ML20202B235
| ML20202B235 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 02/03/1998 |
| From: | Kuehn G GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20202B237 | List: |
| References | |
| 6L20-98-20036, NUDOCS 9802110150 | |
| Download: ML20202B235 (12) | |
Text
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gf j GPU Nuclear,Inc.
( Route 441 South NUCLEAN Post Offies Box 480 Mddletown. PA 17057 0480 Tel717 944 7621 6L20-98-20036 February 03, 1998 '
U. S. Nuclent Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Saxton Nuclear Experimental Corporation Facility Operating License Nn DPR-4 Docket No. 50-146 SNEC Facility Response to the 1 ourth Request for Additional Information Regarding TSCR 59 Enclosed is the response to the Requests for Additional Information (RAl) dated January, 27,1998. It also contains 1) additional information identifying changes to the GPU Nuclear Organization reDecting the recent company reorganization, and 2) editorial changes. To maintain documentation consistency, it was necessary to change the Updated Safety Analysis Report, Quality Assurance Plan, and the PSDAR. The affected pages of those documents are included as attachments to this RAI response, in accordance with 10 CFR 50.4(b)(1), also enclosed are revised pages to TSCR 59 which include revision to prior proposed wording based on the responses to the RAI and additional organizational and editorial changes identifnd. Revision of the proposed Technical Specification sections were reviewed and determined to have no effect on the evaluation and no significant hazards consideration provided with the submittal of TSCR 59 on November 25, 1996.
Pursuant to 10 CFR 50.91(a)(1) requirements, the previous analysis applying the standards of 10 CFR 50.92 in making no signiticant hazards consideration determination remains applicable without revision, since the proposed changes to the text involve administrative, non-te ' nical issues. Also, enclosed is a Certificate of Service for the additional proposed revisions certifying service to the chief executives of Liberty Township and Bedford County, Pennsylvania, in which the facility is located, as well as the designated representative of the Commonwealth of Pennsylvania Bureau of Radiation Protection. It also includes an oath affirming the accuracy of I the information provided. I 1
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For additional information regarding this submittal, contact William Heysek of the TMl Licensing Department at (717) 948 8191.
Sincerely,
. A. Kuehn Vice President SNEC t
- WGH Attachments
, 1. Oath / Affirmation Page for the Fourth RAI for Technical Specification Change Request 59, I page .
2 Certificate of Service for the Fourth RAI for Technical Specification Change Request 59,1 page
'3 Response to the Fourth RAI for Technical Specification Change Request 59,5 pages 4 Proposed Reyised Facility License- affected page 5 Proposed Revised Technical Specifications- complete document 6 Revised SNEC Facility Updated Safety Analysis Report- affected pages 7 Revised Saxton Nuclear Experimental Corporation Facility Decommissioning Quality Assurance Plan- complete document 8 Revised Post Shutdown Decommissioning Activities Report- afTected pages cc: NRC Project Manager, NRR- A. X. . Adams Jr.
NRC Project Scientist, NRR- T. F. Diagoun File 96516 i
L 6L20-% 20036 Attachment i S AXTON NUCLEAR EXPERIMENTAL CORPORATION SAXTON NUCLEAR FACILITY Operating License No. DPR-4 Docket No. 50-146 Response to the Fourth Request for Additional Information Regarding Technical Specification Change Request 59 COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF DAUPHIN )
This information is being provided in regard to the fourth NRC Request for Additional Information for Technical Specification Change Request 59. As such it is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-4 for Saxton Nuclear Experimental facility.
I, G. A. Kuehn Jr., being duly sworn, state that I am the Vice President Saxton Nuclear Experimental Corporation (SNEC) and Program Director SNEC Facility; that on behalf of SNEC 1 am authorized by SNEC to sign, and file with the Nuclear Regulatory Commission, this Application to revise Appendix A and to amend the facility license; that I signed this Application as Vice President of SNEC and Program Director SNEC Facility; and that statements made and the matters set forth therein are tme and correct to the best of my knowledge, information and oelief.
SAXTON NUCLEAR EXPERIMENTAL CORPORATION BY: /.
" ' ' 'Vice'Presipdiit,'SNEC &
Program Director, SNEC Facility Swor and Su abed to before me thi. ao 998.
