ML20063D784

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Proposed TS 3.8,adopting LCO of Section 3/4.7.6, Sealed Source Contamination
ML20063D784
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 01/31/1994
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20063D777 List:
References
JPTS-93-004, JPTS-93-4, NUDOCS 9402080300
Download: ML20063D784 (13)
v • d • e


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ATTACHMENT I to JPN-94-005 r

PEOEOSED_ TECHNICAL SPECJEICAllORSSHANSES BEGARRING31SCELLA_tLEQUSEAD10ACllVE_SDllBCES (JPTS-93-Q04)

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JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 9402000300 940131 Ef PDR ADOCK 05000333 L

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JAFNPP 3.8 LIMITING CONDITIONS FOR OPERATION 4.8 SURVEILLANCE REQUIREMENTS 3.8 MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES 4.8 MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES Acolicability:

Aoolicability:

Applies to the handling and use of sealed special nuclear, source and Applies to the surveillance requirements of sealed special nuclear, by-product material at all times.

source and by-product materials.

Obiective:

Obiective:

To assure that leakage from by-product, source and special nuclear To specify the surveillances to be applied to sealed special nuclear, radioactive material sources does not exceed allowable limits.

source and by-product materials.

Soecification:

Soecification:

Each sealed source containing radioactive material either in excess of Tests for leakage and/or contamination shall be conducted as follows:

100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emitting material, shall have removable A.

Each sealed source, except startup sources subject to core flux, contamination of less than or equal to 0.005 microcuries.

containing radioactive material, other than Hydrogen 3, with a half-life greater than thirty days and in any form other than gas A.

With a sealed source having removable contamination in excess shall be tested for leakage and/or contamination at intervals not to of the above limit, immediately withdraw the sealed source from exceed six months.

use, and either:

B. The periodic leak test required does not apply to sealed sources l

1.

Decontaminate and repair the sealed source, or that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to 2.

Dispose of the sealed source in accordance with applicable another user unless they have been leak tested within six months regulations.

prior to the date of use or transfer. In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, sealed source shall not be put into use until tested.

C. Startup sources shall be leak tested within 31 days prior to being subjected to core flux or installed in the core and following repair or maintenance to the source.

D. The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample._ Testing shall be performed by the licensee or by other persons specifically authorized by the NRC or an agreement State.

Amendment No.124',

214-

JAFNPP 3.8 and 4.8 Bases Ingestion or inhalation of source material may give rise to total body or organ irradiation. ' This specification assures that leakage from radioactive material sources does not exceed allowable limits. In the unlikely event that those quantities of radioactive by-product

. materials of interest to this specification which are exempt from leakage testing are ingested or inhaled, they represent less than one maximum permissible body burden for total body irradiation. The limits for all otherl sources (including alpha emitters) are based upon 10 CFR 70.39(c) limits for plutonium.

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Amendment No.

.214a.

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ATTACHMENT 11 to JPN-94-005 SAFETY EVALUATION ELEGARDING_MISCELLANEQllS_B AD10 ACTIVE _SQ1!BCES IRIS-23-DJL4) i

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E New York Power Authority.

~I JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 a

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DESCRIPTION OF THE PROPOSED CHANGES The proposed changes revise Specification 3.8 on page 214, to adopt the Limiting Conditions for Operation (LCO) of Section 3/4.7.6, " Sealed Source Contamination," as stated in NUREG-0123, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/5)" (Reference 1). In addition, the proposed changes reformat.

Specifications 3.8 and 4.8 to make them consistent with the remainder of the FitzPatrick Technical Specifications. The specific changes are described below:

1. On page 214, delete the " Source Leakage Test" specification in its entirety.
2. Add an " Applicability", an " Objective" and a new " Specification" section to 7

Specification 3.8 to read as follows:

j "Acolicability:

Applies to the handling and use of sealed special nuclear, source and by-product material at all times.

+

Obiective:

To assure that leakage from by-product, source and special nuclear radioactive material sources does not exceed allowable limits.

Soecification:

Each sealed source containing radioactive material either in excess of 100 microcuries of beta and/or garnma emitting material or 5 microcuries of alpha emitting material, shall have removable contamination of less than or equal to 0.005 microcuries.

