ML20213D281
| ML20213D281 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 09/04/1980 |
| From: | Kreger W Office of Nuclear Reactor Regulation |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20213D283 | List: |
| References | |
| FOIA-84-21, RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 8009190562 | |
| Download: ML20213D281 (13) | |
Text
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blSTRIBUTION:
Doctet nos.: 50-445 . DJCKET'FlTES'(2) 1;RR ROG .
and 50-446 SEP 04...:20 P 8 RDG'
' - giock x eger (2)
MC;03.ODJ' i FOR:
TBMurphy
.' Robert L. Tedesco for Licensing. DL Assistant Director i FRG:4: ?
5 William [. Kresor, Assistant Director for Esdiation Protection, ;DSI SUOJECT:
CGMNCNE PEAK 142 - REQUEST FOR ADDITIOML INFOR PLANT !WiE: Comanche Peak 1&2 LICENSING STAGE: OL D3CXET IE4CERS: 50-44S/446 RESP 0:iSIBLE BRANCH:
DESCRIPTION OF RESPONSE:LBF2; S. Bunte11. LPH - -
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Request for Additional Infomation based on r REVIEW STATUS: Continuing THI Lessons Learned (NUREG-0578) .
As a result of T14I related requirements to improve a the apar ti !
facility, letters were sent from Vassallo to Operating Se A)pteabar 27. 1979 on ofLic a nuclear ensee Applicants dated ,
s.hich specified new requirements that must for us to cocplete our FSAR review be addr n order s !
be revised to incoporate these.requ.ircaents which areThe ifcensee's appifcation cast i
'Tiil Related Requireents for New Operating Licenses "sumarized in NUREG-05 j area and access),
analysis Itern II.F.1 (containment monitor) andneItem A raore complete description of these re .. III D 3 (Iodi documentation). sampling l
are enclosed in Appendix A to this emo. quirenants and their i t
Mditionally, Enclosure 1 addresses new questions relating to the j h irganization andand instruments based on the staffs recent ealth physics compilati )
'cr utilityRPS,
. B1cch, canagocent RAB. technical competence . eria '
This review was parfomed by gst sisned f- !
g.,y,,nreger pn I ggq '
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s William' E. Kreger, Assistant Director h i
- losures: ; f 4A for Radiation Protection Division of Systems Integration 1 St:ted -
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W. Ibuston D. Collins t ied R. G m a(11 L. Barrett re-I S. Burue11 i
H. Rrtou/W. Russell D. Yassallo DSI:p .WK\
'DSI@ b ". DSf:R' Add \ Dt.: '
hg h"sincdu ,qwpg"'"w ADRP f.?..j'f.;i""'"#C3n1tns"..f.ME.'*.'.'.'. Fess""'""""""""'"""""5g,"
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. n: -l Bfg counter for measure- j i il an una(t:eptable the neutron counter using a moderated and bare I
f the-art tedhniques. I ment of fast and thermal neutron flux densit e T Please state
. I Rem-meter monitor such as the Snoopyi
' tly.
measure the neutron dose equivalent rate d recddition to the neu '
- your intentions regarding replacement of or a 1 1
monitor listed in Table 12.5.2.
. t " Criteria for i
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. osition that I 331.17 Based on information contained i tion from in the the . draft '
your station organization chain (Figure 13.1-4 r report radiation protection group isi lasupport separate division organ P l directly to the General Superintendent.
j that the RPM should be independent of er the to technresolveca l
and should have direct recourse to the plant managtion d therefore be protectio questions relating to the donduct of the radia l Your FSAR and proposed Technical Specification shoul i revised accordingly. Figure 13.1-4 should '
Concurrent to the change rea Mst in 331.17 h hi above, espective istry technici 331.18 also show that Health Physir" technicians an t .
i Radiation Protection and Chemistry group ma ide backup coverage in the event of Please describe your plan to p+M the qualifications of the indiv 331.19 z
the absence of the RPM and out1The December who will act as the backup. specifies that the tempo degree in science or engineerinoprotection,1 year 6 months of which should be on-site, does not state that a
(e.g., including back- i 331.20 Section an H.P. technician 13.1.2.3 willspecifying be onsite at ation shift, allintimes Support crew of c shiftand. weekends). t tion technician, of Radiological Emergency Rcsponse td Plan '
whose qualifications are described indiation ANSSection protection 13 t
all membertimes. of the shift crew (e.g., reactor operator longer l pitysics technician if he is qualified t powei. to implement taff require-procedures.
acceptable to the staff after the reactor is a 4
l health physics technician will be acceptable l
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}iP TEC11NICIAN QU.tLIFICATIONS Cn $
4 3 Criterza i .
4 The criteria for selection of HP technicians is specified in AMSI N18.I-1971, whilch is referenced by Regulatory Guide 1.8, Rev. 1-R. Section 4.5.2 of th.-
ANSI states:
Technie'ians in r'esponsible positions shall have a rainimum of two years of working experience in their specialty.
