ML20205F949
| ML20205F949 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/08/1985 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| KMLNRC-85-246, NUDOCS 8511130069 | |
| Download: ML20205F949 (7) | |
Text
.
KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY SLENN L. MOESTER vscs persiosst. hucLean Novenber 8, 1985 Mr. Harold R. Denton, Director Office of Nticlear Reactor Regulation U.S. Eclear Regulatory Comission Trhshington, D.C.
20555 KMLNRC 85-246 RE:
Docket No. STN 50-482 SUBJ: Response to Request for Additional Information on 10 GR 20 Exenption REF:
- 1. KMLNRC 85-167 Dated at:1y 1,1985, from GLKoester, KG&E, to HRDenton, NRC
- 2. Ietter dated Septenber 5, 1985, from BJYoungblood, NRC to GMoester, KG&E
Dear Mr. Denton:
In Reference 1 KG&E requested an exenption to 10 CPR 20 respiratory protection requirements relating to iodine filters.
In Reference 2 the NRC staff requested additional information on this request.
The attachment to this letter is KG&E's response to Reference 2.
I you have any questions please call Otto Maynard at (316) 364-8831 extension 2060.
Yours ry truly,
/
mV Glenn L. Koester Vice President - m clear Gm:see xc: PO'Connor (2) w/a JCummins w/a hok"bK
$2 P
i 201 N. Market -WicNta, Kansas - mar Address Ro. Box 208 I Wichita, Kansas 67201 - Telephone: Area Code (316) 261-6451
_ Question ~
1.
'Your submittal of July 1, 1985 indicates that the exemption can tesult
'in potential person-rem reductions over the life of the plant. Briefly discuss particular tasks you have identified which could result'in such dose savirgs and/or provide ~ examples of relevant industry experience in
~ this area (e.g. Farley 1 & 2, San Onofre).
~ Response-s Ll.
Listed in Table 1(see attachment) are' tasks that have been identified at Farley 1 and 2 as having the potential for person-rem reductions by using a full face respirator instead of an airline respirator _or self contained breathing apparatus. The total exposure figure is arrived at by multiplying the task time estimated in the area by the general field.
dose rate.
-Question 2.
Discuss facility programs intended to preclude high radioiodine levels.
Include a general description of fuel quality assurance and r
quality control, as well as routinely practiced operational techniques, engineering controls, ard procedures used to prevent use of faulty i
_ fuel, prevent fuel damage, and minimize the radiological impact of potential fuel defects (e.g. coolant purification,' chenistry control,
. sampling, degasification, planned decay, fuel shipping and replacanent).
Response
2.-
.Ihe Wolf Creek Generating Stations nuclear fuel assemblies are,
fabricated under-the Westinghouse QA/QC program described in NCAP-7800.
IG&E's. quality assurance department audits and approves the Westinghouse Oh progran at least once every three years.' In addition, IC&E's Nuclear Fuel Engineering group performs reviews on the fabrication processes and QC inspection procedures to ensure the
- quality of the fuel being delivered to Wolf Creek. Fuel handling F
' proce$ures are used to prevent fuel damage during fuel movenent.
Procedures are used to detect faulty fuel and prevent the usage of faulty fuel.
~
l.
Operational-techniques used to preclude high radioiodine levels are discussed below:
l1
'l.
Engineering controls - Where a breach of the reactor coolant system occurs (general work area or steam generator manway) negative pressure exhaust (or air handling) units are used to reduce airborne concentrations in work areas.
lC 2.
Reactor coolant cleanup / purification - chenistry control:
Hydrogen peroxide is used to induce crud bursts for pre-outage cleanup.
3.
LDegasification: Degasification of the reactor coolant system is
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required in the normal shutdown procedures.
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Area decontamination: Frequent decontaT.ination of work areas where the reactor-coolant syste _is breached is routinely implemented to minimize airborne radiaoctivity.s 5.