A. With a sealed source having removable contamination in excess of the above limit, immediately withdraw the sealed source from use,

[

and either:

1 1.

Decontaminate and repair the sealed source, or 2.

Dispose of the sealed source in accordance with applicable regulations."

3. Relocate the Pases section from page 214 to a new page 214a titled "3.8 and 4.8 Bases "

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' 1 to JPN-94-005 SAFETY EVALUATION i

Page 2 of 6

4. Add " Applicability" and " Objective" sections to Specification 4.8 to read as follows:

"Acolicability:

Applies to the surveillance requirements of sealed special nuclear,

-l source and by-product materials.

Obiective:

To specify the surveillances to be applied to sealed special nuclear, source and by-product materials."

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5. Replace the following paragraph of the surveillance requirements

" Specification" section which reads:

" Tests for leakage and/or contamination shall be performed by the licensee or by other persons specifically authorized by the Commission or an agreement State as follows:"

with:

" Tests for leakaga and/or contamination shall be conducted as follows:"

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6. Renumber surveillance requirements 4.8.1 and 2 to 4.8.A and B respectively.
7. Replace surveillance requirement 4.8.3 with a new surveillance requirement 4.8.C to read as follows:

"C. Startup sources shall be leak tested within 31 days prior to i

being subjected to core flux or installed in the core and following repair or maintenance to the source."

8. Add a new Specification 4.8.D to _ read as follows:

"D. The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample. Testing shall be performed by the licensee or by other persons specifically authorized by the NRC or an agreement State."

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' 1 to JPN-94-005 SAFETY EVALUATION Page 3 of 6 ll.

PURPOSE OF THE PROPOSED CHANGES The purposes of the proposed changes are:

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1. To eliminate a Technical Specification requirement that is redundant to other federal regulatory requirements, and
2. To adopt the Standard Technical Specifications sealed sources LCO requirements which will reduce the amount of testing of the miscellaneous radioactive material i

sources.

i Ill.

SAFETY IMPLICATION OF THE PROPOSED CHANGES As currently written, Specification 3.8 requires leak testing of sealed sources containing by-product material in excess of the quantities listed in 10 CFR 30.71, Schedule B and of all other sources not listed in Schedule B (including alpha emitters) containing greater than 0.1 microcuries.

This requirement is different than what is specified in the Standard Technical Specifications LCO of Section 3/4.7.6, " Sealed Source Contamination," contained in 3'

NUREG-0123 (Reference 1). The exempt sources are based on the requirements of 10 CFR 31.5 (c)(2)(ii) which states in part:

" Devices containing. not more than 100 microcuries of other beta and/or gamma emitting material or 10 microcuries of alpha emitting material...need not be tested for any purpose;. "

The radioactive sealed sources leak testing requirements stated in the STS and in the proposed Specification 4.8 of the FitzPatrick Technical Specifications are the same as those stated in 10 CFR 3t.5. The test:ag requirement will apply only to sealed sources containing radioactive material meeting the following criteria:

1.

Greater than 100 microcuries of beta and/or gamma emitting material, or 2.

Greater than 5 microcuries of alpha emitting material.

Citing 10 CFR 30.71 in Specification 3.8 of the FitzPatrick Technical Specifications imposes a more restrictive requirement on the testing of radioactive sealed sources than required by the NRC.

The proposed changes meet the requirements for the receipt, possession and use of source material stated in 10 CFR parts 30,40, and 70. The FitzPatrick Radiological Environmental Services procedures and the Radiation Protection Manual meet or

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. 1 to JPN-94-005 j

SAFETY EVALUATION J

Page 4 of 6 :

i exceed the requirements of all applicable criteria of the regulations.

l The failure to leak test a defective sealed source could result in the undetected external contamination of the source and its associated storage and/or handling equipment. This could result in intake of radioactive material by personnel handling the source or in proximity of the source. Established radiological controls (i.e.,

handling techniques and good health physics practices) implemented through plant.

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procedures ensure that the sealed sources are tested as required by the Technical l

Specifications. These radiological controls meet or exceed the testing requirements.

imposed by the applicable regulations.

