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UNB1 ED STATES-
' NUCLEAR REGULATORY COMMISSION wasmNcTcw.o. c. 20sss -
November 7, 1983 r
POTE FOR: Files (LIMITED DISTRIBUTION)
- FROM: Rob'ert A. Purple, Deputy Director Division of Licensing .-
SUBJECT:
TELEPHONECALLFROMDR.HENRYNYERS, SUBCOMMITTEE
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ON ENERGY AND ENVIRONMENT As a followup to our meeting last Friday, Dr. Myers called me today to
-further discuss the information that he had on Diablo Canyon deficiencies.
He prefaced his conversation by stressing that he. intended to give me this information only on the condition that by Friday of this week, I would call him.to tell him what has been done to follow up on the information. He
. expressed reluctance to convey the information to me since he was not. 1
- confident that I would take the matter seriously and make a vigorous effort j~
to get to the bottom of th'ings. He asked me to identify who the single i
- person was -who was in charge of resolving all of the Diablo Canyon l-
' allegations and determining their significance. I told him that since the issues could involve construction deficiences, design control def.iciencies and perhaps even matters for investigation of wroligdoing, the only single ,
4 person in. charge would be the Executive Director for Operations.. He noted ,
that, since most of the items appear to be related to construction defi- "
. ciencies,'he planned to call Jack Martin of Region Y later today. (I subsequently telephoned Mr. Martin's office, who was unavailable, and relayed a summary of the following information to Tom' Bishop of his staff.)
Dr. Myers did not wish to provide copies of the documents to us that we had seen last Friday in his office. He preferred instead to orally identify the areas that he believed the NRC should look into. I believe that he felt that by defining the ' areas in' broad enough terms, the identity of the alleger would be more protected than if he gave us the documents. He warned me that by
. - passing this information on to me that I now shared a personal responsibility for protecting the identify of the alleger and that if, as a result of our investigation of. these issues, the iden'tity of the alleger is made known that.
the: responsibility for that compromise rested with me. He then cutlined the following nine areas of inquiry that he believes the NRC should investigate.
- 1. Reviewallnewconformancereport[concerningthepurchaseofmaterial from non-approved vendors over the last 2 or 3 years. Check all purchase orders against approved vendor lists.
b 8603280058 860123 PDR FOIA DEVINEB4-744 PDR
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. 2. Review all NCR's .vs DCN's and check the disposition thereof. Look'at- .
i PG&E's DCN's vs the Foley and Pullman Companies' DCN's for discrepancies.
3.
Provide a description of deviations over the past 2 years in DCH's and i revisions thereto regarding the control room pressure and ventilation system. j i
j.' 4.
Request all documentation from PG&E, Foley and Pullman regarding the upgrading of materials from non-essential to essential. .
SI? 5. Check documentation to establish Foley and Pullman record on
,,,gp certification of inspectors. Review NCR's against inspector control prior to 1983.
Note those NCR's and their disposition.
- 6. Are there any NCR's on Redhead stud anchors?
7.
Review inspection reports and NCR's by Foley and Pullman on testing 'of concrete and grout and the use of samples.
' Ask PG&E and Foley for all NCR's regarding ' wire traceability. Check work packages to determine if they clearly indicate the source of all wires.
- 9. Ask for documentation establishing wire cable termination and pull test
,o and inspections performed per Appendix B.
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Mr. Myers reiterated that he expected to hear fron me within a few days with respect to the Agency's actions on the.c allegations.
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Robert A.. Purple, eputy Director Division of Licensing 4
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. July 14, 1981 ] ,. ' . ,
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C Mr. Darrell G. Eisenhut, Director E - . --
Divisicn of Li nsing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccruissicn Washi p , D. C. 20555 Re: Docket No. 50-275 Docket No. 50-323 Diablo Canycn thits 1 aM 2
Dear Mr. Eisenhut:
Subject:
Qualification of Ins w don, Examinaticn and 'Ibsting aM Audit Perscnnel Your letter dated May 4, 1981 requested that we furnish ccumit-ments to meet regulatory positicns C.5, 6, 7, 8 and 10 of Regulatory Guide 1.58, Revisicn 1, and Regulatory Guide 1.146, and our planned date for meeting these crrmit:nents.
