ML20237D704
| ML20237D704 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/13/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20237D698 | List: |
| References | |
| NUDOCS 9808270161 | |
| Download: ML20237D704 (4) | |
Text
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g UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 e%...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.115 TO FACILITY OPERATING LICENSE NO. NPF-62 ILLIN0IS POWER COMPANY CLINTON POWER STATION. UNIT 1 DOCKET NO. 50-461
1.0 INTRODUCTION
By letter dated October 27, 1995, Illinois Power Company, the licensee, requested a revision to the Clinton Power Station (CPS) Technical Specifications (TSs).
The proposed amendment would change TS 5.2.2.e, " Unit Staff," by revising the requirements for controls on the working hours of unit staff who perform safety-related functions.
The proposal would clarify the approval requirements for deviations from the overtime guidelines and eliminate the requirement for a monthly review of individual overtime.
2.0 BACKGROUND
The NRC issued Generic Letter (GL) 82-12, " Nuclear Power Plant Staff Working i
Hours," dated June 15, 1982, to clarify the Commission's policy on restricting f
the use of overtime for licensee personnel who perform safety-related j
functions. The GL requested that utilities revise the Administrative Controls 1
Section of their TSs to assure that plant administrative procedures follow the I
working hour guidelines set forth in the revised policy statement (an attachment to the GL), including a provision for documentation of authorized deviations. The NRC subsequently issued Generic Letter 83-02, "NUREG-0737 l
Technical Specifications," dated January 10, 1983, which transmitted a model l
TS for the implementation of the Commission's policy.
NUREG-1434, " Standard Technical Specifications, General Electric Plants, BWR/6," dated September 1992, includes requirements for the control of overtime consistent with the policy statement of GL 82-12.
TS 5.2.2.e of NUREG-1434 provides utilities with two options:
(1) prescribing specific requirements in the TS itself; or (2) including a paragraph that commits to the policy as described in GL 82-12.
When the licensee implemented NUREG-1434, option (1) was selected.
Option (1) is largely the same as the model technical specification transmitted by GL 83-02 and includes a paragraph explicitly addressing review of individual overtime. This paragraph states that, " Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the (plant superintendent) or his designee to ensure that excessive hours have not been assigned." The l
requirements set forth in this paragraph are not explicitly addressed by s
GL 82-12, 9808270161 900813 PDR ADOCK 05000461 l
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, 3.0 EVALVATION Currently, TS 5.5.2.e.4 reads:
4.
Except during extended shutdown periods, the use of overtime should l
be considered on an individual basis and not for the entire staff on a shift.
Any deviation from the above guidelines shall be authorized by the plant i
manager or his designee, in accordance with approved administrative l
procedures, or by higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.
Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the plant manager, or his designee, to ensure that excessive hours have not been assigned.
Routine deviation from the above guidelines is not authorized.
The licensee's proposal modifies TS 5.5.2.e.4 by deleting wording from the last two paragraphs of the TS and combining the two into one paragraph which states:
Any deviation from the above guidelines shall be authorized by the plant manager or his designee, in accordance with administrative procedures with documentation of the basis for granting the deviation.
Routine deviation from the above guidelines is not authorized.
This modification effectively results in two changes to the current TS 5.5.2.e.4 as described below.
The first change to TS 5.2.2.e.4 clarifies the requirements for the plant manager or his designee to approve deviations from the overtime guidelines in accordance with administrative procedures. The current TS requirements potentially permit any of three levels of responsibility to approve deviations from the overtime guideliaes:
(1) the plant manager; (2) persons designated by the plant manager in accordance with approved administrative procedures; and (3) levels of management higher than the plant manager.
The licensee states that the third classification of personnel does not need to be specified in the TS since, for administrative activities such as this, higher i
levels of management always have the authority to authorize activities under their area of responsibility.
Specifically, at the Clinton Power Station, the only level of management higher than the plant manager is the site Vice-President.
