ML20204E471

Forwards Suppl to Ser,Summarizing Status of TMI Lessons Learned Items II.B.2,II.F.1,III.D.3.3,I.b.1.2 & II.B.3 & Request for Addl Info

ML20204E471
Person / Time
Site:	Diablo Canyon
Issue date:	10/28/1980
From:	Kreger W Office of Nuclear Reactor Regulation
To:	Tedesco R Office of Nuclear Reactor Regulation
Shared Package
ML20204E477	List: ML20204E471 ML20204E714 ML20206A861
References
FOIA-84-21, RTR-NUREG-0578, RTR-NUREG-0660, RTR-NUREG-0694, RTR-NUREG-578, RTR-NUREG-660, RTR-NUREG-694, TASK-1.B.1.2, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM NUDOCS 8011240030
Download: ML20204E471 (13)

Text

1. (/,* NUCLEAR RE .. MISSION -

{ s r, - -# waswiwatcw.e.c.rosss D.....l_e Docket Nos.: 50-275 can%x '

and 50-323

.%_[28 M MEMORANDUM FOR: Robert L. Tedesco, Assistant Director ./

for Licensing DL .

FROM: William E. Kreger, 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 RESPONSIBLE BRANCH: LBf3; B.C. Buckley, LPH DESCRIPTION OF RESPONSE: Supplement to SER/ Requests for Additional Infonnation REVIEW STATUS: Continuing e- Enclosed is a supplement to the Diablo Canyon Safety Evaluation Report. This

report summarizes 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 encompasses: 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 II.B.2 - Open - Response from applicant expected in November. SSER pending Q331.18 response.

II.F.1 -

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

III.D.3.3- Complete - Updated SSER attached.

I.B.1.2 -

Open - Additional information regarding RPT on each shift, total numbers of RPT's, and qualification of RPM backup requested. SSER pending Q331.21, 22, 23 response.

II.B.3 - Complete - SSER attached.

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

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

Enclosure:

As Stated ,

cc: w/ enclosure '

D. Ross i F. Miraglia By Buckley

7. Collins

4. Serbu T.!!urphy

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. [v} RADIATION PROTECTION SECTION/ RADIOLOGICAL ASSESSMENT BRANCH

{331.0(471.0) RAB -

iQ331.21 (1.B.1.2) You have previously committed to add sufficient qualified radiation (13.1.2) protection technicians to provide a radi__ation orotectina tachnicha for each shi_ft in accordance with NUREG-0654 and NURFL n?31 ' Guidelines for Utility Management Structure and Technical Resources.* Describe --

how your radiation 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.

Q331.22 In lieu of providing separate chemistry and radiation protection

(1.B.1.2) organizations and in order to gr,gyida a cualified backup for the

(13.1.3) .

ra_diation orotection manaaer function in accordance with the positions ,

of Reculatory Guide 8.8, NUREG-0660, and NUREG-0731. " Guidelines for Utility Management structure and technical Resources," provide a

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

Q331.23 Provide a description of how your radiation protection qualification

!(.i R.I.2) and retraining program for Radiation Protection Technicians meets the criteria of ANSI 18.1.

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It is our position (Letter, D.G. Eisenhut, September 5,1980) that 9(331.24(RSP)

)II.F.1) calibration of high range containment radiation monitors be performed 12.1.4 in-situ using calibrated radiation sources for all decade ranges 3

below 1R/hr. Calibration should be performed each refueling outage (e.g.every18 months).

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(1) Provide a commitment for in-situ caliberation of the high range i radiation monitors for decade ranges below 1R/h'r, or describe j an acceptable alternative. l (2) Provide a comitment to perform an in-situ calibration on the high range radiation monitors at each refueling outage, t

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. " NUCLEAR REGULATORY COMMISSION

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" ' ' ' - FEB : ' 1981 DOCKET NOS: 50-483 and 50-486 Robert L. Tedesco, Assistant Director -

HEMORANDUM FOR:

for Licensing, DL FROM:

William E Kreger, Assistant Director for Radiation Protection, DSI

- CALLAWAY - REQUEST FOR ADDITIONAL Ifjf0RPAlI0N ,

SUBJECT:

Plant Name: Callaway 1 and 2 Licensing Stage: OL Docket Number: 50-483/486 Responsible Branch: LBil; R. Staik, LPHRequest for additional information based Description of Response:

Review Status: Continuing The Radiological Assessment Branch has reviewed the Snupps - Ca protection program as described in their FSAR with criteria for utility management and technical competence of _their staff. Ques tions relating to issues arising from this review are enclosed with this memo.

