ML20137R411
| ML20137R411 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point, 05520726  |
| Issue date: | 04/01/1997 |
| From: | Tetrick R AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF COMMISSION APPELLATE ADJUDICATION (OCAA) |
| Shared Package | |
| ML20137R416 | List: |
| References | |
| CON-#297-18245 SP, NUDOCS 9704140112 | |
| Download: ML20137R411 (1) | |
Text
D m/. Fay 5 e:
97 APR -I PH 6:56 00CKETED
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Office of Commission Appellate USNRC Adjudication
'U.S. Nuclear Regulatory Commission' VI APR -7 #0:30
' Washington - DC 20555 0FFICE OF SECRETARY 00CKETING & SERVICE BRANCH l
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Enclosed you will find my response to the NRC's request for stay and motion for reconsideration in'the matter of Ralph L. Tatrick, Docket #55-20726-SP.
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l Ralph' L. Tetrick 18990 SW 270 Street Homestead, FL 33031 l
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1 9704140112 970401 Op'()
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1 g g'1 PMik k.B.' Block,1 Presiding Officer i
Atomic Safety and. Licensing Board U.S. Nuclear.. Regulatory Commission _
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. Washington,.DC 20555 i
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- Please' find the enclosed responses to'the NRC Staff's Motion for
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Reconsid:rati.on~and. request for issuance of stay.
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'" Ralph L. Tetrick
'03/17/97 r
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PpgM61ock, Presiding Officer 4
g] hPR Atonne Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
NRC Staffs
- motion for Issuance of Stay I, Ralph L Tetrick, respectfully request that the presiding officer deny the NRC Staffs' request for an Issuance of Stay in the matter of the issuance of my Senior Reactor Operator License.
The Staff references 10CFR 2.788(e) and four criteria for issuing a stay. My response to the four are as follows:
1.
Likelihood of Success on the Merits The Staff ci.es NUREG-1021 which specifies a minimum score of 80.
The Presiding Officer rounded up my score to an 80, therefore becoming a i
passing score. Also, NUREG-1021 Revision 8 has not become effective at this time.
2.
Irrenarable Injury in the Absence of a Stay The Staff contends that unless a stay is issued, the continued practice of requiring an 80% to pass will be disrupted. In response, I contend that the future issuance of NUREG-1021 Revision 8 v.i!! clarify any concern the Staff has. As mentioned previously, Revision 8 of NUREG 1021 is not applicable at this time, i
3.
Harm to Other Parties The Staff contends that I, Ralpn Tetrick, will not be harmed by the stay.
My contention is that the possibility and timing of a promotion will be greatly affected. At this time a Nuclear Watch Engineer position will soon become available and a stay will not permit me to qualify for this position, thereby affecting my future earning potential and advancement possibilities with Florida Power and Light.
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Where the Public Interest Lies The Staff contends that the NRCs ability to administer operator license exams will
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j My contention is that the Staffs ability to administer exams will not change. Since t
l in the future the issuance of NUREG 1021, Revision 8 will clarify any areas of confusion.
i Based on the above statements, I respectfully request the Presiding Officer NOT issue a stay, 1
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l Ralph L Tetrick t
Docket No. 55 20726-SP 18990 S.W. 270 St.
i Homestead, F133031 i
(305) 247-6364
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t To:
Peter B.
Block, Presiding Officer
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-Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington,_DC 20555 Subjects NRC Staffs' motion for reconsideration in the matter of Ralph L. Tetrick.
I, Ralph L. Tetrick, respectfully request that the presiding officer deny the NRC Staffs' request for reconsideration, j
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.
- 'he staf f ref erences NUREG-1021 and SECY-86-206 as a basis for l
denial of a license, I contend that as NUREG-1021 revision 8 has not been implemented, it does not apply and therefore the s
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-T EVEL) 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 i
22 minutes (see attached procedure).
At Turkey Point there are two Spent Fuel Pool level indications and five sump level indications in the control Laom.