Furthermore, the inclusion of the third option in the TS is unclear with regard to the level of personnel the plant manager may designate for this function.
Finally, it is not the intent that only higher levels of management may be designated to perform this approval for the plant manager.
I
. The staff has reviewed this proposed change and determined that it does not alter any technical requirements since the same level of approval will be required and the same level of assurance of alertness will be maintained for the unit staff who perform safety-related functions. Therefore, the staff finds this proposed change acceptable.
The second change to'TS 5.2.2.e.4 revises the last paragraph to eliminate the requirement for a monthly review of individual overtime.
From experience gained in complying with the monthly review requirement at CPS, the licensee states that the review has not provided any additional benefit (beyond the requirements or controls prescribed in GL 82-12) for controlling individual overtime. The licensee further states that compiling a monthly report to facilitate a monthly review and performing the review has been a costly administrative burden that is not warranted.
The staff has reviewed this proposed change and determined that the proposed change would result in working hours controls that would not be sufficient to assure that adequate shift coverage is maintained without routine heavy use of overtime.
The objective of the Commission's policy promulgated by GL 82-12 is "to assure, to the extent practicable, that personnel are not assigned to shift
' duties that could significantly reduce their mental alertness or their decision making capability." To this end the Commission provided general guidelines for the control of overtime, citing overtime as a key job-related factor that influences fatigue. The Commission recognized that circumstances may require deviation from the policy guidelines and included provisions in the policy for approval of the deviations by the plant manager or his designee. The staff subsequently developed model TSs that embodied the Commission policy, as presented in GL 83-02.
The licensee's proposed TS amendment would eliminate subsequent monthly review by plant management to assess the actual deviations from the overtime guidelines and the potential for personnel fatigue to have an adverse effect
.on plant safety.
The model TSs include a requirement for a monthly review of individual overtime by the plant superintendent or his designee "to assure 1
that excessive hours have not been assigned." Since the policy does not l
impose specific limits on the size or frequency of deviations from the guidelines and allows delegation of authority to deviate from the guidelines, the monthly review provides a means.for ensuring that plant management is cognizant of cumulative overtime use, that overtime authorizations do not become routine, and that personnel are not impaired by the cumulative fatigue that can result from excessive deviations from the policy guidelines.
l Consequently, the staff finds this portion of the proposed amendment unacceptable.
Therefore, this portion is denied.
A second amendment justification offered by the licensee is that NUREG-1434 allows licensees the option to commit to GL 82-12, which does not explicitly address monthly reviews.
Commission policy statements, by their nature, do not address all administrative controls that may be necessary for a licensee to conduct their operations in accordance with the policy. The issuance of model TSs by GL 82-16 and 83-02 was intended to address just this matter for L________________._________________
\\
l the Comission's working hours policy.
In addition, it was not the staff's intent to provide an optional TS wording that would afford a different level of assurance that the policy objectives are met. Consequently, the staff has taken action to eliminate the apparent inconsistency between the two options in NUREG-1434 for the working hours TSs as documented in a letter dated April 9,1997, from Mr. C. Grimes (NRC) to Mr. J. Davis of the Nuclear Energy
~
Institute (enclosed).
In summary, the staff approves in part and denies in part the licensee's submittal. The staff accepts the licensee's request to eliminate specific wording granting levels of management higher than the plant manager authority to approve deviations from the overtime guidelines in accordance with administrative procedures.
However, the staff denies the licensee's request to remove the monthly review of individual overtime.
4.0 STATE CONSULTATION
In accordance with the Comission's regulations, the Illinois State official was notified of the proposed issuance of the amendment. The State official had no coments.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment changes recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria l
for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment l
need be prepared in connection with the issuance of this amendment.
6.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that:
l.
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendment'will not be inimical to the common-defense and security or to the health and safety of the public.
