ML20136G036
| ML20136G036 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1985 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20136G043 | List: |
| References | |
| RTR-NUREG-0800, RTR-NUREG-800 NUDOCS 8506030606 | |
| Download: ML20136G036 (38) | |
Text
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION U
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HAY I 7 g MEMORANDUM FOR:
Victor Stello, Jr.
Deputy Executive Director Regional Operations and Generic Requirements FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulations
SUBJECT:
ISSUANCE OF PROPOSED NEW SRP SECTIONS 12.6 AND 12.6.1 THROUGH 12.6.4 0F NUREG-0800 Proposed new Section 12.6, "0ccupational Exposure Associated with Expansion of the Spent Fuel Pool - Introduction"; Section 12.6.1, " Radiation Sources";
Section 12.6.2, " Radiation Dose Rates"; Section 12.6.3, " Area Radiation and Airborne Radioactivity Monitoring"; and Section 12.6.4, "As Low As Is Reasonably Achievable Actions To Be Taken" of the Standard Review Plan (SRP), NUREG-0800 have been prepared to incorporate information for review of the licensees' radiation protection program during spent fuel pool (SFP) modifications. These SRP sections will provide criteria used by the
. Radiological Assessment Branch in evaluating radiation protection provided by licensees during the process of converting SFP facility designs from low-density storage racks (currently being used) to new high-density racks.
The ;.te'elines contained in these SRP sections are not new criteria nor will they impose upon the licensees any additional requirements or burdens by their issuance for use.
Authorization for a spent fuel pool facility design modification, accompanied by a Technical Specification change request is submitted for approval by licensees and in some cases utility appifcants.
Thus far, forty-two SFP facility design modification reviews have been performed at the request of licensees, and we expect that at least thirty-six others will be requested in the future.
The criteria incorporated into the SRP sections for these reviews is a formalization and articulation of existing criteria that were used by the staff as a basis for judging the adequacy of radiation protection plans i
l for the forty-two operating reactor plant evaluations (as document by SERs) j that have been previously approved. The use of these SRPs in the regulatory 1
review process will assure that evaluations for all plants will be uniform and complete.
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MAY 17 ggs We intend to process the proposed new SRP sections as a Type I change and to forgo the formal CRGR review of the regulatory package on the bases that the criteria contained therein does not impose new requirements on licensees or applicants. However, in keeping with past practices, we will issue the new SRPs fcr public comments.
Enclosed for your information is a copy of the Regulatory Analysis associated with Revisions 0 to SRP Section 12.6 and 12.6.1 through 12.6.4 of NUREG-0800. Therefore, unless you disagree, we intend to publish the Federal Reaister Notice' for, Issuance of Availability "For Comment" 10 working days af ter youdeceive this memo.
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Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
- 1. Regulatory Analysis
- 2. Proposed SRP Section 12.6 and 12.6.1 through 12.6.4 cc w/o encl.:
R. Bernero D. Muller l
S. Block 4
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l REGULATORY ANALYSIS FOR RADIATION PROTECTION i
PROGRAM USED DURING $ PENT FUEL P00L MODIFICATION i
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SACKGROUND i
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The number of requests to NRC for licensees for authorization to increase their spent fuel capacity is expected to increase in the near future.
This j
is because of increased demand for storage space for spent fuel assembifes f
,since existing off-site storage facilities are not available and some
[
j licensees are nearing exhaustion of their available on-site storage space.
l They are, therefore, susceptible to shutdown for lack of capability to j
l refuel.
Facilities for reprocessing of spent fuel are not expected to be I
operational in this decade or longer, so that a reprocessing / waste disposal j
option is not viable for relief of space in the near future.
]
Since most licensees used low density spent fuel storage racks in their early spent fuel pool ($FP) designs to prevent fuel pool criticality, the l
more recent sooroach to use high-density racks would provide much more i
availaole space. The proposal to replace the low density racks with high density racks involves a change in Technical Specifications with concomitant.
f staff review and issuance of a safety Evaluation Report ($ER).
I, In order to assure a complete review of the licensee's safety Analysis i
Reports.($AR) for modification of the $FP, and speed-up the review process,
(
the staff has developed a Standard Review Plan ($RP) for review of the I
j occupational radiatten protection ptogram of the $FP modification plan.
The i
SAP would provide licensees, and staff responsible for reviewing the SAR as I
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it concerns occupational exposure, with the depth and detail required to j
develop the SAR and SER, respectively.
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Value The value of the Review Plan is twofold.
Firstly, it will provide the Radiological Assessment Branch reviewers uniform technical guidance needed to perform an in-depth review of the licensee's proposed radiation protection plan, as described in the SAR, submitted with the request for increasing the storage capacity of the SFP.
The Review Plan details what the staff considers to be radiologically significant input provided by licensees in the past and necessary for the reviewers to examine in order to
, evaluate the radiation protection impact of the changes in the design of the l
SFP proposed by the licensee.
The end product of the review is development i
of an SER with no detail missing that could create cause for open items.
t Secondly, it would provide the information to a licensee, who is preparing an SAR for expanding the capacity of the SFP, on the details of information needed by the NRC staff to complete their review of the SAR with respect to
, occupational exposure.
It should be noted that some of the details I
addressed in the SRP are based on issues raised by the ASLB and intervenors durino hearino relevant to SFP expansion.
It should also be noted that this SRP was developed using the experience of several staff reviews of SFP i
modification requests.
During fuel capacity expansion, the licensee's plan for removal, disassembly and disposa) of old racks and installation of new racks is reviewed.
This is done to determine the validity of the licensee's estimate of personnel exposure during the expansion.
The ifcensee's estimated costs for alternative ways to perform the expansion and rack disposal (e.g., cutting up the old racks and crating the pieces, or crating and shipping the intact old racks) are reviewed.
These alternate costs and estimated personnel exposure are compared to determine that personnel exposures are as low as is
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reasonably achievable (ALARA).
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The licensee's estimate of the additional personnel exposure for ope l exposure in the expanded SFP is reviewed to compare' it with the total annua to the entire plant.
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There will be no additional burdens or igact imposed on licensees M
i t d with spent applicants since the staff review of safety concerns assoc a e The new SRP fuel pool modifications (SFP) is initiated at their request.
The criteria /
sections consolidate the articulate past review practices.
ff in the past to g
guidelines incorporated into the SRPs were used by the sta that ha i
perform safety reviews for the forty-two nuclear facilit es p-These reviews were requested NRC approval for SFP design modifications.
n based on the conducted on a plant-by-plant basis and to a large extent were i
safety licensees /appiteant interpretation of information (inferred from p The SRPs would have a net l
evaluation reports) needed for the review.
tion of the beneficial effect by avoiding misunderstandings or misinterpreta i
SFP unexpressed criteria that governed safety e9alysis for pr l
j modificctfuns requests.
Thus, it became evident that pool designs that will requ' ae modifications.
iform and the review process should ts formalized as an SRP to assure un ff and complete attention to detail and to increase efficiency of sta No additional applicant resources by providing guidance on the process.
f these SRP l
requirements are being imposed upon the licensees by issuance l sections for use.
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(Formerly NORED 75/087)
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f(v#.U.S. NUCLEAR REGULATORY COMMISSIO STANDARD REVIEW PLAN
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OFMCE OF NUCLEAR REACTOR REGULATION Proposed Revision Standard Review Plan PSRP-12.6. Rev. O This proposed Section to the Standard Review Plan and its supporting Reculatory (value/ impact) Analysis have not received a complete staff review and approval and do not represent an official NRC staff position.
The proposed Section to the Standard Review Plan incorporates guidelines /
acceptance criteria used by the staff for review of Licensees radiation protection program provided during spent fuel pool modifications.
Public corsnents are being solicited on the proposed SRP Section and the associated regulatory analysis (including any implementation schedules) prior to a final review and decision by the Office of Nuclear Reactor Regulation as to whether this proposed revision should be approved.
