LR-N02-0343, Request for Change to Technical Specifications Revise Section 6.12, High Radiation Area.

Request for Change to Technical Specifications Revise Section 6.12, High Radiation Area.

ML023100560
Person / Time
Site:	Hope Creek
Issue date:	10/23/2002
From:	Garchow D Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LCR H02-014, LR-N02-0343, NUREG-1433
Download: ML023100560 (13)

Text

PSEG Nuclear LLC P 0 Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG OCT 2 3 2002 NuclearLLC LR-N02-0343 LCR H02-014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Gentlemen:

REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS REVISE SECTION 6.12, "HIGH RADIATION AREA" HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Pursuant to 10 CFR 50.90, PSEG Nuclear LLC (PSEG) hereby requests a revision to the Technical Specifications (TS) for Hope Creek Generating Station.

In accordance with I OCFR50.91 (b)(1), a copy of this submittal has been sent to the State of New Jersey.

The proposed change to the TS updates the reference to 10CFR20.203 with the corresponding reference to 10CFR20.1601 in conformance with NUREG-1 433.

PSEG Nuclear LLC has evaluated the proposeld changes in accordance with 10CFR50.91 (a)(1), using the criteria in 10CFR50.92(c) and has determined that this request involves no significant hazards considerations. An evaluation of the requested changes is provided in Attachment I to this letter. In addition, there is no significant increase in the amounts or types of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure. Consequently, the proposed amendment satisfies the criteria of 10CFR51.22 (c)(9) for categorical exclusion from the requirement for an environmental assessment. The marked up Technical Specification pages affected by the propcsed changes are provided in .

/4-UDI 95-2168 REV 7/99

Document Control Desk

'ZLCR H02-014 LR-N02-0343 OCT 2 3 200Z Approval of this proposed change is being requested by April 2003.

Ifyou have any questions or require additional information, please contact Mr.

Michael Mosier at (856) 339-5434.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 1101 i"?-- Sincerely D. Gar how Vice Pr sident-Operations Attachments (2) 2

Document Control Desk tLCR H02-014 OCT 2 3 2002 LR-N02-0343 C: Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. G. Wunder, Project Manager- Hope Creek U. S. Nuclear Regulatory Commission Mail Stop 08B3 Washington, DC 20555 USNRC Senior Resident Inspector- Hope Creek (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625 3

Document Control Desk LR-N02-0343

• Attachment I LCR H02-014 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 EVALUATION OF REVISIONS TO THE TECHNICAL SPECIFICATIONS (TS)

TO UPDATE TO NEW 10CFR PART 20

1. DESCRIPTIO N.................................................................. 2

2. PROPOSED CHANGE ...................................................... 2

3. BACKGROUND ............................................................... 2

4. TECHNICAL ANALYSIS .................................................... 3

5. REGULATORY SAFETY ANALYSIS .................................... 3 5.1 No Significant Hazards Consideration ..................... 3 5.2 Applicable Regulatory Requirements/Criteria ........... 4

6. ENVIRONMENTAL IMPACT EVALUATION ................................. 5

7. REFERENCES .................................................................. 5 1

Document Control Desk LRN-02-0343 Attachment I LCR H02-014 REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS TO REVISE SECTION 6.12, "HIGH RADIATION AREA"

1. DESCRIPTION The proposed changes to the Technical Specifications (TS) update the reference to 10CFR20.203 with the corresponding reference to 10CFR20.1601 in conformance with NUREG-1433 (reference 7.1). The new 10CFR Part 20 (reference 7.2) requirements became effective on June 20, 1991. Public Service Electric & Gas (PSEG) had previously elected not to convert to the new requirements since the existing requirements were retained in the Code of Federal Regulations and the associated TS requirements were determined to be more restrictive (reference 7.3). The proposed changes have been incorporated to maintain consistency between Hope Creek Generation Station and Salem Units 1 & 2 Administrative Controls TS.

2. PROPOSED CHANGE The proposed Technical Specification change will revise Hope Creek Technical Specification 6.12, "High Radiation Area" to be consistent with the Standard Technical Specifications General Electric Plants (NUREG-1433 Rev.2). In order to accommodate the additional material provided by this change two pages will be added to the section. These pages have been numbered 24a and 24b so as not to cause any change to the balance of the section.

