ML20209D897
| ML20209D897 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 02/06/1985 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Thomas C Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-1362 NUDOCS 8502110291 | |
| Download: ML20209D897 (1) | |
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MEMORANDUM FOR: Cecil 0. Themas, Chief, Standardization and Special Projects Branch, Division of Licensing FROM: Olan D. Parr, Chief, Auxiliary Systems Branch, Division of Systems Integration
SUBJECT:
REVIEW 0F VITAL AREAS FOR WNP-3 As requested in your memorandum dated December 3,1984, the Auxiliary Systems Branch has reviewed Section 4.0, Identification of Vital Areas and the Appendix of the safeguards safety evaluation report for WNP-3. Based on that review, we have identified no concerns related to meeting 10 CFR 73.55 requirements.
h Olan D. Parr, Chief Auxiliary Systems Branch Division of Systems Integration cc: R. Bernero L. Rubenstein D. Crutchfield J. Wermiel E. McPeek V. Nerses
Contact:
J. Wermiel X29462 Distribution Docket File ASB Rdg. File ASB Members 0Parr OFC :DI:Ap :DSI:ASB a: : : : :
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DATE :2/6/85 :2/7/85 : : : : :
OFFICIAL RECORD coov 8 2110291 850206 '
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NUCLEAR REGULATORY COMMISSION WASMNGToN, D. C. 20555 g ..v..+ j ,
Docket No.: 50-508 CT 311993 MEMORANDUM FOR: Thomas M. Novak Assistant Director for Licensing, DL FROM: Daniel R. Muller Assistant Director for Radiation Protection, DSI
SUBJECT:
DRAFT SAFETY EVALUATION REPORT PLANT NAME: Washington Public Power Supply System, Nuclear Project No. 3 (WPPSS-3)
LICENSING STAGE: OL DOCKET NUMBER: 50-508 RESPONSIBLE BRANCH: LB #3; A. Vietti, LPM DESCRIPTION OF RESPONSE: Draft SER Input REVIEW STATUS: Continuing The Radiation Protection Section of the Radiological Asessment Branch has completed its review of Chapter 12 of the Washington Public Power Supply, Nuclear Project No.3 FSAR which includes sections en.suring that occupational radiation exposures are as low as is reasonably achievable (ALARA) (12.1), as well as describing radiation sources (12.2), radiation protection design fea-tures (12.3), dose assessment (12.4), health physics program (12.5) and related sections.
The attached draft SER contains eight open items, which are indicated below:
- 1. (471.1) The applicant should inform the NRC whether or not post-accident radiation monitors for the containment and sampling area will be provided in compliance with Regulatory Guide 1.97 or should provide the basis for an acceptable deviation.
- 2. (471.6) Regulatory Guide 1.70 and the SRP (NUREG-800) state that the de-scription of health physics instrumentation should include the instrument's sensitivity. The applicant provided in Table 12.5-1 the type of radiation the instrument detects but not the instrument sensitivity. The applicant should provide the instrument sensitivity.
- 3. (471.12) Table 12.2.2-2 and 12.2.2-3 of the FSAR shows maximum expected concentrctions in air, in numerous locations of the plant, in excess of the maximum permissible concentration as defined in 10 CFR 20.203(d)(1)(ii).
The applicant as should r m he t
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. Thomas M. Novak 2
- 4. (471.14) The dose breakdown for refueling work in Table 12.4-8 does not agree with the dose for refueling work given in Table 12.4-2. The appli ~
cant should resolve the discrepancy.
- 5. (471.21) The applicant should describe how the airborne radioactivity man-itoring system will detect ten MPC-hours of radioactivity (particulates, 1 iodine, and noble gases) from any compartment which could contain air-borne radioactivity and which could be occupied by personnel as per SRP, NUREG-800, Section 12.3-12.4, 4.b.1.
- 6. (471.23) As per SRP, NUREG-800, the applicant should commit to the imple-mentation of Regulatory Guide 8.12 and N16.2-1969 or provide a description of an alternative approach relative to the requirements for a criticality accident alarm system, and to Regulatory Guide 8.14 as it relates to use of personnel neutron dosimeters.
