ML20137R791
| ML20137R791 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 04/09/1997 |
| From: | Alexander Adams NRC (Affiliation Not Assigned) |
| To: | Kuehn G GENERAL PUBLIC UTILITIES CORP. |
| References | |
| TAC-M97155, NUDOCS 9704140246 | |
| Download: ML20137R791 (9) | |
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April 9,:1997.'
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Mr~ G. A.lKuehn,;Jr'.1.
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. Program Diret. tor SNEC: Facility-CPU Nuclear, Inc.<
2578 Interstate Drive
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.Harrisburg, Pennsylvania 17110
SUBJECT:
- REQUEST FOR ADDITIONAL.INFORMATION'(TAC NO. M97155)i
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Dear Mr. Kuehn:
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We' are continuing our review of your amendment request..for Amended Facility 1
License ho.' DPR-4 for the GPU Nuclear, Inc.,! and.Saxton' Nuclear, Experimental l
. Corporation, Saxton Nuclear Experimental Facility. During our review of your' amendment request, questions have arisen for which we require additional 1'
information and clarification. 1Please provide responses to the enclosed
. request for additional information within 60 days of the date,of this. letter.1.
in accordar.ca with 10 C.'.7 50.30(b), your response must' be executed in a signed' t original under oath or affirmation.
Following receipt of the additional:
information, we will continue our evaluation of your amendment request.
ThisJ
' ~ : is a partial initial request for additional' information.. Sections 3.6'.2 and
' 3.6.3 of your ' proposed. technical specifications and your quality. assurance:
.i program are still under _ initial' review and. additional' questions may be 1
L forthcoming..
L If you have any questions regarding t his; review, please contact.ms at L
~C (301) 415-1127.
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Sincerely,4
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1 Alexander Adams,by:Jr.# Senior, Pro' ject Manager
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,d UNITED STATES f
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' NUCLEAR REGULATORY COMMISSION
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s April 9, 1997 1
Mr. G. A. Xuehn, Jr.
Program Director SNEC Facility 1
GPU Nuclear, Inc..
2574 Interstate Drive Harrisburg, Pennsylvania 17110 i
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (TAC NO. M97155)
Dear Mr.;Kuehn:
l We are continuing our review of your amendment request for Amended Facility 1.icense No. DPR-4 for the GPU Nuclear, Inc., and Saxton Nuclear Experimental Corporation, Saxton Nuclear Experimental Facility.
During our' review of your amendmentirequest, questions have arisen for which we require additional I
information and clarification.
Please provide responses to the enclosed
)
request for additional information within 60 days of the date of this -letter.
In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation.
Following receipt of the additional information, we will continue our evaluation of your. amendment request. This I
is a partial initial request for additional information.
Sections 3.6.2 and 3.6.3 of your proposed technical specifications and your quality assurance program are still under initial review and additional questions may be forthcoming.
If you have any. questions regarding this review, please contact me at (301) 415-1127.
Sincerely, th(dt C& r (c Q'
f Alexander Adams, Jr., Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-146
Enclosure:
As stated cc w/ enclosure:
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Saxton Nuclear.
Docket No. 50-146 g"
Experimental' Corporation Page 1 of 2 Cc:
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Mr. William P. Dornsife,-Director Carbon Township Supervisors Bureau of Radiation Protection ATTN:
Penny Brode, Secretary Department of Environmental Protection R. D. #1, Box 222-C l
13th Floor, Rachel Carson State-Saxton, Pennsylvania 16678 Office Building P. O. Box 8469 Hopewell Township Supervisors Harrisburg, Pennsylvania 17105-8469 ATTN:
Sally Giornesto, 4
Secretary Mr. Jim Tydeman RR 1 Box 95 1402 Wall Street James Creek, Pennsylvania 16657-9512
-l Saxton, Pennsylvania 16678 i
Mr. D. Bud McIntyre, Chairman Mr. James H. Elder, Chairman Broad Top Township Supervisors Concerned Citizens for SNEC Safety Broad Top Municipal Building Wall Street Ext.
