ML17164A828
| ML17164A828 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/15/1998 |
| From: | Nerses V NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| TAC-MA3620, TAC-MA3621, NUDOCS 9810190236 | |
| Download: ML17164A828 (9) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205550001 October 15, 1998 Mr. Robert G. Byram Senior Vice President-Generation and Chief Nuclear Officer Pennsylvania Power and Ught Company 2 North Ninth Street Allentown, PA 18101
SUBJECT:
REQUEST FOR INTERPRETATION ON 10 CFR 26.27(b)(4), FOLLOW-UP TESTS, SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND2 (TAC NOS. MA3620 AND MA3621)
Dear Mr. Byram:
Your letter dated August 12, 1998 requested the NRC Staffs views on whether a proposed schedule of follow-up testing meets the requirements of 10 CFR 26.27(b)(4).
You posited a follow-up testing schedule whereby the three years of testing are divided into 15 discrete intervals, consisting of four (4) intervals of 30/31 days, followed by eleven (11) intervals of 90 days, and with testing to be conducted "at leasf once during each of these intervals" (emphasis added).
You also stated that "the time between tests is not a factor in the follow-up test schedule (i.e., the time between tests could exceed 31 days for testing performed once a month and could exceed 92 for testing once every three months)." However, you then provide a sample test schedule in the form of a table which shows 15 intervals, with testing conducted only once per interval. You conclude by stating that it is your interpretation that "performance of follow-up testing is only required to be done once perinterval and that the time between tests is not part of the [10 CFR 26.27(b)(4)] requirement" (emphasis added).
The sample test schedule that you posited would not meet the requirements of 10 CFR 26.27(b)(4), and your statement that follow-up testing is required only "once per interval" is an incorrect interpretation of the requirements of that section.
Section 26.27(b)(4) states, in relevant part:
Any person granted unescorted access or whose access is reinstated under these provisions must be given unannounced follow-up tests at least once eveg month for four months and af least once eve~ fhree months for the next two years and eight months...to verify continued abstinence from proscribed substances.
(emphasis added)
The NRC staff considers these words to require that for each day in a testing interval there is an equal probability of being selected for a test, subject to the proviso that at least one test must be conducted within any given testing interval. Based upon this, a testing program that is ~desi ned to test only once per 30/31 day interval for the first four intervals would not comply with Section 26.27(b)(4).
Furthermore, your test schedule would undercut the purpose of the rule by increasing the predictability of the follow-up testing, since once an individual is tested in a given test interval, that individual could know that there would be no further test until at least the beginning of the next test interval. For analogous reasons, testing only once per three months in the eleven remaining test intervals would also not comply with Section 26.27(b)(4). A 9810190236 981015 PDR ADQCK 05000387 P
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R. Byram properly-constituted testing schedule could result in back to back tests being given at the start of the first 30/31-day test interval, and back to back tests being given at the end of the next 30-day interval, which results in over 30/31 days between the tests.
It is only in this sense that your supposition is correct that the time between tests is not part of the 10 CFR 26.27(b)(4) requirement.
Should you have any questions, please contact me.
Sincerely, Docket Nos. 50-387 and 50-388 cc: See next page original signed by:
Victor Nerses, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of. Nuclear Reactor Regulation Docket File PUBLIC PDI-2 Reading JZwolinski RCa ra MO'Brien VNerses OGC ACRS CAnderson, RGN I DRosano
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0 properly-constituted testing schedule could result in back to back tests being given at the start of the first 30/31-day test interval, and back to back tests being given at the end of the next 30-day interval, which results in over 30/31 days between the tests.
It is only in this sense that your supposition is correct that the time between tests is not part of the 10 CFR 26.27(b)(4) requirement.
Should you have any questions, please contact me.
Sincerely, Docket Nos. 50-387 and 50-388 cc: See next page Victor Nerses, Senior Project Manager Project Directorate l-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
R. Byram I properly-constituted testing schedule could result in back to back tests being given at the start of the first 30/31-day test interval, and back to back tests being given at the end of the next 30-day interval, which results in over 30/31 days between the tests.
It is only in this sense that your supposition is correct that the time between tests is not part of the 10 CFR 26.27(b)(4) requirement.
Should you have any questions, please contact me.
Sincerely, Docket Nos. 50-387 and 50-388 cc: See next page original signed by:
Victor Nerses, Senior Project Manager Project Directorate l-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation DIS BU 0 Docket File PUBLIC PDI-2 Reading JZwolinski RCa ra MO'Brien VNerses OGC ACRS CAnderson, RGN I DRosano
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Mr. Robert G. Byram Pennsylvania Power 8 Light Company Susquehanna Steam Electric Station, Units1 &2 Jay Silberg, Esq.
Shaw, Pittman, Potts 8 Trowbridge 2300 N Street N.W.
Washington, D.C. 20037 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 General Manager Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Licensing Group Supervisor Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania I8101 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1, Box 1797 Berwick, Pennsylvania 18603 Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O. Box 35 Berwick, Pennsylvania 18603-0035 Director-Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. O. Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc..
212 Locust Street P.O. Box 1266 Harrisburg, Pennsylvania 17108-1266 George T. Jones Vice President-Nuclear Operations Pennsylvania Power and Light Company 2 North Ninth'Street Allentown, Pennsylvania 18101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603
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