ML19261A413
| ML19261A413 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/10/1979 |
| From: | Gilleland J TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TVA-BFNP-TS-120, NUDOCS 7901180151 | |
| Download: ML19261A413 (12) | |
Text
TENNESSEE VALLEY AUTHORsTY CH ATTA NOOG A. T EN N ESS EE 37401 500C Chestnut Street Tower II JAN 101979 TVA BFNP TS 120 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
In the Matter of the
)
Docket Nos. 50-259 Tennessee Valley Authority
)
50-260 50-296 In accordance with the provisions of 10 'TR Part 50.59, we are enclosing 45 copies of a requested amendment to 1.ensen DPR-33, DPR-52, and DPR-68 to change the technical specifications of Browns Ferry Nuclear Plant units 1, 2, and 3. provides the description of and justification for a change to the testing requirements of the Standby Gas Treatment System (SCTS). Enclosure 2 provides the description of and justification for a 1
change to the radiation control procedures. Approval of this requested 4
change is needed as soon as possible to make the testing requirements of the SGTS consistent with similar requirements of other ventilation systems and to resolve differences of interpretation between TVA and NRC's Office of Inspection and Enforcement.
In accordance with the requirements of 10 CFR Part 170.22, we have determined this proposed amendment to be Class II.
This classification is based on the fact that the proposed amendment is an administrative change that has no safety significance. The remittance for $1200 is being wired to the NRC, A*.tentions Licensing Fee Management Branch.
Very truly yours, o,
L bb t)L
/ J. E. G111 eland Assistant Manager of Power Subscribed and sworn to before me this /d
- day of 1
,o eiv1979.
)
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THIS DOCUMENT CONTAINS o
/d,,ay(@'
Ma um,.
POOR QUAUTY PAGES Notary Public rj
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My Commission Expirea / Y 1
Enclosures cc: See page 2
?S01186i5l An Equal Oppor tumty L mp! oyer
2-Mr. Harold R. Denton J.4[I l O lb7b cc (Enclosures):
Mr. Charles R. Christopher Chairman, Limestoca County Co-=iosion P.O. Box 188 Athens Alabana 35611 Dr. Ira L. Myers State 11ealth Officer State Department of Public Ilealth State Offica Building Montgomsry, Alabama 36104
O O
8 4
ENCLOSURE 1
UNIT 1
LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
- 3. 7,COffrAINMENT SYSTEMS 4.7 CO?TTAINMENT SYSTEMS 2.
a.
The tests and 2.
a.
The results of sample analysis the in-place of Specification cold DOP and 3.7. B. 2 shall be halogenated Performed at hydrocarbon least once per tests at 2 10%
Operating cycle design flow on or once every 18 HEPA filters and months whichever charcoal occurs first for adsorber banks shall show 2995 standby service DOP removal and or af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of 2991 halogenated hydrocarbon system opention removal when and follovAng tested in significant accordance with painting, fire or chemical ANSI N510-1975, release in any ventilation zone b.
The results of laboratory communicating carbon sample with the systaa.
analysis shall b.
cold DOP testing show 290%
shall be radioactive methyl iodide Performed after each complete or removal when tested in Partial replacement of accordance witia the BEPA filter ANSI N510-1975 bank or after (1300C, 951 R. H. ),
any structural ma n enance on c.
System shall be the system shown to operate housing.
within +10%
design flow c.
Halogenated e
hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on 237 the system housing.
UNIT 2 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
- 3. 7 CotFAINMENT SYSTEMS 4.7 COffrAINMENT SYSTEMS 2.
a.
The teste and 2.
a.
The results of sample analysis the in-place of Specification cold DOP and 3.7.B.2 chall be halogenated performed at hydrocarbon least once per teete at 2 10%
operating cycle design flow on or once every 18 HEPA filters and months whichever charcoal occura first for adsorber banks standby service shall show 299%
DOP removal and or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of 299% halogenated hydrocarbon system operation and following removal when tested in significant accordance with painting, fire or chemical ANSI N510-1975.
release in any ventilation zone b.
