ML18153B372
| ML18153B372 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 11/15/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18153B373 | List: |
| References | |
| 93-404A, NUDOCS 9311300064 | |
| Download: ML18153B372 (14) | |
Text
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e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 November 15, 1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 and 2 Serial No.
NL&P/EJL:*
Docket Nos.
License Nos.
. PROPOSED TECHNICAL SPECIFICATIONS CHANGES 10 CFR 20 IMPLEMENTATION - SUPPLEMENTAL CHANGES 93-404A RO 50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 In our letter to you dated July 16, 1993 (Serial No.93-404) we requested amendments, in the form of changes to the Technical Specifications, to Facility Operating License Nos. DPR-32, DPR-37, NPF-4 and NPF-7 for Surry Power Station Units 1 and 2, and North Anna Power Station Units 1 and 2, respectively. The proposed changes would implement the revised 1 O CFR 20, revise the frequency of the radiological release reports from semi-annual to annual, and clarify the site maps.
Subsequently, on October 1, 1993 the NRC staff contacted us to discuss these amendment requests. As a result of this discussion we are proposing supplemental changes to our original amendment requests.
Discussions of the proposed supplemental Technical Specifications changes are provided in Attachment 1 for Surry and Attachment 3 for North Anna. The proposed supplemental Technical Specifications changes are provided in Attachment 2 for Surry and Attachment 4 for North Anna. The material in Attachments 2 and 4 replace the corresponding proposed changes in our July 16, 1993 submittal. It has been determined that the proposed supplemental Technical Specifications changes do not involve an unreviewed safety question as defined in 1 O CFR 50.59 or a significant hazards consideration as defined in 1 O CFR 50.92. The basis for our determination that these changes do not involve a significant hazards consideration is provided in. The proposed Technical Specifications changes have been reviewed and approved by the Station Nuclear Safety and Operating Committees and the Management Safety Review Committee.
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Should you have any questions or require additional information, please contact us.
Very truly yours, qf?c(l)~
f-r W. L. Stewart Senior Vice President - Nuclear Attachments cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRG Senior.Resident Inspector Surry Power Station Mr. R. D. McWhorter NRG Senior Resident Inspector North Anna Power Station Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219
COMMONWEAL TH OF VIRGINIA )
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COUNTY OF HENRICO
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e The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Vice President - Nuclear Operations, for W. L. Stewart who is Senior Vice President - Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this ~o<..._711
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My Commission Expires:
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Discussion of Changes Surry Power Station
Discussion of Changes Introduction Virginia Electric and Power Company requested changes to the Surry Unit 1 and Unit 2 Technical Specifications by letter dated July 16, 1993. The proposed changes comply with the revised 1 O CFR 20 regulations for radiation protection published in the Federal Register on May 21, 1991 and the change in radiological effluent reporting requirements published in the Federal Register on August 31, 1992. A notice that the NRC had made a proposed finding that no significant hazard exists was published on August 18, 1993 in the Federal Register (58FR43937).
On October 1, 1993 a conference call was held with the NRC staff. The NRC staff is working on a generic letter that would provide guidance for licensees who are revising Technical Specifications in order to implement the revisions to 1 O CFR 20.
Based on our discussion with the NRC staff, certain portions of our previously submitted Technical Specifications change request are being changed to be consistent with the NRC draft generic letter. The changes described in this supplemental change request replace the corresponding proposed changes in our July 16, 1993 submittal.
Technical Specification Changes
- 1.
Technical Specification 6.4.B.1 - Our July 16, 1993 submittal proposed to change the 10 CFR Part 20 reference from section 203(c)(2) to 1601 (a)(1 ).
Section 1601 (a)(1) describes one type of control device for an access point to a high radiation area. However this Technical Specification addresses "control device" or "alarm signal" required by the regulations. Section 1601 addresses both control features and is the correct replacement for section 203.(c)(2). This change proposes to replace section 203(c)(2) with section 1601. This is the only change being proposed for this section of the Technical Specifications.
Our July 16, 1993 submittal also proposed to add the access controls required by 1 O CFR Part 20.1602, Control of access to very high radiation areas. The NRC staff has said that the draft generic letter will not address control of access to very high radiation areas. The Technical Specifications do not currently specify requirements for very high radiation areas. This change proposes to delete the 1 O CFR Part 20.1602 requirements.
