ML20054C113
| ML20054C113 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/16/1982 |
| From: | Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Kodner J KODNER, J.L. |
| References | |
| ISSUANCES-OL, NUDOCS 8204200055 | |
| Download: ML20054C113 (5) | |
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April 16,1982 Mr. Jan L. Kodner, Esq.
m 173 W. Madison Street r-
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Suite 1004 9
? 'c}cS ; @ I 11-Chicago, Illinois 60602 S
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9 In the Matter of ga g'9'0.1 j
Illinois Power Company, et al.
2 9
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/2 (Clinton Power Station, Unit 1) 9 Docket No. 50 461 OL AN
Dear Mr. Kodner:
N Enclosed for your consideration is an NRC Staff information response to Prairie Alliance Contention 12. This, coupled with the Staff's prior response to discovery regarding this contention, should serve as a basis for any discussions on this issue during our scheduled meeting on April 28, 1982. With me at that time will be Julian H. (Herb) Williams, the NRC Project Manager for Clinton Station.
Sincerely, Richard J. Goddard Counsel for NRC Staff
Enclosure:
DISTRIBUTION As Stated Goddard Gutierrez Reis cc:
(w/ enclosure)
C unningham/Murray Sheldon A. Zabel, Esq.
Christenbury/Scinto Philip L. Willman, Esq.
FF (2)
Reed Neuman, Esq.
NRC Docket File: PDR/LPDR J. Miller 21 6 M
JHWilliams/C. Grimes 340
/
7 0FC :0 ELD
- 0 ELD 3
_____:____ _______:_______ '4 NAME :RGoddard/dkw EJReis L :
- : / /
DATE :04/[_6/82_____:___ f_______:____h/82
- 04/t 8204200055 820416 gDRADOCK05000g
Contention 12.
Applicants have failed to provide a procedure for preoperational testing of the functional capability of the spent fuel transfer system which provides a reasonable assurance of safety'.
The spent fuel transfer tube is of unproven design for the CPS design.
In the absence of additional testing, the safe operation of the spent fuel transfer system is questionable.
Additionally, there is no assurance that occupational exposure to personnel will be maintained as-low-as-reasonably-achievable for the operation and maintenance of the spent fuel transfer system.
L RESP 0ftSE The f1RC staff has reviewed the transfer tube design, operating features, and initial testing program and has concluded that the system meets current flRC requirements and is acceptable.
(See fiUREG-0853, Sections 9.1.4, 12.3.2, and 14)
Shielding for and access t9 the spent fuel transfer system were compared with the staff's position tal stated in Table 5-1 in fiUREG-0761, " Radiation Protection Plan for fluclear Power Reactor Licensees." The applicant has provided shielding for the spent fuel transfer tube to reduce the exposure rate to a few mR per hour at all points outside the shield where acess is possibl e.
In addition, he has identified two areas within the shielded enclosure where access could be gained by the removal of massive hatches.
The applicant has committed to providing a fail-safe interlock in the fuel transfer system so that the fuel can not be loaded into the spent fuel transfer tubes When the hatches are removed and to providing radiological warning signs that state "potentially lethal radiation fields are possible inside during fuel transfer" according to the staff's position.
The staff has concluded that the applicant has performed an appropriate.,
estimate of the dose rate at the operator's location, in accessible areas of the dry-well, in the vicinity of the refueling pool bellows, and outside the shielding surrounding the spent fuel transfer tube. This conclusion was based on the applicant's use of conservative source terms for the spent fuel assembly and their use of standard calculating techniques employing well known computer codes.
(a) Table 5-1 states that all accessible portions of the spent fuel transfer tube must be shielded during fuel transfer. Use of removable shielding for this purpose is acceptable. This shielding shall be such that the resultant contact radiation levels shall be no greater than 100 rads per hour. All accessible portions of the spent fuel transfer tube shall be clearly marked with a sign stating that potentially lethal radiation fields are possible during fuel transfer.
If removable shielding is used for the fuel transfer tube, it must also be explicitly marked as above.
If other than permanent shielding is used, local audible and visible alarming radiation monitors must be installed to alert personnel if temporary fuel transfer tube shielding is removed during fuel transfer operations.
The applicant is required by 10 CFR 20.201(b) to perform dose rate measure-ments to verify that actual dose rates during fuel transfer 'are in accor-dance with design dose rates. The applicant has committed to make, as appropriate, shielding or procedural modifications to ensure that occupation doses are ALARA.
