ML20249A566

Proposed Tech Specs Section 5.0,revising Administrative Controls

ML20249A566
Person / Time
Site:	Browns Ferry
Issue date:	06/10/1998
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20249A565	List: ML20249A564 ML20249A566
References
NUDOCS 9806170077
Download: ML20249A566 (19)

Text

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i e a e BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 5.0 Revision 4 LIST OF REVISED PAGES l UNIT 1 ITS SECTIONS Replaced page 5.0-21 *R1 with page 5.0-21 *R4 l

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High Radiation Area 5.7 1:

50 ADMINISTRATIVE CONTROLS l 5.7 High Radiation Area l - As provided'in 10 CFR 20, paragraph 20.1601(c), the following controls shall be applied to high radiation areas as an alternative'to the controls required by 10 CFR 20.1601(a) and (b):

5.7.1 Each high radiation area, as defined in 10 CFR 20, shall be l barricaded and conspicuously posted as a high radiation area and l' entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation l' protection procedures (e.g., a radiological controls technician) or personnel escorted by such individuals, shall be exempt from

the RWP requirements during the performance of their assigned i- duties in high radiation areas where radiation doses could be 3 i-received that are $ 1 rem in one hour as measured at 30 centimeters from the radiation source or from the surface which the radiation penetrates, provided they otherwise comply with approved radiation protection procedures for entry into such high radiation areas.

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 that continuously indicates the radiation dose rate in the area,

b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate ,

levels in the area have been established and personnel have l been made knowledgeable of them. '

c. An individual qualified in radiation protection procedures

, who is equipped with a radiation dose rate monitoring l- device. This individual shall be responsible for providing L positive radiation protection control over the activities I l within the area and shall perform periodic radiation i l.

surveillance at the frequency specified in the RWP. j l 5.7.2 In addition to the requirements of Specification 5.7.1, areas that l-are accessible to personnel and that have radiation levels > 1 rem

-in one hour as measured at 30 centimeters, but < 500 rads in one (continued)

.BFN-UNIT 1 5.0-21 Amendment *R4 L

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l BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS , SECTION 5.0 Revision 4 LIST OF REVISED PAGES UNIT 2 ITS SECTIONS Replaced page 5.0-21 *R1 with page 5.0-21 *R4 1

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High Radiation Area l 5.7 i 5 0 ADMINISTRATIVE CONTROLS I

'5.7 High Radiation Area I l As provided in 10 CFR 20, paragraph 20.1601(c), the following controls shall be = applied to high radiation areas as an alternative to the controls required by.10 CFR 20.1601(a) and (b):

5.7.1 Each high radiation area, as defined in 10 CFR 20, 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). Individuals qualified in radiation protection. procedures (e.g., a radiological controls technician) or personnel escorted by such individuals, shall be exempt from the RWP requirements during the performance of their assigned duties in high radiation areas where radiation doses could be received that are s 1 rem in one hour as measured at 30 centimeters from the radiation source or from the surface which the radiation penetrates, provided they otherwise comply with I approved radiation protection procedures for entry into such high radiation areas.

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 that continuously indicates the radiation dose rate in-the area.

b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset i integrated' dose is received. Entry into such areas with 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 shall be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified in the RWP.

5.7.2 In addition to the requirements of Specification 5.7.1, areas that are accessible to personnel and that have radiation levels > 1 rem in one hour as measured at 30 centimeters, but < 500 rads in one (continued)

BFN-UNIT 2 5.0-21 Amendment *R4

BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFIC ATIONS

, , SECTION 5.0 Revision 4 l

LIST OF REVISED PAGES UNIT 3 ITS SECTIONS Replaced page 5.0-21 *RI with page 5.0-21 *R4 i

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. ,c s y, High Radiation Area 5.7 l

5.0 ADMINISTRATIVE CONTROLS 5.7 'High Radiation Area i 0 l As provided in 10 CFR 20, paragraph 20.1601(c), the following controls shall be applied to high radiation areas as an alternative to the controls required by 10 CFR 20.1601(a) and (b): y 5.7.1 Each high radiation area, as defined in 10 CP 20, shall be l barricaded and conspicuously posted as a high radiation area and

entrance thereto shall be controlled by requiring issuance of a L Radiation Work Permit (RWP). Individuals qualified in radiation  !

protection procedures (e.g., a radiological controls technician) l or personnel escorted by such individuals, shall be exempt from the RWP requirements during the performance of their assigned  !

L duties in high radiation areas where radiation doses could be '

' received that are 1 1 rem in one hour as measured at 30 ,

centimeters from the radiation source or from the surface which '

the radiation penetrates, provided they otherwise comply with approved radiation protection procedures for entry into such high radiation areas.

u Any individual or group of individuals permitted to enter such L areas shall be provided with or accompanied by one or more of the following: 4

a. A radiation monitoring device that continuously indicates l the radiation dose rate in the area.

