ML20045C495

Forwards Proposed TS Changes,In Response to NRC 930510 RAI Re Util 920917 Lar,As Supplemented by 930122 & 0226 Ltrs, Associated W/Implementation of New 10CFR20 Requirements at Plant

ML20045C495
Person / Time
Site:	Vogtle
Issue date:	06/16/1993
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20045C496	List: ML20045C495 ML20045C717
References
LCV-0011, LCV-11, TAC-M84529, TAC-M84530, NUDOCS 9306230192
Download: ML20045C495 (5)

Text

.  :

- 4 cenna Pom comrony 40 kwernew Centu Pa4way Post Cdm Bor ?!s5 D rnn nfam A abm:a 35201 1cWr? e /05 B77 71:?

L '

C. K. McCoy Georgia Power )

QD$l ~~ n souwm enunc svuem June 16, 1993 Docket Nos. 50-424 LCV-0011 i 50-425 TAC Nos. M84529  ;

M84530 l U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS In response to your letter dated May 10,1993, enclosed is the additional information you requested regarding Georgia Power Company's (GPC's) license amendment request dated September 17,1992, as supplemented by letters dated January 22 and Februay 26,1993, associated with implementation of the new 10 CFR 20 requiren'. ts at Vogtle Electric Generating Plant. Enclosure 1 contains your request for additional information as worded in the May 10,1993, letter and our responses. Enclosure 2 contains proposed Technical Specification changes associated with the responses which supersede the corresponding chandes previously rubmitted in support of this license amendment request. Additionally, the conclusions of the significant hazards evaluations contained in the September 17,1992, and February 26,1993, submittals are unaffected by the proposed Technical Specification pages provided in enclosure 2.

Georgia Power Company requests that this proposed license amendment be approved by  !

September 1,1993. It is also requested that the conditions of the license amendment be j made effective upon implementation of the new 10 CFR 20 requirements by GPC, but no i later than Januaq 1,1994.

zl003u M l n Il l n

g &pgN$g(lfkFA .

l 9306230192 PDR 930616ADOCK 0500 g $ g' r _.

i

a U. S. Nuclear Regulatory Commission LCV-0011 Page 2  ;

Should you have any questions regarding this information, please contact this ofTice.

Sincerely, l C. K. McCoy_ <

f CKMffMM

Enclosures:

1. Response to NRC Request for AdditionalInformation

2. Proposed Technical Specification Changes c(w): Georgia Power Company Mr. W. B. Shipman Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S D. Ebneter, Regional Administrater Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle State of Georgia Mr. J. D. Tanner, Commissioner, Department of Natural Resources

- _ . _ . - . . - . - - . _ . - . - _ . _ _m J

}

ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS ,

RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION -,

7 i

i f

J

, _ . . _, ~, . . . - - . - , _ _ . . . . . . . .a . . . . _- , , . . . . ~ . - . , . . . - - ., _ -- . , . .:

. - - . . - ..- -- - - . - ~ - - . -. , --

ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION NBC StafrPosition Regarding Request 470.3 Our previous Request 470.3 asked that you revise TS Bases 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. Your response proposed to incorporate a multiplier of 10 times, as requested. However, since issuing Request 470.3, the NRC staff has determined that our request was inappropriate. Accordingly, you should revise your proposed changes to TS Bases 3/4.11.1.4 to delete the addition of the words "10 times."

GPC Response to Request 470.3 As requested, the proposed Technical Specification bases change submitted by Georgia Power Company (GPC) letter dated January 22,1992, regarding the liquid holdup tanks (bases 3/4.11.1.4), has been revised as shown in enclosure 2. The use of a multiplier of a

" ten times" for the limits of 10 CFR Part 20, Appendix B (to paragraphs 20.1001 -

20.2401), Table 2, Column 2, as previously proposed has been deleted.

NRC StaLTPosition Regarding Rtqug.st 470.6 Our previous Request 470.6 asked that you revise your proposed administrative centrols in TS 6.11.2, "High Radiation Area," to specify a dose rate range greater than 1000 mrem in I hour but less than 500 rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to distinguish the controls needed for a High Radiation Area from the requirements for a Very High Radiation Area (10 CFR 20.1602).

You responded that TS 6.11.2 conservatively applies access control methods that are applicable to all accessible areas in which radiation levels exceed 1000 mrem per hour, i including Very High Radiation Areas, and therefore, that specifying the requested dose rate range is unnecessary. We do not agree that the controls in existing TS 6.11.2 for the High Radiation Area are conservative or adequate with respect to 10 CFR 20.1602. The access control measures imposed by Vogtle's TS at 1000 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> are not adequate to meet the " additional measures" required by 10 CFR 20.i602, over those required in

~

i 10 CFR 20.1601. The High Radiation Area TS provides alternt.te methodology from the

" locking" requirement specified in 10 CFR 20.1601 for areas in which an individual might El-1 4

ENCLOSURE I (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS IlESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATIOE receive a deep-dose equivalent of 100 mrem in I hour at 30 centimeters from the radiation _

• source. The alternate locking requirement specified by the TS is for 1000 mrem in I hour. .1 and above;it is not an " additional measure" relative to 10 CFR 20.1602. We are unable to accept the proposed TS change unless it is limited to less than 500 rads in I hour to distinguish it from the requirements of 10 CFR 20.1602. Accordingly, we again request that you specify a range of greater than 1000 mrem in I hour but less than 500 rads in I hour.

_QPC Response to NRC Request 470.6 As requested, the proposed Technical Specification changes submitted by GPC letter dated September 17,1992, regarding administrative controls for a high radiation area (6.11.2) have been revised and are provided in enclosure 2. These changes add an upper limit for a high radiation area of 500 rads in I hour when measured at a distance of I meter from the radiation source or from any surface which the radiation penetrates. This upper limit represents the threshold for classifying a very high radiation area per 10 CFR 20.1602. These changes will distinguish the administrative control requirements for a high radiation area from the procedural requirements to be established for a very high radiation area.

El-2