ML20125B557

Requests Response to Encl Request for Addl Info Re Util 921014 Proposed TS Changes to Implement New 10CFR20,within 30 Days of Ltr Date

ML20125B557
Person / Time
Site:	Hatch
Issue date:	12/02/1992
From:	Jabbour K Office of Nuclear Reactor Regulation
To:	Hairston W GEORGIA POWER CO.
References
TAC-M84730, TAC-M84731, NUDOCS 9212100055
Download: ML20125B557 (6)

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December 2, 1992 Docket Nos. 50-321 and 50-366 f

Mr. W. G. Hairston, III Senior Vice President -

Nuclear Operations Georgia Power Company P. O. Box 1295 Birmingham, Alabama 35201

SUBJECT:

REQUE ~ FOR ADDITIONAL INFORMATION ON PROPOSED TECHNICAL SPECIF1;ATION CHANGES TO IMPLEMENT THE-NEW 10 CFR PART 20 -

i EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M84730 AND M84731)

By-letter dated October 14, 1992, you proposed Technical Specification changes to implement the new 10 CFR Part 20 for Edwin I. Hatch Nuclear Plant, Units 1 and 2.

The NRC staff has reviewed your submittal and finds that additional information, identified in the enclosure, is needed before we can coraplete our review. We request your response to this request within 30 days from the date of this letter.

This request affects fewer than ten respondents and, therefore, it is not 4

l subject to Office of Management & Budget review under P.L.96-511.

Sincerely, 6k dJa0/4~~

Kahtan N. Jabbour, Project Manager Project Directorate II.

Division of Reactor Projects

'I/II Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information i

cc w/ enclosure:

See next page 9212100055 921202 PDR ADOCK 05000321 p

PDR

-1

F December 2,1992 Docket Nos. 50-321 cd 50-366 Mr. W. G. Hairston, 111 Senior Vice President -

Nuclear Operat'ons Georgia Power Company

p. O. Box 1295 Birmingham, Alabama 35201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED TECHNICAL SPECIFICATION CHANGES TO IMPLEMENT THE NEW 10 CFR PART 20 -

EDWIN 1. HATCH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. M84730 AND M84731)

By letter dated October 14, 1992, you proposed Technical Specification changes to implement the new 10 CFR Part 20 for Edwin I. Hatch Nuclear Plant, Units 1 and 2.

The NRC staff has reviewed your submittal and finds that additional information, identified in the enclosure, is needed before we can complete our review.

We request your response to this request within 30 days from the date of this letter.

This request affects fewer than ten respondents and, therefore, it is not subject to Office of Management & Budget review under P.L.96-511.

Sincerely,

/s/

Kahtan N. Jabbour, Project Manager Project Directorate II-3 Division of Reactor Prejeci.s - I/II Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page DISTRIBUTION:

Docket File Hatch R/F

.DMatthews OGC, 15B18 NRC & Local PDRs SVarga KJabbour ACRS (10), P-315 PDII-3 R/F Glainas O

LBerry EMerschoff, RII P0ll-3:LA\\l PDIId*P P

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Mr. W. G. Hairston, III Georgia Power Company Edwin I. Hatch Nuclear Plant cc:

Mr. Ernest L. Blake, Jr.

Mr. R. P. Mcdonald Shaw, Pittman, Potts and Trowbridge Executive Vice Pres 4lent -

2300 N Street, NW.

Nuclear Operations Washington, DC 20037 Georgia Power Company P. O. Box 1295 Mr. J. T. Beckham Birmingham, Alabama 35201 Vice President - Plant Hatch Georgia Power Company Mr. Alan R. Herdt, Chief P. O. Box 1295 Project Branch #3 Birmingham, Alabama 35201 U. S. Nuclear Regulatory Commission 191 Marietta Street, NW, Suite 2900 Mr. S. J. Bethay Atlanta, Georgia 30323 Manager Licensing - Hatch Georgia Power Company Mr. Dan Smith P. O. Box 1295 Power Supply Operations Birmingham,-Alabama 35201 Oglethorpe Power Corporation 2100 East Exchange Place Mr. L. Sumner Tucker, Georgia _ 30085-1349.__

General Manager, Nuclear Plant Cecrgia Power Company Charles A. Patrizia, Esquire Route 1, Box 439 Paul, Hastings Janofsky & Walker Baxley, Georgia 31513 12th Floor 1050 Cone.ecticut Avenue, NW.

Resident Inspector Washington, DC 20036 U. S. Nucler.e hegulatory Commission Route 1, Box 725 Baxley, Georgia 31513 Regional Administrator, Region II i

U. S. Nuclear Regulatory Commission l

101 Marietta Street, NW Suite 2900 l

Atlanta, Georgia 30323 Mr. Charles H. Badger

(

Office of Planning and Budget Room 610 270 Washington Street, SW.

