B13155, Application for Amends to Licenses DPR-61,DPR-21 & DPR-65, Revising Tech Spec Re Admin Controls in High Radiation Area

Application for Amends to Licenses DPR-61,DPR-21 & DPR-65, Revising Tech Spec Re Admin Controls in High Radiation Area

ML20245F239
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	04/25/1989
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245F241	List: B13155, Application for Amends to Licenses DPR-61,DPR-21 & DPR-65, Revising Tech Spec Re Admin Controls in High Radiation Area ML20245F258
References
B13155, NUDOCS 8905020308
Download: ML20245F239 (4)

Text

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,, "Z" "!!/"~, (203) 685-5000 April 25, 1989 Qpcjtel Nos. 50-213 50-245 50-336 B13}5!! j Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Proposed Revision to Technical Specifications Administrative Controls--Hiah Radiation Area Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear energy Company (NNEC0) hereby propose amending Operating License Nos. DPR-61, DPR-21 and DPR-65 by incorporating the changes identified in Attachment Nos. I, II and III into the plant Technical Specifications for the Haddam Neck Plant and Millstone Unit Nos. I and 2, respectively.

Discussion Hiah Radiation Area In order to provide an improved and consistent program for high radiation areas, Connecticut Yankee Atomic Power Company and Northeast Nuclear Energy Company are proposing to specify the current methodology used to determine j locked high radiation areas. The proposed wording is identical to the Millstone No. 3 Technical Specification for measuring dose 18 inches frcm '

the source This practice is not precluded by the Technical Specifications of the Haddam Neck Plant or Millstone Unit Nos. I and 2 since the distance from the source of the " greater than 1000 mR/h" reading is not specified.

This application enhances the radiological control program at Haddam Neck and Millstone plants by providing more appropriate controls for these areas. In addition, it provides uniformity for the determination of locked high radia-tion areas at all four of our nuclear plants.

(1) E. J. Mroczka letters to Document Control Desk, dated April 22, 1988 and July 27,1988.

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U.S. Nuclear Regulatory Commission B13155/Page 2 April 25, 1989 There are three distinct pa ts to this change.

o The first paragraph provids a specific interpretation of the High Radiation Area definitions in 10CrR20.202 and 20.203. "An area in which a major portion of the body could receive a dose of..." is now defined as the dose rate as measured at 45 cm (18 inches) from the source. The concept of using a general area dose rate and the 18-inch distance is not new. This has been an accepted practice at CYAPC0 and NNEC0 and in the industry. Additionally, the NRC has endorsed this interpretation by approval of Technical Specification amendments, specifically Millstone Unit No. 3.

o lhe change increases Radiation Work Permit requirements for entry into locked High Radiation areas with dose rates > 1,000' mR/h by requiring maximum stay time limits or continuous surveillance.

1 o And, finally, the change allows an alternative to enclosing and locking l 1crge areas with dose rates > 1,000 mR/h and in which an enclosure cannot' I be reasonably constructed. It allows the use of barricades, postings, and flashing lights. The " reasonably constructed" terminology has  !

already been misused by some plants according to NRC Information Notice 1 88-79. However, as a matter of practice, NRC Information Notices are routed to the Health Physics Supervisors when Health Physics issues are involved. This action should preclude misuse or misunderstandings of this portion of the change to ensure that our control of High Radiation Areas is responsive to the concerns of Information Notice 88-79.

In addition, these changes will establish consistency between the Technical  !

Specification requirements for the Haddam Neck Plant and Millstone Unit Nos.

1, 2, and .i.

Significant Hazards Consideration CYAPCC and NNECO have reviued the proposed changes in accordance with 10CFR5s.92 and have concluded that they do not involve a significant hazards consideration in that these changes would not:

1. Involve a significant increase in the probability of occurrence or consequences of an accident previously analyzed. These changes are consistent with NRC Standard Technical Specification guidance and Infor-mation Notice 88-79. Our current practice of specifying the measurement distance reduces the possibility of overexposure. . The proposed changa will specify this practice in the Technical Specifications. The proposed change also increases the requirements for entry into locked high radia-tion areas. Since there are no changes to the way the plant is operated, the probability of occurrence or consequences.of an accident previously analyzed is not increased.

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U.S. Nuclear Regulatory Commission B13155/Page 3 .

April 25, 1989 1

2. Create the possibility of a new or different kind of accident from any previously analyzed. The change allows an alternative to enclosing and  !

. locking large areas with dose rate > 1,000 mR/h and in which an enclosure.

cannot be reasonably constructed. It allows the use of barricades,. l postings, and flashing lights. The proposed change will incorporate the 1 current- practice of specifying the measurement distance from the radia-tion source to determine dose rates. The change will also increase-requirements for entry into locked high radiation areas. Since there are no changes in the way the plant is operated, the potential 'for an unanalyzed accident is not created. No new failure modes are introduced.

3. Involve a significant reduction in the margin of safety. Since the I proposed changes do not affect the consequences of any accident previous- 'l ly analyzed, there is no reduction in the margin of safety. The changs .i increases Radiation Work Permit requirements for entry .into locked High l Radiation areas with dose rates > 1,000 mR/h by requiring maximum stay time limits or continuous surveillance. The change allows an alternative ,

to enclosing and locking large areas .with dose. rate > 1,000 mR/h and in which an enclosure cannot be reasonably constructed. It allows the use of barricades, postings, and flashing lights. The proposed change will incorporate the current practice of specifying the measurement distance from the radiation source to determine dose rates. l Moreover, the Commission has provided guidance concerning the Application of Standards in 10CFR50.92 by providing certain examples (March 6, 1986, 51FR7750) of amendments that are considered not likely to involve a signifi-  !

cant hazards consideration. These changes are enveloped by Example (ii), a change that constitutes an additional limitation, restriction or control not presently included in the Technical Specifications, a more stringent surveil- J lance requirement. In fact, the proposed changes increase requirements for entry into locked High Radiation Areas. The change allows an alternative to enclosing and locking large areas with dose rate > 1,000 mR/h and in which an enclosure cannot be reasonably constructed. It allows the use of barricades, postings, and flashing lights. The proposed change will incorporate the current practice of specifying the measurement distance from the radiation source to determine dose rates, Based upon the information contained in this submittal and the environmental assessment for the Haddam Neck Plant and Millstone Unit Nos. I and 2, there are no significant radiological or nonradiological impacts associated with the proposed action, the proposed license amendment will not have a significant effect on the quality of the human environment.

The Haddam Neck Plant and Millstone Site Nuclear Review Boards have reviewed and approved the attached proposed revisions and have concurred with the above determinations.

In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amndment.

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U.S. Nuclear Regulatory Commission B13155/Page 4 April 25, 1989 These proposed changes are not required to support continued plant operation and can be effective upon issuance. Therefore, no schedule for amendment issuance has been proposed.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NOP.THEAST NUCLEAR ENERGY COMPANY t $W E.yMPoczka f/

W Senior Vice President r.c : Kevin McCarthy, Director Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager,. Millstone Unit No. 1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2-A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 J. T. Shediosky, Senior Resident Inspector, Haddam Neck Plant STATE OF CONNECTICUT) ,

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COUNTY OF HARTFORD )

Then personally appeared before me, E. J. Mroczka, who being duly sworn, did 1 state that he is Senior Vice President of Connecticut Yankee Atomic Power Company and Northeast Nuclear Energy Company, Licensees herein, that he 'is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.

Notary Publiit 6 i , W RHfE5 MARai 31,1991 I-

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