ML19339C874
| ML19339C874 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/10/1981 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| LOD-81-40-13, NUDOCS 8102120180 | |
| Download: ML19339C874 (2) | |
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Comm:nwrith Edison C-e ~4st Natem Pan cmcago etreg Accress Repty to: Post Off.ce Sox 767 Cn:cago. Ilhnois 60690 February 10, 1981 Mr. B.J. Youngblood, Chief Licensing Branch 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Subj ect :
LaSalle County Station Units 1 t, 2, Response Radiological Assessment Questions, NRC Docket Nos 50-373/374 LOD 81-40-13
Dear Mr. Youngblood:
The purpose of this letter is to provide supplemental information in response to inquiries from the NRC Staff.
The first of the inquiries addresses the qualification of the candidate (Mr. Lawless) for Radiation Protection Manager.
Although the candidate's quali fications to ANS 18.1 have been questioned with respect to the adequacy of his experience in " applied radiation protection", supplemental biographical information was provided to the Staff and reviewed during the site audit of January 26, 27, 1981 which demonstrate the candidates experience in high energy radio-chemistry and operating nuclear facility radiation protection.
Although it is acknowledged that the candidates background is based heavily in radio-chemistry, i*. is.iudged that the depth of the LaSalle County Station radiation protection organization outweighs what o'ficiency may exist in the RPM candidates qualification.
Specifically the radiation protection organization now includes a second individual who reports directly to the RPM (Mr. J. Lewis) whose qualifications have been found by the NRC Staff to meet ANS-18.1.
This individual will assist the RPM in the day-to-day conduct of radiation protection activities.
In addition, the station will add a full time engineer whose primary responsibility will be to monitor ALARA conformance and participate in the revi w and development of the LaSalle County ALARA program (see a ta chtren t )
The site organization is also supported by an off-site technical liason office under the direction of the Manager of Technical Services-Nuclear, whose office includes individuals qualified to ANS 18.1 as RPM.
This of f-si te.of fice coordinates the development of. generic programs applicable to all Commonwealth Edison nuclear stations and thereby provides further assurance that the on-site RPM.is' aware of potential pr: gram deficiencies as well as related developments that should be addressed in the LaSalle County program. This dialogue is maintained through regular corr.unication between plants sponsored by _the of f-site' liason office including periodic joint meetings.
It is on the basis of these facts and the existence of.another qualified RPM'(Mr. C. Schoeder Technical Staf f Supervisor) that the RPM candidate at LaSalle County
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Mr. B.J. Youngblood, Chief Page Two February 10, 1981 The second it, qui ry questioned the adequacy of the management interface between the RPM and the Plant Manager. As has been previously discussed with the NRC Staff and as was documented in the Commonwealth Edison Q A Topical Report dated December 29, 1980, this interface has been clarified to specify the neces,ity for regular direct access of the RPM to the Plant Manager.
V'.th the prior agreement of the NRC Staf f it is judged that this issue is resolved, she third inquiry questioned the prt:sret consolidation of the chemistry and radiation protection function within the Radiation Protection organization.
Commonwealth Ediscn is presently reviewing this issue and is committed to implement appropriate changes as necessary to assure the proper functioning of the radiation protection organization.
LaSalle County Station will be required to implement the final program recommendations developed as the result of this corporate review which currently is focused on resolving similar inquiries from the Region ill Office of Inspection and Enforcement for the Dresden, quad Cities and Zion facilities.
In this regard, Commonwealth Edison commissioned sal, Inc. to perform a management assessment of the organizations to determine what changes could and should be made to assure oroper coeration. A change that will be made as the result of this study is the addition of a chemistry foreman in the chemistry lab to oversee all chemical analysis activity and assure uniform performance of all rad-chem technicians. This change will be implemented at LaSalle County prior to fuel loading of Unit 1.
A copy of the SAI report and any other Commonwealth Edison recommendations made during the course of the Unit 1 safety review will be submitted for the Staff.
