ML19340A919

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Hazards Analysis Supporting Addl Exemptions from 10CFR20.203(C)(2) Re High Radiation Area Access Regulation, High Radiation Area Criteria & Keys to Radiation Area
ML19340A919
Person / Time
Site: Dresden Constellation icon.png
Issue date: 10/01/1964
From: Boyd R
US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML19340A918 List:
References
NUDOCS 8009080612
Download: ML19340A919 (2)


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HAZARDS ANALYSIS BY THE RESEARCH AND POWER REACTOR SAFETY BRANCH DIVISIm OF REACTOR LICENSING IN THE MATTER OF COMMCWEALTH EDISON COMPANY DOCKET NO. 50-10 ADDITIONAL EXEMPTIONS FROM SECTION 20.203(c)(2) 0F 10 CFR 20 Introduction By letter dated August 23, 1962, the Director, Division of Licensing and Regulation authorized an exemption from the requirements of paragraph 20.203(c)(2) of 10 CFR 20 for operation of the Dresden reactor.

The exemption was authorized subject to procedures outlined in Cemmonwealth's letter dated April 17, 1962. The Commonwealth Edison Company has now requested by letters dated October 21, 1963 and April 29, 1964, the telegram dated September 17, 1964, that the exemption be extended to include the following:

1.

Regulate access to high radiation areas which have developed since August 23, 1962 and any new high radiation areas which develop subsequent to the date cf this letter in accordance with procedures approved in the exemption dated August 23, 1967 2.

Delete areas no longer teeting high radiation area criteria.

3.

Increase from one to two the number of keys available for access to high radiation areas during power operation.

Discussion Paragraph 20.203(c)(2) of 10 CFR 20 requires that a conspicuous visible or audible alarm be energized if the radiation level of an area is above 100 millirem per hour so that an individual entering the high radiatien area and the licensee be aware of the entry.

Commenwenith has instituted an acceptable lock and key procedure for specific areas of the Dresden facility when the radiation levels exceed 100 mr/hr and has been exempted from the alarm system requirement by Commission letter dated August 23, 1962.

Commonwealth has now proposed that all new areas which meet the high radia-tion area criteria defined in 20.202(b)(3) of 10 CFR 20 will be isclated as before and that access will be subject to the lock and key procedures currently utilized.

Commonwealth has indicated that there are several locations at the Dresden facility, such as the turbine area, where the radiation 1cvel falls below 100 millirem per hour af ter reacter shutdown.

Areas falling into this category, under the proposed authorization, would be removed from the high radiation area classification whenever shutdown cen-ditiens were such that the radiation level in these areas fell below 100 800008'O 6m

L millirems per hour. Commonwealth has submitted in their telegram of September 17, 1964, procedures to be followed before withdrawal of rods to ensure that these temporarily reclassified areas will be again posted as high radiation areas and to ensure removal of all personnel from diese areas.

In addition, certain plant areas that have been designated as high radiation areas never did attain radiation levels above 100 millirem per hour, even though they have been classified and treated as such pursuant to the exemption of August 23, 1962.

By reclassifying plant areas, as required, in accord-ance with 20.202(b)(3) of 10 CFR 20, we believe Commonwealth Edison can achieve the desired radiation protection control of the facility with respect to high radiation areas with greater flexibility.

Consonwealth has indicated that the uee of one key is insufficient for access to the increased number of high radiation areas, and that two keys would facilitate maintenance and insure prompt access to high radiation areas in each section of the plant.

Use of the second key would be controlled by the procedures now used for the first key.

Both keys are to be kept in the control room when not in use and will be issued by the Shift Engineer.

A separate log will be kept of the use of each key.

We believe that exemptions' allowing reclassification of high radiation areas and for the use of two keys constitute no significant change in the hazards considerations implicit for the procedures now authorized.

Conclusion We believe that the utilization of the previously accepted substitute pro-visions for the requirements of Paragraph 20.203(c)(2) vith regard to the high radiation areas and the use of two keys for control of access will not result in undue hazard to life or property.

Accordingly, we have concluded that Commonwealth should be further exempted from the provisions of Paragraph 20.203(c)(2) of 10 CFR 20 to the extent that the statements outlined in their letters of October 21, 1963 and April 29, 1964, and telegram of Septe1ber 17, 1964, are applied to the use of two keys and the reclassification of radis-tion areas, provided that the deletion of an area no longer meeting high radiation area criteria shall occur only if the reactor is shutdown or if the radiation level has decreased below 100 millirem per hour for a period of 30 days or more. These exemptions are applied to the operation of the Dresden reactor under License DPR-2, as amended with regard to high radiation areas as defined by the Commission's regulations.

0:fical sigud y Ecgu S. 5:yd Roger S. Beyd, Chief Research & Power Reactcr Safety Eranch Division of Reacter Licensing Date:

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