ML20137F537

NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration

ML20137F537
Person / Time
Site:	Turkey Point, 05520726
Issue date:	03/17/1997
From:	Tetrick R AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20137F486	List: ML20137F481 ML20137F508 ML20137F537
References
SP, NUDOCS 9704010126
Download: ML20137F537 (14)

Text

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9 To t ' Peter B. Block, Presiding Officer ,

Atomic Safety and Licensing Board  ;

U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

NRC Staffs' motion for reconsideration in the matter of  :

J Ralph L. Tetrick.

I, Ralph L. Tetrick, respectfully request that the presiding officer deny the NRC Staffs' request for reconsideration.

The staff contends that I failed the written exam but in accordance with the rules of the Code of Federal Regulations, I have worked with the NRC system and received a grade of 80% which is a passing grade.

The staff references NUREG-1021 and SECY-86-206 as a basis for denial of a license, I contend that as NUREG-1021 revision 8 has not been implemented,_it does not apply and therefore the presiding officers decision to round up is valid and should stand and I should be issued a SRO license.

If the Presiding Officer does reconsider his decision then I request that he also reconsider his decision on question #63.

The staff states that "immediate" action is required under the stated conditions of question #63, because personnel would quickly be exposed to high levels of radiation due to the loss of water. The Staff also contends that two annunciators sounding

'together (ie. H-1/1 SFP LOW LEVEL and G-9/5 CNTMT SUMP HI-LEVEL) is enough corroboration to act immediately to prevent injury to the health of plant employees without regard to actual conditions.

3-ONOP-33.2 states: With an irradiated assembly full up in the manipulation crane and maximum refueling cavity seal leakage, the refueling bridge radiation levels will reach 10 rem /hr in about 22 minutes (see attached procedure).

At Turkey Point there are two Spent Fuel Pool level indications and five sump level indications in the control room. I contend that the 10 to 20 seconds it takes to verify the alarm would not expose personnel inside containment to high levels of radiation, also, this brief period of time to verify the alarms is preferable to causing panic and possible harm to personnel .

evacuating containment if the alarm is invalid. I l

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9704010126 970317 PDR ADOCK 05000250 0 .PDR

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.' With regard to the above, I respectfully request the Presiding i Officer tos reverse his decision on question #63, I am also including a letter written by Brian J. Stamp, Acting Operations

!~ Supervisor at Turkey Point Nuclear Facility regarding question

1. 63.

'P.algfh L. Tetrick Docket No. 55-20726-SP 18990 E.W. 270 St.

Homestead, F1 33031 (305) 247-6364 2

To: Peter B. Block, Presiding Officer Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

NRC Staffs' motion for reconsideration in the matter of Ralph L. Tetrick.

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It is expected that the Licensed Operators at Turkey Point verify plant conditions when one or more annunciators are received in the control room prior to taking corrective actions.

In the case of Question #63, I fully expect the Operators to verify the decrease in the Spent Fuel Pool level and the increase in the Containment Sump level by the indicators located within the surveillance area of the control room. This action would only take seconds and could preclude erroneously sounding the containment evacuation alarm. During refueling outages, there are numerous jobs going on simultaneously inside the containment.

Requiring all personnel to evacuate the area unnecessarily could pose a larger safety hazard than would the increased radiation

< levels at the refueling stations for those few seconds. In addition, the Training Departments question bank has been revised concerning the correct answer to Question #63. l I. nL J B'rianid. Stamp Acting Operations Supervisor Turkey Point Operations Department 4

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Title:

Refueling Cavity Seal Failure Safety Related Procedure Responsible Department: Operations Reviewed by PNSC: 93-149 Approved by Plant GeneralManager: 6/24/93 4/20196 Periodic Review Due:

R TS$ 87-0377P, 88-2210, 89- 1021, 90-2205, 91- 1565P, 91 -0561 T R TSs 92 125 I P, 92- 1032P, 92- 1358P, 93-0930P PCIM 89-332,92-031

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i Refueling Cavity S521 Failure *'I/N'/I3 4

3 ONOP-033.2 3

LIST OF EFFECTIVE PAGES i -

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4 Revision 4

Page Date 1

1 06/24/93 2 06/24/93 4

3 10/21/92 l.