The fourth inquiry was directed at the response to NUREG-0737 Item II.B.2 contained in Section L.19 of the FSAR.
Clarification was requested as to the basis used in developing the radiation source terms.
Currently the response refers only to Regulatory Guide 1.3 whereas NUREG-0737 requests that Regulatory Guide 1.7 also be considered. The LaSalle County assessment was made on a basis which is Judged to be equivalent to and in fact more conservative than the-position defined in RG 1.7. Appropriate reference to this guide will be incorporatti into Section L.19 in a future amendment to the FSAR.
The proposed revision is provided as Attachment 2 of this letter.
Also included as a part of u.e fourth inquiry was a request for plant general arrangement-drawings showing the vital areas delineated in Table L.19-1 of the FSAR as well as planned access routes'to these These vital areas are already shown 'in thenFSAR'in Figures 1.2-6 areas.
through 10 and 1. 2-22.-
However, ~in order ' to simplify the task:of identi fying*
and evaluating those drawings, a. set of drawings has been marked and submitted as Attachment 3 of this letter whicht identifies all the vital areas and their access paths.
Also submitted as Attachment 4 is a tabulation of the personnel-integrated exposure associated with accessing these vital areas using the prescribed pathways, and the assumptions used in arriving at these exposures. This information will be included in a future FSAR amendment as. Table L.19-2.
Mr. B.J. Youngblood, Chief Page Three February 10, 1981 The fifth inquiry was directed at the discussion of iodine analysis techniques described in Section 12.5 3.3.1 of the FSAR; specifically, whether adequate consideration had been given to the effect of background radiation in selecting the areas in which the iodine analysis is to be performed. This section of the FSAR will be modified in a future FSAR amendment to indicate that the areas selected are low background areas, i.e. background levels projected to be at normal shutdown levels as described in Section 12.3 of the FSAR.
The oroposed revision to Section 12.5.3 3.1 is submitted as Attachment 5 to this letter.
The sixth inquiry was directed at verifying that methods exist to relate the radiation leveis read by the high range radiation monitors (see Section L.29 of the FSAR-NUREG-0737 Item II.F.1) to actual radiation levels in the containment. As was indicated in Section L.29 the LaSalle County instrument, located in sleeved penetrations, only moderately attenuates the 60 Kev photons identified in NUREG-0737 In order to resolve the NRC Staf f concern regarding this attenuation, pre-established radiation level correlations will be implemented at LaSalle County Station prior to January 1, 1982 to assure proper operator response to the indicated radiation levels provided by this high range radiation monitor.
Appropriate corrections will thereby be possible to identify the actual containment radiaton levels including consideration of the 60 Kev photons.
Based on our discussions with the Staff, it is judged that this response provides the basis for resolving all outstanding issues related to radiation protection at LaSalle County.
In the event there are any further questions in this regard, please direct them to this office.
Very truly yours, O
L.O. De1 George l
Nuclear Licensing Administrator l -5 f
cc: NRC Resident inspector-LSCS l
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ATTACHMENT I ALARA COORDINATOR A Non-Supervisory staff position with the following basic functions:
Obtaining a proper balance between reducing collective and individual dose equivalents and getting a particular task accomplished in a timely manner. Work activities of the Station ALARA Review Committee and any station Job which has the potential for significant exposure dose reduction.
The suggested qualifications for this position include 2 years station experience in the area of Maintenance, Engineering, Operations, or Radiation Protection.
The ALARA Coordinator should be familiar with plant operations and exposure reduction methods.
Supervisory experience is desirable for this position.
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l LSCS-FSAR ANENDMENT dp>
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L.19 PLANT SHIELDING (II. B. 2) j FULL POWER LICENSE REQUIREMENT:
Provide (1) a radiation and shielding design review that i
identifies the location of vital areas and equipment in which i
personnel occupancy may be unduly limited or safety equipment may q
be unduly degraded by radiation during operations following an j
accident resulting in a degraded core, and (2) a description of 1
the types of corrective actions needed to assure adequate access to vital areas and protection of safety equipment.
ll This requirement shall be met before issuance of a full-pcwer
'l license.