[ b. A radiation monitoring device that continuously integrates i the radiation dose rate in the area and alarms when a preset l integrated dose is received. Entry into such areas with 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 shall be responsible for providing  !

positiva radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified in the RWP.

. 5.7.2 In addition to the requirements of Specification 5.7.1, areas that l- are accessible to personnel and that have radiation levels > 1 rem in one hour as measured at 30 centimeters, but < 500 rads in one  ;

(continued)

BFN-UNIT 3 5.0-21 Amendment *R4

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BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS , , SECTION 5.0 Revision 4 LIST OF REVISED PAGES UNIT 1 CURRENT TECH SPEC M. ARK-UP SECTION j Replaced Section 5.7, page 48 of 50 (6.0-7) Rev 1 with page 48 of 50 (6.0-7) Rev 4 1

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6.8.2 Drills on actions to be taken under emergency conditions involving release of radioactivity are specified in the Radiological msergency Plan and shall be conducted annually. Annual drills shall also be conducted on the actions to be taken following failures of safety-related systems or components.

g RADIATION CONTROL PROCEDURES 6.8.3 Ra ation control P cedures shall be ma tained and made avail le to all stati personnel. These rocedures shall contain adiation dose 1 ts and shall be e intent with the requir es of 10 CFR . This radiation protection

-program shal be organized to e the requir to of 10 CFR 20 except f the

• control dev e" or " alarm ignal" required by 20.1601(a). -

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5.*/. i ! 0.0.1 Each high radiation area as defined in 10 CFR 20 shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiological Work Permit. Individuals qualified in radiation protection procedures (e.g., a radiological control technician) or personnel escorted by 4 such individuals, shall be exempt from RWP requirements during the performance of their assigned duties in high radiation areas rith red]ti- fr : rit:: 2721 te er leca-NW Q ,,N t M 2 0, 49rsq k 20. lb s+* u u ar rua u n .,a,s us.,r.)~thee,Lllowsns ,- , n, ,

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SECTION 5.0 i

Revision 4 LIST OF REVISED PAGES-UNIT 2 CURRENT TECH SPEC MARK-UP SECTION Replaced Section 5.7, page 47 of 49 (6.0-7) Rev 1 with page 47 of 49 (6.0-7) Rev 4 i

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E.8.2 Drills on actions to be taken under emergency conditions j l

involving release of radioactivity are specified in the Radiological Emergency Plan and shall be conducted annually.

Annual drills shall also be conducted on the actions to be taker s

following failures of safety-related systems or components.

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IATION CONTROL PRosauGkss 4.8.3 diation Control Procedures shall be maintained and made ava able to all station pe sonnel. These procedures shall l

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conta radiation dose limits shall be consist t with the requir of 10 CFR 20. This ation protection ram l l

.shall be organ ed to meet the requirements of 10 CFR 20 excep j for the " control device" or " alarm signal" required by 20.1601(a). -

H ia k n ~0.s L A eru. -te. m .s c h p S.7) 5.0.0.1 Each high radiation area as defined in 10 CFR 20 shall be j barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiological Work Permit. Individuals qualified in radiation g g., ,g prdtection procedures (e.g., a radiological control technician) or Personnel escorted by such individuals, shall be exempt from

.M6dAQ dec't.1%LQ [ RWP. requirements during the performance of their assigned duties {

1PW in high radiation are b i;i. d i :i;; i::: r-"  : er ' tr er 1rrr "" ; x; i; i rax at 30 centimeter [ provided they otherwise comply with approved radiation protection procedures

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, , SECTION S.0 Revision 4 LIST OF REVISED PAGES UNIT 3 CURRENT TECH SPEC MARK-UP SECTION Replaced Section 5.7, page 49 of 51 (6.0-7) Rev 1 with page 49 of 51 (6.0-7) Rev'4 4

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DitIILS s.e.2 Drills on actions to be taken under emergency conditions 1 involving release of radioactivity are specified in the Radiological Emergency Plan and shall be conducted annually.

