ML20046B603

Forwards Requested Addl Info Re Util 921014,930115 & 0326 License Amend Requests Addressing Implementation of New 10CFR20 Requirements,In Response to NRC 930610 Ltr.Revised TS Pages Also Encl

ML20046B603
Person / Time
Site:	Hatch
Issue date:	07/30/1993
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046B604	List: ML20046B603 ML20046B606
References
HL-3360, TAC-M84730, TAC-M84731, NUDOCS 9308050219
Download: ML20046B603 (5)

Text

Georgia Power Company

• - 40 invemess Ocr:ter Parkway Post Off ce Box 1295 Dirmingham, Alabama 35201 Telephone 205 877-7279 m

J. T. Beckham, Jr. Georgia Power Vce PresrJont - Nudoar Hatch Propct I'v ' ht'v:n ewi t:C sr.' '

July 30, 1993 Docket Nos. 50-321 HL-3360 50-366 005871 TAC Nos. M84730 M84731 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin 1. Hatch Nuclear Plant Request to Revise Technical Specifications:

Implementation of the New 10 CFR 20 Reauirements Gentlemen:

In response to NRC letter dated June 10, 1993, enclosed is the requested additional information regarding Georgia Power Company's (GPC's) license amendment request dated October 14, 1992, as supplemented by letters dated January 15 and March 26, 1993, addressing implementation of the new 10 CFR 20 requirements at Plant Hatch. The chronological summary of correspondence pertaining to this subject is as follows.

A. In response to NRC Generic Letter 89-01 and to support implementation of the new 10 CFR 20 requirements at Plant Hatch, GPC submitted a request by letter dated September 21, 1992, to relocate the procedural details contained in the Units 1 and 2 Radiological Effluent Technical Specifications to documents controlled by GPC.

B. By letter dated October 14, 1992, GPC submitted a request to revise the remaining sections of the Plant Hatch Units 1 and 2 Technical Specifications affected by the new 10 CFR 20 requirements.

C. By letter dated December 2, 1992, the NRC requested additional information concerning the October 14, 1992 submittal.

D. By letter dated January 15, 1993,'GPC provided the requested information  ;

the revised Technical Specifications pages suggested by the and December 2, 1992 letter.

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U.S. Nuclear Regulatory Commission Page Two July 30, 1993 E. During subsequent conversations with members of the NRC staff, GPC was informed that further changes to the Technical Specifications concerning .

gaseous effluents were necessary. By letter dated March 26, 1993, GPC submitted the necessary proposed changes.

F. By letter dated May 3, 1993, GPC submitted a request to revise the Technical Specifications to change the frequency of the Radioactive Effluent Release Report from semiannual to annual.

i G. By letter dated June 10, 1993, the NRC again requested additional information concerning the previous revision requests pertaining to the new 10 CFR 20 requirements and provided suggested changes to the Plant Hatch Technical Specifications. This letter provides GPC's response to <

the request for information and the associated revised Technical Specifications pages.

Enclosure 1 contains the NRC request for additional information as worded in the NRC letter dated June 10, 1993, and the GPC response.

Enclosure 2 contains revised and hand-marked proposed Technical Specifications changes which supersede the corresponding changes provided in GPC's January 15, 1993 submittal. The revised pages provided in the January 15, 1993 submittal were used for the hand-markups. Additionally, the conclusions of the significant hazards evaluations contained in the October 14, 1992 and March 26, 1993 submittals are unaffected by the proposed i Technical Specifications changes provided in Enclosure 2.

Enclosure 3 contains a complete listing of proposed Technical Specifications i pages included in the above submittals. Listed for each page is the date of the letter which submitted the latest version of that page. Pages submitted by this letter are designated " Enclosure 2" or " Enclosure 4."

Several proposed pages which were previously submitted by one of the above letters, have since been amended with unrelated changes. The current versions of these pages have been revised to show the changes proposed by the previous submittal s. Enclosure 4 contains the final typed versions of these pages. Also included in Enclosure 4 is a description of the proposed and approved changes to these pages. Since the same changes are being proposed, the significant hazards evaluations contained in the previous submittals are still valid.

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Georgia Power d U.S. Nuclear Regulatory Commission Page Three July 30, 1993 GPC requests this license amendment request, together with the other requests associated with the new 10 CFR 20 requirements, the license amendment request submitted in response to Generic Letter 89-01 by letter dated September 21, 1992, and the license amendment request associated with the Semiannual Radioactive Effluent Release Report submitted by letter dated May 3,1993, be approved as a single license amendment by September 15, 1993. It is also requested the conditions of the license amendment be made effective upon implementation by GPC of the new 10 CFR 20 requirements, but no later than January 1, 1994.