Coments should be sent to the Secretary of the Comission. U.S. Nuclear Regulatory Comission. Washington, D.C.
20555. Attention: Docketing and Service Branch. All coments received by will be considered, and all of the associated documents and coments considered will be made publicly available prior to a decision by the Director. Office of Nuclear Regulatory Regulation, on whether to implement this revision. Copies of each of these documents are available upon written request to the Division of Technical Infonnation and Document Control. U.S. Nuclear Regulatory Comission. Washington, D.C.
20555.
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I NUREn-0800 (Formerly NUREG 75/o87)
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OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED REVISION 0 TO SECTION 12.6 OCCUPATIONAL EXPOSURE ASSOCIATED WITH EXPANSION OF THE SPENT FUEL POOL -
INTRODUCTION REVIEW RESPONSIBILITIES
. Primary - Radiological Assessment Branch (RAB)
Secondary - None I.
AREAS OF REVIEW l
The RAB reviews information on the proposed spent fuel pool (SFP) modification with respect to its impact on occupational radiation exposure.
This review considers the procedure for removal and disposal of the low-density storage racks, currently used in the SFP, and installation of new high-density racks; the scope of the radiation sources and respective dose rates; the radiation protection program, including area and airborne radioactivity monitoring equipment, and the as low as is reasonably achievable (ALARA) program that will be used to ensure that occupational radiation exposure will be ALARA.
The various features of the radiation protection program to be reviewed under this SRP *section have been separated and assigned to a set of other SRP sections as follows:
1.
Radiation Sources (SRP Section 12.6.1) 2.
Radiation Dose Rates (SRP Section 12.6.2) 3.
Area Radiation and Airborne Radioactivity Monitoring (SRP Section 12.6.3) 4.
As Low As Is Reasonably Achievable Actions To Be Taken (SRP Section 12.6.4)
A separate SRP section has been prepared for each of these areas.
USNRC STANDARD REVIEW PLAN
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The items reviewed are described in the " Areas of Review" subsections of the four SRP sections listed above.
II. ACCEPTANCE CRITERIA The acceptance criteria are given in the " Acceptance criteria" subsections of the four SRP sections listed above.
III.
REVIEW PROCEDURES Review procedures are given in tho'" Review Procedures" subsections of the four SRP sections listed above.
IV.
EVALUATION FINDINGS The staff's review should verify that sufficient information is contained in the submitted 5FP modification plan to arrive at conclusions that are to be
- addressed in the Safety Evaluation Report.
The following is a representation of the evaluation finding.
Occupational Radiation Exposure The staff has reviewed the licensee's plan for the removal and disposal of the Iow-density racks and installation of the high-density racks with respect to occupational radiation exposure and concludes that the ALARA policy, design, and operational considerations are acceptable.
This conclusion is based on the licensee having considered the requirements of 10 CFR Parts 20.101 and 20.103, and Regulatory Guides 8.8 and 8.10.
The occupational exposure for this operation is estimated by the licensee to range from to man-rem.
This estimate is based on the licensee's detailed breakdowT of occupational exposure for each phase of the modification. The licensee considered the number of individuals performing a specific job, their occupancy time while performingthisjob,andtheaveragedoserateintheareawherethejobis bothQ performed.
The spent fuel assembifes themselves contribute a negligible amount to dose rates in the pool area because of the depth of water shielding the fuel. One potential source of radiation is radioactive activation or corrosion products called crud.
Crud may be released to the pool water because-of fuel movements during the proposed SFP modification.
This could increase radiation levels in the vicinity of the pool.
During refuelings, when the spent fuel is first moved into the fuel pool, the addition of crud to the pool water from the fuel assembly and from the introducton of primary coolant to the pool water is greatest.
However, the licensee does not expect to have significant releases of crud to the pool water during modification of the pool. The purification system for the pool, which has kept radiation levels in the vicinity of the pool to low levels, includes a filter to remove crud and will be operating during the modification of the pool.
The licensee has presented three alternative plans for removal and disposal of the old racks. These are (1) crate and ship intact racks (2) cut the racks into small pieces with a shredder and pack the pieces into drums for burial, and (3) have an outside vendor chemically decontaminate the intact racks.
If the decontamination option is selected, the decontamination chemicals would be 12.6 2 Rev. O
reduced in volume, solidified, and buried.
The bulk of the decontaminated racks could be disposed of as clean scrap.
In any event, the disposal meth-odology will follow ALARA guidelines for each of the alternatives in accordance with Regulatory Guide 8.8.
It should be noted that the procedure for removal of old racks from the pool will be performed independently of the afore-mentioned disposal alternatives; that is, the racks will be individually lifted from the pool water and rinsed by hydrolasing to remove any loose radioactivity that will drip back into the SFP water before being moved to a receiving area for preparation for disposal.
Divers will be used for setting and shimming the hign-density racks.
Relevant experience indicates that the diver exposure should be about man-rem for rack installation including cleanup and diver work.
On the basis of the manner in which the licensee will perform the modification, his radiation protection program, including area and airborne radioactivity monitoring, and relevant experience from other operating reactors that have performed similar SFP modifications, the staff concludes that the (licensee)
SFP modification can be performed in a manner that will ensure ALARA exposures to workers.
The staff has estimated the increment in onsite occupational dose during normal operations after the pool modification resulting from the proposed increase in stored fuel assemblies.
This estimate is based on information supplied by the licensee for occupancy times and for dose rates in the spent fuel area from radionuclide concentrations in the SFP water.
The spent fuel assemblies themselves contribute a negligible amount to dose rates in the pool area because of tte depth of water shielding the fuel. On the basis of present and projected operations in the spent fuel pool area, the staff estimates that the proposed modification should add less than 1% to the total annual occupa-tional radiation exposure at both units.
1he small increase in radiation exposure should not affect the licensee's ability to maintain individual occupeLion41 doses at ALARA levels and within the limits of 10 CFR Parts 20.101 and.20.103.
Thus, the staff concludes that storing additional fuel in the two spent fuel pools will not result in any significant increase in doses received by workers.
V.
IMPLEMENTATION The implementation schedules are given in the " Implementation" subsections of the four SRP sections listed above.
VI.
REFERENCES References are given in the " Reference" subsections of the four SRP sections listed above.
12.6-3 Rev. O
NURE30000 (Formerly NUf.EU 75/087)
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U.S. NUCLEAR REGULATORY COMMISSION ig%,! STANDARD REVIEW PLAN
(...../
OFFICE OF NUCLEAR REACTOR REGULATION Proposed Revision Standard Review Plan PSRP-12.6.1. Rev. 0 This proposed Section to the Standard Review Plan and its supporting Regulatory (value/ impact) Analysis have not received a complete staf f review and approval and da not represent an official NRC staff position. The proposed Section to the Standard Review Plan incorporates guidelines /
acceptance criteria used by the staff for review of 1.icensees radiation protection program provided during spent fuel pool modifications.
Public coments are being solicited on the proposed SRP Section and the associated regulatory analysis (including any implementation schedules) prior to a final review and decision by the Office of Nuclear Reactor Regulation as to whether this proposed revision should be approved.
Coments should bc sent to the Secretary of the Comission. U.S. Nuclear pagniatary fla m ission. Washington. D.C.
20555. Attention: Docketing and Service Branch. All coments received by will be considered, and all of the associated documents and coments considered wilI be made publicly available prior to a decision by the Director. Office of Nuclear Regulatory Regulation, on whether to implement this revision. Copies of each of these documents are available upon written request to the Divisior, of Technical Information and Document Control. U.S. Nuclear Regulatory Comission. Washington, D.C.
20555.
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NUREC 0800 (Forme,1y NUREG 75/007)
/'6 81,.6h U.S. NUCLEAR REGULATORY COMMISSION ig"i STANDARD REVIEW PLAN Sy..v OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED REVISION O TO SECTION 12.6.1 RADIATION SOURCES REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
Secondary - None I.
