ML18043A772
| ML18043A772 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/16/1979 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 7907060498 | |
| Download: ML18043A772 (6) | |
Text
_!.,,
'vJ \\ *.
_r--,..
( r u ocket NR
( f 1,... r.
Loe a 1 PDR.
.JMinns JRBuchanan.
- TERA Docket No. 50-255 ORB #2 Read in*g NRR Reading VStell o DEi.senhut BGrimes RVollmet TJCarter WRussell ACRS (16)
DKDavis Mr. David Bixel Nuclear L 1censing Administrator Consum~rs Power Company 212 West Michigan Avenue
.- Jackson,. Michigan 49201 *
Dear Mr.* Bixel:
- M~'< l {) 1979.
OELD OI&E (3 r. *.
DLZiemann RDSi lVer.
HSmHh SKirsl i.s
. We are continuing o.ur review of the Pali sa.des steam generator replacement program
'. submitted by your letter of J~nuary 3, ]979, and have several questions, -enclosed,
- related to the radiolog.1cal ass.essment~* -:10 maintain our review.schedule we request your reply w1th1n-.60 daysof the date o~ this le~ter..
Additional questions, *related to this or other sections of the report, may_ develop as the review proceeds and we *wn 1.'transmit. such partial set of quest-ions *when' they arise.
Enclosure:
Request for Additional
- information *.
cc w/enclosure:
See next page Sincerely,_
'.0rtg;:ifal r.igned by
- D*~~~;_ui..l:!i L.r ~-:ie1nat1ll Dennis L. Ziemann, Chief Qperating Reactors Branch #2 Div1~ion of Operating Reactor~
- ~*,:.-
.... "... ~R
... P.i!~.:.Q8U?..:...... :......,............. > ***************......................................
- uRNAMB~
- RR....J.~*~r.:.P.h. ~.... o.~.i.i.emq.nn.*..... *........-:... :.. '... :..-....... :.:.*:...... :.. ~.. :.:.....................................................r.
-s1r'*17° --i:.1*1*c,;7°*
. DATB~ * ; **** r:;,..... ;>.......
..v ** **** *::*"*********.............. -. ********, ** ************************: ************************** ****-**.*****oo********.** *
~
- ~
"*U.S. Q~VllRNMBNT~PRINTINO.OP'P'ICB: 1911, ;,,IOI -111 me PORM 318 (~~76) NRCM 0240.
Mr. David Bixel cc w/enclosure:
M. I. Miller, Esquire Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois 60670 Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esquire Suite 4501 One IBM Plaza Chicago, Illinois 60611 Kalamazoo Public Library
~15 South Rose Street Kalamazoo, Michigan 49006 e MAY 1 S 1979
PALISADES PLANT REVIEW OF STEAM GENERATOR REPAIR REPORT REQUEST FOR ADDITIONAL INFORMATION DOCKET NO. 50-255 RADIOLOGICAL ASSESSMENT
!nci'osure
- 1.
Provide the following additional information regarding ALARA considerations (Sections 1.1.5, 4.3.5):
(1) duration of exposure associated with anticipated replacement/repair*
- tasks, (2) repetition rate of the tasks, (3) numbers of work force expo~ed during each task, and (4) occupational exposures associated with anticipated replacement/
repair activities.
- 2.
Describe the designed contamination control envelopes and your plan to maintain occupational exposure within these envelopes 11ALARA".
Include also dose rates, exposure times, and numbers of workers involved in the tasks (Section 4.3.3).
. 3.
Provide a diagram showing the radiation surveys around the steam generator replacement/repair activities.
Include similar radiation surveys for figures 4.2-4 to 4.2-7. Include a table showing the whole body dose received during the inspection and plugging of the degraded steam generator tubes for 1976, 1977 and 1978.
- 4.
Discuss briefly how you would avoid imbalance of the permanent ventilation systems due to the additional construction-related ventilation equipment (portable fans, hoods and filters, etc.).*
- 5.
Your description of compliance* with Regul atciry Guiele 8. 8, 11 Information Relevent to Ensuring that Occupational Exposure at Nuclear Power Stations Will Be As Low As Reasonably Achievable", Revision 3, June 1978 states that the following considerations were not implemented:
(l) Radiation.Zones in the containment work areas, identifying the exposure levels in each work zone.
C.2.(a)
(2) Streaming or scattering of radiation from installed shielding, such as plugs in open ended pipe lines following cutting.. C.2.b.(4)
(3) Outleakage of airborne contamination from the containment due to steam generator replacement/repair activiti~s when the equipment hatch is open.
(4) -Operating experiences should be recorded, evaluated and reflected in th~ selection of replacement instrumentation.
C.2.(c)(3)
(5) Provision to be implemented to minimize exposure of station personnel in performing code inspection, such as removable insulation, smooth welds, etc. C.2.(i)(ll)
(6) An adequate emergency lighting system can reduce potential exposures of station personnel by permitting prompt egress. from high radiation areas if the station lighting system fails.
(7) A staff member who is a specialist in radiation protection assigned the responsibility for contributing to and coordinating ALARA efforts in.support of operation that could result in substantial~
individual and collective dose l~vels.
(8) Station work areas to limit the ave~age concentration of radioactive material in air to levels below... in Appendix B, Table 1, Column of 10 CFR Part 20.
C.2.d Provide justification for not implementing these provisions of Regulatory Guide '8.8, and demonstrate that alternative precautions you have taken will provide comparable levels of protection.
- 6.
Explain what steps you plan to take to help maintain doses ALARA in this project.
Indicate what use will be made of contaminations tents, lead wool blankets, gloveboxes, remote cutting and welding equipment, temporary shielding and ventilation systems.
Also indicate what equipment will be mocked-up for training purposes.
- 7.
Provide a table showing the occupational collective whole body dose estimates for the following phases of the steam generator replacement repair activities: (1) preparation, (2) removal, (3) installation and (4) storage.
Discuss briefly your procedure for calculating these dose~, taking into account the dose reduction measures proposed to maintain doses as low as reasonably achievable (ALARA), including local decontamination, temporary lead shielding, pre-job planning, pre-job* training and use of remote tools where practicable.
- 8.
Discuss your c.utting and welding operations and cleanup of surface contamination in respect to the "ALARA" guidelines (Section 4.3.3).
. '.. ) 9.
Your estimated dose range of 1,200 to 5,000.man-rem for the steam generator replacement/rapair activities is too wide to assure that occupational expsosure will be as low as reasonably practicable.
Justify the high end of the range as being ALARA.
Experiences with other designs indicate the feasibility of performing such work with substantially lower total doses than the high end of the range you have predicted.
- 10.
Provide a rough breakdown of the activities~ person-hour occupancies, and projected dose rates which are used in deriving the estimated total of 40,250 man-rems per unit for retubing in place (Section 8.7).