ML20141G771
| ML20141G771 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/10/1986 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20141G756 | List: |
| References | |
| NUDOCS 8602260342 | |
| Download: ML20141G771 (4) | |
Text
F' Attcchment 1 Revised Technical Specifications for Administrative Controls for High Radiation Areas Revised Pages 226a, 227 Performance Appraisal Inspection Report 50-298/84-21 noted apparent discrepancies between Cooper Nuclear Station (CNS) Technical Specifications, Updated Safety Analysis Report (USAR), CNS Engineering Procedures, and actual station practices regarding the control of high radiation areas (HRA's).
A thorough review of the above documents and practices was conducted by the District in order to identify and correct the noted discrepancies and to improve administrative control of HRA's.
GE Standard. Technical Specifications for Boiler Water Reactors BWR-4 (NUREG-0123) were used to provide guidance for this proposed revision to CNS Technical Specifications.
The CNS USAR and Engineering Procedures will be i,
revised to reflect the Technical Specificatiot. change and resolve any inconsistency between these documents pertinent to HRA's.
l.
Nebraska Public Power District requests a revision to CNS Technical Specifications which modifies the administrative controls for high radiation The proposed change will accomplish the following:
areas.
1.
Expansion cf the definitions of an HRA and a barricade.
2.
Introduction of the Special Work Permit (SWP) as an administrative control for HRA's.
3.
Clarification of radiological control requirements for work in large areas where no structural enclosure exists (i.e.,
no capability for locking the area to restrict access).
It is the District's posture that the proposed revision will improve administrative controls for work in high radiation areas by more clearly defining control mechanisms and (in conjunction with the revised USAR and Engineering Procedures) eliminating tentatively confusing discrepancies between documents.
Therefore, there is no loss of safety function or any reduction in the degree of protection provided public health and safety.
Evaluation of this Revision with Respect to 10CFR50.92 A.
The enclosed Technicc1 Specification change is judged to involve no significant hazards based on the following:
1.
Does the proposed license amendment involve a significant increase in the probability or cansequences of an accident previously evaluated?
Evaluation:
The proposed change does not alter existing equipment or surveillances.
It will necessitate changes to health physics procedures and the USAR for the sake of uniformity and consistency 0
B602260342 860 PDR -ADOCK O 298 pg P
a b
between documents, but. such procedural changes are of an administrative nature, do not impact plant operations, and will improve control of HRA's.
lt is the District's assessment that the proposed change does not affect the probability or consequences of-an accident previously evaluated.
2.
Does the proposed license amendment create the possibility for a new or different kind of accident from any. accident previously evaluated?
Evaluation:
The proposed change does not introduce any new mode of operation and due to its ' administrative nature does not involve any limiting conditions for operation or surveillances.
Therefore, the proposed license amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Evaluation:
The clarification introduced by the proposed change will provide for improved administrative controls for high radiation areas and will not reduce the safety margin in any manner.
B.
Additional basis for proposed no significant hazards consideration determination:
The commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (48CFR14870). The examples' include:
"(ii) A change that constitutes an additional limitation, restriction, or control not precently included in the Technical Specifications..." It is the District's belief that the proposed change is encompassed by the above example, i
g
P c
6.3 (Cont'd) l A.
High Radiation Areas In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c)(2) of 10CFR20, each High Radiation Area (100 mrem /hr or greater with measurements made at 18. inches from the source of the radiation) shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by requiring i
issuance of a Special Work Permit (SWP).* The barricade will impede physical movement across the entrance or access to the high radiation-area; i.e., doors, yellow and magenta rope, turnstile.
Normally, a individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.
For-large areas which are High Radiation Areas or contain High Radiation Areas, such as inside containment, where no structural enclosure exists and no enclosure can be reasonably constructed around the area for access control, the High Radiation Area shall be barricaded and conspicuously posted as a High Radiation Area and entrance shall be controlled by a SWP and the Health Physics requirements specified therein.
Such areas may be frequented by personnel during outages or other scheduled work periods.
~
Because of the large number of personnel involved, issuance of survey instruments is impractical; therefore, area radiation monitots may be placed in the area in lieu of survey instrument issuance, provided that the radiation levels have been established by radiation surveys, the area radiation monitors have been set to alarm if radiation levels increase, and the alarm provides both a visual and an audible signal to alert personnel in the area of an increase.
9 6.3.5 Temporary Changes Temporary changes to procedures which do not change the intent of the original procedure may be made, provided such changes are approved by two members of the operating staff holding SRO licenses. Such changes shall be documented and subsequently reviewed by the Division Manager of Nuclear Operations within one month.
6.3.6 Exercise of Procedures Drills of the Emergency Plan procedures shall be conducted annually, including a check of communications with offsite support groups. Drills on the procedures specified in 6.3.2.A B, and C above shall be conducted as part of the retraining program.
- Health Physics personnel or personnel escorted by Health Physics personnel shall be exempt from the SWP issuance requirements during the performance of their assigned radiation protection duties providing they are otherwise following good Health Physics practices for entry into High Radiation
- Areas, i
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6.3 (Cont'd) 6.3.7 Programs The following programs shall be established:
A.
Systems Integrity Monitoring Program A program shall be established to reduce leakage to as low as practical levels from systems outside the primary containment during a serious accident that would or could contain highly radioactive fluids. This program shall include provisions establishing preeantive maintenance and periodic visual inspection requirements, and leak testing requirements for each system at a frequency not to exceed refueling cycla intervals.
B.
Iodine Monitoring Program A program shall be established to ens'ure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include training of personnel, procedures for monitoring and provisions for maintenance of sampling and analysis equipment.
C.
Environmental Qualification Program A.
By no later than June 30, 1982 all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of: Division of Operating Reactors " Guidelines for Evaluating Environmental Qualification of Class IE Electrical l
Equipment in Operating Reactors" (DOR Guidelines); or, NUREG-0588
" Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment". December 1979. Copies of these documents are attached to Order for Modification of License DPR-46 dated October 24, 1980.
B.
By no later than December 1, 1980, complete and auditable records must be available and maintained at a central location which describe the environmental qualification method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the DDR Guidelines or NUREG-0588.
Thereafter, such records should be updated and maintained current as equipmeat is replaced, further tested, or otherwise further qualified.
D.
Post-Accident Sampling System (PASS)
A program shall be established to ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere semples under accident conditions.
This program shall include training of personnel, procedures for sampling and analysis and provisions for operability of sampling and analysis equipment.
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