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Category:Letter type:E
MONTHYEARE910-06-003, Experimental Corporation, Cancellation of Quality Assurance Program for Radioactive Material Packages No. 09012006-03-13013 March 2006 Experimental Corporation, Cancellation of Quality Assurance Program for Radioactive Material Packages No. 0901 E910-06-002, Experimental Corporation Indemnity Agreement2006-01-16016 January 2006 Experimental Corporation Indemnity Agreement E910-05-068, Experimental Corporation, Response to Additional Comments on Snec Final Status Survey Reports2005-09-29029 September 2005 Experimental Corporation, Response to Additional Comments on Snec Final Status Survey Reports E910-03-035, Experimental Corporation (Snec) FSS Report for Cv Interior, 774' Elev and Below, Revision 1, Erratum2005-09-17017 September 2005 Experimental Corporation (Snec) FSS Report for Cv Interior, 774' Elev and Below, Revision 1, Erratum E910-05-061, Records Required to Be Forwarded to NRC Region 1 Office Prior to Termination of the Saxton Nuclear Experimental Corporation Plant License2005-09-15015 September 2005 Records Required to Be Forwarded to NRC Region 1 Office Prior to Termination of the Saxton Nuclear Experimental Corporation Plant License E910-05-060, Experimental Corporation (Snec) Application for Termination of License2005-09-15015 September 2005 Experimental Corporation (Snec) Application for Termination of License E910-05-064, Experimental Corporation 2005 Radiological Environmental Monitoring Report2005-09-15015 September 2005 Experimental Corporation 2005 Radiological Environmental Monitoring Report E910-05-062, 2005 Annual Radioactive Effluent Releases Report for Saxton Nuclear Experimental Corporation (Snec)2005-09-15015 September 2005 2005 Annual Radioactive Effluent Releases Report for Saxton Nuclear Experimental Corporation (Snec) E910-05-066, Experimental Corporation Response to Comments on Snec Final Status Survey Reports2005-09-0808 September 2005 Experimental Corporation Response to Comments on Snec Final Status Survey Reports E910-05-049, Experimental Corporation, FSS Report for Open Land Area OL22005-07-27027 July 2005 Experimental Corporation, FSS Report for Open Land Area OL2 E910-05-048, Transmittal of Saxton Nuclear Experimental Corporation FSS Report for OL3 Paved Surfaces and Concrete2005-07-27027 July 2005 Transmittal of Saxton Nuclear Experimental Corporation FSS Report for OL3 Paved Surfaces and Concrete E910-05-047, Experimental Corp (Snec) FSS Report for Ssgs Seal Chamber Roofs2005-07-27027 July 2005 Experimental Corp (Snec) FSS Report for Ssgs Seal Chamber Roofs E910-05-051, Transmittal of Saxton Nuclear Experimental Corporation (Snec), FSS Report for Residual Macadam in OL12005-07-27027 July 2005 Transmittal of Saxton Nuclear Experimental Corporation (Snec), FSS Report for Residual Macadam in OL1 E910-05-050, Transmittal of Saxton Nuclear Experimental Corp FSS Report for Residual Concrete in OL12005-07-27027 July 2005 Transmittal of Saxton Nuclear Experimental Corp FSS Report for Residual Concrete in OL1 E910-05-043, Submittal of Saxton Nuclear Experimental Corp FSS Report for Ssgs Structural Surfaces - Intake Tunnel2005-07-26026 July 2005 Submittal of Saxton Nuclear Experimental Corp FSS Report for Ssgs Structural Surfaces - Intake Tunnel E910-05-041, Transmittal of Saxton Nuclear Experimental Corporation (Snec) FSS Report for Open Land Area OL1 - Soils2005-07-26026 July 2005 Transmittal of Saxton Nuclear Experimental Corporation (Snec) FSS Report for Open Land Area OL1 - Soils E910-05-044, Transmittal of Saxton Nuclear Experimental Corp FSS Report for Ssgs Structural Surfaces - Discharge Tunnel2005-07-26026 July 2005 Transmittal of Saxton Nuclear Experimental Corp FSS Report for Ssgs Structural Surfaces - Discharge Tunnel E910-05-042, Transmittal of FSS Report for OL7 - Paved Surfaces and Concrete2005-07-26026 July 2005 Transmittal of FSS Report for OL7 - Paved Surfaces and Concrete E910-05-013, Submittal of Saxton Nuclear Experimental Corporation, FSS Report for Cv Yard Excavation - Soil and Structural Remnants2005-07-26026 July 2005 Submittal of Saxton Nuclear Experimental Corporation, FSS Report for Cv Yard Excavation - Soil and Structural Remnants E910-05-045, Experimental Corporation (Snec) FSS Report for - Ssgs Structural Surfaces - Cv Steam Tunnel2005-07-25025 July 2005 Experimental Corporation (Snec) FSS Report for - Ssgs Structural Surfaces - Cv Steam Tunnel E910-05-038, FSS Report for Ssgs Seal Chambers2005-07-22022 July 2005 FSS Report for Ssgs Seal Chambers E910-05-036, Submittal of Final Status Survey Report for Saxton Nuclear Experimental Corporation, Saxton Steam Generating Station Structural Surfaces - Firing Aisle SS132005-07-22022 July 2005 Submittal of Final Status Survey Report for Saxton Nuclear Experimental Corporation, Saxton Steam Generating Station Structural Surfaces - Firing Aisle SS13 E910-05-035, Final Status Survey Report for Saxton Nuclear Experimental Corporation Open Land Area