HBL-10-004, License Amendment Request 10-01 Deletion of Technical Specification 3.1.3, Fuel Storage Pool Liner Water Level, & TS 1.0, Use & Application, 3.0, Limiting Condition for Operation Applicability, 3.0, Surveillance Requirement.

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License Amendment Request 10-01 Deletion of Technical Specification 3.1.3, Fuel Storage Pool Liner Water Level, & TS 1.0, Use & Application, 3.0, Limiting Condition for Operation Applicability, 3.0, Surveillance Requirement.
ML101090081
Person / Time
Site: Humboldt Bay
Issue date: 04/09/2010
From: Becker J
Pacific Gas & Electric Co
To:
Document Control Desk, NRC/FSME
References
HBL-10-004
Download: ML101090081 (63)


Text

Pacific Gas and Electric Company' James R.Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/5/601 P.0. Box 56 Avila Beach, CA 93424 April 9, 2010 805.545.3462 Internal: 691.3462 Fax: 805.545.6445 PG&E Letter HBL-10-004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Docket No. 50-133 OL-DPR-7 Humboldt Bay Power Plant, Unit 3 License Amendment Request 10-01 Deletion of Technical Specification (TS) 3.1.3, "Fuel Storage Pool Liner Water Level,"

and TS Sections 1.0, "Use and Application," 3.0, "Limiting Condition for Operation (LCO) Applicability," 3.0, "Surveillance Requirement (SR) Applicability," 4.1, "Site Location," and 5.6.2, "Technical Specification (TS) Bases Control Program"

Dear Commissioners and Staff:

In accordance with 10 CFR 50.90, enclosed is an application for an amendment to Facility Operating License No. DPR-7 for Humboldt Bay Power Plant (HBPP) Unit 3.

The enclosed License Amendment Request (LAR) proposes deletion of Technical Specification (TS) 3.1.3, "Fuel Storage Pool Liner Water Level." TS 3.1.3 places restrictions on the maximum operating water level in the gap between the stainless steel liner covering the inside surface of the fuel storage pool and the pool walls.

This TS restriction was originally intended to preclude leakage from the fuel storage pool to surrounding groundwater, and to preclude groundwater seepage into the pool.

The transfer of spent fuel from the fuel storage pool to the Independent Spent Fuel Storage Installation (ISFSI) was completed in December 2008, and the decontamination and dismantlement phase of HBPP Unit 3 decommissioning has commenced. Subsequently, Pacific Gas and Electric Company (PG&E) updated the fuel storage pool rupture analysis to reflect the current radioactive isotope inventory of the pool. This recent analysis demonstrates that the radiological dose consequences to a member of the public from the entire fuel storage pool inventory being released to groundwater are orders of magnitude less than the impact to a member of the public in one year from background radiation. It can therefore be concluded that, without maintaining the liner gap level, the dose consequences to the public from fuel storage pool leakage are also negligible.

The deletion of TS 3.1.3 will eliminate the only remaining Unit 3 TS Limiting Condition for Operation (LCO). Therefore, it is also proposed that TS sections 1.0, "Use and Application," 3.0, "Limiting Condition for Operation (LCO) Applicability,"

3.0, "Surveillance Requirement (SR) Applicability," and 5.6.2, "Technical Specification (TS) Bases Control Program," be deleted because these sections are only applicable to TS LCOs. 4

Document Control Desk PG&E Letter HBL-10-004 April 9, 2010 Page 2 In addition, editorial corrections are proposed for the Table of Contents and TS section 4.1, "Site Location." provides the evaluation of the changes proposed in this LAR. provides a markup of the HBPP Unit 3 TS showing the proposed changes. Enclosure 3 provides a retyped (clean) version of the HBPP Unit 3 TS incorporating the proposed changes.

The changes proposed in this LAR are not required to address an immediate safety concern. However, the proposed changes will result in reduced burden on the HBPP plant staff as a result of the elimination of the TS surveillance requirement to monitor the water level in the fuel storage pool liner gap. PG&E relies on the operating staff of HBPP Units 1 and 2 to fully comply with the TS surveillance requirement. However, PG&E intends to permanently terminate operation of HBPP Units 1 and 2 in September 2010. On this basis, PG&E requests NRC approval of these proposed changes by September 1, 2010, and that the changes be made effective upon NRC issuance of a license amendment, to be implemented within 60 days from the date of issuance of the license amendment.

There are no regulatory commitments made in this letter.

If you wish to discuss the information in the enclosure, please contact David Sokolsky at (707) 444-0801.

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

Executed on April 9, 2010.

SSinc rely, James . ecker Site Vice President cc: Gary W. Butner, California Department of Public Health Elmo E. Collins, Jr., NRC Region IV John B. Hickman, NRC PG Fossil Gen HBPP Humboldt Distribution Enclosures

Enclosure 1 PG&E Letter HBL-10-004 EVALUATION

1.0 DESCRIPTION

Pacific Gas and Electric Company (PG&E) requests to amend Operating License No. DPR-7 for Humboldt Bay Power Plant (HBPP) Unit 3.

