ML20148G653

Notice.* Forwards Documents Received & Read by Author from Rl Tetrick on 970317 W/O Being Served as Required Under Procedural Rules.W/Certificate of Svc.Served on 970527

ML20148G653
Person / Time
Site:	Turkey Point, 05520726
Issue date:	05/27/1997
From:	Bloch P Atomic Safety and Licensing Board Panel
To:
References
CON-#297-18333 96-721-01-SP, 96-721-1-SP, SP, NUDOCS 9706060075
Download: ML20148G653 (16)

Text

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00CKETED USNRC May 27, 1997 W PAY 27 P3 :33 UNITED STATES OF AMERICA 0FFICE OF E3ETARY NUCLEAR REGULATORY COMMISSION DOCKET!NG 15t'.RV!CF BR AW'H ATOMIC SAFETY AND LICENSING BOARD PANEL Before Administrative Judges:

Peter B. Bloch, Presiding Officer Peter Lam, Special Assistant a SERVED MM q<. $gQ'7 In the matter of Docket No. 55-20726-SP RALPH L. TETRICK Re: Operator License (Denial of Application for Reactor Operator License) ASLBP No. 96-721-01-SP NOTICE The attached documents were sent to me by Ralph L. Tetrick on March 17, 1997 and were read. I did not notice that these ,

documents were not served as required under the procedural rules.

'.lh '

Peter 5. Bloch Presiding Officer l

Rockville, Maryland i

9706060075 970527 PDR ADOCK 05000250 i

DSow

Peter B. Bloch, Presiding Officer Administrative Judge Atomic Safety and Licensing Board 4

Mail Stop: T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 r-t Re: Filing of documents with the Office of the Secretary  ;

in Docket Number 55-20726-SP in the matter of Ralph L. Tetrick.

Dear Sir:

Please find the enclosed documents pertaining to the above.

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i Sincerely, -

9*~ .I l 6pf ) f,d ed J!  ;

Ralph L. Tetrick i

18990 S.W. 270 St.

4 Homestead, FL 33031 i (305) 247-6364 i

Enc.  !

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To: United States of America Nuclear Regulatory Commission

Subject:

NRC Staff & Motion for issuance of stay in the matter of Ralph L Tetrick.

Docket No. SS-20726-SP l

On March 27,1997 Peter B. Block, Presiding Officer ruled in favor of myself, Ralph L Tetrick, and ordered that I be issued an SRO License.

In response the Staff contit.ues to contend that the presiding officer was in crror in his decision.

The Staff cites the legal standards governing issuance of a Stay.

I respectfully submit the following responses:

1. Likelihood of Success on the Merits The Staff references NUREG-1021, Rev.8 which was not in effect at the time and wants to backfit the  !

NUREG to the Presiding Officers decision, thereby enforcing rules after the fact.  ;

2. Irreparable injury in the Absence of A Stay The Staff contends that the decision will disrupt the Staff's policy of requiring an 80% passing grade. I j I

contend that the Staffs implementation of NUREG-1021 Rev. 8 clarifies the standards and the Staff's practice will not be disrupted.

3. Harm to Other Parties The Staff contends that 1, Ralph L Tetrick will not be substantially harmed by a stay.

l The very opposite is true, due to the Staffs continual denial of a license i un unable to apply for a Nuclear Watch Engineers position, this has harmed me monetarily and has limited my career advancement opportunities.

4. Where the Public Interest Lies The Staff contends that the Presiding Officers decision,m_gy introduce confusion as to the grade required for an NRC license.

I contend that Revision 8 of NUREG-1021 clarifies any confusion that would arise and that the Staff's abilities to administer tests will not be disrupted.

For the reasons stated above, I, Ralph L. Tetrick respectfully request that the Commission agree with the Presiding Officer and issue a license.

Sincere j,

,7' 1 Ralph L Tetrick 1

1 e

. To: United States of America Nuclear Regulatory Commission

Subject:

Commission's Review of the Presiding Officers Decision in the maner of Ralph L Tetrick.

Docket No. 55-20726-SP 1, Ralph L Tetrick respectfully request that if the Commission reviews the decision of the Presiding l Officer that they also review the decision on question #63.

