ML20011A245
| ML20011A245 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/01/1981 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 ULNRC-521, NUDOCS 8110080367 | |
| Download: ML20011A245 (23) | |
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UNION ELECTRIC COMPANY 1901 GRATIOT sTRKET ST. Louis, MissouMI October 1, 1981
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OON,LD F..CHN.Lt.
P. O. Non 34.
er.i. Oui..mi..c.um.....
Mr. Harold R.
Denton Director.of. Nuclear-Reactor Regulation-U. S.-Nuclear Regulatory Commission Washington,-D.C.-20555 ULNRC 521
Dear Mr. Denton:
DOCKET NUMBERS 50-483 AND 50-486 CALLAWAY PLANT, UNITS 1 & 2-FINAL SAFETY ANALYSIS REPORT RESPONSES TO NRC 00ESTION 260.71C The attached is a response to your question 260.71C which was transmitted by a letter from R. L. Tedesco to J. K. Bryan dated Augu'st 12, 1981.
Portions of this response were discussed'with Dr.
G.
E. Edison, Mr. J.
Spraul and Mr. C.
Block of your staff in a telecon September 29, 1981.
. Based on the attached response, Union Electric will revise our position on Regulatory Guide 1.33, Revision 2,
" Quality Assurance Program Requirements.(Operation)", currently stated ia the Callaway FSAR Site Addendum, Appendix 3A.
The revised position will include
,an added sentence which states, "The activities described in Appendix'A (to. Regulatory Guide 1.33) in Sections 7e, 7f, 7g, 8, 9, and 10 which relate to the health physics program described in the Callaway Radiation Protection Plan are not considered to be safety related and are exempt from'the. Operations QA program.
The administrative controls of'the health physics program are discussed in the Union Electric response to NRC question 260.71C which is discussed in the Callaway Site Addendum ' Responses to NRC
-Questions'".
This.information and the attached response are hereby
!.ncorporated into the callaway Application and will be incorporated into the next revision of the Callaway FSAR Site Addendum.
Very truly yours, O
pesA ck,6lh Donald F.
Schnell 73ooI
-ACP/It.h.
3 Attachments
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ui 8510000367'S11001 PDR ADOCK LA.
05000483:
(PDR f
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. STATE'OF' MISSOURI __)
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ss CITY oF sT. Louis')
Donald F.
Schnell', of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric company; that he has read the foregoing document and knows the content thereof; that he has-executed the same for and on behalf of said company with full power and authority to do so; and that the-facts therein stated are true and correct to the best of his knowledge, information and belief.
By Donald F.
Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this 1st day of October, 1981 y
y V BARE \\RA J. PFAFF NOTAR1r PUBUC, STATE Of ?/10500R1 MY COMMISSION EX? IRES APRIL 22. 1935 ST. LOUIS COUNTY
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ces Glenn'L. Koester
_Vice President.
Operations
, Kansas Gas & Electric.
P.O. Box 208
. Wichita, Kansas 67201 John E.
Arthur Chief Engineer Rochester Gas &' Electric Company HB9 East Avenue
-Rochester, New. York 14649 A. V. Dienhart Vice President Plant Engineering and Construction
' Northern States Power 414:Nicollet Mall Minneapolis, Minnesota 55401 Donald T. McPhee
-Vice President Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, Missouri 64141 Gerald Charnoff, Esq.
Shaw, Pittman,-Potts & Trowbridge 1800 M.
Street, N.W.
Washington, D.C.
20036 Nicholas A.
Petrick Executive Director' SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 W.-Hansen Callaway Resident Office U.S.. Nuclear Regulatory Commission RR#1-Steedman',- Missouri 65077 Gordon Edison Project Manager-SNUPPS U.S. Nuclear Regulatory Commission
. Washington, D.C.
20555 L
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g Union Electric's Response to NRC Questions 260.71C
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-Item 260.71C' Section 17.1.2.2 of the standard format (Regulatory Guide 1.70) requires the identification of safety-related structures' systems, and components
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controlled by the~OA. program.
You are requested to supplement and clarify Table 3.2-1 of the Callaway FSAR in accordance with the following:
.a.
