NOC-AE-02001415, License Amendment Request - Supplement to Proposed Amendment to South Texas Project TS to Revise Administrative Control Requirements

License Amendment Request - Supplement to Proposed Amendment to South Texas Project TS to Revise Administrative Control Requirements

ML023020248
Person / Time
Site:	South Texas
Issue date:	10/23/2002
From:	Jordan T South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-02001415, NUREG-1431
Download: ML023020248 (17)

Text

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October 23, 2002 NOC-AE-02001415 File No.: G25 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 License Amendment Request Supplement to Proposed Amendment to South Texas Project Technical Specifications to Revise Administrative Control Requirements

Reference:

Letter NOC-AE-01001 146, J. J. Sheppard to U.S. Nuclear Regulatory Commission, "Proposed Amendment to South Texas Project Technical Specifications to Revise Administrative Control Requirements," dated November 5, 2001.

Pursuant to 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) hereby submits this supplement to the referenced application for amendment to the South Texas Project Facility Operating Licenses NPF-76 and NPF-80.

The referenced license amendment request proposed to revise various requirements denoted in, or associated with Section 6.0 of the Technical Specifications, "Administrative Controls." These proposed changes update the Technical Specifications (TS) to be consistent with current industry standards and guidance.

During NRC review of the license amendment request, wording differences were noted between the proposed STP changes to Section 6.12 and NUREG-1431 Improved Technical Specifications standard language. As a result, STP submits the attached revised proposed changes to Section 6.12, which supercede and replace the proposed changes submitted in the referenced amendment request. Because there is no change in the intent of these revised changes with respect to the referenced submittal, STP considers these changes to be bounded by the original licensee assessment, no significant hazards consideration determination, and environmental assessment.

STI:31501833

NOC-AE-02001415 Page 2 Attachment 1 provides a detailed description of the revised proposed changes, provided in the same format as the referenced amendment request. Attachment 2 provides the revised TS mark-up pages. Attachment 3 provides a retyped copy of the affected TS pages.

STPNOC is notifying the State of Texas of this supplement to the referenced request for license amendment in accordance with 10 CFR 50.91(b).

If there are any questions regarding the proposed amendment, please contact Mr. J. R. Morris at (361) 972-8652 or me at (361) 972-7902.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on WA-, 'Z3, zooZ-1.J ordaný Vice President Engineering & Technical Services JRM/

Attachments:

1. Description of Changes

2. Annotated Technical Specification Pages

3. Technical Specification Pages with Proposed Changes Incorporated

NOC-AE-02001415 Page 3 cc:

(paper copy) (electronic copy)

Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 M. T. Hardt/W. C. Gunst Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Reliant Energy, Inc.

Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP - Central Power and Light Company Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-02001415 Attachment 1 Page 1 of 7 ATTACHMENT 1 DESCRIPTION OF CHANGES

NOC-AE-02001415 Attachment 1 Page 2 of 7 The specific revised proposed changes are identified in Table la below, which supercedes Items 98 through 111 of Table 1 in letter NOC-AE-01001 146. A detailed description of the change type codes is provided in that letter.

TABLE la Change Type Codes: A Administrative M More Restrictive than Current TS L Less Restrictive than Current TS (other than a relocation of requirements)

R - Relocation from Current TS to Other Licensee-Controlled Documents

1. Affected Change Description of Change Reason / Justification for Sections Type Change 98 6.12.1 A Changed This is an editorial change to improve grammar and "Pursuant to paragraph readability. This requirement is 20.1601(c) of 10 CFR Part 20, in consistent with NUREG-1431.

lieu of the "control device" or "alarm signal" required by paragraph 20.1601 (a)... defined in 10 CFR Part 20..."

to "Pursuant to 10 CFR 20.1601(c),

in lieu of the requirements of 20.1601(a)... defined in 10 CFR 20..."

NOC-AE-02001415 Attachment 1 Page 3 of 7

1. Affected Change Description of Change Reason / Justification for Sections TyTpe Change 99 6.12.1 A Changed The details contained in TS 6.12.1 are revised consistent

"... radiation is equal to or less with the 10 CFR 20.1003 than 1000 mRem/h..." definition of a "High Radiation Area." Since addition of these to details results in no actual change in the requirements, this

"... radiation is greater than 100 is considered an editorial mrem/h but equal to or less than change. The proposed change 1000 mrem/h..." is consistent with NUREG 1431.

100 6.12.1 A Changed This is an editorial change to improve grammar and

"... shall be controlled by readability, and to revise requiring issuance of a Radiation organizational titles to be Work Permit (RWP)." consistent with STP terminology. The proposed to changes are consistent with NUREG-1431.