- 2.
Technical Specification 6.4.B.2 - Our July 16, 1993 submittal did not propose any changes to this section of the Technical Specifications. However, the NRC staff has said that the draft generic letter will limit the applicability of the requirements of this section of the Technical Specifications to high radiation areas and exclude very high radiation areas. This will be done by adding an upper limit of "but less than 500 rads/hr. at one meter from a radiation source or any surface through which radiation penetrates" to the applicability.
This change proposes to add the limit to the applicability in accordance with the draft generic letter. This is the only change being proposed for this section of the Technical Specifications.
Surry Discussion of Changes 1
e
- 3.
Technical Specification 6.6.B.3 - Our July 16, 1993 submittal proposed to establish the Annual Radioactive Effluent Release Report submittal deadline as April 1. The NRC staff has indicated that their draft generic letter will specify May 1 as the deadline. This change proposes to utilize the May 1 date. The remainder of this Technical Specification is the same as discussed in our July 16, 1993 submittal.
Safety Significance These supplemental changes do not alter the conclusions of the safety evaluation associated with our July 16, 1993 submittal. The proposed change to the Part 20 reference that addresses the "control device" or "alarm signal" for an access point to a high radiation area is an administrative issue. Section 1601 is the section of 1 O CFR Part 20 that addresses both control features and takes the place of section 203(c)(2).
This proposed change has no safety significance.
The proposed change to explicitly include the description of the applicability boundary between high radiation areas and very high radiation areas is an administrative issue that conforms to 1 O CFR Part 20 and the draft generic letter. The requirements for very high radiation areas are specifically addressed by 1 O CFR Part 20. This proposed change has no safety significance.
The proposed change associated with the Annual Radiological Effluent Release Report submittal deadline is an administrative issue. The report submittal deadline date neither affects plant operations nor the ability to meet regulatory limits. This proposed change has no safety significance.
Surry Discussion of Changes 2
e Technical Specifications Changes Surry Power Station
TS 6.4-2
- 1.
In lieu of the "control device" or "alarm signal" required by paragraph 20.1601 of 10 CFR 20, each high radiation area in
- 1 which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:
- a.
A radiation monitoring
- device which continuously indicates the radiation dose rate in the area.
- b.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
- c.
An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device.
This individual is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by Health Physics in the RWP.
Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved plant radiation protection procedures for entry into high radiation areas.
Amendment Nos.
TS 6.4-3
- 2.
The requirements of 6.4.B.1 above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr, but less than 500 rads/hr at one meter from a radiation source or any surface through which radiation penetrates.
In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control. of the Shift Supervisor on duty and/or the senior station individual assigned the responsibility for health physics and radiation protection.
- 3.
Written procedures shall be established, implemented, and maintained.covering the activities referenced below:
- a.
Process Control Program implementation.
- b.
Offsite Dose Calculation Manual implementation.
C.
All procedures described in 6.4.A and 6.4.B, and changes thereto, shall be reviewed and approved by the Station Nuclear Safety and Operating Committee prior to implementation.
Amendment Nos.
B.
e TS 6.6-10 Unique Reporting Requirements
- 1.
tnseryjce Inspection Evaluation Special summary technical report shall be submitted to the Director of Reactor Licensing, Office of Nuclear Reactor Regulation, NRC, Washington, D.C. 20555, after 5 years of operation. This report shall include an evaluation of the results of the inservice inspection program and will be reviewed in light of the technology available at that time.
- 2.
Annual Radiological Environment Operating Report1 The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year.
The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 1 O CFR Part 50.
- 3.
Annual Radioactive Effluent Release Report3 the Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year shall be submitted by May 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.
Amendment Nos.
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Discussion of Changes North Anna Power Station
e Discussion of Changes Introduction Virginia Electric and Power Company requested changes to the North Anna Unit 1 and Unit 2 Technical Specifications by letter dated July 16, 1993. The proposed changes comply with the revised 1 O CFR 20 regulations for radiation protection published in the Federal Register on May 21, 1991 and the change in radiological effluent reporting requirements published in the Federal Register on August 31, 1992. A notice that the NRC had made a proposed finding that no significant hazard exists was published on August 18, 1993 in the Federal Register (58FR43937).
