ML20235Z150
| ML20235Z150 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/08/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89124, NUDOCS 8903150195 | |
| Download: ML20235Z150 (7) | |
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-Log' # TXX-89124 File # 10010, 912.1, 912.3, 912.5 nlELECTRIC March 8, 1989 W. J. Cahill Executive Vice President U.~S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC QUESTIONS ABOUT CPSES FSAR, CHAPTER 12 Gentlemen:
Attached is TV Electric's response' to the iiRC staff's questions on Chapter'12 of the CPSES FSAR. The response to Question 2 is being evaluated and is-expected to be submitted by April 28, 1989. On February 24, 1989, an extension to the originally requested due date was granted by Mr. Mel Fields-
'of your office.
Sincerely, a
William J. Cahill, Jr.
GLB/ddm Attachment c - Ms. Melinda Malloy, NRR (OSP)
Mr. Roger Pederson, NRR Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l i
h[gM 8903150195 890308 ADOCK0500g45 PR
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l 400 hrth Olive Street LR 81 Dallas, Texas 75201
'Aitachmentto1TXX-89124.
W lb...
.' March 8, 1989'
.Page 1.of 6-RESPONSE 10 NRC QUESTIONS PERTAINING TO THE CPSES FSAR CHAPTER 12 s
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.LUESTION#1:
Page 12.1-2 states that facility design considerations'are governed by Regulatory Guide 8.8 Revision 2, Section C.2.
The current version of Reg.
Guide 8.8 is Revision 3.
Describe which sections of Re 3, Section C.2 are not applicable to the CPSES design (g. Guide 8.8 Revision and discuss why L
including these design features are not'ALARA) or revise 12.1-2 to reference Revision 3.
RESPONSE #1:
Regulatory Guide 8.8, Revision 3, is applicable to the CP3ES design.
The.FSAR will b.e revised.to reflect Revision 3 to R. G. 8.8.
QUEST 10N'#2:
The following are several apparent discrepancies noted in the data presented
.in Table 12.2-26 " Radioactive Airborne Contamination." Verify the results listed in Table 12.2-26.
If the bases for the input-data for the airborne concentrate.on calculations is not NUREG-0017 - GALE' code, then describe in detail the bases for the input parameters used, Table 12.2-26 sheets 6 through 14 contain calculated airborne a.
concentrations for. radionuclides in nine rooms.and corridors in the safeguards building. Although Table 12.2-25 lists very different-calculational parameters for these areas, the results for each of these
'nuclides are the same for all nine areas (allowing for some round off error).
b.
The input parameters are listed in Tcble 12.2-25 sheet 14 and 15 for the turbine building basement and mezzanine, respectively. Comparing these with the results of airborne Tritium (H3) for these areas (Table 12.2-26 sheets 16 and 17), seems-to indicate that increasing the leak rate by about 2.5 times (in rooms of about the same size and ventilation flow.
rate) increases the H3 airborne concentration by 37 orders of magnitude.
Also, justify a design that has.5 MPC of H3 on the turbine building mezzanine during normat operation.
c.
Table 12.2-26 sheets 23 through 31 have fifty-three (53) incorrectly listed as the atomic number for Br, Co, Rb, Sr, Mo, and Cs.
RESPONSE #2:
The response to this question will be provide (I by April 28, 1989.
LAttachment to TXX-89124
, March 8, 1989 i
Page 2 of 6
. QUESTION #3:
Describe the auxiliary and/or emergency power supply of the area radiation and l
airborne radioactivity monitors at CPSES.
RESPONSE #3:
FSAR Sections 11.5 (Process and Effluent Radiological Monitoring and Sampling Systems) and 12.3.4 (Area Radiation and Airborne Radioactivity Monitoring l
Instrumentation) will be~ revised to describe the power supply of area radiation and airborne radioactivity monitors as follows:
1 Proposed Section 11.5.2.5.2:
All field wiring for communication circuits consists of twisted-shielded pairs l
that are daisy-chained from monitor to monitor and to the display cabinets. A
$6 M t ddWJd if pfd # ddd f6f ddth d6dif6f ddd dispJdf ddWiddf/ Each monitor processor and the display consoles are furnished with safety related or reliable non-safety related power (backed by diesel /non-safety related station batteries) as applicable.
i Proposed Section 12.3.4:
The radiation monitor processors and the control di play consoles are furnished with safety related or reliable non-safety related power (backed by diesel /non-safety related station batteries) as applicable.
QUESTION #4:
Indicate whether, and if so how, the guidance provided in regulatory Guide 8.2 and ANSI N15.2-1969 has been followed with respect to keeping records of results of the area and airborne radioactivity monitoring system.
