ML20128E340

Responds to 850318 & 0404 Requests for Addl Info Re Health Physics Program Summary & Total Activity for Neutron Startup Sources for Storage Only.Startup Source Drawing Number Is 112C3666 & GE Model 1500 Cask Will Be Used

ML20128E340
Person / Time
Site:	Nine Mile Point
Issue date:	04/19/1985
From:	Mangan C NIAGARA MOHAWK POWER CORP.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
(NMP2L-0390), (NMP2L-390), NUDOCS 8505290355
Download: ML20128E340 (5)

Text

{

l 0

T. _ l Y NIAGARA NUMOHAWK NIAGARA MOHAWK POWER CORPORATION /300 EPIE BOULEVARD WEST SYRACUSE, N Y.13202/ TELEPHONE (315) 4741511 April 19,1985 (NMP2L 0390)

Mr. R. W. Starostecki, Director U.S. Nuclear Regulatory Commission Region I Division of Project and Resident Programs 631 Park Avenue King of Prussia, PA 19406 RE: Nine Mile Point Unit 2 Docket No. 50-410

Dear Mr. Starostecki:

On March 18 and April 4, 1985, Mr. Thomas Thompson of the Region I staff requested additional information relevant to the Nine Mile Point Unit 2 Byproduct Material License (NRC Control No.03-489).

Mr. Thompson requested the following information:

1. A general summary of our Health Physics Program, pertinent to storage and control of the usage of the licensed material; leak testing and radiation levels in nearby unrestricted areas.

- 2. Total activity for the neutron startup sources (for storage only).

Attached is our response. Additionally, Mr. Thompson requested the GE drawing number for the startup source and the cask model number. The applicable drawing is numbered ll2C3666. The cask we will use is a GE model 1500 cask.

Very truly yours, 8505290355 850419 PDR ADOCK 05000410 PDR F

C. V. Mangan Vice President Nuclear Engineering and Licensing i

JM/mf  !

xc: R. Gram, NRC Resident Inspector Project File (2) .

l bb $

c1) Health Physics Program

- A. . Program Objectives The .three basic objectives of.the Health Physics Program at Nine ,

. Mile Point are to:

~

• Protect station personnel

• Protect the public

• Protect the station f

Protection of personnel means. surveillance and control over the internal and external radiation exposure of personnel and main-taining the exposure of all personnel within permissible limits, and as low as reasonably achievable in compliance with applicable regulations and license conditions.

4 Protection of the public means surveillance and' control over all station conditions and operations that may affect the health and 1 safety of the public. It includes.such activities as radioactlye c gaseous, liquid and solid waste disposal and the shipment of radioactive materials. It also involves conducting an environ-

. mental radioactivity monitoring program and maintaining an effective; emergency plan.

Protection of the station means the continuous determination and evaluation of the radiological status of the station for operational safety and radiation axposure control purposes. This work is done in order to warn of possible detrimental changes and exposure hazards, to determine changes or improvements needed and to

note trends for planning future maintenance work.

The program organization is as follows: .

The General Superintendent - Nuclear Generation is responsible for the' protection of all persons against radiation and for com-pliance with NRC regulations and license conditions. This respon-l sibility is in turn shared by all supervisors. Furthermore, all l personnel are required to work safely and to follow the regulations, p rules and procedures that have been established for their protection.

The Superintendent of Chemistry and Radiation Management (Radiation Protection Manager - RPM) establishes the Health Physics Program l

j for NMP-2 that.is designed to assure conpliance with applicable regulations,-licenses and regulatory guides. He also provides technical guidance for conducting this program, audit 5.the effec-g-

tiveness and the result'of the program and modifies it as required.

He also provides technical assistance to the' General Superintendent -

[

Nuclear Generation, who has management authority to implement the -

"as low as reasonably achievable" . (ALARA), occupational- exposure policy, to which Niagara Mohawk Power Corporation is committed.

I The Superintendent of Chemistry and Radiation Management (RPM) has the qualifications equivalent to those required by Regulatory Guide 1.8.

I u >

a The Supervisor of Chemistry and Radiation Protection is responsible for conducting the Health Physics Program that has been established for the station. This supervisor has the duty and the authority to

. measure and control the radiation exposure of personnel to a level that is as low as reasonably, achievable and within regulatory exposure limits;.to continuously evaluate and review the radiological status of the. station; to make recommendations for control or elimination of radiation hazards; to train personnel in radiation safety; to assist all personnel in carrying out their radiation protection respon-

, sibilities; and to protect the health and safety of the public both on-site and in the surrounding area.

In order to achieve the goals of the Health Physics Program and fulfill

~

these responsibilities for radiation protection, radiation monitoring, survey and personnel exposure control work are performed for all station operations and maintenance. The extent of this surveillance is outlined below.

' The Health Physics section performs the major portion of the Health Phy' sics work for the station. Personnel in.the Health Physics section normally work on the day shift, five days a week, during periods of routine operation; and deploy onto. the other shifts for major main-tenance, shutdown and the refueling work. The Health' Physics Section is organized into two units, each headed by a supervisor. These units are: (1) Operations and (2) Support Functions.

For the_ purpose of defining and assigning work to be performed-

. by the operating shifts and the Health Physics Sections, the routine station radiation surveillance work can be described as consisting of radiation monitoring, radiation survey, radiation exposure control and radioactive waste disposal activities.

