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' March 10, 1988, .

Docket Nos. 50-445and 50-446

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Mr. William G. CounsilExecutive Vice PresidentTexas Utilities Electric Company400 North Olive Street, L.B. 81Dallas, Texas 75201

Dear Mr. Counsil:

SUBJECT: REQUEST FOR ADDITIONAL INFORMATION CONCERNINGRADIATION PROTECTION ORGANIZATION

We have reviewed FSAR Amendments 59, 60, 62, and 64 relative to theradiation protection organization for Comanche Peak Steam ElectricStation, Units 1 and 2.

In order to complete our evaluation, we have determined that additionalinformation is needed. Please provide the information identified in theenclosure no later than 14 days from the date of this letter.

Should you have any questions regarding this request, please contacteither of our Project Managers, Melinda Malloy at (301)492-0738 orAnnette Vietti-Cook at (301)492-0737.

The reporting and/or recordkeeping requirements contained in this letteraffect fewer than ten respondents; therefore, OMB clearance is notunder P. L. 96-511.

Sincerely,(original signed by)Christopher I. Grimes, DirectorComanche Peak Project DivisionOffice of Special Projects

Enclosure: Request for DISTRIBUTION ~'Additional Information Docket File- MMalloyNRC PDR AVietti-Cook

cc: See next page Local PDR OGC-0WFNOSP Reading BMurrayCPPD Reading LCunninghanSEbneter/JAxelrad TEssigCGrimes FMiragliaPMcKee EJordanJHWilson JPartlowJLyons ACRS(10)RWarnick

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N* [ 'o, UNITED STATES

'i NUCLEAR REGULATORY COMMISSION[*

, r,cWASHINGTON, D. C. 20555 |;; 3 ;y

\ / March 10, 1988

.....

Docket Nos. 50-445and 50-446

Mr. William G. CounsilExecutive Vice PresidentTexas Utilities Electric Company400 North Olive Street, L.B. 81Dallas, Texas 75201

Dear Mr. Counsil:

SUBJECT: REQUEST FOR ADDITIONAL INFORMATION CONCERNINGRADIATION PROTECTION ORGANIZATION

|

We have reviewed FSAR Amendments 59, 60, 62, and 64 relative to the i'

radiation protection organization for Comanche Peak Steam ElectricStation, Units 1 and 2. |

In order to complete our evaluation, we have determined that additionalinformation is needed. Please provide the information identified in theenclosure no later than 14 days from the date of this letter.

Should you have any questions regarding this request, please contacteither of our Project Managers, Melinda Malloy at (301)492-0738 orAnnette Vietti-Cook at (301)492-0737.

The reporting and/or recordkeeping requirements contained in this letteraffect fewer than ten respondents; therefore, OMB clearance is notrequired under P. L. 96-511.

Sincerely,

CTCwChristopher I. Grimes, DirectorComanche Peak Project DivisionOffice of Special Projects

Enclosure: Request for )Additional Information ;

cc: See next page

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W. G. Counsil Comanche Peak Steam Electric StationTexas Utilities Electric Company Units 1 and 2

CC:Jack R. Newman, Esq. Asst. Director for Inspec. Programs 1

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Newman & Holtzinger, P.C. Comanche Peak Project DivisionSuite 1000 U.S. Nuclear Regulatory Comission1615 L Street, N.W. P. 0. Box 1029Washington, D.C. 20036 Granbury, Texas 76048

Robert A. Wooldridge, Esq. Regional Administrator, Region IVWorsham, Forsythe, Sampels & V.S. Nuclear Regulatory Comission

Wooldridge 611 Ryan Plaza Drive, Suite 10002001 Bryan Tower, Suite 2500 Arlington, Texas 76011Dallas, Texas 75201

Lanny A. SinkinMr. Homer C. Schmidt Christic InstituteDirector of Nuclear Services 1324 North Capitol StreetTexas Utilities Electric Company Washington, D.C. 20002Skyway Tower400 North Olive Street, L.B. 81 Ms. Billie Pirner Garde, Esq.Dallas, Texas 75201 Government Accountability Project

Midwest OfficeMr. Robert E. Ballard, Jr. 104 East Wisconsin AvenueDirector of Projects Appleten, Wisconsin 54911Gibbs and Hill, Inc.11 Penn Plazahew York, New York 10001 David R. Pigott, Esq.

