ML20140C738

Forwards Revised Tech Spec B3/4 7-4 for Licenses DPR-62 & DPR-71,in Response to 850828 Request.Leak Testing of Sealed Sources Not Required to Ensure That Allowable Doses Not Exceeded.No Amend Required

ML20140C738
Person / Time
Site:	Brunswick
Issue date:	03/18/1986
From:	Muller D Office of Nuclear Reactor Regulation
To:	Utley E CAROLINA POWER & LIGHT CO.
References
NUDOCS 8603250469
Download: ML20140C738 (4)

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. Docket Nos. 50-325/324 DISTRIBUTION

<5iEEEEFDF EJordan Mr. E. E. Utley l!AR 181996181996NRC PDR BGrimes Senior Executive Vice President Local PDR JPartlow Power Supply and Engineering & Construction RBernero OELD Carolina Power & Light Company SNorris ACRS (10)

Post Office Box 1551 ESylvester Gray File Raleigh, North Carolina 27602 -T h ew b rt N LFMB

Dear Mr. Utley:

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SUBJECT:

CHANGE TO BASES OF BRUNSWICK TECHNICAL SPECIFICATION 3/4.7. 6, " SEALED SOURCE CONTAMINATION" Re: Brunswick Steam Electric Plant, Units 1 and 2 By letter dated August 28, 1985, the Carolina Power & Light Company (CP&L) submitted proposed changes to the Bases to the Technical Specifications appended to Facility Operating License No. PDR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The proposed changes would modify the Bases for Technical Specification Section 3/4.7.6 related to testing for contamination of sealed sources containing radioactive material. The proposed change would clarify the Bases to indicate that it is not necessary to test sealed sources that are continuously enclosed within a shielded mechanism.

We have reviewed your request and agree that sources enclosed in a sealed mechanism need not be tested.for contamination. Past experience at operating nuclear power plants den.onstrates that leak testing of such sources is not required to ensure that the. allowable personnel doses of 10 CFR Part 20 are not exceeded. In fact, the process of testing these sources may actually increase personnel exposures through damage'to the source. We therefore find your requested change acceptable.

Because the proposed change is to the Bases and not to the Technical Specifications, an amendment is not required and is not being issued. We have, however, revised page B3/4 7-4 for Jrunswick Unit I and page 83/4 7-4 for Unit 2. A copy of these revised pages is enclosed.

Sincerely,

< W W 'M Osniel R. leuk.'

Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

See next page DBL:PD#2 SN :rs DBL:PD#2 ESylvester @ DBL:P DMpi 2

3/t4/86 3/C7/86 3V/86 -

9603250469 B6031B DR ADOCM O ,324

=f Mr. E. E. Utley Brunswick Steam Electric Plant Carolina Power & Light Ccmpany Units 1 and 2 cc:

Richard E. Jones, Esquire Carolina Power & Light Company 336 Fayetteville Street Raleigh, North Carolina 27602 George F. Trowbridge, Esquire Shaw, Pittman,'Potts and Trowbridge 1800 M Street, N. W.

Washington, D. C. 20036 Mr. Charles R. Dietz Plant Manager Post Office Box 458 Southport, North Carolina 28461 Mr. Franky Thomas, Chairman Board of Commissioners Post Office Box 249 Bolivia, North Carolina 28422 Mrs. Chrys Baggett State Clearinghouse Budget and Management 116 West Jones Street Raleigh, North Carolina 27603 Resident Inspector U. S. Nuclear Regulatory Commission Star Route 1 Post Office Box 208 Southport, North Carolina 28461 Regional Administrator, Region II -

U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Dayne H. Brown, Chief Radiation' Protection Branch Division of Facility Services Department of Human Resources Post Office Box' 12200 Raleigh, North Carolina 27605 ma -

-,_ w,. - - -

. (BSEP-1-53) 0

. PLANT SYSTEMS BASES (Continued)

SNUBBERS (Continued)

The service life of a snubber is established via manufacturer input j and.information through consideration of the snubber service conditions and associated installation and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc.). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions. These records will provide statistical

bases for future consideration of snubber service life.

3/4.7.6 SEALED SOURCE CONTAMINATION The limitation .on removable contamination for sources requiring leak

testing, including alpha esittera, is based on.10 CFR 70.39(c) Limits for

plutonium. This limitation will ensure that le,akage from by product, source, and special nuclear material sources will not exceed allowable intake values. Sealed sources are classified into three groups according to their use, with surveillance requirements commensurate with the probability of damage to a source in that group. Those sources which are frequently handled are required to be tested more often than those which are not. Sealed sources which are continuously enclosed within a shielded mechanism, i.e., sealed ~

sources with radiation monitoring or boron measuring devices, are considered to be stored and need not be tested unless they are removed from the shielding mechanism.

3/4.7.7 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish I

fires occurring in any partion of the facility where safety-rela.ted equipment is located. The fire su pression c system consists of the water system, spray '

and/or sprinklers, CO 2 , and fire hose stations. The collective capability of the fire suppression systems i's adequate to minimize potential damage to safety-related equipment and is a major element in the facility fire protection program.

In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service.

In the event the fire suppression water system become inoperable, l immediate corrective measures must be taken since this system provides the major fire suppression capability of the plant. The requirement for a 24-hour report to the Commission provides for prompt evaluation of the acceptability of the corrective measures to provide adequate fire' suppression capability for the continued protection of the nuclear plant.

~

sauwswIcx - UNIT 1 a 3/4 7-4

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, (BSEP-2-48) o.

I PLANT SYSTEMS BASES (Continued)

SNUB 3ERS (Continued)

The service life of a snubber is established via manufacturer inpuc and information through consideration of the snubber service conditions and -

associated installation and maintenance records (newly installed snubber, seal replaced, spring replaced,'in high radiation area, in high temperature area, etc.). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions. These records will provide statistical bases for future consideration of snubber service life.

1 l 3/4.7.6 SEALED SOURCE CONTAMINATION The limitation on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) Limits for i

plutonium. This limitation will ensure that leakage from by product, source, and special nuclear material sources. will not. ezceed allowable intake .

! values. Sealed sources are classified into three groups according to their use, with surveillance requirements commensurate with the probability of

damage to a source in that group. Those sources which are frequently handled l are required to be tested more often than those which are not. Sealed sources which are continuously enclosed within a shielded mechanism, i.e., sealed 1 sources with radiation monitoring or boron measuring devices, are considered 1 to be stored and need not be tested unless they are removed from the shielding mechanism.

3/4.7.7 FIRE SUPPRESSION SYSTEMS j The OPERABILITY of the fire suppression systems ensures that

adequate fire suppression capability is available to confine and extinguish i fires occurring in any portion of the facility where safety-related equipment

is located. The fire suppression system consists of the water system, spray and/or sprinklers, CO2 , and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to i safety-related equipment and is a major element in the facility fire protection program.

In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available.in the affected areas until the inoperable equipment is restored to l 4

service.

1

• i In the event the fire suppression water system become inoperable,  !

immediate corrective measures must be taken since this system provides the l 5 major fire suppression capability of the plant. The requirement for a 24-hour i

report to the Commission provides for prompt evaluation of'the acceptability

) of the corrective measures to provide adequate fire suppression capability for the continued protection of the nuclear plant.

BRUNSWICK - UNIT 2 B 3/4 7-4 1

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