The licensee will be required to respond to these questions before we can com-plete our review. The review was performed {y S. Block, RPS, RAB.

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' William E. Kreger, Assist Director

, for Radiation Protecti

Division of Systems Integration

Enclosure:

As stated cc: D. Ross W. Houston W. Gacmill H. Berkow /W. Russell T. Murphy .

D. Collins B.J. Youngblood R. Stark RPS Staff hwg*

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331.1 In accordance with the recommendations of Regulatory Guide 1.8, the Assistant Superintendant, Engineer-Radiochemistry, does not qualify 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 se:lection df the individual delineated for this position _

based on his training 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's'the RPM. -

331.2 Based on information contained in the draft document " Criteria for Utility lianagement 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 lianager (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 canagement that can best be fulfilled if he is indepandent of station divisions, such as operations, maintenance or technical support, whose prime respcnsibility is continuity or improvement of station operability.

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

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Concurrent to the, change request in 331.2 above, Figure 13.1-3 should

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also show that Health Physics technicians and Chemistry technicians i[j 5

become separate groups, be qualified separately as Chemistry and Radia-k

'n tion Protection Technicians, and each report directly to their respective S.:

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-i Radiation Protection and Chemistry group managers. This change request A

/ is also in accordance with the aforementioned draft document.

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iM Please describe your plan to provide backup coverage in the event of g 331.4 ,}

k the absence of the RPM and outline the qualifications of the individual '

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The December 1979 revision of ANSI 3.1 who will 'act as the backup. '

specifies that the temporary replacement for an RPM should have a BS Y

degree in science or engineering, 2 years experience in radiation t 3 protection, I year of which should be nuclear power plant experience, 6 months of which should be on-site, hf h3 iy I 331.5 Section 13.1.2.3 specifying shif t crew composition does not state that 'h I

i g H.P. technician will be onsite at all times (e.g., including back- w an f NUREG-0554 " Criteria for Preparation and Evaluation M shif t and weekends).

M-of Radiological Emergency Response Plans and Preparation in Support of 2

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Nuclear Power Plants" requires that a radiation pro'tection technician, '

whose qualifications are described in ANSI 18.1, shall be onsite at all times. Section 13.1.2.3, as written, would allow a designated f

, member of the shift crew (e.g., icactor operator) to act as a health

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physics technician if he is qualified to implement radiation protection f procedures.

It should be noted that. this qualification is no longer .

Only an assigned acceptable to the staff after the reactor is at power. ff require-health physics technician will be acceptable based on new sta d accordingly.

- n.- .sr.u o. Section 13.1.2.3 should be revise

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ts!STP.IBUTION:-

. DXKEFFTLES (2)

. I;RR RDG, 7 P B RDG Docket Hos.: 50-445 SEPO1.-g to Block and 50-446 .

cxeger(2)

TDiurphy MC;0E*iDU1 FOR: Robert L. Tedesco. Assistant Director

.- for Licensing, DL fa0.*4: Willia:n E. I;reser. Assistant Director for Radiation Frotection, DSI SU%1ECT: CO,M!iCliE PEAK 11.2 - REQUEST FOR ADDITIOML liiFOR:% TION PLA.'iT IM'iE: Comanche Peak 1&2 LICEtiSItiG STAGE: OL .

D3CKET litG ERS: 50-445/446 -

RESPD.iSIBLE EPMCH: LBf2; S. Buntell LPii DESCRIPTION OF RESPONSE: Request for Additional Infomation based on .

THI Lessons Learned (liUREG-0578)

REVIEW STATUS: Continuing As a result of TliI related requirer.ents to improve the oparation of a nuclear facility, letters were sent from Vassallo to Operating Licensee Applicants dated Se 27. 1979 and I.'ovec.bar 9.1979 (reference 3 and 5 of the attached Appendix ..