AREAS OF REVIEW The following areas of the Itcensee's Safety Analysis Report (SAR) are reviewed as they relate to radiation sources during normal operations and refueling:
1.
Sources in the Spent Fuel Pool Water A description of fission and corrosion product sources in the spent fuel pool (SFP) water from (a) introduction of primary coolant into the SFP water, (b) movement of fuel from the core into the pool, and (c) defective fuel stored in the pool should be provided to include a listing of the radfo-nuclides and their concentrations (expressed in pC1/mL) expected or measured
.duringnormalogCo,sa*Cs,and887Cs.erations and refueling.
The radionuclides of interest should include s.Co, *
(See Appendix A of this SRP section.)
2.
Airborne Radioactive Sources A description of radioactive materials that may become airborne as a result of failed fuel and evaporation should be given (e.g., 88Kr and sH, respectively).
The radionuclide description should include calculated or measured concentra-tions expected during normal operations and during refuelings.
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I 3.
Miscellaneous Sources of Exposure r
A description of the effects of more frequent replacement of domineralizer i
filters on cumulative dose equivalent should be addressed in the SAR if this is a factor that results from the modification, i
ACCEPTANCE CRITERIA RAB acceptance criteria are based on meeting the following regulations:
1.
10 CFR Part 20, Section 20.101, " Radiation Oose Standards for Individuals in Restricted Areas," as it relates to limiting radiation doses to protect i
individuals in restricted areas from whole or partial exposures, i
i 2.
10 CFR Part 20, Section 20.103, " Exposure of Individuals to Concentra-tions of Radioactive Materials in Air in Restricted Areas," as it relates to Ilmiting average concentrations of airborne radioactive materials to protect individuals in restricted areas, and control of inhalation or absorption of such materials, i
3.
10 CFR Part 50, General Design Criterton 61, " Fuel Storage and Handling and Radioactivity Control," as it relates to systems that may contain l
i radioactive materials.
The following regulatory guide provides information, recommendations, and guidance for implementing the requirements of 10 CFR Parts 20.101, 20.103 and GDC 61.
1.
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations W111 Se As Low As !s Reason-i ably Achievable," position section as it relates to parameters in deter-ininv Jon from external and internal exposures, i
Radienuclides whose concentrations (pCf/mL) in the SFP contribute to the dose l
rate in occupied areas in the proximity of the SFP should be addressed.
Radionuclides such as seCo, soCo. sa*Cs, and is7Cs are the major contributors to dose rate.
Activities that are less than 10 8 pCf/mL need not be considered, Av. ease of any asMr and 8H into the 5FP ares that may be attributed to the l
j storage of additional assemblies in the SFP should also be addressed.
REVIEW PROCEDURES l
l The reviewer compares the concentrations shown in the table in Appendix A of i
this SRP section (which has been taken from relevant experience) with those concentrations specified by the licensee.
The licensee should justify any of I
his concentrations that are lower than those shown in Column A of the table.
l Appendix A ef this SRP section also indicates the range of dose rates consistent with the given concentrations.
If the dose rates and concentrations do not j
fall within these bounds, the Ifcensee should justify the anomaly.
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12.6.1 2 Rev. O l
IV.
EVALUATION FINDINGS 4
The conclusions reached on completion of the review of this section are presented in the " Evaluation Findings" subsection of SRP Section 12.6.
V.
IMPLEMENTATION The following is intended to provide guidance to Ifcensees regardlig the NRC staff's plans for using this SRP section.
Except in those cases in which the applicant proposes an acceptable atternative method for complying with specified portions of the Commission's regul ttions, the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.
Implementation schedules for conformance to parts of the method discussed herein are contained in the referenced regulatory guide, and in accordance with the following:
S 1.
This SRP section is rat applicable to CP applicants.
2.
This SRP section is not applicabie to 0L applicants unless materials have been stored in the spent fuel pool that may be the cause of conteelnation (i.e., new fuel, spent fuel, reactor components or equipment, etc.).
3.
Operating rear. tor Itcensees will be required to comply with the provisions of this SRP section during design modifications to their spent fuel pool storage facility.
VI.
REFERENCES 1.
10 CFR Part 20, " Standards for Protection Against Radiation"
- 2..-10 CFR Part 50, Deste Criterion 61, " Fuel Storage and Handling and Raatoactivity Control" t
3.
Regulatory Guide 8.4, "Information Relevant to Ensuring that occupational 1
Radiation Exposures at Nuclear Power $tations Will Ae As Low As Is Reason-i ably Achievable" 4.
Appendix A, " Concentrations Normally Found in Spent Fuel Pools" r
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12.6.1 3 Rev. O l
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NU REP-0800 (Formerly NURED 75/087) iM ) U.S. NUCLEAR REGULATORY COMM
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OFRCE OF NUCLEAR REACTOR REGULATION PROPOSED APPENDIX A TO SRP SECTION 12.6.1 CONCENTRATIONS NORMALLY FOUND IN SPENT FUEL POOLS REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
Secondary - None Dose rate levels generally range from 1 to 5 arem/hr at 100 cm above the surface of the pool.
For cools whose concentrations may be greater than the concentra-tions shown in Table A.1. the dose rate above the pool will be commensurately higher.
In these cases the licensee should justify that these dose rates are ALARA. and explain why his spent fuel pool cleanup system is not as effective as those of other licensees.
TABLE A.1 Range of Concentrations Normally Found in Spent Fuel Pools (pC1/mL)
Radionuclide Col A Col B ssCo 5 x 10 5 to 6 x 10 4 80Co 7 x 10 8 to 7 x 10 4 asics 8 x 10 5 to 5 x 10 4 887Cs 6 x 10 5 to 10 8 12.6.1 Al Rev. O USNRC STANDARD MEVIEW PLAN si aa.,a......i.a......... 4.e.,in.1 4.a...ein. o.vei...eu.
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OFRCE OF NUCLEAR REACTOR REGULATION Proposed Revision Standard Review Plan PSRP-12.6.2. Rev. O This proposed Section to the Standard Review Plan and its supporting Regulatory (value/ impact) Analysis have not received a complete staf f review and approval and do not represent an official NRC staff position. The proposed Section to the Standard Review Plan incorporates guidelines /
acceptance criteria used by the staff for review of Licensees radiation protection program provided during spent fuel pool modifications.
Public coments are being solicited on the proposed SRP Section and the associated regulatory analysis (including any implementation schedules) prior to a final review and decision by the Office of Nuclear f.esctor Regulation as to whether this proposed revision shou'd be approved.
Coments should be sent to the Secretary of the Comission. U.S. Nuclear Regulatory Comission. Washington. D.C.
20555. Attention:
Docketing and 9arvira Branch.
All coments received by will be considered.
and.all of the associated documents and coments considered will be made publicly available prior to a decision by the Director. Offico of Nuclear legulatory Regulation. on whether to implement this revision. Copies of each of these documents are available upon written request to the Division of Technical Infomation and Document Control. U.5, Nuclear Regulatory Comission. Washington. D.C.
20555.
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OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED REVISION 0 TO SECTION 12.6.2 RADIATION DOSE RATES REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
' Secondary - None 1.
AREAS OF REVIEW The following areas of the licensee's SAR are reviewed as they relate to dose equivalent rates from the radiation sources described previously:
1.
Dose Rates from Fuel Assemblies, Control Rods, and Burnable Poison Rods a.
A description of the dose rate at the surface of the pool water from the fuel assemblies, control rods, burnable poison rods or any miscellaneous materials stored in the pool should be given.
Additionally, the dose rate from individual fuel assemblies as they are being placed into the fuel racks also should be given.
Information relevant to the depth of water shleiding the fuel ass ablies as they are being transferred into the racks should be specified.