- 7. (471.26) The applicant proposed portable, audible and visual radiation alarm equipment fo'r the fuel transfer tube access to be installed if condi-tions warrant. This is not acceptable as it is not in compliance with NUREG-0800. The applicant should commit to the implementation of NUREG-0800, or equivalent.
- 8. (471.27) The applicant should revise the range of containment Post-Accident monitors in Table 12.3.4-1 to comply with NUREG-0737, Item II.F.1-3.
This review was performed by F.C. Skopec RPS/RAB
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nfA Y/7st L Daniel R. Muller, Assistant Director for Radiation Protection Division of Systems Integration
Attachment:
As stated cc: R. Mattson F. Congel
- 0. Lynch G. Knighton A. Vietti F. Skopec
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Document Name:
WPPSS-3 SER INPUT SEC 12- '
Requestor's ID:
IRENE ,,
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Author's'Name:
- 1. Skopec, DSI 1
Document Conunents:
- KCI/743 RETURN THIS SHEET WHEN YOU SUBMIT REVISIONS O
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DRAFT SAFETY EVALUATION REPORT FOR WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT No. 3 (WPPSS-3)
BY THE RADIOLOGICAL ASSESSMENT BRANCH
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3 ;m 12 RADIATION PROTECTION The staff has evaluated the proposed radiation protection program presented in
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Chapter 12 of the Washington Public Power Supply System Nuclear Project No. 3, (WPPSS-3) FSAR against the review guidelfnes, and criteria set forth in the Standard Review Plan (SRP), NUREG-0800, Section 12. The radiation protection measures at WPPSS-3 are intended to ensure that internal and external radiation dose to plant personnel and contractors, due to plant conditions, including anticipated operational occurrences, will be within applicable limits of 10 CFR 20, and will be as low as is reasonably achievable (ALARA).
The basis of the staff's acceptance of the WPPSS-3 radiation protection program is that doses to personnel will be maintained within the limits of 10 CFR 20,
" Standards for Protection Against Radiation." The applicant's radiation protec-tion design and program features are consistent with the guidelines of Regula-tory Guide 8.8, "Information Relevant To Ensuring That Occupational Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" (Rev. 3).
On the basis of this review, the staff concludes that the radiation protection measures incorporated in the design and the proposed radiation protection program will provide a reasonable assurance that occupational doses will be maintained ALARA and below the limits of 10 CFR 20 both during plant operation and during decommissioning.
12.1 Ensurino That Occuoational Radiation Doses Are As Low As Is Reasonably Achievable The staff has audited the policy considerations, design considerations, and operational considerations contained in the WPPSS-3 FSAR against the criteria set forth in NUREG-0800, Section 12.1. The staff review consisted of ensuring that the applicant had either committed to following the criteria of the regulatory guides and staff positions referenced in NUREG-0800 (SRP)
Section 12.1 or provided acceptable alternatives. In addition, the staff selectively reviewed the applicant's FSAR against the acceptance criteria of 12-1
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the SRP using the review procedures in the SRP. This selective review found
- the plant acceptable in these areas. Details of the review follow.
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12.1.1 Policy Considerations i
The applicant provides a management commitment to ensure that WPPSS-3 will be designed, constructed, and operated in a manner consistent with Regulatory
- j. Guides 8.8 and 1.8 " Personnel Selection and Training" (Rev.1). The applicant has committed to implement a radiation protection program in accordance with Regulatory Guide 8.10 " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable." The overall ALARA responsibility, upper management direction and support lies with the Director of Support Services. The. Plant Manager is responsible for the radiological safety of all in plant personnel and the implemenation of ALARA Policy by his staf* The Plant Health Physics / Chemistry Manager is responsible for develop-ment of good procedures and radiation protection practices, including pre-planning, use of equipment and work techniques.
