ML20205K046
| ML20205K046 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 03/23/1987 |
| From: | Ainger K COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 2892K, NUDOCS 8704010499 | |
| Download: ML20205K046 (4) | |
Text
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} Commemlveelth Edloon i
One First National Plaza. Chcago, Illinois
\\,U/ Address Reply to: Post Omco Box 767 1
Chicago, Illinois 60690 0767 March 23, 1987 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Application for Amendment to Facility Operating Licenses NPF-37 and NPF-66, Appendix A, Technical Specifications NRC Docket Nos. 50-454/455 and 50-456/457 References (a): January 6, 1987 letter from S. C. Hunsader to H. R. Denton (b): March 4, 1987 letter from K. A. Ainger to H. R. Denton
Dear Mr. Denton:
Reference (a) transmitted a request for an amendment to the Technical Specifications that would allow for reconstitution of a fuel assembly. Reference (b) responded to a request for additional information regarding radiation protection measures for fuel reconstitution activities.
An additional question regarding radiation protection has been raised by the NRC, in light of fuel reconstitution experience at the San onofre Station, that pertains to a potential contamination concern with " hot" particles.
Attachment A of this letter contains a list of radiation protection guidelines to be followed during the reconstitution activities. These guide-lines may be revised as necessary during the reconstitution process, but only after consulting with cognizant radiation protection supervision personnel.
We believe these guidelines will help to prevent the contamination concern mentioned above.
0704010499 B70323
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PDR ADOCK 05000454 3
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Mr. H. R. Denton March 23, 1987 Reference (b) discussed the qualifications of the Station Health Physicist at Byron Station. The Braidwood Station Health Physicist has similar credentials that meet Regulatory Guide 1.8 qualifications in accordance with Technical Specification requirements. The NRC Staff has concurred with this as noted in Section 12 of Supplement 1 of the Braidwood SER (NURBG-1002).
Please direct any questions you may have concerning this matter to this office.
Very truly yours, 4
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K. A. Ainger Nuclear Licensing Administrator 1m Attachment cc: Resident Inspector - Byron Resident Inspector - Braidwood j
Region III Office 2892K 1
Attachtnerit A FUEL RECONSTITUTION RADIOLOGICAL CONTROLS 1.
A HEALTH PHYSICS TECHNICIAN WILL BE IN CONTINUED ATTENDANCE.
2.
ALL RECONSTITUTION EQUIPMENT COMING OUT OF THE FUEL POOL MUST BE SMEARED AND CHECKED FOR BETA AND ALPHA AND SURVEYED FOR BETA AND GAMMA EXPOSURE RATES.
3.
SMEARS WILL BE TAKEN OF THE GENERAL WORK AREA WHENEVER ITEMS ARE BROUGHT OUT OF THE POOL AND EVERY FOUR HOURS OTHERWISE.
THE GENERAL AREA SMEARS TO CHECK FOR FLEAS OR OR HOT PARTICLES WILL BE LARGE AREA SMEARS - THESE MAY BE TAKEN WITH A MASLIN BROOM.
SMEARS FOR QUANTIFICATION OF GENERAL CONTAMINATION LEVELS WILL BE PERFORMED AS IS DONE NORMALLY AND OF A 100 SQ. CM. AREA.
4.
THE STEP-OFF PADS WILL BE SMEARED FOLLOWING THE CREW'S EXIT FOR BREAKS OR SHIFT CHANGES.
5.
SHIFT RADIATION PROTECTION SUPERVISION IS TO BE PROVIDED BY R.
ATKINS OR K.
PAINTER OR AN APPROVED ALTERNATE AS DETERMINED BY A CECO H.P.
6 AN AMS-3 WILL BE UTILIZED.
THIS MAY BE BACKED-UP WITH REPEATED PORTABLE AIR SAMPLES FOR PERIODS SHOULD THE AMS-3 BE INOPERABLE.
7.
TOOLS BEING UNPACKED FOR USAGE ON THIS JOB ARE TO BE SMEARED FOR ALPHA AND BETA AND EXPOSURE RATES FOR BETA AND GAMMA DETERMINED.
8.
IF ANY SMEARS INDICATE THE PRESENCE OF ALPHA, AIR SAMPLES WILL BE SCREENED BY APPROPRIATE MEASURES FOR ALPHA.
9.
THE FOLLOWING EQUIPMENT IS REQUIRED AT THE JOB SITE:
- EC4
- RO-7 WITH UNDERWATER PROBE
- HAND-HELD GM AND ALPHA PROBES WITH ASSOCIATED METERS
- 10. PRIOR TO THE BEGINNING OF THE JOB AND THROUGHOUT THE JOB AS DEEMED NECESSARY THE WORK CREW WILL BRIEF RADIATION PROTECTION PERSONNEL ON THE PROTECTIVE MEASURES (BOTH 4
PROCEDURES AND EQUIPMENT) TO PRECLUDE BRINGING FUEL OR PARTS OF A BUNDLE TO WITHIN TEN FEET OF THE SURFACE.
