ML071450414
| ML071450414 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/09/2007 |
| From: | Starefos J L NRC/NRO/DNRL/AP1000B1 |
| To: | Heymer A P Nuclear Energy Institute |
| Starefos, Joelle, NRO/DNRL/NWE1 415-1175 | |
| References | |
| NEI 07-03, Rev 0, TAC MD5248 | |
| Download: ML071450414 (10) | |
Text
July 9, 2007Adrian P. Heymer, Senior DirectorNew Plant DeploymentNuclear Generation DivisionNuclear Energy Institute1776 I Street, NW, Suite 400Washington, DC 20006-3708
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING TOPICALREPORT NO. NEI 07-03, GENERIC FSAR TEMPLATE GUIDANCE FORRADIATION PROTECTION PROGRAM DESCRIPTION, REVISION 0(PROJECT NO. 689; TAC MD5248)
Dear Mr. Heymer:
By letter dated April 12, 2007, the Nuclear Energy Institute (NEI) submitted for U.S. NuclearRegulatory Commission (NRC) staff review its proposed Generic Final Safety Analysis Report(FSAR) Template Guidance for Radiation Protection Program Description, Revision 0. In aletter dated May 14, 2007, the NRC accepted NEI 07-03 for review. The staff has determinedthat additional information is necessary to complete its review. On May 25, 2007, an electroniccopy of the enclosed request for additional information (RAI) was transmitted to Ralph Andersenof NEI. Although this RAI was provided electronically to you earlier than our scheduled date ofMay 30, 2007, we will not expect a response until 30 days followi ng the scheduled date of issuance; therefore, please let me know if you will not be able to provide your written reply on orbefore June 29, 2007.If you have any questions or comments regarding this matter, I may be reached at(301) 415-8488, JLS1@nrc.gov
.Sincerely,/RA/Joelle L. Starefos, Senior Project ManagerAP1000 Projects Branch 1Division of New Reactor LicensingOffice of New ReactorsProject No. 689
Enclosure:
As statedcc w/encl: See next page Adrian P. Heymer, Senior DirectorNew Plant DeploymentNuclear Generation DivisionNuclear Energy Institute1776 I Street, NW, Suite 400Washington, DC 20006-3708
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING TOPICALREPORT NO. NEI 07-03, GENERIC FSAR TEMPLATE GUIDANCE FORRADIATION PROTECTION PROGRAM DESCRIPTION, REVISION 0(PROJECT NO. 689; TAC MD5248)
Dear Mr. Heymer:
By letter dated April 12, 2007, the Nuclear Energy Institute (NEI) submitted for U.S. NuclearRegulatory Commission (NRC) staff review its proposed Generic Final Safety Analysis Report(FSAR) Template Guidance for Radiation Protection Program Description, Revision 0. In aletter dated May 14, 2007, the NRC accepted NEI 07-03 for review. The staff has determinedthat additional information is necessary to complete its review. On May 25, 2007, an electroniccopy of the enclosed request for additional information (RAI) was transmitted to Ralph Andersenof NEI. Although this RAI was provided electronically to you earlier than our scheduled date ofMay 30, 2007, we will not expect a response until 30 days followi ng the scheduled date of issuance; therefore, please let me know if you will not be able to provide your written reply on orbefore June 29, 2007.If you have any questions or comments regarding this matter, I may be reached at(301) 415-8488, JLS1@nrc.gov
.Sincerely,/RA/Joelle L. Starefos, Senior Project ManagerAP1000 Projects Branch 1Division of New Reactor LicensingOffice of New ReactorsProject No.: 689
Enclosure:
As statedcc w/encl: See next page ADAMS ACCESSION NO.: ML071450414NRR-088OFFICEDNRL/NWE1:LADNRL/NWE1:PMCHPB:BCOGCDNRL/NWE1:BCNAMEKGoldsteinJStarefosTFryeSCoffinDATE05/30/0705/30/0705/30/0706/12/0707/09/07OFFICIAL RECORD COPY EnclosureREQUEST FOR ADDITIONAL INFORMATION REGARDING NUCLEAR ENERGY INSTITUTE (NEI) TOPICAL REPORT NEI 07-03, REVISION 0,"GENERIC FSAR TEMPLATE GUIDANCE FOR RADIATION PROTECTION PROGRAMDESCRIPTION"1. The "Operational Radiation Protection Program" sections of Draft Guide-1145(Regulatory Guide (RG) 1.206) and the Standard Review Plan (SRP) (NUREG-0800)refer to several guidance documents that provide guidelines for an acceptableoperational radiation protection program. In general, most of this guidance is explicitlycalled out in Nuclear Energy Institute (NEI) 07-03. However, the staff has noted thefollowing omissions in NEI 07-03:*Regulatory Guide 8.25, "Air Sampling in the Workplace,"
