASS is either unnecessary or is effectively
provided by other indications of process parameters or measurement of
radiation levels. The staff agrees, therefore, with the owners groups
that licensees can remove the TS requirements for PASS, revise (as
necessary) other elements of the licensing bases, and pursue possible
design changes to alter or remove existing PASS equipment.
2.0 Background
In a letter dated May 5, 1999 (as supplemented by letter dated
April 14, 2000), the CEOG submitted the topical report CE NPSD-1157,
Revision 1, ``Technical Justification for the Elimination of the Post-
Accident Sampling System From the Plant Design and Licensing Bases for
CEOG Utilities.'' A similar proposal was submitted on October 26, 1998
(as supplemented by letters dated April 28, 1999, April 10 and May 22,
2000), by the WOG in its topical report WCAP-14986, ``Post Accident
Sampling System Requirements: A Technical Basis.'' The reports provided
evaluations of the information obtained from PASS samples to determine
the contribution of the information to plant safety and accident
recovery. The reports considered the progression and consequences of
core damage accidents and assessed the accident progression with
respect to plant abnormal and emergency operating procedures, severe
accident management guidance, and emergency plans. The reports provided
the owners groups' technical justifications for the elimination for the
various PASS sampling requirements. The specific samples and the
staff's findings are described in the following evaluation.
The NRC staff prepared this model safety evaluation (SE) relating
to the elimination of requirements on post accident sampling and
solicited public comment [ FR ] in accordance with the consolidated
line item improvement process (CLIIP). The use of the CLIIP in this
matter is intended to help the NRC to efficiently process amendments
that propose to remove the PASS requirements from TS. Licensees of
nuclear power reactors to which this model apply were informed [ FR ]
that they could request amendments confirming the applicability of the
SE to their reactors and providing the requested plant-specific
verifications and commitments.
3.0 Evaluation
The technical evaluations for the elimination of PASS sampling
requirements are provided in the safety evaluations dated May 16, 2000,
for the CEOG topical report CE NPSD-1157 and June 14, 2000, for the WOG
topical report WCAP-14986. The NRC staff's safety evaluations approving
the topical reports are located in the NRC's Agencywide Documents
Access and Management System (ADAMS) (Accession Numbers ML003715250 for
CE NPSD-1157 and ML003723268 for WCAP-14986).
The ways in which the requirements and recommendations for PASS
were incorporated into the licensing bases of commercial nuclear power
plants varied as a function of when plants were licensed. Plants that
were operating at the time of the TMI accident are likely to have been
the subject of confirmatory orders that imposed the PASS functions
described in NUREG-0737 as obligations. The issuance of plant specific
amendments to adopt this change, which would remove PASS and related
administrative controls from TS, would also supercede the PASS specific
requirements imposed by post-TMI confirmatory orders.
As described in its safety evaluations for the topical reports, the
staff finds that the following PASS sampling requirements may be
eliminated for plants of Combustion Engineering and Westinghouse
designs:
1. reactor coolant dissolved gases.
2. reactor coolant hydrogen.
3. reactor coolant oxygen.
4. reactor coolant pH.
5. reactor coolant chlorides.
6. reactor coolant boron.
7. reactor coolant conductivity.
8. reactor coolant radionuclides.
9. containment atmosphere hydrogen concentration.
10. containment oxygen.
11. containment atmosphere radionuclides.
12. containment sump pH.
13. containment sump chlorides.
14. containment sump boron.
15. containment sump radionuclides.
The staff agrees that sampling of radionuclides is not required to
support emergency response decision making during the initial phases of
an accident because the information provided by PASS is either
unnecessary or is effectively provided by other indications of process
parameters or measurement of radiation levels. Therefore, it is not
necessary to have dedicated equipment to obtain this sample in a prompt
manner.