If the depth of water shielding over a fuel assembly while it is aeing transferred to a spent fuel rack is less than 10 feet, or the dose rate 3 feet above the spent fuel pool (SFP) water is greater than 5 mR/nr above ambient radiation levels, then the Itcensee should submit a Technical Specification specifying the minimum depth of water shielding over the fuel assembly as it is being trans-ferred to the fuel rack (see Appendix A and Figure A.1 of this SRP sec-tion) and the seasures that will be taken to assure that this minimum depth will not be degraded.
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b.
Dose rate changes at the sides of the pool concrete shield walls, where occupied areas are adjacent to these valls, should be reviewed as a result of the modification.
Increasing the capacity of the pool may cause spent fuel assemblies to be relocated closer to the concrete walls of the pool, resulting in an increase of. radiation levels in occupied areas.
The licensee should evaluate this potential problem.
2.
Dose Rates from SFP Water Information on the dose rates at the surface of SFP water resulting from radioactivity in the water should be given. (See Appendix A to SRP Section 12.6.1.) Dose rate levels in occupied areas and along the edges and center of the pool and on the fuel handling crane should be addressed.
Effects of crud buildup, if any, should be given.
Based on refueling water activity, the dose rates before, during, and after refueling should be considered by the licensee.
3.
, Dose Rates from Airborne Isotopes Based on the source terms, dose rates from submersion and dose commitments frominhalationofairborneactivit{H.should be given for onsite exposures, for the concentrations of asKr and 4.
Oose Assessment from Modification Procedures a.
Outline of Activities: The manner in which old racks are to be removed, decontaminated, and disposed of and the new racks installed should be described.
If double tiering or consolidation of fuel pins is to be effected in the modification plan, then additional details will be required.
(1) Double Tiering - Dose rates above the top tier should be addressed for the assemblies to be stored there.
The SAR should note the
~~
geometrical array planned for new assemblies placed in the racks of the tiers as compared with old assemblies to ensure that as low as is reasonably achievable (ALARA) dose rates are achieved at the pool surface.
During placement of an individual fuel assembly, when the depth of water shielding the assembly is minimal (~4 to 5 feet for a typical pool), dose rates to workers with this minimal shielding should be described.
The licensee should determine, by calculation.
or relevant experience, what the dose rate will be and demonstrate that it is ALARA.
(See Item 1.a. under " Areas of Review.")
(2) Pin (or Rod) Consolidation - The licensee should describe in detail the process to be used for pin consolidation, including number of pins consolidated, dose rate over the surface of the pool water during pin removal for consolidation, methodology used to preclude SFP water from becoming highly contaminated if the pin should rupture 12.6.2-2 Rev. 0
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4 (e.g., close-capture cleanup system with filters appropriately shielded), method used for identifying pins that are most likely to rupture, mockup experience to be achieved, and a scenario that would warrant discontinuing the consolidation procedure for reassessment.
The licensee should determine, by calculation or relevant experience, 4
what the dose rate will be under all operating conditions and demon-strate that it is ALARA.
b.
Dose Control Actions:
For all modification plans, the descriptive information for the following will be required in the report submitted by the licensee:
(1) The manner in which occupational exposure will be kept ALARA during the modification, including the need for and the manner in which~ cleaning of the crud on SFP walls will be performed to reduce exposure rates in the SFP area.
(2) Vacuum cleaning of SFP floors if divers are used.
(3) Cleanup of the SFP water to minimize radiactive contamination i
and to ensure fuel pool clarity and underwater Ifghting accept-ance criteria to help ensure good visibility.
(4) Distribution of existing spent fuel stored in racks to allow maximum water shielding to reduce dose rates to divers (see References 8 and 9 of this SRP section).
(5) Underwater radiation surveys made before any diving operation; these surveys shall be performed before or after any fuel move-ments or movements of any irradiated components stored in the
{
pool, with contact radiation levels greater than 1 R/hr, using twc independent monitors (see References 8 and 9 of this SRP l
section).
(6) Equipping each diver with a calibrated alarming dosimeter and personnel monitoring dosimeters, which should be checked period-ically to ensure that prescribed dose limits are not being exceeded (see References 8 and 9 of this SRP section).
1 (7) Preplanning of work by divers as required.
(8) Provision for surveillance'and monitoring of the work area by Health Physics personnel.
Work Functions and Associated Dose:
The tasks that will be performed c.
during the modification and rack disposal and the associated occupa-tional exposure should be categorized as follows:
(1) task to be performed, (2) manpower required including divers, (3) expected dose rate, (4) time in radiation ficid, and (5) expected man-rems.
Tasks 1
include the removal and disposal of the old rack and installation of the new one. Handling of fuel assemblies already stored in the pool shall also be described with respect to the shifting of fuel from the old racks to the new ones during the modification.
12.6.2-3 Rev. 0
d.
Disposition of Fxisting Racks: With respect to the removal and disposal of the old racks, the licensee should describe the following:
(1) The method that will be used to remove, decontaminate, and dispose of the old racks.
Disposal alternatives should include
~
crating intact racks for disposal at a low-level waste curial site or cutting and placing them in drums for buriah If the racks are to be decontaminated and stored on site, then this alternative should be described.
(2) The number of workers that will be required for each operation, including divers if necessary.
(3) The dose rate associated with each phase of rack removal and disposal, occupancy times, and the total man-rems that will be received by all workers.
The licensee shall demonstrate that his methodology for disposal of racks will provide ALARA exposures and take into consideration Items (1), (2), and (3) above, costs, space available at burial sites, etc.
II.
ACCEPTANCE CRITERIA The acceptance criteria given below are applicable with respect to measurements made of dose rates from all the sources of radiation addressed in SRP Section 12.6.1, including the fuel assemblies or other sources that may be stored in the spent fuel pool; the fission or corrosion products in the pool water; the airborne radioactivity; and the removal, decontamination, and disposal of the low-density racks.
1.
10 CFR Part 20, Section 20.103, " Exposure of Individuals to Concentra-
..tions of Radioactive Materials in Air in Restricted Areas," as it relates to measuring dose rates from airborne radioactivity to ensure compliance with this part.
2.
10 CFR Part 20, Section 20.201, " Surveys," as it relates to radiation surveys that must be made to ensure compliance with the regulations.
3.
10 CFR Part 50, General Design Criterion 61, " Fuel Storage and Handling and Radioactivity Control," as it relates to design of shielding for radiation protection purposes.
The following regulatory guides provide information, recommendations, and guidance for implementing the requirements of 10 CFR Parts 20.101, 20.103 and GDC 61.
1.
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reason-l ably Achievable," position section as it relates to the need for measure-ment of dose rates to determine exposure potential in order to keep doses ALARA during services that must be performed in the SFP area.
Dose rate measurements are also needed to identify the proper radiation zone desig-nation for the area.
12.6.2-4 Rev. O
J 2.
Regulatory Guide 8.10, " Operating Philosophy for Maintaining occupational Radiation Exposures As Low As Is Reasonably Achievable," Position C1 as it relates to management's commitmer.t to keep occupational exposure ALARA, and the manner in which this commitment is best fulfilled.
The licensee shall also address any changes to the aforementioned dose rates that will be incurred from relevant sources as a result of the modtfication.
III.
REVIEW PROCEDURES t
The reviewer should evaluate the ifcensee's radiation protection safety analysis for completeness taking into consideration the modification procedures described in the text.
These include monitoring radioactivity concentrations of all sources; shielding, if any monitoring data in the spent fuel pool area during normal operations as compar;ed with refueling operations (e.g., radiation levels are greater during refueling operation); monitoring releases of krypton and tritium; monitoring corrosion product buildup, if any; and monitoring dose rates associated with minimal shielding for double tiering or pin removal during consolidation if these modification modes are to be used instead of the replacement of low-density racks with high-density racks.
In the case of double tiering or pin removal during consolidation, relevant experience or mathematical models should be cited for any predicted dose rates.
IV.
