L-77-388, Application for Proposed Amendment to License No. DPR-067. Proposed Change Concerns High Radiation Area Monitoring

Application for Proposed Amendment to License No. DPR-067. Proposed Change Concerns High Radiation Area Monitoring

ML18088B287
Person / Time
Site:	Saint Lucie
Issue date:	12/21/1977
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-77-388
Download: ML18088B287 (9)

Text

U.S. NUCL.EAR REGULATORY COMMi~lON DISTRIBUTION AFT'SSUANCE 0 PERATING LICENSE NRC ARM $195 (Z-7B)

'RC DISTRIBUTION FDR PART 50 DOCKET MATERIAL DOCKET NUMBER t5-FILE NUMBER TO Mr. Victor Stello FROM:

Florida Power

& Light Company Miami, Florida@

Robert ED Uhrig DATE OF DOCUMENT 12/21/77 OATS RE CEI V E 0 12/27/77

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~ORIGINAL CJCOPY DESCRIPTION CINOTORIZEO

~ UNC LASS IF I E0 PROP INPUT FORM ENCL OSURE NUMBER OF COPIFS RECEIVED License No.

DPR-67 Appl for Amend: tech specs proposed change concerning high radiation area monitoring. ~ ~ inotorized 12/21/77

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PLANT NAME:

St. Lucie Unit No.

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FLORIDA PGWER & LIGHT COMPANY December 21, 1977 L-77-388 Director of Nuclear Reactor Regulation Attention:

Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D.

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Dear Mr. Stello.:

Re:

St. Lucie Unit 1 Docket No. 50-335 Proposed Amendment to Facilit 0 eratin License DPR-67 In accordance with 10 CFR 50.30, Florida Power 6 Light Company submits herewith three (3) signed originals and forty (40) copies of a request, to amend Appendix A of Facility Operating License DPR-67.

The proposed amendment is described below and shown on the accompanying Technical Specification pages bearing the date of this letter in the lower'xight hand coxner.

Specification 6.13 (High Radiation Area) is replaced with the corresponding section from the Standard Technical Specifications.

The proposed amendment has been reviewed by the St. Lucie Facility Review Group and the Florida Power a Light Company Nuclear Review Board.

They have concluded that it: does not. involve an unreviewed

'safety question.

A written safety evaluation is attached.

Very truly yours, Robert Z. Uhrig Vice President REU/MAS/cpc Attachment cc:

Mr. James P. O'Reilly, Region II Robert Lowenstein, Esquire Edward Reeves'~g800 06'9 PEOPLE... SERVING PEOPLE

ADMINISTRATIVECONT I

Unless otherwise authorized by the Commission, the licensee shall not assign protection factors in excess of those specified.

in Table 6.12-1 in selecting and using respiratory protective equipment.

REVOCATION 6.'12.3 The specifications of Section'6.12 shall be revoked in their entir ty upon adoption of'.th proposed chanq to 10 CFP. 20 Section 20.103, which would make such provisions un;ecessary 6.13 HIGH RADIATION AREA 633.1 In lieu of the "control device" or "alarm signal" required by paragraph 20.203(c) {2) of 10 CFR 20, each high radiation area in which the intensity of radiation is 1000 mrem/hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of' Radiation Vork Permit~.

Any individual or group of individuals p rmitted to e..

-.": such areas shall be provided, with or accoiI.panied by one or more o;:i following=

~ a.

A radiation'monitoring device which continuously indicates the radiation dose rate'n-the area.

b.

.A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset inte-grated dose is'eceived.

Entry into such areas with this

~ rronitoring device may be made. after the dose rata level in 'the area has be n es ablished and personnel have been made knowl-edqeable of-them.

c.

An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device.

.This individual shall be responsible for oroviding posiiive control over the activities within the area and shall perfom periodic radiation surveillance a

the frequency specified by the facility Health Physicist in the Padiation bfork Permit 6.j-3.2 The reouirements of 6.g3.l, above, shall also aoply to each hign radiation'rea in which the intensity or radiation is greater than 1000 mrem/hr En addition, locked doors shall be provided to prevent unauthorized'ntry into such areas and the keys shall be maintained under the admin~strative contro1 of the Shift Supervisor on duty and/or the Plant H alth Physicist.

