ML20209G421
| ML20209G421 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/29/1986 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Oconnor P Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-1368, NUDOCS 8609120464 | |
| Download: ML20209G421 (10) | |
Text
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1901 Gratiot Street. St. Lours Donald F. Schnell Vee President August 29, 1986 Mr. Paul W. O'Connor, Project Manager ULNRC-1368 PWR Project Directorate #4 Division of PWR Licenring - A U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. O'Connor:
DOCKET NO. 50-483 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE EXEMPTION REQUEST BY CALLAWAY PLANT RELATED TO UTILIZATION OF A RADIOIODINE PROTECTION FACTOR The following information is provided in response to your request dated July 11, 1986.
The numbering below corre-sponds to the numbering utilized in the enclosure to your request letter.
Responses indicating specific actions, such as procedure revisions, training, etc., will be completed prior to use of protection factors for the GMR-I canisters and pending NRC approval.
Request 1.
The Union Electric Company submittal indicated that canisters will not be exposed to or used in environments containing organic vapors and chemicals which could cause aging, poison-ing, or desorption of adsorbed radionuclides.
Describe in general the methods and particular procedures which will be applied to prevent the use of GMR-I canisters in the presence of organic vapors and chemicals.
This should include a discussion of:
(a) organic vapors and chemicals of concern to GMR-I use at Callaway; (b) methods and procedures for detecting (sampling) and/or precluding the presence of organic vapors and chemicals where GMR-I canisters are used (e.g.,
identify general sampling procedures applied specifically for GMR-I canister use; identify administrative procedures which preclude use or release of organic vapors and chemicals in GMR-I use areas) ;
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Mahng Address: P.O. Box 149, St. Louis. MO 63166
s' Mr. Paul W. O'Connor Page 2 August 29, 1986 (c) related controls for other systems or operations, such as charcoal filter bed technical specifications, which can also limit GMR-I canister exposure to organics.
Response
1.
(a)
The organic vapors and chemicals of concern relative to GMR-I canister use at Callaway include:
paint, paint thinner / remover (methylethylketones), freon cleaning agents (trichlorotrifluoroethane), isopropyl alcohol and methyl chloroform.
These vapors and chemicals are not of concern in respirator storage areas where GMR-I canisters will be routinely stored.
(b)
Callaway plant procedures (i.e., APA-ZZ-00360) and administrative practices for chemical control preclude indiscriminate use, requiring specific approval for use in plant work areas.
Procedural and administrative controls are employed to prevent unauthorized use of paint or paint-related products in areas where plant filtration systems (e.g., charcoal beds) could be affected.
This includes the areas where GMR-I canisters will most likely be used.
The existing controls provide adequate restrictions on the use of organic vapors and chemicals to assure that GMR-I canisters will not be used in such environments.
Additionally, health physics procedure HTP-ZZ-08002 will be revised to incorporate the restrictions for use of GMR-I canisters described in our initial request.
Therefore, use of GMR-I canisters will not be permitted in areas where painting or use of organic vapors / chemicals is in progress or has recently been completed.
(c)
Technical Specification 3/4.7.7 defines the availability and surveillance requirements related to the emergency exhaust system.
These requirements are utilized to demonstrate system operability with respect to HEPA and charcoal filters.
Since GMR-I canister use will most likely be in the same areas served by che emergency exhaust system, assurance of continuing operability of this system will provide assurance of the proper environment (i.e., no organic vapors / chemicals) for GMR-I canister use.
Additionally, plant procedures governing the operability and functioning of charcoal beds are in compliance with Regulatory Guides 1.140 and 1.52 for design, testing and maintenance of filtration systems.
Mr. Paul W. O'Connor Page 3 August 29, 1986 Request 2.
Identify the specific procedure (s) which will control canister storage and indicate the range of temperature and relative humidity allowed in the storage area.
Response
2.
Recent test results provided by MSA, the manufacturer of the GMR-I canisters, indicates that controlled storage with respect to humidity and temperature is not required (see enclosure).
Canisters will be stored in the Callaway plant warehouse or temporary in-plant storage areas where the environment will be dry and the temperatures are expected to remain below 100'F.
Temperature and humidity are recorded in the callaway warehouse, and records for the last five years show that maximum temperatures were 100'F during summer months at 60 percent relative humidity.
The average summertime temperature is 90*F.
More importantly, the manu-facturer's seal does provide an effective humidity barrier for the canisters as demonstrated by their test results.
Therefore, shelf life will be the controlling factor for storage versus strict limits on temperature and humidity in the storage location.