The proposed change would modify the Technical Specifications (TS) to delete TS 3.1.3, "Fuel Storage Pool Liner Water Level" and TS sections 1.0, "Use and Application," 3.0, "Limiting Condition for Operation (LCO) Applicability," 3.0, "Surveillance Requirement (SR) Applicability," and 5.6.2, "Technical Specification (TS) Bases Control Program." In addition, the heading to Section 4.1, "Site Location," is proposed to be restored.

2.0 PROPOSED CHANGE

S This License Amendment Request (LAR) proposes to revise the HBPP Unit 3 TS to delete TS 3.1.3, "Fuel Storage Pool Liner Water Level," because the radiological dose consequences of fuel storage poolleakage are negligible.

Since the deletion of TS 3.1.3 would also eliminate the only Unit 3 TS LCO, it is also proposed that sections 1.0, "Use and Application," 3.0, "Limiting Condition for Operation (LCO) Applicability," 3.0, "Surveillance Requirement (SR) Applicability," and 5.6.2, "Technical Specification (TS) Bases Control Program," be deleted because the information in these sections is only applicable to TS LCOs.

Two editorial changes are proposed to correct changes made in previous license amendments. The TS Table of Contents will be corrected to delete the word "(Deleted)" for Section 5.8 because this section remains in the TS. The word "(Deleted)" was erroneously added in a previous license amendment. In addition, the heading to Section 4.1, "Site Location," is proposed to be restored because it was inadvertently removed in a previous license amendment.

The proposed changes to the TS are noted in the marked-up copy of the applicable TS sections provided in Enclosure 2. Enclosure 3 provides a retyped (clean) version of the HBPP Unit 3 TS incorporating the proposed changes p

3.0 BACKGROUND

A stainless steel liner covering the inside surface of the fuel storage pool was installed in 1963 because of high chloride concentrations in the pool that were suspected to be from groundwater in-leakage. The liner formed a nominal one-quarter-inch gap between the walls and floor of the pool and the liner. It was discovered in March of 1966 that a leak had developed in the fuel storage pool Page 1 of 8 p

Enclosure 1 PG&E Letter HBL-10-004 liner and that the leakage was from the fuel storage pool to the gap, and then through the structural concrete to the adjacent groundwater. TS 3.1.3 requires that the water level in the gap be maintained below the fuel storage pool water level and below the exterior groundwater level to preclude both pool leakage to the surrounding groundwater and groundwater leakage into the pool. Water level in the liner gap is maintained using a liner gap pump, which discharges to the Turbine Building Drain Tank in the Liquid Radwaste Collection System.

4.0 TECHNICAL ANALYSIS

4.1 TS 3.1.3, "Fuel Storage Pool Liner Water Level," places restrictions on the maximum operating water level in the gap between the stainless steel liner covering the inside surface of the fuel storage pool and the pool walls.

Following completion of transfer of spent fuel from the storage pool to the Independent Spent Fuel Storage Facility (ISFSI) in December 2008, PG&E recognized the need to update the HBPP Unit 3 Defueled Safety Analysis Report (DSAR), including the fuel pool rupture analysis. The pool rupture analysis had not been updated since 1984, and the radionuclides previously evaluated did not accurately represent the current radioactive isotope inventory of the pool. For example, the four radionuclides that were evaluated in 1984 have decayed since that time, some of them significantly (Cesium-134 has a half life of approximately two years and is no longer present). Failures of stainless steel clad fuel early in Unit 3 operation and spent fuel crud have also contaminated plant systems, including the storage pool, with an array of uranium, transuranic and corrosion product radionuclides that were not considered in the 1984 DSAR analysis.

Humboldt Bay Power Plant, Unit 3 Calculation NX-356, "Radiological Consequences for Breach of Defueled Spent Fuel Pool, June 2009," was performed to re-analyze rupture of the fuel storage pool from a heavy load drop. The calculation inputs include the radioisotopic results from a March 2009 sample of fuel storage pool water and the conservative assumption that a uniform layer of high activity sludge is covering the floors of the fuel pit and the cask pit. In summary, the 'calculation concludes that various HBPP site groundwater studies continue to support the DSAR assertion that the only feasible pathway for radiological dose to the public is from human consumption of fish. The sum of the peak yearly doses from each radionuclide released, which occur anywhere from three years to 244 years from the initiating event, is 0.37 mrem; therefore, if all the peak doses were to occur in the same year, the maximum yearly dose to a single member of the public would be approximately 0.4 mrem due to the radionuclide concentrations in edible aquatic foods in Humboldt Bay. The highest yearly dose to a member of the public is 0.24 mrem at 250 years. These dose consequences are orders of magnitude less than the impact to a member of Page 2 of 8

Enclosure 1 PG&E Letter HBL-10-004 the public in one year from background radiation and are therefore insignificant. Based on these results, the fuel storage pool rupture analysis was removed from the DSAR under the provisions of 10 CFR 50.59.

