ML20215H890

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Sixth Partial Response to FOIA Request for Documents Re Allegations.Forwards App C & D Documents.App B Documents Also Available in PDR
ML20215H890
Person / Time
Site: Diablo Canyon, Callaway, Comanche Peak, 05000000
Issue date: 05/05/1987
From: Grimsley D
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To: Garde B
GOVERNMENT ACCOUNTABILITY PROJECT
Shared Package
ML20213D283 List:
References
FOIA-84-21, RTR-NUREG-0578, RTR-NUREG-0675, RTR-NUREG-578, RTR-NUREG-675 NUDOCS 8705070130
Download: ML20215H890 (14)
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I F0!A-84-21 (SixthPartial)

! Appendix 8 l

l Records Available in PDR

, 1. 11/14/83 Memo for V. Gilinsky from H. Hudson,

Subject:

Deviations from Pullman Power Products' Weld Procedure Codes and Pacific Gas &

i Electric's Contract Specification #8711 and #8833XR Quality

) Assurance and Welding Requirements At the Diablo Canyon Nuclear 7 Power Plant Project. Units #1 and #2. (264pages)w/ attachment i PDR/ADOCk/50-275P 8401250217 l 2. 1/10/84 Memo for V. Gilinsky from D. Kirsch.

Subject:

Alle Harold Hudson received on January 9,1984(1 page)gationsof POR 8402150326. w/ attachment: 1/2/84

Subject:

Report #2 - Quality Assurance Deficiencies in the Ultrasonic Measurement of Reactor Coolant Pressure Boundary Valves for Minimum Wall Thickness Requirements as Requested by the Atomic Energy Commission in their Letter of 6/20/72 to Pacific Gas and Electric Company at the Diablo Canyon Nuclear Plant. (91 pages) PDR/ADOCK/50275$.

  1. 8402150329
3. 1/16/84 Memo for Commissioners from D. Eisenhut,

Subject:

Diablo l

Canyon (2pages)PDR/ADOCK/50-275P8312120125 l

l 4. 1/24/84 Memo for Comissioners from D. Eisenhut,

Subject:

Diablo Canyon j (2pages)PDR/A00CK/50-27558312120160

5. 1/13/84 Memo for Denton from Joosten re Diablo Canyon QA Qualifications PDR/ADOCK/50-275 5 #8402150323 l

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  • Re: F0!A-84-21 (Sixth Partial)

APPENDIX C RECORDS MAINTAINED IN THE POR UNDER THE ABOVE REQUEST NUMBER 1, Undated AT5 ho. RY 83 A 018 Allegation or concern No. 20 (3 pagen c, 10 3 7 83 Region V inspection at Diablo Canyon Unit I (Report No.

50 275/83 32) (4 pages) 3, 12 2 63 Memo for William Fisher from F. Wenslawski, ref: Request for guidance on required esperience for chemistry and radiation protection technicians w/ enclosure (2 pages) 4.

I? 23 61 Cover note to Fran6 transmitting documents (1 page) a 72980 MeSc to James $niete6 from George Seith, ref: Requirements for training, qualification, and re training of power reactor health physics technicians w/ enclosure (7 pages) t, .

10 28 80 Merc for Robert Tedesco from William Kreger ref: Diablo (aryon Supplement to safety evaluation report requests for additional information w/ enclosure (4 pages)

7. 2 81 Me o for Robert fedesco from William Kreger ref: Callawa request for adentional infortnation w/ enclosure (2 pages) y U-9480 Meno for Robert Tedesco fror William Krefer ref: Cocanche Peak 1 & 2 Request for additional inforvattor. w/ enclosures (3pages)

AutGA110N ??

y, $.19 83 A) legation data form (1 page) lo. 103783 RegionVIntfectionReport(4pages)

11. 3 15 84 Problemstatement(2pagen)
12. 3 2 84 A15No.RV.83A108AllegationorConcernNo.22(3pages)

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Re: F0!A-84-21 (SixthPartial)

APPENDIX C RECORDS MAINTAINED IN THE POR UNDER THE AB0VE REQUEST NUMBER ALLEGA'10N 23

13. 3 16 84 Probler statement (1 page)
12. . 3 17 84 AT5 No. 05 83 017 Allegation or Concern No. 23 (3 pages)

ALLEGATION 24-26 46 66 10- 3 5 84 Allegation Data Fom ATS No RV-83 A33 (1page)

16. '10 27 83 Memo to Comission from Eisenhut ref: ALLEGATIONS CONCERNING D:ABLO CANYON (80AoD N0i! FICA'!ON No. 831(4) (: ages'
17. 8/11/83 Allegation data form ATS No. RV-83-A28 (1 page) lj. 3 5 84 Problem statement ATS No. RV 83 A52 (1 page)
13. 10 ?? 83 Allegations or concerns Nos. 24 ATS Nos. RY8dA?8, RV83A33, Rv83A5?. Rv83A46 83164 (5 pages)
20. 3 6 84 Allegations Nos. 24, 26, 46 4 66,133 A'5 Nos. RY 83A?8, RV 83A33. RV 83A46 & RV 83A521st draf t (8 pages)
1. 3 6 84 Allegations Nos. 24, 26, 46 4 66,133 Ai$ N35. RV 83A?8, RY 83A33, Rv.83A46 & tV 83AS? 2nd draf t (? pages)
22. 10 ?? 83 Allegation or Concern Ni. 24 (6 pages)
23. Undated Allegation or Concern No. 26 (1 page)
24. Undated Allegation or Concern No. 46 (1 page) 23.