In addition, line supervisors are also responsible for maintaining plant doses ALARA. The ALARA philsophy was applied during the initial design of the plant. Since then, the applicant has continued to review, update, and modify the plant design and construction phases. The plant's staff - Health Physics and Chemistry, periodically review, update, and modify plant design features and maintenance features as appropriate, using dose data and experience gained from operating nuclear power plants. This is done to ensure that occupational doses will be kept ALARA in accordance with Regulatory Guide 8.8 and NUREG-0800 criteria.
12.1.2 Design Considerations The objective of plant radiation protection design is to maintain individual personnel doses ALARA as well as the collective doses of all personnel and within the limits of 10 CFR Part 20.
The applicant, using feedback information from operating plants and following guidelines of Regulatory Guide 8.8, has incorporated facility and equipment 12-2
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, design improvements at St. Lucie 1 and 2, and Waterford 3, which plants are j similar in design to WPPSS-3, to satisfy the plant's radiation protection -
design objectives.
Examples of these design features include:
1 (1) Packaging of units, skid mounted for free access and quick remoral to a i low radiation area for maintenance or repair.
(2) Most pumps are flanged to facilitate ease of removal to a low radiation area, pump casings are provided with drain connections and pumps are equipped with mechanical seals for greater reliability and reduction in servicing time.
(3) Ion exchangers are designed for complete drainage, spent resin is removed remotely by hydraulically flushing the resin to the solid waste management system.
(4) Absorber (Charcoal) Beds are completely drainable, with single point connections for charcoal removal and equipped with accessories to provide a safe and rapid removal of contaminated charcoal.
(5) Tanks are designed to be isolated for maintenance and are completely drainable, and flushable, with a minimum of crevices to avoid accumulation of radioactive crud.
- These design considerations conform with the guidelines of Regulatory Guide 8.8 and NUREG-0800 and are acceptable. -
12.1.3 Operational Considerations The WPPSS-3 operational considerations included the development of a radiologi-cal training program using the guidelines of Regulatory Guide 8.27, " Radiation Protection Training for Personnel at Light-Water Cooled Nuclear Power Plants" and 8.29 " Instruction Concerning Risk From Occupational Radiation Exposure," a radiation zoning and access control system, and general guidelines for worke:s 12-3
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f performing maintenance in high radiation areas. These operational considera- l tions are to ensure that operating and maintenance personnel will follow speci- j fic plans and procedures in order to ensure that ALARA goals are achieved in
! the. operation of the plant. High radiation exposure operations are to be pre- i planned and carried out by personnel trained in radiation protection and using proper equipment. During such activities, personnel will be monitored for ex-i posure to radiation and contamination. Upon completion of major maintenance I jobs, personnel radiation exposures will be evaluated and compared with pre-dicted person-rem exposures. The results are used to make changes in future job procedures and techniques. The plant's' health physics management will periodically review radiation dose trends to determine major problem areas and to determine which worker groups are accumulating the highest dose. Plant personnel will use these findings to recommend design modifications or changes in plant procedures. The operational considerations conform to Regulatory Guides 8.8 (Rev. 3), and to NUREG-0800 and are acceptable.
The staff concludes that the policy, design and operational considerations at WPPSS-3 are adequate to ensure that occuppational radiation exposures will be ALARA in accordance with Regulatory Guides 8.8 and 8.10 and meet the criteria of NUREG-0800 and are acceptable. .
12.2 Radiation Sources The staff has audited the contained sources and airborne radioactive material source terms provided in Section 12.2 and Chaper 11 of the WPPSS-3 FSAR against th'e criteria set forth in Section 12.2 of NU' REG-0800. These source terms are used as inputs for dose assessment and for the design of the shielding and ventilation systems. The staff review consisted of ensuring that the appli-cant had either committed to following the criteria of the regulatory guides and staff positions referenced in Section 12.2 of NUREG-0800 or provided acceptable alternatives. In addition, the staff selectively compared source terms for specific systems used by the applicant against those used for plants of similar design. This selective review found the plant's source terms equivalent to those used at other plants. Details of the review follow.