RESPONSE #4:
The guidance of Regulatory Guide 8.2 was considercd when designing the CPSES Digital Radiation Monitoring System (DRMS) as discussed in Section 12.3.4.4.
Based on this guidance, the system was designed to allow for hard-copy printouts of the radiation levels measured by area monitors and radioactivity concentration levels measured by airborne monitors. Although the DRMS is designed to generate records of measured radiological conditions, the determination of the actual records of surveys and monitoring that will be retcined is an operational concern and is discussed in Section 12.5 of the FSAR.
The record keeping guidance of Regulatory Guide 8.2, as it pertains to radiation surveillance activities, is incorporated in the CPSES radiation surveillance program described in Section 12.5.3.
In )ractice, Radiation Protection intends to use results from DRMS area anil air)orne monitors only as information to supplement the surveillance program l
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Attachment to TXX-89124 March 8,1989 Page 3 of 6' RESPONSE #4:
(Continued) described in Section 12.5.3.
DRMS results are not normally used to establish radiation protection work requirements such as protective clothing requirements, respiratory protection equipment requirements, and stay times, or to demonstrate compliance with regulations.
Therefore, the records of results of DRMS area and airborne monitors are not normally retained.
In summary, the consideration of the guidance of Regulatory Guide 8.2 during system design is not considered a commitment to retain all records generated by the DRMS. Records of DRMS area and airborne monitor results are available and may be retained on a case-by-case basis as determined by Radiation Protection.
However, as discussed above, such records are not routinely retained as documentation of surveillance activities.
Sections 12.3.4 and 12.3.4.4 will be revised to reflect the following changes to clarify the use of DRMS area monitors:
Proposed Section 12.3.4.2:
The objectives of the ARMS are as follows:
1.
To provide plant operators and personnel with a system which 6d66/6f tH6M 16 66 H 66661 6dd $6tY 16 61661 6f66i M iH 166i666616 6tisf6dt6 fH61 tH6 16d16t1661H61t 6t6 6616h tH6t6 t66ditid6 if6ttil 66dit6tidd 6tst6dti6dt informs them of radiological conditions in selected plant areas and provides an indication of changing radiological conditions.
2.
To indicate, alarm, and record abnormal radiation levels in areas where radioactive material is present, stored, handled, or inadvertent 1v introduced.
The primary functions of the ARMS are as follows:
1.
(nochange) 2.
(nochange) 3.
To provide a direct reading indication and 6 66tsid661 tit 6fd an on demand print out of radiation dose rates at each monitor location.
Proposed Section 12.3.4.4:
12.3.4.4 Compliance with regulatory Guides and U;ndards
y; q
. Attachment to TXX-89124 r
March 8, 1989
-Page'4'of 6' RESPONSE #4:
(Continued)
When applicable,-lH6 the guidance provided by Regulatory Guides 8.2, 8.8, 1.21, and ANSI N13.1-1969 has been followed in the design of the area
. radiation and airborne radioactivity monitoring system.-
1.
For Regulatory Guide 8.2, the (dtd/di /dddi/dd 6f f6di6tl6d Mddit6fidd'6Hd disp 6#61 6td dt6 tid 66 51 H6td t661 ftidt66tt 61 tH6 66ttsit 61 tHd digit 61 16ditti66 96dit6 tid 6 ititds it H11 6i it6t666 6d d66ddtil ditti 61 t>d
./dp6ft(6dpdidtititddi system was designed to provide.infomation to plant operators pertaining to radiological conditions in selected plant areas and in releases of radioactive materials in effluents.
Additionally, the system is designed to allow for hard copy printouts of the radiation levels measured by area monitors and radioactivity concentration levels measured by airborne monitors.
QUESTION #5:
4 i
Section 12.3.4.1.1 st'ates that the airborne radioactivity monitor.ing system is i
composed of fixed gas and airborne monitors in effluent streams serving; in.
i conjunction with portable continuous airborne monitors (CAMS).
Describe the location of these CAMS, the sensitivity rang and alarm setpoints.
RESPONSE #5:
I CPSES FSAR Sections 12.3.4.1 and 12.3.4.1.1 state that portable airbor.v I
sampling instrumentation and sampling methods are discussed in Section 12.5.2.
We have reviewed'this section of the FSAR and determined that the information pertaining to portable airborne sampling equipment and sampling methods is inadequate.
Sections 12.3 and 12.5 will be revised to reflect the following changes:
Proposed Section 12.3.4.1:
)
i Detection and measurement of airborne radioactivity is accomplished by the system (PRMS) in conjunction with the area
)
process radiation monitoring (ARMS).
radiation monitoring system These systems monitor activity levels and dose rates resulting from gaseous and particulate airborne radioactivity in various areas of the plant; the systems provide alarms, indication, and
' p6/ddMst /dt6 tdt on-demand hard copy printouts in the Control Room.