Annual drills shall also be conducted on the actions to be i

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ItADIATIcar cearrROL PROCEDURRS 5.8.3 Radiat control Procedures shall be maintained and made availabl to all station pers 1. These i..w "- es shall j contain r tion done limits shall be consist t with the j l requirements 10 CFR 20. This r ation protecti program shall be organis to meet the requir es of 10 CPR except for the " control ce* or " alarm signa = required by 20.1501(a). #

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l [T WAS Radia6'.a 4 <a -ke W .h r& A g w S. *7, ) ' M ? } Each high radiation area as defined in 10 CFR 20 shall be l

barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by rsquiring issuance if (M m of a Radiological Work Permit. Individuals qualified in

' aM Auses radiation protection procedures (e.g., a radiological control M cudecA-84

.u3y technician) or personnel escorted by such individuals, shall be ,

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BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 5.0 Resision 4 LIST OF REVISED PAGES NUREG-1433 BWR/4 STS MARKUP Replaced page 5.0-23 (page 474 of 478) Rev I with page 5.0-23 (page 474 of 478) Rev 4

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conspicuously posted as a high radiation area and entranc thereto ' 2 shall be controlled by requiring issuance of a a-di: tier ork Permit (RWP). Individuals qualified in radiation protection s

g procedures (e.g.u !llo li.n insan.= T.;t.:Mir:') or personnel ,g

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. .b . A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. . Entry into such areas with this monitoring device may be made after the dose rate leveli in the area _ have been establishe_ d and personnel eee-ewere g of thepe w.. A w,, lap % jrp/g

c. An individual qualified in radiation rotection procedures 4 ,, with a radiation dose rate monitorin device. ...m .

responsible for providing positive ontrol over 9,,.g -

activities within the area and shall perform periodic radiation surveillance at the frequency specified 4 th -

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• &h s E P 5.7.2 (In addition to 3ne requi, _ ni.s of ipectrication T.7.1, areaslw44h radiation evels4 IS^^ m'h.shall J be provided with locked ' A r*N, cu tt r =', ; r rr a ggors to prevent unauthorized entry. e keys

,/.43 4* emes e det; e- h='th uMer  ;$y:in the::;;rd administrative aie...shall Doors ne control

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"- of the@in shall rema ocked except '" during griods of access by personnel under an approved

- RWPG tt" 35'speciff the dose rat: k.;;; in the immediate work -

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BROWNS FERRY NUCLEAR PLANT - IMPROVED TECHNICAL SPECIFICATIONS SECTION 5.0 LIST OF REVISED PAGES JUSTIFICATION FOR CHANGES TO NUREG-143.i Replaced pages I of 4 through 4 of 4 Revision I with pages I of 4 through 4 of 4 Revision 4 l

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i JUSTIFICATION FOR CHANGES TO NUREG-1433 SECTION 5.0 - ADMINISTRATIVE CONTROLS

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BRA:..__ID PLANT SPECIFIC INFORMATION L

B1 Incorporates BFN plant specific information regarding position titles, organization names, FSAR chapters, and ISTS section numbers. In 5.2.1.a the bracket [FSAR] is replaced with Nuclear Power Organization Topical

-Report (TVA-NP0089-A).

82 Brackets removed and optional wording deleted since it does not apply to BFN or the program has been relocated to plant procedures.

83 Brackets removed and values revised to reflect BFN plant specific requirements.

84 Brackets removed and wording revised as necessary to reflect appropriate

(,. plant specific requirements. Reviewers notes deleteo.

85 The change to the information contained within the brackets reflects BFN licensing bases requirements.

l B6 These changes modify the requirements for high radiation area control.

l Where dose rates are discussed, they are expressed in terms of the amount of radiation that an individual could receive in one hour, rather than instantaneous dose rates. These changes were made to make the specifications more consistent with the language used in 10 CFR 20 and to ensure that the specifications are not unnecessarily applied to situations where the radiation level is present for very short periods of time. In addition, distances for measurement were inserted where necessary since radiation levels vary with distance from the source.

Specification 5.7.2 applies to areas which exhibit radiation levels l greater than, but not equal to,1 rem in I hour. This is consistent l with CTS and Regulatory Guide 8.38, " Control of Access to High and Very High Radiation Areas in Nuclear Power Plants.'

BFN-UNITS 1, 2, & 3 1 Revision 4

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JUSTIFICATION FOR CHANGES TO NUREG-1433 SECTION 5.0 - ADMINISTRATIVE CONTROLS l i NON-BRACKETED PLANT SPECIFIC CHANGES P1 Incorporates plant specific information regarding Site Vice President.

responsibilities. Added Site Vice President to TS to specify his responsibilities relative to the Plant Manager.

l P2 ISTS renumbering, or minor rewording (TVA preference).

P3 This change incorporates plant specific terminology and changes or deletes NUREG requirements to make the proposed BFN ISTS consistent with the BFN licensing bases.

P4 Incorporates plant specific information regarding position titles, organization names, and functions.

P5 Editorial, grammatical, typographical corrections.

P6 This change modifies requirements for leak testing primary coolant sources outside containment to limit tests to the extent permitted by system design and radiological controls. Rewording to clarify that i preventive maintenance is fulfilled by periodic visual inspections and system leak tests. BFN does not have a comparable Technical Specification requirement. However, BFN's current programs for minimizing leakage are consistent with the proposed Technical l Specification requirement.