The results of communicating laboratory with the ayates.
carbon aample analysis shall b.
Cold DOP testing shew 290%
shall be radioactive performed af ter methyl iodide each complete or removal when partial tested in replacement of accordance with the HEPA filter ANSI N510-1975 bank or after (1300C, 955 any structural R.H.),
main nance on lSystemshallbe the eyotem c.
shown to operate housing.
within +10%
design flow.
c.
Halogensted hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorter bank or after any structural maintenance on 237 the system housing.
cNIT 3 LIMITING CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS
- 3. 7 cottrAINMENT SYSTEMS 4.7 CO?frAINMENT SYSTEMS 2.
a.
The results of 2.
a.
The tests and sample analysis the in-place cold DOP cad Of Specification 3.7.B.2 shall be halogenated Performed at hydrocarbon least once per tests at 2 10 %
design flow on Operating cycle HEPA filters and or once every 18 charcoal months whichever adsorber banks occurs first for shall show 299%
standby service DOP removal and or af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of 299% halogenated hyd rocarbon system operation removal when and following tested in significant accordance with Painting, fire ANSI N510-1975.
or chemical release in any ventilation zone b.
The results og laboratory communicating carbon sample with the system, analysis shall show 290%
b.
Cold DOP testing shall be radioactive methyl iodide Performed af ter removal when each complete or tested in Partial accordance with replacement of the BEPA filter ANSI N510-1975 bank or after (1300C, 95%
R.H.),
any structural a
nance on lSystemsha))
c.
be the system shown to operate housing.
within +10%
de81gn flow.
c.
Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any s tructural maintenance on 248 the system housing.
JUSTIFICATION FOR REQUESTED CHANGE This change will rake testing of the Standby Cas Treatment System responsive to system performance. Such testing will be in compliance with ANSI-N510-1075 and will be consistent with other technical specification ventilation tests.
9 e
ENCLOSURE 2
UNIT 1 t.0 ADMINISTRATIVE CONTROLS C.
Drills on actions to be taken under emergency conditions involving release of radioactivity are op>cified in th e radiological emorgency plan and shall be conducted annually.
Annual drillo shall also be conducted on the actions to be taken following failures of safety related systema or components.
D.
Radiation control Procedures Radiation Control Procedures shall be maintained and nade available to all station pernonnel.
These procedurco shall show permissible radiation exposure and nhall be connistent with the r equ i r e me n t. r. of 10 CFP 20.
This radiation protection program shall te organized to meet the requi remento of 10 CFR 20 except in lieu of the
" con trol device" or " alarm signal" required by paragraph
- 20. 203 (c) (2) of 10 C FR 20:
1.
Each High Hadiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricadod and conspicuously posted an a High Radiation Area, and entrarme thereto shall be controlled by issuance of a special work permit.
Any individual or group of individualo permitted to enter such areas shall be provided with a radiation monitoring device waich continuously indicates the radiation dose white in the area.
2.
Each High Nadiation Area in which the intensity of N'
radiation to greater than 1,0 0 0 mre m/h r nh a ll be subject to the provisions of (a) above; and, in addition, locked doors chall be provided to prevent unauthorized entry into such areas, and the keys shall be maintained under administrative control of the chift engineer on duty.
3.
Pursuant to 10 CFR 20.103 (c) (1) and (3), a llowanc e can be made for the use of respiratory protective equipment in conjunction with activitien authorized by the operating license for this plant in determining whether individuals in Leotricted areas are exposed to concentrations in exceae of the limits specified in Appendix B, Table I, Column 1,
of 10 CFR 20, nubject to the follo. ting condition and limitations:
e The limito provided in section 20.10 3 (a) and (b) are not ex ce eded.
339
UNIT 2 6.0 ADMT.NISTRATIVE coNTROI.S C.
