ML20128Q767
| ML20128Q767 | |
| Person / Time | |
|---|---|
| Site: | 07003002 |
| Issue date: | 06/19/1985 |
| From: | Tucker H DUKE POWER CO. |
| To: | Jennifer Davis, Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25428, NUDOCS 8507150077 | |
| Download: ML20128Q767 (16) | |
Text
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76-J e DUKE POWER GOMPANY P.O. nox 33180 CHARLOTTE, N.C. 28242 HAL B. TUCKER TELEPHONE vum ramasernt (704) 373-4531 June 19, 1985
====r====-
Mr. John G. Davis, Director Office of Nuclear Material Safety and Safeguards U. S.' Nuclear Regulatory Commission d
44 ]
Washington, D. C.
20555
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Attention:
Mr. R. G. Page, Acting Chief f6 Uranium Fuel Licensing Branch Re: Catawba Nuclear Station, Unit 2 cd Docket No. 50-414 Special Nuclear Material License Application e_E
Dear Mr. Davis:
y In response to the June 7, 1985 letter from Mr. Kishore Kodali, of your c
staff, which transmitted a draft of the Catawba Unit 2 Special Nuclear M
Material License, we have the following comments:
1)
In the SER on pages 6, 9 and 15, it indicates that "The Superintendent of Operations approves all fuel handling procedures and any changes to them".
This statement is overly restrictive since we may want to approve procedure changes when the Superintendent of Operations is not available. We propose this voiding indicate a designee to approve fuel handling procedure changes which will allow approval by individuals such as the Superintendent of Technical Services or the Superintendent of Maintenance.
2)
In the SER on page 9, it indicates that " Operations personnel must pass a written exam covering health physics procedures and a fuel handling test using a dummy fuel assembly". We propose deleting "using a dummy fuel assembly" as some individuals are qualified for fuel transfer activities using a real assembly under direction from a qualified individual.
3)
In the SER on page 10 (and License Condition 15) it indicates that "All preoperational testing of fuel handling equipment, related to activities authorized by this license, shall be reviewed and approved by DPC's operations group before receipt of fuel onsite". We propose deleting " operations group".
Some of the tests are not performed b the operations group.
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r Mr. John G. Divio, Director June 19, 1985 Page Two 4)
In the SER on page 17, it indicates that radiation exposure will be monitored with " neutron dosimeters". We utilize no neutron dosimeters for normal personnel monitoring on a regular basis. Neutron exposure is not deemed to be a
" problem" at Catawba. Therefore, the neutron dose equivalent vill be calculated as allowed in Regulatory Guide 8.14 section C.1.c.,
d.,
or e., as applicable.
5)
In the SER on page 15 (and License Condition 18) it indicates that "The Reactor Engineer shall verify correct fuel assembly location after insertion of each assembly into the assigned storage rack..." and "the Reactor Engineer and the Quality Control Inspector shall each sign a document assuring proper storage of each fuel assembly". We propose that " Reactor Engineer" be replaced by " Reactor Engineer or his designee" so that the Reactor Engineer does not have to be present for all fuel movement.
- 6) On page 12 of our application and page 9 of the SER it indicates that " operations personnel involved in fuel handling..." We propose deleting " Operations" and replacing it with " Qualified".
This is because we will be using qualified Maintenance Support personnel to receive fuel.
- 7) On pages 14 and 15 of our application it indicates that Radiation Control Area access is formally controlled using key operated doors and controlling those keys.
This is not true and this information should be deleted from our application. Areas within the RCA that may be a potential exposure hazard may have additional access controls such as key operated doors or other controls as necessary.
- 8) On page 18 of our application, the third paragraph should be changed to indicar tat we calibrated our Geli detectors annually.
- 9) On page 9 of the SER (and License Condition 12) it indicates the technical qualifications for the Superintendent of Operations be in accordance with Section 4.3.1 of ANSI N18.1-1971. This requirement should be deleted or changed to reflect the approved requirements as delineated in FSAR Section 13.1.3.1.(b),
(Attached).
