ML20126B866

Forwards Response to NRC 921118 Request for Addl Info Re 920824 Application for Amend to Licenses NPF-2 & NPF-8, Changing TS to Reflect Implementation of New 10CFR20 Requirements & Overleaf Page in Response to GL 89-01

ML20126B866
Person / Time
Site:	Farley
Issue date:	12/17/1992
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20126B870	List: ML20126B866 ML20126B871
References
GL-89-01, GL-89-1, NUDOCS 9212220255
Download: ML20126B866 (7)

Text

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Docket Nos. 50-348 10 CFR 50.90 50 364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Joseph M. Farley Nuclear Plant Technical Specification Changes Associated With lwPlcmentation of the New 10 CFR 20 RcQuirements Gentlemen:

In response to your letter dated November 18,1992, attached is the additional information you requested regarding Southern Nuclear Operating Company's (SNC) license amendment request dated August 24,1992, associated with implementation of the new 10 CFR 20 requirements at Farley Nuclear Plant. Attachment I contains your questions as numbered and worded in the November 18,1992 letter, and our responses.

Attachment 2 contains revised proposed technical specifications associated with the responses. Land marked and revised pages are included in Attachment 2, and supersede

. the corresponding pages provided in the August 24,1992 submittal. An overleaf page l submitted in SNC's response to Generic Letter 89-01 dated June 23,1992, is also affected l by these responses. Additionally, the significant hazards evaluation contained in the August 24,1992 submittalis unaffected by the revised technical specification pages.

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U. S. Nuclear Regulatory Commission Page 2 Should you have any questions regarding this information, please contact this omee.

Respectfully submitted, NDb d.~,\

T- Voodard SWORN TO AND SUBSCRIBED BEFORE hie

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ATTACllMENT 1 Response to NRC Request for AdditionalInformation Dated November 18,1992 Concerning implementation of the New 10 CFR 20 Requirements i

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J Joseph M. Farley Nuclear Plant Units I and 2

! Response to NRC Request for Additional Infonnation Concerning Implementation of the New 10 CFR 20 Requirements i

Q11gidon 470.1 In Technical Specification (TS) Bases Section 3/4.11.1.4, Liquid IIoldup Tanks, it is proposed to delete "10 CFR Part 20, Appendix B, Table II, Column 2" and replace it with

"10 CFR Part 20.1302(b)(2)(i)."

! NUREG-0133 and Standard Review Plan 15.7.3 provide guidance in this area. The

documents specifically discuss that radioactivity must be controlled so that any leaked fluid does not result in concentrations to a water supply in an unrestricted area in excess of the limits of 10 CFR Part 20, Appendix B, Table 11, Colurnn 2. This is the instantaneous concentration given in the table. It is not the annual average of the concentration, as would be allowed if the section of the rule were cited (20.106). The proposed use of

10 CFR 20.1302(b)(2)(i) as a reference in the bases section would incorrectly imply that j annual averaging of the elliuent concentration is allowed. Annual averaging is not allowed i for this specification.

4 Because the new values in Appendix B, Table 11, Column 2 to 10 CFR 20.1001-20.2401 are, overall, a factor of 10 lower than before, the Nuclear Regulatory Commission Staff considers it acceptable for licensees to propose a factor of 10 increase for these values.

These values will maintain the same overall level of efIluent control that existed under the old 10 CFR Part 20. The 10 curie limit remains unchanged.

f it is requested that the Bases section be revised to reference a value of 10 times the limits

of Appendix B, Table II, Column 2 to 10 CFR 20.1001-20.2401.

BrIppnse to OuellionEQl Bases Section 3/4.11.1.4 has been revised as requested to reference a value of 10 times the limits of 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 2, instead of 10 CFR Part 20.1302(b)(2)(i). Note in the above question there was an incorrect reference to " Table 11" relative to the new 10 CFR 20. The reference should have been to " Table 2."

Qgslion 470.2 In "lNSERT 3B", of the new Administrative Controls, Section 6.8.3.e, Radioactive Ellluent Controls Program, the phrase "which corresponds to a dose rate of 500 mrem / year total effective dose equivalent" is unnecessary, inconsistent with Standard

, ' Technical Specification wording, and provides no additional control in the context of the TS. On this basis, it should therefore be deleted.

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i # s Response to NRC Request for Additionalinfonnation

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The intent of the TS is to limit radioactive material concentrations released in gaseous efiluents to areas beyond the site boundary. The inclusion of wording for purposes other than controlling rt.dioactive gaseous efIluents is discouraged. Ifclarification for other purposes is deemed necessary, it should be placed in the appropriate licensee document,

, not in the TS.

