ML13142A195

State of Rhode Island Atomic Energy Commission - Withdrawal of License Amendment Request

ML13142A195
Person / Time
Site:	Rhode Island Atomic Energy Commission
Issue date:	05/01/2013
From:	Marlone Davis State of RI, Atomic Energy Comm, Nuclear Science Ctr
To:	Xiaosong Yin Document Control Desk, Division of Policy and Rulemaking
References
Download: ML13142A195 (7)

Text

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 1 May 2013 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Mr. Xiaosong Yin

Subject:

Withdrawal of License Amendment Request

Dear Mr. Yin:

In a letter dated 18 April 2013, the Rhode Island Atomic Energy Commission requested that the R-95 (Docket 50-193) license be amended to change Technical Specification 6.2.2, in order to clear up an apparent discrepancy between the required qualifications of the Radiation Safety Officer for the license, and the qualifications of the individual that is currently serving in that position. The purpose of this letter is to withdraw that request. A copy of the original license amendment request is attached.

Thank you for your attention to this matter.

Sincerely, Michael J. Davis Enc.: Letter dated 18 April 2013

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS RHODE ISLAND ATOMIC ENERGY COMMISSION Rhode Island Nuclear Science Center 16 Reactor Road Narragansett, RI 02882-1165 18 April 2013 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Mr. Xiaosong Yin Subject Qualifications of the Assistant Director for Radiation and Reactor Safety at the Rhode Island Nuclear Science Center

Dear Mr. Yin:

It has been brought to our attention that a question has been raised about the qualifications of the

-individual that is currently the Assistant Director for Radiation and Reactor Safety at the Rhode Island Nuclear Science Center (RINSC), who serves as the facility RSO. The individual that is currently in the position has a Master's Degree in Physics, rather than specifically in Health Physics. Additionally, the individual has taken rigorous health physics courses designed specifically for individuals that are going to serve as an organizational RSO. Consequently, we believe that this person has the equivalent combination of education and experience to meet this qualification. As I understand it, there are three options for rectifying this issue:

1) Hire a new individual that has a Master Degree level education specifically in the Health Physics field,

2) Have the current individual earn a Master Degree level education specifically in the Health Physics field, or

3) Request a license amendment to relax the qualification in the RINSC Technical Specifications, to make it more in line with ANSI 15.4, Selection and Training of Personnel for Research Reactors.

The purpose of this letter is to formally request a change to RINSC Technical Specification 6.2.2 which describes the qualifications of the Radiation Safety Officer. The current specification states that:

"The Radiation Safety Officer shall have a master's degree in health physics or radiological health and three years of applied health physics experience in a program with radiation safety problems similar to those in the program to be managed."

The proposed specification is:

"The Radiation Safety Officer shall have a master's degree in health physics or radiological health and three years of applied health physics experience in a program witi radiation safety problems similar to those in the program to be- managed, or any equivalent combination of education and experience."

This proposed wording makes the Technical Specification requirement similar to the wording that the State of Rhode Island uses to describe the qualifications of the individual in this position.

ANSI Standard 15.1-2007, The Development of Technical Specifications for Research Reactors, section 6.1.4 indicates that the selection of personnel should follow the guidance of ANSI Standard 15.4 Selection and Training of Personnel for Research Reactors. Section 4.3 of this standard describes the qualifications of Level 2 facility-management as having:

"...a minimum of six years of nuclear experience. The individual shall have a recognized baccalaureate or higher degree in an engineering or scientific field." The degree may fulfill up to four years of nuclear experience required."

Consequently, the proposed specification is more conservative than what ANSI 15.4 requires for this position in the organization.

As we do not want this apparent discrepancy to impact current operations, we would ask that this matter be considered as quickly as possible.

Thaiik you for your attention to this matter.

Sincerely, Michael J. Davis Assistant Director for Operations Enc.: RINSC Technical Specification Page 44 Amendment 29 RINSC Technical Specification Page 44 Proposed Amendment RI State Job Description for the Assistant Director for Radiation and Reactor Safety

Current RINSC Technical Specifications (Amendment 29):

TECHNICAL SPECIFICATIONS Rhode Island Nuclear. Science Center Docket 50-193, License R-95

4. In accordance with the-emergency plan, a list of emergency personnel, management and offsite agencies is posted in the control room.

6.2 Qualifications of Personnel At the time of appointment to the position, the Director shall have a minimum of six years of nuclear experience. The Director shall have an advanced degree in one of the physical sciences or engineering.

The degree will fulfill four years of the six-*year requirement

2. The Radiation Safety Officer shall have a mastees degree in health physics or radiological health and three years of applied health physics experience in a program with radiation safety problems similar to those in the program to be managed.

3. The reactor operators and senior operators shall be licensed in accordance with the provisions 6f 10CFR55.

4. In the event of temporary vacancy in. the position of Director or .the Radiation Safety Officer, the functions of that position shall .be assumed by qualified altenates appointed by the RIAEC.

6.3 Responsibilities ofPersonnel

1. Director

a. The Director shall have responsibility for all activities in the reactor facility which may affect reactor operations or involve radiation hazards, including controlling the admission of personnel to the building.