[[Page 49274]]
The staff does, however, believe that there could be significant
benefits to having information about the radionuclides existing post-
accident in order to address public concerns and plan for long-term
recovery operations. As stated in the safety evaluations for the
topical reports, the staff has found that licensees could satisfy this
function by developing contingency plans to describe existing sampling
capabilities and what actions (e.g., assembling temporary shielding)
may be necessary to obtain and analyze highly radioactive samples from
the reactor coolant system (RCS), containment sump, and containment
atmosphere. (See item 4.1 under Licensee Verifications and
Commitments.) The contingency plans for obtaining samples from the RCS,
containment sump, and containment atmosphere may also enable a licensee
to derive information on parameters such as hydrogen concentrations in
containment and boron concentration and pH of water in the containment
sump. The staff considers the sampling of the containment sump to be
potentially useful in confirming calculations of pH and boron
concentrations and confirming that potentially unaccounted for acid
sources have been sufficiently neutralized. The use of the contingency
plans for obtaining samples would depend on the plant conditions and
the need for information by the decision-makers responsible for
responding to the accident.
In addition, the staff considers radionuclide sampling information
to be useful in classifying certain types of events (such as a
reactivity excursion or mechanical damage) that could cause fuel damage
without having an indication of overheating on core exit thermocouples.
However, the staff agrees with the topical reports' contentions that
other indicators of failed fuel, such as letdown radiation monitors (or
normal sampling system), can be correlated to the degree of failed
fuel. (See item 4.2 under Licensee Verifications and Commitments.)
In lieu of the information that would have been obtained from PASS,
the staff believes that licensees should maintain or develop the
capability to monitor radioactive iodines that have been released to
offsite environs. Although this capability may not be needed to support
the immediate protective action recommendations during an accident, the
information would be useful for decision makers trying to limit the
public's ingestion of radioactive materials. (See item 4.3 under
Licensee Verifications and Commitments.)
The staff believes that the changes related to the elimination of
PASS that are described in the topical reports, related safety
evaluations and this proposed change to TS are unlikely to result in a
decrease in the effectiveness of a licensee's emergency plan. Each
licensee, however, must evaluate possible changes to its emergency plan
in accordance with 10 CFR 50.54(q) to determine if the change decreases
the effectiveness of its site-specific plan. Evaluations and reporting
of changes to emergency plans should be performed in accordance with
applicable regulations and procedures.
The staff notes that redundant, safety-grade, containment hydrogen
concentration monitors are required by 10 CFR 50.44(b)(1), are
addressed in NUREG-0737 Item II.F.1 and Regulatory Guide 1.97, and are
relied upon to meet the data reporting requirements of 10 CFR Part 50,
Appendix E, Section VI.2.a.(i)(4). The staff concludes that during the
early phases of an accident, the safety-grade hydrogen monitors provide
an adequate capability for monitoring containment hydrogen
concentration. The staff sees value in maintaining the capability to
obtain grab samples for complementing the information from the hydrogen
monitors in the long term (i.e., by confirming the indications from the
monitors and providing hydrogen measurements for concentrations outside
the range of the monitors). As previously mentioned, the licensee's
contingency plan (see item 4.1) for obtaining highly radioactive
samples will include sampling of the containment atmosphere and may, if
deemed necessary and practical by the appropriate decision-makers, be
used to supplement the safety-related hydrogen monitors.
[Note 1--Each licensee should specify a desired implementation
period for its specific amendment request. The implementation period
would be that period necessary to develop and implement the items in
4.1 through 4.3 and, as necessary, to make other changes to
documentation or equipment to support the elimination of PASS
requirements. As an alternative, the licensee may choose to have a
shorter implementation period and include the scheduling of items
4.1 through 4.3 as part of the regulatory commitments associated
with this amendment request. Amendment requests that include
commitments for implementation of the items in Section 4 within 6
months of the implementation of the revised TS will remain within
the CLIIP.]
[Note 2--There may be some collateral changes to the TS as a result
of the removal of the administrative controls section for PASS. The
following paragraphs address three potential changes that the staff
is aware of (editorial changes, mention of PASS as a potential
leakage source outside containment, and revision of the bases
section for post accident monitoring instrumentation).]
(A) The elimination of the TS and other regulatory requirements for
PASS would result in additional changes to TS such as [e.g., the
renumbering of sections or pages or the removal of references]. The
changes are included in the licensee's application to revise the TS in
order to take advantage of the CLIIP. The staff has reviewed the
changes and agrees that the revisions are necessary due to the removal
of the TS section on PASS. The changes do not revise technical
requirements beyond that reviewed by the NRC staff in connection with
the supporting topical reports or the preparation of the TS improvement
incorporated into the CLIIP.