9' Mr. John G. Davis, Dirzctor
- June 19,'1985 Page Three If there are any questions regarding this application, please contact Mr. Roger W. Quellette at (704)373-7530.
Very truly yours, V
fh Hal B. Tucker RWO: sib Attachment cc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Robert Guild, Esq.
P. O. Box 12097 Charleston, South Carolina 29412 NRC Resident Inspector Catawba Nuclear Station Palmetto. Alliance 213515 Devine Street Columbia, South Carolina 29205 Mr. Jesse L. Riley Carolina Environmental Study Group 854-Henley Place Charlotte, North Carolina 28207
_ FSAR Sab /3 /.3 /
(a) Station Manager The station Manager shall have a minimum of ten years of responsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience. A maximum of four years of the remaining seven years of experience may be fulfilled by academic training on a one-for-one, time basis.
To be acceptable, this academic training shall be in an engine-ering or scientific field generally associated with power production.
The station Manager shall have acquired the experience and training normally re-quired for examination by the NRC for a Senior Reactor Operator license, whether or not the examination is taken.
(b) Superintendent of Operations The Superintendent of Operations shall have a minimum of eight years of res-ponsible nuclear or fossil station experience, of which a minimum of three years shall be nuclear station experience.
A maximum of two years of the re-maining five years of experience may be fulfilled by academic training, or related technical training, on a one-for-one, time basis.
The Superintendent l of Operations shall hold or have held a Senior Reactor Operator license.
(c) Superintendent of Technical Services The Superintendent of Technical Services should have a minimum of eight years
(
of responsible nuclear or fossil station experience, of which a minimum of one year shall be nuclear station experience.
A maximum of four years of the remaining seven years of experience should be fulfilled by satisfactory com-pletion of academic training.
(d) Superintendent of Maintenance The Superintendent of Maintenance shall have a minimum of seven years of responsible nuclear or fossil station experience, or applicable industrial experience, of which a minimum of one year shall be nuclear station experi-ence. A maximum of two years of the remaining six years of experience may be fulfilled by satisfactory completion of academic or related technical train-ing on a one-for-one time basis. The Superintendent of Maintenance should also have non-destructive testing familiarity, craft knowledge, and an under-standing of electrical, pressure vessel and piping codes.
(e) Operating Engineer An Operating Engineer shall have a minimum of a high school diploma, or equivalent, and four years of responsible nuclear or fossil station experi-ence, of which a minimum of one year shall be nuclear station experience. A i
maximum of two years of the remaining three years of experience may be ful-filled by academic or related technical training on a one-for-one, time basis.
An Operating Engineer shall hold a Senior Reactor Operator license.
[i 13.1-7 Rev. 7
6 1.
Station Manager The Station Manager exercises overall managerial and supervisory responsi-bility for the safe operation of the plant and its equipment. He is responsible for compliance with all NRC regulations and license conditions.
2.
Superintendent of Operations The Superintendent of Operations is responsible for receipt, shipment, inspection, handling, and storage of special nuclear materials contained in fuel assemblies. The operations are performed in accordance with approved written procedures. The Superintendent of Operations approves all fuel handling procedures and any changes to them.
or his designet j
3.
Reactor Engineer The Reactor Engineer is designated as the Nuclear Fuels Custodian at CNS, Unit 2.
Being such, he is responsible for the following activities:
a)
Restrict the use of the station's special nuclear materials to locations and purposes authorized by the license (s).
b)
Approval of all fuel storage locations and transfers.
c)
Maintaining documentation concerning the receipt, shipment, inventory, accidental loss or diversion and transfer of special nuclear materials within the station's purview.
m
F 8
l In the application, OPC specified the minimum qualifications for the position of Station Health Physicist shall be equivalent to those stated in Regulatory Guide 1.8, " Personnel, Selection, and Training" for Radiation Protection Manager. The person presently serving in this capacity at CNS, Unit 2 does not have a degree in science or engineering as required by Regulatory Guide 1.8.
