ML20245A123

Submits Whole Body Dose Estimates & Request for Changes to Tech Specs 6.8.3.1 & 6.8.4

ML20245A123
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	06/06/1989
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LAC-12767, NUDOCS 8906210102
Download: ML20245A123 (12)

Text

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O DA/RYLAND hbk[ COOPERATIVE

• 2615 EAST AVE. SO.

RO BOX 81) + LA CROSSE. WISCONSIN 54602-0817 (608) 788-4000 JAMES W. TAYLOR General Manage.

June 6, 1989 In reply, please refer to LAC-12767 DOCKET NO. 50-409 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

SUBJECT:

Dairyland Power Cooperative (DPC)

La Crosse Boiling Water Reactor (LACBWR)

Possession-Only License No. DPR-45 Whole Body Dose Estimates and Request for Changes to Technical Specification Submittal

REFERENCES:

(1) DPC Letter, LAC-12501, J. Taylor to Document Control Desk, dated February 22, 1988.

(2) DPC Letter, LAC-12733, J. Taylor to Document Control Desk, dated March 28, 1989.

In the letter of Reference 2, DPC committed to developing Calculations for SAFSTOR Personnel Whole Body Dose Estimates and to submit them to you.

These estimates are included as an attachment to this letter. The estimates were done under two, separate assumptions. One set of calculations assumes no DECON-DISMANTLEMENT takes place during the SAFSTOR period. The second set of calculations assumes limited DECON-DISMANTLEMENT does occur during the SAFSTOR period.

This letter also serves to request minor changes to the Technical Specifications proposed in the letter of Reference 1.

Specifically, DPC requests changes to specification 6.8.3.1 on page 6-12 and 6.8.4 on page 6-13 as follows:

1.

Specification 6.8.3.1 is confusing as submitted. The proposed change would eliminate the words "with the exception of the events qualifying as REPORTABLE EVENTS." Page 6-12 is included with this

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June 6, 1989

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letter, both in its current form with the appropriate'part lined out and in its newly proposed form which can be substituted into the original technical specification proposal if this change is found acceptable.

2.

Specification 6.8.4 was reviewed in detail'and it appears that thei first sentence of this specification is unnecessary. The only emergencies that could occur at LACBWR in its current condition that require expeditious notification are all covered in the Emergency Plan and would, therefore, be reported within one hour.

Other non-emergency events would be reported as Licensee Event Reports within 30 days. Page 6-13.is included in both-its present form and its proposed form. 'If this change is acceptable, please substitute the revised page.6-13.for its counterpart in the technical specification submittal of Reference 1.

Dairyland appreciates your attention to this matter and if you have any questions, please call us at (608) 689-2331.

Sincerely, 1

DAIRYLAND POWER COOPERA IVE James W. Taylor General Manager JWT: REC:sks I

cc:

Mr. A. Bert Davis, Regional Administrator U. S. Nuclear Regulatory Commission, Region III 1

Glen Ellyn, IL 60137 i

Mr. Peter B. Erickson, LACBWR Project Manager Division of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission j

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CALCULATIONS OF SAFSTOR PERSONNEL WHOLE BODY DOSE ESTIMATES Based upon criteria outlined in NUREG-0586, Section 5.3, calculations of total personnel whole body dose estimate for 27-year SAFSTOR period were performed.

It is assumed that normal ALARA practices such as shielding, flushing systems, job pre-planning, possible small-scale chemical and/or mechanical decontamination, etc. would be performed during the SAFSIDR period.

It is assumed that no major system decontamination or dismantlement will be performed during this time period.

TOTAL SAFSTOR DOSE:

418 Person Rem ( 2 ) x 3.64(2) x [0.324 + 2.035 E-4]<a)

= 493 Person Rem Average Total SAFSTOR Dose Per Year:

493 Person Rem = 18.26 Person Rem /yr 27 years Average Total Dose Per Person Per Year and Per Quarter:

18.26 Person Rem /yr = 0.481 Rem /yr/ person 38 persons 0.481 Remfy_r/ person = 0.120 Rem / quarter / person 4 quarters /yr Initially, for SAFSTOR years 0-7, the average annual Person Rem dose will be higher at about 38 Person Rem or about 0.250 mrem /qtr/ person, but should differentia 11y decrease with the decay of gamma emitting radionuclides (principally Co-60, Mn-54, Zn-65), after 27 years of SAFSTOR, to about 5.7 Person Rem, or for 38 persons, an average of about 38 mrem /qtr/ person.

This is illustrated as follows:

(2)

NUREG-0586, a 30 year SAFSTOR dose estimate for a model 3320 Megawatt-thermal GE-BWR-6.

(2)(3)

Scaling factors for LACBWH taking into account age of the reactor, past fuel failures, differences in shielding design, area accessibility, etc.

