ML18153B990

Proposed Tech Specs Eliminating Buddy Sys Requirement for Entry Into High Radiation Areas to Reduce Unnecessary Personnel Exposure & Deleting Duplicate Requirements in CFR & Reorganizes STS Section 6.4.B Format

ML18153B990
Person / Time
Site:	Surry
Issue date:	11/14/1989
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML18153B989	List: ML18153B988 ML18153B990
References
NUDOCS 8911280439
Download: ML18153B990 (8)

Text

- e ATTACHMENT 1 Proposed Technical Specification Change

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Discussion Technical Specification (TS) 6.4.B addresses procedures for personnel radiation protection consistent with the requirements of 10 CFR 20. Specifically, TS 6.4.B.1 contains various provisions which serve as alternatives to the requirements of 10 CFR 20.203(c)(2), dealing with controls to the entrance or access point of high radiation areas. Alternatives to 10 CFR 20.203(c)(2) are allowed under 10 CFR 20.203(c)(5).

The present Section 6.4.B is an "originally issued" portion of Technical Specifications.

Based on a request dated April 1, 1971, for exemption from the provisions of 10 CFR 20.203(c)(2), it appears that the present TS 6.4.B was intended to function as a customized version of the subsequent Standard Technical Specifications (STS),

Section 6.12. Since this exemption request was made prior to the issuance of the Operating License, we surmise that the elements of TS 6.4.B were formed as compensatory/clarifying specifications during Technical Specification development for the Operating License.

Included in TS 6.4.B is a requirement to maintain a "buddy system" for entrance into radiation areas in excess of 1 R/hr. For this requirement, one worker maintains positive control of the locked gate regardless of whether it is open or closed at the time while the other worker (his "buddy") performs the necessary work. The* two individuals are required to maintain continuous communication by visual or verbal means during this period. Due to this requirement, two individuals are subject to radiation exposure, regardless of whether both are required to accomplish the work.

In our review of the historical record, we can find no technical bases or discussion which justifies or directs the inclusion of the "buddy system" into Technical Specifications. With respect to the regulatory and radiation protection standards of today, the "buddy system" requirement of TS 6.4.B.1.f is inconsistent with STS and contrary to common ALARA practices. Deletion of TS 6.4.B.1.f will result in a significant reduction in man-rem exposure (approximately 9.6 man-rem per year). In addition, the proposed TS 6.4.B has been rewritten using a new format. The new format conforms to that used in NUREG-0452, Revision 4, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors." In addition, the content of TS 6.4.B has been revised to be consistent with the corresponding Technical Specifications for the North Anna Power Station. A summary of the changes being requested is as follows:

1. Surry requirements specified by TS 6.4.B.1.c are being deleted. This section duplicates requirements contained in 10 CFR 20.201 and is therefore, not necessary.

2. Personnel indoctrination required* by TS 6.4.B.1.d is being deleted. This section duplicates requirements contained in 10 CFR 19.12.

3. The "buddy system" of TS 6.4.B.1.f is being deleted. The "buddy system" results in unnecessary personnel exposures and is not consistent with maintaining exposures As Low As Reasonably Achievable (ALARA).

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4. The requirement for fencing of buildings contained in TS 6.4.B.1.h is being deleted. Physical protection of buildings and materials is required by 10 CFR 73.

5. Generic terminology has been used to define the responsible individual for health physics and radiation protection to avoid future conflicts due to title changes.

TS 6.4-1 6.4 UNIT OPERATING PROCEDURES Specification A. Detailed written procedures with appropriate check-off lists and instructions shall be provided for the following conditions:

1. Normal startup, operation, and shutdown of a unit, and of all systems and components involving nuclear safety o_f the station.

2. Calibration and testing of instruments, components, and systems involving nuclear safety of the station.

3. Actions to be taken for specific and foreseen malfunctions of systems or components including alarms, primary system leaks and abnormal reactivity changes.

4. Release of radioactive effluents.

5. Emergency conditions involving potential or actual release of radioactivity.

6. Emergency conditions involving violation of industrial security.

7. Preventive or corrective maintenance operations which would have an effect on the safety of the reactor.

8. Refueling operations.

B. 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.

e TS 6.4-2

1. In lieu of the "control device" or "alarm signal" required by paragraph 20.230(c)(2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP)*. 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 vvith this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by Health Physics in the RWP.

• Health Physics personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved plant radiation protection procedures for entry into high radiation areas.

TS 6.4-3

2. The requirements of 6.4.B.1 above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr. In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shift Supervisor on duty and/or the senior station individual assigned the responsibility for health physics and radiation protection.

3. Written procedures shall be established, implemented, and maintained covering the activities referenced below:

a. Process Control Program implementation.

b. Offsite Dose Calculation Manual implementation.

C. All procedures described in 6.4.A and 6.4.B, and changes thereto, shall be reviewed and approved by the Station Nuclear Safety and Operating Committee prior to implementation.

ATTACHMENT 2 Significant Hazards Consideration Determination

e Significant Hazards Consideration The requested change to TS 6.4.B does not represent a significant hazard as defined by 10 CFR 50.92.

1. No significant increase in the probability or consequences of an accident previously evaluated is created. The change to TS 6.4.B revises the TS format, removes TS requirements that are duplicated in other 1o CFR sections, and deletes the use of the "buddy system" for entering areas with radiation levels in excess of 1 R/hr. Thus, the only significant change to TS 6.4.B is to remove the "buddy system" when accessing certain high radiation areas. This change does not alter the facility, its equipment, or procedures affecting equipment operation and, therefore, has no effect on the probability or consequences of any accident.

2. No possibility of a new or different kind of accident from any accident previously evaluated is created. The TS change only changes the access procedures for entering areas with radiation levels in excess of 1 R/hr. As noted before, the proposed changes do not make any change to the facility or plant operation.

3. No significant reduction in a margin of safety is involved. The revised TS provides access control for areas with radiation levels in excess of 1 R/hr by requiring _a locked door with the keys under administrative control of the Shift Supervisor on duty and/or the senior station individual assigned responsibility for health physics and radiation protection. The TS also requires the issuance of a Radiation Work Permit for access,, except for Health Physics personnel during the performance of their assigned radiation protection duties. These controls comply with the access control alternatives specified in 10 CFR 20.203(c)(2)(iii).