"... shall be controlled by Radiation Work Permit (RWP)."

and changed "Health Physics Technician" to "radiation protection technician" 101 6.12.1 A Changed This is an editorial change to improve grammar and

"... areas with dose rates equal to readability. The proposed or less than 1000 mRem/h..." change is consistent with NUREG-1431.

to

"... areas with radiation levels equal to or less than 1000 mremlh..."

NOC-AE-02001415 Attachment 1 Page 4 of 7

1. Affected Change Description of Change Reason / Justification for Sections Type Change 101 6.12.1 A Created a new paragraph in the This is an editorial change to a existing text. improve grammar and readability.

102 6.12.1.a A Changed "; or" to "." This is an editorial change to 6.12.1 .b improve grammar and readability. The proposed change is consistent with NUREG-1431.

102 6.12.1.b A Changed These wording changes are a made to improve consistency "established" to "determined" with NUREG-1431 language.

and "individuals have been made" to "entry personnel are" 102 6.12.1.c M Added new item 6.12.1.c, which This option was added to be b adds option permitting use of consistent with NUREG-1431 remote receiver requirements.

103 6.12.1.d M Restructured existing 6.12.1.c to These changes were added to be add the requirement for self- consistent with NUREG-1431 reading dosimetry, and added requirements.

paragraph ii. to allow the associated option for remote means of surveillance.

NOC-AE-02001415 Attachment 1 Page 5 of 7

1. Affected Change Description of Change Reason / Justification for Sections Type Change 103 6.12.1.d L.5 Changed The requirement of TS 6.12.1.d a pertains to the individual

"... frequency specified by the qualified in radiation protection health physics supervision in the responsible for providing RWP." control over the activities in a high radiation area including to the performance of periodic radiation surveillances. The

"... frequency specified in the responsibility for specifying RWP." surveillance frequency in the RWP is not pertinent to the requirements for entering a high radiation area. RWP details are controlled by plant procedures.

Deleting these details eliminates ambiguity in the TS and possible misinterpretation of the TS requirements.

104 6.12.2 L Changed A guard has been determined to be an equivalent constraint for

"...shall be provided with locked prevention of unauthorized doors to prevent unauthorized entry into such areas.

entry, and the keys shall ... " Therefore, this change does not significantly reduce the to required controls, and provides an additional option for

"...shall be provided with locked preventing unnecessary or continuously guarded doors to radiation exposure. The prevent unauthorized entry. The proposed change is consistent keys to the doors shall ... " with NUREG-1431.

NOC-AE-02001415 Attachment 1 Page 6 of 7

1. Affected Change Description of Change Reason / Justification for Sections T-YP Change 105 6.12.2 A Changed This is an editorial change to improve grammar and

"... Shift Supervisor on duty readability, and to revise and/or health physics organizational titles to be supervision." consistent with STP terminology.

to Also refer to Change #6.

"... shift manager on duty or radiation protection manager." The proposed changes are consistent with NUREG-1431.

106 6.12.2 A Changed The proposed change is consistent with NLJREG-1431.

"...approved RWP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area."

to

"...approved RWP. Prior to entry, individuals shall be informed of the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area."

107 6.12.2 A Changed The proposed change is consistent with NUREG-1431.

"...stay time specification of the RWP, ..."

to

"...stay time specification, ... "

NOC-AE-02001415 Attachment 1 Page 7 of 7

1. Affected Change Description of Change Reason / Justification for Sections Type Change 108 6.12.2 A Changed The proposed change is consistent with NUREG-1431 "For isolated high radiation and 10 CFR 20.

areas..."

to "For individual high radiation areas..."

109 6.12.2 A Changed This is an editorial change to improve grammar and

"...such as PWR containment, readability. The proposed change is consistent with NUREG-1431.

to

"...such as reactor containment, 110 6.12.2 A Changed This change is consistent with the proposed wording in

"...purposes of locking, and Change #104, and is consistent where no enclosure..." with NUREG-1431.

to

"...purposes of locking, or that cannot be continuously guarded, and where no enclosure..."

111 6.12.2 A Changed This is an editorial change to improve grammar and "isolated area" readability, and is consistent with the proposed wording in to Change #108. The proposed change is consistent with "individual area" NUREG-1431.

in two places

NOC-AE-02001415 Attachment 2 Page 1 of 4 ATTACHMENT 2 ANNOTATED TECHNICAL SPECIFICATION PAGES Note to Reviewers:

These pages replace pages 43 and 44 of Letter NOC-AE-01 001146, Attachment 2.

