ML20125C357

Requests Addl Info Re New 10CFR20 Requirements for Review Completion within 45 Days

ML20125C357
Person / Time
Site:	Vogtle
Issue date:	12/03/1992
From:	Hood D Office of Nuclear Reactor Regulation
To:	Hairston W GEORGIA POWER CO.
References
TAC-M84529, TAC-M84530, NUDOCS 9212110158
Download: ML20125C357 (6)

Text

December 3, 1992 Ill STRI BU_T_ ION Docket Nos. 50-424 See next page and 50-425 Mr. W. G Hairston, 111 Senior Vice President -

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

SUBJECT:

RE0 VEST FOR ADDIT 10f1AL INFORMATION REGARDING NEW 10 CFR PART 20, V0GTLE NUCLEAR GENERATING PLANT, UNITS 1 AND 2 (TAC N05. M84529 AND M84530)

The NRC staff is reviewing your application of September 17, 1992, for license amendments to change the Vogtle Technical Specifications to implement revisions to 10 CFR Part 20 as published in the ffederal Reaister (56 FR 23360, dated May 21, 1991).

We find that the additional information and changes identified in the enclosure ar; 'eeded for completion of this review.

Your written response to the enclosure is requested within 45 days of receipt of this letter, if you have questions regarding the enclosure or are unable to meet the requested response date, contact me at (301) 504-3049.

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

Sincerely,

/s/

Darl S. Hood, Sr. Project Manager Project Directorate 11-3 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Enclosure:

Request for Additiona' Information fy cc w/ enclosure: See next page LBerry l'3 9 LA:PDl!

PM:PDil-3 11-3 DHood T,i M'atthews 92 i1/o,/92

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December 3,1992 Distributi'D:

Docket File NRC PDR Local PDR PDil-3 R/F Vogtle R/F S. Varga 14-E-1 G. Lainas 14-H-1

0. Matthews 14-H-25 L. Berry 14-H-25 D. Hood 14-H-25 OGC-WF 15-B-18 ACRS (10)

P-315 E. Merschoff Region 11 S. Klementowicz 10-D-4 T. Essig 10-D-4 L. Cunningham 10-D-4

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UNITED STATES i

NUCLEAR REGULATORY COMMISSION-WASHINGTON, D.C. 20005 December 3,:1992 Docket Nos. 50-424 and 50-425 l

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

Nuclear Operations t

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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NEW 10 CFR PART 20,-

V0GTLE NUCLEAR GENERATING PLANT, UNITS 1 AND 2 (TAC N05. M84529 AND M84530)

The NRC staff is reviewi.ng your application of September 17, 1992, for license amendments to change the Vogtle Technical Specifications to implement-revisions to 10 CFR Part 20 as aublished in the Federal _ Reoister (56 FR 23360, i

dated May 21,1991). We find t1at the additional information and changes identified in the. enclosure are needed for completion of this review.

Your written response to the enclosure is requested-within 45 days of receiptL of this letter.

If you have questions iegarding.the enclosure or are unable to meet the requested response date, contact-me at (301) 504-3049.

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

-Sincerely, fhPL Darl S. Hood, Sr. Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

s Request for' Additional Information cc w/enclosu're:

See next page o-l:

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Mr. W. G. Hairston, III Georgia Power Company Vogtle Electric Generating Plant cc:

Mr. J. A. Bailey Harold Rehels, Director-Manager - Licensing Department of Natural Resources-Georgia Power Company 205 Butler Street, SE. Suite 1252 P. 0.-Box 12S5 Atlanta, Georgia 30334 Birmingham, Alabama 35201 Attorney General Mr. W. B. Shipman Law Department General Manager, Vogtle Electric 132 Judicial Building Generating P1 ant Atlanta, Georgia 30334 P. O. Box 1600 Waynesboro, Georgia 30830 Mr. Alan R. Herdt Project Branch #3 Regional Administrator, Region II U. S. Nuclear Regulatory Commission.

V. S. Nuclear Regulatory Commission 101 Marietta Street, NW.' Suite 2900-101 Marietta Street, NW., Suite 2900 Atlanta, Georgia-30323 Atlanta, Georgia 30323 Mr. Dan H. Smith, Vice President Office of Planning and Budget Power Supply Operations Room 615B Oglethorpe Power Corporation 270 Washington Street, SW.