Principal Contributors:
R. Laufer D. Desaulniers A. Hansen Date:
August 13, 1998 L
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UNITED STATES
(
g NUCLEAR RESULATORY COMMISSION WASHINGTON, D.C. 30006 4 001 k..,*
April 9, 1997 5
l Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W.
Suite 300 4
Washington, DC 20006-2496
Dear Mr. Davis:
I As you know,_ the NRC cancelled its plans to issue a Generic Letter for a line-item improvement to the technical specification administrative controls section, to devote more resources to conversion reviews and additional improvements to the improved standard technical specifications (STS).
However, the proposed Generic Letter would have included several changes to l'
the administrative controls to accomodate changes to 10 CFR 20 and 10 CFR 50.36a.
In addition, since the issuance of Administrative Letter 95-06 on the relocation of administrative controls related to quality assurance, the staff has identified additional changes to the administrative controls to better accomodate the staffing requirements in 10 CFR Part 50 and Part 55, and to include a new staff position regarding controls for the working hours of personnel who perform safety-related functions. is an NRC proposed change, TSB-011, to the administrative controls section of the STS to reflect the changes described above.
In addition, the Technical Specifications Task Force (TSTF) has proposed similar changes to the STS in TSTF-86 and TSTF-121. We request that the TSTF modify their proposals in these travelers, or withdraw those changes and submit a new traveler, to reflect consistent changes to the administrative controls for all versions of the STS. Should you have any questions regarding this matter, please contact Bob Tjader at 301-415-1187.
Sincerely, Christopher I. Grimes, Chief Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
as stated cc:
C. Szabo, BWOG L. Bush, WOG l
B. Mann, CEOG A. Maron, BWROG B. Ford, BWROG D. Hoffman, EXCEL c@ y @j(lG.
.. ~.
April 9, 1997 Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W.
Suite 300 Washington, DC 20006-2496
Dear Mr. Davis:
As you know. the NRC cancelled its plans to issue a Generic Letter for a line-item improvement to the technical specification administrative controls section, to devote more resources to conversion reviews and additional improvements to the improved standard technical specifications (STS).
However, the proposed Generic Letter would have included several changes to the administrative controls to accomodate changes to 10 CFR 20 and 10 CFR 50.36a.
In addition, since the issuance of Administrative Letter 95-06 s
on the relocation of administrative controls related to quality assurance, the I
staff has identified additional changes to the administrative controls to i
better accomodate the staffing requirements in 10 CFR Part 50 and Part 55, and to include a new staff position regarding controls for the working hours of personnel who perform safety-related functions. is an NRC proposed change, TSB-011, to the administrative controls section of the STS to reflect the changes described above.
In addition, the Technical Specifications Task Force (TSTF) has proposed similar changes to the STS in TSTF-86 and TSTF-121. We request that the TSTF modify their proposals in these travelers, or withdraw those changes and submit a new traveler, to reflect consistent changes to the administrative controls for all versions of the STS. Should you have any questions regarding this matter, please contact Bob Tjader at 301-415-1187.
l Sincerely, Original Signed By Christopher I. Grimes, Chief Technical Specifications Bra:1ch Associate Director for Projects
Enclosure:
as stated cc:
C. Szabo, BWOG L. Bush, WOG B. Mann, CEOG A. Maron, BWROG B. Ford, BWROG D. Hoffman, EXCEL DISTRIBUTION: w enclosures FILE CENTER RTjader w/ enclosure RPZimmerman DJohnson w/ enclosure BBoger CGrimes CThomas SKlementowicz DDesaulniers CMiller JArildsen TSB R/F l
occunrut mAME: s nint\\Ac t:Trr.nev
- see previous concurrences omcE TSB:ADPR:NRR C:HHFB:0RCH:NRR NRR/ADPR/T W ;
NAME TRTjader*
COThomas*
CIGrimes ( N DATE 4/03/97 4/08/97 4/ F /YT' 1 0FFICIAL RECORD COPY
f*,
Justification of Changes:
Revision of TS 5.2 and TS 5.3 on staff work hours and: staffing
, requirements removes requirements redundant to regulations while retaining elements required in TS by regulations. Revisions of 10 CFR Part 20 and i
i 10 CFR 50.36a have superseded related information in the TS and other I
regulations, thereby prompting NRC to propose this generic change traveller to update the STS. The model STS provided in this package are specifically intended to eliminate possible confusion or improper implementation of the revised 10 CFR Part 20 requirements.