Undated Allegation or Concern No. 66 (1 page)

I Re: F01A-84-21 (Sixth Partial)

APPENDIX C RECORDS MAINTAINED IN THE PDR UNDER THE ABUVE REQUEST NUMBER ALLEGATIONS 25-58-142 154-176

26. Undated Allegation ho. 25 ATS. No. Ry 83A33 (1 page) 27- Undated Me m .o for T. W. Bishop from P. J. Morrill ref:

INSPECTION RESULTS, LAWDENCE LIVERMORE NATIONAL LAB :ATORY PERSONNEL EIAy!NA!!0N OF PACEWAY SUPPORT BOLTED CCwECTIONS AT DIABLO CANYON (DN 50 275 AND 50-323) (2 pages)

JJ. 12 5-83 Letter to Dec.nis Kirsh from W. O. Wade ref: INSPECTION STATUS P! PORT w/ attache.ents (9 pages)

29. 6-1-79 Letter to Pacific Gas and Electric Co. free G. S. spencer ref: NRC lhSPECTION AT DIABLO CANv0N Uh:'S 1 AND 2 w/ enclosures (12pages)
30. 7-6 79 Letter to Pacific Gas and Electric Co. froc G. S. Spencer ref: NRC INSPECTION AT DIABLO CANYON Uh!TS 1 AND 2 w/ enclosures (1) pages)
31. Undated Xeros pages of RED HEAD anchoring products (4 pages) 3.' . 3-14 84 Allegation Nos. 25. 58. 142. 154. 176 ATS No. Ry-83-A-33 RV 83 A-$7, Ry 84-A-0015. RY-84-A-0017. Ry 84.A-0007 (6pages)
33. 1-27-84 Letter to John Martin from J. O. Schuyler ref: RESPONSE TO A'LEGAil0NS 25. 58 and 96 - $$ER 21 (19 pages)
/, , 2-7-84 Letter to John Martin from J. O. Schuyler ref
WELDING IN THE CABLE SPREADING ROOM FOR DIABLO CANYON UNITS 1 AND 2 w/ enclosure (5pages)

Re: F01A-84-21 (Sixth Partial)

APPENDIX C RECORDS MAINTAINED IN THE PDR UNDER THE AB0VE REQUEST NUMBER

35. 3-P4 False Floor in Cat!e S m eding R:o t is r:: Class I (2 pa;es)
36. 2 1( 94 Letter to John Martin fror J. O. Schuyler ref: SECY-84 El

!! EMS 25, 58, 96,142 154, and 176 CONCRETE EXPANSION ,

ACH0PS w/ enclosures (,29 pages )

37. 2 23-84 h;C Walkdowr, of Anchor Bolt Installations (2 pages)
a. 3 7 64 Fandwritten notes er. titled Anchor Bolts (2 pages) 39, 2-7-f' letter to John Martin fror J. O. Schuyler ref
SSER 21 A' legations 25 SE, and 96, Concrete Expansion Anchors w' enclosures (18 pages)

_AltEGAT10N 27 _

/,0. Undated Allegation Data Form with Problem Statement (2 pages) t,1. Urcated Allegation No. 27 ATS No. RV-83-A-33 (1 page)

ALLEGATIONS 28-34

2. 12-12-83

- Memo re f:

for G. Knighton, H. Scherling, P. Kuo from P. J. Morrill DIABLO CANYON - ALLEGATIONS CONCERNING ERRORS IN OOCUMENTATION OF SAFETY RELATED SYSTEMS, STRUCTURES, AND COMPO-hENTS w/ enclosure (7 pages)

<3. 2 17-84 Letter to George Knighton from J. 0. Schuyler ref: SSER 21 ALLEGATIONS 31 an'$ 32 (2 pages)

':. 10 18 83 Allegation No. 28-34, ATS No. Rv 83A41 (7 pages)

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10-12:83 Allegation Data Form, and attachments (11 pages)

  • Re: F0!A-84-21 (SixthPartial)

APPENDIX C RECORDS MAINTAINED IN THE PDR UNDER THE AB0VE REQUEST NUMBER ALLEGAT10h5 38-45

46. 1
  • E } Le'.e tc 1. W. Bishop f rorr J. B. hach ref: Response to hkC Recsest for Inforw.ation Regarding [ngineering Walkdcwns ar.d ti e A:c *acy of the Jr. fort.6 tion Generated w/ attachments (28 pages) t,7 . Urd!ted Diatto Car. yon Power Plant Plant Design Corrent w/attachrint (5pages)
43. 10 1-81 Cesigr. Change for Diablo Canyon I & 2 (2 pages)
49. i 10 20-83 Le"er to T. W. Bishop from Johr. Cooper (4 pages) 50, 2-5 84 Letter to T. W. Bishop from John Cooper (9 pages)

! 51. 3 13-84 Problem Statement for Allegation No. 38 (2 pages)

U2. 3-16-84 Protlem Statements for Allegations 39-45 (14 pages) l

'33 - 2-15-84

  • Letter to George Knighton from J. O. Schuyler ref:

Diablo Canyon Unit 1 SSER 21-A11egation 45 (2 pages)

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Re: F01A-84-21 (Sixth Partial)

