ML20057F732
| ML20057F732 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 10/08/1993 |
| From: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20057F728 | List: |
| References | |
| HBL-93-058, HBL-93-58, NUDOCS 9310190039 | |
| Download: ML20057F732 (6) | |
Text
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PG&E Letter No. HBL-93-058 ENCLOSURE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
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Docket No. 50-133 l'
In The Matter of
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Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY )
No. DPR-7
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Humboldt Bay Power Plant
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Unit 3
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License Amendment Request No. 93-02 Pursuant to 10 CFR 50.90, Pacific Gas and Electric Company hereby applies to amend its Humboldt Bay Power Plant Facility Operating License No. DPR-7 (License).
The proposed changes revise the Technical Specifications (Appendix A of the License)Section II, " Site,"Section V, " Monitoring Systems," and Section VII,
" Administrative Controls."
Information on the proposed changes is provided in Attachments A and B.
These changes have been reviewed and are considered not to involve a significant hazards consideration as defined in 10 CFR 50.92 or an unreviewed
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environmental question.
Further, there is reasonable assurance that the health and safety of the public will not be endangered by the proposed changes.
l Sincerely,
\\I
/4 % A4y-- -
Gregory M. Rueger Subscribed and sworn to before me Attorneys for Pacific Gas and this 8th day of October 1993.
Electric Company Howard V. Golub Christopher J. Warner
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,/nv Bi nca E. Zelnik, Notary Public
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o PG&E Letter No. HBL-93-058 ATTACHMENT A REVISION OF TECHNICAL-SPECIFICATION SECTIONS II, V AND VII -
CHANGES DUE TO REVISION OF 10 CFR 20 AND ORGANIZATION TITLE CHANGE A.
DESCRIPTION OF AMENDMENT REQUEST This License Amendment Request (LAR) proposes to revise the Humboldt Bay Power Plant (HBPP) Unit 3 Technical Specifications (TS) by deleting Figure 11-2 in Section II, " Site," by deleting the Restricted Area boundary line in Figure V-3,Section V, " Monitoring Systems," by incorporating a title change into Section VII, " Administrative Controls," and by revising Figure VII-2, " Plant Staff Organization." The specific TS changes proposed are as follows:
1.
Page v, " Figures" Delete reference to Figure 11-2.
2.
Section II.B, " Plant Areas" Change "...is shown in Figure 11-2." to "...shall be defined in plant procedures."
3.
Section II, Page II-3 Delete Figure 11-2.
4.
Section V, Page V-14 Delete the Restricted Area boundary line from Figure V-3, "HBPP
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Groundwater Monitoririg Systems Wells," to be consistent with item 3 above.
5.
Section VII.C.2.e, " Supervisor of Maintenance" Change the title from " Supervisor of Maintenance" to
" Maintenance Planner."
6.
Section VII.D.I.b., " Membership" From the list of " Minimum membership shall include:", replace
" Supervisor of Maintenance" with " Maintenance Planner."
7.
Section VII, Page VII-31 In Figure VII-2, " Plant Staff Organization," replace " Maintenance Supervisor" with " Maintenance Planner."
v 61275/85K,
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i 8.
Section VII, Page VII-31 i
In Figure VII-2, " Plant Staff Organization," both the " Mechanical
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Foreman" and the " Instrument / Electrical Foreman" report directly 1
to the " Plant Manager," not to the " Maintenance Planner," as previously shown.
These proposed changes are noted in the marked-up copy of the applicable TS provided in Attachment B.
B.
BACKGROUND On May 21, 1991, revisions to 10 CFR 20 were published in the Federal-Register.
Included in the changes to 10 CFR 20 were the addition of the definition of member (s) of the public and a modified definition of a restricted area.
In accordance with the definitions in the original version of 10 CFR 20, a restricted area is any area that is controlled by a licensee for the purpose of protecting individuals from exposure to radiation or radioactive materials. Any dose that is received in a restricted area is considered occupational exposure. An unrestricted area is any area in which access is not controlled or limited by the licensee for purposes of protection of individuals from exposure to radiation or i
radioactive materials, and any area used for living quarters.
In accordance with the new revision to 10 CFR 20, an unrestricted area is any area to which access is neither controlled nor limited by the licensee. A member of the public is any individual outside a restricted area not receiving occupational dose. A member of the public is controlled to more restrictive radiation exposure limits than an individual that receives occupational radiation exposure. The definition of restricted area did not change as a result of the revision to 10 CFR 20.