The temperature limit of 110'F for use of the canisters will be adhered to and specified in HTP-ZZ-08002.
Request 3.
Identify the specific plant and training procedures which will be developed or modified to incorporate controls, restrictions, and use of GMR-I canisters.
Response
3.
The respiratory protection training will be updated to reflect the procedure revisions / requirements concerning GMR-I canister use, and the updated training will be provided to those employees qualifying for respiratory protection use.
Health physics technicians will receive training on the updated procedures HDP-ZZ-06017 an HTP-ZZ-08002 reflecting GMR-I canister use requirements.
Employees who have qualified for respiratory protection use and will not require further training until their annual requalification will be trained on GMR-I canister use prior to actual use of the canister on a case basis, if required.
Request 4.
Describe how you will verify the effectiveness of this special respiratory protection program.
The following elements (or equivalent) should be considered:
Mr. Paul W. O'Connor Page 4 August 29, 1986 (a) weekly whole body counts for individuals using the GMR-I canister for radiciodine protection; (b) for individuals who exceed 10 MPC hours, a whole body count prior to the individual's next entry into a radiciodino atmosphere; (c) establishment of an uptake level beyond which further entry into a radiciodine atmosphere would be restricted, pending health physics evaluation (e.g. 70 nci) ;
(d) establishment of a whole body count / survey data base to be used to evaluate the results of the program, identify additional necessary restrictions, or provide recommen-dations for reduced requirements.
Response
4.
(a through d)
Health physics procedure HDP-ZZ-01300 will be revised to incorporate elements (a) through (d) as specified in your request for information enclosure.
Additionally, upon collection of a data base adequate to support the effectiveness of the program, we propose to relax those limitations (a through d) in a manner commensurate with the demonstrated hazards involved and the effectiveness of the GMR-I canisters consistent with our current respiratory protection program.
Request 5.
Describe how the quality and function of the MSA GMR-I canisters will be verified by UEC.
Since radiciodine break-through is not directly detectable by the user, it is the utility's responsibility to assure that canister performance and quality are fully adequate through such measures as verification of vendor quality control and quality assurance, and through development of utility / site QA/QC procedures which provide a continuing assurance of canister quality.
(a)
Include a general discussion of any vendor audits performed, or outline the basis of your acceptance of vendor QA/QC controls for GMR-I canisters.
(b)
Cite general controls and procedures related to GMR-I canister QA/QC to be utilized at Callaway by UEC.
Response
5.
(a)
Union Electric had an audit performed of the vendor (Mine Safety Appliances-MSA) for safety-related equipment and currently lists MSA on our Quality Supplier List (OSL), even though manufacture of the
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a Mr. Paul W. O'Connor Page 5 August 29, 1986 f
GMR-I canisters (considered nonsafety-related) was not specifically audited.
Union Electric, as one of the l
SNUPPS plants, routinely shares audit information with l
Kansas Gas and Electric (KGE).
Union Electric reviewed recent audits of MSA performed by KGE for manufacture and testing of the GMR-I canisters.
Based on the audit performed by KGE of GMR-I canister manufacture, Union Electric believes that MSA's QC program and controls are acceptable.
As indicated in the KGE audit reports, Union Electric will only utilize GMR-I canisters tested per the MSA Specification (currently No. 356, Addendum 1) for credit for protection factors.
These canisters are designated by a MSA label worded similar to the following:
"This canister meets the NRC Quality Assurance Specification Required For Radioiodine Protection Factor Credit, In Addition To The NIOSH/MSHA Requirements.
Credit May Only Be Taken By Licensees Who Have Been Granted An NRC Exemption."
(b)
Health physics procedure HTP-ZZ-08002 will require verification that the seal is intact, the MSA label (indicated above) is attached, and the canister shelf life has not exoired prior to use of GMR-I canisters.
Additionally, onsite QA audits and surveillances of the Callaway respiratory protection program will be expanded to include GMR-I canister use and associated procedures and controls.
Request 6.
Describe the methods which will be utilized to reduce potential radiciodine levels to minimal levels in the Callaway work areas.
This should include a discussion of the utilization of engineering controls, reactor coolant cleanup /
i purification, degasification, decay schemes, and system and area decontamination.
Long term efforts to cvoid or alleviate radiciodine problems, such as through fuel quality control programs, fission product trending, and other operational controls, should be briefly discussed.
Response
6.
Engineering Controls Negative pressure ventilation blowers were procured and are utilized to reduce airborne contamination in steam generator manway openings and general work areas where the reactor coolant system (RCS) is breached.