APPENDIX D RECORDS MAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER

1. 10/5/83 Interoffice M aorandum, Diablo Canyon Project, to Etzler from Cranston/ Moore (1 page) w/ attached List of Welding Symbols (6 pages)
2. 9/14/83 Interoffice Memorandum, Diablo Canyon Project, to Cranston from Shipley (2 pages) w/ attachments (48 pages):
1) IOM from Brooks to Rockwell dtd 8/24/83
2) Clarification of Welding Symbols (draft)
3) Some Do's and Don'ts for Pipe Support Welding Design (draft)

(4) Copy of (16) pipe supports having welding problems

3. 10/30/73 Inspection Report, The M.W. Kellogg Company, (10 pages)
4. 2/27/74 Inspection Report, The M.W. Kellogg Company, (7 pages)
5. 2/25/75 Inspection Report, The M.W. Vellogg Company, (10 pages)
6. 5/29/75 Inspection Report, The H.W. Kellogg Company, (21 pages)
7. 8/22/75 Inspection Report, The M.W. Kellogg Company, (5 pages)
8. 8/25/75 Inspection Report, The M.W. Kellogg Company, (11 pages)
9. 1/26/76 Inspection Report, The M.W. Kellogg Company, (8 pages)
10. 6/22/82 Inspection Report The M.W. Kellogg Company, (20 pages)
11. 7/14/82 Pacific Gas and Electric Company Mechanical and Nuclear Engineering Department, "A Designer's Guide to Welded Joints" by Mark Michaels (28 pages)
12. 8/26/82 Oper Item Report (1 page) w/ attachment Minor Variation Report (1 page)
13. 7/22/82 Pacific Gas and Electric Company, Department of Nuclear Plant Operations Diablo Canyon Power Plant Units No(s) 1 and 2, title: Personnel Contaimination Control. (6 pages)
14. 10/25/82 Pullman Power Products, Inspection Report (16 pages)
15. 11/2/82 Pacific Gas and Electric Company, Department of Nuclear Plant Operations, Diablo Canyon Power Plant Unit No(s) 1 and 2

Title:

Radiation Control Procedure Use of Respiratory Equipment for Protection Ageinst Airborne Radioactivity Materials (4 pages)

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Re: F01A-84-21 (SixthPartial)

APPENDIX D (Continued)

16. 1983 Handwritten memorandum re: Diablo Canyon (3 pages) w/ attachments:

A) Appendix A, Effective Throat (1 page), Appendix B.

TableB(1page)

B) SF Plant Deisgn PSM I Instruction (3 pages)

C) Design of Fillet Welds (3 pages)

17. 1/25/83 Pacific Gas and Electric, Department of Nuclear Plant Operations Diablo Canyon Power Unit No(s) 1 and 2, title:

Radiation Control Procedure Control of Access for Radiation Protection Purposes (7 pages)

18. 2/14/83 Diablo Canyon Power Plant Procedure On-The-Spot Change (1 page) 1
19. 2/15/83 Open Item Report (1 page) w/ attached 3/17/83 ltr to Foley Company from Cates (1 page)
20. 4/6/83 Pullman Power Company, Inspection Report (21 pages)
21. 5/13/83 Pullman Power Company, Inspection Report (15 pages)
22. 6/6/83 Foley Company Nonconformance Report (2 pages)
23. 6/14/83 Pacific Gas and Electric Company ltr to Foley Company (2 pages) w/ attached: Weld Test (1 page)
24. 7/11/83 Memo to ALL QC Inspectors from L.R. Wilson, subject:

Existing Work (1 page)

25. 7/11/83 Memo to ALL QC Inspectors from L.R. Wilson, subject:

Existing Work (1 page)

26. 8/9/83 Open Item Report (2 pages)
27. 10/5/83 Pacific Gas and Electric Company Engineering Department, Discrepancy Report (8 pages)
28. 9/20/83 Interoffice Correspondence to WPS Manual Holders from H.W. Karner, subject: General Welding Standard (1 pa w/ attached Pullman Power Products Designs (11 pages)ge) '
29. 11/17/83 Interoffice Memorandum, Diablo Canyon Project to Etzler from Cranston, subject: Welding on Two Parallel Sides of Structural Tube (1 page) w/ attached: Welding Details (1 page)

Re: F01A-84-21 APPENDIX D (Continued) 30, 12/5/83 Interoffice Memorandum, Diablo Canyon Project to Leppke from Curtis,

Subject:

Weld Inspection (1 page)

31. 12/5/83 Interoffice Memorandum, Diablo Canyon Project to Leppke from Curtis,

Subject:

"A Designers Guide to Welded Joints" byM.Michaels(1page)

V t nReuest(2pages)w/attachedInspection hua ai

33. Approveo Suppliers Historic List (8 pages) i
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Task: Allegation or Concern No. 20 l .

ATS No: RV-83-A-018 BN No: N/A 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 l

l The NRC staff approach to resolving this issue was to examine the applicable Technical Specification and related standards; to review the licensee's j

implementation of these requirements; and to assess the licensee's compliance in as:;uring requisite qualifications of Health Physics personnel.

