ML20206U737
| ML20206U737 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/19/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20206U734 | List: |
| References | |
| NUDOCS 9905250320 | |
| Download: ML20206U737 (5) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 231TO FACILITY OPERATING LICENSE NO. NPF-3 FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION. UNIT 1 DOCKET NO. 50-346
1.0 INTRODUCTION
By letters dated October 28,1998, and March 19,1999, Davis-Besse Nuclesr Power Station, Unit 1 (the licensee), submitted proposed changes to the facility Technical Specifications (TS).
The March 19,1999, changes to the application did not modify the application beyond the scope of the description of proposed changes provided in the Federal Reaister notice identified in Section 4.0 below, or alter the proposed no significant hazards consideration determination.
The proposed changes include:
A.
Revising the Station Review Board (SRB) responsibilities in TS 6.5.1.6 regarding the review of changes to plans and programs.
B.
Updating and correcting various references in TS 6.8.4.d.2, TS 6.8.4.d.3, TS 6.8.4.d.7, TS 6.10.2.e and TS 6.15.a.2.
C.
Relocating TS 6.11 " Radiation Protection Program" to the Updated Safety Analysis Report.
D.
Revising TS 6.12, "High Radiation Area," to reference the current revision to 10 CFR Part 20, Subpart G, " Control of Exposure from External Sources in Restricted Areas," and specify alternative methods for controlling access to high radiation areas and monitoring personnel exposure.
2.0 DISCUSSION AND EVALUATION This amendment revises administrative requirements relating to: TS 6.5.1.6, Station Review Board Responsibilities; TS 6.8.4.d, Radioactive Effluent Controls Program; TS 6.10, Records Retention; TS 6.11, Radiation Protection Program; TS 6.12 High Radiation Area; and TS 6.15, Offsite Dose Calculation Manual. A discussion and evaluation of each of the proposed TS changes follows:
9905250320 990519 PDR ADOCK 05000346 P
, 2.1 TS 6.5.1.6. Station Review Board Responsitjhiigg TS 6.5.1.6 specifies, in part, that the SRB is responsible for review of certain program plans and changes to those plans. These plans and changes include the Industrial Security Plan, Security Training and Qualification Plan, Security Contingency Plan, Emergency Plan, and Fire Protection Program. The licensee has proposed that the SRB be responsible only for changes to the plans and the programs. This TS revision is being proposed in order to clearly delineate the extent of the SRB's review of the aforementioned programs and plans, and to more efficiently utilize the SRB's review time. The licensee's basis for acceptability is that each of these plans and programs is audited by other individuals and organizations, as required by other TS and regulations, at least every 12 months, and thus the SRB's review efforts are best focused on changes to the plans and programs.
The staff finds this change acceptable on the basis that the necessary periodic review function for these plans and programs is adequately implemented by the auditing activities identified in the application.
2.2 TS 6.8.4.d. Radioactive Effluent Controls Proaram TS 6.8.4.d identifies cer1ain programs that must be estabiished, implemented, and maintained.
It includes references to "10 CFR Part 20, Appendix B, Table 11." The licensee initially requested that references to "10 CFR Part 20, Appendix B, Table 11" be changed to "10 CFR Part 20, Appendix B, Table 2." The licensee also requested that "10 CFR 20.106" be updated to "10 CFR 20.1302." The application stated that these are editorial corrections to reflect the revised regulations.
In the letter dated March 19,1999, the licensee withdrew the request to change "10 CFR Part 20, Appendix B, Table 11" to "10 CFR Part 20, Appendix B, Table 2", because the concentrations in Table 2 are too low and are therefore impractical to base effluent monitor setpoint calculations for many liquid effluent release situations when monitor background, monitor sensitivity, and monitor performance must be taken into account. The use of Table ll concentration values continues to be an acceptable method to maintain operational flexibility and ensure regulatory compliance with the dose objectives contained in Appendix l to 10 CFR Part 50 concurrent with the implementation of the revised 10 CFR Part 20.
2.3 TS 6.10. Records Retention TS 6.10.2.e requires that " Records of transient of operational cycles for those facility components identified in Table 5.7-1" be retained for the duration of the operating licensee.
Table 5.7-1 was relocated from the TS to the USAR by Amendment No. 204 dated December 8, 1995. The licensee proposes to correct the requirement so as to apply to " Records of transient gI operational cycles for those facility components identified in the USAR Table 5.1-8.
