ML20197D554

Forwards Responses to Addl Questions Raised in Telcon W/Nrc Re Util 850701 Request for Exemption from 10CFR20 Respiratory Protection Requirements

ML20197D554
Person / Time
Site:	Wolf Creek
Issue date:	05/06/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
KMLNRC-86-076, KMLNRC-86-76, TAC-59366, NUDOCS 8605140296
Download: ML20197D554 (4)

Text

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KANSAS GAS AND ELECTRIC COMPANY tt E ELECTFhC COM*ANY GLENN L ROESTER

,,c. . ..u ~c u.. May 6, 1986 Mr. Harold Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washingtoq, D.C. 20555 KMLNRC 86-076 Re: Docket No. STN 50-482 Ref: 1)KMLNRC 85-167, dated 7/1/85, from GLKoester, KG&E, to HRDenton, NRC 2)Iatter dated 9/5/85, from BJYoungblood, NRC, to GLKoester, KG&E ,

3)KMLNRC 85-246, dated 11/8/85, from GLKoester, KG&E, to HRDenton, NRC 4)KMLNRC 86-002, dated 1/7/86, from GLKoester, KG&E, to HRDenton, NRC Subj: Response to Second Request for Additional Information on 10 CFR 20 Exemption

Dear Mr.-Denton:

Kansas Gas and T.lectric Company (KG&E) requested an exenption to"10 CFR 20 respiratory protection requirenents in Reference 1.

A reluest for )

additional information was received via Reference 2. 'Ihis request was i responded to by KG&E in References-3 and 4. Additional questions were l raised in a teleco1 betwean KG&E and the NBC. Attachment A documents these additional questicns end the KG&E responses, j 1

If you have any questions, please contact me or Mr.- .O. L. Maynard of my  !

staff.

.Very truly yours, lenn L. Koester Vice President - Nuclear GLK:see Attachment cc: PO'Connor (2) '

JCtmnins '

O 8605140296 860506 '

PDR ADOCK 00000482 i i

P PDR )

201 N. Market -Wichita, Kansas - Meil Address: RO. Box 208 i Wichita, Kansas 67201 - Telephone: Area Code (316) 2616451

, Mr. H. R. Denton 1

Attachment to KMUGC 86-076 Page 1 of 3  ;

l l

l ATTACHMENT A RESPONSES TO NRC PLANT SYSTEMS BRANCB REQUEST FOR ADDITIONAL INFORMATION I

NRC Ouestion '

10. Describe how the quality and function of MSA GMR-1 canisters will be verified by KG&E. Since radioiodine breakthrough is not directly detectable by the user, it is the utility's responsibility to assure that canister performance and i quality are fully adequate through such measures as l l

verification of venderof through development quality control utility /q/QCuality

/ site QA assurance,which procedures and )

provide continuing assurance of canister quality. l

a. Provide a general discussion of the vendor audit noted l in your 8/11/85 submittal if this information is I available,

b. Cite general controls and procedures related to GMR-I canister QA/QC. l I

Resoonse 10.a Manufacturing activities and acceptance testing  !

activities in the MSA facility in Evans City and quality controls in MSA's Glenshaw warehouse facility were audited on December 10 - 11, 1985. The scope of the audit included verifying MSA's compliance to the MSA procedure for manufacture of GMR-I canisters and verifying MSA's compliance for acceptance testing of manufactured GMR-I canister lots.

Categories covered at the Evans. City facility were:

A. Organization B. Training l C. Work instructions and procedures D. Records E. Nonconformance control and corrective actions .

F. Design control G. Control of measuring and test equipment i H. Procurement control i I. Inspection (in-process and final) i J. Packing and storage K. Audits L. Qualification of test personnel M. Control of measuring and test equipment N. Compliance with MSA Specification No. 356

o '. Attachment to KMWRC 86-076 Page 2 of 3 The programs at these facilities were determined to be

adequate and quality controls acceptable. Two areas of concern were identified. However, these areas of concern do not limit the acceptanc.e of the MSA quality program by KG&E.

Actual procurement of GMR-I canisters will not be allowed until these two minor areas of concern are addressed.

Response

i 10.b Storage and use of GMR-I canisters are included as part of the on-site audits /surveillances of the radiation protection program. Warehouse and purchasing procedures are used to ensure GMR-I canisters are stored in a cool, dry environment which will not exceed 90' F or 70%

humidity. Also, HPH 06-XXX will specify the storage conditions for the canisters. The draft procedure HPH 06-XXX will be finalized after receipt of approval of i this exemption.

1 NRC Ouestion

11. Specify the procedure or other inspectable document which documents your commitment to store canisters in a cool, dry environment which will not exceed 90*F or 70% humidity.

Response

11. A stand alone procedure to cover the issue and use of GMR-I canisters which requires the storage environment to be in a cool, dry environment which will not exceed 90* F or 70%

humidity is currently in draft status and will be finalized as needed to meet the exemption.

NRC Ouestion

12. Provide a response to the second half of RAI 7.b, " Outline the sampling program for radioiodines and what measures will be taken to establish baseline data for organics which are not readily sampled or detected." This should include a general discussion of radioiodine sampling frequencies as contained in station procedures, and should discuss how organic vapors which have a high sampling detection threshold (e.g. 100 ppm), or no practical sampling method, will be detected or precluded (e.g. by administrative -procedures) .

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, . . _ _ _ . . _ . . . . - . . __ _ . . _ _ _ _ _ _ . , . _ . , _ _ .~

~

Mr. H. R. Denton 9 *\ Attachment to KMLNRC 86-076 Page 3 of 3

Response

12. BPH 03-001 "In Plant Radioiodine Monitoring" defines methods used to determine radioiodine concentrations and circumstances when radioiodine sampling is required.

Whenever there may be radiciodine from a suspected primary side leak an air sample is required prior to entry or work in the area.

The draft procedure for the use o'f the GMR-I canister specifies that the protection factor cannot be taken in the presence of organic solvents or painting fumes. Procedure ADM 04-030, "Use of Plant Chemical and Cleaning Agents",

prohibits the use of chemical products that produce organic vapors without appropriate safety reviews. Therefore, the presence of harmful organic vapors can be determined prior to GMR-I usage by laonitoring the work activities in an area.

NRC Question

13. Verify that there are no conditions expected where 110 *F(or up to 120 *F if ~107* dewpoint is not exceeded) will be exceeded in mode (5) or (6). Identify temperature surveys to be taken at such times in association with GMR-I use (e.g.

midsummer in-containment use) .

Response

13. The draft procedure for the use of GMR-I canisters requires temperature to be taken prior to use and coincidently with the use of GMR-I canisters to assure work temperatures do not exceed 110 or 120* if 107* dewpoint is not exceeded, when conditions are suspect of approaching these temperatures.