ML030920457

Experimental Corporation, Issuance of Amendment No. 19 Removal of Containment Vessel Upper Dome

ML030920457
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	01/09/2004
From:	Alexander Adams NRC/NRR/DRIP/RNRP
To:	Kuehn G GPU Nuclear Corp
ADAMs A, NRC/NRR/DRIP/RNRP, 415-1127
References
TAC MB5029
Download: ML030920457 (30)

Text

January 9, 2004 Mr. G. A. Kuehn, Jr.

Vice President SNEC and Program Director SNEC Facility GPU Nuclear, Inc.

Route 441 South P.O. Box 480 Middletown, PA 17057-0480

SUBJECT:

SAXTON NUCLEAR EXPERIMENTAL CORPORATION AMENDMENT RE: REMOVAL OF CONTAINMENT VESSEL UPPER DOME (TAC NO. MB5029)

Dear Mr. Kuehn:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 19 to Amended Facility License No. DPR-4 for the Saxton Nuclear Experimental Facility. The amendment consists of changes to the technical specifications (TSs) in response to your application of April 22, 2002, as supplemented on December 5, 2002, and September 30 and December 22, 2003.

The amendment changes the TSs to allow the removal of the containment vessel (CV) upper dome. The amendment also adds the position of Vice-President GPU Nuclear Oversight to the organizational structure.

A copy of the safety evaluation supporting Amendment No. 19 is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Section New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No. 50-146

Enclosures:

1. Amendment No. 19

2. Safety Evaluation cc w/enclosures:

See next page

Saxton Nuclear Docket No. 50-146 Experimental Corporation cc:

Mr. Michael P. Murphy Bureau of Radiation Protection Department of Environmental Protection 13th Floor, Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mr. Jim Tydeman 1402 Wall Street Saxton, PA 16678 Mr. James H. Elder, Chairman Concerned Citizens for SNEC Safety Wall Street Ext.

Saxton, PA 16678 Mr. Ernest Fuller 1427 Kearney Hill Road Six Mile Run, PA 16679 Saxton Borough Council ATTN: Judy Burket 707 9th Street Saxton, PA 16678 Mr. David J. Thompson, Chair Bedford County Commissioners County Court House 203 South Juliana Street Bedford, PA 15522 Mrs. Alexa Cook, Chairman Huntingdon County Commissioners County Court House Huntingdon, PA 16652 Saxton Community Library P.O. Box 34 Saxton, PA 16678 Carbon Township Supervisors ATTN: Penny Brode, Secretary R. D. #1, Box 222-C Saxton, PA 16678 Hopewell Township - Huntingdon County Supervisors ATTN: Reba Fouse, Secretary RR 1 Box 95 James Creek, PA 16657-9512 Mr. D. Bud McIntyre, Chairman Broad Top Township Supervisors Broad Top Municipal Building Defiance, PA 16633 Mr. Don Weaver, Chairman Liberty Township Supervisors R. D. #1 Saxton, PA 16678 U.S. Army Corps of Engineers Baltimore District ATTN: S. Snarski/P. Juhle P.O. Box 1715 Baltimore, MD 21203 The Honorable Robert C. Jubelirer President Pro-Temp Senate of Pennsylvania 30th District State Capitol Harrisburg, PA 17120 Mr. James J. Byrne Three Mile Island Nuclear Generating Station P.O. Box 480 Middletown, PA 17057 Mr. Robert F. Saunders First Energy Corp.

76 South Main Street Akron, OH 44308 Ms. Mary E. OReilly First Energy Legal Department 76 South Main Street Akron, OH 44308

Mr. Manuel Delgado 2799 Battlefield Road Fishers Hill, VA 22626 Mr. Eric Blocher 216 Logan Avenue Wyomissing, PA 19610 Mr. David Sokolsky 1000 King Salmon Avenue Eureka, CA 95503 Mr. Gene Baker 501 16th Street Saxton, PA 16678 Mr. Dick Spargo 1004 Main Street Saxton, PA 16678 Mr. Mark E. Warner AmerGen Energy Co., LLC P.O. Box 480 Middletown, PA 17057 Mr. G. A. Kuehn, Jr.

Vice President SNEC and Program Director SNEC Facility GPU Nuclear, Inc.

P.O. Box 480 Middletown, PA 17057-0480 James Fockler, Chairman Saxton Citizens Task Force 1505 Liberty Street Saxton, PA 16678 Dr. Rodger W. Granlund Saxton Independent Inspector Radiation Safety Services 133 Old Main Road State College, PA 16801 Mr. Gareth McGrath Altoona Mirror 301 Cayuga Avenue Altoona, PA 16603 Dr. William Vernetson Director of Nuclear Facilities Department of Nuclear Engineering Sciences University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611 Mrs. Bunny Barker Box 143, RR 1 James Creek, PA 16657 Mr. Gary Leidich Executive Vice President First Energy Nuclear Operating Corp.

76 South Main Street Akron, OH 44308

Jan Mr. G.