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,m - (m 12.2.1 Contained and Airborde Sources Inside the containment during power operation, the greatest potential for per-sonnel dose during operation is due to nitrogen-16, noble gases, and neutrons.
Outside the containment and after shutdown inside the containment the primary sources of personnel exposures are fission products from fuel cladding defects and activation products, including activated corrosion products. Almost all of the airborne radoactivity within the plant is due to equipment leakage. The fission product source terms are based on 1% fuel cladding defect at full power f
operation. The coolant and corrosion activation product source terms are based on operating experience and reactors of similar design; allowances are included for the buildup of activated corrosion products. Neutron and prompt gamma source terms are based on reactor core physics calculations and operating experience from reactors of similar design. The source terms presented are comparable to estimates by other applicants with similar design and are acceptable.
The applicant has provided a tabulation of the maximum expected radioactive airborne concentrations in equipment cubicles, corridors, and operating areas, from equipment leakage. The bases or these leakage calculations are in accor-dance with Regulatory Guide 1.112, " Calculations of Releases of Rauioactive Materials in Gaseous and Liquid Effluents From Light-Water-Cooled Power Reactors," and are acceptable.
The WPPSS-3 FSAR shows maximum expected radioactive airborne concentra-tions in some plant areas in excess of maximum permissible concentration as defined in 10 CFR 20.203(d)(1)(ii). The applicant should resolve this discrepancy and, until resolution, this item will remain open (471.12).
The ventilation system will be designed to provide sufficient solume changes per hour in occupied areas which may contain significant airborne activity to maintain exposure to personnel ALARA. Air will be routed from areas of low potential airborne contamination to areas of increasing potential airborne contamination. The resulting estimated airborne radioactivity concentrations in frequently occupied areas will be a small fraction of 10 CFR 20.103 limits and are ac".eptable. In accordance with NUREG-0800, the source terms used to 12-5
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develop these airborne concentration values are comparable to estimates by other applicants with similar design and are acceptable.
12.3 Radiation Protection Desian Features
! The staff has audited the facility design features, shielding, ventilation, 4
and radiation and airborne monitoring instrumentation contained in the WPPSS-3 l FSAR against the criteria set forth in NUREG-0800, Section 12.3. The staff
! review consisted of ensuring that the applicant had either committed to following
, the criteria of the regulatory guides and staff positions referenced in Section 12.3 of NUREG-0800, or provided acceptable alternatives.
In addition, the staff selectively reviewed the applicant's FSAR against the specific areas of review and review procedures identified in NUREG-0800. This review found the plant acceptable in these areas. Details of the review follow.
12.3.1 Facility Design Features The applicant has provided evidence that the dose accumulating functions performed by workers have been considered in the plant design. Features have been included in the design to help maintain doses ALARA in the performance of those functions. These features will facilitate access to work areas, reduce or allow the reduction of source intensity, reduce the time required in the radiatior. fields, and provide for portable shielding and remote-handling tools. The applicant's facility design features are consistent with the guidance of Regulatory Guide 8.8 (Rev. 3) and NUREG-0800. Therefore, the staff concludes that the facility design features are acceptable.
The applicant has provided five radiation zones as a basis for classifying occcupancy and access restrictions for various areas within the plant. On this basis, maximum design dose rates are established for each zone and used as input for shielding of the respective zones. The areas that will have to be occupied on a predictable basis during normal operations and anticipated occurrences are zoned so that exposures are below the limits of 10 CFR 20, and will be ALARA. The zoning system and access control features also meet the posting entry requirements of 10 CFR 20.203 or standard NRC Technical
' Specifications, and are consistent with Regulatory Guide 8.8.
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Several features are included in the plant design and operational program to minimize the buildup of activated corrosion products, a major contribution to occupational doses. Examples include:
(1) Most pumps are provided with drain connections to facilitate decontamination.
(2) Ion exchangers are designed for complete drainage and are designed with a minimum of crevices to reduce accumulation of radioactive crud.