Based on a review of the person's prior extensive experience in radiation protection, the NRC staff recommends granting an exemption from the educational requirements for Regulatory Guide 1.8, for Radiation Protection Manager.
OPC did not commit to the minimum qualifications for CNS, Unit 2 Station Manager, Superintendent of Operations, Reactor Engineer, and System Health Physicist. Accordingly, Conditions 11,12,13, and 14 are recommended to specify the minimum qualifications for these positions and shall read as follows:
Condition 11. The minimum technical qualifications for the Station Manager shall be in accordance with Section 4.2.1, " Plant Manager," ANSI N18.1-1971.
Condition 12. The minimum technical qualifications for Superintendent of Operations shall be in accordance with,Ecctfer '. 2.1, C ;; " :: : W. i r. g ' EC w
, o, " AN';; Nig,1-134 Oe Calau)ba F54R sechao /3 I. 3./ (6).
Condition 13. The minimum technical qualifications for Reactor Engineer shall be in accordance with Section 4.4.1, " Reactor Engineering,"
t
9 Condition 14. The minimum technical qualifications for System Health Physicist shall be in accordance with the requirements for
" Radiation Protection Manager", Regulatory Guide 1.8, September 1975.
C.
Training 1""$be 4
Training is conducted to ensure that all enti;-
personnel involved in fuel handling participate in a formal training program. The Superintendent of Operations is responsible for developing and implementing the formal training program. Topics covered in DPC's training program include the basics of radiation, health physics, fire safety, and emergency response.
Operations personnel must pass a written exam covering health physics procedures and a fuel handling test'k:ing -: d u = y f u e l e a,e;,t,1 The staff has concluded that based on the applicant's radiation safety and fuel handling training programs, the licensee can responsibly carry out the activities for which a license is requested.
D.
Administrative Procedures Administrative procedures for the control and handling of nuclear fuel are reviewed and approved by DPC's operations group.
These procedures and any changes to them require review and approval by CNS, Unit 2 Superintendent of Operationsgor his desgnee
10 VI. NUCLEAR CRITICALITY SAFETY The applicant requests authorization to store fuel assemblies in their shipping containers in the fuel receiving area, in the New Fuel Storage Vault, and in the Spent Fuel Storage Facility.
A.
Fuel Handling Since, OPC did not commit to preoperational testing of all fuel handling equipment related to activities authorized by this license, the staff therefore recommends that the following license condition be added:
Condition 15. All preoperational testing of fuel handling equipment, related to activities authorized by this license, shall be reviewedandapprovedbyDPCf;;^;r:t':r: g-iEElbefore receipt of fuel onsite.
This includes the testing of the following:
- a. New Assembly Handling Fixture
- b. Rod Cluster Control Assembly (RCCA)
Handling Fixture
- c. New Fuel Elevator
- d. Spent Fuel Pool Manipulator Crane
- e. Indexing of Spent Fuel Pool Manipulator Crane
- f. Whiting 10 Ton Crane 4
15 will not be placed closer together in the Spent Fuel Storage Facility than those in a checkerboard pattern. Therefore, Condition 18 is recommended to provide the required assurance; namely:
Condition 18. New fuel assemblies may be stored in the Spent Fuel Storage Facility subject to the following additional conditions:
The maximum U-235 enrichment shall be 3.15 w/o.
a.
b.
The fuel assemblies shall be stored in a checkerboard pattern.
L i
or W5 oeshnee The Reactor Engineer shall verify correct fuel assembly c.
3 location after insertion of each assembly into the assigned storage rack in accordance with a prepared written procedure approved by the Superintendent of Operations.
is jestance.
or d.
An independent loading verification shall be made by a Quality Control Inspector.