The licensee's Technical Specification._6.3.1 requires that each reenber of the Health Physics staff shall meet or exceed the minf== qualifications of ANSI standard N18.1-1971 except for the Supervisor of Chemistry and Radiation G/UL .(0\0-S - Ek _ - -

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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 l

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 Chemistry and Radiation Protection techniciana. Section 4.5.2 of the ANSI standard states " technicians in responsible positions shall have a minimum of two years of working experietce in their specialty." Chemistry and Radiation protection could be considered to be two separate specialties. The licensee, however,

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considers that a combined total of two years experience meets the intent of the ANSI standard. NRC has not specifically developed a position addressing whether 2 or 4 years of experience are appropriate for the disciplines of chanistry and radiation protection T.mBined as a single specialty. There is precedent for both interpretations.

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,. 't Staff Position Region V concludes that the licensee's professional Health Physics staff neet

~the requirements of the Technical Specificatica. Notwithstanding the ANSI standard, the licensee intends tc use only qualified technicians to fill responsible positions. The issue of the required number of years of r.xperience 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 tne 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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GOVEE.NMENT ACCO.'.M.iTY PROJEG

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January 9,1954 HAND-DELIVERED 9 January 19*4 FREEDOM OF INFORMATION ACT REQUEST Director Fo.rA -2 4- al Office of Administration U.S. Nuclear Regulatory Ccn-ission

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Washington, D.C. 2055!.

To Whom It May Concern:

Pursuant to the Freedom of Information Act (FOI A), 5 U.S.C. 55E2, the Government Accountability Project (GAP) of the Institute for Policy Studies, requests copies of any and all agency records and information, including but not limited to notes, letters , memoranda , craf ts , minutes , diaries , logs , calendars , tapes , transcripts ,

summaries, interview reports, procedures, instructions, engineering analyses, draw-ings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, and any other data compilations, interim and/or final reports, status reports, and any and all other records relevant to and/or generated in connection with the Safety Evaluation Report related to the operation of the Diablo Canyon Nuclear Power Plant, Units 1 and 2, NUREG-0675, Supplement No. 21 (December,19 3)

("SSER 21") . This includes, but is not limited to, any and all NRR regulations, calculations, and judgments used to evaluate any of the allegations referred to in SSER 21. We request that each responsive document be ider.tified by the allega-tion number (s) to which it may relate.

If any of the material covered by this request has been destroyed and/or removed, please provide all surrounding documentation, including but not limited to a des-cription of the action (s) taken, relevant date(s), and justification (s) for the action (s).

GAP requests that fees be waived, because " finding information can be considered as primarily benefitting the general public," 5 U.S.C. 5552(a)(4)( A). The Governnent Accountability Project is a non-profit, non-partisan public interest organization concerned with honest and open government. Through legal representation, advice',

national conferences, films, publications and public outreach, the Project promotes whistleblowers as agents of government acccuntability. Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups who seek to ensure the health and safety of their communities. The Citizens Clinic is currently assisting citizens groups in the California area concerning the Diablo Canyon Nuclear Power Plant.

For any docunents or portions that you deny due to a specific F0I A exemption, please provida an index itemizing and describing the documents or portions of documents withteld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is rcquired under

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't g.i.n v . P.osen (1), 45: F.2d 020 (D.C.Cir.1973), cert. denied, 415 U.S. 977 (1974 We look forward to your response to this request w: thin ten days.

Very truly yours, l -'

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l Billie Pirner Garde Citizens Clinic Director BPG: ras

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U. S. NUCII.AR REGULATORY COMMISSION b REGION V a.

Report No. 50-275/83-32 }4 I

Decket No. 50-275 License No. DPR-76 Safegaards Group i

Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 91.106 Facility Name: Diablo Canyon Unit 1 Inspection at: Sac Luis Obispo County, California Inzpection conducted: October 3-7, 1983 Inspectors: - N d d; A/ov. 2R , /f/3 E. M. Garcia, Radiation Specialist Date Signed Approved by: /

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// 23!P3 F. A. Wenslawski, Chief /Date' Signed Radiological Safety Branch Susuma ry:

Inspection on October 3-7, 1983 (Report No. 50-275/83-32)

Areac Inspected: Routine unannounced inspection by a regionally based inspector following up on unresolved items and other follow-up items i

idcutified 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 identified radiation monitors. The inspection also followed up IE Information Notices, Licensee Event Reports, Allegation Number RV-83-A-0018, and licensee preparation for 10 CFR 61 compliance. This inspection involved l,

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 I

i,dentified.

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N inspector observed the location where the source was found and J interviewed the cognizant licensee staff. The inspector reviewed the licensee's radiological evaluatic4n of these events. N evaluation concluded that.a significant health hazard was not likley as a result of misuse of these sources. g 4

i No items of noncompliance were identified. (50-275/83-03-15, Closed) 9it 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 i made these monitors insensitive to Zenon-133 and Krypton-85. 1 l
Regarding the first issue the applicable ANSI standtrd 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

'b 1975.

The qualifications c,f 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 j

Nuclear Facility and have been involved in the development of Diablo i

Canyon since its inception.

l 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. h records reviewed ~

indicate that the licensee has a program for determining whether an individual has the required experierre. N inspector noted, however, that for Chemistry and Radiation Protection Technicians the licensee considers that two years experience :.n chemistry, radiation protection, '

or a combination of both meets tha standard for this position. N l

licensee was informed that although it was not clear that their l  ; interpretation of required experience is correct, it is the licensee's

-- responsibility to insure that technicitas in responsible positions are j- qualified to do the job. Reglon7 will seek from NRR clarification of a the ANSI 18.1-1971 experience requirement as it applies to4he licensee's Chemistry and Radiation Protection technicians.t h inspector will follow up ca this issue (50-275/83-32-01, oien). ,

t In regards to the second general concern, the individual gave three

! enamples of what he (she) felt were poor practices in the ALARA program.

