ML20154L351

Forwards Answers to Request for Addl Info Re Decommissioning Plan & Safe Storage Tech Specs.Some Answers Suggest Changes to Either Tech Specs or Decommissioning Plan

ML20154L351
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	09/09/1988
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LAC-12616, NUDOCS 8809260155
Download: ML20154L351 (23)

Text

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D DNRVLAND hh/4[ COOPERATlVE. eo sox 817 261$ EAST AVE SO. LACROSS 1608) 768 4 000 JAMES W. TAYLOR General Manager September 9, 1988 In reply, please refer to LAC-12616 i

t DOCKET No. 50-409 Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Gentlemen:

SUBJECT:

Dairyland Power Cooperative i

La Crosse Boiling Water Reactor (LACBWR) i Provisional License No. DPR-45 1

LACBWR Deconssissioning Plan -

Answers to Request for Additional Information l

REFERENCE:

(1) DPC Letter, J. Taylor to Document Control Desk (DCD)

(LAC-12460) dated December 21, 1987 r

1 (2) NRC Letter, P. Erickson to J. Taylor, dated July 7, 1988 (TAC-66950)

(3) DPC Letter, J. Taylor to DCD (LAC-12584) dated July 18, 1988 l

(4) Additional Questions, Nos. 46 through 50, 1

submitted by NRC Resident Inspector at LACBWR (5) DPC Letter, J. Taylor to DCD (LAC-12501) dated Feb. 22, 1988 l

i In our letters of December 21, 1987, and February 22, 1988, (References 1 & 5. respectively) Dairyland Power Cooperative (DPC) submitted the l

Decomunissioning Plan and SAFSTOR Technical Specifications for NRC review and e

approval.

In response, you submitted a list of 45 questions (Reference 2) to I

be answered by DPC with an August 15, 1988, deadline.

Five additional questions (Reference 4) were submitted by the LACBWR NRC Resident Inspector, and in telephone cony.ersation with Mr. Peter Erickson, LACBWR Project Manager l

(NRR), a suggestion was made that these questions be answered along with the 1

original 45 subaitted to DPC in the July 7, 1988, letter, f

i Because of the substance and nature of the questions, DPC requested and

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received a revised deadline of October 1, 1988 (Reference 3) with partial l

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Document Control Desk LAC-12616 Page 2 September 9, 1988 submittals to be submitted in the interim when some of the questions were answered.

This letter constitutes the first partial submittal, with answers to questions S-9, 13, 14, 18, 20, 22-33, 37-39, 41, 46 & 48.

Some of the answers suggest changes to either Technical Specifications or the Decommissioning Plan.

If and when the answere to these questions are accepted. Dairyland will submit the appropriate pages with the required revisions to these two documents.

If you have any questiora, please contact us.

Sincerely, DAIRYLAND POWER COOPERATIVE kW James W. Taylor, General Manager JWT:JDP:dh Attachment cc - Mr. A. Bert Davis, Regional Administrator U. S. Nuclear Regulatory Commission Region III Mr. Peter B. Erickson, Project Manager Division of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission PC4-4

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A.

Decommissioning Plan - SAFSTolf 5.

p. 3-7, Section 3.4.8 3

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AR7 C00%WTT e

Provide a discussion of the surficial aquifer (s) including potable unter supply nelis near the site and the potential for radionctive contamination from an accidental spill at the site. Provide the 1

surficial aquifer permeeters (pennenbility, specific yield and l

i swnowhneter cantour anp) necenaary to evalunto the grounketer travel

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twen in the surficini aquifer.

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The following was taken from a report done by Alfred clebach, Jr. and b

Eric L. Meyer.

It is titled "Geology and Hydrology of a Proposed j'

Reactor Site Near Genoa, Vernon County, Wisconsin.

Hydrologic _Dese.*iption j

The reactor site is in the m aissippi River valley.

In the vicinity i

of the site, the valley is deeply cut into highly dissected uplands.

3 From 1.a C osse to Prairie du Chien approximately 40 miles south, the j

valley varies between 2-1/2 and 4-1/2 miles in width.

The valley i

walla rise sharply 500 to G00 feet from river level.