I 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 t.OW LEVEL and G-9/5 CNTMT SUMP j Hi LEVEL) is enough corroboration to act immediately to prevent in,ury to the health of plant employees j without regard to actual conditions. j i 3-ONOP-033.2 states: With an irradiated assembly full up in the manipulation crane and maximum j refueling cavity seat leakage, the refueling bridge radiation levels will reach 10 rem /hr in about 22 -

l minutes (see attached procedure).

4 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 J personnel inside containment to high levels of radiation, also, this brief period of time to verify the alar is is preferable to causing panic and possible hard to personnel evacuating containment if the alarm is invalid.

With regard to the above, I respectfully request the presiding Office to reverse his decision on questioe. l

1. 63, I am also including a letter written by Brian J. Stamp, Acting Operations Supervbor at Turkey Point l Nuclear Facility regarding question number 63.

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Title:

Refueling Cavity Seal Failure ,

Safety Related Procedure Responsible Department: Operations  !

Reviewed by PNSC: 93-149 Approved by Plant General Manager: 6/24193  ;

4/20/96 .

Periodic Review Due:  !

R TSs 87-0377P, 88-2210, 39- 1021, 90-2205, 91- 1565P, 91-0561 T l 1

RTSs92-12S 1 P, 92-1032P, 92-1358P, 93-0930P PCIM 89-332,92-031

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- 3-ONOP 033.2 Refusling Cavity Saal Failure ""'$l5Y$3 LIST OF EFFECTIVE PAGES 4

Revision Pace Date -l 1 06/24/93 .

2 06/24/93 10/21/92  ;

3 4 06/24/93 ,

5 10/21/92 6 10/21/92 ,

7 10/21/92 8 10/21/92 9 10/21/92 10 10/21/92 11 10/21/92

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Procecure Titie; Dage[

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1' ADDroval Da te.

3 ONOP 033.2 Refueling Cavity Seal Failure 10/21/92 l

TABLE OF CONTENTS i

Page Section  !

i

• 4 1.0 PURPOSE ........................................

1. 4 2.0 SYMPTOMS .......................................

5 3.0 ' AUTOMATIC ACTIONS ...............................

5 4.0 IMMEDIATE ACTIONS ........................... ...

5.0 SU B S E Q U E NT A CTIO N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6.0 REFERENCES

/ RECORDS REQUIRED / 11 COMMITMENT DOCUMENTS .........................

9

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Procsour svo.. erecteure ritie: 4 3-ONO P-033.2 Refueling Cavity Sect Failuro ^"' MI/I53 i -

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1.0 . PURPOSE i

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

f

- 1.2' Irradiated fuel shall not be placed in the RCC change out baskets until an j engineering evaluation is completed. Therefore, tiis procedure does not .

address an irradiated fuel bundle in the RCC change out baskets.  ;

2 F 2.0 SYMPTOMS l I El Annur.ciators  ;

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2.1.1 Annunciator H-1/1, SFP LO LEVEL, alarmed i

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. 2.1.2 Annunciator G-9/5, CNTMT SUMP HI LEVEL, alarmed

. 2.1.3 Annunciator I-4/6, CNTMT SUMP HI LEVEL, alarmed  !

1 2.1.4 Annunciator X-4/1, ARMS HI RADIATION, alarmed

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

L.

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

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

4. Channel R-21, Unit 3 Spent Fuel Pit - north wall 5~

2.1.5 Annunciator, H-1/4, PRMS HI RADIATION, alarmed i i

2.1.6 Annunciator H-1/5, CHRMS HI RADIATION, alarmed l i 2.1.7 Annunciator I-7/3, RX VESSEL DRAINDOWN LO40 LEVEL .'

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j. 2.2 Indications ,

2 2.2.1 Increase in local dose rate monitors. l h 2.2.2 Decreasing refueling cavity and spent fuel pit levels as observed j locally.

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

] 2.2.3 '

. and B

! Increase in Containment Water Level Monitors, LI-3-6309A and B 2.2.4 2.2.5 Containment Radiation Monitor R-3-12 increasing or alarmed.

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Approval Date.

Refueling Cavity Seal Failure 10/21/92

. 3 ONOP 033.2 3.0 AUTOMATIC ACTIONS 3.1 Possible containment ventilation isolation due to high containment radiation levels.