Vice Pres Program D GPU Nuclear, Route 441 South P.O. Box 480 Middletown, PA 1705

SUBJECT:

SAXTON NUCL RE: REMOVAL OF CONTAIN (TAC NO. MB5029)

Dear Mr. Kuehn:

The U.S. Nuclear Regulatory Commission Amended Facility License No. DPR-4 for the S amendment consists of changes to the technica application of April 22, 2002, as supplemented on D December 22, 2003.

The amendment changes the TSs to allow the removal of t dome. The amendment also adds the position of Vice-Presid organizational structure.

A copy of the safety evaluation supporting Amendment No. 19 is also Issuance will be included in the Commissions biweekly Federal Registe Sincerely,

/RA/

Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Section New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No. 50-146

Enclosures:

1. Amendment No. 19

2. Safety Evaluation cc w/enclosures:

See next page DISTRIBUTION:

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ADAMS ACCESSION NO.: ML030920457 TEMPLATE #: NRR-106

• Please see previous concurrence OFFICE RNRP:LA TechEd RNRP:PM OGC RNRP:SC NAME

• EHylton:rdr

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• AAdams SUttal PMadden DATE 04/ 03 /03 03/ 10 /03 12/ 23 /03 01/ 05 /04 01/ 09 /04 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY

SAXTON NUCLEAR EXPERIMENTAL GPU NUCLEAR, INC.

DOCKET NO. 50-146 AMENDMENT TO AMENDED FACILITY LICENSE Amendment No. 19 License No. DPR-4 1.

The U.S. Nuclear Regulatory Commission (the Commission) has found A.

The application for an amendment to Amended Facility License No. DPR-4 fi the Saxton Nuclear Experimental Corporation and GPU Nuclear, Inc. (the licensee on April 22, 2002, as supplemented on December 5, 2002, and September 30 and December 22, 2003, conforms to the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the regulations of the Commission as stated in Chapter I of Title 10 of the Code of Federal Regulations (10 CFR);

B.

The facility will be possessed in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance that (i) the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) such activities will be conducted in compliance with the regulations of the Commission; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

This amendment is issued in accordance with the regulations of the Commission as stated in 10 CFR Part 51, and all applicable requirements have been satisfied.

2.

Accordingly, the licen indicated in the enclosure Facility License No. DPR-4 (2)

Technical Specifications The Technical Specifications contained Amendment No. 19, are hereby incorpora Nuclear shall possess the facility in accorda Specifications.

3.

This license amendment is effective as of the date FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Patrick M. Madden, Chief Research and Test Reactors Section New, Research and Test Reactors Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

Enclosure:

Appendix A, Technical Specifications Changes Date of Issuance: January 9, 2004

ENCLOSURE AMENDED FACILIT DOCKET NO. 50-146 Replace the following pages of A pages. The revised pages are iden indicating the areas of change.

Remove Insert 1

1 3

3 4

4 5

5 6

6 9

9 10 10 11 11 12 12 13 13 20 20

1.0 DEFINITIONS 1.0.1 CONTAINMENT VESSEL -

Term used to describe the vertical steel cylinder which housed the Saxton Nuclear Experimental Corporation Facility Nuclear Steam Supply System (NSSS) and related components, also known as the CV.

1.0.2 Deleted 1.0.3 DECOMMISSIONING ACTIVITIES -

The term DECOMMISSIONING ACTIVITIES describes all of those activities needed to decommission the SNEC Facility and return the site to unrestricted use. Examples of these activities include; PRODUCTION ACTIVITIES needed to conduct decommissioning such as physical dismantlement; radioactive waste preparation, treatment, packaging and shipment; radiation protection activities, construction and installation of support systems, structures and components, and final status survey.

1.0.4 Deleted 1.0.5 Deleted Amendment No. 19 January 9, 2004

1.0.11 PROCESS CONTROL PROGRAM (PCP) -

The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.

1.0.12 PRODUCTION ACTIVITIES -

PRODUCTION ACTIVITIES include all of the physical activities needed to conduct the decommissioning of the SNEC facility site. Included are such activities as the removal of systems, structures and components, demolition of structures and associated components, removal of contaminants to allow free release, excavation, trenching and removal of underground facilities.

These activities are a sub-set of DECOMMISSIONING ACTIVITIES.

1.0.13 RADIOACTIVE WASTE MANAGEMENT ACTIVITIES -

The term RADIOACTIVE WASTE MANAGEMENT ACTIVITIES is defined as those activities which involve the handling of radioactive waste materials.

1.0.14 Deleted 1.0.15 SITE BOUNDARY -

The SITE BOUNDARY used as the basis for the limits on the release of gaseous effluents is the line formed by a 200 meter radius from the center of the containment vessel.

Amendment No. 19 January 9, 2004

1.0.16 SNEC -

The term SNEC is an acronym for the Saxton Nuclear Experimental Corporation.