Should you have any questions regarding this information, please contact this office.

Sincerely, O

d.T.Beckham,Jr.

MCM/cr

Enclosures:

1. Response to NRC Request for Additional Information

2. Proposed Technical Specifications Changes

3. Summary Listing of Proposed Pages cc: Georoia Power Comnany Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U.S. Nuclear Reaulatory Commission. Washinaton. D.C.

Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch State of Georoia Mr. J. D. Tanner, Commissioner - Department of Natural Resources C

Enclosure 1 Edwin I. Hatch Nuclear Plant Request to Revise Technical Specifications:

Implementation of the New 10 CFR 20 Requirements Response to NRC Reouest for Additional Information NRC Staff Position Reaardina Reouest 470.3 Our previous Request 470.3 asked that you revise TS Bases 3/4.15.1.4 (Unit 1), and 3/4.11.1.4 (Unit 2), " Liquid Holdup Tanks," to use a multiplier of "10 times" for the values of Appendix B, Table 2, Column 2 to 10 CFR Part 20.1001 - 20.2401. Your response proposed to incorporate a multiplier of 10 times, as requested. However, since issuing Request 470.3, the Nuclear Regulatory Commission (NRC) staff has determined that our request was inappropriate. Accordingly, you should revise your proposed changes to TS Bases 3/4.15.1.4 (Unit 1) and 3/4.11.1.4 (Unit 2) to delete the addition of the words "10 times."

GPC Response to Reauest 470.3 As requested, the proposed Technical Specifications Bases changes submitted by Georgia Power Company (GPC) letter dated January 15, 1992, regarding the Liquid Holdup Tanks (Unit 1 Bases 3/4.15.1.4 and Unit 2 Bases 3/4.11.1.4),

have been revised as shown in Enclosure 2. The multiplier of "10 times" for the limits of 10 CFR Part 20, Appendix B (to paragraphs 20.1001 - 20.2401),

Table 2, Column 2, as previously proposed has been deleted.

NRC Staff Position Recardina Reauest 470.7 Our previous Request 470.7 asked that you revise your proposed administrative controls in TS 6.12.2, "High Radiation Area," to specify a dose rate range greater than 1000 mrem in I hour but less than 500 rads in I hour to distinguish the controls needed for a High Radiation Area from the requirements for a Very High Radiation Area (10 CFR 20.1602). You responded that TS 6.12.2 conservatively applies access control methods that are applicable to all accessible areas in which radiation levels exceed 1000 mrem per hour, including Very High Radiation Areas, and therefore, that specifying the requested dose rate range is unnecessary. We do not agree that the controls in existing TS 6.12.2 for the High Radiation Area are conservative or adequate with respect to 10 CFR 20.1602. The access control measures imposed by Hatch's TS at 1000 mrem in I hour are not adcquate to meet the

" additional measures" required by 10 CFR 20.1602, over those required in 10 CFR 20.1601. The High Radiation Area TS provides alternate methodology from the " locking" requirement specified in 10 CFR 20.1601 for areas in which I an individual might receive a deep-dose equivalent of 1000 mrem in I hour at 30 centimeters from the radiation source. The alternate locking requirement HL-3360 005871 El-1 ,

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t Enclosure 1 Response to NRC Request for Additional Information ,

specified by the TS is for 1000 mrem in I hour and above: it is not an

" additional measure" relative to 10 CFR 20.1602. We are unable to accept the l proposed TS change unless it is limited to less than 500 rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to distinguish it from the requirements of 10 CFR 20.1602. Accordingly, we ,

again request that you specify a range of greater than 1000 mrem in I hour but less than 500 rads in I hour.  !

GPC Response to NRC Reauest 470.7 As requested, the proposed Units 1 and 2 Technical Specifications changes t submitted by GPC letter dated January 15, 1993, regarding administrative '

controls for a High Radiation Area (6.12.2) have been revised and are  ;

provided in Enclosure 2. These changes add an upper limit for a High j Radiatien Area of 500 rads in I hour with a footnote stating the measurement '

is made at a distance of 1 meter from the radiation source or from any surface that the radiation penetrates. This upper limit represents the threshold for classifying a Very High Radiation area per 10 CFR 20.1602. A footnote has also been added to the existing lower limit of 1000 mrem /hr which states the measurement is made at a distance of 30 centimeters from the radiation source or from any surface that the radiation penetrates. These changes distinguish the administrative control requirements for a High .

Radiation Area from the procedural requirements to be established for a Very ,

High Radiation Area.  :

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