Drillo on actions to be taken under emergency conditione involving release of radioactivity a re op cified in the radiologica l emergency plan and chall be conducted
~
annually.
Annual drilla shall also be conducted (n the action s to be taken following failures of safety related systema or components.
D.
Radiat ion cont r ol Procedures Radirtion Cont rol Proceduren shall be :nai n t ained mia nade availablo to all station personnel.
The n.-
proceduren shall show pe rm i e s i bl e radiation e xposu r e and nhalI be con ni n t en t with the r equi r omen t e. o t' 10 cim 20 This radiation protection progran nhall b"
o rg.m iz e d '>
meet the requi rement o of 10 CFR 20 except in lieu of the
" con tr ol device" or " alarm signal" required by paragraph
- 20. 203 (c) (2) of 10 CFR 20:
1.
Each Hign Rad i a ti on Area in which t he intensity of radiation is greater than 100 m rem /hr but less th a r.
1,000 mrem /hr shall be barricaded and conspicuouuly posted an a High Radiation Area, and entrance thereto 9 hall be controlled by insuance of a special work permit.
Any individus1 or group of i ndi vidua l n permitt ed t o enter such areau shall be provided with a radiation monitoring device which continuously indicates the radiation dose while in the area.
2.
Each High Hadiation Area in which the intensity of N
radiation to greater than 1,000 mre:r/hr nhall be subject t o th e provisions of (a) atoie; and, in addition, I c>cked doors chall he pravided to prevent unauthorized entry into nuch areas, and the keys shall be maintained under administrative control of the ehlft engineer on duty.
3.
Pursuant to 10 CFR 20.103 (c) (1) and (3), allowance can he made for the une of respiratory protectivo equipment in conjunction with activities authorized by the operating li cen s e for this plant in determining whether individuals in teatricted aread a re exposed to concentrations in excess of the limi t s specified in Appendix B, Table I, Column 1,
of 10 CPR 20, subject to the follo.<ing condition and limitatione:
a.
The li mi to provided in sect. ion 20.10 3 (a) and (b) are not exceeded.
339
UNIT 1 6.0 ADMINISTRATIVE CONTROLS i
I C.
Drills on actions to be taken under emergency conditions involving release of radioactivity are specified in the radiological emergency plan and shall be conducted annually.
Annual drills shall also be conducted on the actions to be taken following f ailures of safety related systems or components.
D.
Radiation Control Procedures Radiation Control Procedures shall be maintained and made available to all station personnel.
These procedures shall show permissible radiation exposure and shall be consistent with the requirements of 10 CFR 20.
This radiation protection program shall be organized to meet the requirements of 10 CFR 20 except in lieu of the
" control device" or " alarm signal" required by paragraph
- 20. 203 (c) (2) of 10 CPR 20:
1.
Each High Radiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and conspicuously posted as a High Radiation Area, and entrance thereto shall be controlled by issuance of a special work permit.
Any individual or group of individuale permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose while in the area.
2.
Each High Radiation Area in which the intensity of radiation is greater than 1,000 nrem/hr shall be subject to the provisions of (a) above; and, in addition, locked doors shall be provided to prevent unauthorized entry into such areas, and the keyn shall be maintained under administrative control of the shif t engineer on duty.
3.
Pursuant to 10 CFR 20.103 (c) (1) and (3), allowance can be made for the use of respiratory protective equipment in conjunction with activities authorized by the operating license for this plant in determining whether individus1s in restricted areas are exposed to concentrations in excess of the limits specified in Appendix B, Table I, Column 1, of 10 CFR 20, subjec+ to the following condition and limitations:
a.
The Limits provided in section 20.103 (a) and (b) are not exceeded.
369
JUSTIFICATION FOR REQUESTED CHANGE The present requirement for entry into high radiation areas contains some ambiguous wording which has been interpreted differently by plant management and NRC Inspection and Enforcement personnel. This change will clarify the requirement for entry into high radiation areas.