ML19351G497
| ML19351G497 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/06/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Bryan J UNION ELECTRIC CO. |
| References | |
| NUDOCS 8102240035 | |
| Download: ML19351G497 (5) | |
Text
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LB&1 Rdg DEisenhut BJYoungblood 00cket No.: STN 50-483 ADromerick MRushbrook RTedesco Mr. John K. Bryan RVollmer Vice President TMurley Union Electric Company Dross 1901 Gratiot Street RHartfield, MPA bec: TERA P. O. Box 149 VNoonan NRC/PDR St. Louis, Missouri 63166 OELD L/PDR OIE (3)
Dear Mr. Bryan:
Subject:
Request for Additional Information for the Review of the Callaway Plant Unit 1 - Adden 'um As a result of our continuing review of the Callaway Plant, Unit 1 Addendum, FSAR, we find that we need additional infomation to complete our evaluation.
The specific infomation required is as a result of the Radiological Assessment Branch's review and is presented in the Enclosure.
To maintain our licensing review schedule for the Callaway Plant FSAR, we will need responses to the enclosed request by March 22, 1981.
If you cannot meet this date, please inform us within seven days after receipt of this letter of the date you plan to submit your responses so that we may review our schedule for any necessary changes.
Please contact Mr. Dromerick, Callaway Licensing Project Manager, if you desire any discussion or clarification of the enclosed request.
Sincerely,
.Ib Rcbert L. Tedesco, Assistant Director for Licensing Division of Licensing DiI / 42g
Enclosure:
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Mr. J. K. Bryan Vice President - Nuclear Union Electric Company P. O. Box 149 St. Louis, Missouri 63166 cc: Mr. Nicholas A. Petrick Mr. William' Hansen Executive Director - SNUPPS Resident Inscector/Callaway NPS 5 Choke Cherry Road c/o USNRC Rockville, Maryland 20850 Steedman, Missouri 65077 Gerald Charnoff, Esq.
Shaw, Pittman, Potts &
Trowbridge 1800 M Street, N. W.
' Washington, D. C.
20036 i
4 Mr. J. E. Birk Assistant to the General Counsel Union E'ectric Company P. O. Box 149 St. Louis, Missouri 63166 Dr. Vern Starks Route 1, Box 863 Ketchikan, Alaska 99901 Ms. TrevaHearn, Assistant-General Counsel Misscuri Public Service Commission:
I-P. 0. Box 360 Jefferson City, Missouri.65102 Mr. D. F. Schnell Manager-Nuclear Engineering Union Electric Company P. O. Box 149 St.- Louis, Missouri 63166 4
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REQUEST FOR ADDITIONAL INFORMATION CALLAMAY PLANT ADDENDUM - FSAR
?
DOCKET NO. 50-483 331.0 Radiological Assessment Branch 331.1C In accordance with the recommendations of Regulatory Guide 1.8, the (13.1.3.2)
Assistant Superintendent, Engineer-Radiochemistry, does not qualify as a Radiation Protection Manager (RPM) since he does not presently have the three years of professional experience dealing with radiolo-gical problems in applied radiation prctection encounted at an operating nuclear power station or equivalent. Therefore, please justify the selection of the individual delineated for this position based on his training and experience as shown in section 13.1.3.2 and.
specify, as required, how he will achieve the aforementioned experience,
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prior to the plant being licensed, to qualify as the RPM.
331.2C Based on information contained in the draft document " Criteria for (13.1.2.1)
Utility Management and Technical Competence" it is our position that the Radiation Protection Group be a separate organization from the Chemistry Group.
Your station organization chart (Figure 13.1-3) shows these groups combined. Additionally, in accordance with Regulatory Guide 8.8, it is our position that the Radiation Protection Manager (RPM) should have access to the Assistant Plant Superintendent in radiation protection matters.
In matters relating to radiological health and safety, the RPM has direct responsibility to both employees and management that can best be fulfilled if he is independent of station divisions, such as operations, maintenance or technical support, whose prime responsibility is continuity or improvement of. station operability.
_Your FSAR and proposed Technical Specifications should be revised to l
l reflect how your planned radiation protection program reflects this position.
l
Concurrent to the change request in 331.2 above, Figure 13.1-3 should 331.3C (13.1.2.1) also show that Health Physics technicians and Chemistry technicians become separate groups, be qualified separately as Chemistry and Radia-tion Protection Technicians, and each report directly to their respective Radiation Protection and Chemistry group managers. This change request is also in accordance with the aforementioned draft document.
Please describe your plan to provide backup coverage in the event of 331.4C (13.1.2.1) the absence of the RPM and outline the qualifications of the individual who will act as the backup. The December 1979 revision of ANSI 3.1 specifies that the temporary replacement for an RPM should have a BS degree in science or engineering, 2 years experience in radiation protection, 1 year of which should be nuclear power plant experience, 6 months of which should be on-site.
331.5C Section 13.1.2.3 specifying shift crew composition does not state that (13.1.2.3)
H.P. technician will be onsite at all times (e.g., including oack-an shift and weekends). NUREG-0654 " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparation in Support of Nuclear Power Plants" requires that a radiation pro ~tection technician, whose qualifications are described in ANSI 18.1, shall be onsite at all times. Section 13.1.2.3, as written, would allow a designated member of the shift crew (e.g., reactor operator) to_act as a health physics technic'ian if he is qualified to implement radiation protection It should be noted that this qualification is no longer procedures.
Only an assigned' acceptable to the staff after the reactor is at power.
health physics technician will be acceptable based on new staff requi Therefore, Section 13.1.2.3 should be revised accordingly.
ments.
j 331.6C In accordance with Section 12.5.3.1.3 Airborne Radioactivity Surveys, (12.5.3.1.3) please discuss your radiation protection provisions for installation of temporary flexible ducting and monitoring equipmen_t at the site of maintenance operation and repair activity, if a high potential for airborne radioactivity exists, to assure that 10 CFR Part 20 limits are not exceeded and that exposures are maintained as low as is., reasonably Shieveableduringtheoperation.
331.7C Although table 12.5-2 lists 4 portal monitors in the Health Physics (Table 12.5-2) instrument inventory, the table does not include monitoring devices for hands, shoes and self monitoring equipment normally used when leaving radiation areas. Please describe the monitoring equipment and procedures used for hands, shoes, clothing and skin (e.g. face) moni-toring when leaving potentially contaminated areas and entering unre-stricted areas.
331.8C In accordance with Section 12.5.3.1, the radiochemist section provides (12.5.3.1) services normally provided for by health physics personnel. Picase justify using chemis_ts to perform.this]ervice as compared to qualified
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health physics tecnnicians that are trained and experienced in their.
speciality in accordance with ANSI 3.1 (1978). Your response should be coordinated with question 331.3.
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