ML20044C507
| ML20044C507 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/19/1993 |
| From: | George Wunder Office of Nuclear Reactor Regulation |
| To: | Hairston W SOUTHERN NUCLEAR OPERATING CO. |
| References | |
| TAC-M84331, TAC-M84332, NUDOCS 9303230195 | |
| Download: ML20044C507 (5) | |
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March 19, 1993 Docket Nos. 50-348 and 50-364 Mr. W. G. Hairston, III Executive Vice President Southern Nuclear Operating Company, Inc.
Post Office Box 1295 i
Birmingham, Alabama 35201-1295 l
Dear Mr. Hairston:
SUBJECT:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED TECHNICAL SPECIFICATION CHANGES TO IMPLEMENT NEW 10 CFR PART 20 - JOSEPH M.
l FARLEY NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M84331 AND M84332)
By letter dated August 24, 1992, Southern Nuclear Operating Company requested an amendment to the Technical Specifications for the Joseph M. Farley Nuclear Plant, Units 1 and 2.
This amendment request was associated with the implementation of the new 10 CFR Part 20 requirements.
By letter dated November 18, 1992, the staff requested additional information regarding your amendment request. This additional information was provided in a letter dated December 17, 1992.
The staff has reviewed your response and has determined that certain of our concerns have not been addressed fully; therefore, we will require more information in order to complete our review.
The staff's evaluation of your December 17, 1992, response, along with a detailed description of the additional information we require, is provided in the Ehclosure.
If you have any questions, please do not hesitate to contact me.
Sincerely, ORIGINAL SIGNED BY:
9303230195 930319 George F. Wunder, Project Manager i
DR ADOCK0500g8 Project Directorate 11-1 p
Division of Reactor Projects I/II
Enclosure:
Office of Nuclear Reactor Regulation
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Document Name: FAR84331.RAI L<>
j Mr. W. G. Hairston, Ill Joseph M. Farley Nuclear Plant i
Southern Nuclear Operating l
Company, Inc.
cc:
Mr. R. D. Hill, Jr.
State Health.0fficer General Manager - Farley Nuclear Plant Alabama Department of Public Health Southern Nuclear Operating Co., Inc.
434 Monroe Street Post Office Box 470 Montgomery, Alabama 36130-1701 Ashford, Alabama 36312 Chairman Mr. B. L. Moore, Licensing Manager Houston County Commission Southern Nuclear Operating Co., Inc.
Post Office Box 6406 Post Office Box 1295 Dothan, Alabama 36302 Birmingham, Alabama 35201-1295 Regional Administrator, Region 11 James H. Miller, III, Esquire U. S. Nuclear Regulatory Commission Balch and Bingham Law Firm 101 Marietta St., N.W., Ste. 2900-Post Office Box 306 Atlanta, Georgia 30323 1710 Sixth Avenue North Birmingham, Alabama 35201 Resident inspector U.S. Nuclear Regulatory Commission Post Office Box 24 - Route 2 Columbia, Alabama 36319 ll t
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4 ENCLOSURE i
REVIEW 0F FARLEY NUCLEAR PLANT RESPONSE TO NRC REQUEST FOR ADblTIONAL INFORMATION (RAI) ON THEIR PROPOSED TECHNICAL SPECIFICATION CHANGES TO INCORPORATE THE NEW 10 CFR PART 20 Ouestion 470.1 This question asked the licensee to revise the BASES section 3/4.11.1.4, LIQUID HOLDUP TANKS, to use a multiplier of "10 times" for the values of Appendix B, Table 2, Column 2 to 10 CFR Part 20.1001-20.2401.
The licensee responded by incorporating a multiplier of " ten times".
NRC response:
Subsequent to our issuance of the RAI, the staff determined that the use of the multiplier "10 times" for the values of Appendix B, Table 2, Column 2 to 10 CFR Part 20.1001-20.2401 was inappropriate for inclusion in the BASES section of the TS and should not be used.
i The licensee should revise the BASES section to remove the words " ten times".
Question 470.2 This question asked the licensee to remove, from " INSERT 3B",
of the Administrative Controls, section e. Radioactive Effluent Controls Program, the phrase "which corresponds to a dose rate of 500 mrem / year total effective dose equivalent".
l The licensee responded by removing the phrase from the body of the TS and added a footnote which states "At any time, ten times the concentrations stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 1, corresponds to a dose rate of 500 mrem / year total effective dose equivalent."