- NUREG/CR-0041, "Manual of Respiratory Protection Against AirborneRadioactive Materials," *Memorandum from Larry W. Camper to David B. Matthews and Elmo E. Collins, "List of Decommissioning Less ons Learned in Support ofthe Development of Standard Review Plan for New Reactor Licensing,"October 10, 2006 (Agencywide Document Access and ManagementSystem (ADAMS) Accession No. ML062620355). Please incorporate the above guidance documents into the appropriate section ofNEI 07-03 or provide justification as to why these references should not be included inNEI 07-03. 2.The SRP references the following standards in Section 12.5, "Operational RadiationProtection Program":*ANSI/ANS 3.1-1993 R99, "Selection, Qualification, and Training ofPersonnel for Nuclear Power Plants,"*ANSI/HPS N13.6, "Practice for Occupational Radiation Exposure RecordsSystems,"*ANSI/HPS N13.11-2001, "Personnel Dosimetry Performance-Criteria forTesting,"*ANSI/HPS N13.14-1994, "Internal Dosimetry Programs for TritiumExposure-Minimum Requirements,"*ANSI/HPS N13.30-1996, "Performance Criteria for Radiobioassay," *ANSI/HPS N13.42-1997, "Internal Dosimetry for Mixed Fission ActivationProduct,"*ANSI IEEE 309-1991, "Test Procedure for Geiger-Mueller Counters,"
- ANSI N42.20-2003, "Performance Criteria for Active Personnel RadiationMonitors,"*ANSI N42.28-2002, "American National Standard for Calibration ofGermanium Detectors for In Situ Gamma Ray Measurements,"*ANSI N42.17A-1989, "Performance Specifications for Health PhysicsInstrumentation-Portable Instrumentation for Use in NormalEnvironmental Conditions,"*ANSI N323A-1997, "American National Standard Radiation ProtectionInstrumentation Test and Calibration, Portable Survey Instruments."Please incorporate the above listed ANSI standards into NEI 07-03 as references, orprovide justification as to why these standards have been omitted from NEI 07-03.3.(12.5) NEI 07-03 does not reference 10 CFR 20, Subpart B entitled "Radiation ProtectionPrograms." In order to include this reference, consider adding the following phrasepreceding the second paragraph in 12.5 (prior to the words "The purpose of"), "Inaccordance with 10 CFR 20, Subpart B,"4.(12.5) In the description of Milestone 2 ("Prior to receiving reactor fuel under thislicense"), reference is made to providing radiation monitoring in accordance with10 CFR 50.68. Compliance with 10 CFR 50.68 requires the establishment andimplementation of plant procedures relating to criticality accident requirements inaddition to the use of radiation monitoring equipment. Modify item 2 under the milestonesection of 12.5 to add the words, "plant procedures on criticality accident requirementswill be established, implement ed, and maintained and" prior to the words "radiationmonitoring."5.(12.5) In the section describing the four different milestones, no specific mention is madeof when the position of radiation protection manager (RPM) should be filled. It can beinferred from the text that this position should be fill ed prior to initial loading of fuel in thereactor (milestone 3). The description of milestone 3 should be modified to specifically state that the RPM position will be filled during this milestone stage.6.(12.5.1) In the list of management commitments listed, the establishment of an as low asis reasonably achievable (ALARA) Committee is listed as an option (item 8). Theestablishment of an ALARA Committee (or similarly named committee with similarfunctions) is an important part of an effective radiation protection program and shouldnot be listed as an optional management commitment. Please reflect this committee aspart of the main list of management commitments. 7.(12.5.2.1) The same comment (see #6 above) applies to listing the establishment of an ALARA Committee as an optional responsibility of the Plant Manager. RG 8.8 statesthat the RPM should have direct recourse to responsible management and making theALARA Committee one of the responsibilities of the Plant Manager would be one way toestablish such a link between the RPM and Plant Manager.8.