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1 There is little or no agricultural use of the river valley floor which consists prinnevily of marshy land, islands between river i

channele and extensions of low lying flood plair. cut by ponds, r

l sloughs and h or.*wlering stream channels.

Nusserous short, steep-sided l

valleys, that have been cut into the uplands by tributary streams, intercept the main river valley. Walls of both the main tributary channels are wooded.

The flat upland areas ard some of the tributary t

valleys are cultivated and grazed.

i The main channel of the river varies greatly in width above,and below l

the site.

A series of dams are operated by the thiited States Army l

Corps of Engineers for navigational purposes.

Above Dass No. 8 (about i

3/4 mile north of the site) the river is nearly four miles wide.

l Between Dam No. 8 and the site, the river is 1500 to 2000 feet wide.

Below the site, the river is relatively narres for a diriance of l

20 miles, then gradually widens as the river approaches Das No. 9, 33 miles south of the site.

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The site is on e filled-in area north of the Genoa steam plant.

Therefore. drainage at the site must be provided.

There is allowance

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for runoff from the high valley walls to the east.

The site is J

favorably located with respect to this runoff, however, because of i

two short valleys east of the bluffs bordering the site.

One valley PC4-20

drains to the north and one to the south, so that only precipitation 1

that falls on the bluff adjacent to the site and on a small portion of the upland area contributes to runoff directly across the site.

This runoff is presently channeled along the highway and railroad to prevent interference with traffic.

No problems of flash floods have occurred at the site.

The drainage area of the Genoa reactor site is G1,700 square miles.

Downstream _ Water.Um For a distance of 40 miles downstream of the site, virtually all municipal water supplies for cities and towns along the river are obtained from ground water. On the basis of readily available published records, the nearest major city using the river water for direct human consumption is Davenport, Iowa, about 195 miles down-stream.

The nearest user of river water for industrial purposes is the steam-power pleuit in Lansing, Iowa, about 15 miles downstream.

River Water is used at this plant for condenser cooling. There is no other known user af river water for industrial purposes between the reactor site and Prairie du Chien, 40 miles down-river.

j Ground Water j

As the site has valley sand overlaying a layer of Eau Claire sand-l stone of the Cambrian Age which is underlaid by a Mount Simon sandstone, wells have been driven in areas closest to the site but i

i not in valleys characterized by sublayers of Mount Simon sandstone.

Deep welle penetrating the Mount Simon layer flow to the surface i

indicating an artesian hea.d above the level of the river valley I

floor.

Use of water from these artesian aquifers have been limited j

because the chemical quality of this deep water is poorer than that from shallow aquifers.

As a result, there has been no extensive i

withdrawal of water and no serious decrease in the artesian head, i

Therefore, an accidental release of these contaminates can not enter l

the artesian aquifer.

Conclusions 1

In considering the hydrologic consequences of some accident which i

might release radioactive substances, the river is of primary con-cern.

An accident situation in which fluids might flow directly into l

the stream would present the greatest hazard, but fluids released below ground level would aleo move toward the river.

The path that 4

i would be followed underground cannot be predteted accurately because i

it would depend in part on the stage of the river, which is variable in time, as well as on other factors.

Even though movement of fluids i

through the alluvium would he very slow comm-ed to movement on the j

surface, in view of the lack of quantitative data on permeability, i

hydruulic gradients, and absorptive propertie.a of the alluvium, it l

woald be safer to assume that any release of radioactive fluids would move relatively quickly to the river.

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The relatively large discharge of the river, even during times of low flow, and the fact that there is little or no use of water for human consumption for many miles downstream, indicate that the river has a high dilution potential for accidentally released radioactive fluids.

Further, any wastes discharged to the river will be reduced in concentration by many orders of magnitude as they become mixed with the river water.

6.

p. 5-3, Section 5.2.1 WM Mee Deccanrinaianing Plan states that the "control ruin any be raromi to the R3W or a licensed facility during SM51tW. " Is the "liceansJ facility" a licerseed disponni facility?

DPC RESPONSE The "licensed facility" would probably be a disposal facility.

Ilowever, the terminology should not restrict the possible transfer of the control rods or control rod components to any authorized recipient of licensed and/or byproduct material, for example, for research purposes.