Mark-ups in this attachment include references to the list of changes presented in Attachment 1.

These references are formatted as such:

I<-xx where XX is the Change # listed in Table 1.

NOC-AE-02001415 Attachment 2 Page 2 of 4 Insert a Page Break - Header to include 6.0 ADMINISTRATIVE CONTROLS 6.12 High Radiation Area 6.12.1 <-98 Pursuant to 10 CFR paragraph 20.1601(C) of 10 CFR Part 20, in lieu of the "contro. doVic." or "alarm signal" requircd by paragraph requirements of 20.1601 (a),

each high radiation area, as defined in 10 CFR Par 20, in which the intensity of SOUTH TEXAS - UNITS 1 & 2 6-24 Unit 1 - Amendment No. 46, 17, 57, 1 Unit 2 - Amendment No. 35, 36, 46,

NOC-AE-02001415 Attachment 2 Page 3 of 4 ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Gontinued),<

<99 radiation is greater than 100 mrem/h but equal to or less than 1000 mrem/h at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto 100 shall be controlled by ru i .ri.iuane of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., Health-Physis radiation protection Ttechnician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation

<101 areas with radiation levels dose rates equal to or less than 1000 mrem/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas. 1<10a [new paragraph] Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. 1 A radiation monitoring device which continuously indicates the radiation dose rate in the area.i-or

b. 1 A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established determined and individuals have been made entry personnel are knowledgeable of them.-er.

c. 102-b A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.

de. <0 A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and,

i. Be under the surveillance of Aan individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified < by the health physics supervision in the RWPR, or ii. Be under surveillance by means of closed circuit television or equivalent, or personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.

6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to individuals with

<0 radiation levels greater than 1000 mrem/h at 30 cm (12 in.) but less than 500 Rads in one hour at one meter from the radiation source or from any surface which the radiation penetrates shall be provided with locked or continuously guarded doors to prevent unauthorized entry.,-and The ke.s to the doors shall be maintained under the administrative control of the 1<10 sShift Superviser manager on duty and/or radiation protection supervision manager. Doors shall remain locked except during periods of access by individuals under an 1 approved RWP. Which shall specify Prior to entry, individuals shall be informed of the dose rate levels in the immediate work areas and the

NOC-AE-02001415 Attachment 2 Page 4 of 4 maximum allowable stay time for individuals in that area. In lieu of the 1 stay time specification of-the-RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by individuals qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

<0 For isolated individual high radiation areas, accessible to personnel, with radiation levels of greater than 1000 mrem/h at 30 cm (12 in. but less than 500 Rads in one hour at one meter that are located within large areas, < such as PWR reactor containment, where no enclosure exists for 1 purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the isolated individual area, that isolated individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

NOC-AE-02001415 Attachment 3 Page 1 ATTACHMENT 3 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES INCORPORATED

6.0 ADMINISTRATIVE CONTROLS 6.12 High Radiation Area 6.12.1 Pursuant to 10 CFR 20.1601 (c), in lieu of the requirements of 20.1601 (a), each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is greater than 100 mrem/h but equal to or less than 1000 mrem/h at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., radiation protection technician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with radiation levels equal to or less than 1000 mrem/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been determined and entry personnel are knowledgeable of them.

c. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.

d. A self-reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and,

i. Be under the surveillance of an individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified in the RWP, or ii. Be under surveillance by means of closed circuit television or equivalent, or personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance.

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-17 Unit 1 - Amendment No.

Unit 2 - Amendment No.

f 6.0 ADMINISTRATIVE CONTROLS 6.12 High Radiation Area 6.12.2 In addition to the requirements of Specification 6.12.1, areas accessible to individuals with radiation levels greater than 1000 mrerm/h at 30 cm (12 in.) but less than 500 Rads in one hour at one meter from the radiation source or from any surface which the radiation penetrates shall be provided with locked or continuously guarded doors to prevent unauthorized entry. The keys to the doors shall be maintained under the administrative control of the shift manager on duty or radiation protection manager.

Doors shall remain locked except during periods of access by individuals under an approved RWP. Prior to entry, individuals shall be informed of the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by individuals qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

For individual high radiation areas, accessible to personnel, with radiation levels greater than 1000 mrem/h at 30 cm (12 in.) but less than 500 Rads in one hour at one meter that are located within large areas, such as reactor containment, where no enclosure exists for purposes of locking, or that cannot be continuously guarded, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

I SOUTH TEXAS - UNITS 1 & 2 6-18 Unit 1 - Amendment No.

Unit 2 - Amendment No.