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The first example is that air from the chemistry laboratory is only y 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 bysthe licensee's corporate industrial hygienist measured 16 room "mir changes

, per hour considering only the air removed by the fume hoodsy The i minimum recommended room air changes per hour is 10. Furthd,r, the licensee has a Design Change Request (DCR) for= adding a fume hood over

f. sink, and thus further increasing the number of air changes.

The second example of poor ALARA practices given by the individual I

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 J

Operation Health Physics the licensee indicated that they intend to keep hallways " clean" and to control the spread of contamination by the use l

of step-off-pads. Statements in Radiation Control Procedures G-4 and

. G-5 substantiate the licensee's intent.

j The third example of-poor ALARA practices given by the individual concerned is that the-1-icensee will not provide respirators to workers when they want one. "This situation would arise when the radiation work j 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 b Protection Against Airborne Radioactive Materials" establishes prerequisites for use and selection of respiratory equipment. Prior to l 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.

i 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, l

making these monitors insensitive to Ze-133 and Er-85.

l i RE-15 is in a hostile environment, high humidity and temperature. RE-22 l monitors what may be relative high concentrations of an undiluted stream.

The licensee procured environmental shields from the manufacturer of 3, these monitors to protect thest free the hostile environment, and to

decrease the sensitivity, respectively. The manufacturer his provided 5 -

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10 the licensee with analysis of responses for Xe-133 and Kr-85 for these monitors. As expected.the beta emissions from these radion'uclides is f completely shielded by the environmental shields. However, the gamma emissions (514 Kev for Kr-85 and 80.EeV for Xe-133) penetrge the shield and are detected by the monitor. The licensee intents to p rify the vendor's response curves when the plant is operational. +

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? No items of noncompliance or deviations were identified.

Y l'O . 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 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 idantified.

i

11. Unresolved Items L 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 unresclved items. These items have been found t'o be j acceptable. No new unresolved itses have been identified and none of I

the previously identified unresolved items 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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...~^*f DEC 0 219.83 MEMORANDUM FOR: William Fisher, Chief, Section B, i Engineering and Technical Supp, ort Branch, IR-MOM: F. A. Wenslawski, Chief

~

Radiological Safety Branch, Region V

SUBJECT:

REQUEST FOR GUIDANCE ON REQUIRED EXPERIENCE FOR CHEMISTRY AND RADIATION PROTECTION TECHNICIANS A number of facilities have a Technical Specification 6.3.1 which states in part "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N13.1-1971 for comparable positions...." ANSI N18.1-1971 Section 4.5.2 states " Technicians in responsible positions shall have a minimum of two years of working experience in their specialty." Some facilities, such as Diablo Canyon, have a unit staff position of Chemistry and Radiation Protection Technician. Chemistry and Radiation Protection are usually considered to be separate specialties, as is the case in section 4.4 of ANSI N18.1-1971 or section 3.2.4 of the revisions to this standard (ANS-3.1-1978 and 1981). Doug Collins in 1981 suggested that if a facility has a combine position then four years of experience, two in each specialty, would be required to meet the standard (see enclosure 1). It is our understanding, however, that NRR has not established a firm position on this issue. We believe this issue has generic implications and want to be sure that we are.not backfitting a new interpretation of the existing requirement.

We therefore specifically request guidance on:

A. Can we enforce a position that for technicians in responsible positions two years experience in each specialty, Chemistry and Radiation Protection, are required to meet the Technical Specification?

B. For Radiation Protection technicians in responsible positions does preoperational experience count on a one for one basis to fulfill the ANSI N18.1-1971 experience requirement?

M F. A. Wenslawski, Chief Radiological Safety Branch, RV

Enclosure:

As stated cc: M. Shanbaky, RI

--- D. Collins, RII '-

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. R. Greger, RIII .-

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. JUL 2 9 M MEM3RANDUM FOR: James H. Sniezek, Director, Division of Fue Facilities

and Materials Safety Inspection 4 .

FROM:s George H. Smith, Chief, FF&MS Branch, RI ,

SUBJECT:

REOUIREMENTS FOR TRAINING, QUALIFICATION, AND RE-TRAINING OF POWER REACTOR HEALTH PHYSICS TECHNICIANS

'This refers to the cemo to you, dated July 10, from J. Philip Stohr on the same

~

subject. .

We agree with Region II that there is a clear need to take action in this area.

Our wording in a recent Order modifying the Oyster Creek license, copy attached, relates to this question.

We suggest the following material, which builds on the ideas set forth in the Region II memo...be incorporated into the Radiation Protection Plan or a Regula-tory Guide which could contain or refer to the suggested Power Reactor Health Physics Training Manual. .

SUPMARY The radiation protection organization training and qualification p.ogram must be approved by NRC and must consist of the following elements:

1. A set of position descriptions which serve as the focal point and link through which defined authorities and responsibilities are tied to defined training and qualifications.
2. A documented program of classroom training and re-training to be done in accord with a prescribed set of topics. A spe'cified amount of time must be set aside and a documented. testing procedure must be used to verify that the trainee has grasped the key points and enough of the related material to be able to perform satisfactorily. Successful -

completion of this training and re-training and associated examinations must be accomplished in order to become and remain qualified for the position held.