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p. 5-13, Section 5.2-11 t

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1he IRSW curtwotly cartaine 10 control roda in addition to 333

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Arrediated fuel elements. Provide Justification edty the 29 control rode i

in the reactor vessel are not transferred to the JESW as part of SM5ftW

prtgram, i

F DPC RESPONSE I

i The Fuel Element Storage Well was not designed to store irradiated

}

control rods.

The storage racks are loaded with 333 irradiated fuel assemblies and will not be utilized to store additional control rode unless some circumstance requires their transfer.

Storing the control t

rods within the reactor vessel offers the lowest personnel radiation i

i exposure option.

Transfer of the remaining 29 control rods would expose individuals to additional radiation plus requira the removal and replacement of the reactor vessel head (with its accompanying radiation exposure.)

In addition, the facility has a cleanup program underway which involves the recirculation of primary water, thus removing some j

loose material from the primary system followed by subsequent deposition j

of radioactive material in the ion exchangers.

Leaving the control rods i

in the reactor during this cleanup period makes it possible to circulate water around them, thus further reducing the total radionuclide inventory on the site.

The transferring of items unnecessarily over the l

fuel in the storage well would cost in dollars and radiation exposure I

and the loan of opportunity to further cleau up the control rods.

These factors are justification to retain the control rods where they are.

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p. 5-56, Section 5.6 MM Discens your pican for the disponition of sources of radioactivity ansociated with this decommissioning operation.

DPC RESPONS_6 If it beconeen necessery to dispose of any sealed sources used at LACBWR, I

they will be shipped as radioactive waste to an approved burial site.

These sources will be properly packaged, classified and shipped for disposal in accordance with the requirements of 49 CFR and 10 CFH Part 61.

9.

pp. 6-1 and 7-3, Sections 6.1 and 7.3.2 ACC CO NrNT

& Deccanissioning Plan objectiven incisxk' same decontamination arnt i

dissantlement.

1 heme operations should be addreened to discues the specific syntame aruf components, prnponed decontamination methods, arnt expected nonte generation. Expected quantitles of enesten containing chelatirnt Ments and mixed enantee should be Jrwinded.

DPC RESPONSE The Decommissioning Plan objectives mention that decontamination and dismantlement are possibilities. We have no plans or current intentions of any dismantlement during the SAFSTOR period. Tho decontamination and cleanup will include the continued recirculation of the primary reactor system water and deposition of radionuelides in ion exchanger resin beds.

The operation of this system will continue as in past LACBWH practice and the anticipated + taste generation will not exceed two 122 cu. ft. resin liners annually. The material will include no chelating agents. Should any special decontassination projects or any dismantle-ment be anticipated, specific plans would be developed and submitted to tho Nuclear Regulatory Commission before implementation.

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p. 7-3, Section 7.3.2 A0lC CONrNT P>ragrayds 7.3.2 discunses renoval of unuend equipment during SM51tw I

after surveying and dbcunersting that the equipanwst contains no detectable rmfloectise anterial (le ss than Imer Level of Detection (LLD). Since the IlD de'rence 4pon the surveying instrument used and the surveying method, the instruments arni nethodn should be de. scribed.

DPC RESP 0FSJ Equipment no longer deemed necessary during the SAFSTOR period that is J

to be released for unconditional use will be survoyed to ensure no detectable contamination is present in the following rethods.

i (a) The equipment will be smeared externally and internally. The smears will be count-d for pross beta / gamma using an internal 2

proportional counter.

A 4.ti6 signa counting statistic will be used j

to determine the LLD.

i (b) Equipment will also be frisked in a low backgrodud arens.

This will be used to determine any fixed contamination, and again a 4.68 sigma value will be used to determine the LLD.

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p. ?-5, Section 7.4.3 l

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Irnficate the range of the nohic gas detectors in the stack effluent arni l

the gamme monitors in the liquid wriste line.

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i DPC RESPONSE I

j The stack effluent noble gas releases are monitored by a SPING 3/4 unit.