i Staffina Requirements and Workina Hours TS Chances (TS 5.2 & TS 5.31 Revision of TS 5.2.2.e on unit staff working hours reflects recent CRGR-approved changes to the STS. This change, to existing STS paragraph 5.2.2.e.
from s cific working hour limits to administrative procedures to control workin hours will provide reasonable assurance that impaired performance
)
caused by excessive working hours will not jeopardize safe )lant o>eration.
j Specific working hour limits are not otherwise required to,)e in t1e technical
{
1 specifications under 10 CFR 50.36(c)(5). Specific controls for working hours of reactor plaC staff can be described in a licensee procedure that requires a deliberate decision making process to minimize the potential for impaired
~
personnel performance, and that a licensee's established procedure control processes will provide sufficient control for changes to that procedure.
These programs have a level of detail necessary to satisfy the policy statement (SECY-93-067) auidar.ce and are retained in the Administrative Controls secticn of the TS. Therefore, the procedures and details can be relocated outsWe the TS.
Existing STS paragra 10 CFR 50.54(m)(2)(111).pn 5.2.2.b is deleted because it is redundant to Existing STS paragraphs 5.2.2.c is revised and a new STS paragraph 5.3.2 is added to ensure that there is no misunderstanding when complying with 10 CFR 55.4 requirements.
Chanoes to TS realtimo from 10 CFR 20 Cianoes (TS 5.5.4 & TS 5.7)
Revisions of'10 C R Part 20 and 10 C;R 50.36a have superseded related information in the TS and other regulations, thereby prompting NRC to propose this generic change traveler to update the STS.
While 10 CFR Part 20 allows
)
licensees to implement the rule without having to make any changes to their approved TS. the NRC has crafted the enclosed model STS sections to provide q
acceptable language that correlates with the wording in the revised 10 CFR Part 20 and 10 CFR 50.36a. Additionally, in accordance with 10 CFR 20.1601(c), the proposed model STS for high radiation areas contain 1
updated acceptable alternate controls to those given in 10 CFR 20.1601 and l
Regulatory Guide 8.38. Licensees may propose other alternate high radiation area controls based on their plant specific needs.
)
.In the case of gaseous and liquid effluent release rates. the model STS
- were crafted to allow licensees to maintain their same overall level of effluent control while retaining the o>erational flexibility that exists with l
current STS under the previous 10 CFR ) art 20. The model'STS continue to require that radiation doses to members of the public from gaseous and liquid effluent releases from nuclear power plants be within the values given in Appendix I to 10 CFR Part 50 and the limits in 10 CFR Part 20.
The model STS provided in this letter are specifically intended to
)
eliminate possible confusion or improper implementation of the revised 10 CFR
]
Part 20 requirements.
i.
C. J 5.2 Organization 5.2.2 Unit staff 1
1 The unit staff organization shall include the following:
i a.
A non-Licensed Operator shall be assigned to each reactor containing fuel and an additional non-Licensed Operator shall l
be assigned for each unit when a reactor is operating in MODES 1,2,3, or 4.
[Two unit sites with both units shutdown or defueled, a total of three non-Licensed operators are required for the two l
units.)
1 5.
^t in:t =: li=n=d R=:tr ^ r:tr 'RO) :5:115: 'n the Crtr:1 R:= d= f; 1 1: in the;rn:tr.