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'alarn is invalid.
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With regard to the above, I respectfully request the Presiding officer to 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
- 63.
' Ralph L. Tetrick Docket No. 5f-20726-SP 18990 S.W.
270 St.
Homestead, F1 33031 (305) 247-6364 i
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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.
It is expected that the Licensed Op2rators 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 C".estion lf63.
haahED Brian)3. Stamp Acting Operations Supervisor Turkey Point Operations Department 1
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Title:
Refueling Cavity Seal Failure Safety Related Procedure Responsible Department:
Operations93-149 Reviewed by PNSC:
6124/93 Approved by Plant General Manager:
4/20/96 Periodic Review Due:
RTSs 87-0377P,88 2210,89-1021,90-2205,91-1565P,91-0561T R TSs92-125 IP, 92-1032P, 92 1358P, 93-0930P PCIM 89-332,92-051
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Proteco 3 No.:
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- '$/d533 3.ONOP-033.2 Rsfueling Cavity Sac 1 Failuro LIST OF EFFECTIVE PAGES
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Revision
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Date P_ age 06/24/93 1
06/24/93 2
i 10/21/92 3
06/24/93 4
10/21/92 5
10/21/92 6
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10/21/92 8
10/21/92 9
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Procecee Tite; ADDFOval D ate; 10/21/92 Refueling Cavity Seal Fcilurs 3.ONO P.033.2
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TABLE OF CONTENTS J
Page
_ Section.
e 3.
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1.0 PURPOSE 4
2.0' SYM PTOMS 5
3.0 AJTOMATIC ACTIONS 5
4.0
,1,11 MEDIATE ACTIONS 5-5.0 S U B S E Q U E NT A CTI O N S.....
6.0 REFERENCES
/ RECORDS REQUIRED /
11 C6 Mitt 5fENT DOCUMENTS 4
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- ' 472/IE3 3 ONOP 033.2 Refueling Cavity Seal Failure 1.0 PL'RPOSE This procedure provides instructions for protecting plant personnel and 1.1 assuring that public health and safety is not jeopardized fri the event of a Reactor to Refueling Cavity seal failure. [ Commitment - Step 6.3.1]
1.2 Irradiated fuel shall not be placed in the RCC chan ge out baskets until an engineering evaluation is completed. Therefore, this procedure does not address an irradiated fuel bundle in the RCC change out baskets.
2.0.
SXMPTOMS 2.1 Annunciators 2.1.1 Annunciator H-1/1, SFP LO LEVEL, alarmed 2.1.2 Annunciator G-9/5, CNTMT SUMP FU 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 7.ite monitors.
2.2.2 Decreasing refueling cavity and spent fuel pit levels as observed 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 2.2.5 Containment Radiation Monitor R-3-12 increasing or alarmed.
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Proc h re htig; Approvei Datt.
3 ONOP 033.2 Refueling Cavity Sac 1 Failurs 10/21/92 3.0 AUTOMATIC ACTIONS 3.1 Possibin containment ventilation isolation due to high containment radiation levels.
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 refueling cavity seal leakage, the refueling bridge radiation levels will reach 10 i
Remlhrin about 22 minutes.
As reactor ir'emals are exposed, airborne contamination levels in containment e
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will oncrease.
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5.1 Refueline Operator (s)in Containment 5.1.1 WHEN informed by H.P. that any of the following occurs, THEN exit the containment building inmiediately:
1.
Area radiation levels exceed 10 Rem /hr OR 2.
Airborne contamilation levels exceed 1000 times pre-event level OR l
3.
Cumulative dose exceeds 10 Rem whole body or 50 Rem to the thyroid.
NOTE I
1 steps S.I.2 and 5.1.3 should be performed at the same time.
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...-...a IF an irradiated fuel assembly is in the fuel transfer car. THEN lay 5.1.2 assembly down AND transfer assembly to the Spent Fuel Pool.