We will cxrply with Positicns C.5, 6, 7, 8 and 10 of Regulatory ra% 1.58, Revisicn 1 and ANSI N 45.2.6 - 1978 with the follcwing excepticns: Our plant quality control inspectors and perscnnel perfom-ing leak-rate testing, including that required by 10 GR 50, Appendix J, will not have the three levels of qualificaticn. As specified in the NRC interpretaticn of Regulatory Guide 1.58 issued April .7,1977, personnel performing inspecticn, exmunation, and testing functicns associated with normal operaticns of the plant such as surveillance testing, maintenance, and certain technical reviews nor:nally assigned to the plant staff will be qualified to ANSI N 18.1 - 1971. 'Ihese requirenents will be fully inplanented by the date that Unit 1 is issued a full pcuer operating license.
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.f O O Mr. Darrell G. Eisenhut July 14, 1981 He will fully otrply with Regulatorf Guide 1.146 dated August, 1980. %e requirments of this guide will be in place by the &te that thit i receives a full power operating license.
Ne respended previously to these questicns an January 22, 1981*
and M 18, 1981. Se March 18, 1981 response was up!ated per d4 =,=sions with the NFC Staff.
Very truly yours, Philip A. Crane, Jr.
PCHowe/P/C:1s 1
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TO ALL LICENSEES OF OPERATING PLANTS AND HOLDERS OF CONSTRUCTION PERMITS . M . . .
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Gentlemen: P .*1 -
SUBJECT:
QUALIFICATION OF INSPECTION, EXAMINATION, AND TESTING AND AU;)IT PERSONNEL (Generic Letter 81-01)
Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plant ," to 10 CFR Part 50 establishes overall cuality assurance requirements for nuclear power plants. Two Regulatory Guides, discussed below, have been issued which provide guidance on an acceptable way to meet Appendix B requirements. Enclosed for your information and use is a copy of Regulatory Guide 1.58, Revision 1, dated September 1980, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel."
Regulatory Guide 1.58 endorses ANSI N45.2.6 with certain exceptions. The NRC staff has determined that the intent of regulatory positions C.5, 6, 7, 8 and 10, whicn provide additional guidance concerning the qualification of nuclear power plant inspection, examination, and testing personnel, should be impleme' n ted by all operating nuclear plants and those under construction.
Also enclosed for your information and use is a copy of Regulatory Guide 1.146, dated August 1980, "Oualification of Quality Assurance Program Audit Personnel fo.r Nuclear Power Plants." This guide endorses ANSI /ASME N45.2.23-1978 with certain exceptions. The NRC staff has determined that the intent of this guide should be implemented by all operating nuclear plants and those under construct ~ ion.
Therefore, you are requested to furnish the following by 90 days from the date of this letter:
- 1. Comitments to meet regulatory positions C.5, 6, 7, 8, and 10 of Regulatory
' Guide 1.58, Revision 1, and Regulatory Guide 1.146, and your planned date for doing.so; or
- 2. If you elect not to adopt the methods given in' Regulatory Guides 1.58, Revision 1, and 1.146 describe your alternative methods of complying with 10 CFR Part 50, Appendix B regarding qualification of nuclear power plant inspection, examination, and testing personnel, and qualification of audit personnel, and your schedule for implementing the alternative methods.
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In your response please refer to this letter by title and number.
Any questions regarding this matter may be addressed to your project manager. .
incerely, s
Darrell . E nhu .. . irector Division of L ensing Office of Nuclear Reactor Regulation
Enclosures:
.l. Regulatory Guide 1.58, Revision 1, dated September 1980
- 2. Regulatory Guide 1.146, dated August 1980 cc: Service List bec: CPUC Applications 49051'and 50028 (Diablo Canyon Units 1 and 2) bbec: Diablo Distribution bec: CPUC Application No. 41212 (Humboldt Bay Power Plant Unit No. 3) bbec: Humboldt Distribution NOTE: MR. J. B. HOCH - Please prepare reply NOTE: MR. J. D. SHIFFER - Please precare replv 2
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- U. S. NUCLEAR REGULATORY COMMISSION M REGION V Report No. 50-275/83-32 Docket No. 50-275
. License No. DPR-76 Safeguards Group Licensee: Pacific Gas and Electric Company 77 Beale Street .