The replacement of"of"with "or"is editorial ano of no safety significance. The Table reference is consistent with previously approved License Amendment No. 204 which approved the relocation of the content of TS Table 5.7-1 to USAR Table 5.1-8. Therefore, the staff finds the 6.10 changes acceptable.
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) 2.4 TS 6.11 Radiation Protection Prooram
' TS 6.11 states:
Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
The licensee requested deletion of TS 6.11 on the basis of its redundancy to current USAR Section 12.3.1 " Health Physics-Program Objectives," and 10 CFR Part 20 requirements. The licensee noted that the deletion would simplify the TS and that its removal would be consistent with the staff guidance of NUREG-1430 (Standard Technical Specifications).
The proposed removal of TS 6.11 is consistent with NUREG 1430, Revision 1, " improved Standard Technical Specifications for Babcock and Wilcox Plants." The TS requirements to be deleted from the TS are adequately implemented through regulations and licensee controlled documents. Therefore, the staff finds the proposed change to be acceptable.
2.5 TS 6.12 H!ah Radiation Areas TS 6.12.1 identifies radiation protection requirements applicable to those high radiation areas that do not require locked doors. The licensee proposes the following changes to TS 6.12.1:
(1) change a reference to "10 CFR Section 20.203(c)(2)" to "10 CFR Section 20.1601(a), (b) and (c)";
(2) change the threshold dose rate condition that defines those high radiation areas for which TS 6.12.1 applies, from "less than or equal to 1000 mrem /hr" to "not exceeding 1.0 rem /hr at 30 centimeters";
(3) allow barricades for high radiation areas to be opened as necessary to permit entry or exit of personnel or equipment; (4) add a requirement that Radiation Work Permits (RWPs) identify radiation dose rates in the immediate work areas and other appropriate radiation equipment and measures; (5) provide RWP exemption of personnel continuously escorted by individuals qualified in radiation protection procedures (e.g., by health physics personnel);
(6) allow (as an additional attemative to preserstly specified person or group monitoririg devices), the use of a radiation monitoring device that transmits dose rate and cumulative dose to a remote receiver monitored by radiation protection personnel; and (7) allow for use of only a self-reading dosimeter by an individual who is also under the surveillance of qualified radiation protection personnel by means of closed circuit televisiot'.
TS 6.12.2 identifies additional radiation protection requirements applicable to certain high radiation areas that require locked doors. The licensee proposes the following changes to TS 6.12.2:
(1) change the threshold dose rate condition that defines applicability of TS 6.12.2, from
" greater than 1000 mrem /hr" to " greater that 1.0 rem /hr at 30 centimeters, but less than 500 rads /hr at 1 meter";
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(2) allow the use of a locked gate or other locked barrier as attematives to locked doors for preventing unauthorized entry; (3) add a requirement that Radiation Work Permits (RWPs) identify radiation dose rates in the i
immediate work areas and other appropriate radiation equipment and measures; (4) allow for entry using a radiation monitoring device transmitting dose rate and cumulative dose to a remote receiver monitored by radiation protection personnel, as long as there is a means to communicate with and control every individual in the area; 4
(5) allow for entry using a self-reading dosimeter while being under the surveillance of an individual qualified in radiation protection procedures that is equipped with a radiation j
monitoring device that continuously displays radiation dose rates in the area, or while being under surveillance by means of a closed circuit television by qualified radiation protection personnel equipped with the means to communicate arid control every individual in the area; and (6) allow for use of a conspicuous barricade and clearly visible flashing light as a waming device for a high radiation area that is within a larger area where no enclosure exists for the purpose oflocking and where no enclosure can reasonably be constructed.
The Technical Specification changes proposed above are consistent with Regulatory Guide 8.38; therefore, the staff finds them acceptable.
2.6 TS 6.15 Offsite Dose Calculation Manual The licensee has proposed to change the reference "10 CFR 20.106" to "10 CFR 20.1302." The change is editorial in nature and does not alter any substantive requirements. Thus, the staff finds it acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 1u CFR Part 20 or changes a surveillance requirement, or changes recordkeeping, reporting, or administrative procedures or requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radistion exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (63 FR 64126). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
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5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: R. Tadesse, W. Long Date: May 19, 1999 4
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