4 06/24/93 I 5 10/21/92 6 10/21/92 i

7 10/21/92 8 10/21/92 i 4

• 9 10/21/92 l 10 10/21/92 f

11 10/21/92

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• Proc 3durs No.: Proc 3 dure Titis; 3 Approvai Date:

Refueling Cavity Sant Failure 10/21/92 3-ONOP-033.2

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I TABLE OF CONTENTS 4

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Section 4

l 1.0 PURPOSE ........................................

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- 2.0 SYMPTOMS .......................................

i~ .............................. 5 3.0 AUTOMATIC ACTIONS

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4.0 IMMEDIATE ACTIONS

) 5 5.0 SU BSEQ U E NT ACTIO NS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6.0 REFERENCES

/ RECORDS REQUIRED / 11

COMMITMENT DOCUMENTS . . . . . . . . . . . . . . . . . . . ......

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3 ONOP 033.2 Refueling Cavity Sul Failurs *'$YU63 l i

1.0 PURPOSE 1

1.1 This procedure provides instructions for protecting plant personnel and  :

assuring that public health and safety is not jeopardized in the event of a l l

Reactor to Refueling Cavity seal failure. [ Commitment - Step 6.3.1]

1.2' Irradiated fuel shall not be placed in the RCC change out baskets until an engineering evaluation is completed. Therefore, this procedure does not address an irradiated fuel bundle in the RCC change out baskets.

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1 i 2.0 SYMPTOMS  !

l Annunciators 4

2.1 2.1.1 Annunciator H-1/1, SFP LO LEVEL, alarmed 2.1.2 Annunciator G-9/5, CNTMT SUMP HI LEVEL, alarmed 2.1.3 Annunciator I-4/6, CNTMT SUMP HI LEVEL, alarmed 2.1.4 Annunciator X-4/1, ARMS HI RADIATION, alarmed

1. Channel R-2, Unit 3 Containment - operating floor level, El,58 ft

2. Channel R-7, Unit 3 Spent Fuel Building - transfer canal area, El 58 ft

3. Channel R-19, Spent Fuel Pit Exhaust Duct

4. Channel R-21, Unit 3 Spent Fuel Pit - north wall 2.1.5 Annunciator, H-1/4, PRMS HI RADIATION, alarmed 2.1.6 Annunciator H-1/5, CHRMS HI RADIATION, alarmed l 2.1.7 Annunciator I-7/3, RX VESSEL DRAINDOWN LO-LO LEVEL  !

2.2 Indications 2.2.1 Increase in local dose rate monitors.

2.2.2 Decreasing refueling cavity and spent fuel pit levels as observed i locally.

2.2.3 Increase in Containment Sump Water Level Monitors, LI-3-6308A

- and B .

2.2.4 Increase in Containment Water Level Monitors, LI-3-6309A and B i

2.2.5 Containment Radiation Monitor R-3-12 increasing or alarmed.

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• Protscure No : Proctdure

Title:

Approval Date.

Refueling Cavity Sect Failure 10/21/92 3 ONOP.033.2 3.0 AUTOMATIC ACTIONS 3.1 Possible containment ventilation isolation due to high containment radiation levels. l l

3.2. Possible Control Room ventilation isolation due to high containment radiation levels.

4.0 IMMEDIATE ACTIONS 4.1 Sound containment evacuation alarm.

5.0 SUBSEQUENT ACTIONS C AUTIONS

• With an irradiated assembly full up on the manipulator crane and maximum j

refueling cavity sealleakage, the refueling bridge radiation levels will reach 10 i Remlbrin about22 minutes.

e As reactor internals are exposed, airborne contamination levels in containment willincrease. l

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5.1 Refueling Operator (s) in Containment 5.1.1 WHEN informed by H.P. that any of the following occurs, THEN exit the containment building immediately:

1. Area radiation levels exceed 10 Rem /hr OR

2. Airborne contamination levels exceed 1000 times pre-event level OR l

3. Cumulative dose exceeds 10 Rem whole body or 50 Rem to the thyroid.

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NOTE

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Steps 5.1.2 and 5.1.3 should be performed at the same time. l 3

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5.1.2 jf an irradiated fuel assembly is in the fuel transfer car, THEN lay assembly down AND transfer assembly to the Spent Fuel Pool.

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Approvst D2te; Refusling Cavity Ssel Failura 10/21/92 3 ONOP 033.2 5.1.3 IP an irradiated fuel assembly is latched on the manipulator crane, TTf EN perform the following:  ;

1. Fully insert assembly in the core AND leave assembly latched.  :

2. I.F assembly can NOT be inserted into the core, THEN move assembly to the upender AND transfer assembly to the spent fuel building.