San Francisco, California 94106 Facility Name: Diablo Canyon Unit 1 Inspection at: San Luis Obispo County, California Inspection conducted: October 3-7, 1983 Inspectors: Nd > _
['cy. 22,/f/3 E. M. Garcia, Radiation Specialist Date Signed 4
Approved by: /. . A
// 3!P3 F. A. Wenslawski, Chief Gate / Signed Radiological Safety Branch Summary:
Inspection on October 3-7, 1983 (Report No. 50-275/83-32)
Areas Inspected: Routine unannounced inspection by a regionally based.
inspector following up on unresolved items and other follow-up items identified in inspection reports 50-275/80-04, 50-275/81-16, 50-275/83-09, i and 50-275/83-22. These items deal with incomplete preoperational tests, implementation of NUREG-0737 Items II.B.3 and II.F.1, and calibration of FSAR i
identified radiation monitors. The inspection also followed up IE l Information Notices, Licensee Event Reports, Allegation Number RV-83-A-0018, j
and licensee preparation for 10 CFR 61 compliance. This inspection involved 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> onsite by one inspector.,
! Results: Of the nine areas inspected no items of noncompliance were l identified.
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The inspector observed the location where the source was found and
. sr interviewed the cognizant licensee staff. The inspector reviewed the licensee's radiological evaluation of these events. The evaluation concluded that a significant health hazard was not likley as a result of misuse of these sources.
No items of noncompliance were identified. (50-275/83-03-LO, closed)
- 9. Follow up on Allegation Number RV-83-A-0018 .
This allegation express-three areas of concern. These are:
- 1. Licensee's Health Physics personnel are not qualified to American
- National Standard Institute (ANSI) requirements.
- 2. The licensee has poor practices as far as keeping exposures as low as reasonably achievable (ALARA).
- 3. Modifications to the Air Ejector Discharge Radio-Gas Monitor (RE-15) and Gas Decay Tank Discharge Radio-Gas Monitor (RE-22) have made these monitors insensitive to Xenon-133 and Krypton-85.
Regarding the first issue the applicable ANSI standard is N18.1-1971, Standard for Selection and Training of Personnel for Nuclear Power Plants. Technical Specification 6.3, Unit Staff Qualifications further requires that the Supervisor of Chemistry and Radiation Protection shall meet or exceed the qualifications of Regulatory Guide 1.8, September Ihr 1975.
The qualifications of the Supervisor of Chemistry and Radiation
- Protection and his alternate were reviewed by NRR in February 1981 and found to meet both the ANSI standard and Regulatory Guide 1.8, September 1975. The individuals involved have had experience at another Nuclear Facility and have been involved in the development of Diablo Canyon since its inception.
The licensee's program for reviewing the unit staff experience and qualifications to meet the ANSI N18.1-1971 standard were reviewed.
Records of selected individuals were examined. The records reviewed indicate that the licensee has a program for determining whether an individual has the required experience. The inspector noted, however, that for Chemistry and Radiation Protection Technicians the licensee considers that two years experience in chemistry, radiation protection, or a combination of both meets the standard for this position. The licensee was informed that although it was not clear that their interpretation of required experience is correct, it is the licensee's responsibility to. insure that technicians in responsible positions are qualified to do the job. Region V will seek from NRR clarification of the ANSI 18.1-1971 experience requirement as it applies to the licensee's Chemistry and Radiation Protection technicians. The inspector will follow up on this issue (50-275/83-32-01, open).
In regards to the second general concern, the individual gave three examples of what he .(she) felt were poor practices in the ALARA program.
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9 The first example is that air from the chemistry laboratory is only
,gr exhausted by means of the fume hoods and that this is inadequate. The inspector toured the' laboratory and noted that there is an additional room exhaust besides the two fume hoods. Also, a 1981 report by_the licensee's. corporate industrial hygienist measured 16 room air changes per hour considering only the air removed by the spee hoods. The minimum recommended room air changes per hour is 10. Further, the licensee has a Design Change Request (DCR) for adding a -fume hood over sink, and thus further increasing the number of air changes.
- The second example of poor ALARA practices given by the individual concerned is _that the licensee intends to permit all floors ir the restricted area to become contaminated. Whether or not floors will be allowed to become contaminated can not be clearly determined until the plant is operational. In. interviews with the Supervisor
, Chemistry and Radiation Protection and the C&RP Engineer responsible for Operation Health Physics the licensee indicated that they intend to keep hallways " clean" and to control the spread of contamination by the use
- of step-off-pads. Statements in Radiation Control Procedures G-4 and G-5 substantiate the licensee's intent.