The Reactor Engineer,or his desi oee S
e.
and the Quality Control Inspector shall each sign a document assuring proper storage of each fuel assembly.
D.
Exemotion from Criticality Alarm Recuirements The licensee has requested, pursuant to 10 CFR 70.2.4(d), an exemption from the provisions of 10 CFR 70.24 Because of the inherent features associated with the storage and inspection of unirradiated fuel containing uranium
.g.
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16 enriched to less than 5% in the U-235 isotope when no fuel processing activities are to be performed and the inherent features in handling limited quantities of other radioactive materials, the staff hereby determines that granting such an exemption will not endanger life or 2.
I property.
Thisexemptionisauthorizedpursuantto10CFR70.X4.
It is i
recommended that the exemption be identified as Condition 19.
Condition 19.
The licensee is hereby exempted from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under this license.
VII. RADIATION SAFETY OPC is committed, consistent with the recommendation of Regulatory Guide 8.8, to establishing a program to maintain occupational and general public exposure as low as reasonably achievable (ALARA). It is the responsibility of the Station Health Physicist to implement the established radiation safety program to attain this goal. The System Health Physicist will periodically audit the effectiveness and adequacy of such a program.
Since all radioactive material, including fresh fuel assemblies, are sealed sources, the principal exposure pathway to an individual is via external radiation.
For a low-enriched uranium fuel bundle (<4't, U-235 enrichment), the exposure rate at i foot from the surface is normally less than 1 mr/hr; there-fore, it is estimated that the exposure level to workers from these sources
T 17 would be less than 25% of the maximum permissible exposure specified in 10 CFR Part 20. All other special nuclear materials requested by the licensee will also represent no threat to plant personnel or to the environment because of the small quantities of radioactive material involved.
At CNS, Unit 2, all persons subject to occupational radiation exposures will be monitored in accordance with 10 CFR Part 20.202. This is done by using TLD dosimeters, ;utr;r. de:ft:t;re and self reading dosimeters.
Individual s
ud.
exposures will be evaluated daily from self reading dosimeters monthly TLDs z3
- f ::t _
f::t :t: a in accordance with guidance in Regulatory Guide 8.14,
" Personnel Neutron Dosimeter." An administrative limit of 1.0 rem per quarter for personnel has been established to ensure that the regulatory limits are not exceeded.
Storage of other radioactive materials (other than non-f rradiated fuel) will be in a l'ocked storage area. Access to these special nuclear materials shall be under the authority and control of the CNS, Unit 2 Station Health Physicist.
Annex A, " License Condition for Leak Testing Sealed Plutonium Sources," has been adopted as a Branch Technical Position and will be incorporated as License Condition 20. Accordingly, Condition 20 shall read as follows:
Condition 20. The licensee shall comply with provisions of Annex A,
" License Condition for Leak Testing Sealed Plutonium Sources."
L
20 XII. RECOMMENDATIONS The staff recommends approval of the application and its supplement subject to the following conditions which the staff finds are appropriate to protect health or to minimize danger to life or property.
Condition 11. The minimum technical qualifications for the Station Manager shall be in accordance with Section 4.2.1, " Plant Manager," ANSI N18.1-1971.
Condition 12.
The minimum technical qualifications for Superintendent of Operations shall be in accordance with Section 4--2.:, ":_,......,
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Condition 13.
The minimum technical qualifications for Reactor Engineer shall be in accordance with Section 4.4.1, " Reactor Engineering," ANSI N18.1-1971.
Condition 14.
The minimum technical qualifications for System Health Physicist shall be in accordance with requirements for " Radiation Protection Manager", Regulatory Guide 1.8, September 1975.
Condition 15. All preoperational testing of fuel handling equipment, related to activities authorized by this license, shall be reviewed and approvedbyDPC{c;:ntia: ;rr_]beforereceiptoffuel onsite.
This includes testing of the following:
i
r e.
22 Condition 18. New fuel assemblies may be stored in the Spent Fuel Storage Facility subject to the following additional conditions:
The maximum U-235 enrichment shall be 3.15 w/o.
a.
b.