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o Ai 6L20 98-20036' j Attaciunen: 2 ;
I UNITED STATES OF Ah! ERICA
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- NUCLEAR REGULATORY COMhilSSION IN THE MA' ITER OF LICENSE NO. DPR-4 SAXTON NUCLEAR EXPERIhfENTAL CORPORATION DOCKET NO. 50-146
- CERTIFICATE OF SERVICE This is to certify that a copy of response to the founh request for additional information regarding Technical Specification Change Request No. 59 to amend Appendix A to Operating License DPR-4 for the Saxton Nuclear Experimental Corporation facility as revised, have, on the date given below, been filed with executives of Liberty Township, Bedford County, P-nnsylvania; Bedforo County, Pennsylvania; and the Pennsylvania Department of Envirv..mc..iM Pmtection, by deposit in the United States mail addressed as follows:
- hir. Donald Weaver, Chairman hirs. Norma Ickes, Chairmaa-Liberty Township Supervisors Bedford County Commissioners R.D. #1 County Courthouse Saxton, PA 16678 203 South Juliaria Street Bedford, PA 15522 Director, Bureau of Radiation Protection PA Department of Environmental Protection Rachael Carson State Office Bldg.,13th Floor P.O. Box 8469 Harrisburg, PA 17105-8469 Attn: Kenneth Singh SAXTON NUCLEAR EXPERIMENTAL CORPORATION BY: '
// _/-
'Vice PEijdent, SREC &
Program Director, SNEC Facility DATE:
p 6L20 98 20036.
Attachment 3 Page 1 of 6 Response to the Founh RAI for Technical Speci0 cation Change Reauest 59
- 1. Section 2.C. of the license reads in part,
... Section 50.54 of Part 50,10 CFR Chapter 1, and to all applicable..."
In response to a request for additional information from NRC you replied to question 3 on May 30.1997, changing your proposed wording to,
" Sections 50.54, and 50.59 of 10 CFR Chapter 1, and to all applicable..."
It appears that you removed the words "of Part 50," From the license condition. Please clarify the wording of this license condition.
Response: The words "of Part 50," were inadvertently len out of the text during word 3 processing activities. The words "of Pan 50," have been reinserted in the license text. I
- 2. In your letter of August 21,1997, you submitted proposed revised technical specifications (TSs) as attachment 5. Figure 1 appears to be missing from the Proposed TSs. Please clarify.
Response: Figure I has been included in the attached TS accompanying this submittal.
- 3. In proposed TS 3.8, you discuss making reports to the Region 1 Administrator. Due to an internal reorganization of responsibility within NRC, the inspection program for the SNEF is the responsibility of the Non-Power Reactors and Decommissioning Project Directorate in Headquarters. Please update your proposed TSs to reflect this. You may also want to consider updating submitting reports by telegraph to submitting reports by-facsirrile to reDect advances in technology, Response: The referenced section was ievised to identify that more recent technology will be utilized to report any occurrence of a possible unsafe condition relating to the facility or to the public to the regulator and that written reports will be sent to the agropriate NRC office. The new proposed wording is as follows:
3.8.1 A report of any occurrence of a possible unsafe condition relating to the facility or to the public. For each occurrence, SNEC shall promptly, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery, notify by telephone or facsimile, the Non-Power Reactors and Decommissioning Project Directorate Director, or designee, and the NRC Operations Center, and shall submit a written follow-up report to the Document Control Desk and the Non-Power Reactors and Decommissioning Project l
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g 6L20 98-20036 Attachment 3 Page 2 of 6 Directorate Director within 30 days, which describes the circumstances and the l
corrective action taken. These reports shall include:
Section 3.8.2 was also changed to identify the proper location for submission of the annual report.
- 4. Section 1.3.2.15 of the SAR discusses the Decommissioning Support Facility (DSF) which appears to consist of the Decommissioning Support Building (DSB), Material Handling Bay (MHB)(Figure I refers to this as the Material Handling Building) and Personnel Access Facility (PAF). Your TSs only define and refer to the DSB. Should the defmition be for the DSF or should the reference to DSB include all three stmetures?
For example, TS 1.1.3.2 requires the DSB to have an intmsion alarm. Are there any entrances from the outside to the MHB or PAF that need to be alarmed? Section 2.1 of the TSs discusses CV/DSB activities and ventilation system. Should this reference be to the DSF7 Please discuss.
Response: The DELOMMISSIONING SUPPORT FACILITY (DSF) is made up of the DECOMMISSIONING SUPPORT BUILDING (DSB), Material Handling Bay (MHB which is an external component with access to the DSB) and the Personnel Access Facility (PAF) as you noted.
i There is an intended distinction between tt use of the terms DSB and DSF. To eliminate confusion arising from the use of such similar acronyms, a dermition of each term is provided in the TS. The definition of the DECOMMISSIONING SUPPORT {e FACILITY (DSF) has been incorporated w: thin the dermition of the DSB as identified below:
1.0.4 DECOMMISSIONING SUPPORT FACILITY (DSF) and DECOMM11SIONING SUPPORT BUILDING (DSB)-
The DECOMMISSIONING SUPPORT FACILITY (DSF)is the facility constructed southeast of the containment vessel (CV) ard attached to the CV.