The third example,of poor ALARA practices given by the individual concerned is that the licensee will not provide respirators to workers when they want one. This situation would arise when the radiation work permit does not require a respirator but the worker insists on having one.
Licensee's radiation control procedure G-9, "Use of Respiratory Equipment for sk, Protection Against Airborne Radioactive Materials" establishes prerequisites for use and selection of respiratory equipment. Prior to using respiratory equipment each individual must have a physical examination,
- be trained and fitted with the type of respiratory equipment to be used.
Selection of type of equipment to be used is made by the Radiation Protection staff. The procedure does not address the question of providing respirators on demand. In interviews with the Supervisor C&RP and with the CR&P Engineer responsible for respiratory protection, they stated that if after explaining to the individual why a respirator was not needed for a particular task if the worker insisted, and was qualified, a respirator would be provided.
The third general area of concern deals with modifications to the Air Ejector Monitor, RE-15, and the Gas Decay Tank Discharge Monitor, RE-22, making these monitors insensitive to Xe-133 and Kr-85.
RE-15 is in a hostile environment, high humidity and temperature. RE-22 monitors what may be relative high concentrations of an undiluted stream.
The licensee procured environmental shields from the manufacturer of these monitors to protect them from the hostile environment, and to decrease the sensitivity, respectively. The manufacturer has provided
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the licensee with analysis of responses for Xe-133 and Kr-85 for these j, monitors. As expected the beta emissions from these radionuclides is completely shielded by the environmental shields. However, the samma emissions (514 Kev for Kr-85 and 80 kev for Xe-133) penetrate the shield and are detected by the monitor. The licensee intents to verify the vendor's response curves when the plant is operational.
No items of noncompliance or deviations were identified.
- 10. Licensee Preparation for 10 CFR 61 Compliance On December 27, 1983 the new Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, becomes effective. NRC is attempting to determine if licensees are aware of, and are making preparation for ;
compliance with 10 CFR 61. Copies of the final rule with a fact sheet and a branch technical position were mailed to licensees on February 11 and May 11, 1983, respectively. Pacific Gas and Electric is aware of the requirements of 10 CIT. 61 and is developing specific procedures to effect compliance. The guidance provided in the documents described above is being used in developing the procedures. A Chemistry and Radiation Protection Engineer with experience in radioactive waste programs has been hired and placed in charge of developing the licensee's program. -
No items of noncompliance or deviations were identified.
- 11. Unresolved Items 1 Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of
. noncompliance or deviations. Paragraphs 4.b, 4.c and 5 discussed previously identify unresolved items. These items have been found to be acceptable. No new unresolved items have been identified and none of the previously identified unresolved items have resulted in noncompliance or deviations.
- 12. Exit Interview 4
The inspector met with individuals denoted in paragraph 1 at the end of the inspection. The scope and findings of the inspection were presented. Specific areas discussed are described in paragraphs 2 through 10. The liceesee was informed that no items of noncompliance were identified.
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ATS No.(s): pR(Lf2-@2 7 .I BS(s):- @ M $bO3 '[Y 3 This document lists (or directly references) each allegation or concern brought to the attention of NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered. .
. If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will al'so be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an. interview).
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ENCLOSURE 2
/ DIABLO CANYON - ALLEGATION & INVESTIGATION
SUMMARY
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ALLEGATION DESCRIPTION AND ASSIGNMENT
- NUMBER CURRENT STATUS N.A. An anonymous person met with NRR personnel and A(A L -II , g , alleged design deficiencies in the Cor ponent
/)b . i Cooling Water system. NRR had lead responsibiliby.
This item was closed out by Suppliment 18 to the Safety Evaluation Report (SER).
N.A. An NSC A'udit of PG&E in 1977 (apparently very critical of Pullman construction work) was introduced by the Governor's representatives on a motion to have construction Quality gqq) - Ass'urance hearings. Region V is assigned responsibility to follow-up. The audit and the I
PG&E response have been examined. Remaining open q h
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>, 3 issues are being examined at the site October 11-14, 1983. The Region V staff does not feel the
)? p [ NSC audit changes the position previously taken by Region V.
N.A. Allegations of welding and quality assurance
/ deficiencies in " super-strut" material,
{L) were initially followed-up by Region V to verify adequate implementation of quality assurance programs and regulatory requirements by the licensee. NRR has responsibility to close remaining design issues with a suppliment to the SER and to inform Region V if any additional requirements are to be placed on "off-the-shelf" material.