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l When calibrated to KR-85 (the only major noble gas isotope left in the fuel), the prototype SPING monitors had the following ranges a) Low Range Noble tus Detector - BKG to 5 E-2 uCi/cc I

b) Mid Range Noble Gas Detector - DKG to 1 E3 uCi/cc

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The liquid waste monitor is capable of reaching 1 E+5 CPS.

The scintillation detector used for this monitor has a current calibration

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factor for the nuclides nermally present in the liquid waste of 2.0 E-7 uCi/ml/ CPS. This gives the liquid waste detector a nominal range up to 2.0 E-2 uCi/ml.

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MM Are you contaaplating spent fuel pin cwmolidatlar on site prior to shimt to the Federal Righ Level Maete hvoeitory? If so, provide entlanten of the expected occsymtional radiatlwu exposuren involved, of the volume of low level neste generated, and of the contribution of this activity to gnecous and liquid rmflonctivity releases to the envirannent.

DPC RESPONSE We are not contemplating etiy spent fuel consolidation on site prior to shipment to the federal high level waste repository.

20.

4 NAic CO NrNT In reference to assite storage of combustibic fuel, identify the fuel, its location, method of storage, method of resupply, and the maximum quantity stored at any time.

DPC RESPONSE The following is a list of combustible fuel supplies stored onsite, their locations, methods of intorage, and supply methods.

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Pael Storage ! Resupply : Maximum label Location !

Tsve i Method : Method

! Quantity.

Site Storage P.A.

- #'2 Diesel : Above

Tanker

! 20,000 l

l l

Ground : Truck

gal.

! Tank r

. lA Fire Pump Cribhouse

1. 2 Diesel ! Under-

! Fill from : 300 gal.

1

! ground Site I

! Tank l Storage' i

via Hose LB Fire Pemp l Cribhouse

#2 Diesel : Under-

! Fill from : 120 gal.

ground Site

(

Tank

Storaga

)

via Hose :

i lA Diesel Outside of : #2 Diesel Under-Fill fron : 600 gal.

Generator

! Machine ground Site L

Storage

Shop

Tank Storage

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via Home i

i 1A Diesel

In

1. 2 Diesel ! Wall

Auto Fill : 100 ga1 l

Generator

Generator i

Mount i fros' r

Day Tank

Roon

! Storage

)

Tank IB Diesel l Outside of : #2 Diesel : Under

Fill from : 6,500 l

Generator

! IB D.G.

Ground : Site

gal.

Storage Tank l Room

! Storage

Tank 1B D.G. Day

In IB D.G. : #2 Diesel : Floor

Auto Fill : 300 gal.

Tank Hoom

! Mount

from l

l l

l Storage I

! Tank

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l Security D.G.

1 In Admin.

81 Fuel

! Floor

Tanker

100 gal.

Day Tank Buildinit

Oil

Mount

Truck 1

Heating In Fuel

! #2 Fuel

! Floor

Fill from 1.000 i

Boiler i Oil Storage: Oil

! Mount

Site

gal.

l Day Tank l Room

Storage l

l l

l

! Tank l

Pertable

Outside

Gasoline

Flame

Local

10 gal.

Gasoline

Shop

Proof

Vendor Cans

Cabinet :

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ESWSS Pumps

Outside

Gasoliao Puap

Local

40 gal.

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Storage

! Tanks

Vendor l

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-.n,w.n

-nn a

n,nc--n---.--n-~,-cwe,.,nen--A

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Technical specifications 22.

p. 1-1. Section 1.2 hinC COGEVT hhet activitien, such an decontamination amVor rmoval of structuren, syntame and craponents are permitted by the doncription titled "Principal Activitice"7 Aleference to balatory Goldo (R.G.) 1.M any be uned.

DPC RESPONSE Any removal of structures, systems, and components would he done iri compliance with the LACBWR Facility Change procedure (ACP-4.1).

This procedure requires a detensination be made as to whether the proposed 2

Facility Change constitutes an unreviewed safety question as specified in 10 CFR 50.09.

Any system required by Technical Specifications would not be peneitted to be removed. Decontamination of structures and l

components is performed on a routine basis.

Any major decontamination effort, however, would be done only after a procedure detailing the necessary steps was generated and then discussed and app:..ed at an Operations Review Conceittee meeting.

