ML20214P454

Comments on SALP Repts 50-348/86-14 & 50-364/86-14. Recommends All Refs to Apparent Violations & Unresolved Items Resulting from Mar 1985 Insp 85-15 Be Deleted from SALP Rept

ML20214P454
Person / Time
Site:	Farley
Issue date:	11/20/1986
From:	Mcdonald R ALABAMA POWER CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
86-426, NUDOCS 8612040214
Download: ML20214P454 (3)

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Alabama Power Compdny 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 352914400 '

Telephone 205 250-1835 36110V 25 A 9 : 0 8 AlabamaPower bn'ioY* ceYr$voer,t v

86-426-November 20, 1986 Dr. J.-Nelson Grace Regional Adicinistration -

V. S., Nuclear Regulatory Commission, Region II 101 Marietta Street,'N. W.

Atlanta, GA 30322

Subject:

Report No. 50-348/35-14

'50-364/86-14

Dear'.Gr. Grace:

The comments herein concern the SALP Board Report provided by your letter of October 16, 1986.

Comment 1-

-The subject report contains conflicting conclusions concerning the quality of licensee conducted audits in the area of health physics.

In the last paragraph on page 7 of the subject report it states, " Audits performed by-the corporate staff of the health physics, radwaste, environmental and chemistry programs were of sufficient scope and depth to, identify problems and adverse trends." Conversely, in the last paragraph on page 19, it is

-stated, " Audits and their responses were completed in a timely manner,

- comprehensive checklists were utilized and all audit findings were reviewed by the Senior Vice President. However, the site internal audit organization lacked sufficient expertise in the area of health physics to perform meaningful evaluations." Since the " site internal audit organization" is, in fact, an on-site independent organization reporting only to off-site

.managemen, the so-called " corporate staff" and the " site internal audit t

organization" are one and the same group.

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Dr. J. Nelson Grace Page 2

. November 20, 1986 During the period of the SALP, the site audit staff consisted of individual personnel with significant health physics training. experience, and background. Below is a listing of the such personnel:

Name Date Assigned Special Qualifications W. D. Oldfield July 1984-July 31,1986 Navy Nuclear Trained Officer /

Nuclear Engineering Degree W. H. Warren September 1984-July 31,1986 SR0/ Masters Degree-Physics / Health Physics Training T. P. Davis October 1984-July 31,1986 Navy Nuclear Trained Officer R. R. Martin April 1985-July 31,1986 SR0 J. K. Osterholtz January 1986-July 31,1986 SR0/ Nuclear Engineering Degree V. L. Murphy February 1986-July 31,1986 SR0 M. D. Pilcher May 1986-July 31,1986 SR0 Trained J. E. Fridrichsen June 1986-July 31,1986 SR0/ Nuclear Engineering Degree Of.the eight personnel. identified.above,.two members of the staff were nuclear trained officers in the U. S. Navy, and received training and experience in health physics as part of the Navy nuclear program.

Three have nuclear engineering degrees which included several hours of formal training in the health physics area. Five have Senior Reactor Operator licenses which includes formal training on health physics as part of the SR0 training program and refresher training during the requalification program.

Another has completed SR0 training. One of those listed has a masters degree in Physics and has had formal training in the area of health physics.

In addition, this person has worked as a Radio-Chemistry laboratory technician at Farley.

The conclusion on page 19 stating, "However, the site internal audit organization lacked sufficient expertise in the area of health physics to perform meaningful evaluations." is erroneous in that that group is not internal to the site management. Furthermore, the conclusion is inadequately supported as indicated above.

It is recommended that this sentence in the SALP Report be deleted.

Comment 2 On page 24 of the report, it is stated that "During Inspection (85-15)

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Dr. J.- Nelson Grace Page 3 November 20, 1986 conductedin M' arch 1985, nine apparent violations were identified. However, as a result of the current NRC policy statement and agreement with INP0 on training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items."

Despite Alabama Power. Company's efforts to resolve these " apparent" violations with the NRC for a period of 16 months, they were included in the SALP report. Alabama Fbwer Company does not believe that any of the

" apparent" violations were actual violations and, in any case, Alabama ibwer Company believes that upgrading or clarifying actions have been completed in all cases.

It is recommended that all references to the " apparent" violations and unresolved items resulting from the March 1985 inspection (85-15) be deleted from the SALP report.

Sincerely yours, b

R. P. Mcdonald Senior Vice President R PM/JWM:rb D-3.2 m

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Dr. J.. Nel son Grace -

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L Page 2 November:20, 1986L.

During the period of'the SALP,' the site audit staff consisted'.of individual

.. personnel; with significant health physics training, experience, and background..Below is a listing of the such. personnel:

Name' Date'AssignedI Special Qualifications W. D. Oldfield July 1984-July 31,:1986 Navy Nuclear

-Trained.0fficer/

Nuclea'r Engineering.

Degree W. H. Warren.

September 1984-July. 31,1986 SR0/ Masters

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Degree-Physics / Health Physics Training T. P. Davis October 1984-July 31,1986 Navy. Nuclear Trained Officer R. R. Martin April 1985-July 31,1986 SR0-

-J. K. 0sterholtz January 1986-July 31, ~ 1986 SR0/ Nuclear Engineering Degree V. L. Murphy February 1986-July 31,1986 SR0.

M. D. Pilcher May 1986-July 31, :1986 SR0 Trained J. E.'Fridrichsen June 1986-July '31,1986 SR0/ Nuclear Engineering-. Degree 0f the eight personnel-identified above, two members of the: staff were

... nuclear trained officers in the-U. S. Navy, and received training and experience in health physics as part of. the Navy nuclear. program. Three have nuclear engineering degrees which included several hours of formal-training.in the health physics area. Five have Senior Reactor Operator

. licenses which includes formal training on health physics as part of the SR0 training program and refresher training during the requalification. program.

- Another has completed SRO training. ' One of-those-listed has a masters degree in Physics and has had formal training in the area of health physics.

In addition, this person has worked as a Radio-Chemistry

' laboratory technician at Farley.

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The conc us on on page 19 stating, "However, the site internal audit organization lacked sufficient expertise in_ the area of. health physics to perform meaningful evaluations." is erroneous in that that group is not int.ernal.to the site management. Furthermore, the conclusion is

. inadequately supported as-indicated. above.

It is recommended that this

. sentence in -the SALP Report be deleted.

Comment 2 On page 24 of the report, it is stated that "During Inspection (85-15)

Dr. J. Nelson Grace Page 3 November 20,.1986=

conducted in March 1985, nine apparent violations ~ were identified.

However,'

-as a result of the current NRC policy statement and agreement with INP0 on

~

training and qualification of nuclear power plant personnel, these apparent violations are being carried as unresolved items."

Despite Alabama Power Company's efforts to resolve these " apparent"-

violations with the NRC for a period of 16 months, they were included in the SALP report. Alabama Fbwer Company does not believe that any of the

" apparent" violations were actual violations and, in any case, Alabama Power Company. believes that upgrading or clarifying actions have been completed in all cases.

It is recommended that all references to the " apparent" violations and unresolved items resulting from the March 1985 inspection (85-15) be deleted from the SALP report.

Sincerely yours, b

R. P. Mcdonald Senior Vice President

' R PM/JWM:rb D-3.2 t

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