1.0.17 SUBSTANTIVE CHANGE(S) -

SUBSTANTIVE CHANGE(S) are those which affect the activities associated with a document or the documents meaning or intent. Examples of non-substantive changes are: (1) correcting spelling; (2) adding (but not deleting) sign-off spaces; (3) blocking in notes, cautions, etc.; (4) changes in corporate and personnel titles which do not reassign responsibilities and which are not referenced in the Technical Specifications; and (5) changes in nomenclature or editorial changes which clearly do not change function, meaning or intent.

1.0.18 UNRESTRICTED AREA -

An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY access to which is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the SITE BOUNDARY used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes.

As used here the term is used as it applies to radioactive effluents. The definitions as they apply to 10CFR Parts 20 and 100 still apply.

1.1 SITE 1.1.1 Location The Saxton Nuclear Experimental Corporation (SNEC) facility is on a 1.148 acre tract deeded from the Pennsylvania Electric Company to the SNEC. It is located within the property of the Pennsylvania Electric Company near the Borough of Saxton, Pennsylvania, in Liberty Township, Bedford County, Pennsylvania. The Pennsylvania Electric Company property consists of approximately 150 acres along the Raystown Branch of the Juniata River.

1.1.2 Deleted 1.1.3 Deleted 1.1.3.1 Deleted Amendment No. 19 January 9, 2004

1.1.3.2 Deleted 1.1.3.3 Deleted 2.0 PRINCIPAL ACTIVITIES Activities permitted at the SNEC facility shall include the routine and emergency inspections, maintenance associated with the possession of the SNEC facility, characterization activities and activities delineated in section 1.0.3, DECOMMISSIONING ACTIVITIES, of these Technical Specifications.

2.1 Limiting Conditions for Performing DECOMMISSIONING ACTIVITIES 2.1.1 During activities involving removal of the upper dome of the CV that have the potential to cause a MEASURABLE RELEASE to the environment of airborne radioactivity, appropriate ventilation will be operating in a manner such that the release pathway is via the monitored ventilation system exhaust.

2.1.2 When the ventilation exhaust is in operation, the exhaust monitoring instrumentation will be operated simultaneously. The ventilation system will be shutdown if the exhaust monitoring instrumentation is inoperable.

2.1.3 Verification by analysis that release criteria have been satisfied is required prior to making any batch release of liquid waste process effluent. Effluent release calculations will be made in accordance with the OFFSITE DOSE CALCULATION MANUAL.

3.0 ADMINISTRATIVE CONTROLS 3.1 Organization and Responsibilities GPU NUCLEAR has the responsibility for safely performing DECOMMISSIONING ACTIVITIES. Lines of authority, responsibility and communication are procedurally defined and established. The relationships shall be identified and updated, as appropriate, in organizational charts, departmental functional responsibility and relationship descriptions, job descriptions for key Amendment No. 19 January 9, 2004

personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the SNEC Facility USAR.

3.1.1 The GPU NUCLEAR Cognizant Officer is responsible for and provides full-time dedicated staff for the purpose of conducting all activities safely, effectively and in accordance with corporate policies, applicable laws, regulations, licenses and Technical Specifications (TSs).

3.1.2 The Program Director SNEC Facility is responsible for administration of all SNEC facility functions, for direction of all DECOMMISSIONING ACTIVITIES, and for assuring that the requirements of License No. DPR-4 and these TSs are implemented.

3.1.3 The SNEC Facility Site Supervisor provides on-site management and continuing oversight of PRODUCTION ACTIVITIES.

3.1.4 The Radiation Safety Officer (RSO) is responsible for the conduct and oversight of all SNEC radiation safety activities through implementation of the Radiation Protection Plan. All radiological controls personnel shall have stop work authority in matters relating to or impacting radiation safety.

3.1.5 The Group Radiological Controls Supervisor (GRCS) directly supervises radiation safety activities.

3.1.6 Other GPU Inc. personnel provide SNEC facility management with technical support, project management capabilities and manpower.

3.2 Facility Staffing Requirements:

3.2.1 Deleted 3.2.2 The RSO or a GRCS shall be present on site whenever PRODUCTION ACTIVITIES, maintenance, characterization and/or RADIOACTIVE WASTE MANAGEMENT ACTIVITIES are being performed in Radiologically Controlled Areas (RCAs).

Amendment No. 19 January 9, 2004

3.5.1.10 Records of the review activities performed in accordance with 3.5.1.2 through 3.5.1.7 shall be maintained in accordance with section 3.9.

3.5.2 Independent Safety Review 3.5.2.1 The GPU NUCLEAR Cognizant Officer is responsible for ensuring the independent safety review of the subjects described in section 3.5.2.3.

3.5.2.2 Independent safety review shall be completed by an individual or group not having direct responsibility for the performance of activities under review, but who may be from the same functionally cognizant organization as the individual or group performing the original work.

3.5.2.3 GPU NUCLEAR shall collectively have or have access to the experience and competence required to independently review subjects in the following areas:

• nuclear unit operations

• electrical, mechanical and nuclear engineering

• chemistry and radiochemistry

• metallurgy

• instrumentation and control

• radiological safety

• administrative controls and quality assurance practices

• other appropriate fields such as radioactive waste management.