This responsibility shall encompass administrative control of all experiments being performed in the facility including those of outside agencies.

b. It shall be the responsibility of the Director to insmu that all proposed experiments, design modifications, or changes in operating and emergency procedwures are performed in accordance with the license. Where uncertainty exists, the Director shall refer the decision to the NRSC.

2. Senior Reactor Operators Page 44. Amendment 29

4 Proposed RINSC Technical Specification (Amendment 31)

TECHNICAL SPECIFICATIONS Rhode Island Nuclear Science Center Docket 50-193, License R-95

4. In accordance with the emergency plan, a list of emergency personnel, management and offsite agencies is posted in the control room.

6.2 Qualifications of Personnel I. At the time of appointment to the position, the Director shall have a minimum of six years of nuclear experience. The Director shall have an advanced degree in one of the physical sciences or engineering.

The degree will fulfill four years of the six-year requirement

2. The Radiation Safety Officer shall have a master's degree in health physicsý or radiological health and three'years of applied health physics experience in a program with radiation safety problems similar to those in the program to be managed, or any equivalent combination of education and experience.

3. The reactor operators and senior operators shall be licensed in accordance with the provisions of IOCFR55.

4, In the event of temporary vacancy in the position of Director or the Radiation Safety, Officer, the functions of that position shall be assumed by qualified alternates appointed by the RIAEC.

6.3 Responsibilities ofPersonnel'

1. Director

a. The Director shall have responsibility for all activities in the reactor facility which may affect reactor operations or involve radiation hazards, including controlling the admission of.

personnel to the building.

This responsibility shall encompass administrative control of all experiments being performed in the facility inchuding those of outside agencies.

b. It shall be the responsibility of the Director to insure that all proposed experiments, design modifications, or changes in operating and emergency procedures are. performed in accordance with the license. Where uncertainty exists, the Director shall refer the decision to the NRSC.

Page 44 Amendment 31 Draft

RI State Job Description for the Assistant Director for Radiation and Reactor Safety CLASS TITLE: ASSISTANT DIRECTOR FOR RADIATION AND REACTOR SAFETY Class Code: 02505500 Pay Grade: *39A EO: A CLASS DEFINITIONA GENERAL STATEMENT OF DUTIES: To be. responsible for radiation and reactor safety at the Rhode Island Nuclear Science Center (RINSC) and radiation safety at the University of Rhode Island (UtR) to include both ionizing and noa-ionizing forms of radiation with responsibility for planning, organizing 9nd mnaintaining an effective radiation protection program; and to do related work as required.

SUPERVISION RECEIVED: Works under the technical and- administrative supervision of the Director, Rhode. Island Nuclear Science Center and the URI Radiation Safety Committee with considerable latitude for the exercise.of independent judgement in the application of accepted methods, procedures, and techniques of health physics; work is reviewed by the Nuclear. and Radiation Safety Committee (RINSC) and the Radiation Safety Committee (URI) for evaluation of such methods, procedures and techniques; SUPERVISION EXERCISED: Plans, supervises and reviews the work of professional, technical and clerical personnel assigned to assist in performance of asRignments.

ILLUSTRATIVE EXAMPLES OF WORK PERFORMED:

-To be responmsble for radiation and reactor safety at the Rhode Island Nuclear Science Center (RINSC) and radiation safety at the University of Rhode Island (URI) to include both ionizing and non-ionizing formns of radiation with responsibility for planning, organizing, and maintaining an effective radiation protecton program.

To plan, org.anie and maintain a program of facility monitoring, environmental monitoring and personnel exposure monitoring and maintain required records to ensure the safety of individuals and to ensu~re cormpliance with Federal and State Licensing conditions and applicable safet3i and environmental laws.

To exercise authority to halt radiological operations, when necessary, for health'and safety 'easons..

To serve as member of the RINSC and URI radiation safety committees.

To do related work as required.

REQUIRED QUALIFICATIONS FOR APPOINTMENT:

KNOWLEDGES. SKILLS AND CAPACITIES: A thorough knowledge of the principles, practices and.

techniques of the field of health physics especially as it relates to the programs at RINSC and URI- a thorough knowledge of Federal and State regulations and licensing procedures; the ability to plai, supervise and review the work of technical assistants and others engaged in health physics matters; the ability to. demonstrate computer proficiency in the use of programs associated with radiation assessment; the ability to prepare scientific, technical, and other reports containing findings, conclusions, and recommendations.relating to health physics problems and techniques; and related capacities and abilities.

EDUCATION AND EXPERIENCEt Education: Such as may have been gained through: graduation from a college of recognized standing with a Master's Degree in the field of Health Physics; and

Experience: Such as may have been gained through: employment in a responsible technical position with responsibility for professional and technical oversight within a comprehensive radiation protection program, preferably.at a nuclear reactor facility..

Or, any combination of education ind experience that shall be substantially equivalent to the above education and experience.

Class Created: July 4, 1999 Editorial Review: 3/15/03