P7 Proposed changes incorporate current licensing bases requirements that were recently changed (BFN TS 335, Amendment No. 201, 220, and 174 for Units 1, 2, and 3 respectively issued December 2, 1993) to incorporate the corresponding revised 10 CFR 20 terminology or to retain operational flexibility consistent with Appendix I to 10 CFR 50, concurrent with the implementation of the revised 10 CFR 20.

P8 The requirement of Specification 5.5.4.k for the Radioactive Effluent Controls program to include the limitations on venting and purging of the Mark II containment was deleted based on the fact that BFN has a Mark I containment. i 1

BFN UNITS 1, 2, & 3 Revision 4

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JUSTIFICATION FOR CHANGES TO NUREG-1433  ;

SECTION 5.0 - ADMINISTRATIVE CONTROLS P9 The statement that SR 3.0.2 and SR 3.0.3 are applicable to the VFTP i Frequencies has been moved to right after the paragraph stating the l Frequencies. This is to ensure the allowances are not inadvertently I missed and for user friendliness; the allowances should be after the Frequencies, not three pages later.

l P10 The change deletes program requirements 5.5.9.b that are not applicable to the BFN plant specific design. There are not any gas storage tanks (other than holdup pipes) and no method to limit curie content in the holdup pipe except reactor isolation and the fuel integrity itself. The provisions in the NUREG for Waste Gas Systems are for PWRs and not applicable to BFN. Quantities of radioactivity contained in all outdoor liquid radwaste t e ks meeting the conditions of NUREG 5.5.9.c are determined in accordance with the specified surveillance program. The l sentence in the introductory paragraph is not needed to specify a method to determine liquid radwaste quantities.

P11 NUREG Specification 5.5.9 was modified to reflect the plant specific requirements of CTS 4.9.A.1.e. The requirements for testing new fuel oil prior to addition to the 7-day tanks has not been included. At BFN, new fuel oil is not added to the 7 day tanks until it is determined the fuel oil meets applicable ASTM standards. This provides assurance that l the addition will have no effect on the fuel quality in the 7-day tanks.

DG operability is based on surveillance requirements imposed on the 7-dsy tanks. Also, wording changes were made to clarify that the sampling and testing of a and b apply to 7-day fuel oil storage tanks only. l I-P12 The PTLR concept will not be used at BFN since an NRC approved methodology does not exist for BFN.

P13 The High Radiation Area Specification has been changed to be consistent with and reflect revisions to 10 CFR 20. These changes are consistent with the guidance of Regulatory Guide 8.38, " Control of Access to High and Very High Radiation Areas in Nuclear Power Plants." Proposed changes incorporate current licensing bases requirements that were l recently changed (BFN TS 335, Amendment No. 201, 220, and 174 for Units 1, 2, and 3 respectively issued December 2, 1993) to incorporate the corresponding revised 10 CFR 20 terminology BFN-UNITS 1, 2, & 3 3 Revision 4

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I JUSTIFICATION FOR CHANGES TO NUREG-1433 SECTION 5.0 - ADMINISTRATIVE CONTROLS P14 BFN TS 364 incorporates the new 10 CFR 50 Appendix J, Option B J requirements for containment leakage testing requirements. TS 364 was approved by Amendment 228, 243, and 203 to Unit 1, 2, and 3 Technical Specifications, respectively. Therefore, a Primary Containment Leakage Rate Testing Program (5.5.12) has been added to Programs and Manuals (5.5) section of the proposed BFN ISTS.

P15 Current Technical Specifications for testing of fuel oil in storage tanks is conducted on a 92 day interval. This current interval has been

, found to be acceptable for use at BFN and.is being retained in the l proposed ISTS.

P16 The proposed change will revise the requirement for the Operations Manager to hold a Senior Reactor Operator (SRO) license. The change will instead require the Operations Superintendent to hold a current SR0 license on a BFN unit. At BFN, shift personnel report to the Shift Managers, who are required to be licensed as SR0s for BFN in accordance with 10 CFR50.54(m)(2), and who in turn report directly to the Operations Superintendent, i

l P17 The last paragraph of NUREG Specification 5.6.2, Annual Radiological Environmental Operating Report, has been omitted. The omitted paragraph requires additional information be submitted beyond what is currently required by the BFN licensing basis. BFN provides material consistent with the material outlined in the ODCM and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C as required by CTS 6.9.1.5.

l P18 Supports do not lie within the scope of the inservice testing program required by 10 CFR 50.55a(f). Therefore, the proposed change, deleting

. . . including . applicable supports. .." is appropriate.

GENERIC CHANGES G1 This change implements TSTF-118, Administrative Controls Program Exceptions.

! G2 This change implements TSTF-152, Revise Reporting Requirements to be j Consistent With 10 CFR 20.

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