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th: unit i: 'n MODE 2. 2. 2 = f. :t in:t =: li=n= Srir l
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ifIdsT& iip 6fitio#~hhilliiiiitt*thE?HiiiisiMiiiiintiiFstipU1ated
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rein'and in 10 CFR$0.54(m)FShift~creho'mposition ma es's'than the minimum ~ requirement of 10 CFR 50.54(m)(2)(1)y be and 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
4Ri.
A [ Health Physics Technician) shall be on site when fuel is in the reactor.
The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected 6bsence, provided immediate action is taken to fill the required position.
ed.
AdriiinlithfiVF phi 6iiddfii!~ shill?WdiVsibpidTidiniplementsd
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to'11mit1the: working?gi.W11 censed SeniorfReactorihours related ; function ~st(e rators SR0s)M11 censed Reactor Operators TR0s)? health.
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-._ laryloperatorsdand;keLaai_rMneggersonne C
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~~E6ntF6TiHHi113iiE15dETididill'nis~6h765PkTWg~1i5DNYthit ure?adequatei1hift icoverageAallibeEmainta_ine[ytthout
_,ine he_avyyse;oflovertimej diiyTdE9fhTibN3Yhiiii~thh3i6Fk'lsgWTgUiBElisF5TshillIbi luthorized Sin 2 advance <by2theHPlant? Superintendent] Yorithe
- Plant Supe'rintendent's'] designeenin accordance with approved Kiministrative procedurts?and With^doctanentationLof the basis
[or{grantinghe devi,ation[ ~~~~~~~~ ~^~ ~~~~~~~~~^~~~~~~~"
t Continued l
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, l, 5.2 Organization 5.2.2 Unit Staff (Continued)
"istF511Mhs11?ibe 215E1Ddid;9Ethi"pF5Es~d56iis=s~ isch 7thit indi vidual ; overtime hhal l ; be erev iewed monthly.by the 1[P1 ant superintendent] #:thelPlanti5 superintendent;s) Wesig' nee e to msure:that excessive 1hoursJhe've not been assigned.9Aoutine levistionGf
![uthorized? gomithporkirpjhourgguideljnesjls,halQnot(be
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The [0perations Manager or Assistant Operations Manager] shall hold an SRD license, gf.
The. Shift Technical Advisor (STA) shall provide advisory
~
technical support to the Shift Sunrvisor (SS) in the areas of thermal hydraulics, reactor eng< neering, and plant analysis with regard to the safe operation of the unit.
In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
e
w uu TSB-NRC Propssed Change ts the STS 011 04/02/97 Criginettr:
R. Tjader Mgr Approved:
Date:
11/07/96 Purpose of Update STS to Reflect 10 CFR 20 and 10 CFR 50.36a Changes Change:
NUREGs Changed 1430: X 1431: X 1432: X 1433: X 1434: X TechnicalSpeelnestions e d:
n
- 1) Chenes Admin Controle Sectione 5.2 and 5.3 en unit stef6ng requirernente
- 2) Change Admin Controle Section 5.5.4, Radiosotive Effluent Controle Program 1
- 3) Replace Admin controle Section 5.7, High Redistion Area Deser5 tion of M.g:
Revies STS Admin Controle Sectione 5.2 en Unit Stoff and 5.3 en Urdt Staff Qualifications to remove requireme maintain soneistency between the STS and regulation. regulations. Change / replace STS Admi
.hmtifiestien et Change:
Revision of TS 5.2.2.e on unit etsff working hours reflects recent CRGR. approved ohenges to the STS.
