ML20042D216
| ML20042D216 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/22/1989 |
| From: | Frizzle C Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20042D217 | List: |
| References | |
| CDF-89-158, MN-89-151, NUDOCS 9001080039 | |
| Download: ML20042D216 (4) | |
Text
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s MaineYankee
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RELIABti ELECTRICllY FOR MAINE SINCE 1972 EDISON DRIVE
- AUGUSTA,' MAINE 04336 * (207) 622 4F 10 CFR 50.90 December-22, 1989 MN-89-151
'CDF-89-158 Proposed Change No. 148 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:- L Document Control Deski Washington, D. C.
20555-
Reference:
(a)~ License No. DPR-36 (Docket No. 50-309)
Subject:
Proposed Technical Specification Change No.148 - Locked High Radiation Areas Gentlemen:'
_ Maine Yankee hereby submits, pursuant to 10 CFR 50.90, this application'to-amend Section 5.12, High Radiation Area, of the Technical Specifications to our operating? license, _
.]
. _ This:ame'ndment would provide clarification to the Administrative Control b
f requirements of. Technical Specification 5.12.2.
1 As currently written, Technical Specification 5.12.2 states:
" Locked: doors shall be provided to high radiation areas in which the' radiation intensity is at'such levels that a major portion of
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1the body could receive in any one hour a dose in excess of 1000 mrem to prevent unauthorized access to-those areas.
Keys to those-idoors shall be maintained under the administrative control of the Plant Shift Superintendent on duty and/or the Radiological Controls Section Head."
The proposed change would provide clarification on three points.
First, the
. proposed change would explain how the 1000 mrem is determined.
Second, the proposed change would, through.an added paragraph, address administrative controls for unlocking'the locked doors for access; remote surveillance would be allowed as
- part of these administrative controls.
Third, the proposed change would allow direct surveillance in' lieu of locked doors, in the case of such areas established
-for a period of 30 days or less.
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United States Nuclear Regulatory Commission Page 2 Attention: Document Control Desk MN-89-151 An organizational change is also reflected:
the title " Radiological Controls
.Section Head" is replaced with " Radiation Protection Manager", in Specifications 5.12.1.C and 5.12.2.
A proposed revised Technical Specification page 5.12-1 and new page 5.12-2, with the changes indicated by change bars in the right hand margin, are provided as Attachment A.
The changes are further discussed in the following:
Maine Yankee's Technical Specification 5.12.2 on Locked High Radiation Area controls does not, currently, address how the dose value of 1000 mrem is determined.
Standard Technical Specification (STS) 6.12 clarifies this as " measurement made at 18" from the source of radioactivity." Maine Yankee proposes to include this clarification in Technical Specification 5.12.
Maine Yankee's Technical Specification 5.12.2 on Locked High Radiation Area controls does not currently expressly address accessing these areas.
Paragraph 20.203(c)(2)(iii) of 10 CFR 20 addresses access as follows:
"(2) Each entrance or access point to a high radiation area shall be:
(iii) Maintained-locked except during periods when access to the area is required, with positive control over each individual entry."
The first added paragraph in the proposed change would address administrative controls for access. Additionally, to minimize unnecessary dose (ALARA), the proposed change would allow these administrative controls to include such measures as closed circuit television cameras to be used for monitoring
' work and access to these areas, to control exposure and prevent unauthorized access.
Maine Yankee's Technical Specification 5.12.2 on Locked High Radiation Area controls does not address allowance for compensatory controls for areas which might fall under its requirements for only a short term and for which provision of locked door controls cannot be reasonably achieved.
Paragraph 20.203(c)(4) of 10 CFR 20 states:
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[ United States Nuclear Regulatory Commission Page 3 Attention: - Document Control Desk MN-89-151
"(4) In the case of a high radiation area established for a period of 30 days or less, direct surveillance to prevent unauthorized entry may be s'ubstituted for the controls required by paragraph (c)(2) of this section."
The proposed change to Technical Specification 5.12.2 includes a provision to allow direct surveillance in lieu of locked doors, in the case of areas established for a period of 30 days or less which would otherwise require locked doors _ Maine Yankee wishes to utilize this provision to provide a more effective and ALARA conscious means of controlling access to short-term high exposure areas for which locked doors cannot be reasonably provided.
Maine Yankee recently established a new position of Radiation Protection Manager. The res)onsibilities of the Radiation Protection Manager include tiose currently delineated for the Radiological Controls Section Head in Specifications 5.12.1.C and 5.12.2.
The proposed change reflects this organization change.
Maine Yankee has evaluated the proposed change and has determined that it does not:
involve a significant increase in the probability or consequences of an accident previously. evaluated; create the possibility of a new or different kind of accident from any accident previously evaluated; or involve a significant reduction in a margin _of safety. The Standard Technical Specifications were considered during the preparation of this proposed change; we feel that the controls resulting from this change will be consistent with those of the standard specification. The administrative controls addressed by the proposed change will afford opportunities to reduce personnel radiation exposure, incident to establishing and maintaining controls for the subject areas, without impacting on the intended access and exposure control requirements of the specification.
Therefore, the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92. The evaluation is included in Attachment B.
This proposed change has been reviewed by the Plant Operations Review Committee and the Nuclear Safety Audit and Review Committee. The Plant Operations Review Committee has concluded that the proposed Technical Specification change does not constitute an unreviewed safety question.
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7 United States' Nuclear Regulatory Commission -
Page 4 Attention: Document Control Desk-MN-89-151 Ma'ine Yankee requests that the amendment resulting from-this proposed change be stipulated as to be effective within 30 days of issuance.
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A_ State of Maine representative-is being notified of this proposed change by a copy of this letter.
Very truly yours, Charles D. Frizzle President CDF:SJJ Attachments c:
' Mr. William T. Russell Mr.-Cornelius F. Holden Mr. Eric J. Leeds Mr. Clough Toppan STATE OF MAINE Then personally appeared before me, Charles D. Frizzle, who being duly sworn did state that he is President of Maine Yankee Atomic Power Company, that he is duly authorized to execute and file the foregoing request in the name 'and on behalf of Maine Yankee-Atomic Power Company, and that the statements therein are true to the best of his knowledge and belief.
Notary Public ROMRT C. CROOM MY CoMM " i E*
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