See NUFEG- 0578, Section 2.1.6b (Ref. 4), and letters of I
september 27 (Ref. 23) and November 9, 1979 (Ref. 24).
DATED REQUIREMENT:
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Complete modifications to assure adequate access to vital areas i
and protection of safety equipmen't following an accident i
resulting in a degraded core.
I'i This requirement shall be met by January 1, 1981.
See NUREG-0578, Secticn 2.1.6b (Fef. 4), and letters of September 27 i
(Ref. 23) and November 9, 1979 (Re f.
- 24).
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r-A--radiation aut_s ddding-desiw;;i_e er acdcicz 12-Sal 2.8 i
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carries considerable radioactivity (concentrations) throughcut the plant via piping which contains suppression pool water, and by airborne particulate and noble gas concentrations in secondary a
containment.
However, based on the f act that no operator actions I!
other than those which take place in the control room or at the remote shutdown panel are critical for plant shutdown, only these areas and the sampling stations and Technical Support Center i
(TSC) are considered to be vital for personnel access for post-accident cases.
li spatial and mi. c desmud..ct characterirticc-cf La radistion l.
e ma n a ti n g fr c.u thc TJC cccidsut relence preccriptian of '^ -
I Reyuiate.2 Ovids 1.0 wcic f ctcraincd.="Tn general, the shielding design review shows that the vital areas (the:centrol room, the li aaxiliary-electric equipment rocm, where the. remote. shutdown panels tare located,.and the TechnicalasupportuCenter) have dose li rates which allow continuous occupancy:for the. accident scenerio.
'i The results also show that accessibility.to these areas is not a.
problem during such accidents (see also response to Q331.32 for additional'information on the shielding design review).
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INSERT A radiation and shielding design review was made for LaSalle County Station using the source terms speci-fied in Reg..latory Guides 1. 3 and 1. 7.
The spacial and time-dependence characteristics of the radioac-tive sources were derived using Regulatory Guide 1.3.
The resulting source distribution is as conservative or in some cases more conservative than rhe NRC-pre-scribed post-accident source distribution stated in j
NUREG-0578 or NUREG-0737.
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LSCS-FSIR A::UI U:'N:4T g DECE:GCR 1980 12.5.3.3.1 Pen innel Internal Exposure Progrca Durinq Acc i den t _ Cond.i. Lions Five Ebarline Instrument Corporation Pl::G-3 (2A special) pa r ti cula te, iodine, and noble gas air monitoring sys tem (s) are provided for air sarpling plant arets where personnel may be present during accident conditions.
The systems are cart mounted with battery power backup.
Grab samples are obtained using the equip.aont specified in LSCS-FSAR, Table 12.5-2.
During accident conditions, Silver Zeolite cartridges will be used for radiciodine analynis in conjunction with ona Eberline Instrument Cor-pora tion SAM-2.
Station procedures are provided for obtaining and evalu-ating both routine and non-routine air saaples.
In addi-tion to initial training provided for radiation / chemistry personnel, periodic drills are conducted in accordance with Generating Stations Energency Plan (GSEP) Section 8.3 (refer to Section 13.3).
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The analysis of iodine cartridges will be performed in a Icw backgrocnd Icw ecotamination area.
During ac:ident ccnditions, an area such as tr.e lowr storeroom elevation of the service taullding or the rad =4ste control recm can be used for this purpose. The post-accident radiatien levels in these areas are j
projected to be at normal shutdce levels.
Prior to analysis, l
cartridges will be purged using: station sprvice air or tottled nitrogen.<hich Is stored onsite., Analysis for iodine will t>e cerforr>ed using portable equip.,ent stkh as an Eber! ne l
5tabilized Assay ;'eter (SM-ll) or a garna spectrer-eter -
i rN1tichannel analyzer systect with a germaelee detector. -If the radiation levels in the icwer storercon cr. thd radaste:
l centrol rem are higher than projected, this equiseent can':-
l be rmved to other locations. -
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