ML20062L730
| ML20062L730 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 12/20/1993 |
| From: | Hildebrand J SAXTON NUCLEAR EXPERIMENTAL CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20062L732 | List: |
| References | |
| C301-93-2008, SNEC-93-0034, SNEC-93-34, NUDOCS 9401040364 | |
| Download: ML20062L730 (10) | |
Text
SAXTON NUCLEAR EXPERIMENTAL CORPORATION uE
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GENERAL P U B LIC UTILITIES SYSTEM SNEc Jersey Central Power & bgnt Company
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Pennsy#vania Electne Company PE Jc Menoontan Edison Company MAIUNG ADDRESS.
TELEPHONE:
1 Upper Pond Rd.
C301-93-2008 (201) 316-7000 Parsippany, NJ 07054 SEC-93-0034 O=aToor 20, 1993 U. S. Mclear Regulatory Onrnission Attn: DocuTunt Control Desk VWshington, D.C.
20555 GentloTen,
Subject:
Saxton Welear Exporirrental Corporation Operating Licenso bb. DPR-4 Docket 2. 50-146 Response to Roquest for Mditional Irdorrmtion Regarding s -
Technical Specification Gange Roquest 54 and Resultant Supplamnt The purpose of this letter is to transnit the responses to the questions resulting f ron tho hRC's review of Technical Specification Qango Roquest (TECR) bb. 54, in addition to the responses to the specific questions, a revised description of characterization is provided to expand the scope of activitles that wili be needed for charactorization.
As a result of the effort to respond to the reviav questions,: revisions have been nudo to the existing TS pages.
Because the supplomntal verding is adninist rat ive in nature and does not change the conclusions rmde in the previously subnitted Safety Evaluation, that Safety Evaluation-for TECR 54 remins valid.
Attachinnt 1 contains the response to the questions and expanded description of intended charactorization activitles is addressed in Attachinnt'2. Attachmnt 3 contains the revised TS pages.
Sincerely, 4( O A 'Q J. E. Hiidobrand President VCH Attachinnts:
_1)
Response to Roquest for Mditional Inforrmtion 2)
Revi ed Description of Charactorization Activitios 3)
Revised TS pages 9401040364 931220 9
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Lj C301-93-008 Page 2 of 2 cc: Administrator, Region I' NRC Project Engineer, Region I NRC Project Engineer NRR 1
NRC Project Scientist, Region I Mr. William Dornsife Mr. Richard Rice Mr. Donald Weaver l
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SAKiGI MDEM EMPERMNFAL GHUMTKN SAXial MDEM FACILITY-Operating License M. DPR-4 Docket M. 50-146 Response to Request for Additional Inforrration:
Technical Specification Change Pequest M. 54 This Technical Specification Change Request is'sutmitted in support of Licensee's-request to change Appendix A to Operating Li"ense it.'DPR-4 for Saxton Mclear Facility. As a part of this. request, proposed replacemnt pages for Appendix A are also included.
SoXTCNNILFE EXPERIMNTAL CHU%TICN BV:
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President SEC Smrn and subscribed to before nu MO day.of b c M 1993.
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C301-93-008
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Page 1 of 5 Question'1 Administrative Organizat.on The Saxton Nuclear Experimental Corporation (SNEC)'is a subsidiary of General Public Utilities (GPU).
SNEC is a non-profit corporation whose ownership ~is divided among three electrical generating companies of GPU on a percentage basis as follows: Jersey Central Power.and Light (44%), Metropolitan Edison (32%), and Pennsylvania Electric Company (24%).
SNEC is maintained by GPU i
Nuclear Corporation (GPUNC) under a service agreement dated May 21, 1982 between GPUNC and SNEC with written agreement of the Pennsylvania Public Utilities Commission.
The SNEC Board of Directors is comprised of the Presidents of etch of the operating companies and GPUNC.
The SNEC Board of Directors elects a President and Vice President from GPUNC i
to carry out the responsibilities of the Corporation. Technical support functions such as quality assurance, radiation protection, and independent safety review are also provided by GPUNC.
The SNEC organization is shown in the included figure.
The radiation protection function is the responsibility of the Radiation Safety Officer or RSO.
This. position is independent of 'all other organizational' responsibilities and reports directly to the SNEC President.
The audit function is provided through GPUNC. The audit functions are conducted independently of SNEC line management responsibilities.
Independent review for SNEC is provided as described in the response to question 4.
This group reports directly to the-President - GPUNC.
Responsibilities of various management positions are briefly described as follows:
SNEC President - Provides management oversight for all-Saxton activities. Reports to the SNEC Board of_ Directors.