2100 East Exchange Place Atlanta, Georgia 30334 Tucker, Georgia 30085-1349 Mr. C. K. McCoy Charles A. Patrizia, Esquire Vice President - Nuclear Paul, Hastings, Janofsky & Walker Vogtle Project 12th Floor

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Georgia Power Company 1050 Connecticut Avenue, NW.-

P. O. Box 1295 Washington, DC 20036 Birmingham, Alabama 35201

- Art Domby,-Esquire Mr. R. P. Mcdonald Troutman, Sanders Executive Vice President -

600-Peachtree Street Nuclear Operations NationsBank Plaza Georgia Power Company Suite 5200 P. O. Box 1295 Atlanta, Georgia 30308-2210 Birmingham, Alabama 35201 Resident Inspector Office of the County Comissioner U. S.- Nuclear Regulatory Commission Burke County Comission P. O. Box 572 Waynesboro, Georgia 30830 Waynesboro, Georgia 30830 yI,,----

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4 ENCLOSURE l

NRC STAFF POSITIONS AND REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED TECHNICAL SPECIFICATION CHANGES TO INCORPORATE THE NEW 10 CFR PART 20 FOR V0GTLE ELECTRIC GENERATING PLART UNITS 1 AND 2 470.1 Your proposed definition of MEMBER Of THE PUBLIC should retain the last sentence of the original Technical Specification (TS). Also, it should state, "This category may include persons who use portions of the site for recreational, occupational, or other purposes not associated with the plant."

470.2 Your proposed 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 Bases 3/4.11.1.4, " Liquid Holdup Tanks", you propose to replace "10; CFR Part 20, Appendix B, Table II, Column 2" with "10 CFR Part 20.1302(b)(2)(i)."

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

These documents state that radioactivity must be controll ! 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 proposed section of the rule (20.1302) were substituted.

Your proposed use of 10 CFR 20.1302(b)(2)(1) in the Bases would imply that annual averaging of the effluent concentration is allowed.

This would be incorrect as 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, the NRC staff considers it acceptable for licensees to propose increasing these values by a factor of 10.

These values will maintain the same overall level of effluent control that existed under the old Part 20. The 10 curie limit remains unchanged.

The NRC staff's position is that the Bases should 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. Alternatively, provide further justification for your proposed change.

3 o

. 470.4 in the proposed " Insert 2" to the Administrative Controls, Section f.

Radioactive Effluent Controls Proaram, you use the phrase "which corresponds to a dose rate of 500 mrem / year total effective dose equivalent."

The NRC staff finds this phrase to be unnecessary, inconsistent with the Standard Technical Specification, and to provide no additional control in the context of the purpose of the TS.

Therefore, it should be deleted.

The intent of the TS is to limit the concentrations of radioactive material in gases released to 3reas beyond the site boundary.

The NRC staff finds that including words for purposes other than controlling radioactive gaseous effluent is inappropriate.

If you deed clarification for other purposes necessary, such clarification should be placed in appropriate 11cs-ee documents, not in the TS.

Alternatively, provide further justificat)on for your proposed basis.

470.5 In Administrative Controls, Section 6.11, Wnh Radiation Area, your TS should be revised to use 20.1601(a) as the appropriate update fo, 20.203(c). Also, you should 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 NRC staff's position is that your proposed TS should include this requirement.

470.6 In Administrative Controls, Section 6.11.2, Hiah Radiation Area, the dose rate values should be revised to specify a range.

This will distinguish the controls needed for a Hiah Radiation Area from those for a Very Hiah Radiati_om Area.

The TS should be revised to specify a range of greater than 1000 mrem in I hour but less than 500 rads (5 grays) in I hour.

470.7 10 CFR 20.1602, Control of Access to Very High Radiation Areas, requires that measures in addition to those of 10 CFR 20.1601 be taken to prevent unauthorized or inadvertent access to areas in which radiation levels could be encountered at 500 rads (5 grays) or more in I hour at 1 meter from a radiation source or any surface through which the radiation penetrates.

Propose a new TS specifying the measures to be taken to control access to Very High Radiation Areas.

For example, one such measure might be based upon a separate plant procedure, approved by the plant operations review committec, which establishes the control requirements for Very High Radiation Areas.