Atlanta, Georgia 30334 Harold Reheis, Director l

Department of-Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, Georgia 30334 l

Chairman Appling County Commissioners County Courthouse Baxley, Georgia 31513

Enclosuro I

REQUEST FOR ADDITIONAL INFORMATION (RAI) ON PLANT HATCH UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS TO INCORPORATE THE NEW 10 CFR PART 20 TAC NOS. M84730, M84731 470.1 The definition of MEMBER OF THE PUBLIC should retain the last sentence of the original TS wording. Additionally, it should read as follows:

This category may include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant.

470.2 The definition of UNRESTRICTED AREA should retain the last part of the original TS wording in the last sentence that reads: or any area within the SITE B0UNDARY used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes.

470.3 In sections 3/4.15.1.4 (Unit 1) and 3/4.11.1.4 (Unit 2), LIOUID HOLDU_P TANKS, of the BASES, it is proposed to delete "10 CFR Part 20, Appen: 1x A, Table II, (column 2)" and replace it with "10 CFR Part 20.1302(b)(2)(i)."

NUREG-0133 and Standard Revies Plan 15.7.3 provide guidance in this area.

The documents specifically discuss that radioactivity must be controlled so that leaked fluid does not result in concentrations to a water supply in an unrestricted area in excess of the limits of 10 CFR Part 20, Appendix B, Table II, Column 2.

This is the instantaneous concentration given in the table.

It is not the annual average of the concentration, as would be allowed if the section of the rule were cited (20.1302). The proposed use of 10 CFR 20.1302(b)(2)(i) in the bases section would incorrectly imply that annual averaging of the effluent concentration is allowed.

Annual averaging is not allowed for this specification.

Because the new values in Appendix B, Table II, Column 2 to 10 CFR 20.1001-20.2401 are, overall, a factor of 10 lower than before, NRC staff considers it acceptable for licensees to propose a factor of 10 increase for these values. These values will maintain the same overall level of effluent control that existcd under the old Part

20. The 10 curie limit remains urchanged.

It is reconnended that the 3ASES section be revised to reference a value of 10 times the limits of Appendix B, Table II, Column 2 to 10 CFR 20.1001-20.2401.

If you do not accept the position given above, provide an explanation anc rationalization for your alternative.

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2 470.4 In " INSERT 7" (Units 1 and 2), of the Administrative Controls, section 6.18, Radioactive Effluent Controls Prqgnm, item 7, the phrase "which corresponds to a dose rate of 500 mrem / year total effective dose equivalent" is tnnecessary, inconsistent with Standard Technical Specification wording and provides no additional control in the context of the TS. On this basis, it should therefore be deleted.

The intent of the TS is to limit the concentrations of radioactive material that are released in gaseous effluents to areas beyond the site boundary. The inclusion of wording for purposes other than 1

controlling radioactive gaseous effluents is discouraged.

If clarification for other purposes is deemed necessary, it should be placed in the appropriate licensee document, not in the TS.

If you do not accept the position given above, provide an explanation and rationalization for your basis.

470.5 In Administrative Controls, section 6.12 (Units 1 and 2), Miah Radiation Ar.n, your specification needs to be revised to acknowledge that in 10 CFR 20.1601(a), there are three controls listed; a " control device", an

" alarm signal", and " entryways that are locked." The proposed TS must be rewritten to include this requirement.

470.6 In Administrative Controls, section 6.12 (Units 1 and 2), Hiah Radiation Area, the part of the specification which specifies the distance at which the radiation is to be measured is not included.

10 CFR 20.1601 specifies that a distance of 30 cm (12 in.) be used.

Provide a proposed TS change to include the new distance.

l 470.7 In Administrative Controls, section 6.12.2, of Hiah Radiatior, Area, the dose rate values need to be revised to specify a range. This is necessary to distinguish the controls needed for a Hiah Radiation Area from those for a Very Hiah Radiation Area. The TS must be revised to specify a range of greater than 1000 mrem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> but less than 500 rads (5 grays) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

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l 470.8 10 CFR 20.1602, Control of access to very high radiation areas, requires additional measures, over those in 10 CFR 20.1601, be taken to prevent unauthorized or inadvertent access to areas in which radiation levels l

could be encountered at 500 rads (5 grays) or more in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 1 meter from a radiation source or any surface through which the radiation i

penetrates.

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l Propose a new TS that specifies the measures to be taken to control access to very high radiation. areas, j

[e.g., a separate plant procedure, ap) roved by the plant operations review comittee (PORC), w11ch establishes the control requirements for Very High Radiation Areas]

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