r:guiremente removes requirements redundant to regulations while retaining elemente required in TS by regula P:rt 20 and 10 CFR 50.36e have superseded rotated information in the TS and other regulations, thereby p generic change traveller to update the STS. The model STS provided in this package are ope:ifically intended to e tr improper imniementation of the revised 10 CFR Part 20 requirements. (See etteched justification )
i Entered Databeoe Date:
11/7/96 Filename:
3Seemsc,.e.mdb
(
NRC REVIEW OF PROPOSED STS CHANGE 1
TSB Reviewer:
R. Tieder l
Tech Reviewer:
S.10ementowicz (if review required) l Recommendation Dete: 11/7/96 Recommendation:
Date: 11/3/96 i X ] APPROVE I IM000FY I IREJECT IX1 APPROVE I IMODIFY ! I REJECT commanu:
Commente:
See above Justification se ettechmente to traveller. 3/3/97 pkg was incorporated as en enclosure to e letter to NEl and provided to f
C. Grimes for signature. This change wee to have been provided under e Generic Letter, which was concelled. 4/2/97 TS 5.2 and 5.3 added to package: peckage forwerded to C. Grimes for disposition.
PROPOSED STS CHANGE DISPOSITION TSB Action f
[M\\ Date: NC, Q'A' TSTF Action Of appliesblel Date:
I/ APPROVED IMODhlED I IREACTED '
I IAPPROVED [ ] REVISED I I APPEA12D Comments:
l Comments:
1 STS FILE AND RECORD DATA CHANGES ACTION SY DATE ACTION SY DATE I
wp Finse Updated Chenese Certified Chenees Preeted Asenes Databene Updated Resumed for Corrections Comment Roselution Database Updated Centrol Books C8ese out Leta +
Updated Sent to TSTF BSS Files Peekoos Updated Filed SVORMS\\TS8-h0.011
^
Unit Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications
[ Reviewer's Note. Minimum qualifications for members of the unit staff shall be specified by use of an overall qualification statement referencing an ANSI Standard acceptable to the NRC staff or by specifying individual position qualifications. Generally. the first method is preferable: however, the second method is adaptable to those unit staffs requiring)special qualification statements because of unique organizational structures.
5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of [ Regulatory Guide 1.8. Revision 2,1987, or more recent revisions, or ANSI Standard acceptable to the NRC staff). The staff not covered by [ Regulator Guide 1.8) shall meet or exceed the minimum qualifications of [Re ulations. Regulatory. Guides, or ANSI Standards acceptable to NRC staf J.
p~~3:2Tof^the"purpoiE"6Y30'CFR:55?47Ylicehsid sini6&eictF6pirat6FI(SRO)
~~ pnd sa licensed ireactor pddition to meeting 'the 3 operator 5(RO) eareithose?1ncividuals 2who; a in requirementsTofiT Described in:10.CFR 50.54(m) ~'^"^ ^ ~~~^~S;5;3.1dperf~orn:the ; functions
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[ Reviewer's NoteRiThe: minimum 1tsffihg" requirements:sti;idlitedlidi 10 CFR 50.54(m),ifor: unit members: actively performing the; functions offsh bperator or: senior!operatorJcan be exceeded b :sti staffigngfepirementsfjn;paragraphi5.3.2.)f '~y^"~pulating-.the enhanced
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5.5.4 autoactive Effluent controls Mram This program conforms to 10 CFR 50.36a for the control of radioactive i
efnuents and for maintaining the doses to members of the public from radioactive afnuents as low as reasonably achievable. The pro be contained in the CDCM, shall be laplemented by procedures, gram shall and shall include remedial actions to be taken whenever the program limits are exceeded. 1be program shall include the following elements:
Limitattens en the functional capability of radioactive liquid and a.
gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the 4DCM; b.
Lieltations en the concentrations of radioactive material released in liquid efnuents to unrestr.icted areas, conformina to"^ 5" 1 Appendix B, Table 2, Column (h touct.ao. int-u 2vos-(f. t- -a. *.
Monitoring, sampling, and analysis of radioactive liquid and gaseous c.
affluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM; d.
Limitations on the annual and quarterly doses or dose commitment' to a member of the public from radioactive materials in liquid efnuents released from each unit to unrestricted areas, confoming to 10 CFR 50, Appendix I; Determination of cassulative and projected dose contributions from e.
radioactive efnuents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days; f.
Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce' releases of radioactivity when the projected doses in a period of 31 days would exceed 25 of the guidelines for the annual dose or dose coenitment, confoming to 10 CFR 50, Appendix I:
M 44. c.
g.
Limitations an the dose esteInsulung from loactive material released la passous ofnuentshto areasAbeyond the sitt boun(ary
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Limitattens en the annual and guarterly air doses resulting from moble gases released in gaseous efnuents from each unit to areas bayend the site boundary, conforming to 10 CFR 50, Appendix I;
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1.
Limitattens en the annual and guarterly doses to a member of the peblic from lodiee-131, 4edine-133, tritium, and all radionuclides la particulate form with half lives > 8 days la gaseous efnuents rele:tsed from each unit to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and
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7 4 44
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Limitationsfon the annual dose or dose commitment to any member o j.
4 the public,jdue to releases of radioactivity and to radiation from uranium fdel cycle sources, conforming to 40 CFR 190.
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- w-4 5.5.4 Radioactive Efnuent Controls program
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l This program conforming to 10 CFR 50.36a provides for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably
)
achievable. The pmgram shall be contained in the 00CM, shall be implemented by operating precedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:
- 1. imitations on the functional capability of radioactive 11guld a.
and gaseous monitoring instrumentation including surveillance tests and setpoint delamination in accordance with the
' methodology in the 00CM; b.
Limitations on the concentrations of radioactive material released in liquid affluents from the site to UNRESTRICTED AREAS, confoming to 10 times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001-20.2402; Monitoring, sampling, and analysis of radioactive liquid and c.
gaseous effluents pursuant to 10 CFR 20.1302 and with the methodology and parameters in the ODCM; d.
Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid affluents released from each unit to unrestricted areas, confoming to 10 CFR 50, Appendix I; Determination of cumulative and projected dose contributions e.
from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days; f.
Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period l
of 31 days would exceed 2 arcent of the guidelines for the i
annual dose or dose came' taant, confoming to 10 CFR 50, l
Appendix I; g.
Limitations on the dose rate resulting from radioactive eaterial nisased in gaseous efnuents from the site to areas at er beyond the SITE SOUNDARY shall be limited to the
, fe11 ewing:
1.
For noble gaser: less than or equal to a dose rate of 500 arems/yr to the total body and less then or equal to 4 dose rate of 3000 arems/yr to the skin, and 2.
For iodine-131, iodine-133, tritium, and for all radionuclides in particulate form with half-lives greater than 8 days: less than or equal to a dose rate
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.i ' * ' *.
of 1500 mress/yr to any organ; h.
Lia'tations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from each unit I
to areas at or beyond the site boundary, conforming to 10 CFR 50, Appendix I; 1.
Limitations en the annual and the public from todine-131, luarterly doses to a member of odine-133, tritium, and all 2
radionuclides le particulate form with half-lives greater than 8 days la gaseous affluents released from each unit to areas 4eyond the site boundary, conforming to 10 CFR 50, Appendix I; l
and J.
Limitations on the annual dose or dose commitment to any member of the public, beyond the SITE BOUNDARY, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.
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1 I
4 I
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t
.i High Radiation Area 5.1 k'
E.0 ADMINISTRATIVE CONTROLS l
5.1 Nigh Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part to, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.160)(a) and (b) of 10 CFR Part 20:
5.7.1 Ifish Radiation Areas with Deze Rates Not heeedina 1.0 remfhour at 30 J.artimeters from the Radiation Source or from Any surface benetrated by the jtad iation-a.
'Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to pemit entry or exit of personnel or equipment.
b.
Access to, and activities in, each such area shall be controlled by means of Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rates in the immediate work area (s) and other. appropriate radiation protection equipment and measures.
c.
Individuals qualified in radiation protection procedures (e.g., health physics technicians) and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
d.