3.5.2.4 Consultants may be utilized as determined by the GPU NUCLEAR Cognizant Officer to provide expert advice.

3.5.2.5 The following subjects shall be independently reviewed by Independent Safety Reviewers:

3.5.2.5.1 Written safety evaluations of changes in the facility and changes of procedures described in the Safety Analysis Report, and of tests or experiments not described in the Safety Analysis Report, which are completed without prior NRC approval under the provisions of 10 CFR 50.59(c). This review is to verify that such changes, tests or Amendment No. 19

January 9, 2004

experiments did not involve a change to the TS or require NRC approval pursuant to 10 CFR 50.59. Written safety evaluations associated with the direct performance of a change, test or experiment shall be completed prior to the initiation of the activity.

3.5.2.5.2 Proposed changes in procedures, in the facility or tests or experiments, any of which involves a change in the TS or require NRC approval pursuant to 10 CFR 50.59. Matters of this kind shall be reviewed prior to their submittal to the NRC.

3.5.2.5.3 Proposed changes to TS or license amendments shall be reviewed prior to submittal to the NRC for approval.

3.5.2.5.4 Violations, deviations and reportable events which require reporting to the NRC in writing. Such reviews are performed after the fact. Review of events covered under this subsection shall include results of any investigations to prevent or reduce the probability of recurrence of the event.

3.5.2.5.5 Written summaries of audit reports identified in section 3.5.4.

3.5.2.5.6 Any other matter involving the facility which a reviewer deems appropriate for consideration or which is referred to the independent reviewers.

3.5.2.6 The Independent Safety Reviewers shall either have a Bachelors Degree in Engineering or the Physical Sciences and five years professional level experience in the area being reviewed or have nine years of appropriate experience in the field of specialty. An individual performing reviews may possess competence in more than one specialty area. Credit toward experience will be given for advanced degrees on a one-for-one basis up to a maximum of two years.

3.5.2.7 Records of reviews encompassed in section 3.5.2.5 shall be maintained in accordance with section 3.9.

3.5.3 Inspection 3.5.3.1 Facility inspections shall be performed in accordance with approved procedures. The inspection activities shall include:

Amendment No. 19 January 9, 2004

a.

Deleted b.

Deleted c.

The station ventilation system effluent particulate monitor channel checks, source checks, channel test and channel calibration shall be performed at a frequency specified in the ODCM.

d.

The ventilation system HEPA Filter will be tested to verify efficiencies in accordance with the requirements of the ODCM.

3.5.4 Audits The audit function is independent of the SNEC facility management. Audits shall be performed by qualified individuals, as a minimum, for those activities designated within the scope of the SNEC facilitys Quality Assurance Program.

Audits are generally conducted biennially, however, frequency is based on the level of activity at the SNEC facility. Audits may also be performed at the request of the GPU NUCLEAR Cognizant Officer or Vice-President GPU Nuclear Oversight. Audits are performed in accordance with approved Quality Assurance Plan procedures. The audit procedures identify areas which may be included in the audit scope. Audit reports shall be forwarded to the GPU NUCLEAR Cognizant Officer and the Vice-President GPU Nuclear Oversight within 60 days of completion of the audit.

3.5.5 TMI-2/SNEC Oversight Committee 3.5.5.1 The TMI-2/SNEC Oversight Committee shall report to the Vice-President GPU Nuclear Oversight. The Committee will consist of at least four members. Membership will be on the recommendation of the Committee Chairman and approval of the Vice-President GPU Nuclear Oversight. Three members shall constitute a quorum.

3.5.5.2 It shall be responsible to provide independent overview and assessment of all matters with radiological safety implications relative to activities at the SNEC facility. The Committee will review proposed License and Technical Specification changes, DECOMMISSIONING ACTIVITIES, special nuclear and radioactive material activities, facility changes, radiological conditions, audit reports and NRC Inspection reports and corrective actions for deficiencies identified.

Amendment No. 19 January 9, 2004

3.5.5.3 Meetings shall be held at least three times per year.

3.5.5.4 Written minutes of all meetings shall be prepared and distributed to the Vice-President GPU Nuclear Oversight and the GPU NUCLEAR Cognizant Officer within 30 days of the meeting date.

3.6 Procedures, Programs and Manuals 3.6.1 Procedures 3.6.1.1 Activities which are designated as within the scope of the SNEC facilitys Quality Assurance Program shall be prescribed by written, reviewed and approved procedures of a type appropriate to the circumstances.

3.6.1.2 Written procedures shall be established, implemented and maintained for the activities listed below:

3.6.1.2.1 Characterization, decommissioning and maintenance activities determined to be within the scope of the QA program.

3.6.1.2.2 Access control, emergency actions (including fire protection program implementation), facility inspections and audits.

3.6.1.2.3 Radiological exposure control, survey activities and radwaste shipping and handling.

3.6.1.2.4 Activities which could result in a MEASURABLE RELEASE to the environment.

3.6.1.3 These procedures shall require that the following actions be taken:

3.6.1.3.1 All DECOMMISSIONING ACTIVITIES and maintenance work under Health Physics control shall be consistent with 10 CFR Part 20 requirements to minimize the radiation exposure of personnel and to prevent the release of radioactivity in excess of allowable limits to the environment.