5.1.4 WHEN allirradiated fuel assemblies are in the core OR in the spent fuel building, THEN perform the following:  ;

1. Move the fuel transfer car to the spent fuel building.

2. Direct refueling operator in the spent fuel building to close SFP Transfer Tube Gate Valve,3-12-0d1.

5.1.5 IF the upper or lower internal assemblies are being removed from or installed into the reactor vessel TH E N either;

1. Install the upper or lower internal assembly into the reactor vessel if it is located on the reactor vessel guide studs.

OR

2. Place the upper or lower internal assembly in a safe condition.

5.1.6 Inflate the inflatable cavity seal by;

1. Open the instrument air supply valve to the inflatable cavity seal and pressurize the seal to 30 to 35 PSIG.

2. Exit the containment building 5.2 Refueling Operator (s)in Spent Fuel Building 5.2.1 WHEN informed by H.P. that any of the following occurs, THEN exit the spent fuelbuildmg immediately:

1. Area radiation levels exceed 10 Rem /hr OR

2. Airborne contamination levels exceed 1000 times pre-event level

- OR .

3. Cumulative dose exceeds 10 Rem whole body or 50 Rem to the ,

thyroid. l 4

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Procsdur3 Title; Pd9e. l Procidure No : 7 Approval Date; Refueling Cavity Seel Failuro 10/21/92 i 3-ONO P-033.2 )

f 5.2.2 IF_ an irradiated fuel assembly is latched to the spend fuel pit bridge crane, TH E N insert assembly in a fuel rack.

C AUTION

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If more than one irradiated fuel assembly must be removed from containment, at least one of the assemblies shall be transferred to a fuel rack within the first 22 minutes of the event.

5.2.3 IF more than one irradiated fuel assembly must be removed from io~ntainment, THEN move one assembly from the transfer car to a fuel i

rack.

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One irradiated fuel assembly may be left in the transfer car provided that the upender I

I remains in the fulldown position.

1._._._._._._._._._._._._._._._._._._._._._._._.J 5.2.4 WHEN all irradiated fuel assemblies are in the core or in the spent fuel building, THEN perform the following:

1. Verify the fuel transfer car is in the spent fuel building.

2. Verify the fuel transfer car is in the down position.

3. Close SFP Transfer Tube Gate Valve,3-12-031.

5.3 Control Room Operator 5.3.1 Direct Health Physics to perform the following:

1 1 1. Limit access to containment 4 2. Limit access to spent fuelbuilding .

3. hionitor radiation levels in containment and spent fuel building

4. Afonitor containment for airborne contamination

5. hionitor cumulative whole body AND thyroid doses for operators in containment AND spent fuel building.

5.3.2 Isolate containment as follows:

I - 1. hianually initiate containmentisolation phase A.

2. Verify containment isolation phase A valve white lights on VPB are all bright.

3. Verify Unit 3 containment purge exhaust and supply fans are off.

4. Verify Unit 4 containment purge exhaust and supply fans are off.

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Refueling Cavity Seal Fcilura 10/21/92 3 ONOP 033.2 5.3.2 (Cont'd)

5. Verify all Containment Purge Supply AND Exhaust Isolation Valves are closed  !

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a. POV-3-2600 (outside containment)

b. POV-3-2601 (ineide containment)

c. POV-3-2602 (oatside containment)

d. POV-3-2603 (inside containment)

6. IF any ContainmentPurge Supp,y 1 AND ExhaustIsolation Talve is N OT closed, TH EN behincTVPB, pull fuse for any open purge valve.

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a. XEP for POV-3-2600

b. XLAG for POV-3-2601

c. XEQ for POV-3-2602

d. XLAH for POV-3-2603

7. Verify Containment Instrument Air Bleed Isolation Valves are closed.

a. CV-3-2819

b. CV-3-2826

8. Verify all normal containment coolers are tripped A ND associated outlet dampers are closed.

9. Verify containment sump pumps are tripped.

Verify control building ventilation is in emerg'ency recirculation

10. Building Heating mode using ONOP-10308.1, Control Ventilation and Air Conditioning System (HVAC) l 5.3.3 Close allinner AND outer containment access hatches.

5.3.4 Stop SFP cooling pumps.

5.3.5 Shutdown all non-esse'ntial electrical equipment in the containment

- lowerlevels.