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

J 4.0 IMMEDIATE ACTIONS 4.1 Sound containment evacuation alarm.

5.0 SUBSEQUENT ACTIONS C AUTION S l t

• With an irradiated assemblj full up on the manipulator crane and maximum refueling cavity sealleakage, the refueling bridge radiation levels will reach 10 Remihrin about 22 minutes.

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

i 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 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.

,._._._._._._._._._._..._._._._._._._._._._._._., NOTE . l l  !

l Steps 5.1.2 and S.1.3 should be performed at the same time. l l

i._._._._._._._._._._._._._._._._._._._._._._._.i 5.1.2 IF 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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ProCCowre NO.: ProCeC6re Title.

Approva Date; Refusling Cavity Ssal Failure 10/21/92 4 . 3 ONOP 033.2 l

i 5.1.3 IP an irradiated fuel assembly is latched on the manipulator crane, TI4EN perform the following:

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

2. I.F assembly can NOT be inserted into the core, THEN move a

assembly to the upender AND transfer assembly to the spent fuel L building.

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

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

j- 2. Direct refueling operator in the spent fuel building to close SFP Transfer Tube Gate Valve,3-12-031.

! 5.1.5 IF the upper or lower internal assemblies are being removed from or l Installed into the reactor vessel THEN either;

1. Install the upper or lower internal assembly into the reactor -

vessel if it is located on the reactor vessel guide studs.

9.5

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 WH EN- informed by H.P. that any of the following occurs, TH EN exit the spent fuel building 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.

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P'ocedu re No ; Procecsr e ht e -age ADDrovai Qate .

. 3 ONOP 033.2 Refueling Cavity Saal Failure 10/21/92 5.2.2 IF en irradiated fuel assembly is latched to the spend fuel pit bridge cFane, 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 wothin the first 22 minutes of the event.

5.2.3 IF more than one irradiated fuel assembly must be removed from

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containment, TH EN move one assembly from the transfer car to a fuel rack. '

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

I I remainsin the fulldown position.

t._._._._._._._._._._._._._._._._._..._._._._._.i 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. Limit access to containment

2. Limit access to spent fuelbuilding .

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 all bright.

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

4. Vsrify Unit 4 contaiament purge exhaust and supply fans are off.

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,y, proceour. uo; eroceaure ritie. g Approval Otte '.

Rsfueling Cavity Seal Failuro 10/21/92

. 3 ONOP-033.2 1

i 5.3.2 (Cont'd)

5. Verify all Containment Purge Supply AND Exhaust 4 Isolation Valves are closed 1

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a. POV-3-2600 (outside containment)

b. POV-3-2601 (inside containment)

c. POV-3-2602 (outside containment) )

d. POV-3-2603 (inside containment) fl

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6. IF any Containment Purge Supp1y AND ExhaustIsolation i

Talve is NOT closed, TH EN behincTVPB, pull fuse for any open purge valve. j

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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 Verify Containment Instrument Air Bleed Isolation Valves are  :

7.  !

closed. 4

a. CV-3-2819

b. CV-3-2826

8. Verify all normal containment coolers are tripped AND l associated outlet dampers are closed. l

9. Verify containment sump pumps are tripped.  !

10. Verify control building ventilation is in emerg'ency recirculation mode using ONOP-10308.1, Control Building Heating  ;

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Ventilation and Air Conditioning System (HVAC) l i 5.3.3 - Close allinner AND outer containment access hatches.

5.3.4 Stop SFP cooling pumps.

Shutdown all non-essential electrical equipment in the containment  :

5.3.5

- lowerlevels. . .

5.3.6 _I,F any emergency containment filter fans are available, THEN start '

at least one emergency containment filter fan.

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. Procecurg No.; Procscwre T.Ue g Approva1 Date 3 ONOP 033.2 Refueling Cavity Ssal Failure 10/21/92 j -

5.3.7 Maintain RHR system operation:

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

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

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

. 5.3.3 Restore s sent fuel pit level to normal using 3-OP 033, SPENT FUEL PIT COO 11NG 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 i

concentration.  !