3.6.1.3.2 All radiation surveys, tests, counting work, radiation exposure control measures and all other work performed in radiologically controlled areas shall conform with the requirements of the Radiation Protection Plan.

Amendment No. 19 January 9, 2004

3.6.1.3.3 Facility inspections shall meet specific requirements of section 3.5.3 of these TS.

3.6.1.4 These procedures and any subsequent revisions shall be prepared, reviewed and approved in accordance with the requirements of the applicable administrative procedure requirements prior to their initial use.

3.6.2 Programs The following programs shall be established, implemented, and maintained during DECOMMISSIONING ACTIVITIES:

3.6.2.1 Radioactive Effluent Controls Program A program shall be provided conforming with 10 CFR, Section 50.36(a) for the control of radioactive effluents and for maintaining the doses to MEMBER(S) OF THE PUBLIC from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

3.6.2.1.1 Limitations on the OPERABILITY of radioactive effluent monitoring instrumentation, including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; 3.6.2.1.2 Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 times the concentrations specified in 10 CFR 20, Parts 20.1001 - 20.2402, Appendix B, Table 2, Column 2; 3.6.2.1.3 Monitoring, sampling, and analysis of radioactive effluents in accordance with 10 CFR, Part 20.1302 and with the methodology and parameters in the ODCM; 3.6.2.1.4 Limitations on the annual and quarterly doses or dose commitment to a MEMBER(S) OF THE PUBLIC from radioactive materials in liquid effluents released to UNRESTRICTED AREAS conforming to Appendix I to 10 CFR, Part 50; Amendment No. 19 January 9, 2004

FIGURE 1 SAXTON NUCLEAR EXPERIMENTAL CORP. FACILITY LAYOUT Figure deleted Amendment No. 19 January 9, 2004

SAFETY EVALUATION B SUPPORTING AMENDMENT AMENDED FACILITY LICENSE NO SAXTON NUCLEAR EXPERIMENTAL C GPU NUCLEAR, INC.

DOCKET NO. 50-146

1.0 INTRODUCTION

By letter dated April 22, 2002, as supplemented on December 5, December 22, 2003, GPU Nuclear, Inc., and the Saxton Nuclear Ex licensees) submitted a request for amendment to Amended Facility Li Saxton Nuclear Experimental Corporation (SNEC) Facility (SNEF). The would approve changes to Appendix A of Amended Facility License No. DR Nuclear Experimental Corporation Technical Specifications to Amended Facil DPR-4 (TSs). The requested changes would remove the requirement to have a area and allow removal of the upper half of the SNEF containment vessel (CV). Th December 5, 2002, requested additional changes to the TSs to add the position of Vic President GPU Nuclear Oversight to reflect the merger of GPU Inc. and FirstEnergy Cor letters of September 30 and December 22, 2003, supplied clarifying information that did no expand the scope of the January 5, 2003, or January 22, 2003, Federal Register Notices.

2.0 BACKGROUND

The SNEF is in the process of being decommissioned and the licensees have requested changes to the TSs that would remove the requirement to have an exclusion area and allow the licensees to remove the upper half of the CV. The purpose of these TSs was to control access to the large amount of radioactive material and the resulting radiation and high-radiation areas that existed on site at the start of decommissioning activities. Decommissioning activities have resulted in the removal of a significant fraction of the radioactive material that was present on the SNEF site. Activities have proceeded to the point where the major task remaining is the removal of the upper portion of the CV. As an indication of how little radioactive material remains on site, the results of a survey performed by the licensees and submittal to NRC by letter dated December 22, 2003, shows that radiation levels on the filled-in floor level of the CV meet the requirements of 10 CFR Part 20 for doses to members of the public.

The SNEF CV is a cylindrical steel vessel with a hemispherical head at the top and an elliptical head at the bottom. The CV is approximately 109 feet (33 meters) high with a diameter of 50 feet (15 meters). The bottom of the vessel is located about 50 feet (15 meters) below grade.

After removing all nuclear steam supply system components and concrete from the CV, the licensees performed of the CV below ground that the residual radioacti concentration guideline leve 201, ADAMS Accession No. M ADAMS Accession No. ML03342 backfilled the lower half of the CV (t area from the upper section of the CV.

remainder of the CV to prevent potential activities to remove the upper CV dome.

The licensees plan to remove the upper part of th (removal of the CV also will require removal of the d The TSs contain requirements that need to be remove the CV to be removed. One purpose of these TSs was t that members of the public did not enter areas that containe material and that the licensees staff entered these areas unde 3.0 EVALUATION The regulations in 10 CFR 50.36 require nuclear reactors to have TSs. T 10 CFR 50.36(c)(6) state that for nuclear power reactors facilities that have certifications required by 10 CFR 50.82(a)(1), TSs will be developed on a cas In accordance with 10 CFR 50.82(a)(1)(iii), SNEC has been deemed to have sub certifications that they have permanently ceased operations and that fuel has been removed from the reactor vessel because the SNEC license was permanently modifie possession but not operation of the facility before the effective date of 10 CFR 50.82(a)(

SNEC TSs have been developed specifically for decommissioning of the SNEF. The staff concludes that the changes discussed below and the TSs for the SNEF are in accordance wit 10 CFR 50.36(c)(6) because they reflect the changing conditions of the SNEF due to decommissioning activities. The staff also concludes that the TSs being removed by this license amendment are not required by 10 CFR 50.36.