(3) A steam generator drain pump is provided to accomplish a more complete and rapid drainage. -
(4) An electromagnetic filter is used to remove radioactive corrosion products from coolant.
The applicant's corrosion product control features are consistent with the guidance of Regulatory Guide 8.8 (Rev. 3) and NUREG-0800 and are acceptable.
The design features incorporated by the applicant for maintaining occupational radiation doses ALARA during plant operation and maintenance will also serve to maintain radiation doses ALARA during decommissioning operations and are, therefore, acceptable.
12.3.2 Shielding The objective of the plant's radiation shielding is to provide protection against radiation for personnel, both inside and outside the plant, during normal operation, including anticipated operational occurrences and during reactor accidents. The shielding was designed to meet the requirements of the radiation dose rate zone system discussed above. The following are several of the shielding design features incorporated into WPPSS-3:
(1) Reduction of neutron activation of equipment, piping, supports and other materials by providing suitable shielding around the reactor vessel, and 12-7
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. o-to minimize radiation streaming into the reactor cavity and general containment spaces.
-(2) Shielding is provided for all equipment anticipated to contain radiation sources.
(3) Shielding discontinuities such as shield plugs, hatch covers, shield doors to high radiation areas are provided with offsets to reduce radiation streaming.
(4) Access labyrinths are provided for areas containing high level radiation sources to preclude a direct radiation path from the equipment to acces-sible areas. .
These shielding techniques are designed to maintain personnel radiation exposures-ALARA. Therefore, the staff concludes that the shielding design objectives are acceptable.
The applicant's shielding-design methods included the use of standard computer codes. The applicant also used shielding information..from operating nuclear plants as input data for the shield design calculations. The staff concludes that the shielding-design methodology presented is acceptable.
The fuel transfer tube shield structure is a combination of concrete, steel and lead. The design objective of the shield is to completely enclose the fuel transfer tube by shielding materials to prevent inadvertent exposure of personnel to this high radiation source. The access opening is covered by a one foot thick shield of 'ead l shot. The expected dose rate limits are 5 mrem /hr in the most likely occupied areas and 25 mrem /hr in areas of infre-quent occupancy and narrow gap areas.
The applicant stated that portable continuous radiation monitoring equip-ment with local audible and visual alarms will be provided if conditions warrant. It is our position that all accessia.a portions of the spent fuel system must be clearly posted with signs stating that potentially lethal radiation fields are possible during fuel transfer. If other than 12-8
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' 11 permanent shielding is used, local audible and visible alarming radiation monitors must be installed as required by NUREG-0800. Use of portable radiation alarm monitors to be installed "if conditions warrant" is not acceptable. The applicant should state in Subsection 12.3.2.3.5 of the FSAR that the access to fuel transfer tube will be in compliance with NUREG-0800. Until then this remains an open item (471.26) (new item).
In accordance with the criteria of Item II.B.2, NUREG-0737, " Clarification of TMI Action Plan Requirements" the applicant has performed a design review of station shielding to allow access to plant areas.after an accident.
The systems designed to function after an accident include: Safety Injection, Shutdown Cooling, CVCS, Containment Spray and Recirculation, Sampling, Gaseous Radwaste, Shield Building Ventilation and Control Room Air Air-conditioning systems.
The dose rate calculations were performed for the areas of the above systems by using well known computer codes and superimposing the effects of all sources to obtain the maximum expected dose rate throughout the plant. The radiation environment was evaluted for 1, 2, 4, 8, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, 1 day, 1 week, 1, 3, 6 months and 1 year following the reactor shutdown following a LOCA with significant core damage. Oose rate zone maps were provided for each relevant area.
Vital areas requiring accessibility following an accident are identified with respect to location, occupancy requirements, and maximum dose levels. Vital areas include: Control Room, TSC, Sampling room, Hot Lab, Health Physics Office, and Counting room.