The proposed changes do not alter the radioactive materials controls established at the restricted area boundary and do not increase the amount of radioactive materials on j

site. The proposed changes do not increase the probability of causing, either directly -

i or indirectly an uncontrolled release of significant amounts of radiation. The changes -

will not reduce the ability of the operators to detect a leaking sealed radioactiva source.

The limitations on sealed source leakage imposed by 10 CFR 70.39 are intended to ensure that the total body or individual organ irradiation dose does not exceed the l

allowable limit of one maximum permissible body burden for total body irradiation in i

the event of an intake. This is accomplished by imposing a maximum limitation of j

0.005 microcuries of removcble contamination on each sealed source.

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The revision to surveillance requirement 4.8.C adds a defined time frame (i.e.,31 days) to perform leak testing on startup sources. This proposed change is consistent..

with STS requirement. Since startup. sources are not currently in use at the FitzPatrick plant, this proposed change does not affect plant operations.

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The proposed changes will make the LCO of Section 3.8, " Miscellaneous Radioactive j

Material Sources," consistent with the LCO stated in the " Sealed Source -

Contamination" section of NUREG-0123 (STS). The remainder of the proposed changes are administrative in nature and do not alter the conclusions' of the accident '

analyses as documented in the FSAR or the NRC SER (References 8 and 9 respectively).

1 Submitting these changes fulfills the Authority's commitment made in FitzPatrick LER 92-049 (Reference 2).

i IV.

EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION

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Operation of the FitzPatrick plant in accordance with the proposed amendment would' j

not involve a significant hazards consideration as defined in 10 CFR 50.92, since it-

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would not:

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Attachment ll to JPN-94-005 SAFETY EVALUATION Page 5 of 6

1. involve a significant increase in the probability or consequences of an accident previously evaluated.

Adopting the LCO described in the " Sealed Source Contamination" section of NUREG-0123 (STS) does not increase the probability or the consequences of an f

accident or malfunction of a safety-related structure, system, or component previously reviewed in the FSAR. The proposed changes do not increase the probability of causing, either directly or indirectly an uncontrolled release of significant amounts of radiation. Deleting 10 CFR 30.71 as the basis for exempting sealed sources for the leak testing requirements removes a requirement that is redundant to other federal regulations requirements. The proposed changes to reformat Specifications 3.8 and 4.8 are administrative in nature P.nd do not increase the probability or consequences of an accident previously evriuated in the FSAR.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not alter the radioactive materials controls established at the restricted area boundaries and do not increase the amount of radioactive materials on site. There are no modifications to safety systems as a result of the proposed changes. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated in the FSAR.

3. involve a significant reduction in a margin of safety.

Adopting the wording of the STS regarding the sealed sources limiting conditions for operations will not reduce the ability of the operators to detect a leaking sealed radioactive source. Established radiological controls (i.e., handling techniques and good health physics practices) implemented through plant procedures will ensure that the sealed sources will continue to be tested as required by the Technical Specifications and applicable regulations. The proposed changes do not alter the radioactive materials controls established at the restricted area boundary and do not increase the amount of radioactive materials on site. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

V.

JMPLEMENTATION OF THE PROPOSED CHANGE implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environment.

e Attachment il to JPN-94-005 SAFETY EVALUATION Page 6 of 6 VI.

CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. will not increase the probability nor the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report; i
2. will not create the possibility of an accident or malfunction of a type different from any previously evaluated in the Safety Analysis Report;
3. will not reduce the margin of safety as defined in the basis for any technical specification; and 4 involve no significant hazards consideration, as defined in 10 CFR 50.92.

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REFERENCES

1. NUREG-0123, " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/5)," Revision 3, dated Fall 1980.
2. NYPA Licensee Event Report (LER) 92-049-00 (JAFP-92-0836), " Incomplete Sealed Radioactive Source Leakage Surveillance Due to Procedure Deficiency,"

dated December 9,1992.

3.- 10 CFR 20, " Standards for Protection Against Raciation."

l 4.

10 CFR 30, " Rules of General Applicability to Domestic Licensing of Byproduct-Material."

5. 10 CFR 31, " General Domestic Licenses for Byproduct Material."

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6. 10 CFR 40, " Domestic Licensing of Source Material."
7. 10 CFR 70, " Domestic Licensing of Special Nuclear Material."