The licensees have requested a number of changes to the TSs to allow the removal of the upper half of the CV. The licensees have proposed to cease maintaining a portion of the site as an exclusion area by requesting that the definition of exclusion area, and Figure 1 of the TSs, which shows the bounds of the exclusion area, be removed from the TSs. The definition of exclusion area is given in TS 1.0.5 as follows:

EXCLUSION AREA -

The term EXCLUSION AREA refers to the area shown on Figure 1 of the Technical Specifications and defines the area controlled for the purpose of security and access restrictions. The EXCLUSION AREA will be posted.

The exclusion area boundary is defined in TS 1.1.2 as follows:

EXCLUSION AREA The EXCLUSION AREA c enclosed within a fence and Figure 1 of the TSs shows the SN the DSF, which consists of three str decommissioning activities. The minim area is determined by the licensees.

The licensees state that the use of the exclusio based on site radiation and contamination levels exclusion area is controlled for the purpose of secur In response to a question from the NRC staff, the license of the SNEF site would continue to be, as needed, restricte Part 20. A restricted area is an area access to which is limited of protecting individuals against undue risks from exposure to rad materials. The licensees will need to take the appropriate steps, inc controls, to protect the public from radiation and radioactive material a within the requirements of the regulations and as low as reasonably achi NRC inspection program will verify that the licensees control and use of ra meet the requirements of the regulations.

Decommissioning activities have resulted in the removal of a significant fraction of radioactive material that was present on the SNEF site. Radiation levels on the filled-the CV meet the requirements of 10 CFR Part 20 for doses to members of the public.

In response to a question from the NRC staff, the licensees confirmed that they will continue t meet the requirements of 10 CFR Part 20, Subpart I, Storage and Control of Licensed Material, for any licensed material in controlled or unrestricted areas.

The staff finds that decommissioning activities at the SNEF site have progressed to the point were the amount of radioactive material on site has decreased so that an exclusion area as described in the SNEF TSs is no longer needed to protect public health and safety. Control of radioactive material by the licensees will be accomplished by meeting the requirements of the regulations in 10 CFR Part 20. Based on the discussion above, the staff concludes that the definition of exclusion area and Figure 1 can be removed from the TSs and that the health and safety of the public will continued to be protected by the licensees compliance with the existing regulations in 10 CFR Part 20.

The removal of the requirement for an exclusion area from the TSs affects several other TSs.

The licensees have proposed that the definition of secured be removed from the TSs. The definition, given in TS 1.0.14, reads as follows:

SECURED -

The term SECURED is us those controls required to be unauthorized access. SECUR employed to prevent such unauth Such methods shall be at least equi Examples of such means are: window FACILITY (DSF) could be covered with a CONTAINMENT VESSEL (CV) could be we temporary openings in the CV shell or EXCLU physically guarded until otherwise suitably SECU as inaccessible or tamper resistant bolts could be in As the licensees remove the upper half of the CV, it will n secure the exclusion area as required by this definition. Wi requirement to maintain an exclusion area, this definition is no above, if radiological conditions require, the licensees must suita areas on site to meet the requirements of the regulations. Because access to areas on site as needed in accordance with the regulations to controls on the exclusion area, which has been removed from the TS definition from the TSs is acceptable to the NRC staff.

The licensees have requested that TS 1.1.3, EXCLUSION AREA Controls, be the TSs. The TS reads as follows:

EXCLUSION AREA Controls 1.1.3.1 Except for authorized entry, access points to the EXCLUSION AREA will be SECURED.

1.1.3.2 The CONTAINMENT VESSEL (CV) and the DECOMMISSIONING SUPPORT FACILITY (DSF) shall be equipped with an intrusion alarm system. Intrusion alarms will be activated whenever the site is not manned. OPERABILITY shall be verified in accordance with section 3.5.3.1.b.

1.1.3.3 Access points to the CONTAINMENT VESSEL (CV) and the DECOMMISSIONING SUPPORT FACILITY (DSF) will be SECURED following an authorized entry, prior to activating the intrusion alarms.

TS 1.1.3 relates to TS 3.6.1.3.3, which contains required actions that must be in procedures.

The TS currently reads as follows:

Facility inspections and access controls shall meet specific requirements of the sections 3.5.3 and 1.1.3, respectively, of these TS.