23.

p. 2-2, Section 2 i

AEBC CtN6MT

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Under Effluant kleese noundary definitimo, nference is mode to i

Flare 4/S.7.

Os p. 4-62 Flpre 1 is the site op facl Jing e isuent r

niense boundary. Since there is no Figre 4/S. 7, should F%are 1 be renumbered flere 4/S. 77 i

DPC HESPONSE The definition of EFFLUENT RELEASE BOUNDARY o, page 2-2 of Section 2 will be resended to read "See Figure 1. Sec 4."

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p. 4-1, Section 4.1.1 M CMM A cover can be Arnetailed owr the JES1Y to pavelude droppade of objects into the pool and to pavvide a contneinntion control barrier.

Doen LACANr prenantly have a cover or is arm planned to be installed for SAi~. : twt This cover should be deecribed in SAfSitM Decomrissioning i

Plan, if mvlicable.

i DPC RESPvNSE j

No cover presently exists for the FESW.

Facility Change 58-b8-10 has been approved in concept for the construction of a cover.

This cover will be used as a personnel barrier and a contamination barrier.

It j

will be built no that it will be transparent to permit visibility.

The proposed cover will stop small light objects but w uld not be capable of i

stopping heavy items.

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p. 4-1, Section 4 1.1.2 i

MileCOWWWT The depth of sorter ahleidig over a 1%1 assenably shile it is being i

transferred to a spent fuel rack is Jens than 20 feet, and the done r,te 3 feet above the JEMY seter any be greater thats 5 anVhr above ambient radiation levels. Please submit a proposed !\\echnical Specification neich staten the minimum depth of seter shielding over the fuel annanhly I

1 na it is belat transferrut, and the meneuran ihnt will be taken to l

aneure that this ninfeue depth will not be drgradnf.

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DPC RESPONSE P. 4-1 of Section 4.1.1.2 does state the minimum depth of water shielding over the fuel assembly as it is being transferre l.

This i

technical specification has been in force throughout the cperating life of this facility. Ref:

Provisional Operating Authorization Nos. DPRA-5 r

and DPRA-6, also Provisional Operating License No. DPH-45.

Procedures are at d have been in force throughout the life of the plant to maintain a mint aum depth of 10 feet. Special procedures have been t

prepared at times to vary the depth to less than 10 feet but more then 2 feet for inspections of fuel elements, these procedures are established, implemented and maintained in accordance with Technical Specifications, pe 6-8 Section 6.6, of tl.e February 22, 1988, y

Application for Amendment to License; presently it is Section 6.8.

DPC l

feels that no further technical specification submittals are required to satisfy this item.

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p. 4-3, Section 4.1.3 i

An action ntatement to twtuire une of the cleamp syntae abose the

?

lietting value shoul.I he provided.

If the activity cannot be reduced to i

leen than the llelt prior to the natt requirwl aanple, a M-dny resport to Anc nhould be nede.

If the peak activity for any meneurnment exceeds g

a value indicative of 10er cladcling degradetlan ander static conditione an lamedinte report to ANC nhould be required.

i DPC RESPONSR i

During operation of the FESW system, the cleanup system is running I

continuously. Becaus.e of this, an action statement requiring its use is l

not necessary if activity in the water exceeds the specified limits.

j Section 4.1.3 of Technical Specifications will be revised to read as I

follows:

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FUEL Slp,lLAGF AND HANDLING L

PURL ELFNENT STORAGE WELL WATER CifEMISTR_Y LIMITING CON',ITION FOR OPERATION

=====r==========================================================

4.1.3 The Fuel Element Storage Well water shall meet the following requiremen s:

a.

Chlor!de concentration

-- 1 0. 5 pg=

b.

p H --- --- ---------- 5. 3 - 8. 6 c.

Conduct ivi t y---

1 10 unho/cw d.

Gross beta-gamsa activity---- 10.1 uci/ml APJ_LICADIllH Whenever fuel is stored in the Fuel Element Storage Well.

ACTION:

With the Fuel Element Storage Well water chemistry or radiochemistry limits exceeded, initiate action to restore water quality to within the limits.