(B) The TS include an administrative requirement for a program to
minimize to levels as low as practicable the leakage from those
portions of systems outside containment that could contain highly
radioactive fluids during a serious transient or accident. The program
includes preventive maintenance, periodic inspections, and leak tests
for the identified systems. PASS is specifically listed in TS [5.5.2]
as falling under the scope of this requirement. The applicability of
this specification depends on whether or not PASS is maintained as a
system that is a potential leakage path.
[Note that several options (see following) exist for handling the
impact that eliminating PASS requirements would have on the
specification for the program to control leakage outside
containment]
(i) The licensee has stated that a plant change would be
implemented such that PASS would not be a potential leakage path
outside containment for highly radioactive fluids (e.g., the PASS
piping that penetrates the containment would be cut and capped). The
modification would be made during the implementation period for this
amendment such that it is appropriate to delete the reference to PASS
in TS [5.5.2]. Requirements in NRC regulations (e.g., 10 CFR Part 50,
Appendix J) and other TS provide adequate regulatory controls over the
licensee's proposed modification to eliminate PASS as a potential
leakage path.
(ii) The licensee has stated that a plant change might be
implemented such that PASS would not be a potential leakage path
outside containment for highly radioactive fluids (e.g., the PASS
piping that penetrates the containment might be cut and capped). The
modification would not be made during
[[Page 49275]]
the implementation period for this amendment. The licensee has proposed
to add the following phrase to the reference to PASS in TS [5.5.2]:
``(until such time as a modification eliminates the PASS penetration as
a potential leakage path).''
The above phrase would make clear that TS [5.5.2] remains
applicable to the PASS as long as it is a possible leakage path and
reflects that the actual modification of the piping system may be
scheduled beyond the implementation period for this amendment.
Requirements in NRC regulations (10 CFR Part 50, Appendix J) and other
TS provide adequate regulatory controls over the licensee's
modification to eliminate PASS as a potential leakage path. Following
the modification to eliminate PASS as a potential leakage path, the
licensee may elect (in order to maintain clarity and simplicity of the
requirement) to revise TS [5.5.2] to remove the reference to PASS,
including the phrase added by this amendment.
(iii) The licensee has stated that the configuration of the PASS
will continue to be a potential leakage path outside containment for
highly radioactive fluids (e.g., the PASS piping will penetrate the
containment with valves or other components in the system from which
highly radioactive fluid could leak). The licensee has [not proposed to
change TS (5.5.2) or has changed TS (5.5.2) to revise the reference to
this system from PASS to ( )]. The staff agrees [that TS 5.5.2 is not
affected or that the change to revise the reference from PASS to ( )]
is acceptable. A separate amendment request will be required if the
licensee, subsequent to this amendment, decides to modify the plant to
eliminate this potential leakage path and proposes to change the
requirements of TS [5.5.2].
(C) [Note-optional section if licensee provides markup of affected
Bases pages] The elimination of PASS requires that the licensee revise
the discussion in the Bases section for TS [3.3.3, ``Post Accident
Monitoring Instrumentation'']. The current Bases mention the
capabilities of PASS as part of the justification for allowing both
hydrogen monitor channels to be out of service for a period of up to 72
hours. Although the licensee's application included possible wording
for the revised Bases discussion for TS [3.3.3], the licensee will
formally address the change to the Bases in accordance with [the Bases
Control Program or its administrative procedure for revising Bases].
The staff does not believe that the Bases change will require prior NRC
approval when evaluated against the criteria in 10 CFR 50.59,
``Changes, tests, and experiments,'' and, therefore, agrees that the
revision of the Bases to TS [3.3.3] should be addressed separately from
this amendment and should be included in a future update of the TS
Bases in accordance with [the Bases Control Program or the licensee's
administrative controls].
4.0 Verifications and Commitments
As requested by the staff in the notice of availability for this TS
improvement, the licensee has addressed the following plant-specific
verifications and commitments.
4.1 Each licensee should verify that it has, and make a regulatory
commitment to maintain (or make a regulatory commitment to develop and
maintain), contingency plans for obtaining and analyzing highly
radioactive samples of reactor coolant, containment sump, and
containment atmosphere.