OL72005-07-22022 July 2005 Final Status Survey Report for Saxton Nuclear Experimental Corporation Open Land Area OL7 E910-05-003, Experimental Corporation Final Status Survey Report for OL6 and OL102005-07-14014 July 2005 Experimental Corporation Final Status Survey Report for OL6 and OL10 E910-05-031, Transmittal of Saxton Nuclear Experimental Corporation (Snec) FSS Report for Survey of Remediated Soils2005-07-14014 July 2005 Transmittal of Saxton Nuclear Experimental Corporation (Snec) FSS Report for Survey of Remediated Soils E910-05-028, Transmitting Saxton Nuclear Experimental Corporation (Snec) 2004 Annual Report2005-06-28028 June 2005 Transmitting Saxton Nuclear Experimental Corporation (Snec) 2004 Annual Report E910-05-023, Submittal of Final Status Survey Report for Saxton Nuclear Experimental Corporation Fences MA92005-06-22022 June 2005 Submittal of Final Status Survey Report for Saxton Nuclear Experimental Corporation Fences MA9 E910-05-021, Experimental Corporation, Revision 5 of the Snec Facility Quality Assurance Plan2005-06-15015 June 2005 Experimental Corporation, Revision 5 of the Snec Facility Quality Assurance Plan E910-05-007, Experimental Corporation (Snec), Management Change2005-05-19019 May 2005 Experimental Corporation (Snec), Management Change E910-05-011, Experimental Corporation, 2004 Radiological Environmental Monitoring Report2005-04-28028 April 2005 Experimental Corporation, 2004 Radiological Environmental Monitoring Report E910-05-009, Experimental Corporation - Transmittal of 2004 Annual Radioactive Effluent Releases Report2005-04-25025 April 2005 Experimental Corporation - Transmittal of 2004 Annual Radioactive Effluent Releases Report E910-04-018, Experimental Corporation - FSS Report for Snec Penelec Line Shack2004-06-29029 June 2004 Experimental Corporation - FSS Report for Snec Penelec Line Shack E910-04-017, Revised Decommissioning Report for the Saxton Nuclear Experimental Corporation and Financial Test Information2004-05-12012 May 2004 Revised Decommissioning Report for the Saxton Nuclear Experimental Corporation and Financial Test Information E910-04-015, Experimental Corporation (Snec), 2003 Annual Radioactive Effluent Releases Report2004-05-0303 May 2004 Experimental Corporation (Snec), 2003 Annual Radioactive Effluent Releases Report E910-04-016, Experimental Corporation (Snec), 2003 Radiological Environmental Monitoring Report2004-04-28028 April 2004 Experimental Corporation (Snec), 2003 Radiological Environmental Monitoring Report E910-04-006, Letter Transmitting Saxton Nuclear Experimental Corporation Biennial 10 CFR 50.59 Report and Updated Safety Analysis Report2004-03-18018 March 2004 Letter Transmitting Saxton Nuclear Experimental Corporation Biennial 10 CFR 50.59 Report and Updated Safety Analysis Report E910-04-004, Experimental Corporation 2003 Annual Report for 01/01/2003 - 12/31/20032004-01-29029 January 2004 Experimental Corporation 2003 Annual Report for 01/01/2003 - 12/31/2003 E910-03-048, Containment Vessel (Cv) Radiation Survey2003-12-22022 December 2003 Containment Vessel (Cv) Radiation Survey E910-03-041, Experimental Corp, FSS Report for Snec Cv Interior Above 774 Elev and Exterior2003-10-29029 October 2003 Experimental Corp, FSS Report for Snec Cv Interior Above 774 Elev and Exterior E910-03-038, Technical Specification Change Request No. 62, Rev.22003-09-30030 September 2003 Technical Specification Change Request No. 62, Rev.2 E910-03-031, FSS Report for Cv Interior, 774' Elev and Below, Revision 12003-09-0404 September 2003 FSS Report for Cv Interior, 774' Elev and Below, Revision 1 E910-03-019, 2002 Annual Report2003-04-30030 April 2003 2002 Annual Report E901-03-018, Radiological Environmental Monitoring Report2003-04-30030 April 2003 Radiological Environmental Monitoring Report E910-03-017, Annual Radioactive Effluent Releases Report2003-04-30030 April 2003 Annual Radioactive Effluent Releases Report E910-03-010, Decommissioning Reports for Three Mile Island Unit 2, & Saxton Nuclear Experimental Corporation2003-03-21021 March 2003 Decommissioning Reports for Three Mile Island Unit 2, & Saxton Nuclear Experimental Corporation E910-03-002, of Saxton Nuclear Experimental Corporation Facility Quality Assurance Plan2003-01-20020 January 2003 of Saxton Nuclear Experimental Corporation Facility Quality Assurance Plan E910-02-054, Experimental Corporation (Snec) Application for License Termination2002-12-16016 December 2002 Experimental Corporation (Snec) Application for License Termination E910-02-060, Shonka Report Submittal2002-12-16016 December 2002 Shonka Report Submittal E910-02-058, TS Change Request No.62, Rev.12002-12-0505 December 2002 TS Change Request No.62, Rev.1 E910-02-049, Submittal of Information to NRC in 08/29/02 Meeting, Revision 1 Re Updated License Termination Plan2002-10-10010 October 2002 Submittal of Information to NRC in 08/29/02 Meeting, Revision 1 Re Updated License Termination Plan 2006-03-13
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GPU Nuclear, Inc.