I N.A Eight anonymous allegations regarding design
//( L - W. 4 were forw rded by the intervenors' attorney to Nk [$
[/d d' NRR in'NE ~1983. NRR has repeatedly attempted to talk to the alleger, with no success. NRR has the responsibility t'o close this issue out, possibly l with a suppliment to the SER.
83-18 An ex-licensee employee alleged that health J cc physics personnel were not qualified to ANSI requirements, the ALARA program was a paper tiger, and some radiation monitors were not sensitive enough. Region V radiation protection inspection staff has the responsibility to follow-up and close-out (if appropriate) these items.
83-28 A licensee contrator employee alleg'ed there were l and deficiencies in the use of " red-head" anchors for l
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83-33 raceway supports, and that the Foley company was not documenting non-conformance reports issued 7[),[tdF by field inspectors. The Region V examination of b[_these allegations has resulted i n_a_ llc en s e e hb 4, t e clinic al evaluation ofThe hd-head"/ anchors ,
and changes to the Foley procedures to insure all CRs q{1550== are- documented _and dispositioned. .These will are expected to be closed _ou_t in hh gypd C routione Region V inspection reports.
83-34 on September 7, 1983, during the readiness for
- operations meeting, Ms. S. Silver of the Mothers Ci f ggg for Peace raised five issues. These items have gg{been identified j to all parties in the NRC meeting gff/ps- minutes. Follow-up responsibility of these items has not been assigned.
83-38 A representative of Governor's received and forwarded anonymous allegations regarding inadequate electrical circuit pull records to NRR.
tj Lead responsibility has been transfered to Region V. This item is scheduled for resolution by October 19,.1983. It is likely that this schedule-will slip by two to four weeks due to lack of inspection resources.
83-39 Mr. C. Nieburger, a member of the staff of the San Luis Obispo Telegram-Tribune, informed the
]{, Resident Inspoector that he had received allegations that welder qualifications could be purchased. The matter was transfered to the Region V field office of the Office of Investigation on October 13, 1983 to follow-up this item as it related to Diablo Canyon.
83-41 .
An unsigned letter alleging errors in design and fr M documentation of the Diablo Canyon project G W)Af7 (apparently written by project presonnel) was received by the Region V office on October 12, k hbb- 1983. Lead responsibility was transfered to NRR on October 12, 1983 83-42 Subsequent to the readiness for operations meeting on September 7, 1983, Ms. S. Silver of the Mothers
' for Peace, expressed a second-hand allegaticn regarding pitting of the main steam and feedwater piping. This issue has been verified to be true by the Resident Inspector who has been in contact with Ms. Silver and has obtained a committment from the licensee to complete and engineering evaluation of the pitting problem. This item is expected to be closed out in a routine Region V inspection report.
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Task: Allegation or Concern No. 7 ATS No.: NRR-83-02 -
BN No.: 83-03(1/7/83) f> <h I S f
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pteraction of Seismic Category II stru@ctures and~ equipment , f,h ' seismi with ,
Category I structures and equipment.
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Implied Significance to Plant Design, Construction, or Operation /I
( hh If as alleged PG&E did not have a clear understanding of the scope of the targets and comitments to the NRC in the Seismically-Induced Systems Inter- '[ " b action Program (SISIP), then the misunderstanding might be significant to operation of equipment important to safety. At Diablo Canyon " Targets" , ,.j refe\
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to selected set of structures, systems and components that are important to safety and serve to either bring the plant to safe shutdown or maintain
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it in safe shutdown condition. A misunderstanding of the scope of the targetsY ,
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might; affect the capability to safely shutdown the plant following the occurrence of a Hosgri event.
Assessment of Safety Significance At the request of the Advisory Comittee on Reactor Safeguards (ACRS) PG8E agreed to initiate a program to determine if seismically initiated failure of non-seismically qualified equipment and piping would cause inte'raction with safety-related sytems which could prevent the plants from being safely shutdown following the occurrence of a Hosgri, event.
PG4E, by letters dated May 7, July 1. July 15. August 19, and September 16, 1980, submitted drafts of their proposed program to the NRC staff for review and connent. The degree of PG&E's understanding including many details, e.g.,
target selection criteria, application of the target selection criteria, k
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source identification criteria, application of source identification criteria, source-target interaction criteria, application of the source-target inter-action criteria analysis for the resolution of postulated interactions, and the resolution of postulated interactions by plant modifications were contained in their draft program. These drafts were reviewed and coments submitted to PG&E as guidance for their use in improving their program. These reviews were described in Sections 2 through 5 of Supplement No.11 to the ' Safety Evaluation Report (NUREG-0675, supplement 11).
