ML20150C202
| ML20150C202 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/10/1988 |
| From: | Charemagne Grimes NRC OFFICE OF SPECIAL PROJECTS |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8803180063 | |
| Download: ML20150C202 (7) | |
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March 10, 1988 Docket Nos. 50-445 and 50-446 Mr. William G. Counsil Executive Vice President Texas Utilities Electric Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201
Dear Mr. Counsil:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING RADIATION PROTECTION ORGANIZATION We have reviewed FSAR Amendments 59, 60, 62, and 64 relative to the radiation protection organization for Comanche Peak Steam Electric Station, Units 1 and 2.
In order to complete our evaluation, we have determined that additional information is needed.
Please provide the information identified in the enclosure no later than 14 days from the date of this letter.
Should you have any questions regarding this request, please contact either of our Project Managers, Melinda Malloy at (301)492-0738 or Annette Vietti-Cook at (301)492-0737.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not under P. L.96-511.
Sincerely, (original signed by)
Christopher I. Grimes, Director Comanche Peak Project Division Office of Special Projects
Enclosure:
Request for DISTRIBUTION ~'
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March 10, 1988 Docket Nos. 50-445 and 50-446 Mr. William G. Counsil Executive Vice President Texas Utilities Electric Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201
Dear Mr. Counsil:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING RADIATION PROTECTION ORGANIZATION We have reviewed FSAR Amendments 59, 60, 62, and 64 relative to the radiation protection organization for Comanche Peak Steam Electric Station, Units 1 and 2.
In order to complete our evaluation, we have determined that additional information is needed.
Please provide the information identified in the enclosure no later than 14 days from the date of this letter.
Should you have any questions regarding this request, please contact either of our Project Managers, Melinda Malloy at (301)492-0738 or Annette Vietti-Cook at (301)492-0737.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.
Sincerely, CTCw Christopher I. Grimes, Director Comanche Peak Project Division Office of Special Projects
Enclosure:
Request for
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Additional Information cc:
See next page i
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W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Electric Company Units 1 and 2 CC:
Jack R. Newman, Esq.
Asst. Director for Inspec. Programs Newman & Holtzinger, P.C.
Comanche Peak Project Division Suite 1000 U.S. Nuclear Regulatory Comission 1615 L Street, N.W.
P. 0. Box 1029 Washington, D.C. 20036 Granbury, Texas 76048 Robert A. Wooldridge, Esq.
Regional Administrator, Region IV Worsham, Forsythe, Sampels &
V.S. Nuclear Regulatory Comission Wooldridge 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 Lanny A. Sinkin Mr. Homer C. Schmidt Christic Institute Director of Nuclear Services 1324 North Capitol Street Texas Utilities Electric Company Washington, D.C.
20002 Skyway Tower 400 North Olive Street, L.B. 81 Ms. Billie Pirner Garde, Esq.
Dallas, Texas 75201 Government Accountability Project Midwest Office Mr. Robert E. Ballard, Jr.
104 East Wisconsin Avenue Director of Projects Appleten, Wisconsin 54911 Gibbs and Hill, Inc.
11 Penn Plaza hew York, New York 10001 David R. Pigott, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street Mr. R. S. Howard San Francisco, California 94111 Westinghouse Electric Corporation P. O. Box 355 Anthony Z. Roisman, Esq.
Pittsburgh, Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Renea Hicks, Esq.
Washington, D.C. 20005 Assistant Attorney General Environmental Protection Division Robert Jablon P. O. Box 12548, Capitol Station Bonnie S. Blair Austin, Texas 78711 Spiegel & McDiarmid i
1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 Citizens Association for Sound Energy 1426 South Polk George A. Parker, Chairman Dallas, Texas 75224 Public Utility Comittee Senior Citizens Alliance Of Ms. Nancy H. Williams Tarrant County, Inc.