The licensees have Facility inspections shall m With the removal from the TSs removal of the upper section of th discussed above, the licensees mus requirements of the regulations. Beca needed in accordance with the regulation exclusion area, which has been removed f NRC staff. Because TS 1.1.3 has been remov TS 1.1.3 in TS 3.6.1.3.3 is also acceptable to the The licensees have requested that TS 3.5.3.1(a) and (

area be removed from the TSs. The TSs read as follows 3.5.3.1 Facility inspections shall be performed in accordance w approved procedures. The inspection activities shall include:

a.

Verification that EXCLUSION AREA access points are SECURED at the completion of each authorized entry.

b.

Verification of the OPERABILITY of the EXCLUSION AREA intrusion alarms shall be performed quarterly.

With the removal from the TSs of the requirement to maintain an exclusion area, these verifications are no longer needed. As discussed above, the licensees must suitably limit access to restricted areas on site to meet the requirements of the regulations. Because the licensees will continue to limit access to radioactive material in accordance with the regulations and because the verifications refer to controls on the exclusion area, which has been removed from the TSs, removal of these verifications from the TSs is acceptable to the NRC staff.

The licensees have requested that the definition of the DSF and the Decommissioning Support Building (DSB) be removed from the TSs. The licensee has reduced the exclusion area down to the CV and has removed the DSF and DSB from the site. The definitions, given in TS 1.0.4, are as follows:

DECOMMISSIONING SUPPORT FACILITY (DSF) and DECOMMISSIONING SUPPORT BUILDING (DSB) -

The DECOMMISSIONING SUPPORT FACILITY (DSF) is the facility constructed southeast of the containment vessel (CV) and attached to the CV. The DSF consists of three structures, the DECOMMISSIONING SUPPORT BUILDING (DSB), the Material Handling Bay and the Personnel Access Facility. The DSB is used to facilitate the decommissioning process and allow the preparation and packaging of radioactive material for shipping.

The DSF was added enclosed area to suppo DSF was directly adjacen Before the DSF was removed, be performed prior to DSF remov information, the licensees stated tha packaging of radioactive materials that TSs) are completed. After the removal o radioactive waste. This waste will be packa currently used to package waste outside of the are packaged in the DSF). The licensees state th Calculation Manual, SNEC Facility Radiation Protec regulations will be followed. The licensees will use loc outside of the DSF as dictated by ALARA considerations considerations.

Because the DSF must be removed to complete decommissionin and because radioactive waste handling activities will continue to b acceptable manner as discussed above, the staff concludes that the r the definition of the DSF is acceptable.

The licensees have requested that the definition of CV secured, TS 1.0.2, an contains personnel requirements for initial CV entry, be removed from the TSs.

as follows:

CV SECURED -

The term CV SECURED applies to the controls necessary to make an initial CONTAINMENT VESSEL (CV) entry. It does not refer to any security measures.

CV SECURED means that the CV has been sealed for personnel entry.

TS 3.2.1 reads as follows:

At least two individuals, one of which must be knowledgeable in radiation monitoring and the radiological hazards associated with the facility, shall perform radiological surveys necessary to support the initial entry into the CV for the day.

The definition of CV SECURED relates to TS 3.2.2, which reads as follows:

The RSO or a GRCS PRODUCTION ACTIV RADIOACTIVE WASTE M Radiologically Controlled Ar The licensees have proposed cha The RSO or a GRCS shall be present ACTIVITIES, maintenance, characterizat MANAGEMENT ACTIVITIES are being perf Areas (RCAs).

The purpose of this definition and the TSs was to en were applied during the initial entry into the CV for the overnight to the radiologically status of the CV would be status were important to be aware of when the large compo significant radiological hazard, were in the CV. These compon been removed from the CV. With the removal of the CV upper h CV to control entry into. The licensees state that activities involving be considered production activities and subject to the requirements of staff finds that removal of TS 1.0.2 and 3.2.1 and the proposed changes acceptable because with the removal of the upper half of the CV, there will need to control entry into the CV.

The licensees have proposed changes to TSs 2.1.1 and 2.1.2, which read as follow 2.1.1 During activities within the CV/DSB that have the potential to cause a MEASURABLE RELEASE to the environment of airborne radioactivity, the CV/DSB ventilation system will be operating in a manner such that the release pathway is via the monitored ventilation system exhaust.

2.1.2 When the CV/DSB ventilation exhaust is in operation, the exhaust monitoring instrumentation will be operated simultaneously. The ventilation system will be shutdown if the exhaust monitoring instrumentation is inoperable.

The licensees have proposed changing these TSs to read as follows:

2.1.1 During activities involving removal of the upper dome of the CV that have the potential to cause a MEASURABLE RELEASE to the environment of airborne radioactivity, appropriate ventilation will be operating in a manner such that the release pathway is via the monitored ventilation system exhaust.

2.1.2 When the ventilation exhaust is in operation, the exhaust monitoring instrumentation will be operated simultaneously. The ventilation system will be shutdown if the exhaust monitoring instrumentation is inoperable.