3. BACKGROUND On September 8, 1999 the NRC issued amendment 121 Hope Creek Generating Station. This amendment revised the TS by relocating the procedural details of the Radiological Effluent Technical Specifications (RETS) to the Offsite Dose Calculation Manual. The TS were also revised to relocate the procedural details associated with solid radioactive wastes to the Process Control Program. In addition, the Administrative Controls section was revised to incorporate programmatic controls for radioactive effluents and environmental monitoring. These changes are consistent with the guidance provided in Generic Letter (GL) 89-01, "Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of the Procedural Details of RETS to the Offsite Dose Control Manual or to the Process Control Program."

The proposed change is similar to that approved on September 11, 2002 for Nine Mile Point Unit 1, Amendment 176, TAC No. MB2442.

2

Document Control Desk LRN-02-0343

- Attachment I LCR H02-014

4. TECHNICAL ANALYSIS TS 6.12 provides high radiation access control alte~rnatives pursuant to 10 CFR20.203 (c)(2) (to be revised to 10CFR20.1601 (c)). This specification has been significantly revised as a result of the changes to IOCFR20, the guidance provided in Regulatory Guide 8.38, "Control of Access to Radiation and Very High Radiation Areas in Nuclear Power Plants," and current industry technology in controlling access to high radiation areas. The proposed changes include capping dose rate to 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 with, and control of, workers in high radiation areas. These alternate controls relate to the protection of plant personnel from radiation hazards during normal plant operations. As such, the proposed changes have no impact on protection of the public from the consequences of any DBA or transient. The changes are consistent with NUREG- 1433,(reference 7.1) and provide acceptable alternate methods for controlling access to high radiation areas.

5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration PSEG Nuclear LLC has evaluated whether or not a significant hazards consideration is involved with-the proposed amendment by focusing on the three standards set forth in 1 OCFR50.92, "Issuance of amendment," as discussed below:

1. The proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes do not affect accident initiators or precursors and do not alter the design assumptions, conditions, configuration of the facility, or manner in which the plant is operated. The proposed changes do not alter or prevent the ability of structures, systems, or components to perform their intended safety function to mitigate the consequences of an initiating event within the acceptance limits assumed in the UFSAR. The proposed changes are administrative in nature. Technical Specification (TS) 6.12 will be updated to include the new 10CFR20 (effective 06/20/91) requirements. The proposed changes do not alter the conditions or assumptions in any of the previous accident analyses, and as a result, the radiological consequences associated with these analyses remain unchanged.

Therefore, the proposed changes will not involve a significant increase in the probability or consequences of an accident previously evaluated.

3

Document Control Desk LRN-02-0343 SAttachment I LCR H02-014

2. The proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not alter the design assumptions, conditions, configuration of the facility, or the manner in which the plant is operated.

The proposed changes are administrative in nature and the relocated procedural details do not change the level of programmatic controls and procedural details. Accordingly, the proposed changes do not create any new failure modes or limiting single failures associated with a plant structure, system, or component important to safety. Also, there will be no change in the types or increase in the amounts of any effluents released offsite.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment would not involve a significant reduction in the margin of safety.

The proposed changes do not impact equipment design or operation, nor do the changes affect any TS safety limits or safety system settings that could adversely affect plant safety. The proposed changes are administrative in nature. Technical Specification (TS) 6.12 will be updated to include the new 10CFR20 requirements (effective 06/20/91) and are in conformance with NUREG-1433. Furthermore, the proposed changes do not result in a change in the types or an increase in the amounts of any effluents released offsite.

Therefore, it is concluded that the proposed changes do not involve a significant reduction in a margin of safety.

5.2. Applicable Regulatory Requirements/Criteria PSEG has determined that the proposed changes to the TS are in compliance with the following regulatory criteria.

5.2.1 NUREG-1433, Revision 2, June 2001, "Standard Technical Specifications, General Electric Plants, BWR/4" 5.2.2 Title 10 Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation" 5.2.3 Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants" In conclusion, based on the considerations discussed above, (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.