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q ment during the performance of their assigned radiation protection duties, provided they compIy with approved radiation protection procedur s for entry into high radiation areas.

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'I ST. LUCIE -'NIT 1 6-19 3.2/23./77

SAFETY EVALUATION Re:

St. Lucie Unit 1 Docket No. 50-335 Hi A Radiation Area Mon~itorin Introduction This evaluation supports a proposed change to Technical Specification 6.13 on administrative control of high radiation areas.

The existing Specification is replaced by the corresponding section from the Standard Technical Specifications.

Evaluation The current Specification requires that any individual or group of individuals permitted to enter a high radiation area be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.

For the case of containment entry with the reactor at power, such a -requirement represents good.health physics practice.

It does not, however, guarantee'he intended exposure control in all situations.

For example, when an individual or group of individuals enters a high radiation area which has been surveyed and posted in accordance with the stringent requirements of the Radiation Work Permit (RWP) procedure, a continuously indicating dose rate device located in the same area will not necessarily provide additional exposure control.

The device must be read frequently to determine if radiological conditions have changed.

The current Specification does not guarantee that an individual intent on doing his job will also remember to read the radiation monitoring device.

Thus, such a device may satisfy the legal requirements of the current Specification without satisfying the intent of the Specification.

Exposure control is achieved in part by administrative pro-cedures that require a radiation survey prior to entry into high radiation areas.

Once dose rates are known, Health Physics Department personnel set "stay times" for individuals for the purpose of limiting the individual's accumulated dose.

By using one of the proposed alternatives to the current Specification, i.e., the dose integrating/alarming

device, we believe that better exposure control is possible.

Under this alternative, an individual could have an electronic device attached to his protective clothing, or health physics personnel could set

'up a dose integrating device in the area.

Such devices would have an audible alarm that would annunciate when a preset accumulated dose (determined by health physics personnel) was exceeded.

All individuals would be instructed

to leave the work area should an alarm occur.

By using a device with an audible alarm setpoint, personnel would be better protected against the effects of changes in the dose rate.

With current practice, a worker cannot become aware of a change in dose rate without periodically monitoring a dose rate device.

Thus, the proposed specification is con-servative with respect to the current Specification because it does not depend on individuals monitoring their pocket dosi-meters frequently (as they are instructed to do) or monitoring a separate dose rate device.

We are also proposing an additional alternative to the current specification, i.e., the provision for direct health physics coverage of a job by a health physics qualified individual.

For example, consider the case of steam generator water box entries for the purpose of tube inspection or plugging.

Health physics personnel determine the dose rates in the water box, set stay times, and determine what protective clothing must be worn during the entry.

Because of the high. dose rates, airborne activity, and contamination, stay times of only minutes are allowed, and a double set of coveralls, a plastic

suit, and supplied air are required.

During the entry, health physics personnel are at the entrance to the water box to ensure tha" the individual is properly dressed.

Once the entry is

made, the health physics personnel time the individual to ensure that he minimizes his exposure and does not exceed the plant's administrative exposure limits nor those of the Commission.

Because of the air line and other clothing and equipment

that, the individual making the entry must carry into the confined

space, and the necessity for short stay times, he cannot. carry a meter with him.

We believe that in this case and similar

cases, our practice is appropriate and that it is in keeping with the exposure control intent of the present Specification.

III.

Conclusion Based on the considerations described

above, (l) the proposed, change does not increase the probability or consequences o'

accidents or malfunctions of equipment important to safety and does not reduce the margin of safety as defined in the basis for'ny technical specification, therefore, the change does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety o

the public.

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STATE OF FLORIDA

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COUNTY OF DADE

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n Robert E. Uhrig, being first duly sworn, deposes and says:

That he is a Uice President of Florida Power 6 Light, Company, the Licensee herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

Robert E. Uhrig Subscribed and sworn to before me this QJ~~day of 19~7 NOTARY PUBLIC, in and for the County of Dade, State of Florida NOTARY PUBLIC STATE OF FLORIDA eL LARGE MY COMMISSION EXPIRES AUGUST 24, LSSI L4'ommission expires:

BGNDED

'THRU LIAYNARD BGNDIMG AGENGY

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