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8. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report:

Section 1.5.5, " Radioactive Waste Disposal Criteria," Section 7.12 " Process Radiation Monitoring System," and Section 11.5, " Shielding and Radiation Protection."

9. NRC Safety Evaluation of the James A. FitzPatrick Nuclear Power Plant dated November 20,1972 and Supplements.

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ATTACHMENT lil to JPN-94-005 GUBRENLTEClitKALSEECJFICATIORSJO_BE CHANDED BEGABDJ NG_MISCELLAN ERUS_B A D_[Q ACTIV E_SQUBCES_(J PTS-93-0D_4)

I New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333

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I m e d T*2cf Y 3^r"Pe 3.s MISCELLAHEQUS_RADIDACIIYE_ MATERIALS _SQURCES 4.8 SHRVEILLAHClLEEQUIREMENTS (Snutct_Lschagt_ Tant Tests for leakage and/or contamination shall be co$che/ed par L. m1 br u.e 1 w. a : by :ther p::::.u SpecillERti9n:

.apecM4 cal ly athc r isod_la_ t he Cc=ai r e ! a=

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a9 cc c...c..t J t at a, as follows:

Radioactive sources shall be leak tested for con-ltamination. The leakage test shall be capable of h Each sealed source, detecting the presence of 0.005 microcurie of radio-except startup sources subject A*

to core fluz, containing radioactive material, active material on the test sample.

If the test reveals the presence of 0.005 microcurie or more of other than Hydrogen 3, with a half-life greater removable contamination, the source shall be decon-than thirty days and in any form other than gas shall be tested for leakage and/or contamination taminated, and repaired, or be disposed of in at intervals not to exceed six months, cccordance with Commission regulations.

Those quantities of by-product material that exceed The periodic leak test required does not apply to sealed sources that are stored and not being the quantities listed in 10 CTR 30.71 Schedule B are used. The sources excepted from this test shall to be leak tested in accordance with the schedule he tested for leakage prior to any use or transfer chown in Surveillance Requirements. All other sources to another user unless they have been leak tested (including alpha emitters) containing greater than within six months prior to the date or use or 0.1 microcuries are also to be leak tested in accor-transfer.

In the absence of a certificate from a l

dance with the Surveillance Requirements.

transferor indicating that a test has been within six months prior to the transfer, sealed source Ramga gg shall not be put into use until tested.

Ingestion or Inhalation of source material may give

%. Startup sources shall be leak tested prior to and rise to total body or organ irradiation. This following any repair or maintenance and before 4> d A cpecification assures that leakage from radioactive being subjected to core flux.

material sources does not exceed allowable limits.

g gu In the unlikely event that those quantities of radio-cctive by-product materials of interest to this epecification which are exempt from loakage testing gfyg" are ingested or Inhaled, they represent less than one maxir permissible body burden for total body irradia son.

The limits for all other sources (including alpha emitters) are based upon 10 CFR 70.39(c) lim!";s for plutonium.

Amendment N'. '134 214

. Text 1"A" Applicability; Applies to the handling and use of sealed special nuclear, source and by-product material at '

all times.

j

. Object!Ye:

To assure that leakage from by-product, source and special nuclear radioactive material sources does not exceed allowable limits.

Soecification:

Each sealed source containing radioactive material either in excess of 100_microcuries of beta and/or gamma emitting material or 5.microcuries of alpha emitting material, shall have -

removable contamination of less than or equal to 0.005 microcuries.-

A.

With a sealed source having removable contamination in excess of the above limit, immediately withdraw the sealed source from use, and either-1.

Decontaminate and repair the sealed source, or 2.

Dispose,of the sealed source in accordance with applicable regulations.

- Text "B" appHCabilly:

Applies to the sunteillance requirements of sealed special nuclear, source and by-product l

materials.

1 Objectiv_e:

- To specify surveillances to be applied to sealed special nuclear, source and by-product.-

l materials.

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Text "C" i

Startup sources shall be leak tested within 31 days prior to being subjected to core flux or:

installed in the core and following repair or maintenance to the source.

. Text "D" l

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D.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample. - Testing shall be performed by the licensee or by other persons specifically authorized by the NRC or an agreement State.

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