The licensee has [verified that it has or made a regulatory
commitment to develop] contingency plans for obtaining and analyzing
highly radioactive samples from the RCS, containment sump, and
containment atmosphere. The licensee has committed to maintain the
contingency plans within its [specified document or program]. The
licensee has [implemented this commitment or will implement this
commitment by (specified date)].
4.2 Each licensee should verify that it has, and make a regulatory
commitment to maintain (or make a regulatory commitment to develop and
maintain), a capability for classifying fuel damage events at the Alert
level threshold (typically this is 300 Ci/ml dose equivalent
iodine). This capability may utilize the normal sampling system and/or
correlations of sampling or letdown line dose rates to coolant
concentrations.
The licensee has [verified that it has or made a regulatory
commitment to develop] a capability for classifying fuel damage events
at the Alert level threshold. The licensee has committed to maintain
the capability for the Alert classification within its [specified
document or program]. The licensee has [implemented this commitment or
will implement this commitment by (specified date)].
4.3 Each licensee should verify that it has, and make a regulatory
commitment to maintain (or make a regulatory commitment to develop and
maintain), the capability to monitor radioactive iodines that have been
released to offsite environs.
The licensee has [verified that it has or made a regulatory
commitment to develop] the capability to monitor radioactive iodines
that have been released to offsite environs. The licensee has committed
to maintain the capability for monitoring iodines within its [specified
document or program]. The licensee has [implemented this commitment or
will implement this commitment by (specified date)].
The NRC staff finds that reasonable controls for the implementation
and for subsequent evaluation of proposed changes pertaining to the
above regulatory commitments are provided by the licensee's
administrative processes, including its commitment management program.
Should the licensee choose to incorporate a regulatory commitment into
the emergency plan, final safety analysis report, or other document
with established regulatory controls, the associated regulations would
define the appropriate change-control and reporting requirements. The
staff has determined that the commitments do not warrant the creation
of regulatory requirements (items requiring prior NRC approval of
subsequent changes). The NRC staff has agreed that NEI 99-04, Revision
0, ``Guidelines for Managing NRC Commitment Changes,'' provides
reasonable guidance for the control of regulatory commitments made to
the NRC staff. (See letter dated March 31, 2000 from S. Collins,
Director of NRC's Office of Nuclear Reactor Regulation to to R. Beedle,
Nuclear Energy Institute (ADAMS Accession Number ML003696998)) The
commitments should be controlled in accordance with the industry
guidance or comparable criteria employed by a specific licensee. The
staff may choose to verify the implementation and maintenance of these
commitments in a future inspection or audit.
5.0 State Consultation
In accordance with the Commission's regulations, the [ ] State
official was notified of the proposed issuance of the amendments. The
State official had [(1) no comments or (2) the following comments--with
subsequent disposition by the staff].
6.0 Environmental Consideration
The amendments change a requirement with respect to the
installation or use of a facility component located within the
restricted area as defined in 10 CFR Part 20 and change surveillance
requirements. The NRC staff has determined that the amendments involve
no significant increase in the amounts and no
[[Page 49276]]
significant change in the types of any effluents that may be released
offsite, and that there is no significant increase in individual or
cumulative occupational radiation exposure. The Commission has
previously issued a proposed finding that the amendments involve no
significant hazards consideration, and there has been no public comment
on such finding (FR). Accordingly, the amendments meet 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 amendments.
7.0 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
amendments will not be inimical to the common defense and security or
to the health and safety of the public.
Proposed No Significant Hazards Consideration Determination
Description of Amendment Request: The proposed amendments delete
requirements from the Technical Specifications (and, as applicable,
other elements of the licensing bases) to maintain a Post Accident
Sampling System (PASS). Licensees were generally required to implement
PASS upgrades as described in NUREG-0737, ``Clarification of TMI [Three
Mile Island] Action Plan Requirements,'' and Regulatory Guide 1.97,
``Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess
Plant and Environs Conditions During and Following an Accident.''
Implementation of these upgrades was an outcome of the lessons learned
from the accident that occurred at TMI, Unit 2. Requirements related to
PASS were imposed by Order for many facilities and were added to or
included in the technical specifications (TS) for nuclear power
reactors currently licensed to operate. Lessons learned and
improvements implemented over the last 20 years have shown that the
information obtained from PASS can be readily obtained through other
means or is of little use in the assessment and mitigation of accident
conditions.
