ML19319E180
| ML19319E180 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/02/1978 |
| From: | Kaplan D, Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML19319E181 | List: |
| References | |
| NUDOCS 8003310697 | |
| Download: ML19319E180 (4) | |
Text
-. ' '.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
DISTRIBUTION FOR INCOMING MATERIAL 50-312 EC: GOLLER K R ORG: MATTIMOE J J DOCDATE: 02/02/78 NRC SACRAMENTO MUN UTILITY DISTRIC DATE RCVD: 02/hD/78 3CTYPE: LETTER NOTARIZED: YES COPIES RECEIVED JBJECT:
LTR 1 ENCL 40 DVISING SUBJECT FACILITY SHALL ASHERE TO THE CONDITIONS AS STATED 1 REG GUIDE 8.15 AND CONSIDER NUREG-OO41 RE PROPOSED AMEND NO 54 JNCERNING DELETING RESPIRATORY PROTECTION PROGRAM DESCRIBED IN ICTION 6.12 OF TECH SPECS...NOTORIZED 02/02/78.. W/ATT P
_ ANT NAME: RANCHO SECO (SMUD)-
REVIEWER INITI AL:
XJM DISTRIBUTOR INITIAL:
acocoo********** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
GENERAL DISTRIBUTION FOR AFTER ISSUANCE OF OPERATING LICENSE.
(DISTRIBUTION CODE AOO1)
FOR ACTION:
BRANCH CHIEF REID**W/7 ENCL INTERNAL:
_ REG-FILE **W/F_N
)
NRC PDR**W/ ENCL
& E**W/2 ENCL OELD**LTR ONLY
-HANAUER**W/ ENCL CHECK **W/ ENCL EISENHUT**W/ ENCL SHAO**W/ ENCL BAER**W/ ENCL BUTLER **W/ ENCL
' GRIMES **W/ ENCL J COLLINS **W/ ENCL J.
MCGOUGH**W/ ENCL EXTERNAL:
LPDR'S SACRAMENTO, CA --- REGION V**W/ ENCL TIC **W/ ENCL NSIC**W/ ENCL ACRS CAT B**W/16 ENCL i:
@TRIBUTION:
LTR 40 ENCL 39 CONTROL NBR:
EMEMPlukes/
'l ZE: 3P+1P occO**o**************************
THE END 8098810 89 J C
b-
PE in n m %..,L.
~..
5::pm
$,SMUD
=
SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street. Box 15830, Sacramento, California 95813; (915) 452-3211 February 2, 1978 Director _ of N0 clear Reactor Regulation ATTN:
Karl R. Goller Assistant Director for Operating Reactors Divis ion of Operat ing -Reactors U.
S. Nuclear Regulatory Commission Washin g ton, D. C.
20555
~
Re:
Docket No. 50-312 D-M Proposed Amen dmen t No. 54 nt Rancho Seco Nuclear Generating Station
~d A
Un it Number I g ~Q-}
Gen t lemen :
v Q
The letter from you dated July 28, 1977 reques ted an amen dmen t to our Techn ical Speci fica t ion s to implement the requiremen ts of Regula tory Guide 8.15 and NUREG-0041.
This amendmen t will delete the respiratory protection program described in 6.12 of the Techn ical Specifications and replace the description with Section a reference to Regulatory Guide 8.15 with exceptions as specified in this letter an d Amen dmen t.
The review of Regulatory Guide 8.15 and. NUREG-0041 has revealed that there are several requi remen ts wi thin the documen ts that exceed reasonable conservation in Health Physics or do not have application tc a Nuclear Power Gele ra tin g Facility.
Additionally, we would like to clarify inconsistencies and ambiguities betweel RG 8.15 and NUREG-0041 which imply that the NUREG is actually the regulatory document and RG 8.15 is used to relate the original requi remen t (i.e., 10 CRF 2 0.103) to NUREG-0041.
The two documen ts define different requi rements for the " min imum acceptable program. " The NUREG defines the basic ~ program in Chapter 3 but the RG defines the pret: ram by referencinc complete Sect ion s 2, 4, 5, 7, 8, 9, 10, 11 and 12 of the NUREG.
The District shall define a Respiratory Protection Program as s tated in RG 8.15 but shall use NUREG-0041 as a guide only.
Minor exception s to the NUREG-0041 will be Iimited in scope and not alter the basic in ten t of protection for the in d i v i dua l.
The - following clari fication s of NUREG-0041 are:
M' -
-1)
Chapters 5. 2. 2 and' 5. 2. 2. 2 s ta te tha t sorben ts cann isters will not be used.