t Gi'i Three NuclearMile Island Station NUCLEAR Route 441 South Post Office Box 480 Middletown, PA 17057-0480 Tel 717-948-8461 E910-03-038 September 30, 2003 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Saxton Nuclear Experimental Corporation Facility (SNEC)
Operating License No. DPR4 Docket No. 50-146 Technical Specification Change Request No. 62, Rev. 2 Based on recent discussions with your staff GPU Nuclear believes it is necessary to clarify our intention with respect removal of the SNEC Facility Decommissioning Support Facility (DSF).
Technical Specification Change Request (TSCR) No. 62 was developed to reflect the site conditions that would exist following decontamination and NRC acceptance of the Final Status Survey of the SNEC Facility Containment Vessel (CV). At this point the NRC could issue a license amendment that would remove the term 'exclusion area" and any associated specifications from the License. As discussed in TSCR 62 removal of some portions of the DSF may also be required to remove the upper CV dome.
During planning of CV upper dome removal it became obvious that it will be necessary to remove the DSF to provide access to the CV Dome for welding lifting attachments to the dome and for set up of the crane needed to lift the dome. Based on GPU Nuclear's review of the Technical Specifications we believe removal of the DSF can proceed prior to approval of the TSCR SNEC Technical Specifications require the establishment of an Exclusion Area. As discussed in Technical Specification Change Request No. 62 the reason behind the establishment of an Exclusion Area is to prevent members of the public from inadvertent exposure to radiation in excess of 0.002 rem per hour.
The Exclusion Area Boundary at the Saxton Nuclear Experimental Corporation (SNEC) Facility is defined in Technical Specification Figure to consist as a minimum of the Reactor Containment Vessel and may extend to the SNEC outer security fence.
Technical Specification Section 1.0.5 defines the Exclusion Area as the area controlled for the purpose of security and access restrictions. Based on these requirements SNEC is given the flexibility to define which areas of the facility need to be controlled from an Exclusion Area standpoint Sections 1.1.3.2 and 1.1.3.3 specify Exclusion Area Controls for the Containment Vessel (CV) and the Decommissioning Support Facility (DSF).
This establishes an inherent conflict in that if the Exclusion Area is defined as the CV then there is no need for Exclusion Area Controls on the DSF except that specific Exclusion Area Controls are identified for the DSF in the Technical Specifications.
It is SNEC's position that if the Exclusion Area is defined as the CV then the Exclusion Area Controls specified for the DSF are not required as the underlying purpose of this requirement prevention of inadvertent exposure to radiation, is still being accomplished.
Similarly Sections 2.1.1 and 2.1.2 refer to a CV/DSB (i.e. Decommissioning Support Building a portion of the DSF) Ventilation System. As described The SNEC Facility Updated Safety Analysis Report (USAR) this system ventilates the DSB via an opening to the CV. Removal of the DSF would not degrade the ability to ventilate the CV. However as committed in TSCR 62 the DSF would not be removed until activities involving the packaging of radioactive materials that could cause a measurable release as defined in the Technical Specifications have been completed.
Thus based on the above it is GPU Nuclear's intention to remove the DSF following completion of:
- 1. Any activities involving the packaging of radioactive materials in the DSF that could cause a measurable release as defined in the Technical Specifications, and
- 2. Moving the exclusion area alarm from the DSF to the door between the CV and the DSF.
1 declare under penalty of perjury that the foregoing is true and correct.
Sincly Executed on463 Vice President, SNEC cc: Administrator, NRC Region I - Hubert J. Miller NRC Project Manager, NRR - Alexander X Adams NRC Project Scientist, Region I - Thomas F. Dragoun Chairman, Board of Supervisors, Liberty Township Chairman, Board of County Commissioners, Bedford County Director, Bureau of Radiation Protection, PA Department of Environmental Protection