EVALUATION FINDINGS If low density racks are replaced with high density racks, alternatively
" Double Tiering" or " Pin Consolidation" the evaluation findings are prese,nted in Appendix B and C respectively, if either of these methods are preferred as a modification procedure.
1 V.
IMPLEMENTATION The following is intended to provide guidance to licensees regarding the NRC 4
staff's plans for using this SRP section.
Except in those cases in which the licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, i
the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.
1 1
Implementation schedules for conformance to parts of the method discussed i
i herein are contained in the referenced regulatory guides, and in accordance l
with the following:
1.
This SRP section is not applicable to CP applicants.
2.
This SRP section is not applicable to OL applicants unless materials have been stored in the spent fuel pool that may be the cause of contamination (i.e., new fuel, spent fuel, reactor components or equipment etc.).
l 3.
Operating reactor licensees will be required to comply _ with the provisions of this SRP section during design modifications to their spent fuel pool storage facility.
l 12.6.2-5 Rev. 0 l
VI. -REFERENCES 1.
10 CFR Part 20, " Standards for Protection Against Radiation" 2.
10 CFR Part 50, General Design Criterion 61, " Fuel Storage and Handling and Radioactivity Control" 3.
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reason-ably Achievable" 4.
Regulatory Guide 8.10, Position C.1, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable" 5.
Appendix A, " Calculation of Dose Rate Versus Water Height Above Fuel" 6.
Appendix B, " Safety Evaluation Report - Double, Tiering" 7.
Appendix C, " Safety Evaluation Report - Pin Consolidation" 8.
Memorandum, L. D. White, Jr., Rochester Gas and Electric Co., to A. Schwencer, NRC, dated September 29,1976, " Diver Protection Information -
Spent Fuel Pool Modification" 9.
IE Information Notice No. 82-31, " Overexposure of Diver During Work in Fuel Storage Pool" 12.6.2-6 Rev. O
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e esee PROPOSED APPENDIX A TO SRP SECTION 12.6.2 CALCULATION OF DOSE RATE VERSUS WATER HEIGHT ABOVE FUEL REVIEW prsp0NSIPILITIES Primary - Radiological Assessment Branch (RAB)
- Secondary - None The radiation dose rate over the water surface of the spent fuel pool should be con-sidered to be the sum of the dose rates from three sources.
Usually one of the three sources is much larger than the other two.
The following describes the three sources and gives nominal values for each source.
The first source is from the radioactive contaminants, such as 137Cs and soCo, that may be found in the spent fuel storage pool water either suspended or in solution.
These contaminants cause a dose rate of 1 to 2 arem/hr.
The second source is the spent fuel stored on the bottom of the pool. When the usual 24 feet of water is over the top of the spent fuel, the dose rate at the surface of the water is only 10 8 arem/hr.
When the water depth is
~10 feet, the dose rate is about 30 mrem /hr.
The third contribution is from an -
assembly that is being placed into the spent fuel racks.
For example, if a recently dischosoed fuel assembly is carried within 2 feet of the surface, the dose rate at the surface will be about 5 x 105 mR/hr (Figure A.1).
Loveering the fuel assembly to a. water depth of 10 feet will decrease this dose rate to about 3 mR/hr (Figure A.1).
l 12.6.2-Al Rev. O USNRC STANDARD REVIEW PLAN Star.derd review plans are prepared for the guidance of the Office of Nuclear Reactor Regulation staff responsible for the review of apphcotions to construct and operate nuclear power plante. These documents are made evellable to the pubhc as part of the Commission's policy to inform the nuclear industry and the generet public of regulatory procedures and pohcles. Stenderd review plane are not substitutes for regulatory guides or the Commieelon's regulations and compliance with them is not required. The standard review plan sectione are keyed to the Stenderd Formet and Content of Safety Analyelo Reporte for Nucteer Power Plante.
Not ett sectione of the Standard Format have a corresponding review plan.
Published stenderd review plane will be revloed periodically, se appropriate, to accommodate commente and to reflect new informe-tion and emperience.
Commente end suggestione for lenprovement will be considered and should be sent to the U.S. Nuclear Regulatory Commission.
Office of Nuclear Reactor Regulation, Weehington, D.C. 20066.
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DISTANCE FRO:4 TOP OF ACTIVE FUEL, FT.
o Dose Rate in Water Axially Above Maximum Spent Assembly.
Figure A.1 12.6.2-A2 Rev. O
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e PROPOSED APPENDIX B TO SRP SECTION 12.6.2 SAFETY EVALUATION REPORT - DOUBLE TIERING REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
' Secondary - None Occupational Radiation Exposure The staff has reviewed the licensee's plans for the removal and disposal of the low-density racks and the installation of the high-density racks in a double tier with respect to occupational radiation exposure. The licensee has discussed two plans for carrying out this work. The first plan assumes that divers will not be required to perform underwater work unless disconnecting bolts and fittings of the old racks proves to be infeasible above water outside the pool with the use of specially designed tools.
The occupational radiation exposure for this operation is estimated by the licensee to be about _, man-rem.
If diverc are required to disconnect the old storage racks, an alternative plan will be used. Because of the exposure to the divers and increased exposure to other per-sonne.), the occupational exposure commitment will be increased to about man-rem.
The staff considers these to be reasonable estimates. These estimates represent a small fraction of the total man-rem burden from occupational exposure at the plant.
In any event, the licensee will use the plan that will provide a dose that will be consistent with achieving minimal exposure and, at the same time, will. allow him to get back to power with the least delay. Consequently, the staff concludes that exposures should be as low as is reasonably achievable.
The staff has estimated the increment in onsite occupational dose resulting from the proposed increase in stored fuel assemblies on the basis of information supplied by the licensee for dose rates in the spent fuel area from radionuclide concentrations in the spent fuel pool (SFP) water and the spent fuel assemblies.
The spent fuel 12.6.2-B1 Rev. O USNRC STANDARD REVIEW PLAN Standard review plane are prepared for the guldence of the Office of Nuclear Reactor Regulation staff roeponsible for the review of applications to construct and operate nuclear power plente. These documente are made eveliable to the public as part of the Commise6on's policy to inform the nuclear industry and the general public of requietory procedures and policies. Standard review plans are not substitutes for regulatory guides or the Commission's regulatione end compliance with them le not required. The standard review plan sectione are keyed to the Standard Format and Content of Safety Analyeis Reports for Nuclear rower Plants.
Not all sections of the Standard Format have e corroeponding review plan.
Published standard review plane wLil be revloed periodically, es appropriate. to accommodate commente and to reflect new informe-tion and emperience.
Commente and sugn ovjm w g con geed and should be sent to the u.S. Nuclear Regulatory Commiselon,
assemblies themselves in the double tier will contribute a small fract does rates in the pool area because of the depth of water shielding the fuel.
A Technical Specification will require the licensee to provide a minimum of This layer of water should 15 feet of water above the spent fuel elements.
reduce dose rate levels from the SFP elements to small fractions of that pro-Additionally, it will vided by the radionuclide concentration in the water.
also require him to submit a lechnical Specification specifying the minimum depth of water shielding over a fuel assembly during the transfer of a fuel element into the double-tier rack if the dose rate, 3 feet above the surface of the spent fuel pool, exceeds the ambient radiation lev On the basis of hr.
tional spent fuel in the pool represents a negligible burden.
present and projected operations in the spent fuel pool ar gn The small increase in occupational radiation exposure burden at this facility. radiation e occupational doses to as low as is reasonably achievable and p
of 10 CFR Part 20.
double tier in the SFP will not result in any significant increase in doses i
received by occupational workers.
I 12.6.2-B2 Rev. O
l NU REG-0800 (Formerly NUREG 75/087)
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PROPOSED APPENDIX C TO SRP SECTION 12.6.2 SAFETY EVALUATION REPORT - PIN CONSOLIDATION REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
Secondary - None Occupational Radiation Exposure In the consolidation operation, pins will be extracted from the fuel bundles and installed in consolidated assemblies.