4

Document Control Desk LRN-02-0343 1 SAttachment LCR H02-014

6. ENVIRONMENTAL IMPACT EVALUATION PSEG has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7. REFERENCES 7.1. NUREG-1433, Revision 2, June 2001, "Standard Technical Specifications, General Electric Plants, BWR/4" 7.2.1 OCFR Part 20, "Standards for Protection Against Radiation" 7.3. Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants" 7.4. LCR H99-02, March 29, 1999, "Radioactive Effluent Technical Specifications 5

Document Control Desk LRN-02-0343 2 LCR H02-014 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 REVISIONS TO THE TECHNICAL SPECIFICATIONS TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License NPF-57 are affected by this change request:

Technical Specification Page Section 6.12 6-24 6-24a added 6-24b added 1

ADMINISTRATIVE CONTROLS 6.12 HIGH RADIATION AREA 6.12.1 n lieu of the'l"'ntrol device" o "alarm~sigal" 1 equired by aragr h 20.2 (c) (2) :of ý CFR Part 2 , each high radi00ion area in w ch the tensit of radiatio is greater an 100 mrem/hr but less than 1 0 mre:/hr* sh 1 be barriloded and con icuously poste as a high radi ion area a entra e thereto s all be cont *1ed ork Pe t (RWP)**./Any individ by requir g issuance of or group of i;dividuals permi ed to enter adiation )

such ar as shall b provided wi or accompanie by one or more f the

a. r/

A r l~ation doseaente are iation moni .

ring device which continuousl indicates the /X

b. A radiation onitoring devi which contin usly integrateg /he radiation se rate i lth area and ala when a preset tegrated dose is ceived. Ent nto such area with thi monit ing device estbsshed and pers el nave been ade knowledgea e of them. /

c. A adiation prote ion qualified ndividual (i. ., qualified in ar otProtect Supervisor t he RWoP.t i ccessible Amendmentrm a on l e HP

/body could t2 rev nIh oeget hn10 epoie with lockedost rvn nuhrz nradtekssalb maintai unet tsrtvcorloth2n erda'npoeto so.Dosh iSuper oro uyaa7i

• • Radi iaion protect ion p rsnnlorcedrsne escoted radia by ion protecaon S°reaspemonneoin access shllbe eronlitc wphfom h aiainl isW uancsibe frequremn psthve uring Sof the body ldrcie11huadoei eso10ttae

/located roaneoth witnlreae rvil asindradiation-uha ea h otnet hr oecoueeit t ey reqetyectionduiesbyprovided for purp soflcigannoecoue nbresnbycsrce on theintin high 'daara, ethtae rnadia on aotereas.ns h fSberpdofcopcosypsd, 61., ra

'radiation p cinpoeuet rvd oii epsr o ooe Sthe activitie within the area.

ýMeasure nt made at 18 incs from source of rdioactivity*. /

S**Radi ~ion protection p onlo eson sotdb radia 'on protec on Spe onnel shall be e p rmteRPi nereqirement/ uring the/

\ rfo-rmance of the' a sg e ai t o o e t o uties,i provided t ey HOPE CREEK 6-24 Amendment No. '

" I I ADMINISTRATIVE CONTROLS 6.12 HIGH RADIATION AREA As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:

6.12.1 High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation

a. Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b. Access to, and activities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures and personnel continuously escorted by such individuals may be exempted from the rcqui,.rament for an RWP or equivalent while performing their assigned duties provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.

d. Each individual or group entering such an area shall possess:

1. A radiation monitoring device that continuously displays radiation dose rates in the area; or

2. A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or

4. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, (i) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or HOPE CREEK 6-24 Amendment No.

(ii) Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.

e. Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.

6.12.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation, but less than 500 rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation

a. Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and, in addition:

1. All such door and gate keys shall be maintained under the administrative control of the shift supervisor, radiation protection manager, or his or her designee.

2. Doors and gates shall remain locked except during periods of personnel or equipment entry or exit.

b. Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided that they are otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.

d. Each individual or group entering such an area shall possess:

1. A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or HOPE CREEK 6-24a Amendment No.

2. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by. radiation protection personnel res;onsible for controlling personnel radiation etpostre within the area with the means to communicate with and control every individual in the area, or

3. A self-rea6ing dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, (i) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii) Be under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area.

4. In those cases where options (2) and (3), above, are irmpractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle, a radiation monitoring device that continuously displays radiation dose rztes in the area.

e. Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. This dose rate determination, knowledge, and pre-job briefing does not require documentation prior to initial entry.

f. Such individual areas that are within a larger area where no enclosure exists for the purpose of locking and where no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate, nor continuously guarded, but shall be barricaded, conspicuously posted, and a clearly visible flashing light shall be activated at the area as a warning device.

HOPE CREEK 6-24b Amendment No.