E A documented program for supervisor examination and verification that the individual understands and can successfully carry out each pro-cedure associated with the position for which he is a cindidate.

3 ,

P. J. Knapp

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FTS 4S8-1291 9ONNN

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  • Jar.es H. Snietek 2

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JUL 29 MO

4. A documented method through which the Radiation Protection Manager makes a formal determination that an individual has all of the necessary qualifications and training 4nd is appointed to a position.

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  • These areas are expanded on in the following paragraphs. Y POShl0NDESCRIpTIONS .

I-s' Positions in the radiation protection organization, including technician positions.

should be designated. For each position there should be; a) a statement of the responsibilities and authorities of the position and b) a statement of the training and other qualifications which an individual must have in order to be appointed to the position. -

Item five in the Stohr Memo speaks to such a position. This item could be expanded to ' read; The phrase " responsible position" in ANSI-N18.1 should be defined in general terms as a position carrying such responsibilities and authorities that the actions of an individual holding it can have a direct affect on the radiological health and safety of plant personnel and the general public or on compliance with techriical specifications which control the release of radioactive material to the environment. A ifst of specific examples of authorities and responsibilities should be published. This list should include:

1) Approving Radiation Work Permits.
2) Approving Effluent Release Permits.
3) Conducting radiation surveys upon which worker protection is based.
4) Providing personal radiation protection coverage to workers conducting jobs involving substantial radiation hazards .

QUALIFICATIONS FOR ENTRY There should be some minimum qualifications for entry to each position. For exarr.ple a high school diploma with successful completion of Algebra 1 Algebra

2. Trigonometry and one year of science courses or equivalent practical experience should be required for entry to a Junior Technican position. All of the above plus one year of experience in the health physics department at a nuclear power plant.or a plant with radiation protection problems of the same type and magnitude shou 1_d be required for entry to a technician position.

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.- ,y h .as H. Snieze'k 3 JUL 2 91538 TRAINING AND RE-TRAINING ,

The list of topics en the enclosure to the Stohr Memo is excellent. I.would suggest the addition of the following topics:

4 itadiation Work Permit k Guclear Power Plant System Fundamentals -

1 The topics; PWR/8WR Radiation Sources In-Plant and Power Reactor Rules of Thumb which are presently listed as appendices should be moved to the preceding list of Training Manual Topics.

Each topic should be represented by a precis or course outline which presents sufficient detail to pennit an independent determination that the subject is adequately covered. Thekeyconcepts(thosewithoutwhichthetraineecannot perform adequate work) under each topic must be identified.

Examinations must be developed and maintained on file which verify the trainee's grasp of each topic. In addition to obtaining a passing grade on an examination, the trainee must successfully answer questions on the examination which demon-strates that he has grasped every key concept.

, The licensee's program must specify the topics which will be taught and tested for both initial cualification and re-training. As suggested in paragraph 4 of

. the Stohr Memo, the licensee's program should specify the number of hours which l will be allotted to; 1) initial qualification training and 2) requalification

training. -

Successful completion of the training and re-training and associated examinations

are necessary prerequisites for gaining and holding the position in question.

DEMONSTRATION OF UNDERSTANDING OF AND ABil.ITY TO PERFORM PROCEDURES.

The ability to perform the actual procedures which make up the bulk of the health physics duties, particularly at the technician level, is a major qualification for gaining and holding an appointment to a, described position.

The individual's foreman should be required to observe him to perform each pro-cedure successfully and should verify that the individual understands the reasons why the procedure exists and how the procedure accomplishes its purpose.

The foreman should then certify his findings by signature entries in the individ-un1's record. In addition, a formal method for assuring that each individual fullyTynderstands and can implement each-procedure change must be utilized.

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7 Jeres H. Sniezek 4

JUL 2 9 C The program should identify procedures for which re-certification is necessary as part of the annual re-training. ,

FORAL DETERMINATION OF ELIGI8ILITY AND APPOINTMENT {

The Radiation Protection Manager must verify from the individuhs record that; a) hy has the necessary quaiifications for entry, b) he has sucetssfully completed the slassroom training and has passed the required examinations and c) he has successfully demonstrated to the responsible foremen that he understands and can successfully implement every procedure for' which he will be responsible. The Radiation Protection Manager should take whatever additional steps he feels are necessary to assure himself that the individual is qualified. Finally, the Radiation Protection Manager should certify in writing that the individual is eligible for the designated position and has been appoin "ed it.

D .

Ge ge . mith, Chief

. Fue' F cilities and Mr.terials Sa ety Branch

Enclosure:

As stated ,

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FFDiS Branch Chiefs RII '

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  • UNITED STATES OF AMERICA NUCLEAR REGULATORY C034ISSION In the Matter of *
  • y Docket No. 50-219 Jersey Central Powar and Light Company *

(OysterCreekNuclearGenerating  ?

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Sta, tion, Unit No.1) .

< i

? ORDER MODIFYING LICENSE

~

, EFFECTIVE IMMEDIATELY I

The Jersey Central Pcwer and Light Comgan Operating License DPR-16 (the " license which ) y authorizes (the " licensee")

operation is the of theholder of Oyster Creek Nuclear Generating Station at steady state reactor core power levels not in excess of 1930 megawatts thermal (rated power). The license was issued on April 9,1969. The facility consists of a boiling water moderated and cooledreactor(SWR),locatedatthelicensee'ssiteinOceanCounty,NewJersey, nine miles south of Toms River, New Jersey.

