ML18130A527
| ML18130A527 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/31/1979 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7909060165 | |
| Download: ML18130A527 (4) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY R:rcHMOND,VIRO:£NIA 23261 August 31, 1979:
Mr. Harold R. Denton~ Pirect6r Office of.Nuclear Reactcir Regulation Attn: Mr. Albert Schwencei, Chief..
Operating Reactors Branch No. l Divisi6n of Operating Reaciors *
- U. :S. Nuclear Regulatory Commission Washington, DC 10555
Dear Mr. Denton:
Serial No.* 669 LQA/WRM:esh Docket Nqs ~
50-280 50-281 License Nos. DPR-32 DPR-37
. AMENDMENT*ro*oPERATING LICENSE.DPR~32AND DPR~37
. *suRRY'POWER:STATION UNIT'N0~*1:AND 2 *
.. STEAM 'GENERATOR: REPAIR: PROGRAM PROPOSED CHANGE TO LICENSE.CONDITION 3~G~2~b Pursuant to 10CFR50.90, the Virginia Electric_and Power Company requests an amendment to Operating Licenses DPR-32 and DPR-]7 for the Surry Power Sta-tion Unit Nos. l and:2. The proposed changes are enclosed.
The NRC issued additional license conditions for the Steam Generator Repair Program (SGRP) for Surry Unit Nos. T and 2 under Amendment Nqs. 47 and 46 r~spectively. License Condition:3~G~2.b, which applies to the SGRP for both uni ts, requires that 11 the temporary containment and ventilation s:ystems shall be operating for all cutti_ng and grinding operations involv~ng components with removable radioactive contamination > 2200 DPM per l 00 cm during the Steam Generator Repair Program.
The intention of the condition was *to assure the protection of personnel when performing such work as cutting or grinding on contaminated components, particularly where the nature of such work and the amount of contamination presented a significant potential for generating airborne radioactivity and the spread of radioactive materials.
The NRC interpretation of this condition has defined 11temporary containment 11 as including such localized controls as glove boxes and tent enclosur~s.
The application of this requirement to the SGRP for Surry Unit No. 2 has forced the use of glove boxes in numerous situations involving the removal of piping and valves *located in the lower steam generator cubicles and else-where ~ithin the containment building where radiation doses were relatively high.
The Surry Health Physics group performed an evaluation of several pipe
~utting operations where glove *boxes were requir~d. This evaluation showed that *in some cases, a si'gnificantly greater amount of exposure resulted from C.
_ installing and removi.ng the glove boxes than from performing the actual pipe 1{Jlr;p:y,t:~ n{ry~:A%e~W,S-tirri_~~tance, the installation and removal expo~ure was 5o times
""Lgr,eat~r: 9i~*n: tlhe'J,w9.-r;R,fp:er:foir:ma-rs.. i;;! exposul'.'e.
The results of a 1 r samples taken in the vicinity of some pip'e' tutting operations performed within a tent enclos-
~
ure have shown that the airborne radioactivity generated, if any, was usually ~I/..~
localized to the extent that only those personnel actually performing the work l
7909 060 14 5 u>~~~i)*'rf)
e VIRGINIA ELECTRIC A:-;'D POWER COMPANY TO Mr. H:arold.R. Denton 2
were exposed to this hazard. Adequate personnel protection could be provided by the required use of personal respiratory protection. equipment, while eliminatfog the additional unnecessary exposures involved with glove box use.
In light of these o5servations, the unqualified requirement to utilize glove boies or other temporary enclosures is seen to be counter-productive toward achieving the major license tondition objective of maintaining the exposure of personnel to radiation and radioactive riJateria 1 s "as 1 ow as is reasonably achievable" CALARA}. 'Cutting and grinding operations are required for many of the-SGRP activities and involve varying circumstances and radio-l_ogical hazards. A more effective method of satisfying the ALARA objective is to evaluate these operations on a case By case basis, using applicable survey data and prior experience, to determine if the use of temporary enclosures is in fact justified. The proposed change to License Condition
- 3~G~2.b provides the flexibility to more effectively satisfy the ALARA objective. The margin of safety provided by License Condition :3~G~2~b will not be decreased by the proposed change, but rather will be expanded to allow the consideration of all radiol6gic~l hazards associated with a specific task.
This proposed c ha_nge has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the System Nuclear Safety and Operating Committee. It has been determined that this request does not involve ari unreviewed safety questiqn.
- We have evaluated this request in accordance with the criteria in 10 CFR 170.~2. It has been determined that this request involves a Class III amend-ment fee of $~,000.00 and a Class I amendment.fee of $4QO;oo.
Accordingly, we have enclosed a check in the amount of $4,400.00 in payment of the Class I and the Class III amendment fees.
Attachments:
Very truly yours,
- ~
- C. M. Stall i_ngs r
Vice President-Power Supply and Production Operations
- 1. Proposed change to License Condition.3.G.2.b
- 2. Voucher check no. 32570 for $4,400.00 cc: Mr. James:P. O'Reilly, Director Office of Inspection and Enforcement Region I I
COMMONWEALTH OF VIRGINIA CITY OF RICHMOND
)
) s. s.
)
Before me, a Notary Public, in and for the City and Common-wealth aforesaid, today personally appeared c. M. Stallings, who being duly sworn,' made oath and said (1) that he is Vice President-Power Supply and Production Operations, of the Virginia Electric and Power Company, (2) that he is duly authorized to execute and file the fore-going Amendment in behalf of that Company, and (3) that the statements in the Amendment are true to the best of his knowledge and belief.
Given under my hand and notarial seal this 'iZh.. day of
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My Commission expires Jokt!J1rY
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Notary ubl 1c (SEAL}
e ATTACHMENT 1 PROPOSED CHANGE TO LICENSE CONDITION 3.G.2.b A proposed change to License Condition 3.G.2.b is requested in accordance with the reasons stated in the accompanying letter.
The requested change is as follows:;
(2) (b) The temporary containment and ventilation systems shall be operating for all cutting ~nd grinding operations involving components with removable rad.ioactive cont.amination > 2200 DPM per 100 cni2, as deemed necessary based on overall ALARA considerations by the Health Physics Coordinator-for the Steam Generator Replacement Project.