ML19340A947
| ML19340A947 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/23/1962 |
| From: | Case E US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19340A946 | List: |
| References | |
| NUDOCS 8009100783 | |
| Download: ML19340A947 (3) | |
Text
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HAZARDS ANALYSIS BY THE RESEAROI AND POWER REACTOR SAFETY BRANCH D7 VISION OF LICENSING AND REGULATION IN THE MATTER OF COMMONWEALTH EDISON COMPANY EXEMPTION FR0t1 SECTION 20,203(C)2 0F 10 CFR 20 Introduction The Commonwealth Edison Company has requested, by letter dated July 11, 1961, August 9,1961, and April 17, 1962, that operation of the Dresden reactor be exempted from Paragraph 20.203(c)-2 of 10 CFR 20.
This Section of the Commission's regulations concerns caution signs, labels, and signals, and specifically requires that, "Each hi,n radiation area shall be equipped with a control device which shall either cause the level of radiation to be reduced below that at which an individual might receive a dose of 100 milli *em in one hour upon entry into the area or shall energize a conspicuous visible or audible alarm signal in such a manner that the individual entering and the licensee or a supervisor of the activity are made aware of the entry.
In the case of a high radiation area established for a period of 30 days or less, such control device is not required."
Evaluation Commonwealth, in their letter of April 17, 1962, has outlined provisions which they believe are an adequate substitutt for the requirements of paragraph 20.203(c)-2.
They note that the high radiation areas are confined within the plant structures and within shielded compartments.
Access to the high radiation areas are regulated by rigid procedures.
The equipment required in the implementation of high radiation area control includes a series of locks and keys.
During plant operation only one key is available.
During shutdown periods, three keys are available.
One open high radiation area exists adjacent to the high pressure turbine.
Commonwealth has indicated that a wire mesh fence will be erected to encompass the 100 mrem radiation zone.
The fence will be provided with a locked gate; however, construction of the fence will be such that it can j
be removed for turbine maintenance during shutdown periods.
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The procedural safeguards are based upon all high radiation areas being locked at all times except as requit ed for necessary inspections.
The l
specific controls for entry, as list :d in the April 17 letter, are as follows:
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(1) The keys to locks for high radiation areas are the responsibility of the Shift Engineer.
The Shift Engineer is a member of management and holds full responsibility for the safe and proper operation of the plant during his assigned shift.
(2)
During any time the plant,is in operation the one key available is under the control of the Shift Enginee r.
-During shutdown periods the other two keys may be in the possession of some other plant supe rvisor.
(3)
Access to high radiation areas at any time is not permitted unless authorized by the Shift Engineer.
(4)
In addition to the receipt of an authorization to enter a high radiation area and the special key, the individual must contact the Shift Engineer, or his designated alternate in the control room, immediately prior to entry into and immediately upon exiting from.the high radiation area. These calls are recorded on a log sheet and also the time at which the key was obtained and returned.
Said requirements operate as a method of timekeeping and serve as a safety check in the event an individual should become ill or physically injured while present in the high radiation area.
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All personnel entering areas of unknown radiation levels are required to carry radiation survey instruments.
(6)
As a routine operation, personnel open the locked doors to the high radiation areas and proceed only into the shielded labyrinth to listen for abnormal sounds, especially those produced by steam leaks or malfunctioning equipment.
These entries are usually made on a once per day frequency and are limited to a few minutes duration.
Occasionally, conditions within a high radiation area will necessitate more detailed examination.
Operating personnel request a radiation survey of the area by the radiation protection personnel before undertaking further exposure.
This work is all under the direct supervision and with full knowledge of the Shift Engineer.
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3 (7) liigh radiation areas are not surveyed for radiation levels on a routine basis. Spot checks are made at the outside surface of the compartment doors only.- Special surveys of the interior of the compartments are made only upon instruc-tions from the Radiation Protection Engineer or,when required to permit work to be performed in 'the compartment.
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All surveys performed by radiation protection personnel are
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reported on special record. forms which are serially numbered and filed with all permanent radiation protection records.
Unusual or abnormal conditions cre referred to the Radiation Protection Engineer and the Shift Engineer.
(9)
In the event a fuel element leak occurred, the radiation monitors at many points would indicate this increase, in addition to those monitoring the air ejector effluent.
The Operators and the Shift Engineer would be aware of 4
any increase and therefore permission for entry would be refused and the key to the air ejector compartment or other affected high radiation area withheld until the area was surveyed by radiation protection personnel.
Conclusions We believe the statements, contro's and equipment described in Commonwealth s letter of April 17, 1962 are an adequate substitute for the requirements of paragraph 20,203(c)-2 of the Commission's re gulations,
In our opinion, utilization of these substitute provisions will not result in undue hazard to life or property.
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Accordingly, we have concluded that Commonwealth shoulc be exempted t
from the provisions of paragraph 20.203(c)-2 of 10 CFR 20 to the extent that the statements, controls and equipment described in their letter of I
April 17,1962 are applied to the operation of the Dresden reactor under License DPR-2, as amended with regard to high radiation areas as defined
=g by the Commission's regulations.
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Edscn G. Case, Assistant Director Fs:llities Licensing Division of Licensing and Regulation Date:
AUG 2 31962 D**D
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