Since PG&E Calculation NX-356 evaluates the rupture of the fuel storage pool and subsequent discharge of the entire contents of the pool, the results of Calculation NX-356 conservatively envelope the radiological consequences of fuel storage pool leakage. The assumption in Calculation NX-356 that the entire contents of the fuel storage pool are released to the groundwater does not take credit for monitoring and maintaining the fuel storage pool liner gap water level to ensure that leakage is captured and precluded from entering the surrounding groundwater. As a result,

,monitoring and maintaining the fuel storage pool liner gap water level is not required to ensure that the radiological consequences of fuel storage pool leakage are maintained at insignificant levels. Since monitoring fuel storage pool liner gap water level is not required to ensure that average annual releases of radioactive material in effluents and their resultant committed effective dose equivalents are maintained at small percentages of the dose limits specified in 10 CFR 20.1301, retention of this TS requirement is not required. Thus, it is proposed that TS 3.1.3 be deleted.

4.2 TS section 1.0, "Use and Application," consists of sub-sections 1.1, "Definitions," 1.2, "Logical Connectors," 1.3, "Completion Times," and 1.4, "Frequency."

Sub-section 1.1 contains definitions for "ACTIONS" and "ELEVATION."

These two terms are currently used only in TS 3.1.3, which is proposed to be deleted.

Sub-section 1.2 was determined to be no longer applicable in a previous license amendment and can, therefore, be deleted.

Sub-section 1.3 establishes the Completion Time convention and provides guidance for its use. This term is currently used only in TS 3.1.3, which is proposed to be deleted.

Sub-section 1.4 defines the proper use and application of Frequency requirements. This term is used only in TS 3.1.3, which is proposed to be deleted As a result, if all sub-sections within TS section 1.0 are being deleted, it is proposed that TS section 1.0, "Use and Application," be deleted.

4.3 TS section 3.0, "Limiting Condition for Operation (LCO) Applicability,"

establishes the conditions for which TS LCOs must be met and the requirements that shall be met upon failure to meet a given LCO. This Page 3 of 8

Enclosure 1 PG&E Letter HBL-10-004 section applies only to LCOs. TS 3.1.3 contains the only remaining LCO and is being proposed to be deleted. Therefore, it is also proposed that TS section 3.0, "Limiting Condition for Operation (LCO) Applicability," be deleted.

4.4 TS section 3.0, "Surveillance Requirement (SR) Applicability," establishes the conditions for which TS Surveillance Requirements (SR) must be met and the requirements that shall be met when a given SR is not performed within its specified frequency. This section applies only to LCOs. TS 3.1.3 contains the only remaining SR and is being proposed to be deleted.

Therefore, it is also proposed that TS section 3.0, "Surveillance Requirement (SR) Applicability," be deleted.

4.5 The heading of TS section 4.1, "Site Location," is proposed to be restored to the first paragraph of section 4.0, "Design Features." The heading was previously deleted in error.

4.6 TS section 5.6.2, "Technical Specification (TS) Bases Control Program,"

establishes the process for making changes to the TS Bases. This section applies only to LCOs. TS 3.1.3 contains the only remaining LCO and is being proposed to be deleted. Therefore, it is also proposed that TS section 5.6.2 be deleted.

4.7 The Table of Contents is being corrected to delete the word "(Deleted)"

from section 5.8, "High Radiation Area." This section remains in the TS, and the word "(Deleted)" was erroneously added in a previous license amendment.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Pacific Gas and Electric (PG&E) has evaluated the no significant hazards consideration involved with the proposed amendment, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:

"The Commission may make a final determination, under the procedures in §50.91, that a proposed amendment to an operating license or a combined license for a facility or reactor licensed under

§§50.21(b) or 50.22, or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or Page 4 of 8

Enclosure 1 PG&E Letter HBL-10-004 (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety."

The following evaluation is provided for the no significant hazards consideration standards:

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes eliminate the TS requirement to control the operating water level in the gap between the fuel storage pool liner and~the pool concrete structure and delete the TS sections that are applicable to Limiting Conditions for Operation (LCO).

Elimination of the TS requirements to control liner gap water level will not increase the probability or consequences of the previously analyzed (and recently updated) fuel storage pool rupture accident.

The basis of TS 3.1.3 is to preclude both pool leakage to the surrounding groundwater and groundwater leakage into the pool.

The radiological consequences of pool leakage are conservatively bounded by the fuel storage pool rupture analysis, an analysis which demonstrates that the consequences of a breech of the fuel storage pool are insignificant.

Additionally, the proposed changes will not result in the modification of any systems, structures or components and will not affect any parameters or conditions that could contribute to the initiation of an accident.

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

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes will not result in the modification of any systems, structures or components and will not affect any parameters or conditions that could contribute to the initiation of an accident.

Page 5 of 8

Enclosure 1 PG&E Letter HBL-10-004 Therefore, the proposed changes will not create the possibility of a new or different kind of accident from those previously evaluated.