Detailed descriptions of these' systems are given in Sections 11.5 and 12.3.4.2.
I
$pdtf 67 Portable instrumentation and the airborne sampling ddtH6di program are discussed 16 ddt61J in Sections 12.5.2 and 12.5.3, respectively.
Proposed Section 12.3.4.1.1:
The fixed continuous monitors, which are described in detail in Section 11.5, serve in conjunction with a comprehensive air sampling program using portable j
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Attachment to TXX-89124 March 8, 1989 Page 5 of 6 Pf666tdd $6ffl6d 1213/411111 86dliddddl t6dfidd6di di/66fd6 #6dif6fil fHith dfd dititlYdd in ddfdll 16 $difl66 1215/21 airborne sampling equipment.
The portable air sampling equipment and the program for performing air sampling are described in Sections 12.5.2 and 12.5.3.
16 dddlf166 f6 iHd dfdipiddf #ddf16666 ffdil6dfJfI fYdfd it The portable airborne sampling equipment is available fHl(H dill Ed didd to complement 6fHdt ffpdf 6f fixed ddd p6ffdBJ6 instrumentation and if may be used in areas where fixed instrumentation is not provided but where there is a need for short term or periodic monitoring, or when fixed instrumentation is not operable. This equipment either collects samples which are then processed and evaluated, or monitors continuously.
Proposed Section 12.5.3:
Surveys to assess the airborne radioactivity levels will be performed to ensure 10 CFR Part 20 limits are not exceeded, engineering controls are functioning, and respiratory protection techniques are adequate.
Areas to be routinely measured will be determined by fMd Rtdiation Protection Mddddd/ and will be based upon the actual or potential hazard, task to be performed, and occupancy factor.
Frequency of routine measurements for airborne radioactivity will vary depending upon several factors.
For instance, selected areas will be measured daily, weekly. monthly or continuously depending upon the location, work to be performed, and actual or potential hazard.
AJJ fdfidf /dfdJff Afd /did/dddl flJdd ddd Mdf Et pdffdd 16tdJJf f6 difd/d ddddddfd fddl6/6ditd/ (6dff6Jfl In general, continuous air monitor (CAM) survey results are used as a qualitative assessment of changing radiological airborne conditions and grab samples are normally used to quantify the actual airborne activities.
In order to warn personnel of changing airborne conditions, CAM alarm setpoints are normally set at a value corresponding to 25% of the appropriate MPC value given in 10 CFR 20, Appendix B, Table I, Column 1.
These setpoints may be adjusted as necessary based on actual plant conditions in accordance with station procedures.
Appropriate survey results necessary to demonstrate adequate radiological controls are recorded and filed and may be posted locally.
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' Attachment to TXX-89124-
'_ March 8,-1989;-
[
Page 6 of 6 3
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Proposed Table 12.5-2:
INSTRUMENT' SENSITIVITY.
EXAMPLE
- RANGE ACCURACY USE 1
10 -106
+/- 20%
Work area Continuous' Particulate, NMC air monitor
.fullscale
ai r mon.**
noble gas Continuous Particulate NMC'GP-5 10 -106
+/- 20%~
-Work area 1
air monitor cpm fullscale air mon.**
Air grab Particulate, Radeco Sample N/A Work area sampler iodine Model 787 dependent air mon.
- This equipment'may have functionally' equivalent instruments substi.tuted for it.
- The specific locations of CAMS will be detemined on a' case-by-case basis depending on actual plant conditions. Examples of areas where CAMS will most likely be used are:
o Fuel Building (spent fuel pool areas) o Containment (operating deck / refueling deck) o Charging Pump area o Hot Machine Shop or other areas of high maintenance-activities OVESTION #6:
Provide readable diagrams, clearly showing the locations of all the airborne-radioactive and area radiation monitors (including CAMS) discussed in Chapters 11.5 and 12.3.4.
F RESPONSE #6:
Figures 12.3-4 through 12.3-23.(Radiation Zones and Shield Thicknesses) are being revised for legibility and will be included in the May 1, 1989, FSAR amendment submittal. The locations of the airborne radioactive and'non-safety area monitors will be shown on these figures. Accident Monitoring and safety radiation monitors are shown in Figure 7.1-3.
The locations of CAMS are discussed in the response to Question 5.
LEGEND:
Bold text indicates proposed insertions in the referenced FSAR section.
Overstruck text indicates proposed deletions to the referenced FSAR section.
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