A recent NRC interpretation of 10 CFR 19.12 resulting from the recent revision of 10 CFR 20 was provided to NUMARC in a letter dated l
September 14, 1992. This interpretation was contained in a series of
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questions and answers sets concerning the revision of 10 CFR 20 that 1
were primarily intended for training NRC inspectors.
From information in the questions and answers set, it would appear that the NRC expects that in the future, individuals that infrequently enter a restricted area must be provided (1) some instruction concerning radiation and radioactive materials, and (2) must be informed that they are subject to occupational dose limits, regardless of the potential radiological health protection concerns.
In order to limit the number of infrequent visitors that require training concerning radiation and radioactive materials, and to allow them to be more appropriately controlled to member-of-the-public dose limits, portions of the facility at various elevations within the current restricted area will be removed from the restricted area.
This will eliminate areas where exposure is well below allowable member-of-the-public dose limits.
61275/85K C. -
JUSTIFICATION.
I Redefining the restricted area will allow HBPP to better comply with recent interpretations of 10 CFR 19.12 expected to be implemented in the future. Additionally, the deletion of the restricted area from TS Section II, Figure II-2, allows radiation exposure for members-of-the-public and certain classifications of employees to be more appropriately controlled to member-of-the-public dose limits when on portions of the site where no radiological health protection concerns exist.
I The proposed changes to TS Section VII are necessary to accurately reflect the current plant organization title within PG&E's Nuclear Power.
Generation Department.
-l D.
SAFETY EVALUATION The restricted area is currently defined in Figure 11-2 of TS Section II. Upon removal of the reference to restricted area identified by Figure 11-2, the restricted area will be defined and controlled in i
plant procedures, in accordance with the requirements of the recent i
revision to 10 CFR 20.
The removal of the restricted area from Figure II-2 will have no effect on the dose that a member-of-the-public receives. The removal of the restricted area from Figure 11-2 will have no impact on the l
determination of effluent release doses since the effluent release dose rates are based on the site boundary. The removal of the restricted area will have no impact on the emergency plan, since emergency plan limits are based. on the exclusion area boundary.
Finally, the removal of the restricted area will have no impact on the security plan since the area previously. designated as a restricted area will still be controlled by PG&E. Current security procedures are adequate to limit
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access to the area-between the unrestricted area and the restricted area.
The proposed changes to TS Section VII are administ mtive in nature.
i Based on the above evaluation, PG&E believes there is reasonable assurance that the health and safety of the public will not be adversely affected by the proposed TS changes.
E.
NO SIGNIFICANT HAZARDS EVALUATION PG&E has evaluated the no significant hazards considerations involved with the proposed amendment, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:
The Commission may make a final determination, pursuant to the procedures-in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the i
proposed amendment would not l
6127S/85K,
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(1)
Involve a significant increase in the probability or consequences of an accident previously evaluated; or 1
(2)
Create the possibility of a new or different kind of accident from any accident previously evaluated; or i
(3)
Involve a significant reduction in a margin of safety.
l The following evaluation is provided for the no significant hazards consideration standards:
1.
Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
A change to the defined restricted area has no affect on any plant operating parameters.
Consequently, a change to the defined restricted area will not affect the probability or consequences of an accident occurring.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed revisions to the HBPP TS are administrative in nature.
Further, the proposed changes would not result in any l
physical alteration to any plant system, and there would not be a change in the method by which any safety-related system performs its function.
s Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does the change involve a significant reduction in a margin of safety?
4 The proposed revisions to the HBPP TS do not affect the margin of safety of any accident analysis since they do not affect the parameters for any accident analysis, and have no effect on the current operating methodologies or actions which govern plant performance.
Therefore, the prrposed change does not involve a significant reduction in a margin of safety.
F.
N0 5IGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above safety evaluation, PG&E concludes that the changes proposed by this LAR satisfy the no significant hazards consideration standards of 10 CFR 50.92(c) and, accordingly, a no significant hazards
- consideration finding is justified.
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.J G.
ENVIRONMENTAL EVALUATION PG8E has evaluated the proposed changes and determined the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, 4
- pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed changes is not required.
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P 6127S/85K,
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