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3 ONOP 033.2 Refueling Cavity Seal Failure 10/21/92 5.1.34 IF an irradiated fuel assembly is latched on the manipulator crane, TTiEN perform the following:
'1.
Fully insert assembly in the core AND leave assembly latched.
2.
IF assembly can NOT be inserted into the core, THEN move l
assembly to the upender AND transfer assembly to the spent fuel
- building.
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j 5.1.4 WHEN allirradiated fuel assemblies are in the core OR in the I
spent fuel building, THEN perform the following:
1.
Move the fuel transfer car to the spent fuel building.
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Direct refueling operator in the spent fuel building to close SFP l
Transfer Tube Gate Valve,312-031, i
5.1.5 IF the upper or lower internal assemblies are being removed from or Installed into the reactor vessel THEN either; i
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Install the upper or lower internal assembly into the reactor vessel ifit is located on the reactor vessel guide studs.
4 OR 2.
Place the upper or lower internal assembly in a safe condition.
5.1.6 Inflate'the inflatable cavity seal by; Open the instrument air supply valve to the inflatable cavity 1.
seal and pressuri:e the seal to 30 to 35 PSIC.
1 2.
Exit the containment building 5.2 Refueline Operator (s)in Spent Fuel Building
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WHEN informed by H.P. that any of the following occurs, THEN exit 5.2.1 the spent fuel building immediately:
1.
Area radiation levels exceed 10 Rem /hr i
OR 2.
Airborne contamination levels exceed 1000 times pre-event level
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OR 3.
Cumulative dose exceeds 10 Rem whole body or 50 Rem to the
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Uge ADptovas Date, 3 ONOP 033.2 Refueling Cavity Seal Feilure 10/21/92 o
5.2.2 IF an irradiated fuel assembly is latched to the spend fuel pit bridge crane, TH EN insert assembly in a fuel rack.
C AUTION
. 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 c ntainment, THEN move one assembly from the transfer car to a fuel T
rack j
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One irradiated fuel assembly may be left in the transfer car provided that the upender l
I remains in the fulldown position.
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5.2.4 WHEN all irradiated fuel assemblies are in the core or in the spent fuel building, TH E N perform the following:
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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.
Limit access to containment 2.
Limit access to spent fuel building 3.
Monitor radiation levels in containment and spent fuel building 4.
Monitor containment for airborne contamination 5.
Monitor cumulative whole body AND thyroid doses for operators in containment AND spent fuel building.
5.3.2 Isolate containment as follows:
1.
Manually initiate containmentisolation phase A.
2.
Verify containment isolation phase A valve white lights on VPB are afl bright.
Verify Unit 3 containment purge exhaust and supply fans are off.
3.
Verify Unit 4 containment purge exhaust and supply fans are off.
4.
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Pf 0CeCurg T,te; Approvgi Qata, 10/21/92 3 ONOP 033.2 Refusling Cavity Seal Ftilura 5.3.2 (Cont'd) 5, Veri allContainmentPurge Supply AND Exhaust Isola on Valves are closed POV-3-2600 (outside containment)
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b.
POV 3-2601-(inside containment)
POV-3-2602 (outside containment) i c.
d.
POV-3-2603 (inside containment)
IF any ContainmentPurr;e Supply AND ExhaustIsolation 6.
Talve is NOT closed, TH @ behind'VPB, pull fuse for any open purge valve.
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XEP for POV-3-2600 b.
XLAG for POV-3-2601 i
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XEQ for POV-3-2602 d.
XLAH for POV-3-2603 7.
Verif Containment Instruumnt Air Bleed Isolation Valves are close.
a.
CV-3-2819 1
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CV-3-2826 Verify all normal containment coolers are tripped AND h.
4' 8.
associated outlet dampers are closed.
9.
Verify containment sump pumps are tripped.
Verify control building ventilation is in emerg'ency recirculation 10.
mode using ONOP-10308.1, Control Building Heating Ventilation and Air Conditioning System (HVAC) 5.3.3 Close allinner AND outer containment access hatches.