A)ptembars.hich specified new requirenants that must be addressed by applicants in for us to coaplete our FSAR review. The licensee's application cast therefore be revised to incoporate these.requircaents which are sum.irized in liUREG-0094

'Till Related Requirements for fiew Operating Licenses." Iten II.B.2 (for vital

area access). Item II.F.1 (containment raonitor) and Itern III.D.3 (Iodine sampling

andanalysis). A r,iore complete description of these requirements and their docuentation are enclosed in Appendi. /. to this r.mo.

AJditionally, Enclosure 1 addresses new questions relating to the health physics organization and instruments based on the staffs recent compilation of criteria for utility canagcc.ent and technical competence. This review was perfonned by S. Block, RPS, RAB.

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?ws N s i.'illiam E.1;reger, Assistant Director 7T D D K gg- for Radiation Protection Division of Syste,ns Inte; ration  !

E. closures:

I.s Stated ,

cc: D. Ross D. Collins W. !!auston L. Carrett W. Ginaill S. Burwell H. 0:rl.ou/R. Russell D. Vassallo

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the neutron counter using a moderated rtand bare Bf., counl erl techniques.

ment of fast and thermal neutronh flux densities d to

l method for neutron dosimetry l based Please state on state-i to the neutron measure the neutron dose equivalent rate di -

1 monitor listed in Table 12.5.2.

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that 331.17 Based on information contained in the .i d d show that the from theshoul your station organization chain (Figure 13.1-4) t radiation protection group is a separate organ directly to the General Superintendent. division F that the RPH should be independent of the technical olve i program.

suppor and should have direct recourse to the plant manager be to res questions relating to the conduct of the radiation protectJ o Your FSAR and proposed Technical Specification should th r revised accordingly.

Figure 13.1-4 should ' '

Concurrent to the change request in 331.17 above, istry technicians i 331.18 also show that Health Physics technicians and C Radiation Protection and Chemistry group manage f  ;

Please describe your plan to provide backup individual coverage inI:

331.19 the absence of the RPM and outline the qualifications 85 of who will act as the backup.

specifies that the temporary replacement for an i nce. RPM sh degree in science or engineering, 2 years experience ,

protection,1 year of which should be nuclear power plant e 6 months of which should be on-site. that Section 13.1.2.3 specifying shift. crew composition, ding back- does 331.20 an H.P. technician will be onsite at all times in Support (e.g., of inc shiftandweekends). h i ian, of Radiological Emergency Rcsponse be onsite at Plans whose qualifications are described in ANSI health 18.1, all times. of the shif t crew (e.g., reactor operator) to act member t ction as a physic; technician if he is qualified to implemen '

procedures. acceptable to the staff after the reactor is at power.

health physics technician will be acceptable based on n cents.

Therefore. Section 13.1.2.3 should be revised accord

113CEiVED NRC Document Name:

ALIIGATION NO. 20 ..

1581 FE813r AN 10: 45 Requestor's ID: ' ---- #

OPERS Author's Name: REGl0N Vlac

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Document Commee:s: #

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l Task: Allegation or Concern No. 20 ATS No. RV-83-A-018 BN No. N/A Characterization l Licensee's Health Physics personnel are not qualified to American National Standard Institute (ANSI) requirements.

Implied Significance to Desian, Construction or Operation t

Technical Specification 6.3.1 requires that each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 except for the Supervisor of Chemistry and Radiation Protection who shall also meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. At other facilities failure to have properly qualified Health Physics personnel has resulted in poor implementation of the radiation protection program. A poor radiation protection program could result in personnel over exposures or release of materials to the environment above regulatory limits.

Assessment of Safety Sianificance The qualifications of the Supervisor of Chemistry and Radiation Protection and those of 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 reactor facility and have

been involved in the development of the radiation protection program at Diablo Canyon since its inception.