Upon shutdown for an outage, the containment purge system is operated to reduce I
general airborne contamination to as low as practical.
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o Mr. Paul W. O'Connor Page 6 August 29, 1986 Reactor Coolant Cleanup / Purification Upon each shutdown for refueling, hydrogen peroxide is injected into the reactor coolant system to induce a crud i
burst.
Following the crud burst, purification flow via demineralizers is maximized to accomplish cleanup of the reactor coolant prior to opening the system for maintenance.
This procedure reduces iodine concentration levels.
Degasification Normal shutdown procedures require degasification of the RCS by venting the pressurizer vapor space and through letdown via the volume control tank (VCT).
Both processes remove and reduce radioactive gas concentrations including iodine.
Decay Schemes Maintenance planning for scheduled outages includes consideration of decay times for isotopes of concern, particularly iodine, prior to major breaches of primary systems.
When practical, time is allowed for reduction by decay prior to work which could potentially involve airborne radioactivity.
System and Area Decontamination Prior to commencing outage maintenance, time is allotted to decontaminate affected areas.
Surveys are conducted frequently during maintenance activities and cleanup /
decontamination is conducted accordingly.
Throughout each scheduled outage, time is allotted for decontamination of maintenance areas as well as overall decontamination of containment surfaces as appropriate.
Long-Term Corrective Action (a)
Fuel Quality Control - Union Electric's Quality
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Assurance Division audits and approves the Westinghouse Fuel QA Program (WCAP-7800) used to manufacture fuel for Callaway.
Additionally, the Nuclear Function's Fuel Department reviews the fabrication process and QC inspection procedures to ensure high quality fuel is delivered to Callaway.
(b)
Fission Product Trending - Daily and monthly reports are issued which provide information for trending of dose equivalent iodine and ratios of I-131 and I-133.
Additionally, management has established specific goals for dose equivalent iodine levels and provides monthly trending reports of performance relative to the goals.
Mr. Paul W. O'Connor Page 7 August 29, 1986 (c)
Operational Controls - Operational controls are established for startup power ascension rates and generally limit power ascension to 3 percent per hour as recommended by Westinghouse to reduce the potential for fuel degradation.
Other controls include procedures to prevent fuel damage during fuel-handling activities.
Should you desire additional information or have any question concerning this information, please contact Mr. Mike Williams of my staff at 314/554-3766.
Very truly yours, 0
Donald F.
Schnell MCW/lkr Enclosure 4
Mr. Paul W. O'Connor Page 8 August 29, 1986 cc:
Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, NW Washington, DC 20036 Nicholas A.
Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, MD 20850 C. W. Hehl Division of Projects and Resident Programs, Chief, Section 1A U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR #1 Steedman, MO 65077 Manager, Electric Department Missouri Public Service Commission P. O. Box 360 Jefferson City, MO 65102 a
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A Mine Safety Appliances Company
- P.O. Box 426 Pittst urgh, PA 15230 Telephone: (412) 273.Nxx)
Writers Direct Dial No.
412/273-5194 August 27, 1986 Union Electric Company Mail Code 470 P. O. Box 149 St. Louis, M0 63166 ATTN: Mr. Mike Williams
Dear Mike:
Your Gerald Spires asked me to relay the following information concerning the MSA GMR-I Canister (P/N 466220).
As you know, nuclear plants that have received the NRC exemption for radiodine protection factor credit for the GMR-I Canister are required to store the canister in an atmosphere with controlled humidity and temperature (Class A Storage). This requirement came from the NRC and was not due to the results of any MSA laboratory testing.
MSA has since conducted tests to determine the permeability of the canister seals in high temperature / humidity conditions. Twelve GMR-I Canisters were stored at 100"F and 100% RH. Three canisters were tested at 18 weeks using our present quality control test method (110*F, 90% RH, 64 LPM pulse flow, 5-10 PPM Challenge, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). The results of this test were no different from test results for production lots.
The remaining nine canisters still in storage will be tested at staggered time intervals (3 cans at each interval).
The results of these tests will be relayed to you.
RECEIVED AUP 2 '
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M. C. W!LL.'; 33 LOCATION: 60t) Penn Center Blvd.
- Pittsburgh, PA 15235 e,so. as v...
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hnionElectricCompany Page 2 August 27, 1986 Our chemists do not expect the canisters to show any degradation in performance.
Please feel free to call if you have any questions.
Sincerely, JU s
Eric J. Beck Nuclear Industry Specialist kaw cc: Gerald Spires Union Electric Company callaway Nuclear Plant P. O. Box 620 Fulton, MO 65251 Paul Richter f
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