ML20127G845

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Submits Info to Support 841101 Tech Spec Change Request to Change Calibr Frequency for Certain high-range Gamma Measuring Instruments.Request within Frequency Suggested in ANSI-N323-1978.Review & Approval Requested
ML20127G845
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/16/1985
From: Kuemin J
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Office of Nuclear Reactor Regulation
References
NUDOCS 8505210160
Download: ML20127G845 (2)


Text

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  • Consumers Power-Company General offices: 1945 West Parnell Road, Jackson, MI 49201 . (517) 788-0660 May 16, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

PORTABLE HIGH RANGE GAMMA MEASURING INSTRUMENTS -

INFORMATION TO SUPPORT TECHNICAL SPECIFICATIONS CHANGE REQUEST Consumers Power Company submitted a Technical Specifications Change Request on November 1, 1984 which included a request to change the calibration frequency for certain high range gamma measuring instruments. The requested change in

. calibration frequency was from every three months to calibration of the 0-20 R/hr scale every three months and on all scales every six months. The change request resulted from a noncompliance (50-155/84-04) and our commitment to submit a Technical Specifications change.

The requested calibration frequency of every six months is well within the calibration frequency suggested in the American National' Standard ANSI-N323 -

1978, Radiation Protection Instrumentation Test and Calibration, section 4.7.1 which states calibration is required to be at least annually.

Presently there are two portable high range gamma measuring instruments at Big Rock Point. Calibration of the high range scale, 20-1000 R/hr, is accom-plished offsite by a qualified vendor. The turn-around time for shipping and calibration is normally 2 to 3 weeks but has taken up to 6 weeks. The present 3 month ~ calibration frequency leaves the plant with only one instrument for a minimum of 15% of the time (based on a 2 week turn-around period). While the frequency of use of these instruments is low the chances for an instrument to be offsite when the need exists for its use is increased by the present calibration frequency.

The instruments are provided for post-accident personnel monitoring or monitor-ing in incalized high radiation areas and are, as noted above, not used frequently. The infrequent use results'in a smaller likelihood the instru-ments will be mishandled and reduces the need for a shorter calibration frequency. With this low frequency of use, and the turn-around time involved, and because the suggested calibration frequency is well within the ANSI 0505210160 950516 PDR ADOCK 05000155 PDR dd/

OC0585-0198A-NLO4 P L

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" Director? Nuclear Reactor' Regulation- 2 Big. Rock Point Plant Add'l Info to TSCR-May 16,'1985; Standards. suggested frequency we'believe the requested Technical Specifica-

~t ions change of November 1, 1984 is appropriate.

We'also wish to point out that, although the' Big Rock Point Plant. Technical Specifications have retained.the: requirement for the-portable gamma ~ dose-rate measuring instruments and portable neutron dose-rate measuring instruments for

.: establishing permissible _ working limits, and the calibration of these instruments, it can be argued such requirements are not appropriate for the-

. Technical Specifications. We find for example no such similar requirement in-the Standard Technical Specifications or in our Palisades Plant Technical Specifications.

While the need for establishing permissible working limits ia an~important consideration the Technical Specifications are not the appropriate place for this requirement. It is also noted that neither alpha nor beta dose-rate

. measuring instruments are identified in the Technical Specifications as being

. required or calibrated and they too are important in maintaining personnel

' dose within the Federal Regulations.

.It should also'be noted that the present Technica1' Specification preceded the procurement of the two high range gamma measuring instruments. Calibration'of-l

all other portable gamma dose rate measuring instruments is accomplished on-site in the plants calibration facility.- The more stringene Technical Specification calibration frequency has been an acceptable requirement because of the on-site facility.

In conclusion it is our belief the proposed Technical Specifications change is a minor. administrative change that is intended to provide acceptable calibra-tion frequencies for the dose-measuring instruments and your review and approval of the change is requested.

James L Kuomin Staff Licensing Engineer.

CC Administrator, Region-III, USNRC NRC Resident Inspector - Big Rock Point OC0585-0198A-NLO4