SURVEILLANCE REQUIREMENTS

========================================================================== 3 j

5.1.3.1 The Fuel Element Storage Well chemistry and radiochemistry parameters specified in this section shall be determined at least once every 7 days.

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5.1.3.2 If gross beta-ganea activity exceeds the specified limit and cleanup efforts cannot restore the activity to below the specified limit within 7 days, a 30-day report shall be made to the NRC.

5.1.3.3 If the gross beta-gamma activity exceeds 1.0 uct/ml at the time of sampling, an immediate report to the NRC shall be made.

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p. 4-5. Section 4/5.1 MW NE Section 4/S.] linlicalca that the spent ibel stornge rucks contain a boron poison slab between each stornge location te, ensure Kort 0.95.

A descripticus of these spent ibel storage racks with the poison slabs should syywar to be in the SAFSitW Doctmunissioning Plan.

DLT_I!ESPONSE The following description of the spent fuel storage racks will he, added at the end of Section 4.2.1 of the SAFSTOR Deconveissioning Plan.

The spent fuel is stored in racks in the bottom of the spent fuel storage well located adjacent to the reactor bio 2ogical shielding in the containment building. The storage rack systeis is a two-tier configurn-tion such that each storage location is capable of storing two (2) fuel assemblies, one above the other.

Fuel assemblies stored in the lower tier are always accessible (e.g., for periodic inspection) by moving, at most, one other assembly.

Each storage rack consists of a welded asseshly of fuel storage cells spaced 7 inches on center.

A neutron absorbing B4C/ Polymer Composite plate is incorporated between each adjacent fuel storage cell in each orthogonal direction.

llorizontsl seismic loads are transisitted frim the rack structures to the fuel storage well walls at three etevations (the top grid of the upper tier rack section, the top grid of the lower tier rack section and the bottom grid of the lower tier rack section) through adjustable puds attached to the rack atructures. The vertical dead-weight and noisreic loads are transmitted to the storage well floor by the rack support feet.

The fuel storage racks and associated seismic bracing are fabricated from Type 304 stainless steel.

28,

p. 4-5, Section 4/5.1 AW_W_!I A specific minisse anter coverage limit should be stated in the TS.

D0C RESPONSIj A specific minimum water coverage limit is stated in the TS on p. 4-2 Section 4.12, the basis for which is p. 4-5 Section 4/5.1.

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p. 4-36, Section 4/5.6 1

ACC ONENT huvine this section to show the denigra featuren of the monitoring system l

for the SAFSitW decomuiasioning.

Include ihe ofisite and oneite envirunaantsi acnitoring atatians.

D3 1RSPogg System design features will not be included in TS.

Any system design features will be included in the Deccamissioning Plan, Section 5.

30.

p. 4-38, Section 4.6.3 A0lC LM hlnporting requirunents should be mWI for soutum t}mt exceed the remornble contnaination limit.

The following la suggested:

"A report shn11 be ptsperaf and subeitted to the n'gimm1 Akinistrator, U.S.

Moclear hleguintory Cmismian, A.gion III within 30 days of the dnte the lenk trat result (gtreter than 0.0&i microcurien) is knoser.

& report shall specify the source involved, the teet results, and cortsctive retion takeso. kvorths of leak tent reaults shall be kept in units of microcurlee. "

DPC RESPONSR A report for sealed sources with leakage 1 0.005 microcuries of removable contamination is required by the submitted TS.

See Section 5.6.3.3.

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p. 4-56, Table 4.8.1-1 M_GNWlf Offsite danimetern shmid have their location documented on a mnp an i

port of the TS.

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Offalte seter sampling should be specified (location and radionuellde).

& sannpling should be in a daemuttm lomtim with respect to surface seter and gtt2: h, iter, i

i annite saapling should be doncribed an to nedionuclidan swied und the location.

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DPC RESPONSE The offsite dosimeters will be located around the site in a manner that will provide 360* coverage for direct radiation. The exact dosimeter location will be documented in the Health and Safety Procedures (HSP) as t

they presently are. Our operating Technical Specifications (TS) did not include dosimeter location; therefore, it is felt they should not be in our shutdown TS.