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5.3.4 Stop SFP cooling pumps.
Shutdown all non-essential electrical equipment in the containment 5.3.5 lower levels.
I_F any emergency containment filter fans are available, THEN start 5.3.6 at least one emergency containment filter fan.
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Approva' Date.
10/21/92 3 ONOP 033.2 Refueling Cavity Seal Failure 5.3.7 Maintain RHR system operation:
1 1.
Verify RHR pump motor amps stable AND less than 38 amps.l j
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 saent fuel pit level to normal using 3-OP-033, SPENT FUEL PIT COOLING SYSTEM.
5.3.9 Maintain spent fuel pit boron concentration greater than 1950 ppm as follows:
1.
Direct Health Physics to monitor exposure for personnel entering i
the spent fuel pit building.
2.
Direct Chemistry Department to sample spent fuel pit for boron conecntration.
l 3.
Borate spent fuel pit as necessary to maintain spent fuel pit boron concentration greater than 1950 ppm.
5.3.10 Direct Nuclear Plant Supervisor to perform the following:
Check for applicability b conditions listed in EPIP-20101,.
1.
DUTIES OF EMEROENCY COORDINATOR.
2.
Check for applicability to conditions listed in AP-0103.12, i
NOTIFIC ATION OF SIGNIFICANT EVENTS TO NRC.
Check for ap"olicability to conditions listed in AP-0103.6, i
3.
EV ALUATIOb AND Rr., PORTING OF IN-HOUSE EVENTS.
Verify applicable 'I echnical Specification Limiting Conditions for 4.
Operation are satisfied.
5.3.11 WHEN s ent fuel itlevel has been restored to between 56 ft 10 inche and 57 ft 2 inches, hHEN perform the following:
1.
Stop makeup to spent fuel pit 2.
Startup the Spent Fuel Pit Cooling System i
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10/21/92 1
3 ONOP 033.2 Refueling Cavity Sant Failure I._._.._._._...._.._..._..._._._._.._.I.
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When refueling cavity level and RCS level are at the top of the reactor vessel flange.
l I Drain Down Level, LIS-3-6421 and 6423, should indica te approxima tely 60 percent.
- t.._._._._._._._._._._._._._._._..._._._._._._.J 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.
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IF RCS level continues to decrease below the top of the reactor 2.
Te'ssel flange, THEN add makeup to the RCS using charging 2
pumps as necessary to maintain RCS water level at the reactor vessel flange.
i 5.3.13 WHEN plant conditions are stable AND radiation levels permit,
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TH E N initiate repairs to the refueling ca'vTty seal.
5.3.14 Go to appropriate plant procedure as determined by Nuclear Plant l
Supervisor.
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3 ONOP 033.2 Refueling Cavity Ssal Failure 10/21/92_
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6.0 REFERENCES
/ RECORDS REQUIRED / COMMITMENT DOCUMENTS j
i 6.1 References
.,6.1.1 Technical Specifications, Section 3/4.9 Refuel Operations i
i 6.1.2 FSAR 1.
Section 9.5, Fuel Handling System 2.
Section 11.2, Radiation Protections i
3.
Appendix 14E, Spent Fuel Storage Facility Modifications Safety Analysis Report 1
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) i 2.
3-OP-033, Spent Fuel Pit Cooling 6.1.6 IE Bulletin 84-03, Refueling Cavity Water Seal.
G.1.7 FPL Letter JPE PTP0-841546, Re: REA TPN 84 64 (Response to IE bulletin,84 03, Retueling Cavity Water Seal).
NRC Exit Meeting Minutes Dated 4/19/85
Subject:
Refueling 6.1.8 Activities. IE Bulletin 84-03.
6.1.9 INPO SOER 851 (1 and 5), Reactor Cavity Seal Failure 6.1.10 FPL Letter JPN-PTN-90-2609, Re: REA 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 END OF TEXT FINAL PAGE 4
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