With the removal of system will no longer b possibility that activities n radiologically contaminated ventilation controls to ensure a TS 2.1.1 continues to require the measurable release to the environm require that ventilation exhaust monito system is in operation. Because the chan DSF configuration due to the removal of the to have a monitored ventilation exhaust system potential to cause a measurable release is not ch reasonable assurance that uncontrolled releases of removal of the upper half of the CV and the proposed The licensees have proposed changes to the definition of c currently reads:

CONTAINMENT VESSEL -

Term used to describe the vertical steel cylinder which houses the Saxto Nuclear Experimental Corporation Facility Nuclear Steam Supply System (NSSS) and related components, also known as the CV.

The licensees have proposed changing this TS to:

CONTAINMENT VESSEL -

Term used to describe the vertical steel cylinder which housed the Saxton Nuclear Experimental Corporation Facility Nuclear Steam Supply System (NSSS) and related components, also known as the CV.

The change to this TS is administrative in nature and reflects the current condition of the CV.

Because of decommissioning activities, the NSSS and related components have been removed from the CV. Because this change is administrative in nature and reflects the current status of the facility, it is acceptable to the staff.

In response to a staff request for addition information, the licensees have proposed changes to TS 3.5.2.5.1 and 3.5.2.5.2 to make the wording of these TSs consistent with the revisions to 10 CFR 50.59. In both TSs, the references to particular sections of 10 CFR 50.59 have been updated to agree with the revised regulation. Also in both TSs, reference to an unreviewed safety question as defined in has been changed to require NRC approval pursuant to to reflect the changes to the regulation. Because these changes are administrative in nature and result in the TSs correctly referencing the revised 10 CFR 50.59, they are acceptable to the NRC staff.

In the licensees letter of December 5, 2002, which contained replies to the NRC staffs request for additional information, the licensees requested some additional changes to the TSs. The licensees have requ would add the title Vic change reflects the merge and SNEC became FirstEne To align nuclear oversight func Nuclear Oversight has been given of Nuclear Oversight. In TS 3.5.4 co Oversight is given the responsibility to Nuclear Cognizant Officer, who currently audit reports will be forwarded to the Vice-P GPU Nuclear Cognizant Officer, who currently In TS 3.5.5.1, concerning the TMI-2/SNEC Oversigh Nuclear Oversight replaces the GPU Nuclear Cogniza TMI-2/SNEC Oversight Committee. The Vice-President the GPU Nuclear Cognizant Officer in TS 3.5.5.1 as the ma membership of the TMI-2/SNEC Oversight Committee.

In TS 3.5.5.4 the Vice-President GPU Nuclear Oversight will receiv TMI-2/SNEC Oversight Committee in addition to the GPU Nuclear Co currently is required by the TS to receive these reports.

In TSs 3.5.4 and 3.5.5.4 the Vice-President GPU Nuclear Oversight is added requirements of the TSthe change is administrative in nature and acceptable t TS 3.5.5.1, the Vice-President GPU Nuclear Oversight takes over responsibility fro Nuclear Cognizant Officer. The responsibilities remain at a high level within the merg organization and the change is therefore acceptable to the staff.

As part of the application for Amendment No. 15 to the SNEF license, issued on April 20, 199 the licensees presented and the staff reviewed and found acceptable the consequences of various accidents associated with decommissioning activities at the SNEF site. One type of accident analyzed was the segmentation of components or structures without local engineering controls. The licensees calculated the dose to an individual standing at the site boundary as less than 1.5 mrem.

Based on the specific activities that would be performed after approval of this license amendment, the licensees proposed an accident where the CV dome is segmented without local engineering controls. Using conservative atmospheric dispersion parameters and dose calculation methodologies, the licensees calculated the dose to an individual standing at the site boundary as about 0.004 mrem, well within 1.5 mrem dose discussed above. In addition, in response to a NRC staff request for additional information, the licensees stated that at the time that the CV interior would be exposed to the environment, removable contamination levels would be reduced to meet site free release criteria as defined in the site Radiation Protection Plan or would be fixed in place to prevent release. The staff concludes that a segmentation accident involving the CV dome is bounded by the segmentation accident previously evaluated by the staff, and therefore, would pose no serious radiological risk to the general public.

4.0 STATE CONSULTATION

In accordance with N proposed issuance of t 5.0 ENVIRONMENTAL CO Portions of this amendment (CV r component located within the restric inspection and surveillance requiremen involves no significant increase in the am effluents that may be released off site, and occupational radiation exposure. Accordingly, categorical exclusion set forth in 10 CFR 51.22(c environmental impact statement or environmental a with the issuance of this amendment.

Portions of this amendment (the addition of Vice-President changes in recordkeeping, reporting, or administrative procedu Accordingly, the amendment meets the eligibility criteria for categ 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmen environmental assessment need be prepared in connection with the is amendment.

6.0 CONCLUSION

The Commission has previously issued a proposed finding that the amendment inv significant hazards consideration, and there has been no public comment on the findin was published in the Federal Register on January 7, 2003 (68 FR 798), with a correction published on January 22, 2003 (68 FR 3054).

The staff has concluded, on the basis of the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed activities; (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public.

Principal Contributor: A. Adams, Jr.

Date: January 9, 2004