Exact location of offsite dosimeters would hinder our ability to change dosimeter locations if required by changing plant status.

i Offsite water sample locations are also specified in the HSP's.

They I

will be at and below the discharge point.

The radionuclides listed in Table 4.8.1-2 will be the minimum radionucl: ides looked for in the water j

samples.

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The location of any onsite sampling will be specified in the HSP's and

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the minimum radionuclides looked for will be those Itsted in Table l

4.8.1-2 depending on sample type.

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32.

p. 6-3, Section 6.4 NW CDNEI The "Certifini Jbel Handicr" truining prvgrrw should be avviewd arnt ass > roved by the hW.

The TS should only require that to be certifini, a uvrker successfully cwlete the prvgrum.

DPC ifES{pNSij NS The "Certified Fuel Handler" training program has been taken directly frora our accredited operator training program.

Since the hTIC has accepted accredited training programs for all other utilities without their own separate review and approval, we don't believe our program should be any different.

New TS Section G.4.1.1 will state:

"A training program for ' Certified Fuel llandler' shall be completed, as per the accredited operator training progreus procedure, prior to performing fuel handling.

General Employee Training, Health Physics Technician training and retraining shall be completed as per their respectivo Training Plan Procedures (TPP's)." These TPP's were derived using INPO's systematic approach to training and performance-based training.

These programs were rendy for accreditation when the plant was shut down.

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i 33.

p. 6-3, Section 6.4 l

l AGU (** M BI TS abould inciase tainig on 10 CM hvis 19, M, 61 arni il ne a

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minianu. A retrainiod frequency should be specified.

l DPC PESPONSE We presently specify, in our training procedures, which training is to be completed and the frequency for each department.

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37.

p. 6-6, Section 6.5.2.2 ASIC CUWIS#r I

Ne neebership of the SAC includnn the position of Dinctor of Rutemni h

Relatione. Since this position done not show on the Decwamissionlig Plan, se ennnot esmclude how that ponition esmtributan to the dnecribed l

functions of the SK.

Plenne provide the banis for including the Jadirlekses fillist thin reeltion on the SAIC.

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The Director of External Relations le responsible for the envirormental l

1 efforts of the Dairyland Power Coopmrative. The incumbent has been on l

the Dairyland Safety Review Cossaittee for approximately 17 years. He is l

e degreed health physicist who served as Supervisor of Health and Safety j

(radiation protection) at La Crosse Boiling Water Renctor frtm January f

1968 to August 1971. We feel he is well qualified to continue his service on the Safety Review Committee.

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p. 6-7, Section 6.5.7.8 Ahc 6

% licenne han verkscent the fres=.m of nil amfits requient by Section 6.5.2.8 excuvet for Qun11ty Assurance, the firw Protection Progran, and i

Off-site Done Calculation Nanoni nrut the Procews Contrvl Pir -.

i Planee provide a bnals for lengthening the terlod betsnwr amfits, i

DPC RPSPONSE l

The LACBWR-approved Quality Assurance Program Description (QAPD) for e

SAFSTOR does not utilize the term "safety-related." AN3I 18.7-1976 and I

Regulatory Guide 1.33 Rev. 2, both of which are referenced in our approved QAPD, discuss audits of safety-related activities.

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Based on removal of "safety-related" from our QAPD and the reduction of i

activities which could significantly affect the hec +h and safety of the

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public, it was determined that a reduction in audit frequencies is consistent with maintaining a safe and efficient SAFSTOR facility.

Based on safety evaluation reports for the LACBWR Emergency Plan and Security Plan, audits for these plans will be required on an annual

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basis.

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39.

p. 6-8 Section 6.6.1 i

W MNDT

& Procwhrre lfs0 anould tlclude calibration of inetruments, effluent relenese, transportation nad emergency plan farolementing proceduren, i

i DPC RESLUN3' l

i Section 6.6.1 on isges 6-8 will be amended as follows:

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6.6.1 Wcitten procedures shall be established, implemented and maintained covering the activities reconnended in Appendix "A" of Regulatory Guide 1.33 Division 3. February 1978, for a plant in l

the SAFSTOH condition, f

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41.

p. 8, Section 7.2 M GMENE in Section 7.2, pm dencribe the IACNN rmkenete nystew.