SNEC Vice President and General Manager - Provides for management of and-is responsible for all SNEC activities and for assuring that the requirements of License No. DPR-4 and the TS are met. The position reports directly to the SNEC President.
SNEC Site Manager (Technical Support) - Provides on-site management and continuing oversight _of production activities.
Interfaces closely with the Radiation Safety Officer (RS0) on radiological control matters. - May provide direction on radiological matters not related to Radiation Safety such as data gathering activities. ' Reports directly to the SNEC Vice President.
j Radiation Safety Officer (RS0) - The SNEC RSO is directly responsible for the conduct and oversight of all Saxton Radiation Safety Activities through implementation of the SNEC Radiation Protection Plan. The RSO may employ a Group Radiological Controls Supervisor- (GRCS) to supervise day to day site activities as required.
Reports directly to the SNEC President.
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i C301-93-008J Attachment IT Page 2 of 5 i
Group Radiological' Controls -Supervisor (GRCS) - Employed as required to
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directly supervise site Radiation Safety act.ivities.
Reports directly to the RSO.
Project Team (Technical Support) - SNEC management is supported by a project team which provides technical support and project management.
The responsibilities of the. General Manager are contained in TS B.I.a. and the Radiation Safety Officer position will be added as TS B.I.b. as follows:
The SNEC Radiation Safety Officer (RS0) shall have the responsibility for the conduct and oversight of all Saxton Radiation Safety Activities-through implementation of the SNEC Radiation Protection Plan.
With the addition of the description of the RS0 above, the organ _ization -
identified in the TS-is commensurate with the level of work to be -performed during characterization. A more detailed organization description will be submitted as a part of the decommissioning plan.
Question 2 Staffina to Support Entry and Characterization Activities The following wording has been added as section B.2.c. of.the TS to describe the minimum staffing required to perform entry and characterization activities in the containment building:
Initial Containment Vessel entry shall be performed in accordance with a
written procedures. The minimum staffing for initial entry and characterization activities shall require at least two people, who shall be knowledgeable in radiation monitoring and the radiological hazards associated with the facility.
Entry and/or work within the Containment Vessel shall require that the Radiation Safety Officer (RS0) or qualified ~ designee be present on site.
Question 3 Selection and Training of Personnel Radiological Control Technicians shall meet or exceed the qualification requirements of ANSI-N 18.1-1971 or shall be formally qualified through the-NRC approved Radiological Controls training program. The Saxton Group Radiological Controls Supervisor (GRCS) shall be a TMI qualified GRCS. - All personnel conducting Containment Vessel characterization activities will-be -
briefed on SNEC site specific conditions and the requirements of the.
" Characterization Plan".
Those personnel conducting characterization activitics inside the Containment Vessel who are not experienced radiation workers or Health Physics professionals will require escort by such personnel.
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1 C301-93-008 Page 3 of 5
-Question 4 Review'and Audit
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The independent review function for SNEC is provided by a committee which currently exists for the Three Mile Island nuclear' station (TMI), called the General Office Review Board (G0RB). The GORB is'part of the Independent Safety Review function shown in Figure 1 and reports directly to the President of GPUNC. The' committee has persons with extensive' experience in oversight-i review of nuclear, radiological, occupational, and environmental safety. The committee is composed of key internal corporate management and external 1
consultants, however, all are independent of line management responsibilities of SNEC.
A written charter describes the review responsibilities of the GORB.
There are quarterly meetings at which the activities reviewed by the SNEC Committee are reported and documented in the meeting minutes. Since the requirement.
establishing the GORB is not included in the TMI Technical Specifications, it should not be added to the SNEC Technical Specifications.
The audit function is provided within GPUNC and is independent'of the SNEC management. Audits are conducted of Technical Specification activities' and a
regulatory requirements at the request of the SNEC President.
Question 5 Radiation Safety
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The following wording has been added as section B.I.b. of the TS to describe' the positions having responsiblity for radiation. safety and the authority ~ to.
interdict or terminate safety-related activities:
The SNEC Radiation Safety Officer (RS0) shall have the responsibility for the conduct and oversight of all Saxton Radiation Safety Activities through implementation of the SNEC Radiation Protection Plan.
All radiological controls personnel (RSO, GRCS, technician) shall-have "stop-t work" authority in all matter.s relating to or which could impact radiation i
safety. All SNEC management personnel shall have "stop work" authority on any safety related matter.
Question 6 Procedures The following wording has been added as section B.4.e. of the TS to address written procedures, their review and approval, and the methodology for making changes:
Work conducted inside the containment vessel; which could affect containment integrity; or which requires a radiation work permit (RWP) shall be performed in accordance with written procedures and/or plans.