These personnel should have a minimum of one year of related technical training 'in addition to their experience.
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,IditfEpi 2posev,ef 'irispection, alt.echnician .in a responsible position . ,
Mkid3be am.indi.vidual who
- 1. Reviews surveys performed by others ,
- 2. Signs radiation work permits (RWPs) ' '
3, Issues RWPs
- 4. Independently performs surveys or evaluations used to permit compliance with regulatory
.e. requirements.
- One year of experience is 2000 or more working hours accumulated during a total period of not less than 40 weks of assignments at nuclear
- power plants, .
Inspection Item .
For those facilities wh'ose technical specifications require that HP te'chnici.ms meet .or exceed the minimuni qualifications of ANSI N.18.1-1971, examine records of training and experience for HP techn'icians added to the organization within the
, 'last year.- Discuss the content of the records of training and experience with
! the HP technicians to determine if the records are correct and accurately reflect the actual scope and content of training and the scope of experience.
l For those facilities whose technical specifications do not require the HP technicians meet or exceed the minimum qualifications of ANSI N18.1-1971 l
I perform the above for all HP technicians. ,
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- ALLEGATION DATA FORM v.s. uucteA= r;scutATo v ceuuiwou IIIEI instructions on reverse sade RECEIVING OFFICE .
- 1. Facility (lee) involved: INemel N mo'*
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- 2. Functionel Aree(s) Involved:
Icheck sooroonste bouteell operations onsite health and safety construction offsite health and safety safeguards emstgency preparedness other aspecityp 3.
Description:
lHlf l l# IE l4 (f lo ININlt lLl l/ylof ri t oTal 4l2. I liiol i IMM./111 lelli Alr.lA4li. lMnlal liolalolt-InlMhl 141 lP In lr>\ Efrit irl l l DEA R A Cl&lRITIM J INl lDl$ 0l l l INIo INI> I rl olralt I I/vl o 71 13 6.llyifI/
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- 4. Source o"f Allegation: -
(Check stor,ooriete boal . contractor employee __ security guard licensee employee news rnedia
.. NRC employee private citizen
,_., organization tspecityt other tspecityl b /[t* e M.1 PE &mse/cP*ref_'
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- 5. Date Allegatio,n Received:
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- 6. Name of Individual spir : two initiate and inst namel - - ' d- D'l' #
Receiving Allegation:
- 7. Office: "
ACTION OFFICE
- 8. Action Office
Contact:
intes two inie.ese and res, namei MI Jb
- 9. FTS Telephone Number:
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- 10. Status:
ic3 ca on ,
5 '0, pen. If followup actions are pending or in progress
, Closed. If followup actions are completed MM DD YY
- 11. Date Closed: j j p 3 g 3 ,
.72. Remarks:
(Lirvue to 50 cherectorsa l g lg- lg-l l / I4> lS l/ IElf l71.' l0 l *l l# IEl/ I t-l # I /d l II g Iclo l-lal7lrl/lFlJI-lJia l IPlelfle Islel/ l'IM l'7l 12.1 Man-hours /Date ~
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- 13. Allegation Numben g i t v
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Problem Statement Allegation #: 22 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'1 points raised by the alleger are covered.
'If the prcblem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify th e s t a t eme n t . Th e c c.*me n t ary section will also be used if there is apparent conflicting information or if there is ng 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 Statementg Alleoation # Uerbatum Statement or Reference 22 This concern together with those described in allegations 20, and 21 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. emplo>ee. 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).
I These concerns were made to Mike Malmros some time before 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.
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The specific concern is that modifications to the Air Ejector Discharge Radio-Gas moni tor and the Gas Decay Tank Discharge Radio-Gas monitor have made these monitors i n scensi t i v e to Xenon-133 and Krypton-85. The modification, ,
consisted of placing an enviro ental sh i.e l d - -
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I over the detectors of these monitors.- The shield prevents the detection.of these nuclides. -
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s ., .y Task: Allegation or Concern No. 22 gy ATS No: RV-83-A-018 BN No: N/A Characterization Modifications to the Air Ejector Discharge Radio-Gas Monitor (RE-15) and the Gas Decay Tank Discharge R.dio-Gas Monitor (RE-22) have made these monitors insensitive to Xenon-133 and Krypton-85. An environmental shield has been placed over these monitors that prevents the detection of these nuclides.
Implied Significance to Design, Construction or Operation This concern implies that the stated monitors will be unable to accurately measure the radionuclides of Xenon-133 and Krypton-85 and consequently not all released activity will be accounted for.
The Air Ejector Discharge Monitor is used for indications of a primary to secondary system leak. If this monitor is not sensitive to Xenon-133 and/or ,
Krypton-85, primary to secondary leaks would not be detected as promptly.
