ML17221A681
| ML17221A681 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/16/1988 |
| From: | Tourigny E Office of Nuclear Reactor Regulation |
| To: | Conway W FLORIDA POWER & LIGHT CO. |
| References | |
| TAC-67138, TAC-67139, NUDOCS 8803250107 | |
| Download: ML17221A681 (9) | |
Text
March 16,,1988 Docket Nos.
50-335 and 50-389 Mr.
W.
F.
Conway Acting Group Yice President Nuclear Energy Florida Power and Light Company P.O.
Box 14000 Juno
- Beach, Florida 33408
Dear Mr. Conway:
DISTRI BUTION I~b NRC 8 Local PDRs PD22 Reading S.
Varga'.
Lainas D. Miller E. Tourigny OGC-WF E. Jordan J. Partlow ACRS (10)
Gray Files J.
Buchanan
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - ST.
LUCIE UNIT NOS. I AND 2-10 CFR 20 APPENDIX A EXEMPTION REQUEST FOR WORKER RESPIRATORY PROTECTION APPARATUS (TAC NOS.
67138 AND 67139)
In conducting our review of your February 3, 1988 submittal relating to the above subject at the St. Lucie Plant, Unit Nos.
1 and 2, we have determined that we will need additional information identified in the enclosure to con-tinue our review.
In order for us to maintain our review schedule, your response is requested within 45 days of the date of this letter. If you cannot provide a full re-sponse within the requested time, please provide your full response schedule within 30 days of the date of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.
Please contact me at (301) 492-1474 if you have any questions concerning this letter.
Sincerely,
Enclosure:
As stated cc w/enclosure:
See next page E.
G. Tourigny, Project Manager Project Directorate II-2 Division of Reactor Proiects-I/II Office of Nuclear Reactor Regulation L
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3/ 'If'88
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urigny:bg H e 3//4/88 3/P/88 8803250107 8803ih
'PDR ADQCK',05000335, P -;
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Mr.
W. F.
Conway Florida Power Ij'ight Company St. Lucie Plant CC:
Mr. Jack Shreve Office o< the Public Counsel Room 4, Holland Ruildina Tallahassee, Flor',da 32304 Resident Inspector c/o U.S.
NRC 7585 S.
Kwy AIA Jensen
- Beach, Florida 34957
'State Plannina 8 Oevelooment Clearinghouse Office of Planning 5 Budaet Executive Office of the Governor The Capitol Buildina Tallahassee, Florida 32301 Harold F. Reis, Esq.
Newman 5 Holtzinger 1615 L Str eet, N.W.
Washington, OC 20036 John T. Butler, Esq.
- Steel, Hector and Oavis 4000 Southeast Financial Center Miami, Flor ida 33131-7398 Administrator Oepartment of Environmental Reaulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Mr. Weldon B. Lewis, County
'dministrator St. Lucie County 2300 Virginia Avenue, Room 104 Fort Pierce, Florida 33450 Mr. Char les B. Brinkman, Manager Washinaton - Nuclear Operations Combustion Engineering, Inc.
7910 Moodmont Avenue
- Bethesda, Maryland 20814 Jacob Daniel Nash Office of Radiation Contro>
Peoartment o+ Health and Rehabilitative Services 1317 Winewood Blvd.
Tallahassee, Florida 32399-0700 Peaional Administrator, Reaion II U.S. Nuclear Requlatorv Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georaia 3P 23
EtlCLOSUPE Request for AdditionaT'Tnnormation Hos.
7138 an 471.1.
Oescribe the methods that have been used and that will be used to reduce radioiodine levels to minimal levels in St. Lucie work areas.
The description should include (but not be limited to) a discussion of the utilization of engineering controls, radioactive
- decay, purification and degasification of primary coolant, use of local ventilation units and contamination control devices, and system and area decontamination.
Long term efforts to avoid or alleviate the source of radioiodine problems by means of fuel quality assurance/quality control programs and other operational controls to minimize fuel defects should also be discussed.
471.2.
Verify that St. Lucie has developed and implemented an ALARA program consistent with the position in Regulatory Guide 8.8.
47l.3.
The F'lorida Power and Light Company (FPL) submittal of February 3, 1988 indicates that the use of air-purifying respirators wi 11 enable a
25-50K reduction in the time required to conduct tasks requiring respiratory protection and that this correlates to a 25-50% reduction in man-rem exposure for these tasks.
provide the basis for this
- estimate, including discussion of the particular tasks at St. Lucie that have been identified as having the potential for such dose
- savings, and the magnitude of the man-rem exposure savings for these tasks.
Also provide relevant examples of industry experience in this area.
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471.4.
Yerify that St. Lucie has in place a respiratory protection program that meets the requirements of 10 CFR 20. 103 and that can integrate the practical use of sorbent canisters for protection against radioiodines.
471.5.
Provide a description of the SCOTT 631-TEDA-H canister, including particulate filter, sorbent and percent TEDA.
Address the question of the potential toxic hazard to the respirator user from inhalation of TEDA desorbed from the SCOTT 631-TEDA-H canister.
Describe the criteria for use of these SCOTT canisters at St. Lucie (e.g.,
radioiodine concentration, canister labeling, prevention of canister reuse).
471.6.
The FPL submittal includes tabular summaries of test conditions and test results provided by SCOTT for the SCOTT 631-TEDA-H canister but contains r o other information on these tests or on the means for ensuring the reliability of the tests and test results.