The empty cages will be cut up under water and packaged in a shipping cask for disposal. The total annual collective dose equivalent from the consolidation program will range from to man-rems.
This i
range is based on the compaction of assemblies in work areas Eiere the dose rate varies from to mR/hr. To keep liccupational exposure as low as is reasonably achievable diiring Tu'el handling operations involving compaction, the ifcensee will l
provide, as required, an augmented fuel pool cleanup system with close-capture water filtration units aied a localized air filtration system to augment the normal build-ing ventilation system, and the plant Radiation Control Supervisor will evaluate the need to suspend all operations if the expected dose rates are exceeded.
In summary, the estimated collective dose equivalent for the reracking and consolida-tion programs is as follows: _ man-reas for reracking and disposal of all existing fuel racks, and to man rems for the compaction of assemblies and disposal of the empty fueT cageT The dose for the latter operatTon will be an annual dose.
Although _ man-rees is a best-estimate, upper-bound collective dose equivalent for the compaction operation, it nevertheless remains a small fraction of the col.-
1ective dose equivalent from all normal plant operations, representing about J of the plant's annual average man-rem for occupational exposure based on operati_o_ns l
from through
(
Reference:
NUREG-0713, Vol. 2).
Consequently, the esti-mated annual maximum collective dose equivalent for the aforementioned operation represents a small increase in the plant's occupational radiation exposure and should not affect the licensee's ability to maintain individual occupational doses to ALARA levels and within the limits of 10 CFR Part 20.
12.6.2-C1 Rev. 0 USNRC STANDARD REVIEW PLAN at.nde,d re.iew, no e.. sos,ed.o, the g. enc. e, t,,e owee o, Nucieer neector.ogui. tion eten,.ponei.i. or t,,e re.iew o, ro'"r* 'et'4*,=;'t'"04"'n =':'*c.".",*.r,4eT:'t*"e';J,.""p'=,0;n";r'o=%'e'*d"ou."it"!.") r*'. '."
piene are not oubetitutes for regulatory guides or the Commiselon's regulatio,ne and compliance with them le not required. The standard review plan sectione are keyed to the Standard Format and Content o Safety Analysie eporte for Nuclear Power Plante.
Not all sections of the Stenderd Format have a corresponding review plan.
Published standard review piene will be revised periodically, se oppropriate, to accommodate commente and to reflect new in.orma-tion and emper6ence.
I Commente end suggestione for improvement will be conaldered and should be sent to the u.S. Nuclear negulatory Commission, Ml2nr3 M nee cDk W N fM O
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ee Proposed Nevision Standard Review Plan PSRP-12.6.3, Rev. O This proposed Section to the Standard Review Plan and its supporting Regulatory (value/ impact) Analysis have not received a complete staff review and approval and do not represent an official NRC staff position. The proposed Section to the Standard Review Plan incorporates guidelines /
acceptance criteria used by the statt for review of Licensees radiation protection program provided during spent fuel pool modifications.
Public coments are being solicited on the proposed SRP Section and the associated regulatory analysis (including any implementation schedules) prior to a final review and decision by the Office of Nuclear Reactor Regulation as to whether this proposed revision should be approved.
Coments should be sent to the Secretary of the Comission, U.S. Nuclear Regulatory Comission Washington, D.C.
20555, Attention: Docketing and Service Branch. All coments received by will be considered, and all of the associated documents and coments considered will be made putriicly available prior to a decision by the Director, Office of Nuclear Regulatory Regulation, on whether to imolement this revision. Copies of each of these documents are available upon written request to the Division of Technical Information and Document Control, U.S. Nuclear Regulatory Comission, Washington, D.C.
20555.
l USNRC STANDARD REVIEW PLAN Standard review piens are propered for the guldence of the Office of Nuclear Reactor Regulation staff toeponsible for the review of applications to construct and operate nuclear power plants. These documente are made evelfable to the public as part of the Commission's policy to inform the nuclear 6ndustry and the general public of reguletory procedures and policies. Standard review plans are not substitutes for regulatory guides or the Commiss6on's regulations and compliance with them le not required The I
l etenderd review plan sectione are keyed to the Stenderd Format end Content of Sefety Analysis Reporte for Nuclear Power Plants.
Not all sections of the Standard Format have e corresponding review plan.
Published standard review plans will be revised periodically, se oppropriate, to accommodate comments and to reflect new informe-tion and esperience.
Comments and suggestione for improvement will be considered and should be sent to the U.S. Nucleet Regulatory Commission.
Office of Nuclear Reactor Regulation Washington, D.C. 20566 l
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NUREG-0800 (Formerly NUREG 75/067) e
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'e.
U.S. NUCLEAR REGULATORY COMMISSION
!%, %#i. STANDARD REVIEW PLAN e.. e
.o OFRCE OF NUCLEAR REACTOR REGULATION PROPOSED REVISION O TO SECTION 12.6.3 AREA RADIATION AND AIRBORNE RADI0 ACTIVITY MONITORING REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
~ Secondary - None I.
AREAS OF REVIEW The area radiation and airborne radioactivity monitoring systems in the spent fuel pool (SFP) area shall be described as they relate to normal operations, refueling, anticipated operational occurrences, and accidents.
Reference to relevant informa-tion in the FSAR is acceptable.
This information, however, is seldom. included in SARs.
1.
Area Monitorina Systems The location of units in the SFP area, background radiation levels, and alarm ut T.Mnts for each system should be described.
2.
. Airborne Radioactivity Monitoring Continuous airborne radioactivity monitoring in the SFP area should be described.
Accident considerations should be included.
Estimated inhalation exposure to personnel should be provided.
If air samplers are to be used to' collect grab samples, the licensee should describe his procedure for col-l 1ecting and evaluating exposure data.
II. ACCEPTANCE CRITERIA RAB acceptance criteria are based on meeting the following regulations, American National Standards Institute (ANSI) standards, or regulatory guides:
l USNRC STANDARD REVIEW Pl.AN Stenderd review piene are prepared for the guldence of the Office of Nuclear Reactor Regulation staff responsible for the review of applications to construct and operate nucieer power plante. These documente are made eve 6lable to the public es part of the Commisolon'a policy to inform the nuclear industry and the general publ6c of regulatory procedures and policies. Stenderd review piene are not substitutes for regulatory guides or the Comm6eelon*e regulations and compliance with them le not required. The standard review plan sectione are keyed to the Stenderd Formet and Content of Safety Analysie Reporte for Nuclear Power Plante.
I Not all sections of the Stenderd Format have e corroopending review plan.
Published standard review plane will be revloed periodically es oppropriate, to accommodate commente end to reflect new informa-tion and esperience.
Office of Nuclear Meector Regulation. Weehington. D.C. 20586.Commente and suggest6one for lenprovement w
1.
10 CFR Part 20, Section 20.103, " Exposure of Individuals to Concentratio.:
of Radioactive Materials in Air in Restricted Areas," as it relates to-determining compliance with the requirements of suitable measurements of concentrations of radioactive materials for detecting and evaluating air-borne radioactivity in restricted areas.
2.
10 CFR Part 50, General Design Criterion 63, " Monitoring Fuel.and Wast 2 Storage," as it relates to conditions that may result in excessive.adia-tion levels.
The following regulatory guides and standards provide information, recommendations, and guidance for implementing the requirements of.10 CFR 20.103 and GDC 63.
1.
Regulatory Guide 8.8, " Info mation Relevant to Ensuring that Occupational Radiation Exposures at Nuc1*nr Power Stations Will Be As Low As Is Reason-ably Achievable," position section as it relates to verification that air-borne contaminants and gaseous radiation sources in the SFP area are con-trolled to limit average concentrations below the values listed in Appen-dix B, Table 1, Column 1, of 10 CFR Part 20. Measurements are made to ensure that the ventilation system, among other engineering controls, is designed to provide protection against airborne radioactive material, snd that exposures will be as low as is reasonably achievable (ALARA).