Each individual or group entering such an area shall possess:
1.
A radiation monitoring device that continuously displays radiation dose rates in the area; or continued j
N00El. SPECIFICATION 5.0-16 ADMINISTRATIVE CONTROLS
.~
i
'i ;
High Radiation Area 5.7 High Radiation Area 5.1 5.7.1 2.
A radiation monitoring device that continuously (continued) integrates the radiat'on dose rates in the area and alares when the device's dose alare setpoint is reached, with an appropriate alarm setpoint, or 3.
A radiation monitoring device that continuously transaits dose rate and cumulative dose to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area, or 4.
A self-read?ng dosimeter (e.g., pocket fonization l
chamber or electronic dostmeter) and, (1)
Se under the surveillance, as specified in the W P or equivalent, while in the area of an procedures, qualified in radiation pro,tection individual equipped with a radiation monitoring device that continuously displays radiation dose rates in the area who is responsible for controlling person;nel exposure within the area, or (ii) Se under the surveillance as specified in the WP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area.
Except for individuals qualified in radiation protection e.
procedures, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.
5.7.2 Mich Radiation Areas irith tese Rates Ersater than 1.0 rea/ hour at 10 Centimeters from tge Raeintion Source or from Anv Surface Penetrated by t se Radiation. but Less than 500 rads / sour at 1 beter from the ltadiation Source or from Any surface Penetrated by the Radiation:
Each entryway to such an area shall be conspicuously posted a.
as a high radiation area and shall be provided with a locked Continued MODEL SPECIFICATION 5.0-17 ADMINISTRATIVE CONTROLS
4 -
S High Radiation Area 5.7 5.7 High Radiation Area 5.7.2 door or gate that prevents unauthorized entry, and, in (car.tinued) addition:
1.
All such door and gate keys shall be maintained under the administrative control of the shift supervisor, radiation protection manager, or his or her designee.
2.
Doors and gates shall remain locked except during ~
periods of personnel or equipment entry er exit.
b.
Access to, and activities in, each such area shall be controlled by means of an RWP or equivalent that includes specification of radiation dose rates in the immediate work area (s and mea)sures.and other appropriate radiation protection equipment Individuals qualified in radiation protection procedures may c.
be exempted from the requirement for an RWP or equivalent while Mrforming radiation surveys in such areas provided that tasy are following plant radiation protection procedures for entry to, exit from, and work in such areas.
d.
Each individual or group entering such an area shall possess:
1.
A radiation monitoring device that continuously integrates th2 radiation rates in the area and alarms when the device's dose alare setpoint is reached, with an appropriate alarm setpoint, or 2.
A radiation monitoring device that continuously l
transaits dose rate and cumulative dose information to l
a remote receiver monitored by radiation protection personnel responsible for contro111nfi morsonnel radiation exposure within the area w'ta the means to communicate with and control every individual in the l
area, or continued 1
MODEL SPECIFICATION 5.0-18 ADMINISTRATIVE CONTROLS
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1
,g High Radiation Area t-5.7 5.7 High Radiation Area 5.7.2 3.
A self-reading dosimeter (e.g., pocket ionization (continued) chamber or electronic dosimeter) and, (1)
Se under the surveillance, as specified in the AWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii) Se under the surveillance as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, f
responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and contrcl every individual in the area, or 4.
In those cases where options (2)incons(3), above, are and lepractical or determined to be istent with the
'As Low As is Reasonably Achievable" principle, a radiation monitoring device that continuously displays radiation dose rates in the area.
e.
Except for individual qualified in radiation protection procedures, antry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.
f.
Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for the purpose of locking and where no enclosure can reasonable be constructed around the individual area need not be controlled by a locked door or gath but shall be barricaded and conspicuous, clearly visib c diashing light shall be activated at the area as a warning device.
MODEL SPECIFICATION 5.0-1g ADMINISTRATIVE CONTROLS i
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