3. Does the change involve a significant reduction in a margin of safety?

Response: No The design basis and accident assumptions within the Humboldt Bay Power Plant (HBPP) Unit 3 Defueled Safety Analysis Report and the TS relating to spent fuel are no longer applicable. The proposed changes do not affect remaining plant operations, nor structures, systems, or components supporting decommissioning activities. In addition, the proposed changes do not result in a change in initial conditions, system response time, or in any other parameter affecting the course of a decommissioning activity accident analysis. Therefore, the proposed changes will not involve a significant reduction in the margin of safety.

Based on these considerations, it is concluded that the proposed changes will not endanger the public health and safety.

5.2 No Limiting Conditions for Operation (LCO) Requirements 10 CFR 50.36(d)(2)(ii), specifies the criteria for a limiting condition for operation as follows; "A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(D) Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety."

Page 6 of 8

Enclosure I PG&E Letter HBL-10-004 The following evaluation is provided to justify no LCO requirements.

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary..

HBPP Unit 3 is a permanently shutdown facility with the fuel removed, thus there is no active reactor coolant pressure boundary, only a radiological control boundary.

(B) Criterion2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

HBPP Unit 3 is a permanently shutdown facility with the fuel removed, thus there are no longer any reactor design basis accidents or transient conditions that present a challenge to a fission product barrier.

(C) Criterion 3. A structure, system, or componentthat is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier:

HBPP Unit 3 is a permanently shutdown facility with the fuel removed, thus there are no longer any reactor design basis accidents or transient conditions that present a challenge to a fission product barrier.

(D) Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

HBPP Unit 3 fuel has been removed from the spent fuel pool and, in accordance with PG&E Calculation NX-356, dose consequences of not maintaining the liner gap has been shown not to present a significant risk to public health and safety.

Based on the above evaluation, it is concluded that the proposed changes will not endanger the public health and safety.

5.3 Applicable Regulatory Requirements/Criteria The proposed changes have no effect on any plant systems or on maintaining the plant in a safe condition. Therefore, the proposed changes are not considered to have any adverse safety'significance.

HBPP would continue to satisfy applicable regulatoryand safety criteria.

In conclusion, based on the considerations above:

Page 7 of 8

Enclosure 1 PG&E Letter HBL-10-004 (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.

6.0 ENVIRONMENTAL CONSIDERATION

PG&E has evaluated the proposed changes and determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(1 0)(ii).

Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed changes is not required.

7.0 REFERENCES

1. Humboldt Bay Power Plant, Unit 3 Calculation NX-356, "Radiological Consequences for Breach of Defueled Spent Fuel Pool, June 2009."

Page 8 of 8

Enclosure 2 PG&E Letter HBL-10-004 PROPOSED REVISION TO HBPP TECHNICAL SPECIFICATIONS

Technical Specifications Humboldt Bay Power Plant Unit 3 Eureka, California

TABLE OF CONTENTS 1.0 USE AND APPLICATION .......................................... ....... 1.1-1 1 .1 De fin itio n s (D e lete d ) .................................................................................... 1 .1-1 1.2 Logical C onnectors(D eleted) ..................................................................... 1.2-1 1.3 C om pletion T im es(D eleted) ....................................................................... 1.3-1 1.4 Frequency(Deleted) ......................................... 1.4-1 2.0FETYLIMIT....

S ................................. .. . . . . . . ..-

2 .0 SA F ET Y LIMITS ................................................................................................... 2 .0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ..................... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .................................... 3.0-2 3.1 DEFUELED SYSTEMS .......................................................... 3.1-1 3.1.1 Fuel Storage Pool Water Level(Deleted) ................................................... 3.1-1 3.1.2 Spent Fuel Pool Load Restrictions(Deleted) ............................................... 3.1-2 3.1.3 Fuel Storage Pool Liner Water Level(Deleted) .................... 3.1-3 4 .0 D E S IG N F EA T UR E S ........................................................................................ 4 .0-1 4 .1 S ite Lo c a tio n .............................................................................................. 4 .0 -1 4 .2 F u e l Sto ra g e .............................................................................................. 4 .0 -1 5.0 A D MIN ISTRATIVE CO NTRO LS ........................................................................... 5.0-1 5.1 R esponsibility(D eleted) .............................................................................. 5 .0-1 5.2 O rganization(D eleted) ................................................................................ 5.0-2 5.3 Facility Staff Q ualifications(Deleted) ........................................................... 5.0-5 5 .4 T ra ining (D e leted ) ....................................................................................... 5 .0-6 5.5 Procedures .................................................. ......... ............. 5.0-7 5.6 P rogram s and Manuals .............................................................................. 5.0-8 5.7 Reporting Requirements(Deleted) .............................................................. 5.0-12 5.8 High R adiation A rea{D eleted) ..................................................................... 5.0-13 Amendment No. 44

1.0 USE AND APPLICATION This section is not applicable to a facility with no Limiting Conditions for Operation 1.1! Definitions NOTE The defined terms of this section pp cpitalized type and are applicabe throughout thes Technical Specifications and Bases-.

