ML20069E698

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Application for Amend to License DPR-72,App a Including Tech Spec Change Request 106 to Allow Use of Roped & Marked Access Barriers to High Radiation Areas at Plant. Certificate of Svc Encl
ML20069E698
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/18/1983
From: Westafer G
FLORIDA POWER CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20069E700 List:
References
3F-0383-22, 3F-383-22, TAC-49988, NUDOCS 8303220158
Download: ML20069E698 (3)


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M Power Co n80 mareose March 18,1983 3F-0383-22 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Change Request No.106 Control of Personnel Access to High Radiation Areas.

Dear Mr. Denton:

Florida Power Corporation hereby submits three (3) originals and forty (40) copies of Technical Specification Change Request No.106, requesting amendment to Appendix A of Operating License No. DPR-72. Proposed replacement pages for Appendix A are attached.

This proposed change will allow the use of roped and marked access barriers to high radiation areas of the plant when permanent locked enclosures cannot be readily constructed.

Florida Power Corporation considers the requested action involves a Class III amendment, per 10 CFR 170.22, in that it involves a single safety issue. Accordingly, a check in the amount of four thousand dollars ($4,000) is attached.

Also attached is a signed Certificate of Service for Technical Specification Change Request No.106 to the Chief Executive of Citrus County, Florida.

If you have any questions, please contact this office.

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Sincerely, SC g

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[yoo0.Oe G. R. Westafer Manager Nuclear Licensing and Fuel Management SF/mm cc:

Mr. 3. P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission, Region II 101 Marietta St. N.W., Suite 2900 Atlanta, Georgia 30303 8303220158 830318 DR ADOCK 05000 h Street south. P O Box 14042. St Petersburg. Florida 33733 813-866-5151

i-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF

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DOCKET NO. 50-302 FLORIDA POWER CORPORATION )

CERTIFICATE OF SERVICE G. R. Westafer deposes and says that the following has been served on the Chief Executive of Citrus County, Florida, by deposit in the United States mail, addressed as follows:

Chairman, Board of County Commir,sioners of Citrus County Citrus County Courthouse Inverness, FL 32650 One (1) copy of Technical Specification Change Request No. 106 requesting amendment to Appendix A of Operating License No. DPR-72.

FLORIDA POWER CORPORATION G. R. Westafer

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Manager Nuclear Licensing and Fuel Management S%ORN TO AND SUBSCRIBED BEFORE ME THIS 18th DAY OF MARCH,1983.

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ROT %RY PUP'JC STATE Of FLOR!DK 4

v My covwssiot4 EXPIRES NOV 19 1986 Notary Public BONDED THAU GENERAL INSURANCE UND Notary Public, State of Florida at Large My Commission Expires: November 19,1986 (NOTARIAL SEAL)

STATE OF FLORIDA COUNTY OF PINELLAS G. R. Westafer states that he is the Manager, Nuclear Licensing and Fuel Management, of Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set fcrth therein are true and correct to the best of his knowledge, information, and belief.

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G. R. Westafer

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Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 18th day of March,1983.

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Notary Public

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s Notary Public, State of Florida at Large, My Commission Expires: November 19, 1986 scNDED thru crut[l8f5 Nov rg,g,4-3 INSU4NCE UNO l

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EgHNICAL SPECIFICATION CHANGE REQUEST NO.106 HIGH RADIATION AREA Replace page 6-20 of Appendh A with the attached corresponding revised page.

PROPOSED CHANGES On page 6-20, insert provision c. in T.S.6.12.1:

"c.

In lieu of 6.12.1.(b), above, for accessible localized radiation areas in which the intensity of radiation is greater than 1,000 mrem /hr located in large areas such as containment, where no lockable enclosure exis'.2 in the immediate vicinity of the radiation area to control access to that area and no such enclosure can be readily constructed, then the radiation area will be:

i.

Roped off such that an individual at the rope boundary is exposed to 1,000 mrem /hr or less, ii.

Conspicuously posted at the entrance, and lii.

A flashing light shall be cctivated as a warning device."

The use of this method of access control shall be limited to plant locations considered to be permanent Radiation Control Areas.

