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Category:Memoranda
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Report on Status of Open TIAs Assigned to NRR
2023-02-15
[Table view] |
See also: IR 05000315/2014005
Text
June 23, 2017
MEMORANDUM TO: Mohammed A. Shuaibi, Deputy Director
Division of Reactor Safety
Region III
FROM: Kathryn M. Brock, Deputy Director /RA/
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
SUBJECT: DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 - NRR
POSITION ON NCV 05000315/2014005-03; 05000316/2014005-03;
RADIOLOGICAL IMPACT OF THE REMOVAL OF THE AUXILIARY
SHIELD BLOCKS ON THE CONTAINMENT ACCIDENT SHIELD POST
LBLOCA
On March 17, 2017, a teleconference was held between the U.S. Nuclear Regulatory
Commission (NRC) Office of Nuclear Reactor Regulation (NRR) and NRC Region III regarding
the corrective actions performed by Indiana Michigan Power Company (I&M, the licensee), in
response to a non-cited violation (NCV) against Title 10 of the Code of Federal Regulations
(10 CFR) Part 50, Appendix B, Criterion 3, Design Control, which requires that design changes
be subject to design control measures commensurate with those applied to the original design.
The NCV was issued in an inspection report dated February 10, 2015 (Agencywide Documents
Access and Management System (ADAMS) Accession No. ML15042A380). The violation was
identified by NRC inspectors for the licensees inadequate radiological review of permanently
removing auxiliary missile blocks (AMBs) from the Donald C. Cook Nuclear Plant (CNP), Unit
Nos. 1 and Unit 2, containment accident shields. The inspection report stated that by
permanently removing the AMBs, the licensee failed to provide for safe radiation levels outside
the containment building following a maximum design-basis accident. The removal of the
AMBs was performed under 10 CFR 50.59, and the regional inspectors have determined that
the licensee correctly followed the NRC-approved 10 CFR 50.59 process. In response to the
NCV, the licensee took several corrective actions, which included improving evacuation
procedures and adding postings to the access points. However, the licensee does not consider
restoration of the AMBs, or installation of equivalent shielding, to be required for regulatory
compliance.
In order to evaluate the adequacy of the licensees corrective actions, the NRC staff in
Region III requested that NRR provide clarification of the requirements for protecting
occupational workers from radiation exposure during a design basis accident. During the
March 17, 2017 call, the staff agreed that the request could be summarized as follows: Clarify
the occupational dose requirements for personnel evacuating from non-vital areas during a
design basis accident at CNP.
Requirements for accident shielding are located in 10 CFR 50.34(f)(2)(vii), which references
NUREG 0737, Clarification of TMI Action Plan Requirements, II.B.2.Section II.B.2 of
NUREG 0737, requires that each licensee perform shielding design review of the spaces that
may contain highly radioactive materials as a result of an accident. The design review should
M. Shuaibi -2-
identify the location of vital areas in which occupancy may be limited by post-accident radiation
levels, and provide for adequate access to these vital areas. NUREG 0737 defines a vital area
as any area which will or may require occupancy to permit an operator to aid in the mitigation of
or recovery from an accident.
At CNP, the areas of the plant affected by the removed AMBs are the areas outside of the
equipment access hatches for each unit. The licensee calculated that without the AMBs,
radiation levels outside of the equipment access hatches would result in lethal doses to
individuals in a very short period of time in the event of a postulated design basis accident.
However, access to this area would not be required to mitigate the design basis accident.
Therefore, this area is not considered a vital area, and the requirements of
10 CFR 50.34(f)(2)(vii) do not apply.
The inspection report dated February 10, 2015, states that the removal of the AMBs was
inconsistent with the requirements of 10 CFR 20.1101, Radiation Protection Programs. The
inspection report specifically references 10 CFR 20.1101(b), which requires that each licensee
use procedures and engineering controls to achieve occupational doses and doses to the public
that are as low as reasonably achievable. However, as stated in the 1992 Statements of
Consideration (56 FR 23387), compliance with 10 CFR 20.1101 does not require that radiation
doses be an absolute minimum, nor that all possible methods have been used to reduce
exposure. Additionally, there is no requirement for the licensee to demonstrate radiation doses
are ALARA during the extremely unlikely event of a reactor accident. Therefore,
10 CFR 20.1101 is not applicable in this case.
In summary, the licensee is not required to limit the dose to occupational workers in non-vital
areas during design basis accidents. There is no regulation related to radiation exposure that
would require restoration of the AMBs or installation of equivalent shielding at CNP.
Docket Nos. 50-315 and 50-316
ML17080A119
OFFICE DORL/LPL3/PM DORL/LPL3/LA DRA/ARCB/BC
NAME ADietrich SRohrer UShoop
DATE 3/20/17 3/21/17 3/29/17
OFFICE DORL/LPL3/BC DORL/DD
NAME DWrona (RKuntz for) KBrock
DATE 3/30/17 6/23/17