] Responsttq_Quntion 470.2 Proposed Technical Specification 6.8.3.c has been revised by deleting the phrase "which corresponds to a dose rate of 500 mrenVycar total effective dose equivalent," and replacing it with a footnote which states "At any time, ten times the concentrations stated in 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401), Table 2, Column 1, 4

conesponds to a dose rate of 500 mrem / year total effective dose equivalent."

l Existing plant emergency preparedness procedures, which establish emergency action level j guidelines, reference technical specification limits stated in terms of dose rate. It is i

therefore desirable to maintain the reference to a dose rate of 500 mrem / year in the technical specifications.

3 The proposed footnote is accurate and appropriate according to the first paragraph of the section titled " Table 2" contained in Appendix B (to paragraphs 20.1001 - 20.2401) of the new 10 CFR 20, which states in part, "The concentration values given in Columns 1 and 2

, of Table 2 are equivalent to the radionuclide concentrations which, ifinhaled or ingested continuously over the course of a year, would produce a total effective dose equivalent of 0.05 rem (50 millirem or 0.5 millisleverts)." Therefore, if the concentration values are increased by a factor of ten, the corresponding dose rate at any time would be

, 500 mrem / year as included in the proposed footnote.

SNC views this proposed footnote as a necessary change to the technical specifications. It is a clarifying statement that does not diminish any of the controls contained in the technical specifications and is consistent with the NRC stalTs interpretation for complying with the requirements of the new 10 CFR 20.

Ouestion 470.3 in Administrative Controls, Section 6.12, High Radiation Area, your specification needs to be revised to acknowledge that in 10 CFR 20.1601(a), there are three controls listed: (1) a control device, (2) an alarm signal, and (3) entryways that are locked. The proposed TS must be written to include these controls.

Response to NRC Request for AdditionalInformation Page 3 Rup_onse to Ouestion 470.3 The requirements for controlling access to a high radiation area, as presented in the new 10 CFR 20.1601(a), have not changed from those currently stated in 10 CFR 20.203(c)(2). Both the existing and new Part 20 requirements for high radiation areas include at least one of the following: 1) control device, 2) alarm signal device, or 3) locked entrance. The purpose of the existing Farley Units I and 2 Technical Specification 6.12, "lUgh Radiation Area," is to describe alternatives, as permitted by 10 CFR 20.203(c)(5), in lieu of control devices and alarm devices. This same allowance is restated in the new 10 CFR 20.1601(c). Since the regulatory requirements addressed by this technical specification have not changed, the wording need not be changed.

Quotion 470.4 in Administrative Controls, Section 6.12.2,liigh Radiation Area, the dose rate values need to be revised to specify a range. This is necessary to distinguish the controls needed for liigh Radiation Areas from those for Very liigh Radiation Areas. The TS must be revised to specify a range ofgreater than 1000 mrem in I hour but less than 500 rads (5 grays)in I hour.

Response to Qunlion 470.4 The definition of a high radiation area is expressly stated in 10 CFR 20.1003 to be an area in which an individual could receive a dose equivalent of greater than 100 mrem in I hour.

This dermition is imposed by reference in 10 CFR 20.1601 which is cited in Technical i

Specification 6.12.1. Ilowever, as a conservative measure, the FNP technical l specifications establish additional restrictions upon access to areas where an individual could receive a dose of 1000 mrem in a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period. Therefore, although the

, requirements for controlling access to a high radiation area apply to a range from 100 mrem in I hour to 500 rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (very high radiation area), SNC imposes additional requirements for those high radiation areas which could result in a dose equivalent of-greater than 1000 mrem in I hour.

Question 470.5 10 CFR 20.1602, Control of Access to Very High Radiation Areas, requires additional measures, over those in 10 CFR 20.1601, be taken to prevent unauthorized or inadvertent l access to areas in which radiation levels could be encountered at 500 rads (5 grays) or l more in I hour at I meter from a radiation source or any surface through which the radiation penetrates.

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3 Response to NRC Request for AdditionalInformation Page 4 i

j A new TS should be proposed that specifies the measures to be taken to control access to very high radiation areas (e.g., a separate plant procedure, approved by the Plant

! Operations Review Committee, that establishes control requirements for very high j radiation areas).

I i Response to Outstion 470 5 j The existence of a regulatory requirement does not necessarily dictate that a j l corresponding technical specification be written. SNC intends to comply without exception to the requirements specificed in 10 CFR 20.1602 for controlling access to very high radiation areas; therefore, a specific technical specification for very high radiation -

areas is not needed.

s Specific regulatory guidance regarding the requirement to establish additional controls for ,

areas in which an individual could be exposed to radiation levels of 500 rads or more in 1 l hour has not yet been provided, liowever, as stated above, SNC has established restrictions, which are described in Technical Specification 6.12.2, to prevent entry into an area where an individual could receive a dose of 1000 mrem within I hour. These

precautions are in addition to those required for a high radiation area and bound the range j defined for a very high radiation area.

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