The following items do not appear on FSAR Table 3.2-1.
Add the appropriate items to the table and provide a
-commitment that the remaining items are subject to the Pertinent requirments of the FSAR operational quality assurance program or justify not doing so.
- a.1 Safety-related masonry walls (IE Bulletin 80-11).
Callaway Position: There are no safety related masonry walls utilized in the Callaway-design.
Non Category-I walls are included in Section 17D of the D&C QA Program and Table 17.D.1 of the Operating Quality Assurance Manual.
a.2
. Biological shielding within the fuel bldg.
bldg.,
l-control bldg., and reactor bldg.
Callaway Positicn: Included as part of Section 8.1 of Table 3.2-1.
a.3 Miosile barriers within the fuel bldg., aux. bldg.,
control b1dg., diesel-generator bldg., essential service water pump house.
l Callaway Position: Added to Safety Table 3.2-1 Sections 3.0 and 8.1, Rev.
7.
Also, permanent shields are part of Section 8.0, Table 3.2-1.
l a.4 Spent fue.t pool li~ner.
Callaway Position: In Table 3.2-1, Section 8.2.
(Our position is that this item is not safety related).
a.5 Refueling machine.
Callaway Position: Already in Table 3.2-1 Section 3.0.
(Our position is that this item is not safety related),
a.6 Spent fuel. handling tool.
Callaway Position: Added to Table 3.2-1 in Rev. 7 Section 3.0.
1 260.71C-l'
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a.7 Radiation shielding doors.
Callaway' Position: AlreEdy in' Table 3.2-1, Section 8.2.
(Our position is that this-item is not safety related).
a.8 Radiation monitoring (fixed and portable).
Callaway Position: It is Union Electric's position that items 8-16 of 260.71c(a) should not be included in Table 3.2-1, or be subject to the requirements of the operational quality assurance program.
Union Electric does feel that NUREG 0761, " Radiation Protection Plans for Nuclear Power Reactor Licensees" Draft Report, March 1981, which is presently in draft form and out for comments, provides the necessary guidance in formulating the Callaway Radiation Protection Plan.
The Callaway Radiation Protection Manual (CRPM) and Radiation Protection (RP) procedures together will constitute the Callaway Radiation Protection Plan (CRPP). outlines the proposed CRPM, The outline lists the major areas to be addressed in the manual.
It is intended that the CRPM will be a concise statement of the Callaway Radiation Protection Plan that can be understood by all plant personnel.
The manual will be written in general and brief terms with the specifics of the plan to be addressed in the implementing RP procedures.
The Callaway Radiation Protection Plan will be developed in accordance with applicable regulatory requirements, regulatory guides, industry standards,'and accepted p
industry practices, and will incorporate sufficient managerial and administrative controls to ensure that a high level of radiation protection is provided.
outlines the implementing procedures.
.These procedures have been broken down into areas as recommended by the NUREG.
It is intended that administrative controls will be 260.71C-2 E
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implemented via incorporation into administrative and programmatic level "s,
procAdures which will receive onsite I
Reviewz Committee (Plant Review Group) review and approval To verify that-radiation protection functions are being performed as required and that a high level of radiological safety l
is maintained, pericdic review and audit of the radiation prott: tion program will be performed by an independent audit group of Union Electric Nuclear. Engineering (i.e.,
.the corporate health physics group or their consultant).
The General Office Quality Assurance Group will review the activities and Audit program of the independent audit group to assure that appropriate audit procedures are established and implemented.
The performance of audit and review of the areas identified in items 8-16 to assure program effectiveness is consistent with the position of NUREG 0761.
The audit program will be conducted in accordance with established auditing principles:
1.
use of inspectors / auditors with training and expertise in the area being audited 2.
use of audit personnel with no responsibilities or " vested interests" in the areas being reviewed 3.
documentation and review by management of audit results and findings 4.
performance of corrective or followup actions as appropriate Additional quality assurance for items 8-16 of 260.71c(a) are built into RP procedures utilizing quality
-assurance provisions from regulatory guides.
An example is the respiratory protection program.
