ELV-05102, Forwards Responses to NRC 921203 RAI Re Util 920917 License Amend Request Associated W/Implementation of New 10CFR20 Requirements & Revised Proposed TS Associated W/Responses
| ML20127L492 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/22/1993 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20127L496 | List: |
| References | |
| ELV-05102, ELV-5102, TAC-M84529, TAC-M84530, NUDOCS 9301270177 | |
| Download: ML20127L492 (8) | |
Text
Georg a Powe< Corepan/
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COrgia POWCf C. K. McCoy
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v~ *m eax s,wn January 22, 1993 Docket Nos. 50-424 ELV-05102 50-425 TAC Nos.
M84529 M84530 U. S. Nuclear Regulatory Commission v
ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS in response to your letter dated December 3,1992, attached is the additional information you requested regarding Georgia Power Company's license amendment request dated September 17,1992, associated with implementation of the new 10 CFR 20 requirements at Vogtle Electric Generating Plant. Enclosure I contains your questions, as numbered and worded in the December 3,1992, letter, and our responses. Enclosure 2 contains revised proposed Technical Specifications associated with the responses, which supersede the corresponding pages provided in the September 17,1992, submittal. Additionally, the conclusions contained in the September 17,1992, submittal's significant hazards evaluation remain valid.
Should you have any questions regarding this information, please contact this office.
Sincerely,
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C. K. McCoy 250019 9301270177 930122 fi PDR ADOCK 0500 4
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U. S. Nuclear Regulatory Commission ELV-05102 Page Two CKMfrMM
Enclosures:
1.
Response to NRC Request for AdditionalInformation 2.
Revised Proposed Technical Specification Changes c(w): Ge.qrgia Power Company Mr. W. B. Shipman Mr. M. Sheibani NORMS U. S Nugicar Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle Stat 3f Gestrgia 3
Mr. J. D. Tanner, Commissioner, Department of Natural Resources i
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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFIC ATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENTS RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORM ATION
ENCLOSUREI VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECH. ICAL SPECIFICATIONS N
lh1PLEh1ENTATION OF THE NEW 10 CFR 20 REQWREMENIS i
RESPONSE TO 'NRC REO_UEST FOR ADDITIONAL INFORMATION Question 470J Your proposed defmition of h1 EMBER OF THE PUB 1.lC should retain the last sentence
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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."
Response to 0uejtion 470.1 i
The proposed defmition of MEMBER OF Tile PUBLIC has been revised as requested to retain the last sentence of the original TS wording.
Que_stion 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 BOUNDARY used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes."
Besponse to Ouestion 470 2 The proposed defmition of UNRESTRICTED AREA has beea revised as requested to retain the last part of the original TS wording.
Ouestion 470.3 In ' BASES 3/4.11.1.4, " Liquid IIoldup Tanks", you propose to replace "10 CFR Part 20, Appendix B, Table II, Column 2" with "10 CFR Part 20.1302(b)(2)(i)."
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I ENCLOSURE 1 (Continued)
REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPI.EhiENTATION OF THE NEW [0_CFR 20 REOUIREMENTS RESPON_SE TO NRC REOUE.ST FOR ADDIT 10NAL INFORMATION NUREG-0133 and Standard Review Plan 15.7.3 proside guidance in this area. The documents state 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 11, 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 rection of the rule (20.1302) were substituted. Your proposed use of 10 CFR 20.1302(b)(2)(i) in the Bases would imply that annual averaging of the eflluent concentratica is allowed. This would be incorrect as annual averaging is not allowed for this specification.
Because the new values in Appendix B, Table 11, Column 2 to 10 CFR 20.1001-20.2401 are, overall, a factor of 10 lower than before, the NRC stafTconsiders it acceptable for licensees to propose increasing these values by a factor of 10. These values will maintain the same overalllevel of efTluent control that existed under the old Part 20. The 10 curie limit remains unchanged.
The NRC statTs 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.
Response to Ouestion 470 3 Bases Section 3/4.11.1.4 has been revised as requested to reference a value of 10 times the limits of 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 2, instead of 10 CFR Part 20.1302(b)(2)(i). Note that the referen e to " Table II,"
relative to the new 10 CFR 20, should have been to " Table 2."