The Radiation Protection Technicians perform radiation monitoring

' and exposure control work for the~ routine and special operations, This work.is performed under the direction of the appropriate Radiation Protection Supervisor. Radiation Protection Instructions (RPIs) and/or assignments prepared by appropriate Radiation Protection-Supervisor, will designate routine work to be performed.

The CERM Department also performs essentially all of the work necessary to calibrate and maintain (other than repair) the Counting Room-in-struments and the portable radiation monitoring instruments.

Duties concerning radioactive liquid, gaseous and solid waste

' disposal are performed under C6RM Department direction. The detailed analyses and records required to characterize the nature of these releases,'both qualitatively and quantitatively, are under the control of the C6RM Department. In addition, solid waste disposal and ship-ments of radioactive materials are under the control of the CSRM Depart-ment.

4

-- .=, _ _ _ _- , . . - . - . - - _ , . - . , , _ . . - - , _ _ , , , . , . - - -

~ ~ ~ ~~^ ~~ ^ ~ ^ " ~ ~ ~

Training and qualification of personnel in Raiiation' Protection are the responsibility of the Supervisor of Chemistry and Radiation Pro-tection and are performed under his direction.

1

- All administrative aspects of training, such as scheduling and i

documentation are handled by the Nuclear Training Department. ~The J Nuclear Training Department also administers the general standardized  !

Radiation Protection Training, as approved by the Superintendent of Chemistry and Radiation Management.

The C6RM Department also conducts the Offsite Radiological Monitoring Program and Emergency Planning for the station.

B. Radioactive Materials Safety Program Radiation protection procedures are established for the safe handling, storage and inventory of sealed and unsealed radionuclide sources having activities greater than the exempt quantities of radionuclides defined in 10 CFR 20, Appendix C or 10 CFR 30.71.

1. Source Accountability and Storage Upon receipt or preparation, monitoring will be performed in accordance with the requirements of 10 CFR 20.205, and source data will be entered into a Source Accountability Record. The sources will be stored in suitable containers or areas such that radiation levels in nearby unrestricted areas are within the limits for permissible levels in unrestricted areas as defined by 10 CFR 20.105.

Sources will be stored only in designated storage areas at either Nine Mile Point Unit 1 or 2. Storage areas for sources which contain greater than those quantities listed in 10 CFR 20, Appendix C or 10 CFR 30.71 must be locked or placed under the physical controls..of responsible individuals (ie. , Radiation Protection personnel) at all times. Whenever a source is removed

> from it's designated storage area, the person removing the source shall enter applicable data on a Source Movement Log Sheet, to' aid in maintaining source accountability. By procedure, each calibration or check source shall be accounted for quarterly, with the complete inventory maintained current at all times. ]

Licensed material'shall be used by or under the supervision of Edward W. Leach (Supt. of Chemistrv J,d Radiation Management) or James N. Duell (Supv. of Chemist;> r;I Ridiation Protection).

' Personnel authorized to use 'in sse< is shall receive training in procedures which govern d r ea F ,

2. Source Lock Testing Tests for leakage and/or contaminatio, shall be performed on each sealed source, except startup sources subject to core flux or installed in the core, containing radioactive material, other-than hydrogen 3, with a half life greater than thirty days and in any form other than gas at-intervals not to exceed six months.

The periodic leak test required does not apply to sealed sources-that are stored and not being used. These shall be tested, however, prior to any use or transfer to another user unless they have been leak tested within six months. In addition, sealed sources are exempt from such leak tests when the source contains 100 microcurie or less' of beta and/or gansia emitting material or 10 microcurie or less of alpha emitting material.

Startup sources shall be leak tested within 31 days prior to being subjected to core flux or installed in the core and following any repair or maintenance.

The leakage test shall be capable of detecting the presence of 0.005 microcurie of radioactive material on the test sample. If

-the sample provides 0.005 microcurie or more of removable con-tamination, it shall be immediately withdrawn from use, decon-t'aminated and repaired, or be disposed of in accordance with Commission regulations.

Results of required leak test performed on sources, if the tests reveal the presence of 0.005 microcurie or more of removable con-tamination, shall be reported in accordance with Commission regula-tions.

2) Neutron Startup Sources There are 'a total of seven (7) neutron start-up sources (Byproduct License application, Attachment 1, source "A"), consisting of a tubular source (Sb) capsules. The total activity holder and two (2) irradiated antimony!4.20 x 104 Curies.

for-the seven (7) sources is less than The irradiated antimony. capsules are provided separately and are installed in the source holders on site. Due to the irradiated' antimony character-istic _ half-life of 60 days, the irradiated capsules must be ~ prepared and shipped so that their arrival is coincident with their scheduled period of use.

The seven reactor startup sources are shipped to the site in a special shielded cask. Upon receipt, the cask will be surveyed in accordance with the requirements of 10 CFR 20.205. The cask will then be placed in the Spent Fuel Pool for underwater storage until needed. Subsequent removal frca the shielded shipping cask, installation in source holders, and installation into the reactor vessel will be performed under water.

Those sources may remain in the core for the lifetime of the plant; no unique shielding is required after reactor operation has begun.

f.