LIC-12-0161, OPPD Response to NRC Request for Additional Information (RAI) Regarding Miscellaneous Radioactive Material Sources License Amendment Request

OPPD Response to NRC Request for Additional Information (RAI) Regarding Miscellaneous Radioactive Material Sources License Amendment Request

ML12306A248
Person / Time
Site:	Fort Calhoun
Issue date:	10/31/2012
From:	Prospero M Omaha Public Power District
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
LIC-12-0161
Download: ML12306A248 (3)

Text

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October 31, 2012 LlC-12-0161 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington , D.C. 20555

References:

1. Docket No. 50-285

2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk),

"License Amendment Request (LAR) 12-02, Proposed Change to Relocate Operating and Surveillance Requ.irements for Technical Specifications 2.17 and 3.13 Concerning Miscellaneous Radioactive Material Sources," dated March 9, 2012 (LlC-12-0027)

3. Letter from NRC (L. E. Wilkins) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No.1 - Request for Additional Information Regarding License Amendment Request to Relocate Operating and Surveillance Requirements for Technical Specifications 2.17 and 3.13 Concerning Miscellaneous Radioactive Material Sources (TAC ME8220)," dated October 24, 2012 (ML12284A101) (NRC-12-0098)

Subject:

OPPD Response to NRC Request for Additional Information (RAI) Regarding Miscellaneous Radioactive Material Sources License Amendment Request In Reference 3, the NRC requested additional information regarding the Omaha Public Power District's (OPPD) license amendment request (Reference 2) relocating Technical Specification (TS) requirements for miscellaneous radioactive material sources to the Updated Safety Analysis Report. OPPD's response is attached .

If you should have questions, please contact Mr. Bill Hansher at (402) 533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 31, 2012 .

Sincerely, Michael J. Prospero Plant Manager MJPIDMB/mle Attachment Employment with Equal Oppor1unity

LIC-12-0161 Attachment Page 1 REQUEST FOR ADDITIONAL INFORMATION FORT CALHOUN STATION, UNIT NO. 1 MISCELLANEOUS RADIOACTIVE MATERIAL SOURCES LAR By letter dated March 9, 2012, Omaha Public Power District (the licensee) requested an amendment (LAR) to the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No.1. The proposed amendment would relocate Technical Specifications (TS) Limiting Condition of Operation (LCO) 2.17, Miscellaneous Radioactive Material Sources, and the associated surveillance requirement (SR) 3.13, Radioactive Material Sources Surveillance, from the FCS TS. NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Revision 3, does not contain a TS or SR for radioactive source surveillance.

The NRC staff has determined that the information specified below is needed for the staff to complete its evaluation.

NRC Question 1:

Section 4.1.3 of the LAR [License Amendment Request] lists two references as approved Methodologies - Regulatory Guide (RG) 8.21, Revision 1, October 1979 and NUREG-1556, Volume 11. Please identify the specific guidance in these two documents that are being referenced. In addition, please verify that the guidance in RG 8.21 for leak testing sources will be incorporated into the FSAR.

OPPD Response Amendment 11, issued February 4, 1976, placed Limiting Condition for Operation (LCO) 2.17 and Surveillance Requirement (SR) 3.13 into Facility Operating License No. DPR-40. OPPD requested those Technical Specification (TS) changes to comply with a letter from the Atomic Energy Commission (AEC) dated December 16, 1974 (Reference 1). The AEC letter proposed a more generalized approach for nuclear power plants regarding receipt, possession and use of byproduct, source and special nuclear material that was consistent with the provisions of Regulatory Guide (RG) 1.70.3, Radioactive Materials Safety for Nuclear Power Plants, dated February 1974.

However, RG 1.70.3 is no longer an active Regulatory Guide. Regulatory Guide 8.21 and NUREG-1556, Volume 11 were listed as approved methodologies because of their general applicability to the evaluation of radiation hazards associated with the production, use, release, disposal, or presence of radioactive materials or other sources of radiation whether at a power reactor like FCS or at a facility processing byproduct material or manufacturing such material for distribution.

LIC-12-0161 Attachment Page 2 For example, RG 1.70.3 dated November 1974, references several Occupational Health (Division 8) Regulatory Guides including RG 8.10, Operating Philosophy for Maintaining Occupational Exposure as Low as is Reasonably Achievable. RG 8.21 also references RG 8.10 because keeping radiation exposure ALARA (as low as is reasonably achievable) is as critical at facilities processing byproduct material or manufacturing such material for distribution as it is at power reactors.

As shown in the markup provided with the LAR, OPPD is relocating TS 2.17 and SR 3.13, which have requirements for leak testing of byproduct, source, and special nuclear materials to Section 11.2 of the Updated Safety Analysis Report. It is unnecessary to incorporate RG 8.21 guidance concerning leak testing of sources into the USAR because other than minor editorial changes to meet the format of the USAR, the requirements of the LCO and SR are unchanged from those requested of OPPD by the AEC in its 1974 letter (Reference 1). Once relocated to the USAR, future changes are subject to the controls of 10 CFR 50.59, which ensures that if necessary, NRC approval is obtained beforehand.

The Final Commission Policy Statement on Technical Specifications for Nuclear Power Reactors, dated July 22, 1993 (Reference 2), concluded that those existing TS requirements, which do not satisfy the screening criteria specified in regulation 10 CFR 50.36, may be deleted from the TS, and the requirements established in licensee-controlled documents, subject to the controls of 10 CFR 50.59. The miscellaneous radioactive material sources LCO and SR do not meet any of the screening criteria of 10 CFR 50.36(c)(2)(ii), which is supported by the absence of these requirements in NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants.

NRC Question 2 Please verify that the text to be added to the FSAR will be contained in Chapter 16 as part of the Technical Requirements Document.

OPPD Response OPPD has custom TS and does not have a Technical Requirements Document (Manual). As stated above, the changes will be incorporated into USAR Section 11.2.

References

1. Letter from NRC (G. Lear) to OPPD (J. L. Wilkins), Information Regarding Application for License Amendment Regarding Special Nuclear, Byproduct, and Source Material, dated December 16, 1974 (NRC-74-0089).

2. NRC "Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors" (58 FR 39132, dated July 22, 1993).