The staff performed an onsite audit of the program activities (reported in Sections 6 and 7 respectively of Supp 11). Although the audit did not include a 1001 review of PG8E's target list,1.t did include sufficient review to provide
(, confidense that the list reflected the actual plant systems, components, structures and layout.
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By letter dated October 13. 1983, PG&E submitted an inf,ormation' report on the,'
, status of their seismic systems interaction study within the containment of Unit 1. Included in the Information Report Wes the preliminary status of their study of Unit 2. PG&E has not yet completed its study of Unit 2 and- the staff has not yet completed its review. However, the staff has not yet identified any misunderstanding of the original scope of the tarpets and commitments to
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the NRC in the PG8E program. In fact, there has been even more detailed understandings attained and more voluntary conunitments made to the NRC.
Therefore, the extent to which we have comunicated with PGAE provides reasonable assurance that PG&E understands the scope of the targets and the I connitments pade by PG&E to the staff. The commitments are documented in AL .
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. Section 8.2, Supplement 11 to NUREG-0675 (SER):
(a) "PG&E will complete their program and any necessary plant modifications for each unit prior to the issuance of any lic.ense authoriz.ing full-power op' eration of that unit." .
(b) Region V, OIE, will verify "the completion of PG&E's program e7d the accetability of any plant modifications'."
(c) "PG&E will ...provid'e for our information copies of their final report of their program" which will include and identification of all interactions postulated, all walkdown data, interaction resolution, and technical report' s. "
f Staff Position ,
t Based upon (a) the degree of understanding between the staff and PG&E which includes many details documents in Supplement 11 NUREG-0675 and reinforced by extensive informal communication, and (b) the ongoing review of preliminary results, the staff has no basis to conclude that PGAE misunderstands the scope of the targets and their commitments t,o the NRC.
Action Required No new action is required in response, to this allegation. The ongoing review will continue to take steps to assure that'no misunderstandings occur which might be significant to the safe operation of Diablo Canyon.
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o Task: Allegation or Concern No. 5 F Uu.F C o uc i ATS No.: NRR 83-02 BN No.: 83-03 (1/7/83)
Characterization A concern was raised that with all redundant essential heat loads imposed on the component cooling water system (CCWS) following a loss of coolant accident (LOCA), the CCWS could not remove sufficient heat to maintain the design maximum CCWS temperature and assure a safe shutdown. This is because only one CCW heat exchanger is normally on line and operator action could not be taken soon enough to align the normally isolated redundant CCW heat exchanger prior to exceeding the allowable CCW temperature.
Action Required No further action required on this allegation - refer to SSER 21 k
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ALLEGATION DATA FORM u.s suctE4a ascutAtoav ccoui+vos in.t,vei.on. on o.
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- 1. Facility (les) Involved:
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RECEIVING OFFICE
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- 2. Functionel Areals) Involved: -
(Check eneroonm tioiteell _ operations onsite health and safety
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Description:
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- 4. Source "of AIIegation: -
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_ licensee employee _ news media NRC employee private citizen
._ , organization tspecifyl other ispecity b //h ah f et 6 m MP y sip ("
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- 5. Date Allegation Received:
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- 6. Name of Individust tries two inities, and tes names -
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Contact:
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- . Fue 5 p Eidd Task: Allegation or Concern No. 20 e r ATS No: .RV-83-A-018 BN No: N/A 1
Characterization:
Licensee's Health Physics personnel are not qualified to American National-Standard Institute (ANSI) requirements.
Implied Significance to Design, Construction or Operation This concern does not have any implied significance to Design or Construction of the facility. It does have implied significance to Plant Operations.
Failure to have adequately qualified Health Physics personnel could adversely affect the licensee's ability to implement a quality radiation protection program.
Assessment of Safety Significance
- i The NRC staff approach to resolving this issue was to examine the applicable Technical Specification and related standards; to review the licensee's implementation of these requirements; and to assess the licensee's compliance in assuring requisite qualifications of Health Fbysics personnel.