2.
Regulatory Guide 8.15 " Acceptable Programs for Respiratory Protection,"
position section as it relates to providing guidance for elements of an acceptable respiratory protection program that will meet the requirements of 10 CFR Part 20.103.
3.
ANSI /ANS-HPSSC-6.8.1-1981, " Location and Design Criteria for Area Radiation Monitoring Systems for Light Water Nuclear Reactors," as it relates to ensuring ALARA exposure to personnel.
The detectors should be located as close to the SFP as possible so that they can promptly detect inadvertent changes in radiation levels from operational occurrences or accidents in
- ~normally occupied areas.
4.
ANSI N13.1-1969, " Guide to Sampling Radioactive Material," as it relates to measuring general airborne radioactivity levels in working spaces for evaluation of control of individeal inhalation exposure.
Airborne monitoring for accidents requires instrument ranges that include the maximum calculable accident lesel, and the monitoring system should operate properly in the environment caused by the accident.
III.
REVIEW PROCEDURES The SFP safety analysis will be reviewed as necessary to evaluate dose rates in the SFP area, location of area and airborne radioactivity monitoring equip-ment, air sampling procedures, and other surveys as may be required by 10 CFR Part 20.201.
(See Section 12.6.2.II.2.)
12.6.3-2 Rev. O
On the basis of the review, RA8 may request additional information or may request the licensee to reevaluate his radiation protection program during SFP operations to meet the acceptance criteria of this SRP section.
IV.
EVALUATION FINDINGS The conclusions reached on completion of the review of this section-.are presented in the " Evaluation Findings" subsection of SRP Section 12.6.
V.
IMPLEMENTATION The following is intended to provide guidance to licensees regarding the NRC 8
staff's plans for using this SRP section.
Except in those cases in which the licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the method described herein will be used by the staff in its evaluation of
.conformance with Commission regulations.
Implementation schedules for conformance to parts of the method discussed herein are contained in the referenced regulatory guides, and in accordance with the following:
1.
This SRP section is not applicable to CP applicants.
2.
This SRP section is not applicable to 0L applicants unless materials have been stored in the spent fuel pool that may be the cause of contamination (i.e., new fuel, spent fuel, reactor components or equipment etc.).
3.
Operating reactor licensees will be required to comply with the provisions of this SRP section during design modifications to their spent fuel pool storage facility.
VI.
REFERENCES 1.
10 CFR Part 20, " Standards for Protection Against Radiation" 2.
10 CFR Part 50, General Design Criterion 63, " Monitoring Fuel and Waste Storage" 3.
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reason-ably Achievable" 4.
Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection" 5.
ANSI /ANS-HPSSC 6.8.1-1981, " Location and Design Criteria for Area Radiation Monitoring Systems for Light Water Nuclear Reactors" 6.
ANSI N13.1-1969, " Guide to Sampling Radioactive Material" 12.6.3-3 Rev. O
NU REG-0800 (Fgrm'_rly NUREG 75/o87)
/
U.S. NUCLEAR REGULATORY COMMISSION (M(o#
i STANDARD REVIEW PLAN
%.,,e.v OFFICE OF NUCLEAR REACTOR REGULATION
..e Proposed Revision Standard Review Plan PSRP-12.6.4, Rev. O this proposed Section to the Standard Review Plan and its supporting Regulatory (value/ impact) Analysis have not received a complete staff review and approval and do not represent an official NRC staff position. The proposed Section to the Standard Review Plan incorporates guidelines /
acceptance criteria used by the,taff for review of Licensees radiation protection program p.avided during spent fuel pool modifications.
Public coments are being solicited on the proposed SRP Section and the associated regulatory analysis (including any implementation schedules) prior to a final review and decision by the Office of Nuclear Reactor Regulation as to wnether this proposed revision should be approved.
Comments should be sent to the Secretary of the Comission, U.S. Nuclear Regulatory Comission, Washington, D.C.
20555, Attention: Docketing and Sefwh.e Branch. All coments received by will be considered, and_all of the associated documents and coments considered will be made publicly available prior to a decision by the Director, Office of Nuclear Regulatory Regulation, on whether to implement this revision.
Copies of each of these documents are available upon written request to the Division of Technical Information and Document Control, U.S. Nuclear Regulatory Comission, Washington, D.C.
20555.
USNRC STANDARD REVIEW PL.AN Standard review plane are propered for the guidance of the Office of Nuclear Reactor Regstation staff roeponelble for the review of applications to construct and operate nucteet power plants. These documents are made eveilable to the pubke es part of the Commiselon's policy to inform the nuclose industry and the general pubhc of regulatory procedures and policies. Standard rev6ew piene are not substitutee for requietory guides et the Commiselon's regulatione and comphance with them is not requ6 red The atendard review plan sectione are keyed to the Stenderd Format and Content of Safety Analye6a Reporte for Nuclear Power Plante.
Not all sectione of the Stenderd Format have e corresponding review plan.
Published e d review plane will be revi.ed periodicelly, es appropriate, to accommodate commente and to reflect new informe.
Commente end oungestions for improvement will be considered and should be sent to the U.S. Nucteer Regulatory Commission.
Office of Nuclear Meector Regulation, Weehington, D C. 20066
NUREC-0800 (Fcrmerly NURE2 75/087) se en.
i
+
U.S. NUCLEAR REGULATORY COMMISSION i%si STANDARD REVIEW PLAN 1,e u/
OFRCE OF NUCLEAR REACTOR REGULATION 0
seoe PROPOSED REVISION O TO SECTION 12.6.4 AS LOW AS IS REASONABLY ACHIEVABLE ACTIONS TO BE TAKEN REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
. Secondary - None I.
AREAS OF REVIEW The licensee should describe those actions to be taken during spent fuel pool (SFP) modification to reduce occupational exposure to levels that are as low as is reason-ably achievable (ALARA).
1.
Decontamination Procedures A description should be given of procedures, if any, that will be used for vacuuming pool walls to remove crud deposits that might increase radiation levels in the SFP area, vacuuming pool floors if divers are to be used for the modification, and decontamination of all areas around the pool to reduce the general background radiation. Additionally, a description should be given of
~~ fuel, that might affect background radiation levelsany materials that may b The rationale for per-mitting such materials to remain there during the modification should be addressed if this is contemplated, and the licensee should have a controls program to ensure against inadvertent movement or retrieval of radioactive materials.
Recycling the water through the radwaste system to reduce water radionuclide concentrations should also be described. Details of decontamination of the spent fuel racks as they are removed from the pool for disposal or for onsite storage should be given, including dose rates before and after decontamination of the racks.
l USNRC STANDARD REVIEW PLAN Stenderd review plane are prepared for the guldence of the office of Nucleer Reector Regulation staff toeponelble for the rev6ew of o
on's poli to to m t a leer ladue t
pu i une ory p oc e end p 6c. t n ord revie v piens are not avbetitutes for regulatory guides or the Commiselon's regulatione and compleence with them le not required. The etendard review plan sectione are hered to the Standerd Formet end Content of Sofety Anesyees Reporte for Nuclear Power Plante.
Not all sectione of the Stenderd Formet have a corresponding review plan.
Publ6ehod standerd review piene wlet be revloed periodicelly, es appropriate. to accomenodete comments and to reflect new inf orme.
seen end emperience.
Comments and ausgootione for improvement will be considered and should be sent to the U.S. Nuclear Regulatory Commluton.
Office of Nucleer lleector Regulation, Weehington, D.C. aN06.
l' 2.
Surveillance and Monitorinc Health Physics personnel should provide radiation protection surveillance and monitoring during all phases of the modification to ensure that the l
operation will be performed with ALARA occupational exposures.
3.
Trainina 1
A structured and comprehensive training program should be available and j
given to all workers who will be engaged in work in the SFP area during the modification.