The shielding design review by the applicant showed the less-than-15 mrems criterion is met by WPPSS-3 for vital areas requiring extended or continuous occupancy. Additionally, GDC 19 limits are met for those vital areas requiring only infrequent access.
On the basis of its review, the staff has concluded ' hat the applicant has performed a radiation and shielding design review for vital areas access in accordance with Item 11.8.2 of NUREG-0737.
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p q 12.3.3 Ventilation P
The ventilation systems at WPPSS-3 are designed to protect personnel and equipment from extreme thermal environmental conditions and ensure that plant personnel are not inadvertently exposed to airborne contaminants exceeding those given in 10 CFR 20.103. The applicant intends to maintain personnel exposures ALARA by:
(1) Maintaining airflow from areas of potentially low airborne contamination to areas of higher potential concentrations; (2) Ensuring negative or positive pressures to prevent exfiltration or infiltration of potential contaminants, respectively; and (3) locating ventilation systems intakes so that intake of potentially contaminated air from other building exhaust points is minimized.
The design criteria are in accordance with the guidelines of Regulatory Guide 8.8 (Rev. 3). Some examples of exposure reduction features in the ventilation system are listed below. .
(1) Adequate space is provided around the ventilation fans and filter units to allow rapid servicing and replacement of sections and filters.
(2) Pipe equipment vents directly to the appropriate radwaste subsystem for treatment thus preventing spread of contamination.
(3) Welded seams are used throughout the duct work on contaminated systems to the extent possible to reduce system leakage.
(4) Use of filters that can be easily maintained for containing radioactivity so they will not create additional radiation hazards to personnel in
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normally occupied areas.
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12.3.4 Area Radiation and Airborne Radioactivity Monitoring Instrumentation 12.3.4.1 Area Radiation Monitoring Instrumentation .
The applicant's area radiation monitoring system is designed to:
(1) Moniter the radiation levels in areas where radiation levels could become significant and where personnel may be present; (2) Alarm when the radiation le.els exceed preset levels to warn of excessive radiation levels; and (3) Provide a continuous record of radiation levels at key locations throughout the plant.
In order to meet thess objectives, the applicant plans to use 73 area monitors located in areas where personnel may be present and where radiation levels could become significant. The area radiation monitoring system is equipp,ed with local and remote audio and visual alarms and a facility for central recording.
The applicant should inform the NRC whether or not post-accident radiation monitors for containment and sampling area will be provided in compliance with Regulatory Guide 1.97 or should provide a basis for an acceptable deviation (471.1).
The applicant has provided area radiation monitors around the fuel 1 storage area to meet the requirements of 10 CFR 70.24.
- As per SRP, NUREG-0800 the applicant should commit to the implementation of Regulatory Guide 8.12, " Criticality Accident Alarm Systems" and N16.2-1969 or provide a description of their alternative approach. Until then, this remains an open item (471.23).
To meet the criteria of the TMI Action Plan Item II.F.1.3, the applicant has committed to installing two high-range gamma monitors at WPPSS-3.
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i 1 The range of the monitors does not comply with Table II.F.1-3 of NUREG-0737, thus Table 12.3.4-1 of the FSAR should be revised to show a range of 1 R/hr to 107 R/hr (gamma only). Until such revision this remains open item (471.27), (new item).
In addition, the applicant has provided plant layout drawings showing the location of the high-range monitors.
12.3.4.2 Airborne Radioactivity Monitoring Instrumentation The design objectives of the applicant's airborne radioactivity monitoring system are:
(1) To assist in maintaining occupational radiation exposure to airborne contaminants ALARA; (2) To check on the integrity of systems containing radioactivity which are being monitored; and (3) To warn of inadvertent release of airborne radioactivity to prevent over-exposure of personnel.
In order to meet those objectives, the applicant plans to use ventilation duct nonitors in key locations throughout the plant and portable continuous air monitors. The ventilation system monitors will be used to provide representa-tive air concentrations and a rapid indication of abnormal conditions at fixed locations such as exhaust ducts from areas in which the airborne radioactivity could increase and in which personnel nornally have access, consolidated ven-tilation exhausted from the plant, and air intake ducts to the control room for post-accident habitability monitoring purposes. Portable or mobile air monitors can be relocated to virtually any location of the plant, and can be connected to the plant radiation monitoring communication's system through the spare junction boxes lccated throughout the plant.