Decay Schme: _ Major breaches of the reactor coolant system are planned in the outage schedule to allow the maximum amount of time practical for radioiodine decay.
Question 3.
Provide a.comitment that training programs will be modified and training will be. conducted to instruct sorbent canister users and
- health physics personnel in the proper field use of these canisters,' as well as the limitations and restrictions regarding their use. Identify the specific procedures related to such training:and to use and control
-of these canisters.
Response
3.
Respirator training program lesson plans will be modified to include the specific aspects of issue and use of GMR-I canisters prior to
'taking a protection _ factor-greater than 1.
Health Physics procedures will outline _the limitations and restrictions pertaining to the use of G m-I canisters.
Question 4.
. Describe how vendor-and facility quality assurance and quality control
'will be verified for the Gm-I canister. This should include a y
discussion of how the licensee will verify and accept MSA's QA procedures for the GMR-I canister (i.e. Mil Std 414), and how on-site quality control will be maintained to assure identification, use and storage ~of QA'd GMR-I canisters.
Response
4.
An audit has been scheduled at the vendor facility to review the QA/QC 4' -
program in effect for the GMR-I canister. In addition, control (including identification), storage and use of GMR-I canisters will be included as part of the on-site audits /surveillances of the radiation protection program. Results of these audits /surveillences will be available for NRC review.
Question 5.
Provide a comitment that on-site storage in a cool, dry environnent will meet QA Class A Storage as outlined in ANSI N45.2.2, or an-equivalent inspectable storage criteria. Note that canister ptorage in field use/ issue areas need not meet such criteria if such storage is
' temporary and related to field issue and use.
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Response
S.
O!R-I canisters not in the respirator issue area will be stored in a i
0 F or 70% humidity. The cool, dry enviroment which will not exceed 90 storage area environmental conditions are recorded by way of strip charts and routinely monitored.
CNR-I canisters for field use will be temporarily stored in a dry environnent in the issue area with their factory packaging seals intact. A minimm amount of GMR'-I canisters will be stored outside of the controlled enviroment.
~
Ouestion 6.
Provide a comitment to verify the effectiveness of CNR-I canister use, to include the following, or equivalent, controls:
a.
weekly whole body counts for individuals using the GMR-I canister for radioiodine protection; S.
for individuals who exceed 10 MPC hours, a whole body count will be required prior to the individual's next entry into a radioiodine atmosphere; c.
establish an uptake level beyond which further entry into a radioiodine atmosphere would be restricte3, pending health physics evaluation (e.g. at 70 nCi);
d.
establish a data base of survey data and whole body counts _to be usal to evaluate the effectiveness of the program.
Response
6.
The following measures will be used at WCGS, by procedures, to verify the effectiveness of GMR-I canisters for radiciodine protection:
a.
weekly whole body counts shall be required for individuals who use the GMR-I canister for radioiodine protection; b.
individuals who exceed 10 MPC hours exposure to radioiodine shall be required to have a whole body count prior to the individual's next entry into a radioiodine atmosphere; c.
if an individual measures 70 nCi or greatee iodine uptake to the thyroid during a whole body count, his entry into radioiodine abnospheres will be restricted pending health physics evaluation; d.
a whole body count data base will be compiled to evaluate the effectiveness of the radioiodine protection program.
Upon collection of a data base which is adequate to judge the results of the above verificatio:1 program, we propose to relax these limitations in a stepwise fashion, if necessary, to controls conmensurate with the hazard involved and within our current respiratory protection program.
~
Question 7.
Provide additional details regarding the limitation and controls for use of the Gm-I canisters as follows:
Identify those organic vapors of concern at Wolf Creek (e.g.
a.
freons, alcohols, carbon tetrachloride, paint fumes, EDIA, etc.)
where CNR-I canisters are to be used or stored; b.
Outline the methods and procedures to be used to preclude the presence of organic vapors in canister use areas, and briefly discuss detection and sampling methods to be used, where the are feasible. Outline the sampling program for radioiodines and what measures will be taken to establish baseline data for organics which are not readily samples or detected.
c.