On October 1, 1993 a conference call was held with the NRC staff. The NRC staff is working on a generic letter that would provide guidance for licensees who are revising Technical Specifications in order to implement the revisions to 1 O CFR 20.
Based on our discussion with the NRC staff, certain portions of our previously submitted Technical Specifications change request are being changed to be consistent with the NRC draft generic letter. The changes described in this supplemental change request replace the corresponding proposed changes in our July 16, 1993 submittal.
Technical Specification Changes
- 1.
Bases 3/4.11.1.4 - Our July 16, 1993 submittal stated that the uncontrolled release of the contents of the liquid holdup tanks addressed by Technical Specification 3/4 11.1.4 would result in concentrations in the nearest potable water supply and the nearest surface water supply in unrestricted areas less than ten times the limits of 1 O CFR Part 20, Appendix B, Table 2, Column 2.
After further review and discussion with the NRC staff, it has been concluded that the concentration limits will not be exceeded. Additionally, the NRC staff has indicated that the draft generic letter will not make reference to 'ten times the limits". This change deletes the reference to ten times the limits. The remainder of this Bases is the same as discussed in our July 16, 1993 submittal.
- 2.
Technical Specification 6.9.1.9 - Our July 16, 1993 submittal proposed to establish the Annual Radioactive Effluent Release Report submittal deadline as April 1. The NRC staff has indicated that their draft generic letter will specify May 1 as the deadline. This change proposes to utilize the May 1 date. The remainder of this Technical Specification is the same as discussed in our July 16, 1993 submittal.
- 3.
Technical Specification 6.12.1 - Our July 16, 1993 submittal proposed to change the 1 O CFR Part 20 reference from section 203(c)(2) to 1601 (a)(1 ).
Section 1601 (a)(1) describes one type of control device for an access point to a high radiation area. However this Technical Specification addresses "control device" or "alarm signal" required by the regulations. Section 1601 addresses both control features and is the correct replacement for section 203.(c)(2). This change proposes to replace section 203(c)(2) with section 1601. This is the only change being proposed for this section of the Technical Specifications.
North Anna Discussion of Changes 1
Our July 16, 1993 submittal also proposed to add the access controls required by 1 O CFR Part 20.1602, Control of access to very high radiation areas. The NRC staff has said that the draft generic letter will not address control of access to very high radiation areas. The Technical Specifications do not currently specify requirements for very high radiation areas. This change proposes to delete the 10 CFR Part 20.1602 requirements.
- 4.
Technical Specification 6.12.2 - Our July 16, 1993 submittal did not propose any changes to this section of the Technical Specifications. However, the NRC staff has said that the draft generic letter will limit the applicability of the requirements of this section of the Technical Specifications to high radiation areas and exclude very high radiation areas. This will be done by adding an upper limit of "but less than 500 rads/hr. at one meter from a radiation source or any surface through which radiation penetrates" to the applicability.
This change proposes to add the limit to the applicability in accordance with the draft generic letter. This is the only change being proposed for this section of the Technical Specifications.
Safety Significance These supplemental changes do not alter the conclusions of the safety evaluation associated with our July 16, 1993 submittal. The proposed change to the Bases for the activity limit for the liquid holdup tanks merely clarifies the description of the results of an uncontrolled release of the contents of the tanks. The appropriate regulatory limits will be met. This proposed change has no safety significance.
The proposed change associated with the Annual Radiological Effluent Release Report submittal deadline is an administrative issue. The report submittal deadline date neither affects plant operations nor the ability to meet regulatory limits. This proposed change has no safety significance.
The proposed change to the Part 20 reference that addresses the "control device" or "alarm signal" for an access point to a high radiation area is an administrative issue.
Section 1601 is the section of 1 O CFR Part 20 that addresses both control features and takes the place of section 203(c)(2).
This proposed change has no safety significance.
The proposed change to explicitly include the description of the applicability boundary between high radiation areas and very high radiation areas is an administrative issue that conforms to 1 O CFR Part 20 and the draft generic letter. The requirements for very high radiation areas are specifically addressed by 1 O CFR Part 20. This proposed change has no safety significance.
North Anna Discussion of Changes 2
Technical Specifications Changes North Anna Power Station