All radiation monitors will be periodically calibrated with standard sources traceable to the NBS.
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The applicant should describe how the radioactive airborne monitoring system will detect the MPC-hours of radioactivity (particulates, iodine, and noble gases) from any compartment which could contain airborne radio-activity 'and which could be occupied by personnel as per SRP, NUREG-0800,
! Section 12.3-12.4, 4.b.1. (471.21).
i-12.4 Dose Assessment The staff has audited the applicant's dose assessment for the WPPSS-3 provided in Section 12.4 of the FSAR, against the criteria set forth in NUREG-0800, Section 12.3-12.4. This review consisted of ensuring that the applicant had either committed fta following the criteria of the regulatory guides and staff positions referenced in Section 12.3-12.4 of NUREG-0800, or provided accept-
, able alternatives. In addition, the staff selectively compared the dose assess-ment made by the applicant for specific functions against those made for other plants of similar design. This selective review found the plant's dose assessment equivalent to those of other plants. Details of the review follow.
The applicant has performed an assessment of the doses that will be received ,
by plant and contractor personnel. This does assess. ment is based on occupancy, factors, expected dose rates, expected airborne radioactivity concentrations, and historical information from operation BWR power plants. The dose assess-ment includes a breakdown of the annual person-rem doses associated with major ;
functions such as routine operations, routine maintenance, inservice inspec-
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tions, special maintenance, radwaste processing, refueling, and. health physics.
The applicant estimated the total annual collective dose to plant personnel ,
and contractors to be 440 person-rems. This estimate is consistent with the acceptance criteria in NUREG-0800, that is, using the methods outlined in Regulatory Guide 8.19. t Currently, operating BWRs average 740 person-rems per unit annually, with particular plants experiencing an average lifetime annual dose as high as 1850 person-rems. These dose average are based on widely varying yearly doses for EWRs. The staff finds the bases for the WPPSS-3 exposure estimate acceotable.
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.The dose breakdown for refueling work in Table 12.4-8 does not agree with dose for refueling work given in Table 12.4-2. The applicant should resolve the discrepancy (471.14).
The cpplicant has provided a tabulation of the maximum expected radioactive airb;rne concentrations, as well as estimates of the inhalation dose equiva-1:nt rates to plant personnel. The dose equivalent rates are derived from the airb3rne radioactivity source terms given in Chapter 11 of the FSAR. The applictnt's assumptions and models on which his internal and submersion dose in estimates are based for occupational exposures are consistent with those of the st3ff and are acceptable.
The staff concludes that the applicant's dose assessments for contained sources and cirborne radioactive material are comparable to estimates by other applicants with sisilar design and are acceptable.
12.5 Operational Radiation Protection Procram The staff has audi'ted the organization, equipment instrumentation, facilities,
- nd pr:cedures for radiation protection contained in the WPPSS-3 FSAR against the criteria of NUREG-0800, Section 12.5. The plant's health physics program objectives are to provide reasonable assurance that the limits of 10 CFR 20 are /
not exceeded, to further reduce unavoidable exposures, and to ensure that indi- in viduc.1 and total person-rem occupational radiation doses are maintained ALARA.
The staff review consisted of ensuring that the applicant had either committed Go following the criteria of the regulatory guides and' staff positions refer-
- nc d in Section 12.5 of NUREG-0800 or provided acceptable alternatives and selcctively compared the appliant's FSAR against the acceptance criteria of the SRP using review procedures in NUREG-0800. This selective review found the plcnt acceptable in these areas. Details of the review follow.
12.5.1 Organization t
The H:alth Physics / Chemistry manager at WPPSS-3, in conjunction with line supervisors, is responsible for implementing and enforcing the plant's health 12-14
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