Those workers who will be monitoring the operation, as described in Ito 2 above, but who are not qualified as Health Physics or Radiation Protectit9/ Chemistry technicians, shall have equivalent training 1
I to perform this function. The training should include, but not be limited to, radiation protection procedures radiation survey instruments, respira-l tory protection, high radiation area, control, and contamination control.
II. ACCEPTANCE CRITERIA i
RA8 acceptance criteria are based on meeting the following regulations and j
the positions of regulatory guides which are used to implement the requirements j
of the regulations:
I 1.
10 CFR Part 20, Section 20.1, " Purpose," as it relates to licensees who.
i should make every reasonable effort to maintain radiation exposure as low
(
as is reasonably achievable taking into account the state of technology 1
and the economics of improvement.
~
2.
Regulatory Guide 1.8, " Personnel Selection and Training," position section as it relates to qualification of Health Physics personnel and
~
j their training.
i
- 3.
- Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational j
Radiation Exposures at Nuclear Power Stations Will Se As' Low As Is Reason-ably Achievable," position section as it relates to planning, designing, i
constructing, and operating the spent fuel pool before and after the modification.
l 4.
Regulatory Guide 8.10. " Operating Philosophy for Maintaining Occupational l
Radiation Exposures As Low As Is Reasonably Achievable," Position C1 as j
it relates to the general operating philosophy necessary to plan, construct, l
and operate the SFP to ensure that occupational exposure will be maintained l
I i
In addition to those items previously described, acceptance of the spent fuel j.
pool ALARA actions will also be based on the following determinations:
l 1.
Portable radiation survey instruments shall be used to survey all phases j
of the SFP operation, from transfer of fuel elements from old low-density racks to new high-density racks through removal and disposal of the old racks.
j; i
2.
Anticontamination clothing shall be worn to protect workers from contami-nation.
l 12.6.4-2 Rev. 0 l
-- a
3.
If divers are used, appropriate surveys shall be made to assess that their exposures are ALARA. The geometry of the stored fuel should be arranged so that dose rates to the divers in their work areas are minimized.
4 (See References 8 and 9 of SRP Section 12.6.2.)
4.
The SFP cleanup system shall be in operation at all times.
i i
5.
Efforts should be made to decontaminate the surfaces of the Sih walls if crud has accumulated that could cause an increase in background levels.
If divers are used, the floor of the SFP should be vacuumed if this will reduce their exposure to any significant degree.
6.
Personnel shall be thoroughly trained to perform their specific duties during the modification operations.
This includes any contractor Health Physics personnel, if they are used, who shall also be qualified in accordance with Regulatory Guide 1.8.
III.
REVIEW PROCEDURES The reviewer will determine whether the ALARA program of the licensee is con-sistent with the acceptance criteria of all the radiation protection criteria established in this SRP.
On the basis of this review, RA8 may request any additional information or may request the licensee to reevaluate his program for the purpose of modifying those areas that do not meet the recommendations of Regulatory Guide 8.8.
IV.
EVALUATION FINDINGS The conclusions reached on completion of the review of this section are presented in the " Evaluation Findings" subsection of SRP Section 12.6.
V.
IMDLE"ENT?.TIOM The following is intended to provide guidance to licensees regarding the NRC staff's plans for using this SRP section.
Except in those cases in which the licensee proposes an acceptable alternative
{
method for complying with specified portions of the Commission's regulations, l
the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.
i Implementation schedules for conformance to parts of the method discussed herein are contained in the referenced regulatory guides, and in accordance with the following:
i 1
1.
This SRP section is not applicable to CP applicants.
1 2.
This SRP section is not applicable to OL applicants unless materials have been stored in the spent fuel pool that may be the cause of contamination (i.e., new fuel, spent fuel, reactor components or equipment, etc.).
3.
Operating reactor licensees will be required to comply with the provisions of this SRP section during design modifications to their spent fuel pool storage facility.
12.6.4-3 Rev. O i
VI.
REFERENCES 1.
10 CFR Part 20. " Standards for Protection Against Radiation" 2.
Regulatory Guide 1.8, " Personnel Selection and Training" 3.
Regulatory Guide 8.8, "Information Relevant to Ensuring that eccupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reason-ably Achievable" 4.
Regulatory Guide 8.10 " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievabit" l
t 12.6.4-4 Rev. O
. [*
UNITED STATES
' f%gM ;j, NUCLEAR REGULATORY COMMISSION y.,
WASHINGTON D. C. 20555
%M P!EPORANDUll FOR:
Thomas R. Combs, Chief Correspondence and Records Branch Office of the Secretary of the Cemnission FRCf':
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
PROPOSED REVISION O TO NEW SRP SECTION 12.6
, AMD 12.6.I THRCUGH 12.6.4 0F NUREG-0800 Enclosed for publication in the notice section of the Federal Register
~ is a notice of issuance and availability of the "For Coment" editions of
,, Proposed Revision 0 to SRP Section 12.6, " Occupational Exposure Associated with Expansion of the Spent Fuel Pool - Introduction"; Section 12.6.1,
" Radiation Sources"; Section 12.6.2, " Radiation Dose Rates"; Section 12.6.3,
" Area Radiation and Airborne Radioactivity Monitoring"; and Section 12.6.4, "As Low As Is Reasonably Achievable Actions To Be Taken" of NUREG-0800,
" Ster.dcrd !!cvicw Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," and its supporting Regulatory Analysis (value/ impact statement). These documents are being issued for public coment.
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
Federal Register Notice e
9
7590-01 U.S. NUCLEAR REGULATORY COMMISSION NUPEG-0800 "STANDAPD REVIEW PLAN FOR THE PEVIEW OF SAFETY ANALYSIS REPORTS FOR NUCLEAR POWER PLANTS" a
FOTICE OF ISSUANCE AND AVAILABILITY "FOR COMMENT"
. PROPOSED PEVISION O TO SRP SECTION 12.6 AND 12.6.1 THP0 UGH 12.6.4 AND THE REGULATORY ANAYLSIS i
~
The U.S. Nuclear Regulatory Commission (NRC) has published proposed i
Revision 0 to Section 12.6, " Occupational Exposure Associated with Expansion of the Spent Fuel Pool - Introduction"; Section 12.6.1, " Radiation Sources";
Section 12.6.2, "Radiction Dose Rates"; Section 12.6.3, " Area Radiation and Airborne Radioactivity Monitoring"; and Section 12.6.4, "As low As Is Reasonably Achievable Actions To Be Taken" of the Standard Review Plan.
The proposed new SRP Sections consist of Section 12.6, Rev. 0; Section 12.6.1, Rev. 0; Section 12.6.2, Rev. O. Section 12.6.3, Rev. 0; Section 12.6.4, Rev 0; and the supporting Regulatory (value/ impact) Analysis. The guidelines / acceptance criteria incorporated into these SRP Sections are used l
to prepare Safety Evaluation Report (SER) for spent fuel pool (SFP) modifications requested by licensees. The staff evaluates acceptability of rad.iation protection programs provided by licensees during the process of f
converting SFP facility designs from low-density storage racks (currently being used) to new high-density racks.
l l
1 r
M r
7590-01 Comments are being solicited from interested organizations, groups and individuals.
The staff will evaluate the comments received, and address them, as apprcpriate, in the final documents.
Copies of the "For Comment" documents will be available after 1985.
Copies will be sent directly to utilities, utility industry Other groups a,nd associations and environmental and public interest groups.
copies will be available for review at the NRC Public Document Room, 1717 H
- " Street, N.W., Washington, D.C., and the Commission's Local Public Document Rooms located in the vicinity of nuclear power plants. Addresses of these
,-Local Public Document Rooms can be obtained from the Chief, Local Public Document Room Branch, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, telephone (301)492-7536.
Comments should be sent to the Secretary of the Commission, U.S.
Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Docketing and Service Branch, by Dated at Bethesda, Maryland, this day of
, 1985.
FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation 4
4, 9
6 2
.