ML20037B029
| ML20037B029 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/29/1964 |
| From: | Bower D COMMONWEALTH EDISON CO. |
| To: | Case E US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8009030720 | |
| Download: ML20037B029 (5) | |
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Mr. Edson G. Case
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Docket 50-10
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Dese Mr. Caset
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CU3 JECT: Hirh ?adiation Areas
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Co:x:enwealth Edison Company h-is su0mitted in previous correspondence commencing with July 11, 1961, statements, pmcedures, and substantial supplementary laformation to support a request for exemption fmm paragraph 20.203(c)(2) of 10 Cf 3 20 The requested exemption was granted by the Commission in a letter dated August 23, 1352.
Attacned to our letter of July 11, 1961, was a listing of high radiation areas, Exhibit "A", which *hre established or anticipated at that tine.
Additional h!;h Mistien m :0
. i :5 trm12 od were Ca: 2d in cur letter of Octooer 21, 1963.
Finally, "C" Instrument Room which is located in the northeast corner of the 548' elevation of the reactor enclosure, developed as a high -adiation area subsequent to our October 21, 1963 letter.
Therefore, to clarify this mat +2r, we have attached herewith Exhibit "A" (revised) which lists all those high radiation areas in existence as of April 12,1964, prior to plant shutdown.
In the ensuing interval, Comunnwealth has demonstrated that (1) the procedures exercised at Dresden are safe and practical, and do not change the considerations in the Hazards Summary Report and (ii) the method of access to locked high radiation areas in the manner authorized in the Commission's letter dated August 23,1962, " Locked Hi.fh Radiation Area Precedure", provides an effective control of exposures of plant personnel.
In the light of this experience it appears that it is apprepriate to review again with you the method which we have followed and propose to follow in our Locked High Radiation Area Procedure.
First, it may be noted that our original listing of high radiation areas set forth in our letter of July 11,1961, was 1 ased in part on
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. Mr. Edson G. Case April 29, 1964 anticipated, rather than actual, radiation levels.
ith respect to three of the areas listed *, in Exhibit "A" to that letter, the anticipated high radiation levels never developed, and the actual radiation levels observed in such areas is the best evidence that there is no need to include them in the Incked High Radiation Area Procedure.
Second, there are several locations such as the turbine and other areas where the radiation level exceeds that which is defined in 20.202(b)(3)
(High Radiation Area) only during reactor operation and falls below that level pmmptly after :.t: actor shutdown. This experience indicates the desirability of providing seme flexibility in the Locked High Radiation Area
?recedum which vill nflect changes in plant operatina cenditions.
Third, our experienca also indicates there may be a gradual increase ovar the lifs of the plant in the -ber of aMas or compartments in which the radiatica levels will est th. r.igh radiation area criteria.
Accordin gly,
the locked High Fadiation Area Procedure should provide means for addition of new areas subject to tne same controlled access as those new estaolished.
All of this experience demonstrates the need for flexibility in the Locked High Radiatien Ares Procedure-flexibility which, taking account of changes in observed cenditions, per nits additiens, delstians, ud restorations of areas in the plant where controlled access is required.
In our opinion the procedures which we have followed, and propese to continue in effect, mvide this flexibility necessary for adequate radiation protsction.
3uen pro:sauras require th2 rsn u m2 apprevn
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?rotection Eagineer before an area may be removed from the Locked High hdiation Area Procedure.
If the removal is anticinated to be temporary, such as during reactor shutdown, the srea involved is surveyed after resumption of reactor operation to determine the need for restoring the area to the "Iocked" status.
Our routine surveillance program of all areas in the plant provides assurance that the Radiation Protection Engineer is forawarned of any trends of increasing radiation levels in any particular area. With this forewaming he is enabled to anticipate and adjust his surveillance routines to establish controlled access to any area as the radiation in such area approaches high radiation area criteria.
In our view this type of program is a feasible means of conducting the operations at the plant which are compatible with the need for providing safe conditions for plant personnel and control of radiation exposums.
Condensate Pump Pit, Condensate Domineralizer Resin-regeneration ?com, and Mechanical Vacuum Pump Room.
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, Mr. Edson G. Case April 29,1964 Therefore, Consonwealth mquests persaission to establish High.
Radiation Areas as required; rw:;ulate-access to these areas under the Locked High Radiation Area Procedure s and delete from th's procedure those areas which cease to :neet the High Radiation Area criteria.
'de trust that this request will be granted and that these mattsrs will be discharged to the mutual satisfaction of both interested parties.
Very truly yours, COME:I'iEALTM IDISCN CT'?ANY
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?.t t. (Exhibit " A" (2evi::ed))
Submit ad ud rier ::.?f-r?
me this 4 day of April, 1964 by saic J. 3. 3cwer.
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CoundmwealEdicen Company - Dresden Nuclo<^ Power Stction EXHIBIT "A" (REVISED)
HIGH RADIATION ARCAS Turbine Building 1.
"C" Heater Compartment 2.
"3" Heater Compartnent 3.
" A" Heater Compartment 4
" A" Air Ejector Room 5.
Turbine Pipeway and Condenser Area S.
Condensate Demineraliser ?oco 7.
"B" Air Ejector Room 9.
Turbine 9.
Off-cas Moniter 2.res Poactor nclesure 1.
"A" Reactor Enclosure Drain Tank 2.
"3" ?sactor Enclosure Crain Ter.k 3.
Sub-reactor Room 4
"N' Clean-up Domineralizer Room S.
"3" Clean-uo *:emineralizer 7.cca 6.
?ipoway 7.
'Jnloading Heat Excnanger 3cco 3.
" A" Secondarf Steam Generater ?cem 9.
"3" "acend w/ Cteam Cenerster Eccm 12.
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"3" Second w/ Steam %nerater ?com 12.
Reactor Fefueling Canal and 384' Elevation 13.
Primarf :: rum Compartnent 14 641' Elevation - Persennel and Equipment Hatches to Primary Drum Compartment 15.
Scram Dump Tank Roots 16.
"C" Instrument Foom 17.
West Unassigned Foom - 532' Pad Waste Facility 1.
Pilters - Basement 2.
" A" Centrifuge Building 3.
"B" Centrifuge Building April 12, 1964
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