T-eff' gefl4iý

,AGI4QNJ ACTIONS shall be that pa~t of a Specification that-prescribes Required Actions to be taken under designated Conditions Within specified Comnpletio-n Tmimes ELEVATON All elevations shall apply to a datumR of m~ean lower low water (MLLWV) level except where noted.

1.1-1 Amendment No. 44

I ICI- AKIII ADDI If'A-rlt"%ll 1.2 LoGgical Connectors This section is not applicable to a facility with all Of the Spent nuclear fuel stored in an Independent Spent Fuel StorFage Installation (ISESI). (Page 1.2 2 has been deleted).

1.2-1 Amendment No. 44

1.0 USE AND APPLICATION 1.3 Completion Time PIIRPGSOE The purmpose of this section is to establish the Completion Time convention and to provide guidance for its uise..

BACKGROUND Limititng Conditions for Operation ([=Cgs) specify m!inimum requiremients when water in the- Spent Fuel Storage Pool or liner i contaminated with radio~active mfaterials. The ACTIONS associated with an LCO lstatlezCniin that typically describe the ways in Which the requiremet* S of the LCO can fail to be maet. Specified with each stated ondition are RequirFed Actien(s) and Completion Times(s).

DESCGRI1PTI ON The Comnpletion Time is the amou~nt of timne allowed for completing a Required AtlioRn. It is referFened to the timne of discovery of a situation (e.g., variable not within limits) that requires enteFRig an ACTIONS ConRdition un~less otheR~ise specified, providing the unit is in a MODE or-specified condition stated in the Applicability of the LCO. Required Actions mu..st be completed prior to the expiration of the specified Cormpletior Tirme. An ACTIGN*S Condition remainsin effect and the RequirFed Acin Ipply until the Condition no longer exists or the un~it i not within the LCO Applicability.

E=X-4-NA P 1-F= SThe following examples illus111tratf the use of Completion Tim.es with different types of Conditions.

1.3-1 Amendment No. 44

4 '* t"* l*.i.;* '1";*

E=X-444P1-E-S- EXAMPLE 1 .3 1 (GE)RtOR6ed)

AG-T40N9 GONDITION REQUIRED ACTION COMPLETION TIME A.-Requied A.1-Ve~ify--. 6hA s asGG aed AND GOe4pptetin- A.2 Restoee op Tmme not Met3 Condition A has two Required Actions. Each Required Action. has its I* IVIVI VI DVVM 41, irie 4:A4)4 IMri inHii kA-flfHI+Ifl1. nnirQ IA [1fRI mQ~etiirt-H AG-uTIiuRi Of f, A;4.: A L- A f-rit-Nki A 4 within 6 hor n oPe~frm the restoration required by ACTION A.2 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for pe~f9rming ACTION ArCTION A.2 from the time that ConditionA as entered. If ACTION A41 iEcmpleted within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time alloed copeing ACTION A.2 isthe next 33 hour3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />s- becoa-use the total time allowed for completing ACTION A.2 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

IMMEDIATE When "Immediately" is used as a Completion Time, the Required COMPLETION Action sheold be pursu.ed without delay and in a cnoemanner.

TIME 1.3-2 Amendment No. 44

1.0 USE AND APPLICATION 4.4 Frequenciy PiIEPQI The purpose of this section is to define the proFper use ad application of Frequency requirments.

DESCRIPTION Each Surveillance Requirement (SR) has a Specified frequency in which the survefillance must be met in order to meet the- associated LCO. An understanding of the correct application of the specified Frequency is.n r- for *omplianRe With the SR.

The "Specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, "Surveillance Requiremnent (SR) Applicability." The "Specified Frequency" conRsists of the-requremets enie*/'

R t&"

of the frequency

  • "J ,

colum~n .iof each p, v, * ,, ,vj SR, v ,

as well,*,as Ge~tain Noties inthe surveillance column that modify performance EXAMP-LE The following exam.ples illustrate th wy6s that frequencie a.re specified. In these examples, the applicability of the LCO (LGCOnt shown) is when irradiated fuiel is stored in the fuel pool.

EXA~MPLE 1.4.1 SURVEDILLANCE REQUIREMENTS SURVEILLANCE F=RE QU11 ENCI Y Example 1.1 1 contains the type of SR mos~t often encountered in the TS. The frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveffillance mrust be pe, erm-ed at least one tim+e.-

Pe.."rmaRte of the surveillance initiates the subsequent interval.

Although the frequency is 6tated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an exte...On of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 forF operational flexibility. The measurement of this itra continuies at all times, even when the SR is not required to be mnet per SR 3.0.1 (such as when a variable is outside specified fimnits, or the unit is outside the applicability of the LCO). if the interval specified by SR 3.0.2 is exceeded while the unit is in the specified cond~itio in the applicability of the LCO, and

  • " *,,+-"M*+h ,.v the

+

  • pe*11 14+
  • oif IC~"* r1Ialynr-le

.. j........I..*l.*li*. the surveillance

'` aP,.*lG-,-.*,..k;,- hi not yed):

otherwise moadified, then SR 3.0.3 becomnes applicable.