Quality assurance for procurement of respiratory equipment is maintained
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260.71C-3
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SNUPPS-C by the purchasing of only NIOSH certified equipment.
In complying y,
withl Reg. Guide 8.15, additional quality ass.urance is established.in the r'espiratory protection program.
In summary, the program described above will meet or exceed the equivalent applicable portions of the Union Electric operational quality assurance program, a.9 Radioactivity monitoring (fixed and portable).
Callaway Position: Refer to a.8 above.
a.lO Radioactivity sampling (air, surfaces, liquids).
Callaway Position: Refer to a.8 abavo.
a.ll Radioactive contamination measurement and analysis.
Callaway Position: Refer to a.8 above.
a.12 Personnel monitoring internal (whole body counter) and external (TLD system).
Callaway Position: Refer to a.8 above.
a.13 Instrument storage, calibration, and maintenance.
Callaway Position: Refer to a.8 above.
a.14 Decontamination (facilities, personnel, equipment).
Callaway Position: Refer to a.8 above.
a.15 Respiratory protection, including testing.
Callaway Position: Refer to a.8 above.
a.16
. Contamination Control.
Callaway Position: Refer to a.8 above.
a.17 Radiation shielding (permanently installed).
Callaway Position: Included as part of 8.0 of Table 3.2-1.
1 a.18 Accident-related meteorological data collection equipment.
4 260.7.r-4
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Callaway Position:-Meteorological instrumentation is calibrated periodically to assure the validity of the meteorological data
_as required,by Technical Speci'fications.
Calibration of this instrumentation will be subject to the pertinent requirements of the Appendix B Quality Assurance Program.
Procedures for use of the instrumentation under post-accident c
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conditions (i.e.,
those conditions covered by-the Emergency Plan) will be controlled by the pertinent portions of the Appendix B Quality Assurance Program.
a.19 Expendable and consumable items necessary for the functional performance of safety-related structures, systems, and omponents (weld rod, fuel oil, boric acid, snubber oil, etc.).
Callaway Position: As stated in FSAR Site Addendum Section 17.2.2, related consumables utilized'in safety-related structures, systems, and components, although not listed in Table 3.2-1, are also under the control of the Operational Quality Assurance Program.
a.20 Roof drains and parapets of buildings which house safety -
related equipment.
Callaway Position: Not safety related--no credit is taken for these in FSAR safety
- analyses, a.21 Site drainage system including grading, culverts,.and channels.
Callaway Position: Grading and channels of the Callaway Drainage system are included in the Union Electric Quality Assurance Program.
The culverts of the system are considered blocked for the Callaway probable maximum precipitation analysis and therefore is not included in the quality assurance program.
a.22 Steam generator = (primary and secondary).
Callaway Position: Already in Table 3.2-1, Section 1.1.
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SNUPPS-C a.23 Steam geneator piping located inside containment'.
Callaway Position: Already included as part of Sections 5.1 and 5. 2 of Table 3. 2-1.
a.24 Valve operators for all safety'.related valves.
Callaway Position:.See 4th paragraph of FSAR Section 3.2.
The P & ID's for safety related systems define system boundaries and those components which are safety
- related, a.25 Motors for all safety-related pumps.
Callaway Position: See 4th paragraph of FSAR Section 3.2.
The P & ID's for safety related systems define system boundaries and those components which are safety related.
b.
The following items from FSAR Table 3.2-1 need expansion and/or clarification as no' ed.
Revisc the list as indicated or justify not doing so.
1.
Identify the safety-related instrumentation and control systems to the same scope and level of detail as provided in Chapter 7 of the FSAR.
(This can be done by footnote).
Verify that this includes I & C for:
b'.l(a)
Containment spray system.
Callaway Position: Included as Section 1.5 of Table 3.2-1.
Also see the 4th paragraph of FSAR Section 3.2.
t b.l(b)
Containment cooling system.
Callaway Position: Included as Section 1.6 of Table 3.2-1.
Also see the 4th paragraph of FSAR Section 3.2.
b.l(c)
Containment hydrogen control system.
Callaway Position: Included Section 1.8 of Table 3.2-1.
Also see the 4th paragraph of FSAR Section 3.2.
b.l(d)
Containment pressure indication.