Basis for proposed no significant hazards consideration
determination: As required by 10 CFR 50.91(a), an analysis of the issue
of no significant hazards consideration is presented below:
Criterion 1--The Proposed Change Does Not Involve a Significant
Increase in the Probability or Consequences of an Accident Previously
Evaluated
The PASS was originally designed to perform many sampling and
analysis functions. These functions were designed and intended to be
used in post accident situations and were put into place as a result of
the TMI-2 accident. The specific intent of the PASS was to provide a
system that has the capability to obtain and analyze samples of plant
fluids containing potentially high levels of radioactivity, without
exceeding plant personnel radiation exposure limits. Analytical results
of these samples would be used largely for verification purposes in
aiding the plant staff in assessing the extent of core damage and
subsequent offsite radiological dose projections. The system was not
intended to and does not serve a function for preventing accidents and
its elimination would not affect the probability of accidents
previously evaluated.
In the 20 years since the TMI-2 accident and the consequential
promulgation of post accident sampling requirements, operating
experience has demonstrated that a PASS provides little actual benefit
to post accident mitigation. Past experience has indicated that there
exists in-plant instrumentation and methodologies available in lieu of
a PASS for collecting and assimilating information needed to assess
core damage following an accident. Furthermore, the implementation of
Severe Accident Management Guidance (SAMG) emphasizes accident
management strategies based on in-plant instruments. These strategies
provide guidance to the plant staff for mitigation and recovery from a
severe accident. Based on current severe accident management strategies
and guidelines, it is determined that the PASS provides little benefit
to the plant staff in coping with an accident.
The regulatory requirements for the PASS can be eliminated without
degrading the plant emergency response. The emergency response, in this
sense, refers to the methodologies used in ascertaining the condition
of the reactor core, mitigating the consequences of an accident,
assessing and projecting offsite releases of radioactivity, and
establishing protective action recommendations to be communicated to
offsite authorities. The elimination of the PASS will not prevent an
accident management strategy that meets the initial intent of the post-
TMI-2 accident guidance through the use of the SAMGs, the emergency
plan (EP), the emergency operating procedures (EOP), and site survey
monitoring that support modification of emergency plan protective
action recommendations (PARs).
Therefore, the elimination of PASS requirements from Technical
Specifications (TS) (and other elements of the licensing bases) does
not involve a significant increase in the consequences of any accident
previously evaluated.
Criterion 2--The Proposed Change Does Not Create the Possibility of a
New or Different Kind of Accident from any Previously Evaluated
The elimination of PASS related requirements will not result in any
failure mode not previously analyzed. The PASS was intended to allow
for verification of the extent of reactor core damage and also to
provide an input to offsite dose projection calculations. The PASS is
not considered an accident precursor, nor does its existence or
elimination have any adverse impact on the pre-accident state of the
reactor core or post accident confinement of radionuclides within the
containment building.
Therefore, this change does not create the possibility of a new or
different kind of accident from any previously evaluated.
Criterion 3--The Proposed Change Does Not Involve a Significant
Reduction in the Margin of Safety
The elimination of the PASS, in light of existing plant equipment,
instrumentation, procedures, and programs that provide effective
mitigation of and recovery from reactor accidents, results in a neutral
impact to the margin of safety. Methodologies that are not reliant on
PASS are designed to provide rapid assessment of current reactor core
conditions and the direction of degradation while effectively
responding to the event in order to mitigate the consequences of the
accident. The use of a PASS is redundant and does not provide quick
recognition of core events or rapid response to events in progress. The
intent of the requirements established as a result of the TMI-2
accident can be adequately met without reliance on a PASS.
Therefore, this change does not involve a significant reduction in
the margin of safety.
Based upon the reasoning presented above and the previous
discussion of
[[Page 49277]]
the amendment request, the requested change does not involve a
significant hazards consideration.
Dated at Rockville, Maryland, this 7th day of August, 2000.
For the Nuclear Regulatory Commission.
William D. Beckner,
Chief, Technical Specification Branch, Division of Regulatory
Improvement Programs, Office of Nuclear Reactor Regulation.
[FR Doc. 00-20419 Filed 8-10-00; 8:45 am]
BILLING CODE 7590-01-P