The DSF consists of three structures, the DECOMMISSIONING SUPPORT BUILDING (DSB), thc Material Handling Bay and the Personnel Access Facility. The DSB is used to facilitate the decommissioning process and allow the preparation and packaging of radioactive material for shipping.
The dermitions were combined to eliminate section numberiag problems. Identification of the non-interchangeability of the acronyms DSB and DSF resulted in a review of the meaning of each use in the TSs and a change of acronym where appropriate. Changes were made in the following sect!ons and are identified by margin bars in the revised proposed TS: 1.0.4,1.0.14,1.1.3.2 end 1.1.3.3 Nat_c: the MHB has no external entrances.
4; 6L20 98 20036 Attaclunent 3 Page 3 of 6 Any unauthorized attempt to gain access from the outside into the CV, DSB and PAF components of the DSF will activate the intrusion alarm system.
- 5. In your proposed TS 1.1.3 for exclusion area controls, it is possible to leave the DSB and CV unlocked when the site is not manned because the proposed TS requirement is for the intrusion alarms to be activated. Please address a requirement to the TSs to secure the CV and DSB whenever the site is not manned orjustify why securing the CV and DSB need not be a TS requirement. If an alternate method is used to provide equivalent security, please include this in the proposed TSs orjustify why it is not needed.
Response: A new subsection has been included to add a requirement to secure the access points to the CV and DSF 1.1.3.3 Access points to the CONTAINMENT VESSEL (CV) and the DECOMMISSIONING SUPPORT FACILITY (DSF) will be SECURED l following an authorized entry, prior to activating the intrusion alarms.
- 6. In your reply dated May 30,1997, to our request for additional information concerning i
the quality assurance program, you proposed several changes to the program that you
( would incorporate if the p, posed changes were acceptable to NRC. To allow NRC to review a complete progra. , lease submit a revision to the program that incorporates your proposed changes.
Response: The Saxton Nuclear Experimental Corporation Decommissioning Quality Assurance Plan has been ruv d as identified in the May 30,1997 responses to the April 24,1997 Request for Additional Information. A copy of the QA Plan, as revised, as committed to in the RAI response and including the organizational changes described b-low, is included as Attachment 7 of this submittal.
Additional Changes A. Oreanizational Chanees A reorganization of GPU Nuclear has resulted in the elimination of the position of Vice President, Nuclear Safety and Technical Services. The responsibilities of the Vice President Nuclear Safety and Technical Services have been transferred to other vice presidents and directors of the company. As a result of that action, the responsibility for managing the decommissioning of the SNEC facility has been assigned to the Vice President Engineering.
The organization and organizational responsibilities describing the responsibility for the SNEC facility decommissioning in license basis documents must be revised to reflect the changes brought about by the reorganization of GPU Nuclear. The revised TS sections follow:
4 6L20-98-20036 Attachment 3 Page 4 of 6 3.1.2 The Vice President Engineering Division assures that all division and corporate activities are performed in accordance with corporate policies, l
applicable laws, regulations, licenses and Technical Specifications (TSs).
3.5.5.1 The Radiation Safety Committee shall report to the Vice President Engineering. The Committee will consist of at least four members.
l Membership will be on the recommendation of the Vice President Engineering. Three members shall constitute a quorum. l 3.5.5.4 Written minutes of all meetings shall be prepared and distributed to the Vice President Engineering within 30 days of the meeting date. l The changes identified are administrative in nature and are a reflection of the transfer of responsibilities within GPU Nuclear as a result of the company reorganization. There is no change in the independence of the oversight positions and the level of management attention within GPU Nuclear to the SNEC facility is not diminished.
B. Editorial changes
- 1. The listed TS sections were revised to correct the spelling of, case of, or a form of the word " operability"; 1.0.14,1.1.3.2,3.5.3.1.b, 3.6.2.1.1 and 3.6.2.1.6. Mergin bars mark the changes in the revised TS at these sections.
- 2. The 8/21 '97 proposed revised TS submittal did not incorporate words regarding
" posting ' :.' the EXCLUSION AREA as indicated in the response to question 3. The change was made in TS section 1.1.2. Based on the 8/21/97 response, the wording in TS 1.0.5 has been revised to address " posting" as shown below:
1.0.5 FJCLViON AREA-The term EXCLUSION AREA refers to the area shown on Figure 1 of the Techni::al Specifications and defmes the area controlled for the purpose of security and access restrictions. The EXCLUSION AREA will be posted.