CYGNA Energy Services 6048 Wonder Drive 2121 N. California Blvd., Suite 390 Fort Worth, Texas 76133
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Walnut Creek, CA 94596
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S W. G. Counsil Comanche Peak Electric Station Texas Utilities Electric Company Units 1 and 2 cc:
Joseph F. Fulbright Fulbright & Jaworski 1301 McKinney Street Houston, Texas 77010 Roger D. Walker Manager, Nuclear Licensing Texas utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Jack Redding c/o Bethesda Licensing Texas Utilities Electric Company 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette, Esq.
i Counsel for Tex-La Electric Cooperative of Texas i
Heron, Burchette, Ruckert & Rothwell i
Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C.
20007 GDS ASSOCIATES, INC.
Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 37830
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' ENCLOSURE Request for Additional Information l
l Comanche Peak FSAR Amendments 59, 60, 62, and 64 Radiation Protection Organization 1.
Section 13.1.3.1 (Amendment 62) of the FSAR, states "If the appointed Radiation Protection Manager (RPM) does not meet the Regulatory Guide 1.8 criteria, then a Radiation Protection Advisor (RPA) shall be desig-nated who does satisfy the Regulatory Guide 1.6 criteria." Based on information provided in the FSAR (through Amendment 64), a comparison is made below between the Comanche Peak Steam Electric Station (CPSES)
RPM candidate's qualifications and the Regulatory Guide 1.8, Rev 1-R criteria:
Regulatory Guide 1.8 Criteria CPSES RPM Candidate _
- Bachelor's degree in
- Bachelor's degree in science or engineering, science (Biology).
including some formal No apparent formal training in radiation training (college-level) protection.
in radiation protection.
- A Master's degree may
- Master's degree in be considered equivalent Chemical Oceanography.
to one year of professional No coursework in experience where coursework radiation protection related to radiation apparently taken, protection is involved.
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- At least five years' pro-
- At most, candidate fessional experience in has only approximately two radiation protection, three years (since 1986) of of which should be in a professional radiation nuclear facility dealing with protection experience, radiological problems similar All of this experience was to those encountered in gained in an environment nuclear power stations, lacking actual radiation preferably in an actual protection problems due to nuclear power station.
the plant being in the construction phase.
Based on the above, it appears to the staff that the individual named as RPM for the CPSES (p. 13.1-84 of the FSAR, Amendment 62) does not meet the RPM criteria in Regulatory Guide 1.8, Rev 1-R.
Please state how the RPM candidate will obtain the necessary fomal training and professional radi-ation protection experience in order to eventually meet the Regulatory Guide 1.8, Rev 1-R criteria.
2.
FSAR Amendment 62 states (as quoted in Question No. 1 above) that an RPA who meets Regulatory Guide 1.8 criteria would be designated in the event that the RPM did not meet the criteria.
In view of the staff's conclusion that the RPM candidate does not meet the Regulatory Guide 1.8 qualification criteria (see Question No.1), the alternative course of action needs to be pursued.
4 TV Electric has proposed the RPA concept as this alternative.
Under this concept, the RPA would report directly to the RPM, closely ad-vising and guiding the RPM on all radiation protection matters. The RPA would have direct access to the Manager, Plant Operations and the Corporate Health Physics Supervisor.
Additionally, the RPA would be assigned as an advisor to the Station Operating Review Comittee.
The staff finds that TU Electric's proposed arrangement involving a not-yet-qualified RPM supported by an RPM-qualified RPA would be ex-tremely difficult and awkward, if not impossible, to work.
An arrange-ment of this nature might be feasible in situations where the RPM can-didate is nearly qualified, e.g., having 3 to 4 of the necessary 5 years of professional radiation protection experience and some formal radiation protection training.
However, this does not appear to be the case at CPSES.
Please provide a resume of qualifications for a "Regulatory Guide 1.8-qualified" RPM who can fill the position of RPM until such time as the candidate proposed in the FSAR is determined to be qualified.