In the staff's review, a question was asked about the radiation protection
. features of the spent fuel transfer tube. The applicant responded in.
Amendment 7, dated September 1981. This question and response is attached.
The Standard Technical Specification for BWR/6's covers the inclined fuel transfer system and provides additional assurance that the system will be operated in a safe and acceptable manner. The purpose of the specification is to control personnel access to those potentially high radiation areas immediately adjacent to the system and to assure safe operation of the system.
Section 3.9.12 includes requirements that must be met before the system can be operated.
In addition, there are surveillance requirements that are performed to verify the safety and radiation (ALARA) features.
Regulatory Guide 1.68, Appendix A, paragraph m indicates that appropriate tests should be conducted for equipment and components used to handle irradiated fuel to demonstrate that they will operate in accordance with design. The initial testing of the spent fuel transfer system to be performed is described in FSAR s,ection 14.2.12.1.10 " Fuel Handling and Vessel Servicing Equipment." Based upon a review of the " Initial Test Program" including FSAR section 14.2.12.1.10, the staff has concluded that the initial plant test program meets NRC requirements and is acceptable.
Therefore, based upon the staff's review of the fuel transfer tube design,
. operation, shielding, administrative procedures, and testing the staff concludes that the system meets NRC requirements and is acceptable.
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I CPS-FSAR AMENDMENT 7 i
SEPTEMBER 1981
-f 471.08 (12.3.1.9.1)
It is our position that all accessible portions of the spent fuel transfer tube and canal must be shielded during. fuel transfer such that contact radiation levels are less than 100 rads per hour.
The.use of removable shielding for this purpose is acceptable.
All accessible portions of the spent fuel transfer tube must be clearly marked with a sign stating that potentially lethal radia-tion fields are possible during fuel transfer.
If other t'h'H5 p'erm'anent shielding is used, local audible and yisible. alarming.. radiation monitors,must.be installed to alert;p.ersonnel if temporary _ shielding is removed duri.ng
,-i, fuel transfer: operations.
Outline your.pr.o-cedures*for implementing this positi'on.
(see Regulatory Guide 8.8, Section C.2.a(1)
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RESPONSE
The spent fuel assemblies are..the strongest radiation sources in the station.
Special sh'ielding and other design features e
are provided, as suggested-in Regulatory Guide 8.8, Section
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C. 2.a (1), for the transfer of the spent fuel asse'mblies within the station, with the objective of' minimizing the dose and the potential for inadvertent exposure to plant personnel.
Following is a description of such design features.
a.
The fuel assemblies.are moved under water in such a way that there is sufficient' water shielding at all
.s times to reduce the dose rate at the operator location to a few mrem /hr.
b.
An area radiation monitor is provided on the refueling platform and is interlinked.with the crane hoist.
The monitor acts to stop the upward movement of the hoist when the area radiation level exceeds a predetermined value.
(See Subsection 12.3.4.)
c.
In the vicinity of the refueling pool bellows, the water or concrete shielding is'not' sufficient to protect the people occupying certain areas of the drywell.
Permanent lead shielding.is provided in this area, which is 4 inches thick, encased in stainless steel, andIcovers a 180* sector around the fuel transfer gate.
(See Figure 12.3-63.)
With this shielding in place permanently, the dose rates in the accessible areas of the drywell
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will not' exceed 16 mrem /hr when the fuel assembly is passing ove'r the bellows.,
Q&R 12-5 d
t CPS-FSAR AMENDMENT 7 SEPTEMBER 1981 l
(471.08 Cont'd) i d.
The fuel transfer-tube is shielded on all sides with concrete and/or steel shielding, as shown in. Figure ei 12.3-63, such that the contact dose rates on the shielding i
are limited to a few mrem /hr.
e.
There are two accessible areas within.th'e transfer tube shielding envelope, one in the containment building and the other in.the fuel building, as shown in Figure 12.3-63.
There are radiation monitors with available and visible alarms in this area.
Access can be gained
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to these areas only through the removal of massive hatches.
Access to these areas is administratively controlled.
The following features are provided at the entrances
~to these areas to protect personnel from an inadvertent high exposure while they occupy these areas.
(i)
Signs are posted stating 'that potentially lethal radiation fields are possible inside during fuel transfer.
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(ii)
Interlocking mechanisms are provided between these hatches and the fueli transfer tube operating mechanism, such that the power to the transfer tube mechanism is cut off when either one of the hatches is open.
(See revised Subsection 12.3.1.9.1 and revised Figure 12.3-63.)
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Q&R 12-6 e