Callaway Position: Included'as part of Section 9 of Table 3.2-1.
Also see the 4th paragraph of FSAR Section 3.2.
260.71C-6
I SNUPPS-C b.l(e)
Condainment water. level indication.
O' Cal'laway Positions.Part of Section 9 of Table 3.2-1.
Also see the 4th paragraph of FSAR Section 3.2.
b.l(f)
Containment hydrogen indication.
Callaway Position: Included as part of Section 1.8 of Table 3.2-1.
Also see the 4th paragraph of FSAR Section 3.2.
2.
For the systems shown below, expand the list in Table
.3.*2-1 to include the indicated components under the pertinent-10 CFR 50 Appendix B quality assurance requirements or verify that they are included as part of the components already listed.
b.2.1.5 Containment spray system containment sump.
Callaway Position: Part of Section 8.1 of Table 3.2-1.
b.2.1.6 Containment cooling system.ductwork.
Callaway Position: See 4th paragraph of Section 3.2.
b.2.1.8, Containment hydrogen control system piping and valves.
Callaway Position: See 4th paragraph of Section 3.2.
-a b.2.2.7 U'ltimate heat sink retention pond sicpes retention pond rip rap.
Ca'llaway Position: Part of Section 2.7 of Table 3.2-1.
c.
- Enclosure 2 of NUREG-0737, " Clarification of TMI Action
' Plan Requirements" (November 1980) identified numerous items that are safety-related and appropriate for OL l application and therefore should be on Table 3.2-1.
These items are listed below.
Add the appropriate items to Table 3.2-1 and provide a commitment that the remaining items are subject to the pertinent re'quirements of FSAR operatior71 QA program or justify
.not doing so.
col Plant safety -parameter display console.
.Callaway Position: Not avai,lable yet--appropriate quality programs will be applied.
c.2
. Reactor coolant system vents.
Callaway Position: Included as part of 1.1 of Table 250.71C-7
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c.3-
. Plant shielding.
Callaway Position: None that is not permanently installed.
(See item a.2).
c.4 Post accident sampling capabilities.
Callaway Position: The equipment used for inplant post accident sampling is not safety related and therefore is not included in Table 3.2-1.
The programs which control the monitoring activities are administered to meet the requirements of 10CFR20.
a
- c.5 -
Valve position indic'ation.
Callaway Position: Part of Section 3.1 of Table 3.2-1.
c.6 Auxiliary feedwater system.
Callaway Position: Section 5.4 of Table 3.2-1.
c.7 Auxiliary feedwater system initiation and flow.
Callaway Position: Part of Section 5.4 of Table 3.2-1.
c.8 Emergency power for pressurizer heaters.
Callaway Position: Part of Section 1.1 of table 3.2-1.
c.9; Dedicated hydrogen penetrations.
,Callaway Position: N/A for Callaway.
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. Containment isolation dependability.
Callaway Position: Part of Section 1.7 of Table 3.2-1.
c.ll A.ccident monitoring instrumentation.
Ca'llaway Position: Part of Section 9.0 of Table 3.2-1.
c.12 Instrumentation of detection of inadequate core-cooling.
Callaway Position: See 4th paragraph of Section 3.2.
c.13 Power supplies for pressurizer relief valves, block valves, and level indicators.
Callaway Position: Part of Section 1.1 of Table 3.2-1.
260.71C-8 L
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' Automatic.PORV isolation.
Callaway Position': See 4th paragraph of Section 3.2.
c.15.
Automatic trip of reactor coolant pumps.
zCallaway' Position: N/A'for Callaway.
c.16' PID controller.
Callaway Position: Not functional in Callaway design.
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c.17~
Anticipatorf reactorLtrip on. turbine trip.
Callaway Position: Part of Section 9.0 of Table 3.2-1
'for the Reactor Protection System.
The. remainder of the system is non-IE but meets special criteria as defined
. in the FSAR, Chapter 17.
.c.18
. Power'on pump seals.
Callaway Position: Included as part of Section 2.3 of Table 3.2-1.
'c.19-Emergency plans (and related equip).