5.3.6 IF any emergency containment filter fans are available, THEN_ start at least one emergency containment filter fan.

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Refueling Cavity Scel Felluro 10/21/92

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' 5.3.7 Maintain RHR system operation:

1. Verify RHR pump motor amps stable AND less than 38 amps l

. . 2. Verify RHR flow on FI-3-605 between 3000 and 3750 gpm

3. Verify annunciator H 6/2, RHR HX HI/LO FLOW, clear

' . 5.3.8 Restore s)ent fuel pit level to normal using 3-OP-033, SPENT FUEL i PIT COO 1ING SYSTEM. l Maintain spent fuel pit boron concentration greater than 1950 ppm as j 5.3.9 l

i follows:

1. Direct Health Physics to monitor exposure for personnel entering the spent fuel pit building.

2. Direct Chemistry Department to sample spent fuel pit for boron concentration.

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3. Borate spent fuel pit as necessary to maintain spent fuel pit boron l concentration greater than 1950 ppm.

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5.3.10 Direct Nuclear Plant Supervisor to perform the following:

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1. Check for applicability to conditions listed in EPIP-20101,.

l DUTIES OF EMERGENCY COORDINATOR. .

Check for applicability to conditions listed in AP-0103.12, l 2.

NOTIFIC ATION OF SIGNIFIC ANT EVENTS TO NRC. 4 t

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3. Check for ap")licability to conditions listed in AP-0103.6,

' EVALUATIOb AND REPORTING OFIN-HOUSE EVENTS.

4. Verify applicable Technical Specification Limiting Conditions for Operation are satisfied. .

5.3.11 WHEN spent fuel pitlevel has been restored to between 56 ft 10 inches and 57 ft 2 inches, TH EN perform the following:

1. Stop makeup to spent fuel pit

2. Startup the Spent Fuel Pit Cooling System w.

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Refueling Cavity Sssl Failura 10/21/92 l 3 ONOP-033.2 l

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. I I When refueling cavity level and RCS level are at the top of the reactor vessel flange,

. I I Drain Down Level LIS-3-6421 and 6423, shouldindicate approximately 60 percent.

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5.3.12 WHEN refueling cavity level drops to the top of the reactor vessel flange, THEN perform the following:

Verify containment sump level stops increasing. I 1.

2. IF RCS level continues to decrease below the top of the reactor Essel flange, THEN add makeup to the RCS using charging pumps as necessary to maintain RCS water level at the reactor vessel flange.

5.3.13 WHEN plant conditions are stable AND radiation levels peE THEN initiate repairs to the refueling cavity seal. i 5.3.14 Go to appropriate plant procedure as determined by Nuclear Plant Supervisor.

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Approval Datt; 3 ONOP 033.2 Refusling Cavity Seal Failurs 10/21/92 s

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6.0 REFERENCES

/ RECORDS REQUIRED / COMMITMENT DOCUMENTS 6.1 References

- - 6.1.1 Technical Specifications, Section 3/4.9 Refuel Operations 6.1.2 FSAR

1. Section 9.5, Fuel Handling System

2. Section 11.2, Radiation Protections

3. Appendix 14E, Spent Fuel Storage Facility Modifications Safety Analysis Report  !

6.1.3 Civil Drawing,5610-C-562, Rev 3 6.1.4 General Arrangement, 21774-1, General Arrangement of Fuel Transfer System 6.1.5 Operating Procedures

1. ONOP-10308.1, Control Building Heating Ventilation and Air Conditioning System (HVAC)

2. 3-OP-033, Spent Fuel Pit Cooling 6.1.6 IE Bulletin 84-03, Refueling Cavity Water Seal.

6.1.7 FPL Letter JPE-PTP0-84-1546, Re: REA TPN 84-64 (Response to IE bulletin, 84-03, Refueling Cavity Water Seal).

6.1.8 NRC Exit Meeting Minutes Dated 4/19/85

Subject:

Refueling Activities. IE Bulletin 84-03.

6.1.9 INPO SOER 85-1 (4 and 5), Reactor Cavity Seal Failure 6.1.10 FPL Letter JPN-PTN-90-2609, Re: RE A TPN-90-272 6.2 Records Reauired 6.2.1 None 6.3 Commitment Documents 6.3.1 NRC Inspection Report 89-053, March 14,1990 l

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