ML20141C654

Clarifies Statements in Safety Insp Rept 50-146/97-01 for Saxton Nuclear Experimental Corp Facility,That Do Not Reflect Utils Practices or Intentions

ML20141C654
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	06/16/1997
From:	Kuehn G GENERAL PUBLIC UTILITIES CORP.
To:	Dragoun T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
50-146-97-01, 50-146-97-1, C301-97-2011, NUDOCS 9706250372
Download: ML20141C654 (4)

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• , 1 l GPU Nuclear, Inc. l

( Route 441 South NUCLEAR Post off'c' Bc" *80 l Middletown. PA 17057-0480 ,

Tel 717 944-7621 l

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C301-97-2011 June 16,1997 1 I

U. S. Nuclear Regulatory Commission l

Attn: Mr. Thomas Dragoun l Project Scientist, Region I  !

475 Allendale Dr.

King of Prussia, PA 19406-1415 l

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Mr. Dragoun,

Subject:

Saxton Nuclear Experimental Corporativa Facility Operating License No. DPR-4 Docket No. 50-146 i SNEC Facility Inspection Report 97-01 l l

The purpose of this letter is to clarify statements in safety inspection report 97-01 for the Saxton 1 Nuclear Experimental Corporation facility which do not reflect GPU Nuclear's practices or intentions. This action is being taken to assure that there is no misunderstanding between the Commission staff and GPU Nuclear with regard to the specific items and to correct the record.

Sincerely, 9 ,

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f f G. A!Kuehn '

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i Vice President SNEC i

WGH Attachment cc:

NRC Project Manager MAR- Alexander Adams NRC Document Control Desk lfllfllllllllll0ll l{lfllj]l]llll 9706250372 970616 PDR ADOCK 05000146 G PDR

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- 1 C301-97-2011 Attachment Page 1 of 3 Item 1 03.b. Operations Procedures and Documentation Observations and Findings j The policy requires, in part, two levels of review by certified individuals, the Independent ,

Safety Reviwer, and the Responsibfe Technical Reviewer (RTR) prior to issuance of a i procedure.

Clarification Two levels of review are not always required. The number of reviews associated with a particular procedure are determined by the responses to the safety determination screening questions as provided by the procedure initiator. If the activity involved 1) does not have the potential to adversely affect safety during decommissioning activities,2) will not require a change to the system / component description or the procedural / operating description in either the Updated Safety Analysis Report (USAR) or the Technical Specifications (TS), or 3) will not involve a test or experiment not described in the US AR or TS, only the first review hy the Responsible Technical Reviewer is required.

Item 'J 06.b. Operations Organization and Administration Observations and Findings Management assigned responsibility to SNEC Quality Assurance to maintain a list of ,

commitments and to condJCt audits to verify implementation.  !

Clarification Responsibility to maintain the commitment listing has been assigned to the Decontamination and Decommissioning Engineering (D&DE) departroent. Individuals j from the GPU Nuclear Inc. Nuclear Safety Assessment department are assigned to I perform monitorings and audits of activities which are in the scope of the SNEC Facility Quality Assurance Plan. There is no group within GPU Nuclear Inc. designated "SNEC Quality Assurance" Item 3 Rl.1 b Radiological Protection and Chemistry Controls: Control ofTransuranic Isotopes, Observations and Findings 3a) . Work areas will be color coded to reflect the level of alpha and beta / gamma contamination and degree of controls required to minimize internal exposures.

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C301-97-2011 Attachment Page 2 of 3 Clarification

! The level of alpha and beta / gamma contamination and degree of controls required to

! minimize internal exposures will be identified by color coding system equipment and ,

l components not by color coding the work area in which it is located.

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i 3b)- The zone designations will be based on NRC Regulatory Guide 1.86 criteria.

Clarification NRC Regulatory Guide 1.86 criteria will not be the singular basis for zone designations.

Regulatory Guide 1.86 criteria and appropriate values listed in 10 CFR 20 Appendix B will be used as guidance for designating zories..

i Item 4 RI.2 b.Efiluent and Environmental Monitoring, Observations and Findings 4a) There are 27 environmental TLDs distributed in concentric rings around the site, biased in downwind directions based on historic wind rose data.

Clarification The environmental TLDs are distributed at the site boundary and several off site locations.

The concept of the concentric rings is inaccurate in that the site boundary is not equidistant from the Containment Vessel.

4b) The alarm setpoint will be based on a 7 millirem TEDE population dose per quarter (15 millirem per year) calculated assuming a dispersion factor of IE-5 for a ground level release under adverse atmospheric conditions.

I Clarification SNEC facility gaseous effluent combined releases are controlled per the Offsite Dose l Calculation Manual (ODCM) by effluent sampling and radiation monitor set points. These measures assure that releases do not combine to produce dose at the site boundary which would exceed 1500 mrem per year to an organ. The ventilation radiation monitor set poir.t will be based on a fraction of the limit. The effluent radiation monitor set point i ealculation is described in the ODCM.

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,, l C301-97-2011 Attachment Page 3 of 3

5) The licensee stated that the efIluent control and environmental monitoring programs will be submitted to the NRC for approval as a Radiological Environmental Technical l

Specification.

l Clarification GPU Nuclear submitted the Environmental Report on April 17,1996 which contains as Section 7.5 the Environmental Radiological Surveillance Program currently in etTect at the SNEC facility It is the " environmental monitoring program" In its response to the NRC's request for additional information regarding the submittal of the SNEC Facility Decommissioning Plan and Environmental Report dated July 18,1996, GPU Nuclear committed to submittal of the Offsite Dose Calculation Manual (ODCM) when it was issued. It contains the " effluent control program" It was submitted to the NRC on June 5,1997.

The submittal of these documents should not be construed as satisfying a requirement for a Radiological Environmental Technical Specification. The SNEC facility was operated and shutdown prior to the institution and elimination of Radiological Environmental Technical Specifications from operating plant technical specifications.

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