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Estimated Annual l

l Personnel Whole Body Doses l

for SAFSTOR(2)

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l SAFSTOR AVER M TOTAL PERSON AVERM BM/

PERIOD IERSON/

BIN F(Mt PERIOD Pen n /

(YE M )

E M/ YEAR QUARTEIM2) 1-3 46 137 0.303 4-6 33 100 0.217 7-9 24 73 0.158-10 - 12 18 54 0.118 l

13 - 15 13 39 0.086 16 - 18 10 29 0.066-19 - 21 8

24 0.053 22 - 24 6.5 20 0.043 24 - 27 5.7 17 0.038 Cumulative 18.26 493 0.120 (1)

Doses are due to monitoring, surveillance and routine radioactive waste processing.

These values assume that no major process system chemical decontamination, no major shielding modifications, and no dismantling system components would be undertaken during the SAFSTOR period.

These estimated doses were calculated taking into account age of the reactor system, actual plant radiation' surveys, area accessibility, and past fuel failures.

(2)

Assumes a 38 person SAFSTOR organization.

These dose estimates may vary depending upon the scope of work in l

radioactive material controlled areas, and when this work is performed.

l Initially,the effective dose half-life is approximately 7 years due to the relative abundance of co-60 (75%) and Cs-137 (25%). By the year 2010, the effective dose half-life increases to approximately 12 years since the ratio of Cs-137 to Co-60 increases.

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l SAOSTOR DOSE ESTIMATESjF_ LIMITED IW_DISMANTIMENT IS CONDUCTED Calculations of a total personnel whole body dose estimate for a 27-year SAFSTOR period which would include Limited DECON-DISMANTLEMENT throughout the SAFSTOR period were performed.

No major shielding changes are assumed to be done.

Limited process system chemical and/or mechanical decontamination could be performed during this time period.

Normal ALARA practices would be performed during the SAFSTOR period.

TOTAL SAFSTOR/LTD. DECON-DISMANTLEMENT DOSE:

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917 Person Rem ( 2 ) x 2.204(2) x [0.324 + 2.035 E-4)(3)

= 655 Person Rem Average Annual Dose:

655 person Hem = 24.26 Person Rem / year 27 years Average Annual Dose per person per Year and per Quarter:

0' 3 46

'137 0.303 4-6 64

-192 0.421 7-9 29 87

'O.191 10 - 12 21 62 0.138 13 - 15 22 67 0.145 16 - 18 11 33.

0.072 19 - 21 10 30 0.066 22 - 24 10

'29 0.066 24 - 27 6

18 0.040 Cumulative 24.26 655 0.160 (1)

Doses are due to monitoring, surveillance and routine radioactive wastes processing.

These values assume that limited process system clunuical/ mechanical decontamination, some dismantling of unneeded components, and processing additional radioactive waste material is done during the SAFS1DR period.

(2)

Assume a 38 person SAFSTOR organization.

These dose estimates may vary depending upon the scope of work in radioactive material controlled areas and when this work is perfonned.

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ADMINISTRATIVE CONTROLS - (Cont'd)

==============================================================r

j.

Any airborne radioactivity release that exceeded 2 times the applicable concentrations of the limits specified in Appendix B.

Table II of 10 CFR Part 20 in unrestricted areas, when averaged over a time period of one hour.

k.

Any liquid effluent release that exceeded 2 times the limiting combined Maximum Permissible Concentration (MPC) (See Note 1 of Appendix B to 10 CFR Part 20) at the point of entry into the receiving water (i.e., EFFLUENT RELEASE BOUNDARY) for all radionuclides except tritium and dissolved noble gases, when.

averaged over a time period of one hour.

6.8.4 IMMEDIATE NOTIFICATION REQUIREMENTS Jn lieu-of-the reporting requirements of in an 50r72 -the,rventMisted-in-7 7 specification-61Or373mhall-be reported-to-the-NfWOperations-Center-within-4--

-hours.

Notification of declaration of an Emergency Class listed in the l

LACBWR Emergency Plan shall be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

i 6.9 RECORD RETENTION In addition to the applicable record retention requirements of Title 10 Code of Federal Regulations, the minimum period indicated.the following records shall be retained for at least

[

ADMINISTRATIVE CONTROLS - (Cont'd t

==================================)

===============================

6.9.1 The following records shall be retained for at least five years:

Records and logs of facility operation.

a.

b.

Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipmen't related to nuclear safety.

p All REPORTABLE EVENTS submitted to the Commission.

l c.

d.

Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

Records of changes made to the procedures required by Specification e.

6.6.1.

f.

Records of radioactive shipments.

Records of scaled source and fission detector leak tests and g.

results.

6-13

jnATIVE CONTROLS - (Cont'd)

,=======::====================================

r,=======================

g.8.2 SPECIAL REPORTS Special reports shall be submitted to the Regional A6ninistrator of the Regional Office of the NRC within the time period specified for each report.