Defiance, Pennsylvania 16633 Saxton, Pennsylvani; 16678 Mr. Don Weaver, Chairman 1
Mr. Ernest Fuller Liberty Township Supervisors i
R. D. #1 R. D. #1 Six Mile Run, Pennsylvania 16679 Saxton, Pennsylvania 16678 j
i Saxton Borough Council U.S. Army Corps of Engineers ATTN:
Peggy Whited, Secretary Baltimore District 9th and Spring Streets ATTN:
S. Snarski/P. Juhle Saxton, Pennsylvania 16678 P. O. Box 1715 i
Baltimore, Maryland 21203 Ms. Norma Ickes, Chair Bedford County Commissioners The Honorable Robert C. Jabelirer County Court House President Pro-Temp Senate of 203 South Juliana Street Pennsylvania Bedford, Pennsylvania 15522 30th District i
State Capitol Mr. Larry Sather, Chairman Harrisburg, Pennsylvania 17120 Huntingdon County Commissioners County Court House Mr. William G. Heysek Huntingdon, Pennsylvania 16652 Licensing Department THI Nuclear Sth; ion 1
J Saxton Community Library P. O. Box 480 Front Street Middletown, Pennsylvania 17057 Saxton, Pennsylvania 16678 Mr. Manuel Delgado Mr. Arthur Rone 2799 Battlefield Road Vice' President Nuclear Fishers Hill, Virginia 22626 Safety and Technical Services GPU Nuclear Inc.
Mr. Eric Blocher 1
1 Upper Pond Road 216 Logan Avenue Parsippany, New Jersey. 07054 Wyomissing, Pennsylvania 19610 Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts, and Trowbridge 2300 bl Street, NW Washington, DC 20037
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- Mr. Dick;Spargo-1004 Main. Street.
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-Mr. Tom'Strnad-
' 'lTLG Services-148'New Milford Roa'd East
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Mr. Gareth.McGrath-l
'Altoona Mirror.
301,Cayuga Avenue Altoona. Pennsylvania.16603
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i ENCLOSURE-REQUEST FOR ADDITIONAL INFORMATION SAXTON NUCLEAR EXPERIMENTAL FACILITY DOCKET NO. 50-146 1.
Please provide a description of the containment vessel
'(CV)/ decommissioning support building (DSB) ventilation system.
2.
In your proposed Section 2.B.(3) of the SNEF license, you removed the word " Domestic" from the title of Part 30.
Is this a typographical t
error?
If so, please correct.
3.
In your proposed Section 2.C of the SNEF license, you added Appendix B of Part 50 as a specific regulation to which the license is subject. The provisions of Appendix B are not applicable to the SNEF.
Is it your intention, through this amendment application, to commit to the provisions of Appendix B7 4.
You have proposed changes to Section 3 of the SNEF license.
Please provide a justification for your proposed changes.
5.
In Section III(a)li, ii, iii, iv, v, vi, and ix af your amendment application, reference is made to Section 3.1 of the post-shutdown decommissioning activities report (PSDAR).
The topic of this section of the PSDAR does not match the amendment application discussion.
Please I
explain.
i 6.
In Section III(a)1viii of your amendment application, reference is made to Sections 3.3, 3.5, and 3.6 of the PSDAR.
The topic of Section 3.3 of the PSDAR does not match the amendment application discussion and there are no Sections 3.5 and 3.6 in the PSDAR.
Please explain.
7.
Section 3.9B of the USAR refers to Section 3.8C, and Sections 3.10A, B, D, and G refer to Section 3.8A.
However, the USAR does not have a Section 3.8A or C.
Please explain.
8.
Section 3.10A of the USAR refers to a previous SAR from 1972.
The date of the 1972 SAR in the USAR is incomplete.
Please correct.
9.
Proposed elimination of current Technical Specification (TS) A.2.d.
Will employees of the Pennsylvania Electric Company be on site at times when the SNEF work force will not (e.g., nights and weekends)?
If so, pleasa provide additional justification for the elimination of this TS.
10.
Please provide a definitions.section for the revised TSs which defines terms that are unique to the SNEF TSs.
. 11.
Proposed TS 1.3.1.
You hace proposed changina the word " locked" to
" secured." Please define " secured" and explain how this will provide a level of security equivalent to keeping access points locked.
12.
Proposed TS 2.0.