Provide a
complete description and discussion of the test program (including apparatus used),
the means for ensuring the reliability of the tests and test results, and the basis for your acceptance of the test results.
Include the complete name and address of the manufacturer (SCOTT) and the identification of the organization or group that actually performed the tests, if other than SCOTT.
471.7.
Describe how the quality and function of the SCOTT 631-TEDA-H canisters will be verified by Florida Power and Light Co.
(FPL).
It is the utility's responsibility to ensure that canister performance "I 5 ',< 8 Wf
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and quality are fully adequate
.hrough such measures as verification of vendor quality assurance/quality control (QA/QC) and through development of utility/site QA/QC procedures which provide a continu-ing assurance of canister quality.
(a) Include a general discussion of any vendor audits performed, or outline the basis for your accep-tance of vendor QA/QC controls for the SCOTT 631-TEDA-H canisters.
(b) Cite general controls and procedures related to SCOTT 631-TEDA-H canister QA/QC to be utilized at St. Lucie by FPL.
(c) Clarify the "Equilibration" entry for the "SCOTT RADIOIODINE PROPOSAL" in Table A
of Attachment 1 of the FPL submittal.
Clarify how and by whom the "Quality Control Lot Acceptance Plan..."
(Attachm'ent
"- of the FPL submittal) has been and is to be used; verify that only the SCOTT 631-TEDA-H canisters from lots accepted under this MIL-STD 414 acceptance plan will be used at St. Lucie by FPL.
471.8.
The FPL submittal states that the SCOTT canisters will not be used in the presence of organic solvent vapors.
Describe the methods and particular procedures that will be applied to prevent the use of the SCOTT canisters in the presence of organic solvent/chemical vapors at St. Lucie.
This should include a discussion of (a) which organic solvent/chemical vapors if present would preclude the use of the SCOTT canisters at St. Lucie; (b) methods and procedures for detecting (sampling) and/or precluding the presence of organic solvent/chemical vapors where the SCOTT canisters are used (e.g identify general sampling procedures applied specifically for SCOTT canister use; identify administrative procedures which preclude use or release of organic solvent/chemical vapors in areas in which the
SCOTT canisters are used);
and (c) related controls for other systems or operations, such as charcoal filter bed technical specifications, which can also limit SCOTT canister exposure to organics.
Are there any other potential contaminarts in air at St. Lucie that could adversely affect the performance of the SCOTT canisters7 If there are, describe the methods and procedures that will be used to prevent use of the SCOTT canisters in the presence of these contaminants.
471.9.
The FPL submittal states that the SCOTT canisters are to be stored in sealed, humidity barrier packaging, but does not specify whether the canisters are hermetically sealed nor does it specify the conditions of storage.
Specify whether or not the canisters are to I
be stored in hermetically sealed packaging.
Identify the specific procedures that will be used to control canister storage, indicate the range of temperature and relative humidity allowed in the storage area(s),
and describe where these canisters will be stored at St. Lucie.
Specify the shelf life of the canisters and testing to verify shelf life.
471.10.
The FPL submittal states that the SCOTT canisters are to be used only with a full facepiece respirator for which the canister has been NIOSH/MSHA certified.
Provide the details of this NIOSH MSA certifi-cation and explain its relevance to the use of this equipment for protection against radioiodine.
Specify the means by which FPL will determine that the fit of the full facepiece (to be used with the canister) will reasonably ensure that a workplace radioiodine protec-tion factor of 50 can be achieved for each user of the respirator.
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(A minimum fit factor of 500 should be obtained for each potential user of the full facepiece respirator as determined by fit testing with a HEPA filter and challenge aerosol).
471.11.
The FPL submittal states that the canisters are not to be used ir, challenge concentrations of total organic, iodide, including "nonradiometric" (nonradioactive?)
iodide, greatet than I ppm.
Describe the methods and particular procedures that will be applied to prevent the use of the SCOTT canisters in the presence of chal-lenge concentrations of total organic iodides and other halogenated compounds greater than 1.0 ppm, including nonradioactive compounds.
471. 12.
The FPL submittal states that the SCOTT canisters are not to be used in environments greater than 120' but does not provide a limit on the relative humidity.
Specify a 1;mit on the relative humidity for canister use ana provide the basis for this limit.
Specify how compliance with the limits for temperature and humidity will be demonstrated.
471. 13.
Identify the specific plant and training procedures that will be used to verify the effectiveness of this special respiratory protection program.
The following elements should be considered:
(a) weekly whole-body/thyroid counts for individuals using the SCOTT canisters for radioiodine protection; (b) whole body/thyroid counts for indi-viduals who exceed 10 NPC hours in seven (7) consecutive days, prior to their next entry into a radioiodine atmosphere; (c) establishment
of a thyroid radioiodine uptake level (e.g.,
70 nCi) which if ex-ceeded will result in restricting the individuals entry into radioiodine atmospheres pending health physics evaluation; and (d) establishment of a whole body count/survey data base to be used to evaluate and verify the effectiveness of the program.
471.14.
Identify the specific plant and training procedures that will be deve'loped or modified to incorporate controls, restrictions, and use of the SCOTT canisters and to instruct SCOTT canister users and health physics personnel in the limitations for use of the canisters and in their proper field use.-