Orrick, Herrington & Sutcliffe600 Montgomery Street

Mr. R. S. Howard San Francisco, California 94111Westinghouse Electric CorporationP. O. Box 355 Anthony Z. Roisman, Esq.Pittsburgh, Pennsylvania 15230 Suite 600

1401 New York Avenue, NWRenea Hicks, Esq. Washington, D.C. 20005Assistant Attorney GeneralEnvironmental Protection Division Robert JablonP. O. Box 12548, Capitol Station Bonnie S. BlairAustin, Texas 78711 Spiegel & McDiarmid i

1350 New York Avenue, NWMrs. Juanita Ellis, President Washington, D.C. 20005-4798Citizens Association for Sound Energy1426 South Polk George A. Parker, Chairman I

Dallas, Texas 75224 Public Utility Comittee I

Senior Citizens Alliance OfMs. Nancy H. Williams Tarrant County, Inc.CYGNA Energy Services 6048 Wonder Drive ,

2121 N. California Blvd., Suite 390 Fort Worth, Texas 76133 )Walnut Creek, CA 94596

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W. G. Counsil -2- Comanche Peak Electric StationTexas Utilities Electric Company Units 1 and 2

cc:Joseph F. FulbrightFulbright & Jaworski1301 McKinney StreetHouston, Texas 77010

Roger D. WalkerManager, Nuclear LicensingTexas utilities Electric CompanySkyway Tower400 North Olive Street, L.B. 81

' Dallas, Texas 75201

Mr. Jack Reddingc/o Bethesda Licensing

|Texas Utilities Electric Company3 Metro Center, Suite 610Bethesda, Maryland 20814

William A. Burchette, Esq. i

Counsel for Tex-La Electric Cooperativeof Texas i

Heron, Burchette, Ruckert & Rothwell i'Suite 700

1025 Thomas Jefferson Street, NWWashington, D.C. 20007

GDS ASSOCIATES, INC.Suite 7201850 Parkway Place |Marietta, Georgia 30067-8237

Administrative Judge Peter BlochU.S. Nuclear Regulatory ComissionWashington, D.C. 20555

Elizabeth B. JohnsonAdministrative JudgeOak Ridge National LaboratoryP. O. Box X, Building 3500Oak Ridge, Tennessee 37830

Dr. Kenneth A. McCollom1107 West KnappStillwater, Oklahoma 74075

Dr. Walter H. Jordan'

881 West Outer DriveOak Ridge, TN 37830 !

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| ' ENCLOSURE

Request for Additional Information;

||Comanche Peak FSAR Amendments 59, 60, 62, and 64

Radiation Protection Organization

1. Section 13.1.3.1 (Amendment 62) of the FSAR, states "If the appointed

Radiation Protection Manager (RPM) does not meet the Regulatory Guide

1.8 criteria, then a Radiation Protection Advisor (RPA) shall be desig-

nated who does satisfy the Regulatory Guide 1.6 criteria." Based on

information provided in the FSAR (through Amendment 64), a comparison

is made below between the Comanche Peak Steam Electric Station (CPSES)

RPM candidate's qualifications and the Regulatory Guide 1.8, Rev 1-R

criteria:

Regulatory Guide 1.8 Criteria CPSES RPM Candidate _

* Bachelor's degree in * Bachelor's degree in

science or engineering, science (Biology).

including some formal No apparent formal

training in radiation training (college-level)

protection. in radiation protection.

* A Master's degree may * Master's degree in

be considered equivalent Chemical Oceanography.

to one year of professional No coursework in

experience where coursework radiation protection

related to radiation apparently taken,

protection is involved.

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* At least five years' pro- * At most, candidate

fessional experience in has only approximately two

radiation protection, three years (since 1986) of

of which should be in a professional radiation

nuclear facility dealing with protection experience,

radiological problems similar All of this experience was

to those encountered in gained in an environment

nuclear power stations, lacking actual radiation

preferably in an actual protection problems due to'

nuclear power station. the plant being in the

construction phase.

Based on the above, it appears to the staff that the individual named as

RPM for the CPSES (p. 13.1-84 of the FSAR, Amendment 62) does not meet the

RPM criteria in Regulatory Guide 1.8, Rev 1-R. Please state how the RPM

candidate will obtain the necessary fomal training and professional radi-

ation protection experience in order to eventually meet the Regulatory

Guide 1.8, Rev 1-R criteria.

2. FSAR Amendment 62 states (as quoted in Question No. 1 above) that an RPA

who meets Regulatory Guide 1.8 criteria would be designated in the event

that the RPM did not meet the criteria. In view of the staff's conclusion

that the RPM candidate does not meet the Regulatory Guide 1.8 qualification

criteria (see Question No.1), the alternative course of action needs to

be pursued.

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TV Electric has proposed the RPA concept as this alternative. Under

this concept, the RPA would report directly to the RPM, closely ad-

vising and guiding the RPM on all radiation protection matters. The

RPA would have direct access to the Manager, Plant Operations and the

Corporate Health Physics Supervisor. Additionally, the RPA would be

assigned as an advisor to the Station Operating Review Comittee.

The staff finds that TU Electric's proposed arrangement involving a

not-yet-qualified RPM supported by an RPM-qualified RPA would be ex-

tremely difficult and awkward, if not impossible, to work. An arrange-

ment of this nature might be feasible in situations where the RPM can-

didate is nearly qualified, e.g., having 3 to 4 of the necessary 5 years

of professional radiation protection experience and some formal radiation

protection training. However, this does not appear to be the case at

CPSES.

Please provide a resume of qualifications for a "Regulatory Guide 1.8-

qualified" RPM who can fill the position of RPM until such time as the

candidate proposed in the FSAR is determined to be qualified.

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