Your proposed TS refers to Section 1.2.1 of the SNEC 1
Your proposed wording would make this part of the PSDAR a TS requirement needing a license amendment to change.
A purpose of the recent amendments to the decommissioning regulations was to reduce the regulatory burden on licensees carrying out decommissioning activities.
To allow latitude to change Section 1.2.1 of the PSDAR without requesting i
a TS amendment change, wording such as "... and activities delineated in Section 1.2.1 of the SNEC Facility Post-Shutdown Decommissioning Activities Report (PSDAR) that are not prohibited by license condition or technical specification" could be used.
13.
Proposed TS 3.1.
This TS refers to the SNEC organization.
Because SNEC and GPU Nuclear are joint licensees, should this refer to the SNEC facil'ty organization to include GPU Nuclear? The proposed TS also states that the organization is depicted on Figures 2.3-1 and 2.3-2 of the SNEC Facility PSDAR. This could be interpreted as the organizational charts being a TS requirement.
To prevent this interpretation, wording such as "these requirements shall be documented in the SNEC Facility PSDAR" could be used.
Please see Generic Letter 88-06 dated March 22, 1988, for additional information.
14.
Proposed TS 3.1.4.
Please define " production activities." Should this De interpreted as " decommissioning activities"? Please clarify.
j 15.
Proposed TS 3.2.1.
Your proposed TS discusses the CV being secured.
This is defined in your current TS but not your proposed TS.
Please define what is required to have the CV secured.
Your proposed TS requires radiological surveys if the CV has been secured for a period greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Considering the increase in activities that will accompany dismantling of the CV, please justify not conducting a radiological survey at each initial entry after the CV is secured.
j 16.
Proposed TS 3.2.2.
Your evaluation states (top of page 4 of 23) that the current TSs addresses radioactive waste management activities within the CV.
Current TS B.1.c. 2 addresses entry and/or maintenance or characterization activities within the CV.
Please justify the changes in your proposed TS and define " radioactive waste management activities."
l 17.
Proposed TS 3.4.1.
This proposed TS refers to training as delineated by Section 2.4 of the PSDAR.
How will it be ensured that changes will not be made to this section of the PSDAR, and thus, a change to the TS, without prior NRC approval?
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4 18.
Proposed TS 3.5.1.1.
Why is the responsibility of the Vice President level within GPU Nuclear limited to the activities described in proposed TS 3.5.1.2 and 3.5.1.77 For the proposed activitics in TSs 3.5.1.3, 3.5.1.4, 3.5.1.5. and 3.5.1.6, please state wnat 1evel of management has responsibility and justify the management level.
19.
Proposed TS 3.5.1.5.
Why does the proposed TS refer to facility structures, systems and components in the PSDAR as opposed to the SAR?
20.
Proposed TS 3.5.1.8.
This proposed TS uses the term "unreviewed safety question."
Is this TS related to meeting the requirements of 10 CFR 50.597 If so, explain the relationship between the reviews in proposed TS 3.5.1.2 through 3.5.1.6 and the requirements of 10 CFR 50.59(a).
21.
Proposed TS 3.5.2.5.1.
This proposed TS discusses evaluations of changes in the facility and changes of procedures described in the SAR which are completed without prior NRC approval under the provisicas of 10 CFR 50.59(:.)(1).
Please indicate the sections of the Saxtcn SAE that describe the SNEF that would be subject to this proposed TS and 10 CFR 50.59(a)(1). Also indicate what procedures listed in the SAR would be subject to this TS and 10 CFR 50.59(a)(1).
22.
Proposed TS 3.5.2.5.1.
Your proposed TS states that the rnviews discussed in this TS need not be performed prior to implementation of the changes, tests or experiments.
Please explain this position.
23.
Proposed TS 3.5.3.1.c.
Please propose and justify an upper bound for this surveillance that appears in the TS. Are there any requirements for calibration of the radiation monitoring system? Consider a TS requirement for rystem calibration and to verify operability of the system after system maintenance occurs.
24.
Proposed TS 3.5.3.1.d.
This surveillance requirement should specify testing details such as acceptabie filter leakage and bypass flow, design flow rate of the system to be tested, and acceptable pressure drop across the filters at the design flow rate.