The Gas Decay Tank Discharge Monitor is used to monitor discharges from the gas decay tanks. This channel will alars at the main control board and Auxiliary Building control board and close the gas decay tank vent valve on a high radiation level. Failure of thiTeonitor to detect Xenon-133 or Krypton-85 could result in an unmonitored release or an unplanned, release.
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Assessment of Safety Significance The NRC staff approach to resolving this issue was to examined the installed
' instrumentation; to review the applicable procedures; to review the correspondance between the licensee and the instrument vendor; and to interview the cognizant licensee staff.
4 Environmental shields are installed as alleged, however there are valid reasons for their presence. When the inspector examined the situation in detail the following was found:
4 The Gas Decay Tank Discharge Monitor monitors what may be relativly high concentrations of an undiluted stream. The Air Ejector Monitor is in a hostile environment: high humidity and temperature. The licensee procured environmental shields from the masufacturer of these monitors to protect them from the hostile environment, and to adjust the sensitivity to a proper operating range respectively. The manufacturer has provided the licensee with analysis of responses for Xe-133 and Kr-85 for these monitors. As expected the beta emissions from these radionuclides are 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 intends to verify the vendor's response curves when the plant is operational.
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M Region V considers the licensee to have made an adequate review of the effects of the modifications to the monitors and the reduced sensitivity of these monitors does not adversely effect the ability of the instrumentation to
- perform its intended design function.
Action Required No action is required.
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. 'is Problem Statement Allegation f(s): ,h h1 :.
ATS No.(s): Q (-(~#;P'd() .}
BN(s):
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 also 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).
Problem Statements (use extra sheets as necessary) l Allegation # Verbatum Statement or Reference -
@ Inspector Concerns s
Commentary
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Date This Statement was Completed
' b Technical Reviewer Si'gnature
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Task: Allegation or Concern No.23 Fl'mumme F 1 o, l I
ATS No: QS-83-017 BN No:
Characterization QA Inspector concerns Implied Sinnificance to Plant Desian, Construction, or Operation Assessment of Safety Significance Staff Position Sensitive Action Required
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. . , 4 $7 FILE CO P Task: Allegation or C'ncern o No. 23 $
ATS No.: QS-83-017 BN No.:
s.n ti Characterization A former QC Inspector for Pullman Power Corporation stated he was terminated on August 15, 1983 for excessive tardiness. The former inspector alleged'that on the day he was terminated, a production superintendent called him " names".
The inspector refused to provide further information as his union was resolving his termination. The inspector was asked to recontact OI:RV when he could provide further information. The inspector never recontactedl0I:RV.
Implied Sinnificance to Plant Design, Construction, or Operation 1
Production intimidation of QC Inspectors.
Assessment of Safety Significance Field work by OI:RV has been unable to locate the QC Inspector. He is reported to be at an unknown location in Indiana.
1 Staff Position Due to inability to locate alleger, d ormation from this case has been incorporated into cases Q5-84-oll, QS-84-012, and Q5-84-013, which relate to e
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intimidation of Pullman Power Corporation QA/QC personnel.
d e e v s ~-~ e e+e e * * *>= * * - * '*
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e Action Required .
Finish investigation of cases QS-84-011, QS-84-012, and Q5-84-013, which are currently in progress.
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U. S. NUCLEAR REGULATORY COMMISSION b 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: N/ E; A/ov. Ra , /M3 E. M. Garcia, Radiation Specialist Date Signed Approved by: / o
// 23!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, 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 l identified radiation monitors. The inspection also followed up IE i Information Notices, Licensee Event Reports, Allegation Number RV-83-A-0018, l and licensee preparation for 10 CFR 61 compliance. This inspection involved f 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> onsite by one inspector.
1 Results: Of the nine areas inspected no items of noncompliance were identified.
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The inspector observed the location where the source was found and s# 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 re 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.
kW 1975.
The qua'lifications 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 protectiou, 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 techniciana 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 L 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
-, 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 fume 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 in 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 k, 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 af ter 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 manuiscturer of these monitors to protect them from the hostile environment, and to decrease the sensitivity, respectively. The manufacturer has provided e
, .f 10 the licensee with analysis of responses for Xe-133 and Kr-85 for these g monitors. As espected the beta emissions from these radionuclides is' completely shielded by the environmental shields.' Nowever, 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 4dentified.
- 10. Licensee Preparation for 10 CFR 61 Compliance On December 27, 1983 the new Part 61, Licensing Requirements for Land Disposal of Radioactive Weste, 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, 1933, respectively. Pacific Gas and Electric is aware of the requirements of 10 CFR 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
.Y Unresolved itees are estters 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 itses have resulted in noncompliance or deviations.
- 12. Exit Interview 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 licensee was informed that no items of noncompliance were identified.
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