Question 470.4 in " Insert 2" to the Administrative Controls, section f, Radioactive Effluent ContrgLs Prggra_rn, you use the phrase "which corresponds to a dose rate of 500 mrem / year total E l-2
ENCLOSURE I (CONTINUED)
' VOGTLE ELECTRIC GENERATING PLANT-REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR_20 REOUIREMENTS RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION effective dose equivalent." The NRC stafTfind: this phrase to be unnecessary, inconcistent with the Standard Technical Specification, and to proside no additional controlir: the-context 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 areas beyond the site boundary. The NRC stafTfinds that including words for pnrposes tther than controlling radioactive gaseous efiluent is inappropriate. If you need clarification for other necessary purposes, such clarification should be placed in appropriate licensee documents, not in the TS.
Alternatively, provide further justification for your proposed basis.
Response to Ouestion 470.4 Proposed TS 6.7.4.fl7) has been revised by deleting the phrase "which corresponds to a dose rate of 500 mrem / year total effective dose equivalent," and replacing it with a footnote which states "At any time, ten times the concentrations stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 1, corresponds to a dose rate of 500 mrem / year total effective dose equivalent." By footnoting the concentration limits, the relationship between gaseous eflluent concentrations and corresponding dose rates is clearly stated.
Limitations on gaseous effluent release rates currently contained in the Vogtle Electric Generating Plant Unit I and Unit 2 TS are expressed in terms of dose rate. Accordingly, several plant documents, especially emergency preparedness documents that present emergency action level guidelines, reference TS limits stated in terms of dose rate.-
Therefore, since key plant documentation keys itself to the dose rate limits contained in the TS, it is desirable that this continuity be maintained.
The proposed footnote is accurate and appropriate according to the first paragraph of the section titled " Table 2" contained in Appendix B (to paragraphs 20.1001 - 20.2401) of the new 10 CFR 20, which states in part, "The concentration values given in Columns 1 and 2 of Table 2 are equivalent to the radionuclide concentrations which, ifinhaled or ingested
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1 ENCLOSURE 1 (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CJR 20 REOUIREMENTS RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION continuously over the course of a year, would produce a total efTective dose equivalent of 0.05 rem (50 millirem or 0.5 millisieverts)." Therefore, if the concentration values are increased by a factor of ten, the corresponding dose rate at any time would be 500 mrem / year as included in the proposed footnote.
Georgia Power Company views this proposed footnote as an important change to the TS, which provides a clarifying statement that does not diminish any of the controls contained in the TS and is consistent with the NRC staffs interpretation for complying with the requirements of the new 10 CFR 20.
Question 470.5 In Administrative Controls, Section 6.11, High IhdLation Area, your TS should be revised to use 20.1601(a) as the appropriate update for 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 staffs position is that your proposed TS should include this requirement.
Response to Ouestion 470.5 Administrative Controls Section 6.11 has been revised to use 20.1601(a) as the appropriate update for 20.203(c). The requirements for controlling access to a high radiation area, as presented in the new 10 CFR 20.1601(a), have not changed fron; those currently stated in 10 CFR 20.203(c)(2). Both the existing and new Part 20 requirements for high radiation areas include at least one of the foliowing: 1) control device,2) alarm signal device, or 3) locked entrance. Technical Specifications 6.11.1 and 6.11.2 already acknowledge the three controls; therefore, no further revisions to this specification are being requested.
O_uestion 470.6 In Administrative Controls, Section 6.:1.2, High Radiation Area, the dose rate values should be revised to specify a range This will distinguish the controls needed for a High E l-4
ENCLOSURE I (CONTINUED)
VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS IMPLEMENTATION OF THE NEW 10 CFR 20 REOUIREMENT.S RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION Radiation Area from those for a Very High Radiation 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.
Response te Question 470.6 Technical Specification 6.11.2 conservatively applies access control methods that are applicable to very high radiation areas to all areas accessible to personnel in which radiation levels are greater than 1000 mR/ hour. Therefore, it is not necessary to specify a dose rate range.
Question 470.7 10 CFR 20.1602, Control of Access tc Very High Radiation Areas, requires that measures in addition to those in 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)(
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 committee, which establishes the control requirements for Very High Radiation Areas.
Response to Ouestion 470.7
- Georgia Power Company intends to comply without exception to the requirements specified in 10 CFR 20.1602 for controlling access to very high radiation areas; therefore, a specific TS is not needed. Restrictions have been established, which are described in TS 6.11.2, to control or prevent access to any area where an individual could receive a dose greater than 1000 mrem within I hour. These restrictions bound the exposure rate defined for a very high radiation area.
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