ML20204B769
| ML20204B769 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/18/1999 |
| From: | PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20204B758 | List: |
| References | |
| NUDOCS 9903220233 | |
| Download: ML20204B769 (5) | |
Text
_.
. to VPN-038-99 High Radiation Area March I8,1999 5.6 Page1 of1 5.0 ADMINISTRATIVE CONTROLS
- 5.6 High Radiation Area 5.6.1 High Radiation Areas, as defined in 10 CFR 20, will be identified and access controlled in accordance with 10 CFR 20.1601 except for the tops of designated CONCRETE CASKS. Pursuant to 10 CFR 20, paragraph 20.1601 (c), in lieu of the requirements of 10 CFR 20.1601 (a), a CONCRETE CASK where the tcp is designated a high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is >100 mrem /hr but < 1000 mrem /hr, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto does not have to be locked but shall be controlled by the Radiation Protection Program of 5.5.4.
I i
l Trojan ISFSI 5.6-1 3/18/99
@/
9903220233 990318 PDR ADOCK 05000344 9
l W
PDR k
- to VPN-038 99 March 18,1999 Page1 of2' Justification for Inclusion of High Radiation Area Technical Specificatian in Trojan ISFSI Technical Specifications
Background:
l 10 CFR 20.1601, Control of Access to High Radiation Areas, subparagraph (a) requires, "... that each entrance or access point to a high radiation area has one or more of the following features "
(1)
A control device that reduces the level of radiation upon entry; I
(2)
A control device that energizes a conspicuous visible or audible alarm to the individual entering and the supervisor of the activity that indicates the area has l
been entered; or (3)
Locked entryways, except during periods when access to the areas is required with positive control over each indiv 3ual entry.
10 CFR 20.1601 (c) states that "A licensee may apply to the Commission for approval of altemative methods for controlling access to high radiation areas."
The Trojan ISFSI has been designed to maintain radiation doses ALARA. However, the design, j
surface, and working maximum expected dose rates at the Concrete Cask Top are estimated to exceed 100 mrem /hr (Table 7.4-1 of the ISFSI SAR). Based on these calculations,it is likely that measured dose rates at the top of some of the Concrete Casks will indeed exceed 100 mrem /hr. This condition would require either the top of thase Concrete Casks or the entire ISFSI be established and controlled as a High Radiation Area in accordance with 10 CFR 20.1601.
MiSCUSslon*
Although the ISFSI will be locked and access to it controlled, it will be for security reasons i
rather than radiation levels. The radiation levels on the sides of the Concrete Casks are only
)
expected to be 19.1 mrem /hr for surface dose rates and 10.2 mrem /hr for working dose rates (Table 7.4-1 of the ISFSI SAR). It is not a recommended health physics practice to categorize an i
area as large as the ISFSI as a High Radiation Area because of the dose rates at the top of some of the Concrete Casks when general area radiation levels are expected to be so low. In addition, i
when an area is classified as a High Radiation Area, it is not expected that access would be i
frequent or routine. For approximately one year, teams ofindividuals will enter the ISFSI at i
least 34 times to bring loaded Concrete Casks into the ISFSI and to connect the temperature monitoring instrumentation. Anytime loaded Concrete Casks are stored in the ISFSI, entry into the ISFSI is also required at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for a visual inspection. When access occurs i
so frequently, personnel working in the ISFSI could become complacent to the significance of i
High Radiation Areas if the entire ISFSI is categorized and treated as such. Furthermore, with i
the entire ISFSI already classified as a High Radiation Area, personnel are likely to be less i
u
-. ~ ~. -
j L
L
~ Enclosure 2 to VPN-038-99 I
j' March 18,'l'999 i
l Page 2 of 2 1
sensitive to changes in radiation doses at specific locatic ns. Regardless of the precautions taken, i
there would be an increase in the likelihoc,d of higher radiation doses from this practice.
i Similarly, it is not practical or an efficient use of resources to erect a locked barrier around the sides of the Concrete Casks with dose rates in excess of 100 mrem /hr at the top to comply with 10 CFR 20.1601 (a). Accessing the top of the 15-foot high, smooth-sided Concrete Casks is not i
an easy nor a normal operation. This aspect of the Concrete Casks ahng with the controls in
- proposed ISFSI Technical Specification 5.6 is considered a sufficient barrier to achieve the goal of preventing unauthorized entry into S Mig,n Radiation Area at the top of the Concrete Casks and to maintain exposure as low as reasonably chievable.
. Radiation doses at the top of other ISFSIs designed oy BNFL Fuel Sources (BFS, formerly Sierra i Nuclear Corporation, SNC), i.e., VSC 24 Casks are on the order of 40 mrem /hr, about half of the. i minimum dose rate to be categorized as a High Radiation Area. However, the spent fuel at those i
other installations had already decayed over ten years and was of a lower heat load than the spent i
fuel at Trojan. The VSC 24 Storage Systems are designed somewhat differently than the Trojan i
TranStor System which has less shielding in the top than the VSC 24 Casks.
i
==
Conclusion:==
j Based upon the above, it is recommended that the approach to controlling access to High I
Radiation Areas with dose rates in excess of 100 mrem /hr but less than 1000 mrem /hr be as submitted in proposed ISFSI Technical Specification 5.6 in accordance with 10 CFR 20.1601 (c) as an alternative to 10 CFR 20.1601 (a).
i I
i i
STATE OF OREGON,
)
)
)
COUNTY OF COLUMBIA
)
I, S. M. Quennoz, being duly sworn, subscribe to and say that I am the Vice Presid.nt Nuclear and Thermal Operations for Portland General Electric Company, the licensee herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best u 'my knowledge, information, and belief the statements made in it are true.
2d /!
,1999 Date MWe =
j S. M. Quennoz Vice President Nuclear and Thermal Operations Portland General Electric Company On this day personally appeared before me, S. M. Quennoz; to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free j
act.
GIVEN under my hand and seal this /
day of l/l)
,1999.
'/
A2 0FFICIAL SEAL 9
COMMISSIONN0.045755
/
PAT SCHAFFRAN Notary 1 ubli for the NO M PUBLC M G M State of n
MY COMMISSION EWIRES.lULY271999 Residing at _
M My commission expires %47-99 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY
)
Docket 72-017 THE CITY OF EUGENE, OREGON, AND
)
PACIFIC POWER & LIGHT COMPANY
)
(TROJAN NUCLEAR PLANT)
)
l CERTIFICATE OF SERVICE I hereby certify that copies of the Trojan Nuclear Plant, Independent Spent Fuel Storage Installation Emergency Plan, dated March I8,1999, have been served on the following by hand delivery or by deposit in the United States Mail, first class, this 18th day of March 1999:
Director, Oregon Office of Energy State of Oregon 625 Marion Street NE, Suite 1 Salem, Oregon 97301-3742 Chairman of County Commissioners Columbia County Courthouse St. Helens, Oregon 97051
=
L.G,8us'ek Manager, Nuclear Regulatory Affairs On this day personally appeared before me L. G. Dusek, to ine known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act.
GIVEN under my hand and seal this 18th day of March 1999.
OFRCIAL SEAL 9
NOTARYPUBUC-OREGON PAT SCHAFFRAN Nota P blic in and for the State f Oregon My 27 1999 Residing at /8drl'Wd My commissh^n expires 747-W l
I i