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The licensee has a program for reviewing the qualifications of the unit staff j to insure that the ANSI N18.1-1971 requirements are met. Our review of this

! prograa has found it to be adequate. Region V has raised a question regarding l 1 1 l

l the experience requirements as it applies to Chemistry and Radiation Protection technicians. Section 4.5.2 of the ANSI standard states

" technicians in responsible positions shall have a minimum of two years of working experience in their specialty." Chemistry and Radiation protection I are usually considered to be be two separate specialties. The licensee ,

l considers that a combined total of two years meets the requirements of the l 1 l ANSI standard. It is Region V understanding, however, that NRR has not j established a firm position on this issue. j j Staff Position  !

I Region V staff believes that the licensee's professional staff meets the requirements of the ANSI standard and of Regulatory Guide 1.8, September 1975.

I j The question of the required number of years of experience for Chemistry and Radiation Protection technicians in responsible position needs to be resolved.

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! Action Required 1

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l Region V submitted a request for guidance on the required experience for

, Chemistry and Radiation Protection technicians to IE on December 2,1983.

This issue has generic implications and needs to be reviewed in that light.

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Implementation of this requirement at Diablo Canyon should be consistent with implementation at other reactor facilities.

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Docurant Ncsa:

ALLEGATION NO. 21

. .Y .. Raquaotor'o ID: B5CBVE[)

OPER10 HF.C Author's Name; f=TsiPKcti""-"X T 158T FE813 AM 10: 45 Document Comments: s Please forward to Tom Bishop. Thanks - dot s y NYl86 Du I 9) P3 4

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Task: Allegation or Concern No. 21 l ATS No. RV-83-A-018 BN No. N/A Characterization The licensee has poor practices as far as keeping exposures as low as l reasonably achievable (ALARA). Specifically, (1) the air from the chemistry I i laborato'ry is only exhausted by means of the fume hoods and this is inadequate; (2) the licensee intends to permit all floors in the restricted p

i area to become contaminated; (3) the licensee will not provide respiratory protection equipment to workers on demand.

9 Implied Significance to Design, Construction or Operation Regarding the specific concerns there are no specific NRC requirements covering these subjects.

l l Assessment of Safety Significance 1

These concerns are not founded. The fume hoods are not the only means of removing air from the chemistry laboratory and the hoods alone exceed the OSHA required number of air changes per hour. Statements in the licensee's i radiation control procedures indicate that corridors in the restricted area l

l will not be permitted to remain contaminated, if they so become.

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Finally the licensee currently plans 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 in the specific equipment being used.

Staff Position A licensee's operational ALARA program cannot be clearly examined until the plant is operational. The licensee is committed to a strong ALARA program and this commitment is reflected in statements in their procedures.

Action Required Region V will review the licensee's implementation of their operational ALARA program when the plant becomes ope: rational.

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ALLEGATION NO. 22 tlECE!VEb

$ . L'F C Requestor's ID:

OPER10 REGION Vl&S Author's Name:

Document Cot:ments:

Please forward to Tom Bishop. Thanks , dot ' J//

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ATS No. RV-83-A-018 BN No. N/A Characterization 4

I i Modifications to the Air Ejector Discharge Radio-Cas Monitor (RE-15) and the 1

Cas Decay Tank Discharge Radio-Cas Monitor (RE-22) have made these monitors 1

insensitive to Xenon-133 and Krypton-85. An environmental shield has been 3 placed. over these monitors that prevents the detection of these nuclides, a

Implied Significance to Design, Construction or Operation 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 4

gas decay tanks. This channel will alarm 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 this monitor to detect Xenon-133 or Krypton-85 could result in an unmonitored release or an unplanned release.

Assessment of Safety Significance The Air Ejector Monitor is in a hostile environment, high humidity and j temperature. The Gas Decay Tank Discharge Monitor monitors what may be J

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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 sentitivity, 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 is completely shielded by the environmental shields.

However, the gamma emissions (514 Kev for Kr-85 and 80 Kev for Xe-133) penetrate the shield and are detected by the monitor. The licensee stated that the vendor's response curves will be verified when the plant is operational.

Staff Position i

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Region V believes that the concerns expressed have been addressed and that the reduced sensitivity of these monitors does not constitute a significant safety issue.

Action Required l

No action is required.

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