REASONS FOR PROPOSED CHANGES Under the present requirements Florida Power Corporation must:

a)

Lock the high radiation area, or b)

Fabricate a lockable enclosure around the high radiation area and lock it, or c)

Place the high radiation area under direct surveillance as allowed by 10CFR20.203 (c)(4).

l in areas such as the containment or the Fuel Handling Area, several areas have dose rates exceeding 1,000 rnrem/hr. It is not practical in these areas to provide the required measures during refuel outages. Requirement (a) would cause frequent unlocking of the containment to allow personnel access.

Requirement (b) would entail expending unnecessary time and materials to fabricate a temporary enclosure. Finally, requirement (c) requires additional personnel be posted in a radiation area, thus unnecessarily increasing personnel radiation exposure.

The requested inclusion of Technical Specification 6.12.1.6 will save a considerable amount of time, materials and exposure.

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PDR ADOCK 05000302 P

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Page SAFETY ANALYSIS The alternative measure described above will provide equally adequate personnel access control to localized high radiation areas exceeding 1,000 mrem /hr.

Curreritly, each person entering a radiation area must also be authorized by a Radiation Work Permit.

This requirement will not change. The provisions proposed, will conspicuously mark the areas which have a significantly higher dose rate. These measures provide a high degree of assurance that these areas will not be entered inadvertently by unauthorized personnel.

A similar change has been granted for Joseph M. Farley Nuclear Plant, Unit No. 1 (Amendment No. 17, December 10, 1980) and Fort Calhoun Station, Unit No. 1 (Amendment No. 61, August 20, 1981). In addition, these measures are permissable in the sense that 10 CFR 20.203 (c)(2)(ii) suggests "a conspicuous visible or audible alarm signal" at each entrance to a high radiation area.

As stated in the Specification, 6.12.1.(c) will be applied only in those areas where no lockable enclosure exists or can be readily constructed. Florida Power Corporation does not intend to totally eliminate the practice of locking High Radiation Areas.

ADMINISTRATIVE CONTROLS e.

Records of gaseous and liquid radioactive material released to the environs.

f.

Records of transient or operational cycles for those facility components identified in Table 5.7-1.

g.

Records of training and qualification for current members of the plant staff.

h.

Records of inservice inspections performed pursuant to these Technical Specifications.

1.

Records of Quality Assurance activities required by the QA Manual.

j.

Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k.

Records of meetings of the PRC and NGRC.

1.

Records for Environmental Qualification which are covered under the provisions of paragraph 6.13.

4 6.11 RADIATION PROTECTION PROGRAM Procedures for personriel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

i 6.12 HIGH RADIATION AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20:

A High Radiation Area in which the intensity of radiation is greater than 100 a.

mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.

b.

A High Radiation Area in which the intensity of radiation is greater than 1000 i

mrem /hr shall be subject to the provisions of 6.12.1.(a). above, and in addition locked doors shall be provided to prevent unauthorized entry into such areas.

l The keys shall be maintained under the administrative control of the Health Physics Supervisor with one key assigned to the administrative control of Shift t

Supervisor on duty.

CRYSTAL RIVER - UNIT 3 6-19

ADMINISTRATIVE CONTROLS c.

In lieu of 6.12.1.(b), above, for accessible localized radiation areas in which the intensity of radiation is greater than 1,000 mrem /hr located in large areas such as containment, where no lockable enclosure exists in the immediate vicinity of the radiation area to control access ta that area and no such enclosure can be readily constructed, then the radiation area will be:

1.

Roped off such that an individual at the rope boundary is exposed to 1,000 mrem /hr or less, ii.

Conspicuously posted at the entrance, and lii.

A flashing light shall be activated as a warning device.

The use of this method of access control shall be limited to plant locations considered to be permanent Radiation Control Areas.

6.13 ENVIRONMENTAL QUALIFICATION 6.13.1 By no later than June 30, 1982, all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of Division of Operating Reactors " Guidelines for Evaluating Environmental Qualification of Class lE Electrical in Operating Reactors" (DOR Guidelines); or, NUREG-0588 " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment",

December 1979. Copies of these documents are attached to Order for Modification of License DPR-72 dated October 24,1980.

6.13.2 By no later than December 1,1980, complete and auditible records must be available and maintained at a central location which describe the environmental qualification method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the DOR Guidelines or NUREG-0588.

Thereafter, such records should be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified.

CRYSTAL RIVER - UNIT 3 6-20

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