II During an inspection conducted March 18 and 19,1980 it was detennined that one of the major factors contributing to an incident involving a breakdown in radia-tion protection controls was the use of an unqualified technician to provide radiation protection coverage during the servicing of a heavily contaminated reactor control rod blade handling tool. The incident involved exsosure to airborne radioactive material which resulted in intake by one of tie workers of approximately 29 percent of the maximum allowable quantity of cobalt 60. A second instance of the use of unqualified personnel was identified during a Health Physics Appraisal inspection conducted May 12-16, 1980. During this inspection, an unqualified contractor technician was observed to allow personnel to exit a work area, used for repair of heavily contaminated control rod drive m2chanisms, without performing whole body frisking. This individual was deter-mined to be at times directly responsible for the health and safety of the werkers rebuilding the control rod drive mechanisms.

  • t As a result of the first instance, a letter dated April 2,1980. was sent to the Director, Region I, U.S.N.R.C.. In this letter, the licensee's Manager of Nuclear Generation addressed irnr.ediate corrective actions and, among other
things, stated, "0ister Creek will use Radiation Protection Technicians who r eet or exceed AR$1N18.1-1971 in responsible positions. Unqualified t'echnicians acting irt.less responsible positions will be closely supervised. T)isActionwill l be implemented April 7,1980." .

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. 2 As a result of the second instance and as a result of the normal inspection review process, it was determined on May 16, 1980 that the licensee was utilizing contractor supplied radiation protection techniciaris in responsible positions who did not meet the requirements of ANSI N18.I-1971. The initial NRC review of resumes, observation of field perforinince and questioning indictted 4 of 28 contractor technicians designated by the licensee as meeting ANSI N18.1-1971 requirements did not meet these requirements. Of the 4 and including the latter indivqidual discussed above, 2 contractor technicians were detardlined to have no priorvapplied nuclear power plant experience. By May 19, 1980,'it was determined through further licensee review that an additional 10 of the 28 contractor technicians did not meet the ANSI N18.1 requirements.

The findings of the appraisal suggest that the licensee has not adopted appro-priate controls to assure the utilization of only qualified technicians in activities important to the protection of workers. -

- In view of the significance to safety in assuring the establishment and imple-mentation of appropriate management controls over safety-related activities and tne prompt resolution of identified problems, I have determined that the public health, safety and interest require, effective imediately, modification of License No. DPR-16 as stated in Part III of this Order.

III Accordingly, pursuant to t'he Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50 License No. OPR-16 is modi-fled by the following addition to Technical Specification 6.3, Facility Staff

. Qualifications: ,

6.3.2 Each member of the radiation protection organization for which there is a comparable position described in ANSI N18.1-1971 shall meet or exceed s .

the minimum qualifications specified therein or, in the case of technicians, j- shall have at least one year's continuous experience in applied radiation protection work in a nuclinar, facility dealirig with radiological problems similar to those enceuntered in nuclear power stations, preferably in an actual nuclear power station, and shall have been certified by the Supervisor, Radiation Protection, as qualified to perfonn specified work. This certification must be based on an NRC approved, documented program consisting of classroom training with appropriete examinations and documented positive findings by i

responsible supervision that the individual has demonstrated his ability to perform each specified procedure and function with an understanding of its l basis and purpose. However, the Supervisor, Radiation Protection, shall i

meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

i T. ' IY~

The licensee, or any~ other person who has an interest affected bytthis Order, j

1

=ay, within twenty-five days of the date of this Order, request a? hearing. A -

i request for a hearing shall be addressed to the Director Office of Inspection and Enforcement, U.S.N.R.C. , Washington, D.C. 20555. If a hearing is requested by the licensee or an interested person, the Commission will issue an Order i

! designating the time and place of hearing. Such a request for hearing SHALL NOT STAY THE IMMEDIATE EFFECTIVENESS OF THIS ORDER.

= =~.; _-a.----.,._-----.,_

3

. Y In the event the licensee or any other interested person requests a hearing as provided above and a hearing is held, the issues'to be considered at such a hearing shall be:

+

(1) phether the facts set forth in Part II of this Order are c{rrect; and, (2) yhether 'this Order should be sustained.

FOR THE NUCLEAR REGULATORY COMMISSION

~

Yictor Stello, Jr.

Ofrector -

Office of Inspection and Enforcement ,

Dated at Bethesda, Maryland this day of . 1980 ,

e 9

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. UNITE D $TAf f 8 f f ** ,'n NUCLEAR REGULATORY COMMISSION

  • n .sw. ovce.o.c.resse w

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. up;ae Docket Nos.: 50-275 and 50-323

..DCT

_. 1 8 1980 -

j .

MEMOAANDUM FOR:

,7 Robert L. Tedesco. Assistant Director for Licensing', DL

' [ . .'

FROM:' William E. Kre2er, Assistant Director for Radiation Protection. DSI

SUBJECT:

DIABLO CANYON - SUPPLEMENT TO SAFETY EVALUATION REPORT -

REQUESTS FOR ADDITIONAL INFORMATION PLANT NAME: Diablo Canyon Nuclear Power Station, Units 1 and 2 LICENSING STAGE: OL DOCKET NUMBERS: 50-275/323 MILESTONE NUMBER / BRANCH CODE: 40/33 i RESPONSIBLE BRANCH: LBf3; B.C. Buckley, LPM DESCRIPTION OF RESPONSE: Supplement to SER/ Requests for Additional Information -

REVIEW STATUS: Continuing , .