The fuel assemblies shall be stored in a checkerboard pattern.
or his destand The Reactor Engineer shall verify correct fuel assembly c.
3 location after insertion of each assembly into the assigned storage rack in accordance with a prepared written procedure approved by the Superintendent of Operations.
or k1s basi nee 3
3 d.
An independent loading verification shall be made by a Quality Control Inspector.
The Reactor Engineer,oc ks desi ua ity Control Inspector e.
and the shall each sign a document assuring proper storage of each fuel assembly.
Condition 19.
The licensee is hereby exempted from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under this license.
Condition 20.
The licensee shall comply with provisions of Annex A, " License Condition for Leak Testing Sealed Plutonium Sources."
Condition 21.
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- 11. The minimum technical qualifications for the Station Manager shall be in J
j accordance with Section 4.2.1, " Plant Manager", ANSI N18.1-1971.
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- 12. The minimum technical qualifications for Superintendent of Operations shall be
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- 13. The minimum technical qualificat' np3 opRec49r Engineer shall be in f
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accordance with Section 4 4V eactor Engineer NSI N18.1-1971.
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- 14. The minimum technical lifications for System Health icist shall be l
in accordance with.reifuirements for " Radiation Protection hager",
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Regulatory Guide IJ, Septemb, 1975.
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- 15. All preoperational testing of ~{ 1)hancHinp e{
,dt, relatego activities.
j Authorized by this license, shad
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% before receipt of fbal onsite., Thjf pac 1[rties the testQf of the following:
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New Assembly Ha ndli ng Fikkure,, i f.j ){.t :
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Rod Cluster Control Assembly'(RCCA) Handlins/Fkxture.
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New Fuel Elevator
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Spent Fuel Pool Manipulator $ Crane 4
d e.
Indexing of Spent Fuel Pool Manipulator Crane
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Whiting 10 Ton Crane 4
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New Fuel Storage Racks in the New Fuel Storage Vault, and 4
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Spent Fuel Storage Racks in the Spent Fuel Storage Facility q!
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, N ;C Furm 374A U.S. NUCLEAR REGULATCRY COMMISSION 3
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MATERIALS LICENSE A
I SUPPLEMENTARY SHEET DockH M Refmace m I
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- 16. a.
No more than two fuel assemblies shall be out of approved shipping containers I
l or fuel assembly storage racks at any one time.
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b.
The minimum edge-to-edge distance between the two fuel assemblies, the I
I shipping container array, and the storage rack arrays shall be 12 inches.
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- 17. Fuel assemblies shall be stored in such a manner that water would drain freely I
y from the assemblies in the event qf oogng go g[bsequent draining su i
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I fuel storage area.
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- 18. New fuel assemblies mah stored in the Spent Fuel Sto Facility subj ect to I
g the following condit,io?fs:
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I a.
The maximum U-24) enrichcmk shall be 3.15 w/o O
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8 b.
The fuel asse@ lies shall-tfi tored.tndcy rhoard patg.
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i 34 l3 The Reactor Engineergtbalir fep~t corf~e'ctj
',} assembly logion after c.
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./rn insertion of each assimbly into. tid a:r :,;ttyned'.y-storage. rack A accordance
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-n with a prepared 'writtea.proce(ure dhrolved by..tM Superintendent of g
I IiInspector.
Opera tions f/d
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loe his, cfpipee_.
d.
An independent loadi% verification shall be made by a Quality Control i
or Nes desi,$NC.
The Reactor Engineer and the Quality Control Inspector shall each sign e.
3 a document assuring proper storage of each fuel assembly.
Il
- 19. The licensee is hereby exempted from the provisions of 10 CFR 70.24 insofar as this section applies to materials held under this license.
- 20. The licensee shall comply with provisions of Annex A. " License Condition for Leak Testing Sealed Plutonium Sources."
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