Discuss the frequency and conditions for determination of temperature and dew point / relative htnidity during canister use.
0 0
(120 F is acceptable if dew point does not exceed 107 g),
Response
7 a.
N indiscriminant use of chemical products is prohibited at NOGS for health arx3 system contamination concerns. The following compounds are permitted which may result in organic vapor release: paint; paint thinner / remover (methylethylketone); freon cleanir.g agent (trichlorotrifluoro ethane); isopropyl alcohol; and methyl chloroform. Organic vapor exposure is not a m ncern in respirator storage areas. N canisters are purchased in a hermetically sealed condition and are not opened until placed in use at the work location.
b.
Safety related ventilation filtration systems at NOGS contain charcoal for atmospheric radiciodine removal and require measures to provent organic vapor contamination for reasons similar to GiR-I concerns. Measures will be implenented to prohibit painting and chemical releases in areas where a protection factor for the GiR-I canister is taken. The canister will not be used after recent painting or use of organic substances. Additionally, for those occasions when paintirx3 is permitted in areas served by safety related ventillation systems, use of GM-I canister will be restricted. These provisions will be included in Q4R-I canister use procedures. In-plant radioiodine concentrations will be evaluated in accordance with station Health Physics procedures.
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c.
Temperature and dew. point will be measured at the beginning of a shift in the area where the G R-I canister will be utilizedc if the plant is in mode.five (5) or six (6).. Ihereafter, temperature -
s will be measured once per shift _or coincident with evolutions which would impact upon. temperature or humidity in' the area of concern to insure that the limitation is not exceedei. The temperature and dew point limitations will be in the Gm-I use procedures.
i Question
' 8..
Verify that facepiece protection factors will have been determined by fit test to be greater than 100 PF capability.
Response
8.
Facepiece protection factors will have been determined by fit test to be greater than 100 PF capability. Station a&ninistrative limits require a fit booth protection factor greater than 100 prior to approval for use of a full face air purifying respirator.
Question 9.
Identify existing requirarents (related to Q471.7), such as technical specifications for main IEPA filter banks, which provide measures of control for the environments where Gm-I canisters will be used, and briefly indicate how they contribute to control cf use and conditions.
Response
9.
Prior to entry into environnents where GR-I canisters will be used air samples will be taken-to determine airborne radioiodine levels as per.
procedures. Tech Spec. 3/4.7.7 specifies the availability of the energency exhaust system in case of high airborne concentration
. levels. 'Ihese measures of control are used for determining if additional steps (air ' exchanges, more decay time,-etc.) ~ need to-be taken to insure exposure to airborne radioiodine is maintained ALARA.
4
Table 1 Task Dose Rate Man Power Task Time Total Exposure (mR)
Exposure Reduction (General field) with Airline respirator or SCBA-(A)
(A - B)
(mR/hr) with GMR-I canister (B)
Presrure Safety 26 6
7 182 Valva Testing 6
- 5 130-52 Contairrnent -
11 6
57 627 Sump Work 6
37 407 220 RCS Seal Inspect 55 "12 180 9900 cnd Replace 9
135 7425 2475-Rcactor Cavity 22 18 314 6908 Decon 18 235-5170 1738 RHR Check 37 5
52 1924 Valve Repair 4
39 1443 481 Acetrnulator Check 45 8
77 3465 Valva Repair 6
58 2610 855 RHR Heat Excharger 59 13 144 8496 Gasket Replacement 10 100 5900 2596 Spent Fuel Pool 4
21 252 Transfer Canal Work 12 4
16 192 60 Contairunent Entry 9
27 2025 at 100% Power 75 6
12 900 1125 Incore Thimble 17 16 90 1530 374 Cleaning 12 68 1156 Total with Airline Respirator or SCBA 35309mR 9976mR
=
Total with Gm-I canister 25333mR
=
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