ML021210229

Email - Proposed RAI Re Proposed RETS Amendment

ML021210229
Person / Time
Site:	Nine Mile Point
Issue date:	04/30/2002
From:	Tam P NRC/NRR/DLPM/LPD1
To:	Dosa J Niagara Mohawk Power Corp
Tam P, NRR/DLPM, 415-1451
References
TAC MB2442
Download: ML021210229 (3)

Text

From: Peter Tam To: INTernet:dosaj@nimo.com; INTernet:leonardm@nimo.com; internet:wolniakd@nimo.com Date: 4/30/02 10:41AM

Subject:

Proposed RAI re. proposed RETS amendment (TAC MB2442)

John:

After our telecon of 4/10/02, we revised our comments on your application. We propose to issue these revised comments (below in italics) as an RAI:

(1) Proposed Technical Specifications (TS) 6.12.1.d.1 Please provide justification for the use of the underlined words "radiation monitoring and indicating device" in lieu of the words "[a] radiation monitoring device that continuously displays radiation dose rates in the area" as provided in NUREG-1433, "Standard Technical Specifications for General Electric Nuclear Plants, BWR/4 and BWR/6," Revision 1.

(2) Proposed TS 6.12.1.d.2 Provide justification for the use of the underlined words "alarming dosimeter" in lieu of the words "[a] radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the devices dose alarm setpoint is reached," as provided in NUREG-1433, Revision 1.

(3) Proposed TS 6.12.1.d.4(b)

The NRC has provided guidance in NUREG-1433, Revision 1, to licensees on acceptable methods to control access to high radiation areas in lieu of the requirement in subpart G of 10 CFR Part 20. Section 5.7.2.c of NUREG-1433 states that "An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area...."

In addition, Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," Section B.1.4, provides the following guidance:

"Good communication is essential among all departments concerned with entry into high and very high radiation areas to prevent excessive and unwarranted radiation exposures."

"The access control program should include procedures and provision for the use of equipment to ensure adequate communication."

Please provide information (procedures, administrative controls, etc.) demonstrating that "positive control within the area" is maintained.

(4) Proposed TS 6.12.2.a and TS 6.12.2.1.2 NUREG-1433, Revision 1, Section 5.7.2 provides this guidance "....areas with radiation levels 1000 mrem/hr shall be provided with locked or continuously guarded doors...."

It is the NRC staffs regulatory position that the word "continuously" be inserted in the proposed TS.

If you want, we can have another telecon to discuss these revised comments. Please tell me what you want us to do with these comments. Thanks.

Peter S. Tam, Senior Project Manager Project Directorate I-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation e-mail: pst@nrc.gov Tel.: 301-415-1451 CC: Audrey Hayes Mail Envelope Properties (3CCEAD2A.501 : 10 : 20510)

Subject:

Proposed RAI re. proposed RETS amendment (TAC MB2442)

Creation Date: 4/30/02 10:41AM From: Peter Tam Created By: PST@nrc.gov Recipients Action Date & Time nimo.com Transferred 04/30/02 10:41AM dosaj (INTernet:dosaj@nimo.com) leonardm (INTernet:leonardm@nimo.com) wolniakd (internet:wolniakd@nimo.com) nrc.gov owf2_po.OWFN_DO Delivered 04/30/02 10:42AM ACH2 CC (Audrey Hayes) Opened 04/30/02 05:17PM Post Office Delivered Route nimo.com INTernet owf2_po.OWFN_DO 04/30/02 10:42AM nrc.gov Files Size Date & Time MESSAGE 4477 04/30/02 10:41AM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard

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