ML20064E633
| ML20064E633 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/09/1994 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2207, NUDOCS 9403140387 | |
| Download: ML20064E633 (2) | |
Text
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s CENTERIOR ENERGY
'6200 Ook Tree Boulevard Moi! Address Donold C. Shelton independence OH PO Box 94661 Senior Vice President 216-447-3153 Cleveland. OH 44101-4661 Nuclect Fox 216-447 3123 Docket Number 50-346 License Number NPF-3 Serial Number 2207 March 9, 1994 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Subj ect :
Comments on Draft Generic Letter (GL), " Guidance for Modification of Technical Specifications to Reflect (A)
Revisions to 10 CFR Part 20, " Standards for Protection Against Radiation" and 10 CFR 50.36a, " Technical Specifications on Effluents from Nuclear Power Reactors", (B) Related Current Industry Initiatives, and (C) Miscellaneous Related Editorial Clarifications".
Gentlemen:
Toledo Edison (TE) has reviewed the subject draft Generic Letter.
Based on this review, TE is providing the comments contained in the attachment to this letter.
Should you have any questions or require additional information, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.
V truly yours S/amb 5
Attachment ec:
J. B. Martin, Regional Administrator, NRC Region III S. Stasek, NRC Region III DB-1 Senior Resident Inspector R. J. Stransky Jr., DB-1 NRC/NRR Project Manager Utility Radiological Safety Board 9403140387 940309 operchng Cornpomes
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Toledo tdison
Docket Number 50-346 License Number NPF-3 e
Serial Number 2207 Attachment Comments on Draft Generic Letter (GL), " Guidance for Hodification of Technical Specifications to Reflect (A) Revisions to 10 CFR Part 20,
" Standards for Protection Against Radiation" and 10 CFR 50.36a,
" Technical Specifications on Effluents from Nuclear Power Reactors", (B)
Related Current Industry Initiatives, and (C) Miscellaneous Related Editorial Clarifications."
Specific Comments 1.
Technical Specification 5.1.3 of Enclosure 1 should be modified to delete the maps from Sectfon 5.0, Design Features, of the Technical Specifications which depict: 1) the release points for radioactive gaseous and liquid effluents, 2) the UNRESTRICTED AREAS and 3) the SITE BOUNDARY.
These Technical Specification figures are proposed for deletion on the basis that the same information provided by these figures is (or could be) located in figures in the updated Final Safety Analysis Reports (FSAR) of plants.
Furthermore, SITE BOUNDARY and UNRESTRICTED AREA are defined and controlled in Section 1.0, Definitions, of the Technical Specifications (reference:, Paragraph 1.30 and 1.38) and in the definitions of 10 CFR 20.1003.
A sampling of various plants' existing Technical Specifications j
maps depicting the SITE B0UNDARY and UNRESTRICTED AREAS shows that the maps are typically difficult to read and simply cannot provide the detail necessary to physically determine boundary or area delineations.
To address this concern, Toledo Edison recommends that the first paragraph of Technical Specification 5.1.3 be revised to state:
The UNRESTRICTED AREAS and SITE B0UNDARY are defined in Technical Specifications Section 1.0, Definitions.
This wording, in conjunction with the proposed Technical Specifications 1.30 of Enclosure 1, would better achieve the underlying purpose of the Technical Specifications.
2.
Technical Specification 5.11.1 of Enclosure 3 should be modified to include a definition of the terms " entryway" and " barricade."
3.
Technical Specification 5.11.2 of Enclosure 3 should be modified to include a definition of the term " barrier" and place this term in context with the term " locked door or gate" (5.11.2.A).
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