The licensee's Technical Specification 6.3.1 requires that each member of the Health Physics staff shall meet or exceed the minimum qualifications of ANSI standard N18.1-1971 except for the Supervisor of Chemistry and Radiation ko-
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', Protection who shall also meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
' The NRC staff has reviewed the qualifications of the Health Physics staff and found them to be adequate and in conformance with requirements. The .
qualifications of the Supervisor of Chemistry and Radiation Protection and
, those of his alternate were reviewed by the Office of Nuclear Reactor Regulation (NRR) in February 1981 and found to meet both the ANSI standard and Regulatory Guide 1.8, September 1975. The individuals involved have had experience at another reactor facility and have been involved in the development of the radiation _ protection program at Diablo Canyon since its inception.
The licensee has a program for reviewing the qualifications of the Health Physics staff to insure that the ANSI N18.1-1971 requirements are met. Region V has reviewed this program and found it to be adequate. However an issue was identified regarding the. experience requirements as it applies to Chemistfy and Radiation Protection technicians. Section 4.5.2 of the ANSI standard states " technicians in responsible positions shall have a minimum of two years l
of working experience in their specialty." Chemistry and Radiation protection could be considered to be two separate specialties. The licensee, however, considers that a combined total of,two years experience meets the intent of~
the ANSI standard. NRC has not specifically developed a position addressing j whether 2 or 4 years of experience are appropriate for the disciplines of chemistry and radiation protection combined as a single specialty. There is precedent for both interpretations.
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'. Stati Position Region V concludes that the licensee's professional Health Physics staff meet
'the requirements.of the Technical Specification. Notwithstanding the ANSI standard, the licensee intends to use only qualified technicians to fill .
responsible positions. The issue of the required number of years of experience for Chemistry and Radiation Protection technicians will be pursued on a generic basis by Region V.
Action Required No further action is required relative to the specific allegation.
Region V submitted a request of guidance on the required experience for Chemistry and Radiation Protection technicians to the Office of Inspection and Enforcement (IE) on December 2, 1983. This issue has generic implications and needs to be reviewed in that light.
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j Problem Statement Allegation N: 20 t ATS No.: RV-83-A-0018 BN: N/A ~
This document lists each allegation or concern brought to the, attention of NRC personnel. The purpose of this statement sheet is to assure that al points raised by the alleger are covered.
If the problem sta temen t is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is E2 or very li ttle original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview).
Problem Statements Alleoation # Verbatum Statement or Reference 20 This concern together with those described in allegations 21, and 22 were presented to Mike Malmros,.former senior resident inspector at Trojan Nuclear Power Plant. The concerns were expressed by a former Pacific Gas and Electric, Co. employee. The identity of this individual is not known to the reviewer.
These concerns appear to have made more as a casual comment and were not intended as a formal allegation. They can be viewed to be similar to statements made by an employee at an " exit interview" (an interview performed when an individual ceases employment with a company).
o These concerns were made to Mike Malmros some time-befo're May 19, 1983. Malmros first conveyed these comments to the reviewer by telephone, and after the urging of the reviewer Malmros submitted the attached Allegation Data Form.
The specific concern was'that the Health Physics staff at Diablo Canyon Nuclear Power Plant was not qualified to do their Job. The individual mention specifically as not qualified are Jerry Boots, Bill O'Hara, Dale Clifton, and Paul Lyon. He (She) stated that Paul Lyon only had experience at Diablo Canyon and therefore was not ANSI qualified.
The other individual only had experience at 1
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Humbolt.and Diablo Canyon. However, he (she)
' felt that Henry Fong and Alex Taylor were very well qualified.
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Task: Allegation or Concern No. 21 b ATS No: RV-83-A-018 BN No: N/A Characterization .
The licensee has poor practices as far as keeping internal exposures to radioactive materials as low as reasonably achievable (ALARA). Specifically, (1) the air in the chemistry laboratory is only exhausted by means of the fume hoods and this is. inadequate; (2) the licensee intends to permit all floors in ~
the-restricted area to become contaminated; (3) the licensee will not provide respiratory protection equipment to workers any time the workers want it.
Implied Sinnificance to Desian, Construction or Operation b
These concerns do not have any implied significance to construction of the facility. The first concern implies that the proper air exchange was not considered when the chemistry laboratory was being designed. All three concerns have implications for proper operation of the facility. Poor practices in the respiratory. protection program could lead to unneccessary internal exposure to radioactive materials.