- 11. THE ALARA GROUP WILL VIDEO ASPECTS OF THE JOB FOR OUTSIDE VIEWERS AND FOR FUTURE USE IN THE ALARA FILE.
- 12. WHENEVER A WORKER EXITS THE AREA A HEALTH PHYSICS TECHNICIAN WILL SURVEY WORKERS FOR FLEAS AND HOT PARTICLES PRIOR TO REMOVING THE OUTER PROTECTIVE LAYER.
(THIS IS NECESSARY TO DO A DOSE ASSESSMENT SHOULD THE WORFER HAVE HAD A FLEA OR HOT PARTICLE ON THEM.)
THE TECHNICIAN WILL ALSO SURVEY THE INNER PROTECTIVE CLOTHING DEFORE REMOVAL. (THIS IS NECESSARY TO VEEP HOT PARTICLES AND FLEAS OUT OF THE LAUNDRY).
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FUEL RECONSTITUTION RADIOLOGICAL CONTROLS
- 13. WHENEVER WORK IS GOING ON AND ITEMS ARE BEING HANDLED OR PUT INTO OR TAKEN OUT OF THE FUEL POOL, THE WORKERS WILL HAVE THEIR OUTER PROTECTIVE CLOTHING CHECKED HOURLY FOR HOT PARTICLES AND/OR FLEAS. WHEN AN INDIVIDUAL IS CHECKED FOR FLEAS OR HOT PARTICLES IT WILL BE WITH A GM OR ION CHAMBER INSTRUMENT WITH THE WINDOW OPEN, AS APPROPRIATE.
- 14. A DEMIN.
WATER WASH DOWN IS REQUIRED OF ALL i
RECONSTITUTION RELATED ITEMS COMING OUT OF THE POOL.
IT IS DESIRABLE TO PERFORM A DEMIN WATER RINSE OF ITEMS BEFORE THE ARE PUT IN THE POOL.
- 15. THE HIGHEST LEVEL OF CECO SUPERVISION PRESENT UP TO THE STATION HEALTH PHYSICIST LEVEL WILL BE INFORMED j
IMMEDIATELY OF SIGNIFICANT RADIOLOGICAL PROBLEMS INCLUDING AIRBCRNE PROBLEMS, THE DISCOVERY OF FLEAS OR HOT PARTICLES, EXPOSURE CONCERNS, PERSONNEL CONTAMINATIONS, ETC.
- 16. ALL HOT PARTICLES OR FLEAS ARE TO BE SAVED.
D.
GOLDSMITH WILL DETERMINE WHEN THESE ARE TO BE DISPOSED OF.
- 17. ITEMS BEING REMOVED FROM THE POOL FOR ANY EXTENDED LENGTH OF TIME WILL BE BAGGED OR PLASTIC WRAPPED.
- 18. AN ALARA PRE-JOB BRIEFING IS REQUIRED WITH THE WORK CREW, THE HEALTH PHYSICS TECHNICIANS AND SUPERVISION IN ATTENDANCE.
- 19. IT IS A HIGH PRIORITY TO KEEP THE IPM-7 MONITORS OPERATIONAL. THIS IS NECESSARY AS THEY ARE THE BEST INSTRUMENT IN DETERMINING THE PRESENCE OF FLEAS OR HOT PARTICLES.
SHOULD THESE MONITORS BECOME INOPERABLE IMMEDIATE ACTIONS SHOULD BE TAKEN TO RESTORE THEIR OPERABILITY.
- 20. HEALTH PHYSICS TECHNICIANS SHOULD BE ESPECIALLY THOROUGH IN CHECKING FOR FLEAS WHERE EQUIPMENT PHYSICALLY CONTACTS ANY PORTION OF THE FUEL BUNDLE.
THIS IS BECAUSE THESE PLACES ARE THE MOST LIKELY ONES TO SEE FLEAS.
- 21. EITHER ISOTOPIC ANALYSIS AND/OR THE USE OF STAINLESS STEEL ABSORBERS SHOULD BE UTILIZED FOR DETERMINING THE DIFFERENCE BETWEEN FLEAS AND HOT PARTICLES.
CONTACT HEALTH PHYSICS SUPERVISION AS NECESSARY FOR GUIDANCE ON THIS.
- 22. HEALTH PHYSICS TECHNICIANS NEED TO BE AWARE THAT FLEAS BEHAVE IN A MANNER THAT HAS BEEN DESCRIBED AS A GRAIN OF SAND.
THEY MAY NOT " SMEAR-UP" LIKE DIRT USUALLY DOES.
THEY DO NOT OFTEN STICK WELL TO SURFACES.
- 23. PERSONNEL CONTAMINATED WITH HOT PARTICLES OR FLEAS MUST BE ASSESSED FOR THE NEED FOR SKIN DOSE CALCULATIONS AS 1
SOON AS POSSIBLE.
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