1.4-1 Amendment No. 44

1.4 FrequencGy EXAMPLE EXAMPLE 1.4 2 (GGRti~ed)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENGY

§ prier.te irradiated-fuel AN-D thefe ,,,t ,,,

24 hew~s-

~, vnn jV~~,,I rnri m ,n'm c fPTI~'TI1 lflf,~T/rl 1--)(= Fn !ý :j a -L Mý ý 3: ^ Q MT Q = nný X! IQ 4

nnh nrrn.,nra rranu ant-u, ,,nrl tha oarnn~ ic, af tha tutna OHrQA, Fr~ un r". . . . . ... . ' . . J . . .. . . .... . . .Jr--. ........ .

Example~ -1.4 -. -IH QgiC a un:eutG:

GGIUI PON Iniu;~tst Frequency requirements must be met. The use of "prior to"iniae that the sur'weillancc must be performed once before the initiation Of fuel hn,.,Ai.-u, ',,-illitu,9 Thic. tutna Of Iracu nd, dr-W CGSR'nt qualif" fer the axtnen .i~ru~r A QO D I r 0 "-kr,+r d "r.,,Ma+ fi it ra perfoprmances mqust be established per SR 3.0.2, but only after a

& t I e xample).

1.4-2 Amendment No. 44

2.0 SAFETY LIMITS This section is not applicable since Humboldt Bay Power Plant (HBPP) Unit 3 is permanently defueled.

2.0-1 Amendment No. 44

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY This section is not applicable to a facility with no Limiting Conditions for Operation LIO 3.04 LC s shall t ig the specified conditions in the Applicability, except as provided in LCO 3.0.2.

LGO-3.0 7 Upon discovery of the failure to meet an LCO, the required actions of the associated CorditiRns shall be met.

If the LCO is met or is noe lenger applicable prier to expiration of the Specified Completion Time(s), completion of the required action is not required unless otherwise stated.

3.0-1 Amendment No. 44

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY This section is not applicable to a facility with no Limitingi Conditions for Operation

.R 37.-0 SRs shall be me urnpecific conditions in the Applicability for individual LCGs unless otheRvise stated inthe SR. Failure to meet a Sureilanewhether suc~h failue is experienced dur~ing the

> peorfemance o'f the- Surveillance or between peorfemances of the Surveillance, shall be failure to meet the LCOG. Failure to pecform a Surveillance within the specified Frequency shall be failure to meet the LCO eXcept as provided in SIR 3.0.3. Surveillances do not have to be performed OnRnpeal equipment orF variables outside specified SR '30.2 The specified FrequencY for each SR is mnet if the Surveillance is pe~formed within 1.25 times the interval specified in the Frequency, as measured from the previous pe~formance or as measured fro~m the time a specified conRditionR of the frequency is,met.

S.R-3.03 if it s isovered that a Surveillance was no~t per-frmed within t specified frequency, then complian~e w~ith the requirement to declare the LCO not met may be delayed from the time of discover,' up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, which ever is less.

This delay perio~d is permitted to allow pweormance of the surveillance.

if the Surveill'anc-e is not pe~fermcd within the delay period, the LCO(

must immediately be declared no~t met and the applicable ConRdfition(s) must be enteretd., The Coempletion Times of the Required Actions begin immnediately upon expiration of the delay period.

When the Surveillance is per-ormed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met-and the applicable ConRdition(s) must be entered. Thez Comrpletion Times of the Required Actions begin immediatelyuo alr to meet the Surveillance.

3.0-2 Amendment No. 44

3.1 DEFUELED SYSTEMS 3.1.1 Fuel Storage Pool Water Level This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

3.1-1 Amendment No. 44

3.1 DEFUELED SYSTEMS 3.1.2 Spent Fuel Pool Load Restrictions This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI 3.1-2 Amendment No. 44

3.1 DEFUELED SYSTEMS 3.1.3 Fuel Storage Pool Liner Water Level This section is not aplicable in accordance with Humboldt Bay Power Plant, Unit 3 Calculation NX-356, "Radiological Consequences for Breach of Defueled Spent Fuel Pool, June 2009."

LCO 3.1.3 The Fuel Storage Pool Linep Water Level shall be at an ELEVATION less-,o than + 9inhs APPLICABILITY: 'When the water in the pool o ine is co. with radioactive

.ntaminated ACTIONS.___

NODITION REQUIRED ACTIO COMPLETION TIME A.