Assessment of Safety Sianificance
- The NRC staff's approach to resolving this issue was to review the licensee's p procedures; to examine the chemistry laboratory; and to interview the cognizant licensee staf(.
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i NRC's review of this matter found no basis to indicate the existence of unacceptable ALARA conditions or practices. (1) The fume hoods are not the-only means of air exchange for the chemistry laboratory. Also, considering only the effect of the fume hoods, the number of air changes per hour exceed the OSHA requirements.
(2) Statements in the licensee's radiation control.
procedures indicate that corridors in the restricted area will not be permitted to remain contaminated, if they so become. (3) The licensee currently intends to provide respiratory protection equipment to individuals who demand their use, even if the radiological conditions do not require respiratory protection. Individuals will have to have been tested and trained on the specific equipment being used.
Staff Position Region V concludes the specific concerns cited are not founded. In the inspector's opinion,-the licensee is committed to a strong ALARA program. .
This commitment is reflected in statements in their procedures. The inspector note, however, that the ultimate performance can't be clearly demonstrated until the plant is operational.
Action Required No further action is required relative to the concerns expressed. Region V I will review the licensee's implementation of their operational ALARA program through the routine inspection program.
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t Problem Statement Allegation #: 21 ATS No. -RV-83-A-0018 BN: N/A
- This document lists each allegation or concern brought to the attention of NRC personnel. The purpose of this statement sh e'e t is to assure that all points raised by the alleger are covered.
If the problem statement is not clear as to who, what, where, when, or why regarding th'e issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is an or very little original information available which describes the concern (s). (This can occur if, for example, a line concern was received in an interview).
Problem Statements Alleoa' tion # Verbatum Statement or Reference 21 This concern together with those described in allegations 20, and 22 were presented to Mike Malmros, former senior res6 dent inspector at Trojan Nuclear Power Plant. The concerns were expressed by a former Pacific Gas and Electric, Co. employee. The identity of this indiv! dual is not known to the reviewer.
These concerns appear to have made more as a l
casual comment and were not intended as a formal allegation. They can be viewed to be similar to statements made by an employee at an " exit interview" (an interview performed when an individual ceases employment with a c omp an y) .
These concerns were made to Mike Malmros some time befo're May 19, 1983. Malmros first conveyed these comments to the reviewer by telephone, and after the urging of the
- reviewer Malmros submitted the attached Allegation Data Form.
The specific concern is that Diablo Canyon has poor practices as far as keeping internal exposures to radioactive materials as low as reasonably achievable. The alleger gave three i examples in which he bases his concern. <!)
l The air in the chemistry laboratory is only exhausted by means of the fume hoods and this is inadequate. (2) The licensee intends to permit all floors in the restricted area L '
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to becerne contaminated. (3) The licensee will not provide respiratory protection equipment to workers any time the workers want it.
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mac r e ao7 til e21 ALLEGATION DATA FORM gne,,,ci,an, on ,,,,,se sede u s sucL( AR REGUL ATORY CCMMM'nN RECEIVING OFFICE
- 1. Facility (les) Involved: INemel ' " '
IN '"*'* 'M" 3. of W genanc, wnte GENERIC) bl O b w -r o et O f C O D a[ ') f bi d le D cm '2 O [ O O O ] al. ]
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- 2. Functional Areals) Involved: .
Icket appropnete boirest I operations onsite health and safety
__ construction _ offsite health and safety
_. safeguards __ emergency preparedness
_ other ispecifyl 3.
Description:
'"'"***'** lHlf l le IE la lf lo lNEI[Ill l/Ylol Tl l DIidl #ll. U~ [lO l l lAINI.Illi leltl Alr.lAalt Iginlal IrInfolt-Inledhi Inl
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- 4. Source o' f Allegation.
Icheck opp,op,ete boil contractor employee
_ security Quard
_ licensee employee _ news media
. . . . . NRC employee private citizen
_ , organization tspecity) other tspecif,) 5 - llt Ht1 e t. > rs 1* t
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- 5. Date Allegation Received:
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- 8. Name of Individual trim two inities end last namel
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Receiving Allegation:
- 7. Of fice: "
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- 8. Action Office
Contact:
triest two initi.is and i.si namel
- 9. FTS Telephone Number:
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- 11. Date Closed:
j 7 3 g 3 712. Remarks:
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- 13. Allegation Number: Y.., w-e.,
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