Please justify your proposed inspection interval of annually.
Alternatively, if these details are contained within the 00CM, a commitment to test in accordance with the 00CM would be acceptable.
25.
Proposed TS 3.5.4.
Please justify your proposed minimum biennial audit cycle in light of the increase in activities that will occur with CV dismantlement.
You also state on page 16 of 23 of your amendment application that the TS is being revised to identify the audit function provided by CPU Nuclear.
Your current TS states th&t the audit functior, is provided by GPU Nuclear but your proposed TS does not refer to GPU Nuclear.
Please clarify this apparent inconsistency.
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26.
Proposed TS 3.5.5.3.
Your proposed TS retains the current annual meeting frequency of the radiation safety committee.
Please justify this meeting-F 1
frequency considering the increase in activities that will accompany CV dismantling.
4
'27. -Proposed TS 3.6.1.2.
Please add fire: protection program implementation (as stated in Section 3.7.1) and emergency proceduras under required written procedures.
a 28.
P'roposed TS 3.6.1.2.1.
Your proposed TS 3.6.1.2.1.is an update to
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existing TS B.3.b.l.
The addition of decommissioning activities is.
described on page 9 of 23 of your amendment application. However, the L
proposed TS also has another proposed change related to the scope of the QA prograri that is not justified in your application.
Please explain and justify this change.
29.
Proposed TS 3.6.1.2.4.
You propose eliminating TS B.3.c.2.
Your i
justification appears to be the wording of your proposed T9 3.6.1.2.4.
i TS 8.3.c.2 discusses obtaining radiation levels and surveys prior to beginning work in controlled areas of the CV.
Proposed TS 3.6.1.2.d discusses activities which could result in a measurable release to the environment. While some activities under TS 8.3.c.2 could be part of i
TS 3.6.1.2.4 because the activities could result in a measurable release l
to the environment, one reason for TS B.3.c.2 is worker protection by assuring that information on radiological conditions is up to date.
' Please reinstate wording similar to TS B.3.c.2 or provide additional justification for its elimination.
30.
Proposed TS 3.6.1.3.
Instead of procedures requiring that the actions delineated therein be taken, the requirement for these actions should be elsewhere in the TS.
This proposed TS should only insure that the required actions are addressed in procedures.
Please address.
31.
Proposed TS 3.6.1.3.1.
Your proposed TS 3.6.1.3.1 is an update to existing TS B.3.c.l.
The addition of decommissioning activities is described on page 9 of 23 of your amendment application.
However, the proposed TS also has another proposed change related to the release of radioactivity in excess of. allowable limits that is not justified.
Please explain and justify this other change.
.32.
Proposed TS.3.6.2.1.
Please provide a copy of your ODCM.
33.
Proposed TS 3.6.2.3. - Please provide a copy of your process control program.
34.
Proposed TS 3.7.
Please provide a copy of your fire protection program that you will use to meet the requirements' of 10 CFR 50.48(f).
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Proposed TS 3.8.'
Your proposed TS has SNEC responsible for certain
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i reporting requirements.
Given the division of responsibilities between SNEC and.GPU Nuclear discussed in-paragraphs 2.B.(1) and (2) of.the i
license, justify your proposed TS.
e 36.
Proposed TS 3.8.1~..Your proposed TS refers to notification by telegraph.
To reflect advances in technology, you may change this to notification by-facsimile.
37.
proposed TS.3.8.1.1.
Your proposed TS uses the term " facility boundaries." Do you mean the CV7 Please define and justify the use of this~ term.
I 38.
Proposed TS 3.8.'2.
Your safety analysis in the third paragraph on a
page 11 of 23 discusses proposed TS 3.8.2 which concerns reporting and current TS B.2.a.2 which concerns the Radiation Safety Committee. The i
connection between these TSs is not clear.
Please provide additional information about your proposed change to the TSs.
3 39.
Proposed TS 3.9.
In the area of records, your proposed TSs have eltminated current TSs 8.5.a and B.S.f.
Please provide justification for-1 these eliminations.
j 40 - Proposed Figure 1.
Your figure shows the location of the proposed l
decommissioning support facilities.
These facilities now exist.
Please l
modify this figure as needed to reflect the current conditions at the site.
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