(12.5.2.3) The same comment (see #6 above) applies to participating as a member of the plant ALARA Commi ttee as an optional responsibility of the R adiation Pr otectionManager. RG 8.8 states that the RPM should have direct recourse to responsible management and making the ALARA Committee one of the responsibilities of the RPMwould be one way to establish such a link between the RPM and Plant Manager.9.(12.5) For all Regulatory Guides referenced in NEI 07-03, please specifiy the revisionnumber.10.(12.5.3.2) In the list of "Personnel Monitoring Instrumentation and Equipment" there is nomention of remote and local reading alarm dosimeters (which may be coupled with director electronic surveillance equipment) for monitoring workers in high-dose/high-dose-rateenvironments. Please include "remote and local reading alarm dosimeters (which maybe coupled with direct or electronic surveillance equipment, as necessary)"
in the list asan example of Personnel Monitoring Instrumentation or provide justification as to whythese dosimeters should not be listed.11.(12.5.3.2) The nominal range shown for the neutron survey instruments listed under"Portable Monitoring Instrumentation and Equipment" is 0 - 5 rem/hr. Compared to thenominal ranges given for the other portable instrumentation, the upper range of 5 rem/hrseems low. Please justify why this is an appropriate nominal range for a neutron surveyinstrument.12.(12.5.4.4) The third paragraph in this section makes reference to 10 CFR 20.1903. Should this reference be 10 CFR 20.1602, which describes the additional administrativecontrols for restricting access to Very High Radiation Areas? 13.(12.5.4.7) The first paragraph in this section states that the requirements of10 CFR 20.1301 will be met. Please indicate in the text that the requirements of 10 CFR20.1302 will also be met, as they relate to controlling the maximum dose rate inunrestricted areas.14.(12.5.4.7) The first paragr aph states that the requirements of 10 CFR 20.1201 will becomplied with. However, no mention is made of 10 CFR 20.1202, 20.1203 or 20.1204. Please reflect the commitment to meet the requirements of 20.1201, 20.1202, 20.1203,and 20.1204, as they relate to demonstrating compliance with internal and external doselimits, in this section.15.(12.5.4.8) In the sixth paragraph of this section, please change the following sentence"Practical measures are implemented to prevent the spread of contamination, including,for example:" to "Practical measures are implemented to prevent the spread ofcontamination, including:" 16.(12.5.4.10) In the list of regulations for this section no mention is made of10 CFR 20.2201, "Reports of theft or loss of licensed material." Please indicate ifprocedures will be in compliance with this regulation by adding 20.2201 to the existinglist.Editorial ChangesConsider the following editorial changes as shown in Bold:E1.(12.5) In the paragraph describing the purpose of the radiation protection program,please correct as follows: "...as low as is reasonably achievable (ALARA)."E2.(12.5) In the paragraph describing Milestone 3, please change the first sentence to read,"Prior to initial loading of fuel in the reactor, the radiation protection program."E3.(12.5.1) Please change item number 7 of this section so that it reads as follows: "Establish a direct reporting chain of the Radiation Protection Manager to the PlantManager that is at the same reporting level as, but independent of, the reportingchains for Operations and Maintenance."E4.(12.5.2.3) Please modify item number 3 in this section as follows: "Provide radiation protection input to facility design, including plant modifications, and work planning;"E5.(12.5.2.4) Please change the first sentence of the second paragraph as follows: "Thequalifications and experience of RPTs are consistent with the guidance contained inRegulatory Guide 1.8."E6.(12.5.2.4) Please modify the third paragraph in this section as follows: "...trained andqualified staff in Radiation Protection (as described in section 12.5.2.5) other thanRPTs..."E7.(12.5.3.1) In the section titled "Storage and Issue Area for Contaminated Tools andEquipment" please change the last sentence in that paragraph to: "Clean andcontaminated tools and equipment are segregated to avoid cross-contamination."E8.(12.5.3.1) In the section titled "Facility for Dosimetry Processing and Bioassay" pleasechange the first sentence to: "A facility or facilities are provided to suppor t processing ofdosimetry and performance of bioassay..."E9.(12.5.3.1) In the section titled: "Laundry Facility" please make the following change to the second sentence:
"...applicable limits in 10 CFR Parts 20 and 50 and as low as isreasonably achievable..."E10.(12.5.4.2) In the section titled: "Refueling" please change the last sentence to thefollowing: "...the normal radiation level on the refueling bridge during these operationsis expected to be less than 5 mrem/h."E11.(12.5.4.2) In the section titled: "Inservice Inspection" please change the first sentence inthe following way: "...previous radi ation and contamination surveys, and/or previousRWPs appropriate to the particular job to be performed." E12.(12.5.4.2) In the section titled "Radwaste Handling" please modify the last sentence inthe paragraph in the following way: "The radwaste system is described in FSAR Chapter 11."E13.(12.5.4.2) Please reword the first two sentences of the section titled "Normal Operation"in the following way: "The plant was designed so that significant radiation sources areminimized, shielded, and/or located in cubicles. Instrument readouts forinstrumentation required for normal operation, for the most part, can be read remotelyfrom the control room or from other low radiation areas."E14.(12.5.4.2) The last sentence of the first paragraph under the section titled "RoutineMaintenance" should be changed as follows: "This serves to minimize the time spent inthe radiation area and thereby minimize personnel dose
."E15.(12.5.4.2) The first sentence of the second paragraph of the "Routine Maintenance" section should be modified to "In addition, the preventive maintenance procedure..." The word "usual" should be deleted.E16.(12.5.4.2) The second sentence of the second paragraph of the "Routine Maintenance" section should be modified to "...shielding is specified
, if appropriate, and additionalspecific instructions..."E17.(12.5.4.2) The first sentence of the third paragraph of the "Routine Maintenance" sectionshould be modified as follows: "Extension tools are used when practical to minimizedose when personnel are working on radioactive components/equipment
."E18.(12.5.4.2) The second to last sentence of the third paragraph of the "RoutineMaintenance" section should be changed as follows: "...accomplished as safely andquickly as possible, and what the acceptance criteria for completing the job are."E19.(12.5.4.4) The second sentence of the third paragraph should be modified as follows:
"...restricting access to each Very High Radiat ion Area as required by 10 CFR 20.
1602."E20.(12.5.4.7) Please change the second paragraph of this section as follows:"To the extent practical, procedures and engineered controlsbased on sound radiation protection principles are used to keepoccupational doses and doses to members of the public as low as is reasonably achievable (A LARA). A description of facility designfeatures and engineered controls intended to maintainoccupational exposures ALARA is included in FSAR Sections 12.3-12.4. A description of systems and facility design featuresintended to maintain public exposures ALARA is included in FSARChapter 11."E21.(12.5.4.7) Please change the second sentence in the paragraph marked by thenumber 3 in the following way: "The briefing s are intended to assure that personnel understand..." E22.(12.5.4.8) Please change the fourth and fifth bullets in this section in the following way: "Containments, caches and enclosures are used during maintenance, repairs, andtesting , when practical , to contain spills and releas es;" and "Engineer ing controls , suchas portable ventilation or filtration units to reduce concentrations of radioactivity in air orfluids, are used where practical;"E23.(12.5.4.8) Please change the seventh bullet in this section to read as follows:"...necessitate disposal as radioactive waste is minimized;"
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