Enclosed is a supplement to the Diablo Canyon Safety Evaluation Report. This report sumarizes the status of the Three Mile Island Lessons Learned items

  • from NUREG-0578 which are reviewed by the Radiation Protection Section (RPS).

The RPS review ehcompasses: Item II.B.2(2.1.6.b) - access to areas not including vital equipment protection; Item II.B.3(2.1.8.a) - post-accident sampling ALARA considerations not including systems and procedures; Item II.F.1(2.1.8.b) - high range in-containment radiation monitors; Item III.D.3.3 -

(2.1.8.c) - portable radiciodine air sampling and analysis; and Item I.B.1.2 from NUREGS-0660/0694 - radiation protection organization only.

Status of Review ,

i 11.8.2 -

Open - Response from applicant expected in November. SSER pending Q331.18 response. -

II.F.1 - Open - Additional information regarding in-situ calibration and i calibration frequency requested. SSER pending Q331.24 response.

!!I.D.3.3- Complete - Updated SSER attached. l I . B] .2 -

Open - Additional informatTn reg.rding RPT on each shift, total  !

numbers of RPT's, and qualification of RPM backup reguested. SSER  !

pending Q331.21, 22, 23 response. 3

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11.8.3 -

Complete - SSER attached.

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R. Tedesco -

Staff positions and requests for additional information are additionally included. This evaluation was perfomed by R. J. Serbu, RPS/RA8.?

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William E. Kreger' Assista Director for Radiation Protectio Division of Systems Integration

Enclosure:

As Stated , ,

cc: w/ enclosure -

D. Ross F. Miraglia -

By Buckley T. Collias

  1. t. Serbu T. Murphy 9

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RADIATION PROTECTION SECTION/ RADIOLOGICAL ASSESSMENT BRANCH

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.0 [471.0) ~RAB

1.21 TP B.1.2)  ; Youhavepreviouslycommittedtoaddsufficientqualified$diati'on
.l.2) -r orotection technicians to provide a radiation orotactina +=chairi==

i for each thift in accordance with NUREG-0654 and Ntfam_nm / Guidelines For Utility Management Structure and Technical Resources.* Describe --

how your radiat' ion protection organization is staffed and structured to provide a qualified radiation protection technician on each shift, with enough radiation protection technicians overall to assure adequate -

radiation protection coverage for normal operation, maintenance and outages, and emergency situations.

1.22 In lieu of providing separate chemistry and radiation protection B.l.2) organizations and in order to Eryid= a cualified backup for the

.l.3) .

radiation _orotection manaaer function in accordance with the positions ' ,

of Regulatory Guide 8.8. NUREG-0660, and NUREG-0731. " Guidelines for Utility Management nructure ano technical Resources," provide a

. comitment so that the Senior Radiation Protection Engineer, or his replacement, is qualified in accordance with Regulatory Guide 1.8. .

1.23 Provide a description of how your radiation protection. qualification 8.1.2) and retraining program for Radiation Protection Technicians meets

}) the criteria of ANSI 18.1.

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1.24(RSP) It is our position (Letter, D.G. Eisenhut. September 5,1980) that

.F.1) calibration of high range containment radiation monitors be performed 1.4 in-situ usino calibrated radiation sources for all decade rances -

below 1R/hr. Calibration should be performed each refueling outage

'(e.g.every18 months).

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l l (1) Provide a commitment for in-situ caliberation of the high range l radiation monitors for decade ranges below 1R/hr, or describe l an acceptable alternative.

l (2) Provide a commitment to perform an in-situ calibration on the high ,

, range radiation monitors at each refueling outage.

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Callaway Q.1 .

. _r 331.1 In accordance with the recomendations of Regulatory Guih 1.8, the h Assistant Superintendant, Engineer-Radiochemistry, does not qualify t

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as a Radiation Protection Manager (RPM) since he does not presently .

have the three years of professional experience dealing with radiolo-gical problems in applied radiation protection encounted at an operating nuclear power station or equivalent. Therefore, please .

justify the selection o'f the individual delineated for.this position _

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based on his tr'aining and experience as shown in section 13.l.3.2 and , ,

specify, as required, how he will a'chieve the aforementioned experience, prior to the. plant being licensed, to qualify a' 'the s RPM. -

331.2 Based on information contained in the draft document " Criteria for Utility Management and Technical Competence" it is our position that the Radiation Protection Group be a separate organization from the Chemistry Group. Your station organization chart (Figure 13.1-3) shows these groups combined. Additionally, in accordance with Regulatory-Guide 8.8, it is our position that the Radiation Protection Mana.ger

, (RPM) should have access to the Assistant Plant Superintendent ,

in radiation protection matters. In matters relating to radiological

. health and safety, the RPM has direct responsibility to both employees and management that can best be~ fulfilled if he is independent of station r.- e divisions, such as operations, maintenance or technical s$pport, whose prime responsibility is continuity or improvement of stat on operability.

Your FSAR and proposed Technical Specifications should be revised to reflect how your planned radiation protection program reflects this position.

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