Se~agePoolLi~er F~l, A.1 Restore Fuel Storage Imdael Water Level not within Pool Liner Water Level Sto within limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify the Fuel Storage Pool Liner Water Level is 24-heum, at an ELEVATION less than + 9i 3.1-3 Amendment No. 44

C-4.0 DESIGN FEATURES 4.1 Site Location HBPP Unit 3 is located in Humboldt County, California, approximately 4 miles southwest of the center of the city of Eureka, on a site owned and controlled by Pacific Gas &

Electric Company.

4.2 Fuel Storage 4.2.1 Fuel assemblies shall not be stored in the Spent Fuel Storage Pool. Fuel assemblies previously stored in the Spent Fuel Storage Pool are now stored in dry casks in the ISFSI.

4.0-1 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility Personnel responsibilities are identified in the Quality Assurance Plan.

5.0-1 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.2 Organization This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

(Pages 5.0-3 and 5.0-4 have been deleted).

5.0-2 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications Facility staff qualifications are identified in the Quality Assurance Plan.

5.0-5 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.4 Training This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

5.0-6 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.5 Procedures 5.5.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. (Deleted)
b. Fire Protection Program implementation;
c. Quality assurance for radiological effluent and environmental monitoring;
d. (Deleted)
e. All programs specified in Specification 5.6.

5.0-7 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.6 Programs and Manuals The following programs shall be established, implemented and maintained.

5.6.1 Offsite Dose Calculation Manual (ODCM)

ODCM requirements are described in the Quality Assurance Plan.

(Continued) 5.0-8 Amendment No. 44

5.6 Programs and Manuals 5.6.2 Technical Specification (TS) Bases Control Program This section is not applicable to a facility with no Limiting Conditions for Operation This pro~gram provides a m~eans for processing changes to the ae of these Technical SpeGifiGatien&s,

a. Changes to the Bases of the TS shall be Made un~der appropriate administrative-controls and reviews.
b. Licensees ma" make changes to Bases without prior NRC approval provided the changes do Rot irnlhve either of the foll*o*Win
1. a change in the TS icroaeinthe ficense; or
2. a change to the updated DSAR or Bases that requires prior NRC

.approval as defined in. I GFR 50.59.

c. The Bases Control Program shall contain provisions to eRsure that the Bases are maintained consistent with the DSAR.
d. 'Proposed changes that mneet the criteria of Specification 5.6.2b above shall be-reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consisteent with 1OCER 50.71 (e).

5.6.3 Fuel Storage Pool Water Chemistry Program This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

5.6.4 Radioactive Effluent Controls Program (RECP)

RECP requirements are described in the Quality Assurance Plan.

(Continued) 5.0-9 Amendment No. 44

5.6 Programs and Manuals THIS PAGE HAS BEEN DELETED 5.0-10 - Amendment No. 44

5.6 Programs and Manuals 5.6.5 Neutron Absorber Surveillance Proqram This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

5.0-11 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements Reporting requirements are described in the Quality Assurance Plan.

(

IJ 5.0-12 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.8 High Radiation Area As provided in paragraph 20.1601(c) of 10CFR 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 10CFR Part 20:

5.8.1 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 a 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 requirement 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 (continued) 5.0-13 Amendment No. 44

5.8 High Radiation Area 5.8.1 Higqh 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 (continued):

(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.

5.8.2 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 foreman, 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 (continued) 5.0-14 Amendment No. 44

5.8 Hiah Radiation Area 5.8.2 Hiqh Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from 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: (continued)

2. 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 with the means to communicate with and control every individual in the area, or
3. 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 (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, or
4. In those cases where options (2) and (3), above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle, a radiation monitoring device that continuously displays radiation dose rates 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 large area, such as the refueling building, 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.

5.0-15 Amendment No. 44

Enclosure 3 PG&E Letter HBL-10-004 RETYPED (CLEAN) VERSION OF PROPOSED CHANGES TO THE HBPP UNIT 3 TECHNICAL SPECIFICATIONS Remove Page Insert Paqe All All

Technical Specifications Humboldt Bay Power Plant Unit 3 Eureka, California

TABLE OF CONTENTS 1.0 USE AND APPLICATION ..................................................................................... 1.1-1 1.1 Definitio ns(D e leted ) .................................................................................... 1.1-1 1.2 Logical Connectors(Deleted) ...................................... ................................ 1.2-1 1.3 Completion Times(Deleted) ....................................... ................................. 1.3-1 1.4 Frequency(Deleted) ................................................................................... 1.4-1 2 .0 S A FE T Y LIM IT S ................................................................................................... 2 .0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ..................... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ................. 3.0-2 3.1 DEFUELED SYSTEMS ........................................................................................ 3.1-1 3.1.1 Fuel Storage Pool Water Level(Deleted) ........................ 3.1-1 3.1.2 Spent Fuel Pool Load Restrictions(Deleted) ............................................... 3.1-2 3.1.3 Fuel Storage Pool Liner W ater Level(Deleted) ........................................... 3.1-3 4.0 DESIGN FEATURES ........................................................................................... 4.0-1 4 .1 S ite Lo ca tio n .............................................................................................. 4 .0 -1 4 .2 F ue l S to rag e .............................................................................................. 4 .0-1 5.0 ADMINISTRATIVE CONTROLS ........................................................................... 5.0-1 5.1 Responsibility(Deleted) .............................................................................. 5.0-1 5.2 Organization(Deleted) ..................................... 5.0-2 5.3 Facility Staff Qualifications(Deleted) ........................................................... 5.0-5 5 .4 T raining(D eleted) ....................................................................................... 5.0-6 5 .5 P ro ce d ures ................................................................................................. 5 .0-7 5.6 Programs and Manuals .............................................................................. 5.0-8 5.7 Reporting Requirements(Deleted) .............................................................. 5.0-12 5.8 High Radiation Area .................................................................................. ;5.0-13 Amendment No. 44

