ML20244D876

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Forwards Sser Re Util Airborne Radioactivity Monitoring Program.Health Physics Dept Organization Reporting Level of Radiation Protection Manager & Qualifications Requirements Acceptable.Salp Input Also Encl
ML20244D876
Person / Time
Site: Seabrook, 05000000
Issue date: 05/19/1986
From: Rossi C
Office of Nuclear Reactor Regulation
To: Nerses V
Office of Nuclear Reactor Regulation
Shared Package
ML20235T530 List: ... further results
References
FOIA-87-51, RTR-NUREG-0800, RTR-NUREG-800, RTR-REGGD-01.008, RTR-REGGD-1.008 NUDOCS 8605270159
Download: ML20244D876 (5)
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DISTRIBUTION PSB R/F L.G. Hulman PSB Plant File 0. Parr C. E. Rossi W. Minners J. Milhoan B. Dgglittle T. Quay SocG7 FILE t Docket No.: 50 443 ,

1 MEMORANDUM FOR: Victor herses, Project Manager j PWR Project Directorate # 5 1 Division of PWR Licensing-A j FROM: Charles E. Rossi, Assistant Director for PWR.A l Division of PWR Licensing.A )

SUBJECT:

SEABROOK UNRESOLVED LICENSING ISSUES AND SUPPLEMENTAL SAFETY EVALUATION REPORT 1

The Plant Systems-Branch (PSB) has reviewed the status of the unresolved licensing issue related to the Health Physics Organization (Item C-37, SER Section 12.5.1). Based on our review of the Public Service of New Hampshire (PSNH) commitments in their Final Safety Analysis Report (FSAR), and Region I inspection results (Inspection No. 50-443/85 28), the staff has found the Seabrook Health Physics Department Organization, the reporting level of the current Health Physics Department Supervisor (radiation protection manager / RPM) and the qualification requirements for the Health Physics Department Supervisor position to be acceptable. A previous staff review found the qualifications of the currently assigned Health Physics Department Supervisor to be acceptable.

An additional issue related to the applicant's comments on the staff's SER regarding the location of the Primary Auxiliary Building ventilation system monitoring has also been evaluated and resolved.

A supplemental safety evaluation report regarding these matters is enclosed.

SALP input based on interaction with the applicant regarding RPM qualifications and PAB monitor location are included as Enclosure 2.

This review was conducted by R. J. Serbu (PSB, x27380).

Origins 1 eigne&Y;

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Charles E. Rossi, Assistant Director for PWR-A Division of PWR Licensing-A

Enclosure:

(1) SSER (2) SALP Input -

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DATE :5/10 86 :5/1V86 :5/lL/86 :5//g/86  :  :  :

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1 Enclosure 1 SUPPLEMENTAL SAFETY EVALUATION REPORT-SEABROOK POWER STATION Supplement to Section 12.5.1 12.5.1 Organization j

The staff has further reviewed Public Service of New Hampshire (PSNH) j commitments in their Final Safety Analysis Report (FSAR) for Seabrook through  !

Amendment Number 56, and has reviewed Region I inspection results related to i the Seabrook health physics organization (Inspection No. 50-443/85-28). Wnile i the Health Physics Department Supervisor (HPDS) is two organizational levels below the Station Manager, he has direct access to him on radiation protection matters, and reports through a management chain independent of operations (i.e., Technical Services).

The staff has found the Seabrook Health Physics Department Organization, as well as the reporting level of the Health Physics Department Supervisor (equivalent to RPM - Radiation Protection Manager), to be in accordance with our positions in the Standard Review Plan (NUREG-0800), and therefore, acceptable. This resolves the staff concern regarding organizational placement of the HPDS noted in Section 12.5 of the Seabrook SER.

The current Health Physics Department Supervisor's qualifications have been detennined to be acceptable based on a previous review of this specific case, including personnel interviews and an evaluation of the individual's experience and qualifications. By submittal dated May 10, 1986, the applicant has committed that the basic qualifications for Health Physics Department Supervisor, other than the currently assigned Health Physics Department Supervisor, will meet Regulatory Guide 1.8 (Rev.1), September 1975, and personnel selected for backup of the HPDS will meet ANSI /ANS 3.1-1981, or equivalent. These commitments meet our positions in the SRP and are acceptable.

This evaluation clarifies the staff position noted in the Seabrook SER, Section 12.5.1, indicating that the HPDS would have " qualifications similar to those specified in RG 1.8."

Supplemen' to Section 12.3.4.2 By submittal dated May 10, 1986, Public Service of New Hampshire (PSNH) has provided information establishing an equivalent alternative to staff positions regarding airborne radioactivity monitoring as established in the Standard Review Plan (SRP), NUREG-0800, Chapter 12.3-12.4 regarding monitoring of radioactivity upstream of HEPA filter banks. PSNH has included descriptions and justifications for installin Primary Auxiliary Building (PAB)g ventilation monitoring downstream of theirventilati and have revised the Final Safety Analysis Report (FSAR), Section 12.3.4.2.b.2(c), to reflect this change.

The staff has evaluated this proposed change in accordance with the intent of the SRP, namely to provide the capability to detect significant levels of airborne radioactivity in normally occupied spaces, and keep potential exposures as low as reasonably achievable. The applicant's proposal is acceptable, based on the following summary evaluation:

(1) a significant portion of the PAB will be monitored for gross activity upstream of the HEPA filters;

(2) noble gas monitors which are effective upstream or downstream of the

  1. ilters can also indicate particulate and radioiodine release and should effectively detect radioactive leakage from upstream areas and systems; (3) air monitoring, sampling, and analyzing will be routinely perforned in PAB areas through the use of mobile constant air monitors and portable air samplers; (4) work which could result in releases of radioactive materials will be i controlled by radiation work permits, engineering controls, respiratory j protection controls, and radiation protection staff oversight. j 1

This evaluation approves the applicant's justification as an exception and equivalent alternative and revises the Seabrook SER statement that, "The applicant will also provide upstream monitoring for the PAB," to "The appliant will also provide downstream monitoring for the PAB."

s I

1

. i Enclosure 2 SUPPLEMENTAL SAFETY EVALUATION REPORT SALP INPUT FOR SEABROOK NUCLEAR POWER STATION 50-443, 141415 Functional Areas: Licensing Activities

1. Management involvement in assuring quality.

PSNH has shown adequate planning and understanding of NRC policies in dealing with the issues related to this SSER. Reviews have been generally timely, and technically sound, with issues promptly elevated to appropriate management levels for resolution.

Rating: 2

2. Approach to resolution of technical issues from a safety standpoint.

PSNH has proposed a generally sound and viable approach to a complex technical issue regarding a ventilation monitoring issue. The technical justification was comprehensive and provided more than the minimum information necessary for resolution. PSNH initiated action to identify and resolve the above issue.

Rating: 2

3. Responsive to NRC initiatives.

Responses were timely and sound and generally acceptable once staff positions were understood clearly.

Rating: 2

4. Staffing:

]

Adequate technical and licensing staff were assigned to address the issues.

Personnel knowledgeable of the plant were assigned to the technical issue, and were able to adequately respond to all staff inquiries.

Rating: 1

5. Reporting and analysis of reportable events.

N/A j Rating: N/A

6. Training and qualification effectiveness.

N/A Rating: N/A k__------______--__________________________________

7. Overall Rating for Licensing Activity Functional Area: 2 Other Functional-Areas
1. Radiological . Controls.

PSNH has identified a potential issue related to ventilation system monitoring and worked with the staff to resolve the issue. Adequate personnel resources were made available and technical assessments conducted to justify the licensee positions.

Rating: 2 l

l i

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