(n) Since IACnN ciruelating noter will not be nynilable for liquid i

rednente dilution prior to dincharp, atute how pm intend to provide adesamte dilution of Joer level liquid rarbuste to meet the i

mexlene permissible conmntration leveln of 10 CIN 1%rt 20 prior to i

dischere into the Mississippi River.

(b) State hoet pm interut to procean liquid rebente generntent the the operation of bachamehnble filters.

These met seentee (filter t

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slankew) are not dencribed in Section 8 of the Dewarissicaing plan an a type of net enente to be svildified or skenteruf.

(c) You identify skcontamination liquide na potewtini sourcew of 11guld montee to be processed during SA15ftW period. #wcribe the type eruf expected anjor chneicel cusvonition and procnes method to be need.

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I (a) The statement given in (a) is untrue.

P. 8 of Sec'. ion 7.2 does not discuss the availability of the LACBWR Circulating Water System.

The Decosamissioning Plan Section 5.2.22 on p. 5-24 states that the i

Circulating Water System is maintained operational for periodic use for oilution of liquid waste discharges.

I (b) The backwashable filters located in the waste water discharge line are a nominal 100 nicron mesh size.

They are not designed to filter out small sludge particles but rather they were installed to prevent any large particles such as resin beads, strings, mop hair, i

etc. from being discharged to the river.

The matertal collected by these filters is discharged directly to the spent resin receiving tank where it is mixed into the spent resin.

The spent resin is placed into a Radlock-100 and dewaterex3 prior to disposal at a l

burial site.

(c) The decontamination liquids referred to as normal and potential l

sources of liquid wastes are not chenical compounds used to perfone l

major system or plant deconteueination.

The liquids referred to in this section are used to pet for1s the noneal day-to-day plant i

cleanup.

They consist primarily of detergent-based cleaning agents i

mixed in water. This is not 5 major source of liquid waste. There

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are only 5-20 gallons of decon soap / water mixture produced per day for no1 sal plant cleanup.

No process method is needed for this I

type of cleaning solution.

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46.

p. 5-3, Section 5.2 bW CtMhT A descriptims of the containment system and the SAb51tN? systew status uns not included in the Decommissioning Plan.

ply _nEsroNsg The existing containment system consists of the various penetrations and valves of various systems required to maintain containment integrity.

A subsection of Section 5 will be added to include a description of the containment system and SATSTOR system status, as follows:

Cont alnment_Ittggf.lt'/ Sya t res, t

t With the plant in the SAFSTOR condition, there is no longer a postulated accident that would result in containment pressurization.

The requireisent for containment integrity during fuel handing has been retained.

Containment integrity shall exist when all penetrations required to be isolated are either capable of being closed by an operable containment automatic isolation valve system, or closed by at least one manual valve, blind flange, or deactivated automatic valve secured in its closed position.

The freight door is closed, each airlock is operable, the containment leakage rates are within the limit and the scaling mechanism associated with each penetration is operable.

System Status These systeus will be maintained in accordance with LACBWH Technical Specifications.

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48.

p. 4-1. Section 4.1.1 l

t M CUEFE b Bones for this section ntate that the fuel handlig system handlee only one fuel etreant at a time.

Nis requitmaant should nino be inciankd an a part of 15.

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i DN RESPONSE Technical Specification 4.1.1.2 on page 4'-l of our proposed SAFSTON l

Technical Specifications will be revised as follows:

i 4.1.1.2 During the handling of irradiated fuel elements that have been operated at power levels greater than 1 Hwt, the depth of water

^j in the reactor upper cavity and/or the Fuel Element Storage Well i

shall be at least 2 feet above the active fuel and only one fuel I

element will be moved at a time.

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p. 6-3, Section 6.4.1 l

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Anst Standerxl N18.1-1971, Section S.S n&lrennen only the retrainirnt nruf j

zwincement trainig progrne. Section 6.4.1 should also addreas general wlmve trainirst, certified fuel inondier titeining naut certification, l

and henith phywice technician trair'M and retraining.

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pN RESPONSE i

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See response to No. 32.

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