Rancho Seco will use sorben t cannisters when isotopes of iodine may be presen t but no protection factor will be credited.
The assigned exposures shall be from air samples unless superceded by bioassay tests.
2)
Chapter'5.2.3.5 limits the reuse of particulate cartridges after the seal has been broke.1.
These filters do not sign ificantly degrade ~ wi th t ime.
The respirator use cycle at Rancho Seco is characterized by extensive use during refueling shutdown and sporadic use during the remainder of the year.
No limitation should force. the unnecessary disposal of.large quan tities of good cartridges.
The program at Rancho Seco will require that the cartridges be' resealed ' a f ter in spect ion an'd 00P tes ted af ter one year of use. ppg / h
.f
/
s
'L IDirector of Nuclear Reactor Regulation Februatr'2, 1978
~
ATTN: Karl R. Goller 3)
Chapter 6 indicates the protection factors to be used with the various types of respirator equipment.
The factor stated in Table 6-1 will be used until Rancho Seco develops the protection f actor for each individ-ual.
Due factor will. be based on three independent DOP man tests for each person tested and the lowest factor observed during the tests will be used.
The results will be documented for each person tested.
4)
Chapter'7.2-states that several models of facepieces from various manu-facturers be made available. The maintenance of a varied inventory con-tains several serious drawbacks. 'These include difficulty of control during issuance of brand for each individual, confusion of spare parts and added cost.
Individuals who can not be properly fitted will utilize hoods or other equipment or.they will be prohibited from working within challenge atmospheres.
5).
Chapter 7.4 requires that each person utilizing the respiratory program have a physical exam,ination at least annually.
Physical screening is merited but due to the extensive training program for the site employees, the transient nature of contract personnel and the time and cost involved in the medical examinations, Rancho Seco will pursue an alternate program.
A consulting physician will establish a questionnaire for each worker to complete which will identify specific problems that may effect their per-formance with the equipment. A reasonable effort will be made to identify the problems as stated in Chapter 7.4 but the major emphasis will be the individual's responsibility to determine the physical or mental ability to use respiratory equipment during the training / retraining programs.
6)-
Chapter-8.5.2.2 states that stannic chloride smoke tubes can be used for qualitative mask fit testing.
Experience shows that the smoke from stan-nic chloride tubes (MSA) can.not be detected even when breathing the smoke cloud directly. This method will not be used at Rancho Seco and acceptable alternate tests will be used to verify acceptable mask fitting.
7)
Chapter 9.2 requires that respirators be checked after each use at least monthly.
Respirators are seldom used at Rancho Seco during normal opera-tions but frequently during refueling outages when extensive inspections and modifications'are made. This requires that a large inventory of res-pirators be available during the refueling period.
Presently after each
-respirator use, it is cleaned, disinfected, inspected and then sealed in a' plastic bag to prevent deterioration. This should eliminate any neces-sity for periodic checks. Respirators assigned to emergency use are checked ~ monthly _and all respirators are checked annually.
Rancho Seco intends to. continue these procedures.
8)'
Chapter 9.6_ states several limits for contamination surveys and decontam-ination of respiratory equipment.
The limits that will be used at Rancho Seco will require decontamination to a minimum of 1000 cpm fixed beta 2
. gamma and 200 dpm/100 cm smearable inside the facepiece and 5000 cpm and 200'dpm/100 cm2 smearable on the exterior of the facepiece.
Contamination levels 'will be determined with a GM type pancake probe.
y
~t.'
p
~
^
- Director. of ' Nuclear Reactor. Regulation - February 2,'1978 ATTN: -Karl R. Goller-
.In summary,:we would like to state that Rancho ~Seco shall adhere to the condi-
~
tions'as. stated in' Regulatory Guide-8.15 and consider NUREG-0041 as a guide only, with exceptions taken as' stated in this letter.
If we' can provide any additional.information, please feel free to contact us.
Respectfully submitted, SACRAMENTO MUNICIPAL UTILITY DISTRICT
.t A
- J. J. Mattimoe Assistant General Manager and Chief Engineer
-1
['[
s hy'.la U DAVID S. KAP AN General Couns'el for
. Sacramento Municipal' Utility District-Sub:cribed and sworn to before me this 2nd day of February _1978
- R %,
D :'
?
O D 7 redidh. n$
r d
$\\
yy i
b GL nU A)
[
Pdh ?
\\.
g% e.,. v*( the -County of Sacramento, State of to co# f etty Mattier, Notary Public in and for e
' California My Commission Expires January 12, 1980 1
.JJM:jg Attachments.
I L_-
L
-