The licensee maintains that this reference is needed as a clarifying statement for use in conjunction with their emergency preparedness procedures.
NRC response:
The use of this footnote as a clarifying statement for other licensee documents and which provides no additional control in the context of the TS is unacceptable. Additionally, the statement is not correct. The multiplier of 10 does not apply to radionuclides for which the major exposure pathway is from submersion. For those radionuclides with a " submersion" classification, the use 1
of a multiplier of 10 would correspond to a dose rate of 1000 mrem / year total effective dose equivalent.
l The licensee should be requested to remove the footnote.
Question 470.3 This question asked the licensee to revise their Administrative Controls, section 6.12, High Radiation Area TS to acknowledge that there are three controls listed in 10 CFR 20.1601(a) versus only two listed in the TS.
2 The licensee responded that there is no change in the wording used in the new rule versus the old, so "since the regulatory requirements addressed by this TS have not changed, the wording need not be changed".
i NRC response:
The licensee's response is acceptable. The request to revise i
the TS is withdrawn.
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Ouestion 470.4 This question asked the licensee to revise their Administrative Controls, section
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6.12, High Radiation Area TS to specify a range of greater than 1000 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> but less than 500 rads in I hour, in order to distinguish it from the requirements for the Very High Radiation Area rule (20.1602).
i The licensee responded that it is not necessary to specify a range because their
~j TS already controls high radiation areas and "as a conservative measure", their TS " establish additional restrictions upon access to areas where an individual l
could receive a dose of 1000 mrem in a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period". The licensee concludes that "Therefore, although the requirements for controlling access to a high radiation area apply to a range from 100 mrem in I hour to 500 rads in I hour (very high radiation area), SNC imposes additional requirements for those high i
radiation areas which could result in a dose equivalent of greater than 1000 mrem in I hour".
NRC response:
g The licensee's response that existing TS (TS 6.12, High Radiation Area) requirements encompass conservative controls necessary to comply with the requirements of 20.1602 is.not correct. Their justification maintains 'that the
" additional restrictions" imposed by their TS at the 1000 mrem in I hour are adequate to meet the " additional measures" required by the 20.1602, over those required in 20.1601. This is not correct. The high radiation area TS provides alternate methodology from the " locking" requirement specified in 20.1601, for areas in which "...an individual might receive a deep-dose equivalent of 0.1 rem in -1 hour at 30 centimeters from the radiation source...".
The locking requirement is imposed by the TS at 1000 mrem in I hour and above. This brings the TS into conformance with 20.1601.
Therefore, it is not an " additional control" relative to 20.1602.
Although there is no regulatory requirement to i
specify a dose rate range in the TS, the staff's approval cannot continue unless it is limited to less than 500 rads in I hour as required by the new Part 20.
The controls specified by the licensee in the proposed TS (6.12) are not adequate i
to meet the " additional control" requirement specified in 20.1602.
The licensee is requested to specify a range of 1000 mrem in I hour but less than 500 rads in I hour, in order to distinguish it from the requirements of 20.1602.
Question 470.5 This question asked the licensee to propose a TS that " specifies the measures to be taken to control access to very high radiation areas (e.g., a separate plant procedure, approved by the Plant Operations Review Committee, that establishes control requirements for very high radiation areas)".
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The licensee responded that "the existence of a regulatory requirement does not necessarily dictate that a corresponding TS be written. SNC intends to comply without exception to the requirements specified in 10 CfR 20.1602 for controlling access to very high radiation areas; therefore, a specific TS... is not needed".
They add that "... specific regulatory guidance regarding the requirement to establish additional controls... has not yet been provided". "However, as stated above, SNC has established restrictions... to prevent entry into an area.. 1000 mrem within I hour.
These precautions are in addition to those required for a high radiation area and bound the range defined for a very high radiation area".
NRC response:
The request to provide a TS for very high radiation areas is withdrawn. However, as discussed in Question 470.4, the controls specified by the licensee in the proposed TS (6.12, High Radiation Area) are not adequate to meet the " additional control" requirement called for in 20.1602.
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