Written plans and procedures shall be developed, reviewed and approved under a system approved by the SNEC - President and documented in SNEC i
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o C301-93-008 -
Page 4 of 5 administrative procedures.
Procedures and changes thereto shall be reviewed by technically qualified persons, other than the preparer, and approved by the implementing authority for the. subject' activity.
Question 7 Reports The following wording has been added to section B.5.a. of the TS to require reporting the violation of license conditions and the discovery of the conditions in TS B.2.b.:
(3)
Any event described under section B.2.b.
(4)
Any violation of a requirement or condition of the facility license or the Technical Specifications.
Question 8 Records GPUN agrees that characterization activities may result in temporary or permanent changes to the facility described in the Saxton Decommissioning Plan-and Safety Analysis Report as revised by SNEC letter dated May 31, 1974.
GPUN also agrees to maintain records of the results of the characterization studies. As a result, Section 3 of the Saxton TS has been revised by addition of words to section B.3.e. and the addition of section B.3.f. as follows:
3.e.
.... Records of design changes and maintenance necessary to accomplish characterization activites associated with decommissioning will also be retained.
3.f.
Records of the results of characterization studies.
Question 9 Revision to 10 CFR Part 20 The reference to 10 CFR Part 20 was updated by revision to paragraph B'.3. as follows:
Replacing the words "... Section 20.401 of 10 CFR 20..." with the words "subpart L of 10 CFR 20, 20.2101 through 20.2110 inclusive,...
2 Question 10 Characterization Activities Characterization activities have been included as work to be performed under the control of Health Physics by revision of TS section B.4.c. ' as' follows:
"All required maintenance and characterization work associated with the 1
Containment Vessel...."
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C301-93-008-Page'5 of SL Question 11 Shield Block Removal It is intended to' replace the shield blocks at the conclusion of j
characterization activities.
If conditions develop which would prevent block
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-replacement other means to prevent access to this area would_ be implemented and recorded in accordance with TS B.3.e.
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Question 12 Industrial Hazards All work involving potentially toxic / hazardous materials will be' conducted I
under the auspices of the "GPU Nuclear Safety &' Health Manual" and the "GPU Nuclear Industrial Safety & Health Policy & Procedure Manual." All such j
hazards will be reviewed by-a competent individual within the cognizant-organization.
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Figure 1 SAXTON NUCLEAR EXPERIMENTAL CORPORATION (SNEC)
~l ORGANIZATION
.z SNEC-BOARD OF DIRECTORS President GPUNC
_l SNEC M
,f PRESIDENT.
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SNEC SNEC Corocrate Succort Radiation Vice President;
. Safety and General'
-Engineering:
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- Officer Manager Independent Safety Review
' Group Quality.
Rad Con SNEC Assurance:
l Supervisor Technical.
(as-needed)
Support Licensing-Industriali
'I Safety-Rad Con Techs Environmental ~
(as needed)
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C301-93-008 Page 1 of 1 Revised Description of Characterization Activities t
GPUN letter C301-93-2005 stated:
"No pe"manent changes or modifications to the facility, except for the core tores and the addition of equipment to support rigging activities, will take place."
Based on the "results of further radiological surveys, if external system characterization indicates internal samples are needed, the current wording of the statement prevents such activities as cutting system piping to obtain the samples and modifications to repower and reactivate the overhead crane.
't SNEC is revising the characterization description to permit opening of systems at any desired location and if determined viable, to permit reactivation of the crane.
Therefore, the description of characterization activities delineated in C301-93-2005 is revised as follows (bold-face type denotes additional wording and bold face in ()s indicates a deletion):
"3)
Component disassembly, cutting of piping systems and shield block-removal to. permit access for the sample / survey activities described above. No dismantlement or component removal will occur beyond that required to permit characterization. No permanent changes or modifications to the facility, except for core bores, pipe cutting,-and the addition or reactivation of equipment to support rigging activities will take place'..The overhead crane may be temporarily reactivated to support rigging activities.
Temporary reactivation of the crane may require permanent changes to the facility as well as replacement or refurbishment of crane components.
"4)
Inspection and evaluation of the material / physical condition of the facility (ie. Containment Vessel and overhead crane to permit (conceptual) design (modification) engineering, modification and refurbishment planning) activities in support of characterization and decommissioning.
Extensive radiological and toxic / hazardous-material characterization, as described above, is necessary to provide data indicative of current plant conditions relative to these concerns. The information is key to the development of a practical decommissioning plan for SNEC since appropriate work practices and the extent of contaminated / radioactive waste resulting from the decommissioning activity will be determined from this data.
As revised, these characterization activities, performed in accordance with approved procedures, will not produce any effect which would cause a release
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of radiological material in excess of 10 CFR 20 limits.
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