3. Borate spent fuel pit as necessary to mair.tain spent fuel pit boron 4,

concentration greater than 1950 ppm.

l 5.3.10 Direct Nuclear Plant Supervisor to perform the following:

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

DUTIES OF EhERGENCY COORDINATOR.  ;;

2. Check for applicability to conditions listed in AP-0103.12, 1 l

NOTIFICATION OF SIGNIFICANT EVENTS TO NRC.

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3. Check for ap?licability to conditions listed in AP-0103.6, EVALUATION AND REPORTING OF IN-HOUSE EVENTS.

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

5.3.11 WHEN s ent fuel it level has been restored to between 56 ft 10 inches and 57 ft 2 inches, THEN_ perform the following:

1. Stop makeup to spent fuel pit

2. Startup the Spent Fuel Pit Cooling System I f

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

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USC$o29b0, Pf0Ceowr e Tit.e'. 4,e Apptoval 04te.

3 ONOP 033.2 Refusling Ccvity Seal Failure 10/21/92 1

4 I.._.._._._._.._._.._._.._._._.._.._...l

'~ NOTE -

1 i l .

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

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

=

l.._._._._._....-._..._._._._._.._.._._.J i

i 5.3.12 WHEN refueling cavity level drops to the top of the reactor vessel

flange, THEN perform the following:

1. Verify containment sump level stops increasing,

2. IF RCS level continues to decrease below the top of the reactor Fe'ssel flange, THEN add makeup to the RCS using charging 4 pumps as necessary to maintain RCS water level at the reactor vessel flange.

5.3.13 WHEN plant conditions are stable AND radiation levels permit,  :

TH EN initiate repairs to the refueling cavity seal.

e 5.3.14 Go to appropriate plant procedure as deteanined by Nuclear Plant j Supervisor.

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. 3 ONOP-033.2 Refusling Cavity Seal Failure 10/21/92 f

6.0 REFERENCES

/ RECORDS REQUIRED / COMMITMENT DOCUMENTS 6.1 ' References j - - 6.1.1 Technical Specifications, Section 3/4.9 Refuel Operations

. 6.1.2 FSAR l

}

1. Section 9.5, Fuel Handling System f

2. Section 11.2, Radiation Protections l

! l

3. Appendix 14E, Spent Fuel Storage Facility Modifications Safety I i Analysis Report 4

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

1. ONOP-10308.1, Control Building Heating Ventilation and Air ]

Conditioning System (HVAC) ,

s

2. 3-OP-033, Spent Fuel Pit Cooling l i 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 l

bulletin, 84-03, Refueling Cavity Water Seal).

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6.1.8 NRC Exit Meeting Minutes Dated 4/19/85

Subject:

Refueling i Activities. IE Bulletin 84-03. l l

l 6.1.9 INPO SOER 85-1 (4 and 5), Reactor Cavity Seal Failure 1 I 6.1.10 FPL Letter JPN-PTN-90-2609, Re: REA TPN 90-272 j

6.2 Records Reauire'd i 6.2.1 None v

6.3 Commitment Documents

-i 6.3.1 NRC Inspection Report 89-053, March 14,1990 END OF TEXT FINAL PAGE

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I UNITED STATES OF AMERICA '

3 NUCLEAR REGULATORY COMMISSION j In the Matter.of ,

RALPH L. TETRICK . Docket No.(s) 55-20726-SP. l (Denial of Senior Reactor Operator's

License) i CERTIFICATE OF SERVICE

(

I hereby certify that copies of the foregoing LB NOTICE--SERVICE OF FILINGS }

have been served upon the following persons by U.S. mail, first class, except  :

as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.

Administrative Judge

!' Office of Commission Appellate Peter B. Bloch, Presid'g Ofer

Adjudication _ Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 Washington, DCL 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 i \

Administrative Judge Mitzi A. Young, Esq.

1 Peter S. Lam -

Sherwin E. Turk, Esq.

Special Assistant Office of the General Counsel

- Atomic Safety and Licensing Board Mail Stop 15 B18 Mail Stop - T-3 F23- U.S. Nuclear Regulatory Commission i U.S. Nuclear Regulatory Conmiission Washington, DC 20555-

. Washington, DC 20555 Ralph L. Tetrick 18990 SW 270 Street Homestead, FL 33031 Dated at Rockville, Md. this 27 day of May 1997 _

Office of the Secrdtary ~of tAe Commission

.