ML082350078

GE Hitachi Nuclear Energy - Technical Basis for No Significant Hazard Analysis for EVESR Technical Specifications, Amendment 7

ML082350078
Person / Time
Site:	Vallecitos File:GEH Hitachi icon.png
Issue date:	08/19/2008
From:	Latonya Mahlahla GE-Hitachi Nuclear Energy Americas
To:	Document Control Desk, NRC/FSME
References
Download: ML082350078 (3)

Text

r" Q HITACHI GE Hitachi Nuclear Energy LaTonya Mahlahla Vallecitos Nuclear Center 6705 Vallecitos Rd Sunol, CA 94586 USA U.S. Nuclear Regulatory Commission T925 862 4092 F 910-341-2972 One White Flint North Latonya.mahlahla@ge.com 11555 Rockville Pike Rockville, Maryland 20852-2738 Attn: Document Control Desk August 19, 2008

Subject:

10 CFR 50.91(a) No Significant Hazard Analysis for EVESR Technical Specifications, Amendment Seven

References:

1) License DR-10, Docket 50-183

2) EVESR Technical Specification Amendment 7, (Letter from Latonya Mahlahla to Document Control Desk 6/23/08, LLM-2008-19)

3) No Significant Hazard Analysis (Letter from Latonya Mahlahla to Document Control Desk 8/11/08, LLM-2008-23)

Enclosure:

Technical Basis For No Significant Hazard Analysis submitted to Document Control Desk on August 11, 2008 Enclosed in the Technical Basis for the No Significant Hazard Analysis submitted for EVESR Technical Specifications, Amendment 7 (Reference 2). Enclosure 2 was inadvertently omitted from the submittal to the NRC on August 11, 2008 (Reference 3).

Ifyou have any.quq, or need additional information, please contact me at 925-862-4092. /

Sincerely Y( -7 .2008.08.19 15:12:04

-07'00' LaTonya L.Mahlahla Mgr., Regulatory Compliance & EHS cc: John Buckley LLM-2008-24 Technical Basis for No Significant Hazard Analysis UkkS~c120

Enclosure 2 Technical Basis For No Significant Hazard Analysis for EVESR Technical Specifications, Amendment 7 Summary of Changes for EVESR Technical Specifications, Amendment 7 Affected Section: Technical Specifications Section A.2, Principle Activities currently states:

"The principal activities carried on within the plant area shall be the possession of the reactor facility, the dismantling of components other than the reactor pressure vessel, and activities authorized by licenses issued by appropriate regulatory authorities provided such activities do not involve access, except for reason of inspection, maintenance, and surveillance, to areas below the 549-ft. elevation within the containment building."

Proposed Change 1) Delete "provided such activities do not involve access, except for reason of inspection, maintenance, and surveillance, to areas below the 549-ft. elevation within the containment building" from page 1 of Technical Specification Section A.2. GEH request condition A.2 be amended as follows:

A.2 "The principalactivitiescarried on within the plant area shall be the possession of the reactorfacility, the dismantling of components other than the reactorpressure vessel, and activities authorized by licenses issued by appropriateregulatoryauthorities."

Affected Section: Techncial Specifications Section B. 3 Surveillance and Security currently states:

"Access to areas below the 549-ft level shall remain covered by concrete blocks over the reactor vessel and the head and shield plug storage pit, by a wood cover over the empty spent fuel storage pit and by locked covers on the personnel and equipment hatchways.

Keys to locks on the hatches and on the crane power switch shall be available only to the facility supervisor of his designated alternate."

Proposed Change 2) Delete the paragraph below condition C.3, Surveillance and Security in its entirety and replace with the following:

B.3 "Access to areas of the EVESR containment shall be controlled in a manner consistent with the requirementsof 10 CFR 20.1601, Control of access to high radiation areas,as applicable."

10CFR50.91(a) No Significant Hazard Analysis

1) Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

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Enclosure 2 Technical Basis For No Significant Hazard Analysis for EVESR Technical Specifications, Amendment 7 Proposed change one is an administrative change submitted to clarify the area where dismantling activities will occur as authorized by the facility license. The majority of the component removal activities will occur in areas below the 549-ft. elevation. Proposed change two removes the specific shielding and covering requirements for the reactor vessel, shield plug storage pit and the empty spent fuel storage pit and modifies the access control requirements to be consistent with 10CFR20. The EVESR reactor was shutdown in 1967 and has remained in a "Possess Only" status. All fuel bundles were removed from the facility and the radiation and contamination levels have been reduced by the removal of radioactive material and natural decay. No aspect of the proposed changes will involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the change create the possibility of a new or different kind of accident from any accident evaluated?

Response: No.

Proposed change one is an administrative, therefore there it cannot create a new or different kind of accident. Removal of the specific shielding and covering requirements for the reactor vessel, shield plug storage pit and the empty spent fuel storage pit and modification of the access control requirements as described in proposed change two will not impact the function or integrity of the reactor pressure vessel, which is the primary safety system required to be maintained by the license. The proposed changes do not create the possibility of a new or different kind of accident from any accident evaluated.

3) Does the change involve a significant reduction in a margin of safety?

Response: No.

Removal of the specific shielding, covering and access control requirements will not result in a reduction of the margin of the safety for the EVESR facility. These controls were implemented to provide shielding and access controls to High Radiation Areas. Since the reactor is no longer operating and the radiological conditions have been significantly reduced, the specific controls specified in the current technical specifications are not required. All areas in the EVESR containment will be controlled in accordance with 10 CFR

20. High Radiation areas will be controlled in a manner consistent with the requirements of 10CFR20.1601. The proposed changes do not affect the margins of safety.

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