1.0 USE AND APPLICATION This section is not applicable to a facility with no Limiting Conditions for Operation J

1.1-1 Amendment No. 44

2.0 SAFETY LIMITS This section is not applicable since Humboldt Bay Power Plant (HBPP) Unit 3 is permanently defueled.

2.0-1 Amendment No. 44

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY This section is not applicable to a facility with no Limiting Conditions for Operation 3.0-1 Amendment No. 44

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY This section is not applicable to a facility with no Limiting Conditions for Operation 3.0-2 Amendment No. 44

3.1 DEFUELED SYSTEMS 3.1.1 Fuel Storage Pool Water Level This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

3.1-1 Amendment No. 44

3.1 DEFUELED SYSTEMS, 3.1.2 Spent Fuel Pool Load Restrictions This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI 3.1-2 Amendment No. 44

3.1 DEFUELED SYSTEMS 3.1.3 Fuel Storage Pool Liner Water Level This section is not applicable in accordance with Humboldt Bay Power Plant, Unit 3 Calculation NX-356, "Radiological Consequences for Breach of Defueled Spent Fuel Pool, June 2009."

3.1-3 Amendment No. 44

u 4.0 DESIGN FEATURES 4.1 Site Location HBPP Unit 3 is located in Humboldt County, California, approximately 4 miles southwest of the center of the city of Eureka, on a site owned and controlled by Pacific Gas &

Electric Company.

4.2 Fuel Storage 4.2.1 Fuel assemblies shall not be stored in the Spent Fuel Storage Pool. Fuel assemblies previously stored in the Spent Fuel Storage Pool are now stored in dry casks in the ISFSI.

4.0-1 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility Personnel responsibilities are identified in the Quality Assurance Plan.

5.0-1 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.2 Organization This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

(Pages 5.0-3 and 5.0-4 have been deleted).

5.0-2 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications Facility staff qualifications are identified in the Quality Assurance Plan.

J 5.0-5 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.4 Training This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

5.0-6 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.5 Procedures 5.5.1 Written procedures shall be established, implemented, and maintained covering the following activities:

a. (Deleted)
b. Fire Protection Program implementation;
c. Quality assurance for radiological effluent and environmental monitoring;
d. (Deleted)
e. All programs specified in Specification 5.6.

5.0-7 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.6 Programs and Manuals The following programs shall be established, implemented and maintained.

5.6.1 Offsite Dose Calculation Manual (ODCM)

ODCM requirements aredescribed in the Quality Assurance Plan.

(Continued) 5.0-8 Amendment No. 44

5.6 Programs and Manuals 5.6.2 Technical Specification (TS) Bases Control Program This section is not applicable to a facility with no Limiting Conditions for Operation 5.6.3 Fuel Storage Pool Water Chemistry Program This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSI.

5.6.4 Radioactive Effluent Controls Program (RECP)

RECP requirements are described in the Quality Assurance Plan.

(Continued) 5.0-9 Amendment No. 44

5.6 Programs and Manuals THIS PAGE HAS BEEN DELETED 5.0-10 Amendment No. 44

5.6 Programs and Manuals 5.6.5 Neutron Absorber Surveillance Program This section is not applicable to a facility with all of the spent nuclear fuel stored in an ISFSl.

5.0-11 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements Reporting requirements are described in the Quality Assurance Plan.

5.0-12 Amendment No. 44

5.0 ADMINISTRATIVE CONTROLS 5.8 High Radiation Area As provided in paragraph 20.1601 (c) of 10CFR 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 1 OCFR Part 20:

5.8.1 High Radiation Areas with dose Rates Not Exceedinq 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 a 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 requirement 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 (continued) 5.0-13 Amendment No. 44

5.8 High Radiation Area 5.8.1 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 (continued):

(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.

5.8.2 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 foreman, 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 (continued) 5.0-14 Amendment No. 44

5.8 Hich Radiation Area 5.8.2 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from 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: (continued)

2. 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 with the means to communicate with and control every individual in the area, or
3. 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 (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, or
4. In those cases where options (2) and (3), above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle, a radiation monitoring device that continuously displays radiation dose rates 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 large area, such as the refueling building, 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.

5.0-15 Amendment No. 44