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- 3. The term " containment building" in section 1.0.15 was changed to " containment vessel" to conform with the terminology used throughout the TS. A change bar annotates the change.
- 4. TS section 1.0.7 wording was revised between the 5/30/97 and 8/21/97 submittals as follcws without being noted as a change in the 8/21/97 submittal. The wording was changed from " .that radioactive release. " to " .those potential radioactive releases. " so that the words did not present an expectation for a release but to identify the potential that one might occur.
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p 6L20-98 20036 Att chment 3 Page 5 of 6
- 5. TS section 1.0.12 wording was revised between the 5/30/97 and 8/21/97 submittals as follows without being noted as a change in the 8/21/9 submittal. The wording was changed from ". .are phpical activities. " to " . include all physical activities. ." to expand the scope of applicability from only the specinc activity to include those that support it.
- 6. TS section 21.2 was revised by replacing the term " SECURED" with " shutdown" to identify the operational status of the equipment. The section was further revised to permit operation of the exhaust monitoring instrumentation with tlie ventilation system shutdown which the prior proposed wording did not support.
2.1.2 When the CV/DSB ventilation exhaust is in operation, the exhaust monitoring instrumentation will be operated simultaneously. The ventilation system will be shutdown if the exhaust monitoring instrumentation is inoperable.
- 7. Section 3.1 identined the document containing requirements for identifying and updating organizational rela'ionships as the PSDAR. Those requirements are now located in the Updated Safety Analysis Report (USAR) and the TS section text was revised to indicate that change.
- 8. Section 3.3.2 was revised by eliminating the phrase "the SNEC PSDAR for" since the PSDAR is not a document which is considered to contain requirement statements.
- 9. Section 3.5.1.5 !.tentified the document containing descriptions of the facility structures l systems and components as the PSDAR. Those descriptions are now located in the l Updated Safety Analysis Report (USAR) and the TS section text was revised to I indicate that change.
3.5.1.5 Proposed modifications to facility structures systems and components as described in the SNEC Facility US AR determined to be within the scope of l the SNEC Facility Decommissioning QA Plaa and QA program, shall be designed by an individual / organization knowledgeab'.e in the areas affected by the proposed modification. Each such modi 6 cation shall be technically reviewed by an individual / group other than the individual / group which designed the modification but may be from the same group as the individual who designed the modification.
- 10. TS section 3.6.2.3 was revised to change "solidined" to " solid" since the PCP as submitted does not allow for the solidification of SNEC facility wastes. If solidi 6 cation should become an appropriate process, the PCP will be revised in accordance with TS 3.6.2.3.1.
I 1. TS section 3.6.3.1 was revised to show the title in upper case to identify it with the definition in TS section 1.0.9
p 6L20 98 20036 Attaciunent 3 Page 6 of 6
- 12. - TS section 3.6.1.3.3 was revised to correct a reference as follows' 3.6.1.3.3 Facility inspections and access controls shall meet specific requirements of the sections 3.5.3 and 1.1.3, respectively, of these TS.
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- 13. - TS sections 3.9.9 and 3.9.12 to shie. the location of the word "and" to the second last item of the listing.
The eleven changes proposed above are administrative in nature.
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6L20 98-20036 Attaciunent 4 s
Attachment 4 Proposed Revised Facility License 1Page l
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6L20-98 20036 Attachment 4 !
- 2) SNEC, pursuant to the Act and 10 CFR Part 50, is licensed to possess, but not to manage, use, maintai or operate, the Saxton facility at the designated location in Liberty Township, nedford County, Pennsylvania, in accordance with the '
procedure and limitations set forth in the facility license; and
- 3) GPU Nuclear, pursuant to the Act and 10 CFR Part 30, " Rules of General Applicability to Domestic Licensing of Byproduct Materia", is licensed to possess, but not to separate, such byproduct material as may have tuen produced by operation of the Saxton facility.
C. This license shall be deemed to contain and be subject to the conditions specified in Part 20, Section 30.34 of Part 30, Sections 50.54,50.59 of Part 50,10 CFR Chapter I, and to l all applicable provisions of the Act and to the niles, regulations and orders of the Commission now or hereafter in efTect, and to the additional conditions specified below:
- 1) GPU Nuclear shall not reactivate the facility without prior approval of the Commission.
- 2) The Technical Specifications contained in Appendix A as revised through Amendment No.14 are hereby incorporated in the license. SNEC and GPU Nuclear shall possess the facility in accordance with the Technical Specifications.
- 3. This license is effective as of the date ofissuance and shall expire at midnight on February 11,2000. It will continue in effect until the Commission notifies the licensee ofits termination.