G.8.3 LICENSEE EVENT REPORTS 6.8.3.1 A Licensee Event Report shall be submitted to the Nuclear Regulatory Commission if any REPORTABLE EVENT of the type listed in Specification G.8.3.3 occurs. The report shall meet the requirements of 10 CFR 50.73,, ""-

ihr en.tiu, J u.me.+i,twwlMyi 4 er " "ORTABLE EVENT 3.

6.8.3.2 Each REPORTABLE EVENT shall be reviewed by the ORC and the Licensee Event Report shall be submitted to the SRC and General Manger.

6.8.3.3 The following types of events are REPORTABLE EVENTS:

Any violation of or condition prohibited by Technical a.

Specifications.

h.

Any deviation from Technical Specifications authorized by 10 CFR 50.54(x).

c.

Serious degradation of nuclear fuel.

d.

Loss of CONTAINMENT INTEGRITY when it is required to exist.

Any event or condition that resulted in the plant being in an e.

unanalyzed condition that significantly compromised plant safety, f.

Any event or condition that resulted in the plant being in a condition outside its design basis.

g.

Any event or condition that resulted in the plant being in a condition not covered by normal or emergency procedures.

h.

Any natural phenomenon, other external phenomenon, or event such as i

fire, toxic gas release, or radioactive release, that posed an actual threat to plant safety or significantly hampered site personnel in the performance of duties necessary for plant safety.

i.

Any event or condition that resulted in unplanned and unexpected manual or automatic actuation of the Emergency Diesel Generators or Containment Isolation.

G 12

,rHATIVE CONTROLS - (Cont'd)

,,=========================r.===========================================

s.8.2 SPECIAL REPORTS Special reports shall be submitted to the Regional Administrator of the Regional Office of the NRC within the time period specified for each report.

6.8.3 LICENSEE EVENT REPORTS 6.8.3.1 A Licensee Event Report shall be submitted to the Nuclear Regulatory Commission if any REPORTABLE EVENT of the type listed in Specification 6.8.3.3 occurs. The report shall meet the requirements of 10 CFR 50.73, with the exception of the events qualifying as REPORTABLE EVENTS.

6.8.3.2 Each REPORTABLE EVENT shall be reviewed by the ORC and the Licensee Event Report shall be submitted to the SRC and General Manger.

6.8.3.3 The following types of events are REPORTABLE EVENTS:

Any violation of or condition prohibited by Technical a.

Specifications.

b.

Any deviation from Technical Specifications authorized by 10 CPR 50.54(x).

c.

Serious degradation of nuclear fuel.

d.

Loss of CONTAINMENT INTEGRITY when it is required to exist.

Any event or condition that resulted in the plant being in an e.

l unanalyzed condition that significantly compromised plant safety.

f.

Any event or condition that resulted in the plant being in a condition outside its design basis.

g.

Any event or condition that resulted in the plant being in a condition not covered by normal or emergency procedures, b.

Any naturni phenomenon, other external phenomenon, or event such as fire, toxic gas release, or radioactive release, that posed an actual threat to plant safety or significantly hampered site personnel in the performance of duties necessary for plant safety.

i.

Any event or condition that resulted in unplanned and unexpected manual or automatic actuation of the Emergency Diesel Generators or Containment Isolation.

G-12

t ADMINISTRATIVE CONTROLS - (Cont'd)

==-_=========================================================n===

j.

Any airborne radioactivity release that exceeded 2 times the applicable concentrations of the limits specified in Appendix D.

Table II of 10 CPR Part 20 in unrestricted areas, when averaged over a time period of one hour.

k.

Any liquid effluent release that exceeded 2 times the limiting combined Maximum Permissible Concentration (MPC) (See Note 1 of Appendix B to 10 CFR Part 20) at the point of entry into the receiving water (i.e., EFFLUENT RELEASE BOUNDARY) for all radionuclides except tritium and dissolved noble gases, when, averaged over a time period of one hour.

6.8.4 IMMEDIATE NOTIFICATION REQUIREMENTS In lieu of the reporting requirements of 10 CFR 50.72, the events listed in Specification 6.8.3.3 shall be reported to the NRC Operations Center within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Notification of declaration of an Emergency Class listed in the LACBWR Emergency Plan shall be made within I hour.

G.9 RECORD RETENTION In addition to the applicable record retention requirements of Title 10 Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated.

ADMINISTRATIVE CONTROLS - (Cont'd)

=====================================================

6.9.1 The following records shall be retained for at least five years:

Records and logs of facility operation.

a.

b.

t Records and logs of principal. maintenance activities, inspections, repair and replacement of principal items of equipmen't related to nuclear safety.

[

I All REPORTABLE EVENTS submitted to the Commission.

I c.

d.

Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

Records of changes made to the procedures required by Specification e.

G.6.1.

f.

Records of radioactive shipments.

Records of sealed source and fission detector leak tests and g.

results.

I G-13

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