Callaway Position: Emergency Plans are not considered safety related and are therefore not
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included in Table 3.2-1.
- However, the Emergency Plan is.a part of the FSAR and is therefore distributed and controlled according to an existing
/-
Union Electric Nuclear Engineering Quality Assurance procedure.
It will continue to be so controlled during the operating phase of the plant.
c.20
- Equipment and other items associated with the emergency support facilities.
'Callaway Position: These are not considered safety related and'are therefore not included in Table 3. 2-1.
Appropriate engineering and reference documents (i.e., FSAR, prints, procedure manuals) will be placed in Callaway emergency response facilities.
The controls:and update of reference documents'will be handled in accordance with provisions of the existing'Callaway Plant Document Control-Program.
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'260.71C-9.
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- p c.21 Inplant Ig, radiation monitoring.
Callaway Position: Inplhnt iodine monitoring is not considered. safety related and is-therefore not included in Table 3.2-1.
Provisions for monitoring of inplant iodine' levels are incorporated within the scope of the Callaway Radiation Protection Plan as described in Union Electric's response to question 260.71C, items A.8-A.16.
The referenced independent audit group will review the radiation protection program to verify that adequate equipment procedures and training of personnel is provided to enable accurate quantification of o
inplant. iodine concentrations during emergency situations.
c.22 Control room habitability.
Callaway Position: Section 7.1 of Table 3.2-1.
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-Attachment 1 PROPOSED OUTLINE ~OF CALLAMAY PLANT RADIATION PROTECTION MANUAL
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Introduction II.
Management Policy
'III.
Radiation Protection Organization and Functions IV..
' Radiation Protection Organization and Qualifications V.-
Dose Control-VI.
Radioactive Material (RAM) Control VII.
Surveillance
-VIII. -Review and Audit IX. -
Radiation Protection It ?ident Analysis X.-
Radiation Work Practices
- List-of Implementing Procedures XI.
J NOTE:
The instrumentation section has been deleted from this manual.
It will'be included in detail in the implementing procedurec.
The employee will receive adequate information-during General' Employee Training.
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IMPLEMENTING PROCEDURES 1.
Dose Control as presented in procedural details, on page 25-28 of NUREG 0761, would be presented as follows:
ALARA RWP's Personnel-Monitoring Area Posting Bioassay Use of. Protect.ve Clothi ng d
Each of the above areas would have its own administrative procedure describing specifics or methods not addressed in g
the CPRPM.
The number of individual implementing l
. procedures tied to each administrative procedure would vary.
See Fig. 260.71C-1.
2.
Radioactive Material (RAM) Control as presented in a procedural detail, on page 31-32 of NUREG 0761 would have an administrative procedure with individual implementing procedures tied to it.
See Fig. 260.71C-2.
3.
Surveillance.as. presented in procedural details, on pages 37 of NUREG 0761, would have an administrative procedure with individual implementing procedures.
See Fig. 260.71C-3.
4.
Instrumentation as presented ir. procedural details, on pages 39-40 of NUREG 0761 would be presented as follows:
Inventory Calibration
+
Operation Each of the above would have an administrative procedure with an individual implementing procedure for inventory and an individual implementing procedure for each type of instrument under calibration and operation.
This would include portable and fixed instruments.
See Fig. 260.71C-4.
-5.
i
.Rev ew and At'dit as presented in procedural details, on page 4I of-NUREG 0761, would have an administrative procedure with individual implementing-procedures.
6.-
Radiological Protection. Incident Analysis as presented in procedural details, on page 43 of NUREG 0761, would have an administrative procedure with individual implemanting procedures for each possible incident.
See Fig. 260.71C-5.
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' IMPLEMENTING PROCEDURES (Cont.)
. 7.
Radiation Work Practices as presented in procedural
-details, on page 44 of' NUREG 0761, would have an administrative procedure with-individual implementing
. procedures tied to it.
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w SNUPPS-C FIGURE 260.71C-1 DOSE CONTROL I
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SNUPPS-C FIGURE 260.71C-3 SURVEILLANCE I
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SNUPPS-C FIGURE 260.71C-4 INSTRUMENTATION I
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